C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-773

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

1. 4) A moratorium on wind power developments on and crossing Federal Lands. Wind power development causes roads, 

vehicles, power lines and fences to be built. All this adds up to more disturbance than the sage grouse leks will bear.

All Both emc0011GB

2. The EIS must examine the negative economic impacts to Renewable Energy in detail; such as publically subsidized tax breaks 

to developers; and loss to visual amenities (both day and nighttime) and viewscapes will have on regional tourism and 

recreation. For example, in Union and Baker counties there has been no significant increase in employment owing to the 

wind farm near Telocaset. There has been no significant rural development related to the Renewable Energy project, other 

than the wind farm and transmission lines.

All Both rmc0036GB

3. keep wind farms, transmission lines and other developments off of high priority sage-grouse areas. All Both cfc0019GB

4. While examining the BLM maps and displays I noted that there was substantial area within the sage grouse range designated 

for the development of wind generated electricity. I believe there should be a moratorium on wind power development on 

all government lands but particularly on federal lands where Land Use Plans (LUPs) are being revised to facilitate 

conservation of candidate species such as sage grouse. My position is based the following points:

- development of wind farms is totally dependent on government subsidies

- wind farms have an incredibly high kill rate for birds

- wind farms have proven to be unsustainable over time.

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5. Much of Lassen County contains sagebrush steppe habitat. The obvious reason to not permit siting of wind farms in the 

county is because of the potential mortality to sage grouse and other wildlife species during the operational phase. A less 

obvious reason is the negative impact construction of wind farms would have on the long-term economic viability of the 

county

All Both rmc0038GB

6. Should the siting of wind farms be permitted under revised LUPs, within sage grouse management areas, then at minimum the 

developers and operators of those wind farms should be required to post reclamation bonds to cover the entire cost of 

returning wind farm sites to pre-disturbance conditions. Other energy industries that disturb or impact spatially large areas 

of ground are required to post reclamation bonds. Reclamation bonds would not reduce sage grouse mortality during the 

operational phase of a wind farms. However, reclamation bonds would ensure that failed wind farm sites could be returned 

to historic land use condition and not become visual blights on the landscape.

All Both rmc0038GB

7. There is mounting evidence that absent significant government subsidies, wind power is neither economical nor sustainable 

and reclamation bonds should be imposed if they are constructed. The long-term economic viability of rural western 

counties must be considered when proposed revisions to LUPs are implemented.

All Both rmc0038GB

8. March 2010, the U.S. Fish and Wildlife Service (USFWS) made a finding of “warranted but precluded” regarding a petition for 

listing of the greater sage‐grouse as threatened or endangered under the Endangered Species Act (ESA).5 In its finding, 

USFWS noted that greater sage‐grouse now occupy only 56% of their historical territory (an area of 258,075 mi2), and that

habitat loss is a primary threat to the species. Energy development related to fossil fuel extraction and infrastructure was 

identified as a large contributor to the habitat loss.6 While renewable energy development was also recognized to have 

habitat impacts, USFWS did not describe related land use as intense as that for fossil fuel development.

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9. Notably, BLM, in its Notice of Intent (NOI), highlighted renewable energy development and transmission among preliminary All Both emc0110GB
C. Comments by Resource Planning Issue

C-774 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

issues that must be considered in the Environmental Impact Statement (EIS) scoping process. Moreover, BLM and the 

USFWS have stated that they will “focus on the relative value of resources while contributing to the conservation of the 

greater sage‐grouse and sage‐grouse habitat.”10 While SEIA applauds BLM’s recognition that public land can support a 

variety of important resources, overly restrictive rules related to habitat conservation could stifle future utility‐scale solar 

development. Flexibility in land use permitting is needed to keep pace with the fast‐growing and ever evolving solar industry, 

and help increase investment in a clean, renewable energy source that creates jobs.

10. SEIA requests that BLM clarify how it will address sage grouse conservation in conjunction with the ongoing Programmatic 

Environmental Impact Statement for Solar Energy Development in Six Southwestern States (PEIS) process and ensure that 

solar energy development remains a priority both within the solar energy zones (SEZs) and the areas outside of those zones.

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11. III. BLM Should Continue to Prioritize Solar Energy Development in the PEIS and Clarify the Sage Grouse Conservation 

Process In the October 2011 Supplement to the Draft PEIS, BLM reduced the already limited opportunities for solar energy 

development in the SEZs by over 50 percent (in terms of acres). Now, less than 225,000 acres are actually available for new 

projects within the 17 remaining SEZs, but BLM has determined that these remaining acres are highly suitable for solar

development. However, to meet the objectives of BLM’s sage‐grouse conservation policy, the revised Appendix J to the 

Supplement to the Draft PEIS indicates that further reductions in land within the SEZs may be necessary due to possible 

sage‐grouse occurrence in areas of the proposed Escalante Valley, Gold Point, Milford Flats South, Millers and Wah Wah 

Valley SEZs.11 According to the Supplement to the Draft PEIS, greater sage‐grouse occupy approximately 8% of the acres

within the SEZs and the variance areas combined, but their territory spans across RMPs in California, Colorado, Nevada, 

New Mexico, and Utah.12 Moreover, the Supplement to the Draft PEIS requires solar projects be “at least 3 mi (5 km) from 

the nearest lek [breading ground].”13 It also would prohibit development on lands “where BLM has made a[n unspecified]

commitment to take certain actions with respect to sensitive species habitat, including, but not limited to sage grouse core 

areas, nesting habitat, and winter habitat . . . .”14 This standard should specifically identify authoritative commitments that 

could properly prohibit development and how they are established. Moreover this biological reason for excluding lands 

requires further definition and a sound legal or scientific basis for their imposition. This exclusion is vague and destined to be 

applied inconsistently across different decision makers. Finally, this restriction could constitute a larger portion of public land 

than expected.

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12. SEIA requests that BLM provide clarification as to how this sage grouse conservation process will proceed in conjunction 

with the PEIS process. While the potential overlap between RMPs and SEZs may be low, as noted above, rigid conservation 

strategies may impede solar energy development by further decreasing the already minimal amount of land available for solar

development in the PEIS.

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13. SEIA further recommends that BLM fully explore the availability of mitigation measures and proactive conservation practices 

as an alternative to further reductions within SEZs and variance areas. By using flexible approaches, it should be possible to 

develop site‐specific conservation tools that allow for the protection of sage‐grouse and sage‐grouse habitat without the 

need for removing even more land from potential renewable energy development. For example, lands suitable for solar 

energy development could be subject to adaptive management tools, mitigation banks, or pre‐listing or pre‐compliance 

conservation agreements that would keep those areas open for leasing and project siting while meeting the biological needs 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-775

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

of sage‐grouse. Creative use of existing land and species conservation mechanisms should make it possible to keep all of the 

lands in Figure 1 available for development, with exclusion from solar project sitting ebbing used as only a last resort.

14. In conclusion, SEIA is supportive of BLM’s efforts to conserve the greater sage‐grouse and its habitat with the goal of 

developing comparable strategies in relevant RMPs and LMPs. However, interfering with the Solar PEIS process by further 

reducing the acreage available for development could hinder the growth of the solar industry. BLM must ensure that

conservation measures do not limit the effectiveness of its goals regarding SEZs and variance areas emerging from BLM’s 

Solar PEIS. SEIA appreciates BLM’s commitment and hard work in protecting the biodiversity of public lands, but asks that 

BLM clarify how it will balance its conservation efforts with utility‐scale solar energy development.

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15. Secretarial Order 3285 Amendment I Renewable Energy Development by the Department of Interior (February 22, 20 I 0) 

and the Energy Policy Act of 2005 encourages the development of renewable and alternative energy resources, as part of an

overall strategy to develop a diverse portfolio of domestic energy supplies. Furthermore, S03285Al states that "encouraging 

the production, development, and delivery of renewable energy is one of the Department's highest priorities." NV Energy 

requests that potential impacts to the development of renewable energy projects and associated transmission be analyzed in 

the proposed EIS.

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16. The development of renewable energy facilities and utility infrastructure has been a priority for Congress and the current 

administration and is currently a top priority in the DOl strategic plan. Preliminary recommendations by the National 

Technical Team on greater sage-grouse habitat designation indicate significant overlap of greater sage-grouse habitat with 

potential renewable energy development areas. 9 In addition, the designation of vast areas of critical habitat currently 

proposed by some agencies may significantly impair the development of linear infrastructure projects. If these effects are not 

considered, the improper implementation of conservation efforts may have the effect of precluding renewable development 

and hampering the ability of the agencies to meet their renewable energy goals

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17. PCW recommends a balanced conservation policy that provides for prudent and responsible development of renewable 

energy and transmission infrastructure. BLM and USFS should insure that any plan amendments and conservation measures 

implemented are also compatible with agency goals and mandates and that adequate consideration is given to competing 

interests and resources.

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18. In the absence of knowledge, agencies often resort to the "precautionary principal" which states that if an action or policy has 

a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action 

or policy is harmful, the burden of proof that it is not harmful falls on those taking action. Under the precautionary principal, 

BLM and the USFS may be tempted to prohibit certain forms of development on public lands and National Forest System 

lands in order to protect greater sage-grouse in the absence of scientific proof of lack of harm; however, not taking action 

may cause greater harm to the species then allowing responsible renewable energy development to proceed

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19. Exclusion and Avoidance Areas. The NTT Report recommends that Priority Habitat Areas be classified as "exclusion areas" 

for new ROW permits except within designated ROW corridors and that general greater sage-grouse habitat areas be 

classified as "avoidance areas". These recommendations simply go too far, ignore BLM's multiple use mandate, and have no 

scientific basis. Priority Habitat Areas should not be managed as wilderness areas, which is the practical effect of classifying 

priority habitat as an exclusion area. Given the vast extent of greater sagegrouse habitat in the western United States it is

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C. Comments by Resource Planning Issue

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Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

simply not feasible to avoid siting multi-state transmission lines and other long linear facilities within the Rocky Mountain or 

Great Basin regions without encroaching upon greater sage-grouse priority and general habitat areas.

20. Additionally, use of sagebrush habitat management by BLM is necessary to meet renewable and conventional energy 

development standards mandated by the Energy Policy Act of 2005. By making Priority Habitat Areas exclusion areas, BLM 

will be in violation of this and other federal mandates. The BLM must not adopt the recommendations of its Sage-Grouse 

National Technical Team to classify these areas as exclusion and avoidance areas.

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21. The BLM has a trust responsibility to treaty tribes which includes protection of culturally important species such as sage 

grouse and sharptail grouse. The BLM can do this by not allowing any wind turbines to be built within five miles of any sage 

grouse and sharptail leks.

All Both emc0009RM

22. The importance of addressing new threats such as transmission lines and wind development. All Both emc0212GB

23. Sage grouse conservation measures, if too onerous, may also threaten renewable energy generation such as solar and wind 

power and the new transmission lines (such as the Energy Gateway South and Trans West Express projects) needed to 

convey such power to market.

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24. I believe that there are several factors involved in the decrease of their population. Industry such as oil and gas drilling and 

wind generators that are located in their habitat areas have a great influence on the nesting and strutting leks.

All Both cfc0014RM

25. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: Closed to renewable energy development;

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26. BLM should put the following management prescriptions in place for L WCs at a minimum: Closed to renewable energy 

development.

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27. BLM and the Forest Service should incorporate zones and/or provide detailed guidelines for locating wind energy 

development that will protect sage-grouse habitat in affected RMPs and land use plans.

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28. Substantial amounts of sage-grouse habitat have high potential for wind energy development. We support wind development 

in suitable areas, with proper planning for protection of sensitive resources. Without proper planning, sage-grouse can be 

threatened and wind energy development can be delayed while agency resources are spent on projects that will not be

successful. The recently-delayed proposed China Mountain Wind Energy project is an instructive example of a project that 

was proposed in important sage-grouse habitat, would clearly have unacceptable impacts on sage-grouse, and yet required 

many years of analysis by BLM before it was delayed to take into account this EIS process. Identifying areas that are best 

suited to wind energy development, in addition to those that should be protected from energy development to protect 

sage-grouse, will serve two important goals: (l) protecting the greater sage-grouse and (2) supporting wind energy 

development.

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29. Recommendations: The BLM can use this land use planning process for incorporating sagegrouse conservation measures and 

its many other ongoing opportunities to identify areas that are most appropriate for wind energy development, including by 

protecting sage-grouse habitat, and can also incorporate detailed guidelines for designating zones

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30. The Forest Service should also use this opportunity to incorporate identification of areas most appropriate for wind energy 

development and/or providing detailed guidelines for doing so

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-777

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

31. Furthermore future mapping efforts for sage grouse habitat should consider how remote renewable resources might 

connect as this information is available now and can be used to mitigate the risk of overlapping conservation plans and 

transmission projects. Prioritizing sage grouse conservation areas that avoid transmission lines will further regional and 

national efforts to deploy renewable energy at the pace and scale that we need, while planning to protect sage brush species 

in a pro-active way that avoids known and planned for potential new infrastructure. Because transmission planning is 

conducted multiple years in advance of a project breaking ground, the BLM has the opportunity to ensure that sage grouse 

conservation, and transmission

that is necessary to facilitate renewable generation, can exist within the same landscape.

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32. Similarity, the agencies should take into consideration how planned infrastucture to link renewable resources will impact 

sage grouse habitat.

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33. In addition to oil and gas development, wind potential in the Eastern Region is very high. We believe development of wind 

energy can be compatible with wildlife if wind development occurs outside of sensitive areas. Because greater sage-grouse 

avoid tall structures, special care should be taken to develop wind energy outside of identified core areas and all structures 

should be placed at least five miles from the nearest lek if the population is non-migratory and up to 12.5 miles if the 

population is migratory (USFWS 2004).

All Both emc0034

34. In the Steens Mountain area, we are particularly concerned about industrial wind farm development and poor livestock 

grazing practices and the threats they pose to sage‐grouse in the area.

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35. Have you checked with the people, (not govt officials) in the Ft Bridger, WY area. Their grouse populations have increased 

in the wind farm areas. Makes you wonder why! Increased predator control, higher reseeded area???

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36. Sometimes it appears there is a double standard when you consider how many birds are killed each day, even endangered 

species, by wind tubines then stop all drilling because sage grouse habitat is near by.

All Both emc0081RM

37. The RMP amendments also should address significant new threats to sage‐grouse: electrical transmission lines and wind 

power developments.

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38. Wind energy development. Issue: Wind turbines and associated infrastructure can negatively affect sage-grouse. All Both emc0391GB

39. Significant areas of sage-grouse habitat have high potential for wind energy development, and wind energy development is 

increasing in sage-grouse range. FWS recognizes the potential negative effects of wind energy development on sage-grouse 

(75 Fed. Reg. 13949-13952) and has indicated that lek buffer recommendations for other types of development may be

appropriate for wind energy projects (USFWS, undated (a)). Buffer recommendations generally range from “3-5 miles and 

beyond” (USFWS, undated (b); Manville 2004; USFWS 2003). The NTT report identified “wind turbines” as a discreet 

disturbance in sage-grouse habitat, but did not make specific recommendations for wind energy development (SGNTT 

2011). FWS has stated that wind energy development should be prohibited sage-grouse core areas designated in Wyoming 

unless and until it can shown to have no impact on the species (Kelly 2009, letter). This suggests that wind energy 

development should be prohibited in priority habitat in other states. We support wind development in suitable areas and in 

accordance with the prescriptions in the recovery alternative, but it should not proceed in the absence of proper planning to 

protect sagegrouse and other resources. Landscape-level planning that designates zones for wind energy development would 

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C. Comments by Resource Planning Issue

C-778 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

save the agency from committing time and resources to analyze inappropriate wind energy projects. The proposed China 

Mountain Wind Energy Project, now delayed,14 is an example of a project proposed in important sage-grouse habitat that 

would clearly have unacceptable impacts on sage-grouse, and yet required many years of analysis by BLM before it was 

suspended to account for the sage-grouse planning process. The BLM has data on the quality of wind resources (compiled 

during the preparation of the Wind PEIS), potential conflicts from wind energy development with other resources and values,

and the availability of transmission (in addition to current transmission-specific planning efforts), which the agency can use to 

designate wind energy zones for leasing. Further, the BLM’s 2012 budget justification proposed a $3,000,000 increase for the 

Renewable Energy Management program to conduct studies and prepare regional planning studies and environmental 

reviews of potential wind energy zones in Nevada and Oregon. These studies will be completed in addition to those being 

supported with base funds in New Mexico, California, and Wyoming.15 The BLM’s budget proposal iterates the agency’s 

intent to plan for wind energy development zones and to update the Wind Programmatic EIS completed in 2005, while also 

taking into account planned transmission. The agency should use the sage-grouse planning process to inform planning for 

renewable energy development in sagebrush steppe. Similarly, the Forest Service should use this opportunity to identify 

areas most appropriate for wind energy development and/or develop guidelines for doing so.

40. We encourage BLM and FS to fully consider the risks caused by renewable energy development to sage-grouse and the 

sagebrush steppe ecosystem and to err on the side of caution in the development of new management standards and 

conservation measures.

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41. While there is no published research that specifically addresses the effects of wind development on greater sage-grouse, 

there is very strong evidence obtained from similar forms of disturbance, most notably fossil fuel extraction. Wind 

development typically requires many of the same features as oil and gas development. Because of this, FWS, in their 

12-month finding on the petition to list greater sage-grouse, stated that "we anticipate that potential impacts from direct 

habitat losses, habitat fragmentation through roads and powerlines, noise, and increased human presence will generally be 

similar to those already discussed for nonrenewable energy development."

The Service explicitly addresses side-effects of wind development in their 12-month finding, "As with oil and gas 

development, the average footprint of a turbine unit is relatively small from a landscape perspective, but the effects of 

large-scale developments have the potential to reduce the size of sagebrush habitats directly, degrade habitats with invasive 

species, provide pathways for synanthropic predators (i.e., predators that live near and benefit from an association with 

humans), and cumulatively contribute to habitat fragmentation."

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42. An inevitable consequence of any large, ground-disturbing project is the increased risk of colonization by invasive, non-native 

species. In the sagebrush-steppe community, in addition to the slow regeneration of sagebrush, the biggest threat is the 

invasion of cheatgrass. Cheatgrass has the potential to completely alter the ecosystem it invades, increase fire frequency, and 

prevent the establishment of sagebrush and native grass and forb understory. When cheatgrass becomes a dominant 

presence on the landscape it can change the fire regime over a very broad area, causing hotter and more frequent fires that 

destroy nearby sagebrush plants that were not impacted by the original construction project. Even assuming revegetation 

was successful, there is an increased risk of predation on nests by newly accommodated synanthropic predators. Raven, 

coyotes and other opportunistic predators will benefit from an open corridor, putting sage-grouse at further risk. The 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-779

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

introduction of aggressive fauna and flora invasive species are often linked to human disturbances, such as new roads and 

construction of facilities associated with any proposed wind project in sagegrouse habitat.

43. Maintaining greater sage-grouse population numbers and connectivity throughout the planning area will play a key role in 

preserving the species. The science is clear: the best scenario for improved sage-grouse abundance and distribution is to 

conserve habitats with existing populations and then work outward from those core areas to improve habitats in more

peripheral areas. Biologically important sage-grouse habitat throughout the range should be managed conservatively, 

including in areas of high renewable energy potential.

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44. Lastly, we encourage the BLM and FS to incorporate elements of the final Fish and Wildlife Service Wind Energy Guidelines 

into their decision making including: the use of best available science, early public engagement and post-construction wildlife 

monitoring and a comprehensive strategy for effective mitigation.

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45. The proposed amendment to the Land Use Plans must adhere to Federal and State Executive Orders, Statutes, and Policies 

that mandate that the BLM accelerate and encourage renewable energy development.

The Energy Policy Act of 2005 ("EPAct 2005") and other Executive Orders and Policies provide mandates and direction to 

BLM to promote alternative energy development. The Council on Environmental Quality (CEQ) regulations require the BLM 

to "prepare draft environmental statements concurrently and integrated with environmental impact analysis and related 

surveys and studies...and other environmental laws and executive orders." CEQ Regulations §1505.25.

Congress provided a mandate to the Secretary of the Interior in the EPAct 2005 to "seek to have approved non-hydropower 

renewable energy projects located on the public lands with a generation capacity of at least 10,000 megawatts of electricity" 

in the next ten years. Energy Policy Act of 2005 §211. Another Executive Order signed by President George W. Bush directs 

agencies to

[T]ake appropriate actions, to the extent consistent with applicable law, to expedite projects that will increase the 

production, transmission, or conservation of energy...For energy-related projects, agencies shall expedite their review of 

permits or take other actions as necessary to accelerate the completion of such projects...

Executive Order 13212 at Sections 1 & 2 (emphasis added).

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46. B. Renewable Energy Development

The boom of renewable energy sources, including wind, geothermal, and biomass, threatens to degrade or convert 

sage-grouse habitat throughout the West. The conversion of land to support these developments can destroy sage-grouse 

habitat. Additionally, noise and human presence during construction, road construction and use, and water quantity changes 

all have the potential to displace or seriously stress present sage-grouse in the area. And along with energy development 

often comes transmission corridors and associated roads, which can seriously fragment sagebrush landscapes. For these 

reasons, the Fish and Wildlife Service has stated that “the effects of both conventional and nonconventional renewable 

sources may claim a substantial toll on sage-grouse habitats and geographic areas that were in the past considered refugia for 

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Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

the species.” 75 Fed. Reg. at 13952.

47. Geothermal energy production is similar to oil and gas development in terms of impacts. It requires surface exploration, 

exploratory drilling, field development, and plant construction and operation, and direct habitat loss can occur from well 

pads, structures, roads, pipelines, and transmission lines. Human presence during construction, development and operation 

of geothermal processes may cause additional impacts to sage-grouse. Currently there are no enforceable regulations to 

protect sage-grouse during geothermal activities. Rather, the Bureau of Land Management implements best management 

practices to minimize impacts to sage-grouse, but these guidelines are unenforceable and very general in nature.

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48. Similar to geothermal energy, there are currently no regulatory mechanisms for wind development, although mechanisms 

are being developed for core sage-grouse areas in Wyoming. Controversy regarding wind energy grew when FWS wrote the 

Wyoming Game and Fish Department advising that using core population areas for research on the impact of wind energy

would be inconsistent with protecting those areas for sage-grouse because the impacts on the species were unknown. 

Studies predict that wind energy will advance in Wyoming and Montana considerably over the next 20 years, and wind energy 

has been increasing noticeably in Idaho.

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49. Biomass energy development may also create impacts for sage-grouse. Direct conversion of sage-grouse habitat for growing 

biomass fuels creates a threat, as well as use of limited water resources that sage-grouse may rely upon.

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50. Wind power is definitely a negative effect of sage grouse, raptors, wildlife , destruction of land surrounding pads, road 

construction, water consumption and impact of recreation. Decommissioning and restoring after decommissioning, 

upgrading transmission lines and collector lines and oversight relate to nothing short of frivolous spending.

All Both rmc0001RM

51. Recognizing the threats imposed by climate change, NWF has called for a rapid transition to energy sources other than fossil 

fuels that contribute to greenhouse gas emissions. The generation of electricity via solar and wind energy, including 

utility-scale facilities, is an important component of that transition. At the same time, NWF recognizes that while wind power 

may be carbon pollution free, it is not impact free. It leaves an industrial footprint on the land and some wildlife habitats will 

be forever altered by their presence.

More than 30% of greater sage-grouse habitat has high potential for wind power. Utility-scale wind energy development can 

have damaging effects on sage-grouse and their habitat. As such, wind energy development in sage-grouse habitat has the 

potential to cause significant impacts on greater sagegrouse. The BLM plays a critical role in ensuring that the boom in wind 

energy development does not lead to declines in the greater sage-grouse population. The BLM has sufficient data on the 

quality of wind resources, potential conflicts with other resources and values, and availability of transmission, which the 

agency can use to designate wind energy zones, similar to SEZs. Through amendments to affected land use plans, BLM can 

incorporate not only wind energy zones, but also areas that are off limits to wind energy development (as specific 

industrial-level energy ROW avoidance and exclusion areas).

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52. BLM needs to resolve internal policy initiative conflicts within the Department of the Interior (DOI), as they apply to 

renewable energy development and wild horse management. These land uses are DOI priorities even though they have

the same or greater adverse impacts to sage grouse habitat as do other land uses that BLM now proposes to end or restrict;

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-781

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

53. A. Push for Renewable Energy Conflicts With Sage Grouse Habitat Protection

Only two months ago, the Interior Secretary did a series of personal briefings to push for rapid approval of regional 

transmission lines to carry wind energy and for wind farms. At the same time, the Interior Secretary and the Department of 

Energy continue to promote solar and wind energy which are being built on public lands. The adverse impacts from renewal 

energy development are the same or similar to those from oil and gas, mineral or coal development. Nevertheless, the two

departments continue to push and subsidize renewable energy projects, while proposing to shut down oil and gas, coal and 

other mining to protect sage grouse habitat.

Bird mortality due to wind farms remains largely unquantified but is high.1 CLG is also cooperating on the transmission line 

EIS’ where BLM’s rapid approval process gives these lines significant latitude not made available to other projects. The EIS 

documents that the mitigation measures for sage grouse are sufficient, when the same or similar measures are insufficient for 

oil and gas, coal or mining.

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54. Secretarial Order 3285 Amendment 1 Renewable Energy Development by the Department of Interior (February 22, 2010) 

and the Energy Policy Act of 2005 encourages the development of renewable and alternative energy resources, as part of an 

overall strategy to develop a diverse portfolio of domestic energy supplies. Furthermore, S03285A1 states that "encouraging 

the production, development, and delivery of renewable energy is one of the Department's highest priorities." NV Energy 

requests that potential impacts to the development of renewable energy projects and associated transmission be analyzed in 

the proposed EIS.

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55. • Wind development is not necessarily analogous to other development activities and, therefore, studies from those other 

activities should not be used to impose conservation measures on the wind industry.

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56. • The scale of the core area protection approach and its blanket exclusion of wind development compromises state and 

Federal renewable energy and economic development objectives.

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57. C. Renewable Energy Development on Federal Public Lands is an Appropriate and Accepted Land Use under the 

Multiple-Use Mandates

Renewable energy is unquestionably among the diverse multiple uses that Congress intended for the public lands. Not only 

are renewable energy sources, like wind, a "renewable resource" as mentioned directly in the definition of "multiple use" 

under FLPMA and NFMA,37 but they are also an appropriate use of public lands explicitly envisioned by Congress. In the 

Energy Policy Act of 2005, Congress called for approval of nonhydropower renewable energy projects located on the public 

lands with a generation capacity of at least 10,000 megawatts of electricity within ten years of the enactment of the Act.38 

Furthermore, on May 18, 2001, President Bush issued Executive Order (E.O.) 13212, "Actions to Expedite Energy-Related 

Projects," establishing the policy that federal agencies should take appropriate actions, consistent with applicable law, to 

expedite projects to increase the production, transmission, or conservation of energy.

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58. D. Wind Development is Not Necessarily Analogous to Other Development Activities

All development that may impact sage grouse is distinct and includes differing densities of roads, structures, and traffic, 

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lighting, structures of varying heights etc. It is not reasonable to just extrapolate impacts from one kind of development onto 

a totally different kind of development or to just assume that conservation measures applicable to one type of development 

are necessary for another kind of development.

The typical wind project is several orders of magnitude smaller than many other types of development activities where 

greater sage-grouse have been previously studied. The “typical” wind farm is about 100-200 MW and the land needed by 

wind farm infrastructure is about one acre per MW. Studies of some wind energy facilities indicate prairie grouse continue 

to use areas in close proximity to wind turbines. These include studies of greater prairie chickens in Kansas and Minnesota 

and studies of greater prairie chickens and sharp-tailed grouse in Nebraska.186 Most of these studies have only covered a 

relatively short time period and may not document lag effects noted for sage-grouse responses to other development 

activities.187 Thus, to definitively answer whether studies for development activities hold true for wind energy development 

will require actual long-term data from multiple existing wind energy facilities in the sage-grouse range. Until this is done, 

BLM appears willing to continue to rely on surrogate development activities (other than wind) to support the basis for 

imposing restrictions on wind energy development, even though there is no evidence to support drawing such an analogy 

and, in turn, imposing similar restrictions for such distinct development activities.

59. F. The Scale of the Core Area Protection Approach and its Blanket Exclusion of Wind Development Compromises State and 

Federal Renewable Energy and Economic Development Objectives

The sage-grouse conservation documents that the NOI states will inform the RMP amendment process adopt an approach 

whereby important environments for sage-grouse preservation are identified and subsequently established as core areas in 

which development activities are prohibited. For example, there is a blanket prohibition on wind energy development in PPH 

areas in which a 3 percent disturbance threshold has already been met.196 Another related core area protection measure 

requires that PPH areas be managed or restored so that at least 70 percent of the land cover provides sagebrush habitat for 

the sage-grouse.197

Given that the sage-grouse occupies an expansive range across the western United States, much of which overlaps with the 

nation’s regions that possess the greatest potential for wind energy development, such a rigid conservation framework has 

the potential to bring wind energy development on public lands to a halt. AWEA has analyzed the PPH and PGH sage-grouse 

areas designated within different states and how they overlap witheach state’s capacity for wind development. According to 

our analysis, restricting development in the designated areas would result in the loss of 82.2 percent of all lands suitable for 

wind development in Wyoming, 55 percent for Nevada, 53 percent for Montana, 52.1 percent for Idaho, 38.4 percent for 

Oregon, and 9 percent for Utah.198 Considering the magnitude of these percentages, adopting a core area approach 

premised on blanket wind development exclusions would significantly derail the nation’s energy, environmental, and job 

creation objectives associated with renewable energy, and prioritized by the Obama Administration.

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60. H. Conservation Measure Alternatives to the Core Area Exclusion Approach All BLM emc0344GB
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AWEA believes that preservation of the sage-grouse can best be achieved by enlisting the wind industry as a partner in 

conservation and that wind developments can be designed and operated to coexist with sagegrouse habitats. Site-specific 

habitat analyses can be completed pre- and post-construction research to assess the potential impact of wind energy projects 

on sage-grouse to determine how they these projects can best be sited and maintained to mitigate any potential impacts on 

sage-grouse habitats. Compensatory mitigation measures can also be pursued to provide a net benefit to the species, such as 

establishing conservation banks that benefit specific populations in various regions that are most in need.

Another approach to preserving the sage-grouse is augmenting small existing populations in isolated areas by translocating 

sage-grouse from other areas and combining the relocations with habitat enhancement activities. These strategies would 

help to prevent extirpation at the edges of the range and enhance the genetic diversity in these small populations as well.199 

Significant scientific uncertainty surrounds the threats posed to sage-grouse and the value of different conservation tactics. 

Therefore, the sponsorship of applied research to determine what measures are effective in enhancing existing sagebrush 

habitat could provide significant contributions to the species. Examples of other potential mitigation and/or conservation 

measures that we believe would have the greatest positive impact on sage-grouse populations are as follows:

1. Funding a database that would compile all known data on sage-grouse populations, mortality, trends, etc. on a regional and 

national basis.

2. Funding programs focused on habitat improvements and preservation.

AWEA and the wind industry remain available to discuss these and other options that could provide a net positive benefit to 

sage-grouse populations.

61. These measures are minimal, and ineffective. We note that BLM did not even bother to include BMPs for industrial wind, 

solar development, or transmission in the NTT, and its previous 2010 IM and other policies for these are completely 

inadequate. However, we use examples from some recent renewable energy project proposals to illustrate the inadequacies 

of these BMPs for all kinds of development in sagebrush habitats. Industrial renewable energy projects sited on public land

often have colossal impacts and a huge disturbance Footprint similar to oil and gas and industrial geothermal development. 

The guidance is limited, loose and uncertain. It cannot be considered effective. Example: Design roads to an "appropriate" 

standard no higher than necessary to accommodate their intended purpose. This means a freeway could be built "to 

appropriate standards" if the developer said they needed a freeway.

Do not issue rights-of-way..unless.. BLM uses words like "unless" - always giving itself and pliant managers facing political 

pressures to approve projects the ability to do so. Exceptions should not be granted. The word "shall" must be used. 

Under "operations", BLM would "cluster disturbances". Yet the core and priority schemes allow large-scale linear 

disturbances 3%-5% of additional habitat with an immense footprint to slice through "priority" habitats, and uncontrolled 

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sacrifice of general habitats.

62. A moratorium should immediately be placed on all wind energy development projects, rights-of-way, and MET towers on 

public lands. Across the range of sage-grouse and the western landscape, very little is known about migration patterns for 

migratory songbirds and other migrants, including bats and migrating insects like dragon flies. Many areas with the higher 

wind potential are often ridges or plateau rims, and are also the relatively undeveloped remaining sagebrush wild lands - as 

these areas typically have shallower soils, or abundant rocks in some areas, or steep drop-offs, rimrocks or cliffs. So these 

windy areas were not targeted by agencies for livestock sagebrush eradication projects, crested wheatgrass seedings,

intensive pasture fencing and pipeline schemes that typically accompanied livestock forage schemes on productive sites. 

Thus, they are less developed for livestock, and are often better condition remnant habitats that serve as refugia for 

sage-grouse.

Moreover, sage-grouse impacts are but one part of the large-scale adverse impacts of industrial wind facilities. Lethal golden 

eagle impacts, and impacts to migrating species, are often just not understood in sufficient detail to enable agencies to merely 

push siting onto non-priority or non-sage-grouse habitats.

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63. Much more detailed studies of bird and other volant species migration and habitat use patterns must be conducted before 

any areas can be proposed for wind development on public lands. Across the western landscape, very few studies have been 

done. Those that have conducted are often overseen by wind developers or in response to threats of development – and 

may include only spotty observations over a single season. Necessary night-time radar studies over all migration periods and 

thorough ground-based observation studies have often not been conducted. Storms during migration periods - and especially 

spring storms – can down migratory birds and alter areas of highest migrant presence. These effects are seldom if ever 

addressed.

The studies we have seen repeatedly point to the most exceptional known high-use areas, such as the Goshute range in the 

context of raptor migration, as a benchmark for significance of avian use. The studies then try to minimize importance of all

other areas by claiming that, for example, ridges in the Great Basin don’t have as much raptor use as the Goshute Range. 

Thus, they are deemed to be of much lesser importance. With Spring Valley Wind, BLM (and NDOW capitulated) knowingly 

impacted 9% of the North Spring Valley PMU, and further severed habitat connectivity between PMUs. Placing a moratorium 

on industrial wind development and associated infrastructure on public lands in the sagebrush biome would ensure that 

adequate knowledge could be gained so that:

- Sage-grouse habitats will be effectively protected and conserved.

- Conservation actions aimed for sage-grouse do not shift wind development into, and harm, wildlife in other areas – and 

cause significant harm and mortality to other species whose migration pathways are not known – such as migrating warblers, 

western tanagers, rare bats like the Townsend’s big-eared bat, or into areas where high golden eagle mortality is likely.

All Both emc0411GB

64. Plus industrial wind farms have a large adverse Footprint on people who may live near where they might be sited, or shifted 

to, as well. A moratorium is important until the full adverse impacts of wind development on public lands can be better 

understood. The Forest and at times BLM policy of issuing CEs to paper over placement of MET towers must be

immediately ended (if agencies fail to adopt a moratorium)

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65. Sage grouse standards for wind and transmission lines.

Wind power generation represents a clean, renewable alternative to fossil fuels, but construction of wind farms in key 

habitats is likely to lead to unacceptable levels of impact. Although there is little published science directly addressing the 

impact of wind turbines or transmission lines on sage grouse, there is a broad consensus among biologists that sage grouse 

avoid tall structures (such as wind turbines and transmission towers) and abandon adjacent habitats. One unpublished study 

found that sage grouse habitat use increased with distance (up to 600 meters) from transmission lines. It is notable that 

modern perch inhibitors emplaced on transmission lines result in a major decrease, but not elimination, of raptor perching 

(Slater and Smith 2010). Molvar (2008) compiled BLM data from a wind power project on Cotterel Mountain, Idaho and was 

able to determine that the erection of seven meteorological towers led to drastic declines in sage grouse populations across 

nine sage grouse leks, while populations in the surrounding area remained stable. See Attachment 5. There has been 

abundant scientific information that other types of energy development, particularly oil and gas, has a major impact on sage 

grouse populations, and oil and gas development has some similar features such as habitat fragmentation and tall structures 

(in the form of drilling rigs).

All Both emc0343GB

66. The USFWS (no date) conducted a literature review through 2010 and found that recommended buffer distances for sage 

grouse were generally 3.1 to 4 miles and beyond. We endorse the recommendations of USFWS (2003) and Mannville (2004) 

that wind power facilities be sited at least five miles from active sage grouse leks, regardless of whether or not they occur 

within Priority Habitats. Similarly, lands identified as sage grouse winter habitat should similarly be avoided by a distance of 

not less than three miles.

All Both emc0343GB

67. Wind and Transmission

Inside Core Areas

• No wind energy development

• Transmission lines should be buried underground or limited to existing electrical transmission corridors of ... mile 

maximum width.

Outside Core Areas

• Wind farms and transmission lines sited at least 5 miles from active sage grouse leks and at least 3 miles from identified 

winter habitats.

• Transmission lines allowed along existing electrical transmission corridors of ... mile maximum width.

All Both emc0343GB

68. At minimum, the NEPA analysis should address the following:

• Excluding core areas and all other lands within 5 miles of an active sage grouse lek from wind turbine permitting.

All Both emc0343GB

69. Even renewable energy development, which needs to be developed to reduce the harmful effects of climate change, poses a 

great threat to sage-grouse.

All BLM fld0000rm, 

fld0000gb

70. Don't allow new wind or solar facilities in priority sage-grouse habitat. (There are plenty of other good places for renewable 

energy.)

All Both flf0000gb 

flf0000rm
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71. I urge you to consider coordinated plan amendments that will : limit new power lines, wind turbines and other tall structures 

in or near sage grouse priority habitat

All Both flg0000gb 

flg0000rm

72. There are radars that will shut down turbines, there are systems that are not turbines. Please, let's get head together because 

this is killing our wildlife across the nation at an alarming rate. Let's look to European solutions as a guideline. They have 

learned what we apparently cannot.

All Both fla0106gb

73. In my area the PSE Wild Horse Wind Farm near Ellensburg WA is an example of an energy facility built with restoring Sage 

Brush Steppe in mind. I suggest you look at that facilities habitat restoration activities.

All Both fla0012gb

74. No new leasing of non-renewable energy resources within priority sage-grouse habitat. All Both flb0000gb and 

rm

75. The lack of energy development in Middle Park has been beneficial to sustaining our current sage-grouse population levels. 

To sustain the Middle Park population the working group supports the NTT report recommendation of no leasing within 

PPH areas for the Middle Park population. The Middle Park population is the third largest in the state of Colorado after 

Northwest and North Park populations. These 3 populations account for 93% of the males counted. Of the three largest 

populations Middle Park is the only population that does not currently have any energy development activity. There are 

limited leases in Middle Park but at this point most of the lease sales have been deferred until the completion of the BLM 

Kremmling Field Office Resource Management Plan. The MPSGWG strongly encourages protection of the Middle Park 

population from future lease sales to assure that the Middle Park population is not further threatened by energy 

development. The EIS should include an analysis of the NTT recommendations in reference to Mineral Development as 

stated on pg 21 last paragraph of the NTT report and use the most current research to guide BLM in their planning. The CCP 

GrSG Disturbance Guidelines are attached in Appendix II as a reference for BLM to utilize while addressing the issues 

identified in this letter.

CO Both emc0063RM

76. 2. Limit wind and solar energy development. The NTT is silent on both wind and solar energy development. The Routt Plan 

amendment should include a prohibition on wind and solar energy structures in priority habitat and a sufficient area around 

such developments to buffer the effects. Given the height of the turbines used in wind energy and the noise associated with 

them, the buffer may have to be large.

CO USFS emc0175RM

77. WWF, in partnership with The Nature Conservancy, recently developed maps of wind energy potential on already disturbed 

lands in the five states encompassed by the Northern Great Plains Ecoregion (Montana, Wyoming, North Dakota, South 

Dakota, Nebraska; Fargione et al. 2012). Wind potential on disturbed lands alone far exceeds the Department of Energy’s 

goals in each of these states. Thus, we advocate for wind energy development on already disturbed lands that lie outside 

greater sage-grouse core areas.

East Both emc0034RM

78. iii. Strong components of Wyoming’s approach

Wyoming contains some of the highest categories of wind potential (Exhibit 1). However, inappropriately siting and design of 

wind farms can have adverse impacts on wildlife and erode public support at a time when clean renewable power is urgently 

needed. The Wyoming EO 2011-05 rightly states that wind development is not recommended in sage-grouse core areas. 

Wind development and other land uses for which research on the impacts to sage-grouse are lacking are prohibited unless 

it can be demonstrated that they will not cause sage-grouse population declines. EO 2011-5 provides for reevaluation, on a 

East Both emc0089RM
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continuous basis, as new science, information and data become available. In response to an inquiry letter from WGFD, 

former USFWS field supervisor Brian Kelly stated in July 2009, that "constructing wind farms in core areas, even for research 

purposes, prior to demonstrating it can be done with no impact to sage-grouse, negates the usefulness of the core area 

concept as a conservation strategy and brings into question whether adequate regulatory mechanisms are in place to protect 

the species.” USFWS explained that a mitigation plan for wind power development in core areas does not exist.

79. 14. Blm should designate and/or provide guidelines for wind energy development zones that will protect sage-grouse habitat

On December 29, 2011, the BLM issued an Advance Notice of Proposed Rulemaking Regarding a Competitive Process for 

Leasing Public Lands for Solar and Wind Energy Development 76 Fed. Reg. 81906. The notice describes one of the main goals 

as “establish[ing] competitive bidding procedures for lands within designated solar and wind energy development leasing 

areas.” Notably, while BLM is in the process of designating solar energy zones in a Solar Energy Development Programmatic 

EIS (PEIS), the BLM has not designated or undertaken a process to designate specific leasing areas for wind energy 

development. While the BLM completed a PEIS for wind energy development in 2005, the PEIS only generally identified lands

available for wind energy rights-of-way. Much additional research on the impacts of wind energy on wildlife has occurred 

since that time.

The solar energy zones that the BLM will designate in the Solar PEIS are those places that the agency believes best suited to 

utility scale development, based on quality of solar resources, low conflict with other values, and proximity to transmission. 

Similarly, the BLM now has data on the quality of wind resources (compiled during the preparation of the Wind PEIS), 

potential conflicts with other resources and values, and the availability of transmission (also evaluated during the Solar PEIS, 

as well as transmission-specific planning efforts), which the agency can use to make similar designations of wind energy zones 

for leasing. In addition to the benefits of facilitating renewable energy development in areas with high solar and wind 

resources and few conflicts with natural and cultural resources, designation of zones can also aid in planning for future 

transmission development by identifying areas to be prioritized for access when planning new lines. BLM’s 2012 Budget 

Justification included a $3,000,000 increase for the Renewable Energy Management to conduct studies and prepare regional 

planning studies and environmental reviews of potential wind energy zones, specifically in Nevada and Oregon. This is in 

addition to wind studies underway in New Mexico, California, and Wyoming and will support an update to the Wind 

Programmatic EIS completed in 2005. We recognize, however, that while designating renewable energy zones can facilitate 

wind energy development nationwide, individual wind farms and wind turbines must be sited appropriately after careful 

consideration and evaluation of the potential site-specific impacts on wildlife and other resources.

East Both emc0089RM

80. Recommendation: The BLM and FS should use range-wide planning as an opportunity to provide input on how zoning could 

help direct both wind turbines and transmission away from sage-grouse and other sensitive wildlife habitats, including 

designating zones and/or providing detailed guidelines for designation.

East Both emc0089RM

81. Only two months ago, the Interior Secretary did a series of personal briefings to push for rapid approval of regional 

transmission lines to carry wind energy and for wind farms. At the same time, the Interior Secretary and the Department of 

Energy continue to promote solar and wind energy which are being built on public lands. The adverse impacts from renewal 

energy development are the same or similar to those from oil and gas, mineral or coal development. Nevertheless, the two

departments continue to push and subsidize renewable energy projects, while proposing to shut down oil and gas, coal and 

East Both emc0155rm
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other mining to protect sage grouse habitat. Bird mortality due to wind farms remains largely unquantified but is high. VRLP 

is also cooperating on the transmission line EIS where BLM's rapid approval process gives these lines significant latitude not 

made available to other projects. The EIS documents that the mitigation measures for sage grouse are sufficient, when the 

same or similar measures are insufficient for oil and gas, coal or mining.

82. The Great Basin sagebrush ecosystems are experiencing a relatively new threat in the form of large-scale industrial wind 

energy projects. Part of Spring Valley in Nevada has recently been developed with large wind turbine generators very close 

to active leks. This is inappropriate for the recovery of the Greater sage grouse.

GB Both emc0404GB

83. Wind projects fragment large areas of sagebrush with many miles of new roads, as well as providing new perches for raptor 

predators of the grouse. Wind projects need to be very carefully sited away from sage grouse habitats in the future.

GB Both emc0404GB

84. The Western region will not likely experience high rates of natural gas or oil development in the short term due to limited 

resources; however all of the region will have increases in renewable energy development and the expansion of high-voltage 

electric transmission lines. Many planning efforts related to transmission and renewable energy siting are underway by BLM 

and other federal agencies. The BLM should ensure these plans and environmental review processes take into account 

recommendations from the NTT, and are compatible with sagegrouse conservation efforts. With increase of applications for 

renewable energy facilities within sage-grouse habitat, a greater emphasis must be placed on developing specific standards 

and guidelines for energy development in known or potential sage-grouse habitat. BLM should seek to steer development 

away from areas with important sage-grouse habitat, and establish an expectation that proposed development in high-conflict 

areas will face significant risks and challenges. While the research outlining the impacts of renewable energy facilities on 

sage-grouse

populations is still in early stages, research detailing the impacts of oil and gas extraction is available. Although these 

developments may be different in the footprint they share, they do include disturbances such as roads, increased human 

activities, transmission corridors, and fences. The deficiency of published data on the impacts of renewable energy does not 

negate the potential for detrimental effects. Negative impacts of these developments can include: - Avoidance behavior, 

potentially dispersing adults from lek sites or winter ranges; - Increased mortality through collisions, stress, and nest 

abandonment; the Western region will not likely experience high rates of natural gas or oil development in the short term 

due to limited resources; however all of the region will have increases in renewable energy development and the expansion 

of high-voltage electric transmission lines.

Many planning efforts related to transmission and renewable energy siting are underway by BLM and other federal agencies. 

The BLM should ensure these plans and environmental review processes take into account recommendations from the NTT, 

and are compatible with sagegrouse conservation efforts. With increase of applications for renewable energy facilities within 

sage-grouse habitat, a greater emphasis must be placed on developing specific standards and guidelines for energy 

development in known or potential sage-grouse habitat. BLM should seek to steer development away from areas with 

important sage-grouse habitat, and establish an expectation that proposed development in high-conflict areas will face 

significant risks and challenges. While the research outlining the impacts of renewable energy facilities on sage-grouse 

populations is still in early stages, research detailing the impacts of oil and gas extraction is available. Although these 

developments may be different in the footprint they share, they do include disturbances such as roads, increased human 

GB Both emc0355GB
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activities, transmission corridors, and fences. The deficiency of published data on the impacts of renewable energy does not 

negate the potential for detrimental effects. Negative impacts of these developments can include: - Avoidance behavior, 

potentially dispersing adults from lek sites or winter ranges; - Increased mortality through collisions, stress, and nest 

abandonment.

85. With specific regard renewable energy transmission and resource development, the proposed action must take into account 

the years of work done by:

The Western Governors Association Regional Transmission Expansion Project, analysis of transmission requirements under 

a broad range of alternative energy futures and to develop long-term, interconnection-wide transmission expansion plans. 

More information may be found at http://www.westgov.org/rtep .

These studies provide the basis for developing a balanced program of habitat management with energy development 

potential in terms of designated land use.

All of these studies have been developed with a broad range of expertise and experience. State and federal agencies were 

contributing members along with utility, conservation and industry groups. All have extensive map products available for use 

and incorporation into the proposed action. All consider constraints of cultural, social, and biological issues among others.

All have recommendations of primary renewable energy zones and necessary transmission corridors for delivery of energy.

All of the studies are less than three years old and pertinent to the proposed action.

GB Both emc0254GB

86. With specific regard renewable energy transmission and resource development, the proposed action must take into account 

the years of work done by:

The Nevada Renewable Energy Transmission Access Advisory Committee (RETAAC), commissioned under executive order 

by Nevada State Governor Jim Gibbons, in support of Nevada’s adoption of the Renewable Portfolio Standard, defined 

renewable energy zones, zones of constraint and transmission corridors. RETAAC’s Phase II report, published on July 1, 

2009, is ultimately the product of more than 25 General Committee and Workgroup meetings conducted by and with 

participation from a significant cross-section of agency and industry stakeholders, including RETAAC Phase II Committee 

Member Amy Lueders who concurrently served as Nevada BLM’s Associate State Director and is currently State Director. 

Other notable participating agencies with representative RETAAC Committee Members include the Nevada Division of 

Environmental Protection, Nevada Division of Minerals, Office of the Governor - Nevada State Office of Energy, Public 

Utilities Commission of Nevada, and the Nevada Department of Wildlife. The full reports and maps can be downloaded at 

http://sites.google.com/site/retaac.

These studies provide the basis for developing a balanced program of habitat management with energy development 

potential in terms of designated land use.

All of these studies have been developed with a broad range of expertise and experience. State and federal agencies were 

contributing members along with utility, conservation and industry groups. All have extensive map products available for use 

and incorporation into the proposed action. All consider constraints of cultural, social, and biological issues among others.

NVCA Both emc0254GB
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All have recommendations of primary renewable energy zones and necessary transmission corridors for delivery of energy.

All of the studies are less than three years old and pertinent to the proposed action.

87. With specific regard renewable energy transmission and resource development, the proposed action must take into account 

the years of work done by:

The California Renewable Energy Transmission Initiative (RETI) assessment all competitive renewable energy zones in 

California and in neighboring states that can provide significant electricity to California consumers by the year 2020. RETI 

also will identify those zones that can be developed in the most cost effective and environmentally benign manner and will 

prepare detailed transmission plans for those zones identified for development. More information can be found at

http://www.energy.ca.gov/reti/index.html .

These studies provide the basis for developing a balanced program of habitat management with energy development 

potential in terms of designated land use.

All of these studies have been developed with a broad range of expertise and experience. State and federal agencies were 

contributing members along with utility, conservation and industry groups. All have extensive map products available for use 

and incorporation into the proposed action. All consider constraints of cultural, social, and biological issues among others.

All have recommendations of primary renewable energy zones and necessary transmission corridors for delivery of energy.

All of the studies are less than three years old and pertinent to the proposed action.

NVCA Both emc0254GB

88. In the Renewable Energy Section of Appendix VI, the EIS cites a Northwest Economic Associates, 2003 study of wind farms 

economic impacts. More current information is available on the negative impacts from the northeast Oregon wind farms in 

Baker Co.

OR Both rmc0036GB

89. For powerline transmissions, and wind energy projects it might be advantageous to have the lowest wire on the transmission 

line or tip of the wind turbine be above a specific distance from the ground in core area habitat. Sage Grouse do not fly very 

high but a minimum could be set.

WY Both emc0050RM

90. iii. Strong components of Wyoming’s approach

Wyoming contains some of the highest categories of wind potential (Exhibit 1). However, inappropriately siting and design of 

wind farms can have adverse impacts on wildlife and erode public support at a time when clean renewable power is urgently 

needed. The Wyoming EO 2011-05 rightly states that wind development is not recommended in sage-grouse core areas.

Wind development and other land uses for which research on the impacts to sage-grouse are lacking are prohibited unless 

it can be demonstrated that they will not cause sage-grouse population declines. EO 2011-5 provides for reevaluation, on a 

continuous basis, as new science, information and data become available. In response to an inquiry letter from WGFD, 

former USFWS field supervisor Brian Kelly stated in July 2009, that "constructing wind farms in core areas, even for research 

purposes, prior to demonstrating it can be done with no impact to sage-grouse, negates the usefulness of the core area 

concept as a conservation strategy and brings into question whether adequate regulatory mechanisms are in place to protect 

the species.” USFWS explained that a mitigation plan for wind power development in core areas does not exist.

WY Both emc0089RM
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91. The boom of renewable energy sources such as wind and geothermal, threatens to degrade or convert sage-grouse habitat 

throughout the West. The conversion of land to support these developments can destroy sage-grouse habitat. The FWS 

writes, Renewable energy resources, such as windpower and geothermal energy, require many of the same features for 

construction and operation as do non- renewable energy resources. Therefore, we anticipate that potential impacts from 

direct habitat losses, habitat fragmentation through roads and powerlines, noise, and increased human presence (Connelly et 

al. 2004) will generally be the same as already discussed for nonrenewable energy development. Windpower may have 

additional mortalities resulting from sage-grouse flying into turbine rotors or meteorological towers (Erickson et al. 2001).

Additionally, noise and human presence during construction, road construction and use, and water quantity changes all have 

the potential to displace or seriously stress present sage-grouse in the area. Transmission corridors and associated roads 

accompanying energy development can seriously fragment sagebrush landscapes. For these reasons, the FWS has stated that 

"the effects of both conventional and nonconventional renewable sources may claim a substantial toll on sage-grouse habitats 

and geographic areas that were in the past considered refugia for the species." (75 FR 13952.)

Currently it is estimated that 21 percent of Wyoming core areas have high wind potential, and about 51 percent are subject 

to either wind development or are authorized for development of oil and gas leases. Studies predict that wind energy will 

advance in Wyoming and Montana considerably over the next 20 years. Fortunately, in Wyoming, "wind development is not 

recommended in sage-grouse core areas, but will be reevaluated on a continuous basis as new science, information and data 

emerges" (Wyoming Executive Order 2011-5, Wyoming Greater Sage-Grouse Core Area Protection). While this "not 

recommended' preference is commendable, the Wyoming Core Area strategy should take a precautionary approach and 

"exclude" wind development from core areas until thorough bodies of scientific literature indicate that wind energy 

development does not harm sage grouse conservation.

WY Both emc0167RM

92. The State of Wyoming is pursuing a sound policy with regard to wind power development in sage grouse habitat, that of 

excluding wind power development from designated Core Areas (although for several wind projects, Core Area boundaries 

have been shifted to exclude lands desired by the wind industry). Excluding wind power development from core habitats 

makes sense; in Wyoming, more than four million acres commercially viable for wind energy development are outside of 

Core Areas and have no other identified environmental conflicts (Molvar 2008), which represents approximately four times 

the maximum acreage needed for the high benchmark for wind development through 2030 (estimated at 10,000 turbines by 

the wind power industry).

There are some real emerging problems, however, with Core Area boundaries being altered to allow wind projects to be 

built in lands originally designated as Core. The Power Company of Wyoming’s Chokecherry project is the most egregious 

example of these, and is a thousand-turbine project in recently undesignated Core habitat that is likely heading for litigation. 

Another example is a proposal by Whirlwind LLC for the South Pass Core Area; a carve-out was granted for this project, and 

although Whirlwind has thankfully relocated to another site in Carbon County, the carve-out remains.

WY Both emc0343GB
C. Comments by Resource Planning Issue

C-792 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.D

Comments Related to Renewable Energy Development

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

93. In the GIS-based report, Wind Power in Wyoming: Doing it Smart from the Start (Attachment 5), BCA was able to identify 

almost 4 million acres in Wyoming with commercial wind potential and no environmental conflicts, and an additional 12.5 

million acres with manageable environmental conflicts which are readily ameliorated through the use of Best Practices 

outlined in the report. Given that the maximum build-out of 10,000 turbines by 2030 could be accommodated on 1 million 

acres, there is no reason to allow wind development in important sage grouse habitat. We recommend that wind power 

facilities be sited no closer than 5 miles from any active sage grouse lek or within 3 miles of identified winter concentration 

areas.

WY Both emc0343GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-793

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Detrimental projects must not be rammed through regardless of the consequences to sage grouse and other 

sagebrush-dependent species.

All Both rmc0039GB

2. The Ranch has numerous pastures in its Jackpot allotment (an Elko Field Office managed allotment) that will be affected by 

the construction and operation of the proposed China Mountain Wind Project (the “Project”). The Project will result in 

approximately 70 miles of all‐weather gravel roads and increase public access and traffic within the heart of prime sage 

grouse habitat, as well as within our fee ground and our grazing allotments. Construction schedules have varied for the 

Project, but the proposed schedules consistently show construction beginning no later than the summer of 2013. We 

question how the BLM can approve a plan of development for the Project before Records of Decision and approved RMP 

Amendments for sage‐grouse are issued in 2014 for both the Nevada/ NE California and the Idaho/ SW Montana 

sub‐regions.

All Both emc0037GB

3. The other issue that is hurting habitat is the sprawl of home building and construction in critical habitat areas. Planning and 

zoning should be a part of the process of habitat preservation. I have been a part of seeing the wildlife biologists hands being 

tied by the Governors' advisory council which has to respond when issues are raised about wildlife conflict with proposed 

development and habitat. If input from wildlife concerns were submitted on proposed projects in a timely manner, the 

input could help shape planning on critical development.

All Both emc0405GB

4. The distances set for no surface disturbance activities is probably excessive in all reality. All Both cfc0018RM

5. BLM should put the following management prescriptions in place for LWCs at a minimum: Closed to construction of new 

roads

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6. There is significant scientific evidence that the BLM should protect sage grouse habitat by establishing a 4-mile No Surface 

Occupancy zone around each and every sage grouse lek, For the reasons enumerated below, this would promote their 

conservation and minimize the need for listing sage grouse under the ESA.

All BLM emc0057RM

7. Review of Literature from GSGCM Report. Upon reviewing the GSGCM report, we reviewed literature cited by the 

report as the basis for the conservation measures. The GSGCM report suggests that only a 3% disturbance of a section be 

allowed in very limited circumstances at any one time, and on page 21 regarding energy development, the GSGCM reports 

Conservation Measures present that the exclusion of mineral development and other disturbances from priority habitats 

is needed where possible and that agencies should limit them as much as possible in other areas (including private lands). 

The same section also states that a 4-mile NSO [no surface occupancy] likely would not be practical given most leases are 

not large enough to accommodate a buffer of this size, and lek spacing within priority habitats is such that lek-based buffers 

may overlap and preclude all development (emphasis added). It further states that 4-mile buffers around leks are needed to 

ensure the continued persistence of the greater sage-grouse. The 3% surface disturbance conservation measure equates to 

only 19.2 acres of disturbance in a 640-acre section, based on "professional judgment from Holloran 2005, Walker et al. 

2007, Doherty et al. 2008, Doherty et al. 2011, and Naugle et al. 201la, b"(see pg. 8 of GSGCM report). Further, the 

GSGCM report states that if there is already 3% surface disturbance within sage-grouse habitat, then no other uses should 

be allowed. The GSGCM report also indicates that if there is already more than 3% surface disturbance in sagegrouse 

habitats, then significant reclamation activities and mitigations should take place. However, upon reviewing the scientific 

All Both emc0058RM
C. Comments by Resource Planning Issue

C-794 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

literature cited by the GSGCM report, we do not see where these articles support a maximum limitation of 3% surface 

impacts within sage grouse habitats as needed for the continued persistence of the species. We believe that while the cited 

scientific articles do present solid science that sage grouse are sensitive to loss of sagebrush habitats and indirect impacts 

from road traffic, noise, etc., the GSGCM report takes a very extreme stance that is not supported in the cited articles that 

effectively halting any further realistic land-use activities within sage-grouse habitat is needed to protect the species.

8. The County further questions the viability of restricting access to leased or unleased federal fluid mineral estate by 

helicopter-portable drilling methods in priority habitat areas without the ability to transport the gas to market. This is 

especially challenging when there may already be seasonal timing restrictions are already in place. "Alternative B" on Page 

22 of the National SGS Report appears to be more reasonable as it provides an opportunity for energy development to 

occur so long appropriate mitigation measures are also being pursued. The County recommends that the EIS contain an 

alternative that is consistent with this approach rather than a complete NSO alternative with very limited (3%) disturbance 

rules.

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9. With regards to anthropogenic disturbances and their distance relationship to lek sites, it is the BLM’s responsibility to 

allow no further disturbances to take place within a 5.5 mile radius of lek sites.

All BLM emc0074RM

10. Balancing Protection of Natural Resources

In order to maintain valuable ecological functions across the landscape, we believe that it is preferable to direct 

development away from areas of high conflict and sensitive resources and towards areas of low conflict, such as previously 

disturbed sites, areas adjacent to previously disturbed sites, and locations that minimize construction of new roads and 

transmission lines. This position is consistent with the intent of the ELM's Instructional Memorandum No. 2011-061.

All Both rmc0020RM

11. Air Quality

We recommend that the EISs also analyze the air quality implications of proposed conservation measures. We are 

especially interested in how conservation measures influence fugitive dust, wind erosion, wind-borne particulate matter, 

and construction emissions, operational emissions from energy and mineral development, and smoke, both within and 

outside of greater sage-grouse conservation areas

All Both rmc0020RM

12. Man-Made Disturbance in Areas of Low-Quality and Degraded Sage-Grouse Habitat

There should be a positive, proactive relationship between sage grouse, man-made disturbance, and restoration of 

low-quality and degraded sagebrush communities (R-values as explained in the attachment: Greater Sage-Grouse Habitat 

Categorization). Because sage grouse habitat is a special issue, we need a special classification of disturbance pertinent to 

the issue. On a case by case basis, we need a disturbance classification that supersedes permitted disturbance limits (e.g., 

5 acres per notice on BLM administered lands, Plan of Operations, and EAs) and that makes consideration for low quality 

or degraded (R3/X3 juniper/pinion encroachment and R4/X4 cheat grass and noxious weeds) sage-grouse habitat.

All disturbances must be bonded and reclaimed, at operator's expense, to appropriate vegetation. In sage-grouse country, 

that vegetation would be suitable for sage-grouse habitat. To the extent that disturbance can be conducted on or routed 

through low quality sage-grouse habitat, especially R3/X3 and R4/X4 areas, reclamation can only improve, not degrade, 

habitat for sage-grouse. In these areas, disturbance and its requisite reclamation to sage-grouse habitat should be 

encouraged by not having the disturbance count against the permitted limit. This is one way to get the sage-grouse habitat 

All Both emc0-250GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-795

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

issue to win-win through multiple use of the land.

13. The plan amendments will need to specify which use or user will have priority to create new disturbances within habitat 

areas. The first-come, first-served approach may not be in the long-term public interest.

All Both emc0376GB

14. The plan amendments will need to specify whether surface disturbance limitations will include the existing disturbance or 

just new disturbance after the effective date of the amendments.

All Both emc0376GB

15. Specifically, VGC is concerned about the large-scale land use restrictions and prohibitions - including the withdrawal of 

lands with high-priority sage grouse habitat from mineral entry - that is proposed in Instruction Memorandum ("IM") 

IM-2012-044, "BLM National Greater Sage-Grouse Land Use Planning Strategy" and in the December 2011 National 

Technical Team Report entitled, A Report on National Sage-Grouse Conservation Measures ("the NTT Report").

If implemented as currently proposed, these draconian conservation measures will thwart mineral exploration and 

development and other private-sector uses of public land under the guise of sage-grouse habitat conservation.

All Both rmc0029RM, 

rmc0060GB

16. Priority and general habitat, as recommended by the NTT, must be diligently designated to ensure that all key habitat areas 

are considered in management planning processes. Priority habitat should include all winter range, breeding habitat and 

migration corridors for sage grouse and policies on disturbances should be based on peer-reviewed science and technical 

reports from federal agencies and NGO’s.

All Both emc0380GB

17. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence:

- Tall structures and associated activities in greater sage grouse habitat may lead to negative impacts on greater sage 

grouse.

All Both emc0343GB

18. BLM is in reality only making some changes, often meager, in some new activities even in the Priority zone- while all the 

existing damage, and the meager and inadequate project "mitigations" that have been used in the past as conservation 

measures remain with relatively minor changes made. Avoidance distances are greater. But it is now known that applying 

avoidance periods during construction while letting the development proceed, does not achieve conservation. NTT at 21. 

"We do not include timing restrictions on construction and infrastructure because they do not prevent impacts of 

infrastructure (e.g., avoidance, mortality) at other times of year, during the production phase, or in other seasonal habitats 

that are crucial for population persistence (e.g. winter Walker et al. 2007)." 

Stripping seasonal avoidance periods means that "take" and harassment of birds during construction is much more likely to 

occur during construction. While we recognize the gat inadequacy of these measures, WWP is very concerned that this 

aimed more at allowing project to be rapidly ripped in - destroying nests, killing nesting birds, etc. This is in fact a huge gift 

to developers. If BLM allows development to occur by saying it doesn’t make any difference - the grouse are doomed 

anyway - this would still appear to violate the Migratory Bird Treaty Act.

All BLM emc0411GB

19. BLM is to: 

- Manage priority sage-grouse habitats so that discrete anthropogenic disturbances cover less than 3% of the total 

sage-grouse habitat regardless of ownership. These features are: paved highways, gravel roads, transmission lines, 

All BLM emc0411GB
C. Comments by Resource Planning Issue

C-796 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

substations, wind turbines, oil and gas wells, geothermal wells and facilities, pipelines, landfills, homes and mines. 

This definition purposefully omits fences that kill sage-grouse, livestock water developments that promote West Nile virus 

and severe degradation of de-watered spring habitats, and degraded upland habitats. Spring developments dry up or greatly 

reduce flows and shrink meadow and other brood rearing areas. It omits disturbance such as imposing large herds of 

livestock - including in combination with damaging facilities and management practices. The degree and severity of 

understory degradation into areas where pipelines or roads are built - are habitat-degrading anthropogenic disturbances 

associated with livestock grazing. Livestock grazing disturbance is an imposed impact caused by man. Domestic livestock 

are not native to the sagebrush biome (Mack and Thompson 1982), and are imposed by humans with catastrophic 

historical degradation and loss, and chronic continuing harm- including landscape-level desertification, and loss of habitats 

and populations. 

Plus this ignores blocks of private cropland and activities that may already occur in these habitats. How are these going to 

be dealt with? 

Careful examination of the wording shows that lands could be completely torn to pieces, but BLM will be able to look at 

the direct bulldozed disturbance, and not the real ecological Footprint or impact of the disturbance. For example, there is 

a large difference between the many square mile visual Footprint of a wind turbine, and the bulldozed footprint where 

turbines are placed- the difference is square miles vs. small fractions of a mile.

20. BLM narrowly defines disturbance when it comes time to mitigate impacts - which unfortunately these days usually means 

having a developer throw money at studies or woody vegetation treatment, and ignore mitigation by avoidance - i.e, 

appropriate siting, thus not building projects in sensitive lands.

All BLM emc0411GB

21. This 3% disturbance threshold ignores the spatial configuration of the 3% of disturbances within any given land unit, as 

well as the cumulative impacts of all of these "anthropogenic" disturbances, along with the livestock grazing facilities and 

disturbances that would also be occurring in this same land area. Plus there are usually many pre-existing disturbances 

-such as roads, vegetation treatments, etc. that have fragmented, altered destroyed sagebrush habitats.

All Both emc0411GB

22. Under the 3% more new Development scheme, the sagebrush habitat could be crisscrossed by myriad roads, powerlines, 

gas pipelines, and wind towers placed in several areas. On top of these would be occurring all the other "anthropogenic" 

disturbances like grazing. All direct, indirect and cumulative impacts of which must be fully assessed. Yet the tattered 

Core/Priority area still would not exceed 3% new development under this arbitrary definition. So habitats could be 100% 

disturbed by grazing, all existing roads remain, and the land be additionally chopped apart with new linear livestock water 

pipelines, natural gas pipelines, wind farms, mines, etc. NTT at 7-8 defines the new allowed disturbance as "discrete 

anthropogenic disturbances cover less than 3% of the total sage-grouse habitat regardless of ownership. Anthropogenic 

features include ..paved highways, graded gravel roads, transmission lines.."

This also seems to assume that disturbance is neat and tidy, and all its effects are predictable and stay confined to the 3% 

All Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-797

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

land area. This of course is seldom of ever the case. Small disturbances can promote weed infestations that promote 

wildfires that flash across the landscape, especially in lands that suffer large-scale degradation from livestock grazing and 

trampling impacts, which aids weed spread and domination. 

Wouldn’t it make a difference -given the complete footprint of lines, roads, energy facilities- if all manner of linear 

development tore up 3% of the land surface of the Priority habitat- compared to a mine in one discrete area or corner of 

an area tearing up 3%? These arbitrary percentages allowing even more disturbance and habitat destruction are arbitrary. 

The Core Model, and its development enabling components, which is being used to enable additional oil and gas in 

Wyoming, should not be applied. Indirect and cumulative effects, such as weed invasion, were not adequately examined in 

those energy field studies - which looked at a snapshot of time, and then made sweeping assumptions. What happens with 

mid and long-term losses as habitats get choked with weeds emanating outward from linear disturbances, or other similar 

effects? 

The condition of the habitat, the status of the population, and how severe habitat loss and fragmentation has already been, 

all must serve as the basis for understanding how much disturbance must be decreased, rolled back, and the degree to 

which habitats must be protected and both actively and passively restored. 

Nearly all of the biome has many fewer sage-grouse at far lower densities - and often existing in naturally fragmented 

habitats - such as Basin and Range topography, on top of which areas have been fragmented by wildfire or human 

development. The model allows large amounts of linear disturbances. These would have a far greater ecological footprint 

than the 3% disturbance.

23. The cumulative impacts of all disturbances must be examined. Any assessment of disturbance must include the total 

Footprint of an activity, and must include grazing disturbance and fire, as well. Habitats are often subject to 100% 

disturbance use by livestock. BLM simply cannot allow 3% more disturbance on its lands. It cannot allow "disturbance" to 

just be considered the bulldozed land area of a project, and not grazing.

All BLM emc0411GB

24. While it is easy to list "remove or re-inject water" to limit mosquitoes - just how does one remove water from artificial 

created roadside berm puddles, and all manner of other stagnant water areas created by oil and gas energy development, 

mining, industrial wind and associated roading, and livestock facilities across public lands? Plus what pollutants are in 

re-injected water - and how much could this harm wildlife waters, aquatic habitats, and humans?

All BLM emc0411GB

25. A clear framework must be established that triggers mitigation by avoidance –i.e. not claiming that

building a project in important occupied habitats can be mitigated.

All Both emc0411GB

26. As landscapes have become increasingly altered, degraded and fragmented, opportunities for

“mitigation” by replacing habitats has often become difficult. This is especially the case since sage-grouse habitat needs are 

complex, and the specific assemblage of habitat features required for a population to be sustained are often just not 

available elsewhere. So we are to a point now that any additional losses of sagebrush habitats simply cannot be effectively 

mitigated in many instances. Mitigation by avoidance must be practiced. A clear framework to assess the adequacy of 

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C. Comments by Resource Planning Issue

C-798 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

mitigation up front, and allow agencies to say no to projects before they progress to the point of rights-of-way, exploratory 

development, etc. must be provided. BLM must fully consider removal/cessation of grazing disturbance over large areas to 

be passive restoration that serves as mitigation. BLM must amend all Land Use Plans to allow for grazing permit retirement 

to accomplish this.

27. The section “Calculating the Density of Disturbance within Key Habitat” describes conducting an “additional site-specific 

analysis of disturbance” after alternatives and a preferred alternative have been selected. Intensive site-specific information 

needs to be collected and analyzed to guide the development of alternatives and a Preferred Alternative before putting out 

a DEIS. This has not been done. Several potential route segments that BLM is allowing to be put forward are the dead 

opposite of co-locating or bundling lines.

All BLM emc0411GB

28. This sage-grouse process must require that mitigation by avoidance be placed first and foremost. Developers must be 

required to find other areas.

All Both emc0411GB

29. At minimum, the NEPA analysis should address the following:

• Providing NSO buffers of at least 2 miles and up to 4 miles inside core areas to protect breeding and nesting habitats from

impacts.

All Both emc0343GB

30. At minimum, the NEPA analysis should address the following:

• Evaluating winter habitat and placing key wintering areas with an adequate buffer (at least 2 miles) off-limits to industrial 

activity.

All Both emc0343GB

31. At minimum, the NEPA analysis should address the following:

• Identifying key early and late brood-rearing habitats and placing them off-limits to industrial use, with a biologically 

adequate buffer.

All Both emc0343GB

32. It is critical for BLM to consider implementing the following technical team recommendations as minimum standards:

* Fully protect priority habitat from large scale disturbances (e.g. transmission lines, oil and gas wells, graded roads etc.) 

that will harm sage-grouse populations.

* If priority habitat can't be fully protected from large-scale disturbances due to existing rights, minimize impacts by limiting 

disturbances to one per section with no more than 3% surface disturbance.

* Ensure that small scale disturbances don’t disturb more than 3% of each priority area.

All BLM fln0000rm

33. Also a fact that is not accounted for or disclosed in the GSGCM report, is that the literature cited to support the 

Conservation Measures are from studies which all took place in highly developed natural gas and CBM fields in Wyoming, 

where in many cases the density of well pads was often near 15 pads per section (40 acre spacing), and that the studies took 

place in areas that also had other significant surface impacts (e.g., water evaporation ponds, roads, pipelines, compressor 

stations and gas plants, as well as infill projects; e.g., Jonah Field (I & II}, Pinedale Anticline, Powder River Basin, Continental 

Divide-Crestone project, etc.). We feel that while these studies may be applicable for sage-grouse direct and indirect 

impacts adjacent to high density gas field development in Wyoming, it is not accurate or appropriate to reference the types 

CO Both emc0058RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-799

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

of impacts seen in some of the highest density gas fields in the U.S. and apply conservation measures arbitrarily and equally

to all habitats in all States and Counties.

We interpreted the results presented in these articles as indicating that within 0.25 to 1.5 miles of very intensive natural 

gas/CBM field development there are significant decreases in sagegrouse habitat utilization, and that the further habitats 

are from intensive land use activities, the less impact there is. But we again contend that the results of these studies do not 

indicate that 4 mile buffers are warranted for the protection of the species, and that the GSGCM report, while referencing 

these studies as its scientific basis, does not accurately reflect the facts presented in the studies, and if anything presents a 

biased interpretation of the results. The GSGCM report's Conservation Measures appear to only consider the needs 

sage-grouse in remaining habitats in Wyoming, and does not accurately account for or respect the ongoing uses, needs, of 

other permitted uses of public, and more importantly, of private lands. While the long-term protection of greater 

sage-grouse is also important to the County, we believe that more balance and a more realistic land use management 

process is needed and should be incorporated into any management planning efforts.

34. The NTT Report recommends a 3% disturbance threshold across landownership. At the time of the Draft, the EIS should 

clarify what is meant by 3% disturbance and if it includes habitat treatments or just anthropogenic disturbance such as 

roads, well pads, and power lines. The EIS should clarify how this analysis will be done, especially when considering 

disturbance on private lands. The EIS should also include an analysis of the current/baseline amount of disturbance within 

PPH in North Park. Because BLM regulations do not apply on private lands, the BLM should address why private lands 

cannot be excluded from the PPH and PGH maps for the purposes of this EIS.

CO BLM emc0060RM

35. The bright line prohibitions mandated by "no surface occupancy" areas where "no future development" can occur may 

seem reasonable on paper, but may actually be counterproductive when compared to boots-on-the-ground oversight. We 

believe that a more reasonable approach would be to designate sensitive habitat areas, and then only allow development 

in or around such designations after review by BLM and state stewards with the operator as described in the recent 

examples above. This would not only better protect Sage Grouse habitat, but would also be more in keeping with the 

multiple use and public interest standards traditionally underpinning recent RMP and EIS documents issued in the State of 

Colorado.

CO BLM emc0073RM

36. The radius of 4 miles given to each known operating lek is inadequate. The circumference for each lek needs to be raised 

to a MINIMUM 5.5 mile radius, therefore increasing overall coverage of all priority habitats. Mere “adequate” coverage, 

when considering this plan covers the span of 20 years, negates the whole preservation and enhancement of current 

greater sage grouse numbers. Current data suggesting a 4 mile radius is enough does not plan for the future.

CO Both emc0074RM

37. The following recommendations must be analyzed as a starting point for effective conservation: Fully protect priority 

habitat from large scale disturbances (e.g., transmission lines, oil and gas wells, graded roads, etc.) that will affect population 

distribution and abundance at any level.

CO BLM emc0070RM

38. The BLM should consider a ‘conservation alternative’ that: - Includes conservation measures recommended by the NTT 

Report, with improvements, including, but not limited to the following:

o Avoid sagebrush reduction/ treatments to increase livestock or big game forage in priority habitat and include plans to 

restore high-quality habitat in areas with invasive species.

CO BLM emc0070RM
C. Comments by Resource Planning Issue

C-800 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

o Implement range management practices outlined by the NTT, with addition of further conservation measures, including 

avoiding new range and water developments that negatively impact sage-grouse and applying the 3% disturbance cap to 

certain range developments.

o Design fuel treatments to protect existing sagebrush ecosystems (including avoiding such treatments where they will 

harm sagebrush ecosystems) and prioritize fire suppression to conserve the highest quality habitat.

o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t negatively impact sage-grouse 

populations in priority habitat,31 thus negating the value of designated priority habitats. Include small or isolated 

populations (such as those along the periphery of the greater sage-grouse’s range) in priority habitat, and protect and 

enhance such populations with science-based prescriptions.

- Combines this with designations of a subset of priority habitat as Areas of Critical Environmental Concern that receive 

a higher level of protection than that recommended by the NTT.

39. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria:

ACECs can be designated for habitat, but also for historic, cultural and scenic values. BLM should prioritize ACEC 

designation for lands that contain priority habitat and other vulnerable resources, such as wilderness characteristics, other

endangered species, or cultural resources. This approach will allow BLM to ensure that ACECs maximize protection of 

multiple sensitive resource values benefiting a range of user groups.

CO BLM emc0070RM

40. In the Draft RMP for the Kremmling (CO) Field Office, Alternative C would commit the BLM to: .proactively identify, 

protect, and improve wildlife habitat, including treatments for the benefit of sagebrush-dependent species, especially in 

areas identified as historical habitats. Alternative C would include establishing reference areas that would be used as

control groups for evaluating management activities in sagebrush habitat. In sage-grouse core areas within the Planning 

Area, BLM-managed public lands would be closed to oil and gas leasing.

Draft RMP32 at 2-24. Alternative B (preferred alternative) would prohibit surface occupancy or use in core habitat. Draft 

RMP at 2-55 – 2-56. Alternative C would prohibit oil and gas leasing in core sage-grouse habitat. Draft RMP at 2-55. 

Alternative C would also limit surface disturbance in core habitat to one percent at any one time, while Alternative B 

would limit surface disturbance to three percent at any one time. Draft RMP at 2-74.

CO Both emc0089RM

41. The modifications to the RMP should not include restrictions that exceed those established by Colorado Parks and 

Wildlife (CPW) for surface use or mineral development with respect to the Greater Sage Grouse. We have implemented 

a process for the utilization of the stipulations and Best Management Practices developed by CPW throughout Colorado.

CO Both rmc0050RM

42. It is critical for BLM to consider implementing the following technical team recommendations as minimum standards

- Fully protect priority habitat from large scale disturbances (e.g. transmission lines, oil and gas wells, graded roads etc.) 

that will harm sage-grouse populations.

- If priority habitat can't be fully protected from large-scale disturbances due to existing rights, minimize impacts by limiting 

disturbances to one per section with no more than 3% surface disturbance.

- Ensure that small scale disturbances don't disturb more than 3% of each priority area.

CO Both flm0000RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-801

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

43. It is critical for BLM to consider implementing the following technical team recommendations as minimum standards:

• Fully protect priority habitat from large scale disturbances (e.g. transmission lines, oil and gas wells, graded roads etc.) 

that will harm sage-grouse populations.

• If priority habitat can’t be fully protected from large-scale disturbances due to existing rights, minimize impacts by limiting 

disturbances to one per section with no more than 3% surface disturbance. Ensure that small scale disturbances don’t 

disturb more than 3% of each priority area.

CO BLM fll0000RM

44. i. Lander, WY RMP

The Lander draft RMP proposes extending seasonal wildlife protections to identified operations and maintenance (O&M) 

activities in non-Designated Development Areas, if those activities are identified as detrimental to wildlife (Alternative D). 

As noted in the DEIS, this action "would not preclude development or limit the number of wells and would result in no 

more adverse impacts than management under Alternative A, which does not have timing limitations on O&M" (DEIS at 

649). Extending seasonal protections beyond the development/construction period will benefit wildlife during the sensitive 

winter and nesting periods. Protections would be instituted for activities like fracking, power line reconstruction, range 

improvements, and road maintenance. As recognized by the DEIS, these activities can "stress and disturb wildlife during the 

sensitive winter and nesting periods due to the time it takes to complete the work, the level of noise generated, and the 

presence of people and equipment. It is expected that project O&M activities would result in both short-term adverse 

impacts related to animal displacement and long-term adverse impacts if the level of activity results in area avoidance or 

loss of nests or young" (DEIS at 818). We strongly encourage the BLM to adopt this provision.

East Both emc0089RM

45. i. Lander, WY RMP

Alternative B also prohibits new permanent structures taller than 12 feet within 1 mile of occupied nesting habitat. We 

strongly support this as a means to prevent area avoidance by sage-grouse.

East Both emc0089RM

46. i. Lander, WY RMP

Reclamation should be mandatory and managers must recognize that methods for achieving success vary by region and are 

site-specific. Reclamation efforts should be monitored and results maintained in a single database to improve our 

understanding about effectiveness of such efforts. In addition, a process should be established to identify and address failed 

reclamation projects. Successful reclamation of surface disturbance is necessary to establish connectivity within previously 

fragmented habitats and to achieve and maintain ecosystem function (DEIS at 864).

East Both emc0089RM

47. The following recommendations must be analyzed as a starting point for effective conservation:

Fully protect priority habitat from large scale disturbances (e.g., transmission lines, oil and gas wells, graded roads, etc.) that 

will affect population distribution and abundance at any level.

East Both emc0089RM

48. iv. The BLM and FS should analyze an alternative that provides more protection than that afforded by implementation of 

the National Technical Team’s Recommendations.

The BLM and FS should consider an alternative that:

- Includes conservation measures recommended by the NTT Report.

- Combines this with designations of a subset of priority habitat as Areas of Critical Environmental Concern that receive 

a higher level of protection than that recommended

East Both emc0089RM
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Table C-5.E

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by the NTT.

- Incorporates improvements to the NTT’s recommendations, including the following:

o Avoid sagebrush reduction/ treatments to increase livestock or big game forage in priority habitat and include plans to 

restore high-quality habitat in areas with invasive species.

o Implement range management practices outlined by the NTT, with improvements, including avoiding new range and 

water developments that negatively impact sage-grouse and applying the 3% disturbance cap to certain range 

developments.

o Design fuel treatments to protect existing sagebrush ecosystems (including avoiding such treatments where they will 

harm sagebrush ecosystems) and prioritize fire suppression to conserve the highest quality habitat.

o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t negatively impact sage-grouse 

populations in priority habitat,10 thus negating the value of designated priority habitats.

o Include small or isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority 

habitat, and protect and enhance such populations with science-based prescriptions.

49. iii. Strong components of Wyoming’s approach

Future surface disturbance is minimized by encouraging co-locating disturbances within already disturbed areas or those 

that are naturally unsuitable for grouse.

East Both emc0089RM

50. 11. The Agencies Should Carefully Consider Use Of Mitigation And Ensure That Mitigation Generates Net Conservation 

Benefits

BLM’s habitat mitigation policy, codified at 43 C.F.R. § 1508.20, lists habitat mitigation actions in descending order of 

preference: avoidance, minimization, rectification, reduction, and compensation. As BLM considers the siting and impacts

of proposed new energy projects, it must keep in mind this mitigation hierarchy and consider "avoidance" the foremost 

objective. The BLM and FS should require off-site mitigation for impacts which cannot be mitigated onsite, or where 

landscape approaches to mitigation offer opportunities to address conservation needs on a larger scale while generating 

net conservation benefits for sage-grouse. Off-site mitigation should follow these guidelines: 1) be a "net conservation 

benefit" requirement for resources and values; 2) a requirement for project developers to fund mitigation efforts based on

the amount and value of the land impacted from development; 3) a centralized body should be established to oversee the 

funds and maximize the effectiveness of their use; and 4) off-site mitigation should be required to take place in the same 

ecoregion as the project site. The increase in compensation and offsite mitigation will require careful management and new 

approaches. The importance of mitigation was reinforced on January 14, 2011, with the release of the new CEQ Guidance 

on "Appropriate Use of Mitigation and Monitoring and Clarifying the Appropriate Use of Mitigated Findings of No 

Significant Impact."

East Both emc0089RM

51. NEPA requires that BLM discuss mitigation measures in an EIS. (40 C.F.R. §§ 1502.14, 1502.16.) In order to show that 

mitigation will reduce environmental impacts to an insignificant level, BLM must discuss the mitigation measures "in 

sufficient detail to ensure that environmental consequences have been fairly evaluated." 25 Simply identifying mitigation

measures, without analyzing the effectiveness of the measures, violates NEPA. Agencies must "analyze the mitigation 

measures in detail [and] explain how effective the measures would be ..”A mere listing of mitigation measures is insufficient 

East Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-803

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

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to qualify as the reasoned discussion required by NEPA."26 NEPA also directs that the "possibility of mitigation" should not 

be relied upon as a means to avoid further environmental analysis.27 Further, general statements that BLM will conduct 

monitoring are also not an appropriate form of mitigation. Simply monitoring for expected damage does not actually 

reduce or alleviate any impacts.

52. Key considerations for off-site mitigation should include:

- Identification of uses, resources and values associated with the project site. Establishing the connection between off-site 

mitigation and the resources of the public lands will require detailed understanding and knowledge of the values and uses 

present on the project site before development occurs, such as wildlife habitat, various recreational uses (ranging from 

hunting to bird watching to all terrain vehicle use) and scenic values. BLM should require that necessary inventory of the 

project site be completed prior to developing off-site mitigation measures.

- Requirements for project developers to fund mitigation efforts based on the amount and value of the land impacted from 

development. Project developers should be required to make deposits to a mitigation fund based on the amount of land 

used for the project and the fair market value of that land, the costs of any restoration or enhancement actions necessary 

to produce a net conservation benefit, and the stewardship costs necessary to maintain conservation benefits over time. -

If funds are received as a part of mitigation, a centralized body should be established to oversee the funds and maximize the 

effectiveness of their use. BLM should establish a centralized body comprised of BLM staff, and other federal and state 

agencies with expertise and interest to oversee the distribution of funds and maximize the effectiveness of their use. This 

body should be required to take into consideration recommendation from the public in the distribution of funds.

East Both emc0089RM

53. Mitigation protections will require additional and ongoing monitoring to determine effectiveness. There is an important 

distinction between the monitoring required to assess effectiveness of mitigation, and research or monitoring completed 

in lieu of on-the-ground mitigation. We do not support research funding as a substitute for compensatory habitat 

mitigation applied on the ground.

East Both emc0089RM

54. BLM and FS should put in place a "net conservation benefit" requirement for the mitigation of impacts to resources and 

values. BLM should ensure that any loss of resources or values on a development site is compensated with the addition and 

protection of equivalent or better resources and values offsite with appropriate assurances that conservation values will be

maintained for at least as long as project impacts persist. BLM and FS should also make a determination about the value of 

the habitat to be impacted and adopt direction for mitigation requirements for the specific habitat types impacted. For 

example, for high quality habitat which is relatively scarce or becoming scarce on a national basis or in the ecoregion 

section 28, BLM policy should ensure a net gain of in-kind habitat value. Additions of lands and resources should exceed the 

value of any resources lost. Additions could be gained through restoration and research efforts to improve the quality and 

quantity of equivalent resources and values off-site. Mitigation for impacts to water resources could be addressed by 

purchase and retirement of water rights to offset groundwater pumping by the project.

East Both emc0089RM

55. Recommendations: Greater sage-grouse efforts and mitigation strategies should be designed and continuously monitored 

to ensure that they are effective and generate net benefits. Mitigation requirements should emphasize avoidance and 

minimization of impacts. Actions to offset unavoidable impacts should generate net conservation benefits for sage grouse

East Both emc0089RM
C. Comments by Resource Planning Issue

C-804 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

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populations and habitats consistent with the conservation purposes and principles of the National Sage-grouse Planning 

Strategy.

56. The NTT report recognizes that BLM is committing "to a new paradigm in managing the sagebrush landscape." NTT at 6. 

The report further recognizes that: [The] new paradigm will require collaborative conservation efforts among private, 

state, tribal, and other federal partners to conserve sage-grouse. Land uses, habitat treatments, and anthropogenic 

disturbances will need to be managed below thresholds necessary to conserve not only local sage-grouse populations, but 

sagebrush communities and landscapes as well.

The NTT also observed that "development on private lands, which is not subject to mitigation, will focus greater needs for 

conservation of sage-grouse and sagebrush on public lands." Report at 12. The point is well taken that the remaining habitat 

on federal lands must be prioritized for protection because we have less control over management decisions on private 

holdings.

East Both emc0089RM

57. We believe that federal agencies should consider three viable options for furthering habitat conservation efforts on private 

lands. First, the agencies’ approach can be integrated with private land conservation benefits provided by the National 

Resource Conservation Service’s Sage

Grouse Initiative (SGI):

Second, biodiversity offsets for greater sage-grouse are discussed in Doherty et al. (2010b): "The simplest and most cost 

effective first step in conservation is to halt the large-scale actions that further reduce or eliminate the largest populations 

in the best remaining landscapes." BLM and FS should consider using the approach outlined in this paper to develop 

methods to forecast population losses that will result from unavoidable development of valid existing rights, and to ensure 

that offsite mitigation permanently reduces similar risks to other sage-grouse populations of equal size. The analyses and 

recommendations in this paper should be carefully considered when designing conservation strategies and taking account 

of cross-jurisdictional issues.

East Both emc0089RM

58. We believe that federal agencies should consider three viable options for furthering habitat conservation efforts on private 

lands. First, the agencies’ approach can be integrated with private land conservation benefits provided by the National 

Resource Conservation Service’s Sage Grouse Initiative (SGI):

Third, another potential resource to consider when developing a collaborative approach to conservation across 

boundaries is the Framework for Mitigation of Impacts from Infrastructure on Sage-grouse and Their Habitats, developed 

by the Sage-Grouse Mitigation Subcommittee of the Idaho Sage-Grouse State Advisory Committee. The Idaho Mitigation 

Framework (December 6, 2010) is labeled a "Discussion Paper Final Draft" but has not yet been adopted. This draft

framework, the result of a stakeholder process, may offer some guidance and helpful concepts for habitat conservation on 

non-federal lands, thereby complementing conservation strategies on federal lands. According to the summary: [T]the 

Mitigation Framework would serve as a science-based "mitigation module" that project developers and government 

regulators could use to achieve compensatory mitigation objectives called for in project plans and permits. While 

compensatory mitigation may help offset certain impacts arising from infrastructure projects, mitigation

should not be considered a substitute for first avoiding and then minimizing impacts. In addition, it is important to 

recognize that federal and state regulatory or land-management agencies, and county or local governments may also 

East Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-805

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

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require additional stipulations, conditions of approval or other requirements as well as on-site mitigation, in accordance

with applicable law, regulation or policy. Discussion Paper Final Draft at 1.

59. i. Lander, WY RMP

Alternative B addresses the important protection of natural functions in riparian-wetland areas, providing important 

benefits to sage-grouse. In the arid western states, the value of riparian wetland communities is inversely proportional to 

their physical extent - supporting the greatest diversity of plant and animal life of all habitat types (DEIS 343, DEIS 351). 

Actions that iimprove riparian-wetlands would improve habitats for special status wildlife species, especially increasing the 

quantity and quality of riparian-wetland vegetation and insects. Riparian-wetland areas are a component of brood-rearing 

habitat for greater sage-grouse because they provide needed forbs and insects necessary for chick survival. Alternative B 

prohibits surface disturbing activities within 1,320 feet (0.25 mile) of surface water, riparian-wetland areas, playas, and 100-

year floodplains where mapped (except for areas of high and moderate oil and gas potential), and provides important 

protections for this habitat type.

East Both emc0089RM

60. In the Draft RMP for the Kremmling (CO) Field Office31, Alternative C would commit the BLM to: proactively identify, 

protect, and improve wildlife habitat, including treatments for the benefit of sagebrush-dependent species, especially in 

areas identified as historical habitats. Alternative C would include establishing reference areas that would be used as

control groups for evaluating management activities in sagebrush habitat. In sage-grouse

core areas within the Planning Area, BLM-managed public lands would be closed to oil and gas leasing.

Draft RMP 32 at 2-24. Alternative B (preferred alternative) would prohibit surface occupancy or use in core habitat. Draft 

RMP at 2-55 – 2-56. Alternative C would prohibit oil and gas leasing in core sage-grouse habitat. Draft RMP at 2-55. 

Alternative C would also limit surface disturbance in core habitat to one percent at any one time, while Alternative B 

would limit surface disturbance to three percent at any one time. Draft RMP at 2-74.

East Both emc0089RM

61. The Dillion Local Working Group identified 5 key issues in the area: "tie" for 3rd, 3. ii. Conversion and fragmentation of 

habitat caused by residential subdivision and development

IDMT Both rmc0028GB

62. We believe that federal agencies should consider three viable options for furthering habitat conservation efforts on private 

lands. First, the agencies’ approach can be integrated with private land conservation benefits provided by the National 

Resource Conservation Service’s Sage Grouse Initiative (SGI): Third, another potential resource to consider when 

developing a collaborative approach to conservation across boundaries is the Framework for Mitigation of Impacts from 

Infrastructure on Sage-grouse and Their Habitats, developed by the Sage-Grouse Mitigation Subcommittee of the Idaho 

Sage-Grouse State Advisory Committee. The Idaho Mitigation Framework (December 6, 2010) is labeled a "Discussion 

Paper Final Draft" but has not yet been adopted. This draft framework, the result of a stakeholder process, may offer some 

guidance and helpful concepts for habitat conservation on non-federal lands, thereby complementing conservation 

strategies on federal lands. According to the summary: [T]the Mitigation Framework would serve as a science-based 

"mitigation module" that project developers and government regulators could use to achieve compensatory mitigation 

objectives called for in project plans and permits. While compensatory mitigation may help offset certain impacts arising 

from infrastructure projects, mitigation should not be considered a substitute for first avoiding and then minimizing 

impacts. In addition, it is important to recognize that federal and state regulatory or land-management agencies, and county 

IDMT Both emc0089RM
C. Comments by Resource Planning Issue

C-806 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.E

Comments Related to General Construction Impacts

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or local governments may also require additional stipulations, conditions of approval or other requirements as well as 

on-site mitigation, in accordance with applicable law, regulation or policy. Discussion Paper Final Draft at 1.

63. The rancher's love of the land is the only thing protecting private land in northeast Montana from the development that has 

harmed sage grouse elsewhere.

MT-RM Both emc0013RM

64. The Little Missouri Grazing Association (LMGA) has taken a proactive approach towards the sage-grouse. We have two 

years of habitat monitoring data collected. We also have data showing historical grazing use showing that the stocking rates 

have not changed in many years. The land use practices have not changed. We have no oil & gas impact and no industrial 

encroachment.

ND Both emc0039RM

65. Instead, "mitigation" for development impacts on Sage Grouse and priority habitats is often proposed by project 

proponents and seemingly automatically accepted by the agencies. Or, mitigation funds can be used for other purposes, 

including making up for agencies' budget shortfalls. It is difficult if not impossible for the public to track the use of 

"mitigation" funds - how, where and when funds were expended and what benefits or costs resulted to either Sage Grouse 

or its habitat. Annual reporting on the implementation of agencies' Sage Grouse conservation measures, including the use 

of required mitigation funds, must be a land use plan requirement. For example, the public is currently unable to access the 

effectiveness of required and voluntary mitigation, especially about $15 million in financial mitigation paid by the proponent 

of the Ruby gas pipeline project in northern Nevada to the BLM, the USFWS, NDOW, and other private organizations. No 

mitigation funds should be required or accepted by agencies without a mitigation plan with quantified goals and objectives 

and full accountability for the use of mitigation funds to the public through annual reporting of funds expended and the 

results of effectiveness monitoring. We have other conservation measures to recommend for inclusion in the EIS.

NVCA Both emc0283GB

66. The ODFW files should provide specific information and the basis of an initial assessment on Public Improvements related 

to wildlife programs in eastern Oregon. In addition, to determine potential economic impacts; in conjunction with BLM/FS 

and DOGAMI staff conduct an inventory of Federal and State lands containing active and inactive borrow pits, and their 

remaining accessible and potential reserves and availability for use on Public Improvement projects. The EIS then should 

determine the replacement costs for materials withdrawn from the inventory due to the ODFW management 

recommendations.

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67. Address Impacts of Development: Industrial development, whether for fossil fuels or renewable sources, has habitat 

impacts. BLM should recognize the research that clearly demonstrates the impacts from roads, noise, infrastructure, and 

increased predator access, and protect priority sage-grouse habitat accordingly.

OR Both emc0385GB

68. The Interim Memorandum (IM) and adjoining technical report do not provide mineral developers with any ability to 

mitigate for impacts on sage-grouse habitat. One principal effectively learned over the past 25 years of Endangered Species 

Act (ESA) management is that mitigation can be a very effective tool to conserve a species and allow responsible 

development simultaneously. In many instances, industry mitigation has been the catalyst for recovery of species in the 

West. The assumption within the IM is that forcing industry off Federal lands will recover the species. The BLM should 

consider the establishment of a mitigation program that project proponents may voluntarily use to facilitate the allocation 

and management of mitigation dollars to fund sage-grouse habitat improvement projects. Such programs would support 

Uintah County's plan of allowing development in marginal sage-grouse habitat and utilizing mitigation dollars to enhance 

UT Both emc0376GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-807

Scoping Summary Report

Table C-5.E

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habitat in sage-grouse areas designated by the County plan.

69. i. Lander, WY RMP

The Lander draft RMP proposes extending seasonal wildlife protections to identified operations and maintenance (O&M) 

activities in non-Designated Development Areas, if those activities are identified as detrimental to wildlife (Alternative D). 

As noted in the DEIS, this action "would not preclude development or limit the number of wells and would result in no 

more adverse impacts than management under Alternative A, which does not have timing limitations on O&M" (DEIS at 

649). Extending seasonal protections beyond the development/construction period will benefit wildlife during the sensitive 

winter and nesting periods. Protections would be instituted for activities like fracking, power line reconstruction, range 

improvements, and road maintenance. As recognized by the DEIS, these activities can "stress and disturb wildlife during the 

sensitive winter and nesting periods due to the time it takes to complete the work, the level of noise generated, and the 

presence of people and equipment. It is expected that project O&M activities would result in both short-term adverse 

impacts related to animal displacement and long-term adverse impacts if the level of activity results in area avoidance or 

loss of nests or young" (DEIS at 818). We strongly encourage the BLM to adopt this provision.

WY Both emc0089RM

70. i. Lander, WY RMP

Alternative B also prohibits new permanent structures taller than 12 feet within 1 mile of occupied nesting habitat. We 

strongly support this as a means to prevent area avoidance by sage-grouse.

WY Both emc0089RM

71. iii. Strong components of Wyoming’s approach Future surface disturbance is minimized by encouraging co-locating 

disturbances within already disturbed areas or those that are naturally unsuitable for grouse.

WY Both emc0089RM

72. i. Lander, WY RMP

Alternative B addresses the important protection of natural functions in riparian-wetland areas, providing important 

benefits to sage-grouse. In the arid western states, the value of riparian wetland communities is inversely proportional to 

their physical extent - supporting the greatest diversity of plant and animal life of all habitat types (DEIS 343, DEIS 351). 

Actions that improve riparian-wetlands would improve habitats for special status wildlife species, especially increasing the 

quantity and quality of riparian-wetland vegetation and insects. Riparian-wetland areas are a component of brood-rearing 

habitat for greater sage-grouse because they provide needed forbs and insects necessary for chick survival. Alternative B 

prohibits surface disturbing activities within 1,320 feet (0.25 mile) of surface water, riparian-wetland areas, playas, and 100-

year floodplains where mapped (except for areas of high and moderate oil and gas potential), and provides important 

protections for this habitat type.

WY Both emc0089RM

73. i. Lander, WY RMP

Reclamation should be mandatory and managers must recognize that methods for achieving success vary by region and are 

site-specific. Reclamation efforts should be monitored and results maintained in a single database to improve our 

understanding about effectiveness of such efforts. In addition, a process should be established to identify and address failed 

reclamation projects. Successful reclamation of surface disturbance is necessary to establish connectivity within previously 

fragmented habitats and to achieve and maintain ecosystem function (DEIS at 864).

WY Both emc0089RM
C. Comments by Resource Planning Issue

C-808 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

Comment 

No.

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Agency CmtLtrCode

1. RIGHTS of WAY

ISSUE: The proposed Conservation Measures fail to address ROW maintenance roads becoming roads for the general 

public.

Most low and mid-elevation powerline / gas line / communications line ROW’s become OHV trails and eventually roads for 

the general public. See discussion on individual OHV use under Travel and Transportation. The only mitigation available is 

signage stating that a maintenance road is closed to public travel; the signage is universally ignored. Because the Measures 

identified ROW’s as potential discrete disturbances, the use of the ROW road by the individual public OHV user must also 

be a discrete disturbance.

All Both emc0083GB

2. IPC’s service area overlaps with greater sage-grouse habitat in Idaho and Oregon and actions the Bureau of Land 

Management (BLM) and U.S. Forest Service (FS) implement to protect greater sage-grouse will affect our ongoing operation 

and maintenance activities and construction of new distribution and transmission lines.

All Both emc0090GB

3. The NTT report recommends that in areas where the three percent disturbance threshold has already been exceeded, that 

no other anthropogenic disturbance be permitted until habitat has been restored to maintain the area under the threshold.

The NTT report then recommends collocation of disturbances and consideration of a new ROW authorization only if the 

disturbance is confined to the area previously disturbed by the existing ROW. Collocation within an existing ROW is not 

always feasible depending on the proposed and existing facility. Idaho Power and other utilities operate under regulations 

promulgated by the Federal Energy Regulatory Commission (FERC), Western Energy Coordinating Council (WECC), and 

North American Electric Reliability Corporation (NERC). In order to avoid large-scale blackouts, utilities are required to 

maintain separation between lines (the distance depends on the electrical pathway, capacity rating, and voltage of the line) 

and this would preclude collocating some facilities within the same ROW. Rather than a blanket requirement that facilities 

must be located within an existing ROW, the BLM should consider an alternative that allows for separation distances 

between facilities; this could be similar to the requirements in the Wyoming Governors’ Executive Order 2011-51

All Both emc0090GB

4. It is also not clear how the BLM will address corridors established as part of the West-wide energy corridor (WWEC) 

programmatic decision. These are designated energy corridors, but they may not yet be encumbered with ROWs. Based on 

the NTT’s recommendations, only corridors already encumbered with a ROW should be considered for additional ROWs.

The BLM must address how the WWEC in priority and general habitat will be addressed in land use planning.

All Both emc0090GB

5. The NTT recommends the planning process identify opportunities to remove, bury, or modify existing power lines within 

priority habitat areas. As part of its analysis, the BLM must consider the cost to utilities and ratepayers to convert overhead 

lines to underground lines and how underground lines can affect a utility’s ability to quickly identify and repair an outage. 

Ground disturbance may also be significantly higher for underground lines than overhead lines because of trenching activities 

and installation of pulling vaults. While there are some advantages to underground lines, these are not the panacea that some 

perceive them to be. For a detailed discussion on high voltage underground transmission lines, please refer to section 2.6.4

of the July 2011 Gateway West Transmission Line Draft Environmental Impact Statement prepared by the BLM. While 

underground distribution lines are more feasible than transmission lines, they also cost more than overhead lines and result 

in increased ground disturbance during construction and maintenance activities.

All Both emc0090GB

6. Modifications to power lines and structures commonly suggested by the BLM include designing towers or the use of All Both emc0090GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-809

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Table C-5.F

Comments Related to Transmission

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anti-perching devices to prevent raptor perching and installation of markers to reduce collisions. Designing towers to 

prevent raptors from using them as perches is not feasible for larger transmission structures (e.g., lattice steel towers) due 

to the increased cost and size of the structures, and has limited value for smaller distribution structures. Moreover, the use 

of anti-perching devices has consistently been shown to be ineffective.2 Furthermore, the installation of daytime visual 

markers on guyed towers should be assessed on a case-by-case basis where collisions have been identified as an issue and 

should not be anautomatic requirement for all new lines. In both cases, the installation and long-term maintenance of 

anti-perching and line-marking devices can increase project costs substantially while not resulting in significant protections 

for birds.

7. Rights of Way

The NTT Report suggests possibly removing, burying, and modifying existing power lines that are within PPH areas. Burying 

transmission lines is an extremely costly venture, and may make many projects uneconomical. We feel that this mitigation 

should only be used in extreme circumstances in which studies indicate that there is very high value in burying such 

transmission lines in very localized cases, and in exchange for this mitigation, proponents receive high value in other 

proposed actions within the PMU. For example, a proponent could offer to bury an existing power line segment through 

high-value PPH as mitigation to a new proposed impact. The mitigation should more than offset the impact of the proposed 

new development.

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8. In regard to new overhead, wood pole, transmission and distribution lines typically utilized by rural utilities to transmit 

power over the significant distances that must be covered. the RMP should recognize the limited impact of these projects on 

sage grouse habitat. Specifically, if such facilities can be routed near existing roads, new permanent ground disturbance is 

generally

not required. In many locations overland ground construction techniques will not require grading and areas temporarily 

disturbed by vehicle tracks during construction return to their preconstruction condition within a very few years.

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9. Secretarial Order 3285 Amendment I Renewable Energy Development by the Department of Interior (February 22, 20 I 0) 

and the Energy Policy Act of 2005 encourages the development of renewable and alternative energy resources, as part of an

overall strategy to develop a diverse portfolio of domestic energy supplies. Furthermore, S03285Al states that "encouraging 

the production, development, and delivery of renewable energy is one of the Department's highest priorities." NV Energy 

requests that potential impacts to the development of renewable energy projects and associated transmission be analyzed in 

the proposed EIS.

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10. NV Energy is concerned that the renewal of existing right of way grants or special use permits for those transmission and 

distribution facilities within preliminary priority sage grouse habitat may require significant permitting and mitigation 

requirements including additional NEPA analysis; undergrounding of existing facilities; relocation of transmission and/or 

distribution corridors; etc. It is the opinion of NV Energy that these potential mitigation requirements could create greater 

disturbances and have a more negative effect than what exists presently. Therefore, NV Energy requests that proposed 

mitigation for existing transmission and distribution infrastructure be analyzed in the EIS. It should be noted mitigation 

measures including, but not limited to, the relocation of existing electrical infrastructure would directly impact Nevada rate 

payers.

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C. Comments by Resource Planning Issue

C-810 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-5.F

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11. Effects of Power Lines on Greater Sage-grouse. Contrary to the statements of the NTT Reports, the effects of power lines 

on greater sage-grouse have not been established, are poorly understood, and require more research. The NTT Report 

casually uses Steenhof et al. 1993 (raptor nest research) and Lammers and Collopy 2007 (perch deterrents research) with 

very little insight on effects of power lines on greater sage-grouse. Lammers and Collopy (2007) discuss that perch 

deterrents did not have an effect on the observed number of greater sage-grouse predators and concluded that sagebrush 

conservation may better serve greater sage-grouse populations.

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12. The presence of the power line itself does not seem to be directly or indirectly increasing mortality or reducing overall 

breeding success. The BLM's LUP process should consider all available science regarding effects of power lines on greater 

sage-grouse, and identify and disclose areas where scientific information and data are lacking.)

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13. The County request more detailed information in terms of how designation of priority and general habitat will impact 

current and future rights-of-way. Perhaps this is a topic that could be further discussed at a local workshop

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14. The wildlife buffers and timing restrictions in the current RMP's and Forest Plans make it very difficult to maintain an 

acceptable level of electrical service. Additional restrictions will add to this burden and may make it impossible to serve 

established communities when they are located in or near areas containing several habitats of species of concern. We would 

like to provide a specific example? A large portion of our existing system is constructed on sage flats surrounding the Sevier 

River Valley. The ROWs are on a mixture of public, state, and private lands that are classified as Deer, Elk and Prong horn

crucial winter habitat, which is also classified as active, suitable (currently inactive) or potential reintroduction Utah Prairie 

Dog habitat, is Greater Sage Grouse nesting, brood-rearing and winter habitat and a winter concentration area for wintering 

Bald Eagles. It is possible for us to plan our work around restrictions for a few specific species but in this case with this many 

buffers and restrictions we are left with no significant time period when existing infrastructure can be maintained or required 

new construction completed. We request that you address this issue in the planning strategy and provide a way in which we 

can continue to provide electrical service in areas that contain other species of concern with the associated buffers and 

restrictions in addition to those for the Sage Grouse.

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15. 2. The importance of addressing new threats such as transmission lines and wind development. All Both emc0212GB

16. Sage grouse conservation measures, if too onerous, may also threaten renewable energy generation such as solar and wind 

power and the new transmission lines (such as the Energy Gateway South and Trans West Express projects) needed to 

convey such power to market.

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17. Definitive research on whether and to what extent powerlines are significant factor affecting Sage Grouse. There is much 

anecdotal evidence that powerlines provide perch sites for Common Ravens and other raptors and that Sage Grouse rarely

are successful in nesting attempts within a mile or two of a powerline.

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18. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: ROW exclusion (such as electric transmission and fluid mineral pipelines

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19. BLM and Forest Service should evaluate planned transmission in this process and should also ensure that broader ongoing 

transmission planning incorporate conservation measures for sage-grouse, including the Western Electricity Coordinating 

Council.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-811

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

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20. As sources of generation in the West Interconnection change from fossil to renewable resources, there is likely to be a need 

for additional long distance lines. Early consideration of the geographic location and plans for expansion of remote renewable 

resources can aid in reducing conflicts between transmission infrastructure and prime habitat for sensitive species like the

greater sage-grouse. This EIS process should provide key information and recommendations to ongoing transmission 

planning and also set out conservation measures based on ongoing transmission planning.

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21. Iterative transmission planning efforts are underway at the state and regional level. The primary clearing house for 

transmission expansion planning across areas identified as sage grouse habitat is the Western Electricity Coordinating 

Council (WECC). WECC included environmental data in its Transmission Expansion Planning process and WECC's

Scenario Planning Working Group Environmental Data Task Force (EDTF) was tasked with building a decision support tool 

to allow for a comparison of future transmission alternatives through the lens of environmental and cultural data sets. These 

data sets provide transmission planners with a method by which to show the relative 'risk' to a project developer of trying 

to develop a particular route. Lands were screened and classified under four tiers of suitability resulting in a risk 

determinations dependent upon resources, such as lands with dense sage-grouse populations.

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22. Going forward, EDTF will continue to conduct regular outreach to stakeholders across the West to update, collect and 

integrate additional environmental and cultural data into this decision support tool for use by regional transmission planners. 

Within this framework, information regarding greater sage-grouse habitat protection can and should flow two ways. BLM's 

sagegrouse conservation planning efforts provide an opportunity to incorporate planning efforts for renewable energy 

generation and transmission expansion based on long-term and west-wide modeling of existing and future renewable energy 

goals and reliability constraints. Conversely, the BLM should ensure that transmission planning efforts underway at WECC 

have considered the BLM's efforts to update resource management plans to reflect a future sage grouse conservation policy 

so that WECC may incorporate this data into future scenario planning through EDTF tools.

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23. Concurrently, the President's Council on Environmental Quality Interagency Rapid Response Transmission Team (RRTT), 

formed in 2011, has identified five priority transmission lines in the West, and two in the East. These lines are planned for

reliability and to promote the development of remotely constrained renewable resources, largely wind. Of the five projects

included in the West-SunZia, Cascade Crossing, Boardman to Hemingway, Gateway West, and TransWest Express - four 

cross within areas identified through BLM's Greater Sage-Grouse Range-Wide Breeding Density Threshold map as having a 

25% or higher breeding density. BLM should ensure that the RRTT is made aware of sage grouse conservation efforts and 

encourage the CEQ to work with BLM and the U.S. Fish and Wildlife Service to incorporate and further develop greater 

sage-grouse conservation plans within the permitting framework for these priority projects.

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24. The BLM and Forest Service should ensure that transmission planning efforts underway at WECC have considered their 

efforts to update land use management plans to reflects a future sage grouse conservation policy so that WECC may 

incorporate this data into future scenario planning.

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25. The agencies should also ensure that transmission lines under consideration by RRTT are subject to conservation measures 

set out in this EIS process.

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26. The RMP amendments also should address significant new threats to sage‐grouse: electrical transmission lines and wind 

power developments.

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C. Comments by Resource Planning Issue

C-812 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

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27. Some of the “best practices” being suggested by the IM and NTT Report are unrealistic. For example, the documents suggest 

burying power lines as a mitigation tool. This is problematic from both economic and engineering perspectives. A number of 

factors influence the feasibility of burying power lines, including voltage, land use, terrain, soils and geology of the area, 

density of existing buried facilities (water gas, etc), highway crossings, surface water crossings, floodplains, and presence of 

other biological and cultural resources of concern. Burying high voltage transmission lines poses a significant operational 

issue for utilities and would substantially increase the cost of constructing high voltage transmission lines. (The cost of 

burying a high voltage transmission line can increase overall project cost anywhere from 4-10 times the comparable costs of 

an overhead line.) Other factors regarding the feasibility of building an underground transmission line include longevity, 

maintenance and operational issues and increased habitat fragmentation effects. Underground transmission lines have half 

the life expectancy of overhead transmission lines. There are also reliability concerns: when an outage occurs on an 

underground line, it is difficult to pinpoint and reach the source of the outage. Repairs take longer and require additional 

ground disturbance, potentially increasing disturbances to sensitive habitats.

Above-ground facilities have been found to be generally compatible with the type of short brush that sage grouse uses for 

habitat. As a result, above-ground facility ROWs can actually help preserve such habitat.

Finally, it is important to note: burying power lines actually carries a significant set of environmental degradation risks. We 

would point you to comments submitted from the Edison Electric Institute which speak to this issue. In particular, please 

consider the referenced study from the University of California, which provides a life cycle assessment of the potential 

environmental impacts of overhead vs. buried power lines.

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28. The IM and NTT Report also suggest relocation of transmission lines outside priority habitats for sage-grouse. Relocating 

multi-million dollar linear facilities is cost-prohibitive. Further, doing so would require: local, state, and federal permits; the 

acquisition of new easements on private lands; and new NEPA compliance for facilities that have been in operation for 

decades. It is not clear that doing so would necessarily benefit grouse habitat. In fact, modification to existing lines that have 

been in use for decades would likely result in increased environmental impacts due to disturbance of habitats that have 

otherwise been reclaimed or restored.

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29. It would greatly benefit both land management and regulatory agencies and the electric utility industry if additional research 

could help determine effective buffer and seasonal restrictions for linear features that can protect sage-grouse and their 

breeding habitats, while facilitating reasonable and effective energy infrastructure planning.

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30. In addition, within PCW's study area, which has a number of distribution lines and kV and 230 kV power lines, over the 

course of our study we have not been able to detect any avoidance of power lines by greater sage-grouse. In fact, our data 

show frequent crossings of the power lines by greater sage-grouse.

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31. Second, NGP urges the agencies to implement the clear and long-repeated will of the people of the United States to support 

renewable energy, and the clear federal policies on renewable energy- and accommodate renewable energy installations and 

their related transmission lines on federal lands.

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32. More stringent mitigation should only be taken where there is a demonstrated lack of effectiveness.

Every study of US power supply concludes that more transmission is badly needed. Burying power lines is costly in terms of 

money, increased surface disturbance, increased maintenance, and increased energy loss which requires more generation. 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-813

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

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Power lines must be built. The mitigations recommended in this proposed action must address this reality.

33. Comments on "A Report on National Greater Sage-grouse Conservation Measures" (produced by the Sage-grouse National 

Technical Team, December 21, 2011).

The following comments pertain to specific parts of the above-referenced document.

Page 13, "Rights of Way" section, 3rd bullet. "Power lines effectively influence (direct physical area plus estimated area of 

effect due to predator movements) at least 39% of the sage-grouse range."

While this paper is cited in the Conservation Strategy, another paper from the same book that found no effect of power lines 

on sage-grouse lek counts was not cited (see Johnson et al., pages 407-450 in Greater Sage-grouse: Ecology and 

Conservation of a Landscape Species and Its Habitats). The Conservation Strategy appears to select citations that support 

perceptions of negative impacts associated with power lines, yet does not include papers that do not support this view or 

that acknowledge the lack of data on the subject (e.g., UWIN literature review).

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34. Comments on "A Report on National Greater Sage-grouse Conservation Measures" (produced by the Sage-grouse National 

Technical Team, December 21, 2011).

The following comments pertain to specific parts of the above-referenced document.

Page 13, "Rights of Way" section, 3rd bullet. "Deaths resulting from collisions with power lines were an important source of 

mortality for sage-grouse in southeastern Idaho." This citation documented two sage-grouse collisions with power lines out 

of 56 collared birds; the sample size should be included when referencing this citation. As part of an Avian Protection Plan 

and with input from the U.S. Fish and Wildlife Service, PacifiCorp, an APLIC member, has conducted annual surveys of its 

power lines to assess avian electrocution and collision risks since 2001 and has surveyed over 100,000 power poles,

much of which is within sage-grouse habitat. During these surveys, no sage-grouse collisions have been documented. Of 

4,044 identified prey remains, sage-grouse comprised 0.05%. Considering the range of sage-grouse as a whole, collision with 

power lines is extremely low and conservation measures should reflect this.

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35. Comments on "A Report on National Greater Sage-grouse Conservation Measures" (produced by the Sage-grouse National 

Technical Team, December 21, 2011).

The following comments pertain to specific parts of the above-referenced document.

Page 64, last bullet. "Fit transmission towers with anti-perch devices." The paper cited with this recommendation (Lammers 

and Collopy 2007) found that avian predators were able to overcome perch discouragers, and that the deterrents "did

not have the desired short-term effect on avian predators." Of the research conducted on perch discouragers (e.g., Lammers 

and Collopy, Prather and Messmer, HawkWatch International, and PacifiCorp), the effectiveness of discouragers is 

influenced by the line location, line configuration, proximity to other perch sites, and avian use of the area. PacifiCorp’s avian 

risk assessment surveys (described above) have documented limited effectiveness, increased raven and raptor nesting rates, 

and increased electrocution risk associated with poles with perch discouragers. Because of the limited benefits of perch

discouragers and the potential negative implications (electrocution "takes" of federally protected eagles and migratory birds; 

increased likelihood of ravens nesting), the potential risks and benefits of their use should be considered on a case-by-case 

basis rather than a blanket requirement for all power lines.

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C. Comments by Resource Planning Issue

C-814 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

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No.

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36. In November 2009, nine federal agencies signed a Memorandum of Understanding seeking to expedite the construction of 

new transmission lines on federal lands. If these transmission lines cross sage-grouse habitat, sage-grouse will likely be 

negatively impacted. The Gateway West Transmission Project, for example, will include ten power line segments and is 

expected to cut across 1,100 miles in southeastern Idaho and northern Wyoming, with approximately 500 miles of 

powerlines proposed on BLM lands. It is anticipated that this project may significantly impact sage-grouse habitat in those 

areas.

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37. Consider the impacts of power lines and poles that create perches for predators in sage grouse habitat. All Both emc0305GB

38. The BLM is using a “Framework for sage-grouse impacts analysis for interstate transmission lines 05-17-2011” in the 

Gateway Transmission line process. This states: An analysis of sage grouse populations within 18 km of the project is a 

critical component of an indirect impacts analysis for grouse. They may be impacted by loss habitat functionality. Yet the core 

model doesn’t even prioritize habitats within 18 km. This also states that: the construction of a transmission project or other 

linear facility may pose an additional hindrance of seasonal migration patterns or avoidance of important seasonal habitats 

once used extensively by local sage grouse populations”. It continues: “Qualitative and quantitative measures of habitat 

change must be considered in describing the potential impacts. In the context of managing a species that requires a large 

landscape of habitats to meet their life cycle needs, and the nature of the proposed disturbance, it is reasonable to make 

some assumptive predictions about the relative impacts within 18km”.

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39. Sage grouse standards for wind and transmission lines

Wind power generation represents a clean, renewable alternative to fossil fuels, but construction of wind farms in key 

habitats is likely to lead to unacceptable levels of impact. Although there is little published science directly addressing the 

impact of wind turbines or transmission lines on sage grouse, there is a broad consensus among biologists that sage grouse 

avoid tall structures (such as wind turbines and transmission towers) and abandon adjacent habitats. One unpublished study 

found that sage grouse habitat use increased with distance (up to 600 meters) from transmission lines. It is notable that 

modern perch inhibitors emplaced on transmission lines result in a major decrease, but not elimination, of raptor perching 

(Slater and Smith 2010). Molvar (2008) compiled BLM data from a wind power project on Cotterel Mountain, Idaho and was 

able to determine that the erection of seven meteorological towers led to drastic declines in sage grouse populations across 

nine sage grouse leks, while populations in the surrounding area remained stable. See Attachment 5. There has been 

abundant scientific information that other types of energy development, particularly oil and gas, has a major impact on sage 

grouse populations, and oil and gas development has some similar features such as habitat fragmentation and tall structures 

(in the form of drilling rigs).

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40. Wind and Transmission

Inside Core Areas

• No wind energy development

• Transmission lines should be buried underground or limited to existing electrical transmission corridors of ... mile 

maximum width.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-815

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

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Outside Core Areas

• Wind farms and transmission lines sited at least 5 miles from active sage grouse leks and at least 3 miles from identified 

winter habitats.

• Transmission lines allowed along existing electrical transmission corridors of ... mile maximum width.

41. At minimum, the NEPA analysis should address the following:

• Excluding transmission lines from Core Areas, pursuant to the new BLM nationwide sage grouse IM.

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42. I urge you to consider concolidated plan amendments that will: limit new power lines, wind turbines and other tall structures 

in or near sage grouse priority habitat

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43. In the past few years we at White River Electric Association, Inc. have participated in the Piceance/Parachute/Roan Sage 

Grouse Local Working Group and recently attended the North Eagle/Southern Routt Greater Sage Grouse Working 

Group. White River Electric Association, Inc. is a member of the Avian Power Line Interaction Committee, and we are 

serious and conscientious in our efforts to construct and maintain power lines with the best interests of all parties involved.

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44. We continually strive to work with the BLM, Forest Service, US Fish & Wildlife, and all regulatory agencies, yet at the same 

time we are obligated to insure that right-of-ways, access roads and structures be efficiently and effectively placed. As a 

non-profit, member-owned cooperative we are forced to closely look at the feasibility and logistics of placing and maintaining 

our facilities.

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45. In reviewing the BLM's Greater Sage-Grouse Interim Management Policies and Procedures the first unrealistic suggestion 

that comes to mind is the burying of power lines. To my knowledge there is no science showing that grouse avoid the 

overhead structures; I have personally witnessed greater Sage Grouse leks below both transmission and distribution power 

lines. Often times the previously cleared (no blading, only brush beating) right-of-ways below the power lines enhance the 

habitat by removing the old growth sage and creating a more desired habitat. Transmission voltage power lines e.g. 69-kV 

and greater voltages, cannot be feasibly buried; buried high voltage power lines can be very dangerous, costs are extreme, 

and the life expectancy of such a buried line is less than half that of an overhead power line. And please consider that our 

distribution power Hnes only actually disturb a 2' circle of earth every 300 feet +/- ... only where the pole is set ... verses a 

trench and bladed right-of-way the entire length of the power line that must be reclaimed, reseeded, monitored and 

maintained. Yet another example of Greater Sage Grouse not being affected by overhead structures is the abundance of 

windmills in the habitat where the birds often congregate.

As far as the thought that eagles and the other large predatory birds can use the structures as an unfair advantage when 

hunting a threatened or endangered species such as Greater Sage Grouse - there are now perching discourages designed, 

implemented and proven to reduce the perching of large predatory birds on such structures.

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46. A second issue requiring additional research is the incidence of greater-sage-grouse collisions with power lines. To date, 

grouse collision risk with fences has been established. The Colorado Sage-Grouse Conservation plan indicates that 

sage-grouse collisions with power lines have been documented, but examples have been few, isolated, and anecdotal.

Information to date infers no population-level impacts to grouse, but this has not been thoroughly studied

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C. Comments by Resource Planning Issue

C-816 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

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47. i. Lander, WY RMP

Alternative B also requires anti-perching devices to be installed on all new overhead powerlines in greater sage-grouse, 

white-tailed prairie dog, mountain plover, and pygmy rabbit habitats to reduce predation from raptors. In addition, the BLM 

will work with ROW holders to identify conflict areas and get anti-perching devices installed on existing overhead 

powerlines in these same habitats. (DEIS 882) Because approximately 74-80% of sage-grouse females nest within 4 miles of 

leks (Moynahan 2004, Holloran and Anderson 2005), this measure may help to reduce predation pressures on nesting and 

foraging grouse. We recommend the use of deterrent devices on H-frame structures because recent research indicates they 

are effective tools in reducing perch use of such structures (Lammers and Collopy 2007, Slater and Smith 2010). The BLM 

and FS should consider not only anti-perching devices to reduce raptor predation on grouse, but also measures (not included 

in the Lander RMP) that would reduce conditions (e.g., nest substrates and anthropogenic attractants) that enhance local 

raven populations, to reduce potential raven predation on sage-grouse nests. Energy development in undeveloped sagebrush 

areas has been shown to facilitate increases in the abundance of breeding ravens, with concomitant negative effects on nest 

survival of sage-grouse (Bui et al. 2010, Coates and Delehanty 2010). Raven predation on grouse nests may have a 

significantly adverse impact on local grouse populations (Coates 2007). BLM and FS should recommend that any newly 

permitted permanent, highprofile structures will be outfitted with raven deterrents.

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48. iii. Strong components of Wyoming’s approach

For transmission lines, 2-mile wide transmission corridors have been identified in an effort to collocate disturbances. 

Construction is prohibited between March 15 and June 30 (or between December 1 and June 30 in winter concentration 

areas) and within 0.5 miles on either side of the existing transmission lines. If new lines are proposed for core area, they must 

be either buried or outfitted with raptor per deterrents to minimize avian predation pressure on sage-grouse.

East Both emc0089RM

49. With specific regard renewable energy transmission and resource development, the proposed action must take into account 

the years of work done by:

The Western Governors Association Regional Transmission Expansion Project, analysis of transmission requirements under 

a broad range of alternative energy futures and to develop long-term, interconnection-wide transmission expansion plans. 

More information may be found at http://www.westgov.org/rtep.

These studies provide the basis for developing a balanced program of habitat management with energy development 

potential in terms of designated land use.

All of these studies have been developed with a broad range of expertise and experience. State and federal agencies were 

contributing members along with utility, conservation and industry groups. All have extensive map products available for use 

and incorporation into the proposed action. All consider constraints of cultural, social, and biological issues among others.

All have recommendations of primary renewable energy zones and necessary transmission corridors for delivery of energy.

All of the studies are less than three years old and pertinent to the proposed action.

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50. We respectfully request that structures, such as power lines, that are currently in use and which have long been in place 

under valid permits be "grandfathered in" or exempted from changes to greater sage-grouse management plans. We offer 

qualified support for mitigation measures which will demonstrably improve habitat or species success. The relative benefits 

of mitigation measures must be carefully balanced against the negative impacts which will occur during the installation of 

GB Both rmc0056GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-817

Scoping Summary Report

Table C-5.F

Comments Related to Transmission

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those measures. Marking and raptor perching prevention are far superior to the impacts of relocating or removing existing 

overhead power lines and to the impacts of converting to underground power lines.

51. In regard to new overhead, wood pole, transmission and distribution lines typically utilized by rural utilities to transmit 

power over the significant distances that must be covered, the RMP should recognize the limited impact of these projects on 

sage grouse habitat. Specifically, if such facilities can be routed near existing roads, new permanent ground disturbance is 

generally not required. In many locations overland ground construction techniques will not require grading and areas 

temporarily disturbed by vehicle tracks during construction return to their pre-construction condition within a very few 

years.

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52. The Dillion Local Working Group identified 5 key issues in the area: "tie" for 3rd, 3. i. infrastructure (includes fences, roads, 

power lines, communication towers, and pipelines, developed for any purpose)

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53. With specific regard renewable energy transmission and resource development, the proposed action must take into account 

the years of work done by:

The California Renewable Energy Transmission Initiative (RETI) assessment all competitive renewable energy zones in 

California and in neighboring states that can provide significant electricity to California consumers by the year 2020. RETI 

also will identify those zones that can be developed in the most cost effective and environmentally benign manner and will 

prepare detailed transmission plans for those zones identified for development. More information can be found at

http://www.energy.ca.gov/reti/index.html.

These studies provide the basis for developing a balanced program of habitat management with energy development 

potential in terms of designated land use.

All of these studies have been developed with a broad range of expertise and experience. State and federal agencies were 

contributing members along with utility, conservation and industry groups. All have extensive map products available for use 

and incorporation into the proposed action. All consider constraints of cultural, social, and biological issues among others.

All have recommendations of primary renewable energy zones and necessary transmission corridors for delivery of energy.

All of the studies are less than three years old and pertinent to the proposed action.

NVCA Both emc0254GB

54. On page 13, second solid bullet, the report indicates that collisions with power lines "were an important source of mortality

for sage-grouse in southeastern Idaho ..." The EIS should define "important" and compare this collision-caused mortality to 

annual hunting mortality. In Nevada, the Nevada Department of Wildlife claims that hunting is not an important mortality 

factor. The number of sage-grouse killed annually by each of these causes needs to be disclosed in the EIS.

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55. Lands and Realty issues such as preservation of energy corridors for pipelines and overhead power lines must be addressed 

in the RMP amendments. Existing energy corridors and proposed Energy Gateway South and TransWest Express corridors 

should be recognized and considered for exclusion from sage grouse preliminary priority or preliminary general habitat 

designation.

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56. i. Lander, WY RMP

Alternative B also requires anti-perching devices to be installed on all new overhead powerlines in greater sage-grouse, 

white-tailed prairie dog, mountain plover, and pygmy rabbit habitats to reduce predation from raptors. In addition, the BLM 

will work with ROW holders to identify conflict areas and get anti-perching devices installed on existing overhead 

WY Both emc0089RM
C. Comments by Resource Planning Issue

C-818 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.F

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powerlines in these same habitats. (DEIS 882) Because approximately 74-80% of sage-grouse females nest within 4 miles of 

leks (Moynahan 2004, Holloran and Anderson 2005), this measure may help to reduce predation pressures on nesting and 

foraging grouse. We recommend the use of deterrent devices on H-frame structures because recent research indicates they 

are effective tools in reducing perch use of such structures (Lammers and Collopy 2007, Slater and Smith 2010). The BLM 

and FS should consider not only anti-perching devices to reduce raptor predation on grouse, but also measures (not included 

in the Lander RMP) that would reduce conditions (e.g., nest substrates and anthropogenic attractants) that enhance local 

raven populations, to reduce potential raven predation on sage-grouse nests. Energy development in undeveloped sagebrush 

areas has been shown to facilitate increases in the abundance of breeding ravens, with concomitant negative effects on nest 

survival of sage-grouse (Bui et al. 2010, Coates and Delehanty 2010). Raven predation on grouse nests may have a 

significantly adverse impact on local grouse populations (Coates 2007). BLM and FS should recommend that any newly 

permitted permanent, highprofile structures will be outfitted with raven deterrents.

57. For powerline transmissions, and wind energy projects it might be advantageous to have the lowest wire on the transmission 

line or tip of the wind turbine be above a specific distance from the ground in core area habitat. Sage Grouse do not fly very 

high but a minimum could be set.

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58. iii. Strong components of Wyoming’s approach: For transmission lines, 2-mile wide transmission corridors have been 

identified in an effort to collocate disturbances. Construction is prohibited between March 15 and June 30 (or between 

December 1 and June 30 in winter concentration areas) and within 0.5 miles on either side of the existing transmission lines. 

If new lines are proposed for core area, they must be either buried or outfitted with raptor per deterrents to minimize avian 

predation pressure on sage-grouse.

WY Both emc0089RM

59. BLM must implement policies to protect sage-grouse habitat on private split estate lands rather than permit BLM oil and gas 

drilling underlying important sagebrush habitat on private lands. BLM must also recognize that much of the sagebrush habitat 

that has been and is being eliminated and impacted in the Powder River Basin and Wyoming is from BLM permitted mineral 

development underlying private lands. BLM cannot simply ignore the impacts their permitting actions cause to millions of 

acres of sage grouse habitat by permitting mineral activity underlying millions of acres on private split estate surface that 

provides sage grouse habitat. BLM must implement measures to protect sage grouse habitat on all lands that they impact by 

their own permitting activity regarding BLM authorized mineral development. BLM must also restrict leasing of oil and gas 

and coal resources in high quality sage grouse habitat, regardless of surface ownership.

WY Both emc0129RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-819

Scoping Summary Report

Table C-5.G

Comments Related to Utilities

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. We respectfully request that structures- such as power lines, that are currently in use and which have long been in place 

under valid permits be "grandfathered in" or exempted from changes to greater sage-grouse management plans. We offer 

qualified support for mitigation measures which will demonstrably improve habitat or species success. The relative benefits of 

mitigation measures must be carefully balanced against the negative impacts which will occur during the installation of those 

measures. Marking and raptor perching prevention are far superior to the impacts of relocating or removing existing 

overhead power lines and to the impacts of converting to underground power lines.

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2. in regard to new overhead. Wood pole, transmission and distribution lines typically utilized by rural utilities to transmit 

power over the significant distances that must be covered, the RMP should recognize the limited impact of these projects on 

sage grouse habitat. Specifically, if such facilities can be routed near existing roads, new permanent ground disturbance is 

generally not required. In many locations overland ground construction techniques will not require grading and areas 

temporarily disturbed by vehicle tracks during construction return to their preconstruction condition within a very few 

years.

All Both fxc0006GB

3. Energy corridors do no good if they do not meet the requirements necessary to be viable for electrical providers. The DEIS 

and SEIS documents need to include planning requirements and a documented process for: 1) understanding electrical energy 

demands in areas where sage-grouse occur; and 2) evaluating utility corridors and ROWs for transmission line development 

in coordination with local utility owners, operators, state/local governments and municipalities.

All Both emc0378BG

4. While the BLM’s IM allows for the ongoing operation of existing facilities, it seems to place impediments in the way of access 

to those facilities. Problematic is the recommendation that additional mitigation might be required for existing access roads 

and/or previously authorized access ROWs that might not have been constructed or improved to-date, if this improvement 

would exceed the proposed three percent disturbance threshold. The ability of electricity providers to safely access/maintain 

existing electrical facilities is crucial to reliability of the Western grid.

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5. Some of the IM’s recommendation may conflict with standards and federal regulations that utilities are required to meet. For 

example, BLM calls for co-locating power lines within existing ROWs. However, for operational and safety reasons, utilities 

may not be able co-locate facilities within existing ROWs. Utilities are required to maintain clearances identified in the 

National Electric Safety Code for the safe and reliable operation of the transmission system.

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6. Some of the “best practices” being suggested by the IM and NTT Report are unrealistic. For example, the documents suggest 

burying power lines as a mitigation tool. This is problematic from both economic and engineering perspectives. A number of 

factors influence the feasibility of burying power lines, including voltage, land use, terrain, soils and geology of the area, density 

of existing buried facilities (water gas, etc), highway crossings, surface water crossings, floodplains, and presence of other 

biological and cultural resources of concern. Burying high voltage transmission lines poses a significant operational issue for 

utilities and would substantially increase the cost of constructing high voltage transmission lines. (The cost of burying a high 

voltage transmission line can increase overall project cost anywhere from 4-10 times the comparable costs of an overhead 

line.) Other factors regarding the feasibility of building an underground transmission line include longevity, maintenance and 

operational issues and increased habitat fragmentation effects. Underground transmission lines have half the life expectancy 

of overhead transmission lines. There are also reliability concerns: when an outage occurs on an underground line, it is 

difficult to pinpoint and reach the source of the outage. Repairs take longer and require additional ground disturbance, 

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C. Comments by Resource Planning Issue

C-820 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.G

Comments Related to Utilities

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

potentially increasing disturbances to sensitive habitats. Above-ground facilities have been found to be generally compatible 

with the type of short brush that sage grouse uses for habitat. As a result, above-ground facility ROWs can actually help 

preserve such habitat. Finally, it is important to note: burying power lines actually carries a significant set of environmental 

degradation risks. We would point you to comments submitted from the Edison Electric Institute which speak to this issue. 

In particular, please consider the referenced study from the University of California, which provides a life cycle assessment of 

the potential environmental impacts of overhead vs. buried power lines.

7. We would point you to the work of the Avian Power Line Interaction Committee (APLIC). In partnership with the Utah 

Division of Wildlife Resources, Utah State University and a number of utilities, APLIC has supported efforts coordinated by 

Utah Wildlife in Need (UWIN) to assess sage-grouse and tall structures. These efforts include stakeholder workshops and a 

literature review to assess current knowledge and concerns and to develop research protocols to be used when assessing 

potential impacts. BLM needs to work with APLIC and other interested entities to get a better understanding of the 

construction and operational constraints involved.

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8. It would greatly benefit both land management and regulatory agencies and the electric utility industry if additional research 

could help determine effective buffer and seasonal restrictions for linear features that can protect sage-grouse and their 

breeding habitats, while facilitating reasonable and effective energy infrastructure planning.

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9. Western Area Power Administration (Western) has reviewed your letter and scoping document pertaining to planning 

efforts for the greater-sage grouse and its habitat on National Forest System lands included in the Routt National Forest near 

Yampa, Colorado. Western's HaydenGore. Tap 230-kilovolt (kV) transmission line is located near the identified core area in 

Township 2 North, Ranges 83 and 84 West while its Gore Tap-Hayden 138-kV transmission line is located on adjacent lands 

in Township 1 North, Range 83 West, 6th Principal Meridian, Routt County, Colorado (see the enclosed map). Both 

transmission lines are served by access roads that cross or about the core area.

While there are no Western facilities lying on National Forest System lands within the core area identified by the Routt 

National Forest as "moderate priority" habitat, the proximity of Western' s transmission line towers and access roads used 

to operate and maintain the powerlines may be of concern to the Forest Service. Western asks that as your staff reviews the 

1997 Revised Routt National Forest Land and Resource Management Plan to ensure the forest is implementing available 

regulatory mechanisms to protect the greater-sage grouse and its habitat, please keep in mind that valid, existing uses will 

conflict or interfere with or even prevent the establishment of viable sage grouse populations. Transmission line structures 

may provide a perch for raptors and powerline roads may provide access to areas during times of breeding and 

brood-rearing, or during times of migration or winter survival, but because the powerlines and roads exist already, they 

should be considered as part of the baseline.

All Both rmc0040RM

10. If the Forest Service determines that an appropriate prescriptive standard to conserve greater sage grouse habitat is to close 

areas at certain times, then Western would request notification of such closure and would try to limit its activities to time 

periods when the area is open, except in the case of an emergency. If there is a power outage, Western will access the area, 

take care of the outage as quickly as possible then leave the area. If additional mitigation measures requiring changes or 

additions to the transmission towers are anticipated as part of this review, Western· asks that it be involved in the discussion 

prior to the issuance of any prescriptive guidance affecting its infrastructure.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-821

Scoping Summary Report

Table C-5.G

Comments Related to Utilities

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

11. Right-of-ways.

Issue: Utility corridors, including powerlines, pipelines and associated infrastructure, fragment habitat and affect sage-grouse 

populations. Potential geothermal and solar energy development on federal lands may also impact sage-grouse.

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12. Utility poles and wires have been known to pose a threat to sage-grouse since at least 1938, when evidence of grouse striking 

telephone wires was reported (Borell 1939). Utility corridors also fragment habitat and contribute to increased predation of 

sage-grouse locally by subsidizing raptors and corvids. The Oregon Department of Fish and Wildlife recently reviewed 

literature on the contributions of utility corridors to sage-grouse predation in the Sage-Grouse Conservation Assessment 

and Strategy for Oregon (Hagen 2011: 47-48, internal citations omitted). Perching on power poles and transmission 

structures increases a raptor or corvid’s range of vision, allowing for greater speed and effectiveness in searching for and 

acquiring prey. Increased abundance of raptors and corvids within occupied sage-grouse habitats may result in predation 

rates outside the range of natural variation. Population level impacts to sage-grouse populations have been mixed. 

Transmission structures may also provide nesting sites for corvids and raptors in habitats with low vegetation and relatively

flat terrain. Thus, these birds may preferentially seek out transmission structures in areas where natural perches and nesting 

sites are limited.

Case Studies

• Within one year of construction of a 372.5 mi transmission line in southern Idaho and Oregon, raptors and common ravens 

(Corvus corax) began nesting on the support structures, and within 10 years of construction 133 pairs of raptors and ravens 

were nesting on the transmission structures .

• Raptor observations have remained stable over a 5 year period after construction of a power line in Nevada, but common 

ravens have increased >200%.

• Golden eagle (Aquila chrysaetos) predation of sage-grouse increased from 26% to 73% (of the total predation) after a 

transmission line was constructed within 220 yd of an occupied lek in northeastern Utah. The lek was extirpated, and the 

presence of the transmission line resulted in changes in sage-grouse dispersal patterns and fragmentation of the habitat.

• In Washington, 95% (19 of 20) of leks ≤4.7 miles from 500 kV transmission lines are now unoccupied, while the unoccupied 

rate for leks >4.7 miles is 59% (22 of 37 leks).

• Leks within 0.25 miles of new power lines constructed for coalbed methane development in the Powder River Basin of 

Wyoming had significantly slower growth rates compared to leks further from these lines, which was presumed to be the 

result of increased raptor predation.

• The presence of a power line may fragment sage-grouse habitats even if raptors are not present. Use of otherwise suitable 

habitat by sage-grouse near power lines increased as distance from the power line increased for up to 660 yards. The 

presence of power lines may limit sage-grouse use within 0.6 miles in otherwise suitable habitat.

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13. While electric lines are required to power oil and gas facilities, there seems to be confusion throughout the National 

Sage-Grouse Technical Team's report of what facilities apply where and acknowledgment that utility owners and operators 

may provide power to oil and gas providers, but in some cases oil and gas operators build their own power lines to 

interconnect to the larger transmission system. Tli-State requests the final guidance identifies recommended conservation

measures according to fac ility type. Each applicant needs to understand the requirements for their respec tive fac ilities 

CO Both rmc0019RM
C. Comments by Resource Planning Issue

C-822 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.G

Comments Related to Utilities

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

without hav ing to understand another industry's guidance.

14. SNWA respectfully requests that the EIS consider and discuss the following: the management guidelines for projects within 

utility corridors

NVCA Both rmc0069GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-823

Scoping Summary Report

Table C-5.H

Comments Related to Geothermal Energy Development

Comment 

No.

Comment Sub

RegionID

Agency CmtLtrCode

1. There are also spring and wet meadow brood rearing complexes that are likely to be impacted by geothermal development. All Both emc0411GB

2. The Middle Park population is the third largest in the state of Colorado after Northwest and North Park populations. These 

3 populations account for 93% of the males counted in the state. Of the three largest populations, Middle Park is the only 

population that does not currently have any energy development activity. There are limited leases in Middle Park, but at this

point most of the lease sales have been deferred until the completion of the BLM Kremmling Field Office Resource 

Management Plan. We strongly believe that protecting this population from oil and gas development should bc a priority in the

effort to maintain or increase the population. Due to the absence of energy development activity in Middle Park, it is 

imperative to put in place strong protections for sage grouse that presents a unique opportunity to maintain and/or increase 

sage grouse abundance and distribution. Additionally leasing and development impacting the Middle Park population will 

destroy this unique unspoiled habitat.

CO Both emc0059RM

3. The Middle Park population is the third largest in the state of Colorado after Northwest and North Park populations. These 

3 populations account for 93% of the males counted in the state. Of the three largest populations, Middle Park is the only 

population that does not currently have any energy development activity. There are limited leases in Middle Park, but at this

point most of the lease sales have been deferred until the completion of the BLM Kremmling Field Office Resource 

Management Plan. I strongly believe that protecting this population from oil and gas development should be a priority in the 

effort to maintain or increase the population. Due to the absence of energy development activity in Middle Park, it is 

imperative to put in place strong protections for sage grouse that presents a unique opportunity to maintain and/or increase 

sage grouse abundance and distribution. Additionally leasing and development impacting the Middle Park population will 

destroy this unique unspoiled habitat.

CO Both emc0064RM

4. Of course, conserve the grouse and its habitat. Also consider the need for more oil production and out need for jobs for men 

and women

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5. A 2010 Instruction Memorandum (No. WY-2010- 012) recommends Wyoming BLM Field Offices identify areas not available 

for energy development (including oil, gas, and wind) and leasing, and defer leasing when a lease expires. This practice should 

be incorporated range-wide in all priority areas to prevent anthropogenic disturbance in sage-grouse habitat. Geothermal 

energy production is similar to wind energy, as well as oil and gas development, in terms of impacts. It requires surface 

exploration, exploratory drilling, field development, and plant construction and operation, and direct habitat loss can occur 

from well pads, structures, roads, pipelines, and transmission lines. Human presence during construction, development and 

operation of geothermal processes may cause additional impacts to sage-grouse. Currently there are no enforceable 

regulations to protect sage-grouse during geothermal activities. Rather, the BLM implements best management practices to 

minimize impacts to sage-grouse. These guidelines, however, are unenforceable and very general in nature. Looking to the 

future, standards and guidelines, as well as clearly enforceable requirements, must be delineated for geothermal energy 

production in sage grouse habitat. Given surface impacts from this form of energy extraction, exclusion of geothermal energy 

production should be strongly considered in priority sage grouse areas.

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C. Comments by Resource Planning Issue

C-824 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.H

Comments Related to Geothermal Energy Development

Comment 

No.

Comment Sub

RegionID

Agency CmtLtrCode

6. As a primary stakeholder, however, we are fully aware of the fact our property is affected by a checkerboard land ownership 

pattern in which the Bureau has management jurisdiction for the public. It also lies within areas identified as supporting 

75-100% breeding population densities of the species (2010). For these reasons, we would be opposed and are extremely 

concerned in supporting any objectives or conservation measures that would have a direct or indirect impact on our abilities 

to develop our private surface and sub-surface land and resources. Such conservation measures would include, but are not 

limited to, actions that could place restrictions on access, surface disturbing activity levels or hinder the ability to locate, 

explore and extract mineral resources.

NVCA Both rmc0053GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-825

Scoping Summary Report

Table C-5.I

Comments Related to Noise

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. CPW would like the PRMP to include the identification, description, analysis and proposed mitigation measures for noise 

disturbance to greater sage-grouse. In part, CPW requests that BLM/USFS develop noise abatement stipulations for 

compressor stations, pump jacks, diesel motors, etc that will be implemented range-wide for consistency.

All Both emc0072RM

2. Another disturbance not specifically identified or addressed in existing or draft RMPs is the impact that natural gas flaring poses 

to greater sage-grouse. Flaring is believed to pose a threat from several standpoints. Noise associated with flaring may cause 

disturbance and increased predator effectiveness. Sound may directly interfere with lek display vocalizations and harmonics. 

Light from flaring can extend far beyond the immediate pad area, and this increased availability of light may provide increased 

opportunity for predation at times when natural light is normally not available. Light may also directly preclude grouse from 

using lek sites or other seasonal habitats.

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3. Noise from drilling and associated activities can drive sage-grouse from the area, can cause physiological stress, and moreover 

may interfere with auditory cues and communication between individual birds. If birds do stay in the area, the effects from 

noise would likely have negative impacts in terms of breeding and reproductive success

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4. Analyze the impacts of noise generated by oil and gas development, military aircraft, and vehicles on sage grouse, and their leks 

in particular.

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5. BLM states that disturbance from motion [and reflections?] of industrial energy or other structures is a concern. BLM 

proposes to "design or site permanent structures that create movement ..to minimize disturbance to grouse." What other 

activities besides fluid mineral on public lands result in "movement"? What about low level military overflights? Startle effects? 

This is often coupled with sudden onset of loud noises. Why is there no section of this report to address the very loud noises 

and visual impacts of military training activities that occur across vast areas of Idaho, Oregon, Nevada, Utah and portions of 

other western states - with flights down to 100 ft, AGL (above ground level).

All BLM emc0411GB

6. Why not require noise shields at all times of the year, not just when drilling and during some periods? Why is BLM allowing 

drilling during nesting, and wintering periods for any reason? This means not just noise intrusion, but also flushing birds from 

human activity - thus making them more vulnerable to predation, and displacing them. 

Here is an example of where older land use plans are typically better than the newer ones - and amending them, for example, 

to put in place such a toothless noise provision would eliminate the more protective standard old LUP seasonal avoidance of 

intrusion into breeding and wintering habitats. We have frequently seen that wildlife protection language in some MFPs and 

older RMPs is actually stronger than the recent weak, ineffective RMP measures - which this NTT list largely parrots. 

Time after time, in energy development EAs (wind, transmission) BLM is using these laundry lists of uncertain BMPs to avoid 

stopping all disturbances during sensitive periods. The Forest’s grazing EIS’s overflow with similar loose, uncertain BMP lists.

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7. We are concerned that the noise provisions are inadequate - especially since the type of noise

(frequencies) being generated may be important. Plus, ambient noise is typically averaged in developer studies that we have 

seen. Species perception of noise differs greatly from humans. In calm air, generator noises, for example, can carry over vast 

distances. So can gas-line pump sounds - for example the Paiute gas pipeline crossing of the East Fork Owyhee that is audible 

over several miles.

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C. Comments by Resource Planning Issue

C-826 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-5.I

Comments Related to Noise

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

8. At minimum, the NEPA analysis should address the following:

• Assessing the impact of noise from drilling rigs, compressor stations, and other equipment on dispolaying sage grouse and 

emplacing measures to ensure that noise pollution is regulated below the appropriate decibel level to allow sage grouse to 

breed unhindered.

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9. While existing or draft RMPs in NW Colorado discuss a number of traditional sources of direct and indirect impacts of 

anthropogenic developments on greater sage-grouse, CPW has noticed a lack of information and discussion of how and when 

noise from oil and gas development impacts greater sage-grouse. There is a developing body of literature suggesting that 

limiting anthropogenic sources of noise is necessary to minimize human impacts on greater sage-grouse (as well as other 

grouse species in the family Tetraonidae). There are a number of mechanisms by which anthropogenic sources of noise can 

negatively impact grouse, including the following:

• Industrial noise masks the sounds of strutting males and may disrupt female choice of males on the lek (leading to reduced

productivity)and cause females (and consequently males) to abandon leks;

• Industrial noise masks sounds made by approaching predators and may lead to increased predation and reduced survival for 

all age and sex classes in all seasonal habitats, not just at leks. Over time, this may result in reduced survival of birds inhabiting 

areas near noise sources and ultimately, fewer birds in developed areas. Sage-grouse may also avoid areas with industrial noise, 

which would result in the same pattern;

• Industrial noise in brood-rearing habitats may mask the predator-warning vocalizations given by females to chicks or the 

contact calls of lost chicks, either of which could lead to reduced brood survival;

• Sage-grouse of all age and sex classes in all seasonal habitats may respond to increased ambient noise by increasing time spent 

being vigilant, thereby increasing energetic costs and decreasing time available for foraging and self-maintenance, leading to 

poorer body condition and reduced productivity; and

• Industrial noise could cause chronic physiological stress that leads to poorer body condition and reduced survival or 

productivity

CO Both emc0072RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-827

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. The conservation measures you propose will drive many true rangeland stewards off the land and will severely impact other 

businesses within the western economy. Careful review of the NOI and relevant associated documents reveals that the US 

Fish and Wildlife Service’s own analysis demonstrates that the greater sage-grouse is not legally qualified for listing under the

Endangered Species Act. Yet the BLM has proposed and implemented under their December 2011 Instruction 

Memorandums Endangered Species Act styled sage-grouse conservation measures under the misguided notion that the Act 

somehow authorizes or even mandates ecosystem conservation prior to a species listing. These unnecessary and legally

unsupportable decisions to impose and enforce sage-grouse conservation measures under the auspices of the Endangered 

Species Act when the greater sage-grouse does not currently meet the listing requirements of the Act have and will 

negatively impact most economic activities across the species range by increasing the regulatory cost and burden to conduct 

natural resource related activities, both commercial and recreational, thereby significantly impeding or virtually eliminating 

such activities.

All Both 0398GB

2. Consider having sage-grouse conservation on equal footing with livestock grazing on private allotments. We wish to not 

lose our grazing allotment if we designate it as sage-grouse conseration habitat.

All Both cfc0001

3. Proper "Savory" like grazing is the answer. Simple statistical correlation proves this. All Both cfc0002GB

4. Couple this with grazing cuts and increased fires since 1980 and there you have simple statistical analysis of the 3 reasons for 

sage-grouse decline.

All Both cfc0002GB

5. I'm not advocating past grazing practices, I'm advocating more grazing animal for less time. Yes this means ranchers who 

turn their livestock out forget about them will have to change or go away. We need to have flexibility within grazing permits

to hit invasive species hard then move on.

All Both cfc0002GB

6. You should set aside an area where predators can be retaced and creative grazing system can be developed that will be more 

intense in some key areas.

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7. There is little emphasis on treating and restoring range-land to bring it back to its full productive potential for sage grouse 

and all wildlife and livestock. There should be no retirement of Grazing Priveleges to achieve this.

All Both cfc0006RM

8. There are research projects under way that are documenting that grazing by livestock is done under conditions that are 

appropriate for that specific areas needs, the outcome is nutral to positive as far as maintain, manipulating as desired, or 

improving habitat for grouse in general and even sage-grouse in specific. Any analysis would be incomplete withut a through 

update and incorporation of recent research on grazing's effects and potential benefit in improving habitat needs.

All Both cfc0010GB

9. The causes are many and varied. When sheep were prevalent poisons were used widely to eradicate any meat eating 

animals. Sheep were also herded and not allowed season long access to individual grazing areas. Ephemeral draws were 

generally in better condition with that mgt.

All Both cfc0011RM

10. To prevent listing of Sage-grouse livestock grazing and vegetative management projects and programs must be modified to 

provide sufficient quality Sage-grouse habitat.

All Both cfc0016GB

11. The NTC recommendation "consider retirement of grazing priviledges in priority sage grouse habitat areas" is a concern. 

I believe this will give radical environmental groups a tool to contest BLM and Forest Service allotment renewals. I would 

encourage you to use "deferment" rather than retirement.

All Both cfc0017RM
C. Comments by Resource Planning Issue

C-828 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

12. National Tech Recommendation of retiring grazing permits would be very counter- productive from many standpoints. Most 

importantly from the s. grouse perspective- there would be many more fires that would wipe out sagebrush -Duh!

All Both cfc0018RM

13. I would like to see documentation and numbers on sage grouse dying from crashing into fences. They may be stupid, but they 

aren't that dumb. I have travelled thousands of miles down fence lines and have never seen a dead grouse by a fence, and 

neither has any of the dozens of permittees I've talked to.

All Both cfc0018RM

14. I am especially concerned that a "hard look" is taken at livestock grazing, its affects on the environment, its affects on sage 

grouse.

All Both cfc0020GB

15. The grazing has help with the habit for the chickens. They're thriving on the range. All Both cfc0024GB

16. Grazing restrictions should be limited to non-native species. All Both cfc0024RM

17. Retirement of grazing privileges is not in the interest of securing the nation's food supply. All Both cfc0024RM

18. If grazing privileges are retired, how will the agencies manage the health of the rangeland? It is common knowledge that 

semi-arid environments need grazing to keep the plants healthy. This is essential for the sage grouse that depend of these 

plants.

All Both cfc0024RM

19. Livestock Grazing. #1 - good. 

#3 Within much of TBNG, wetlands are often temporary and seasonal due to precipitation. Encourage pasture rotation or 

defered grazing, perhaps with compensation. Possible temporary electric fencing. Case by case.

All Both cfc0025RM

20. Livestock Grazing- Disturbance- 4 miles radius of a lek means 14 square miles of land or more. That is way too much to 

expect anyone to give up use on. 2 miles seems to be fairly standard and is still a large area.

All Both cfc0025RM

21. 3% disturbance is a lot, especially considering the past 14 years. 10% would be more realistic. No more than 1 disturbance 

per section is not realistic either due to changing landscapes. There should be mitigation allowances made. Erusting used 

roads and large/medium reservoirs should not be counted.

All Both cfc0025RM

22. "Remove, modify or mark fences." You might be able to put something on posts to keep hawks from searching but would a 

"flag" waving from the wires be a disturbance also? I don't know if sage grouse go under a fence for protection but we have 

seen rabbits do so.

All Both cfc0025RM

23. "Retirement of grazing priviledges in priority sage grouse area." NO! May use deferred/rotational grazing. Sage grouse at 

their most plentiful were co-existing with large grazing animals. You would still have antelope, deer and elk in some places. 

Fox, Swift fox, skunks and badgers are likely more destructive than cattle or sheep.

All Both cfc0025RM

24. "All Activities" #1 NTR Ranches may have to do some activities during this time. They can use care not to disturb birds- no 

dogs, little noise, especially when birds are on nest or before chicks leave nest. #5 same as above

All Both cfc0025RM

25. Don't blame lwisted (SP) and grazing for sage hen loss. All Both cfc0026GB

26. This has the potential to be the distruction of the western public land based livestock industry All Both cfc0030GB

27. Malheur County has added vector control bringing attending to the issue of west nile virus. The virus is known to affect 

horses, sage grouse, and humans which leads me to conclude that blaming the livestock industry for sage grouse issues is 

unfounded scientifically and if taken to the extreme will result in economic and ecosystem damage.

All Both cfc0030GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-829

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

28. Where I have personally senn sagehens in a lek was an area containing several fences and grazed by cattle. This is one of the 

few areas that sage grouse population is stable.

All Both cfc0031GB

29. The fact that we have Sage Grouse here that have co-existed with the livesstock operation for over 100 years should be 

proof that they are not in danger from livestock use, and grazing, waster development and control of predators actually 

enhance the benefits to grouse. The water we develop for livestock is very important to the birds and will not be there if 

cattle are removed.

All Both cfc0032RM

30. More research on sagebrush manipulation and proper grazing and timing of grazing needed. All Both cfc0044GB

31. Science- proves there was fewer acres burned in Nevada in 1950-1970 why? The obvious answer, livestock grazed the fire 

fuel off. Yes, there is a balance.

All Both cfc0046GB

32. Use cows to improve the forage for birds and wildlife and to prevent wildfires. All Both cfc0047GB

33. Since wildfire is the#1 threat to sage-grouse and their habitat -Please include grazing with cattle and sheep in the strategy 

plan to help reduce the fire threat.

All Both cfc0050GB

34. I think if the Sage-grouse is listed there will be unintended consequences - you will lose the cooperation of the range users 

and the other people that use the range if there are too many regulations.

All Both cfc0053GB

35. It has become very obvious to us that as cattle numbers and utilization levels have declined sage hen population have gone 

down.

All Both cfc0056GB

36. The benefits of a well managed grazing system are advantagous to healthy sagehen population. The sage-grouse we observe 

like to follow the sows in a pasture and eat the tender plant growth after livestock grazing.

All Both cfc0056GB

37. I do not believe that grazing has any negative impact on the sage-grouse population. I believe the data available also supports 

that.

All Both cfc0059GB

38. WE have watched the sage-grouse poulation fluctuate up and down and it does not appear to be tied to cattle grazing in any 

way.

All Both cfc0060GB

39. The facts handed out at the meeting are not correct. Our local sage-grouse work group has been studying science about 95. 

They show grazing has helped the grouse habitat.

All Both cfc0062GB

40. Basically from years of living in the Great Basin and from the BLM map display I think one salient problem is that so much 

critical Sage-grouse habitat is also designated as grazing allotment

All Both cfc0066GB

41. Over the years (1870-present) over grazing, riparian abuse, invasive species, climate change, wild fires regarded as a 

"business opportunity"/cowboy lightening have altered the habitat in favor of public welfare ranching vs. native species, plant 

+ animal. Crested wheat monoculture is not a diverse biological ecosystem.

All Both cfc0066GB

42. My comments are regarding the use of BLM ground for the grazing of cattle. I think that cattle and sage-grouse have a 

symbiotic relationship. Both species benefit from each other. Some benefits that cattle offer to sage-grouse is

1) The water tanks supply water for the birds

2) Cattle graze down fire hazerdous grass

3) Cows don’t bother birds in nature & cows feed people before cattle are kicked off the BLM, I feel that there are bigger 

threats to sage-grouse that should be addressed first.

All Both cfc0068GB
C. Comments by Resource Planning Issue

C-830 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

43. First of all, since fire is the #1 destroyer of sage-grouse habitat, I think that we should figure how to prevent desert fires. One 

of the best ways to prevent fires would actually be to more intensively graze the forage with sheep and cattle. The BLM has 

so many regulations on the grazers that don’t allow the livestock to be on the grass long enough to take it down to a less fire 

hazardous length. Better management of the land could do a lot to prevent fires. Also I have heard that BLM workers 

actually go start fires on the desert. That is rediculous!

All Both cfc0068GB

44. My comments are going to be directed towards sage-grouse and cattle grazing co-habitation. I feel that they co-habitation. 

I feel that they co-habitat very well, and if cattle are not allowed to graze on BLM land, there will be an increase in fires due 

to the amount of dry grass which fuel huge fires.

All Both cfc0069GB

45. I hope you will consider and take into account that if cattle grazing is regulated or restricted, this will have a huge impact on 

many rancher's lives and livelihoods. It could mean that ranchers that graze on public land would be forced out of business. 

That would be a sad event.

All Both cfc0069GB

46. While I know that wildfire, weeds, fencing, etc have an affect on the sage-grouse, I feel that the each of the Forest Service & 

BLM to monitor grazing over the many years has lead to decrease in habitat for beautiful birds.

All Both cfc0072GB

47. Sound scientific research indicates that grazing is beneficial to the greater sage-grouse and other flora and fauna in multiple 

ways. Grazing reduces the instances and severity of wildfires. (Launchbaugh et al.2007). It improves greater sage-grouse 

habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et a1.l994, Evans 1996). It has 

also been used to control invasive weeds (Olson and Lacey 1994, Walker et aI.1994).

All Both em0396GB

48. Just a quick note to say that I hope the new guidelines continue to allow for livestock grazing of these native grasslands. This 

ecosystem evolved with grazing by large herbivores and needs grazing to continue to function properly. That said, I'm sure 

improvements can be made regarding timing, season-of-use, and stock densities to improve habitat conditions relative to 

ground-nesting birds.

All Both emc0010RM

49. 2) End livestock grazing on Federal Lands. Grazing destroys the sage brush habitat needed by the grouse to feed and nest. 

Cattle and other livestock destroy the natural vegetation and open areas to invasive species.

All Both emc0011GB

50. I'd like to comment on the sage grouse strategy. I understand that during the 60's there were a great number of sage grouse 

in southwest montana. During this time period there was an active predator control going on. Sheep were being grazed in 

largenumbers. Also at this time, eagles, facons, hawks and the like were not protected and the no.s were down due to DDT. 

Cattle grazing was having a greater impact on the vegetation. Also in the 60's, large areas were sprayed to kill sagebrush and 

make more grass. I have dates of spraying but can't find dates and data of sage no.s for that time frame or after. I would like 

to see a comparison of no. of sage grouse before, during and after spraying to see if reduction in sagebrush had an effect on

sage grouse no.s. Since then, grazing by sheep and cattle has been reduced. Making better riparian and vegetation overall. 

Some burning of sagebrush was done in the 80's but since that time, sagebrush treatment has been reduce greatly. So no 

change in sagebrush quality! Predator control has been reduced and the eagles, falcons, hawks, etc have been protected and 

increased.

All Both emc0013GB

51. Despite anti-livestock bias, some people have recognized cattle grazing's importance to certain species. Because sage grouse 

currently thrive in an area with a long history of grazing, the BLM should make every effort to understand the ways in which 

the cattle are important to the birds.

All BLM emc0013RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-831

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

52. The RMP should take a hard look at places where cattle have been removed to see what impact this has had on the sage 

grouse. Grazing clears areas the grouse can use as leks. Stock ponds provide water. Disturbance encourages growth that can 

provide nesting cover the following spring.

All Both emc0013RM

53. Humans have biases. Even well-meaning, scientific, logical people have biases that they do not recognize. To give the sage 

grouse a fair chance, it is important to realize that most ecologists have been educated with an anti-livestock bias. To 

overcome this bias, it is necessary to actively look hard for ways in which cattle might be benefiting the sage grouse.

The alternative is to remove cattle, drive ranches out of business, and then blame the resulting decline of the grouse on 

something else. This might be good politics, but it is bad for the grouse.

All Both emc0013RM

54. The presence of a ranching community using BLM allotments increases the chances of catching a wildfire when it starts, 

which reduces the amount of big sage brush habitat lost. If economic and political forces undermine this community, they 

also undermine grouse habitat.

All Both emc0013RM

55. People who ride the range moving cattle or fixing fence have more opportunity to find noxious weed infestations, which 

reduces the amount of sage grouse habitat lost to non-native invasive plants. If economic and political forces remove riders 

from an allotment, the habitat becomes less resistant to invasive plants.

All Both emc0013RM

56. Sage grouse leks benefit from livestock disturbance. If economic and political factors force the ranch to sell out to absentee 

landowners, the lek could be lost.

All Both emc0013RM

57. Much of sage grouse habitat is on private land. If economic and political factors encourage the ranch to try farming, this 

habitat will be lost to the plow.

All Both emc0013RM

58. The RMP needs to acknowledge that the economic benefits of the partnership between ranches and the BLM are also 

ecological benefits for sage grouse.

All BLM emc0013RM

59. Each proposed conservation measure in the EIS should be analyzed in terms of how much it costs and how much the grouse 

population will benefit. The following conservations measures should be included in this analysis:

- Various methods of coyote control.

- Various methods of raptor control.

- Various methods to reduce danger from fences.

- Various methods to reduce danger from vehicle traffic.

- Various methods to protect grouse from disease.

- Various methods to limit exposure to pesticides.

Each method should be rated according to two measures:

1. Number of grouse saved per dollar spent on materials and labor.

2. Number of grouse saved per laborer-hour of time spent.

When considering these measures, the EIS should analyze costs from three different viewpoints:

1. When the BLM employs the person doing the labor;

2. When the BLM contracts with a third party to do the labor;

3. When the BLM encourages ranchers or other partners to perform the labor. Ranchers' time and BLM funds are limited. 

All Both emc0013RM
C. Comments by Resource Planning Issue

C-832 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

The RMP should focus on conservation measures that provide the highest return for the time and money invested.

60. The EIS should study the impact that pesticides might be having on sage grouse in regions where the grouse are not doing as 

well as they are in northeast Montana. The RMP should acknowledge that keeping private land owners in the cattle business 

is preferable to forcing them to try crop-raising methods that might rely on chemicals harmful to sage grouse.

All Both emc0013RM

61. Whenever the RMP considers a course of action that could reduce the economic viability of a ranch, it should also consider 

whether that course of action would harm sage grouse by increasing the likelihood that the ranch would plow prairie, 

overgraze, or sell land to developers to compensate for the lost revenue.

All Both emc0013RM

62. Because big sage brush can be permanently destroyed by fire, any change in grazing should take into account the increased 

risk of fire.

All Both emc0013RM

63. The EIS should estimate how much the coyote population would increase and how much the sage grouse population would 

decrease if the ranches were not putting pressure on the coyote population.

All Both emc0013RM

64. The EIS should identify the ways in which sage grouse benefit from cattle on the range. If this identification cannot be 

accomplished during the planning process, grazing plans should not be altered until the benefits of cattle are understood.

All Both emc0013RM

65. -The EIS should identify ranches where the sage grouse are doing well. Grazing plans on these ranches should not be altered.

- The EIS should identify ranches without sage grouse that could be grouse habitat. Grazing plans on these ranches should be 

changed to make them more like the ranches where grouse thrive.

All Both emc0013RM

66. In areas where sage grouse currently thrive, the RMP should make no changes to current grazing, road use, and 

fire-suppression practices.

All Both emc0013RM

67. The RMP should explore ways to keep ranches grazing the land instead of farming it. All Both emc0013RM

68. The EIS needs to acknowledge that the economic benefits of the partnership between ranches and the BLM lead to 

ecological benefits for sage grouse. The RMP should protect the economics of this relationship.

All BLM emc0013RM

69. I am a rancher in north cental Mt. We live on the milk river and run cattle on red rock creek, as well as Lodge creek, and up

by the Canadian border. Working together with the State, BLM, and our local conservation district we currently have the 

healthiest, most diverse grassland ecosystem in the world. Our sage grouse numbers are very plentiful. We are currently in 

a position where we are able to through the Montana Department of Fish, Wildlife & Parks translocate some of our birds to

Canada.

As a fourth generation rancher on the same homestead, we are facing many hardships keeping the ranching industry up and 

running. I encourage you to look into what has worked well for so many years and maybe model other areas after us. Please 

do not upset the apple cart by trying to change our way of operation that has and is working so well.

All Both emc0014RM

70. In a recent book edited by S. T. Knick and J. W Conmelly on Sage-Grouse research it was stated that most attempts to 

restore sagebrush habitats have been unsuccessful. In fact a noted grouse expert, Dr. Clait E. Braun, stated, "I know of no 

areas where Sage-Grouse have re-established their distribution over significant areas of former habitat," (The Wilson 

Journal of Ornithology, Vol. 123, p 655). What this effort will require will be for you to put Sage-Grouse management 

above all other uses on public lands. This means that grazing of livestock and fences should be eliminated in core 

All Both emc0021RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-833

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Sage-Grouse areas. All types of land fragmentation, such as roads, power lines, wind farms, oil and gas drilling, etc. will have 

to be secondary to the management of Sage-Grouse. I do not have much faith that your agencies will be capable of such a 

drastic turn-around. In fact, BLM planned to study ecological trends in much of the 260 million acre of the West’s grazing 

allotments, but told the scientists not to consider livestock grazing, due to "anxiety from stakeholders." Such attitudes will 

absolutely have to change if there is any hope to save Sage-Grouse and their habitat. The only real solution that I see is buying 

out willing ranchers who graze in core Sage-Grouse areas. As said, both your agencies will have to put the grouse first.

71. The Multiple Use Sustained Act Yield Act requires BLM to manage its lands for "multiple uses," including livestock grazing 

and oil/gas exploration and recovery. Resource Management Plans (RMP) should recognize that sage grouse management 

can be compatible with livestock grazing and oil development. Furthermore, normal activities of multiple uses should be 

allowed to continue until the plan revisions have been made. No activities, such as livestock grazing, should be stopped in the 

interim. Any change in use should follow existing legal procedures for changing such use.

All BLM emc0024RM

72. While sage‐grouse conservation may be a consideration in managed livestock grazing, it should not be the overriding 

consideration. Sage‐grouse should be one management consideration for grazing management, but not the primary one. The 

same is true for range improvements. Sage‐grouse may be considered in making range improvements, but it should not be 

the overriding consideration.

All Both emc0024RM

73. Radio news tells me that policies removing cattle grazing have resulted in the destruction by fire of over 75% of the 

sagegrouse habitat in states to the west of us. The judge responsible for trying to protect sagegrouse by removing grazing has 

decided some grazing may be necessary, but it is a little late. Big sage can take more than 100 years to recover from fire. Do 

not make that mistake!

All Both emc0028RM

74. Historically, sagegrouse numbers were greater in this area during and after a period of extreme overgrazing. At that time, 

the federal government actively poisoned and paid bounties for furred predators. Winged predators were shot by 

homesteaders to protect their chickens. Sage-grouse took advantage of lower predation as did jackrabbits. In 1926, the 

Opheim paper published jackrabbit poisoning advice. In 1936, 12,500 rabbits were reported killed near Opheim

All Both emc0028RM

75. It is possible the overgrazing may have helped the sagegrouse by protecting big sage from fire. It certainly did not seem to 

depress sagegrouse numbers. This overgrazing due to roving graziers of "free grass" was the main reason the Taylor Grazing 

Act was enacted. Next, the BLM was formed and has worked with established ranchers to create the conditions we have 

today. It is a success story that should not be ignored. Do not repeat the mistakes made in surrounding states

and destroy sage grouse habitat.

All Both emc0028RM

76. In the 1960' s, I owned the hay meadows that ran near the B.L.M. foothills. Then these foothills were totally overgrazed. My

hay meadow would green-up after haying. About five o' clock, bunches of sage hen would fly from the foothills onto my 

meadow. We had marvelous hunting! Today, the foothills are only slightly grazed in comparison, the meadow is still

green, but no sage hens. Why? In my humble opinion, the culprit may be the crow. 40 years ago, one would see a crown 

occasionally. Today, there are crows everywhere. Bunches of fifty crows are common.

All Both emc0029GB

77. Curiously, grass may be a limiting factor to the sage grouse numbers. Sagebrush habitat is the ecological home of the greater 

sage grouse. So it is interesting to note, lands with an abundance of grass tend to have less sagebrush. Plus, grass encourages 

large wild land fires which are devastating to sage grouse habitat. We have read stories and seen pictures oflarge numbers of 

All Both emc0029GB
C. Comments by Resource Planning Issue

C-834 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

sage grouse in the early 1900' s. Then, large numbers of livestock also grazed these federal lands. Grass was not in abundance 

then, as it is now. So .. . Why have sage grouse numbers declined? The axiom-more cows... more sage

grouse-Iess cows...less sage grouse; may have merit.

78. ... "the world population is seven billion and growing. Global agriculture production needs to continue growing at a 

significant pace to keep up with demand." so states the 2011 Global Agricultural Report. The report states that we need to 

double agriculture output in the next forty years. What does this mean to federal and state agencies managing our state and 

federal lands? The mind-set of limiting livestock grazing on federal lands need to be reviewed. Pressure will mount to harvest 

as much protein as possible. We need to do our share feeding the people of our world!

All Both emc0029GB

79. I would like to comment on the sage grouse. The decline of the sage grouse in Nevada is a combination of problems. First the 

removal of the beef cow off the range. Cows are fire suppression they also eat grasses leaving room for sage to grow.

All Both emc0031GB

80. 2. Encourage the use of riparian areas by livestock. Sage grouse prefer riparian areas that have been grazed to those that 

haven't. The sage grouse have more succulent grass they prefer, the chicks find bugs easier, and predators are less likely to 

be able to sneak up on them.

All Both emc0032GB

81. Encourage livestock grazing to keep the range from being burned out due to the build up of fire fuels. All Both emc0032GB

82. The petition for listing the Greater Sage Grouse as an endangered species specifically targets two important western 

industries in particular. The energy industry, and the agricultural industry. Both of these industries are vitally important to 

the economy of our western states and vitally important to our small local economies as well. This fact cannot be 

emphasized enough.

While both of these industries bear responsibility to manage their operations to provide for conservation of natural 

resources, we maintain that these industries have demonstrated that they are doing so. The regulatory environment in 

which these industries exist must retain flexibility in order for these industries to survive. The regulatory environment must 

also allow industry leaders and federal agencies the flexibility to develop adaptive management strategies to achieve the 

appropriate balance between the increasing demand for resources and conservation objectives.

All Both emc0032RM

83. The petition for listing clearly blames the livestock industry as the primary cause of all ecological issues surrounding the Sage 

Grouse. Past grazing practice may have not been optimal for conservation, nor for profitable livestock production, however 

modern livestock management embraces a scientific understanding of how grazing modifies the environment it occurs in and 

that knowledge is applied to an adaptive management strategy. Properly managed, grazing poses no significant threat to Sage 

Grouse habitat. In contrast when grazing is used as a management tool along with vegetation management, it can be 

effectively used to improve sagebrush habitat and livestock forage alike.

All Both emc0032RM

84. Ironically, Sage Grouse numbers were highest during the 1920's and 1930's when livestock stocking rates were also at their 

highest numbers. Part of the reason Sage Grouse were doing well at the time, despite very intensive grazing, is that predators 

were kept in check. Today we have very little predator control. In fact in Colorado leg hold traps are illegal, and predator 

hunting is at an all time low. Predator control must be a part of any recovery plan.

All Both emc0032RM

85. West Nile virus, which is linked to standing water associated with some forms of energy development and agricultural water 

use, also poses a threat to greater sage-grouse in the Eastern Region. Naugle et al. (2004) showed that up to 25% of a 

All Both emc0034RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-835

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

population may die due to West Nile virus. The BLM produced an Information Bulletin (MT-2011-033) regarding best 

management practices to reduce the availability of breeding grounds for mosquitoes that carry West Nile virus. We 

recommend that these best management practices be implemented across BLM lands and particularly in sage-grouse core 

areas to prevent the death of this species. WWF has also produced, along with partners at the University of Wyoming, a 

spatially explicit map showing where West Nile virus is most likely to become prevalent under climate change conditions 

(Schrag et al. 2011). Areas with a high threat of West Nile virus (areas coded in yellow, orange and red in the figure below)

that are located within core areas should be prioritized for reduction of standing water and other factors that increase the 

likelihood of becoming Culex mosquito breeding grounds. *Included an attachment (Figure 4)

86. In addition to energy development and disease, sagebrush-steppe habitat quality may be impacted by grazing practices, 

invasive species and resulting changes in the frequency and severity of fires.

All Both emc0034RM

87. The Y‐3 II Ranch (the “Ranch”) headquartered just south of Jackpot, Nevada has fee ground and grazing allotments adjacent 

to each other in southern Idaho (the allotments are within the BLM areas served by both the Jarbidge and Burley Field 

Offices) and northern Nevada (the allotments are within the BLM area served by the Elko Field Office). Therefore, the Ranch 

falls within both the Nevada/ NE California and the Idaho/ SW Montana subregions.

Cattle are constantly moved between these pastures and allotments in Idaho and Nevada during the grazing season. One of 

our concerns is the consistency among the RMP’s that will be adopted for these land use planning areas. In other words, we 

don’t want to be subject to significantly different rules and regulations simply because our cattle have crossed the 

Idaho/Nevada border. Please take situations of this sort into consideration when addressing proposed Records of Decision 

and RMP Amendments for sage‐grouse within both the Nevada/ NE California and the Idaho/SW Montana sub‐regions.

All Both emc0037GB

88. How does livestock grazing, at various levels and at various timing configurations, influence:

1) vegetative structure and its effectiveness as sage grouse hiding cover from predators,

2) vegetative composition, especially in brood rearing areas (riparian), and the resulting impact on the abundance/ availability 

of insects to young grouse,

3) vegetative structure as it may affect the distribution and behavior of aerial and ground predators...And their consequent 

predatory efficiency in taking sage grouse.

All Both emc0041GB

89. Public lands are for public use, and that means public lands must be managed for multiple use. I am definitely in favor of 

conservation measures for sage-grouse such as managing for sagebrush, water developments to improve habitat, proper 

planned grazing, etc. However, we must be careful to not manage the public lands for one species or one purpose. For 

example, to eliminate livestock grazing in favor of sage-grouse conservation would not only be a bad biological decision (i.e. 

poor plant health, increased fire risk, etc); it would also go against the basic theory of multiple use.

All Both emc0043RM

90. The sage grouse population is NOT impacted by grazing, current roads, or energy factors. (I never saw a cow kill a grouse). All Both emc0052RM

91. US Fish and Wildlife has identified grazing as one of the threats to sage grouse. However, very little research has been done

to identify those threats, or to look at possible benefits that livestock grazing might have on sage grouse and sage grouse 

habitat. Even Connelly, et al., (2000) admitted, "There is little direct experimental evidence linking grazing practices to sage 

All Both emc0054GB
C. Comments by Resource Planning Issue

C-836 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

grouse population levels."

92. Livestock grazing may be the most compatible human activity in sage grouse habitat. Evidence for this can be inferred from 

the fact that livestock grazing is the primary human activity in the habitats of the only three populations of greater sage 

grouse in Utah that are considered sufficiently healthy to be hunted by the Utah Division of Wildlife Resources. These are 

Parker Mountain, Rich County and Diamond Mountain. Habitats, e.g., Strawberry Valley, where grazing has been largely 

curtailed for years and which have become primarily used for recreation no longer support huntable populations.

All Both emc0054GB

93. My concern is that if grazing is restricted unreasonably on BLM or Forest Service lands then grazing permittees and private 

landowners may sell out to recreational users whose activities may be more detrimental to sage grouse than grazing.

All Both emc0054GB

94. I'm also concerned that grazing practices may be prescribed that may do more harm than good. For example, some think 

that intensively managed grazing may be less of a threat than large pastures where cattle graze for longer times. But if 

additional fencing is required to accomplish the grazing management objectives, the negative effect of fencing could more 

than offset any positive effect of increased grazing management. The point is that there is a lot of interaction between factors 

and we don’t know very well how various practices will impact sage grouse. Therefore, much caution should be applied to 

making changes to current grazing practices where the healthiest populations of sage grouse now exist.

All Both emc0054GB

95. I agree with the NTT document that with best management practices, the grazing of livestock has little to no effect on 

sage-grouse, and could actually improve the habitat. As the NTT document states, "proper livestock management can assist 

in meeting sage-grouse habitat objectives and reduce fuels".

All Both emc0064RM

96. Livestock grazing can degrade habitat, rendering it unsuitable for Greater Sage-grouse. We therefore advocate consistent 

management standards throughout the Greater Sage-grouse’s range, based on the best available science and following the 

recommendations of the National Technical Team.

All Both emc0068GB

97. We advocate the creation of sagebrush reserves, preserving the best remaining habitat, and a voluntary program for 

ranchers to turn in their grazing permits in exchange for compensation paid for by conservation groups.

All Both emc0068GB

98. This scoping exercise has been brought about by litigious extremists that want to remove livestock grazing from the public 

lands of the West and are using the declining numbers of sage-grouse as their weapon via the ESA.

All Both emc0070GB

99. Wildfire and its extent are directly related to fuel loading and the absence of fuelbreaks. The only realistic tool the agencies 

have in reducing the fuel load is through a well managed grazing program. Wildlife will not adequately harvest fuels and 

manual removal is cost prohibitive. Grazing public land is essential if wildfire is to be minimized. Prescriptive grazing can be 

a tool that could be used to break up fuel loads. There are lots of grazing options. Designed fuel breaks using existing 

infrastructure and promoting fire resistant vegetation that is strategically located is important.

All Both emc0070GB

100. Much of the rangeland in sagebrush habitat is made up of intermingled ownerships fashioned into functional grazing units via 

the Taylor Grazing Act and more recently NRCS programs. The management of these lands can only be successful if the 

private landowner is included. They have the work ethic, the physical contact with the land, the knowledge of site specificity, 

the longevity and ability to work a management plan, and can serve as a vehicle to secure many kinds of funding that the 

federal government is not eligible for as a single entity.

All Both emc0070GB

101. As one drives through the millions of acres of open space in the west, you wonder who takes care of all this land. It is neither All Both emc0070GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-837

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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Agency CmtLtrCode

the government nor the environmental community; it is the rancher whose house is out of the wind and out of site. The west 

does not have another management option. Be careful of what you regulate as a result of this scoping process.

102. In many cases grazing permitee’s Taylor Grazing dollars or other non-federal funds have paid for range improvements. What 

analysis will be included in the EIS to assure the continued availability of these funds are not prohibited or reduced by the

outcome of the EIS?

All Both emc0071GB

103. A possible new strategy to include for analysis might be to do a complete review of the positive impacts that ranching, 

grazing, Taylor Grazing projects, Boy Scout projects and etc. have on the ground to the benefit of Sage Grouse habitat and 

include them in the EIS. This may provide the opportunity to expand on this type of project in any alternative at the end of 

this work.

All Both emc0071GB

104. We are very concerned about the domestic livestock grazing systems authorized by many of the administrative units of the 

Bureau of Land Management (BLM) and U.S. Forest Service (USFS). Greater Sage-Grouse require sufficient cover for nesting 

(April and May), brood rearing (May, June, July) and survival, and it is our opinion that few grazing systems authorized by 

these administrative units provide adequate cover for these activities and during these times of the year to ensure sufficient 

reproductive success for Greater Sage-Grouse. Without adequate cover for nesting and brood rearing, it is our opinion-and 

the professional opinion of many scientists-that Greater Sage-Grouse populations will continue to decline throughout their 

range.

We believe that nearly all grazing systems need to incorporate adequate rest or very low livestock stocking rate (>35% 

annual utilization) to enablethe native vegetation to maintain its health and vigor and to provide adequate cover for Greater 

SageGrouse and other grassland/shrubland birds. To provide for successful nesting and brood rearing, good cover is needed 

in the spring from the previous years growth and in the spring and summer from the current years growth. Even with less 

than 35% utilization, many areas near water sources can be overgrazed and ultimately provide poor nesting and 

brood-rearing success.

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105. Recommendation #1 - We recommend that the BLM and USFS require all related administrative units to modify their 

respective livestock grazing permits and grazing allotment management plans to incorporate grazing systems that provide at 

least 15-month of rest every 3 years for each grazing pasture or require immediate removal of livestock once a 35% 

utilization level is reached within any given year on federal public lands under their prevue.

All Both emc0074GB

106. Livestock-free portions of our Greater Sage-Grouse range may be necessary to ensure viable populations are maintained in 

otherwise disturbed landscapes, particularly in conservation priority (core) areas. We believe that closing these areas to 

livestock grazing through the permanent retirement of existing grazing permits should protect them from the risk of 

overgrazing, greatly reduce the risk of invasion by undesirable vegetation (invasive plants), and enable federal land managers 

to compare these lands to other grazed areas, enabling them to better evaluate the effects of livestock grazing on these 

sagebrush ecosystems and Greater Sage-Grouse populations.

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107. Recommendation #2 - We recommend that the BLM and USFS retain retirement of grazing privileges as an option in priority 

conservation (core) areas for Greater Sage-Grouse when base property is transferred or the current permittee is willing to 

retire grazing on all or part of an allotment.

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C. Comments by Resource Planning Issue

C-838 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

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108. Water can be a critical factor in determining the abundance and distribution of wildlife, especially in arid western 

ecosystems; although the impacts vary by species, habitat, and season. Over the past 150 years, the availability and 

distribution of water have been drastically altered by both natural processes and human actions. By some estimates, 95 

percent of natural riparian ecosystems (those associated with water features) and wetlands in the arid West already have 

been degraded or lost. We believe the loss of natural water resources threatens Greater Sage-Grouse population viability, 

but we realize domestic livestock also require water to survive.

Federal public-land managers and ranchers have improved existing water supplies and developed new water systems for 

livestock and wildlife. Hundreds-of-thousands of these water developments are scattered across the western U.S. Water 

developments increasingly replace or augment diminishing natural sources in many areas and have become crucial for many 

species, especially Greater SageGrouse when stressed by drought, high temperatures or rearing young. These water sources 

and associated moist-soil (riparian) habitats are critical for Greater Sage-Grouse survival and reproduction. Springs, 

wetlands, seeps, wet meadows, bogs, fens, ephemeral and permanent streams, rivers, ponds, stock tanks and lakes all serve 

as or are surrounded by crucial habitats for Greater Sage-Grouse and other wildlife in the arid West. We believe that all 

water sources and associated moist-soil habitats on federal public lands should be protected from the effects of livestock 

disturbance and grazing. In most cases, livestock drinking water can be transported away from water sources and riparian 

habitats to sites that are not in limited supply and that are more compatible with livestock disturbance and grazing.

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109. While Greater Sage-Grouse depend on livestock troughs and tanks for water, they also can drown while attempting to drink 

or bathe in these structures. It is a common practice to temporarily shut off water to tanks and troughs when livestock are 

moved, forcing Greater Sage-Grouse and other wildlife that have become dependent on that water supply to find 

alternative-often distant-sources or perish. This is particularly harmful during the warmest months when Greater 

Sage-Grouse are rearing young. We believe that preventing wildlife fatalities at water troughs not only conserves Greater 

Sage-Grouse, but also helps maintain the clean, uncontaminated water that is critical for any livestock operation. Decaying 

animal carcasses greatly diminish water quality.

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110. The need for wildlife escape structures (also called wildlife ramps or bird ladders) in troughs and tanks has been 

documented. Most livestock water troughs were not designed or installed with Greater SageGrouse in mind, and they 

seldom include a means of escape for wild animals that fall into the water while attempting to drink or bathe. These animals 

drown unless a properly-designed and well-placed escape structure is available. Wildlife drownings increase when 

alternative water supplies are unavailable and escape structures are absent, especially when water levels are lowest and 

during periods of drought, high temperatures and wind. Tragically, some of the most common attempts to provide wildlife 

escape structures do not work or are unreliable.

Effective wildlife escape structures are easy and inexpensive to build and install and can eliminate Greater Sage-Grouse 

mortality in water troughs and tanks. Properly designed and installed, these structures also improve livestock health by 

maintaining clean water that's uncontaminated by drowned Greater Sage-Grouse or other wildlife.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-839

Scoping Summary Report

Table C-6.A

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111. Recommendation #4 - We recommend that all troughs and tanks with vertical or nearly vertical sides be modified with 

escape structures and that high water levels in these troughs and tanks be maintained throughout the year.

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112. With regards to grazing rights on BLM lands, the BLM will honor existing contracts. However, once said contracts are set to 

expire, if grazing should fall within the 5.5 mile radius of a lek, regardless of its activity designation, the BLM will make it 

mandatory for BLM offices to, “...consider the conservation measure(s) [of the Greater Sage Grouse] to the fullest 

extent...” when considering grazing permit renewals. Understanding this could cover large tracts of previously leased lands 

to grazing permits, I argue the BLM has faulted on the preservation and enhancement of the Greater Sage Grouse, therefore 

contributing to its current ESA status.

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113. Livestock grazing is one of the most significant management practices affecting sage grouse, partly because grazing is such a 

widespread practice with far-ranging effects on vegetation height and density affecting cover for sage grouse, as well as 

palatability and nutritional quality of forbs utilized by grouse chicks. Grazing also has numerous undesired side-effects such 

as weeds, roads, fences, non-native seedings, and water developments. The EIS must address specific standards for 

sage-grouse friendly grazing practices, including fewer animals, shorter grazing seasons, more rest, closed allotments, and 

curtailment of the side effects of fences, roads, weeds, etc.

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114. The EIS should address the conflict between the common practice of adding fencing to grazing allotments, which is perceived 

to improve livestock management, but is also adverse to sage grouse. What criteria can help resolve this conflict?

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115. Ranchers and farmers live in these beautiful, rural areas. We try to be good stewards of the land we use. A lot of it we share 

with many others with the same values.

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116. Although livestock grazing is the highest and best use for much BLM land, many areas of public land managed by BLM grazing 

land could easily be better managed for wildlife. On some BLM land, decades of livestock use has continued to depress game 

habitat as clearly evidenced by adjacent right of way and sometimes adjacent private land sagebrush, greasewood, and habitat 

cover.

Habit studies have rarely appeared to change actual use. Certainly cost feasibility prohibits fencing off or separating many 

small areas of riparian or other critical habitat. However, many areas exist where habit can be significantly protected without 

major effects on livestock permit numbers and, in considering minimal grazing fees, certainly without significantly impacting 

income from public lands. I also believe that through the years the oversight and field reviews by range staff has varied greatly

between different BLM areas.

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117. Although any increase in grazing costs will meet with objections, a moderate raise is so long overdue that it is difficult to 

imaging a sound basis for continued objection. Better care of public high wildlife habitat value and riparian areas including

some additional fence and water development with emphasis on wildlife habitat will also encounter some objections. 

Although I believe that sage grouse numbers remain well above the threshold of endangerment or seriously threatened 

species and will remain so, the simple suggestion alone that such designation is possible should be a great embarrassment to 

an agency trusted with management of the public's lands. It is time for simple and logical management adjustments, not 

studies.

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118. RANGE MANAGEMENT

ISSUE: The proposed Conservation Measures fail to include a discussion of the conversion of sheep dominant grazing to 

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C. Comments by Resource Planning Issue

C-840 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

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cattle dominant grazing on public land in the Great Basin and possibly Colorado Plateau as being a potential indirect 

herbivory impact on sage grouse and their habitat.

In Nevada and throughout much the West, there has been a shift in the dominant domestic livestock grazer on public and 

USFS administered lands. Not long ago, domestic sheep were the most common permitted livestock on grazing allotments 

in the Great Basin and Colorado Plateau physiographic areas. Domestic sheep closely mimicked the predominant historic 

grazer – wild bighorn sheep. Economic and other factors caused the gradual switch to cattle. This has and will have an 

important effect on the rangeland with sage grouse habitat.

Cattle select grasses and forbs as the preferred forage. Cattle often stay in one area, eating until the understory is gone, or 

the cattle are removed. Under cattle grazing over time, rangelands become dominated by “increaser” shrubs and 

encroaching woodlands as “decreaser” understory species are used. Domestic sheep however, eat little bits of grasses, 

forbs, shrubs and small pinyon-juniper trees that can keep a vegetation community more balanced. Additionally, domestic

sheep are herded daily and can easily be rotated throughout a pasture / allotment. Cattle are occasionally pushed, certainly 

not daily, and often return to an area already grazed. Old-time sheep producers followed a practice for grazing their sheep 

of “once over, lightly”..

Domestic sheep grazing may assist in maintaining sage grouse food items such as ants and certain forbs for chicks. In eastern

Nevada, when the majority of grazing allotments had domestic sheep rather than cattle (pre-1980-90’s), sage grouse 

numbers were strong and fluctuated within a normal range. No studies to date have tried to prove a correlation between 

historically higher numbers of sage grouse (at least in Nevada) and predominance of domestic sheep grazing. The possible 

correlation exists as grey science and historical anecdotal information that just might be true. A recommendation should be 

made to favor domestic sheep grazing over cattle when possible and disallow conversion of an existing domestic sheep 

permit in sage grouse habitat unless no other option exists.

119. ISSUE: The proposed Conservation Measures need to include yearlong livestock herbivory in the Great Basin and Colorado 

Plateau as being a direct impact on sage grouse and their habitat. There are currently several livestock grazing allotments, 

with Nevada as an example, that have permits and allotment plans which allow yearlong grazing in some of the most fragile 

sage grouse habitat areas. In theory, livestock are rotated through pastures within the allotment during the year. Rotation 

rarely occurs due to permittee negligence *or is in practice, unworkable due to the topography / elevation of the allotment. 

While yearlong grazing may be sustainable in Montana and Wyoming at lower elevations due to summer precipitation which 

allows plant re-growth in summer, it is not acceptable in Nevada and other arid areas that are winter precipitation 

dependent. This is especially true where cattle now graze rather than domestic sheep for the reasons stated in the preceding 

narrative.

* In at least one 500,000 acre+ allotment in Nevada, where sage grouse used to be plentiful in a domestic sheep allotment, 

sage grouse are now seen only occasionally. The current permittee proudly states that his cattle search out forage all over 

the allotment yearlong. He is also proud of his cattle knocking down “overgrown” riparian areas along the allotment’s only 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-841

Scoping Summary Report

Table C-6.A

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creek so that both his livestock and wildlife can water. A few sage grouse still use the creek. There is no attempt made to

enforce the allotment management plan for rotating livestock on this yearlong grazing allotment much less any attempt to 

enforce vegetation standards.

120. ISSUE: The proposed Conservation measures need to include class of livestock, i.e. cow / calf pairsopposed to yearlings / 

steers, as being an indirect herbivory impact on sage grouse and their habitat. For a variety of reasons cattle may continue 

to be the dominant permitted grazer. The kind of cow that grazes is important to sage grouse habitat. Rangeland managers 

and livestock producers know that cow / calf pairs use a grazing allotment differently than steers, particularly yearlings. Cows 

tend to remain in gentler topography and nearer water which in Nevada means areas with riparian areas. Stockmen tend to 

not push pairs into rougher country. Use levels on riparian areas and bottom lands are met quickly – often well ahead of the 

AMP’s “off” date. When this occurs, pairs often remain in the pasture or allotment for a variety of reasons; utilization levels 

are exceeded, riparian / range conditions change or deteriorate. Conversely, steers will travel farther within an allotment to 

seek forage and can be pushed into rougher country. Yearling animals exhibit a natural curiosity that helps disperse these 

animals better and they can be pushed further into rougher country. A recommendation to favor yearlings / steers in sage 

grouse habitat should be made.

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121. ISSUE: The proposed Conservation Measures contain a glaring inconsistency in how measures are written depending on the 

political volatility of certain programs. Many of the proposed Conservation Measures are written in very strong language 

using words such as “avoid”, “do not allow” etc. The glaring exception to this is the politically charged range program. 

Conservation Measures in that program are the same ones that have been written into LUPs for years. As proposed, these 

will be re-stated as something that should be “considered”. The reason for the inconsistency would be that “we need 

long-term studies” to make definitive recommendations. Range studies have been going on for years and the conservation 

measures can be written only as suggestions? One wonders how we can be so certain of impacts caused by programs with 

a relatively short history and use such strong language in the recommendations for those. The Measures language should be 

standardized at least for the basic management practices – we do know those for healthy range vegetation.

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122. Limits on road access do not necessarily reduce cattle grazing, and grazing reduces floristic diversity that supports sage 

grouse. In addition to road limitation, therefore, cattle grazing limitation is needed until areas of poor grouse habitat quality

are identified, at which time grazing may be allowed or re-allowed in these areas. There are other places to grow cows, but 

sage grouse grow only here.

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123. The Report identifies several potential impacts to sage-grouse from grazing; however, the discussion, fails to put into 

perspective that many of these impacts are not just livestock related. Plant communities change over time, with or without 

grazing, and when the plant communities are not managed concomitantly with grazing, the changes discussed in the Report 

can occur. BLM and the FS have the responsibility for managing vegetation on public lands, and vegetation management based 

on the ESDs, and State and Transition Models (STMs) for each ESD should be implemented as part of any conservation 

measures. Without appropriate vegetation management, the ability of the ecological sites to support sage-grouse 

populations will not be maintained.

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124. The Report's assumption that retiring grazing privileges will improve habitat for sage-grouse is also unfounded. As 

mentioned above, management of both the vegetation and grazing is required to ensure that viable sage-grouse habitat is 

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C. Comments by Resource Planning Issue

C-842 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

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provided. Moreover, where grazing privileges are retired, the base property (i.e., private fee lands) is likely to be used for 

other uses, such as commercial development, vacation homes or rural homesteads. The BLM must consider the potential 

impacts of such uses in any analysis of future grazing restrictions.

125. Reduce livestock grazing (cattle, sheep and wild horses) as necessary to restore depleted sage-grouse habitat. Grazing 

permits should be revised to reflect acceptable stocking rates for compatibility with sagegrouse.

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126. Grazing receives five pages of summary discussion, much of which seems to stand in contrast to pioneer records, ranchers’ 

histories and current resident witness to sage grouse life cycle, habit and extent. The discussion does not reflect the 

measured and diligent statement of Nevada Assemblyman Ira Hansen (2011).

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127. Research has shown that properly managed grazing improves habitat for ground-dwelling birds, such as sage grouse 

(Sage-Grouse ((Centrocercus Urophasianus)) Use of Different-Aged Burns and the Effects of Coyote Control in 

Southwestern Wyoming by Steven J. Slater). In sage brush areas, sheep crop the brush to a height favored by sage grouse, 

leaving it neither to course nor too sparse. In addition, grouse (and other prey species, such as deer) tend to be more 

abundant in areas, private and public, where sheep are grazed, due to predator control.

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128. Research has shown that properly managed grazing improves habitat for ground-dwelling birds, such as sage grouse 

(Sage-Grouse ((Centrocercus Urophasianus)) Use of Different-Aged Burns and the Effects of Coyote Control in 

Southwestern Wyoming by Steven J. Slater). In sage brush areas, sheep crop the brush to a height favored by sage grouse, 

leaving it neither to course nor too sparse. In addition, grouse (and other prey species, such as deer) tend to be more 

abundant in areas, private and public, where sheep are grazed, due to predator control

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129. My primary concern is the loss and degradation of habitat caused by incompatible uses. This includes extraction of energy 

sources and the grazing by livestock. Recent increases in the amount of federal lands that have been opened to oil and gas 

drilling has lead to loss of large patches of grouse habitat. Degradation from over‐grazing and grazing in an appropriate areas 

has destroyed thousands (millions??) more acres. Both of these activities need to be better managed and monitored, or 

better yet, not even allowed in Greater Sage‐grouse habitat.

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130. According to BLM Instruction Memorandum (IM) No. 2012-043 and as summarized in the BLM’s National Greater 

Sage-Grouse Planning Strategy, emphasis for protecting and managing greater sage-grouse habitat incorporates the following 

primary principles:

1) Protection of unfragmented habitats;

2) Minimization of habitat loss and fragmentation; and

3) Management of habitats to maintain, enhance, or restore conditions that meet greater sage-grouse life history needs.

Livestock grazing contributes positively to the above primary principles, being both compatible with and beneficial to greater 

sage-grouse habitat conservation. Resource users such as ranchers are the stewards of the greater sage-grouse habitat on 

both the private and public land they use. Ranchers provide an outstanding line of defense against

fire and noxious weeds. Ranchers typically manage forage for optimum production, and are the primary providers of private 

land open space in Wyoming. Without livestock producers utilizing and protecting private lands of the west, large areas of 

greater sagegrouse habitat would be in jeopardy. The benefits provided by ranching relate directly to several identified 

threats to greater sage-grouse habitat, including wildfire, invasive plants, and predation.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-843

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131. As recognized by the BLM in IM No. 2012-043, grazing can be “used as a tool to protect intact sagebrush habitat and increase 

habitat extent and continuity which is beneficial to [the] Greater Sage-Grouse and its habitat.” The IM continues, “Given the 

potential financial constraints in addressing the primary threats identified by the FWS, enhanced

management of livestock grazing may be the most cost-effective opportunity in many instances to improve Greater 

Sage-Grouse habitat on public lands.” According to Natural Resources Conservation Service (NRCS), grazing “has been 

responsible for retaining expansive tracts of sagebrush-dominated rangeland from conversion to cropland” and can

“stimulate growth of grasses and forbs, and thus livestock can be used to manipulate the plant community toward a desired 

condition.”

Sound defensible scientific research indicates that grazing is beneficial to the greater sage-grouse and other flora and fauna 

in multiple ways. Grazing reduces the instances and severity of wildfires. (Launchbaugh et al.2007). It improves greater 

sage-grouse habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et al.1994, Evans 

1996). It has also been used to control invasive weeds (Olson and Lacey 1994, Walker et al.1994).

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132. Services provided by livestock producers can only be furnished when those producers are viable in the long run. The best 

strategies land management agencies can use will be those that are workable for livestock producers and the greater sage 

grouse. Reducing livestock grazing will not work as a strategy. Reducing livestock grazing would increase pressure on private 

lands and could reduce the viability of livestock producers. This reduction of viability could reduce the private land greater 

sage grouse habitat.

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133. Livestock grazing is compatible and beneficial to greater sage-grouse habitat conservation. Livestock producers are the 

stewards of the greater sage-grouse habitat on both the private and public range lands. Allowing livestock producers the 

continued use of public lands without unnecessary restrictions due to the potential listing of a species with such a large 

habitat encourages this stewardship and prevents fragmentation through development. As seen in many areas of successful 

rangeland conservation, livestock grazing and habitat conservation go hand in hand.

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134. I also want to know the real impact of public-land domestic grazing on this and other wildlife species, be it good, bad or 

indifferent - the truth needs to be known.

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135. Consider complete removal of livestock if net primary production is less than 200lbs/acre (Connelly, J. W., M. A. Schroeder, 

A. R. Sands, and C. E. Braun. 2000. Guidelines to manage sage grouse populations and their habitats. Wildl. Soc. Bull. 

28(4):967-985);

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136. Remove all unnecessary structures, including livestock management facilitating structures (e.g. fencing, and watering 

facilities), roads, buildings, trees, cell towers, power lines, haystacks, old farm equipment etc. from all priority areas.

Only add new structures if it can be demonstrated that their habitat improvement value to GSG outweighs the potential 

costs to GSG; and

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137. Provide site-specific information on all Leks to the permittees for grazing adjustments within the existing RMPs. There 

should be a stated ability to adjust season of use, timing, and rest rotation within current authorized allotments to address 

specified Leks, even if they don’t follow the BA. The only option shouldn’t be reduced grazing alternatives, especially when 

there is compliance with land health standards.

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C. Comments by Resource Planning Issue

C-844 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

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138. Grazing - Interim Management Policies and Procedures (IMPP) In the memorandum No. 2012-043, dated 12-27-11, it states 

that this IM is “...to be applied to ongoing ... authorizations and activities..” “....across multiple programs, in order of threat 

magnitude, while the BLM considers amendment or revisions to LUPs.” It continues to discuss the various policies and 

procedures related to specific actions and relationship to grazing:

1. Livestock Grazing Management Plans: Grazing is number 6 on the list of threats with a relative rank of 45 they provide the 

greatest visibility and generate the greatest judicial action, therefore are perceived as having the largest impact. Fully 

implemented “Managed Livestock Grazing plans’ meet the three most critical requirements for Habitat viability

a. Impacts

i. Time duration

ii. Timing season

iii. Frequency

iv. Intensity of grazing

b. Management of plant succession

i. Grazing

ii. Fire

iii. Chemical treatment

c. Land Health Standards

i. Grazing management practices – plan

ii. Replace scarcity mentality with multiple use and abundance mentality

iii. ‘Science based’ – diverse team members, i.e. Utah Grazing Improvement project.

iv. State and local leadership – defined based on the ground participation

v. Provide ‘political coverage for the right management decisions.

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139. Grazing, a Habitat Enhancement Tool: While it is noted that “... grazing practices can also be used as a tool to protect intact 

sagebrush habitat and increase habitat extent and continuity which is beneficial to Greater Sage-Grouse....” The IMPP 

approach addresses “....localized adverse effects...” and places an undue constraint and burden on Public Land grazers due 

to “... the potential financial constraints in addressing the primary threats identified by the FWS, enhanced management of 

livestock grazing may be the most cost-effective opportunity ...to improve...habitat..” While the connotation is not 

necessarily negative, previous efforts at range improvements have been constrained:

a. The funding for improvements has been limited in regards to fencing, water facilities, and etc. While additional funding has 

been appropriated, BLM officials indicate a large percentage of it will be directed towards NEPA review and monitoring, 

justifiably so. Even with NRCS funding, there needs to be additional funds for ‘on the ground’ projects. The limitation to the 

state plan [referenced above] was the lack of funding.

b. When funding is available, or permittees are willing to provide, the agency is limited due to a lack of a biological 

assessment. There needs to be a defined set of permissible actions that can occur to facilitate improvements within the IM 

and once NEPA is complete.

c. The ‘Wildfire Suppression and Fuels Management’ section of the IMPP doesn’t mention Sage Brush stripping; there are 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-845

Scoping Summary Report

Table C-6.A

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numerous PPH that need sage treatment to increase the viability of forbes, grasses, and sage health. Numerous allotments 

are overgrown, limiting the native vegetation and vigor of the sage. All methods and alternatives to improving range health, 

a critical part of ‘Managed Livestock Grazing Plans’. (see Utah Grazing Improvement Project, Mr. bill Hopkins)

140. Grazing Alternatives: Within the range of alternatives needs to be broadened to include the consolidation of adjoining 

allotments to ‘super grazing allotments’, which will allow full utilization for grazing for all permittees while providing for 

deferred and/or rest-rotation grazing, allotment treatments of junipers, sage, and native grasses.

a. With a ‘no grazing alternative’ considered, the NEPA document needs to address the micro socio-economic impacts on 

the community not just the usual macro considerations. “The council on Environmental Quality's (CEQ's) Regulations for

Implementing the Procedural Provisions of the National Environmental Policy Act (40 CFR 1500-1508) point-out that

the "human environment" is to be "interpreted comprehensively" to include "the natural and physical environment and the 

relationship of people with that environment" (40 CFR 1508.14). Agencies need to assess not only so-called, "direct" effects, 

but also "aesthetic, historic, cultural, economic, social, or health" effects, "whether direct, indirect, or cumulative" (40 CFR 

1508.8).

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141. With respect to Retirement of Grazing Privileges on page 17 of the NTT Report,

- "Maintain retirement of grazing privileges as an option in priority sage‐grouse areas when base property is transferred or 

the current permittee is willing to retire grazing on all or part of an allotment. Analyze the adverse impacts of no livestock 

use on wildfire and invasive species threats (Crawford et al. 2004) in evaluating retirement proposals.

- Planning direction Note: Each planning effort will identify the specific allotment(s) where permanent retirement of grazing 

privileges is potentially beneficial." Several options are potentially available for creative grazing administration. Although this

section is specific to Retirement of Grazing Privileges and specific allotments in high priority habitats, presumably it does not 

preclude active pursuit of retirement of grazing privileges in non-priority areas so that grazing privileges in the priority 

habitat could be shifted to the non-priority areas. Is that interpretation accurate?

The challenge for the BLM is to be able to "think outside the box" programmatically and be open-minded about innovations 

that might be proposed. With regard to the upcoming EIS process, this presents a situation where Headquarters Office 

guidance seems warranted regarding the nature and scope of potential grazing and grazing administration modifications that 

might be analyzed in the EISs, perhaps even addressing things like non-use and suspended non-use. Some innovations could 

necessitate changes in either regulation or law that could represent marked departures from the BLM's historical and 

agency-culture approach to management. Clearly, statutory and regulatory changes would not be achievable prior to

the EIS process being fully underway. However the effects of some proposed changes could be analyzed in the EIS as to how 

they would facilitate BLM achieving it goals and objectives. Although it could be argued that such considerations are not 

within the scope of this particular EIS effort, I would disagree. Since EISs are supposed to seriously consider all reasonable 

alternatives, this presents a high-profile opportunity to do just that, and in the process lay the foundation for pursuing 

reasoned and reasonable changes, including legislative and regulatory. The National Resource Advisory Council could serve

as a valuable "sounding board" for any such proposals.

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C. Comments by Resource Planning Issue

C-846 Greater Sage-Grouse LUPAs/EISs May 2012

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EIS analysis of these and other changes would provide a building block for longer-term changes that could help the BLM 

succeed in its "new paradigm" endeavor. One example of a programmatic proposal is for the BLM to initiate a long-term 

infrastructure reduction program on pubic lands as a means of enabling landscape healing and attendant defragmentation of 

habitat. The effects of such a program could be analyzed, with each EIS identifying areas suitable for infrastructure reduction. 

Although fences are the primary consideration here, other infrastructure could be considered. As a tool for recovering 

habitats, the concept of infrastructure removal to improve habitats has historic significance. Recent examples that are part 

of long-term restoration programs include American Prairie Reserve fence removal (American Prairie Foundation)

and dam removals to restore fisheries. Coincidentally, the current header photo on the American Prairie Foundation home 

page features greater sage-grouse. Thinking outside the box in support of the new paradigm.

With respect to the "Planning direction Note," presumably the habitat to be conserved by retiring grazing would either be 

of reasonably high quality, robustly resilient and highly resistant to change, or classified through the HAF as 

potentially-suitable and likely to respond fairly quickly from discontinued grazing, otherwise it would seemingly be a low

priority for discontinuing grazing. Is that an accurate characterization?

With respect to the phrase "potentially beneficial," it would be useful to present some general criteria that may be used in 

making such determination. What is the time frame for achieving benefits from cessation of grazing? Given the length of time 

it takes lowerprecipitation habitats to demonstrably change after grazing is removed, some benefits might not be achieved 

for decades. Could the removal or substantial modification of infrastructure be a consideration in making the "potentially 

beneficial" determination? It certainly seems so.

Any EIS analysis of grazing privilege retirements to improve sage-grouse habitat would seemingly address associated 

socio-economic impacts. Although this EIS effort is not the most appropriate venue for an economic analysis of federal 

agency grazing fees and how they affect use of the land, it seems appropriate to incorporate a discussion comparing

federal grazing fees and those charged for state and private lands, particularly as they may relate to grazing privilege 

retirement.

142. 19) Comment: Range suitability, "expected use"- Incorporate land slope considerations (range suitability, "expected use") 

into all proposed management actions and projects. Delineate such gradients for all allotments within both occupied and 

suitable but unoccupied sage-grouse habitats. This information will help better determine how habitats would likely respond 

to changes in grazing.

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143. My hope is that all attempts to enhance the sage grouse habitat are kept reasonable and sensible. My concern is for the 

welfare of the farmers and ranchers that could potentially be affected in their public land allotments. Ranchers haven’t been 

doing much different in their continuing operations and should not be blamed unduly for the decrease in habitat for the sage 

grouse. Ranchers have been grazing public lands for over a century and not until just recently has the habitat been an issue.

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144. The EIS must take an honest look at the impact of cattle grazing on the public lands in regard to the sage grouse. Is grazing 

destroying the nesting cover under sagebrush to such a degree that sage-grouse populations are negatively impacted? Can 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-847

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

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Agency CmtLtrCode

healthy sage-grouse populations exist in grazing areas? The analysis should also apply to horses and burros where their 

numbers are significant.

145. The IM states that “enhanced management of livestock grazing may be the most cost-effective opportunity in many instances 

to improve Greater Sage-Grouse habitat on public lands.” We agree not only that it may be, but that it is the most 

cost-effective approach. In 1960 when Sage Grouse populations were the highest, the Utah BLM permitted livestock AUMs 

was 1.7 million. The Sage Grouse population decline closely resembles the decline of permitted livestock AUMs to the 

current .7 million AUMs. The numbers are very similar for Forest Service AUM’s.

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146. The IM talks about when droughts occur evaluate “season of use and stocking rate and adjust through coordination and 

annual billings process” If grazing has been properly planned there should be plenty of grass in the bank to carry grazing 

through drought periods.

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147. The IM recommends coordinating with other federal and state agencies and non-federal partners to leverage funding for 

habitat projects and to fully implement the recent MOU between the BLM, NRCS, FWS and USFS for enhancing 

Sage-Grouse habitat through grazing practices. We applaud this approach, but strongly urge to invest in and improve grazing 

management first, and then doing the appropriate habitat projects where needed.

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148. The IM talks about prioritizing supervision and effectiveness monitoring of grazing activities to ensure compliance. What this 

monitoring is, needs to be defined (UDAF/UGIP have recommendations that we believe reduce cost and provide better 

monitoring data).

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149. What is meant by “continue to evaluate existing range improvements” For how long? What will be monitored on a watering 

trough? A fence?

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150. The Memo States “pursue opportunities to incorporate multiple allotments under a single management plan/strategy where 

incorporation would result in enhancing Greater Sage-Grouse populations or its habitat as determined in coordination with 

the respective state wildlife agency” This is a great approach, we would like to add the coordination of the Grazing 

Improvement Program in Utah which has real experience in working to do exactly this (To be successful, such a plan must 

benefit permittees, Sage Grouse, and sustainable resource health) .

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151. The IM doesn’t mention the benefits that can be obtained by using multiple grazing species to achieve desired vegetation 

conditions for Sage-Grouse. An example would be winter grazing with sheep to enhance sage-brush.

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152. Prescriptive grazing should be considered as the priority tool for use in increasing and establishment of habitat for Sage 

Grouse.

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153. Range Improvements to benefits species and maintained by permittees who hold Federal Range Maintenance agreements 

should be allowed mitigation credits.

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154. Our economic stability is dependent upon the ability to graze our cattle on public ground. If grazing on public ground 

becomes so limited that we are unable to make a viable living as cattle ranchers, we would have to explore other sources of 

revenue. None of the alternatives (development and or recreation to name a couple) would be beneficial to the sage grouse 

populations residing in and around our private holdings.

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155. I urge you to take a very large step back and look at more than curtailing grazing as a strategy to improve Mountain Sage All Both emc0133GB
C. Comments by Resource Planning Issue

C-848 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

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Grouse numbers.

156. Rangeland Management: The current range management is not working. The plan should put into affect trials of the varied 

management techniques that have been developed by Allen Savory and many others. Just try!!! If a grazing system works in

Wyoming and not in Nevada then allow the system to be used in Wyoming and try something different in Nevada. Listen to 

the rancher as to the best grazing practices for an area. The rancher is not in the cow business but rather is in the grass 

business.

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157. Lands suitable for grazing shOldd continue to be designated for managed livestock grazing systems. The preferred alternative 

in this EIS should include assessments of the benefits and positive attributes of health y. actively growing grassland 

conditioned during the last 40 years through managed livestock grazing.

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158. Whenever the BLM determines that ecological conditions on an a llotment or pasture are not meeting the Fundamentals or 

the Standards and Guidelines it is imperative to take a "hard look" to determine if grazing is impacting the condition of a plant 

community and how it is happening. Professional opinion is inadequate and should not serve as a substitute for

intensive site investigations leaving BLM with an arbitrary decision.

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159. Solutions to problem areas should be written with the perspective that livestock grazing can be cunailed through adaptive 

managcment techniques and not through eli mination of the animal usc. Utilization levels should not be based on residual 

stubble heights without conducting appropriate height to weight relationship studies. because different grass species do not 

all reach total maturity heights that are the same. Furthermore. grass species do not grow as a monoculture plant

community. Species are randomly interspersed and onc-size-fits all grazing standards have never been successful tools for 

vegetation management. Vegetation treatments applied to the land arc valuable tools and grazing should be included as part 

of the solution instead of iso lated as a threat to the success of meeting the project objective.

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160. Due to the size and scope of these actions by the land management agencies, it is imperative that ranchers and the public land 

grazing industry are involved throughout the process.

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161. According to BLM Instruction Memorandum (IM) No. 2012-043 and as summarized in the BLM’s National Greater 

Sage-Grouse Planning Strategy, emphasis for protecting and managing greater sage-grouse habitat incorporates the following 

primary principles:

1) Protection of unfragmented habitats;

2) Minimization of habitat loss and fragmentation; and

3) Management of habitats to maintain, enhance, or restore conditions that meet greater sage-grouse life history needs.

Livestock grazing contributes positively to the above primary principles, being both compatible with and beneficial to greater 

sage-grouse habitat conservation. Ranchers are the stewards of the greater sage-grouse habitat on both the private and 

public land they use. Without ranchers, who provide an effective line of defense against fire and noxious weeds, manage 

forage for optimum production, and are the primary protectors of open space in the private lands of the west, large areas of 

greater sage-grouse habitat would be in jeopardy. The benefits provided by ranching relate directly to several identified 

threats to greater sage-grouse habitat, including wildfire, invasive plants, and urbanization and development.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-849

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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As recognized by the BLM in IM No. 2012-043, grazing can be “used as a tool to protect intact sagebrush habitat and increase 

habitat extent and continuity which is beneficial to [the] Greater Sage-Grouse and its habitat.” The IM continues, “Given the 

potential financial constraints in addressing the primary threats identified by the FWS, enhanced management of livestock 

grazing may be the most cost-effective opportunity in many instances to improve Greater Sage-Grouse habitat on public 

lands” (emphasis added). According to the Natural Resources Conservation Service (NRCS), grazing “has been responsible 

for retaining expansive tracts of sagebrush-dominated rangeland from conversion to cropland” and can “stimulate growth of 

grasses and forbs, and thus livestock can be used to manipulate the plant community toward a desired condition.”

Sound scientific research indicates that grazing is beneficial to the greater sage-grouse and other flora and fauna in multiple 

ways. Grazing reduces the instances and severity of wildfires (Launchbaugh et al. 2007), improves greater sage-grouse 

habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et al.1994, Evans 1996), and can 

be used to control invasive weeds (Olson and Lacey 1994, Walker et al.1994). Furthermore, grazing with appropriate range 

improvements can be utilized in some areas to improve greater sage-grouse habitat to mitigate for the disturbance caused 

by other multiple-use activities, such as mineral development.

162. Evidence of the real impact of the above-mentioned benefits has been demonstrated by landscape-scale level statistics. 

Permitted livestock levels (animal unit months, or AUMs) have dropped dramatically on BLM and FS lands from 1940 to 

today. Greater sage-grouse numbers have mirrored that decline. In Utah, for example, a roughly four-fold decrease in 

permitted livestock AUMs parallels the decline in greater sage-grouse during the same period (see graphs, Appendix A). Also 

worth noting is the fact that mule deer, a species that relies on similar habitat conditions as greater sage-grouse, has suffered 

the same decline.

This decline can be largely attributed to the lack of spring forbs and insects for broods naturally promoted by the added 

disturbance from greater numbers of livestock, and to the loss of the vast numbers of sheep (in Utah, numbers dropped 

from 2.2 million in 1930, to .25 million today) that at one time eased predation pressure (because predator control was 

more aggressive and because sheep served as an alternative food source to common predators), and encouraged multiple 

age classes of sage brush. Biologists often point to brood rearing and winter habitat limitations as factors influencing the 

decline of the greater sage-grouse. The diversity of sage brush age classes (once encouraged by greater numbers of sheep) 

is important to providing greater winter nutritional opportunity for the birds. We insist that this relationship be examined 

in every area occupied by greater-sage grouse.

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163. As further evidence of the value of livestock grazing to the health of greater sage-grouse, we are prepared to provide data 

from large, private land holdings where large ungulate numbers have doubled over the last 30 years and greater sage-grouse 

lek counts have increased five-fold.

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164. These services can only be provided by ranches that are stable and viable; thus, the best strategies for agency land managers 

to employ will be those that work for ranchers and greater sage-grouse, alike. Reducing livestock numbers is not effective as 

a mitigation strategy, and would, in fact, be detrimental to greater sagegrouse habitat and, ultimately, sage grouse numbers. 

The EIS and SEIS revisions should clarify that grazing should be used to reduce the risk of catastrophic wildfire, improve 

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C. Comments by Resource Planning Issue

C-850 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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Agency CmtLtrCode

forage, remove invasive species and provide open space. We strongly encourage the agencies to focus on those public land 

uses (or non-uses) that pose a real threat to the greater sage-grouse and its habitat.

165. Managed livestock grazing programs have the potential to maintain habitat diversity and quality for greater sage-grouse. For 

example, research shows that grazed lands produce forb growth and are preferred to nongrazed lands by greater 

sage-grouse (Evans 1986). Additionally, research shows that nesting cover (undercanopy vegetation) remains adequate with 

up to 40 percent utilization levels and is not substantially diminished until later in the grazing season, thus indicating that a 

variety of grazing regimes may be implemented without adversely affecting nesting (France et al.) In areas of high production, 

utilization in excess of 40 percent will still result in adequate nesting cover. Grazing systems should be implemented and

managed to comply with the respective resource area management and forest plans. Site-localized, long-term trend 

monitoring should be the basis for determining compliance with management plans. Utilization percentages or 

stubble-height measurements, set forth in a formula and applicable west-wide throughout the greater sage-grouse range, are 

not effective tools for adaptive management. Adequate residual plant cover must be determined by short-term and 

long-term monitoring, which includes accounting for various environmental conditions.

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166. Existing Rights

As stated in the NOI, “The RMP and LMP amendments/revisions will recognize valid existing rights.” We agree that all 

decisions made through revisions to RMPs and LMPs must recognize valid existing rights. As such, the EIS and SEIS 

alternatives should include provisions to ensure the continuation of our members’ existing rights and uses. Inclusion of such 

provisions will also help ensure their ability to continue the practices that contribute to greater sage-grouse habitat 

conservation. Such provisions might include:

• The “grandfathering” of long-established range structures into management plans;

• The maintenance of grazing permit numbers no lower than at their present economically feasible levels;

• RMPs and LMPs should include a full range of alternatives in order to provide flexibility adequate to avoid litigation; and

• Provisions for grant funding to livestock producers for their greater sage-grouse management efforts.

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167. Greater sage-grouse are attracted to grazed meadows; research shows that peak attendance of greater sage-grouse

in grazed meadows (especially hens with chicks, starting in late July) is significantly higher than in ungrazed meadows. 

Grazing, even at moderate levels, affects forb phenology by changing the maturation process. Ungrazed plants mature, seed 

and weather after dispersion of the seeds, whereas grazed plants continue to grow new leaves throughout the summer, 

providing food forbs for greater sage-grouse (Evans 1986).

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168. Rangeland improvements

There are many functioning structures, such as livestock corrals, that have been in use and in place for years and which 

should be “grandfathered in” or exempted from changes to greater sage-grouse management plans. Research from the 

University of Idaho shows there is a six-fold decrease in bird strikes when fences are marked, particularly where the fences 

are in areas of flat terrain (Stevens et al. 2011). All marked fences should be taken into account for the benefit they have 

provided in saving greater sage-grouse. Marking should be considered as a strategy prior to any removal or relocation of 

fences. Initial research being conducted at the University of Idaho shows that fences’ impacts on greater sage-grouse

are more dependent on topography than on the proximity of fences to leks. Initial findings show that areas with varied 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-851

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

elevation may not require marked fencing or adjustments to fence locations, as the grouse tend to dive into the lek areas 

rather than fly overland to reach the leks. Thus, fence markers are better placed in areas of flat terrain (Stevens 2011).

Electric fences should not fall under the same specifications as permanent fences. Electric fences are low-impact and often 

temporary, and should not be considered a threat to the greater sage-grouse.

169. Ongoing Conservation Actions by Ranchers

Ranchers continually strive to improve the quality of the land they own or manage. All federal grazing permittees must 

manage their grazing allotments so as to achieve certain rangeland standards and guidelines. Consequently, enforceable 

measures are already in place to ensure that rangeland, and greater sage-grouse habitat, is in good condition. Furthermore, 

it is in their best interest to undertake sound conservation practices that improve both the quality of their grazing land and 

the wildlife habitat. These actions include:

• Preservation of open space;

• Noxious weed and invasive species eradication and containment;

• Wildfire prevention and controlled burn efforts;

• Managing for and maintaining a mosaic of habitat types;

• Implementing grazing practices which benefit the greater sage-grouse, such as increasing nesting cover through 

rest-rotational grazing;

• Selective placement of salt or supplements;

• Developing wildlife watering sources and making them suitable for wildlife, i.e. installing bird ladders in troughs;

• Fence marking and relocation; and

• Predator control.

NEPA analyses should not start with the assumption that livestock grazing is a threat to sage grouse conservation in 

management areas. Instead, such analyses should start from the premise that properly managed livestock grazing is beneficial 

to greater sage-grouse, as scientific studies have shown. The analyses, therefore, must consider how to incorporate properly 

managed livestock grazing into the protection strategy.

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170. In addition to the above-mentioned actions on behalf of ranchers, activities underway through the NRCS SGI should be 

recognized as beneficial to conservation of the greater sage-grouse on BLM and FS managed lands (Greater Sage-Grouse 

Multiple Agency MOU, 2008). Similar to the state and local working groups, any NEPA documentation must consider the 

work being done by the NRCS on private lands. NRCS conservation in a particular area may allow for less BLM-FS 

protection in that area, and vice versa. Unlike state and local working groups, however, we do not believe that BLM and FS 

documents must defer to the NRCS program. But the BLM-FS NEPA strategy must consider the effects of the NRCS 

program, and both programs must be coordinated and reflected in the NEPA documents.

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171. In order to avoid redundant regulations, it should be noted that the BLM has developed Rangeland Health Standards and 

Guidelines to manage grazing for uplands ecosystems and sensitive species. BLM is required by regulation to make 

adjustments to livestock grazing permits where standards are not being met and grazing is determined to be the cause. We 

believe this regulatory mechanism, having already been incorporated into existing RMPs and LMPs, should negate the need 

for further regulation in those areas.

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C. Comments by Resource Planning Issue

C-852 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

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172. Conclusion

Livestock grazing is compatible and beneficial to greater sage-grouse habitat conservation. This has been proven by 

independent, peer-reviewed, scientific analysis, as referenced many times in these comments. Ranchers are the stewards of 

the greater sage-grouse habitat on both the private and public range lands. Allowing ranchers the continued use of public 

lands without unnecessary restrictions due to the potential listing of a species with such a large habitat encourages this 

stewardship and prevents fragmentation through development. As seen in many areas of successful rangeland conservation, 

including efforts to conserve the Gunnison Sage-Grouse, livestock grazing and habitat conservation go hand in hand.

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173. Sage brushes greatest threat is not cattle, it is fire. And what fuels fire and spreads it besides wind? Grass. If cattle are not 

allowed to graze the land, the grass will only get thicker providing more fuel for a fire. Thus resulting in more sage brush 

being burnt and the habitat of sage hens being destroyed. Cattle are the best friend of sage hens and sage brush. It’s merely

common sense

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174. And what is to become of cattle ranchers and their cattle if you kick them off their grazing lands? It will disrupt the economic 

progress and put many ranchers out of business.

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175. Grazing should be considered a benefit to sage grouse habitat improvement and maintenance if correctly managed. The 

primary focus of managing grazing to improve sage grouse habitat should be to increase understory production and riparian 

areas (streams and meadows). There are several examples where livestock producers, BLM, private land owners and 

conservationists have come together and used grazing rotation management systems to enhance understory needed for sage 

grouse. Examples where rotation type grazing and water development projects are being used successfully to

enhance sage grouse habitat and increased population levels are found at

http://www.westgov.org/wga/publicat/sagegrouse-rpt.pd. The sage grouse planning strategy should have a discussion on this 

topic and encourage field offices and ranger districts to create partnerships and adopt successful practices into there grazing

management. There should also be build-in flexibility to alter turn-out dates and length of grazing seasons depending on 

vegetation growth, drought conditions, etc. to benefit sage grouse. Set dates are not realistic from year to year.

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176. However, I can say this for most ranchers; we are very dedicated to the health and stability of these wonderful birds. The 

resident rancher can cooperate with scientist doing 'on the ground studies'.

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177. Closure of roads and trail, and elimination of grazing (both of which have been around long before the Sage Grouse 

popUlation were in trouble) is not the answer to restoration of the Grouse populations.

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178. Cattle actually exist in harmony with all types of birds and fowl and actually share areas of habitat and live alongside each 

other. Cattle do not eat sagebrush. But, prairie dogs do, thus destroying sage grouse habitats. However, cattle do help 

control wild fires by grazing overvegetated areas so these areas do not become tinderboxes for lightning strikes causing wild

fires.

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179. I assume you will be asked to remove all grazing in at least one alternative. That is ok. It is part of the NEPA process. But to 

be fair you need to address the ability to increase the use of livestock grazing as a tool to build fire breaks, reduce fuel loads 

and protect key plant species from fire. Not through permits, but through fuel reduction projects. Permits are usually tied 

to specific dates, numbers, and types of livestock. Therefore, they are not adaptable to be used here. This use needs to be 

flexible and responsive to meet the needs of fuel reduction objectives and reduce fire occurrence. Some decisions need to 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-853

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

be made here to reduce processes on individual projects later. Long drawn out processes left to complete after this EIS will 

never work to help sage grouse or their habitats.

180. Address the effects of livestock grazing on sagegrouse nesting areas. (leks) All Both emc0153GB

181. Livestock grazing has consistently and adequately been managed over the last 50 years. Any references to "past grazing" 

impacts to the landscape should be limited unless the EIS can identify and quantify specific impacts that remain in the present 

time. The use of "historical grazing impacts" as a way to excuse the lack of current data and quantification through inventory 

collections is unacceptable as a way to judge how the sage grouse management can or cannot proceed. The EIS should 

recognize ways to provide for studies in the plan that take the steps necessary to gain knowledge and understanding for 

development of a road map for future activities. This may require numerous, rigorous studies and we hope to see a full 

discussion of the research and study gaps that must be addressed in conjunction with the multiple uses on public lands for 

the conservation of sage grouse.

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182. Lands suitable for grazing should continue to be designated for managed livestock grazing systems since adaptive 

management techniques are a major part of each grazing area and monitoring has been used to support the objectives of 

each plan. The preferred alternative in this EIS should include assessments of the benefits and positive attributes of healthy, 

actively growing grassland conditioned during the last 50 years using livestock grazing management. Solutions to problem 

areas should be written with the perspective that livestock grazing can be curtailed when needed through adaptive 

management techniques and not through elimination of animal use. The EIS should weigh the benefits of grazing where 

grasslands are a major component of the landscape. Rangeland vegetation benefits from grazing use and bunch grasses are 

invigorated by all herbivore use. Livestock grazing is an asset and is supported in science literature through rigorous, 

repeatable research studies which are superior to the speculative interpretations in gray literature.

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183. There are few scientific, peer-reviewed articles that address the grazing and sage-grouse issue, none that are designed 

experiments, and none with replicates. Most of what is available reflects conclusions or thoughts without empirical data, or 

it represents gray literature (Wambolt et. al, 2002).

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184. Grazing permitting should continue near current levels with the BLM identifying critical key sage grouse habitat that grazing 

permits should be minimized or even eliminated (moratorium) for 5 years within in key habitat

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185. I'm not suggesting that we go back to historic livestock AUMs or to reduce range land health. I am suggesting that livestock 

numbers do not negatively impact sage-grouse numbers and livestock grazing should not be restricted further due to 

sage-grouse

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186. The BLM should not cut livestock grazing unless a permit is not meeting rangeland health standards. All Both emc0165GB

187. I am very supportive of efforts to incorporate sagebrush habitat protections into every relevant plan or project administered

by the BLM or the USFS, especially those relating to livestock grazing. It seems to me that neither grazing nor wildlife habitat 

are sustainable in much of the west as currently managed. But there is hope that innovative approaches, combined with 

data-based monitoring, can achieve a better habitat and a more appropriate balance between land uses.

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188. Another requirement may be to move the cattle into that pasture before the sage grouse start to nest. That way the 

introduction of cattle to the pasture wouldn't disturb nesting birds, but the birds could choose not to nest in that pasture if 

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C. Comments by Resource Planning Issue

C-854 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

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the cattle were bothering them

189. On the National Forest, have had a pasture that we help mitigate livestock and grouse conflicts by the location of water sets

based on dates. I was still allowed to use the pasture, but we also meet the grouse objective. It was a very workable 

compromise. In general I believe a healthy grazing system that incorporates rest, deferment, and rotation leads to habitat 

that is good for sage grouse. I think that is much better than a system where the same pastures are used every year at the 

same time.

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190. The range needs to be looked at as a system realizing when you take one pasture out of production more stress is placed on 

all of the other pastures. Many ranches have BLM, National Forest, State, and private lands that the one herd grazes.

By reducing the amount of grazing on BLM you might be increasing the grazing on adjacent , land that is just as critical for sage 

grouse. That is one reason why I'm happy to see the collaboration with the National Forest on this EIS.

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191. The sage grouse management measures being contemplated have a potential for a large impact on hay farming and cattle 

ranching business. And measures to protect and enhance the grouse will come on top of significant impacts to livestock 

operations by a rapidly expanding Oregon wolf population.

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192. Water: Ranching in this area offers significant opportunities for water enhancements for sage grouse. Much of the key grouse 

habitat is on BLM and private land and buried pipelines are common. Currently water is pumped to tanks to meet livestock 

needs and not grouse needs. There would be an opportunity to pump water to meet grouse needs especially after cattle are 

moved off BLM and up to higher pastures. In some instances dedicated storage tanks could be installed to provide water if 

pipelines must be shut off for the season. In certain instances longer term water flows could provide moist soil sites

in key brood use areas.

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193. Livestock grazing has consistently and adequately been managed over the last 50 years. Any references to "past grazing" 

impacts to the landscape should be limited unless the EIS can identify and quantify specific impacts that remain in the present 

time. The use of "historical grazing impacts" as a way to excuse the lack of current data and quantification through inventory 

collections is unacceptable as a way to judge how the sage grouse management can or cannot proceed. The EIS should 

recognize ways to provide for studies in the plan that take the steps necessary to gain knowledge and understanding for 

development of a road map for future activities. This may require numerous, rigorous studies and we hope to see a full 

discussion of the research and study gaps that must be addressed in conjunction with the multiple uses on public lands for 

the conservation of sage grouse.

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194. Lands suitable for grazing should continue to be designated for managed livestock grazing systems since adaptive 

management techniques are a major part of each grazing area and monitoring has been used to support the objectives of 

each plan. The preferred alternative in this EIS should include assessments of the benefits and positive attributes of healthy, 

actively growing grassland conditioned during the last 50 years using livestock grazing management. Solutions to problem 

areas should be written with the perspective that livestock grazing can be curtailed when needed through adaptive 

management techniques and not through elimination of animal use. The EIS should weigh the benefits of grazing where 

grasslands are a major component of the landscape. Rangeland vegetation benefits from grazing use and bunch grasses are 

invigorated by all herbivore use. Livestock grazing is an asset and is supported in science literature through rigorous, 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-855

Scoping Summary Report

Table C-6.A

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repeatable research studies which are superior to the speculative interpretations in gray literature.

195. There are few scientific, peer-reviewed articles that address the grazing and sage-grouse issue —none that are designed 

experiments, and none with replicates. Most of what is available reflects conclusions or thoughts without empirical data, or 

it represents gray literature (Wambolt et. al, 2002).

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196. Livestock grazing has consistently and adequately been managed over the last 50 years. Any references to “past grazing”

impacts to the landscape should be limited unless the EIS can identify and quantify specific impacts that remain in the present

time. The use of “historical grazing impacts” as a way to excuse the lack of current data and quantification through inventory

collections is unacceptable as a way to judge how the sage grouse management can or cannot proceed. The EIS should

recognize ways to provide for studies in the plan that take the steps necessary to gain knowledge and understanding for

development of a road map for future activities. This may require numerous, rigorous studies and we hope to see a full

discussion of the research and study gaps that must be addressed in conjunction with the multiple uses on public lands for

the conservation of sage grouse.

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197. Lands suitable for grazing should continue to be designated for managed livestock grazing systems since adaptive

management techniques are a major part of each grazing area and monitoring has been used to support the objectives of

each plan. The preferred alternative in this EIS should include assessments of the benefits and positive attributes of healthy,

actively growing grassland conditioned during the last 50 years using livestock grazing management. Solutions to problem

areas should be written with the perspective that livestock grazing can be curtailed when needed through adaptive

management techniques and not through elimination of animal use. The EIS should weigh the benefits of grazing where

grasslands are a major component of the landscape. Rangeland vegetation benefits from grazing use and bunch grasses are

invigorated by all herbivore use. Livestock grazing is an asset and is supported in science literature through rigorous,

repeatable research studies which are superior to the speculative interpretations in gray literature.

All Both emc0179GB

198. There are few scientific, peer-reviewed articles that address the grazing and sage-grouse issue —none that are designed 

experiments, and none with replicates. Most of what is available reflects conclusions or thoughts without empirical data,

or it represents gray literature (Wambolt et. al, 2002).

All Both emc0179GB

199. Unfortunately, the Greater Sage Grouse has fallen victim to that same westward expansion, but the culprits aren't really 

hunters--it's over development, be it housing or over grazing or the new pandemic-- gas & oil development.

All Both emc0182rm

200. I'm a big proponent of habitat enhancement for this bird species via prescribed burns that stimulate historic natural fire 

patterns, along with other measures, such as light-on-the-land, sustainable grazing methods (or complete cow restriction in 

some fragile areas). The type of land stewardship will of course also benefit many other native lifeforms in our region's 

sagebrush steppelands.

All Both emc0189GB

201. BLM has never reduced a grazing permit to account for the loss of productive rangeland. Every NEPA document looks at 

individual projects and decides they are insignificant to grazing, never looking at the cumulative effect. So as a consequence, 

we have the same number of livestock grazing on a much reduced rangeland base, to the detriment of native grasses and 

perennial forbs. If BLM does not want to reduce the AUMs accordingly, a better solution would be livestock removal from 

sagegrouse ranges in the spring.

All Both emc0197GB
C. Comments by Resource Planning Issue

C-856 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

202. The economic aspect related to any proposed action relating to sage grouse must be carefully taken into account and goes 

far beyond the cost of administration. Proposals have been tabled by some parties to severely limit or eliminate commercial 

grazing. This would have a devastating effect on many western cattle ranching and an equally devastating effect on rural 

communities and counties.

All Both emc0200GB

203. Therefore, I strongly urge the agencies to recognize the benefits of livestock grazing to greater-sage grouse and to 

prioritize their focus on those issues that pose a real and specific threat to the greater sage-grouse and its habitat.

All Both emc0202GB

204. Livestock grazing represents a legal and valid use of public. All Both emc0202GB

205. NEPA analysis should start from the premise that properly managed grazing can be a benefit to sage-grouse and properly 

managed grazing should be incorporated into the sage-grouse management strategy.

All Both emc0202GB

206. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the econoimic viability of ranching operations.

All Both emc0202GB

207. Historical evidence indicates a positive correlation between livestock numbers and sage grouse populations. All Both emc0202GB

208. I am extremely concerned about the impact the above referenced Notice of Intent will have on the range livestock industry 

in Nevada. Economically viable ranching operations provide both stewardship of public lands and economic stimulus and 

viability to local and regional communities. The conservation of rangelands for livestock production is extremely important,

not only to the sustainable production of food and fiber for the United States and worldwide markets, but also to providing 

quality habitat to support wildlife populations. Scientific research indicates that properly managed grazing is beneficial to the 

greater sage-grouse and to a host of other wildlife. Grazing can improve sage-grouse habitat by increasing the quality and

accessibility of forbs and other beneficial vegetation and also aids in the control of invasive plant species

All Both emc0204GB

209. Therefore, I strongly urge the agencies to recognize the benefits of livestock grazing to greater-sage grouse and to prioritize 

their focus on those issues that pose a real and specific threat to the greater sage-grouse and its habitat.

All Both emc0204GB

210. NEPA analysis should start from the premise that grazing can be a benefit to sage-grouse and grazing should be incorporated 

into the sage-grouse management strategy.

All Both emc0204GB

211. Historical evidence indicates a positive correlation between livestock numbers and sage-grouse populations All Both emc0204GB

212. On February 6, 2012 Judge Windmill indicated that actions such as fencing spring to prevent trampling by cattle were

unacceptable , since they ”ensure(s) that this potential critical habitat cannot be used by the sage grouse.” The springs, that 

I have seen fenced off, were done with barbed wire and the sage grouse could go under or over the wire to get into the 

enclosure. Some of the very small ones 10 feet by10 feet are done just around the spring were done with woven wire or

chicken wire still have hole that a sage grouse could get in. The excess water that does not get piped to the tanks and ponds 

comes out under the enclosures fence and produces green grass and mud for the insects to live in. I have never seen where 

a sage grouse has flown into a fence and gotten caught there.

All Both emc0207GB

213. Common sense would dictate that if the sage chicken and mule deer numbers were at their zenith, so were cattle and sheep 

numbers. Historically cattle and sheep numbers were much higher than those that are allowed today. In just this area there 

were multiple bands of sheep, thousands of cattle and hundreds of domestic horses, and still the old timers tell of the sky 

All Both emc0208GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-857

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

turning black with the chickens flying off their feeding grounds. It seems as though there is a trend that every time the cattle 

numbers fall so do those of the sage grouse. Even in the 1980’s our cattle numbers were higher than they are at the present 

time and the chickens seemed plentiful. Although I can’t say that I ever saw the sky turn black with them flying, it was quite 

common to see flocks of hundreds of birds come in to graze on the hay meadows in the evening. There is a bunch that still 

comes to graze on my lawn during the summer, which indicates to me that they are bothered very little by human 

development

214. Livestock grazing has very little if any detrimental impact on the sage grouse population. In fact, grazing seems to be beneficial 

to sage grouse. The grouse typically follow around where livestock have been grazing, which allows the birds to find insects 

and eat the tender new growth of the shrubs and forbs. I have never noticed any conflict between cattle and sage grouse, I 

have driven a herd of cattle with-in yards of grouse strutting and they did not even notice us passing. I have never seen a sage 

grouse that has been trampled or killed by a cow, horse or sheep.

All Both emc0208GB

215. Livestock grazing has consistently and adequately been managed over the last 50 years. Any references to "past grazing" 

impacts to the landscape should be limited unless the EIS can identify and quantify specific impacts that remain in the present 

time. The use of "historical grazing impacts" as a way to excuse the lack of current data and quantification through inventory 

collections is unacceptable as a way to judge how the sage grouse management can or cannot proceed. The EIS should 

recognize ways to provide for studies in the plan that take the steps necessary to gain knowledge and understanding for 

development of a road map for future activities. This may require numerous, rigorous studies and we hope to see a full 

discussion of the research and study gaps that must be addressed in conjunction with the multiple uses on public lands for 

the conservation of sage grouse.

All Both emc0209GB

216. Lands suitable for grazing should continue to be designated for managed livestock grazing systems since adaptive 

management techniques are a major part of each grazing area and monitoring has been used to support the objectives of 

each plan. The preferred alternative in this EIS should include assessments of the benefits and positive attributes of healthy, 

actively growing grassland conditioned during the last 50 years using livestock grazing management. Solutions to problem 

areas should be written with the perspective that livestock grazing can be curtailed when needed through adaptive 

management techniques and not through elimination of animal use. The EIS should weigh the benefits of grazing where 

grasslands are a major component of the landscape. Rangeland vegetation benefits from grazing use and bunch grasses are 

invigorated by all herbivore use. Livestock grazing is an asset and is supported in science literature through rigorous, 

repeatable research studies which are superior to the speculative interpretations in gray literature.

All Both emc0209GB

217. There are few scientific, peer-reviewed articles that address the grazing and sage-grouse issue, none that are designed 

experiments, and none with replicates. Most of what is available reflects conclusions or thoughts without empirical data, or 

it represents gray literature (Wambolt et. al, 2002).

All Both emc0209GB

218. Implementation of a top down BLM solution for BLM managed land that prohibit or prevent proper grazing management by 

other land managers will be counterproductive.

All Both emc0212GB

219. The BLM has noted in their handout (Preliminary Planning Criteria) the LUP amendments will contain decisions that are 

allocative andlor prescriptive to conserve sage-grouse habitat and management actions to restore, enhance and improve 

sage-grouse habitat. The BLM has developed Rangeland Health Standards and Guidelines that have standards that address 

All Both emc0212GB
C. Comments by Resource Planning Issue

C-858 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

uplands ecosystems and species that are sensitive, threatened or endangered. I believe that the BLM has regulatory 

mechanisms to management livestock grazing on BLM through the Rangeland Health Standard and Guidelines procedures 

that have already been incorporated in existing LUPs. BLM is required by regulation to make adjustment to livestock grazing 

permit when it has been determined that livestock is the cause for a standard not being met. This existing process of 

amending LUPs should be very limited when addressing changes to livestock grazing on BLM lands.

220. The conservation of rangelands for livestock production is extremely important, not only to the sustainable production of 

food and fiber for the United States and worldwide markets, but to wildlife habitat as well. Scientific research indicates that 

properly managed grazing is beneficial to the greater sage-grouse and to a host of other wildlife. Grazing can improve 

sage-grouse habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and also aids in the 

control of invasive weeds.

All Both emc0215GB

221. Therefore, I strongly urge the agencies to recognize the benefits of livestock grazing to greater-sage grouse and to prioritize 

their focus on those issues that pose a real and specific threat to the greater sage-grouse and its habitat.

All Both emc0215GB

222. Livestock grazing is a valid use of public rangelands and is a vital component of my livelihood. All Both emc0215GB

223. Historical evidence indicates a positive correlation between livestock numbers and sage grouse populations All Both emc0215GB

224. NEPA analysis should start from the premise that properly managed grazing is a benefit to sagegrouse and properly managed 

grazing should be incorporated into the sage-grouse management strategy.

All Both emc0215GB

225. Since BLM lands have historical grazing rights attached to them, every effort should be made to accommodate the existing 

lease holder with comparable grazing opportunities or allow them to trade for or purchase the land.

All Both emc0217GB

226. Livestock grazing has consistently and adequately been managed over the last 50 years. Any references to "past grazing" 

impacts to the landscape should be limited unless the EIS can identify and quantify specific impacts that remain in the present 

time. The use of "historical grazing impacts" as a way to excuse the lack of current data and quantification through inventory 

collections is unacceptable as a way to judge how the sage grouse management can or cannot proceed. The EIS should 

recognize ways to provide for studies in the plan that take the steps necessary to gain knowledge and understanding for 

development of a road map for future activities. This may require numerous, rigorous studies and we hope to see a full 

discussion of the research and study gaps that must be addressed in conjunction with the multiple uses on public lands for 

the conservation of sage grouse.

All Both emc0222GB

227. Lands suitable for grazing should continue to be designated for managed livestock grazing systems since adaptive 

management techniques are a major part of each grazing area and monitoring has been used to support the objectives of 

each plan. The preferred alternative in this EIS should include assessments of the benefits and positive attributes of healthy, 

actively growing grassland conditioned during the last 50 years using livestock grazing management. Solutions to problem 

areas should be written with the perspective that livestock grazing can be curtailed when needed through adaptive 

management techniques and not through elimination of animal use. The EIS should weigh the benefits of grazing where 

grasslands are a major component of the landscape. Rangeland vegetation benefits from grazing use and bunch grasses are 

invigorated by all herbivore use. Livestock grazing is an asset and is supported in science literature through rigorous, 

repeatable research studies which are superior to the speculative interpretations in gray literature.

All Both emc0222GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-859

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

228. There are few scientific, peer-reviewed articles that address the grazing and sage-grouse issue, none that are designed 

experiments, and none with replicates. Most of what is available reflects conclusions or thoughts without empirical data, or 

it represents gray literature (Wambolt et. al, 2002).

All Both emc0222GB

229. The Instruction Memorandum states that "enhanced management of livestock grazing may be the most cost-effective 

opportunity in many instances to improve Greater Sage-Grouse habitat on public lands." Well managed public land with 

respect to multiple use helps to provide better public land health which in turn would help to improve sage grouse habitat.

All Both emc0233GB

230. When droughts occur, there should be an evaluation of "season of use and stocking rates and adjustments through 

coordination and annual billings processes". If grazing has been properly planned there should be plenty of grass in the bank 

to carry grazing through drought periods. Any science based grazing management plan should allow for such insurances 

during drought periods where livestock will always be considered as a "tool" to manage rangelands and habitat for sensitive 

species like sage grouse.

All Both emc0233GB

231. The IM talks about prioritizing supervision and effective monitoring of grazing activities to ensure compliance. We would 

suggest that monitoring be planned by federal, state and local officials around grazing principals assessed over land scape 

scaled areas and not be tied to specific locations only.

All Both emc0233GB

232. The IM doesn't mention the benefits that can be obtained by using multiple grazing species to achieve desired vegetation 

conditions for Sage-Grouse. An example would be winter grazing with sheep to enhance sagebrush. Well managed sheep 

grazing provides for greater sagebrush health.

All Both emc0233GB

233. We agree that several reasonable alternatives should be analyzed in each NEPA document prepared dealing with grazing 

practices. WCA suggests that two alternatives be considered. These two alternatives would include a deferred or 

rest-rotation grazing system. Lin rural counties of the Western United States, the effect of a no-grazing alternative would be 

devastating to the local customs/culture/economics with a great multiplying effect.

All Both emc0233GB

234. Prescriptive grazing should be considered as the priority tool for use in increasing and establishment of habitat for sage 

grouse. The method of monitoring should be flexible enough to allow local input and modifications on the adaptivity of the 

species. Range improvements that benefits species and maintained by permittees who hold Federal Range Maintenance 

Agreements should be allowed mitigation credits.

All Both emc0233GB

235. I am writing to express my concern about the sage grouse and its potential impact on public land grazing by livestock. To my 

understanding, there is no conclusive evidence that livestock grazing is detrimental to sage grouse.

All Both emc0236GB

236. In my own experience, I have seen many cases where sage grouse actually choose to be near cattle, presumably as a defense 

mechanism against predators and scavengers.

All Both emc0236GB

237. The necessary and productive grazing industry should not be made a sacrificial lamb when many such factors have effect on 

the sage grouse populations.

All Both emc0236GB

238. The positive effects of livestock grazing sage grouse habitat are many, from the grazing and subsequent regrowth of plant life, 

to the natural process of seeds being scattered via livestock. Livestock contributes to the health of sage grouse habitat, and 

grazing permit holders do as well, with the maintenance and development of water resources. Allowing lands to lie dormant 

for too long creates nothing but tangled overgrowth of no nutritional value.

All Both emc0236GB
C. Comments by Resource Planning Issue

C-860 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

239. The result I have seen has been that native wildlife, especially birds, choose to be nearer to the cattle across the fence in the 

grazed area, rather than the "preserved" land.

All Both emc0236GB

240. Livestock grazing of public lands is unique in that it converts a product unusable by humans (grass), to a product that is 

consumable by humans (meat), in an all natural, environmentally sound manner. Careful, balanced management of public 

lands grazing is of course central to the success of the multiple use ideal.

All Both emc0236GB

241. Keeping food production safe and sustainable leads to a safe, plentiful, and affordable food supply for our nation and the 

world community. Public land grazing is an integral part that, and the dubious status of the sage grouse should not preclude 

that.

All Both emc0236GB

242. I would like to express my concern that currently grazing is potentially going to be sacrificed for sage grouse. All Both emc0237GB

243. Being a life-long rancher, I've heard many similar comments come and go. Grazing and livestock always seeming to be the 

at-risk potential sacrificial lamb. I've watched areas where livestock graze and it well known that where livestock graze, many 

other species flock. Yes, grazing cattle is a BENEFIT to sage grouse.

All Both emc0237GB

244. Look at areas where grazing has not been allowed. The tall dry grasses not only pose a fire danger, but when the dry grasses 

are fed off, you will see an increase in other game. Other birds, including the sage grouse, actually hang in areas where 

livestock have grazed. It has been proven that elk follow livestock grazing. Thus, by creating a thriving environment where 

cattle are grazed, other species follow and create a balanced ecosystem.

All Both emc0237GB

245. We all know that where livestock are grazed, the owners help to develop water sources. No specie can live without water. 

By maintaining a healthy and active water source, sage grouse along with other game bird species have a viable habitat.

All Both emc0237GB

246. Considering that livestock provides many goods and services to the entire human population, not just food, but through 

other by-products, it is a shame to see environmental activists attempt to manipulate grazing and negatively impact the cattle 

industry through their lack of sense.

All Both emc0237GB

247. It appears to be a common misconception that ranchers who use public land allotments for grazing are somehow getting that 

grazing for free or that they are not a part of the "public." Since ranchers actually are a part of the taxpayer base and provide 

a vital resource for all Americans and other countries for that matter, the BLM should say no to the groups attempting to use 

sage grouse as a pawn to run grazing off public lands. Whether it is sage grouse or any other specie, grazing is good for the

environment and good for our nation.

All Both emc0237GB

248. Support grazing. All Both emc0237GB

249. I am writing to express my concern about the sage grouse and its potential impact on public land grazing by livestock. My 

understanding is that there is no conclusive evidence that livestock grazing is detrimental to the sage grouse habitat.

All Both emc0238GB

250. The sage grouse are being used as a pawn by extremist environmental groups to stop public use of lands, and the very 

beneficial grazing by livestock.

All Both emc0238GB

251. On page 14, Range Management, only negative aspects of herbivory are listed, yet there is scientific evidence that grazing can 

improve nutrition of sage-grouse food items, that sage-grouse prefer grazed meadows over ungrazed meadows, and in areas 

dominated by grasses and widely spaced shrubs, grazing can be an effective fuels management tool. These seem like 

conservation measures that should also be used to benefit sage-grouse and they should be included in the EIS analysis.

All Both emc0239GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-861

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

252. On page 17, Retirement of Grazing Privileges, the planning note at the bottom of the page indicates that BLM and USFS will 

target specific allotments for permanent retirement of grazing privileges. The authority for this use of BLM and USFS action 

needs to be identified in the EIS and the socio-economic impacts of this type of action need to be analyzed in the EIS.

All Both emc0239GB

253. Changing grazing patterns with intent to increase Sage Grouse habitat will in fact cause detriment to other species that are 

both wild and domestic in nature. It will also threaten grazing permits due poor grazing systems. Forcing aggressive 

management of Sage Grouse habitat, will in fact threaten access for business use.

All Both emc0240GB, 

emc0096RM

254. Increase grazing by cattle, sheep, and horses to bring the over abundant fuel load of cheat grass and other non-native species 

of plants down to end the danger of catastrophic wildland fires. Managed and rotated grazing has beneficial effects for the 

sagegrouse by removing woofy dead grasses and stimulating softer forages.

All Both emc0241GB

255. Increase grazing by cattle, sheep, and horses to bring the over abundant fuel load of cheat grass and other non-native species 

of plants down to end the danger of catastrophic wildland fires. Managed and rotated grazing has beneficial effects for the 

sagegrouse by removing woofy dead grasses and stimulating softer forages.

All Both emc0241GB

256. Rangeland management must recognize the beneficial aspects of grazing in sustaining rangeland health and the rangeland 

improvements that have been made through the coordinated efforts of BLM managers and grazing permittees. Rest-rotation 

grazing systems should be considered rather than no-grazing alternatives.

All Both emc0242GB

257. Cattle ranching is a mainstay of Nevada (the state most heavily impacted by the threatened sage grouse), and the livelihoods 

of thousands of American citizens could be extinct due to the restrictions placed on ranchers by the Interim Policy.

All Both emc0244GB

258. Copy of the policy guidelines call for reduction of livestock grazing on public lands. Historically, sage grouse and other 

species such as antelope have followed livestock grazing patterns and flourished where ranchers are allowed to care for the 

rangeland

All Both emc0244GB

259. Limiting ranchers' ability to develop water sources for fear of increasing mosquitos that might carry West Nile is 

counteractive to increasing sage grouse numbers. Lifting restrictions and allowing ranchers to develop water sources, fence 

and protect meadows, and allowing regulated shooting of the raven would help boost sage grouse numbers.

All Both emc0244GB

260. Cooperative conservation measures should focus on restoration of rangelands that have been negatively affected by 

catastrophic fires, along with well‐designed and well‐managed grazing plans.

All Both emc0247GB

261. With proper management, grazing is a beneficial tool to rangeland health, removing overgrown grasses to expose fresh 

green grass, developing and maintaining watering sources, and keeping the rangeland in a productive grazing system rather 

than being developed for other uses are all beneficial to sage‐grouse.

All Both emc0247GB

262. Structural Range improvements: Water infrastructure and fences to manage livestock can pose increased mortality risk to 

sage grouse. Within the boundaries of the ACEC, development or modification of water infrastructure should be done in a 

way that minimizes the potential propagation of West Nile virus. (SGNTT 2011). Existing and new fencing should be marked, 

modified or removed to reduce sage-grouse strikes and mortality, particularly near leks, in known flight paths, in 

concentrated winter range, or where fence strikes have been documented.

All BLM emc0248GB

263. Livestock grazing contributes positively to the stated primary principles of the strategy, being both compatible with and 

beneficial to greater sage-grouse habitat conservation. Ranchers are the stewards of the greater sage-grouse habitat on both 

All Both emc0248GB
C. Comments by Resource Planning Issue

C-862 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

the private and public land they use. Without ranchers, who provide an effective line of defense against fire and noxious 

weeds, who manage forage for optimum production, and who are the primary protectors of open space in the private lands 

of the west, large areas of greater sage-grouse habitat would be in jeopardy. The benefits provided by ranching relate directly

to several identified threats to greater sage-grouse habitat, including wildfire, invasive plants, and urbanization and 

development

264. Let us instead go back to the practices that helped the birds flourish. These are agriculture and grazing and a vigorous 

program to control predators such as crows, ravens and coyotes.

All Both emc0249GB

265. There is ample greater sage-grouse habitat within existing Wilderness Areas, National Wildlife Refuges, National Parks, and 

National Conservation Areas to support the minimum effective population of 5,000 breeding adults needed to safeguard the 

species against extinction. These nationally designated areas are already managed under special regulatory mechanisms that 

in many instances mirror the proposed mechanisms that current sage-grouse planning strategies recommend for 

conservation of the species and its habitat. Thus, the proposed EIS process must first analyze greater sage-grouse 

populations and trends in these nationally designated areas. If analysis of these nationally designated areas, which likely 

support more than 5,000 sage-grouse, shows that the regulatory mechanisms currently in place have maintained or 

increased such populations, then there is no need to implement additional conservation measures anywhere else in the 

bird’s occupied range because its existence and trend in these nationally designated areas provide sustainable populations to 

avoid any need for listing under the ESA. In contrast, if analysis shows that sage-grouse populations have declined in these 

nationally designated areas, like they have elsewhere in their currently occupied range, then the entire line of reasoning 

regarding the factors responsible for the decline must be reevaluated. If sage-grouse have declined in these nationally 

designated areas despite the regulatory mechanisms that constrain their use, all recommendations to implement similar 

regulatory/policy restrictions across vast additional portions of the species range need to be rejected entirely. Instead, 

management practices that were in place when greater sage-grouse populations dramatically increased from the mid 1800s 

to early 1900s need to be identified and implemented again, including increased livestock grazing to reduce fire fuel loads and 

wildfire impacts, as well as concerted predator control.

All Both emc0251GB

266. Indeed, human disturbances of all sorts, roads, railways, fences, reservoirs, towns, homesteads, farms, mines, etc. flourished 

in the early to mid 1900s, and so did the sage-grouse. The mere presence of human activity seems to have little biologically

relevant connection to sage-grouse population trends. However, specific human activities appear to correlate positively with 

GSG population trends. Livestock grazing management, with its associated intensive development of meadows, hayfields, 

and surface water sources increased markedly in the Great Basin in the late 1800s and early 1900s, and GSG populations 

boomed. During this period, high livestock densities (both sheep and cattle) reduced fine wildfire fuel loads across the Great 

Basin, and wildfires were rare and small. High densities of livestock dung also supplied an abundance of insect activity, 

particularly in closely grazed meadows and riparian areas, and the close grazing stimulated succulent new herbaceous growth 

and increased the forb component in these meadows and riparian areas, thereby increasing the quantity and quality of the 

forage supply for sage-grouse. At the same time, concerted predator control was practiced. In fact, predator control was 

encouraged, subsidized, and implemented on a vast scale by the Federal and State governments. By the mid 1900s, Federal 

and State regulations were implemented and all of the grazing management practices discussed above were controlled and 

All Both emc0251GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-863

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

moderated. The GSG population boom moderated at about the same time. By the late 1960s, livestock numbers and grazing 

levels were significantly scaled back across the west, and predator control programs were largely curtailed. Fire fuel levels 

increased, and the incidence of large-scale wildfires rose exponentially. GSG population trends reversed and started to 

rapidly decline.

267. Thus, intensive livestock management which diminished the frequency and size of wildfires, and concerted predator control 

which greatly reduced GSG loses to these killers, are management actions in the Great Basin that seem to be highly relevant 

to the biology of the GSG and help explain the trajectory of their populations over time. As shown in Figure 1 on page 17 

herein, it is reasonable to assume that a return to effective management to increase livestock grazing levels, reduce fire fuel 

loads and wildfire impacts, and increase predator control would result in another significant upward trend in GSG 

populations. In contrast, proposed GSG conservation measures to provide heavier cover levels through further livestock 

grazing reductions, and the lack of conservation measures to address ever increasing predation levels, are a prescription to 

assure that GSG populations will ultimately decline. Heavier cover for GSG translates to higher fire fuel loads across the 

landscape, and substantial fuel loads make large-scale wildfires inevitable in many sagebrush communities. Repeat burns 

increase the likelihood that plant communities will shift toward cheatgrass dominance, which in turn increases wildfire 

frequency, eliminating the ability of sagebrush communities to re-establish. Thus, conservation measures that intend to 

benefit GSG by providing them with more hiding cover will ultimately harm the species by converting significant swaths of 

existing habitat to annual grasslands that provide no habitat value for GSG. This will concentrate the remaining birds in an 

ever shrinking area, making them more vulnerable to poorly controlled predator populations

All Both emc0251GB

268. Thus, intensive livestock management which diminished the frequency and size of wildfires, and concerted predator control 

which greatly reduced GSG loses to these killers, are management actions in the Great Basin that seem to be highly relevant 

to the biology of the GSG and help explain the trajectory of their populations over time. As shown in Figure 1 on page 17 

herein, it is reasonable to assume that a return to effective management to increase livestock grazing levels, reduce fire fuel 

loads and wildfire impacts, and increase predator control would result in another significant upward trend in GSG 

populations. In contrast, proposed GSG conservation measures to provide heavier cover levels through further livestock 

grazing reductions, and the lack of conservation measures to address ever increasing predation levels, are a prescription to 

assure that GSG populations will ultimately decline. Heavier cover for GSG translates to higher fire fuel loads across the 

landscape, and substantial fuel loads make large-scale wildfires inevitable in many sagebrush communities. Repeat burns 

increase the likelihood that plant communities will shift toward cheatgrass dominance, which in turn increases wildfire 

frequency, eliminating the ability of sagebrush communities to re-establish. Thus, conservation measures that intend to 

benefit GSG by providing them with more hiding cover will ultimately harm the species by converting significant swaths of 

existing habitat to annual grasslands that provide no habitat value for GSG. This will concentrate the remaining birds in an 

ever shrinking area, making them more vulnerable to poorly controlled predator populations

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269. If regulatory/policy controls to minimize human disturbance have failed to allow GSG populations to flourish within the vast 

wilderness areas and other nationally designated conservation areas, then it is unreasonable to apply such draconian control 

measures to broad landscapes beyond the boundaries of these areas in the vain hope that such regulation will somehow 

work in other locations. To implement regulatory mechanisms that are certain to severely interfere with other valid existing 

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uses of the landscape and negatively impact local and regional economies in the face of evidence that such mechanisms did 

not reverse the plight of the GSG in these nationally designated areas would be unreasonable, irrational, and 

counter-productive. Instead, if the minimum effective population of GSG necessary to protect the species from extinction 

cannot be supported within such nationally designated areas, then management practices that were in place when greater 

sage-grouse populations dramatically increased from the mid 1800s to early 1900s need to be identified and implemented 

again in other areas, including increased livestock grazing to reduce wildfire fuel loads, and concerted predator control 

practices

270. Enhance Current Populations Alternative Given the fact that current GSG populations exceed the minimum effective 

breeding population by 70 to 107 times, it is clear that GSG are not at imminent risk of extinction, and therefore do not 

legally qualify for listing as “endangered” under the ESA. The FWS Findings express concerns regarding rapidly declining GSG 

populations between the late 1960s and late 1980s, and continued downward population trends (although at a slower rate) 

from the late 1980s to the present. The FWS Findings fret that such downward trends in GSG populations may threaten the 

species with extinction at some point in the future. Given the recent (1985 – 2007) rate of decline of 1.4% annually (FWS 

Findings, 3 page 13922), it would take 300 to 330 years for the current greater sage-grouse population (350,000 to 535,000 

birds) to shrink to the minimum effective population (as high as 5,0000 birds). Theorizing about what might happen three 

centuries from now reaches well beyond the foreseeable future. Thus, the FWS Findings expression of concern about 

long-term outcomes from the continuation of recent GSG population trends does not rise to a determination that the 

species is threatened with extinction in the foreseeable future. A concern that populations may reach levels small enough to 

put them at risk of extinction at some point in the future does not meet the legal requirement to allow listing under the ESA 

unless the risk is likely in the foreseeable future. Given current circumstances, any such risk for GSG is likely 300 or more 

years distant, so the species does not legally qualify for listing as “threatened” under the ESA at this time. Nevertheless, it is 

reasonable to consider an alternative that would facilitate an increase in GSG populations, so long as that alternative does 

not negatively impacting existing socioeconomic uses occurring on BLM and FS administered lands. An analysis of the past 

management history within the Great Basin indicates that GSG flourished when livestock grazing levels were significantly 

higher than they are now. During this same period, large wildfires in the region were very infrequent (likely due to lower 

wildfire fuel levels as a result of close grazing), and concerted predator control measures were practiced. These 

management actions could be put into practice again to benefit GSG without harming the existing socioeconomic climate, 

but rather enhancing it. In fact, it is reasonable to argue that the FWS Findings get it wrong when they conclude that there 

is a lack of regulatory mechanisms in place to protect the GSG. Instead, many of the regulatory mechanisms currently in 

place are harming the species. For example, regulations restricting livestock numbers and use levels increase fire fuels across 

the Great Basin, and these regulations have resulted in a dramatic increase in large wildfires in the region in recent decades, 

which has destroyed GSG habitat to the detriment of the species. Repeated fire has led many sagebrush communities to

convert to cheatgrass dominance, which assures that the habitat will remain unfit for GSG into the foreseeable future. Rules 

restricting predator control, regulating the use of poisons and baits, and protecting ravens have resulted in excessive GSG 

loses due to predation. Whenever a species like the GSG with a relatively low reproduction rate (FWS Findings, 3 page

13916) loses the vast majority of its eggs to predation, and can trace more than 80% of the mortality of those individuals that 

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manage to hatch to predation (FWS Findings, 3 pages 13930, 13971, and 13972), its populations can be expected to decline. 

Again, it appears that existing rules are harming GSG populations, not a lack of adequate rules.

271. It is reasonable to analyze an alternative to eliminate existing regulatory/policy mechanisms that are harming GSG, or replace 

them with rules that again implement management practices that allowed the species to rapidly increase in the past, at least

within the Great Basin. Because current GSG populations greatly exceed the minimum effective population, any 

management alternative that would stabilize or increase the current population level would eliminate any perceived 

justification to list the species under the ESA. However, given the multiple-use mandates applicable to BLM and FS

administered lands, consideration and analysis of such an alternative to help GSG populations is only reasonable if it does not 

negatively impact other valid existing uses. An alternative to increase livestock grazing to reduce fuel loads and minimize 

wildfire impacts, and to return to concerted predator control practices is reasonable because it would benefit GSG without 

harming the existing socioeconomic climate, but rather enhancing it

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272. COMMENTS ON Interim conservation Measures and Policies for Preliminary Priority Habitat, No. 2012 ‐As the 043 (IM

interim policy and program guidance in the IM: These comments are consistent with and applicable to the strategic 

suggestions above for the proposed action. Grazing For Proposed Authorizations and Renewals where current livestock 

grazing has been identified as causal in not achieving land health standards that have the potential to impact Greater 

Sage 

Much of the language in this section only requires interdisciplinary teams to assess conditions and to evaluate progress. It 

seems that if livestock grazing has a known negative impact to Greater Sage 

opportunity to reduce or restrict future livestock grazing through the authorization process, then the IM Greater 

Sage 

adequate mitigation in future authorizations.

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273. As far as the comments about fencing being a problem, lets understand that larger birds of prey use fence post as a place to 

eat their meals.

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274. Fences are a huge problem for sage grouse. Studies have shown that every mile of barbed-wire fencing causes a certain

number of sage-grouse deaths, every year, due to sage-grouse hitting the wires. This is a continuous loss to the

population. Yet the BLM (and the Forest Service, for that matter) continue to build more fences. The only reason for

building more fencing is to attempt to influence the movements and reduce the damage caused by livestock. The option

of reducing or eliminating livestock use of the public's lands is seldom considered. Sometimes "jack-leg" fencing is used

in place of barbed-wire fencing. While wooden fences do not kill sage-grouse, sage-grouse are still threatened by them,

as raptors use them as places to perch and pounce on passing prey. Also, cattle use fence-lines as trails, and these wide

trails are also used by coyotes, foxes, and other predators, thus making it easier for them to nab sage-grouse chicks.

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275. Reduced availability of forbs and insects -- the latter a high-protein food that chicks must have -- are caused by the yearly 

stripping of vegetation from an area by livestock. Sage-grouse need to eat, but they are literally being starved to death 

because the biomass that they need simply is not available in many places. Many areas under BLM management are grazed 

from May to October, every single year. This level of use does not allow native vegetation to recover. When I walk through 

these areas, I see much bare ground, which encourages the invasion of cheatgrass and knapweed, the seeds of which are 

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carried by livestock and vehicles. These then spread if there is a wildfire. But livestock grazing was the beginning of the 

problem.

276. In the memory of older ranchers, many more cattle and sheep grazed the range lands than are allowed to today due to the 

many restrictions placed on ranchers. During this time, there were also many more sage grouse. At that time, grazing kept 

wild fires from destroying millions of acres of wildlife habitat. Fires have become a devastating problem in recent times, due 

to drastically restricted grazing and a huge build-up of un-used forage that creates fuel for these massive fires. Not only do 

fires destroy the necessary habitat and coverage for the nesting areas, they also kill any birds or wildlife in their path. A less 

restrictive approach to livestock grazing would greatly aid in saving the lands that the sage-grouse live on as well as all other 

animals that use the areas as well.

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277. 2.7. Grazing Grazing receives five pages of summary discussion, much of which seems to stand in contrast to pioneer 

records, ranchers’ histories and current resident witness to sage grouse life cycle, habit and extent. The discussion does not 

reflect the measured and diligent statement of Nevada Assemblyman Ira Hansen (2011). One correlation which must be 

considered is that the relatively high sage grouse population counts from the 1920s through the 1950s were contemporary 

with extensive grazing of both cattle and sheep (Barr, 2012a, Steninger & Barr, 2012). Additionally, there was concerted

predator control encouraged and sanctioned by the government.

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278. As the National Technical Team indicated, historic grazing management has contributed to lower numbers of sage-grouse 

across the range.12 Livestock grazing is the most widespread use of sagebrush lands across the West, and most sagebrush 

habitats have been grazed by livestock repeatedly during the past century. Livestock grazing exerts repeated pressure on the 

landscape, and can affect soils, vegetation, and animal communities. Livestock consume or alter vegetation, redistribute or 

disturb nutrients and plant seeds, trample soils and sagebrush plants, alter water availability, and impact microbiotic crusts.

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279. By consuming or trampling native grasses, livestock may reduce canopy cover considered necessary for successful nesting 

and brood-rearing of sage-grouse. Similarly, several authors have noted that livestock grazing can reduce the suitability of 

habitat for breeding, nesting, and brood-rearing. If breeding is successful, livestock has the potential to trample nests, thus

negatively affecting sage-grouse populations. Although the effect of trampling at a population level is unknown, outright nest 

destruction has been documented and the presence of livestock can cause sage-grouse to abandon their nests, exposing eggs 

to an increased risk of predation.

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280. Livestock and sage-grouse may also end up in direct competition for rangeland resources. Although livestock generally 

prefer to feed on grasses, cattle will nevertheless make seasonal use of forbs and shrub species such as sagebrush. Domestic 

sheep also may use forbs and shrub species like sagebrush. In addition to consumption of sagebrush reducing canopy cover, 

this particular impact may disproportionately affect pre-laying hens that require essential calcium, phosphorus, and protein 

found provided by forbs.

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281. Livestock grazing also causes numerous indirect effects that can negatively impact sage-grouse. For example, in addition to 

direct competition with sage-grouse for rangeland resources, livestock may also create similar competition for other species 

such as mule deer, white-tailed deer, elk, pronghorn, and bison. This competition may alter the distribution of these species,

which may be particularly important when management for one species is in potential conflict with sage-grouse. One 

example would be the removal of sagebrush for improvement of elk range. Additionally, livestock can often indirectly spread 

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invasive species or weeds, such as cheatgrass, which can negatively impact sagebrush survival and alter the fire-risk of an

ecosystem

282. Infrastructure often associated with livestock can also cause negative impacts to sage-grouse. Fencing, for example, in 

addition to directly modifying the landscape, can cause direct mortality to sage-grouse due to collisions. Additionally, fencing 

can influence livestock and predator movements, creating the number and density of perches for raptors and creating 

predator corridors. Fencing can also facilitate the spread and success of exotic plants. Sources state that more than 1,000 

kilometers of fences were constructed each year from 1996 through 2002, mostly on lands in Montana, Wyoming, Nevada 

and Oregon. Fencing of this extent seriously fragments habitat for sage-grouse, denying grouse the continuous sagebrush 

habitat that they need to survive.

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283. Additionally, sagebrush lands used for grazing often are subject to unnatural habitat modifications, including prescribed fire 

and herbicide use. These alterations are generally used to eradicate sagebrush to create more grass for domestic livestock. 

Additionally, water provided for livestock can become incubators for West Nile virus, the biggest disease threat to 

sagegrouse. Water troughs may also cause direct mortality through drowning when escape ramps are not provided. 

Development of springs and other water sources to support livestock can also artificially concentrate domestic livestock and 

wild ungulates in important sage-grouse habitats, thereby exacerbating grazing impacts in those areas.

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284. Additionally, sagebrush lands used for grazing often are subject to unnatural habitat modifications, including prescribed fire 

and herbicide use. These alterations are generally used to eradicate sagebrush to create more grass for domestic livestock. 

Additionally, water provided for livestock can become incubators for West Nile virus, the biggest disease threat to 

sagegrouse. Water troughs may also cause direct mortality through drowning when escape ramps are not provided. 

Development of springs and other water sources to support livestock can also artificially concentrate domestic livestock and 

wild ungulates in important sage-grouse habitats, thereby exacerbating grazing impacts in those areas.

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285. There are also several cumulative effects that must be considered. For example, livestock grazing in combination with 

drought and climate change can have a severe impact on sagebrush communities. Fire risk to sagebrush habitats may also 

increase, as livestock consume native vegetation and spread noxious weeds and invasive plants. And when grazing is 

combined with other disturbances, sagebrush habitats may experience greater shrub loss and increase the chances of the 

introduction and spread of cheatgrass compared to landscapes having a single source of disturbance.

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286. Exactly how and to what extent grazing may affect sage-grouse is relatively difficult to predict, and can vary greatly from 

landscape to landscape. Water developments and distribution of water sources can significantly influence movements and 

distribution of livestock, and thus grazing pressure may be unevenly distributed across the landscape of concern. 

Additionally, certain grazing systems encourage short, but intensive use by livestock, thus leading to more significant impacts 

over a shorter period of time.

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287. The importance and impacts of grazing pressure, rest, and rotation on the condition of sagebrush landscapes and the 

capability of these sagebrush habitats to support sage-grouse are not fully understood, largely due to a lack of research and 

experimentation. Also, impacts to sage-grouse may be different depending on which season and stage of life is being 

considered: breeding, nesting, brood rearing, or wintering.

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288. Impacts from livestock grazing can be so great that the affected sagebrush system is often unable to be returned to an 

undisturbed state. This problem is compounded by the fact that restoration of sagebrush habitat by itself presents a 

challenge, and once alteration of vegetation, nutrient cycles, topsoil, and cryptobiotic crusts have exceeded recovery 

thresholds, restoration may be impossible. Even if restoration was more successful, however, true restoration efforts may 

take decades and thus often is considered cost-prohibitive.

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289. Fences will also cause similar adverse impacts to sage-grouse and sage-grouse habitat. Fences fragment habitat as 

sage-grouse seek to avoid areas close to fences, likely to avoid predation, as fences provide cover and perches for potential 

predators. Sage-grouse may also collide with fences, resulting in direct mortality. Finally, similar to powerlines and 

communication towers, fences threaten to spread invasive plants and noxious weeds, threatening the integrity of the habitat 

for sage-grouse.

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290. Finally, the agencies should determine what changes need to be made in domestic livestock grazing in priority sage-grouse 

habitat to protect such habitat, including decreasing grazing intensity, implementation of rotational grazing patterns, 

adjusting stocking rates, strategic placement of water troughs and other associated infrastructure, phasing out grazing 

permits, or prohibiting future grazing. Such measures are especially necessary in areas not meeting rangeland health 

standards. We agree with the Technical Team Report’s suggestion to prioritize completion of land health assessments within 

priority sage-grouse habitat areas.34 When lands supporting sage-grouse or suitable sage-grouse habitat are not meeting 

rangeland health standards, grazing should be halted until the land is brought into compliance with those standards. 

Additionally, the agencies should reduce hot season grazing on riparian and meadow complexes to promote recovery or 

maintenance of appropriate vegetation and water quality.35 All NEPA analyses for AMP revisions for allotments in priority 

habitat should include at least one alternative that considers phasing out grazing in priority sage-grouse habitat. Each RMP 

should identify the specific allotments where permanent retirement of grazing privileges is potentially beneficial to 

sage-grouse.36 See infra Section III.C for more information on the impacts associated with grazing.

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291. Where domestic livestock grazing continues in sagebrush habitats, the agencies should develop and implement binding 

grazing management practices to protect the sagebrush ecosystem to the greatest extent possible. These standards should 

aim to maintain the soil quality and ecological processes necessary for a properly functioning sagebrush community to 

address long terms needs of sage-grouse and other sagebrush associated species. Particular emphasis should be placed on

how grazing affects sage-grouse nesting and early brood-rearing habitat. Some authors suggest that impacts from grazing may 

be minimized where intensity of grazing is reduced. All RMPs or grazing management plans should include stipulations to 

document lek locations and avoid new sources of disturbance on lek sites, manage grazing to maintain a vigorous sagebrush 

community with adequate cover, avoid repeated grazing of riparian areas in seasons when temperatures are high, and ensure 

any winter grazing should avoid heavy use of herbaceous standing crop and avoid any levels of browsing on sagebrush that 

would limit sage-grouse access to their food supply and cover. The agencies should also address documented impacts to 

sage-grouse from grazing infrastructure. For example, water troughs can cause unnecessary mortality to sage-grouse. As

required by BLM Instruction Memorandum No. 2007-179, escape ramps should be required in all water troughs/tanks. 

Furthermore, springs and seeps should be protected from livestock trampling. And in areas with documented West Nile 

Virus, plans should incorporate measures to minimize mosquito habitat, including minimizing areas of standing water with 

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emergent vegetation.

292. Barrick is the largest nongovemmentallandowner in Nevada. In addition to our mining projects, we own several large 

ranching operations in the northern part of the state, including the Tumbling JR, 7H, Dean, Squaw Valley, Hay, Dean, and JD 

Ranches. Our ranches also hold grazing allotments on more than a million acres of BLM land within the Ely, Elko, 

Shoshone-Eureka, Sonoma-Gerlach and Winnemucca districts, and on approximately 14,000 acres in the Humboldt 

National Forest Service. Despite their size, the ranches are dependent on these BLM and USFS grazing allotments for their 

long-term economic success. Without access to the allotments, the ranches would be unable to provide adequate revenue 

to remain sustainable.

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293. Barrick has conducted assessments of the ranches adjacent to some of its mining operations that may be useful to the 

agencies, particularly if the agencies are interested in evaluating the potential for mitigation projects or "banks" in these

areas. These same type of assessments are being included in the baseline studies conducted on potential mine development 

sites. This information may be available for the NEPA analysis and may allow for determination of impacts and mitigation for 

the impacts. The existing information for the ranches provides guidance and opportunity for where off-site mitigation can be 

conducted within the vicinity of the impacts.

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294. The management plan revisions must comply with multiple use and sustained yield requirements BLM must also recognize 

"the Nation's need for domestic sources of minerals, food, timber, and fiber from the public lands." Id. § 1701(a)(12). And 

BLM must manage the public lands for a "sustained yield," requiring "the achievement and maintenance in perpetuity of a 

high-level annual or regular periodic output of the various renewable resources of the public lands consistent with multiple 

use." [d. § 1702(h). Mineral extraction, grazing, and other productive uses must be considered on equal footing with 

sage-grouse management, and not merely as an afterthought. The National Forest Management Act and the Multiple-Use 

Sustained-Yield Act require the Forest Service to similarly manage for mUltiple uses and sustained yield. Forest Service 

management plans must provide for "multiple use and sustained yield of the products and services obtained therefrom in 

accordance with the [Multiple Use Sustained Yield Act], and, in particular, include coordination of outdoor recreation, 

range, timber, watershed, wildlife and fish and wilderness." 16 U.S.C. § 1604(e). The Forest Service must recognize "the 

policy of the Congress that the national forests are established and shall be administered for outdoor recreation, range, 

timber, watershed, and wildlife and fish purposes." Id. § 528. Accordingly, both the Forest Service and BLM must recognize 

multiple uses during the revision process.

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295. In addition to adhering to its long-standing multiple-use policy, the BLM must also analyze the economic impacts of the 

restriction of energy development and infrastructure as wel l as traditional uses such as grazing through the implementation 

of sage-grouse conservation measures. Many local and regional economics are dependent upon the multiple lIses of the 

public lands and as such deserve a comprehensive economic evaluation of the economic impact of any large-scale, 

range-wide conservation measures.

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296. We have seen positive effects on rangeland function and GSG from strategic vegetative treatments when done in 

conjunction with time-controlled, rotational grazing (see below).

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sagebrush canopies and others requiring early seral conditions. A well managed landscape is managed not to maximize value 

for any one specie (whether cattle or sage grouse) but rather maximizes overall value by ‘optimizing’, or maintaining viable 

habitat for multiple species (including wildlife and livestock, Danvir et al 2005).

298. Successful livestock operations plan at least one year in advance, and the most successful plan for contingencies such as 

drought. Reducing stocking rate during the first year of a drought can be devastating to producers, and is often marginally 

beneficial to the land. However, with advance notice and consultation, operators can generally find alternatives allowing 

them to reduce stocking rate in subsequent years of a multi-year drought, and especially during the first ‘Normal” rainfall 

year following a drought.

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299. Resting pastures during a year with average or above average growing-season precipitation provides a better opportunity for 

plants to recover health (since they are actively growing) than rest during drought (as the plants are dormant). Please 

consider prescribing rest from drought in this manner, as to minimize economic hardship and maximize plant recovery.

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300. We have found that by implementing multi-pasture grazing systems, having 5-15 pastures per herd, large herds, large 

pastures, allowing adequateperiods for plant recovery (generally 12 or more months) and providing season long rest 

toapproximately 20% of pastures annually we see increased upland and riparian herbaceous vegetation and decreased bare 

ground while maintaining a healthy brush component (Danvir 2002, Danvir et al 2005).

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301. Cattle, mule deer, pronghorn, pygmy rabbits, sagebrush passerines, cutthroat trout and cattle can all thrive. This type of 

rotational grazing strategy (providing rest for recovery) meets all four rangeland health guidelines, and provides a ‘drought 

reserve’ in that if needed pastures planned to be rested season-long may be grazed late in the year (during dormancy) if 

drought occurs.

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302. Our observations on sagebrush rangelands throughout the GSG range has been that the best way to create healthy GSG 

habitat and meet rangeland standards is to graze right - by implementing rotational grazing whereby plants experience 

periodic defoliation in a relatively short time period (generally 1 month or less) followed by a period of adequate growing 

season rest from grazing for plants to recover. If properly implemented, this practice will increase herbaceous plant cover 

and litter at the expense of bare ground-increasing soil moisture and plant productivity.

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303. Conversely, reducing stocking rates without shortening the grazing period and lengthening the rest-recovery period does 

little to improve rangeland health, increases fire intensity, and will continue to harm some herbaceous plant species.

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304. We agree that poorly designed and placed fences kill wildlife and disrupt seasonal movements and migrations. All fences 

within 1.25 miles of known leks, or in heavily used winter concentration areas of GSG should be periodically monitored for 

signs of GSG collisions, and if so modified or visibly marked to reduce mortality.

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305. However, as described above, fences can provide time-control, and proper grazing can significantly improve rangeland 

function and GSG habitat, improving vital rates and increasing populations. If used properly, fence benefits to rangeland 

function outweigh the negative effects. Large herds and large pastures are preferential than small herds and small pastures 

from and economic and ecological perspective

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306. We are concerned that BLM not develop a ‘one size fits all’ GSG management strategy. We have experience with GSG 

range-wide, from the uplands of Nevada through the northern and central Rocky Mountains of Montana, Wyoming, Utah 

and Colorado and into the northern Great Plains of eastern Wyoming and Montana. The weather, soils, vegetation and 

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ecology of these areas varies across the range, and to a degree the GSG has adapted to this variation. Having spent the past 

6 or more years working with Local Sage Grouse Working groups across the range, I (R. Danvir) have been impressed with 

the dedication, knowledge, insight and creativity expressed by the people who know these areas - their ability to identify 

stressors, threats and solutions to maintain or enhance GSG in their area. These local Working Groups included BLM 

biologists and range conservationists. The quickest way to lose the support of these hundreds of dedicated people is to 

disregard the hard work and existing GSG Local Working Group Conservation Plans already done. It is absolutely essential 

that BLM management henceforth recognizes and incorporates the work of the local working groups throughout the range

of the GSG, and maintains their adaptive management approach

307. Reducing livestock numbers is not effective as a mitigation strategy, and would in fact be detrimental to greater sage-grouse 

habitat and, ultimately, sage grouse numbers. The EIS and SEIS revisions should clarify that grazing should be used to reduce 

the risk of catastrophic wildfire, improve forage, remove invasive species and provide open space.

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308. NEPA analyses should not start with the assumption that livestock grazing is a threat to sage grouse conservation in 

management areas. Instead, such analyses should start from the premise that properlymanaged livestock grazing is beneficial 

to greater sage-grouse, as scientific studies have shown. The analyses, therefore, must consider how to incorporate 

properly-managed livestock grazing into the protection strategy.

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309. Permitted livestock levels have dropped dramatically on BLM and FS lands from 1940 to today. Greater sage-grouse 

numbers have mirrored that decline. The agencies should not overlook this statistic.

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310. Managed livestock grazing programs have the potential to maintain habitat diversity and quality for greater sage-grouse. 

Site-localized, long-term trend monitoring should be the basis for determining compliance with management plans. 

Utilization percentages or stubble-height measurements, set forth in a formula and applicable west-wide throughout the 

greater sage-grouse range, are not effective tools for adaptive management.

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312. please do not alienate the best tool available to protect Sage Grouse which is the grazing of livestock and the ranchers who 

depend on these lands for their livelyhoods.

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313. page IS, Implementing Management Actions after land health and Habitat Evaluations, bullet point 3, sub-point 2). Cattle 

numbers have declined 50% on the Public Lands. Sage-Grouse have also declined. Cattle are not the problem. We have 

learned to graze the land and leave grass for the wildlife.

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314. 7. page 14, Range Management, bullet point I). Overgrazing can actualJy enhance sagebrush stands along with sagebrush 

longevity simply because there is no fine fuel to carry wildfires. SRCA does not advocate overgrazing, but it should be taken 

into consideration. Correlate grazing cuts since the mid 1970's with increased fires and the declining sage-grouse

populations throughout Northern Nevada and Southern Idaho. (Hansen, 2012)

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315. 9. page 14, Range Management, bullet point 3). Very rarely does nest trampling occur by livestock. This is why land managers 

and ranchers need to form partnerships to share information so that livestock concentration does not occur near nesting 

areas, (e.g. salting and watering areas).

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it seemed the livestock and sage-grouse coexisted very well. Sage-grouse seemed to co-mingle with livestock in riparian 

areas. Maybe this is because predation could not occur around livestock. Sagegrouse had a sense of security around 

livestock. There were also more forbs and insects for sage-grouse in these riparian areas where livestock comingled with 

sage-grouse.

317. We agree there would be adverse impacts in eliminating grazing. These adverse impacts include invasive species after 

wildfires. Wildfires occurring where grazing did not occur would be very intense. The Murphy Complex Fire is a prime 

example. TNR was taken from this area several years ago which led to a devastating fire due to fuel buildup. How many acres 

of sagebrush burned? SRCA does not agree that permanent retirement of grazing privileges would ever be potentially 

beneficial.

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318. A blanket policy of resting for two full growing seasons can have adverse impacts. Short intense grazing could help reduce 

cheat grass infestations as well as other invasive species in some instances when done properl y. The lack of grazing is a 

threat to sage-grouse populations and sagebrush ecosystems. There is a correlation between grazing cuts (sheep and cattle),

increased fires and decreased sage-grouse populations (see map 1). Livestock producers do realize the difference between 

proper and improper grazing. (Smith., Sheley, & Svejcar, 2012)(Frost et al ., 2012)(United States Department of Agriculture 

[USDA], 2006)

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319. Livestock grazing is a legal and valid use of public rangelands and is a vital component to the balance of nature. If one looks 

at the statistics, more rangeland has burned in the past 10-15 years because of the restrictions on the rangeland. If ranchers 

can’t utilize the feed on BLM and Forest Service properties because of this sage-grouse issue, then it will be like adding fuel 

to an already burning fire. More vegetation will just make a bigger fire! Historical evidence indicates a positive correlation 

between livestock numbers and sage grouse populations. Grazing keeps the fuel down so there isn’t so much vegetation to 

burn. Sage-grouse don’t like to live in burned out areas either. They prefer to live in an area where nature is balanced.

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320. Livestock grazing has been one of the most important factors in the population explosion seen during the mid 1900s. Any 

reduction of grazing will actually be detrimental to the birds habitat.

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321. The BLM states fire as the greatest threat to the birds and grazing is the most effective management tool that is available to 

help control fuels to prevent wildfires.

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322. Reduce livestock grazing in priority habitat and potential recovery areas to restore native plants that the sage grouse depend 

upon.

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323. We have been successful promoting this effort by finding conservation practices that will benefit the rangeland, and thus 

increase the sustainability of the ranching operation. Our slogan, "what's good for ranching is good for the grouse sums up 

this effort. It's a win-win program to conserve world class wildlife and sustainable ranching.

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324. From 2010-2011 NRCS Utah has planned and funded 23 SGI projects on 42,300 for approximately $2.6 million ~Every 

grazed acre has a NRCS prescribed grazing plan designed to improve habitat. We have planned to mark or remove over 10 

miles of fences near leks and brood rearing areas to reduce collisions. Implementation of these projects is underway. 2012 

projects are still being planned. In addition, we have secured conservation easements on nearly 15,000ac of sage grouse 

habitat. Numerous 2012 easement applications are being considered for funding.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-873

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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325. The largest positive impact we have had in the last decade is working with private landowners on hundreds of thousands of 

acres of prescribed grazing through SGI and through other Farm Bill programs. On all prescribed grazing projects, NRCS 

provides land owners with a grazing plan designed to increase the amount of vegetation on the landscape.

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326. Since the 2008 Farm Bill, we have had the opportunity to plan and fund conservation projects on BLM-managed lands by 

working with the grazing leasee and the BLM. The use of this option has been limited thus far, but should be a priority for 

both of our agencies to explore the vast potential to get more conservation on the ground via this mechanism

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327. The decrease in large fires associated by adequate grass grazing by cattle, and the stimulation of new herbaceous growth and 

increased forb component that grazing promotes.

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328. Measures that the BLM has the power to enact that will have the greatest benefit to sage grouse numbers are likely 

maintaining or increasing their access to reliable water sources, reducing wildfire number and severity, and increasing new 

herbaceous growth and forb diversity. Livestock grazing promotes all these aims.

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329. We have seen positive effects on rangeland function and GSG from strategic vegetative treatments when done in 

conjunction with time-controlled, rotational grazing (see below).

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330. Page 7-"If periods of drought occur, where appropriate evaluate the season of use and stocking rate and adjust through 

coordination and annual billings processes." The BLM allotments and associated private lands in sagebrush country provide 

habitat for diverse wildlife species as well as providing the economic base for these rural counties. Successful livestock 

operations plan at least one year in advance, and the most successful plan for contingencies such as drought. Reducing 

stocking rate during the first year of a drought can be devastating to producers, and is often marginally beneficial to the land. 

However, with advance notice and consultation, operators can generally find alternatives allowing them to reduce stocking 

rate in subsequent years of a multi-year drought, and especially during the first 'Normal" rainfall year following a drought. 

Resting pastures during a year with average or above average growing-season precipitation provides a better opportunity for 

plants to recover health (since they are actively growing) than rest during drought (as the plants are dormant). Please 

consider prescribing rest from drought in this manner, as to minimize economic hardship and maximize plant recovery.

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331. Page 8- "Pursue opportunities to incorporate multiple allotments under a Single management plan/strategy where 

incorporation would result in enhancing Greater Sage-Grouse populations or its habitat as determined in coordination with 

respective state wildlife agency." We also agree with this strategy, are actively pursuing allotment consolidation projects in 

Utah, and are monitoring the effect on GSG vital rates and rangeland health response.

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332. We have found that by implementing multi-pasture grazing systems, having 5-15 pastures per herd, large herds, large 

pastures, allowing adequate periods for plant recovery (generally 12 or more months) and providing season long rest to 

approXimately 20% of pastures annually we see increased upland and riparian herbaceous vegetation and decreased bare 

ground while maintaining a healthy brush component (Danvir 2002, Danvir et al 2005).

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333. Cattle, mule deer, pronghorn, pygmy rabbits, sagebrush passerines, cutthroat trout and cattle can all thrive. This type of 

rotational grazing strategy (providing rest for recovery) meets all four rangeland health guidelines, and provides a 'drought 

reserve' in that if needed pastures planned to be rested season-long may be grazed late in the year (during dormancy) if 

drought occurs.

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C. Comments by Resource Planning Issue

C-874 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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334. Our observations on sagebrush rangelands throughout the GSG range has been that the best way to create healthy GSG 

habitat and meet rangeland standards is to graze right - by implementing rotational grazing whereby plants experience 

periodic defoliation in a relatively short time period (generally 1 month or less) followed by a period of adequate growing 

season rest from grazing for plants to recover. If properly implemented, this practice will increase herbaceous plant cover 

and litter at the expense of bare groundincreasing soil moisture and plant productivity. Conversely, reducing stocking rates 

without shortening the grazing period and lengthening the rest-recovery period does little to improve rangeland health, 

increases fire intensity, and will continue to harm some herbaceous plant species.

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335. page 8 - "Fences". We agree that poorly designed and placed fences kill wildlife and disrupt seasonal movements and 

migrations. All fences within 1.25 miles of known leks, or in heavily used winter concentration areas of GSG should be 

periodically monitored for signs of GSG colliSions, and if so modified or visibly marked to reduce mortality. However, as 

described above, fences can provide time-control, and proper grazing can significantly improve rangeland function and GSG 

habitat, improving vital rates and increasing populations. If used properly, fence benefits to rangeland function outweigh the 

negative effects. Large herds and large pastures are preferential than small herds and small pastures from and economic and 

ecological perspective.

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336. Evaluate fencing in sage grouse habitat for its impact on grouse. Reduce the miles of fence near leks. Mark other fences to 

increase visibility.

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337. Quantify and verify the specific use and impacts to sage grouse habitat by domestic livestock (cattle, sheep, etc.) use, 

including grazing's promotion of invasive species and the resultant fire regime. Assess significance of grazing impacts relative 

to other sage grouse adverse factors, e.g. agriculture, wildfires, disease, energy development, and other anthropogenic 

disturbances. Ensure that each grazing allotment in sage brush habitat uses best management practices to ensure the 

protection of sage grouse.

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338. Include retirement of grazing allotments as an alternative method to protect sage-grouse habitat. All Both emc0305GB

339. Please do not insist on additional provisions in land use plans to further limit grazing management options. Standards and 

guidelines for livestock grazing and protocols for evaluating rangeland health are well established. Wild horse and burro use 

must be recognized in land use plans. Their grazing use must not exceed standards and guidelines and appropriate 

management levels must be adhered to.

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340. The BLM should encourage the use of any other voluntary methods, such as long term rest for a grazing allotment or short 

term durational grazing in appropriate seasons on BLM lands, that would minimize or avoid disturbance in sage grouse 

habitat.

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341. I very much want to see Sage Grouse numbers increased to to levels that are mutually acceptable to all stakeholders. 

However, I do not believe that stopping or curtailing grazing will help in restoring their populations

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342. Good science....if people will actually believe it....shows that cattle grazing has many beneficial affects on our rangeland like 

re‐seeding of desirable grasses and feed. Natural cover and elimination of toxic weeds to name a few

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343. Historic and current research and science have proven that ecologically-based grazing of domestic livestock can be beneficial 

in ecosystem functioning, and by inference, for sage-grouse and associated species.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-875

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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344. It is also necessary that the preferred alternative explicitly recognize the key importance of public lands ranching operations 

to the success of sage-grouse conservation. Scientific research has repeatedly shown that properly managed grazing is 

beneficial to the greater sage-grouse and to a host of other wildlife species. Well-managed grazing can improve sage-grouse 

habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and also aids in the control of 

invasive plant species.

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345. Moreover, public lands ranchers own a significant portion of high-quality lowland brood rearing habitat as deeded property. 

According to the USDA Natural Resources Conservation Service (NRCS), "[a]pproximately 40 percent of sage-grouse 

habitat that supports populations occurs on privately owned lands." However, if regulatory measures on public lands make 

ranching operations economically unsustainable, these operations are subject to sale and development, leading to

fragmentation and loss of key habitat. It is therefore essential that the preferred alternative incorporates explicit steps to 

ensure that sage-grouse conservation measures do not undermine the viability of public lands ranches.

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346. Any EIS or SEIS developed must also recognize and incorporate the extensive research that has already been conducted by 

NRCS on the complimentary relationship between sage-grouse conservation and grazing. According to NRCS, "the same 

factors that negatively affect sage-grouse also negatively affect the health, productivity, and sustainability of native grazing 

lands. Therefore, improvements to benefit sage-grouse also benefit grazing lands and the ranchers that depend on them."

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347. Any EIS or SEIS must also explicitly recognize the following points: - Properly managed grazing can enhance sage-grouse 

habitat and should be incorporated into the sage-grouse management strategy. - Historical evidence indicates a positive 

correlation between livestock numbers and sage grouse populations.

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348. Any EIS or SEIS must also explicitly recognize the following points: In the Great Basin, and much ofthe western United 

States, livestock operations are highly dependent upon the combined use of private and public lands. Regulatory actions that 

make public lands grazing economically unsustainable will not only negatively impact individual ranch owners, but also entire 

rural communities that largely depend on ranching to maintain businesses and tax base.

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349. PFA believes livestock grazing (overgrazing) is the number one issue facing Greater Sage-grouse conservation in Idaho. 

Overgrazing contributes to huge losses of Sage-grouse, and other sagebrush obligate species, due to loss and degradation of 

native habitat and important watersheds.

In Overgrazing: Is A Solution Available?, a paper by Brian Osborn, overgrazing can be defined as "the occurrence of a 

population of grazers (usually cattle) utilizing an area which cannot support the population indefinitely without being allowed

to recover."

Why is overgrazing so harmful? Homewood and Rodgers (1987) report that if overgrazing is continued, its endpoint will be 

desertification. Desertification is the sustained decline and/or destruction of the biological productivity of arid and semiarid 

lands caused in large part by man-made stresses. If these stresses are continued, ecological degradation and desert like 

conditions may arise (Wallace 1989).

In addition, overgrazing leads to a decline in local wildlife populations by destroying their habitat. Since one ecosystem is not 

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C. Comments by Resource Planning Issue

C-876 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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working in isolation, other ecosystems that rely on the damaged one also suffer. As a result, populations of species living 

outside of the degraded area can also be affected.

350. When PFA refers to the word "overgrazing" in these comments, we are talking about the impacts of grazing on public land 

over a long period of time, one hundred years or more in most cases. During most of that time period of that time, there was 

not adequate monitoring and oversight by BLM, USFS, and State Lands Commission, agencies that were set up specifically to 

protect public land.

Below is a list of impacts PFA members have observed and documented over the last twenty or more years. These are 

concerns we have for sage steppe habitat overgrazed by livestock on public land. We are not all scientists or biologists, but

we have worked to learn as much as we can about issues and impacts by livestock as well as properly functioning ecosystems.

Concerns about grazing (overgrazed) impacts in sage steppe habitat:

· Soil erosion and compaction (we believe in most cases, the degree of severity is limited only by topography);

· Loss of mesic and riparian areas;

· Loss of riparian vegetation and bank integrity;

· Gulley and wash formation;

· Lowering of the water table;

· Dysfunctional watersheds;

· Invasive weeds and grasses;

· Loss of mosses and biotic soils;

· Loss of native vegetation such as forbs, shrubs, trees, and grasses;

· Loss of ground cover, including little or no litter in many areas;

· Trampling of nesting and brooding areas of ground nesting birds including CEUR;

· Little or no understory in many areas;

· Over-utilized crested-wheat seedings;

· Plant pedestalling, surrounding bare ground, and exposed roots;

· Large areas of open and connecting bare ground;

· Large "sacrifice" areas near streams, springs, seeps, and water developments (improvements?);

· Loss of water quality, silt and pollution (introduction of livestock feces and urine);

· Fencing unfriendly to wildlife, netting and many strand fencing still found on BLM and Forest lands;

· Loss of native habitat to wildfire and encouraging repeated fire cycle;

· Loss of reseeded areas, burns and vegetation treatment projects by allowing livestock back before plants have sufficient 

growth to survive (two full years or less);

· Grazing in early spring, late winter, prolonged wet seasons, and year round

· Insufficient cover for wildlife

· Frequent aerial gunning (observed and documented by PFA members in Burley F.O.);

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-877

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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· Failure to maintain water troughs or substituting with ponds that quickly become polluted and encourage the spread of 

West Nile Virus and,

· Failure to rehabilitate pipelines and burns (invasive weeds, grasses and bare ground).

Most of the concerns listed above due to the impacts of overgrazing are moderate to severe in most LM and USFS 

allotments throughout sagebrush steppe/CEUR habitat in our area. We have serious concerns about year-round grazing, 

continuous grazing throughout the grazing season, and livestock grazing during wet seasons.

Additional disturbances caused by livestock improvements, infrastructure, recreation, mining, energy projects, and gas and 

oil exploration all contribute to the degradation and elimination of sage steppe habitat, and ultimately Greater Sage-grouse.

351. We see nothing new in the Instructional Memorandum 12-27-2011(IM) and the National Technical Team (NTT) report. We 

are concerned that the NTT report is too general particularly the Range Management section. It does not adequately 

address ongoing and cumulative threats and impacts by livestock. We found the NTT's recommendations to be pretty much 

the same ones recommended now to improve rangeland for livestock grazing. The report avoids tackling the important issue 

of direct, indirect, and cumulative impacts by livestock grazing (overgrazing) on public land for more than a hundred and fifty

years.

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352. Prairie Falcon Audubon members have documented grazing impacts for the last twenty years. We have seen very little 

change in the way sagebrush steppe and sage-grouse habitat are managed. The BLM, while making all kinds of promises, 

seems unwilling to protect, or conserve or enhance natural resources for Sage-grouse and sage steppe in any real way. As 

an example, the BLM still allows year-round, continuous, late winter, and early turnout for spring grazing. These are critical 

times when habitat is vulnerable to soil compaction and when early native forbs and grasses, need time to become 

established. The elimination of early native forbs and grasses from the landscape is deleterious to Sage-grouse and other 

sagebrush obligate species. Fuels projects and lax forage utilization management, Meteorological Towers for wind projects 

and aggressive exotic kochia seeding for "fire breaks" in sage steppe across the west etc. allow easier predation and major 

loss of native vegetation and habitat.

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353. As stated above, our concerns about vegetation treatments and burns are valid, as we have observed and documented what 

happens after treatments when grazing is allowed back at two years or sooner. We believe the BLM and the USFS must not 

allow grazing until after a much longer period of time, five to ten years. This allows for a more permanent restoration to 

counter invasive grasses, weeds and wildfire and save taxpayers' dollars. In order to stop and/or reverse the alarming and 

accelerating downward trend of habitat conditions found on public lands, federal agencies have a responsibility to clearly 

define an environmentally sound direction for States to follow, as there is always state and local political pressure by private 

interests and short-sighted stakeholders to side -step, profit from, and simply ignore federal regulations.

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354. Start implementing strict measures for grazing such as the enforcement of Standards and Guides using restorative measures 

to ensure conservation of sage steppe habitat now and in the future.

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355. Restrict and retire grazing allotments in all key habitat areas. Reassess, manage and monitor livestock to improve and protect 

all restoration areas. Rest treatment and burn areas for a much longer time, five to ten years.

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C. Comments by Resource Planning Issue

C-878 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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356. The biggest issue we see is livestock grazing (overgrazing) for the past one hundred years or more. Issues that livestock 

impacts are management of riparian and mesic areas and grazing during critical times of the year, including wet and early 

growing seasons to protect the native forbs, grasses and biotic soils that are so important to Sage-grouse. Agencies must 

adhere to their own forage utilization standards and rigorously monitor and manage grazing on our public lands. To that end 

the BLM and the USFS must:

-Develop alternatives to control grazing impacts that include a "no grazing" alternative in key habitats and areas of 

restoration of potential key habitat;

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357. The evaluation of the need for permanent roads or seasonal road/area closures should include public input as part of the 

evaluation. Many of these roads that receive limited use are important to ranchers for getting to water developments, 

distributing salt or supplements, and towing horse trailers to the ends of the roads to initiate riding to move livestock. 

Effective livestock grazing, which can benefit sage-grouse, depends on the continued use of such roads and trails.

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358. On page 14, Range Management, only negative aspects of herbivory are listed, yet there is scientific evidence that grazing can 

improve nutrition of sage-grouse food items, that sage-grouse prefer grazed meadows over ungrazed meadows, and in areas 

dominated by grasses and widely spaced shrubs, grazing can be an effective fuels management tool. These seem like 

conservation measures that should also be used to benefit sage-grouse and they should be included in the EIS analysis.

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359. In addition, the list of "negative" aspects of herbivory does not recognize that many of these same conditions can be achieved 

in the absence of grazing. Plant dynamics of the various sagebrush ecological sites will result in shrub-dominated vegetation 

over time in the absence of disturbance. Therefore, the lateral cover necessary for nesting and the changes in sage-grouse

habitat due to shrub-grass competitive dynamics create habitat conditions unfavorable to sage-grouse nesting, early brood 

habitat, and pre-laying habitat. While proper grazing management can be a beneficial tool, improper vegetation management 

can be a detriment to sage-grouse.

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360. At page 16, Riparian Areas and Wet Meadows, managing for proper functioning condition of these sites within sage-grouse 

priority habitats should include grazing. As indicated above, grazing of meadows improves the nutrition of the forbs used by 

sage-grouse and sage-grouse demonstrate a preference for grazed versus ungrazed meadows. This needs to be included in 

the EIS analysis.

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361. On page 17, Retirement of Grazing Privileges, the planning note at the bottom of the page indicates that BLM and USFS will 

target specific allotments for permanent retirement of grazing privileges. The authority for this use of BLM and USFS action 

needs to be identified in the EIS and the socio-economic impacts of this type of action need to be analyzed in the EIS.

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362. Grazing as a fuel reduction tool that can be useful where grasses are the fuel that carries the fire, but limiting grazing in 

sage-grouse habitats conflicts with the conservation measure of reducing fuels.

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363. Our family business is in the cattle business and our community and many local businesses are dependent upon livestock 

grazing on public lands - arbitrary changes to land-use plans could seriously damage our local economy, private businesses 

and sagegrouse populations in our area. The assumption of many managers inside and outside BLM and other agencies is that 

because of the proposed listing of sage-grouse, that something different in land use or management needs to be done when 

the opposite should be the starting point for sage-grouse conservation measures and they need to be site specific.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-879

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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364. Specific to grazing, reduction in grazing levels, removal of grazing during the nesting or mating season may be very negative 

towards nesting success and sustainability of sagegrouse. Livestock grazing can provide a direct and indirect benefit for many 

wildlife species especially sage-grouse through stimulating forbs and herbaceous growth conditions that meet sage-grouse 

needs during critical physiological and seasonal periods and needs. Livestock grazing is very beneficia! to decreasing the risk 

of wildfire and mortality of important understory plant species. Research by the Agricultural Research Service (Bates, 

Svejcar et. AI.) indicates healthy grazed plants are less susceptible to hot fire conditions compared to ungrazed protected 

plants.

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365. Public lands ranchers own a significant portion of high-quality habitat as deeded property and that deeded property is 

managed and used in conjunction with public grazing permits for the mutual benefit of protecting sage-grouse habitat, 

populations and major risks. According to the USDA Natural Resources Conservation Service (NRCS), "[a]pproximately 40 

percent of sage-grouse habitat that supports populations occurs on privately owned lands." The continued viability 

oflivestock operations and beneficial role public land grazing plays and benefits sustainable livestock businesses needs to be 

emphasized in any national guidance.

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366. Again, the burden of proof needs to be on proponents of major changes in timing and duration of grazing and historical levels

of grazing. We have example after example where removal of grazing negatively impacts sage-grouse and other species not 

to say increasing the risk of wildfire.

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367. o Grazing Permits The IM appears to presume that that livestock grazing is a threat to sage grouse conservation in 

management areas. BLM should start from the premise that properly managed livestock grazing can be a benefit for sage 

grouse, and the analyses should consider how to incorporate properly managed livestock grazing into the protection 

strategy. Many NMA members hold and operate federal grazing interests. Owners of such interests are often the stewards 

of the greater sage-grouse habitat on both the private and public land they use. They provide an effective line of defense 

against fire and noxious weeds, manage forage for optimum production, and are the primary protectors of open space in the 

private lands of the West. Without ranchers, large areas of greater sage-grouse habitat would be in jeopardy. The benefits 

provided by ranching and grazing relate directly to several identified threats to greater sage-grouse habitat, including wildfire, 

invasive plants, and urbanization and development. Sound scientific research indicates that grazing is beneficial to the 

greater sage-grouse and other flora and fauna in multiple ways. Grazing reduces the instances and severity of wildfires. 

(Launchbaugh et aI.2007)6. It improves greater sage-grouse habitat by increasing the quality and accessibility of forbs for sage 

grouse (Neel 1980, Derner et. 1994, Evans 1996)7. It has also been used to control invasive weeds (Olson and Lacey 1994, 

Walker et aI.1994)8. Furthermore, regarding rangeland management, the NTT document suggests that new water 

development for diversion from springs or seep sources should be authorized only when priority sage grouse habitat would 

benefit from such development. This recommendation is extreme and should be rejected. Instead of this requirement, the 

policy should not discourage water development unless it significantly harms sage grouse populations.

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368. Livestock grazing on public and private land contributes to the Sage grouse habitats by managing the optimum use of the 

forage, therefore less dry fuels for wild fires. The EIS and SEIS revisions should clarity that grazing should be used to reduce 

the risk of catastrophic wild fires and improve forage.

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369. At any rate, it would be a mistake to put them on the endangered species list. They co-exist with sheep well. It would be All Both emc0336GB
C. Comments by Resource Planning Issue

C-880 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

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detrimental to ranchers such as myself if we had no access to public lands for grazing.

370. The BLM must analyze the positive impacts of grazing upon the health of the range, and the retention of water in the area, 

with the resultant benefits to sage grouse.

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371. It is also necessary that the preferred alternative explicitly recognize the key importance of public lands ranching operations 

to the success of sage-grouse conservation. Scientific research has repeatedly shown that properly managed grazing is 

beneficial to the greater sage-grouse and to a host of other wildlife species. Well managed grazing can improve sage-grouse 

habitat by increasing the quality and accessibility of other beneficial vegetation and also aids in the control of invasive plant 

species. Moreover, public lands ranchers own a significant portion of high quality lowland brood rearing habitat as deeded 

property. NRCS estimates that approximately 40 percent of sage-grouse habitat that supports populations occurs on 

privately owned lands. Any EIS or SEIS developed must recognize and incorporate the fact that properly managed grazing 

can enhance sage-grouse habitat and should be incorporated into the sage-grouse management strategy and livestock 

operations are highly dependent upon the combined use of private and public lands. If regulatory measures on public lands 

make ranching operations economically unsustainable, these operations are subject to sale and development, leading to 

fragmentation and loss of key habitat. It is therefore essential that the preferred alternative incorporates explicit steps to 

ensure that sage-grouse conservation measures do not undermine the viability of public lands ranches. Regulatory actions 

that make public lands grazing economically unsustainable will not only negatively impact individual ranch owners, but also 

entire rural communities that largely depend on ranching to maintain businesses and tax base.

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372. Numerous scientific studies have shown that well-managed livestock grazing is both compatible with and beneficial to Sage 

Grouse habitat conservation. Local ranchers provide defense against fire and noxious weeds, manage forage for optimum 

production, and are the primary protectors of open space. According to BLM's Instruction Memorandum No. 2012-043, 

"Given the potential financial constraints in addressing the primary threats [to Sage Grouse] identified by the [Fish and 

Wildlife Service] FWS, enhanced management oflivestock grazing may be the most cost-effective opportunity in many 

instances to improve Greater Sage-Grouse habitat on public lands." Similarly, the Natural Resources Conservation Service 

("NRCS") has stated that grazing "has been responsible for retaining expansive tracts of sagebrush-dominated rangeland 

from conversion to cropland" and can "stimulate growth of grasses and forbs, and thus livestock can be used to manipulate 

the plant community toward a desired condition."

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373. Wildlife species can actually benefit from some levels of livestock grazing. In fact, wildlife species diversity was highest in a 

mosaic of light to moderately grazed areas with mid to upper level ecological states. Grazing can be used to improve wildlife 

habitat and benefit certain wildlife species. This includes several wildlife species which are candidates for listing under the 

Endangered Species Act. See ~ E. W. Anderson & R. J. Scherzinger, Improving Quality of Winter Foragefor Elk by Cattle 

Grazing, 28 J. Range Mgmt., 120 (1975); Martin Vavra, Livestock Grazing and Wildlife: Developing Compatibilities, 58 

Rangeland Ecology & Mgmt 128 (2005); K. E. Severson & P. J. Urness, Livestock Grazing: A Tool to Improve Wildlife Habitat, 

in Ecological Implications of Livestock Herbivory in / _ f5 the West, 232.

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374. Grazing additionally reduces the instances and severity of wildfires (Launchbaugh et al. 2007); improves Sage Grouse habitat 

by increasing the quality and accessibility of forbs for sage grouse (NeeI1980, Derner et al. 1994, Evans 1996); and can be 

used to control invasive weeds (Olson and Lacey 1994, Walker et al. 1994).

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-881

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

375. Clearly a BLM Technical Team review that does not include the review and expertise from the range scientists should not 

be used for informing the BLM how to manage range and livestock grazing

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376. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: -

Landscapes managed for livestock grazing may fail to provide optimum habitat for sage grouse.

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377. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: -Fences 

cause direct mortality for sage grouse and serve as perches for their predators

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378. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: 

-Human-caused impediments to natural water drainage can reduce the input of water, nutrients and sediments, which help 

to sustain and recruit sagebrush.

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379. Livestock grazing is considered the single most important influence on sagebrush habitats and fire regimes throughout the 

Intermountain West in the past 140 years (Knick et al. 2005: 68). Grazing is the most widespread use of sagebrush steppe 

and almost all sagebrush habitat is managed for grazing (Connelly et al. 2004; Knick et al. 2003; Knick et al. 2011).6 Livestock 

grazing disturbs the soil, removes native vegetation, and spreads invasive species in sagebrush steppe (Knick et al. 2005). 

Cattle or sheep grazing in sage grouse nesting and brood-rearing habitat can negatively affect habitat quality; nutrition for 

gravid hens; clutch size; nesting success; and/or chick survival (Connelly and Braun 1997; Beck and Mitchell 2000; Barnett and 

Crawford 1994; Coggins 1998; Aldridge and Brigham 2003). Livestock may directly compete with sage grouse for grasses, 

forbs and shrub species; trample vegetation and sage grouse nests; disturb individual birds and cause nest abandonment 

(Vallentine 1990; Pederson et al. 2003; Call and Maser 1985; Holloran and Anderson 2003; Coates 2007).

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380. The potential conflict between livestock grazing and sage grouse intensifies near water sources due to the importance of 

these areas to sage grouse, particularly during early brood rearing. Heavy cattle grazing near springs, seeps, and riparian 

areas can remove grasses used for cover by grouse (Klebenow 1982). According to Call and Maser (1985:17), “rapid 

removal of forbs by livestock on spring or summer ranges may have a substantial adverse impact on young grouse, especially 

where forbs are already scarce.”

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381. Grazing infrastructure, such as water developments and fences, fragment and degrade sage grouse habitat (Connelly et al. 

2004; Braun 1998; Call and Maser 1985; Knick et al. 2003). Fatal collisions with fences were “relatively common and 

widespread” in sage grouse breeding habitat in southern Idaho (Stevens 2011), corroborating other evidence that fences 

may pose a significant risk to low flying sage grouse (e.g., Danvir 2002, unpublished report). Fence densities exceed 2 

km/km2 in many areas occupied by sage grouse (Knick et al. 2011).

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382. Native vegetation communities in Great basin sagebrush steppe did not evolve with grazing pressure (Mack and Thompson 

1982). Excessive livestock grazing by domestic livestock during the late 1800s and early 1900s had significant impacts on 

sagebrush steppe and those effects persist today (Knick et al. 2003). Grazing (in addition to other factors) is implicated in the 

encroachment of conifers in sagebrush steppe, including western juniper (Juniperus occidentalis) (Kerr and Salvo 2007). 

Decades of livestock grazing have altered plant communities and soil and reduced productivity in sagebrush steppe (Knick et 

al 2003). Cattle grazed at “conservative” levels in sagebrush steppe in the northern Great Basin initially selected 

bunchgrasses in interspaces between sagebrush plants (France et al. 2008). The removal of native species from interspaces 

by cattle, in conjunction with other factors, appears to facilitate invasion by cheatgrass (Bromus tectorum) into these areas

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C. Comments by Resource Planning Issue

C-882 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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No.

Comment SubRegion

ID

Agency CmtLtrCode

(Reisner 2010). The spread of cheatgrass and other invasive plants into degraded rangelands has accelerated the natural fire 

cycle and threatens to convert enormous areas of sagebrush habitat into annual grasslands (Wisdom et al. 2005; Miller et al. 

2011).

383. Grazing management was identified as a threat to sage grouse by three expert panels and in recent reviews (Connelly et al. 

2011, Table 1). Federal scientists have suggested that “livestock grazing across the public lands of western landscapes has 

impacted and will continue to impact the quality of those habitats and their ability to support source populations of 

sagebrush bird species” (Rich et al. 2005: 592). The Fish and Wildlife Service concluded that grazing “can seriously degrade 

sage-grouse habitat” locally and that, “given the widespread nature of grazing, the potential for population-level impacts 

cannot be ignored” (75 Fed. Reg. 13942-13943). In their study on sage grouse in eastern Oregon, Call and Maser (1985: 3) 

made the following basic assumption: “Where there are conflicts between sage grouse and livestock on public lands, it may 

be essential to give priority to sage-grouse if they are to continue to exist on these areas.”

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384. According to Taylor et al. (2010:36), “Our vital rate analyses indicate that, in unstressed environments, altering grass height 

through grazing management may be an effective way to increase population growth rate and therefore population size.” 

Female survival and chick survival had the highest sensitivity to this variable, but nest success was also affected.

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385. Baker (2006) reviewed the fire history of sagebrush ecosystems and found natural fire to be a rare event, suggesting a fire 

rotation 325-450 years in length. However, overgrazing across many of the Great Basin states has led to the invasion of 

cheatgrass, a highly flammable noxious weed that accelerates the fire cycle to less than five years destroying the sagebrush 

upon which sage grouse rely for food and cover. Approximately 36 percent of the greater sage grouse range is invaded by 

cheatgrass (Lebbin et al. 2010). Because sagebrush requires at least 15 years (and up to 50) to reoccupy burned sites, 

restoring invades areas is a difficult and slow process. Preventing further spread into intact sagebrush should be prioritized.

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386. Sage grouse do not use cheatgrass. Invasive species was identified as a threat to sage grouse by three expert panels and in 

recent reviews (Connelly et al. 2011, Table 1). One panel listed cheatgrass as the most important threat to sage grouse in the 

western portion of its range (70 Fed. Reg. 2267), where it has invaded much of the lower elevation, xeric sagebrush habitat 

(Miller et al. 2011). Land uses such as livestock grazing (Reisner 2010), off-road vehicle use, and coalbed methane 

development (Bergquist et al. 2007), can facilitate cheatgrass incursion in sagebrush steppe.

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387. The recovery of sagebrush “treatment” areas is further complicated by livestock grazing, which can hamper the 

establishment of native plants and spread the seeds of noxious weeds such as cheatgrass. Lambert (2005) recommended 

protecting re-seeded areas from livestock grazing for no less than 3 to 5 years. However, this standard is virtually never 

adhered to in practice in the West, where virtually every acre of public land falls within a grazing allotment.

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388. Livestock Grazing • During spring and summer, do not permit grazing in key sage grouse habitats until after June 20 and 

remove livestock by August 1 with a goal of leaving at least 70 percent of the herbaceous production each year to form 

residual cover to benefit sage grouse nesting the following spring. • Prohibit twice-over grazing systems, where livestock pass 

through an area twice in a grazing season. • Encourage winter grazing, which is generally less negative for herbaceous 

vegetation and sage grouse than grazing during the growing season. • Water and salt should be placed near fences or fence 

corners, as livestock tend to congregate in these areas. The goal should be to reduce livestock impacts in the centers of

pastures or allotments. • Avoid constructing new fences; remove unnecessary fences; and visually mark remaining fences to 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-883

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

reduce sage grouse collisions with fences. • Facilitate permanent, voluntary grazing permit/lease retirement. (see Braun 

2006).

389. At minimum, the NEPA analysis should address the following: • Managing grazing levels in a way that is compatible with sage 

grouse habitat needs, and in Core areas, managing grazing to optimize sage grouse habitat conditions rather than maximizing 

livestock production.

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390. At minimum, the NEPA analysis should address the following: • Assessing the impact of fences as causes of sage grouse 

mortality, preventing new fence construction within 5.3 miles of sage grouse leks to protect nesting habitat, and eliminating 

existing fence in these areas to the greatest extent practicable.

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391. General Comments on the December 21, 2011 report from the Sage-grouse National Technical Team “A Report on 

National Greater Sage-Grouse Conservation Measures An alternative based on the Report will go far beyond what is 

required by the Purpose and Need. The Report fails to adequately incorporate the successful efforts by the local sage grouse 

working groups and may stop effective efforts that are currently underway. It places arbitrary and capricious limits on 

recreational activities (roads and trails) as well as water developments. It would also direct the agencies to retire grazing

allotments, which is currently prohibited by law. Additional alternatives should be developed to respond to these and other 

concerns

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392. Finally, the Coalition urges BLM and the Forest Service to proceed with caution in implementing the prescriptions for sage 

grouse management found in the 2011 Technical Team Report. The majority of these conservation measures lack supporting

data and many will cause harm to rangeland resources and destroy local communities and their economies.

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393. Livestock Grazing Incorrectly Singled Out Livestock grazing is described as a diffuse disturbance while the IM ignores other 

direct and diffuse disturbances, including wild horses, wildlife herbivory and hunting. Technical Team Report at p.14. It is 

difficult to understand the basis or the criteria used. CLG views this portion of the Technical Team Report is naked attack 

on livestock grazing that merits sanctions for its lack of merit. The recommendations for grazing show a fundamental lack of 

knowledge about grazing regulation and other grazing animals. In most western states, livestock numbers have declined 

while wildlife and predator numbers have increased. Ex. 1 pp. 3-4; Ex. 1A pp. 6-9 (grazing created more favorable habitat 

conditions for sage grouse). The RMP revisions need to develop the data regarding big game, wild horses and livestock

numbers for each project area. Livestock grazing initially set in motion plant succession that created sage grouse habitat and 

predator control in defense of livestock made it a safe environment for sage-grouse. Ex. 1A pp. 9-10. Livestock grazing on 

the majority of the allotments has been managed under use limits, rotations and stocking rate limits. It should be noted that 

an important difference between livestock grazing and wild horses/big game is that the entire annual increase of livestock is 

removed each and every year and sent to market This is not the case, especially with wild horses. Healthy native range is as 

important to range livestock production as it is to sage grouse. The premise that livestock grazing as currently managed 

adversely affects sage-grouse or sage grouse habitat lacks documentation. Ex. 1A p. 8. Livestock do not eat sagebrush which 

is the winter cover and food source for sage grouse. Livestock do not directly harm sage grouse. For more than 15 years, 

grazing has been regulated under rangeland health standards. 43 C.F.R. §4180.2 (grazing must meet, maintain or make 

progress towards meeting range health standards). These standards were developed to protect and improve riparian areas, 

native vegetation and plant health and cover for all rangelands, which contributes to improvement of sage grouse habitat. 

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C. Comments by Resource Planning Issue

C-884 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Virtually all operators use a deferred or rest rotation system and do not use the rangelands year-round, unlike some wildlife 

and all of the wild horse herds. To the extent that the criteria are not consistent with rangeland health standards, they must 

be ignored or set aside because rangeland health standards are mandated by regulation which supersedes an IM. 43 C.F.R. 

Part 4180. The Technical Team Report conservation measures appear to attribute livestock use to the decline in sage grouse 

habitat, Ex. pp. 3-4. This ignores the irreplaceable role that grazing plays in reducing fuel loads, improving plant palatability 

and vigor. If livestock grazing were removed, the private land associated with these ranches will be subdivided, with a loss in 

wildlife habitat and recreation access. The trend towards subdivisions accelerated after BLM contended incorrectly that 

livestock grazing caused the desertification of western rangelands, declines in wildlife habitat, and water quality degradation 

in the contest of the grazing rules revision. If BLM is going to require removal of livestock during key periods of its life cycle,

Technical Team Report at p.15 (implement management actions which could include temporary non-use or livestock 

removal), it must do so for all other herbivores, including wild horses. It is not feasible to remove all herbivores, and for the 

same reason, it is ridiculous to assume that livestock should be removed as well. The recommendation to retire grazing 

privileges is unwarranted. BLM could improve rangeland health more quickly by moving wild horses onto private lands in 

nonpublic land states. The Technical Team Report also fails to recognize the stewardship of the livestock industry

394. B. Adaptive Management Not Prescriptive Management CLG believes that continued management of public rangelands to 

meet healthy standards will also ensure viable populations of sage grouse for decades to come. CLG supports adaptive 

management but IM 44, Technical Team Report, leaves no room for adaptive management. BLM should adopt the object of 

managing for rangeland resources and rangeland health and monitor population numbers. Then if there are changes in 

numbers, BLM would adjust based on the factors specific to the site.

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395. Listing the sage grouse on the endangered species list, or enacting inhibitive rules upon western range lands will be 

extremely detrimental to my family’s livelihood and our way of life.

Though I was raised on a ranch in northern Nevada, I recently returned to the area with my husband and two year-old 

daughter, after purchased a ranch last year. The ranch, like most in the area, is dependent upon public range land for cattle 

grazing. Without grazing access on rangelands, our newly purchased ranch is no longer a viable business.

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396. Cattle and sage grouse have cohabitated western rangelands for years. All Both emc0372GB

397. Most importantly, there is no better steward of the land than a rancher. When Forest and BLM agencies consistently speak 

of underfunding and understaffing, ranchers are there, caring for rangelands. Ranchers distribute salt and mineral, attracting 

and benefiting various wildlife species. Not to mention the water sources established and maintained by ranchers.

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398. Removing cattle and ranchers from public lands will take away an ally from the sage grouse, and take away the livelihood 

from many western ranchers.

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399. The BLM has a multiple use mandate under Federal Land Policy and Management Act (FLPMA). The existing Resource 

Management Plans (RMPs) were developed after many years of analysis and public input, resulting in land use plans that 

struck an acceptable balance between multiple uses. Yet, this latest effort illustrates the continued threat of political vagaries 

potentially shifting that balance in a manner that is detrimental to energy development, grazing, fuel and vegetation 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-885

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

management, mineral development and recreation. Any selected alternative must minimize the restrictions placed on these 

legitimate and important land uses. We encourage the BLM to follow through on its commitment to protect valid, existing 

rights; such as grazing and energy leases and RS 24 77 access rights. We encourage the BLM to look not only at habitat 

availability, but also habitat suitability given the energy and mineral potential and other multiple use potential of preliminary 

priority sagegrouse habitat areas. The adoption of sound consistent land use areas insures there is no risk of sage-grouse 

conservation efforts hampering the energy industry's ability to produce domestic natural resources

400. Rangeland management must recognize the beneficial aspects of grazing in sustaining rangeland health and the rangeland 

improvements that have been made through the coordinated efforts of BLM managers and grazing permittees. Restortation

grazing systems should be considered rather than no-grazing alternatives.

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401. In the NOI, it states that, “The inadequacy of regulatory mechanisms to conserve the greater sagegrouse and its habitat was 

identified as a significant threat in the FWS finding on the petition to list the greater sage-grouse as a threatened or 

endangered species." We strongly disagree with this statement and believe that BLM already has a surplus of regulatory 

mechanisms, primarily through rangeland health standard and guidelines, to conserve GSG habitat. Rangeland health 

standard and guidelines included provisions that apply to any use of federal lands including grazing, wild horses, and other 

vegetation disturbances including mining and grants of rights-of-way. These standards and guidelines are in addition to many 

controls specific to certain uses (e.g., mining) with strong regulatory controls at both the state and federal levels. If meeting 

habitat needs and rangeland health through established standards and guidelines and regulations is inadequate to conserve 

GSG habitat, what will ever be considered adequate? Perhaps the real issue lies within the fact that federal land managers and 

wildlife agencies are not currently adequately managing to meet the standards and guidelines for working, healthy rangelands 

and habitats. More regulation and red-tape should not be a measure considered to keep the GSG from being listed. More 

rules and regulations don't make progress happen on the land. The federal land management agencies should focus on what 

is already in place.

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402. a county that strongly relies on ranching conducted on or in concert with federally managed land, we are confused and 

alarmed over the allegations of "inadequate regulatory mechanisms." Based on the terms and conditions of livestock grazing 

permits and wide latitude granted to BLM on administering grazing permits that make progress towards established 

standards and guidelines, where are the actual shortages of not having enough control over livestock grazing? Even with 

many allotments meeting the standards for healthy rangelands, it appears that this does not seem to be sufficient for FWS, 

or an impetus for BLM to defend current protections that are or can already be put in place regardless of a LUP amendment. 

We have seen examples of instances within our county where it has been determined that livestock grazing is not a causal 

factor for not meeting standards yet we still see grazing permit changes made. We see this process as being magnified with 

the possibility of more restrictions being unduly placed on grazing permits. Those special interests who actively advocate 

for listing of the GSG openly consider it to be their best tool to achieve their overall goal of ending many uses on federally 

managed lands including livestock grazing. These entities are assisted in reaching their goal by federal and state government 

agencies who fail (or refuse) to recognize that proper management, when it occurs, is sufficient in maintaining, and often 

enhancing, GSG habitat. Given the potential for beneficial gains to enhance protection of habitat areas (especially for the

management of fine fuel loads and invasive plants) properly managed livestock grazing should be the focus rather than grazing 

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C. Comments by Resource Planning Issue

C-886 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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No.

Comment SubRegion

ID

Agency CmtLtrCode

prohibition. Grazing must be evaluated in the context of a tool to assist in accomplishing rangeland health objectives and 

GSG habitat enhancement. These considerations need to be documented and advanced in a proactive, unapologetic manner.

Because livestock grazing, as is also the case with any number of other authorized uses, are managed with a significant set of 

regulatory oversight, we maintain that the impression of there being a lack of regulatory control, as a false pretense for 

further expansion of a regulatory regime. We believe that the LUP amendments should be based on a full range of possible 

approaches with the end results of rangeland health, socioeconomic stability, and GSG population improvements tied

strongly together and not mutually exclusive. Ongoing monitoring and adaptive management procedures need to be spelled 

out to ensure that actions are measured against measurable and attainable objectives and fine-tuned or completely changed 

within an identified range of opportunities for public involvement. NEPA analyses should not start with the assumption that 

livestock grazing is a threat to GSG conservation in management areas. Instead, such analyses should start from the proven 

premise that managed livestock grazing are a benefit for GSG, and the analyses should consider how to further incorporate 

managed livestock grazing into the protection strategy.

403. While evaluating the ramifications of possible curtailment of livestock grazing use, consideration shouldtake into account the 

linkage between private ranch lands and federal land permits. Although we don't agree with the perspective that curtailment 

of properly-managed livestock grazing will have a beneficial result, we do want to stress the potential negative consequences 

for GSG habitat on private lands, if a livestock grazing permit is not allowed to be used. In order to maintain business 

operations, possible conversion of private land holdings may result from not being able to make use of federally-managed 

lands. More intensive land use of these private resources could result in a negative outcome for habitat located on private 

land. In areas where private lands and federally-managed lands are found in alternating sections (i.e., “checkerboard” lands) 

or where private lands make up a significant portion of large tracts of habitat, this increase in fragmentation would 

undoubtedly be far more of a problem and impact on GSG.

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404. For the most part we are concerned that the designation of these habitats and the regulatory application of conservation 

measures will be arbitrary without actual land-based conditions or grounded with proper rangeland science—namely 

Ecological Site Descriptions and State and Transition Models. The large majority of Ecological Sites in the state of Nevada do 

not have State and Transition Models developed and our local experience has shown that rangelands with their associated 

GSG habitats are too often managed based on old, outdated, and disproven Clementsian succession. The support 

documents attached or referenced by BLM are described as the “science” that will lay the foundation for the LUP revisions 

and on-the-ground management. These reports and documents magnify our concern because it is very apparent that much 

of the described understanding by the wildlife biologists is disconnected from current rangeland science.

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405. Our main concern is that kicking cattle off the range is not the intent of the protection agencies. It is a fact that properly 

managed grazing is very beneficial for the wildlife on the range. Cattle grazing can improve sage grouse habitat by increasing 

the accessibility of vegetation. Grazing also stimulates re- growth and helps re-seed. Historically, the co-mingling of cattle 

grazing and sage grouse has been shown to be positive. For example, the greatest number of sage grouse correspondswith 

the greatest number of livestock grazing.

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406. I believe that habitat plans should be site specific and not a state wide blanketed plan. We have already have had and are in

the middle of Sage Grouse habitat vegetation projects on public and private lands in our allotment and county. A lot of 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-887

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

private land in this area has some preferred use for Sage Grouse, taking livestock off the public range will result in over use 

of the private which in some areas more preferred to the Sage Grouse.

407. History, studies, and common sense dictate that good livestock grazing promotes a strong, healthy, sage-grouse population. 

In the past, when sage-grouse populations were higher, livestock (both cattle and sheep) grazed the range in higher numbers. 

There was also not the high incidence nor huge magnitude of rangeland wildfires that is occurring today. Grazing itself 

ensures a more vigorous, palatable plant community. Thus, livestock grazing and a prolific sage-grouse population go hand in 

hand.

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408. Public land is public and serves many uses besides ranching, however responsible livestock grazing is crucial to managing 

public land. It only makes sense that livestock grazing be a key component to not only managing for sage grouse, but wildlife 

in general.

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409. In addition, should ranchers find it economically unviable to remain ranching, private land will likely go on the market and 

quite possibly exit the agriculture sector. As urbanization has been the trend, It would be a shame for more prime 

agricultural land to go into housing development.

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410. The success of most cow/calf operations depends on being able to use federal rangeland. We gladly accept responsibility of 

managing the range that has been entrusted to us. As stewards of this range we are closer to it than anyone and fervently 

request to be involved firsthand in this quest to conserve the greater sagegrouse.

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411. Bottom line...because our livelihood depends on public land grazing we CARE about public lands. Because our livelihood 

depends on public land grazing we are very willing to work with efforts aimed at wildlife conservation, including that of the

greater sage-grouse. Removing livestock from the public rangeland would be detrimental to wildlife, the general public, 

ranching, and the local economy.

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412. Livestock grazing management.

Issue: Livestock grazing is the most pervasive land use in sagebrush steppe and has led to significant loss of grass and forb 

cover in sage-grouse habitat. Most sage-grouse habitat fails to meet sage-grouse habitat objectives.

Issue: Livestock grazing contributes to the spread of invasive species, conifer encroachment and unnatural fire in sagebrush 

steppe.

Issue: Livestock management as normally practiced by federal agencies leads to significant degradation of riparian areas.

Issue: Range facilities such as water developments, fences, and nutrient supplements generally negatively affect sage-grouse.

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413. Livestock grazing is considered the single most important influence on sagebrush habitats and fire regimes throughout the 

Intermountain West in the past 140 years (Knick et al. 2005: 68). Grazing is the most widespread use of sagebrush steppe 

and almost all sagebrush habitat is managed for grazing (Connelly et al. 2004; Knick et al. 2003; Knick et al. 2011).11 

Livestock grazing disturbs the soil, removes native vegetation, and spreads invasive species in sagebrush steppe (Knick et al. 

2005). Cattle or sheep grazing in sage-grouse nesting and brood-rearing habitat can negatively affect habitat quality; nutrition 

for gravid hens; clutch size; nesting success; and/or chick survival (Connelly and Braun 1997; Beck and Mitchell 2000; Barnett 

and Crawford 1994; Coggins 1998; Aldridge and Brigham 2003). Livestock may directly compete with sage-grouse for 

grasses, forbs and shrub species; trample vegetation and sage-grouse nests; disturb individual birds and cause nest 

abandonment (Vallentine 1990; Pederson et al. 2003; Call and Maser 1985; Holloran and Anderson 2003; Coates 2007). The 

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C. Comments by Resource Planning Issue

C-888 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

potential conflict between livestock grazing and sage-grouse intensifies near riparian and mesic habitats due to the

importance of these areas to sage-grouse, particularly during brood-rearing and in summer. Heavy cattle grazing near 

springs, seeps, and riparian areas can remove grasses used for cover by grouse (Klebenow 1982). According to Call and 

Maser (1985:17), “rapid removal of forbs by livestock on spring or summer ranges may have a substantial adverse impact on 

young grouse, especially where forbs are already scarce.”

414. Grazing infrastructure, such as water developments and fences, also fragment and degrade sagegrouse habitat (Connelly et 

al. 2004; Braun 1998; Call and Maser 1985; Knick et al. 2003). Fatal collisions with fences were “relatively common and 

widespread” in sage-grouse breeding habitat in southern Idaho (Stevens 2011), corroborating other evidence that fences 

may pose a significant risk to low flying sage-grouse (e.g., Danvir 2002, unpublished report). Fences (like other high 

structures) may serve as perches for raptors and other avian predators of sage-grouse nests, chicks and adults (Connelly et 

al. 2011b). Fence densities exceed 2 km/km2 in many areas occupied by sage grouse (Knick et al. 2011).

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415. Native vegetation communities in sagebrush steppe did not evolve with significant grazing pressure by large ungulates (Mack 

and Thompson 1982). Excessive livestock grazing by domestic livestock during the late 1800s and early 1900s had significant 

impacts on sagebrush steppe and those effects persist today (Knick et al. 2003). Grazing (in addition to other factors) 

isimplicated in the encroachment of conifers in sagebrush steppe, including western juniper (Juniperus occidentalis) (Knick et 

al. 2011, citing Miller and Rose 1999; Kerr and Salvo 2007, unpublished report). Decades of livestock grazing have altered 

plant communities and soil and reduced productivity in sagebrush steppe (Knick et al 2003). Cattle grazed at “conservative”

levels in sagebrush steppe in the northern Great Basin initially selected bunchgrasses in interspaces between sagebrush 

plants (France et al. 2008). The removal of native species from interspaces by cattle, in conjunction with other factors, 

appears to facilitate invasion by cheatgrass (Bromus tectorum) into these areas (Reisner 2010). The spread of cheatgrass and

other invasive plants into degraded rangelands has accelerated the natural fire cycle and threatens to convert enormous 

areas of sagebrush habitat into annual grasslands (Wisdom et al. 2005c; Miller et al. 2011). Ecological modeling indicates that 

sheep grazing in sagebrush steppe may cause declines in sage-grouse populations (particularly where large, frequent fires also 

occur in the same area) (Pederson et al. 2003).

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416. Rich et al. (2005: 592) suggested that “livestock grazing across the public lands of western landscapes has impacted and will 

continue to impact the quality of those habitats and their ability to support source populations of sagebrush bird species.” 

The authors contended that, contrary to prevailing sentiment, the number of animal unit months (AUMs) provided on 

federal public lands in Oregon, Idaho and Washington, has varied little over the period from 1949 and 2000 and

that there were more AUMs on public lands in these states in 2000 than 1949 (when recordkeeping began) (Rich et al. 2005). 

Further, “livestock have been selected so that the mean mass of individuals has increased over time” and, consequently, “the 

total grazing impact on the vegetation and other resources is substantially greater than it was historically” (Rich et al. 2005:

599 and figures).

Beck and Mitchell (2000) reviewed literature for positive and negative direct and indirect effects of livestock grazing on sage 

grouse. Their review found more negative than positive impacts from grazing. (Beck and Mitchell 2000: 994, Table 1). 

However, of greater importance is the scope of the reported positive and negative impacts on sage-grouse and sagebrush 

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habitats. While positive impacts are generally limited to specific areas and circumstances (e.g., light grazing regenerates 

upland meadow), negative impacts often affect much larger areas, rendering them unusable for sage-grouse. Impacts should 

be considered in the context of their scale. For example, a sage grouse population in southeastern Idaho may have benefited 

indirectly from presence of livestock when they established strutting grounds on sheep salting areas [very small areas

relative to overall habitat], whereas weed infestations induced by livestock grazing in the Great Basin may reduce quality of 

habitat for sage grouse populations across this vast region. (Beck and Mitchell 2000: 997, citations omitted). Connelly et al. 

(2007), citing Coggins (1998) and Beck and Mitchell (2000), stated that “[t]he large number of documented negative impacts 

of livestock grazing in sagebrush shrub steppe appears to neutralize or outweigh any positive effects.” Jones (2000) found 

that 11 of 16 analyses of the effects of livestock grazing in arid ecosystems revealed significant negative effects on a

range of ecological components from livestock grazing, including reduced grass and shrub cover, and reduced total 

vegetation biomass.

Beck and Mitchell (2000) concluded that livestock grazing appears to most affect productivity of sage grouse populations. 

Moynahan et al. (2007) also noted that condition of greater sage-grouse nesting habitat, an important factor in sage-grouse 

productivity, is likely affected by livestock grazing, among other influences. Holloran et al. (2005: 648) documented the 

importance of herbaceous cover, including residual grass, to sage-grouse nesting success and concluded that “annual grazing 

in nesting habitat, regardless of the timing, could negatively impact the following year’s nesting success [by reducing residual 

vegetation].” Aldridge and Boyce (2007: 522), citing Manier and Hobbs (2006), suggested that removing cattle or reducing 

livestock intensity may result in increased shrub cover and/or plant diversity in shrubsteppe. They also suggested that 

eliminating water impoundments (such as earthen livestock watering holes) may allow water to recharge former mesic sites 

in sagebrush steppe, which would benefit sage-grouse (Aldridge and Boyce 2007: 523).

Grazing management was identified as a threat to sage-grouse by three expert panels and in recent reviews (Connelly et al. 

2011: 555-556, Tables 24.1, 24.2). Federal government scientists have suggested that “livestock grazing across the public 

lands of western landscapes has impacted and will continue to impact the quality of those habitats and their ability to support

source populations of sagebrush bird species” (Rich et al. 2005: 592). In their study on sage-grouse in eastern Oregon, Call 

and Maser (1985: 3) made the following basic assumption: “[w]here there are conflicts between sage grouse and livestock on 

public lands, it may be essential to give priority to sage-grouse if they are to continue to exist on these areas.”

417. Contributions of Livestock Grazing to Cheatgrass Incursion

Livestock grazing appears to spread cheatgrass through multiple effects (Chambers 2008b) and grazing is probably not 

effective to control cheatgrass in preparation for restoring sagebrush steppe (Hempy-Mayer and Pyke 2008). Other 

information suggests that there are simply not enough livestock available to graze at the preferred locations, at the preferred 

intensity, at the preferred times during the year, to control cheatgrass at a landscape-level (McAdoo et al.,

undated, factsheet). The number of livestock and grazing intensity required to control cheatgrass would also probably have 

additional negative effects on native vegetation, soil, and other resources in sagebrush steppe that could outweigh any 

benefits from cheatgrass control. The removal of herbaceous perennials by grazing may increase water and nitrate 

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availability to cheatgrass, and less perennial herbaceous cover may increase cheatgrass invasion (Chambers et al. 2007). The 

removal of cheatgrass by grazing may also increase cheatgrass seed production the following year (Chambers et al. 2007). 

Cheatgrass invasibility is lowest on sites with relatively high cover of perennial herbaceous species (Chambers et al. 2007).

Cheatgrass incursion in sagebrush steppe began in the 1850s with the introduction of domestic livestock, which trampled 

the biological soil crust that occupied the interspaces between native vegetation (Mack 1981) and facilitated the species’ 

spread. Intact, lichen-dominated biological soil crusts can significantly inhibit germination and root penetration of cheatgrass 

(Deines et al. 2007), while the presence of cheatgrass can negatively affect biological soil crust richness and cover (Ponzetti 

et al. 2007). Moss-dominated biological soil crusts may also effect germination of annual grasses, including cheatgrass (Serpe 

et al. 2006). The diversity, cover and resiliency of biological crusts are positively correlated to low abundance of cheatgrass, 

low level of soil disturbance and high moss cover (Ponzetti et al. 2007). Shinneman et al. (2008) discovered that

herbaceous and biological soil crust cover and species richness and diversity were generally greater on ungrazed than grazed 

areas in semi-arid shrubsteppe in western Colorado.

The recent proclamation by Davies et al. (2011: 3) that “livestock grazing per se is not a stressor threatening the 

sustainability of the [sagebrush] ecosystem”—that did not account for the direct and indirect contributions of grazing to the 

spread of cheatgrass—is without merit. The authors failed to consider the role of livestock grazing in altering the outcome 

of competitive interactions between bunchgrasses and cheatgrass, or the role of disturbance in succession and community

assembly in sagebrush steppe (see Reisner 2010). Similarly, even if sagebrush steppe in the Wyoming Basin evolved with 

moderate herbivory (Mack and Thompson 1982), grazing prescriptions in sage-grouse habitat in Wyoming (e.g., Cagney et 

al. 2010) that fail to recognize the increasing presence of cheatgrass in the state (Smith and Enloe 2006, factsheet) may

inadvertently contribute to its spread.

418. Livestock Grazing Management.

Developing and implementing grazing systems that are positive or neutral for sage-grouse is complex (Vavra 2005) (and may 

be impossible). Kuipers (2004) found (weak evidence) that nesting habitat selected by sage-grouse hens, nest success and 

brood-rearing habitat were associated with greater canopy cover, residual grass, and forb availability, respectively, on sites

that were not grazed, or only lightly grazed in spring in Wyoming. Woodward (2006) (c.f. Adams et al. 2004) confirmed 

some of these findings and noted that reduced grazing/light grazing and/or deferred grazing in sage-grouse nesting habitat in 

spring lessened impacts on shrubsteppe vegetation and reduced conflicts with sage-grouse. Aldridge et al. (2008)

recommended altering grazing practices in sagebrush steppe during times of drought to conserve herbaceous vegetation for 

sage-grouse.]

Some references recommend implementing high intensity, short-duration (rotation) grazing systems to conserve prairie 

grouse (e.g., Lupis et al. 2006). Notwithstanding the fact that large areas of sagebrush-steppe did not evolve with large, 

hoofed herbivores (Mack and Thompson 1982), Holechek et al. (1999) reviewed the literature and found that forage 

production generally did not differ between rotation grazing systems and continuous or season-long grazing. Further,

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Wolfe et al. (2007) noted that high intensity, short-duration livestock grazing recommended to conserve prairie grouse 

frequently requires more fencing, which can be negative for sage-grouse. Decades of research by range professionals provide 

direction to recover depleted bunchgrass communities, restore production and provide cover for sage-grouse and other 

wildlife species in upland (nesting) and riparian (brood-rearing) areas. Galt et al. (2000) and Holecheck et al. (2010)

recommend 25 percent utilization to improve productivity and land health compared to higher utilization levels. To maintain 

adequate cover in riparian areas, USFS researchers determined that 24-30 percent utilization across the riparian zone will 

maintain 6” residual height (Clary and Webster 1989). These authors also indicated that, for riparian areas in degraded 

condition, as much as 15 years rest may be needed for recovery (Clary and Webster 1989).

Native bunchgrasses in sagebrush steppe, such as bluebunch wheatgrass and Idaho fescue, also require rest after being 

grazed during the growing season. Hormay and Talbot (1961) designed rest-rotation grazing to allow recovery after each 

grazing session, allowing sensitive native bunchgrasses to recover their vigor. Other BLM and USFS researchers have 

provided guidance for recovery of native bunchgrasses that may require multiple years of rest to restore vigor

(Anderson 1991; Mueggler 1975). Anderson and Inouye (2001) working in sagebrush steppe in southern Idaho determined 

that native perennial grasses were recovering after 45 years of livestock exclusion and the increasing trend of these native 

grasses was inversely correlated to non-native invasive species such as cheatgrass. Range scientists have determined that 

stocking rate rather than grazing system is the primary factor affecting rangeland production (Briske et al. 2008; Holechek et 

al. 1998; Van Poollen and Lacey 1979), yet agencies continue to place emphasis on water developments and increased

fencing rather than addressing current forage capacity and landscape constraints. For example, cattle heavily graze riparian 

areas before moving on to adjacent uplands to seek forage (Pinchak et al. 1991). Deferred rotation grazing resulted in higher 

use of meadows and there was no correlation of upland presence of cattle with upland water developments (Gillen et al. 

1984). Galt et al. (2000) and Holechek et al. (2010) provided recommendations for establishing stocking rates in arid 

rangelands that recognize the constraints of topography, water availability and forage production on livestock stocking rates. 

Table 3 presents factors that are applied to align stocking rates with capacity and reduce the risk of excessive grazing. These 

are then combined with current forage availability available and the consumption rates of livestock to determine the

stocking rate.

419. Discrete Disturbance from Livestock Grazing.

The NTT report considers livestock grazing a “diffuse” disturbance in sage-grouse habitat, which disregards the pronounced 

effects of grazing around water developments, salting and supplemental feeding areas, and fences. It is important to recognize 

that livestock infrastructure such as water developments and salt placement are attractants to livestock, resulting in

concentrations at these locations that can have similar impacts on sagebrush steppe as other “discrete” disturbances (e.g., oil 

and gas wells). Fencelines also become travelways for trailing livestock and can have noticeable effects on sagebrush habitat.

The concentrated effects of livestock use near water sources is an example of how diffuse grazing can cause discrete 

disturbance on the landscape. Holechek et al. (2001) stated that, depending on topography, areas of severe degradation, or 

“sacrifice areas” around water sources, including water developments, can extend from one to several miles from water 

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Table C-6.A

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sources. Holechek et al. (2004), citing others, described the effects of water developments on forage production and native 

bunchgrasses in Idaho, Montana and New Mexico, noting that nearly all forage is used around water developments, 

decreasing with increasing distance from water. They reported that, under moderate grazing intensities, forage production 

was most severely reduced in the zone 0.5 miles from water. The authors noted that “perhaps the greatest problem with

additional water developments is degradation of rangeland in high ecological condition” (Holechek et al. 2004: 321). They 

lamented that “[r]egrettably we have observed the degradation of many publicly owned, high condition rangelands when 

permanent water developments were installed” (Holechek et al. 2004: 321).

Rinehart and Zimmerman (2001) studied the effects of livestock water developments on plant communities in the Little 

Missouri National Grassland, measuring total species, native bunchgrasses, other perennials, native species, decreasers, 

vegetation structure, and grass production. Each of these parameters was lowest in the areas near water developments and

gradually increased out to one mile, the furthest point measured. Green needlegrass and needle and thread, both 

bunchgrasses valuable for their height, cover and production, were considered decreasers, while blue grama, a short grass, 

was an increaser that replaced the taller bunchgrasses in areas closer to water. The effect of this disturbance on factors 

relevant to sage grouse habitat are tabulated in Table 4.

Based on these sources, livestock grazing around water developments may adversely affect an area up to one-mile radius 

from the development. There is little information on disturbance from grazing and trampling around salt blocks, 

supplemental feeding areas and fences. It is incumbent on federal agencies to define an area of impact around water 

developments and other infrastructure in sage-grouse habitat in order to account for these disturbances in the maximum

allowable disturbance on the landscape.

420. We also want to emphasize the benefits of livestock grazing to the range and to species and that it can and should be used 

as a tool to manage for the primary threats to sage grouse in Idaho. As the agencies move forward with NEPA analysis, it is 

critical that they do not start with the assumption that livestock grazing is a threat to sage grouse conservation in 

management areas. Instead, such analyses should start from the premise that properly-managed livestock grazing is beneficial 

to greater sage-grouse, as scientific studies have shown. The analyses, therefore, must consider how to incorporate 

properlymanaged livestock grazing into the protection strategy.

Grazing is both compatible and beneficial to sage grouse habitat conservation. This has been proven by independent, 

peer-reviewed scientific analysis. Ranchers are the stewards of the sage grouse habitat on both the private and public range 

lands. Allowing ranchers the continued use of public lands without unnecessary restrictions due to the potential listing of a

species with such a large habitat encourages this stewardship and prevents fragmentation through development. As seen in 

many areas of successful rangeland conservation, livestock grazing and habitat conservation go hand in hand. Adequate 

regulatory mechanisms are already in place through rangeland standards and guides to ensure that grazing is managed for 

ecosystems and sensitive species.

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421. Without ranchers, who provide an effective line of defense against fire and noxious weeds, who manage forage for optimum All Both emc0392GB
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production, and who are the primary protectors of open space in the private lands of the west, large areas of greater 

sage-grouse habitat would be in jeopardy. The benefits provided by ranching relate directly to several identified threats to 

greater sage-grouse habitat, including wildfire, invasive plants, and urbanization and development.

422. Historically, the co-mingling of cattle grazing and sage grouse has been shown to be positive. For example, the greatest 

number of sage grouse corresponds with the greatest number of livestock grazed. The sage grouse like the small fine grass 

that is left behind after livestock have eaten off all of the tall grass. Eliminating the old tall grasses in areas allows the birds to 

eat and see predators that may eat the chicks

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423. well-managed livestock grazing is an etTective and sustainable method for combating several of the most significant threats 

to sage grouse habitat including fuels reduction to minimize wild fires and to prevent or slow invasive species and conifer 

proliferation.

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424. As recognized by the BLM in 1M No. 2012-043, grazing can be "used as a tool to protect intact sagebrush habitat and 

increase habitat extent and continuity which is beneficial to the Greater Sage-Grouse and its habitat." The 1M continues, 

"Given the potential financial constraints in addressing the primary threats identified by the FWS, enhanced management of 

livestock grazing may be the most cost-effective opportunity in many instances to improve Greater Sage-Grouse habitat on 

public lands." According to Natural Resources Conservation Service (NRCS), grazing "has been responsible for retaining 

expansive tracts of sagebrush-dominated rangeland from conversion to cropland" and can "stimulate growth of grasses and 

forbs, and thus livestock can be used to manipulate the plant community toward a desired condition."

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425. Grazing as a Conservation Tool. PCW supports BLM's recognition that grazing can be used as a conservation tool for 

greater sage-grouse. Bainter et al. (2009), among other studies, have demonstrated that through implementation of 

appropriate grazing and vegetation management practices, sagebrush and sage-grouse habitats improve at a higher rate than 

if grazing is excluded from the landscape. Since the mid-1990s, TOTCO has utilized an intensive rest-rotation and seasonal 

timing grazing program that has resulted in improvement of all types of seasonal greater sage-grouse habitat as well as 

resulting in an increase in livestock forage and productivity. Rather than considering retirement of grazing privileges on an 

allotment when a base property is transferred or the current permittee is willing to retire grazing, BLM should evaluate 

changing its grazing paradigm and use grazing as a management tool to improve greater sage-grouse habitat

rather than eliminating grazing altogether.

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426. Probably fire is greatest danger to the sage grouse: controlled grazing is the greatest protection for controlling fire. All Both emc0403GB

427. Another recent impact that is happening to these wet meadows is on Blue Mt. there has been an explosion of elk numbers 

and their uncontrolled grazing is having an impact on these wet areas

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428. Indeed, human disturbances of all sorts, roads, railways, fences, reservoirs, towns, farms, mines, etc. flourished in the early 

to mid 1900s, and so did the sage-grouse. The mere presence of human activity seems to have little biologically relevant 

connection to sage-grouse population trends. However, specific human activities appear to correlate positively with GSG 

population trends. Livestock grazing management, with its associated intensive development of meadows, hayfields, and 

surface water sources increased markedly in the Great Basin in the late 1800s and early 1900s, and GSG populations 

boomed. High livestock densities of both sheep and cattle reduced fine fuel loads across the Great Basin, and wildfires were 

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rare and small. High densities of livestock dung also supplied an abundance of insect activity, particularly in closely grazed 

meadows and riparian areas, and the close grazing stimulated succulent new herbaceous growth and increased the forb 

component in these meadows and riparian areas, thereby increasing the quantity and quality of the forage supply for 

sage-grouse. At the same time, concerted predator control was practiced. In fact, predator control was encouraged,

subsidized, and implemented on a vast scale by the Federal and State governments. By the mid 1900s, Federal and State 

regulations were implemented and all of the grazing management practices discussed above were controlled and moderated. 

The GSG population boom moderated at about the same time. By the late 1960s, livestock numbers and grazing levels were 

significantly scaled back across the west, and predator control programs were largely curtailed. Fire fuel levels increased, and 

the incidence of large-scale wildfires rose exponentially. GSG population trends reversed and started to rapidly decline.

Thus, intensive livestock management which diminished the frequency and size of wildfires, and concerted predator control 

which reduced GSG loses to these killers, are management actions in the Great Basin that seem to be highly relevant to the 

biology of the GSG and help explain the trajectory of their populations over time. As shown in Figure 1, it is reasonable to 

assume that a return to effective management to increase livestock grazing levels, reduce fire fuel loads and wildfire impacts, 

and increase predator control would result in another significant upward trend in GSG populations. In contrast, proposed 

GSG conservation measures to provide heavier cover levels through further livestock grazing reductions, and the lack of 

conservation measures to address ever increasing predation levels, are a prescription to assure that GSG populations 

continue to decline. Heavier cover for GSG translates to higher fire fuel loads across the landscape, and substantial fuel loads 

make large-scale wildfires inevitable in many sagebrush communities. Repeat burns increase the likelihood that plant 

communities will shift toward cheatgrass dominance, which in turn increases wildfire frequency, eliminating the ability of 

sagebrush communities to re-establish. Thus, conservation measures that intend to benefit GSG by providing them with 

more hiding cover will ultimately harm the species by converting significant swaths of existing habitat to annual grasslands 

that provide no habitat value for GSG. This will concentrate the remaining birds in an ever shrinking area, making them more 

vulnerable to expanding predator populations.

429. We believe that prescriptive grazing is and historically has been a major factor in maintaining the health and sustainability of 

our lands in the west. We believe this to be a recognized and proven method that. recognized and used as a tool will 

promote Sage Grouse habitat restoration and preservation. As grazing is one ofthe strongest tools we possess, we

believe it is absolutely necessary that public lands ranching involvement and input into the EIS/SEIS and later the amendment 

process is crucial.

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430. If sage-grouse are to be conserved, BLM’s management paradigms and on-the-ground actions must immediately be changed. 

Habitats must not be sacrificed. The National Technical Team report underplays the serious ubiquitous pervasive threat to 

sage-grouse habitats posed by domestic livestock grazing across nearly all public lands. The Report and associated IMs 

continue near-status quo management for livestock and many other threats. The IM is riddled with loopholes, and very weak 

and ineffective provisions that are at times weaker than the NTT. For example, with livestock grazing where there is no 

requirement that anything at all actually has to change on the ground. For other threats, the NTT and Memos fall back on 

largely the same lists of BMPs and Standard Operating Procedures that have helped caused the demise of sage-grouse 

habitats over the years. Some oil ad gas provisions may be better than BLM had previously put on paper but applied only in 

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Priority areas.

431. BLM has a long history of making lofty promises of better management and conservation, then never implementing them. For 

example, in 2004, BLM’s National Sage-grouse Habitat Conservation Strategy) promised under Guidance for the 

management of sagebrush plant communities for sagegrouse: - Avoid constructing livestock management facilities (i.e. 

corrals, tanks, troughs, pipelines, fences, etc.) next to leks. - Design and locate the placement of fences for livestock so as 

to not disturb important sagegrouse habitat areas. - Consider seasonal closures to protect priority sage-grouse habitat if 

other alternatives will not achieve desired objectives. - Use grazing practices that promote the growth and persistence of 

native shrubs, grasses and forbs needed by sage-grouse for seasonal food and concealment - Maintain seeps, springs, wet 

meadows, and riparian vegetation in a functional and diverse condition for young sage-grouse. - Maintain sagebrush 

understory and diversity adjacent to crucial season sage-grouse habitat unless removal is necessary to achieve 

sage-grouse habitat objective. - Where other grazing practices are not achieving, or cannot achieve, the desired objectives, 

a short term option may be livestock exclusion. There were also some measures for oil and gas and geothermal 

development that have also been routinely ignored by the agency: - Avoid the impact of construction and operations by not 

placing mines, oil and gas and geothermal drilling sites and facilities, roads, and mineral material disposal sites in or next to 

sensitive habitats such as sage-grouse leks, nesting, brood rearing, breeding, or wintering habitat. - Whenever feasible and 

environmentally preferred, avoid surface occupancy by roads powerlines, fences, or other structures adjacent to occupied 

leks - Consider seasonal closures to protect priority sage grouse habitat if other alternatives will not achieve the desired 

objective. So BLM had already adopted some requirements to protect sagebrush habitats in permits for grazing recreation, 

mining, and oil and gas. The first energy provision above has been significantly weakened in the most recent iteration Priority 

scheme that allows more development to occur. The loose wording that always allows BLM an out so it can cave into 

industry has not been tightened up. Some of the provisions, such as relating to springs and seeps for Oil and Gas are not even 

included for geothermal in the IM. BLM’s Conservation Plan appears to provide broader protection for these habitats (see 

above). Now BLM uses maintain enhance, or restore only for PPH. None of this wording applies to PGH in the IM. So the 

situation is immediately worse for General habitat than under the Conservation Plan. Now BLM is only supposed to reduce 

and mitigate to the extent practical. The IM’s appalling General Habitat provisions appear to violate BLM’s 2004 

Conservation Plan.

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432. Wildfire, invasion of non-native plant species and livestock grazing work synergistically. Yet BLM and other agencies 

repeatedly try to point to fire and invasive species as threats divorced from livestock grazing disturbance, the most pervasive 

ecological stress across all parts of the sage-grouse range. Fires are occurring more frequently, and the size and intensity of 

fires are increasing. Fires reduce or eliminate shrubs, disturb soils, destroy microbiotic crusts, and release nutrients that

allow cheatgrass and other weeds to thrive. The end result in grazed landscapes is a paucity of shrub cover, few forbs, a 

shorter period of green plant material (as fires result in hotter, drier sites with little vegetation to trap snow, shade ground, 

and block wind), and a longer fire season.

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433. Cattle evolved in, and are adapted, to, cool, moist climates and are not native to the arid West (Mack and Thompson 

1982). Cattle feed preferentially on native grasses and forbs reducing or eliminating critical components of sage-grouse 

habitats. Historic and chronic ongoing livestock grazing eliminates or reduce food, nesting cover and cover from predators. 

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Livestock and management activities disturb and displace sage-grouse including in lek, nesting and winter habitats.Through 

degradation of the native plant communities, and trampling, displacement, compaction, erosion, of soils and microbiotic 

crusts, the livestock create ideal sites for weed infestation. Livestock are also vectors of weed spread. Weeds thrive in 

livestock manure nutrients (Belsky and Gelbard 2000). Impacts are intensified by livestock facilities like fences, water 

troughs, supplemental feeding/salting sites, yet agencies promote all of these actions, and continue to tout these actions as

beneficial and include them in laundry lists of BMPs. Many of these actions are conducted with minimal or piecemeal NEPA. 

In reality, such practices are overwhelmingly beneficial only to livestock, and serve to shift and intensify disturbance into

remnant less grazed areas.

434. Agencies have focused overwhelming on forage grass for livestock to eat and ignored many other stresses on the sagebrush 

ecosystem and biological conflicts and harms that are caused by livestock grazing disturbance to species’ habitats. This 

includes physical disturbance and displacement due to the presence of livestock, and a battery of other livestock-related 

disturbances to ecosystem components ranging from alteration of the complexity of sagebrush structure to trampling 

pulverizing microbiotic crusts.

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435. Now BLM in this sage-grouse EIS is stating that it is indeed going to address allocations. As part of the process of amending 

the Land Use Plans in this EIS process, BLM must fully consider causal factors of weed invasions and fuels problems like 

grazing and the plethora of BLM’s own treatments in making these allocations. It must change allocations, like livestock 

grazing, that promote weeds and flashy fine fuels like cheatgrass. BLM must also adopt an integrated weed management 

strategy, rather than the current Spray and Walk Away approach that ignores causes of weeds and fails to provide integrated 

weed/invasive species management. BLM treatment relies overwhelmingly on futile use of expensive chemical herbicides.

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436. BLM must re-examine all activity plan decisions that serve as the basis for continued management actions. Agencies must 

also look at much more than a ballpark estimate of forage in making allocations. Allocations, and findings of suitability or 

non-suitability for any continued grazing disturbance use must include detailed analysis of conflicts with sage-grouse habitat 

needs for space and cover, highlighting the species need for secure habitats free of disturbance. In any areas that may remain 

grazed after this suitability analysis is applied, levels of use to ensure the habitat characteristics that grouse actually require 

such as residual grass cover at nests must be applied. Sage-grouse must be guaranteed habitats secure from disturbance 

during lekking, nesting, brood rearing and wintering periods.

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437. Across many portions of the range of sage-grouse, livestock stocking rates are the results of old adjudication process, and 

AUMs never have been adequately reduced to levels that the land could be expected to sustain, even under the limited 

forage worldview of range science. Others derive from old settlements of rancher Appeals of BLM decisions. This means 

that ranchers often got more livestock, more facilities, and more forage seedings removing sagebrush habitat and other 

projects than BLM had even recommended in many of those decisions. The BLM MFPs and vintage RMPs typically have 

separate Rangeland Program Summaries or documents with lists of allotments and AUMs, often with reductions proposed. 

Some of these had AUM tallies that were based on Ecological Site Inventories and forage calculations from the early late 

1970s-1980s. These detailed ESI baseline studies have rarely ever been repeated. Many of the AUM reductions then 

proposed were never fully carried out.

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438. The primary, and often only, annual barometer of livestock use monitored by BLM is utilization. Utilization is based on All BLM emc0411GB
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May 2012 Greater Sage-Grouse LUPAs/EISs C-897

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

aboveground biomass of grass plants, i.e. weight of the plant material and not height. Most of the weight of a native 

bunchgrass grass plant is towards the base of the plant. So 40% utilization often means that a plant that stands 12 inches tall 

can be grazed down to 3-4 inches in height and still be measured as having only 40% use. This height is too low to provide 

the necessary residual screening cover to conceal sage-grouse nests from visual and scent predators. Plus utilization is 

averaged across the landscape, so 40% average utilization means many plants receive much greater use. Those higher use 

levels are harmful to the crown of the bunchgrass plant, which is exposed to winter freezing and baking in hot sun. Harms 

to the plant from such use levels may be even worse during the active and critical growing period for the plant. Changes in 

species composition occur over time, and larger or grazing-sensitive grasses are depleted. Sheridan CEQ 1986, Mack and 

Thompson (1982), Anderson (1991), Jarbidge AMS (2007), U.S. Forest Service Utilization Gauge, Anderson 1991 BLM 

Technical Bulletin. In lands that have become depleted by historical grazing, and then are faced with continued annual chronic 

grazing disturbance, many larger-statured grasses are missing. So the plant community composition has been altered and 

depleted - with smaller statured increaser species replacing larger grasses (a symptom of desertification, see Sheridan CEQ 

1986). Yet BLM often overlooks the utilization of the smaller grasses such as small native bluegrasses Poa that greens up 

with fall rains, and measures use only on scattered remnant larger grasses. Plus, BLM typically averages utilization over 40 or 

50 grass plants. This means that if the average utilization at a site is recorded as 40% - some plants are likely grazed to levels 

of 70% or more, which is quite damaging and can lead to injury, weakening/lack of vigor or death of the plant.

439. BLM avoids monitoring in areas receiving heavier levels of livestock disturbance. So the heavier use areas over large portions 

of the landscape go completely unexamined. Although BLM has monitoring manuals and methodologies, the truth is that 

often monitoring sites are agreed upon with ranchers, are rarely if ever actually random, and are selected to purposefully 

avoid areas of heavier livestock use. So BLM’s high utilization levels, combined with non-random cherry-picked monitoring 

sites, means that vast areas of degraded lands are not being monitored, and only one component of the environment (grass 

biomass removed) is measured when monitoring does occur. No use standards of any kind are ever applied to limit upland 

trampling impacts and damage to soils and microbiotic crusts.Even though some BLM monitoring guidance recommends 

monitoring at damaged areas because they are most vulnerable to weeds, soil erosion, and other threats, and serve as 

warning signs for ecological deterioration this does not happen. Even when BLM calls monitoring random, it is often far from 

being random. See Attached WWP 2011 critique of Winnemucca BLM’s 2011 non-random random ecological monitoring. 

Fundamentals of Rangeland Health (FRH) Rangeland Health Assessments are also done at cherrypicked representative sites 

with the areas suffering more damage also purposefully avoided. Many current upland Rangeland Health Assessment 

methods fail to include sufficient indicators and data required to understand sage-grouse habitat disturbance and the 

ecological health and biodiversity of the sagebrush ecosystem. The Forest Service, similarly, uses cherry-picked 

representative areas. See WWP Ely Westside Appeal. Various monitoring methods, including even the ESI conducted in the 

Jarbidge, tend to seek out more uniform “deal discrete vegetation community types and avoid the very often mottled, and 

varied communities that have resulted from more intensive use, past BLM treatments, etc. These more disturbed or altered 

sites are likely to contain more weeds and more degraded conditions. So again the results often over-represent better 

condition areas while ignoring degraded lands

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440. BLM also practices forage mining through extending facilities and salt and supplements. Areas closer to watering sites, flatter All Both emc0411GB
C. Comments by Resource Planning Issue

C-898 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

terrain, or other areas frequented by livestock become depleted. But rather than cutting livestock numbers, BLM has instead 

incrementally extended water systems and thus extended degradation of sagebrush upland sites, built more fences to enable 

more intensive use in ncreasingly depleted lands, and also killed sagebrush and trees to try to produce more forage and 

maximize continued livestock grazing numbers. This has enabled more intensive livestock disturbance of remnant better 

condition areas of the sagebrush uplands across public lands. Meanwhile, there is minimal, if any, improvement in the 

depleted sites. Livestock facilities have intensified use in many areas in recent decades, while the areas already highly 

impacted and depleted have not recovered. These sites are vulnerable to, and often are undergoing, weed invasions. Thus, 

this system of keeping as many cattle/sheep on the land as possible without cutting AUMs has resulted in incremental 

depletion equivalent to forage mining. Along with forage mining goes the need for ever more treatments. BLM has also 

aggressively manipulated and treated native communities rather than allowing passive restoration of damaged understories 

to occur. Rachel Carson in Silent Spring described the war on sagebrush that began in the late 1950s, and continued in the 

open for livestock forage for decades. This War continues to the present, papered over with misleading terms like fuels 

treatment, treatment of decadent sagebrush, habitat improvement project, but the end result is the same.

441. Given all of these concerns (and there are many more) how is BLM going to allocate lands for continued grazing use, and at 

what level of stocking allocation, under this process? How will BLM and the Forest determine the suitability of lands for 

continued grazing or other uses in amending these Plans? This must be done fully and fairly, and a clear honest fair 

science-based process established to do so. A starting place for one part of this analysis would be an honestly conducted 

capability and suitability analysis, incorporating a full and fair risk assessment detailing how livestock grazing disturbance is a 

causal factor for weeds, loss of native species, loss of microbiotic crusts, etc. The degree of risk to lands if such disturbance 

is continued must be determined. See WWP 2011 Ely Westside Rangeland EIS Appeal, detailing how dishonest agency 

capability and suitability analyses have been conducted. That does not mean, however, that the underlying concept is flawed. 

A strengthened capability and suitability analysis and risk assessment process, done honestly and not contrived to get results 

to support the status quo, must be part of this process.

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442. What can realistically produce the most significant change in 20 years in the chronically grazed landscapes across nearly all 

the western public lands? Realistically, removing livestock grazing disturbance is the only restoration action that can rapidly

promote recovery of existing sagebrush communities across landscapes, and that can provide the best basis for effective 

recovery of any actively restored areas. It thus provides the best taxpayer investment in restoration. Removal of grazing 

would immediately produce positive changes like increased cover of native species, no intrusion of livestock into critical 

seasonal habitat space required by sage-grouse, ecological processes that are less disrupted, termination of grazing 

management activity disturbance, dramatic reduction in livestock carcasses and carrion, and other subsidies that promote 

nest predators and mesopredators, Plus the drain on taxpayers from subsidizing livestock grazing and attempts to deal with 

its constant habitat degradation would end.

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443. BLM buries livestock grazing under a catch-all of rangeland management at this link

http://www.blm.gov/id/st/en/sage-grouse_west-RMP.html despite livestock grazing being a primary cause of degradation and 

adversely impacting many of the “preliminary categories” for the EIS planning including fire/fuels, veg/invasive species, 

wildlife/special status species, riparian resources, soil and water conditions, wilderness characteristics, visual resources [and 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-899

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

the degree of unnatural or grazing-caused contrasts], wild horses and worsening the ecological impacts of climate change 

and desertification. We stress that nearly 90% of riparian areas have been lost or highly altered. The full degree and severity 

of loss and desertification of sag-grouse habitats that has resulted must be fully examined. Understanding the degree and 

severity of loss in all sage-grouse habitats is necessary to understand how greatly reduced habitats currently are.

444. In order to understand the baseline conditions on BLM and other public lands, agencies must incorporate all land uses and 

influences (or change agents) on their lands. Without a proper science based understanding of these conditions, the 

consequences of land management actions on sage grouse cannot be fully understood. The BLM manages livestock grazing 

on 157 million of its 245 million acres of land (or 64%). Nearly all BLM land in the sagebrush biome is grazed. The adverse 

effects of livestock grazing on plant communities, soil properties, erosion, invasive and sensitive species and wildlife habitat 

have long been recognized in the scientific community. Therefore, sound science dictates that livestock grazing must be 

included as a change agent on BLM lands. Without specifically including livestock grazing as a primary change agent, the utility 

of all assessments and management plans will be called into question.The BLM, through its monitoring, past studies and 

analyses, retain data that characterizes grazing influences. Additionally, there has been a wealth of data collected on grazing 

allotments over a long period of time. Regardless of the scale at which the data was collected, it can be re-scaled to the 

landscape level. Many different data sets, collected at a variety of scales, can be scaled up and down. Data such as point data 

for fires have been scaled up and utilized in BLM’s Rapid Ecological Assessments. The BLM needs to utilize their existing data 

to integrate the effects of cattle grazing on all resource values and grazing impacts must be assessed with a scientifically valid 

method. Without a thorough understanding of the influence of grazing on BLM lands, critical habitats and listed species 

cannot be accurately assessed, making it impossible for the agency to develop plans to mitigate and manage sensitive 

environments, particularly for sage grouse, riparian habitat, or habitat for other listed plant and animal species.

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445. Livestock grazing is not merely a component of ‘herbivory’ a catchall for any species that utilize rangelands for forage. 

Livestock grazing is specific, measurable, allotted and controlled by agency protocols and management strategy. Lumping of 

all foragers into one category does not address the tremendous influence of livestock grazing as a landscape change agent. 

Wildlife grazing, compared to livestock grazing, on most allotments is not significant and BLM is remiss in categorizing 

wildlife and cattle together. BLM can estimate wildlife grazing separate from livestock using data obtained from state fish and 

game agency inventories or assessments of big game populations by management units.

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446. Where Are All Existing Leases/Permits/Valid Existing Rights? What Are They? Who Holds Them? Which Ones Can Be 

Canceled, or Terminated? How Would This Be Done? Can’t All Be Immediately Amended? Agencies must carefully 

catalogue all existing permits, leases, etc. and provide information on their interface or overlap with sage-grouse habitats. 

Detailed mapping and analysis of current ecological conditions must be provided. Then, both in the Interim and as a direct 

outcome of this process, these permits, leases, etc. should be amended, bought back, canceled, or otherwise addressed.

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447. Despite livestock grazing (and invasive species and other threats it grazing causes) being recognized as a threat, the 

Wyoming basin ecoregional Assessment failed to analyze the risk and threat from grazing. Despite exotic seedings 

converting sagebrush to grasses and spread of invasive annual grasses cheatgrass being admitted to be threats to the 

Wyoming Basin already circa 2006, BLM and USFWS have recently been trying to segregate out East and West regions, in 

order to minimize acknowledging pervasive disturbances across the sagebrush biome, and to try to confuse the sage-grouse 

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C. Comments by Resource Planning Issue

C-900 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

ESA Listing debate.

448. Below is another excerpt from the WBEA, with our comments [in brackets] illustrating how grazing must be fully 

incorporated into this 2012 sage-grouse EIS process. Decisions about which potential threats to address in a particular 

assessment area may be based on any of several criteria, including: Spatial extent or pervasiveness of the threat across the

ecoregion; [Grazing disturbance and its lethal infrastructure is pervasive across all sage-grouse habitats]. Capability to 

quantify and map the threat; [BLM can identify, analyze, map and address grazingcaused degradation of soils, vegetation, 

microbiotic crusts, fences, water developments, destruction of sagebrush in treatments, weeds, roads linked to livestock 

facilities if it wants to. See WWP critique of Stiver et al. 2010 HAF Report (referenced in NTT IM) and its omissions for 

suggestions. Agreement among those conducting the assessment about the relative importance of the threat to sagebrush 

habitats in the ecoregion; [Grazing is a major threat that synergistically acts with, and often causes, weed invasions and 

altered fire cycles, and impacts all components of the sagebrush landscape and all seasonal habitats used by sage-grouse. So 

if invasive species and fire are threats, then grazing must be a prominent threat as well]. Available resources to address the 

threat. [Livestock grazing removal will allow passive restoration to occur, and protect tax payer investments in active 

restoration. It will greatly free up resources, save large sums of tax dollars. Right now tens of millions of dollars are being 

thrown annually all at projects with minimal benefit and that in fact are often fragmenting and degrading sage-grouse habitats 

even more]. Timeframe required to implement effective treatments across the ecoregion; [Grazing could be phased out in 

many areas in five years or less, if there was a political will, and large amounts of tax dollars would be saved. Further, many 

parties such as foreign-owned gold mines in Nevada, Oil and Gas in Wyoming and SNWA in Nevada hold huge public lands 

grazing permits. Ending their grazing disturbance and degradation could readily be part of mitigation for damage to sagebrush

habitats being done by these same parties, who acquired base properties along with which came the grazing permits. Often, 

as in the case of mines or energy ndustry acquired private lands to keep ranchers from complaining about losses of water or 

other values harmed by the footprint of the mining or oil and Gas development. Instead of leasing public lands grazing to 

locally powerful ranchers to curry political favor, these entities must end grazing as partial mitigation for the harms being

caused. Also, many permits are now held by hobby ranchers, or wealthy individuals such as the Hilton hotel magnate permits 

that are a great concern in Bi-State Mono Basin lands in the Bodie California-Nevada region. Another example is large 

grazing permits in Idaho’s Pahsimeroi controlled by hobby ranchers]. Costs versus benefits of addressing the threat; [The 

environmental benefits of terminating grazing disturbance in western watersheds and ecosystems are tremendous 

increased watershed health, more abundant clean water, greatly reduced weed spread, reduced herbicide use, more 

effective integrated weed treatments, increased carbon sequestration, decreased soil erosion in wind and water (including 

dust that speeds early melting of snowpacks), removal of disturbance of tens of thousands of domestic livestock turned out 

each spring on top of nesting sage-grouse, and/or intruding into winter habitats and subsidizing mesopredators, cessation of 

livestock trampling impacts causing desiccation and loss of springbrook/riparian areas critical for broods, recovery of 

understory components to support nesting and brood rearing sage-grouse, removal of large source of mesopredator 

subsidies carrion, feed/supplement, sub-optimal habitat conditions increasing predator success for both visual and scent 

predators, etc]. Potential effects of addressing the threats on non-target species. [Many of the same beneficial effects of 

removing grazing for sage-grouse would apply across sagebrush habitats for other species, too. Plus the endless push for 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-901

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

reatments to kill woody vegetation to try to grow more grass that are resulting in fragmentation, weeds, and further loss of 

sagebrush especially important to species like the pygmy rabbit or sage sparrow would end}.

449. In the embargoed WBEA assessment, the BLM citing Connelly et al. 2004 described the pervasive adverse impact of 

livestock grazing disturbances. Thus, its influence on sage-grouse habitat is perhaps the most pervasive of any land 

management practice. However, we did not have data available across the study area on stocking rates and seasons of use 

(Appendix 6). Effects of livestock on sage-grouse habitat include removal of the herbaceous understory that supports insect 

prey and of forbs used as forage by hens, and concealment of nests from predators; moreover, livestock may trample 

sage-grouse nests (see Beck and Mitchell [2000] and Rowland [2004] for summaries of effects of livestock grazing on 

sage-grouse) In the WBEA Report Page A5-3 Screen 31: Sage-grouse - Grazing was assigned a threat of 1.We could not 

evaluate the potential effects of livestock grazing--the most pervasive land use in the sagebrush ecosystems in the Wyoming 

Basins because of the lack of area-wide spatial data on animal unit months, stocking rates, grazing systems, and allotments for 

public lands managed by the USDI Bureau of Land Management (BLM), USDA Forest Service, and other federal agencies. 

Moreover, some of the available data pertaining to livestock grazing are reported inconsistently across administrative units,

thus precluding the use of these data in our assessment. Consequently, the potential influences of livestock grazing were not 

evaluated either in our human footprint analysis or our species models So BLM claimed it could not assess grazing because 

it didn’t know how many AUMs were on the books, or being grazed. Just as with the later REA, this of course was false. We 

present this information so that BLM cannot again claim, at the time of the DEISs for this sage-grouse process, that it just 

didn't have time to assemble enough information on grazing. If BLM really can’t assess grazing impacts, then it can’t control 

impacts, and grazing permits should be terminated immediately.

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450. Congressional Riders and other legislated actions that threaten sage-grouse have resulted from political pressure from the 

livestock industry. Public lands ranchers have thwarted adequate scientific and environmental review and management of 

grazing disturbance actions across BLM and Forest lands. A long-standing example is the Rescissions Act, where 10 year 

grazing permits can be renewed without any environmental review at all, for another decade – as long as no changes are 

made to the permits. So this cements in place status quo harmful agency management actions of imposing herds of cows and 

sheep on top of nesting sage-grouse, hot season use on summer brood rearing habitats, keeping lethal fences and 

disease-promoting water facilities in place while also often expanding facilities with minimal NEPA, continued overstocking, 

etc. BLM and the Forest must provide detailed analyses of how many such permit authorizations are currently and during the 

course of this process, will foreseeably be made. Is BLM going to be issuing status quo Rider permits with status quo 

provisions through 2014, or whenever this EIS process is completed?

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451. Agencies do not act in the interest of sagebrush ecosystems when it comes to grazing disturbance. Across areas like the vast 

Humboldt-Toiyabe Forest, grazing is the overwhelming land/water disturbance factor promoting weed invasions, habitat 

alteration and loss, including erosion, headcutting, and desertification of very scarce and precious springs, seeps, and the 

small streams that characterize these often rugged water-limited Forest wild lands. As an example, in the Santa Rosa District 

near the Oregon-Nevada border, a grazing EIS imposed loose, uncertain adaptive management, and retained every single 

AUM/HM on the land. So in this very important sage-grouse habitat, there is significant uncertainty about how grazing will be 

conducted. The Forest moved three allotments with sage-grouse habitat that had been Vacant, including lands in Wilderness, 

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C. Comments by Resource Planning Issue

C-902 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

into the completely Open grazing category. This also included newly acquired land that was supposed to have been 

purchased for “conservation” purposes with SNPLMA funds. In the Ely Westside EIS, the Forest also attempted Opening a 

Close allotment that had long been Closed under the Forest Plan, but where the agency had actually allowed for over five 

years illegal grazing in habitat for the nearly extirpated Quinn sage-grouse PMU. As a result of this relentless grazing, on top 

of an area that was burned and should have been undergoing passive restoration, a cheatgrass weedland has resulted. So 

even in places where sage-grouse are known to be very low in number (see NDOW 2004 Sage Grouse Plan discussion of 

Quinn PMU) agencies sacrifice habitats to placate industry to the maximum degree possible. We present these examples, 

showing that even though a Forest Plan Closes an allotment, the Forest may act illegally to placate or please powerful 

livestock interests. This illustrates the disconnect between lofty claims made on paper, and what actually occurs on the 

public land. At present, there is no sound system to monitor and vet agency compliance with its own regulations, including 

how they are complying with any commitments made to sage-grouse conservation. This EIS process must establish a system 

to do so.

452. Then the real analysis would come with establishing a valid current baseline of ecological conditions so that critically 

important conservation measures and restoration actions could be applied, and in drawing boundaries and integrating 

management for large ACECs that encompass habitats necessary to conserve, enhance and restore populations. Current 

sage-grouse abundance and distribution must be expanded. In these areas, BLM must require that ongoing disturbance be 

minimized, and that disturbance be eliminated in sensitive areas. The ACECs must also encompass restoration areas and 

specific actions necessary to support populations that can expand and be viable over the mid and long term. Passive 

restoration, such as removing livestock grazing disturbance, which produces benefits very rapidly and is much less expensive 

over large areas than risky manipulation schemes, must be conducted in areas with remaining native sagebrush vegetation 

components occupied by sage-grouse. Active restoration must focus on removal and rehab of fences, water lines and 

troughs, linked roading, and numerous other disturbances, and seeding sagebrush and other native species to expand 

habitats.

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453. This EIS process uses yet another broad category to better enable agencies to mask declines, or claim they are addressing 

threats. It broadly breaks sage-grouse populations into East and West, and then claims that there are different threats in 

these different regions. This ignores chronic degradation and threats like livestock grazing disturbance that are promoting 

invasive species which promote frequent fires, or that causes degradation of all components of ecosystems in both east and 

west. Grazing threats extend across the sagebrush biome. Areas that were once claimed to be immune from cheatgrass are 

now facing cheatgrass invasion in areas of livestock, fire, or other disturbances. Portions of Wyoming now are facing 

cheatgrass invasion and spread. In reality, continuing death by a thousands cuts of sage-grouse habitat is occurring 

biome-wide.

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454. BLM states: The LUP amendments will contain decisions that are allocative and/or prescriptive to conserve sage-grouse 

habitat as well as objectives and management actions to restore, enhance, and improve greater sage-grouse habitat. We 

have previously discussed how BLM avoids making or changing allocations. What is the difference between an allocative and 

a prescriptive use? BLM must do both at the same time. Both allocative and prescriptive changes must occur together for this 

process to be effective and action happen in time to stop further declines. For example, BLM cannot substantially reduce 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-903

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

grazing standards to provide for 9 inch nesting cover for sage-grouse, while keeping AUMs/stocking in grazing allotments the 

same. Risk assessments must be conducted and findings on continued suitability of lands for any grazing use must be made. 

Then, if grazing continues, necessary reductions in livestock to allow this level of grass nesting cover must be made. It is 

unacceptable to shift impacts into other areas - for example, onto segregated General or Non habitats, to achieve a small 

degree of hoped-for "improvement" in a Priority zone. If this is the approach BLM is contemplating with its wording here, 

sacrificing those other areas will not protect sage-grouse, and adverse impacts will occur and boomerang back onto the 

sage-grouse that are supposed to somehow prosper in only a portion of their occupied and required habitat, i.e. the limited 

Priority areas. Is BLM just planning the smokescreen of avoiding allocation changes by applying "prescriptions" where 

grazing use will be rotated in an easterly direction, rather than a westerly direction each year - or something similar? Or 

planning to allow industrial wind development to proceed in sensitive occupied habitats by churning out a 20 page list of 

"prescriptions" for developers to follow?

455. Weeds destroy the ability of the native species to recover, especially with any continued disturbance. Disturbances like 

grazing must be removed so sagebrush communities can withstand invasive species and the unraveling that ensues following 

cheatgrass/medusahead dominance. This is supported by the ICBEMP science of over a decade ago that has been ignored by 

federal agencies.

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456. BLM pays lip service to WSA Interim Management measures. BLM must identify sources of degradation and impairment in 

WSAs and Wilderness related to livestock grazing, water developments, fences, salting/supplement feeding, roading, seasons 

of use interfering with sage-grouse nesting and native plant health, and other disturbances and degradation. It must act to 

remove these as part of this process, as livestock facilities and roading adversely impact sagebrush communities and thus 

sage-grouse habitats and populations. BLM must fully recognize that the values of sagebrush landscapes are now much 

greater than at the time the old BLM Wilderness inventories were conducted. BLM must carefully determine how the 

natural values of WSAs are enhanced and elevated by the WSA supporting thriving populations of sage-grouse. Sage-grouse 

management complements management for wild untrammeled landscapes. BLM must identify actions to promote this. What 

livestock facilities were present when the WSA was inventoried? How does this compare to those now present? Which 

facilities are harming natural and other values - and which must be removed due to degradation and harms/impairment 

including of natural features, and sage-grouse habitats and populations?

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457. There is great variation between states, and even within states like Nevada in how the FRH are applied. As part of this 

process, BLM must greatly upgrade, strengthen and increase the scientific rigor of how it carries out FRH processes in each 

state/area. There are greatly inadequate state or even RAC area S&Gs that do not appear to meet the legal requirements of 

the BLM grazing regulations at 43 CFR 4180. Example: Elko (Northeast NV) RAC standards are vague, weak, and allow all 

manner of ecological disturbances to go unaddressed. BLM must adopt much more rigorous Standards and Guides at the 

state/area level that are fully compliant with its FRH regulations.

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458. BLM must conduct current, honest and detailed S&G assessments across all parts of the sagebrush biome, including areas 

where there are existing inadequate S&G assessments, BLM must conduct new S&G assessments. BLM must systematically 

critique its existing S&G assessments.

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459. Risk and vulnerability to cheatgrass and other weed invasions, the degree and severity of existing desertification and All Both emc0411GB
C. Comments by Resource Planning Issue

C-904 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

degradation, and full and fair assessment of grazing-impacted land areas - not just "ideal" areas distant from livestock 

disturbance zones - must be competently conducted. See also discussion of the Stiver et al 2010 HAF.

460. For over a decade, WWP has been asking BLM not to build post-wildfire fences that enable livestock grazing on nearly every 

unburned acre. The agency should instead close existing partially burned pastures entirely. Sage-grouse have just lost critical 

habitats in a fire. Then the grouse, in the remaining habitat they have left, suffer grazing disturbance (often intensified) as well 

as new lethal fences off so that intensive disturbance is perpetuated. Agencies must adapt to fire by providing more ungrazed, 

undisturbed habitat.

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461. All the energy development, mining, roading, veg treatments that result in cumulative adverse impacts to sage-grouse play 

out on a landscape that is near-universally subject to annual grazing disturbance from domestic livestock. Sagebrush lands 

have been industrialized with many harmful facilities put in place to facilitate and/or intensify grazing disturbance. Likewise, 

new developments will only add to the sagebrush habitat intrusion, disturbance and losses. The cumulative impacts of 

disturbances must be honestly examined in any RFDS. This scenario must be conducted for livestock grazing across agency 

lands, including stocking levels and lands suitable for, or open to, grazing use. The impacts of these actions related to grazing 

disturbances and developments, and the threats posed to all sage-grouse seasonal habitats, must be fully examined.

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462. A valid and complete environmental baseline of habitat quality, quantity and threats must be provided for the effects of 

development scenarios to be understood. This effort must first answer basic questions such as: How much loss of critical 

habitat components has already occurred - including desertification and loss of site potential, water tables, etc.? How much 

further loss of adequate sagebrush understories, microbiotic crusts and structurally complex sagebrush cover will occur if all 

the livestock water pipelines, fences, near-status quo stocking rates, high use levels/standards are allowed to continue- and 

the new developments under the Scenario are allowed to occur? How much irreversible loss and harm (such as cheatgrass 

or medusahead invasion) will occur? In arid sagebrush lands, placing water developments in uplands results in a bulls-eye 

pattern of depletion emanating outward from the water sources (with variations taking topography into account). With 

continued high stocking, and high use levels, no controls on trampling disturbance, and retention of existing livestock 

facilities - the depletion continues and recovery of damaged areas is not possible. Continuing or expanding facilities, or 

renewing grazing permits at levels above the use that has actually been occurring, must be fully taken into consideration 

here. All of this is of course dependent on what the current baseline and environmental conditions are, including how 

severe current threats and risks of continuing disturbance activities may be to all components of all sage-grouse seasonal 

habitats and lands necessary for restoration.

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463. Agencies must also consider the threat of habitat loss and amount of risk of irreversible weed invasion and habitat 

fragmentation associated with treatment disturbance, and must fully consider the uncertainty that any substantial positive 

recovery may occur, and its pace. If agencies propose to kill, alter, thin, destroy mature of old growth sagebrush 

communities in vegetation manipulation projects, then how long will it take for a plant community with similar

characteristics to recover? How does continued grazing disturbance slow, retard, or alter recovery for decades or centuries 

to come? How does continued grazing disturbance promote cheatgrass or other weeds, effectively truncating succession so 

that hoped-for recovery does not happen? Examples: Trampling seedlings, browsing/breakage of sagebrush cover, alteration 

of understory grasses and forbs, disruption of microbiotic crusts, etc. Current science-based recovery intervals must be 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-905

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

used. So many of the existing projects including those of the past decade and continuing up to the present have been 

conducted based on false and now disprove claims of short historical disturbance intervals, and short claimed recovery 

intervals that had been erroneously promoted by Winward, Miller, and others with a range background. See Welch and 

Criddle (2003), Baker (2006), Baker Chapter in Knick and Connelly (2009). How many treatments exhibit much slower 

recovery of sagebrush, forb, microbiotic crust, and other community components than predicted?

464. For the past couple of years, agencies have been using another category to try to separate out populations, and minimize the 

importance of losses to the sagebrush habitats. This is the effort to segregate greater sage-grouse into eastern vs. western 

portions of the range on the basis of claims that grouse face different threats in different parts of their range. USFWS used

this artifice in defending its toothless Warranted but Precluded Finding in litigation, and took it to absurd lengths in its 

arguments there. First, many of the same threats occur across the range - livestock grazing, roads no matter what the 

cause, invasive species, mining. Second, increasingly renewable energy threats with many of the same impacts as oil and gas 

are accelerating in the western portion of the species range, and mining is exploding in northern and central Nevada and 

some other western areas. Plus hundreds of thousands of acres are now being leased for oil and gas development all over 

Nevada. Renewable energy examples: Major industrial wind farm on Steens Mountain Oregon and new transmission lines, 

major new transmission lines like Gateway and MSTI, geothermal development often by foreign entities (McGinness Hills 

and other areas), massive geothermal leasing proposals are appearing - for over 500,000 acres on Bridgeport Ranger District 

lands and elsewhere in NV. Mining is expanding into new areas where sage-grouse populations are already barely hanging on, 

and new mining is proposed in areas with larger populations, as well. In the east, weeds like cheatgrass are increasing (see 

WBEA Assessment discussion). New and expanded mining, new transmission lines, and oil and gas harms are far exceeding 

those agencies claimed would occur from these new or recently expanded developments. See 2012 Yubanet article on 

failures of Wyoming Core Model in the Powder River Basin.

All Both emc0411GB

465. Many measures proposed are not mandatory - not even in Priority areas. General areas receive almost no protections. If the 

weak and uncertain conservation measures listed in the NTT are not greatly expanded (much more stringent controls 

placed on grazing disturbance, for all sagebrush habitats - and not just the segregated Priority areas) and made mandatory 

scarcely anything effective will be done to "conserve" the species across vast lands areas facing a plethora of energy, 

grazing-facilitated weed invasions, and threats.

All Both emc0411GB

466. It is essential that all ongoing activities, all leases /ROWs already issued - all get reviewed, altered, changed, amended and/or 

terminated where conflicts are identified with habitats in the interim and immediately upon completion of this process. 

Existing leases, rights-of-way, etc. must be immediately amended to at least comply with the terms of IMs that must be 

greatly strengthened and that should not be based on segregating habitat. This can be readily done. Simply overlay the land 

records of leases, rights-of-way, grazing permits, etc. with mapped habitats, and inform the lease/permit holder of new 

protective provisions.

All Both emc0411GB

467. In non-mountainous areas of more broad, rolling plains type settings (such as the Jarbidge or portions of the Snake River 

Plain) in many of the western areas - there has first been extensive "development" for livestock with crested wheatgrass 

seedings, and sagebrush eradication the 1960s and 1970s. These areas take an extraordinarily long time to recover. Chronic 

livestock use retards or prevents recovery of the composition, function and structure required by sage-grouse. For example, 

All Both emc0411GB
C. Comments by Resource Planning Issue

C-906 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

depletion of forbs. See Jarbidge AMS.

468. BLM is to: - Manage priority sage-grouse habitats so that discrete anthropogenic disturbances cover less than 3% of the 

total sage-grouse habitat regardless of ownership. These features are: paved highways, gravel roads, transmission lines, 

substations, wind turbines, oil and gas wells, geothermal wells and facilities, pipelines, landfills, homes and mines. This 

definition purposefully omits fences that kill sage-grouse, livestock water developments that promote West Nile virus and 

severe degradation of de-watered spring habitats, and degraded upland habitats. Spring developments dry up or greatly 

reduce flows and shrink meadow and other brood rearing areas. It omits disturbance such as imposing large herds of 

livestock - including in combination with damaging facilities and management practices. The degree and severity of 

understory degradation into areas where pipelines or roads are built - are habitat-degrading anthropogenic disturbances 

associated with livestock grazing. Livestock grazing disturbance is an imposed impact caused by man. Domestic livestock are 

not native to the sagebrush biome (Mack and Thompson 1982), and are imposed by humans with catastrophic historical 

degradation and loss, and chronic continuing harm- including landscape-level desertification, and loss of habitats and 

populations. Plus this ignores blocks of private cropland and activities that may already occur in these habitats. How are 

these going to be dealt with? Careful examination of the wording shows that lands could be completely torn to pieces, but 

BLM will be able to look at the direct bulldozed disturbance, and not the real ecological Footprint or impact of the 

disturbance. For example, there is a large difference between the many square mile visual Footprint of a wind turbine, and 

the bulldozed footprint where turbines are placed- the difference is square miles vs. small fractions of a mile.

All BLM emc0411GB

469. NTT Grazing Items: Page 15 "Implementing Management Actions after Land Health and Habitat. Evaluations" largely 

perpetuates the status quo. There is only one thing in the small list of: Season of use or timing, numbers of livestock, 

distribution, intensity type of livestock that is different from often harmful status quo practices. We are encouraged to see 

that numbers of livestock (includes temporary non-use or livestock removal) is listed. How will this be determined? This is 

not carried forward in the IM. Does this mean that BLM will continue persecuting permit holders who seek extended 

non-use in the interim? So does this mean these considerations are going to be left up to the discretion of the Field Manager 

during the extended period between now and implementation of the EIS’s actions?

All BLM emc0411GB

470. We are alarmed at the expanded developments and several other aspects of the largely status quo grazing and FRH actions 

in IM 4-5. We are very concerned that pages 14-15 "Range Management" appears mired in "herbivory." Plus, as page 8 of 

IM 2012-043 shows, nothing at all related to grazing is applied to General Habitat. Is this too part of a habitat sacrifice 

scheme, enabling use to be intensified in general habitat?

All Both emc0411GB

471. NTT at 18, and IM at 7 regarding Wild Horses: BLM must evaluate AMLs for horses at the same time as it addresses livestock 

grazing permits. These must be based on balancing needs of horses for food, cover and space including natural band 

structure, and analyzing adverse impacts of livestock grazing disturbance on all aspects of the thriving natural ecological 

balance. This must be done fairly.

All Both emc0411GB

472. This contains a list of BMPs on"how to make a pond." However, there is no accounting for how tens of thousands of 

improperly built livestock and other ponds currently exist, inevitable leaks and spills in pipe or other water systems, or the 

role of livestock trampling of riparian or pond margins in creating mosquito habitat. There is also no accounting for water 

troughs - and pipelines extending waters and thus mosquitoes into areas remote from water. There is no analysis of any 

All Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-907

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

kind of the adverse impacts of building ponds in plugging intermittent or ephemeral drainages - and the extensive livestock 

sacrifice zone that typically results. Prolonging water presence in ponds often prolongs and exacerbates intensive livestock 

degradation of large surrounding areas. Many thousands of ponds have been dug into portions of springs and wetlands in 

sage-grouse range as livestock "improvements." These improvements destroy the functionality of the spring, meadow, seep 

or drainage. They promote desiccation and desertification of the spring/meadow/riparian area, and loss of essential 

sage-grouse brood rearing habitat. There is no analysis of the impacts of livestock watering at ponds trampling and pocking 

shoreline depressions that serve as breeding spots for mosquitoes. Why isn't BLM requiring removal of ponds, and real 

restoration of functioning riparian systems and watersheds? Instead, just as with the greatly flawed Core and Priority 

schemes, BLM focuses on expanding habitat degradation and loss. Where is BLM guidance on How to Remove a Pond and

Restore Watershed Processes? BLM must prohibit more ponds in sensitive areas altogether, and greatly reduce the 

existing number of energy, livestock, mining and other impoundments. BLM must also address the full Footprint and 

impacts of tens of thousands (if not more) of livestock troughs and associated water spillover areas in promoting West Nile 

virus acres uplands of the sagebrush biome.

473. How does directional and horizontal drilling affect aquifers and the spring and riparian areas whose surface expression is 

linked to them? How will water tables be impacted? Will waters essential for wildlife or human uses be polluted? How does 

punching pond after pond into areas with shallow water tables or aquifers, as described in the previous Appendix disrupt 

hydrological systems?

All BLM emc0411GB

474. Why are there provisions to "have no tanks at well locations within priority areas" for fluid minerals, but no similar 

provisions for the battery of livestock wells, water tanks, and other elevated structures that exist across the sagebrush 

biome in occupied sage-grouse habitats? Is the battery of tens of thousands of elevated livestock range development 

structures all going to be "grandfathered in" and allowed to continue to be in left in place degrading sage-grouse habitats and 

public wild lands? These elevated structures promote opportunities for nesting and perching by ravens, or elevated raptor 

perches, or may impact grouse use of an area by providing taller visual intrusions.

All Both emc0411GB

475. BLM merely lists washing vehicles to limit invasive species, a standard practice for decades now. BLM ignores integrated 

weed management actions like removing livestock disturbance that spreads weeds crosscountry affecting a landscape much 

beyond the bulldozed disturbance area weed infestation footprint of a typical energy project and its associated roading and 

other disturbances.

All BLM emc0411GB

476. BLM is to "require sage-grouse safe fences." What is a "safe" fence? Why in the world isn’t BLM requiring an immediate 

survey of all fencing, and identifying huge lengths of fence for removal? What is a safe fence? Don’t grouse at times still collide 

with fences that have with reflectors? How does this balance with other uses - for example, fencing inside a Wilderness Area 

becoming even more visually intrusive? Greatly reducing fence density must be a primary goal, BMP, outcome. How much 

will the added reflectors and other visual distractions affect sage-grouse use of a landscape? With fences that remain, 

livestock zones of intensive disturbance, weed infestation sites, and predator travel corridors all will still be present.

All BLM emc0411GB

477. This section also includes: "restrict the construction of tall facilities and fences to the minimum number and amount needed." 

How is the "minimum number needed" to be determined? Developers will always ask for whatever makes their development 

the most profitable - i.e. maximizes profits. Why isn't BLM requiring removal of livestock grazing to minimize weed spread, 

All BLM emc0411GB
C. Comments by Resource Planning Issue

C-908 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

mesopredators, etc.ad to enhance rehab success and prevent added disturbance of native species in the footprint of 

development and surrounding lands? BLM must avoid placing development in undisturbed sagebrush lands and habitats in 

the first place must be the first consideration. Why isn’t there a requirement that livestock and other fencing be removed -

if new fencing is to be added? What about nearly invisible electric fence wires - used by the Forest and at times BLM? We 

have seen these imposed under Categorical Exclusions on a temporary basis as band-aids that also serve to intensify 

livestock use in all mesic areas that are not within the fence perimeter. These must prohibited. As an example, in Challis BLM 

sage-grouse lands in the Pahsimeroi, Decisions have been issued allowing locations of such fencing to be shifted all over the 

place as a transitory band-aid so that BLM can claim "improvement" or "progress" toward rangeland health standards in small 

temporarily fenced off areas. Such fencing intensifies impacts in unfenced areas.

478. Why is there no discussion about protecting flows of all springs, seeps and streams affected by energy and mining activity? 

For example, cyanide heap leach mining causes aquifer declines and aquifer drawdown of springs/streams. Water sources 

critical for wildlife may be severely altered by mining activity, and watershed by associated surface disturbance. These 

systems in arid western lands are typically already under significant stress from degradation by ubiquitously grazed livestock, 

and livestock water developments that remove water from spring sources to promote livestock use, as well as gouge stock 

ponds in springs or drainages. See Sada et al. BLM Technical Bulletin 2003. This alters and disrupt drainage networks, flow 

patterns, and extent of riparian and meadow habitats. There is serious risk of declines in water levels or cessation of flows 

altogether due to combined effects of mining, roading, grazing disturbances - all serving to desertify landscapes. Why are 

there no protections for such threats, especially given the breakneck speed of mining development in already fragmented 

areas of Nevada and other western states?

All Both emc0411GB

479. Power washing vehicles does nothing to stop transport from roads accessing sites. When is BLM going to start "power 

washing" livestock - i.e. conducting integrated weed management to minimize transport and spread of weeds? Through 

quarantining animals for weed seeds to pass through guts, prohibiting turnout into lands without weed problems when 

livestock are coming from a weedy area, prohibiting knowing turnout onto weedy area until weed infestation is addressed, 

etc.?

All BLM emc0411GB

480. BLM is not going to be able to prevent large wildfire. Fuelbreaks will not do that, and often promote weeds that fuel frequent 

fires. And if BLM attempts to engineer a massive series of fuelbreaks, it will only further fragment the sagebrush ecosystem 

and hasten its demise. So as an alternative, BLM must manage lands to be in the best possible condition using native species.

That way, if an area burns, it is naturally more resilient and better able to recover. Livestock grazing must be removed if 

recovery is to be effective, and to occur without significant risk of cheatgrass and other weeds. Removal of grazing also 

hastens the speed of recovery. Thus, passive restoration -both before and after fires - is essential to resiliency, and reducing 

and minimizing the adverse effects of fire on wild land sagebrush habitats. In some instances, active restoration (re-seeding 

with local native ecotypes) may be necessary. But this must be followed by long-term removal of livestock grazing 

disturbance.

All BLM emc0411GB

481. NTT Report "Diffuse Disturbance" Category Is An Effort by BLM to Again Avoid Examining or Controlling Livestock 

Disturbance The NTT report would allow 3% new disturbance in Core Areas. The NTT does not include "diffuse" 

disturbances. It is hard to understand how a fence is "diffuse" disturbance, or herds of several hundred cows imposed on 

All BLM emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-909

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

nesting sage-grouse are "diffuse" disturbance. These are real damaging disturbances to and disruption of physical space. 

Under this reasoning, exploration for Oil and Gas, or Geothermal, would be a "diffuse" disturbance. After all, the heavy 

equipment moving crosscountry crushing vegetation is having an effect similar to a herd of grazing sheep or cattle. There is 

direct physical intrusion into space, as well as flushing, disturbing and displacing birds and damage to nests from both. The 

NTT describes livestock grazing and fire as "diffuse disturbances." This makes no sense at all. Fires burn a discrete area, and 

removes sagebrush cover required by sage-grouse. The effects are long-lasting. They are persistent. They alter, degrade and 

destroy habitats. This is not a diffuse disturbance, but a discrete, able to be mapped, long-term disturbance. Grazing 

involves discrete infrastructure and developments that alter habitats in specific, mappable locations. Grazing alters habitat

components in specific, measurable ways. It imposes disturbance of livestock and management actions on discrete areas 

(pastures) for specific periods of time. Intensity of use can be mapped with use pattern mapping and other methods. 

Agencies apply various typically excessive use standards that are supposed to govern some measurable ways in which grazing 

alters habitats annually. Agencies measure ecological site inventories, rangeland health assessments, etc. to examine 

qualitative and at times quantitative ways in which grazing alters sagebrush systems and thus sage-grouse habitats. It cannot 

merely be considered a generally benign, diffuse disturbance as the Ims and NTT do. Management activities such as 

placement of salt or minerals, or any other activities that concentrate livestock, can cause long-term disruption and loss of 

sagebrush that can take hundreds of years to recover, even with a one-time substance placement. See Fite Jarbidge 

Declaration, with photos showing destruction of mature and old growth big sagebrush due to placement of mineral 

supplements on BLM lands, for example. This is typically followed by weed invasion. All of this is not diffuse disturbance. 

Over the course of just one grazing season, dozens if not hundreds of such damaged sites pepper the landscape. Mature and 

old growth sagebrush is killed, and soils are severely trampled and disturbed. Copious amounts of weed-promoting manure 

are deposited. The site is primed for weed invasion. Further, livestock trailing to concentrate on watering or other sites 

break sagebrush, destroy microbiotic crusts, and where slopes are present, trailing may cause incipient gullying that worsens 

over time.

482. BLM must fully consider removal/cessation of grazing disturbance over large areas to be passive restoration that serves as 

mitigation. BLM must amend all Land Use Plans to allow for grazing permit retirement to accomplish this.

All Both emc0411GB

483. Disturbance Calculation. This focuses on non-grazing anthropogenic disturbances only (see J-3) - using the same categories 

as the BLM IM (transmission lines, distribution lines, wind development, and oil and gas/facilities, geothermal, communication 

towers, pipelines, paved roads, and others”). It is also to take into account “approved permits” – but it is unclear if this 

includes leases – often held by speculators and others. (See discussion elsewhere). Then, the HEA calculates “existing and

allowable suitable habitat disturbance”. Here, the HEA lapses back to the Idaho Sage Grouse Plan Model – i.e. pre-core 

modeling habitat categories that are: Key, potential restoration area type 1 (R1),Potential restoration Area Type - Perennial 

grasslands. R2), Potential restoration area Type 2 – annual grasslands, Potential restoration area Type 3 – conifer 

encroachment. The HEA model itself is a great disappointment. While the first page describes the need to consider

cumulative and indirect effects and, and analysis of sage-grouse population within 18 km. – the model is a failure and does not 

do so.

All Both emc0411GB

484. We are very concerned that the Scoping Information provided by the current BLM/federal Sage-grouse EIS Scoping, and its All Both emc0411GB
C. Comments by Resource Planning Issue

C-910 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

extremely weak NTT and BLM IMs, are following very much the same failed, ineffective and time-wasting path as the 

Humboldt-Toiyabe Forest Rangeland EISs. The Forest Service “herbivory” narrow view of grazing impacts is largely 

mirrored by BLM’s statements about “herbivory” in the 2012 sage grouse EIS process. In order to be effective in any way, 

agencies must base the EIS and its outcomes/actions on ecology, not the old, failed, broken paradigm of tinkering with 

managing “herbivory” and endless livestock facilities and “treatments” endlessly applied. We request that ecologists and 

biologists from outside federal agencies that are not associated with land grant colleges be fully involved in reviewing and 

addressing livestock impacts, and actions to remove and reduce these adverse impacts that synergistically are killing 

sagebrush ecosystems across the West.

485. All waivers should be ended immediately. The same goes for the loose uncertain “flexibility” BLM now routinely applies to 

grazing permits. Sudden changes in grazing schemes to accommodate the livestock industry must be prohibited

All Both emc0411GB

486. BLM must immediately develop much more stringent livestock grazing controls and development controls in the Interim to 

protect all habitats.

All Both emc0411GB

487. I am concerned that it will have a great impact on the ranching community we live in. With the high probability that it will 

stop all grazing on Public lands. With no grazing the probability of having wild fires is far greater. As an example, I was 

personally involved in a ranch that grazed the Dahlanega Creek area to Sheep Creek, Silver Leads, 4th of July Creek and on 

toward Salmon. After the ranch changed ownership, the range was closed. The grazing made better areas for wildlife. Today 

the area is over grown with weeds and the area is a lot harder to walk in. Public land grazing has been around since the mid 

to late 1800s and has not been a problem.

All Both emcc0131GB

488. Furthermore, sage-grouse habitat must be protected from land uses such as energy development and livestock overgrazing 

that can degrade the natural landscape. Consistent management standards for these and other industries must be adopted 

throughout the bird’s range based on the best available science, and according to recommendations made by the National 

Technical Team in their sage-grouse report.

All Both fla0000GB

489. Giving ranchers the option to voluntarily relinquish their grazing permits back to the federal managing agency in exchange for 

compensation paid for by conservation groups would also provide a new tool with which to conserve and manage 

sage-grouse populations.

All Both fla0000GB

490. As a person who has spent time in the prairie lands of the west, I have been appalled at the wholesale habitat destruction that 

has already occurred from land uses by absentee landlords for energy development and lifestock overgrazing. One is 

hard-pressed to find any semblance of what the western prairies once looked like. Time to stop this land 

MIS-MANAGEMENT before we lose more than just the poor Sage-Grouse

All Both fla0005GB

491. As a person who has spent time in the prairie lands of the west, I have been appalled at the wholesale habitat destruction that 

has already occurred from land uses by absentee landlords for energy development and lifestock overgrazing! One is 

hard-pressed to find any semblance of what the western prairies once looked like. Time to stop this land 

MIS-MANAGEMENT before we lose more than just the poor Sage-Grouse

All Both fla0005GB

492. private livestock grazing on PUBLIC LANDS is a huge driver of degradation of riparian and grassland habitat. American 

taxpayers effectively subsidize this destruction through the artificially low grazing fees charged of $1.35/month/cow-calf pair. 

This is the same rate as in 1936 and is a fiscal disaster and objective policy cheat

All Both fla0016gb
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-911

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

493. You must fully analyze all direct indirect and cumulative adverse impacts of livestock grazing, and act to remove livestock 

from remaining sagebrush landscapes

All Both fla0030gb

494. Grazing promotes weeds that promote frequent fires ‐ and degrades sa All Both fla0030gb

495. The habitat for the sage-grouse must be protected from different kinds of land use, form energy development conducted 

irresponsibly, to overgrazing by domestic livestock

All Both fla0031gb

496. The sagebrush regions of the Great Basin and Rocky Mountain corridor are part of our great heritage as Westerners and 

Americans, still ‐of wild land that have much to offer coming generations if managed properly. But the habitat vast expanses

has been drastically impacted by invasive species such as cheatgrass, frequently exploitative use by grazing and mineral 

interests, and shortfalls in regulation and enforcement.

All Both fla0086gb

497. As it states below, I am a conservationist who would be very happy to be part of a payment plan to ranchers to relinquish 

their grazing permits. Many of us are ready to put our money where our mouths are to save habitats and birds like the Sage 

Grouse

All Both fla0087gb

498. Only by requiring the strongest protective measures when considering new development proposals in sage-grouse habitat 

will you be able to ensure survival of this spectacular species. To that end, I ask that you require the following conservation 

measures in the relevant Resource Management Plans and Land Management Plans-Develop and implement grazing systems 

and management practices that maintain the soil quality and ecological processes necessary for a properly functioning 

sagebrush community to address short-term and long-term needs of greater sage-grouse.

All Both flb0000gb

499. Develop and implement grazing systems and management practices that maintain the soil quality and ecological processes 

necessary for a properly functioning sagebrush community to address short-term and long-term needs of greater 

sage-grouse.

All Both flb0000gb and rm

500. I am particularly concerned that livestock grazing is getting a free pass. Everything from trampled wet meadows and riparian 

areas where the chicks feed for the first month of life to fences that create perches for birds of prey to water troughs where 

West Nile Virus lurks, to introduction of weeds and creation of conditions favorable for spread of exotics like cheat grass 

are contributing to the decline in sage grouse. Any serious effort to save the grouse must reduce or eliminate livestock 

grazing from major sage grouse population strongholds.

All Both flb0045gb

501. The planning process must address all degrading land uses in sage-grouse habitat, such as energy development and livestock 

grazing, and management standards must be based on the best available science. Federal planners must ensure that all 

planning documents make the same prescriptions for land uses across sage-grouse range.

All Both flc0000gb

502. Authorizing grazing permit retirement in the West would also provide managers new tools to conserve and restore critical 

sage-grouse habitat.

All Both flc0000gb

503. The BL M has always claimed that wild horses destroy wild lands, but the here the BLM goes, letting livestock destroy 

Greater Sage Grouse lands of which horses have no impact. I see the extreme land erosion of cattle on recreational areas 

first hand, so your claim that you are concerned about wild lands rings hollow.

All Both flc0012gb

504. Fences too are a problem, - they should be removed near leks of sage grouse] All Both flc0023gb
C. Comments by Resource Planning Issue

C-912 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

505. It should be of no surprise to anyone after all these years of data collection that ridding the range of livestock will do more 

to aid these species and range than anything else that could be done. I hope that we get real and immediately start phasing 

out livestock grazing on public land.

All Both flc0042gb

506. In order to effectively preserve the species and prevent ESA listing, it is imperative to remove livestock grazing from public 

lands that include sage grouse habitat. The damage done by livestock is pervasive, devastating and long-term - particularly in 

arid climates. Even renewable energy development is not as fundamentally damaging as is cattle grazing.

All BLM fld0006rm, 

fld0006gb

507. I believe measuring stubble is very appropriate in determining when grazing should be reduced or eliminated. All Both fld0007rm, 

fld0007gb

508. Reduce livestock grazing in order to restore the grasses and other flowering plants that sage grouse need. Give priority to 

restoring riparian areas from overgrazing.

All Both flf0000gb 

flf0000rm

509. I urge you to consider consolidated plan ammendments that will: reduce livestock grazing in priority habitat and potential 

recovery areas to restore native plants that the sage grouse depend upon;

All Both flg0000gb 

flg0000rm

510. It is also necessary that the preferred alternative explicitly recognize the key importance of public lands ranching operations 

to the success of sage-grouse conservation. Scientific research has repeatedly shown that properly managed grazing is 

beneficial to the greater sage-grouse and to a host of other wildlife species. Well-managed grazing can improve sage-grouse 

habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and also aids in the control of 

invasive plant species. Moreover, public lands ranchers own a significant portion of high-quality lowland brood rearing 

habitat as deeded property. According to NRCS, [a]pproximately 40 percent of sage-grouse habitat that supports 

populations occurs on privately owned lands. However, if regulatory measures on public lands make ranching operations

economically unsustainable, these operations are frequently subject to sale and development, leading to fragmentation and 

loss of key habitat. It is therefore essential that the preferred alternative incorporates explicit steps to ensure that 

sage-grouse conservation measures do not undermine the viability of public lands ranches.

All Both fli0000gb

511. Any EIS or SEIS developed must also recognize and incorporate the extensive research that has already been conducted by 

the USDA Natural Resources Conservation Service (NRCS) on the complimentary relationship between sage-grouse 

conservation and grazing. According to NRCS, the same factors that negatively affect sage-grouse also negatively affect the 

health, productivity, and sustainability of native grazing lands. Therefore, improvements to benefit sage-grouse also benefit 

grazing lands and the ranchers that depend on them.

All Both fli0000gb

512. Any EIS or SEIS must also explicitly recognize the following points: • Properly managed grazing can enhance sage-grouse 

habitat and should be incorporated into the sage-grouse management strategy. • Historical evidence indicates a positive 

correlation between livestock numbers and sage grouse populations.

All Both FLI0000GB

513. In the Great Basin, and much of the western United States, livestock operations are highly dependent upon the combined 

use of private and public lands. Regulatory actions that make public lands grazing economically unsustainable will not only 

negatively impact individual ranch owners, but also entire rural communities that largely depend on ranching to maintain 

businesses and tax base.

All Both fli0000gb

514. Scientific research indicates that grazing is beneficial to the greater sage-grouse and to a host of other wildlife. Grazing can 

improve sage-grouse habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and also aids 

All Both flj0000GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-913

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

in the control of invasive plant species

515. NEPA analysis should start from the premise that grazing can be a benefit to sage-grouse and properly managed grazing 

should be incorporated into the sage-grouse management strategy.

All Both flj0000GB

516. Historical evidence indicates a positive correlation between livestock numbers and sage grouse populations. All Both flj0000GB

517. Threats to sage-grouse should be avoided in all situations, especially livestock grazing and related influences thereof. This 

includes elimination of over grazing, fences, water developments and diversions, predator management, and leasing land to 

livestock interests where there is no profit being made by the federal government.

All Both flk0002gb

518. Furthermore, grazing, if managed correctly, can benefit sage-grouse habitat. The NESRSGWG requests that the Draft EIS 

analyze the beneficial impacts from livestock grazing on sage-grouse habitat.

All Both fxc0003RM

519. The NESRSGWG also requests that the BLM analyze the impacts of making specific project environmental analysis (EA's) so 

burdensome and complex that there is no longer any incentive for ranchers to complete range improvement projects. Some 

range improvement projects may have an indirect positive impact on sage-grouse habitat through improved grazing 

management.

All Both fxc0003RM

520. As recognized by the BLM in IM No. ?012-043. grazing can be "used as a tool to protect irrtact sagebrush habitar and 

increase habitat exteilf and continuity which is beneficial to the Greater Sage-Grouse and its hahitat." The IM continues. 

"Given the potential financial constraints in addressing the primary threats identified by the FWS, enhanced management of 

livestock grazing may be the most cost-effective opportunity in many instances to improve Greater Sage- Grouse habitat on 

public lands." According to Natural Resources Conservation Service (NRCS) gr:azing "has been responsible for retaining 

expansive tracts of sagebrush-dominated rangeland from conversion to cropland" and can "stimulate growth of grasses and 

forbs. and thus livestock can be used [o manipulate the plant community toward a desired condition."

All Both fxc0006GB

521. Sound scientific research indicates that grazirrg is beneficial to the Ereater sage-grouse and other flora and fauna in multiple 

ways. Grazing reduces the instances and severity of wildfires" (Launchbaugh et al. 2007). It improves greater sage-grouse 

habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et aI.1994, Evans 1996). [t has 

also been used to control invasive weeds (Olson and Lacey 1994, Walker et at.1994).

All Both fxc0006GB

522. The EIS and SEIS revi,sioils should clarify that multiple-une management concepts should be used to reduce the risk of 

catastrophic wildfire, improve forage. refilove invasive species and provide open space. We strongly encourage the agencie.r 

to prioritize theit focus on public land use, or disuse, which poses a real threat to the greater sage-grouse and its habitat

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523. In regard to livestock grazing management, an adequate regulatory meehanisnl already exists to provide for the protection 

and peTpetuation of sage b'1'ouse and sagebrush habitat. It is called the Standards for Rangeland Health and Guidelines for 

Livestock Grazing Management and was incorporated into federal grazing rebrulations in 1995. The true issue here is 

whether the USFWS believes tIns authority is being properly applied on BLM lands. If the answer is yes, there is no need to 

proceed further with this EIS effort as it relates to grazing. If the answer is no, the lmderlying reason for BLM failure to 

manage the public land in accordance with law needs to be dcterrn.ined and evalLlated. As stated within your NOr, the

Fundamentals ofRangc1and Health, 43 CFR 4180, are planning criteria for all altematives. As such, public land grazing is a 

non-issue in tins planning process, since "regulatory mechanisms" are alr.eady in place for sage grouse/grazing via Standard 8 

All Both fxc0011gb
C. Comments by Resource Planning Issue

C-914 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

Comments Related to Livestock Grazing

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of the FIliI. See 43 C.F.R. 4180.2(c) (wherein the "autIlorized officer (of BLM) shall take appropriate ac.iion as soon as 

practicable but not later than the strut of the next grazing year upon determining that existing grazing management practices 

or levels of brrazing use on public lands m:e significant factors in failing to achieve the standards (for Rangeland Health, which 

is inclusive of Standard 8 relating to ~1)ecies, like the sage bTfOUse)). (2) Notwjlh~1anding (1) above, we fully understand 

and have concerns .j~)( the potential consequences ofUSFWS determining the need for "regulatory mechanisms" to avoid 

ESA listing of sage grouse and BUvllUSFS eFforts to attain these mechanisms tlu'ough a Land Use Plan amendment process. 

The comments below are intended to address those concerns.

524. 11) The EIS must evaluate the impact proposed sage grouse conservation measures will have on other land uses. Unintended 

consequences of management prescriptions/restrictions are a major problem when imposed by broad scale plmming 

decisions that focus on relatively minor components of the ecosystem. The most obvious example of this unintended 

consequence problem is restricted livestock grazing that increases residual fine fuels and ultimately results in incrca<;ed fire 

fi·equency. See Attachment B, which also details unintended consequences 111at oftentimes result from. Misl:,ruided and 

mi!lapplied grazing restrictions.

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525. Habitat fragmentation is an issue that needs much more research and understanding prior to imposing additional resuictions 

on land uses and development. Major questions remain as to the significance of the physical presence of infrastructure withiu 

sage grouse habitat as opposed to its frequency of use or potential for subsequent consequences. Does a two U11Ck road 

that is only used 1-2 times per year truly result in habitat fragmentation as far as the sage grOUSf: is concerned? Additional 

knowledge also needs to be obtained to answer the questions listed below: Knowledge Gaps in Livestock Infrastructure 

Issues Related to Sage Grouse Habitat Although there is a large body of popular "wisdom" about the effects of livestock 

fences and water developments on sage grouse, there has been little research on these issues. • Collisions with fences are 

known to kill sage grouse and related species (Wolfe et aI. 2007) Knick et al. 2011, Stevens et al. 2011), although the effects 

on these populations is unknown. We need information on how fence mortalities affect sage grouse population stl1lcturc, 

including effects on age c1a(]s and sex of the birds.Rowl<lud al1d Wisdom (2002) pointed out that there is no empirical 

research on raptOl's and corvids llsing power lines and l~nces as perches to improve their success in preying on sage grouse. 

We know of no recent research or information on this.

All Both fxc0011gb

526. 17) It has heen suggested that thc impacts of livestock grazing are spread lmevenly across the landscape and may posilively 

or negatively affeet sage grouse habitat. Additional conservation measures should not be applied to lhose locales where 

existing Or Cllrrent management strategies are resulting in improving sagebrush habitat conditions and increasing sage 

grOlL"ie population numbers. For example. when the BLM has made a determination that the CUlTent grazing use conforms 

to Standard 8 of the Rangeland Heath Standm:ds, then there is no legal or faclual justitkation for the BLMlUSFSW or for a 

Land Usc Plan to prescribe something more or different. See (1) above. The unintended consequences of new management 

restrictions men(ioned in (11) also apply here.

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527. 21) There is only little evidence of direct negative effect of livestock grazing on sage grouse and fuere is no evidence that 

livestock grazing is the primmy cause of sage grouse population decline.

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528. 22) Nest trampling by livestock appears to be exaggerated. Trampling of sage bTfouse nests by livestock and nest desertion 

due to disturbance by livestock have been reported, although relatively rarely. Only two out of 161 nests in a Utah study 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-915

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

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Agency CmtLtrCode

were trampled by livestock (one by cattle and one by sheep) and five were deselted following disturbance (Rasmussen and 

Griner 1938, as cited by Rowland 2004). Disturbculce by livestock is most likely when cattle and sheep are herded together 

and moved (Call and Master 1985), willi sheep being more likely to disturb sage grouse than are cattle (Patterson 1952, as 

citcd by Call aJ1d Maser 1985).

529. 26) The following statements relate directly to livestock grazing and its effect on sage grouse anellor sage brush ha.bitat. The 

point!'; must be considered and fully assessed when developing livestock mmlagement strategies intended to benefit sage 

grouse. • DOlmant season grazing ruld appropriate Sl.Lrnmer grazing by cattle can improve habitat for sage grouse. • There 

is little indication that fall grazing affects grass growth during the following nesting seaC)on, although fall grazing does afCeet 

the residual grass available for nesting cover (though it is a que~ .. tion ofrelanve degree). • Appropriate cattle grazing in 

mesic meadows during summer can increase the availability offorbs for sage grouse. Sage grouse depend on lush forbs for 

bro~)d rearing during summer (Peterson 1970, Drut 1994b, IIuwcr 2004). Cattle gr.~zing in mesic meadows can increase 

this food supply (Evans 1986, NecI 1980 as cited by Holechcck et al. 1982, Evan~ 1986, and Wambolt et al. 2002). Sage 

grouse were attracted to nOlthern Nevada meadows that had been grazed belore forbs went dormant in late July and used 

these significantly more than adjacent lUlgrazed meadows (Evans 1986). The regrowth was higher in protein c:md lower in 

fiber than mature tissues. • A second study in the same ar.ea fOlUld that a rest-rotati.on g.razing system was especially

beneficial for sage grouse (Nee1 1980 as cited by Holecheck et aL 1982, Evans 1986, and Wambolt et al. 2002). Rest periods 

allowed forbs to thrive and subsequent grazing reduced grass cover and made the forbs rnore available to sage grouse (Neel 

1980 as cited by Evans 1986). A third study in tlns area fOlmd that sage grouse prefened to forage in areas where vegetation 

ranged fTom 8 to 15 em, rather than adjacent areas where vegetation ranged from 10 to 25 em (Klebenow 1985 as cited by 

Wamboldt et al. 2002) • No signiflecmt relationship wa~ found between sage grouse extirpation from its hlSt0l1C range and 

cattle density in those areas (Aldridge et al. 2(08). • Claims of direct negative effects of livestock b'l'azing on sage grouse are 

poorly supported by the scientific literature. BLM must insure that studies cited as jU'ltification for management changes 

intended to benetit sage grouse are applicable to sage b'l'ouse. In numerous cases, management recommendations for sage 

grouse have been based on~tudies conducted on other birds. For example, in his "A Blueprint for Sage-grouse Conservation 

and Recovery", Braun (2006). stated that "Grazing by domestic cattle can negatively impact nesting success of ground-nesting 

birds," and cited Walsberg (2005) as support. However, the cited study did not study sage grouse and is not directly

applicable to sage grouse. R...'lther, Wal:-;berg (2005) discussed ollly dark-eyed jlU1COS (Junco hyemalis) in ponderosa pine 

communities ofnolthern i\rizona. LOwer success of dark-eyed juncos in grazed areas was attributed to more extreme nest 

micro-climates resulting from the removal of herbaceous vegetation by cattle. However, grazing did not begin until after all 

clutches had hatched (Walsberg 2005). In addition, dark-eyed junco chicks remain in the ncst for up to 13 days after hatching 

(Walsberg 2005), in contrast to sage grotL')e chicks, which leave the nest soon after hatching (Schroder, 1999). This means 

that sage grouse chicks are little affected by nest micro-climate, the putative cause of reduced dark-cyedjunco chick success. 

Walsberg (2005) also suggested that vegeta.tion removed by cattle may have int:reased predation by making nests more

visible, although predation rates were not recorded in thJl:i ~iudy.

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530. Regulations to greater limit livestock grazing are not solutions to stop the decline of sage grouse. Historically sage grouse 

have been found thriving where cattle have grazed or are grazing.

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C. Comments by Resource Planning Issue

C-916 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

531. Our public lands are used and enjoyed by many different people. We all need to be responsible citizens to protect these 

lands and habitats. We as a ranching family love the land our existence is dependent on public lands grazing. We have and will 

continue to be stewards of our public lands.

All Both fxc0012GB

532. We stress flexibility in a plan that will show compatibility with grazing, mining, and recreation. All Both fxc0012GB

533. I control several hundred thousand acres of federal and for grazing purposes and the majority of it is considered critical and 

essential habitat. Sage Grouse are plentiful on most of my range. The highest nwnber of birds however is on my deeded 

ground. Maybe ranchers like my self are better lands managers than the government and capable preserving habitat while at 

the same time harvesting more forage from the deeded than is allowed by the BLM.

All Both fxc0017GB

534. My ranches produce about 800,000 pounds of beef every year. That is enough to feed every person in the State of Nevada 

for several days. To put an actual food producing operation in jepordy because of an unfounded environmentalist driven act 

would be unconscionable. Support any action on your part.

All Both fxc0017GB

535. Within 10 years of establishing the rotation method I would say our available forage doubled. Now, after 20 years of practice 

we leave considerable standing forage and the cattle benefit from continually moving onto fresh pasture.

All Both rmc0003RM

536. How does this benefit Sage Grouse? Small chicks need a succulent understory that contains lots of juicy bugs for survival. 

When first hatched they probably can't even reach Sage Brush leaves. With cattle on each area for only about two weeks out 

of the entire year it leaves the rest to the birds and other wildlife. As the cattle are moved any rain that falls during the 

summer benefits regrowth as cattle are not there to eat off the young shoots. The clue to rotation grazing is to not return 

to the same pasture until the grass has recovered. In our arid climate we do not return to regraze an area in the same year 

thus leaving a great deal of cover. We also rotate the cattle through the pastures in a different sequence each year. This 

allows plants to flower and seed undisturbed every few years no matter what time of the summer they bloom.

All Both rmc0003RM

537. I feel the biggest detriment to habitat for cattle and wild life is club moss. Many people look out over their pastures and see 

sagebrush as a threat to their pastures. We did too until we started looking under the sagebrush. The real culprit is club 

moss. This cannot be removed by reducing cattle numbers. On one range field trip we examined and exclosure that had not 

one head of cattle on it for the last 40 years. It had as much club moss inside the fence as outside of it. A range expert told 

me once that he had placed a clump of club moss in a box up on a shelf in his office. Six months later he took it down and 

poured water on it. The club moss turned green and started to grow. There are a few ways to kill club moss. Chemicals do 

not work very well and are expensive. The best luck we have had on our own land is: (1) winter feeding on it. You will find 

no club moss on your winter feed grounds. Even rolling one round bale off a hillside will show benefits years later. The heavy 

concentration of cattle urine kills the moss. Rotating winter feed grounds with summer or fall pasture really improves them. 

(2) Spiking and drag harrowing the pasture. Gouging up the moss and throwing dirt over it will kill the moss. Just once over 

with spikes leaves enough sagebrush intact for the grouse. The more club moss that can be killed the more understory will 

grow among the sagebrush benefiting the sage grouse. Once killed, rotation grazing will keep the club moss from returning. 

(3) Concentrating a large enough number of cattle in a small enough area will trample the moss. This is difficult to do over 

a large area. We put salt and mineral out in areas of the worst club moss infestation. No matter where you put out the salt 

or how far it is from water the cattle will find it.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-917

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

538. In conclusion I do not believe simply reducing the number of cattle in a pasture will benefit sage grouse very much if at all. 

Managing the cattle in a rotation method of grazing would be much more beneficial to both sage grouse and cattle. If you 

have a good habitat for one, it is good for the other. Any money the BLM may have available would be best spent in spiking 

and cross fencing to benefit sage grouse.

All Both rmc0003RM

539. Prescriptive grazing shall be considered and a tool for use in increasing and establishment of habitat for Sage Grouse. All Both rmc0004GB

540. Range Improvements to benefit species and maintained by permittees who hold Federal Range Maintenance agreements will 

be allowed mitigation credits.

All Both rmc0004GB

541. As well as the impact of grazing should be controlled in grouse habitat All Both rmc0008RM

542. In addition to its economic significance, livestock grazing provides irreplaceable environmental and social values. These 

values contribute irreplaceable wildlife habitat, open spaces, ranchland buffers between federal lands and developments, 

scenic vistas, visual beauty, and the traditional image and heritage of the historic rural landscapes of Wyoming and the West. 

Losses of these essential environmental, historic, and social values of livestock grazing to users and visitors of the area and 

residents of impacted communities should be included in the scope of the EISs/SEISs.

All Both rmc0010RM

543. Livestock grazing is an important tool used to enhance and sustain rangeland health. In Chapter Two of the EISs/SEISs,

which includes goals, objectives, and management actions of the various resource values, it is essential these goals, objectives 

and management actions for livestock grazing management include the promotion of livestock grazing

management. This is a stark contrast to the belief that livestock grazing management exists only to promote all other

resource values. Chapter Two should be written with the understanding that livestock grazing is an important resource 

value in and of itself. Often, the effects livestock grazing has upon other uses are focused on and the impacts of those uses 

upon livestock grazing management, forage availability and grazing permittees are overlooked. Planning needs to include the 

effects greater sage-grouse management has upon livestock grazing management.

All Both rmc0010RM

544. So will designation of a system of sagebrush reserves as Areas of Critical Environmental Concern (to protect the highest 

quality remaining habitat from degrading land uses) and retirement of grazing permits in the West.

All Both rmc0020GB; 

rmc0004RM

545. Sage Grouse benefit from livestock grazing. Thus, the EIS and SEIS scoping process must analyze the positive impact livestock

grazing on public lands has on sage grouse populations; and must analyze the loss of those benefits should grazing on public 

lands be reduced or eliminated.

All Both rmc0021GB

546. - It is well·established science that proper grazing practices serve to benefit public lands, as well as the wildlife populations 

that habitat such areas;

- It is also well-established that sage grouse populations benefit by grazing on public lands and that grazing is compatible with 

good sage grouse habitat;

- Grazing reduces the frequency and severity of fires, one of the biggest threats to Sage Grouse habitat. See, Karen 

Launchbaugh, et. al, Interactions Among Livestock Grazing Vegetation Type, and Fire Behavior in the Murphy Wildland Fire 

Complex in Idaho and Nevada, 30 (USGS July 2007);

- Additionally, livestock increase the quality and availability of forage for Sage Grouse. See. id.; see arso Matthew J. Holloran 

and Stanley H. Anderson, Greater Sage Grouse Research in Wyoming: An Overview of Studies Conducted by the Wyoming 

All Both rmc0021GB
C. Comments by Resource Planning Issue

C-918 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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cooperative Fish and Wildlife Research Unit between 1994 and 2005, C-28 (2005);

- For example, strategic supplementation coupled with intensive grazing by livestock at high stock densities for short periods 

may be an economical and sustainable way to rejuvenate sagebrush steppe (Provenza et al. 2003).

- Finally, keeping livestock on the landscape prevents range land and Sage Grouse habitat from being converted either into 

crop land or, more important, into human development, such as subdivisions;

- Livestock grazing, particularly when such grazing occurs on parcels of adjoining deeded and public lands, helps to minimize 

the negative impacts to sage grouse populations of land fragmentation and human development. Sage grouse populations in 

Montana are healthy precisely because of decades of good rangeland management by agriculture producers in this State;

- For these reasons, responsible livestock management and grazing is a helpful tool in Sage Grouse habitat management and 

should be used accordingly;

- MWGA's membership recommends that BLM analyzed, address, and recognize the benefit grazing has to healthy sage 

grouse populations as part of the EIS/SESIS process.

547. Ranching is a crucial component of Sage Grouse success. Thus, BLM should recognize, as a result of the scoping process, that 

the EIS and SEIS alternatives should analyze the benefits of continued responsible rancbing practices to the sage grouse and 

its habitat.

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548. In sum, it is an undeniable fact that the most important remaining habitat for sage grouse in Montana resides in the hands of 

agriculture producers. BLM must analyze what part its public land management policies have played in the decline of sheep 

ranching over the last 40 years. Because sage grouse must consume soft-tissue foods, sage grouse used to thrive on sheep 

droppings. But, this source of sage grouse food has dropped as the number of sheep ranchers have dropped. MWGA 

recommends strongly that BLM take these realities into account when shaping its sage grouse management policies.

All BLM rmc0021GB

549. Prescriptive grazing should be considered as the priority tool for use in increasing and establishing the habitat for 

sage-grouse. We feel it is the most cost-effective approach and stats have shown that when the sage-grouse populations 

were the highest. the Utah BLM permitted livestock AUM's were 1.7 million. The sage-grouse population decline closely 

resembles the decline of permitted livestock AUM's to the current .7 million AUM's . The numbers are very similar for 

Forest Service AUM's. We would like to add the coordination of the Grazing Improvement Program in Utah to improve 

long-term grazing management.

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550. We encourage the BLM and USFS to look at multiple grazing species to achieve desired vegetation conditions for 

sage-grouse such as winter grazing with sheep to enhance sagebrush. We feel the BLM and USFS should consider other 

alternatives such as restrotation systems. The no-grazing alternative would be devastating to the local 

customs/culture/economics of Box Elder County.

All Both rmc0023GB

551. We strongly encourage habitat projects where needed. Vegetation treatments without improvement management will be 

very short-lived. Local sage-grouse working groups should have a major voice as to where and how money is spent with the 

advice of the University Extension and local biologists.

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552. Range improvements to benefit species and maintained by permitees who hold Federal Range Maintenance agreements 

should be allowed mitigation credits. We strongly support olI-site mitigation for projects that impact sage-grouse habitat.

All Both rmc0023GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-919

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

553. Protection and restoration of sage-grouse is a major objective for public lands. To achieve this objective, it is necessary to 

manage grazing so that the habitat characteristics needed for breeding and wintering can be consistently maintained.

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554. Livestock grazing is compatible with sage-grouse where the habitat characteristics needed for breeding and wintering can be 

consistently maintained. It is paramount that only light grazing be permitted on important sage grouse wintering areas, 

because during winter, sage grouse often use tall, dense stands of sagebrush which remain relatively exposed through deep 

snow. Light grazing produces mosaics in vegetation and an increase in herbage production that are favorable for 

Sage-Grouse nesting and brood-rearing habitat. Riparian areas and wet meadows used for brood rearing are especially 

sensitive to grazing by livestock. 

Protecting sage grouse nesting and brood-rearing habitat from livestock use also encourages climax vegetative conditions. If 

this is not feasible, limit grazing to the month of July. Defer grazing until after the peak of the growing season with the intent 

of providing herbaceous cover and forage for the majority of the nesting, hatching, and early brood-rearing. Cessation of 

grazing by 1 August is designed to minimize livestock concentrations in wet meadows and riparian areas with open water by 

avoiding "hot season" use and to allow a 30-day regrowth period before the first killing frost. Additionally, late summer-early 

fall regrowth is important for carbohydrate storage in roots and stem bases of cool season grasses. This enhances plant vigor

while allowing residual vegetation to accumulate cover for nesting and early brood-rearing the following spring.

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555. Data shows that successful grazing systems were found to have significantly (p=0.01) less grazing during the ''hot season'' 

(July through early September) (12.5 d) than unsuccessful systems with 33 .4d. Likewise, the duration of all livestock 

treatments was significantly (p=0.001) shorter in successful systems (28.2d) compared to 59.3 d in unsuccessful systems. 

Given the reluctance of cattle to disperse from riparian areas, the duration of grazing treatments becomes a key factor in 

determining the severity of impacts such as trampling and mechanical damage, soil compaction, and utilization. A 

combination of longer duration and more frequent fall grazing deteriorated woody species vigor and regeneration, 

contributing to diminished floodplain function and reduded riparian dependent values.

All Both rmc0024GB

556. It has also been shown that increased use of meadows and riparian areas in mid-to late summer is common as herbaceous 

vegetation in upland habitat becomes desiccated. Potential for competition with Sage-Grouse young may be in proportion to 

the extent to which cattle select mesic/moist sites that are preferred foraging areas. Young birds seek out insects and 

succulent forbs in these habitats. Although the adult diet switches to forbs and insects in addition to sagebrush, developing 

young depend heavily upon insects for food. These habitats are critical brood-rearing and summer use areas in regions with 

low annual rainfall and during drought years.

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557. Protect sage grouse spring, summer and fall ranges during periods of drought. Drought alone has been identi ied as a major 

factor contributing to the range-wide decline of sage grouse (Connelly and Braun 1997). Design adaptive management 

strategies to protect against the cumulative effects of grazing use on sage grouse forage and cover during drought. Livestock

grazing of sagebrush ranges during years of unusually low precipitation and poor plant growth will cause an earlier than 

normal removal of grasses and forbs. This can have a serious impact on grouse dependent on forbs in that locality. Results 

suggest the timing and amount of moisture received were important to nest success...cool season grass growth during the 

preceding year (i.e., available as residual grass to nesting females) appeared to be important for overall greater sage grouse 

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C. Comments by Resource Planning Issue

C-920 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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nesting success.

The drought indicators from the National Climatic Data Center can give long term percent of normal precipitation forecasts 

that give forward looking projections of one, three, six and twelve months. Such information is critical to manage for sage 

grouse. The effects of low precipitation and drought are difficult for all wildlife and if grazing livestock are allowed in sage 

grouse habitat, the negative effects to sage grouse are well known. stocking at near-normal levels during periods of 

moderate to severe drought is probably the greatest cause of rangeland deterioration. Reduced stocking rates during 

drought, and for some time after drought, are necessary to minimize damage and hasten recovery of perennial vegetation.

558. Also, during times of drought, cattle are attracted to moist areas. Failure to adequately manage for these periods may result

in greater impact in the form of reduced vegetative cover. Brood-rearing habitats for sage-grouse are typically mosaics of 

upland sagebrush and other habitats (e.g., wet meadows, riparian areas) that together provide abundant insects and forbs for 

hens and chicks. Although the adult diet switches to forbs and insects in addition to sagebrush, developing young depend 

heavily upon insects for food.

All Both rmc0024GB

559. Avoid livestock water developments and salt grounds in traditional sage grouse spring, summer, and fall habitats. These 

developments significantly concentrate livestock and increase forage use, trailing, and soil compaction that fragment 

sagebrush habitat. These heavy-use areas may extend up to 0.8 km away from the site providing a niche for noxious weeds 

and other undesirable or unpalatable vegetation to take hold.

All Both rmc0024GB

560. It is advisable to avoid and eliminate man-made water sources that support breeding mosquitoes known to vector the West 

Nile Virus. This infectious disease is known to exist in the sage grouse ranges in Montana.

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561. Have quantifiable data collected that show there is enough herbaceous cover (at least 18cm under and around sagebrush. 

This cover is to be a condition of grazing on public land.

All Both rmc0024GB

562. Limit grazing to the month of July. All Both rmc0024GB

563. Limit grazing in riparian areas. During low precipitation years, livestock should not be in riparian areas. All Both rmc0024GB

564. Limit and avoid man-made water sources. All Both rmc0024GB

565. Have a drought management plan, with quantifiable objectives, in place before cattle are turned in to graze. All Both rmc0024GB

566. Have regulatory and enforceable actions in place when grazing changes need to be made. These actions must be based on 

quantifiable evidence. The possible changes need to be well understood by livestock producers before the permit turnout 

dates and, when data indicates, need to take effect immediately.

All Both rmc0024GB

567. Many like to point fingers at the livestock industry for the demise of sage-grouse, while more obvious culprits are to blame. 

Wildfire, development, fragmentation and predation are less emphasized because livestock grazing is more easily modified, 

even though it is clear that those other threats are substantial and, in many cases, livestock grazing has been proven beneficial 

to sage-grouse and sage-grouse habitat.

All Both rmc0025GB

568. Ranching is an important component of many of our western, rural economies and the ability to graze livestock on 

BLM/USFS lands is critical to these communities. Livestock numbers and season of use should not be changed to the point 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-921

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

that it is no longer economically feasible to graze. Functioning structures, such as corals and livestock bedding sites, should 

be ''grandfathered'' in. Often, sage-grouse prefer these disturbed areas for lekking, and the permittee should be restricted 

for created such habitat.

569. Targeted grazing should be allowed and encouraged as a tool for creating fire breaks, controlling weeds, and improving 

habitat. In some cases, fencing can help facilitate the success of a Targeted Grazing project. Electric and net wire fencing 

should not fall under the same specifications as other high-impact problem fencing.

All Both rmc0025GB

570. Grazing is very compatible with sage grouse habitat and reducing livestock numbers is not the solution for improving 

sage-grouse population and it should not be used as a mitigation strategy.

All Both rmc0025GB

571. Over the past 30 years the west has encountered wildland fires that have destroyed millions of acres of public and private 

lands. The wildland fires have destroyed not only sage-grouse habitat but other wildlife and wildlife habitat. Elko County 

believes that the changes in public land grazing policies that have been implemented in recent years has directly contributed 

to the catastrophic fires and degradation of much of the public lands in the west. These fires have directly contributed to the 

loss of wildlife and wildlife habitat including the Greater Sage-Grouse habitat. In 2006 in northern Nevada alone over 11 

million acres of public and private lands along with wildlife habitat was lost to wildland fire. These catastrophic fires were not 

prevalent nor as severe in the west during the period of time that cattle and sheep livestock grazing was at its peak. The 

consistent removal, restriction or limiting of livestock grazing has promoted decadent dry fuels that are easily ignited and 

become enormous wildland fires destroying all in its way.

All Both rmc0026GB

572. The decrease of livestock grazing public lands has directly contributed to the degradation of sagebrush and other habitat due

to the loss of consistent grazing activities that help initiate fresh habitat growth. The theory that the European settlers 

somehow caused loss of habitat and changes to the Sage-Grouse habitat and populations is not a plausible concept. Elko 

County has taken countless public testimony and researched many historical documents and journals of settlers, pioneers 

and explorers that expressed and documented that Sage-Grouse or any type of wildlife was not as abundant in our region 

before western settlement as many would believe. It has been documented by many lifelong ranchers, hunters and 

recreationist that that the Sage-Grouse and wildlife populations did not increase until settlers and ranchers established 

ranching and farming operations and livestock grazing was introduced to the west.

All Both rmc0026GB

573. We believe the management of federal lands must provide for both sage-grouse and livestock grazing as well as be made 

compatible with people and other resource uses. The large acreage ranching/farming operations are essential to protect sage 

grouse habitat from land use changes, such as housing developments. That means grazing permits must continue to be issued 

that enhance the economic viability of these livestock operations. This county and our neighboring county have seen small, 

often marginal ranch operations converted to second homes and other uses that destroyed critical habitat or enhanced 

predator opportunities resulting in substantial reductions in all wildlife numbers. It is extremely important that this 

interspersed ranchland holding foster grazing use and retention of ownerships that supports sage-grouse and the ecosystem 

they use. Our county has a limited private land tax base. The retention of economically viable operations such as ranching 

and forestry operation are far less costly to the county than the infrastructure and the safety and support facilities that come 

from second home and other such developments. In order to provide information and interact with the agencies as this 

program goes forward we would like to be granted coordinating government to government status.

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C. Comments by Resource Planning Issue

C-922 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

574. The beneficial effects of grazing on sage-grouse and its flora and fauna must be made clear. Deal especially with fire effects, 

plus forbs community enhancement.

All Both rmc0032gb

575. Reducing livestock numbers should be the least used mitigation measure because it has been a major influence in retaining 

large tracts of the essential sagebrush ecosystem while maintaining grasses and forbs. Focus measures on real threats to 

sage-grouse and its habitat.

All Both rmc0032gb

576. Functional structures, corrals, etc. that are old should be exempt from management. All Both rmc0032GB

577. Fences vary substantially as far as influencing sage-grouse and should have effects evaluated individually. All Both rmc0032Gb

578. We have many concerns related to the restrictions already being discussed for livestock grazing within the NEPA planning 

process. A BLM instruction memorandum (1M) sent to all field offices states, "Given the potential financial constraints in 

addressing the primary threats identified by the FWS, enhanced management of livestock grazing may be the most 

cost-effective opportunity in many instances to improve Greater Sage-Grouse habitat on public lands." The National 

Greater Sage-Grouse Planning Strategy lists grazing as fifth on the list of identified threats to the greater sage-grouse. What

potential financial constraints have been identified for the other primary threats? Why is enhanced management of livestock 

grazing the solution for other threats?

All Both rmc0034rm

579. Livestock grazing was introduced to the western states in the 1860's. Region wide declines in sage-grouse populations were 

not documented until after the middle of the 20th century. Were sage-grouse and grazing compatible for the first 100 years 

of coexistence but not in the last 50 years? What changed? We do not believe one industry should bear the economic 

burden of improving sage-grouse habitat when there are multiple threats identified for the species.

All Both rmc0034rm

580. The following are excerpts from Policy Analysis Center for Western Public Lands Policy Paper SG-02-02 Conservation of 

Greater Sage-Grouse on Public Lands in the Western U.S.: Implications of Recovery and Management Policies 4.1. What 

About Livestock Grazing? para 1. Livestock grazing is possibly the most contentious. polarizing. politically charged and 

complex issue facing those who make and implement public land policy. Para 2. The key policy issue before us is this: to 

restore grouse populations, saaebrush svstems will have to be manaaed for the benefit of the bird. How this affects livestock

grazing is a complex question. Overall, most of the research on sage-grouse habitat needs took place, and continues to take 

place, on habitats that are grazed. We can see from the range of data that grouse and grazing coexist in many, if not most,

areas so we know with reasonable certainty that grouse and livestock are not mutually exclusive. Para 3. There are few 

scientific, peer-reviewed articles that address the grazing and sage-grouse issue - none that are designed experiments, and 

none with replicates. Most of what is available reflects conclusions or thouahts without emoirical fi.ala, or it represents gray 

literature. Our general opinion is that any argument that livestock grazing presently is the primary cause of sage-grouse 

population decline cannot be supported by available research. Para 4. Relatively healthy populations of sage-grouse occur 

where domestic livestock graze sage-grouse habitats, and grazing management in these areas results in habitat characteristics 

that support sage-grouse populations. --------. Changes in grazing management may be necessary to increase these 

sage-grouse populations, but experimental data are lacking to guide these management decisions. The empirical data we 

have on sage-grouse habitat includes some uncertainties. Para 5. In the final analysis, grazing considerations will always be 

important to maintain habitat quality, but, do not appear as important in the next three to five years for the recovery of 

All Both rmc0034rm
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-923

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

sage-grouse as are fire, habitat loss, invasive species and the other alternatives that we discuss in other sections. (emphasis 

added) In para 2. above: The one statement in this paper that we adamantly disagree with is; "sagebrush systems will have to 

be managed for the benefit of the bird." This statement is in complete violation of NEPA and the protection of the Human 

Environment. NEPA directs that the Human Environment will be protected. Otherwise for the most part the paper is 

correct in its statements. Paragraph 3 above is absolutely correct. There is not scientific data to support that livestock 

grazing is harmful to sage-grouse.

581. To the greatest extent possible, a non-regulatory approach shall be used to influence management alternatives within Core 

Population Areas. Management alternatives should reflect unique localized conditions, including soils, vegetation, 

development type, predation, climate and other local realities."§ The Governor's EO specifies a non-regulatory approach for 

management of the sage-grouse and habitat within the State of Wyoming, WYO BLM indicates that it agrees with the 

Governor's EO and will abide with this strategy. Why are the BLM and the Forest Service so intent on going far beyond the 

Governor's desires when it comes to livestock grazing in the State of Wyoming, Weston County, and the 4W Ranch? For 

instance, Prescribed Grazing Practices and Rangeland Health Issues are very regulatory in their context. On pages 15, 16 and 

17 of Instruction Memorandum No. WY-2012-019 titled "Livestock Grazing" there are numerous statements on how BLM 

desires to control the management of livestock in the sage-grouse core areas Wyoming. pg. 15 It is the policy of BLM WY 

to promote proper livestock grazing management practices that maintain or enhance desired saae-arouse habitat conditions 

In order to ensure the necessary implementation of these types of practices and protections, this policy IM directs FOs to 

implement the following practices for all on-going and proposed permits for livestock grazing authorizations and activities in 

the context of the Wyoming Governor's core population area strategy for Greater Sage-Grouse. Continue to Prioritize 

oversight and effectiveness monitoring of grazing activities to ensure compliance with permit conditions and that proaress is 

being made on achieving WYland health standards.Continue to evaluate existing range improvements (e.g., fences, watering 

facilities) associated with grazing management operations for impacts on Greater Sage-Grouse and its habitat. Coordinate 

BMPs and vegetative objectives with NRCS for consistent application across jurisdictions where the BLM and NRCS have 

the greatest opportunities to benefit Greater SageGrouse, particularly as it applies to the NRCS's National Sage-Grouse 

Initiative pg. 16 Evaluate opportunities to coordinate management plans and strategies on multiple allotments where 

coordination under a single management plan/strategy would result in enhancing Greater Sage-Grouse populations or its 

habitat as determined in coordination with the State wildlife agency Where current livestock grazing management has been 

identified as a causal factor in not meeting Land Health Standards (43 CER 4180), use the process in WO-lM-2009-007, 

Process for Evaluating Status of Land Health and Making Determinations of Causal Factors When WY Land Health Standards 

Are Not Achieved, to identify appropriate actions. • Evaluate progress towards meeting standards that mav affect Greater 

Sage-Grouse or its habitat orior to authorizina arazina on an allotment that was not achievina land health standards in the 

last renewal cvc/e and livestock was a significant causal factor. • Where monitoring data are not available or are inadequate 

to determine whether progress is being made toward achieving WYLand Health Standards. An interdisciplinarv team should

be deploved as practicable to conduct a new land health assessment in coordination with the arazina oermitteel/essee • Plan 

and authorize livestock grazing and associated range improvement projects on BLM lands in a way that maintains and/or 

improves Greater Saoe-Grouse and its habitat o Incorporate management practices that will provide for maintenance 

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C. Comments by Resource Planning Issue

C-924 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

and/or enhancement of saae-arouse habitats includiaa specific attention to maintenance of desired under stodes of sagebrush 

plant communities. o In determining appropriate management actions that will be considered, refer to the document 

"Grazing Influence Management and Objective Development in Wyomimis Greater Sage-Grouse Habitat" (Cagnev eta/. 201 

0) for guidance. ------The information and discussion matedals found within this document wiU orovide resource 

professionals in BLM WY in planning livestock grazing strategies that meet the objectives of the Wvomina policv and strategy

pg. 17 o Evaluate and implement grazing practices that promote the growth and persistence of native shrubs, grasses, and 

forbs. Grazing practices include kind and numbers of livestock, distdbution seasons of use and other livestock manaaement 

practices needed to meet both livestock management and Greater Sage-Grouse habitat objectives. o If land treatments 

and/or range improvements are the primarv action for achieving land health standards for Greater Saae-Grouse habitat 

maintenance or enhancement clearlv disolay tbe effects of such actions in the alternatives analvzed 6 All of the above are 

regulatory in nature and thus do not follow the guidelines of EO 2011-5. Neither do they conform with NEPA and the NEPA 

Process as required by the Council on Environmental Quality and CFR 1500 - 1508.

582. Question: "Subject: Greater Saae-Grouse Habitat Manaaement Policy on Wyomina Bureau of Land Manaaement (BLM) 

Administered Public Lands lncludinQ the Federal Mineral Estate. " also "and regardless of land ownershio patterns. " When 

referring to the Federal Mineral Estate and and regardless of land ownership patterns is the BLM saying that our split-estate 

lands will be subject to the guidelines of this document? Will the BLM or the Forest Service be dictating how, when and 

where we will be grazing our livestock on our private surface estate? This must be clarified immediately.

All Both rmc0034rm

583. Predation, along with mineral production and disease are the 3 greatest factors affecting the survivability of the sage-grouse, 

far over shadowing livestock grazing as a possible culprit.

All Both rmc0034rm

584. In fact the use of Prescribed Fire on the range is a Federal Land Management action to clear lands and make them more 

productive for the Grazing Industry. It's a practice that has been used for the last 20 years that is now recognized as 

producing unwanted effects in Sage Grouse habitat.

All Both rmc0036GB

585. Other detrimental effects of the Grazing Industry are known and documented in the literature. It's been my observation that 

most published information critical of the Grazing industry is suppressed by the Cattle Industry and discounted whole sale 

as "Environmentalist". One such book by Denzel Ferguson titled "The Sacred Cow at the Public Trough" was widely decreed 

as Environmentalist Clap-Trap when it was published in the early 1980's; even though it was well founded in fact The ODFW 

may wish to review some outside sources of information in preparing revisions.

All Both rmc0036GB

586. The conservation alternative would correctly require BLM and the Forest Service to identify and protect their breeding, 

brooding and winter habitats. In these habitats, the BLM and Forest Service must not allow human disturbance such as oil 

and gas drilling, power lines, and excessive cattle grazing that reduces the vegetation cover below what these animals 

require. The BLM and Forest Service have, for decades, found ways to evade and obfuscate out of their mandate to maintain 

viable and widespread populations of the Sage Grouse and other wildlife, rolling under a pseudo-legalistic rug each successive 

geographic and demographic vanquishing of the Sage Grouse. Over'the long saga of this species, each year has brought 

further population losses, with precious little acknowledgement by the BLM and Forest Service of this cumulative loss over 

time.

All Both rmc0037RM, 

rmc0070GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-925

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

587. Excessive grazing in particular has dramatically altered the vegetation community of semi-arid habitats through the Great 

Basin, for very little economic value in the forage utilized, representing a gross failure by the BLM to roughly balance the 

marginal values of competing uses. As a former resident of Utah and New Mexico, I was astounded by the willingness of the 

BLM to strip vast areas of desert, sagebrush, and semi-arid grassland of their very thin vegetation cover for an extremely 

meager biomass volume of livestock feed, supplementing the diet of an extremely small number of cattle for a 

correspondingly minute number of ranchers. If the BLM is to uphold its mandate to provide an equitable and reasonable

balance of values to the American people, it must protect these precious ecosystems and the Sage Grouse that lives among 

them, not strip them for the piddling bit of livestock-palatable biomass that provides their physical scaffolding.

All Both rmc0037rm, 

rmc0070GB

588. I believe livestock grazing is compatible with the "Multiple Use" mandate for Federal lands in the western United States. 

Livestock grazing provides a stable, long-term economic base for many western counties.

All Both rmc0038GB

589. Upon review of the documentation provided at the Susanville public meeting I have concerns related to the restrictions 

already being discussed for livestock grazing within the NEPA planning process. A BLM instruction memorandum sent to all 

field offices states, "Given the potential financial constraints in addressing the primary threats identified by the FWS, 

enhanced management of livestock grazing may be the most cost·effective opportunity in many instances to improve 

Greater Sage Grouse habitat on public lands." The National Greater Sage-Grouse Planning Strategy lists grazing as fifth on 

the list of identified threats to the greater sage-grouse. What potential financial constraints have been identified for the other 

primary threats? Why is enhanced management of livestock grazing the solution for other threats?

All Both rmc0038GB

590. Livestock grazing was introduced to the western states in the 1860's. Region wide declines in sage grouse populations were 

not documented until after the middle of the 20th century. Were sage grouse and grazing compatible for the first 100 years 

of coexistence but not in the last 50? What changed? I do not believe one industry should bear the economic burden of 

improving sage grouse habitat when there are multiple threats identified for the species.

All Both rmc0038GB

591. As livestock grazing is often a significant contributor to the economic health and social fabric of rural counties, care must be 

taken to avoid prescriptive management practices that would impair or eliminate that industry.

All Both rmc0038GB

592. Political interests should not be allowed to water down needed sage grouse protections. The new plan needs quantifiable 

objectives- especially with regard to livestock grazing. General ideas for evaluating management activities are not enough. 

Specific protection measures need to be required. Guidance and enforcement are necessary. For example, saying merely 

that land managers should plan livestock grazing and "range improvement projects "in a way that maintains or improves 

Greater sage grouse and its habitat" is clearly inadequate and too wide open to interpretation. For one thing, maintaining 

current conditions obviously will not save the sage grouse.

All Both rmc0039GB

593. Additionally, Sanpete County is a predominately agriculture county. Our farmers and ranchers rely on the Forest as well as 

the BLM lands for grazing. It was hard to determine exactly from the maps who will be impacted by conservation measures 

included in the BLM and Sanpitch Mountain Range LUPs specific to our county, but we would hope that a cooperative 

management strategy would be proposed for those farmers and ranchers who use grazing permits in those areas.

All Both rmc0043GB

594. The Board believes the BLM already has a wide range of regulatory mechanisms in place to manage grazing on public lands. 

We do NOT believe additional mechanisms are required for the regulation of grazing. Any new Conservation Strategies 

regarding improved grazing practices MUST be based on sound science relevant to site-specific conditions and not on 

All Both rmc0050GB
C. Comments by Resource Planning Issue

C-926 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

political pressures and agendas of outside organizations.

595. Many permittees have voluntarily implemented adaptive grazing management strategies to encourage Sage-grouse 

Conservation on their allotments and private lands, and many of the recent permit renewals have included such measures. 

The Board requests that the BLM make every effort to work collaboratively with permittees to recognize and use grazing as 

a tool to enhance Sage-grouse conservation. For example, the use of grazing to reduce fine fuel loads and noxious species 

could greatly enhance efforts related to "integrated vegetation management" and "wildfire suppression and fuels 

management." Also, prescribed grazing can be used effectively to improve or enhance Sage-grouse habitat as noted in the 

Report.

All Both rmc0050GB

596. The Board is adamantly opposed to developing more cumbersome regulatory mechanisms specific to grazing or seeking to 

defer or retire allotments that would permanently eliminate a proven conservation tool and vital management option. This 

approach may result in negative management impacts on associated private lands and economic impacts to rural 

communities that are vital for long-term Sage-grouse conservation.

All Both rmc0050GB

597. Under the "Range Management" Section, this Report describes negative effects of "historic overgrazing" and "direct effects 

of herbivores on sage-grouse, such as trampling of nests and eggs." The current grazing industry and individual permittees 

should not be held accountable for historic overgrazing due in part to a lack of regulatory controls, and ineffective federal 

management. The report is deficient in identifying the current grazing regulations that have curtailed the lack of management 

in the past. In addition, statements such as "trampling of nests and eggs" are out of context and do not belong in a technical 

report without a scientific citation to support such as statement. Some concepts explored in this section such as 

maintenance of residual cover are very site-dependant, and should be identified as such.

All Both rmc0050GB

598. The consideration of changing "season of use", "number of livestock", "distribution of livestock", "intensity of use" and "type 

of livestock" to accommodate seasonal Sage-grouse habitat requirements MUST be based on sound science and not political 

pressures. These options are already considered as part of the current permitting process. Any considerations MUST 

include working with the permittee to identify a system that is feasible for the operation based on site-specific conditions and 

requirements of the involved ranching operation.

All Both rmc0050GB

599. The section on "Retirement of Grazing Privileges" is offensive and completely unnecessary. By retiring grazing privileges, the 

BLM would be eliminating a key management option and discouraging a spirit of cooperation. The Board is ADAMANTLY 

OPPOSED to this option being included in the PElS!

All Both rmc0050GB

600. The "Grazing Permit/Lease Issuance/Grazing Management" section states, "Given the potential financial constraints in 

addressing the primary threats identified by the FWS, enhanced management of livestock grazing may be the most 

cost-effective opportunity in many instances to improve Sage-grouse habitat on public lands." The BLM has properly 

acknowledged that grazing was not identified by FWS as a primary threat to Sage-grouse, and as such, new "regulatory 

mechanisms" should NOT be developed in a manner that is punitive. Rather, current regulations and procedures should be 

developed that provide a greater degree of cooperation and flexibility between the BLM and permittees.

All Both rmc0050GB

601. The new mandate for NEPA analysis for permit/lease renewals to have a range of "reasonable" alternatives that includes a 

new deferred or rest-rotation system, and includes a "no grazing", "increased grazing", and "decreased grazing" is a major 

All Both rmc0050GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-927

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

concern to this Board. Because different grazing systems are tools available to tailor to both the resource need and the ranch 

operation, they should be referenced as such, rather than emphasized as are the two mentioned above. If a permittee is 

meeting their rangeland health standards, or is making progress towards them, or if livestock is not the reason for not 

achieving standards, they should not be subject to alternatives that include no grazing or significantly reduced grazing. This 

is an unwarranted punitive policy to operators who are constantly working to maintain or improve range conditions, and 

ripe for abuse in how the policy is administered and more importantly how it is addressed in court. The Board requests that 

this policy be removed or significantly altered in the Draft PElS.

602. FIRST We suggest that a comparison study be completed comparing levels of sage grouse production on private lands 

owned by the Sorensen Family in Secret Valley to that of lands where livestock have been excluded for sixteen years now -

which are located midway along the Mary's River, above the old Hawks Place. Perhaps, if a study of this nature was 

completed it would go a long way in dispelling the myth that livestock grazing has been a leading cause of habitat degradation, 

harmful to sage grouse.

All Both rmc0054GB

603. SECOND Agency personnel need to assess the part that domestic sheep have played in increasing winter range health and 

productiveness in the Great Basin since the time of first settlement.

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604. A study needs to be completed which will confirm or discredit those advocating the use of livestock for the purpose of 

preventing plant stagnation or opening up canape cover for the benefit of wildlife.

All Both rmc0054GB

605. In our travels throughout the Great Basin and elsewhere throughout the intermountain west during the last forty years we 

have spoken to and interviewed hundreds of people - some ranchers, some farmers, outdoorsmen, hunters, sheepherders, 

sheepmen, cowboys and nature lovers, and not once have we had someone tell us that they witnessed sage grouse being 

killed when encountering fences or fence lines.

All Both rmc0054GB

606. 4. Livestock Grazing: In Nevada, the most productive sage grouse areas have a long uninterrupted history of livestock use. 

Livestock use can be beneficial, neutral, or detrimental to sage grouse. A broad brush statement cannot be made one way or 

the other. Timing, length of period of use; periods of rest: class of livestock; distribution of use are among factors that apply 

in sage grouse habitat. Studies have shown that sage grouse prefer meadow areas that are grazed over rested areas. 

Grazing can create A patchwork of tall and short cover, a variety preferred by sage grouse. Grazing has less seasonal impact 

on upland sagebrush dominated sites, here change is slow.

All Both rmc0057GB

607. Sage Grouse survival depends on some degree of removal of vegetative material. Green shoots that are both palatable and 

nutritious are necessary for a portion of the year. Survival also depends on sufficient habitat to nest in and sufficient habitat 

to survive the winter. Managed grazing by domestic cattle and sheep has provided these needs.

All Both rmc0057GB

608. To suggest removal of all grazing on public land also suggests increased fuel and uncontrolled burning of sage grouse habitat, 

a result that the birds may not survive. The extremist view of removal of all grazing on public lands is far beyond lIextent or 

range of view" involved in this scoping effort. Rather, the retention of a viable ranching industry on public lands is vital for the 

bird's survival.

All Both rmc0057GB

609. As a representative of livestock grazing interests, we are confused over the allegations of "inadequate regulatory 

mechanisms". Based on the terms and conditions of livestock grazing permits, based on the obligations to meet healthy 

rangeland standards and guidelines, where are the actual shortages of not having enough control over livestock grazing or 

All Both rmc0058GB
C. Comments by Resource Planning Issue

C-928 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

other multiple-use? We know of many allotments meeting the standards for healthy rangelands, and are troubled that this 

doesn't seem to be sufficient to be a response for the U.S. Fish and Wildlife Service's indictment of "inadequate regulatory 

mechanisms". We see examples of instances when livestock grazing is not attributed as a cause for healthy rangelands and 

still see grazing permit changes made. This is still more vilification that livestock grazing "can have localized adverse effects on 

Greater Sage-Grouse habitat" (as quoted in the Instruction Memorandum 2012-043).

610. Given the potential for beneficial gains to enhance protection of habitat areas (especially for the management of fine fuel 

loads and invasive plants) properly-managed livestock grazing should be evaluated for land use plans in the context of a tool 

to assist in accomplishing rangeland health objectives. These considerations need to be documented and advanced in a 

proactive, unapologetic manner. Because livestock grazing, as is also the case with any number of other authorized uses, are 

managed with a significant set of regulatory oversight and jurisdiction, we maintain that the implication of there being a lack 

of regulatory control is a false pretense for further expansion of the regulatory regime. We further maintain that a de ired 

consistency for land-use decisions to be pre-oriented to rejections of proposals does not constitute "regulatory 

consistency". The measurement of "regulatory adequacy" should be whether land-use decisions, carried out through the 

current NEPA evaluation process, result in sound management actions that are site-specific and consistent with improved 

habitat conditions that match the needs for the Sage-Grouse populations that inhabit the specific area.

All Both rmc0058GB

611. Another major issue is the interrelationship of responsible livestock grazing and wildfire management and prevention. All Both rmc0063GB

612. We recommend that the BLM/FS look for opportunities to incorporate or merge multiple grazing allotments under a single 

landscape based management plan. Sage-grouse are a landscape species not a single allotment species. These landscape 

opportunities should be identified LWGs. Livestock grazing constitutes a major land-use within Utah LWG areas. As such it 

is and can be an important component to sage-grouse persistence in Utah. We encourage the BLM/FS to be open to 

innovative process such as landscape-based grazing allotments as a tool in improving grazing management practices.

All Both rmc0066GB

613. We agree and encourage several reasonable aiternatives be analyzed in each NEPA document prepared dealing with grazing. 

The LWG plans identify proper grazing as an important tool for sage-grouse habitat management. To even consider a 

no-grazing alternative would be contrary to LWG sage-grouse plans, impact local economies, and be contrary to the 

multiple use concepts. Conversely, we strongly encourage alternative practices to include deferred or rest-rotation systems 

implement on a landscape level simultaneously across multiple allotments. This may require "blurring" jurisdicational 

boundaries, but may provide the best option to achieve sustainable sage-grouse conservation and local communities.

All Both rmc0066GB

614. My biggest concern is that this will in someway inhibit grazing on the grasslands. As a TBGA Board member I don't want any 

of our permitees to lose AUM's. We need to preserve our rights to graze the land in The Thunder Basin National 

Grasslands, as well as defend private property rights.

CO Both cfc0019RM

615. Appropriately, the GSGCM report does not apply, nor does Garfield County suggest, the 4-mile 'no surface occupancy' and 

a maximum 3% disturbance approaches that would effectively prohibit existing grazing on established allotments. Garfield 

County supports the approach provided in the Parachute-Piceance-Roan Greater Sage-Grouse Conservation Plan for the 

appropriate management of domestic livestock and wild ungulates. In doing so, the EIS should carefully consider and 

potentially implement the following goals:

CO Both emc0058RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-929

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1) Continue to foster a sustainable and economically viable ranching community while also providing high-quality 

sage-grouse habitat; and

2) In conjunction with sustainable livestock interests and sport hunting industries, ensure that grazing by other ungulates is 

not adversely affecting sage-grouse habitats.

616. First, we request that the BLM EIS process consider the voluntary commitment that the local Sage-Grouse Work Groups in 

Colorado have demonstrated toward improving habitat conditions for sage-grouse. Local Work Groups have developed 

long-standing, cooperative working arrangements across private and public lands. For example, in North Park, the Owl 

Mountain Partnership, a partner to the NPSGWG, has formed public/private partnerships and developed large-scale grazing 

management plans across BLM, State, and private lands. The grazing management plans have improved grazing management 

and improved habitat conditions for sage-grouse. The NPSGWG requests that the BLM analyze the impacts which "over 

regulation" might have on these cooperative and voluntary efforts to conserve sage-grouse. Regulating all uses on the BLM 

so they benefit sage-grouse over other uses, as suggested in the NTT report, may have an increased negative effect on 

greater sage-grouse because people will no longer voluntarily engage in proactive practices for the benefit of the 

sage-grouse. In addition, displacing activities from BLM to private lands could potentially have negative impacts to some of 

the most productive sage-grouse habitat on private lands. We request that the BLM consider these negative impacts in the 

EIS analysis.

CO BLM emc0060RM

617. The NPSGWG also requests that the EIS consider the variability in BLM Field Offices and how they have managed grazing in 

the past. The EIS should not be a "one-size-fits-all" approach. As mentioned above, the Kremmling Field Office has been 

extremely proactive in terms of grazing management. Only one allotment in last five years has not met minimum land health 

standards.BLM, HPP, and CPW have implemented a seeding project and grazing deferment in the allotment to bring it back 

to minimum standards. Grazing management in North Park is working. In 2010, the CPW conducted over 100 vegetation 

measurements at sage-grouse nest and female late-summer use sites. Vegetation measurements indicate that grazing 

management on BLM and private land is meeting the structural guidelines outlined in the Colorado Greater Sage-Grouse 

Conservation Plan (2008). CPW also documented good nesting success in 2010 with 47% of nests hatching at least one egg 

and better nest success in 2011 with 64% of nests hatching. North Park probably has the most stable greater sage-grouse 

population in Colorado and we believe this is a result of the good grazing management in Jackson County.

CO BLM emc0060RM

618. NPSGWG partners and the BLM are already taking a proactive approach to improving range projects for greater 

sage-grouse. For example, we have been installing high visibility top wire on fences to reduce mortality to sage-grouse. New 

water developments all have a sage-grouse design component to allow for an overflow wet seep.

CO BLM emc0060RM

619. The NPSGWG also requests that the EIS conduct a thorough analysis of the potential impacts of applying NTT measures

prioritizing sage-grouse over livestock management and structural range improvements because if measures designed to 

improve habitat for sage-grouse end up making it impossible for ranchers to make a living, then some of them may end up 

having to subdivide their land. Housing development scattered throughout North Park would have detrimental

impacts to sage-grouse.

CO BLM emc0060RM

620. Ranching has a long, rich history in the Northwestern Colorado. Ranches in Western Colorado rely on public land grazing 

leases for survival and to make a contribution to the nation’s food supply. Grazing and sage grouse habitat are inextricably 

CO Both emc0068RM
C. Comments by Resource Planning Issue

C-930 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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related. Properly managed, grazing will enhance sage grouse habitat; indeed there is a direct correlation to reduction in 

grazing and reduction in the number of sage grouse.

621. The objective to disturb no more than 3% of habitat regardless of ownership is totally objectionable. Areas of private 

ownership should not be considered in this 3%. The area covered by the 3% is not defined - is it 3% of the entire map or 3% 

of a section? Livestock should not be included in this.

CO Both emc0069RM

622. Retirement of grazing permits should only be considered with a willing permit tee and should not become an issue when a 

property is sold or transferred to another person or entity.

CO Both emc0069RM

623. Throughout the years of my observations, it is very obvious to me that the majority of the sage-grouse inhabit areas that are 

located where livestock are grazed. Removal of livestock will not enhance sage grouse habitat; in fact, it will be detrimental 

to the grouse.

CO Both emc0069RM

624. The following recommendations must be analyzed as a starting point for effective conservation:

Increase the amount of protected priority habitat by aggressively pursuing available tools, including fluid mineral lease 

retirements, voluntary grazing permit retirement (where beneficial), mineral withdrawal, coal unsuitability findings, and 

mineral claim buyouts.

CO BLM emc0070RM

625. The BLM should consider a ‘conservation alternative’ that:

- Includes conservation measures recommended by the NTT Report, with improvements, including, but not limited to the 

following:

o Avoid sagebrush reduction/ treatments to increase livestock or big game forage in priority habitat and include plans to 

restore high-quality habitat in areas with invasive species.

o Implement range management practices outlined by the NTT, with addition of further conservation measures, including 

avoiding new range and water developments that negatively impact sage-grouse and applying the 3% disturbance cap to 

certain range developments.

o Design fuel treatments to protect existing sagebrush ecosystems (including avoiding such treatments where they will harm 

sagebrush ecosystems) and prioritize fire suppression to conserve the highest quality habitat.

o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t negatively impact sage-grouse 

populations in priority habitat,31 thus negating the value of designated priority habitats.

Include small or isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority 

habitat, and protect and enhance such populations with science-based prescriptions.

CO BLM emc0070RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-931

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- Combines this with designations of a subset of priority habitat as Areas of Critical Environmental Concern that receive a 

higher level of protection than that recommended by the NTT.

626. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria:

Consider ACEC designation in high biological value areas that, although encumbered by valid existing rights, are not yet 

developed. This may be particularly feasible where actual development potential is low despite the existence of valid existing 

rights (e.g., due to speculative leasing in areas of low energy potential). It may also be feasible in areas where other 

constraints (e.g., lack of infrastructure, other resource conflicts) will make development relatively difficult and costly. 

Management of ACECs designated in such areas could include aggressive pursuit of available tools to increase the amount of 

protected habitat, including fluid mineral lease retirements, voluntary grazing permit retirement (where beneficial), mineral

withdrawal, coal unsuitability findings, and mineral claim buyouts. This is important, as Doherty et. al. (2011) found that 1/3 

of the 25% core areas have been leased for oil and gas development. Further, 44% of areas with high biological value are at 

risk for energy development. 

CO BLM emc0070RM

627. CPW believes the following range-wide threats pose the greatest risk to greater sage-grouse populations and their habitats 

(not in order of risk):

Inappropriate livestock management can have long term negative impacts to sage-grouse habitat. BLMIUSFS should expedite 

changes in grazing management to bring range conditions up to the standard where Land Health Standards are not

met within an allotment.

CO Both emc0072RM

628. CPW recommends that the USFS work with allotment permittees to address any identified grazing management issues 

sage-grouse habitat as well as provide for deferment when vegetation restoration projects are in the early stages of

establishment.

CO USFS emc0072RM

629. Wildlife Impacts Should be Evaluated

There have been acknowledgements by federal and state land management agencies in Colorado that Colorado Parks and 

Wildlife claims authority over wildlife while the BLM claims authority to manage the habitat which they graze. Although this 

may be true from the strictest legal sense, it is unsettling from a concept of managing Sage-grouse. There are areas

of Moffat County that Colorado Parks and Wildlife acknowledges higher than acceptable wildlife numbers. Moffat County 

would like to clarify that we do not support livestock numbers being reduced in areas where wildlife are overstocked on the 

rangeland.

CO BLM emc0076RM

630. I feel that a one size fits all approach will do more harm than good. I think that the range managers and the private land 

owners will need a plan that will benefit the Sage Grouse and still allow grazing. Aggressively changing in grazing on BLM 

Property could actually do more harm than good. By changing the grazing rules, ranchers would have to change grazing 

practices on private property that could negatively impact Sage Grouse summer habitat.

CO Both emc0077RM
C. Comments by Resource Planning Issue

C-932 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

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631. I think that the grazing management plan in Jackson County is working, vegetation measurements indicate that grazing 

management on BLM and private land is meeting the structural guidelines outlined in the Colorado Greater Sage Grouse 

Conservation Plan. This is because we have a good grazing plan in effect and private land owners and the BLM are working 

together.

CO Both emc0077RM

632. I think that we need to be able to do sage brush treatments. This will enhance and or restore sage-grouse habitat and keep 

the grass in good health for grazing.

CO Both emc0077RM

633. (One of the NTT recommendations most important for Routt NF) "Implement management actions (grazing decisions, 

AMP/Conservation Plan development, or other agreements) to modify grazing management to meet seasonal sage‐grouse

habitat requirements... Consider singly, or in combination, changes in:

1) Season or timing of use;

2) Numbers of livestock (includes temporary non‐use or livestock removal);

3) Distribution of livestock use;

4) Intensity of use; and

5) Type of livestock.."

Id. at 15.

"Only allow treatments [that increase forage for livestock and/or wild ungulates] that conserve, enhance or restore 

sage‐grouse habitat (this includes treatments that benefit livestock as part of an AMP/Conservation Plan to improve 

sage‐grouse habitat)." Id. at 16.

CO USFS emc0175RM

634. V. AMEND THE ROUTT PLAN VIA MECHANISMS THAT WILL BEST HELP CONSERVE GSG. The current Forest Plan 

direction potentially applicable to GSG conservation (SRC at 5-6) is inadequate to ensure survival and recovery of the 

species. None of the measures are specifically geared toward protecting GSG, and none of the oil-gas lease stipulations apply 

year-round. In order to ensure the highest likelihood of conserving GSG, the Forest Service will have to limit human uses of 

GSG habitat and surrounding areas. It will be especially important that no oil-gas leasing or mineral development be allowed 

on any GSG habitat and some adjacent land. No road construction can be allowed in GSG habitat, subject to valid existing 

rights. Livestock grazing may have to be adjusted.

Also, as is discussed in part 3 below, the current management prescription assigned to the draft core areas is not appropriate 

for ensuring the protection of GSG. Thus new Forest Plan direction is needed to incorporate the recommendations outlined 

by the National Technical Team and ensure the best chances for recovery of GSG populations. The agency should amend the 

Routt Land and Resource Management Plan via the following methods, using point 1 alone, or preferably, in combination 

with points 2 and/or 3:

CO USFS emc0175RM

635. A critical look at the relationships and dependence between livestock grazing and the Sage-grouse. There are a number of 

sound scientific studies that have shown well-managed livestock grazing is both compatible with and beneficial to 

Sage-Grouse habitat conservation. Grazing reduces the instances and severity of wildfires (Launchbaugh et al. 2007). It 

improves greater sage-grouse habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner 

CO Both emc0178RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-933

Scoping Summary Report

Table C-6.A

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et al. 1994, Evans 1996). It has also been used to control invasive weeds (Olson and Lacey 1994, Walker et al. 1994). BLM’s 

own Instruction Memorandum No. 2012-043 states "Depending on design and application, grazing practices can also be used 

as a tool to protect intact sagebrush habitat and increase habitat extent and continuity which is beneficial to Greater 

Sage-Grouse and its habitat. Given the potential financial constraints in addressing the primary threats identified by the FWS, 

enhanced management of livestock grazing may be the most cost-effective opportunity in many instances to improve 

Greater Sage-Grouse habitat on public lands."

636. Sage grouse have been effectively accomodated by cooperation between agencies and ranchers in the Gunnison Valley. Why 

not learn from them?

CO Both fln00009RM

637. The nations taxpayer's money has been doled out through the BLM, SCS, and other agencies to remove sagebrush, make 

meadows, and build ponds on low sagehen breeding grounds. All of these projects fail to consider these birds or their needs 

as long time residents of the country.

CO Both rmc0016RM

638. The EIS should consider studies completed by CPW, including those by Clayton Braun and Anthony Apa, in evaluating the 

impact of surface uses such as grazing and recreation, and mineral development including oil and gas and mining on the 

Greater Sage Grouse. Certainly sage grouse have been shown to benefit from proper livestock grazing (Bainter et. al2009, 

Briskc et. al2005), which has occurred on these lands for over I 00 years. Groundtruthing impacts before applying severe 

limitation or no activity is a necessity, but expensive. Reconciliation or reducing the imbalance ohvildlife AUMs should be 

addressed in the EIS. Livestock numbers should not be reduced at a severe cost to producers just because wildlife numbers 

are so high.

CO Both rmc0050RM

639. The following recommendations must be analyzed as a starting point for effective conservation:

Increase the amount of protected priority habitat by aggressively pursuing available tools, including fluid mineral lease 

retirements, voluntary grazing permit retirement (where beneficial), mineral withdrawal, coal unsuitability findings, and 

mineral claim buyouts.

East Both emc0089RM

640. iv. The BLM and FS should analyze an alternative that provides more protection than that afforded by implementation of the 

National Technical Team’s Recommendations.

The BLM and FS should consider an alternative that:

- Includes conservation measures recommended by the NTT Report.

- Combines this with designations of a subset of priority habitat as Areas of Critical Environmental Concern that receive a 

higher level of protection than that recommended by the NTT.

- Incorporates improvements to the NTT’s recommendations, including the following:

o Avoid sagebrush reduction/ treatments to increase livestock or big game forage in priority habitat and include plans to 

East Both emc0089RM
C. Comments by Resource Planning Issue

C-934 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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restore high-quality habitat in areas with invasive species.

o Implement range management practices outlined by the NTT, with improvements, including avoiding new range and water 

developments that negatively impact sage-grouse and applying the 3% disturbance cap to certain range developments.

o Design fuel treatments to protect existing sagebrush ecosystems (including avoiding such treatments where they will harm 

sagebrush ecosystems) and prioritize fire suppression to conserve the highest quality habitat.

o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t negatively impact sage-grouse 

populations in priority habitat,10 thus negating the value of designated priority habitats.

o Include small or isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority 

habitat, and protect and enhance such populations with science-based prescriptions.

641. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing population), 

along with designation of ACECs informed by the following additional criteria:

Consider ACEC designation in high biological value areas that, although encumbered by valid existing rights, are not yet 

developed. This may be particularly feasible where actual development potential is low despite the existence of valid existing 

rights (e.g., due to speculative leasing in areas of low energy potential). It may also be feasible in areas where other 

constraints (e.g., lack of infrastructure, other resource conflicts) will make development relatively difficult and costly. 

Management of ACECs designated in such areas could include aggressive pursuit of available tools to increase the amount of

protected habitat, including fluid mineral lease retirements, voluntary grazing permit retirement (where beneficial), mineral 

withdrawal, coal unsuitability findings, and mineral claim buyouts. This is important, as Doherty et. al. (2011) found that 1/3 

of the 25% core areas have been leased for oil and gas development. Further, 44% of areas with high biological value are at 

risk for energy development.

East Both emc0089RM

642. i. Lander, WY RMP

Alternative B stresses avoiding construction of new infrastructure (such as fencing) and instead focuses on livestock grazing 

management throughout seasons of use and lower forage utilization. This alternative includes the removal or modification of 

existing fences when and where opportunities exist.

East Both emc0089RM

643. i. Lander, WY RMP

Alternative B stipulates light livestock grazing levels in areas typically preferred by cattle, such as riparian-wetland areas, 

adjacent upland areas, and around salt and mineral supplements and water troughs and developments. Also, Alternative B 

prohibits salt or mineral supplements within 0.5 mile of riparian-wetland habitats to prevent livestock congregation at water 

East Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-935

Scoping Summary Report

Table C-6.A

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sources. Alternative B prohibits the placement of salt or mineral supplements within 0.6 mile of greater sage-grouse leks. All 

these provisions would protect important sage-grouse habitats (foraging areas, breeding areas, nesting areas) from livestock 

trampling and the impacts of heavy plant utilization.

644. Livestock grazing is described as a diffuse disturbance while the IM ignores other direct and diffuse disturbances, including 

wild horses, wildlife herbivory and hunting. Technical Team Report at p. 14. It is difficult to understand the basis or the 

criteria used. VRLP views this portion of the Technical Team Report is naked attack on livestock grazing that merits 

sanctions for its lack of merit. The recommendations for grazing show a fundamental lack of knowledge about grazing

regulation and other grazing animals. In most western states, livestock numbers have declined while wildlife and predator 

numbers have increased. Ex. 1 pp. 3-4; Ex. 1A pp. 6-9 (grazing created more favorable habitat conditions for sage grouse). 

The RMP revisions need to develop the data regarding big game, wild horses and livestock numbers for each project area.

Livestock grazing initially set in motion plant succession that created sage grouse habitat and predator control in defense of 

livestock made it a safe environment for sage grouse. Ex. 1A pp. 9-10. Livestock grazing on the majority of the allotments has 

been managed under use limits, rotations and stocking rate limits. It should be noted that an important difference between 

livestock grazing and wild horses/big game is that the entire annual increase of livestock is removed each and every year and 

sent to market. This is not the case, especially with wild horses. Healthy native range is as important to range livestock 

production as it is to sage grouse. The premise that livestock grazing as currently managed adversely affects sage grouse

or sage grouse habitat lacks documentation. Ex. 1A p. 8. Livestock do not eat sagebrush which is the winter cover and food 

source for sage grouse. Livestock do not directly harm sage grouse.

For more than 15 years, grazing has been regulated under rangeland health standards. 43 C.F.R. §4180.2 (grazing must meet, 

maintain or make progress towards meeting range health standards). These standards were developed to protect and 

improve riparian areas, native vegetation and plant health and cover for all rangelands, which contributes to improvement of 

sage grouse habitat. Virtually all operators use a deferred or rest rotation system and do not use the rangelands year-round, 

unlike some wildlife and all of the wild horse herds. To the extent that the criteria are not consistent with rangeland health 

standards, they must be ignored or set aside because rangeland health standards are mandated by regulation which 

supersedes an IM. 43 C.F.R. Part 4180. T

he Technical Team Report conservation measures appear to attribute livestock use to the decline in sage grouse habitat, Ex. 

Pp. 3-4. This ignores the irreplaceable role that grazing plays in reducing fuel loads, improving plant palatability and vigor. If 

livestock grazing were removed, the private land associated with these ranches will be subdivided, with a loss in wildlife 

habitat and recreation access. The trend towards subdivisions accelerated after BLM contended incorrectly that livestock 

grazing caused the desertification of western rangelands, declines in wildlife habitat, and water quality degradation in the 

contest of the grazing rules revision.

If BLM is going to require removal of livestock during key periods of its life cycle, Technical Team Report at p. 15 (implement 

management actions which could include temporary non-use or livestock removal), it must do so for all other herbivores, 

including wild horses. It is not feasible to remove all herbivores, and for the same reason, it is ridiculous to assume that 

East Both emc0155rm
C. Comments by Resource Planning Issue

C-936 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

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livestock should be removed as well. The recommendation to retire grazing privileges is unwarranted. BLM could improve

rangeland health more quickly by moving wild horses onto private lands in nonpublic land states. The Technical Team Report 

also fails to recognize the stewardship of the livestock industry.

645. VRLP believes that continued management of public rangelands to meet healthy standards will also ensure viable populations 

of sage grouse for decades to come. VRLP supports adaptive management but IM 44, Technical Team Report leaves noroom 

for adaptive management. BLM should adopt the object of managing for rangeland resources and rangeland health and 

monitor population numbers. Then if there are changes in numbers, BLM would adjust based on the factors specific to 

thensite.

East Both emc0155rm

646. The Technical Team cites potential impacts of livestock on sage-grouse and their habitat to include long-term changes to 

habitat due to herbivory, the trampling of nests and eggs directly by livestock, altered sage-grouse behavior due the presence 

of herbivores, and impacts on sage-grouse due to structures associated with grazing management (p. 14).

Land use plans should incorporate coordinated livestock grazing and sage-grouse habitat objectives in all grazing allotments 

or permit renewals in priority sage-grouse habitat and . Particular emphasis should be placed on how grazing effects 

sage-grouse nesting and early brood-rearing habitat, as grazing appears to have the greatest impact on such habitat, notably 

in terms of availability of cover. In their 2010 report titled Grazing Influence, Objective Development, and Management in 

Wyoming’s Greater Sage-Grouse Habitat With Emphasis on Nesting and Early Brood Rearing, the authors state, "While 

grazing management has limited effect on sagebrush, grazing management is important in terms of effects to height and 

density of herbaceous material available for hiding and cover." A sagebrush/bunchgrass community provides the highest 

quality sage-grouse nesting and early-brood rearing habitat available, as well as good livestock forage (Cagney, et al., 2010).

At a minimum, plans for grazing management on sage-grouse habitat should focus on two aspects of plant health: (1) 

promoting desirable plant communities in the long term, and (2) annually managing standing crop to provide cover for 

sage-grouse. In general, appropriately timed grazing with moderate utilization levels will maintain plant communities in the 

preferred ecological state (sagebrush/bunchgrass) and will promote vigor and sage-grouse values in less-preferred ecological 

states (Briske, et al., 2005).

Moderate utilization should reflect percentage of key species utilization as defined by rangeland health standards for a given 

geographic region. Most often, moderate utilization results in less than 35 percent use on total herbaceous vegetation and 

less than 60 percent use of key species (NRCS). Moderate utilization is also critical in that it ensures residual cover, which 

increases the effectiveness of precipitation by: 1) impeding run-off, 2) enhancing infiltration into soils, and 3) helping retain 

organic material in the soil.

East Both emc0167RM

647. Federal agencies should incorporate the following recommendations in all grazing management plans associated with priority 

sage-grouse habitat (adapted from Cagney et al., 2011):

- Mating-Leks: Document the location of leks through consultation with appropriate federal or state biologists. Avoid any 

new sources of disturbance on lek sites (ex. range improvements).

- Nesting/Early Brood-Rearing: Maintain a sagebrush/bunchgrass plant community where present. Manage for high vigor 

across all plant communities. Avoid repeated use of cool-season bunchgrasses during the growing season. Limit utilization to 

East Both emc0167RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-937

Scoping Summary Report

Table C-6.A

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moderate levels to assure previous’ year’s standing crop for sage-grouse cover; utilization objectives must be applied to 

locations preferred by livestock (ex. water sources) which may result in lower utilization across the entirety of the 

management unit.

- Late Brood-Rearing Habitat: Avoid repeated grazing of riparian areas in seasons when temperatures are high.

- Winter: Avoid levels of browsing on sagebrush that would limit sage-grouse access to their food supply and cover. Avoid 

heavy use of herbaceous standing crop.

Finally, federal agencies should ensure all grazing management plans incorporate achievable objectives, and should develop 

methods to evaluate and adjust grazing management strategies, preferably annually.

648. Grazing Infrastructure: Water Development and Fences

Multiple pastures allow for better control of timing and utilization, but often require a greater investment in infrastructure, 

notably fencing and water development. As sage grouse can be killed or injured by fences, agencies should require 

permanent fence markers on fences: 1) constructed with steel posts, 2) constructed near leks, 3) bisect winter 

concentration areas, 4) border riparian areas, or 5) show evidence of previous grouse fence strikes. Agencies should 

prohibit construction of any fences within 0.6 miles of leks. Wood fences reduce strikes, but provide perch sites for raptors 

and ravens. Agencies should require the use of anti-perching devices on all wood posts. Generally, unnecessary fences 

should be removed and new fencing projects limited in sage-grouse priority habitat. Water-troughs can cause unnecessary 

wildlife mortality, including sage grouse. As required by BLM Instruction Memorandum No. 2007-179, escape ramps should 

be required in all water troughs/tanks. Overflow areas provide water on the ground, and lessen wildlife mortality. Springs 

and seeps should be protected from livestock trampling. In areas with documented West Nile Virus, plans should 

incorporate measures to minimize mosquito habitat, including minimizing areas of standing water with emergent vegetation 

and, where not possible, treating with a biological larvicide. Ideally, all new water development projects should meet 

minimum standards set by the Water for Wildlife Initiative (Taylor et al., 2007). As above, agencies should develop methods 

to evaluate and ensure compliance of all infrastructure projects.

East Both emc0167RM

649. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations.

GB Both emc0204GB

650. Address Impacts of Grazing: The BLM must recognize effects of grazing on sage-grouse, including removal of cover, 

vegetation composition change, behavioral changes, and impacts from grazing-related infrastructure. Reduction of grazing 

impacts will necessarily include management changes quantified by conservation metrics tracked through reliable, enforced 

reporting and analysis.

GB Both emc0355GB

651. Address Impacts of Fencing: Fences increase predator presence and cause direct sage-grouse mortality through collisions. 

BLM should remove unnecessary fences and limitnew fencing in priority sage-grouse habitat, particularly in nesting and early 

broodrearing habitat.

GB Both emc0355GB

652. Revisions to Land Use Plans need to adequately outline threats related to grazing and agricultural practices, and consider GB Both emc0355GB
C. Comments by Resource Planning Issue

C-938 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

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conservation guidelines intended to address those threats. Grazing management is important because it affects the height 

and density of herbaceous material available for sage-grouse hiding cover.24 According to the NTT, potential impacts of

livestock on sage-grouse and their habitat include long-term changes to habitat due to herbivory, the trampling of nests and 

eggs directly by livestock, altered sage-grouse behavior due the presence of herbivores, and impacts on sage-grouse due to 

structures associated with grazing management (Page 14).

The NTT suggests that BLM incorporate management considerations into all grazing allotments or permit renewals in 

priority sage-grouse habitat (page 14). In order to accomplish conservation objectives, BLM will need to determine methods 

to monitor compliance by livestock managers and permit-holders as a part of land use planning. The BLM should include

comprehensive measures for analyzing the impact of livestock grazing on sage-grouse populations and habitat, and create 

metrics to be used to measure to achieve conservation goals in allotments. This should include reporting on progress in 

implementation of modifications of fences, water development, and other management changes required of permit holders 

by BLM.

According to the NTT, “managing livestock grazing to maintain residual cover of herbaceous vegetation so as to reduce 

predation during nesting may be the most beneficial for sage‐grouse populations,” and, other “objectives that control 

livestock movements and grazing intensities can be achieved broadly through rotational grazing patterns or locally through 

water and salt placements.” All methodologies for analyzing environmental impacts should use the most recent science.

BLM should employ science-based conservation management practices of livestock—especially during critical times of the 

year such as wet and early growing seasons for the protection of native forbs and grasses, and biotic soils important to 

Sage-grouse. Additionally, allotments that are under review should have a full inventory of natural features and sage-grouse 

habitat addressed in the analysis.

Summary: The BLM must recognize effects of grazing on sage-grouse, including removal of cover, vegetation composition 

change, behavioral changes, and impacts from grazing-related infrastructure. Reduction of grazing impacts will necessarily 

include management changes quantified by conservation metrics tracked through reliable, enforced reporting and analysis.

653. Fences not only fragment a landscape, but they also create perches for raptors. Coates and Delehanty (2010) found that an 

increase in raven numbers equivalent to one additional raven per 6 linear fencing miles was found to be associated with a 

7.4% increase in the odds of sage-grouse nest failure. Fences can also be a significant source of mortality for sage-grouse 

through direct strikes.

BLM Land Use Plans must present conservation guidelines that reflect the most current science on sage-grouse movement 

and migrations. Recent studies of nest-site selection and nest success have made clear that nest distributions are spatially 

related to lek locations (Holloran and Anderson 2005, Aldridge and Boyce 2007, Doherty et al. 2010). This is contrary to 

BLM’s reliance on the outdated study of Wakkinen et al. (1992; REA AR 779). Holloran and Anderson (2005) documented 

64% of nests occurred within 3.1 miles of leks, 80% of nests occurred within 5 miles of leks, and 20% of nests occurred at 

distances greater than 5 miles from leks; nest success also was greater the farther a nest occurred from a lek, indicating a

disproportionate potential importance of these more distant nests for population recruitment. Based on their results, 

Holloran and Anderson (2005) concluded that to protect and maintain sage-grouse populations, land managers should 

GB Both emc0355GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-939

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

minimize or halt actions that reduce suitability of nesting habitats within 3.1 miles of a lek. BLM should redefine fencing rules 

within 5 miles of leks.

The NTT cites Christiansen (2009) and Stevens (2011) and suggests that, “To reduce outright sage‐grouse strikes and 

mortality, remove, modify or mark fences in high risk areas within priority sage‐grouse habitat based on proximity to lek, lek 

size, and topography.” Overall, BLM should work towards removing unnecessary fences and limit new fencing projects in 

priority areas.

Summary: Fences increase predator presence and cause direct sage-grouse mortality through collisions. BLM should remove 

unnecessary fences and limit new fencing in priority sage-grouse habitat, particularly in nesting and early brood-rearing 

habitat.

654. We have observed that well-managed livestock grazing is an effective and sustainable method for combating several of the 

most significant threats to sage grouse habitat including fuels reduction to minimize wild fires and to prevent or slow invasive 

species and conifer proliferation. While the ESA does not provide for the cost of a mitigation strategy to preclude its 

implementation, funding to implement strategies is none the less naturally limited. Our continued ability to serve a broad 

spectrum of multiple-use industries is crucial to maintaining their ability to provide beneficial habitat management and their 

financial viability to implement appropriate mitigation measures. Minimizing wild fires also protects our infrastructure from 

damage and reduces our need to mobilize crews and equipment to rebuild power lines in areas which may be sage grouse 

habitat.

GB Both rmc0056GB

655. As recognized by the BLM in IM No. 2012-043, grazing can be "used as a tool to protect intact sagebrush habitat and increase 

habitat extent and continuity which is beneficial to the Greater Sage-Grouse and its habitat." The IM continues, "Given the 

potential financial constraints in addressing the primary threats identified by the FWS, enhanced management of livestock

grazing may be the most cost-effective opportunity in many instances to improve Greater Sage-Grouse habitat on public 

lands." According to Natural Resources Conservation Service (NRCS), grazing "has been responsible for retaining expansive 

tracts of sagebrush-dominated rangeland from conversion to cropland" and can "stimulate growth of grasses and forbs, and 

thus livestock can be used to manipulate the plant community toward a desired condition."

GB Both rmc0056GB

656. Sound scientific research indicates that grazing is beneficial to the greater sage-grouse and other flora and fauna in multiple 

ways. Grazing reduces the instances and severity of wildfires. (Launchbaugh et al. 2007). It improves greater sage-grouse 

habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et al.1994, Evans 1996). It has 

also been used to control invasive weeds (Olson and Lacey 1994, Walker et al.1994).

GB Both rmc0056GB

657. There is much discussion about nest trampling by livestock but poor evidence that suggests it occurs regularly on Great 

Basin Rangelands. The conditions that appear to lead to nest trampling do not exist on Great Basin rangelands (see attached 

article). Again, we reiterate that rule making that occurs because of this EIS should be based on probability of activities having 

an adverse effect, not mere potential that something could happen. Rules and policies need to be based upon the actual 

conditions under which adverse effects are likely.

GB Both rmc0067GB
C. Comments by Resource Planning Issue

C-940 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

658. Fences needed to ensure the success of a grazing management system should not be removed. This includes allotment or 

pasture boundary fences, drift fences and exclosure fences.

GB Both rmc0076gb

659. The retirement of grazing permits should be a last resort, used only when grazing induced resource degradation across an 

allotment cannot be prevented. Livestock grazing is a legally recognized multiple use, and is an appropriate land use unless 

management cannot prevent large scale permanent declines in resource capability and production. In most of the Great 

Basin, permanent retirement of grazing permits will result in either abandonment of working ranches or their subdivision. 

Both actions are likely to have greater adverse effects on sage-grouse and other resources than the perceived positive 

effects of removing livestock. As the national population moves toward 500 million residents by 2050, national food security 

is going to require some level of food production from arid rangelands. From a national policy perspective, it makes little 

sense to eliminate working ranches and the institutional knowledge possessed by those who prqperiy manage them.

GB Both rmc0076gb

660. As you consider grazing allotments please keep in mind the agriculture based economy in the Magic Valley and the possible 

negative impact that the reduction of grazing rights will have on the base economy in Twin Falls County.

IDMT Both cfc0021GB

661. live in Ashton, Idaho and I am a school teacher in Dubois, Idaho. In the spring I travel the Red Road to work every morning 

which holds a large population of birds with around eight leks along the road. Last year I noticed the rutting was not in full 

swing until the middle of April and I continued to see activity through Memorial Weekend. Around the first of May there 

were thousands of sheep along the Red Road starting their grazing especially right smack in the middle of the main lek near

Split Rock(the Idaho Fish & Game people out of Idaho Falls know this area well). This lek holds over a hundred birds and I 

thought to myself then that this could not be a good thing for the birds. The sheep were so thick in there that no nest would

have been safe. I don't know how long it takes for the eggs to hatch and the birds are off the nest but I think May 1st is too 

early and I now believe that domestic livestock is one of the sage grouse's biggest threat. I also know that the two need to 

co‐exist but we don't have any control on what sage grouse do but we can control what livestock does to help the birds. I 

hope you come up with an effective plan for both parties.

IDMT Both emc0048GB

662. The BLM needs to review the Grazing Policy adopted by the Custer County Commissioners prior to any actions set forth 

in the Interim Management Policies or Procedures, and the implementation of any alternatives included in the NEPA

document.

IDMT Both emc0112GB

663. The Group has developed a sage-grouse conservation plan for Jarbidge Planning Area, which includes the goals outlined 

below. We ask that the BLM consider these goals as they finalize the Sage-Grouse Planning Strategy.

-Maintain or improve livestock operations

IDMT Both emc0158GB

664. While I have concerns for sage-grouse throughout their range, I am most familiar with the area around Leadore, including 

the Timber Creek, Eighteen Mile Creek, Hawley Creek, Railroad Canyon Creek, and Mill Creek drainages. I have

commented on proposals by the Salmon BLM office in the past. It seems to me that the greatest threats to sage-grouse

in this area are habitat fragmentation by roads and fences, and reduced availability of forbs and insects for broodrearing.

The greatest root cause of these problems is livestock grazing.

IDMT Both emc0268GB

665. The 2006 Jarbidge ESI, conducted as a result of settlement of grazing litigation and which found significant deterioration, is 

the only comprehensive ESI of which we are aware in recent years.

IDMT BLM emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-941

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

666. BLM must amend all Land Use Plans including those underway. Plans currently in process have very weak goals, objectives, 

and uncertain non-mandatory language. Plus they greatly avoid addressing livestock disturbance, removing grazing from lands 

where there is risk of weed invasion or sagegrouse loss, and otherwise are inadequate. Example: Winnemucca DRMP/DEIS, 

and the potentially aborted Bruneau RMP.

IDMT Both emc0411GB

667. Here, after this new sage-grouse EIS has started and awareness of the pressing need to address sagegrouse habitats is great, 

BLM’s site-specific analyses of critically important land areas are a throwback to some of the worst livestock centered 

proposals we have seen. And nearly all of the Garat allotment is mapped as PPH! This shows how terrible BLM’s NTT and

IMs are when it comes to addressing livestock grazing which is the overwhelming disturbance factor across 200,000 acres 

of the Garat allotment in the heart of critical sage-grouse habitat – under any habitat segregation scheme. This illustrates the 

serious long-term entrenched industry-biased agency behavior patterns that must be honestly dealt with in the current 

effort.

IDMT Both emc0411GB

668. It is important that you recognize that livestock grazing is compatible and beneficial to greater sagegrouse habitat 

conservation. This has been proven by independent, peer-reviewed scientific analysis. Ranchers are the stewards of the 

greater sage‐grouse habitat on both the private and public range ands. Allowing ranchers the continued use of public lands 

without unnecessary restrictions due to the potential listing of a species with such a large habitat encourages this 

stewardship and prevents fragmentation through development. As seen in many areas of successful rangeland conservation, 

livestock grazing and habitat conservation go hand in hand. Adequate regulatory mechanisms are already in place through 

rangeland standards and guides to ensure that grazing is managed for ecosystems and sensitive species.

IDMT Both flh0000GB

669. It appears that the agency has overlooked many of the benefits that the continuance of livestock grazing provides. These 

include: Preservation of open space; Noxious weed and invasive species eradication and containment; Production of forb 

growth that is preferred by greater sage‐grouse to non-grazed areas; Wildfire prevention and controlled burn efforts; 

Development of wildlife watering sources, including placement of bird ladders in troughs; and Predator control. Rather than 

undertaking an attitude of restricting livestock, the agencies should utilize grazing as a tool to manage for the U.S. Fish & 

Wildlife Service's list of primary threats affecting sage grouse in Idaho including fires and invasive weeds.

IDMT Both flh0000GB

670. - Just as grazing improves Sage Grouse habitat, ranching plays a pivotal role in both maintaining Sage Grouse habitat and 

minimizing other external threats.

- Every day, Montana's agriculture producers work diligently to minimize the presence of invasive weeds, to reduce 

exploding predator populations, to maintain Montana's open spaces, and to prevent fires, all of which seriously threaten Sage 

Grouse habitat;

- This hard work by Montana's agriculture is demonstrated by the fact that Eastern Montana has one of the healthiest, most 

diverse, grassland ecosystems in the world;

- It is because of the work of Montana's ranching community that it is possible for Montana Fish, Wildlife and Parks, the state

agency responsible for wildlife management in Montana, to translocate sage grouse from this State to Canada and other 

places where sage grouse populations are less healthy;

- Sage grouse populations in Montana are generally healthy because ranchers and federal land agencies have worked 

cooperatively for decades to preserve this species;

IDMT BLM rmc0021GB
C. Comments by Resource Planning Issue

C-942 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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- As a result, MWGA's membership recommends that BLM analyze the importance to sage grouse of BLM partnering 

positively with and seeking input from agriculture producers as to proper sage grouse management and habitat;

- As part of this analysis, BLM should address and set forth measures that can be taken to keep ranches economically viable;

- Further, the BLM should analyze the negative impact that amending the RMP's could have on the existing on the ground 

conditions in Montana, which, as noted above, presently provides the best habitat in the world for sage grouse populations;

- What is more, MWGA's membership feels that the EIS and SEIS alternatives should include detailed proposals to ensure 

that Montana's sheep producers can continue to carry out these cooperative practices. These elements might include:

a. grandfathering long-established range structures into management plans;

b. maintaining grazing permit numbers at their present economically feasible levels;

c. limiting the ability of self-styled environmental groups to excessively litigate sage grouse management efforts and to reap 

financial windfalls from the same;

d. and providing grant funding to livestock producers for sage grouse management efforts

671. The Dillion Local Working Group identified 5 key issues in the area:

5. Unsustainable or incompatible grazing

IDMT Both rmc0028GB

672. A Resolution establishing an interim policy of the Custer County Commissioners that no allotments or individual 

permittee's livestock numbers and/or season of use be lowered because of the declaration of critical habitat; and that any 

and all activities in regard to such changes in numbers and/or season of use must be coordinated with the Custer County 

Commissioners.

IDMT Both rmc0146GB

673. The BLM needs to review the Grazing Policy adopted by the Custer County Commissioners prior to any actions set forth 

in the Interim Management Policies or Procedures, and the implementation of any alternatives included in the NEPA 

document. In part this 'Grazing Policy' states that " .. the preservation of historic and customary agricultural use is important 

to the citizens of Custer County and with much of the economy derived from agriculture and related activities, maintaining 

viable tracts of agricultural and rangeland is a County goal;"

IDMT Both rmc0146GB

674. NOW, THEREFORE BE IT RESOLVED that it is the interim policy of the Custer County Commissioners do not support the 

lowering of allotments or individual permittee's livestock numbers and/or season of use because of any declaration of critical 

habitat;"

IDMT Both rmc0146GB

675. BE IT FURTHER RESOLVED that any and all activities In regard to such changes in numbers and/or season of use must be 

coordinated with the Custer County Commissioners as mandated by FLMPA of 1976 and other Acts and Regulations."

IDMT Both rmc0146GB

676. Northeast Montana provides year-round habitat for large numbers of sage grouse. The bird thrives in this region because of 

the abundance of rangeland that has been conserved since the BLM and ranches began the partnership initiated by the Taylor 

Grazing Act. As this region comes under the scrutiny of anti-grazing groups, much political effort is expended in attempts to 

remove ranches that have been part of the rangeland ecosystem for a hundred years. The Resource Management Plans and 

the Environmental Impact Statements need to recognize that threats to these ranches are also threats to the rangeland 

ecosystem, and thus are threats to the species of the ecosystem, including the sage grouse. Only by preserving on-the 

ground partners in rangeland conservation can the Department of the Interior fulfill its obligation to preserve rangeland 

species.

MT-RM BLM emc0013RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-943

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

677. Those who remember the 1930's in northeast Montana can recall dust bowl conditions in which livestock foraged by pawing 

the bare ground to expose roots they could eat. Those who remember the 1950's tell of acres or even sections of hardpan 

flats, overgrazed by feral horse herds, on which only cactus would grow. Today, northeast Montana is recognized as the 

largest, best, most intact prairie ecosystem in the world. What brought about this remarkable recovery?

1. The Taylor Grazing Act ended homesteading and protected rangeland from the plow.

2. The ensuing range adjudication and fencing eliminated non-local herds.

3. The BLM and the ranches worked to find sustainable stocking rates.

MT-RM Both emc0013RM

678. This region is great sage grouse habitat because the BLM and the local ranches have worked together to make it that way. 

A successful sage grouse conservation strategy will recognize the successes of the partnership between local ranches and the 

BLM. It will build on those successes by making the partnership stronger.

MT-RM BLM emc0013RM

679. A ranch is often portrayed as a commercial enterprise. Yet in rural communities, most ranches function more like a 

household than a business. Some federal land managers view ranches -or at least their grazing -as a management tool.

To the prairie, however, a ranch is a component of the ecosystem. Losing a ranch can be as harmful to the prairie as losing 

an elk herd, losing a wolf pack, losing a beaver population, or climate change.

MT-RM Both emc0013RM

680. In partnership with the BLM, ranches in northeast Montana have turned a dust bowl into thriving grassland. Of all federal 

agencies, only the BLM understands the value of grazing to a prairie ecosystem. By working with ranches on water and 

fencing projects, the BLM continues to improve the health of this rangeland. Management of the prairie's dominant herbivore 

is the most obvious contribution ranches make to the prairie ecosystem, but there are many others.

MT-RM BLM emc0013RM

681. The Taylor Grazing Act protected the BLM lands from the plow, but it is the partnership with the BLM that protects private 

lands from the plow. Many pastures include private and BLM rangeland within the same fence.

MT-RM Both emc0013RM

682. The rancher's love of the land is the only thing protecting private land in northeast Montana from the development that has 

harmed sage grouse elsewhere.

MT-RM Both emc0013RM

683. The history of the Northern Plains Resource Council shows that some farmers and ranchers are even willing to protect 

their land from energy development. If the oil boom is the greatest threat to sage grouse, then anything that encourages 

ranches to sell out must also be acknowledged as a threat.

MT-RM Both emc0013RM

684. Although fire disturbance can have positive effects on some prairie species, it should be noted that big sage brush is 

incredibly slow to recover from fire, which means a wildfire can eliminate sage grouse habitat and forage for decades. 

Ranchers and ranching communities provide a look-out and first-response system that absentee owners do not. The BLM 

and the counties have historically done a very good job of partnering with the local ranches to keep summer wildfires

controlled. Furthermore, grazing is effective at fire prevention.

MT-RM Both emc0013RM

685. In a cottonwood grove survey of the upper Missouri River, Kudray et al. (2004) compared cattle-inaccessible river islands 

with accessible cottonwood groves on similar sites. They found no correlation between accessibility and any of their 

ecological measures. In other words, their analysis of the data supports the hypothesis that current grazing practices have no 

effect on riparian vegetation. 

The study devotes many paragraphs to the hypothesis that cattle are responsible for a decline of red-osier dogwood and 

MT-RM Both emc0013RM
C. Comments by Resource Planning Issue

C-944 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

chokecherry along the Missouri River. Because the study measured these species only once, it is not possible for it to reveal

whether these species are increasing or declining. Furthermore, the experiment that was performed indicated that cattle did 

no harm. Why did the authors devote paragraphs to this hypothesis but only one sentence to the actual results of their 

experiment? Because they were trained to believe that cattle harm riparian ecosystems.

A more careful analysis of the data might have noted that all the cattle-inaccessible river islands had 90% non-native herb 

cover, while some of the cattle-accessible sites were much better. But the idea that cattle could be benefiting native plants 

apparently did not occur to these researchers.

686. Several ranches in the Fort Peck Lake watershed participated in a riparian enhancement and repair project. We were given 

forms to monitor the health of the riparian area. These forms include an estimate of trailing and bare ground due to 

livestock.

On our ranch, these sites have scattered deer droppings, deer beds, and deer tracks. One site is visited by elk on their way 

to graze the neighbor's alfalfa field. How are we to tell what percentage of trailing is caused by cattle and what percentage is 

caused by wildlife? The answer to this evaluation question reveals only the biases of the researcher.

MT-RM Both emc0013RM

687. There is a sagegrouse dancing ground not quite a mile from the ranch house. Sage-grouse numbers cycle, but this ground has 

plenty of sagegrouse even in years when they are not so numerous. There are two factors that make this place preferred by 

sagegrouse compared to the surrounding countryside. In the 1920s, my great grandfather installed a stock dam here. To this 

day it still provides good livestock water, but it is also very popular with waterfowl and sagegrouse. Even in drought years,

when the grouse that have chosen other areas have to move or die of thirst, this reservoir offers a dependable drink, and 

they know it. Secondly, this dancing ground is quite near the livestock corrals. Short bursts of heavy use periodically through 

the year have managed to keep this area with the proper combination of bare ground and sagebrush that create the kind of 

dancing ground sagegrouse like. This spot is the nucleus of our sagegrouse populations. When times are good, rains are 

frequent and predators are few, they expand out from it, but when the wind turns dry and coyote and eagle numbers soar, 

then they survive here, waiting for good times to return.

MT-RM Both emc0023RM

688. There is no evidence that cattle have any impact on sagegrouse, either positive or negative. However, there is plenty of 

evidence that ranching has a strong positive impact on sagegrouse. Ranches need to be relatively large and usually in native 

vegetation. This protects against habitat fragmentation and the destruction of sagebrush for fields or lawns. Ranchers need 

vegetation and will control fires to some extent. Hot, late, uncontrolled fires will destroy large areas of big sagebrush, which 

takes over a century to recover from a burn of this kind. Ranches tend to have some degree of predator control, and 

predators are the largest negative impact on sagegrouse, following sagebrush destruction. Areas with healthy sagegrouse 

populations tend to have ranches, areas that have lost their ranches have also lost their sagegrouse. It is easy and popular to 

protect sagegrouse from cattle, but the cattle don't harm the sagegrouse. If you remove the cattle, you also remove the 

ranches, which are important to the sagegrouse. Sagegrouse can be protected into extinction just like rare orchids and 

desert pupfish.

MT-RM Both emc0023RM

689. About thirty years ago BLM sent a questionnaire to Southeastern Montana area lenders seeking comments on a possible MT-RM BLM emc0082RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-945

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

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Agency CmtLtrCode

increase in BLM grazing costs. I recommended a considerable increase but a cost still well below better private land leases 

due to range quality, water, and fencing. I later visited with several banks and Farm Credit Services and universally found that 

they shared the same belief, although they would never admit it to their rancher clients. Some years later I was asked 

whether a proposed increase in grazing costs would pose a serious hardship to any rancher clients. After reviewing various 

loan files, I determined that BLM grazing cost increases would represent a very minor portion of total operating costs and 

would not be significant in determining success or failure of any of those operations. In neither instance were grazing costs 

raised. When long overdue fee increases happen, a portion of the additional income should be tied to use for improvements 

in fencing and water, not to graze out the last untouched corners of pastures, but instead to be used strictly for wildlife 

habitat improvement on lands which are to repeat again, owned by the public.

690. Our members have proven that livestock grazing contributes positively to wildlife habitat and is especially compatible and 

beneficial to greater sage-grouse habitat conservation. Ranchers are the stewards of the greater sage-grouse habitat on both 

the private and public land, amounting to 27 million acres in Montana. Without ranchers, who provide an effective line of 

defense against fire and noxious weeds, who manage forage for optimum production, and who are the primary protectors 

of open space in the private lands of the west, large areas of greater sage-grouse habitat would be in jeopardy. The benefits 

provided by ranching relate directly to several identified threats to greater sage-grouse habitat, including wildfire, invasive 

plants, and urbanization and development. The ranching community is also the most cost effective means to provide these 

benefits.

MT-RM Both emc0157RM

691. In Montana, it is important to point out that the sage grouse population is thriving. Because of the stable population, our 

members do not support reductions of livestock on federal lands as a means to conserve sage grouse. Livestock grazing is 

proven to be a benefit to sage grouse, as stated in the Montana Sage Grouse Management Plan. Our organizations support 

more proactive measures to conserve sage grouse, such as support for local working groups and the NRCS Sage Grouse 

Initiative. These types of efforts will have a much more favorable collaboration of community members working toward 

maintaining and improving communities and wildlife habitat. These types of efforts should be used as a model in other 

programs or as a pilot program in the development of the upcoming Farm Bill. Simply reducing livestock grazing on federal 

lands will not benefit the ranching stewards of the land or the sage grouse. The unintended consequences of decisions that 

negatively impact our rancher members will also impact the greater sage-grouse, by encouraging the conversion of private 

rangelands into farmland, urban development, or other uses not conducive to greater sage-grouse habitat.

MT-RM Both emc0157RM

692. Livestock grazing is compatible and beneficial to greater sage-grouse habitat conservation. This has been proven by 

independent, peer-reviewed scientific analysis, much of which was conducted in our own state. Ranchers are the stewards 

of the greater sage-grouse habitat on both the private and public range lands. Allowing ranchers the continued use of public 

lands without unnecessary restrictions due to the potential listing of a species with such a large habitat encourages 

stewardship and prevents fragmentation through development. It is imperative that a stable economic environment be 

sustained and enhanced so that our members may assist in the conservation of rangeland for the greater sage-grouse.

MT-RM Both emc0157RM

693. In Montana, it is important to point out that the sage grouse population is thriving. Because of the stable population, our 

county does not support reductions of livestock on federal lands as a means to conserve sage grouse. Livestock grazing is 

proven to be a benefit to sage grouse, as stated in the Montana Sage Management Plan. Our county supports more proactive 

MT-RM Both rmc0023RM
C. Comments by Resource Planning Issue

C-946 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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No.

Comment SubRegion

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Agency CmtLtrCode

measures to conserve sage grouse, such as support for local working groups and the NRCS Sage Grouse Initiative. These 

types of efforts will have a much more favorable colaboration of community members working toward improving 

communities and wildlife habitat.

694. In conclusion, Judith Basin County believes ranching and farming are the most efficient and cost effective means to sustain 

wildlife populations, while also producing food and fiber for our nation. It is important that conservation activities work 

hand-in hand with agriculture, because negative impacts on ranching will have negative impacts on sage grouse. Our county 

recommends that your agency continues to enact or develop strategies that will benefit both agriculture and the sage grouse 

population.

MT-RM Both rmc0023RM

695. The Little Missouri Grazing Association (LMGA) has taken a pro active approach towards the sage-grouse. We have two 

years of habitat monitoring data collected. We also have data showing historical grazing use showing that the stocking rates 

have not changed in many years. The land use practices have not changed. We have no oil & gas impact and no industrial 

encroachment.

ND Both emc0039RM

696. Let the ranchers graze there herds on there allotments, keep hunters off the land. We have million acres of land in Nevada

that is not owed by the public. Let them hunt there.

NVCA Both emc0012GB

697. The County supports a "No Net Loss of Grazing AUMs" policy. That being said, we request more detailed information in 

terms of potential impacts to grazing operations and allotments within the County. We encourage working collaboratively 

with grazing permittees to examine methods of grazing which benefit and enhance Sage-grouse habitat. We are adamantly 

opposed to regulations that encourage closure and economically infeasible restrictions on existing operators. Closure or 

retirements of allotments removes a key management option for proper rangeland and habitat management, and will have a 

profound economic impact to this County.

NVCA Both emc0130GB

698. If we get the livestock industry back on the range like they were in the 50’s 60’s and 70’s we will not only have fewer wildfires 

but a larger big game population as well.

NVCA Both emc0187GB

699. I am extremely concerned about the impact the above referenced Notice of Intent will have on the range livestock industry 

in Nevada. Economically viable ranching operations provide both stewardship of public lands and economic stimulus and 

viability to local and regional communities.

NVCA Both emc0202GB

700. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations and local rural economies.

NVCA Both emc0202GB

701. The last thing the State of Nevada and our local BlM district offices need is a "directive" from Washington, DC. We need to 

promote grazing as one of the longest standing tools in keeping wild land fires in check and in generating and maintaining 

viable sage-grouse habitat.

NVCA Both emc0213GB

702. I am extremely concerned about the impact that the above referenced notice of intent will have on the range livestock 

industry in Nevada. Economically viable ranching operations provide both stewardship of public lands and economic stimulus 

and viability to local and regional communities.

NVCA Both emc0215GB

703. Buckhorn Land and Livestock, LLC owns the Winnemucca Ranch and has a Grazing allotment located in the Virginia Range 

in Nevada. We have owned the ranch and operated the Winnemucca Ranch allotment since 2005. When we purchased the 

NVCA Both emc0232GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-947

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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No.

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ranch in 2005 we noticed a declined population of the sage-grouse within our allotment. However, since 2005 we have 

noticed increased number of sage-grouse on the range over the seven year period we have owned the ranch while at the 

same time ran cattle on this same allotment, Thru our grazing practices we don't allow our cattle to camp on riparian areas 

as we believe in keeping our herds moving thru the range.

704. We have noted that livestock grazing was identified as a moderate risk to sage-grouse in the Virginia range conservation plan 

yet the best available science as reported by Pete Coates does not support this risk assessment

NVCA Both emc0232GB

705. The Nevada Wilderness Project respectfully requests that you address the impacts to sage­grouse and sage‐grouse habitat 

caused by feral horses, including removal of vegetational cover necessary for nesting and brood-rearing, changes to 

vegetational composition that results from feral horse use, horse impacts to springs and other important free water sources 

utilized by sage-grouse, possible disturbance caused by feral horses during the nesting period, infrastructure used to mitigate 

horse impacts (e.g., fences) and how it may negatively affect sage-grouse, any connection to West Nile Virus as that disease 

is recognized as affecting both horses and sage-grouse, and the potential for feral horse management actions to negatively 

affect sage-grouse and sage-grouse habitat.

NVCA Both emc0243GB

706. Interestingly, Barrick's ranches may provide unique opportunities for mitigation of impacts from its mining operations. As 

operating ranches, these off-site restoration opportunities, including restoration of habitat on fee land, would likely be 

unavailable without their connection to the mining operations. Creating new riparian vegetation or wetlands to mitigate for 

potentially impacted wetlands, improving degraded habitats to replace impacted areas, and developing water sources when 

access to water is prevented due to safety fencing are just a few examples of off-site mitigation that potentially could be 

available on Barrick's ranch lands.

NVCA Both emc0277GB

707. Range management: Poorly managed grazing by domestic livestock, wild horses and burros (rarely wildlife), range 

improvements and vegetation forage projects have contributed to the loss, degradation, and fragmentation of Sage Grouse 

habitats, according to the USFWS listing decision. The agencies' current regulatory authorities in the grazing programs have 

not prevented this damage. Some agency managers and others believe that grazing, properly managed, can be a tool for 

improving Sage Grouse habitats, but there is little recent scientific research supporting these beliefs or agreement on what 

"proper grazing management" is or can be. It is very important for the EIS to include conservation measures which both 

improve grazing management to benefit, not continue to harm, Sage Grouse and priority habitats, but also to add regulatory 

authority for agencies to encourage grazing which results in healthy rangelands and healthy Sage Grouse populations and 

habitats, but also to curtail grazing practices which are not meeting standards and guidelines for healthy rangelands, including 

meeting Sage Grouse habitat requirements. At a minimum, we suggest the following measures be included in the EIS.

a. the agencies should continue existing range management where Sage Grouse priority habitats are in excellent condition 

(meeting vegetation and structural requirements for Sage Grouse).

b. the agencies should develop and implement financial and other incentives for grazing which meets or exceeds standards 

and guidelines for healthy rangelands, including Sage Grouse habitat requirements.

c. the agencies must examine standards and guidelines for rangeland health for their adequacy in protecting Sage Grouse and 

priority habitats and change, if necessary, including providing sufficient vegetative cover for nesting and riparian and wet 

NVCA Both emc0283GB
C. Comments by Resource Planning Issue

C-948 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

meadow habitat for brood-rearing, and seasonal requirements, with priority given to allotments with a greater percent of 

acreage in priority habitats.

d. the agencies must change AMPs and permit terms and conditions in all allotments not meeting standards and guidelines, 

including those where "progress" is unsatisfactory, adding specific vegetation objectives and restrictions on livestock and 

wild horses and burros numbers, timing and seasons of use, rest rotation, and other necessary provisions.

e. the agencies should include require habitat protection measures for Sage Grouse habitats in drought restrictions on 

grazing uses.

f. the agencies should approve not proposed water developments unless benefits to Sage-Grouse (increased availability of 

water) outweigh costs ( including damages to natural springs, seeps and wet meadows from structures and dewatering and 

concentration of livestock and wild horses and burros as well as the increased potential for water developments to support 

mosquitoes which spread West Nile virus.

g. the agencies should evaluate and modify water developments in priority habitats in order to meet Sage Grouse habitat 

requirements.

h. the agencies should prohibit vegetation treatments in priority habitats which don't benefit Sage-Grouse.

i. the agencies should modify crested wheat grass seedings if necessary for restoration of Sage-Grouse habitat.

j. the agencies should design range improvements to conserve, enhance, and restore Sage-Grouse habitat.

k. the agencies should evaluate existing range improvements and modify to meet specific Sage-Grouse habitat requirements, 

including removal or modification of fences close to leks and treatment of invasive weeds associated with fences and other 

structures.

l. the agencies should prohibit livestock grazing of burned areas until vegetation recovery objectives have been met.

m. the agencies should identify allotments where permanent retirement of grazing is more beneficial than costly to Sage 

Grouse, including the risk of making unused stock water and ranching water rights available for interbasin transfers.

708. Grasses Dominate the Revegetated Area and are used Extensively for Grazing: Due to the predominance of grass species in 

the BLM-approved reclamation seed mix used to revegetate the mine site, grass is the dominant plant species growing on the 

reclaimed areas. These areas are highly utilized for grazing by cattle, horses and antelope. In addition, the private sections 

cover water sources and pasture lands heavily impacted by these larger animals. Large areas of cheat grass are locally 

present, as well.

NVCA Both emc0287GB

709. In the NTT document, livestock grazing is considered to be a diffuse disturbance (pressure is exerted over broad spatial or 

temporal scales). Livestock grazing, as well as wild horse and burro activity can greatly affect nest success on any 

ground-nesting bird as well as decimate any viable vegetation in the grazing area. Wild horse numbers have increased 

exponentially in the Rochester area and no gatherings have occurred to decrease population size. Since wild horses have 

different grazing patterns then cattle the magnitude of grazing increases across the entire landscape in the Rochester area. 

Damage to vegetation communities (i.e. reduction of grass, shrub, and forb cover and increases in unpalatable forbs and 

exotic plants as well as complete decimation of any vegetation community) is highly visible in the Limerick and Rochester 

canyon areas. If any mitigation efforts were made in or adjacent to Rochester mine's project area wild horses and cattle 

would have to be fenced out for any type of habitat restoration or sage grouse re-introduction to have a chance.

NVCA Both emc0302GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-949

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

710. In the NTT document, livestock grazing is considered to be a diffuse disturbance (pressure is exerted over broad spatial or 

temporal scales). Livestock grazing, as well as wild horse and burro activity can greatly affect nest success on any 

ground-nesting bird as well as decimate any viable vegetation in the grazing area. Wild horse numbers have increased 

exponentially in the Rochester area and no gatherings have occurred to decrease population size. Since wild horses have 

different grazing patterns then cattle the magnitude of grazing increases across the entire landscape in the Rochester area. 

Damage to vegetation communities (i.e. reduction of grass, shrub, and forb cover and increases in unpalatable forbs and 

exotic plants as well as complete decimation of any vegetation community) is highly visible in the Limerick and Rochester 

canyon areas. If any mitigation efforts were made in or adjacent to Rochester mine's project area wild horses and cattle 

would have to be fenced out for any type of habitat restoration or sage grouse re-introduction to have a chance.

NVCA Both emc0302GB

711. Economically viable ranching operations provide both stewardship of public lands and economic stimulus and viability to 

local and regional communities. The conservation of rangelands for livestock production is extremely important, not onlj' to 

the sustainable production offood and fiber for the United States and worldwide market.

NVCA Both emc0304GB

712. But also to providing quality habitat to support wildlife populations. Scientific research indicates that properly managed 

grazing is beneficial to the greater sage-grouse and to a host of other wildlife.

NVCA Both emc0304GB

713. Grazing can improve sage-grouse habitat by increasing the quality and accessibility of forbs and other beneficial vegetation 

and also aids in the control of invasive plant species.

NVCA Both emc0304GB

714. NEPA analysis should start from the premise that properly managed grazing can be a benefit to sage-grouse and properly 

managed grazing should be incorporated into the sage-grouse management strategy.

NVCA Both emc0304GB

715. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations.

NVCA Both emc0304GB

716. Historical evidence indicates a positive correlation between livestock numbers and sage grouse populations. NVCA Both emc0304GB

717. There are some specific concerns that the Association has regarding the main threats to the greater sage-grouse. According 

to the US Fish and Wildlife Service (USFWS), the five greatest threats to greater sage-grouse in the West are invasive 

species, infrastructure, wildfire, agriculture and grazing respectively. The Association understands that these threats are 

analyzed to assess the impacts to the general rangeland health needed to sustain a healthy, thriving population of greater 

sage-grouse and their habitat. Because ranchers serve as stewards of the range and especially in Nevada, we feel it is 

important to observe the benefits of livestock grazing in relation to habitat health and stable populations of greater 

sage-grouse.

According to Natural Resources Conservation Service (NRCS), grazing "has been responsible for retaining expansive tracts 

of sagebrush-dominated rangeland from conversion to cropland" and can "stimulate growth of grasses and forbs, and thus 

livestock can be used to manipulate the plant community toward a desired condition." Grazing on public and private 

rangelands in Nevada has occurred for about 150 years and as such, has co-existed with sage-grouse populations. As 

recognized by the NRCS, grazing has and can be very beneficial to the health of the range, specifically sagebrush 

NVCA Both emc0328GB
C. Comments by Resource Planning Issue

C-950 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

communities. The Association believes that livestock grazing can be used as a beneficial mitigation measure to enhance 

habitat conservation and sustain viable greater sage-grouse populations and encourages the BLM to consider mitigation 

measures that use livestock grazing.

718. Managed livestock grazing to maintain residual cover of herbaceous vegetation so as to reduce predation during nesting may 

be the most beneficial for sage grouse populations (Beck and Mitchell 2000, Aldridge and Brigham 2003.) This does not 

clearly state what residual cover of herbaceous vegetation is. Furthermore, residual cover will vary across landscapes and 

the sagebrush ecosystem and should be approached as such.

NVCA Both emc0328GB

719. If an effective grazing system that meets sage‐grouse habitat requirements is not already in place, analyze at least one 

alternative that conserves, restores or enhances sage‐grouse habitat in the NEPA document prepared for the permit 

renewal (Doherty et al. 2011b, Williams et al. 2011). Coordination of the specialists within the agencies should already 

ensure that an effective grazing system is in place that supports the resources per the NEPA process. Further clarification

is not needed if regulations within the agencies are followed.

NVCA Both emc0328GB

720. Maintain retirement of grazing privileges as an option in priority sage‐grouse areas when base property is transferred or the 

current permittee is willing to retire grazing on all or part of an allotment. Analyze the adverse impacts of no livestock use 

on wildfire and invasive species threats (Crawford et al. 2004) in evaluating retirement proposals.

- Planning direction Note: Each planning effort will identify the specific allotment(s) where permanent retirement of grazing 

privileges is potentially beneficial. Retirement of grazing privileges should not be an option. This is an existing right and, per 

76 FR 77008-77011, "the RMP and LMP amendments/revisions will recognize valid existing rights." Furthermore, as the 

Association has already stated, cattle grazing management techniques can be used to address wildfire and invasive species 

threats.

NVCA Both emc0328GB

721. I am writing this letter in protest to any removal of livestock from the range here in Lincoln County Nevada. NVCA Both emc0389GB

722. My feeling towards the sage grouse populations in Lincoln Co. are different from other county's populations, biologist in our 

area have always maintained that the area is a fringe of sage grouse habitat and that livestock grazing is beneficial to the sage 

grouse habitat.

NVCA Both emc0389GB

723. We are extremely concerned about the impact the above referenced Notice of Intent will have on the range livestock 

industry in Nevada.

NVCA Both emc0390GB

724. The Forest Service has three categories of grazing allotments. Open, Closed, Vacant. The HT Scoping Notice for the next 

Rangeland EIS in line, Austin-Tonopah, proposes to fling Open several Vacant allotments in Monitor-Toiyabe lands where 

sage-grouse on the southern margin of the species range are present on leks in reasonable numbers. Grazing disturbance has 

serendipitously been absent for around a decade or longer in some areas. The reason is that grazing permits were canceled 

due to Sagebrush Rebel livestock trespass and other transgressions, and also large areas of rugged terrain. So here we have 

an anomaly a fairly stable sage-grouse population with reasonable numbers of birds on leks at the southern margin of the 

species’ range that is persisting– rather than dwindling out. It is critical that agencies examine the lessened grazing pressure 

here, as well as in Hart Mountain and Sheldon where there is no domestic livestock grazing. It highlights the adverse impacts 

NVCA F emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-951

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

of grazing disturbance in arid sagebrush habitats. This Monitor-Toiyabe landscape has also suffered relatively little sagebrush 

and tree killing treatment disturbance. This area is one of the ACECs that WWP is proposing in this EIS Process.

725. BLM must amend all Land Use Plans including those underway. Plans currently in process have very weak goals, objectives, 

and uncertain non-mandatory language. Plus they greatly avoid addressing livestock disturbance, removing grazing from lands 

where there is risk of weed invasion or sagegrouse loss, and otherwise are inadequate. Example: Winnemucca DRMP/DEIS, 

and the potentially aborted Bruneau RMP.

NVCA BLM emc0411GB

726. WWP requests that the Forest Service incorporate into this Sage-grouse EIS process the Humboldt- Toiyabe Rangeland 

EIS’s, the Biological Assessments that rubberstamped the near-status quo grazing actions and continued stocking levels and 

harmful facilities and use periods - and the full administrative record. They serve to illustrate the depths to which agencies 

stoop to paper over grazing disturbance impacts. We incorporate these documents and the accompanying administrative 

records by reference into these comments to illustrate the degree of significant changes that must be made across Forest 

Regions where Plans are being amended. Analysis of the full spectrum of harms from livestock grazing, not general 

discussions of “herbivory” must drive this process. In all of these processes, there was no effort made to address stocking 

rates, and AUMs/HMs were carried forward at levels that greatly exceeded actual use. Any reductions in livestock were to 

be left to following years, out of the public eye in closed door meetings with ranchers

NVCA USFS emc0411GB

727. We request that as part of this current sage-grouse process, decision makers review the HT Forest EISs, the agency e-mails 

shoving aside concerns for sage-grouse, the woefully inadequate and biased Forest BAs tailored only to support whatever 

grazing outcome the range staff described – which was keeping as many AUMs on the books as possible – no matter how 

many new fences, sagebrush destruction projects, and the additional ever-expanding harmful de-watering spring 

developments and pipelines and trough systems that might require as a laundry list of disjointed BMPs and “tools” was to be 

applied in the future. Plus these documents never analyzed alternatives that seriously looked at conserving habitats, 

removing livestock developments, and de-stocking or greatly reducing stocking while applying much more conservative 

standards of use in any areas where livestock grazing might continue. Analysis of the No Grazing alternative was minimal, and

biased. The Forest refused to conduct an honest Capability and Suitability analysis – to determine if Forest lands were 

Capable of supporting livestock use, and then if those lands, even if found Capable (factoring in forage production, slope, 

distance from water, topographic factors, fragile/erodible soils, forested vegetation, and a combination of all of these), were 

really suitable for continued grazing. Then, on lands that might meet these capability criteria, the suitability of continued

grazing use was to have been determined while fully considering all other watershed, wildlife, wilderness, roadless area, 

recreational values. Given the values of these attributes to the public and the conflicts of livestock with all of these – are 

Forest lands, watersheds and wildlife really suitable for continued grazing use? The Forest merely defaulted to its 1986 

finding, where less than 1% of the half million acres project area had been found not to be suitable for grazing use.

NVCA USFS emc0411GB

728. The Forest has failed to conduct current honest capability and suitability analyses. Instead, as in the Ely Westside EIS, claimed 

that areas of steep, rugged, limestone outcropping topography in the pinyon-juniper zone were “capable” of supporting 

livestock – in defiance of reality. Such claims, never really explained, could only be based on the hopes of deforesting the 

lands someday. But even if the lands were deforested and desertified and made vulnerable to weed infestation – the 

combination of slope, rocks/cliffs and other topographic features would make it impossible to graze livestock. This also 

NVCA Both emc0411GB
C. Comments by Resource Planning Issue

C-952 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

highlights the lack of benefit of many proposed and completed deforestation projects that the agencies are claiming would 

somehow benefit sage-grouse. Sage-grouse don’t use steep, rugged slopes – no matter how many trees the forest burns or 

masticates. The Forest, in all of these EIS processes, instead of conducting a valid current analysis, simply claimed that the old 

Forest Plan from 1986 adequately dealt with Suitability. So of the over half a million acres of the Ely Westside lands, all but 

three thousand or so acres (tiny campgrounds and RNAs) were all found to be suitable for continued livestock grazing 

disturbance. The half million acre affected lands include the habitat of the vanishing Quinn PMU as well as the White Pine 

PMU where some leks still persist, including in portions of the even the 2010 Doherty Core-mapped areas. Thus, even 

where grouse are in serious trouble (Quinn) or a population still has some birds but is declining like White Pine and 

threatened by expanding mining, and new powerline development (SWIP), agencies refused to take needs of sage-grouse 

into account.

729. Page 2 lists Threats. This list includes reductions in habitat quantity and/or quality and other degradation but the word 

livestock or grazing as a causal factor is not even mentioned. Nor is livestock disturbance of lek and nesting and wintering 

habitats. Nor the adverse impacts of livestock in lowering nest success, and increasing predators particularly mesopredators. 

Nor are fences as causes of mortality yet collisions with powerlines and vehicles is listed. West Nile virus and livestock 

water developments such as stock ponds, troughs, pipelines, and highly degraded trampled stream margins are also ignored.

NVCA Both emc0411GB

730. We are also concerned about targeting pinyon-juniper without an understanding of historical deforestation, and the fact that 

in many areas, pinyon-juniper are in reality the climax vegetation on a site. It appears much easier for agencies to promote 

expensive tree killing projects, rather than address the extensive degradation caused by livestock grazing, roading, or other

disturbances throughout Nevada’s sagebrush habitats.

NVCA Both emc0411GB

731. How did NDOW and BLM determine that habitats of moderate importance were not at potential? We are very concerned 

that agencies are writing off habitats with significant livestock degradation without considering alternatives such as removal 

of livestock so that passive restoration can occur. R-1, R-2, R-3 habitats could be included here. How was each decision 

made?

NVCA Both emc0411GB

732. We have observed that well-rnanaged livestock grazing is an effective and sustairrable method for combating several of the 

most significant threats to sage grouse habitat including fuels reduction to mirrimize wild fires and to prevent or rlow 

invasive species and conifer proliferation. While the ESA does not provide for the cost of a mitigation strategy to preclude 

its implementation, funding to implement strategie,s is none the less rraturally limited. Our continued ability to serve a broad 

spectrum of multiple-use industries is crucial to maintaining their ability to provide beneficial habitat managerflent and their 

financial viability to implement appropriate mitigation ffieasure5. Mininrizing wild fires also protects our infrastructure from 

damage and reduces our need to mobilize drews and equipment to rehuild power lines irt areas which may be

sage grouse habitat.

NVCA Both fxc0006GB

733. Grazing is alleged to be a detractor for sage grouse habitat. We have found that proper grazing management can improve 

habitat for all wildlife, including sage grouse. Proper livestock grazing allows residual growth to be managed at sustainable

levels based on annual precipitation, site potential, and species composition

NVCA Both fxc0010GB

734. Although livestock can be found on a majority of public lands, grazing shouldn't be prohibitive to sage grouse health. The 

people that see sage grouse on a day~to-day basis are our western ranchers. No one else spends the amount of time as 

NVCA Both fxc0010GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-953

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

ranchers out on public lands- It is ridiculous to assume that grazing is more harmful to sage grouse because It occurs on 

more acres than energy or mineral development. Sage grouse and cattle can co-exist. Sage grouse cannot, however, live on 

a gravel road or well pad.

735. Grazing is alleged to be a detractor for sage grouse habitat. We have found that proper grazing management can improve 

habitat for all wildlife, including sage grouse. Proper livestock grazing allows residual growth to be managed at sustainable 

levels based on annual precipitation, site potential, and species composition.

NVCA Both fxc0010GB

736. Although livestock can be found on a majority of public lands, grazing shouldn't be prohibitive to sage grouse health. The 

people that see sage grouse on a day~to-day basis are our western ranchers. No one else spends the amount of time as 

ranchers out on public lands- It is ridiculous to assume that grazing is more harmful to sage grouse because It occurs on 

more acres than energy or mineral development. Sage grouse and cattle can co-exist. Sage grouse cannot, however, live on 

a gravel road or well pad.

NVCA Both fxc0010gb

737. Is livestock grazing one of the causes for the decline of sage grouse? Or is the large decrease in livestock numbers since the 

1980's to 2011 one of the causes tor the decline in sage grouse?

NVCA Both fxc0014GB

738. The BLM's, IM goes into extensive detail on how livestock grazing has to he changed in order to help the Sage Grouse. No 

studies were presented to show how this is going to help the Sage Grouse and how many birds it will produce or even hope 

to produce. Nevada is different then most states in that the BLM and the Forest Service manage land use plans for over 85% 

of the land. In 74 years, the BLM has not been able to maintain a steady population of Sage Grouse. Granted their main focus 

has not been the Sage Grouse, but why does the BLM and the USFS think that doing more of the same thing like manipulating 

the current Land Use Plans is going to produce a different result? We have read a lot of assumptions and theories, but no 

hard facts. From 1982 through 2011, Nevada had a reduction of 230,000 head of cattle as well as a reduction of 59,000 head 

of sheep. In this same time period there has been an increase in regulation for livestock grazing on public lands i.e. "timing, 

location and intensity" (as stated in the National Greater Sage-Grouse Conservation Measures report). Shawn Espinoza of 

NDOW showed sage grouse numbers from 1975-2011. There has been a cycle of ups and downs, but there is no evidence 

that the regulations imposed by the BLM or USFS had any effect on these cycles. It is wrong to focus on only one factor 

especially if it is only because, "enhance management of livestock grazing may be the most cost-effective opportunity in many 

instances to improve Greater Sage-Grouse habitat on public lands." (BLM Instruction Memorandum 12-27-2011) Again, if 

heavily regulated livestock management is supposed to benefit the Greater Sage-Grouse, then why haven't the last 30 years 

plus of heavily regulated livestock management from the BLM and USFS steadily increased sage hen numbers?

NVCA Both fxc0014GB

739. Since the tum of the century the area has been grazed by cattle and wild horses and burros. The wild horse and burro 

population got out of control in the 80's and 90's but by that time most of the sage hen were gone.

NVCA Both rmc0044GB

740. Infrastructure is listed as the second largest threat. What is included in infrastructure? Is this just pasture fences and water 

development? We need clarification.

NVCA Both rmc0064GB

741. The table lists grazing as the 5th largest threat to Sage Grouse. Does this include moderate rest rotation grazing? If so, we

wonder how this could be? In fact we feel like moderate grazing could be a huge benefit to the Sage Grouse and their habitat 

for the following reasons. - Moderate grazing of pastures results in decreased fine fuel available as an ignition source for 

wildfire. - Moderate grazing by livestock on pastures in early spring or summer can provide a break in fuel load that will 

NVCA Both rmc0064GB
C. Comments by Resource Planning Issue

C-954 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

sometimes stop a wildfire or effectively slow it down so fire crews can contain it. Scott Sayer, BLM Range Specialist from the 

Burley District, has pictures taken recently on the Burley District that supports this concept. - Moderately grazed ranges 

that are burned over by wildfire recover from the burn sooner and easier, than non-grazed ranges, due to cooler burn 

temperatures. The crowns of perennial grass plants sustain less damage from the cooler fire. - Up until 1958, BLM 

documents show permitted cattle on Jim Sage being twice as many as they are now, plus a band of sheep. Most local 

residents agree there were several times more Sage Grouse than there are now. Two senior livestock operators of the 

1960's era, Bob Ward and Dale Pierce, remember seeing large wintering flocks of Sage Grouse near Lower Kane Springs 

Canyon. "When they flew up they were too numerous to count." How could all of these birds have thrived on Jim Sage when 

permitted grazing was double what it is now? It is the resolute conclusion of the Jim Sage Grazing Association permittees, 

that grazing by livestock could very well be a benefit rather than a threat to the Sage Grouse and their habitat due to reasons 

expressed above. We would like to draw your attention to a Declaration by Karen Launchbaugh. It was recently submitted 

on behalf of the State of Idaho, in response to the remedies sought by Plaintiff Western Watersheds Project in connection 

with the Craters of the Moon National Monument Resource Management Plan and associated environmental impact 

statements. Ms. Launchbaugh is a professor of Rangeland Ecology, and the Director of the Rangeland Center for the 

University of Idaho. Her Declaration supports our list of reasons why livestock grazing benefits Sage Grouse and their 

habitat.

742. I am extremely concerned about the impact the above referenced Notice of Intent will have on the range livestock industry 

in Nevada. Economically viable ranching operations provide both stewardship of public lands and economic stimulus and 

viability to local and regional communities. The conservation of rangelands for livestock production is extremely important,

not only to the sustainable production of food and fiber for the United States and worldwide markets, but also to providing 

quality habitat to support wildlife populations. Scientific research indicates that properly managed grazing is beneficial to the 

greater sage-grouse and to a host of other wildlife. Grazing can improve sage-grouse habitat by increasing the quality and

accessibility of forbs and other beneficial vegetation and also aids in the control of invasive plant specles.

NVCA Both rmc0065GB

743. With regards to livestock grazing, I have often observed sage-grouse in our mountain meadows which have been recently 

grazed by cattle. As noted by the biologist referred to above, there seems to be a positive relationship between cattle grazing 

and sage-grouse. Assemblyman Hansen's article also refers to scientific studies which verify this positive relationship. (The

Relationship of Cattle Grazing to Sage Grouse by Carol Evans).

NVCA Both rmc0065GB

744. In summation, I strongly urge the agencies to recognize the benefits of livestock grazing to sagegrouse and to prioritize their 

focus on those issues that pose a real and specific threat to the Greater Sage Grouse and it's habitat. NEP A analysis should 

start from the premise that properly managed grazing can be a benefit to sage-grouse and properly managed grazing should 

be incorporated into the sage-grouse management strategy. I would also encourage the agencies involved to work together 

to arrive at a strategy for the entire ecosystem which includes both private and government lands. As a private landowner, 

I am prepared to work with the various agencies to enhance and improve the habitat for sage-grouse.

NVCA Both rmc0065GB

745. SNWA respectfully requests that the EIS consider and discuss the following:

the relationship between grazing operations and priority habitat, including effects of implementation of additional or revised 

greater sage-grouse conservation measures on operations of existing grazing allotments and under what circumstances 

NVCA Both rmc0069GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-955

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

grazing permits can or cannot be renewed

746. The BLM/USFS are also reminded that the Oregon Cattlemen’s Association (OCA) is working with Oregon BLM to develop 

a statewide Programmatic CCA for public lands beneficial to the sage‐grouse. The cumulative benefit of these 

aforementioned local and statewide initiatives should substantially serve to lessen, if not eliminate, the need to ESA list the 

Greater Sage‐Grouse within the State of Oregon.

OR Both emc0129GB

747. The economic and social values of the local agri culture and ranching community in Malheur County are important 

considerations that must be studied and taken into account for the sage grouse EIS. Habitat protection areas for this species

of bird should be carefull y studied to retain compatibility wilh the private landowner’s business activities to avoid confli cts. 

Livestock and agriculture production are primary economic concerns in Malheur County and land management

opportunities on federal and state lands must remain flexible (meet the needs of the community as well as sage grouse).

OR Both emc0136GB

748. The cries about habitat loss are the most overrated and overused excuse for changes in land management since "crying 

wolf." Until such time disease and predation are addressed, no amount of habitat preservation or restoration will work.

A perfect example of this is the Beaty Butte unit in the BLM's Oregon lakeview district. The unit does not have "threats" of 

habitat loss and fragmentation due to energy development and agricultural activities or livestock grazing. Livestock grazing is 

ten percent of what it was in the 1950s and 60s when sage grouse populations were high. Sage grouse populations began to

decline as grazing and trapping were reduced. The loss of the Dept. of Agriculture predator control program had a major 

negative impact. The correlation of reduced grazing and predator control and a decline in sage grouse populations cannot be 

overlooked.

OR Both emc0139GB

749. We are appalled at the generally poor condition of the public lands in Central Oregon. It would appear that the public lands 

have been overgrazed for so many years that there aren't many grasses or shrubs left to provide food and shelter for the 

grouse, antelope, or other native species. Wherever we hike, cheat grass is outcompeting the native grasses. Why? Because 

cheat grass sprouts early in the spring, and goes to seed by May or June. Guess when the cattle are set lose on the land? Not 

when the cheat grass is growing strong, but later in the year when the native bunch grasses are trying to put up seeds. The 

"management" practices of the high desert BLM land have been encouraging cheat grass and juniper growth, and therefore 

have upset the balance of all the native plants. The current practices continue to worsen the available fodder for the livestock 

set out to graze them. These practices have got to stop. You need to manage the BLM lands in a manner that can continue 

to sustain both the native plants and animals, which will also improve the grazing for livestock. You cannot continue to allow 

the cattle and sheep to graze the same sparse terrain every year. Give it a rest. Let the bunch grasses and native flowers go 

to seed for a couple of years before allowing the livestock back. Or change the time of year you allow grazing to March -

April because there is plenty of cheat grass to eat. And they will eat it when it's green.

OR Both emc0152GB

750. The report's author, ODFW sage-grouse lead Christian Hagen (also a member of the Sage-Grouse National Technical 

Team) made explicit in the Plan's executive summary that well-managed grazing is compatible with sage-grouse 

conservation, stating:

OR Both emc0221GB

751. Any EIS or SEIS developed must also recognize the benefits of active farming and ranching operations to Sage-Grouse 

habitat/fIn fact, extensive research has already been conducted by NRCS on the complimentary relationship between. 

OR Both emc0221GB
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Sage-grouse conservation and grazing. According to NRCS, "the same factors that negatively affect sage-grouse also 

negatively affect the health, productivity, and sustainability of native grazing lands. Therefore, improvements to benefit

sage-grouse also benefit grazing lands and the ranchers that depend on them."

752. Conservation measures and practices recommended as an outcome of the BLM and USFS National Sage‐Grouse Planning 

Strategy initiative are anticipated to be of interest and informative to the benefit of this Steering Committee as it develops 

a Programmatic CCAA, and the Steering Committee requests and seeks cooperative efforts and the sharing of this 

information in collaboration with our Oregon BLM Districts and USFS offices.

OR Both emc029GB

753. Finally, OSGA encourages the agency to take into account the research by NRCS showing a complimentary relationship 

between sage-grouse conservation and grazing. The scientific research conducted by NRCS clearly shows that grazing can 

actually improve sage-grouse habitat. It is important for this research to be taken into consideration as the agency proceeds 

in developing an EIS and SEIS.

OR Both emc0309GB

754. In summary, the best available scientific evidence shows that public grazing is important for sage-grouse conservation. In 

addition, public grazing maintains the economic sustainability of livestock producers and provides substantial economic 

benefits to the communities in which they live and the economy of Oregon as a whole. In turn, by maintaining the economic 

sustainability of livestock producers, public grazing protects sage-grouse habitat by reducing the need for ranchers to sell or 

develop their private property in a manner that is detrimental to sage-grouse habitat.

OR Both emc0309GB

755. In the state of Oregon, a thorough strategy for sage-grouse conservation based on best available science has already been 

developed. In April 2011, the Oregon Department of Fish and Wildlife (ODFW) revised the state's Greater Sage-Grouse 

Conservation Assessment and Strategy (henceforth the "Plan"). In this report, guidance specifically tailored to conserving the 

sage-grouse populations in Oregon was developed with a view to maximizing the success of conservation efforts. The 

report's author, ODFW sage-grouse lead Christian Hagen (also a member of the Sage Grouse National Technical Team) 

made explicit in the Plan's executive summary that well-managed grazing is compatible with sage-grouse conservation,

stating: This Plan recognizes that livestock ranching operations which manage for ecologically sustainable native rangelands 

is compatible with sage-grouse conservation, and necessary management activities to maintain a sustainable ranching 

operation are not considered "development actions" under the application of the Mitigation Policy to sage-grouse habitat.

-Greater Sage-Grouse Assessment and Strategy for Oregon: A Plan to Maintain and Enhance Populations and Habitat, p. viii, 

April, 2011.

OR Both emc0315GB

756. Economically viable ranching operations provide both stewardship of public lands and economic vitality to local and regional 

communities. The continuation of livestock production on Oregon's public lands is extremely important, not only for the 

sustainable production of food and fiber for the United States and worldwide markets, but also for the long-term success of 

sage-grouse conservation.

OR Both emc0315GB

757. It is important to take in account the many things already being done in Oregon regarding sage-grouse conservation. In 

April 2011, the Oregon Department of Fish and Wildlife (ODFW) revised the state’s Greater Sage-Grouse Conservation 

Assessment and Strategy. In this report, guidance specifically tailored to conserving the sage-grouse populations in Oregon 

was developed with a view to maximizing the success of conservation efforts. In that report it was stated that, “this plan 

recognizes that livestock ranching operations which manage for ecologically sustainable native rangelands is compatible with 

OR Both emc0341GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-957

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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sage-grouse conservation.” Given that the Oregon Plan has been very recently updated, amending land use plans in Oregon 

according to a different set of regulatory standards would not only represent a senseless waste of resources and local 

expertise, it would by necessity make sage-grouse conservation efforts in Oregon less appropriate and specific to 

sage-grouse populations and habitats in our state

758. The threats to sage-grouse habitat across the West are numerous.4 Here in Oregon, domestic livestock grazing has lead to 

the establishment and spread of weeds, erosion, denuded vegetation and associated lack of cover, pollution of water, and 

other impacts to sagebrush habitats. Projects that are necessary for continued domestic livestock grazing such as 

barbed-wire fencing provide predator perches and can pose a mortality threat for sage-grouse when flying grouse collide 

with the fencing, particularly around late brood rearing habitat such as springs, seeps and wet meadows.5 As well, the 

proliferation of non-native annual grasses such as cheatgrass and medusahead and other noxious weeds is spreading rapidly 

and replacing sagebrush. And, West Nile virus directly effects sage-grouse and causes mortality. This disease is spread 

through mosquito populations as they colonize wet areas on the landscape including livestock water developments.

OR Both emc0385GB

759. Address Impacts of Grazing: The BLM must recognize effects of grazing on sage-grouse, including removal of cover, 

vegetation composition change, behavioral changes, and impacts from grazing-related infrastructure. Reduction of grazing 

impacts will necessarily include management changes quantified by conservation metrics tracked through reliable, enforced 

reporting and analysis.

OR Both emc0385GB

760. Address Impacts of Fencing: Fences increase predator presence and cause direct sage-grouse mortality through collisions. 

BLM should remove unnecessary fences and limit new fencing in priority sage-grouse habitat, particularly in nesting and early 

brood-rearing habitat. BLM should also undertake mapping exercises to evaluate which existing fencelines might be 

appropriate for removal.

OR Both emc0385GB

761. Livestock Grazing is today by far the largest area land use throughout eastern Oregon. Grazing activity at almost any 

intensity can be shown to product Invasive Weed problems that require use of Vegetation Treatments detrimental to Sage 

Grouse productivity.

OR Both rmc0036GB

762. The ODFW EIS provides a blanket EXCLUSION to "...livestock grazing operations which manage for ecologically sustainable 

native rangelands is compatible with Sage Grouse conservation, and necessary management activities to maintain a 

sustainable ranching operation are not considered "development actions" under the application of the Mitigation Policy to 

Sage Grouse habitat."

How many currently existing livestock grazing operations qualify for this exemption in Oregon and the various FS and BLM 

districts?

What percentage of grazing lease holders will be exempt in eastern Oregon, and how many acres/amu's do they represent 

compared to non-exempt operations?

OR Both rmc0036GB

763. Range management is also a primary use to be considered in ongoing land use planning and sage-grouse management. This is 

an aspect of the cooperative effort with local ranchers, which we continue to integrate into our mine plans.

OR Both rmc0074GB

764. The south Warner region has been recognized as one of the most important "sage-grouse strongholds," throughout the 

Great Basin. The relative abundance of sage-grouse in this region underlines the fact that well-managed grazing is entirely 

compatible with sage-grouse conservation; many of our members have been successfully grazing cattle on permits with

OR Both rmc0078GB
C. Comments by Resource Planning Issue

C-958 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

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substantial sage-grouse populations for generations. A number of District members have also been working closely with the 

Natural Resource Conservation Service (NRCS) to reclaim important sage-grouse habitat on their private land by removing 

encroaching juniper. Our community is dedicated to the responsible stewardship and conservation of the greater 

sage-grouse; the enviable populations of sage-grouse in this region demonstrates that ranching has a vital role to play in that 

process.

765. It is also necessary that the preferred alternative explicitly recognize the key importance of public lands ranching operations 

to the success of sage-grouse conservation. Scientific research has repeatedly shown that properly managed grazing is 

beneficial to the greater sage-grouse and to a host of other wildlife species. Well-managed grazing can improve sage-grouse 

habitat by increasing the quality and accessibility offorbs and other beneficial vegetation and also aids in the control of 

invasive plant species. Moreover, public lands ranchers own a significant portion of high-quality lowland brood rearing 

habitat as deeded property. According to NRCS, "[a]pproximately 40 percent of sage-grouse habitat that supports 

populations occurs on privately owned lands." However, if regulatory measures on public lands make ranching operations

economically unsustainable, these operations are frequently subject to sale and development, leading to fragmentation and 

loss of key habitat. It is therefore essential that the preferred alternative incorporates explicit steps to ensure that 

sage-grouse conservation measures do not undermine the viability of public lands ranches.

OR Both rmc0078GB

766. Any EIS or SEIS must also explicitly recognize the following points: Properly managed grazing can enhance sage-grouse 

habitat and should be incorporated into the sage-grouse management strategy.

OR Both rmc0078GB

767. Any EIS or SEIS must also explicitly recognize the following points: Historical evidence indicates a positive correlation 

between livestock numbers and sage-grouse populations.

OR Both rmc0078GB

768. We agree that several reasonable alternatives should be analyzed in each NEPA document prepared dealing with grazing. 

We also agree that one of the considered alternative should include deferred or rest-rotation systems and feel that if 

allotment size is big enough this should be the preferred alternative. In rural Utah the effect of a no-grazing alternative would 

be devastating to the local customs/culture/economics.

UT Both emc0126GB

769. The IM Memo repeatedly points out the “State Wildlife Agency” as the important agency to talk to and get approval form. 

State Departments of Agriculture and the Sage Grouse working groups are the key participants with the tools to improve 

management on the ground. Vegetation treatments without improved management will be very short lived. Local Sage 

Grouse working groups should have a major voice in where and how money is spent with the advice of University Extension 

and local biologists. Emphasis should be placed on working with the Utah Grazing Improvement Program to improve long 

term Grazing management.

UT Both emc0126GB

770. When Sheep winter grazing declined in our area, this resulted in the sage brush being allowed to mature and we now have 

40‐50 year old brush. Not good for Sage Grouse. If grazing of livestock were to stop, the ground cover would become 

almost impossible for the young birds to get through and find the insects they need to survive

UT Both emc0137GB

771. The district believes future listing of this species would ultimately be a major detriment to continuing voluntary incentive 

based conservation projects, planning and the local economy. Farmers and ranchers in Southern Utah rely heavily on 

maintaining federal grazing allotments to sustain their livestock operations and livelihoods in the district's local communities.

UT Both emc0178GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-959

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

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772. In 1960 when Sage Grouse populations were the highest in Utah, the Utah BLM permitted livestock AUMs was at 1.7 million. 

The Sage Grouse population decline closely resembles the decline of historic permitted livestock AUMs to the current.7 

million AUMs. The numbers are very similar for Forest Service AUM's

UT Both emc0233GB

773. With a small amount of fencing the grazing system used on Desseret Land and Livestock in Rich County, that has proven so 

beneficial to the sage grouse populations there, would be easy to duplicate on Blue Mt.

UT Both emc0296GB

774. The BLM must consider the importance of the ranching and agricultural industry to the state's economy, and to the health 

ofthe sagebrush ecosystem.

UT Both emc0337GB

775. With a small amount of fencing the grazing system used on Desseret Land and Livestock in Rich County, that has proven so 

beneficial to the sage grouse populations there, would be easy to duplicate on Blue Mt.

UT Both emc0406GB

776. Livestock production tied directly to access and use of the federal lands is the backbone of Utah's agriculture Industry, 

contributing more than 65 percent of our state's $1.5 billion in farm gate sales. This contribution and its economic ripple 

effect are significant to the state of Utah and of critical importance to rural communities.

It has been estimated that more than 70 percent of Utah's cattle and sheep utilize the public lands for some portion of the 

grazing year. Sustainable grazing practices, harvesting renewable forage, provides value to all Americans, enhances rangeland 

resources and controls dead grass and brush helping control deadly Wildfires.

UT Both rmc0003GB

777. With only about 18 percent of Utah privately owned, any major agency decision that eliminates or decreases livestock 

grazing on federal or interspersed state lands will damage Utah's livestock industry. In a state with limited private grazing

land, there are not private grazing lands available to transition to. Any reduction BLM grazing permits requiring greater 

dependence on purchased hay and forage will make Utah cattle and sheep operations less economically viable.

UT Both rmc0003GB

778. Decisions impacting Congressional multiple-use mandates must consider the local history, culture, social and economic and 

how those decisions impact sustainable ranching practices. Congress recognized when the Federal Land Management Policy 

Act (FLPMA) was passed that without policy concessions there could be major adverse impacts on stales with federal land 

holding within their borders. FLPMA recognizes the contribution livestock grazing makes to the West and the economic 

foundation it provides for rural communities.

The Taylor Grazing Act clearly determines the high priority Congress places on livestock grazing in the West based on the 

"chiefly valuable for grazing" principle. This is a principle that has been upheld in the courts.

UT Both rmc0003GB

779. These same federal laws require a consistency review with state and local statutes. rules, policies and planning processes. 

Federal policies cannot adversely affect state or county land use plans and planning processes. Sovereign borders, 

interspersed trust lands and private property. as provided by the Fifth Amendment to the Constitution cannot be adversely 

affected for public use, without due process and just compensation.

Utah State Law supports livestock grazing and opposes transfer of rangeland resources for wildlife through the reduction or 

retirement of livestock grazing rights. The basis for major investments by the State of Utah, sportsmen's groups and ranchers 

was to improve the habitat for all the parties and uitimately return suspended and non-use livestock grazing to productive 

UT Both rmc0003GB
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C-960 Greater Sage-Grouse LUPAs/EISs May 2012

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cattle and sheep grazing.

Utah counties have adopted policies regarding public lands. These policies embrace continued livestock grazing. recognizing 

the "grazing right" as granted by federal law. The counties are on record as opposing the transfer of livestock grazing rights 

to wildlife utilization based on a federal agency's reasoning of "rangeland health reasons." In addition. the counties have 

recommended vigorous treatments of areas overrun with invading species like pinyonjuniper and other woody plants 

adversely affecting multiple use. Any reduction in livestock grazing must be based on science.

780. The Utah Sage Grouse Initiative has aggressively addressed habitat related issues and is designed to sustain working ranches 

while focusing local attention on threats facing Sage Grouse populations. Utah Farm Bureau county leaders have been 

engaged in Sage Grouse Working Groups.

Utah's Grazing Improvement Program (GIP) is focused on range health, productivity and sustainability of the grazing 

resource for livestock. wildlife and Sage Grouse habitat. 

Millions of dollars of federal, state and private resources have been invested in implementing conservation practices that 

improve Sage Grouse habitat through seeding with Sage Grouse food plants, installing fencing and water improvements 

beneficial to Sage Grouse, removing pinyon-juniper in sites critical to grouse numbers and incorporating livestock grazing 

rotations beneficial to Sage Grouse.

UT Both rmc0003GB

781. Utah Farm Bureau policy related to the Endangered Species Act supports any cost burdens affecting private landowners 

should be borne by the public not the farmer or rancher. Efforts related to restoration or monitoring of sensitive species 

should be based on sound science. And Utah Farm Bureau opposes endangered, threatened or sensitive species taking 

priority over established water, property or grazing rights.

UT Both rmc0003GB

782. Predation - In the agency assessment of threats to Sage Grouse, predation is identified as approximately half the threat as 

agriculture and grazing. Our experience in Utah suggests otherwise. Proper grazing enhances Sage Grouse habitat and 

populations. Proper grazing practices allow Sage Grouse to strut and more safely occupy habitat where they can observe 

predators like fox, ravens and coyotes.

Utah's Strawberry Valley experience suggests that predators are a major threat to Sage Grouse. In an area with no energy 

development or livestock grazing. Sage Grouse numbers have been greatly impacted by predators - especially fox and ravens.

UT Both rmc0003GB

783. Agency Land Management Policies - BLM and Forest Service policies related to invasive species. wildfires and predators 

along with strategic livestock grazing should be reassessed pertaining to Sage Grouse habitat. Reduced livestock grazing and

reduced chaining of pinyon-juniper coupled with wildfire policy have allowed invasive plant species to expand across the 

West. including on Sage Grouse habitat. Short duration, heavy grazing on invasive cheatgrass areas when palatable for 

livestock as a management tool could help return healthy livestock grazing land and Sage Grouse habitat with little or no 

government expenditure. Policies that don't allow chemical treatments of predators and invasive species on federal lands 

need reevaluation.

UT Both rmc0003GB

784. Deseret Land and livestock Experience - In closing, Utah Farm Bureau would recommend the agencies review the Deseret 

Land and Livestock (DL&L) Sage Grouse experience. Located mainly in Rich County Utah, along the Utah-Wyoming border, 

UT Both rmc0003GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-961

Scoping Summary Report

Table C-6.A

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DL&L have put in place land resource management strategies that embrace livestock and wildlife habitat. Over the past 30 

years, sheep and cattle stocking rates have been increased to more than double the stocking rate on most federal lands while 

the number of Sage Grouse, an '·indicator" species, have increased by five times.

785. We believe that prescriptive grazing is and historically has been a major factor in maintaining the health and sustainability of 

our lands in the west. We believe this to be a recognized and proven method that, recognized and used as a tool will 

promote Sage Grouse habitat restoration and preservation. As grazing is one of the strongest tools we possess, we believe 

it is absolutely necessary that public lands ranching involvement and input into the ElS/SElS and later the amendment process 

is crucial.

UT Both rmc0026RM

786. The position that the threat of possible Sage Grouse listing has placed our citizens, western land states and their local 

government entities in, we view as a direct result of years of federal regulatory onus. Carbon Comity shall take a willing role 

in working to remedy this issue but believe that until the federal agencies and our national leadership recognizes that; 

reducing grazing AUM's west wide consistently for over 50 years, listing under ESA the natural predators of the grouse 

species, outlawing the use of poisons used to prevent predation and the promotion of fuel/biomass buildup by interrupting 

natural fire regimes have hosted the consequences weand the bird now endure.

UT Both rmc0026RM

787. My biggest concern is that this will in someway inhibit grazing on the grasslands. As a TBGA Board member I don't want any 

of our permitees to lose AUM's. We need to preserve our rights to graze the land in The Thunder Basin National 

Grasslands, as well as defend private property rights.

WY Both cfc0019RM

788. Tuesday, March 13, 2012 there were at least 10 sage grouse strutting on Keyton 1 lek. Cattle were also on the lek. 

Sunday, March 18, 2012 there were 12 strutting males. 

Monday, March 19, 2012 there was a golden eagle near the lek and no grouse. 

I realize this is "anecdotal" and we here on the ground are "not credible" but this is the truth.. It's not cattle, traffic or fences 

that have caused grouse problems.

WY Both cfc0032RM

789. Policy Statement 7: West Nile Virus: ‘ Artificial water impoundments will be managed to the extent of BLM’s authority for 

the prevention and/or spread of West Nile Virus...This may include..(c) building steep shorelines to reduce shallow water 

and emergent aquatic vegetation; (d)maintaining the water level below rooted vegetation; (i) restricting access of ponds to 

livestock and wildlife (Doherty 2007).The BLM mentions several instances where they would regulate reservoir use by 

fencing out, making the banks too steep for livestock use, keep water level low: The reservoirs on federally managed lands 

are for the wildlife as well as livestock use. If the reservoirs are fenced out, banks made too steep or the reservoir is unfit for 

livestock to use; the water will also be unfit for wildlife use. Young elk, pronghorn and deer will not be able to get out of 

steeply sloped reservoirs any more than sheep or cattle. You are not allowing yourselves to look at the whole picture. 

Multiple use means wildlife and livestock. The use of larvicide is a good recommendation if used according to the label.

WY BLM emc0050RM

790. Fencing out is a bad idea because if an animal is thirsty enough they will crawl over and then either be caught in the fence or 

unable to get back out to graze. Eventually the fence will be down and be a hazard with loose wires to entangle animals. This 

applies for wildlife as well as livestock.

WY Both emc0050RM

791. There are several legal documents that uphold the right of landowners and livestock owners to use trails, pasture and 

reservoirs on federally managed lands. One of these is the MCKELVEY VS. US where the Supreme Court ruled that a stock 

WY Both emc0050RM
C. Comments by Resource Planning Issue

C-962 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-6.A

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trail 3 miles in width established in local custom was equally as legitimate as an SRHA stock trail. Cattle owners or their 

employees who have such ROWs (rights-of ways) are the owners of such ROWs and cannot be held guilty of trespass by the 

use of such ROWs. (Curtin vs. Benson 1911). "Land to which right and claims of others exist is not public land" -upheld by 

the U.S. Supreme Court.

792. In Steptoe Live Stock Co. V. Gulley, 295 P. 772 (1931) the Supreme Court of Nevada held that the establishment of livestock 

trails providing access to water sources was sufficient to constitute a valid appropriation and establishment of water rights. 

There are numerous other precedents set by several courts showing that a livestock owner has a right to use the water on 

federally managed lands. BLM does not have complete authoritarian control over the federally managed land for right of 

water usage. The water is for multiple use not just wildlife.

WY Both emc0050RM

793. If road closures for a time period during the year is considered then the lease holder and local landowners must be allowed 

to travel the areas roads as needed for maintenance and livestock needs. Their travel cannot be limited to certain times of 

the year if they have ranching requirements that must be met. The same must be taken into consideration for trailing, 

branding, docking, feeding, calving and lambing of livestock, as well as irrigation and summer hay cutting. These ranching 

activities all occur with regularity within the time frame of the courting and nesting of the sage-grouse (March 1-June 30) The 

ability of the landowner and lease holder to adequately calve or lamb and take care of their livestock must be placed in the 

forefront as well. It is possible to take into the consideration the management and conservation of a species without causing

undue hardship on landowners living in the area. Landowners are limited by area landscapes and habitats as well when it 

comes to adequately protecting newborn livestock. Their livestock management plans are made well in advance each year 

and for the most part cannot be easily changed. Corrals, barns and other facilities needed for livestock cannot be 

transported to far away pastures for shelter and convenience. Some pastures are used at the same time each year for the 

specific reason that they will help provide nourishment and shelter to a landowner’s livestock from storms during the spring 

of the year.

WY Both emc0050RM

794. I have seen cattle and sage grouse grazing and resting side by side. The cattle will keep the predators away to protect their

calves. Yearlings will follow a coyote for a long way out of curiosity. My point is that sage grouse are safer with cattle in the 

same area because the coyote, fox and bobcat will be not as prevalent.

WY Both emc0050RM

795. Work to address and prevent overuse areas by managing for good livestock distribution’. (pg. 3 attachment 8). Part of good 

distribution of livestock is the availability of water in harder to access areas. Livestock will not walk any farther than 

necessary to reach water. All wells and other water resources such as develop springs and reservoirs placed away from 

natural riparian areas will help protect those riparian areas. Authorize new water development for diversion from spring or 

seep source only when priority sage-grouse habitat would benefit from the development (page 16 National) The more water 

available in a pasture the less use any one watering place will have and the less damage to sage grouse habitat in the area. 

There needs to be several areas of water available to prevent one part of a pasture from being overused.

WY Both emc0050RM

796. 'For actions other than those taken for human health and safety, regulatory compliance or emergency, BLM FOs must 

determine if any activity proposed...is "disruptive" by determining if the activity would require people and/or the structure or 

activity to be present in these habitats for a duration of more than 1 hour during any one 24 hour period...’ (page 5 letter).

This should include the trailing of livestock. When moving livestock the area is seldom disrupted over an hour; unless the 

WY Both emc0050RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-963

Scoping Summary Report

Table C-6.A

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herds are excessively large. In this case rather than the federal agencies overregulating the livestock owner: the herd could 

be split and moved on continuous days so as not to disrupt a core area more than an hour on a 24 hour period.

797. Livestock trailing that is authorized through crossing permits...will include a trailing plan that...will include specific routes and 

timeframes for trailing.(page 15 letter) This could cause undue hardship on a landowner trying to get livestock from point A 

to point B during a certain time of the year. If a route chosen by BLM is several miles around a core area and the time frame 

is chosen to be weeks or months later than a landowner needs then you are forcing the landowner to pay the extra expense 

of buying trucking or not to move his livestock at an opportune time for them. BLM is not in the ranch management business 

and again I would like to refer you to the ROW-Rights-of-Way- precedent stated as #3 of my comments. If a landowner will 

not be in an area over 1 hour for disruption of a specific sage grouse area- we are not talking miles here-then the trail activity 

should not be considered a disruption. If there are concerns about the presence of leks or sage grouse nests in and area, then 

the BLM should let the landowner or lease holder know where these are and the livestock owner would be very willing to 

do their best to mitigate any disturbance in an area or to avoid leks altogether. Communication is the key here. Landowners 

are usually receptive to concerns if presented in a positive way and are willing to do what they can to cause as little harm as 

possible to any wildlife within reason. You might be surprised how well things will work out if the livestock owner is given 

an opportunity to deal with a concern over nesting or leks.

WY BLM emc0050RM

798. ‘Activities excepted by the State plan from the conductance of a DDCT calculation’ (page 7 letter) What about herbicide and 

pesticide use that occurs on the rangeland away from roads, locations, pipelines and ROWs---? The treatment of pests and 

noxious and exotic invasive grass species are important to help any habitat improve. If the treatment will not disturb a 

specific area for more than 1 hour in a 24 hour period and will not reduce the sagebrush canopy as per the WGFD protocol 

then these treatments should be exempt as well. And so noted.

WY Both emc0050RM

799. ‘In all cases, direct, indirect and cumulative impacts of proposed action on sage-grouse, other wildlife and all other impacted 

resources must be described regardless of distance from the project or whether inside or outside sage grouse core areas.’ 

(page 9 letter). Also included in this must be the direct, indirect and cumulative impact of the proposed action upon livestock 

management or grazing plans. What is the maximum distance considered here 11 miles, 4 or ?

WY Both emc0050RM

800. When several small or isolated allotments occur within a watershed or delineated geographic area, strive to evaluate all of 

the allotments together. (page 15 letter) This should only be considered if the allotments are under the same or very similar 

management. One lease holder should not be punished for the mismanagement of another lease holder and by evaluating all 

allotments together there is a chance of this occurring. Make sure there is a stipulation where the allotments are evaluated 

separately if there is a negative assessment that results from the overall group evaluation.

WY Both emc0050RM

801. Evaluate the potential risk .. from existing structural range improvements. Address potential for modification of those 

structural range improvements, identified as posing a risk during the renewal process.(page 17letter) Just what structural 

range improvements does the BLM mean here? Corrals, windbreaks, fences, sheds, ditches, dams, windmills? If these things 

have been there several years the grouse are already using them to their best advantage. If new windmills or reservoirs are 

needed then the grouse can take advantage of these to not travel so far. What are you referring to here? Just fencing-then

so state.

WY Both emc0050RM
C. Comments by Resource Planning Issue

C-964 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

802. Implementing management actions after land health and habitat evaluations (page 15 National) There are grazing rights on 

federally managed lands and the removal of livestock from a grazing area must be a last resort. Manage the timing and 

numbers of the livestock to acquire the forage base desired-if a rest is needed then another area should be offered to the 

lease holder for grazing privileges. If the lease holder has purposely overstocked and grazed a much longer time than stated 

on the lease then livestock removal might be considered. Range conditions can be low for numerous reasons that do not 

involve livestock. Before removal the burden of proof must be on the BLM to prove the negative range evaluation is due to 

the livestock use.

WY Both emc0050RM

803. Maintain retirement of grazing privileges as an option in priority sage-grouse areas when base property is transferred or the 

current permittee is willing to retire grazing on all or part of an allotment (Crawford et al. 2004 page 17 National) People buy 

base property with the expectation that the grazing leases will follow the land. The new purchaser should have the option to 

use the grazing lease and if they decline and the land in question is part of a grazing association then the grazing lease must 

go to the association for others to use. Grazing is not a privilege but a federally mandated right as part of multiple use of

federally managed lands.

WY Both emc0050RM

804. There is no scientific data that proves livestock grazing is harmful to sage grouse. The BLM and Forest Service and the US 

Fish and Wildlife Service all must use proven "sound" scientific data before they enact any regulatory mechanisms over 

landowners and livestock managers.

WY Both emc0050RM

805. There should be no prescribed burning of forage within sage grouse core areas unless it is for ditch cleaning or similar 

maintenance. When prescribed burns occur within core areas that presents a disturbance that counts towards the total 5% 

surface disruption. The managing federal agency can then come back and cut the AUMs in that area because there has been 

too much surface disturbance—due to the burn. A planned burn by any federal agency should occur outside of the core 

areas for this reason. Lease holders should not be punished by a drop in AUMs because the federal agency decided to do a 

burn within a core sage grouse area.

WY Both emc0050RM

806. i. Lander, WY RMP

Alternative B stresses avoiding construction of new infrastructure (such as fencing) and instead focuses on livestock grazing 

management throughout seasons of use and lower forage utilization. This alternative includes the removal or modification of 

existing fences when and where opportunities exist.

WY Both emc0089RM

807. i. Lander, WY RMP

Alternative B stipulates light livestock grazing levels in areas typically preferred by cattle, such as riparian-wetland areas, 

adjacent upland areas, and around salt and mineral supplements and water troughs and developments. Also, Alternative B 

prohibits salt or mineral supplements within 0.5 mile of riparian-wetland habitats to prevent livestock congregation at water 

sources. Alternative B prohibits the placement of salt or mineral supplements within 0.6 mile of greater sage-grouse leks. All 

these provisions would protect important sage-grouse habitats (foraging areas, breeding areas, nesting areas) from livestock 

trampling and the impacts of heavy plant utilization.

WY Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-965

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

808. 14) Identify and remove or modify rangeland fences which cause sage-grouse deaths due to collisions. WY USFS emc0144RM

809. Livestock grazing are important issues locally as is energy development in the Hoback Basin. WY USFS emc0144RM

810. In the particular case of the Casper area, overuse of sagebrush by big game and livestock is an important issue (BHSBLWG 

2006:13).

WY Both emc0343GB

811. From what we can determine, the mapping for Wyoming for this current EIS process just defaults to the flawed Core 

mapping. We are very concerned about the Wyoming Core model development and the process by which it was imposed 

on public lands there. A presentation in Boise by the Wyoming Core Area facilitator, Mr. Budd, heightened our concerns. 

The process that came up with the Core Model was not really consensus. Mr. Budd, the facilitator, admitted that he at times 

dictated. Plus, it is clear that this process ignored important scientific considerations. For example, Budd showed outright 

scorn for essential components of arid lands ecosystems like microbiotic crusts, and has a strong prolivestock industry bias.

So that entire process minimized consideration of livestock grazing disturbance effects. And this is the very same bias carried 

forward in the NTT’s extremely weak and minimal grazing provisions, and the IM’s even weaker application of these 

provisions, along with its apparently providing no protections at all to general habitats related to grazing, in apparent 

violation of the BLM’s 2004 Conservation Plan.

WY Both emc0411GB

812. (8) The NOI is silent as to the protection of existing m:es (even though it states it will "re(.:ognize valid existing rights"). Our 

question is: Is grazing considered as a "valid existing right"? The Wyoming ELM signed-off on a Wyoming IM: that approved 

the Wyoming Core Area Plan that averred existing uses, in-place as of2008, were not subject to stipulations (aka 

conservation measures) within core areas. Are the amended Rl\,fp's going to follow this same approach?

WY Both fxc0011gb

813. The WDA supports the greater sage-grouse strategy outlined in the Governor's Executive Order 2011-05, particularly 

Attachment C (Exempt Activities). The list of Exempt (de minimus) Activities includes several livestock grazing management 

practices that have occurred on public lands for more than 100 years. In addition, the Wyoming Standards for Healthy 

Rangelands and existing regulations allow Federal agencies the flexibility to make meaningful and educated adjustments to 

livestock grazing management if conflicts with other resources occur. Livestock grazing management decisions should be 

made on a case-by-case, allotment-by-allotment basis and not as an overarching land use planning decision. Because of these 

reasons, the WDA does not believe it is necessary to address livestock grazing management in the upcoming EISs/SEISs.

WY Both rmc0010RM

814. The WDA strongly recommends that planning criteria includes information from Grazing Influence, Objective

Development, and Management in Wyoming's Greater Sage-grouse Habitat (Cagney et al. 2010), and recommendations 

developed by Local Sage-Grouse Working Groups and the forthcoming Great Sage-Grouse Programmatic CCAA for 

Wyoming Ranch Management. In addition, peer-reviewed science and solid monitoring data should underlie decisions. The 

Amendment needs to identify the science supporting the discussions, decisions and actions.

WY Both rmc0010RM

815. Secondly, I question strongly the notion that AUM cuts on grazing allotments will have any effect. If grazing is truly a factor, 

why were sage grouse so plentiful from the 1950's through the 1970's? This is a time frame when, typically, turnout dates 

were earlier and grazing allotments were not near so closely monitored, further, stubble height should not be used as a 

benchmark for sage grouse habitat, adjacent to leks. Soil type, in this instance is critical I am familiar with two leks in our area 

(on private land) that are located on white hardpan, which would never have sufficient srubble height on an exceptional year. 

WY Both rmc0012RM, 

rmc0022RM
C. Comments by Resource Planning Issue

C-966 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.A

Comments Related to Livestock Grazing

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Stubble height requirements, in my view, could be used in an arbitrary and capricious way to force AUM cuts, without any 

corresponding benefit to sage grouse populations.

816. Specifically, the EIS affecting three permit holders in the Antelope creek drainage should be revised. The proposal to cut a 

month from the grazing season on these permits should be changed to 15 days, taken from the early season. Removing 15 

days from the winter part of the grazing season seems arbitrary, and will not enhance sage grouse populations in that area 

The permit holders have shown a willingness to compromise. The BLM should reciprocate and work with them, to avoid 

hurting the viability of their cattle operations.

WY Both rmc0012RM, 

rmc0022RM

817. Through the rotational grazing and management of its resource, the 4W is an economically viable ranching business along 

with being an abundant wildlife haven. Sage-grouse thrive on the northern 1/3 of the ranch, where our winter and calving

pastures are located along with active leks. Why should this vibrant livestock operation be forced to change its proven 

stewardship to accommodate unproven theories when it comes to the livestock grazing and management of this ranch and 

this area? This position is supported by the following Policy Analysis Center for Western Public Lands3 PACWPL Policy 

Paper SG-02-02.

WY Both rmc0034rm

818. Properly managed grazing should cause no harm to the Sage Grouse, yet curtailing grazing is always one the first actions land 

agency managers have on their list of actions.

WY Both rmc0044RM

819. While it is temptillll to reduce grazing, primarily be<;ause it is easy to accomplish, reducing or even eliminating grazing will 

accomplish little to improve habitat for the sage glOUse, except possibly In a very few small key areas. The ad'/i!rse effects 

on the economy outwei&h the benefits of reducing grazing. Other conservation efforts will be much more productive to 

increase sage grouse populatiOns.

WY Both rmc0045RM

820. Regarding the proposed Plan Amendment changes as presented at the Douglas scoping open house on February 7. 2012, 

Current provisions of the Plan are more than adequate to conserve sage grouse habitat insofar as grazing is concerned- no 

changes are needed. Indeed, if current provisions are implemented to their full extent, significant adverse effects to grazing 

would be reaii'ed with only a small amount of habitat improvement. Suitable habitat is currently present- other factors than 

habitat improvement must be implemented, as described above. For the sage grouse population to recover.

WY Both rmc0045RM

821. The SG plan seems to presuppose that most SG population decline is due to livestock grazing and mineral extraction. This 

point of view may be based leks on science and more on a particulcu political point of view. There seems to be a difference 

of opinion between" best available science" and the observations of those who live and work on the land.

WY Both rmc0048RM

822. I have found through many years of ranching experience that the management that is good for the land is good for the 

livestock and what is good for the livestock is good for the wildlife is as well. Heavy consideration should be given to the 

people and communities who depend upon the land for their livelihood. Under no circumstances should there be a 

reduction of AUM's and absolutely no retirement of grazing permits. Especially if the managing agencies are not willing to 

actively control predation.

WY Both rmc0048RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-967

Scoping Summary Report

Table C-6.B

Comments Related to Farmland and Agricultural Use

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. In 2008-2009 leks were cut in half, agriculture caused reductions in leks as did a lot of roads. Sage-grouse were found to be half 

as likely to maintain their nests in Silver Sage as in Big Sage. North Dakota saw a tremendous drop in bird populations.

All Both emc0012RM

2. Much of sage grouse habitat is on private land. If economic and political factors encourage the ranch to try farming, this habitat 

will be lost to the plow.

All Both emc0013RM

3. Each proposed conservation measure in the EIS should be analyzed in terms of how much it costs and how much the grouse 

population will benefit. The following conservations measures should be included in this analysis: - Various methods of 

coyote control. - Various methods of raptor control. - Various methods to reduce danger from fences. - Various methods to 

reduce danger from vehicle traffic. - Various methods to protect grouse from disease. - Various methods to limit exposure to 

pesticides. Each method should be rated according to two measures: 1. Number of grouse saved per dollar spent on 

materials and labor. 2. Number of grouse saved per laborer-hour of time spent. When considering these measures, the EIS 

should analyze costs from three different viewpoints: 1. When the BLM employs the person doing the labor; 2. When the 

BLM contracts with a third party to do the labor; 3. When the BLM encourages ranchers or other partners to perform the 

labor. Ranchers' time and BLM funds are limited. The RMP should focus on conservation measures that provide the highest 

return for the time and money invested.

All Both emc0013RM

4. The EIS should study the impact that pesticides might be having on sage grouse in regions where the grouse are not doing as 

well as they are in northeast Montana. The RMP should acknowledge that keeping private land owners in the cattle business is 

preferable to forcing them to try crop-raising methods that might rely on chemicals harmful to sage grouse.

All Both emc0013RM

5. Whenever the RMP considers a course of action that could reduce the economic viability of a ranch, it should also consider 

whether that course of action would harm sage grouse by increasing the likelihood that the ranch would plow prairie, 

overgraze, or sell land to developers to compensate for the lost revenue.

All Both emc0013RM

6. The EIS should propose a study of the impact of pesticides on sage grouse in regions where the grouse are showing long-term 

decline.

All Both emc0013RM

7. The RMP should explore ways to keep ranches grazing the land instead of farming it. All Both emc0013RM

8. West Nile virus, which is linked to standing water associated with some forms of energy development and agricultural water 

use, also poses a threat to greater sage-grouse in the Eastern Region. Naugle et al. (2004) showed that up to 25% of a 

population may die due to West Nile virus. The BLM produced an Information Bulletin (MT-2011-033) regarding best 

management practices to reduce the availability of breeding grounds for mosquitoes that carry West Nile virus. We 

recommend that these best management practices be implemented across BLM lands and particularly in sage-grouse core 

areas to prevent the death of this species. WWF has also produced, along with partners at the University of Wyoming, a 

spatially explicit map showing where West Nile virus is most likely to become prevalent under climate change conditions 

(Schrag et al. 2011). Areas with a high threat of West Nile virus (areas coded in yellow, orange and red in the figure below) that 

are located within core areas should be prioritized for reduction of standing water and other factors that increase the 

likelihood of becoming Culex mosquito breeding grounds. *Included an attachment (Figure 4)

All Both emc0034RM

9. If the many agricultural groups to which most rural people belong (Farm Bureau, Farmers Union, National Cattlemens and 

many others) were asked to find a voluntary solution to protecting the Sage Grouse, it could be done without costly and 

All Both emc0082GB
C. Comments by Resource Planning Issue

C-968 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.B

Comments Related to Farmland and Agricultural Use

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

obstructive regulations

10. The Prairie Chicken in eastern Colorado has benefitted from such cooperation. Former Colorado Agriculture Commissioner 

with the Colorado Division of Wildlife and these same entities did a good job without the interference by federal agencies and 

extreme enviros with the winner being the Prairie Chicken. The same could be done in other states for the Sage Grouse.

All Both emc0082GB

11. Ranchers and farmers live in these beautiful, rural areas. We try to be good stewards of the land we use. A lot of it we share 

with many others with the same values.

All Both emc0082GB

12. We have managed our grazing leases for many years so as to enhance the resource for our livestock and for the wild species 

which also make the forest their home. Research shows that healthy private land ranches are crucial to healthy adjoining public 

lands. See Maestas, et al 2001. This was the subject of a paper, "Ranching as a Means of Conservation," presented by Dr.

Richard Knight, Colorado State University to the Society for Rangeland Management in 2007. Go to the following link to read 

the paper: http://www.allenpress.com/pdf/rala-29-05-04-09.pdf The economic success of our ranching operation is 

inextricably tied to our ability to graze our livestock on BLM and Forest Service lands. Without our grazing leases, we would 

not be an economically viable ranch. Not only does the prosperity of ranches like ours enhance the quality of contiguous 

landscapes and habitats, but they add to the long-term viability of rural communities. Most importantly, agricultural operations 

produce food. USDA Secretary Thomas Vilsack addresses the need for food production. "We need to increase both the 

sustainability and productivity of global agriculture so that food is available, accessible and usable to people everywhere in the 

world,"

All Both emc0088RM

13. While this may seem far afield for comments on Sage Grouse, we want to emphasize that healthy sage grouse habitat goes 

hand-in-hand with private/public lands ranching. These ranchlands, including ours, keep the landscape open and provide the 

habitat essential for such keystone species. Good management for livestock and wildlife speaks to Secretary Vilsack’s point of

sustainable food production.

All Both emc0088RM

14. I expect that comments from radical groups such as Western Watersheds will be less inclined to respect the role that 

livestock husbandry plays in the health of the forests, wildlife habitat, open space, rural community vitality, food production 

and national security. We hope that reviewers will consider the positive role of grazers, both for species such as Greater Sage 

Grouse, and for positive contributions which fit into the Mission Statements of the USDA and the Forest Service.

All Both emc0088RM

15. While this may seem far afield for comments on Sage Grouse, we want to emphasize that healthy sage grouse habitat goes

hand-in-hand with private/public lands ranching. These ranchlands, including ours, keep the landscape open and provide the 

habitat essential for such keystone species. Good management for livestock and wildlife speaks to Secretary Vilsack’s point of

sustainable food production.

All Both emc0088RM

16. We have managed our grazing leases for many years so as to enhance the resource for our livestock and for the wild species 

which also make the forest their home. Research shows that healthy private land ranches are crucial to healthy adjoining public 

lands. See Maestas, et al 2001. This was the subject of a paper, “Ranching as a Means of Conservation,” presented by Dr.

Richard Knight, Colorado State University to the Society for Rangeland Management in 2007. Go to the following link to read 

the paper: http://www.allenpress.com/pdf/rala-29-05-04-09.pdf The economic success of our ranching operation is 

inextricably tied to our ability to graze our livestock on BLM and Forest Service lands. Without our grazing leases, we would 

All Both emc0088RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-969

Scoping Summary Report

Table C-6.B

Comments Related to Farmland and Agricultural Use

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

not be an economically viable ranch. Not only does the prosperity of ranches like ours enhance the quality of contiguous 

landscapes and habitats, but they add to the long-term viability of rural communities. Most importantly, agricultural operations 

produce food. USDA Secretary Thomas Vilsack addresses the need for food production. “We need to increase both the 

sustainability and productivity of global agriculture so that food is available, accessible and usable to people everywhere in the 

world,”

17. I expect that comments from radical groups such as Western Watersheds will be less inclined to respect the role that 

livestock husbandry plays in the health of the forests, wildlife habitat, open space, rural community vitality, food production 

and national security. We hope that reviewers will consider the positive role of grazers, both for species such as Greater Sage 

Grouse, and for positive contributions which fit into the Mission Statements of the USDA and the Forest Service.

All Both emc0088RM

18. Wildfire Management Wildfire management has two components, range grass fuel buildup and USFS timber loads. Range fires 

throughout Southern Idaho and portions of SE Idaho may have been limited through the use rotational grazing and developing 

fire breaks. There are numerous areas that no longer are utilized for grazing, such as the INEL, thus creating a significant fuel 

load that devastates huge sections of sage grouse habitat. The failure to provide management action, whether grazing, 

controlled strip burning on ungrazed federal lands, or restoration of previously burned areas, needs to be included within the 

NEPA process, so the cumulative affect of these inactions on the habitat is considered.

All Both emc0112GB

19. The sage grouse management measures being contemplated have a potential for a large impact on hay farming and cattle 

ranching business. And measures to protect and enhance the grouse will come on top of significant impacts to livestock 

operations by a rapidly expanding Oregon wolf population.

All Both emc0173GB

20. OFS is concerned that protection measures could severely limit the ability of farmers and foresters to effectively manage their 

lands.

All Both emc0221GB

21. I am glad to hear that efforts are being made towards working with land owners whose land includes sage grouse habitat. This 

is a good step. However, effort should also be made working with farmers whose land is adjacent to sage grouse habitat. 

Specifically hay/alfalfa farmers. I say this based on an experience I had several years ago. I am an avid bird hunter and have been 

hunting sage grouse since I was old enough to hunt. I was scouting sage grouse in August and found a alfalfa field that bordered 

public land. This was west of Roberts and south of Mud Lake within a few miles of the INL border. In the evenings I would see 

between 100 and 200 grouse fly out of the alfalfa and into the adjacent sage brush. So opening day I went out to shoot my 

grouse. I only saw 3 birds and the alfalfa field was cut. Trying to figure out where to go next, I looked up and a farmer was 

driving across the field towards me. He stopped and started taking. He was unfriendly towards me even though I was on public 

land. I told him I had seen hundreds of grouse in his field a few weeks earlier and virtually no birds today. He smiled and said 

it was because he had killed them all. He said that when he cut his field, the birds could not get out of the way from his swather. 

He showed no remorse. I was disgusted. Anyway, I think it would be beneficial to discuss solutions with land owners such as 

this. Maybe there is something that could be placed on the swather that would scare the birds up before it gets too close.

All Both emc0231GB

22. The worldwide food demand will increase exponentially in coming years, and it is vital that sustainable food production be 

allowed to continue.

All Both emc0236GB

23. Livestock grazing of public lands is unique in that it converts a product unusable by humans (grass), to a product that is 

consumable by humans (meat), in an all natural, environmentally sound manner. Careful, balanced management of public lands 

All Both emc0236GB
C. Comments by Resource Planning Issue

C-970 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.B

Comments Related to Farmland and Agricultural Use

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

grazing is of course central to the success of the multiple use ideal.

24. Keeping food production safe and sustainable leads to a safe, plentiful, and affordable food supply for our nation and the world 

community. Public land grazing is an integral part that, and the dubious status of the sage grouse should not preclude that.

All Both emc0236GB

25. Let us instead go back to the practices that helped the birds flourish. These are agriculture and grazing and a vigorous program 

to control predators such as crows, ravens and coyotes.

All Both emc0249GB

26. We believe that, if anything, the ranchers help the sage grouse by controlling some of the predation problem, maintaining 

habitat and water supplies, and helping to reduce wildfire threats (which destroy the sage brush so needed by the sage grouse) 

by grazing the land and minimizing overgrowth of vegetation.

All Both emc0293GB

27. As America's Federal private lands conservation agency, we see the potential for our agency to make a significant difference in 

the sage grouse conservation efforts across the west. To highlight and coordinate this, NRCS announced its "Sage Grouse 

Initiative (SGI)" in 2010. SGI has harnessed the power of the Farm Bill to strategically focus budgets and partner funding 

matches.

All Both emc0300GB

28. There is a positive synergistic relationship between sage grouse welfare and ranching use. Livestock producers stress predator 

control, help with fire control, and do project work like water developments that benefit wildlife as well as domestic animals. 

Sage grouse and ranching needs can both be met while rangeland health is improved.

All Both emc0307GB

29. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: - Management 

of agricultural lands can adversely affect sage grouse (e.g. pesticides and crop harvesting)

All Both emc0343GB

30. Farming creates single-crop monocultures that lack the habitat elements needed by sage grouse for their survival. Taylor et al. 

(2010) found that agricultural tillage also contributes to sage grouse population declines. It is rare for tillage to occur on 

BLMmanaged surface estate, and it is typically limited to private surface. As BLM has little ability to guide the management of 

private surface as regards agricultural uses, the Plan Amendments should stick to a moratorium on agricultural tillage on 

BLM-managed surface for both Priority Habitats and General Habitats for sage grouse.

All Both emc0343GB

31. BLM is to: - Manage priority sage-grouse habitats so that discrete anthropogenic disturbances cover less than 3% of the total 

sage-grouse habitat regardless of ownership. These features are: paved highways, gravel roads, transmission lines, substations, 

wind turbines, oil and gas wells, geothermal wells and facilities, pipelines, landfills, homes and mines. This definition 

purposefully omits fences that kill sage-grouse, livestock water developments that promote West Nile virus and severe 

degradation of de-watered spring habitats, and degraded upland habitats. Spring developments dry up or greatly reduce flows 

and shrink meadow and other brood rearing areas. It omits disturbance such as imposing large herds of livestock - including in 

combination with damaging facilities and management practices. The degree and severity of understory degradation into areas 

where pipelines or roads are built - are habitat-degrading anthropogenic disturbances associated with livestock grazing. 

Livestock grazing disturbance is an imposed impact caused by man. Domestic livestock are not native to the sagebrush biome 

(Mack and Thompson 1982), and are imposed by humans with catastrophic historical degradation and loss, and chronic 

continuing harm- including landscape-level desertification, and loss of habitats and populations. Plus this ignores blocks of 

private cropland and activities that may already occur in these habitats. How are these going to be dealt with? Careful 

examination of the wording shows that lands could be completely torn to pieces, but BLM will be able to look at the direct 

All BLM emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-971

Scoping Summary Report

Table C-6.B

Comments Related to Farmland and Agricultural Use

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

bulldozed disturbance, and not the real ecological Footprint or impact of the disturbance. For example, there is a large 

difference between the many square mile visual Footprint of a wind turbine, and the bulldozed footprint where turbines are 

placed- the difference is square miles vs. small fractions of a mile.

32. Lassen County is not wealthy when compared to other counties in California. It ranks 50 out of 58 in per capita income. It is

a large rural county with agriculture providing a significant contribution to the county's economy. As such, county planners 

included a section within the revised land use plan completely devoted to agriculture. In the Agriculture Element within the 

county land use plan Goal A-5 states, "Productive cooperation with and from Federal and state agencies which manage natural 

resources in Lassen County and improved consistency in resource management objectives, policies and programs." Lassen 

County appreciated the need to cooperate with Federal agencies when land use policies were revised.

All Both rmc0038GB

33. Additionally, Sanpete County is a predominately agriculture county. Our farmers and ranchers rely on the Forest as well as the 

BLM lands for grazing. It was hard to determine exactly from the maps who will be impacted by conservation measures 

included in the BLM and Sanpitch Mountain Range LUPs specific to our county, but we would hope that a cooperative 

management strategy would be proposed for those farmers and ranchers who use grazing permits in those areas.

All Both rmc0043GB

34. Production agriculture is also important in maintaining some of the late summer habitat found in irrigated hay meadows and 

other moist areas. The agricultural producers in North Park are effectively maintaining sage-grouse habitat by keeping the vast 

majority of North Park undeveloped. We would request thorough analysis of the impacts of removing production agriculture 

on the overall quantity and quality of sage-grouse habitat.

CO BLM emc0060RM

35. Actions that reduce or minimize sage brush habitat include: -New conversion of sagebrush land to cropland IDMT Both rmc0028GB

36. The Taylor Grazing Act protected the BLM lands from the plow, but it is the partnership with the BLM that protects private 

lands from the plow. Many pastures include private and BLM rangeland within the same fence.

MT-RM Both emc0013RM

37. In conclusion, Judith Basin County believes ranching and farming are the most efficient and cost effective means to sustain 

wildlife populations, while also producing food and fiber for our nation. It is important that conservation activities work 

hand-in-hand with agriculture, because negative impacts on ranching will have negative impacts on sage grouse. Our county 

recommends that your agency continues to enact or develop strategies that will benefit both agriculture and the sage grouse 

population.

MT-RM Both rmc0023RM

38. Much of the federal lands that wildlife, including the sage-grouse, benefits from today were developed by pioneer agriculturists 

yesterday. In many cases the green Nevada we have today is directly due to the land development practices by agriculturists 

over the past 150 years. Many of the projects done on private property to develop and increase agriculture production have 

also developed new habitat areas for the sage-grouse. Nevada agriculture producers are first and foremost stewards of the 

land because of its importance to the sustenance of their family. I hope that your team evaluates how agriculture can be used 

as a tool to increase the health of the Nevada range and wildlife habitat.

NVCA Both emc0269GB

39. I am extremely concerned about the impact the above referenced Notice of Intent will have on the range livestock industry in 

Nevada. Economically viable ranching operations provide both stewardship of public lands and economic stimulus and viability 

to local and regional communities. The conservation of rangelands for livestock production is extremely important, not only 

to the sustainable production of food and fiber for the United States and worldwide markets, but also to providing quality 

NVCA Both flj0000GB
C. Comments by Resource Planning Issue

C-972 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-6.B

Comments Related to Farmland and Agricultural Use

Comment 

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habitat to support wildlife populations.

40. The table lists agriculture as the 4th greatest threat. Again, we would like clarification. NVCA Both rmc0064GB

41. The economic and social values of the local agriculture and ranching community in Malheur County are important 

considerations that must be studied and taken into account for the sage grouse EIS. Habitat protection areas for this species 

of bird should be careful y studied to retain compatibility with the private landowner’s business activities to avoid conflicts. 

Livestock and agriculture production are primary economic concerns in Malheur County and land management opportunities 

on federal and state lands must remain flexible (Q meet the needs of the community as well as sage grouse.

OR Both emc0136GB

42. Economically viable farming and ranching operations provide both stewardship of I public lands and economic vitality to local 

and regional communities. This fact should not be ignored in the crafting of the EIS or resulting management plans.

OR Both emc0221GB

43. The BLM must consider the importance of the ranching and agricultural industry to the state's economy, and to the health of

the sagebrush ecosystem.

UT Both emc0337GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-973

Scoping Summary Report

Table C-7.A

Comments Related to Wildlife-General

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1. I do not support closures Rds. As this will allow an increase in predators. All Both cfc0007GB

2. As the bird goes so go other species. Our obligation is to protect. All Both cfc0008RM

3. Control of predators- fox, ravens, crows, raptors, coyotes. The area around the north end of the Sierra's hasn't changed in the 

almost 50 years I've been here. Except there are no longer 500,000 thousand sheep in this county, and coyotes were controlled. 

Fox and ravens were non-existent. We own the Forest Edge Ranch and Tullis at the northwest of the Sierras. There is no oil, gas 

or coal, no subdivisions, etc. i.e. we had 4 of grouse in front of Tullis with broods of 4 & 5 & 6 & 6. We also had a den of foxes. 

Every week the brood got smaller and smaller until they disappeared.

All Both cfc0010RM

4. The predator problem should be listed as prehaps the biggest single issue in restoring sage grouse populatins. We need more 

science-based research to show the full impact on sage grouse populations.

All Both cfc0012RM

5. Like others at the meeting held in Saratoga on February 13, I am in favor of better predator control. If an exemption were granted, 

ravens would be the best candidates for thoroughgoing control in a large area of sage grouse habitat- chiefly BLM and private- over 

a number of years. But special attention to a few small National Forest parcels would not be useful. I believe the USFS should 

concentrate its available resources on the Thunder Basin National Grasslands. However, if the amendment is adopted the Forest

Service should select just one parcel for related activities.

All Both cfc0015RM

6. One thing you could do to help the grouse would be to remove windmill towers that are no longer being used. The towers serve 

as perches for raptors.

All Both cfc0018RM

7. Predator control how will it be handled when controls around lek are a direct benefit to sage grouse. All Both cfc0020RM

8. Until the natural predators (raptors, canine, & etc) are controlled the sage grouse is headed down the road to being a listed

species. I suggest that we start a predator control program in all priority sage grouse habitats. There has to be a balance, too many 

raptors and not enough rabbits result in sage grouse predation. People don't like killing, but if your going to save one species you 

might have to control others.

All Both cfc0022RM

9. Place more focus on predator control. All Both cfc0023RM

10. Predator control should be recognized as an effective tool and should be encouraged. All Both cfc0024RM

11. "Remove, modify or mark fences." You might be able to put something on posts to keep hawks from searching but would a "flag" 

waving from the wires be a disturbance also? I don't know if sage grouse go under a fence for protection but we have seen rabbits 

do so.

All Both cfc0025RM

12. The fact that we have Sage Grouse here that have co-existed with the livesstock operation for over 100 years should be proof that 

they are not in danger from livestock use, and grazing, waster development and control of predators actually enhance the benefits 

to grouse. The water we develop for livestock is very important to the birds and will not be there if cattle are removed.

All Both cfc0032RM

13. I see no threats in the "predator" area listed. This is a great concern. All Both cfc0034GB

14. History - has proven there is more wildlife now than in the 1800s when trappers and settlers came west, other early journals state 

they had to eat their horses to stay alive. With that being the case, how do you determine what number of animals "sage-grouse" 

are in danger?

All Both cfc0046GB
C. Comments by Resource Planning Issue

C-974 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-7.A

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15. We need to have access to our natural resources. The problem is not drilling. The problem is predators - coyotes - wolves -

crows - foxes.

All Both cfc0063GB

16. Ravens especially and to a lesser degree rodents and coyotes can have a tremendous effect on nests and young birds in some 

areas. Predation in some areas must be addressed in the plan.

All Both cfc0065GB

17. Plan updates must address the impact of predation on sage-grouse and allow for the ability to manage predators for the ability to 

manage predators for the benefit of sage grouse.

All Both cfc0070

18. I realized the BLM has little to do with predator control, but they should support and facilitate any predator control efforts. All Both ecmc0165GB

19. comment on sage grouse, I have spent many years on the oregon high desert, on foot and horse back. There were cattle, sheep 

and wild horses everywhere when I was growing up, plus lots of hunters. You saw sage grouse on most ridges that had a water 

source. Now when I travel thru the high desert I see very few cows, no sheep, no deer, a few wild horse's and ten fold the amount 

of grass and sage brush that use to be there. Our government never seems to understand the most basic problem of bird or game

decline, its not people it's predators. I have witnessed golden eagels catching sage grouse along with magpies and ravens eating 

there eggs, that’s not counting the coyotes that get lucky. When I was growing up the county had a bounty they paid to get rid of 

these predators, now days they worship them. If you truly want the sage grouse to come back, then get somebody in leadership 

that understands the most basic concept of predator vs prey. The Oregon Fish & wildlife took some chicken eggs and hid them in 

some nesting sights in sage grouse habitat areas, what they found was the eggs were gone with in a few weeks. Thank you for at 

least letting the public comment on the problem even though it won't make a tinker's darn on your ruling. Clark couch

All Both emc0009GB

20. Until hunters are made to trully obey the laws and stay off private land , we will be loosing more than sage grouse. All Both emc0012GB

21. I'd like to comment on the sage grouse strategy. I understand that during the 60's there were a great number of sage grouse in 

southwest montana. During this time period there was an active predator control going on. Sheep were being grazed in large

numbers. Also at this time, eagles, falcons, hawks and the like were not protected and the numbers were down due to DDT. 

Cattle grazing was having a greater impact on the vegetation. Also in the 60's, large areas were sprayed to kill sagebrush and make 

more grass. I have dates of spraying but can't find dates and data of sage numbers for that time frame or after. I would like to see 

a comparison of no. of sage grouse before, during and after spraying to see if reduction in sagebrush had an effect on sage grouse 

numbers Since then, grazing by sheep and cattle has been reduced. Making better riparian and vegetation overall. Some burning of 

sagebrush was done in the 80's but since that time, sagebrush treatment has been reduce greatly. So no change in sagebrush 

quality! Predator control has been reduced and the eagles, falcons, hawks, etc have been protected and increased.

All Both emc0013GB

22. You also need to look at predator control and birds of prey and how they affect the sage grouse All Both emc0013GB

23. I feel that the decline in sage grouse numbers not JUST habitat loss/change, it is habitat quality, predator control and birds of prey. 

Sagebrush needs to be disturbed, burned most likely. The govt. needs to tell the public that we can't have everything. If we have 

birds of prey and coyotes we most likely l won't have numbers of sage grouse and other birds. If we want more sage grouse, we 

need to improve the sagebrush habitat, not just lock it up and do nothing to it. And we need to reduce our predatory animals and 

birds. Can't have it all.

All Both emc0013GB

24. It is common knowledge that when ranchers were aggressively controlling all predators, game birds were incredibly abundant. 

Although ranches no longer eliminate raptors, they do impact coyote populations. The RMP must include a solid study of the 

All Both emc0013RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-975

Scoping Summary Report

Table C-7.A

Comments Related to Wildlife-General

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impact of coyotes on sage grouse populations. The RMP should estimate how much the coyote population would increase and 

how much the sage grouse population would decrease if the ranches were not putting pressure on the coyote population.

25. Each proposed conservation measure in the EIS should be analyzed in terms of how much it costs and how much the grouse 

population will benefit. The following conservations measures should be included in this analysis: - Various methods of coyote 

control. - Various methods of raptor control. - Various methods to reduce danger from fences. - Various methods to reduce 

danger from vehicle traffic. - Various methods to protect grouse from disease. - Various methods to limit exposure to pesticides. 

Each method should be rated according to two measures: 1. Number of grouse saved per dollar spent on materials and labor. 2. 

Number of grouse saved per laborer-hour of time spent. When considering these measures, the EIS should analyze costs from 

three different viewpoints: 1. When the BLM employs the person doing the labor; 2. When the BLM contracts with a third party 

to do the labor; 3. When the BLM encourages ranchers or other partners to perform the labor. Ranchers' time and BLM funds are 

limited. The RMP should focus on conservation measures that provide the highest return for the time and money invested.

All Both emc0013RM

26. The EIS should consider how proposed changes might impact other species that affect rangeland health and sage grouse 

populations:

All Both emc0013RM

27. Anything that increases coyote or raptor populations will put more predation pressure on sage grouse. All Both emc0013RM

28. The relationships between the plant and insect communities are understudied. What insects do grouse eat? What plants to those

insects eat? What insects pollinate those plants? What insects benefit big sage brush? What do they eat? What insects harm big 

sage brush?

All Both emc0013RM

29. How important is the late-summer grasshopper population? All Both emc0013RM

30. When the ecosystem held fewer coyotes and raptors, the sage grouse were more abundant. The EIS should include an evaluation 

of whether this ecosystem was healthy. The EIS should acknowledge that attaining these numbers again will be impossible without 

eliminating the predators again.

All Both emc0013RM

31. Predation is a big culprit in the decline in these birds. Naturally, your management plan gives little consideration to that fact. 

Biologist seem to consider predation some "good tool" to take the sick and the weak but that's not the facts. Predation is large and 

I believe that's a problem for populations.

All Both emc0025RM

32. I am really concerned about the total devastation caused by the enormous wild fires over the past several years. I'm not seeing any 

of the usual animals that generally frequent these areas jackrabbits, cottontails, etc). Nor am I seeing the game birds that 

frequented the waterholes and scrub brush . As far as sage grouse are concerned , can they be re-introduced into their former 

destroyed habitat?

All Both emc0027GB

33. Ironically, Sage Grouse numbers were highest during the 1920's and 1930's when livestock stocking rates were also at their 

highest numbers. Part of the reason Sage Grouse were doing well at the time, despite very intensive grazing, is that predators 

were kept in check. Today we have very little predator control. In fact in Colorado leg hold traps are illegal, and predator hunting 

is at an all time low. Predator control must be a part of any recovery plan.

All Both emc0032RM

34. An issue that continually comes up when discussing sage-grouse conservation with other ranchers: Why do we not do 

something to control predators? Especially coyotes, as the coyote population is huge compared to what it was 20 - 30 years ago. 

Maybe it is just a coincidence, but all those years ago when the coyote population was much smaller, the sage-grouse population 

All Both emc0043RM
C. Comments by Resource Planning Issue

C-976 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-7.A

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was much larger. We all agree development from oil & gas, urban sprawl; etc has affected the sage-grouse population, but let’s not 

ignore the effect of predators.

35. As a long time (40+ years) hunter/fisher/experienced outdoor observer in Colorado, the basic answer to the sage grouse 

population is simple: Predators, cycles and water supplies. But mainly Predators.

All Both emc0052RM

36. Why so many Predators? a) Between all the rules of the USFS, BLM, DOW, State, it has become so complex that hunters of 

predators can never assume he/she is adhering to the regulations of each group. In other words "Keep it simple". b) Fewer people 

hunt predators because: Roads have been closed or are planned to be closed. There is an anti-hunting attitude exuded by the 

above groups. Cost of hunting (Equipment, travel, fees) Older hunters (60+) find previous access methods unusable and current 

long walking is difficult so they quit. The DOW statistics will substantiate fewer hunters as the old guys are not mentoring new

young kids.

All Both emc0052RM

37. The predator population has expanded and have learned to focus on drainages (where sage grouse are to be found). All Both emc0052RM

38. Studies indicated that predation was limiting sage grouse numbers, and their research suggested that low nest success from 

predation was related to poor nesting habitat. Most reported nest-success rates are >40%, suggesting that nest predation is not 

a widespread problem. Similarly, high survival rates of adult) and older (>10 weeks of age) juvenile sage grouse indicate that 

population declines are not generally related to high levels of predation. Thus, except for an early study in Oregon, predation has 

not been identified as a major limiting factor for sage grouse.

All Both emc0057GB

39. Following the science must be part of this conversion. There will continue to be calls from livestock interests including Aphis 

Wildlife Services, for extensive predator control and closing hunting. While those strategies may be appropriate purely as stop 

gap measures in extreme cases, they address only symptoms. You cannot correct population declines resulting from habitat loss 

or degradation by closing hunting or killing predators, and to promote such an approach is patently dishonest.

All Both emc0058GB

40. In preparing the EIS, the County recommends the BLM examine the historic and current impact of predation and natural low 

recruitment on the overall numbers of the sage-grouse as these impacts and how management can help these other factors is 

lacking in the GSGCM report. It has been suggested that as the United States federal policy changed over time from the early 

1970's, certain tools were eliminated that were used to control certain predator populations such as coyotes, and habitat 

improvement project are now under-funded. It has also been suggested that because of these policy changes the SGS population 

numbers in the United States significantly decreased (as documented in research conducted by John W. Connelly, recognized 

sage-grouse biologist with the Idaho Department of Fish and Game, Blackfoot, ID) because the predators were no longer heavily 

controlled and other factors have negatively impacted habitats. This research suggests that the high population numbers reported 

in the late 1960s (showing approximately 350% of the 2003 population according to Connelly) were the result of significant 

predator control and that the normal population numbers were likely much less. In other words, the EIS should carefully review 

and present research that examines the rise and fall of the GSG populations with the rise and fall of predator control policy and 

habitat improvement/management to place rea listic population numbers and other population control factors into context, and 

not solely place the burden of protecting sage-grouse on the energy industry.

All Both emc0058RM

41. As important as the institutional issue is, I will add this. Sage grouse is likely an "umbrella species" for many other high-dessert 

species and for the high-dessert ecosystem itself. That is, as an indicator of habitat quantity and quality it is a key species to 

All Both emc0066GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-977

Scoping Summary Report

Table C-7.A

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protect, and its protection and restoration by default would likely extend to other sagebrush-dependent species. But I delve into 

the technical with those statements, so I will leave it at that.

42. There are five listing factors under section 4 of the Endangered Species Act (64FR32726). We understand these are considered 

"threat factors". What level of analysis will be done during the EIS process to determine if any or all of these threats exist now or 

in the future? How specific might such a determination be? (i.e., district wide, species wide or ???) If any of the five are determined 

to be a threat on the District will they be fully analyzed to assure that they are addressed? Will a strategy be determined to 

eliminate an identified threat known to exist broadly but not existing on this district? If they are not analyzed will that be an 

indicator that a particular threat does not exist on the District? The five threat factors are listed as: a. A the present or threatened 

destruction, modification, or curtailment of the species habitat or range; b. Overutilization for commercial, recreational, scientific 

or educational purposes; c. Disease or predation; d. The inadequacy of existing regulatory mechanisms; e. Other natural or 

manmade factors affecting its continued existence.

All Both emc0071GB

43. Population past EIS’s have tended to focus on habitat and recognized that ODFW has the responsibility to manage populations of 

wildlife. Is there an opportunity to address populations and measures to enhance them along with habitat in the EIS? It would seem 

that even with great habitat on the majority of the District we have not accomplished anything without adequate or improved 

populations?

All Both emc0071GB

44. Past EIS’s have tended to focus on habitat and recognized that ODFW has the responsibility to manage populations of wildlife. Is 

there an opportunity to address populations and measures to enhance them along with distribution in the EIS? It would seem that 

even with great habitat on the majority of the District we have not accomplished anything without adequate or improved 

populations.

All Both emc0071GB

45. Sound Science Must Recognize Local Experience - While scientists count leks and evaluate habitat potential, it is important that 

sound alternatives recognize both current conditions, and local experience regarding historic sage grouse activity. In reviewing the 

habitat mapping, it has been noted that some areas identified as habitat have not had documented grouse presence or activity in 

over a decade. Another factor that must be carefully weighed is the potential for the grouse to adapt to changing conditions and 

environment, and the influence and impacts of other environmental factors, such as predation.

All Both emc0071RM

46. Another disturbance not specifically identified or addressed in existing or draft RMPs is the impact that natural gas flaring poses to 

greater sage-grouse. Flaring is believed to pose a threat from several standpoints. Noise associated with flaring may cause 

disturbance and increased predator effectiveness. Sound may directly interfere with lek display vocalizations and harmonics. Light 

from flaring can extend far beyond the immediate pad area, and this increased availability of light may provide increased 

opportunity for predation at times when natural light is normally not available. Light may also directly preclude grouse from using 

lek sites or other seasonal habitats.

All Both emc0072RM

47. While Greater Sage-Grouse depend on livestock troughs and tanks for water, they also can drown while attempting to drink or 

bathe in these structures. It is a common practice to temporarily shut off water to tanks and troughs when livestock are moved, 

forcing Greater Sage-Grouse and other wildlife that have become dependent on that water supply to find alternative-often 

distant-sources or perish. This is particularly harmful during the warmest months when Greater Sage-Grouse are rearing young. 

We believe that preventing wildlife fatalities at water troughs not only conserves Greater Sage-Grouse, but also helps maintain 

the clean, uncontaminated water that is critical for any livestock operation. Decaying animal carcasses greatly diminish water 

All Both emc0074GB
C. Comments by Resource Planning Issue

C-978 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.A

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quality.

48. The need for wildlife escape structures (also called wildlife ramps or bird ladders) in troughs and tanks has been documented. 

Most livestock water troughs were not designed or installed with Greater Sage Grouse in mind, and they seldom include a means 

of escape for wild animals that fall into the water while attempting to drink or bathe. These animals drown unless a 

properly-designed and well-placed escape structure is available. Wildlife drownings increase when alternative water supplies are 

unavailable and escape structures are absent, especially when water levels are lowest and during periods of drought, high 

temperatures and wind. Tragically, some of the most common attempts to provide wildlife escape structures do not work or are 

unreliable. Effective wildlife escape structures are easy and inexpensive to build and install and can eliminate Greater Sage-Grouse 

mortality in water troughs and tanks. Properly designed and installed, these structures also improve livestock health by 

maintaining clean water that's uncontaminated by drowned Greater Sage-Grouse or other wildlife.

All Both emc0074GB

49. Recommendation #4 - We recommend that all troughs and tanks with vertical or nearly vertical sides be modified with escape 

structures and that high water levels in these troughs and tanks be maintained throughout the year.

All Both emc0074GB

50. In some cases, predation may also substantially affect sage-grouse populations, and local predator control measures in certain 

areas, such as known nesting areas, may provide substantial benefits. Focusing on conservation measures that address these types 

of impacts will provide a beneficial option whereby sage-grouse habitat would be protected without substantial adverse effects on 

economically-productive activities. Improving the quality of existing habitat should also be a high priority, as better habitat will 

support more birds and facilitate the inclusion of other land uses across the broader landscape.

All Both emc0084GB

51. Predation control through either poisoned bait (eggs) or small bore firearms can be immediately effective. Fire control through 

free-market grazing decisions of cattlemen or sheep growers can be effective in protecting sage grouse within one climate season. 

Bureaucratic habitat control will take no less than multiple budget cycles, and personnel reviews, before any agency even begins 

to be an effective advocate for the benefit of sage grouse.

All Both emc0087GB

52. The apparent agency refusal to seriously consider predation and fire in the survivability of the sage grouse assures not only the 

endangered species listing of the sage grouse, but in fact the actual endangerment of the species. Extinction will not be the fault of 

the rancher nor the hunter nor the industrial worker. Sage grouse extinction will be the fault of the politically-correct scientist and 

the politically-correct bureaucrat.

All Both emc0087GB

53. While research indicates that habitat destruction is the greatest cause of the decline in the numbers of Sage Grouse, the role of 

predators is not far behind. Not only does our ranching operation control coyotes, but we get assistance from USDA APHIS in 

order to control crows and ravens. Corvid numbers have increased greatly in this area in the past decade, and all research cites 

them as major predators of grouse eggs.

All Both emc0088RM

54. In addition to habitat improvement, I believe there is a need to reduce predators and eliminate the hunting of Sage Grouse All Both emc0091GB

55. I believe where required there is a need for predator control. All Both emc0091GB

56. I believe we need more genuine scientific studies on all of our wildlife populations. All Both emc0091GB

57. There may have been a slight decline after the BLM killed many sage hens by poisoning crickets. They most likely are recovering 

and need no help from the BLM.

All Both emc0098RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-979

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Table C-7.A

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58. The effects of predation of sage grouse must also be analyzed. Several predator type animals will predate on greater sage grouse, 

including coyotes, red fox, raccoons, bobcats, badgers, striped skunks, weasels, eagles, and other raptors. The preliminary results 

from year one of a study in Wyoming’s Big Horn Basin, located in north-central Wyoming, shows a majority of failed nests were 

due to predation. This study has been active for only one year but the results do show predation can have serious impacts on sage 

grouse. More work must be done in other areas of Wyoming to determine the effects of predation on sage grouse.

All Both emc0106RM

59. Of the listed threats to Sage Grouse and habitat is predation of equal weight as humans, number 9 with relative rank of 30. Within 

our region there are numerous predators that are having an impact on the birds, coyotes, fox, magpies, crows, hawks, eagles. The 

NEPA process needs to include the cumulative affect of predators, especially birds. During the past 50 years while the sage grouse 

numbers have declined, the construction of aerial utility lines in the rural areas have proliferated. These provide roosting locations 

for predators especially during the mating period. What are the cumulative affects of these predators on the population? While 

the placement of underground utilities is discussed as BMPs, is it the impact the aerial line or the predator that uses it?

All Both emc0112GB

60. The EIS should look at the issues surrounding sage-grouse predator control. If predator control is now being used, or proposed 

to be used in given areas, there must be an examination of the positives and negatives associated with that. Although predator 

control could conceivably increase sage-grouse populations, there are several issues that are tied to predator control in general 

and perhaps to control of certain predator species in particular.

All Both emc0121GB

61. Sir, I have been involved with the sagegrouse study for 5 years, we know what kills them. Until we have a predator program to thin 

out the crow ravens and the coyotes they will never come back. If you find a raven nest look below it and see all the eggs they have 

taken to feed their young. We counted 18 under one nest. The coyotes flush the hen then search for the chicks

All Both emc0123GB

62. Two examples of range management that supports all wildlife, not just the sage grouse are found on the Julian Land & Livestock 

Co. in Kemmerer WY. and the Deseret Land & Livestock Ranch in Rich County UT. An entrenched bureaucracy with a “My way 

is the only Way” is the greatest detriment to viable habitat for all wildlife. The BOA supports all wildlife to be enjoyed for all forms 

of recreation as well as hunting. Number based management is a bad way to manage any game species due to manipulation of data 

in far too many cases. The current debate on the wolf recovery issue and who has the numbers and what the numbers mean as 

well as how large a number is sufficient to delist a species is but one example. The second paragraph concludes with the idea that 

the Federal land management policies should affect privately owned habitat. Current management practices of private property 

land owners is far superior to anything the Federal managers have tried. The heavy hand of the Federal Government must stay off 

private lands. Private land owners in Southwestern Montana are providing superior habitat and security to all wildlife pushed off 

Federal lands by pine beetle, conifer encroachment into meadows and pressure from predators, most notably the wolf.

All Both emc0133GB

63. Work on Predator concerns. All Both emc0137GB

64. BLM has explicitly stated in its public scoping materials that the resource management plan and land management plan 

amendments/revisions will be limited to making land use decisions specific to the conservation of greater sage-grouse habitats. 

The scoping notice did not identify predation or predation management as an issue or a component of sage-grouse conservation. 

Rather the FWS and BLM identified habitat conditions as the most significant range-wide threats to greater sage-grouse. However, 

predation was ranked 13th out of 19 potential causes for sagegrouse declines and was followed by disease (BLM and FS National 

Greater Sage-Grouse Planning Strategy, January 2012). In circumstances where predation has been identified as limiting local 

All Both emc0138GB
C. Comments by Resource Planning Issue

C-980 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.A

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sage-grouse populations, predation management may provide relief or benefit to local sage-grouse populations either alone or in 

combination with other actions, such as habitat improvements. Of the 19 identified threats to greater sage-grouse, predation may 

be one of only a few threats that could be managed to provide more immediate local relief while longer term habitat 

improvements and land use changes are made and begin to show results. Predation management may provide the time needed to 

maintain a healthy core sage-grouse population while habitat is recovered or expanded which could ultimately result in the ability 

for the sagegrouse population to expand.

65. We understand that BLM’s management authorities may limit the ability to initiate predation management since sage-grouse are 

currently managed by the states. However, since state wildlife management agencies and FWS are cooperating in BLM’s NEPA 

process to conserve sage-grouse, BLM planners and cooperating agencies should use this venue to collaborate in more 

comprehensive sage-grouse conservation planning and analyze issues outside of its normal jurisdiction such as predation and 

disease threats. At a minimum, defining the inter-relationships between BLM and other land managers, state wildlife management 

agencies, FWS and others, including APHIS-WS, would show how different conservation roles and actions may assist to enhance 

sage-grouse. If sage-grouse were to become listed under the ESA, jurisdictional roles would change. This possibility should be 

disclosed and analyzed as this scenario may provide useful information to the public and stakeholders for sage-grouse 

conservation.

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66. During the 1950s, 1960s and 1970s, sage grouse populations in lake County were high due to efforts of the Dept of Agriculture's 

government trappers that kept predators (such as coyotes) at bay and allowed sage grouse to breed and raise their broods 

successfully. During the same period certain predatory and scavenger avian populations were low. Raptor, raven, and crow 

populations were affected indirectly by poisons used in some predator control programs using cyanide and 1080.

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67. Currently, sage grouse populations must now contend with predation from coyote, raptor, raven, and crow populations that have 

increased dramatically since the 1970s. Predators teach their young how and where to find food. Sage grouse leks are extremely 

vulnerable to predation since the locations of the leks are passed on to each successive generation of predators. Considering the 

fact that most sage grouse nest within close proximity of the leks, it doesn't take scavenging predators such as coyotes, ravens, and 

crows very long to inflict heavy losses. "losses of sage grouse nests and young to predation are probably the most significant factor 

in determining annual recruitment" (Allred 1942, Autenrieth 1981, Batterson and Morse 1948, Gill 1964, Patterson 1950). In fact, 

a study in Oregon showed that the greatest single limiting factor of sage grouse was predation by ravens (Batterson and Morse 

1948) Badgers and Richardson ground squirrels are also efficient predators (Keller et al. 1941).

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68. In order to achieve a successful breeding season a predator reduction/disruption program must be instituted in and around leks 

during the breeding and brooding periods. No amount of vegetation cover will protect breeding sage grouse since the act itself is 

performed in open areas.

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69. Developing water sources in the more arid areas to reduce predation is critical. Predators congregate around water sources. 

Having more choices to water keeps predators guessing and reduces predation.

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70. Managed livestock grazing programs have the potential to maintain habitat diversity and quality for greater sage-grouse. For 

example, research shows that grazed lands produce forb growth and are preferred to nongrazed lands by greater sage-grouse 

(Evans 1986). Additionally, research shows that nesting cover (under canopy vegetation) remains adequate with up to 40 percent 

utilization levels and is not substantially diminished until later in the grazing season, thus indicating that a variety of grazing regimes 

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may be implemented without adversely affecting nesting (France et al.) In areas of high production, utilization in excess of 40 

percent will still result in adequate nesting cover. Grazing systems should be implemented and managed to comply with the 

respective resource area management and forest plans. Site-localized, long-term trend monitoring should be the basis for 

determining compliance with management plans. Utilization percentages or stubble-height measurements, set forth in a formula 

and applicable west-wide throughout the greater sage-grouse range, are not effective tools for adaptive management. Adequate 

residual plant cover must be determined by short-term and long-term monitoring, which includes accounting for various 

environmental conditions.

71. Predator Control The EISs and SEISs must analyze the impact of predation as a leading cause of greater sage-grouse mortality, and 

must analyze the benefits that predator control efforts have provided to greater sage-grouse populations. Numerous studies

indicate that predation by eagles, foxes, coyotes, badgers, ravens (a major predator that is now a protected species) and others is 

a leading cause of greater sage-grouse mortality in the West. In a BLM funded study by Montana Fish, Wildlife and Parks, 

depredation by nest predators was the primary cause of nest failure in both 2010 and 2011. Almost 90 percent of hen mortality 

was attributed to depredation. The report states, “We did not observe any direct negative impact of livestock on nesting grouse 

(e.g., trampling of nests)” (Foster, 2012). Preliminary research conducted in Wyoming shows that predation can account for up to 

80 percent of greater sage-grouse chick mortality, and that predator control efforts are a crucial component of greater 

sage-grouse conservation (Orning-Tschampl et al., study pending). Predation of nests (eggs) and juveniles is a serious problem for 

greater sage-grouse populations; this is partially habitat-related and partially a matter of predator levels and distribution; however, 

regardless of the quality of habitat, some predators exist today at exponentially elevated levels, and non-indigenous predators 

(such as the red fox) have been recently introduced into many greater sage-grouse ranges (Baxter et al. 2007).

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72. The issue of predation merits further evaluation and, as it varies from area to area, is best addressed at the local level. EISs and 

SEISs should recognize the importance of predation to grouse numbers and provide adequate authority and flexibility to local land 

managers to use all available control methods.

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73. When the population level of a wildlife species is low and can no longer compensate for predation, pressure from predators then 

becomes the single most limiting factor of survival for that species. The sage grouse is at that critical stage. Iron County realizes 

that the federal land agencies do not have the authority to manage predation, and habitat rests with the state wildlife agencies and 

USDA, Animal Plant Health Inspection Service, Wildlife Services (APHIS WS). However, we encourage a lengthy discussion on 

this subject to recognize the impacts predation is having on sage grouse. It will also be important that recommendations are made 

in the planning strategy to state wildlife agencies and APHIS WS on predator management in sage grouse areas. If predators, 

primarily ravens, are not controlled to relieve the pressure being placed on sage grouse, habitat enhancement project will be of no 

consequence to their survival. State wildlife agencies seem to have an aversion to recognizing this fact even after numerous 

research studies in all the western states supports selective removal of predators for sage grouse survival.

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74. The County supports the work of state and federal wildlife agencies to protect the sage grouse hatching areas through vigorous 

predator control. Appropriate monitoring by these agencies have established that predators such as coyotes, ravens, hawks, 

eagles all pose a threat to the sage grouse and are major factors in the decline of the sage grouse populations.

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75. Sirs, I worked on the sage grouse study . Here is the results of one study done in 1997. We radioed 9 hens 1069 made 2 attemps 

to hatch hatched 13 chicks from last attempt. I chick survived. 0.525 made one attempt ravens got her eggs. 1.559 hatched 13 eggs 

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only 5 chicks raised. 1.306 hatched 12 chicks 5 survived. 0.951 made one attempt and was killed on nest by coyote. 0.504 hatched 

13 eggs 2days later only had 2 chicks. We saw raven flying off with one chick. 0.475 was killed on nest by avian predator. 1.017 

made 3 attempts to hatch and was killed on nest by a coyote. 1.571 was killed on nest. Total attempts to hatch was 12 total eggs 

hatched was 51 total chicks that survived was 13. We found a ravens nest and found 18 sage grouse egg shell below it. So we know 

the ravens and coyotes are really doing some damage on the sage grouse. If we are ever going to get them to rebound we need 

to do some predator control. My good friend and trapper killed over 50 coyotes that winter. He can no longer hunt or trap as he 

is in bad heath. But I would hope we could get other trapper to help. By the way the study I did was in Shoshone Basin

76. Predator control must be implemented for sage-grouse to recover. Predator control should target mammalian predators and 

avian predators including: coyotes, bobcats, foxes, raccoons, skunks hawks, crows, raven and any other predator determined to

negatively influence sage grouse populations. Of course predator control efforts should be conducted in accordance to local laws 

and regulations.

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77. Most importantly, any projects implemented should be conducted with the goal to improve multiple wildlife species and interests. All Both emc0165GB

78. What is the problem with sage grouse. 1.The Federal Government protects raptors eagles, hawks, falcons, owls, and some 

carrion(and egg ) eating birds 2.The Federal Government bans the poison 1080 and others, that kill predators, coyotes, bobcats,

raptors, skunks, foxes, raptors, carrion eaters etc. For obvious reasons. 3.The Federal Government attempts to ban wildfire , and 

almost eliminates land treatments , chaining, prescribed fire etc. 4. The Federal Government reduces livestock numbers.

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79. Protection should be ensured not just for sage-grouse, but for other sage-grouse obligate species (Sage Sparrow, Sage Thrasher, 

Brewer's Sparrow, pygmy rabbit, etc.)

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80. Predators have a huge impact on sage grouse chick survival. I believe raptors of all stripes are hard on them, but especially ravens. 

I would like to see some form of raven control take place, and am offering my ranch as a place to use as an experiment. I would 

be open to anything from a Department of Fish and Wildlife supported hunt, to a graduate student placing poisoned eggs. I would 

also like to see some agency place a bounty on coyotes during critical brood rearing times. Eliminating perches is a great idea.

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81. Predation needs to be considered as a reasonable factor on the impact to sage grouse populations in the EIS. Based on

observations by numerous local ranchers, the impact is a critical factor to consider. Where studies are lacking, the EIS should take

into account what is available and give serious weight to the ODFW plan that states a rigorous data collection is needed in the

sampling schemes for lek counts. The same is true for many areas of the sage grouse habitat and other wildlife issues. Discussing

science is not the same as doing science. The basic principles of doing science requires a good study design, rigorous data

collection, and analysis. • Population ecology—Understanding annual survival and seasonal mortality is critical and largely

undocumented in Oregon. Similarly there is still a need to refine methods to estimate population sizes. Similarly, development of

a probabilistic sampling scheme for lek counts is paramount to provide some level of rigor to the data collection. (Oregon Dept.

Fish and Wildlife, April 2011. Greater Sage-­Grouse Conservation Assessment and Strategy for Oregon: A Plan to Maintain and

Enhance Populations and Habitat). • Survival of sage-grouse is typically high with more than approximately 60% of a cohort 

surviving from year to year. • Of the 40% of a grouse population that succumbs to mortality during a year predation accounts for 

approximately 85% of reported non-hunting mortalities and 79% of nest failures (Bergerud 1988). • Specifically, predation on nests 

and young chicks can be high and affect populations (Gregg et al. 1994, Aldridge and Brigham 2001, Schroeder and Baydack 2001, 

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Coates 2007). However, few studies have indicated that predation is a major limiting factor to sage grouse. • In Idaho, predation 

was the most common cause of death for radio-marked sagegrouse (83% of males and 52% of females) in a hunted population 

(Connelly et al. 2000a) where apparent survival was 71 and 68% for male and female sagegrouse, respectively. Coyotes (Canis 

latrans), badgers, (Taxidea taxus), bobcats (Felis rufus), and several species of raptors are common predators of juvenile and adult 

sage-grouse throughout most of sage-grouse range (Hagen 2011). Additionally, coyotes, badgers, common ravens (Corvus corax), 

and black billed magpies (Pica pica) commonly prey on sage-grouse eggs (Hagen 2011).

82. Some manageable issues, ideas and options that should be addressed in and EIS can be broken down into the following principal 

points. 2. Predation

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83. Predation is an increasing problem throughout the west. I have been seeing a noticeable increase in coyote, fox, raccoon and 

skunk populations. The increase in the coyote and fox populations is I believe largely due to the increasingly bad public opinion of 

trapping that historically helped control these populations at no cost to the taxpayer. The raccoon and skunk population increases 

may be natural, but are having devastating effects on all ground nesting birds. Programs to improve public perception of the 

important role trapping plays in controlling predation of sensitive species at no cost to the taxpayers and I or the government 

would be a good first step to remedy this over the long term.

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84. The conservation of rangelands for livestock production is extremely important, not only to the sustainable production of food 

and fiber for the United States and worldwide markets, but also to providing quality habitat to support wildlife populations.

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85. From the mid 1970’s to now there has been a great deal of change. The predator control has slacked off. The coyote control is 

down due to most of the poisons are off the market,the liability of workers carrying fire arms on the job and the price for the pelts 

is down. The number of coyotes has risen but goes in cycles. In 1972, a revised Migratory Bird treaty with Mexico was signed that 

protected the predators (hawks, ravens, crows, magpies and eagles) and other birds. Since then the hawks and eagles have steadily 

increased. Where we have the largest explosion in population is in the crows, ravens, and magpie numbers. These predators and 

or scavengers will get all sizes of sage grouse from eggs, chicks, young flyers and adult birds. On any spring or summer day you can 

see 5 to 20 hawks flying and 40 to 50 crows, ravens and magpies. They have been around all spring and I would bet that they have 

been feasting largely on sage grouse. The coyotes are also looking to feed on them if they can find and catch them. Other 

predators are skunks, badgers, ferrets, and ground squirrels.

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86. I am also concerned with the way the habitat guide lines are interpreted and presented. I admit that I do not know what all the 

recommendations are but when I read them it sound like the ground will only be managed for the sage grouse. There are other 

wild life out here living in the same area. Some of the wild life have conflicting needs so both cannot have the optimal habitat but 

they still live in the same ecosystem. We cannot manage the land for all animals at their optimal habitat. We need to find a middle 

ground where all animals (wild life and livestock) can flourish.

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87. Critical Wildlife habitat for native species (summer and winter) needs to be identified and protected. Again, land trades and 

purchases should be used to increase these areas and provide more protection.

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88. In addition, when predator control decreased sage grouse numbers declined as well. Predators have always been a problem for 

sage grouse. They are keen to find nests with eggs or young birds that cannot protect themselves.

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89. The section on Treatments to Increase Forage for Livestock/Wild Ungulates, page 16 is very single-species oriented and does not 

uphold the principles of multiple-use management. The socio-economic impacts of these conservation measures should be 

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analyzed in the EIS. In addition, many of the sagebrush ecological sites can only be maintained through periodic disturbance,

releasing the perennial grasses and forbs before they become too scarce from competition with shrubs, and so scarce that 

non-native invasive can establish on the site. Treatments of sagebrush are not always intended to increase livestock forage, but are 

useful ways to maintain the integrity of the ecological site.

90. BLM has indicated that the findings of the Sage-grouse National Technical Team's report "A Report on National Greater 

Sage-Grouse Conservation Measures" will be relied on to establish conservation measures. We are concerned that this report, 

which is supposed to represent the best science available, fails to mention three significant causes of sage-grouse mortality: 

hunting, predation and disease (see page 6 of the report). The report does consider the impacts of Wild Horse and Burro 

Management on sage grouse (see Page 18) but fails to look at the impacts associated with hunting, predators [wildlife] and disease. 

By failing to look at the entire picture, the findings of this report become suspect.

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91. Sage grouse mortality via hunting, predation and disease must be analyzed in the plan amendment process in spite of the failure of

the national technical report to address these issues.

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92. The BLM should discuss predator control and limitations on hunting with state wildlife managers as more effective ways to 

increase sage grouse populations.

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93. Population augmentation is a wildlife management tool that should be considered for sage grouse in local areas where the need

exists.

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94. Thus, intensive livestock management which diminished the frequency and size of wildfires, and concerted predator control which 

greatly reduced GSG loses to these killers, are management actions in the Great Basin that seem to be highly relevant to the 

biology of the GSG and help explain the trajectory of their populations over time. As shown in Figure 1 on page 17 herein, it is 

reasonable to assume that a return to effective management to increase livestock grazing levels, reduce fire fuel loads and wildfire 

impacts, and increase predator control would result in another significant upward trend in GSG populations. In contrast, 

proposed GSG conservation measures to provide heavier cover levels through further livestock grazing reductions, and the lack 

of conservation measures to address ever increasing predation levels, are a prescription to assure that GSG populations will 

ultimately decline. Heavier cover for GSG translates to higher fire fuel loads across the landscape, and substantial fuel loads make 

large-scale wildfires inevitable in many sagebrush communities. Repeat burns increase the likelihood that plant communities will 

shift toward cheatgrass dominance, which in turn increases wildfire frequency, eliminating the ability of sagebrush communities to 

re-establish. Thus, conservation measures that intend to benefit GSG by providing them with more hiding cover will ultimately 

harm the species by converting significant swaths of existing habitat to annual grasslands that provide no habitat value for GSG. 

This will concentrate the remaining birds in an ever shrinking area, making them more vulnerable to poorly controlled predator 

populations

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95. If regulatory/policy controls to minimize human disturbance have failed to allow GSG populations to flourish within the vast 

wilderness areas and other nationally designated conservation areas, then it is unreasonable to apply such draconian control 

measures to broad landscapes beyond the boundaries of these areas in the vain hope that such regulation will somehow work in 

other locations. To implement regulatory mechanisms that are certain to severely interfere with other valid existing uses of the 

landscape and negatively impact local and regional economies in the face of evidence that such mechanisms did not reverse the 

plight of the GSG in these nationally designated areas would be unreasonable, irrational, and counter-productive. Instead, if the 

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minimum effective population of GSG necessary to protect the species from extinction cannot be supported within such 

nationally designated areas, then management practices that were in place when greater sage-grouse populations dramatically 

increased from the mid 1800s to early 1900s need to be identified and implemented again in other areas, including increased 

livestock grazing to reduce wildfire fuel loads, and concerted predator control practices

96. Enhance Current Populations Alternative Given the fact that current GSG populations exceed the minimum effective breeding 

population by 70 to 107 times, it is clear that GSG are not at imminent risk of extinction, and therefore do not legally qualify for 

listing as “endangered” under the ESA. The FWS Findings express concerns regarding rapidly declining GSG populations between 

the late 1960s and late 1980s, and continued downward population trends (although at a slower rate) from the late 1980s to the 

present. The FWS Findings fret that such downward trends in GSG populations may threaten the species with extinction at some

point in the future. Given the recent (1985 – 2007) rate of decline of 1.4% annually (FWS Findings, 3 page 13922), it would take 

300 to 330 years for the current greater sage-grouse population (350,000 to 535,000 birds) to shrink to the minimum effective 

population (as high as 5,0000 birds). Theorizing about what might happen three centuries from now reaches well beyond the 

foreseeable future. Thus, the FWS Findings expression of concern about long-term outcomes from the continuation of recent 

GSG population trends does not rise to a determination that the species is threatened with extinction in the foreseeable future. 

A concern that populations may reach levels small enough to put them at risk of extinction at some point in the future does not 

meet the legal requirement to allow listing under the ESA unless the risk is likely in the foreseeable future. Given current 

circumstances, any such risk for GSG is likely 300 or more years distant, so the species does not legally qualify for listing as 

“threatened” under the ESA at this time. Nevertheless, it is reasonable to consider an alternative that would facilitate an increase 

in GSG populations, so long as that alternative does not negatively impacting existing socioeconomic uses occurring on BLM and 

FS administered lands. An analysis of the past management history within the Great Basin indicates that GSG flourished when 

livestock grazing levels were significantly higher than they are now. During this same period, large wildfires in the region were very 

infrequent (likely due to lower wildfire fuel levels as a result of close grazing), and concerted predator control measures were 

practiced. These management actions could be put into practice again to benefit GSG without harming the existing socioeconomic 

climate, but rather enhancing it. In fact, it is reasonable to argue that the FWS Findings get it wrong when they conclude that there 

is a lack of regulatory mechanisms in place to protect the GSG. Instead, many of the regulatory mechanisms currently in place are 

harming the species. For example, regulations restricting livestock numbers and use levels increase fire fuels across the Great 

Basin, and these regulations have resulted in a dramatic increase in large wildfires in the region in recent decades, which has 

destroyed GSG habitat to the detriment of the species. Repeated fire has led many sagebrush communities to convert to 

cheatgrass dominance, which assures that the habitat will remain unfit for GSG into the foreseeable future. Rules restricting

predator control, regulating the use of poisons and baits, and protecting ravens have resulted in excessive GSG loses due to 

predation. Whenever a species like the GSG with a relatively low reproduction rate (FWS Findings, 3 page 13916) loses the vast 

majority of its eggs to predation, and can trace more than 80% of the mortality of those individuals that manage to hatch to 

predation (FWS Findings, 3 pages 13930, 13971, and 13972), its populations can be expected to decline. Again, it appears that

existing rules are harming GSG populations, not a lack of adequate rules.

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97. is reasonable to analyze an alternative to eliminate existing regulatory/policy mechanisms that are harming GSG, or replace them 

with rules that again implement management practices that allowed the species to rapidly increase in the past, at least within the 

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Great Basin. Because current GSG populations greatly exceed the minimum effective population, any management alternative that

would stabilize or increase the current population level would eliminate any perceived justification to list the species under the 

ESA. However, given the multiple-use mandates applicable to BLM and FS administered lands, consideration and analysis of such 

an alternative to help GSG populations is only reasonable if it does not negatively impact other valid existing uses. An alternative 

to increase livestock grazing to reduce fuel loads and minimize wildfire impacts, and to return to concerted predator control

practices is reasonable because it would benefit GSG without harming the existing socioeconomic climate, but rather enhancing 

it

98. Fences are a huge problem for sage grouse. Studies have shown that every mile of barbed-wire fencing causes a certain number of 

sage-grouse deaths, every year, due to sage-grouse hitting the wires. This is a continuous loss to the population. Yet the BLM (and 

the Forest Service, for that matter) continue to build more fences. The only reason for building more fencing is to attempt to 

influence the movements and reduce the damage caused by livestock. The option of reducing or eliminating livestock use of the 

public's lands is seldom considered. Sometimes "jack-leg" fencing is used in place of barbed-wire fencing. While wooden fences do 

not kill sage-grouse, sage-grouse are still threatened by them, as raptors use them as places to perch and pounce on passing prey. 

Also, cattle use fence-lines as trails, and these wide trails are also used by coyotes, foxes, and other predators, thus making it 

easier for them to nab sage-grouse chicks.

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99. Understanding the focus and limitations of the process under discussion here, at some point, through some mechanism, 

recognition of the increased role natural predation has played in the last several decades of Greater Sage Grouse population 

fluctuations, cycles and overall population reductions should be attempted.

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100. Fences will also cause similar adverse impacts to sage-grouse and sage-grouse habitat. Fences fragment habitat as sage-grouse seek 

to avoid areas close to fences, likely to avoid predation, as fences provide cover and perches for potential predators. Sage-grouse 

may also collide with fences, resulting in direct mortality. Finally, similar to powerlines and communication towers, fences 

threaten to spread invasive plants and noxious weeds, threatening the integrity of the habitat for sage-grouse.

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101. Predation is a natural threat common to all upland game birds, including the greater sage-grouse. Predators include animals that 

consume sage-grouse as well as those that will consume sagegrouse eggs. Although there are many predators that will consume 

sage-grouse, none specialize on the species. Sage-grouse have co-evolved with a variety of predators, and thus have adapted 

biological and behavioral strategies for avoiding significant mortality effects.

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102. Sage-grouse are perhaps most vulnerable to predators during nesting, when they remain on the ground to protect their nests. 

Nests with greater grass and forb cover, however, show a decrease in predation rates. Nesting success is positively correlated 

with the presence of big sagebrush and sufficient grass and forb cover, and thus nesting success is greater in unaltered habitats 

versus altered habitats. Generally, studies have found that low nest success due to predation is ultimately related to poor nesting 

habitat

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103. An unnatural increase in predator populations may threaten sage-grouse survival rates. Landscape fragmentation, habitat 

degradation, and human encroachment all have the potential to increase predator populations. For example, infrastructure that

increases suitability for ravens may limit sage-grouse populations. Potentially as a result of land-use practices that favor high 

predator abundance, raven abundance has increased as much as 1500 percent in some areas of western North America since the 

1960s, and thus have become an increasing threat to sagegrouse persistence.

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104. The Fish and Wildlife Service concluded that where habitat is not limited and is of good quality, predation is not a significant threat 

to the species. However, the agency remains concerned that continued landscape fragmentation will increase the effects of 

predation on this species, resulting in more significant effects on sage-grouse productivity and persistence.

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105. As the climate warms, associated climate impacts such as shifts in timing and amount of precipitation and changes in seasonal high, 

low, and average temperatures may significantly alter distributions of individual species and ecosystems. For example, some 

species that can only survive in cooler weather may be pushed further north or higher in altitude to seek cooler climates. This shift 

may affect all plant and animal species, as the equilibrium of predator and prey species shifts and the natural balance of ecosystems 

is altered.

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106. A better use of money would be to actually improve the range where the birds live. But there will be NO ANSWERS OR 

IMPROVEMENT IN THEIR HABITAT UNTIL THE PREDATORS ARE CONTROLLED. The wolves, the coyotes and crows or 

ravens are devastating to success of these ground nesting birds. It is sickening to watch a crow or coyote steal the eggs while the 

mother bird chirps her complaint, but to no avail. The predator always wins.

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107. The EISs and SEISs must analyze the impact of predation as a leading cause of greater sage-grouse mortality, and must analyze the 

benefits that predator control efforts have provided to greater sage-grouse populations.

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108. 4. page 6, Goals and Objectives, paragraph Goal. The focus is on "conserving, enhancing or restoring the sagebrush ecosystem." 

There are other factors that directly or indirectly affect sage-grouse numbers; i.e. predation. It is common knowledge that crows 

and ravens destroy sage-grouse nests. Consideration should be given to having a bounty on crows and ravens for 'X' number of 

years to determine the benefit (increased successful nesting) for sage-grouse. With a successful hatch sage-grouse chicks are 

subjected to increased predation by coyotes and many other mammals. Even if temporary, an extended hunting season and/or 

bounty should be considered for 'X' number of years and a determination made of the increased survival rate of sage-grouse 

chicks. SRCA feels there needs to be more focus on predation. Studies have found interesting results in regards to sage-grouse 

predation. The history of predator control in Elko County, Nevada shows the direct impact of predators in relation to 

sage-grouse populations. (McQuivey, 2003)

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109. Predators have been on the increase in recent years. Ravens are known to destroy nests. Predator control should be used as a 

tool. As a child and young adult, I never saw ravens here.

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110. Please remember these landscapes often provide essential habitat to multiple species-some of which require old-age sagebrush 

canopies and others requiring early seral conditions. A well-managed landscape is managed not to maximize value for anyone 

species (whether cattle or sage grouse) but rather maximizes overall value by 'optimizing', or maintaining viable habitat for

multiple species (including wildlife and livestock, Oanvir et al 2005).

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111. Cattle, mule deer, pronghorn, pygmy rabbits, sagebrush passerines, cutthroat trout and cattle can all thrive. This type of rotational 

grazing strategy (providing rest for recovery) meets all four rangeland health guidelines, and provides a 'drought reserve' in that if 

needed pastures planned to be rested season-long may be grazed late in the year (during dormancy) if drought occurs.

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112. The EIS must address the role of predators on species population and alternatives for a variety of enhanced predator control 

efforts.

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113. The concept of "connectivity" could be interpreted in such a way so as to expand priority habitat areas. The EIS must define 

"connectivity" and the specific parameters for determinations and boundary FS- establishment. Corridors should not be used as 

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de facto priority habitat areas.

114. The EIS should specifically analyze the natural cycle of wildlife populations and how they relate to sage-grouse in the western U.S. All Both emc0310GB

115. The EIS must define "migration or connectivity corridors". How will the agencies identify such corridors especially in light of the 

fact they may be broken and fragments by natural processes such as pj woodlands or other non-anthropogenic activities.

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116. Any EIS or SEIS must also explicitly recognize the following points: The beneficial effects of predator control must be addressed 

in sage-grouse management strategies. Specifically, raven control could be beneficial to nest and chick survival.

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117. Other Issues to Be Considered • Balancing of Species Another aspect that BlM must consider is the balancing of various 

species. While it is understandable that BlM's focus is on sage grouse, some of the policies being enshrined in the IMs and NTT 

report recommendations will result in pitting the sage grouse, which is not yet listed, against other endangered species that are. 

For example, pinyon-juniper habitat, which is criticized by the new policy, is valuable for other endangered species such as some 

species of raptors and hawks. While BlM is right to implement policies that are helpful in avoiding the listing of sage grouse, the 

agency must also be mindful that its policies can have unintended negative consequences for other important species. BlM must 

include a detailed discussion in its EIS regarding how it has evaluated and balanced such considerations.

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118. VI. BLM and USFS Must Evaluate a Reasonable Range of Alternatives In light ofthe different reasons for sage-grouse habitat decline 

from region to region, and the fact that there remains significant sagebrush habitat in Wyoming and Nevada, each sub-regional EIS 

should carefully evaluate a reasonable range of alternatives to the conservation measures and regulatory mechanisms proposed in 

the NTT Report. Some of the contemplated measures may not be necessary or effective in each region or sub-region. Examples 

of such alternatives include, but are not limited, to the following: C. The Better Predator Control Altemative For regions and 

sub-regions where predation is a major factor affecting sage-grouse populations, the ElS should evaluate a Better Predator 

Control Altemative to assess the impacts that would be associated with implementing more effective predator control measures.

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119. After much study, we found that Sage Grouse did not seem to be on the decline in our area. The number one factor our studies 

showed that made them decline slightly in numbers was predators such as racoons, red fox, skunks, crows, and hawks.

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120. Research has found that greater sage-grouse can be applied in conservation planning as an "umbrella species," meaning one whose 

"conservation confers protection to a large number of naturally cooccurring species" For example, Rowland et al. found that 

"some species, especially sagebrush obligates such as pygmy rabbit and Brewer’s sparrow, may receive substantial conservation

benefits if habitats for sage-grouse in the Great Basin are the focus of conservation planning and restoration." Other species of 

conservation concern that would benefit from greater sage-grouse conservation, just in the Great Basin, include: · Wyoming 

ground squirrel · Pygmy rabbit · Vesper sparrow · Sage thrasher · Sage sparrow · Merriam’s shrew · Sagebrush vole · White-tailed 

jackrabbit · Brewer’s sparrow · Gray flycatcher · Pronghorn · Green-tailed towhee · Northern grasshopper mouse · Dark 

kangaroo mouse · Western burrowing owl · Prairie falcon · Short-eared owl · Northern harrier

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121. An inevitable consequence of any large, ground-disturbing project is the increased risk of colonization by invasive, non-native 

species. In the sagebrush-steppe community, in addition to the slow regeneration of sagebrush, the biggest threat is the invasion 

of cheatgrass. Cheatgrass has the potential to completely alter the ecosystem it invades, increase fire frequency, and prevent the 

establishment of sagebrush and native grass and forb understory. When cheatgrass becomes a dominant presence on the 

landscape it can change the fire regime over a very broad area, causing hotter and more frequent fires that destroy nearby 

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sagebrush plants that were not impacted by the original construction project. Even assuming revegetation was successful, there is 

an increased risk of predation on nests by newly accommodated synanthropic predators. Raven, coyotes and other opportunistic 

predators will benefit from an open corridor, putting sage-grouse at further risk. The introduction of aggressive fauna and flora 

invasive species are often linked to human disturbances, such as new roads and construction of facilities associated with any 

proposed wind project in sagegrouse habitat.

122. Predation is a significant factor in managing Sage-grouse habitat. A paper, based upon 3 years of research, was recently published 

in Ecological Processes, a Springer Open Journal, titled Landscape Features and Weather Influence Nest Survival of a 

Ground-Nesting Bird of Conservation Concern, the Greater Sage-Grouse, in Human-altered Environments (Attachment E) has 

identified several methods for conserving Sage-grouse but points out that there is a specific lack of understanding of the 

relationship between energy development and nest and brood failure. Consequently, more research is needed before determining 

what mitigation measures would be most effective. Another recent paper, Identifying and Prioritizing Greater Sage-Grouse 

Nesting and Brood-Rearing Habitat for Conservation in Human-Modified Landscapes (Attachment E), published in the journal 

PLoS ONE (Attachment F) recommended that constraints on human activity be focused in specific areas rather than applied on a 

regional scale. Importantly, mitigation measures should be utilized primarily in areas of high habitat value. As such, mitigation 

should aim for a specific percent reduction in the risk of nest failure by contemplating constraints on infrastructure or water 

management activity within a given distance of a high probability of occurrence of nesting habitat. It is critical for a distinction to 

be made between low-performance habitat for nesting and brood rearing and high-performing habitat. Nevertheless, we 

recognize that measures to avoid or minimize the creation of new anthropogenic risk factors in high-performance habitat are 

needed along with steps to reduce existing risk factors that render a habitat low-performance such as burying utility lines, 

removing utility poles, and discouraging the use of facilities by avian predators would reduce predator density and effectiveness. 

In all, we strongly recommend that the agencies work closely with the oil and gas industry in developing site-specific measures that 

achieve the desired result of lowering predation risk in developed areas.

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123. Sage-grouse are a group of three separate species of grouse dependent, at least in part, on sagebrush ecosystems in the Western 

United States. As these ecosystems/habitats differ widely across the entire range, and even more so over the historical range, 

understanding their function is imperative in any plan or strategy to help protect, or enhance them. Other species of wildlife are 

also dependent on the same rangeland, and are further reason that single-species management, in lieu of ecosystem management 

for all species, should not be the management criteria for all dependent species. Sage grouse and related species also cross all 

classes of land ownership, and management. An all lands strategy should be implemented for the protection of the species, 

economic activities, dependent communities, and rangeland health.

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124. All stakeholders throughout the West, whether their goal is sage grouse recovery or merely avoidance of additional regulations, 

should be able to agree that sage grouse recovery is an outcome that best provides certainty for both sage grouse persistence and 

for industries that do business and communities who live within its range. At the same time, a strong sage grouse conservation 

plan, founded in establishing core habitats where land uses are made compatible with maintaining healthy habitat, is the 

cornerstone for protecting not only the grouse itself but also a broad diversity of other sagebrushdependent wildlife. Many of 

these species are also declining and may soon become candidates for ESA listing in the absence of a comprehensive conservation 

strategy.

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125. We have attached a map of proposed Sage Grouse Areas of Critical Environmental Concern, a selection of the highest-density 

sage grouse populations with the most pristine and defensible habitat. We believe that all high-density sage grouse lek complexes 

meet the relevance and importance criteria for ACEC designation as a wildlife resource, due to the BLM Sensitive Species status 

and current trend toward listing, and the strong fidelity of these birds to particular breeding, nesting, and wintering habitats. These 

areas also feature habitat for an entire sagebrush ecosystem encompassing a variety of other sagebrush-obligate species including 

sage sparrow, sage thrasher, Brewer’s sparrow, pygmy rabbit, and white-tailed prairie dog, as well as other species such as swift 

fox, ferruginous hawk, Wyoming pocket gopher, and burrowing owl, further underscoring their importance and relevance as a 

wildlife resource.

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126. At minimum, the NEPA analysis should address the following: • Assessing the impacts of BLM-permitted activities on predation 

patterns, particularly with regard to coyote control, which results in an increase of smaller meso-predators that prey on grouse, 

eggs, or chicks at a much higher rate than do coyotes.

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127. In addition, an alternative should be developed that emphasizes fire suppression and predator control. All Both emc0345GB

128. In this section, the authors focus primarily on land health assessments and vegetation as a means to measure and mitigate livestock 

use. The NTT does not take into account any quantification of predation on sage grouse (e.g. where an abundance of predators 

and/or hunting pressure can create population "sinks" for the species").

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129. Any conservation strategy needs to address the roles of predation and disease on sage grouse numbers and support the state and 

local government programs;

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130. The sage grouse is found in areas where there are numerous predators, including coyotes, foxes, mountain lions, ravens, eagles, 

hawks and wolves, to name a few. Predator populations are at an all time high in the western states. While research has 

acknowledged the role of raptors on nesting success, the proposed interim conservation measures and most notably the NOI 

entirely omit the role of predators in direct sage grouse mortality. Ex. 1 at pp. 2-3 (noting the correlation between predator 

control and sage grouse numbers); Ex. 1A pp. 9-13. DOI and BLM’s support for predator control has been hostile at times or 

lukewarm at best. The omission of predators promotes the erroneous conclusions regarding the impacts of land uses on sage 

grouse numbers.

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131. 1. Role of Big Game Animals on Herbivory The NOI and Technical Team Report conspicuously omit the role of big game on 

herbivory. This is a material flaw, because big game populations have increased significantly over the last several decades. Ex. 1A 

p. 5 (big game numbers were low in days of early western settlement). In Wyoming, elk numbers continue to increase, often in or 

overlapping with sage grouse habitat areas. Elk are ungulates with the same or very similar habitat impacts as cattle. The elk 

populations are, in fact, significantly impacting sagebrush on wintering concentration areas. They have eliminated sagebrush at the 

Hardware ranch, for example. Some of these wintering areas are also sage grouse wintering areas. Sage brush is an absolute 

requisite to wintering sage grouse. on summer ranges, elk do not eat sage brush, but they concentrate on forb and grasses. In 

addition, deer and antelope, which are browsers that will consume sage brush, have also increased. Livestock do not eat the sage 

brush, only forbs and grasses that might form an understory for the sage brush. Omission of the browsers’ impacts, their numbers 

and the issue of direct competition must be rectified in the RMP amendment process.

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132. Sage-grouse mortality via hunting, predation and disease must be analyzed in the plan amendment process in spite of the failure of All Both emc0376GB
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the national technical report to address these issues.

133. The BLM should discuss predator control and limitations on hunting with state wildlife managers as more effective ways to 

increase sage-grouse populations.

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134. Things that haven't been addressed are predators and hunting. Not only are the predators numbers increased by several hundred 

percent their opportunities have been enhanced. We have built power lines throughout our country and every few poles down 

the line you see a bird of prey. They are very good hunters without the advantage. their numbers have also increased many times 

over. there are other predators such as ravens} red fox ground squirrels by the millions} raccoons that never used to be in our 

area and I am sure in many other areas. There number are un checked

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135. One major issue that needs to be addressed is the predator control. We feel this is an issue that really needs heavy attention in 

your management strategies, which includes coyote and raven control. The ravens cause a huge problem during our calving season 

, by eating at soft tissue (eyes, rear ends ) until death of a calf. By controlling the raven population, the sage-grouse chick 

population will have a higher survival rate.

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136. There are a number of other factors that should be considered in cause and effect of SSG population variations, such as: Wolves: 

All the earlier journals and other documents confirm high wolf populations (and few, if any, Coyotes) in the 1800's and early 

1900's. It is highly possible wolves were a significant predator of GSG during that period.

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137. Ravens and Coyotes: I firmly believe these two predator species have had, and continue to have, significant effect on GSG 

reproduction levels.

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138. Ban on use of 1080: This resulted in a significant increase in coyotes, ravens, hawks, and eagles; all predators of GSG All Both emc0388GB

139. I believe that this plan should have some predator management and horse management, the BLM has historically fallen short of 

maintaining the horses AML's in this state, horses have a greater impact on the habitat through their repeated use of areas unlike 

livestock were they are only in a area for short periods and are controlled.

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140. To begin with the wildlife picture as a whole has changed. There are much fewer mule deer in this area today. Conversely elk are 

present whereas they were not here until recently. The number of ravens have increased dramatically over the years. Often, you 

can drive through parts of our family ranch and see a raven perched on fence post after fence post after fence post. Ravens love 

eggs and especially easy prey from a newborn calf to a cow laying down calving. While we are not wildlife biologists it seems quite 

logical that elk would compete for the forage used by sage-grouse and the ravens are a nasty predator that preys upon their eggs 

and young.

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141. Public land is public and serves many uses besides ranching, however responsible livestock grazing is crucial to managing public 

land. It only makes sense that livestock grazing be a key component to not only managing for sage grouse, but wildlife in general.

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142. Bottom line...because our livelihood depends on public land grazing we CARE about public lands. Because our livelihood depends 

on public land grazing we are very willing to work with efforts aimed at wildlife conservation, including that of the greater 

sage-grouse. Removing livestock from the public rangeland would be detrimental to wildlife, the general public, ranching, and the 

local economy.

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143. Predator control is one of the major problems facing the sage grouse as there is not enough of it. Ravens, eagles and coyotes take 

a toll on the young chicks and has a direst negative affect on the sage grouse population. I am not saying these animals need to be 

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eradicated, just that if there was more predator control than there currently is the sage grouse population would see a rise. I have 

personally see the raptors circling on water holes that the chicks are at waiting for a chance for one of the to come out into the 

open.

144. The impact of predators must be addressed in sage-grouse management strategies. Predator controls used to limit the loss of 

eggs, juveniles and mature sage grouse will need to be carefully balanced with the simultaneous need to control other species 

which might negatively impact forage or cover but which are also vulnerable to the same predators. Predator density in relation 

to historical levels, distribution and relative impact should inform management decisions. Elevated levels of native predators and 

the presence of non-indigenous predators should be incorporated into management strategies. Again, the local working group 

model should be utilized to determine and implement the measures which are most likely to benefit the species.

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145. Avian and mammalian predation and hunting both have the potential to reduce population-level survival of greater sage-grouse. 

PCW's greater sage-grouse study evaluates cause-specific mortality when possible. Mortality for most seasons and for most 

grouse age cohorts is predominantly attributed to avian and mammalian predators. During fall hunting seasons, in areas of PCW's 

study site open to hunting, up to 30-40% of tagged birds are killed by hunters. These hunting mortalities include all ages and sexes 

of grouse.

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146. While BLM does not control predator management or hunting activities, the BLM should evaluate enhanced coordination with 

state and federal management agencies to identify and implement hunting closures or predator control measures where those 

sources of mortality have a major impact on population-level survival of greater sage-grouse.

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147. Unusually severe predation of Sage Grouse should not be underestimated. Many years of land management decisions involving 

promotion of rapt or friendly power lines and structures has not occurred without some undesirable affects. These practices for 

new and previously installed structures should be reviewed and re-evaluated in potential Sage Grouse locations. In addition 

control programs to discourage corvid nesting and persistence should be considered in specific Sage Grouse areas exhibiting 

excessive numbers of these birds.

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148. "Fit transmission towers with anti-perch devices." It doesn’t matter what guidance is in place, BLM typically allows all manner of 

clearly hazardous transmission designs. For example, in minimal analysis for SWIP, Ely BLM in 2011 defied all current guidance on 

limiting guy wires that are collision hazards for birds and bats. It authorized what appears to be the world’s worst design towers 

with myriad raven nesting and sites. Anti-perch devices currently in use may fall off, be dislodged, etc. as occurs with such devices 

on wind MET towers. See WWP China Mountain DEIS comments. All of this must be accompanied by a coordinated effort to 

remove artificial upland water developments for livestock, as well as remove large herds of livestock that provide carrion and 

other sources of food that subsidize unnaturally high raven and mesopredator populations.

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149. Areas of low biological value and low energy potential (19% of eastern range, Fig. 3) represent low conflict opportunities for 

sage-grouse. Our analyses document the importance of these areas in maintaining connectivity to high value core regions in 

Montana (Fig. 3). Core regions with low biological value and low energy potential will be important in this regard, with restoration 

being one of the key strategies ... So this appears to be sacrificing areas important for connectivity if the habitat has high energy 

potential. How is “low biological value” being determined? By only relying on sage-grouse? Needs of a whole suite of other 

species may be minimized. See, for example, ICBEMP Wisdom Terrestrial Vertebrate analyses (2002) and species groups/suites. 

Agencies must apply integrated conservation planning, and not sacrifice other habitats, or displace damaging grazing like grazing 

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into other habitats that are important for other rare or declining species.

150. Other population segments of Greater Sage-Grouse, and species that depend on sagebrush habitat, such as the Sage and Brewer’s 

Sparrows, should also be considered in your environmental analysis, and best management practices for conserving these species 

should be included in any proposed management alternatives.

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151. Helping to preserve this species can also help protect many other plant and animal species, many of them are sagebrush specialists. All Both fla0057gb

152. Any plan amendment should include adequate site-specific analysis on anticipated impacts of motorized and non-motorized 

recreational activities, which often have little to no impact on wildlife. The impacts of motorized and mountain bike routes that are 

primarily used for recreation should not be "lumped in" with highways and other high-speed access roads.

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153. Other sagebrush obligate species, such as Sage and Brewer's Sparrow, pygmy rabbit, Wyoming pocket gopher, and myriad fishes, 

plants and mollusks should be considered in the environmental analysis and best management practices for conserving these 

species should be included in the proposed management alternatives.

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154. The grouse is a part of an ecosystem. It would be a shame to loose this bird, but to save it the areas in which it lives must protected 

as well as other wildlife that is a part of the ecosystem.

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155. Any EIS or SEIS must also explicitly recognize the following points: The beneficial effects of predator control must be addressed 

in sage-grouse management strategies. Specifically, raven control could be beneficial to nest and chick survival.

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156. The beneficial effects of predator control must be addressed in sage-grouse management strategies. I believe that the predator 

control measures practiced during the 1940’s through the 1960’s had a marked impact on sage-grouse and deer populations. 

Specifically, raven control can be beneficial to nest and chick survival. Nevada’s raven population has grown dramatically over the 

past 25 years and it has been stated we currently have extremely higher numbers of ravens over historic levels.

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157. Threats to sage-grouse should be avoided in all situations, especially livestock grazing and related influences thereof. This includes 

elimination of over grazing, fences, water developments and diversions, predator management, and leasing land to livestock 

interests where there is no profit being made by the federal government.

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158. Landowner members in the NESRSGWG request that the BLM analyze the impacts of predation on sage-grouse population 

sustainability. Increased regulation on BLM may not be enough to conserve sage-grouse populations if nothing is done to control 

predators.

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159. Management of predators is a must in maintaining a health Sage Grouse population. We request that a more aggressive predator 

control program be initiated in Sage Grouse populated areas.

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160. The impact of predators must be addressed in sage-grouse management strategies. Predator controls used to limit the loss of 

eggs, juveniles and mature sage grouse will need to be carefully balanced with the simultaneous need to control other species 

which might negatively impact forage or cover but which are also vulnerable to the same predators. Predator density in relation 

to historical levels, distribution and relative impact should inform management decisions. Elevated levels of native predators and 

the presence of non-indigenous predators should be incorporated into management strategies. Again" the local working group 

model should be utilized to determine and implement the measures which are most likely to benefit the species.

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161. We have seen greater numbers of predators in our area the past few years. Ravens, crows, and magpie have devastating effects of 

nesting sage grouse. We have also seen greater numbers of fox and skunks that were almost unheard of a few years ago. Predation 

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of sage grouse needs to be addressed.

162. It has been proven that it is impossible to determine an exact population number of sage grouse and we are therefore left to 

biologists to tell those making decisions for the management to lands what is required to satisfy the sage grouse needs. The biggest 

problem is that the sage grouse are so dumb that they are unable to read the literature written about their needs and 

requirements. For example, the biologist tells us that we can continue to hunt this species and that taking a given number will not 

affect the continuation of the population. Yet, the predator impact on the populations continues to have a large affect on the 

numbers.

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163. What has dramatically changed especially in the last 40 years is the ratio of predators to prey. Predator species have increased 

dramatically in relationship to prey species. Current prey species populations are extremely low compared to predator 

populations. Ravens, Coyotes, Mountain Lions, Badgers, Foxes, Skunks, Eagles, and Hawks have all increased dramatically while 

rabbits, mice, rats, snakes, deer, and sage grouse have declined. What do predators eat if there are fewer rabbits, mice, snakes, or 

deer? They eat sage grouse. The sage grouse's utilization as a predator prey species has increased with predator populations as 

easier prey populations have declined. Most Sage Grouse historical habitat was occupied when there were low or no predator 

populations. If future land use plans include increased predator populations then historical sage grouse reference populations are

grossly overstated. Future populations of Sage Grouse can not live in historical areas unless you remove the predators-they are 

too visible to predators and too easy to find. Predators associate leks as giant sized dinner plates!

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164. Finally, I believe that sagebrush obligate species, such as Sage and Brewer's Sparrow, pygmy rabbit, Wyoming pocket gopher, and 

myriad fishes, plants and mollusks should be considered in the environmental analysis and best management practices for 

conserving these species should be included in the proposed management alternatives.

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rmc0004RM

165. We recommend predator management. All Both rmc0023GB

166. Elko County believes that there are many scientific and philosophical questions that must be asked and answered prior to the 

implementation of conservation and preservation of the Greater Sage-Grouse habitat planning strategies. Is the current decline in 

wildlife caused by human impacts on public lands or are they a normality of nature? Many would like to believe that most of the 

west prior to settlement was abundant and profuse with wildlife and wildlife habitat. There have been many government 

sanctioned and funded explorations and settlements made in the 1800's into the west that document that there was no such 

abundance of wildlife in the region. Many explorer's and settlers journals documented the widespread lack of wildlife to sustain 

even the explorer's expeditions and travels. Many writing that they were forced to kill and harvest their own horses and dogs for 

food. As is well documented we know that wildlife migrate and move to habitat as needed for life. Could the changes in the wildlife 

and wildlife habitat over that past 100 years as the biologist state, been a common or natural occurrence? Does the presence of 

humans really have significant impact over such a diverse community of wildlife? Why do we believe that ecosytems that create

such a habitat are so vulnerable, weak and fragile that they cannot survive human presence? Do the wildlife biologists and scientists 

have sufficient pertinent, credible and reliable data available encompassing the past 200 years to establish baselines as to exactly 

what the wildlife populations were in specific regions prior to the recent years that indicate declines?

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167. The FWS listing decision also overlooks a significant issue in development of a conservation strategy, mainly recently released 

research from the Forest Service indicates that the number one killer of grouse is natural predators. 1 The Organizations note 

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that potential predator issues simply are not addressed in the FWS listing decision or the 2010 Conservation Measures.

168. Predation, along with mineral production and disease are the 3 greatest factors affecting the survivability of the sage-grouse, far 

over shadowing livestock grazing as a possible culprit.

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169. If pinyon juniper is restricted, will it later have a long term impact on other species (e.g., restricting raptor nesting habitat or 

reducing foraging lands?). The conservation of one species (e.g., sage grouse) should not have an impact on another species (e.g., 

raptors). These issues should be analyzed in the proposed EIS.

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170. More importantly initiate a worthwhile like you mean it predator program - coyotes, ravens and badgers. Almost every coyote 

den in springtime will have feathers and bird parts around it. My personal view is that predators have 90% of bird population issues.

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171. The Board supports the work of state and federal wildlife agencies to protect the Sage-grouse nesting and brooding areas through 

predator control. Appropriate monitoring by these agencies have established that predators such as coyotes, ravens, hawks, and 

eagles all pose a threat to the Sage-grouse and are major factors in the decline of the Sage-grouse populations. Documentation has 

shown that the number one cause of Sage-grouse nest failure is predation. The Board believes this issue should be thoroughly and 

accurately addressed within the PElS in order to allow Sage-grouse specific predator control projects on BLM managed lands.

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172. Over time it has been demonstrated, scientifically and historically, no practice is more important for restoring or maintaining a 

healthy balance and abundance in wildlife than that of carrying on sound predator control practices.

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173. Analyze: The U.S. Fish and Wildlife Services inclusion of ravens in. SOCFR21.43 "Control of Depredation Birds". A species 

assessment on the raven as a limiting factor to sage-grouse population stability and increase.

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174. 2-Predation- The impact of predation is directly proportional to the population of the prey. When Sage grouse numbers are low 

it is easy for predation to keep numbers down. This is the situation at the present time on many sage grouse areas. Information 

that would provide a side by side comparison of the raven population and sage grouse numbers over time in Nevada would be 

revealing. It has been reported that ravens have increased by 5% annually in Idaho. Historically Sage grouse numbers were 

highest when predator control was at its peak. To concentrate on Habitat issues, and relegate a factor such as predation to a

minor problem is unrealistic. Factual information rather than emotion is needed.

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175. We are aware of the strong propensity for wildlife managers and other government agency personnel to be biased against 

meaningful management of predators. We understand that more can be gained by way of regulatory expansion by focusing on 

keeping habitat deficiencies in the fore-front as opposed to being actively engaged in actions that do something to improve bird 

production. We also are not of the belief that predator control actions are a "silver bullet" which will cure all ailments. Having laid 

these two opposite poles of perspective, we maintain that some middle-ground needs to be included in management activities that 

will be considered for mitigation and enhancement. Based on assessments of limiting factors, which are preventing sage-grouse 

populations from achieving maximum potentials, predator control action steps need to be included as part of the tool box of 

options. Properly applied predator control prescriptions should be presented for evaluation in the draft EIS document.

All Both rmc0058GB

176. The analysis should include a complete analysis of predator impacts on the Grouse. Recent finding in other regions have noted an 

increase in predation attributed to an uncontrolled population growth of ravens. The Proposed Planning Strategy is largely silent 

on the issue of predator control with respect to management strategies for the Grouse. We strongly believe that no strategy can 

move forward without addressing a comprehensive review of predators and their impact on the Grouse.

All Both rmc0061GB, 

rmc0035RM
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177. The NPSGWG also recommends that the Sage-Grouse EIS include an analysis of the impacts of predation and hunting on the 

sustainability of the sage-grouse population in North Park.

CO Both emc0060RM

178. The issue of predators must be addressed as I believe predators are the greatest threat to sage-grouse. CO Both emc0069RM

179. There is an urgent need for BLM to develop and implement substantive conservation measures between now and 2015, when the 

U.S. Fish and Wildlife Service (FWS) will again consider whether the greater sage-grouse needs the protection of the Endangered 

Species Act (ESA). At the national level, through the establishment of the National Sage-Grouse Planning Strategy, the Bureau of 

Land Management has committed to a new paradigm in managing the sagebrush landscape. If BLM succeeds in its regional goal of 

improving management of the sagebrush landscapes across the West, this has the potential to not only conserve the greater 

sage-grouse and ensure that the species does not need to be protected under the Endangered Species Act, but also effectively 

conserve sagebrush natural areas, big game herds and 350 other species that rely on sagebrush landscapes, all while benefiting 

western economies and communities.

CO BLM emc0070RM

180. The Meeker/White River and Parachute Piceance/Roan populations (Colorado Plateau MZ) are in the Uintah-Piceance geologic 

basin. These populations are small and isolated, and are threatened by demographic, genetic and environmental stochasticity due 

to small size and isolation. In addition, these populations are threatened by a suite of deterministic threats, including: housing and 

energy development, predation, disease, and conifer invasion. Based on projected habitat impacts (particularly energy 

development) under current management prescriptions, the FWS believes that all of the populations in the Colorado Plateau MZ 

will be reduced in size and isolated in the future.

CO BLM emc0070RM

181. While existing or draft RMPs in NW Colorado discuss a number of traditional sources of direct and indirect impacts of 

anthropogenic developments on greater sage-grouse, CPW has noticed a lack of information and discussion of how and when 

noise from oil and gas development impacts greater sage-grouse. There is a developing body of literature suggesting that limiting 

anthropogenic sources of noise is necessary to minimize human impacts on greater sage-grouse (as well as other grouse species 

in the family Tetraonidae). There are a number of mechanisms by which anthropogenic sources of noise can negatively impact 

grouse, including the following: • Industrial noise masks the sounds of strutting males and may disrupt female choice of males on 

the lek (leading to reduced productivity)and cause females (and consequently males) to abandon leks; • Industrial noise masks 

sounds made by approaching predators and may lead to increased predation and reduced survival for all age and sex classes in all 

seasonal habitats, not just at leks. Over time, this may result in reduced survival of birds inhabiting areas near noise sources and 

ultimately, fewer birds in developed areas. Sage-grouse may also avoid areas with industrial noise, which would result in the same 

pattern; • Industrial noise in brood-rearing habitats may mask the predator-warning vocalizations given by females to chicks or 

the contact calls of lost chicks, either of which could lead to reduced brood survival; • Sage-grouse of all age and sex classes in 

all seasonal habitats may respond to increased ambient noise by increasing time spent being vigilant, thereby increasing energetic 

costs and decreasing time available for foraging and self-maintenance, leading to poorer body condition and reduced productivity; 

and • Industrial noise could cause chronic physiological stress that leads to poorer body condition and reduced survival or 

productivity

CO Both emc0072RM

182. Habitat Mitigation: Moffat County generally supports the concepts of compensatory mitigation philosophies, however, broad 

reaching concepts can sound good until the details have been discussed. Therefore, we look forward to discussions about how the 

details will be addressed. Distance from disturbance where mitigation may occur is critical in these discussions. Moffat County 

CO Both emc0076RM
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generally does not support mitigating impacts in areas long distances from where the impacts occur. Local basin compensation, 

generally within the same watershed, is most favorably looked upon . Mitigation long distances from the effect can result in 

sacrificing one area in favor of another miles, counties, or states away. And is generally less favorably looked upon.

183. Wildlife predation needs to be addressed. Especially the birds and mammals that prey on egg nests such as the ravens, crows, 

coyotes, fox and skunks

CO Both emc0135GB

184. Critical look at the role of predation on the Greater Sage-Grouse including what is going to be done to address that predation. No 

matter the amount of habitat available, if the predation continues as is the grouse numbers will continue to decline to the 

detriment of all other multiple uses and all for nothing.

CO Both emc0178RM

185. Natural areas that are habitat for sage-grouse also support some our state’s largest and most prized big game herds, and more 

than 350 other kinds of animals and plants. Protecting these areas will help conserve Colorado’s wildlife, including deer, antelope,

and songbirds. I enjoy the outdoor recreation opportunities that these natural areas provide. I also feel that conserving these 

natural wildlife areas is important to the success of wildlife related recreation and tourism, which provides good jobs and is 

important to our economy.

CO BLM fll0000RM

186. The BLM should put mandatory standards in place to safeguard sage-grouse. Because inappropriately located oil and gas 

development has been formally recognized by U.S. Fish & Wildlife Service as being a major threat to sage-grouse in Colorado (and 

throughout the eastern range), the Resource Management Plans cannot rely on voluntary standards to minimize the negative 

impacts of oil and gas drilling. BLM should require companies to act responsibly to protect greater sage-grouse. I respectfully ask 

that the BLM put important safeguards in place in its long-term management plans, to save the sage-grouse and conserve our land, 

water and wildlife for future generations to enjoy. Thanks for your consideration.

CO Both flm0000RM

187. The BLM's Resource Management Plans could identify analysis areas within the overall pliolity habitat areas within their planning 

areas similar to what is done for other species such as the Canada lynx, in order to reasonably manage sage-grouse and allow for 

the responsible development of electric delivery and other energy facilities within suitable sage-grouse habitats.

CO BLM rmc0019RM

188. The EIS should also consider impacts from predation and other uses such as ATV s, recreational 4X4s, mountain bikes, camping,

hiking, horseback riding, and other recreation uses.

CO Both rmc0050RM

189. i. Lander, WY RMP The Lander draft RMP proposes extending seasonal wildlife protections to identified operations and 

maintenance (O&M) activities in non-Designated Development Areas, if those activities are identified as detrimental to wildlife 

(Alternative D). As noted in the DEIS, this action "would not preclude development or limit the number of wells and would result 

in no more adverse impacts than management under Alternative A, which does not have timing limitations on O&M" (DEIS at 

649). Extending seasonal protections beyond the development/construction period will benefit wildlife during the sensitive winter 

and nesting periods. Protections would be instituted for activities like fracking, power line reconstruction, range improvements, 

and road maintenance. As recognized by the DEIS, these activities can "stress and disturb wildlife during the sensitive winter and 

nesting periods due to the time it takes to complete the work, the level of noise generated, and the presence of people and 

equipment. It is expected that project O&M activities would result in both short-term adverse impacts related to animal 

displacement and long-term adverse impacts if the level of activity results in area avoidance or loss of nests or young" (DEIS at 

818). We strongly encourage the BLM to adopt this provision.

East Both emc0089RM
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190. Why is the bird population declining? We believe it is due to the following: West Nile virus, eagles, hawks, fire, cheat-grass and 

numerous predators.

East Both emc0108RM

191. Any conservation strategy needs to address the roles of predation and disease on sage grouse numbers and support the state and 

local government programs;

East Both emc0155RM

192. The sage grouse is found in areas where there are numerous predators, including coyotes, foxes, mountain lions, ravens, eagles, 

hawks and wolves, to name a few. Predator populations are at an all time high in the western states. While research has 

acknowledged the role of raptors on nesting success, the proposed interim conservation measures and most notably the NOI 

entirely omit the role of predators in direct sage grouse mortality. Ex. 1 at pp. 2-3 (noting the correlation between predator 

control and sage grouse numbers); Ex. 1A pp. 9-13. DOI and BLM's support for predator control has been hostile at times or 

lukewarm at best. The omission of predators promotes the erroneous conclusions regarding the impacts of land uses on sage 

grouse numbers.

East Both emc0155rm

193. The NOI and Technical Team Report conspicuously omit the role of big game on herbivory. This is a material flaw, because big 

game populations have increased significantly over the last several decades. Ex. 1A p. 5 (big game numbers were low in days of 

early western settlement). In Wyoming, elk numbers continue to increase, often in or overlapping with sage grouse habitat areas. 

Elk are ungulates with the same or very similar habitat impacts as cattle. The elk populations are, in fact, significantly impacting 

sagebrush on wintering concentration areas. They have eliminated sagebrush at the Hardware ranch for example. Some of these 

wintering areas are also sage grouse wintering areas. Sage brush is an absolute requisite to wintering sage grouse. on summer 

ranges, elk do not eat sage brush, but they concentrate on forb and grasses. In addition, deer and antelope, which are browsers 

that will consume sage brush, have also increased. Livestock do not eat the sage brush, only forbs and grasses that might form an

understory for the sage brush. Omission of the browsers' impacts, their numbers and the issue of direct competition must be 

rectified in the RMP amendment process.

East Both emc0155rm

194. I heard several speakers indicate predation is the primary cause of sage-grouse declines. You know full well that increased 

predator control is needed and that the current system restricting predator control is actually doing harm. The need to provide 

habitat that is not overrun with predators detrimental to sage-grouse survival is an issue that needs to be fully addressed. Properly 

managed predator populations would benefit sage-grouse more than any other available management action.

GB Both emc0160GB

195. Predation: We also have concerns that predation to sage-grouse is a major contributing factor to the current declines in 

sage-grouse numbers. In particular, we have concerns regarding current population numbers of crows and ravens throughout the 

Great Basin. Mechanisms need to be put in place to better monitor and manage these species in order to conserve sage-grouse.

GB Both emc0180GB

196. The impact of predators must be addressed in sage-grouse management strategies. Predator controls used to limit the loss of 

eggs, juveniles and mature sage grouse will need to be carefully balanced with the simultaneous need to control other species

which might negatively impact forage or cover but which are also vulnerable to the same predators. Predator density in relation 

to historical levels, distribution and relative impact should inform management decisions. Elevated levels of native predators and 

the presence of non-indigenous predators-should be incorporated into management strategies. Again, the local working group 

model should be utilized to determine and implement the measures which are most likely to benefit the species.

GB Both rmc0056GB

197. (identified as a priority issue in the Dillion Area) effects of predation IDMT Both rmc0028GB
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198. There is no evidence that cattle have any impact on sagegrouse, either positive or negative. However, there is plenty of evidence 

that ranching has a strong positive impact on sagegrouse. Ranches need to be relatively large and usually in native vegetation. This 

protects against habitat fragmentation and the destruction of sagebrush for fields or lawns. Ranchers need vegetation and will 

control fires to some extent. Hot, late, uncontrolled fires will destroy large areas of big sagebrush, which takes over a century to 

recover from a burn of this kind. Ranches tend to have some degree of predator control, and predators are the largest negative 

impact on sagegrouse, following sagebrush destruction. Areas with healthy sagegrouse populations tend to have ranches, areas 

that have lost their ranches have also lost their sagegrouse. It is easy and popular to protect sagegrouse from cattle, but the cattle 

don't harm the sagegrouse. If you remove the cattle, you also remove the ranches, which are important to the sagegrouse. 

Sagegrouse can be protected into extinction just like rare orchids and desert pupfish.

MT-RM Both emc0023RM

199. Being on the ground every day, our members concerns over predation on the sage grouse have been largely disregarded. Our 

groups would like to request that additional research be conducted on the effects of predation on sage grouse and its impacts on 

the population. In many cases, habitat is the only factor considered in relation of sage grouse populations, but our community 

members know that other factors impact this species. Additional studies need to be conducted, similar to the USDA study, which 

showed significant predation on sage grouse by predators. 

http://billingsgazette.com/news/state-and-regional/wyoming/predation-leading-cause-of-grouse-mortality-usda-study-suggests/art

icle_. In addition, a BLM-funded study by Montana Fish, Wildlife and Parks, depredation by nest predators was the primary cause 

of nest failure in both 2010 and 2011. Almost 90% of hen mortality was attributed to depredation. The report states, 'We did not 

observe any direct negative impact of livestock on nesting grouse (e.g., trampling of nests)' (Foster, 2012)

MT-RM Both emc0157

200. Our county would like to request that additional research be conducted on the effects of predation on sage grouse and its impacts 

on the population. In many cases, habitat is the only factor considered in relation of sage grouse populations, but our community 

members have on-the-ground knowledge that other factors impact this species. Additional studies need to be conducted, similar 

to the USDA study, which showed significant predation on sage grouse by predators. http 

://bilJingsgazette.com/news/state-andregi onallwyo min g/predati on -1 ead in g-cause-of-grouse-mortal I ty-usda-study-su 

ggests/arti cl e

MT-RM Both rmc0023RM

201. Let the ranchers graze there herds on there allotments,keep hunters off the land. We have million acres of land in Nevada that is 

not owed by the public let them hunt there.

NVCA Both emc0012GB

202. And last but not least the predator control program needs to be increased across the board, we are spending to much money 

doing study’s when the answer is right in front of our face, take out the predator equation and all populations increase.

NVCA Both emc0187GB

203. Predators are likely the biggest problem but what can be done in today’s climate? Crows and ravens should not be protected and 

coyotes need to be controlled. Those three are the worst grouse predators.

NVCA Both emc0253GB

204. The agencies should coordinate Sage Grouse conservation measures with the agencies' wildlife programs. Since predators are 

being cited as a scapegoat for Sage Grouse population declines by some and predator control or extermination is being proposed 

by some as a "conservation" measure, the EIS should examine whether predation is a significant threat limiting Sage Grouse 

populations in all PMUs, using information from the state's Sage Grouse conservation plan.

NVCA Both emc0283GB

205. There are Significant Populations of Sage Grouse Predators: Coyote, bobcat and raptor populations are high in this area, probably 

due to cattle and horse populations and rodents in the grassy reclaimed areas. The predator and rodents particularly utilize the 

NVCA Both emc0287GB
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elevated rock mounds emplaced during reclamation to resemble the original natural topography of spotty elevated outcrops and 

cliff. These elevated areas could serve as perching sites for preying raptors.

206. But also to providing quality habitat to support wildlife populations. Scientific research indicates that properly managed grazing is 

beneficial to the greater sage-grouse and to a host of other wildlife.

NVCA Both emc0304GB

207. NDOW White Paper March 2012: The paper describes the five categories of habitat, plus non-habitat. It has no category for 

historical habitat that has been lost. At a minimum, habitat of moderate importance and transitional range, as well as low value 

habitat that has mature or old growth sagebrush present, must be included as high value, or key, habitat. It is of great concern that 

human land-use development will be allowed to proceed, but detailed site-specific studies are not required. While sage-grouse 

may be broadly distributed, the habitat is peppered with holes, and often is highly degraded as well. There is extensive natural 

fragmentation all the Great Basin mountain ranges as well as salt desert habitats in valley bottoms. On top of this is a plethora of 

livestock, mining, energy, agency treatment, and fire disturbance adversely impacting remaining habitat quality and quantity. While 

sage-grouse may be considered an umbrella species by some, in Nevada the agency attitude (for example Ely BLM and ag interests 

supporting ranchers who seek continued destruction of sagebrush) towards mature and intact sagebrush communities is causing 

big leaks in the umbrella. In fact, the umbrella is collapsing in many areas as cheatgrass and other weeds sweep Ely treatments 

claimed to be for sage-grouse. Sage-grouse are being used as an excuse to radically alter sagebrush, and destroy old growth and 

mature pinyon-juniper as well as trees re-colonizing historic ranges. In fact, the Ely RMP proposes manipulation of fully 2/3 of the 

native vegetation communities an action likely to result in tremendous desertification and habitat loss for both sagebrush and 

pinyon-juniper dependent species. We are concerned that the NDOW report claims sage-grouse are an umbrella species for the 

pygmy rabbit when in fact, NDOW will promote Ely and Elko BLM and Forest Service projects like in the Santa Rosa RD projects 

that purposefully alter, reduce destroy denser sagebrush required by the pygmy rabbit. This is in part justified by claiming that 

sagebrush with good microbiotic crust understories and denser Wyoming sagebrush cover is somehow deficient based on biased 

soil inventories and then added onto this are claims that the community is decadent and only destroying it will somehow save it. 

When in fact, these are very important habitats that often support high densities of pygmy rabbit, sage sparrow, etc. NDOW also 

supports (as in the Montana Mountains) band-aid fencing projects of riparian or stringer meadow areas rather than an integrated 

hard look at livestock impacts. For sage-grouse in Nevada to be an umbrella species, NDOW needs to start sticking up for wildlife 

values, and not taking the easy route out by endorsing projects that alter sagebrush, destroy it in the process of a general purging 

of trees, or that serve to shift and intensify harmful livestock impacts in other areas as the agency currently is doing.

NVCA Both emc0411GB

208. Killing predators is the easy path to take, rather than promoting livestock reductions. Yet there is very little information provided 

on all the ways in which livestock grazing and facilities promote ravens and mesopredators, and strip and reduce cover necessary 

to conceal nests and otherwise greatly exacerbate predation risk. This includes: Carrion, livestock body parts such as docked

sheep trails or parts from calf castration that we have observed littering public lands in Nevada, livestock waste food sources 

(including insects under cattle manure cow “flops” that ravens turn over to look for insects); artificial upland livestock water 

sources that attract ravens and extend areas used by them such as pipelines, water hauling, water troughs; elevated structures like 

fence posts, well tanks, etc. where ravens perch (and they also may nest on well troughs or other structures); livestock feed

supplements with bits of cracked horn or other raven food; and many other sources of additional food and water that support 

ravens and often other mesopredators. Then there are the myriad ways that ivestock grazing disturbs nesting birds and alters 

NVCA Both emc0411GB
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critical habitat components necessary to protect nests from visual predators.

209. The beneficial effects of predator control must be addressed in sage-grouse management strategies. Specifically, raven control 

could be beneficial to nest and chick survival. Nevada’s raven population has grown dramatically over the past 25 years and it has 

been stated we currently have extremely drastic increase in ravens over historic levels.

NVCA Both flj0000GB

210. What I have noticed is that from year to year or decade to decade the amount of animals that live in our ecosystem changes. 

There have been years where we have had larger numbers in our deer population then in the past The balance of an ecosystem 

is an ever changing thing and a process that far exceeds the understanding of any individual.

NVCA Both fxc0016GB

211. The implementation of government sponsored predator control at the time of the advent of agriculture in the Great Basin 

resulted in a reduction of coyotes and other sage-grouse predators (Nevada Wildlife Federation,' Enhancing Sage Grouse Habitat 

... a landowner's guide). The guide also refers to the increase in sage-grouse popUlations brought on by settlement and the 

changes of plant communities, followed by declines in populations attributed to market hunting and liberal seasons and bag limits. 

Those issues, combined with the banning of effective predator control (1080) by government edict, must be a factor in the decline 

of the sage-grouse population. The proliferation of ravens in our area is a major problem. These voracious creatures must be 

having a detrimental effect upon the sage-grouse population, and some type of controls should be implemented. Human predation 

is also an issue. Continued hunting of a species which has been declared "warranted but precluded" from protection under the 

Endangered Species Act is outrageous.

NVCA Both rmc0065GB

212. Reference to and use of the Oregon Dept. Fish and Wildlife. April 2011 . Greater Sage-Grouse Conservation Assessment and 

Strategy for Oregon: A Plan to Maintain and Enhance Populations and Habitat should be addressed during the EIS development. 

The plan has numerous references to published literature that can provide a framework for the federal plan regarding many 

aspects of the sage grouse survival. habitat, and vulnerability to predators and disease. Predation is one area that needs to be 

investigated to further the knowledge about sage grollse populations. The following is Stated by the ODFW plan: • Population 

ecology-Understanding annual survival and seasonal mortality is critical and largely undocumented in Oregon. Similarly there is 

still a need to refine methods to estimate population sizes. Similarly, development of a probabilistic sampling scheme for lek counts

is paramount to provide some level of rigor to the data collection. (Oregon Dept Fish and Wildlife, April 2011. Greater 

Sage-Grouse Conservation Assessment and Strategy for Oregon: A Plan to Maintain and Enhance Populations and Habitat).

OR Both emc0136GB

213. The District wildlife inventories in Oregon should be up-dated to provide a credible road map about the landscape. This work and 

information should be referred to the Wildlife programs where education, training, an experience with wildlife issues will 

complement the work that needs to be done. There should be cooperation between wildlife programs to coordinate studies that 

can identify new population count methods. As stated in the ODFW plan. the BLM should heed the need for more rigorous 

sampling procedures: • Understanding annual survival and seasonal mortality is critical and largely undocumented in Oregon. 

Similarly, there is still a need to refine methods to estimate population sizes. Similarly, development of a probabilistic sampling 

scheme for lek counts is paramount to provide some level of rigor to the data collection.

OR Both emc0136GB

214. Another reason is back then the cattle and sheep men used 1080 poison on the predators and that really helped. Not only did this 

help the sage hens, but all of the rest of the wild life also. In our area, the Experiment Station has done a study about this and the 

sage hens started going downhill right after they banned the use of 1080 on the predators.

OR Both rmc0046GB
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215. I know in our area the range hasn't changed that much, but you don't see very many sage hens and I know the livestock are not 

the problem, but we have every predator there is and the last several years we have seen a large increase in cougars. In my 

opinion, we will never help the sage hen problems without some serious control of the predators.

OR Both rmc0046GB

216. Any EIS or SEIS must also explicitly recognize the following points: The beneficial effects of predator control must be addressed 

in sage-grouse management strategies. Specifically, raven control could be beneficial to nest and chick survival.

OR Both rmc0078GB

217. My name is scott hatch from spanish fork utah. I recently drove from St George to Spanish Fork and decided to count the number 

of ravens along the side of the freeway. I counted 52 and I wasnt really looking that hard. these ravens and the coyotes and fox are 

probably the reason the sage grouse arent surviving. you should probably get a bounty on the ravens. i have also seen ravens 

chasing hawks and stealing their kills.

UT Both emc0049RM

218. Coyote, Raven and Eagle populations have been allowed to increase in recent years, this could become a predator/ prey problem 

again

UT Both emc0137GB

219. The main problem that exists locally is the increased presence of predators: Crows, Ravens, Eagles, Hawks, Foxes, Coyotes, 

Raccoons, Skunks, etc. are everywhere nowadays and increasing In numbers each year. I have no doubt that they take a very large 

toll on Sage Grouse eggs and nests, as well as other upland animals.

UT Both emc0405GB

220. Many members of the local working groups -- from agency biologists to local ranchers -- are particularly coverned because the 

management options for improving sage-grouse habitat, especially using vegetation management, vary considerably depending on 

location, elevation, local land use management history, etc. What works to improve habitat in some areas may be potentially 

detrimental in other areas. For example, the effects (for sage-grouse) of similar mechanical treatments could vary dramatically 

based on upon precipitation zones, elevation, weed infestations, and other factors

UT Both emc0405GB

221. Predation - In the agency assessment of threats to Sage Grouse, predation is identified as approximately half the threat as 

agriculture and grazing. Our experience in Utah suggests otherwise. Proper grazing enhances Sage Grouse habitat and 

populations. Proper grazing practices allow Sage Grouse to strut and more safely occupy habitat where they can observe 

predators like fox, ravens and coyotes. Utah's Strawberry Valley experience suggests that predators are a major threat to Sage 

Grouse. In an area with no energy development or livestock grazing. Sage Grouse numbers have been greatly impacted by 

predators - especially fox and ravens.

UT Both rmc0003GB

222. Garfield County requests specific analysis regarding identification of predators, impact of predators, existing predator control 

efforts, and all reasonable predator management options as they relate to Sage Grouse populations.

UT Both rmc0006GB

223. The position that the threat of possible Sage Grouse listing has placed our citizens, western land states and their local government 

entities in, we view as a direct result of years of federal regulatory onus. Carbon Comity shall take a willing role in working to 

remedy this issue but believe that until the federal agencies and our national leadership recognizes that; reducing grazing AUM's 

west wide consistently for over 50 years, listing under ESA the natural predators of the grouse species, outlawing the use of 

poisons used to prevent predation and the promotion of fuel/biomass buildup by interrupting natural fire regimes have hosted the 

consequences we and the bird now endure.

UT Both rmc0026RM

224. Predation is greatly under estimated as a threat of the sage grouse. When the use of 1080 and strychnine was eliminated as 

predator controls, the population of Coyotes and raptors as increased greatly, and the population of sage grouse has declined 

correspondingly. Heavy losses in the winter to Coyotes and eagles.

UT Both rmc0062GB
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225. Additionally, Emery County agrees with the concerns, which were repeatedly expressed by attendees at the public meetings, 

regarding the need to address the impacts of predation on conservation of the Greater Sage-grouse.

UT Both rmc0073GB

226. Policy Statement 7: West Nile Virus: ‘ Artificial water impoundments will be managed to the extent of BLM’s authority for the

prevention and/or spread of West Nile Virus...This may include..(c) building steep shorelines to reduce shallow water and 

emergent aquatic vegetation; (d)maintaining the water level below rooted vegetation; (i) restricting access of ponds to livestock 

and wildlife (Doherty 2007).The BLM mentions several instances where they would regulate reservoir use by fencing out, making 

the banks too steep for livestock use, keep water level low: The reservoirs on federally managed lands are for the wildlife as well 

as livestock use. If the reservoirs are fenced out, banks made too steep or the reservoir is unfit for livestock to use; the water will 

also be unfit for wildlife use. Young elk, pronghorn and deer will not be able to get out of steeply sloped reservoirs any more than 

sheep or cattle. You are not allowing yourselves to look at the whole picture. Multiple use means wildlife and livestock. The use 

of larvicide is a good recommendation if used according to the label.

WY BLM emc0050RM

227. Fencing out is a bad idea because if an animal is thirsty enough they will crawl over and then either be caught in the fence or unable 

to get back out to graze. Eventually the fence will be down and be a hazard with loose wires to entangle animals. This applies for 

wildlife as well as livestock.

WY Both emc0050RM

228. The BLM could make it a point to distribute the B.t.i. Briquets within 3 miles of nesting and lek areas on standing large bodies of 

water. These are not poisonous to wildlife (if directions are followed) and should only be distributed on waters not for human 

consumption. An incorrect use of these might cause litigation of mismanagement due to animal illness. The Briquet will prevent 

the mosquito larvae from thriving and help decrease the chance of spreading West Nile.

WY BLM emc0050RM

229. Hard winters are a fact of life. There are times that the snow is so deep there is no protection from predators for the sage grouse. 

The sagebrush in several areas of the state is not tall but will protect sage grouse during most normal winters.

WY Both emc0050RM

230. The habitat is there but no sage grouse for whatever reason. Several private landowners maintain good habitat, if the habitat is 

there and predator population is managed then the sage grouse could be brought back. Predators kill many grouse every year and 

need to be controlled especially around sage grouse core areas.

WY Both emc0050RM

231. I have seen cattle and sage grouse grazing and resting side by side. The cattle will keep the predators away to protect their calves. 

Yearlings will follow a coyote for a long way out of curiosity. My point is that sage grouse are safer with cattle in the same area 

because the coyote, fox and bobcat will be not as prevalent.

WY Both emc0050RM

232. i. Lander, WY RMP The Lander draft RMP proposes extending seasonal wildlife protections to identified operations and 

maintenance (O&M) activities in non-Designated Development Areas, if those activities are identified as detrimental to wildlife 

(Alternative D). As noted in the DEIS, this action "would not preclude development or limit the number of wells and would result 

in no more adverse impacts than management under Alternative A, which does not have timing limitations on O&M" (DEIS at 

649). Extending seasonal protections beyond the development/construction period will benefit wildlife during the sensitive winter 

and nesting periods. Protections would be instituted for activities like fracking, power line reconstruction, range improvements, 

and road maintenance. As recognized by the DEIS, these activities can "stress and disturb wildlife during the sensitive winter and 

nesting periods due to the time it takes to complete the work, the level of noise generated, and the presence of people and 

equipment. It is expected that project O&M activities would result in both short-term adverse impacts related to animal 

displacement and long-term adverse impacts if the level of activity results in area avoidance or loss of nests or young" (DEIS at 

WY Both emc0089RM
C. Comments by Resource Planning Issue

C-1004 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.A

Comments Related to Wildlife-General

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

818). We strongly encourage the BLM to adopt this provision.

233. BLM’s indirect effects section should consider impacts and benefits to other sage-dependent species The decline of the greater 

sage-grouse is just one symptom of a much larger problem – the decline of the sagebrush ecosystem. Sage-grouse is just one of 

many species that uses the sagebrush habitat and it has been used an indicator species of sagebrush ecosystem health. See, e.g. 

Steven E. Hanser and Steven T. Knick, Greater Sage-Grouse as an Umbrella Species for Shrubland Passerine Birds: a Multiscale

Assessment, ECOLOGY AND CONSERVATION OF GREATER SAGE-GROUSE: A LANDSCAPE SPECIES AND ITS 

HABITATS, USGS, Nov. 2009, at 18: (“Management to benefit Greater Sage-Grouse may benefit the broader community of birds 

that use sagebrush steppe habitats”). Sagebrush ecosystem conservation may also benefit sage-dependent large game like 

pronghorn and mule deer. BLM should disclose the indirect benefits (or impacts) of its proposed action and alternatives on other 

species and the sagebrush ecosystem itself.

WY Both emc0129RM

234. 10) Avoid or minimize impacts on sage grouse populations and habitat when developing management strategies or actions for 

other wildlife species that use sagebrush habitat.

WY USFS emc0144RM

235. Factors such as vegetation management, fire management, conflicting wildlife management, predation, subdivision and 

infrastructure development, and invasive plants are a higher priority in the Upper Snake River Basin Conservation Area 

(USRBCA) and include large areas that could be affected by project actions.

WY USFS emc0144RM

236. Wyoming is the last remaining stronghold for the greater sage grouse, and clearly the Wyoming population, having become the 

core of the rangewide sage grouse population, offers the last best hope of preventing sage grouse extinction. GIS analysis shows 

that Wyoming has the largest expanse of least fragmented sagebrush habitat remaining in North America (Knick et al. 2003). 

According to Rowland et al. (2006:v), “Concomitant with the amount of sagebrush habitat, the Wyoming Basins area harbors 

some of the largest extant populations of sagebrush-obligate species, such as greater sagegrouse and pronghorn. Future 

persistence of these sagebrush-obligate species therefore is closely linked to effective management of sagebrush habitats in the 

Wyoming Basins.” These researchers mapped sagebrush habitats versus fragmentation in relation to sage grouse in the Wyoming 

Basins Ecoregion (see p. 5-31), and found that the Red Desert is one of the remaining major hotspots. But sage grouse populations 

in the state have been on a longterm downward trend, still cycling upward and downward but both the peaks and the troughs in 

population are steadily being reduced over the past 50 years.

WY Both emc0343GB

237. A collateral impact of coalbed methane development is increased threat of West Nile virus, which is deadly to sage grouse (Naugle 

et al. 2004). Coalbed methane (“CBM”) wastewater ponds are known to provide ideal habitat for the Culex spp. mosquitoes 

which carry the WNv and infect sage grouse. Mosquito infection with WNv associated with Powder River Basin CBM wastewater 

ponds was demonstrated by Naugle et al. (2004). While West Nile virus has been a lesser cause of mortality for sage grouse over 

the last two years, this does not guarantee that a major outbreak will not sweep across the sage grouse range at some time in the 

near future, as illustrated by the repeated outbreaks of similarly non-native Yersinia pestis in black-tailed prairie dogs. West Nile 

virus is a significant threat to sage grouse, and has contributed to population declines (Naugle et al. 2004, 2005). In laboratory 

experiments, the demonstrated ability of sage grouse to develop immunity to this disease has been shown to be very poor (Clark 

et al. 2006), and resistance to the disease in wild grouse populations is very low (Walker et al. 2007). Coalbed methane 

development in some parts of the sage grouse range has been associated with surface disposal of produced water, which typically 

entails the construction of infiltration reservoirs or local flooding, or both. Coalbed methane wastewater ponds have been shown 

WY Both emc0343GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1005

Scoping Summary Report

Table C-7.A

Comments Related to Wildlife-General

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

to increase habitat for the Culex spp. Mosquitoes which carry the WNv and infect sage grouse (Doherty 2007). In the Powder 

River Basin, the interaction of West Nile virus with standard-density coalbed methane development has been predicted to result 

in the “functional extirpation” of the population (Taylor et al. 2012, see Attachment 2). Indeed, according to these researchers, “if 

development continues, future viability of the already small sage-grouse populations in northeast Wyoming will be compromised.” 

To add to the problem, reservoirs attract sage grouse predators, and as a result Dzialek et al. (2011) recommended siting 

reservoirs and other water features more than 200m from nesting habitat.

238. First, I would like to point out that predator populations in the breaks area have increased dramatically in the last thirty years. 

While coyote, bobcat, and mountain lions are plentiful, the most noticeable change has been the increased number of red fox, 

hawks, golden eagles and crows. This has put a lot of negative pressure on game bird populations, including sage grouse. In my 

view, it would be pointless for federal and state agencies to try and devise a management plan for sage grouse without 

acknowledging this central fact.

WY Both rmc0012RM, 

rmc0022rm

239. Case in point: Keyton 3 Lek, located in the northwest part of the 4W Ranch had always been an active lek with 20 to 30 males 

strutting annually. 314 of a mile to west of this lek on Frog Creek in a small grove of Cottonwood Trees there has been a historic 

and active Red-Tail Hawk nest. In 2007 a pair of Golden Eagles took over that nest for one breeding season. The close proximity 

of these eagles completely disrupted the lek for that year and the sage-grouse have notreturned to Keyton 3 Lek since. Red-tails 

returned to their nest in 2008, but the Grouse have not. This was certainly not the fault of livestock grazing, and this is a clear case 

of predation. How many other leks are influence by the presence of Golden Eagles and other large raptors? Then you add the 

Coyote and the Red Fox in this area and you have quite an arsenal of predators working on a limited prey base of sage-grouse and 

rabbits. It must also be understood that Red-tailed Hawks by nature are mousers. Small rodents are their main prey and a 

sagegrouse is by far too large of a prey for them. This is probably why the Red-tail and the grouse coexisted in this area for so 

many years.

WY Both rmc0034rm

240. Another case in point. Sage -Grouse habitat has been destroyed by Black-tailed Prairie Dog (PD) population expansion and 

encroachment into the sagebrush. During the past 20 years the 4W Ranch has witnessed the complete destruction or the thinning

of sagebrush areas by the PD in what is now part of the Sage-Grouse Core Area. The Forest Service's Prairie Dog Management 

Strategy Plan 3 which prevents aggressive lethal control of the PD in certain areas of the Thunder Basin National Grasslands is 

contributing to the destruction of the Sage-Grouse Habitat on the 4W Ranch.

WY Both rmc0034rm

241. This photo taken on 17 March 2012 shows the Rangeland destruction caused by the PD. This once vibrant stand of sagebrush and 

rangeland was destroyed, not by fire, not by overgrazing by livestock, but totally destroyed by the Black-tailed Prairie Dog.The 

above photo is indicative of the destruction that is now happening to a once healthy sagebrush ecosystem throughout the 

Thunder Basin National Grasslands by one species of destructive wildlife. Are we going to have protected PO's or are we going 

to have habitat for Sage Grouse? [Note: photo included as attachment in comment letter]

WY Both rmc0034rm

242. The continued expansion of prairie dog habitat upon and encroaching into and thereby limiting sage grouse habitat is detrimental 

to the qual ity and quantity of .age grouse ha bitat in the area, addressed. There are a large number of aues devoted to prairie dog, 

which are critical to sage grouse livelihood in Ihe TIING. It I, well known that prairie dog inhabitation change, the vegetative 

landscape from bru.h and a mid gra,s community to a dominate blue gamma grass community. That is definitely to the disadvantage 

of our sage grouse in the TBNG. They thrive where sagebrush in addit ion to several mid gra;~s dominate the land,cape. They are 

WY Both rmc0043RM
C. Comments by Resource Planning Issue

C-1006 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.A

Comments Related to Wildlife-General

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

not viable in a blue gamma dominate landscape because far too much open ground lead, tn de:oth for them.

243. A large portion of the Catecory 1 and the Category 2 prairie doc management areas contain vital sage grouse habitat. To furth er 

a llow prairie dog, to decimate that critical habitat would ring a death kn oll for lar too many ,age grouse. The total ~~reS allucated 

fo, prai,;e dog inhabitation I, too iarge, and it i. with th i' method of management of the prairie dogs that I find erroneous. I believe 

that it would be far more productivity to manage the actual population number of prairie dogs as opposed to alioLating acres for 

prairie dogs to inhabit. It will lake a purposeful calc ul at ion to determine that the sage grouse habitat is critical to that species, and 

to award the sage grouse their due habitat acres by d isa llowing so many acre, to be overrun by the prairie dogs, The sile of the 

Category 1 boundary should be shrunk to a manageable , i,e to allow suffiCient amount of acre, ava ilable for the prairie dog' to 

thrive. and they will survive with fewer than are now dedicated. A very real solution would be to trulV man"ge the actual 

population numbers of prairie dogs as opposed to the acres The sage grouse ha bitat with in the category 1 boundary should be 

protected

WY Both rmc0043RM

244. in all the information presented at the recent open house I saw none regarding the effects of predation on the Sage Grouse by all 

the various predators that frequent the TBNG and surrounding areas. To name a few....red fox, swift fox, coyote, raven / crow, 

eagles, and various varieties of hawks. Common sense should tell us that all these predatory animals and birds would have a 

tremendous negative effect on the survivability of the Sage Grouse.

WY Both rmc0044RM

245. When talking about Sage Grouse and their population numbers, all folks that have been around for 40 – 50 years and longer will 

tell you that there used be a lot of grouse everywhere. They usually go on to say that nothing has changed as far as grazing and 

habitat goes. In point of fact, there has been one huge change that can be attributed for the decline in Sage Grouse numbers over 

the last 30 – 40 years. The poison, Compound 1080 has not been in use during that time. When 1080 was widely used, there were 

few predators of any kind. The fox weren’t here yet, there were few eagles, and the 1080 took care of the coyotes

WY Both rmc0044RM

246. Folks, I’m here to tell you that the primary cause of the decline of the Sage Grouse is predation and until you address that, you are 

spinning your wheels.

WY Both rmc0044RM

247. Many predators prey on the sage grouse, including nest predators, such as coyote, fox, raccoon, skunk, weasels, crows and ravens, 

as well as other smaller birds and those who prey on juvenile and adult birds, such as eagles, coyotes and fox.

WY Both rmc0045RM

248. I was informed by an FS official that the SG population had been in decline since1968. I believe that the SG population was at a 

historical high at that time and the predator population was very low, due to many years of predator control. As protection of the 

eagle and other predators began to take place in the late 1960's, sage grouse numbers began to decline as the result of increased 

predation and have continued to decline as raptor population increases. I have lived in the area for 15 years and I have observed 

a marked increase in the number of eagles and other raptors. During the same period I have not witnessed any significant change 

in sage cover. In fact there seems to be plenty of good SG habitat. In this same time frame I have seen the Sage Grouse population 

decline in relation to the number of raptors and other predators. If the managing agencies are not willing or able to actively 

control the raptor / predator population we will never see any meaningful increase in the SG population, regardless of the SG 

habitat. If you want to have an effective plan to protect the SG population, it must address predation in a way other than just 

growing more sage brush.

WY Both rmc0048RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1007

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Raven poplulation has increased by 1100% since 1980. A 15 year study by ISU came up with this raven statistic while 

finding raven are the number one nest egg predator.

All Both cfc0002GB

2. Poor hunting season policy compounded the loss of population by raven nest predation and increased predator numbers 

as sheep declined.

All Both cfc0011RM

3. I also feel that the ravens and magpies do a lot of predation on the nests. All Both cfc0014RM

4. What is going to be the issue with the raptor perches that were erected 30 some years ago on the grasslands in an effort 

at that time to control prairy dogs with raptors? Will they be taken down?

All Both cfc0016RM

5. Hawk clean out birds as soon as they come. We have watched them do this!! Bird come to building for protection as long 

as hawks and predators are protected by your agencies don't come after me these other issues. I am doing the best I can 

I wish you would listen to me. I have been here for 45 years.

All Both cfc0054GB

6. Understand the raven (crows) and eagles are contributing to the decline in large numbers - get rid of the ravens/crows!! All Both cfc0057GB

7. In the 1960' s, I owned the hay meadows that ran near the B.L.M. foothills. Then these foothills were totally overgrazed. My 

hay meadow would green-up after haying. About five o' clock, bunches of sage hen would fly from the foothills onto my 

meadow. We had marvelous hunting! Today, the foothills are only slightly grazed in comparison, the meadow is still green, 

but no sage hens. Why? In my humble opinion, the culprit may be the crow. 40 years ago, one would see a crown 

occasionally. Today, there are crows everywhere. Bunches of fifty crows are common.

All Both emc0029GB

8. One day, I swathed by a pond. Three half-grown ducks were scared onto the meadow. Five minutes later, I came by the 

pond. Again, the crows had two of the ducks torn apart. The crow is a smart and aggressive bird. As long as we have large 

numbers of crows, it will be difficult to increase sage hen numbers!

All Both emc0029GB

9. Avoidance of small and large above ground structures on the landscape by greater sage-grouse is well documented. Buried 

pipelines present a unique set of challenges because they consist of three main types of structures: 1) the pipeline; 2) pump 

stations and associated roads; and 3) overhead power lines. Pump stations are permanent aboveground structures that 

require 5-10 acres and are constructed at approximately 48-50 mile intervals. Pump stations require road construction, 

which greater sage-grouse will avoid, and overhead power lines, which are likely to increase the number of aerial predators 

in greater sage-grouse habitat by providing perching areas.

All Both emc0034RM

10. I would like to make the comment that a key component to sage grouse management will be management of ravens. Ravens 

are proven to eat sage grouse eggs and chicks. We cannot expect to be able to enhance any opportunity to protect sage 

grouse without addressing this significant factor. We can change everything else in the system like removing grazing, 

providing waters, etc., but if we do not address the fact that ravens are unmanaged they will continue to be affected. We 

must manage ravens to protect sage grouse.

All Both emc0059GB

11. Conduct under burns in the pine and fir stands to reduce the fuel load within the Mt. Dome Area of Critical Environmental 

Concern. This will aid in preventing catastrophic fires on the mountain top and losing the entire stand of timber used by 

nesting and wintering Bald Eagles in the Klamath and Tule Lake basins.

All Both emc0061GB

12. Other sagebrush obligates, such as the Sage Sparrow and Brewer’s Sparrow are in decline, and these species should also 

considered in proposed management alternatives.

All Both emc0068GB, 

emc0020rm
C. Comments by Resource Planning Issue

C-1008 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

13. The conclusions of minimal effect of predation do not seem to follow from the discussion, especially as regards corvids. It 

bears noting that one of the references (Bui, et al., 2010) recommends taste aversion training to discourage ravens from 

eating sage grouse eggs. Will the bureaucracy consult with Mrs. Obama for insight on the change of diet she hoped for 

schoolchildren? With a $16 trillion national debt, the bureaucracy is recommending diet therapy for the birds. Ravens are 

ranked in the category of Least Concern (IUCN, 2011) as regards susceptibility to extinction. They are recognized as 

subsidized predators in large through their ability to adapt to resources made available by human activity. Due to their wide 

diet and hunting characteristics, they engage in hyperpredation whereby they can remain in an area and continue to hunt 

declining species while extending their diet to more abundant prey. In so doing, they continue to threaten the less 

numerous species rather than move on and relieve the predation pressure. With a 15-fold increase of raven population 

in the last fifty years, the bureaucracy does not consider that active reduction of ravens merits scientific, let alone policy 

discussion. In the same time frame, the bureaucracy consistently has neither counted nor reported sage grouse 

populations, yet asks the taxpayer to accept the bureaucratic conclusion that listing is inevitable.

All Both emc0087GB

14. One of the Mojave desert studies reported by Boarman & Coe (2002) indicates 3.35 ravens per square kilometer. Applying 

that density to the 284,449 square kilometers comprising the state of Nevada suggests there may be 952,000 subsidized 

predators available to prey on sage grouse. The 2004 sage grouse count for California and Nevada indicated 88,000 birds 

(Form). Even were all these sage grouse within the boundaries of Nevada, apparently there are nearly eleven ravens for 

each sage grouse. Since some of those sage grouse are in California, there actually may be more than eleven ravens per 

grouse within Nevada. This author recognizes and stresses these numbers must be accepted with care, as they are 

neither spatially nor temporally consistent. The fact is that readily comparable numbers are difficult to obtain precisely 

because the agencies consistently gloss over the actual counts of both the subsidized predator and the prey, and they never 

directly compare the raven and sage grouse populations. Certainly this author’s decades of living and working in sage 

grouse and raven range suggest the eleven-to-one ratio is realistic.

All Both emc0087GB

15. In sage grouse habitat, raven predation of nests essentially is 100% effective, in that whether one or all eggs are taken, the 

sage grouse subsequently abandon the nest (Bui et al., 2010). With the overwhelming raven population, this assures sage 

grouse extinction is on the way. Yet the agencies maintain that ranchers, power plants, mines and recreational visitors must 

be restricted while paying no substantial attention to the actual subsidized predators. In 2010, NDOW allowed the taking 

of 1,500 ravens to reduce sage grouse predation. That appears to be less than two tenths of a percent of that subsidized 

predator population. Out of a legislatively mandated budget of $600,000 for predation control, $50,000 were spent on 

taking these ravens. Fiscal as well as predation control may be an issue. The prime directive of the bureaucracy is growth 

of the bureaucracy, not growth of the sage grouse population. This is evident since by far the greatest portion of the Form 

is devoted to regulatory mechanisms. That extensive discussion reads as a rationalization for greater regulatory expansion. 

Essentially, it states that central planning by an enlarged bureaucracy will improve habitat by restricting or eliminating 

human activity on or near sage grouse habitat.

All Both emc0087GB

16. Predation and fires are immediate events. Habitat control and management are long term solutions which cannot

immediately protect sage grouse from predation and fires.

All Both emc0087GB

17. Idaho Power and other utilities will need to build transmission and distribution lines in the future and these will need to All Both emc0090GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1009

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

traverse priority and general habitat areas. In some cases, rerouting a line may not be feasible or may be cost prohibitive 

(e.g., providing distribution service to a customer). We encourage the BLM consider future utility needs and how the 

constraints implemented through this process can significantly impact the costs and feasibility of future projects.

18. There also didn't use to be so many predatory birds. When we were kids you didn't see near as many hawks and especially 

as many crows. We feel the crows are the number one enemy to the grouse. Conni's father has found crows nests year 

after year with over 30 sage grouse egg remnants. That's total devastation to the hatches each year. But yet we cannot hunt 

the crows, nor is an effort made to control them.

All Both emc0128GB

19. I particpated in sagegrouse study in utah in the late 70s we tagged the birds and put radio transmitters on some , the 

number one cause of mortality , golden eagles.

All Both emc0167GB

20. lIn addition observations suggest that the raven population on the high desert has been steadily increasing. The birds appear 

to be constantly hunting the grouse habitats, are extremely aggressive and would appear to be very effective predators on 

young grouse.

All Both emc0173GB

21. Again, anecdotally, I have recently observed 40 - 60 ravens at one time cruising/hunting behind alfalfa swathers and 

effectively gobbling up any animals exposed or injured by the machines

All Both emc0173GB

22. If you want to know what is devestating the grouse just take a drive from st george to provo and count the number of 

ravens of the side of the freeway. i counted 52 and was not even looking that hard. i have also seen ravens chasing hawks 

and taking their kills. get rid of some of the ravens and knock down the coyote population and you will see the grouse come 

back.

All Both emc0186GB

23. The beneficial effects of predator control must be addressed in sage-grouse management strategies. Specifically, raven 

control could be beneficial to nest and chick survival. Nevada's raven population has grown dramatically over the past 25 

years and it has been stated we currently have extremely drastic increase in ravens over historic levels.

All Both emc0202GB

24. There has been a steady increase in predator type birds over the past several decades along with the mammalian predators 

that are not as vigorously controlled as they once were.

All Both emc0208GB

25. The beneficial effects of predator control must be addressed in greater sage-grouse management strategies, especially in 

areas where habitat changes have faciltated predation. I have seen efforts to poison Ravens and common Crows. Some of 

the poison eggs were deliberately hidden to see if the Ravens could still find them. They still found every one of them. The 

most effective approach to limiting the Raven and Crow predation is to focus on controlling Raven and Crow populations, 

not spending all of our efforts to make the habitat more "sagegrouse friendly".

All Both emc0215GB

26. Birds of prey are directly and negatively impacting the nesting success of sage grouse. In one study completed in Eastern 

Idaho, birds of prey accounted for over 60% of grouse nesting failures. In addition, birds of prey are negatively impacting 

adult grouse survival in part due to the installation of man-made perches such as telecom and electricity towers and poles. 

The conclusion of studies indicating sage grouse avoid elevated structures is only partially correct - they avoid them 

because of the predators that use them for perches or they are killed and eaten.

All Both emc0216GB

27. YOU PEOPLE NEED TO PAY ATTENSION TO THE STUDY'S THAT WAS DONE ON THE SAGE GROUSE. NEST 

WAS MADE WITH EGGS IN THEM TO COPY NEST LIKE THE SAGE GROUSE , PREDATORS ATE THE EGGS. AND 

IF YOU LOOK AT THE EAGLE THAT WAS BROUGHT BACK OFF THE ENDAngered LIST. WAS THIS NOT DONE 

All Both emc0220GB
C. Comments by Resource Planning Issue

C-1010 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

WITH EGG'S? DID WE HAVE TO TIE UP MILLIONS OF ACRES FOR THE EAGLES? WHAT ABOUT THE CONDOR, 

DO WE RAISE QUAIL AND PHEASANT FOR RELEASE? YES WE CAN AND DO. IT IS NOT SO MUCH THE SERVIVAL 

OF THE GROUSE AS IT IS TO HAVE IN PLACE A GROUSE MANAGEMENT TEAM, MORE GOVERNMENT, MORE 

PAY ROLL, MORE CONTROL. GET ON WITH THE PROGRAM HATCH AND RELEASE. IT'S BEEN DONE BEFORE, 

IT WORKS,

28. I understand too that the population of ravens, crows and magpies has increased greatly since they gained protection in 

1972, with the amendment to The Migratory Bird Treaty Act of 1918. Such birds are known to prey on sage grouse nests.

All Both emc0236GB

29. I understand that the population of ravens, crows and magpies has increased greatly after they have gained protection from 

the 1972 amendment of The Migratory Treaty Act of 1918. These birds prey on sage grouse nests. The necessary and 

productive grazing industry must not be made sacrificial lambs when many such factors have effect on sage populations.

All Both emc0238GB

30. Measures to limit perching by avian predators should not be required outside of a 0.6 mile distance from the center of a lek. All Both emc0242GB

31. Limiting ranchers' ability to develop water sources for fear of increasing mosquitos that might carry West Nile is 

counteractive to increasing sage grouse numbers. Lifting restrictions and allowing ranchers to develop water sources, fence 

and protect meadows, and allowing regulated shooting of the raven would help boost sage grouse numbers.

All Both emc0244GB

32. The effective range-wide predator and sage grouse occurrence intersection is shown in Figure 2. The Form conclusions of 

minimal effect of predation do not seem to follow from the discussion, especially as regards corvids. It bears noting that one 

of the references (Bui, et al., 2010) recommends taste aversion training to discourage ravens from eating sage grouse eggs. 

Will the bureaucracy consult with Mrs. Obama for insight on the change of diet she hoped for schoolchildren? With a $16 

trillion national debt, the bureaucracy is recommending diet therapy for the birds.

All Both emc0274GB

33. In sage grouse habitat, raven predation of nests essentially is 100% effective, in that whether one or all eggs are taken, the 

sage grouse subsequently abandon the nest (Bui et al., 2010). With the overwhelming raven population, this assures sage 

grouse extinction is on the way. Yet the agencies maintain that ranchers, power plants, mines and recreational visitors must 

be restricted while paying no substantial attention to the actual subsidized predators.

All Both emc0274GB

34. In 2010, NDOW allowed the taking of 1,500 ravens to reduce sage grouse predation. That appears to be less than two 

tenths of a percent of that subsidized predator population. Out of a legislatively mandated budget of $600,000 for 

predation control, $50,000 were spent on taking these ravens. $40,000 of the actual expenditure was funding separate 

from the NDOW predation control budget (NDOW, 2012). Fiscal as well as predation control may be an issue.

All Both emc0274GB

35. The nesting phase of the sage grouse life cycle may be critical in addressing predation. The Form states an average clutch 

size of seven eggs. Since the grouse completely abandon a depredated nest, the actual kill ration becomes 7:1. That is, there 

are seven grouse killed for each single predation event, whether the predator eats all the eggs or not. With that kill ratio,

suggesting predator control provides no significant benefit to the sage grouse flies in the face of both common sense and 

decency.

All Both emc0274GB

36. Discussion has been tendered that predation control is ineffective since removed territorial ravens simply are replaced by 

a higher number of transitory ravens (Coates, 2012). Barr (2012b) points out the following regarding this research: The 

predation control studies indicate the territorial ravens, knowing their normal hunting range, are three times as effective at 

All Both emc0274GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1011

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

nest depredation as the transitory birds. When the territorial ravens are removed by predation control, the transitory 

ravens, no longer harassed out, replace the territorial birds at twice the density. The two replacement birds thus hunt at 

a combined two-thirds the effectiveness of the removed raven. If the territorial raven takes ninety sage grouse eggs during 

the nesting cycle, this indicates the two transitory birds will take sixty. Though all ninety sage grouse will not be saved, 

thirty will be. There is an immediate benefit in using predator control, despite the government scientist and agency 

bureaucrat conclusions to the contrary.

37. The population numbers, hunting effectiveness, and kill ratios allow reasonable planning to immediately benefit the sage 

grouse. The following may provide a thirty percent sage grouse population growth per year. Additional government 

personnel will not be required, and the predator control will not interfere with habitat management, locally or range-wide. 

The plan outlined is most effective if applied throughout the eleven-state sage grouse range, though it will be locally 

effective and could be initiated sequentially. 2.8.1. Establish harvest rates for predators. This can be locally determined 

based on local conditions and population counts. For instance, using Boarman and Coe (2002) in Nevada the raven:sage 

grouse rate could be 11:1. Other predators and prey, such as coyotes and pygmy rabbits, would have specific harvest rates 

for the predators. 2.8.2. Establish a bounty. This can be a cash amount or it can be a service credit. The cash could be the 

expected government hunter cost per harvested bird. The cash bounty would simply be paid for submitted wings. The 

service credit would be an appropriate hunting license for the commensurate harvest rate. In Nevada, submitting eleven 

ravens would earn a sage grouse license or stamp. 2.8.3. Consider the kill ratios for the life phases of the prey. They may 

be multipliers to the base harvest rate. For instance, with the sage grouse, the raven kill ratio during the nesting cycle is 7:1. 

That ratio may be much lower during other phases of the sage grouse life cycle, since subsequent predation events may not 

kill as many sage grouse in one action. 2.8.4. Enact and then monitor predator and prey population levels. Adjust harvest 

rates as appropriate. This approach manages the animals, not the people. Significantly, it allows the citizen to be the 

principal agent in protecting the sage grouse. The current agency policies, as with the unsuccessful spotted owl program, 

presume government personnel must be intimately involved. Habitat management essentially is a people-management 

mechanism, and does not directly, certainly does not immediately, help the prey. Habitat management solves the wrong 

problem at the wrong time.

All Both emc0274GB

38. Immediate predator control is essential for the survival of the sage grouse. Agency numbers indicate that in Nevada there 

are eleven ravens for every sage grouse. Agencies still insist controlling that significant predator is not a priority. That is like 

putting one lone player on the football field against a full opposing lineup. The government scientists are telling the lone 

player not to worry about what will happen after the starting whistle, because the habitat-managing bureaucrats are 

building the lone player a fine clubhouse

All Both emc0274GB

39. On page 19, Minerals section, second paragraph, there is mention of abandonment of leks by male sage-grouse if leks are 

repeatedly disturbed by raptors perching on power lines near leks. The mitigation measure or conservation measure 

should include anti-perching devices on these structures and not prevent mining or energy development. Similarly, 

predator control of ravens, crows, and magpies (corvids) is possible in identified nesting areas where power lines provide 

perches for corvids to watch for sage-grouse hens to leave the nest.

All Both emc0322GB

40. Sage grouse standards for wind and transmission lines Wind power generation represents a clean, renewable alternative All Both emc0343GB
C. Comments by Resource Planning Issue

C-1012 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

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No.

Comment SubRegion

ID

Agency CmtLtrCode

to fossil fuels, but construction of wind farms in key habitats is likely to lead to unacceptable levels of impact. Although 

there is little published science directly addressing the impact of wind turbines or transmission lines on sage grouse, there

is a broad consensus among biologists that sage grouse avoid tall structures (such as wind turbines and transmission 

towers) and abandon adjacent habitats. One unpublished study found that sage grouse habitat use increased with distance 

(up to 600 meters) from transmission lines. It is notable that modern perch inhibitors emplaced on transmission lines result 

in a major decrease, but not elimination, of raptor perching (Slater and Smith 2010). Molvar (2008) compiled BLM data 

from a wind power project on Cotterel Mountain, Idaho and was able to determine that the erection of seven 

meteorological towers led to drastic declines in sage grouse populations across nine sage grouse leks, while populations in 

the surrounding area remained stable. See Attachment 5. There has been abundant scientific information that other types 

of energy development, particularly oil and gas, has a major impact on sage grouse populations, and oil and gas development 

has some similar features such as habitat fragmentation and tall structures (in the form of drilling rigs).

41. At minimum, the NEPA analysis should address the following: • Assessing the impacts of permitted activities that increase 

the nesting populations of ravens (see Bui et al. 2010, Dzialek et al. 2011), an important nest predator, by providing nest 

platforms, and creating standards to minimize this effect in sage grouse habitats.

All Both emc0343GB

42. We have also not been able to detect in our studies any increased avian predation on greater sage-grouse as a result of the 

power Iines.I\Furthermore, work performed by Dr. James Sedinger of the University of Nevada, Reno, in studying the 

Falcon to Gondor transmission line in eastern Nevada, has resulted in eight years of data showing that impacts to greater 

sage-grouse are more attributed to natural predation, wildfire impacts-habitat impacts from cheatgrass invasion, habitat 

fragmentation, and fitness of females.

All Both emc0399GB

43. Why are there provisions to "have no tanks at well locations within priority areas" for fluid minerals, but no similar 

provisions for the battery of livestock wells, water tanks, and other elevated structures that exist across the sagebrush 

biome in occupied sage-grouse habitats? Is the battery of tens of thousands of elevated livestock range development 

structures all going to be "grandfathered in" and allowed to continue to be in left in place degrading sage-grouse habitats 

and public wild lands? These elevated structures promote opportunities for nesting and perching by ravens, or elevated 

raptor perches, or may impact grouse use of an area by providing taller visual intrusions.

All Both emc0411GB

44. A moratorium should immediately be placed on all wind energy development projects, rights-of-way, and MET towers on 

public lands. Across the range of sage-grouse and the western landscape, very little is known about migration patterns for 

migratory songbirds and other migrants, including bats and migrating insects like dragon flies. Many areas with the higher 

wind potential are often ridges or plateau rims, and are also the relatively undeveloped remaining sagebrush wild lands - as 

these areas typically have shallower soils, or abundant rocks in some areas, or steep drop-offs, rimrocks or cliffs. So these 

windy areas were not targeted by agencies for livestock sagebrush eradication projects, crested wheatgrass seedings, 

intensive pasture fencing and pipeline schemes that typically accompanied livestock forage schemes on productive sites. 

Thus, they are less developed for livestock, and are often better condition remnant habitats that serve as refugia for 

sage-grouse. Moreover, sage-grouse impacts are but one part of the large-scale adverse impacts of industrial wind facilities. 

Lethal golden eagle impacts, and impacts to migrating species, are often just not understood in sufficient detail to enable 

agencies to merely push siting onto non-priority or non-sage-grouse habitats.

All Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1013

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

45. Much more detailed studies of bird and other volant species migration and habitat use patterns must be conducted before 

any areas can be proposed for wind development on public lands. Across the western landscape, very few studies have 

been done. Those that have conducted are often overseen by wind developers or in response to threats of development 

– and may include only spotty observations over a single season. Necessary night-time radar studies over all migration 

periods and thorough groundbased observation studies have often not been conducted. Storms during migration periods 

- and especially spring storms – can down migratory birds and alter areas of highest migrant presence. These effects are 

seldom if ever addressed. The studies we have seen repeatedly point to the most exceptional known high-use areas, such 

as the Goshute range in the context of raptor migration, as a benchmark for significance of avian use. The studies then try 

to minimize importance of all other areas by claiming that, for example, ridges in the Great Basin don’t have as much raptor 

use as the Goshute Range. Thus, they are deemed to be of much lesser importance. With Spring Valley Wind, BLM (and 

NDOW capitulated) knowingly impacted 9% of the North Spring Valley PMU, and further severed habitat connectivity 

between PMUs. Placing a moratorium on industrial wind development and associated infrastructure on public lands in the 

sagebrush biome would ensure that adequate knowledge could be gained so that: - Sage-grouse habitats will be effectively 

protected and conserved. - Conservation actions aimed for sage-grouse do not shift wind development into, and harm, 

wildlife in other areas – and cause significant harm and mortality to other species whose migration pathways are not known 

– such as migrating warblers, western tanagers, rare bats like the Townsend’s big-eared bat, or into areas where high 

golden eagle mortality is likely.

All Both emc0411GB

46. The sage steppe is important habitat for th Greater Sage grouse, but also to other species, e.g. Gunnison Sage]grouse, Sage 

Sparrow, Sharp-tailed Grouse.

All Both fla0029gb

47. The beneficial effects of predator control must be addressed in greater sage-grouse management strategies, especially in 

areas where habitat changes have faciltated predation. I have seen efforts to poison Ravens and common Crows. Some of 

the poison eggs were deliberately hidden to see if the Ravens could still find them. They still found every one of them. The 

most effective approach to limiting the Raven and Crow predation is to focus on controlling Raven and Crow populations, 

not spending all of our efforts to make the habitat more “sagegrouse friendly”.

All Both flj0002gb

48. The U.S. Government has created and developed treaties with other nations to protect natural predators specific to the 

Greater Sage-Grouse, the Raven. The Raven protected by 50 CFR "Birds Protected by The Migratory Bird Treaty Act" of 

1918. This restricts and limits predator control by the state agencies responsible for wildlife and wildlife habitat. The 

USF&WS is permitted to allow for a specific number of Ravens to be harvested each year. Mr. Mike Conover, a wildlife 

biologist at Utah State University, states after a four year study in southwest Wyoming that the sage grouse are big birds 

with big eggs, which make them tempting targets for ravens. Mr. Conover also stated it appears many nests fail because 

ravens eat the eggs and the young. Mr. Conover also stated that the Raven population booms are in part attributed to 

human household waste and its availability to the Raven. Although there aren't as many statistics, Conover said the raven 

population is swelling unchecked in Wyoming, as the birds have few significant predators, this has been the circumstance 

for Northern Nevada as well. There have been numerous other studies and data prepared that have researched and 

developed concerning Raven predation that indicate the same results. It is acknowledged that other predators may also 

have negative impacts to the Greater Sage-Grouse however, the Raven is a protected species and cannot be controlled 

All Both rmc0026GB
C. Comments by Resource Planning Issue

C-1014 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

without a permit and only within the limits set forth by The Migratory Bird Treaty Act.

49. VGC knows from working with BLM to secure authorization for our mineral activities on BLM administered lands, that 

BLM already has rules and policies to ensure that mineral projects protect sage-grouse habitat. The U.S. Forest Service 

("USFS") has similar policies to protect sage-grouse habitat on National Forest System lands. BLM Notices and BLM and 

USFS Plans of Operations for mineral projects contain numerous permit conditions and stipulations to protect sage-grouse 

habitat. Examples of these measures include seasonal restrictions on when and where activities can occur, buffer zones 

around identified sage-grouse leks, limiting constructionof new overhead structures that provide raptors perching sites, 

and installing anti-perching devices on existing transmission lines.Given the existing regulatory framework under which 

VGC and other mineral exploration and development companies must operate, we question the need for a completely 

new policy direction, like that proposed in the NTT Report. Before BLM and USFS "go back to the drawing board" and 

create new regulatory programs to protect sage-grouse habitat, they should first perform a gap analysis of the existing 

policies to determine what - if anything - needs to be improved or modified.

All Both rmc0029RM, 

rmc0060GB

50. iii. Strong components of Wyoming’s approach For transmission lines, 2-mile wide transmission corridors have been 

identified in an effort to colocate disturbances. Construction is prohibited between March 15 and June 30 (or between 

December 1 and June 30 in winter concentration areas) and within 0.5 miles on either side of the existing transmission 

lines. If new lines are proposed for core area, they must be either buried or outfitted with raptor per deterrents to 

minimize avian predation pressure on sage-grouse.

East Both emc0089RM

51. i. Lander, WY RMP Alternative B also requires anti-perching devices to be installed on all new overhead powerlines in 

greater sage-grouse, white-tailed prairie dog, mountain plover, and pygmy rabbit habitats to reduce predation from 

raptors. In addition, the BLM will work with ROW holders to identify conflict areas and get anti-perching devices installed 

on existing overhead powerlines in these same habitats. (DEIS 882) Because approximately 74-80% of sage-grouse females 

nest within 4 miles of leks (Moynahan 2004, Holloran and Anderson 2005), this measure may help to reduce predation 

pressures on nesting and foraging grouse. We recommend the use of deterrent devices on H-frame structures because 

recent research indicates they are effective tools in reducing perch use of such structures (Lammers and Collopy 2007, 

Slater and Smith 2010). The BLM and FS should consider not only anti-perching devices to reduce raptor predation on 

grouse, but also measures (not included in the Lander RMP) that would reduce conditions (e.g., nest substrates and 

anthropogenic attractants) that enhance local raven populations, to reduce potential raven predation on sage-grouse nests. 

Energy development in undeveloped sagebrush areas has been shown to facilitate increases in the abundance of breeding 

ravens, with concomitant negative effects on nest survival of sage-grouse (Bui et al. 2010, Coates and Delehanty 2010). 

Raven predation on grouse nests may have a significantly adverse impact on local grouse populations (Coates 2007). BLM 

and FS should recommend that any newly permitted permanent, highprofile structures will be outfitted with raven 

deterrents.

East Both emc0089RM

52. i. Lander, WY RMP Alternative B also prohibits new permanent structures taller than 12 feet within 1 mile of occupied 

nesting habitat. We strongly support this as a means to prevent area avoidance by sage-grouse.

East Both emc0089RM

53. Additionally, we have noticed a substantial increase of Hawks and Raven popularions in the Virginia Range and question 

what type of impact the increased populations have on the sage-grouse and there nesting

NVCA Both emc0232GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1015

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

54. Ravens are ranked in the category of Least Concern (IUCN, 2011) as regards susceptibility to extinction. They are 

recognized as subsidized predators in large through their ability to adapt to resources made available by human activity. 

Due to their wide diet and hunting characteristics, they engage in hyperpredation whereby they can remain in an area and 

continue to hunt declining species while extending their diet to more abundant prey. In so doing, they continue to threaten 

the less numerous species rather than move on and relieve the predation pressure. With a 15-fold increase of raven 

population in the last fifty years, the bureaucracy does not consider that active reduction of ravens merits scientific, let 

alone policy discussion. In the same time frame, the bureaucracy has neither consistently counted nor consistently 

reported sage grouse populations, yet asks the taxpayer to accept the bureaucratic conclusion that listing is inevitable. One 

of the Mojave desert studies reported by Boarman & Coe (2002) indicates 3.35 ravens per square kilometer. Applying that 

density to the 284,449 square kilometers comprising the state of Nevada suggests there may be 952,000 subsidized 

predators available to prey on sage grouse. The 2004 sage grouse count for California and Nevada indicated 88,000 birds 

(Form). Even were all these sage grouse within the boundaries of Nevada, apparently there are nearly eleven ravens for 

each sage grouse. Since some of those sage grouse are in California, there actually may be more than eleven ravens per 

grouse within Nevada. This author recognizes and stresses these numbers must be accepted with care, as they are neither 

spatially nor temporally consistent. The fact is that readily comparable numbers are difficult to obtain precisely because the 

agencies consistently gloss over the actual counts of both the subsidized predator and the prey, and they never directly 

compare the raven and sage grouse populations. Certainly this author’s decades of living and working in sage grouse and 

raven range suggest the eleven-to-one ratio is realistic.

NVCA Both emc0274GB

55. The beneficial effects of predator control must be addressed in sage-grouse management strategies. Specifically, raven 

control could be beneficial to nest and chick survival. Nevada's raven population has grown dramatically over the past 25 

years and it has been stated we currently have extremely drastic increase in ravens over historic levels.

NVCA Both emc0304GB

56. In the analysis of Predation Factors contributing to Sage Grouse declines, the ODFW EIS fails to include analysis of the 

effects that past ODFW and NFWS raptor recovery programs conducted in the western US over the course of the last 40 

years have had on increased Sage Grouse populations. Without such information the EIS analysis is incomplete, and one 

cannot reasonably assess whether the Raptor conservation and recovery programs so far conducted are in themselves a 

major or significant contributor to regional Sage Grouse Decline. Raptor Recovery efforts and success over the last 4 

decades may be measured using data and information from The Audubon Society through Bird Count and other 

Publications as well as data from the USFWS and numerous local birding groups. Estimates of concurrent increases in Sage 

Grouse Predation should be examined in relation to this data. The EIS must answer the question; Is the observed 

declining Sage Grouse population simply responding to increased predation by the increased numbers raptors over their 

range?

OR Both rmc0036GB

57. The practice of erecting artificial hawk nests or raptor perches that have taken place in some of the winter grounds of the 

sage grouse can’t be good for the grouse as it enables their natural enemies (eagles) a perfect opportunity to infiltrate the 

wintering ground.

UT Both emc0295GB

58. The practice of erecting artificial hawk nests or raptor perches that have taken place in some of the winter grounds of the 

sage grouse can’t be good for the grouse as it enables their natural enemies (eagles) a perfect opportunity to infiltrate the 

UT Both emc0296GB
C. Comments by Resource Planning Issue

C-1016 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.B

Comments Related to Wildlife-Birds

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

wintering ground.

59. There are a great deal more raptors in NE Wyoming than there were 40-50 years ago, and while I'm not recommending 

killing eagles, that factor should be strongly considered in lower grouse numbers.

WY Both cfc0018RM

60. There are many natural threats to grouse which seem to get very little attension. In our area, expansion of and distruction 

of sage brush by prairie dogs is a very real threat which could be greatly avoided by active control of prairie dogs. Another 

problem which probably can not be addressed is the predation by large raptors. We are seeing as increase in these, 

particularly eagles, which certainly have a bearing on Sage Grouse survival, as well as dissturbance at leks.

WY Both cfc0032RM, 

rmc0025RM

61. The Bentonite Road in Valley County is recognized as one of the best places to see a mountain plover. The RMP should 

preserve the current management of that habitat.

WY Both emc0013RM

62. iii. Strong components of Wyoming’s approach For transmission lines, 2-mile wide transmission corridors have been 

identified in an effort to colocate disturbances. Construction is prohibited between March 15 and June 30 (or between 

December 1 and June 30 in winter concentration areas) and within 0.5 miles on either side of the existing transmission 

lines. If new lines are proposed for core area, they must be either buried or outfitted with raptor per deterrents to 

minimize avian predation pressure on sage-grouse.

WY Both emc0089RM

63. i. Lander, WY RMP Alternative B also requires anti-perching devices to be installed on all new overhead powerlines in 

greater sage-grouse, white-tailed prairie dog, mountain plover, and pygmy rabbit habitats to reduce predation from 

raptors. In addition, the BLM will work with ROW holders to identify conflict areas and get anti-perching devices installed 

on existing overhead powerlines in these same habitats. (DEIS 882) Because approximately 74-80% of sage-grouse females 

nest within 4 miles of leks (Moynahan 2004, Holloran and Anderson 2005), this measure may help to reduce predation 

pressures on nesting and foraging grouse. We recommend the use of deterrent devices on H-frame structures because 

recent research indicates they are effective tools in reducing perch use of such structures (Lammers and Collopy 2007, 

Slater and Smith 2010). The BLM and FS should consider not only anti-perching devices to reduce raptor predation on 

grouse, but also measures (not included in the Lander RMP) that would reduce conditions (e.g., nest substrates and 

anthropogenic attractants) that enhance local raven populations, to reduce potential raven predation on sage-grouse nests. 

Energy development in undeveloped sagebrush areas has been shown to facilitate increases in the abundance of breeding 

ravens, with concomitant negative effects on nest survival of sage-grouse (Bui et al. 2010, Coates and Delehanty 2010). 

Raven predation on grouse nests may have a significantly adverse impact on local grouse populations (Coates 2007). BLM 

and FS should recommend that any newly permitted permanent, highprofile structures will be outfitted with raven 

deterrents.

WY Both emc0089RM

64. i. Lander, WY RMP Alternative B also prohibits new permanent structures taller than 12 feet within 1 mile of occupied 

nesting habitat. We strongly support this as a means to prevent area avoidance by sage-grouse.

WY Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1017

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Make sure all federal lands are included in the conservation plan. Use the best available conservation biology science. All Both cfc0015GB

2. For too long, management of these lands has focused first on the needs of humans who wish to use the area: miners, 

ranchers and recreation users. While these individuals certainly may have legitimate interests in making use of these 

lands, their needs and desires must be subordinated to the scientifically based needs of the native wildlife of the lands if 

proper management is followed. Only through this approach can the flora and fauna of these lands be adequately 

protected and the BLM and Forest Service fulfill their responsibilities.

All Both emc0065GB

3. What is important in resource management is first identifying what you have and then designing a management strategy 

to get where you need to go. In the science of range resource management, you need an experienced range ecologist to 

accomplish this task. They are few and far between and they cannot be replaced by biologists. The agencies must use 

seasoned professionals with expertise in range ecology to develop realistic sagebrush management strategies in order to 

be effective in managing sage-grouse habitat.

All Both emc0070GB

4. We urge that this planning process embrace an ecosystem approach to management of the full suite of sage-obligate 

species, and consciously strive to provide conservation benefits to pygmy rabbits, and other flora and fauna.

All Both emc0078GB

5. Monitoring: Methodology of monitoring should be flexible enough to allow local input and modifications on the 

adaptability of the species. Monitoring should compel decision-making for adjustments in multiple-use activities only 

when adequate data justifies decisions. FLPMA and the land use planning regulations call for BLM to maintain a current 

inventory of the public lands and to collect updated information about ecological conditions in preparing land use plans. 

See 43 U.S.C. § 1711(a); 43 C.F.R. § 1610.4-3. Moreover, this information is essential for BLM’s analysis of greater 

sagegrouse impacts and alternatives in the RMP/LMP EIS/SEIS processes, as BLM recognized in its 2004 National 

Sage-Grouse Habitat Conservation Strategy, Section 1.3.1, pp. 2-4 (Docket No. 90-5). In accordance with the 

Memorandums of Understanding (MOUs) between Public Lands Council (PLC) and both BLM and FS, (WO 220-2004-0 

and NO. 09-SU-11132421-171, respectively), the agencies should work cooperatively with permittees to collect data 

and accept monitoring data collected by permittees.

All Both emc0140RM

6. Whenever the BLM determines that ecological conditions on an allotment or pasture are not meeting the Fundamentals 

or the Standards and Guidelines it is imperative to take a “good look” to determine if grazing is impacting the condition 

of a plant community and how it is happening. The BLM assessments using Standards of Rangeland Health has limitations 

in the elements that can identify the cause and effects of resource condition, because it is more qualitative than 

quantitative. Where areas fail to meet the standards, a close look must follow to rigorously quantify the resources to 

determine if the process failed to take into account natural factors, livestock use, or other BLM activities. As stated 

above, this may require numerous, rigorous studies and we hope to see a full discussion of the research and study gaps 

that must be addressed in conjunction with the multiple uses on public lands for the conservation of sage grouse.

All Both emc0159GB

emc0222GB 

emc0209GB

7. Whenever the BLM determines that ecological conditions on an allotment or pasture are not meeting the Fundamentals 

or the Standards and Guidelines it is imperative to take a “good look” to determine if grazing is impacting the condition 

of a plant community and how it is happening. The BLM assessments using Standards of Rangeland Health has limitations 

in the elements that can identify the cause and effects of resource condition, because it is more qualitative than 

All Both emc0179GB
C. Comments by Resource Planning Issue

C-1018 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

quantitative. Where areas fail to meet the standards, a close look must follow to rigorously quantify the resources to 

determine if the process failed to take into account natural factors, livestock use, or other BLM activities. As stated 

above, this may require numerous, rigorous studies and we hope to see a full discussion of the research and study gaps 

that must be addressed in conjunction with the multiple uses on public lands for the conservation of sage grouse.

8. Livestock grazing also causes numerous indirect effects that can negatively impact sage-grouse. For example, in addition 

to direct competition with sage-grouse for rangeland resources, livestock may also create similar competition for other 

species such as mule deer, white-tailed deer, elk, pronghorn, and bison. This competition may alter the distribution of 

these species, which may be particularly important when management for one species is in potential conflict with 

sage-grouse. One example would be the removal of sagebrush for improvement of elk range. Additionally, livestock can 

often indirectly spread invasive species or weeds, such as cheatgrass, which can negatively impact sagebrush survival and 

alter the fire-risk of an ecosystem

All Both emc0276GB

9. ii. Range of alternatives should not be more restrictive than an Endangered Species Act ("ESA") Listing The agencies' 

objective in launching the RMP revision process is to "conserve sage-grouse and its habitat and potentially avoid an ESA 

listing...21 While the prospect of a sage-grouse listing and its regulatory consequences may be daunting, the restrictive 

measures recommended by the National Technical Team may be even more so. Indeed, the ESA permits the Fish and 

Wildlife Service to at least consider each proposed action individually, taking into consideration the site-specific 

circumstances, species and habitat conditions, potential effects to the species, and potential mitigating actions. While 

"take" of listed species is prohibited under the ESA, there are opportunities for take permits. By contrast, some National 

Technical Team recommendations would put millions of acres of public lands off limits from mineral entry or arbitrarily 

cap disturbance regardless of sitespecific species occurrence and habitat conditions, or mitigation opportunities that 

might be offered by the project proponent. In deciding what conservation measures should be imposed to avoid a listing, 

the agencies must consider whether the measures proposed may cost more than the ESA listing it is attempting to avoid. 

The irony of the agencies' purpose to avoid a listing and the BLM National Technical Team's recommended conservation 

measures is highlighted by the Technical Team's proposal to withdraw from mineral entry priority sage-grouse habitat 

areas.22 The Technical Team also recommends a 3% surface disturbance cap in priority habitat.23 Such blanket 

prohibitions that admit no exceptions based on habitat conditions and quality, species occurrence, or mitigation that 

might be offered by the project applicant are at once inflexible and draconian, evidencing a singularity of purpose that 

directly contradicts the agencies' multiple-use mandates. By contrast, an ESA listing does not automatically put off 

limits all projects that might adversely affect the species or its critical habitat within its range. In fact, the ESA specifically 

provides processes to obtain "take" authorization for both private projects and those with a federal nexus. For private 

projects that might result in "take"-defined broadly to include any activity that would or would attempt to harass, harm, 

pursue, hunt, shoot, wound, kill, trap, capture, or collect a species, 50 C.F.R. § 17.3-an applicant can obtain an Incidental 

Take Permit under ESA Section 10 after preparing an approved Habitat Conservation Plan. 16 U.S.c. § 1539(a)(l)(B); 50 

C.F.R. § 17.22(b)(l)(iii). A Habitat Conservation Plan specifies the actions that will be taken by the project applicant to 

minimize and mitigate effects to the listed species. Measures can be as varied as avoiding Impacts by relocating project 

facilities, minimizing impacts through timing restrictions and buffer zones, rectifying impacts by restoration and 

All Both emc0277GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1019

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

re-vegetation, and compensating for impacts by habitat restoration or protection at an offsite location.24 The Fish and 

Wildlife Service can issue an incidental take permit if after considering the effects and committed mitigation measures, 

the taking will not appreciably reduce the likely survival or recovery of the species as a whole. 50 CF.R. § 17.22(b)(2). 

Similarly, when an agency such as BLM permits an activity that is likely to adversely affect a listed species, it must initiate 

Section 7 consultation with the Fish and Wildlife Service to ensure that the proposed action will not jeopardize the 

continued existence of the species. 50 C.F.R. § 402. 14(a). The Service issues a Biological Opinion to determine whether 

jeopardy will occur. /d. § 402.14(g). The Service may take into consideration any conservation measures or other 

agreements between the action agency and the project proponent, including commitments to mitigate and minimize 

impacts. See Selkirk Conservation Alliance v. Forsgren, 336 F.3d 944, 956 (9th Cir. 2003). Thus, in both the Section 10 

and Section 7 context, there is no absolute prohibition on activities that might "take" species. Rather, project approval 

is based on whether, after applying the mitigation measures proposed by the applicant, the action will appreciably reduce 

the likelihood of the survival or recovery of the species, or result in jeopardy, respectively. The ESA permitting 

processes encourage cooperation between the Service and the applicant to find solutions that both allow the applicant's 

project to move forward while conserving the species. The mineral industry is familiar with ESA processes and has 

worked successfully with the Fish and Wildlife Service over several decades to ensure mining operations do not place 

listed species such as the Lahontan cutthroat trout in jeopardy. Whatever conservation measures the agencies 

ultimately implement in its various RMPs, they should encourage similar collaboration for species conservation and 

avoid industry-stifling blanket prohibitions that fail to take into consideration individual project proposals and 

site-specific circumstances. Barrick encourages the agencies to consider, and incorporate in their management plan 

revisions, alternatives that provide flexibility to the agencies to work with industry toward effective conservation while 

permitting multiple uses of the public lands.

10. However, as described above, fences can provide time-control, and proper grazing can significantly improve rangeland 

function and GSG habitat, improving vital rates and increasing populations. If used properly, fence benefits to rangeland 

function outweigh the negative effects. Large herds and large pastures are preferential than small herds and small 

pastures from and economic and ecological perspective.

All Both emc0281GB

11. SGI efforts are focused on priority areas, which were identified by working with Utah Division of Wildlife Resources and 

sage grouse biologists in Utah.

All Both emc0300GB

12. NRCS, in conjunction with numerous partners, has funded three 3-year SGI rangeland ecologist positions in Utah. These 

positions are 100% focused on planning and implementing projects to benefit sage grouse.

All Both emc0300GB

13. The TRCP values our fish & wildlife resources and encourages you and your staff to establish options that ensure 

responsible energy development in a way that sustains sage grouse. The TRCP’s recommendations and priorities 

regarding management of fish and wildlife during energy development are organized under the five fundamental areas of 

Funding, Accountability, Coordination, Transparency and Science (FACTS). The IM’s issued must take these areas into 

account for the national planning strategy to be successful. In 2006, the TRCP released the “FACTS for Fish and

Wildlife,” specific recommendations for balancing fish and wildlife needs with the development of energy resources. 

Revised in 2011, the current FACTS document updates those recommendations, expands their applicability to broader 

All Both emc0380GB
C. Comments by Resource Planning Issue

C-1020 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

Comment 

No.

Comment SubRegion

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Agency CmtLtrCode

geographic regions, and addresses forms of energy development beyond traditional oil and gas. The FACTS revision will 

allow for fish and wildlife stewardship through better policy and management during energy development. The FACTS 

recommendations are applicable, with a few exceptions, to land and water, traditional or renewable energy, public or 

private lands, and infrastructure associated with development. They can increase our ability to responsibly manage fish

and wildlife during energy development, balance competing values, become conservation stewards and ensure a future 

for our fish and wildlife populations. These practices – driven by the FACTS – will sustain and uphold our nation’s shared

natural resources and unique outdoor legacy.

14. Funding is required for adequate fish and wildlife management. Historically, fish and wildfire programs are underfunded 

or rely on funding sources other than federal monies. While funding alone will not solve the problem, it plays a critical

role in our ability to balance energy development with the needs of fish and wildlife. Funding must be secure, substantial 

and properly allocated to make a difference. TRCP recommends that you: · Determine adequate funding for sustainable

fish and wildlife management, including monitoring, in areas proposed for energy development. · Prior to development, 

identify and secure appropriate funds for fish and wildlife monitoring and mitigation, including compensation if necessary 

or required. · Establish a long-term, dedicated “mitigation trust” to benefit fish and wildlife that is funded by royalties, 

rents, fines or voluntary payments. · Ensure that funds designated and intended for fish and wildlife management are not

redirected to other causes. · Work cooperatively with various funding sources to leverage additional federal or state

grants.

All Both emc0380GB

15. Accountability entails accepting responsibility for actions. On public lands, promises are made through various decision 

strategies and should be considered “contracts with the people” that mandate proper stewardship of the nation’s lands

and minerals. TRCP recommends that you: · Proactively address fish and wildlife management needs with a specific

“conservation strategy” for each energy field or project. Finalize conservation strategies before development starts and 

specify recommendations and actions to minimize impacts and establish plans for mitigation, detailed monitoring and 

adaptive management. · Establish and update regularly a system of tracking commitments, in plans or agreements, along 

with any actions contrary to those commitments. · Ensure that laws, regulations and policies intended to conserve and 

protect fish and wildlife during energy development are not abdicated or abridged. · Utilize lease development plans or 

master lease planning to evaluate and address potential impacts to fish and wildlife prior to development. · Notify the 

public and allow public comment on energy development projects involving public lands or resources. Provide the public

with information regarding modifications to current development plans.

All Both emc0380GB

16. Coordination is essential in ensuring that fish and wildlife are properly managed, within and across administrative 

boundaries. All stakeholders must be involved, and experts that manage fish and wildlife at the local, state or national 

levels must be included in energy project planning and implementation. Coordination enables unanticipated or 

unforeseen actions that arise during development to be addressed in a timely and appropriate manner. A key 

stakeholder in the administration of public lands and fish and wildlife resources, the public must be included to build

trust and brainstorm management tactics. TRCP recommends that you: · Foster broad-based coordination between fish 

and wildlife managers, landowners and affected stakeholders to ensure fish and wildlife sustainability. · Establish 

expanded coordination across geopolitical boundaries between property owners (public and private). Coordination

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1021

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

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No.

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Agency CmtLtrCode

between the Wyoming Game & Fish Department, US Fish & Wildlife Services, and other federal and state land agencies 

must occur to ensure consistent and comprehensive management objectives across geo-political boundaries. · Ensure 

that managers consider the crucial habitats as well as movement or transitional corridors of fish and wildlife. · 

Coordinate among all affected stakeholders during planning and implementation of public-lands energy projects. · 

Include state fish and wildlife agencies in energy development planning and the monitoring of fish and wildlife during and 

after development. · Establish a process for annual review and adjustments of actions that affect fish and wildlife. An 

adaptive management strategy is appropriate if based on established adaptive management guidelines and science.

17. Transparency is essential to building trust among stakeholders and the general public. Transparency can prevent 

unnecessary delays, legal actions or bad press. Openness during energy development enables fish and wildlife 

management that benefits all stakeholders, not just project proponents. TRCP recommends that you: · Identify “special 

places” with exceptional resource concerns or values where energy development should not be allowed. Map these 

locations and incorporate these values into management plans. · Continue to provide up-to-date information through a 

range of media and informational outlets to the public and fish and wildlife managers regarding energy development

projects. · Direct and manage leasing and development using complete and up-to-date baseline information on fish and 

wildlife resources. · Utilize coordinated plans for energy development and fish and wildlife management. · Provide the 

public with information about all proposed public-lands energy leases and development; allow sufficient time for public 

comment. · Ensure that all meetings related to public lands use and energy development part of the public record.

All Both emc0380GB

18. Science is the foundation of sustainable land and resource management. It is essential to understanding how fish and 

wildlife react to energy development and maintaining sustainable populations during and after development. Utilizing 

peer reviewed and published science enables a balanced approach that sustains both energy AND fish and wildlife 

instead of either energy OR fish and wildlife. TRCP recommends that you: · Utilize science, including most current 

published science in all fish and wildlife decisions, particularly when specific research has been conducted on the impacts 

of energy development. For your convenience, a list of recently published literature has been attached to this letter. · 

Assure that mitigation and monitoring based on new scientific information is implemented in the energy development 

process. · Incorporate science-based mitigation, using tested and proven methods of adaptive management, when 

making decisions about fish and wildlife management and energy development. Identify and address “gaps” in science 

prior to development and implement coordinated research to address these gaps. · If necessary, utilize a third-party 

review of development and mitigation proposals. · Establish a credible and qualified “science review team” and engage 

science-based organizations for fish and wildlife management and development decisions. · Establish a process to 

incorporate new information and science into planning and implementation of existing and new energy projects.

All Both emc0380GB

19. Developing and implementing conservation strategies at regional or landscape scales will have the greatest benefit for 

sage-grouse and sagebrush steppe (Holloran 2005). Protecting large expanses of sagebrush steppe and current 

populations of Greater Sage-grouse are the highest priority (Connelly et al. 2011a; Wisdom et al. 2005c). Establishing a 

system of habitat reserves in sagebrush steppe will help conserve habitat components and ecological processes 

important to species conservation. Sage-grouse are a useful, if imperfect, umbrella species1 for sagebrush steppe. A suite 

of sagebrush birds are declining and would benefit from increased protection of sagebrush steppe (Knick et al. 2003). 

All Both emc0391GB
C. Comments by Resource Planning Issue

C-1022 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Rich et al. (2005: 602) contended that “conservation of Greater and Gunnison Sage-grouse populations in reasonable 

numbers well distributed across their historical ranges also will provide for the conservation of many, or even most, 

other bird species that co-occur with these grouse.” Rowland et al. (2006) also found that conserving Greater 

Sage-grouse may benefit other species, particularly sagebrush obligate wildlife. Given the importance of public lands to 

sage-grouse conservation; the sensitivity of these lands to disturbance, longer recovery periods and variable response to 

restoration; and their susceptibility to invasion by exotic plants (Knick 2011), land uses that negatively affect these lands 

should be restricted or eliminated in key habitat areas to conserve sage-grouse habitat.

20. Habitat loss and mismanagement. Issue: Sagebrush steppe is among the most imperiled landscapes in North America; 

millions of acres have been lost to crop agriculture, urban development, and other land uses, while remaining sagebrush 

habitat is degraded and fragmented by gas and oil drilling, livestock grazing, unnatural fire, invasive species, roads, fences, 

utility corridors and related effects. Habitat loss and degradation continues and efforts to protect and restore sagebrush 

steppe are inadequate, ineffective and hampered by myriad factors.

All Both emc0391GB

21. The EIS needs to examine the different habitat factors that exist over the range occupied by Sage Grouse. The overall 

habitat in Nevada, which is a Basin and Range region, is quite different than the rolling sagebrush plains of Wyoming. It 

is critical that the EIS acknowledge the differences in physiography and habitat characteristics which exist over the range 

occupied by the Greater Sage Grouse.

All Both emc0397GB

22. Furthermore, in the process of developing the conservation reserve design for Greater Sage-Grouse under whichever 

landscape-scale ecological assessment is used, the following criteria must be considered: Locations that support other 

sensitive biological resources, including: federally designated and proposed critical habitat; significant populations of 

federal or state threatened and endangered species; significant populations of sensitive, rare and special status species; 

and rare or unique plant communities;

All Both emc0407GB

23. Landscape-level biological linkage areas required for the continued functioning of biological and ecological processes and 

allowing for long-term shifts in distribution of native species in response to climate change;

All Both emc0407GB

24. Areas that support a geophysical or other ecosystem processes upon which sensitive biological resources depend. All Both emc0407GB

25. Many of the older Land Use Plans had goals or objective to improve specific ecological conditions sagebrush habitats, 

meadow habitats, riparian habitats, mountain mahogany communities, etc. To what degree have these goals been met, 

and has the ecological condition been improved? Where? To what degree? How have flows (where records are 

available, for example from Water Inventories in Nevada) changed over time? How many wet meadow or spring areas 

have been lost since the Plan was put in place?

All Both emc0411GB

26. When was the last ESI (Ecological Site inventory) done for all affected lands? What did it show? What does updated 

ecological analysis show? Has BLM changed how it does analysis? What areas never had SVIN or ESI inventories?

All Both emc0411GB

27. A valid and complete environmental baseline of habitat quality, quantity and threats must be provided for the effects of 

development scenarios to be understood. This effort must first answer basic questions such as: How much loss of 

critical habitat components has already occurred - including desertification and loss of site potential, water tables, etc.? 

How much further loss of adequate sagebrush understories, microbiotic crusts and structurally complex sagebrush 

All Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1023

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

cover will occur if all the livestock water pipelines, fences, near-status quo stocking rates, high use levels/standards are 

allowed to continue- and the new developments under the Scenario are allowed to occur? How much irreversible loss 

and harm (such as cheatgrass or medusahead invasion) will occur? In arid sagebrush lands, placing water developments 

in uplands results in a bulls-eye pattern of depletion emanating outward from the water sources (with variations taking 

topography into account). With continued high stocking, and high use levels, no controls on trampling disturbance, and 

retention of existing livestock facilities - the depletion continues and recovery of damaged areas is not possible. 

Continuing or expanding facilities, or renewing grazing permits at levels above the use that has actually been occurring, 

must be fully taken into consideration here. All of this is of course dependent on what the current baseline and 

environmental conditions are, including how severe current threats and risks of continuing disturbance activities may be 

to all components of all sage-grouse seasonal habitats and lands necessary for restoration.

28. Please consider effective management strategies for the Greater Sage-grouse as a viable, valuable outlet for those efforts 

that will protect not just a few threatened species, but an entire ecosystem capable of inspiring future generations of 

Americans lucky enough to spend a bit of time out in the sage

All Both fla0086gb

29. It is evident that ecosystemic deterioration, rise in health degradation, and threats to population dynamics of wildlife and 

plant communities can be directly attributed to habitat destruction.

All Both fld0002RM, 

fld0002GB

30. Management of habitat for the greater sage-grouse occurs on a complex sagebrush dominated landscape with 

tremendous variability locally and range wide. It is ecologically impossible to regulate for improved sage-grouse

performance with species specific regulatory measures. Local citizens working together to resolve local and site specific 

issues offers the best chance for success. Considerable work has already been accomplished at the local level in planning 

for improved vegetative management. To date the agencies have failed to implement the majority of these planning 

efforts. Agencies should prioritize and implement these measures before increasing regulatory control that often 

paralyzes needed action. Therefore, I strongly urge the agencies to recognize the benefits of livestock grazing to 

greater-sage grouse and to prioritize their focus on those issues that pose a real and specific threat to the greater 

sage-grouse and its habitat.

All Both flj0000GB

31. t is evident that ecosystemic deterioration, rise in health degradation, and threats to population dynamics of wildlife and 

plant communities can be directly attributed to habitat destruction.

All Both flld0002RM

32. it is important that this does not become a single species management plan that could be detrimental to other species 

in the sage grouse habitat area.

All Both fxc0012GB

33. The West must be protected as a contiguous whole on a large scale for historic native species as well as on a site-specific 

scale. Conservation biology must be integral to any meaningful sage grouse protection plan, including landscape scale, 

bioregionally planned biological core habitat areas, migration and dispersal corridors, wild rivers, and riparian areas 

considerations.

All Both rmc0039GB

34. The Board is supportive of "implementing management actions after land health and habitat evaluations." However, 

managing" ... for vegetation composition and structure consistent with ecological site potential and within the reference 

state to achieve sage-grouse seasonal habitat objectives" is not practical. Historic management practices and landscape 

alterations, coupled with the introduction of noxious weeds and catastrophic wildfire have effectively eliminated the

All Both rmc0050GB
C. Comments by Resource Planning Issue

C-1024 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

Comment 

No.

Comment SubRegion

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Agency CmtLtrCode

"reference state" condition. The focus should be on maintaining vegetative resilience and resistance by maintaining 

critical ecological processes identified by the reference state, and avoiding the crossing of ecological thresholds. Every 

effort should be made to achieve this including the utilization of the best available indigenous science and knowledge 

combined with the use of all management tools, including grazing, herbicides, mechanical treatments, and nonnative 

adapted plant materials.

35. We have identified habitats that are approaching ecological thresholds, which when crossed will either eliminate the 

area as habitat or will require extensive and expensive work to rehabilitate the habitat. NNSG would like to see specific 

habitat management conservation measures that are pro-active, not just reactive. These pro-active measures should be 

based on ecological site descriptions (ESDs) and state and transition models (STMs), where available.

All Both rmc0051GB

36. The entire subject of habitat restoration demands more attention and greater clarity from the scientific community. 

Considerable published, quality data, unpublished scientific and economic data, and experience now exist. Some covers 

many decades. (eg. Young and Clements; Cheat Grass, Fire and Forage on the Range; University of Nevada Press, 2009) 

Wishful thinking and popular notions cannot overcome biological and economic realities.

All Both rmc0063GB

37. Please extend comment periods. Maps, GIS Data, etc are not even available online. All GEN Both cfc0003GB

38. No actions should be more restrictive than that required from a biological assessment and subsequent biological opinion 

should sage-grouse become listed. For example, withdrawal of mineral activities should not be a default stipulation, or 

“conservation measure”, taken without a full analysis warranting the decision.

All GEN Both emc0103GB

39. Take a step back from the constant monitoring and studying of the sage grouse. They are becoming a species that could 

be studied to death. Stay away from lek areas, don't do fly overs or egg counts for a period of time and see if their 

numbers are able to increase on their own without interference. Educate public land users on known sage grouse sites 

(ie leks, rousts) and tell them to try to avoid them.

All SG-GN Both emc0241GB

40. For the record we believe in the efforts to protect all species, yet strongly deem that the efforts need to be realistic in 

nature and based on science - which isn't completely the case in the Instructional Memorandum.

CO Both emc0056RM

41. Ecosystem level planning and strategies should be employed in addition to species-specific analyses. The Endangered 

Species Act provides that “t]he purposes of this Act are to provide a means whereby the ecosystems upon which 

endangered species and threatened species depend may be conserved, [and] to provide a program for the conservation 

of such endangered species and threatened species[.]” 16 U.S.C. § 1531(b). An assessment tool or evaluation strategy 

approved by USFWS should be used to quantify the interim and permanent impacts (injury) to habitats (direct, indirect 

and cumulative) and the ecological services provided by those habitats. This will enable a more accurate, predictive 

approach to impact mitigation.

GB Both emc0355GB

42. A scientific panel selected by the Bureau of Land Management outlined conservation measures that are an important 

starting point for effective conservation, in the 2011 'Report on National Greater Sage-Grouse Conservation Measures'. 

We recommend conservation biology recommendations be followed and large areas of functional, unfragmented habitat 

be conserved.

GB Both emc0404GB

43. Sound scientific research indicates that grazing is beneficial to the greater sage-grouse and other flora and fauna in GB Both rmc0056GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1025

Scoping Summary Report

Table C-7.C

Comments Related to General Biological Resources

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multiple ways. Grazing reduces the instances and severity of wildfires. (Launchbaugh et al. 2007). It improves greater 

sage-grouse habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et al.1994, 

Evans 1996). It has also been used to control invasive weeds (Olson and Lacey 1994, Walker et al.1994).

44. habitat restoration: While Sage Grouse habitat restoration is something which nearly everyone can support, there is 

much disagreement over what restoration actually means, how to achieve it, and how to evaluate whether restoration 

efforts are effective or not. The proposed EIS is a good forum for a robust public discussion of restoration. Does it mean 

conditions before Native Americans arrived in sagebrush country about 12,000 years ago? before white settlers arrived 

160 years ago? or does it mean as much ecosystem functionality which can be achieved, given existing uses, our inability 

to stop weed invasion or to control increasing carbon in our atmosphere or "manage" increasing droughts or other 

weather disturbances? And, is "restoration" different regionally or in each PMU area? We believe it will facilitate public 

support of restoration of Sage Grouse habitats if there is more clarity on what this means. The EIS should contain 

conservation measures which set and enforce habitat restoration goals for all Sage Grouse habitats - priority, general, 

and recovery habitats. a. the agencies should examine the assumed benefits to Sage Grouse of projects to remove 

pinyon-juniper woodlands. Is pinyon-juniper "invasion" simply a recolonization of areas denuded of trees more than a 

century ago for mining, a response to millennial influences of woodland expansion/retraction in the Great Basin, or a 

response to management practices (overgrazing reducing competition from grasses)? In any event, the agencies should 

prioritize changing management actions which are conducive to pinyon-juniper expansion before spending limited funds 

to eradicate trees. B. the agencies should include Sage Grouse habitat requirements in restoration objectives, including 

sagebrush cover and desirable understory plants. C. the agencies should prioritize expenditures of weed suppression

funds for use in priority Sage Grouse habitats, with specific quantified objectives. D. the agencies should take additional 

actions to avoid or minimize the spread of invasive weeds in priority habitats. E. the agencies should prioritize the use 

of native seeds and preservation of native vegetation in priority habitats. F. the agencies should establish seed harvest 

areas adjacent to burned areas. G. the agencies should develop and implement methods for prioritizing and restoring 

sagebrush steppe invaded by nonnative plants. H. the agencies should evaluate the costs and benefits of using livestock 

grazing to improve priority habitats, especially the undesirable adverse impacts on native vegetation and facilitation of 

weed invasions. I. the agencies should evaluate other pest control programs, such as Mormon crickets, for unacceptable 

impacts on Sage Grouse and their food sources and modify to meet habitat requirements. J. the agencies should disclose 

in the EIS that funding for restoration and rehabilitation is not assured as it is subject to annual agencies' budgets and 

Congressional directions.

NVCA Both emc0283GB

45. The Horse Ridge/Brothers/Hampton high desert area is on the far western edge of the North American sage grouse 

range. It's in a very low precipitation area with extremely low presence of surface water and is dominated by low density 

low sage relative to habitats in the more central parts of grouse range. Wet meadows and well-distributed riparian areas 

are almost non-existent. Thus populations in the high desert area could be expected to fluctuate more widely and likely 

are not as dense as are populations further east in Oregon as well as Idaho, Utah and Wyoming. The core area map of 

ODFW reflects this to some extent

OR SG-GN Both emc0173GB
C. Comments by Resource Planning Issue

C-1026 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.D

Comments Related to Terrestrial Wildlife

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. There is no mention of impacts and competition from elks, antelope, deer and other wildlife on vegetation and vegetative 

cover.

All Both cfc0006RM

2. How is the sage grouse habitat within the prairie dog category 1 going to be dictated were they may overlap each other? Is 

there a "happy medium" that can be achieved to support both sage grouse and hi population prairie dogs?

All Both cfc0016RM

3. Control prairie dogs encroaching into sagebrush areas. All Both cfc0018RM

4. "Retirement of grazing privileges in priority sage grouse area." NO! May use deferred/rotational grazing. Sage grouse at their 

most plentiful were co-existing with large grazing animals. You would still have antelope, deer and elk in some places. Fox, 

Swift fox, skunks and badgers are likely more destructive than cattle or sheep.

All Both cfc0025RM

5. Pocket gophers churn the soil, providing greater moisture capture which leads to thicker plant growth. Pocket gophers seem 

to be spreading. How will this impact the sage grouse?

All Both emc0013RM

6. Can sage grouse get the plague from prairie dogs? All Both emc0013RM

7. Will wolves increase predation on sage grouse or reduce predation by killing coyotes? All Both emc0013RM

8. The EIS should include a study (or plan for a study) evaluating the impact of individual ranches' approach to coyote control on 

the local sage grouse numbers.

All Both emc0013RM

9. The EIS must include a solid study of the impact of coyotes on sage grouse populations. All Both emc0013RM

10. The EIS should estimate how much the coyote population would increase and how much the sage grouse population would 

decrease if the ranches were not putting pressure on the coyote population.

All Both emc0013RM

11. The two biggest threats to sage grouse habitat areas are wild fires and large ever expanding prairie dog towns. The USFS and 

the BLM are both very negligent in their efforts to control the destruction of sage grouse habitats by the wild fires and they 

have made no attempt to control the complete obliteration of sage grouse habitat areas caused by the expanding number of 

prairie dogs.

All Both emc0148GB

12. Copy of the policy guidelines call for reduction of livestock grazing on public lands. Historically, sage grouse and other species 

such as antelope have followed livestock grazing patterns and flourished where ranchers are allowed to care for the rangeland

All Both emc0244GB

13. We have successfully implemented cool season burns, chemical, mechanical treatments to thin brush and release herbaceous 

vegetation (Danvir 2005). The overall effect is early season openings in a sagebrush sea. Hunnicutt 1992 clearly showed that 

hens selected nest sites in homogeneous sagebrush patches at least 300m in diameter for nesting, but immediately moved 

broods to highly heterogeneous areas having an interspersion of sagebrush cover and grass-forb dominated feeding areas. 

Pronghorn populations (Aoude and Danvir 2002) showed similar production and population increases.

All Both emc0281GB

14. We know little about the effects of fragmentation on terrestrial predators. Kuipers (2004) pointed out that the popular 

trapping literature describes canine predators using roads, although this is absent from the scientific literature. Although these 

observations are intriguing, they must be tested with planned experiments. These would include searching for evidence of 

canine predators in both roads and other areas and considering differences in detectability in roads and in other habitats.

All Both fxc0011gb

15. Several ranches in the Fort Peck Lake watershed participated in a riparian enhancement and repair project. We were given 

forms to monitor the health of the riparian area. These forms include an estimate of trailing and bare ground due to livestock. 

MT-RM Both emc0013RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1027

Scoping Summary Report

Table C-7.D

Comments Related to Terrestrial Wildlife

Comment 

No.

Comment SubRegion

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Agency CmtLtrCode

On our ranch, these sites have scattered deer droppings, deer beds, and deer tracks. One site is visited by elk on their way to 

graze the neighbor's alfalfa field. How are we to tell what percentage of trailing is caused by cattle and what percentage is

caused by wildlife? The answer to this evaluation question reveals only the biases of the researcher.

16. When I was a teenager in the 50's there were probably twice as many cows, sheep and horses on the range as there are now. 

The sage hens were plentiful around every water hole and spring on the desert and they hung around these places even 

though all of the other animals were there too. I think the reason they did this was while the animals stayed around water the 

predators stayed away.

OR Both rmc0046GB

17. Livestock/Wildlife Grazing Policy Disconnect - The Sage Grouse Interim Management Strategy identifies a habitat priority to 

keep Sage Grouse from being listed. The sage step has many competing interests including livestock, deer, elk and wild horses

that impact Sage Grouse habitat. BLM in conjunction with stockmen manage livestock. Utah Division of Wildlife Resources 

and the Wildlife Board manage big game. a process that currently is increasing elk numbers by approximately 20 percent. It 

would be unfair to reduce livestock grazing rights to address habitat concerns without including other competing interests, 

including elk, in the decision. The Fish & Wildlife Service's "Identified Threats to Greater Sage Grouse" did not include other

competing wildlife interests on the sage step.

UT Both rmc0003GB

18. There are many natural threats to grouse which seem to get very little attention. In our area, expansion of and destruction of 

sage brush by prairie dogs is a very real threat which could be greatly avoided by active control of prairie dogs. Another 

problem which probably can not be addressed is the predation by large raptors. We are seeing as increase in these, 

particularly eagles, which certainly have a bearing on Sage Grouse survival, as well as dissturbance at leks.

WY Both cfc0032RM

19. Irrigation from reservoirs and dirt work systems that are in place on Federal lands should be allowed to continue. Sage grouse 

still need the grassy areas for food and shelter. The irrigation of the sparse grasslands ecosystems in the landscape will slow 

down the encroachment of the prairie dog and allow forage for more than one species survival in the area.

WY Both emc0050RM

20. Prairie dogs are the largest destroyer of sage grouse habitat. The prairie dogs utilize the sagebrush year around and destroy

the whole plant for visual protection from predators. The BLM and Forest Service must manage the prairie dogs away from 

the sage grouse areas to prevent the encroachment upon and destruction of core sage grouse habitat.

WY Both emc0050RM

21. The Black-Tailed Prairie Dog Conservation Assessment and Management Strategy (BTPDCAS ) plan in the Thunder Basin 

National Grassland calls for at a minimum of 18,000 and up to 52,000 acres of prairie dogs within an area called Category 1. 

There are several Category 2 areas proposed as well with the plan of maintaining 9000 acres of black tailed prairie dogs within 

the sum of those Category 2 areas. "Inside the Category 1 Area, prairie dogs will be allowed to expand their distribution and 

colonize new areas. Any prairie dog control efforts to address unwanted colonization onto non-federal lands within Category 

1 Prairie Dog Habitat proposing to use rodenticide may only be initiated if cumulative acreage of active prairie dog colonies

within Category 1 exceeds 18,000 acres. Use of rodenticide on federal lands may only be employed within 1⁄2 mile of the 

TBNG boundary and only in cases where appropriate and available non-lethal options have been tried and found ineffective 

for changing the rate and direction of colony expansion. The acreage in Category 1 is not capped at 18,000 acres, but would 

be allowed to grow within the boundary of the MA 3.63. ...Although the objective in the Category 1 area is to provide 

minimum of 18,000 acres of active colonies, the area is approximately 52,000 acres, this allows for prairie dogs to disperse and 

colonize into preferred habitats and provides more flexibility for prairie dogs to disperse and colonize new areas before they 

WY USFS emc0050RM
C. Comments by Resource Planning Issue

C-1028 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.D

Comments Related to Terrestrial Wildlife

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

spread outside of the designated boundary." (PAGE 45 of the BTPDCAS) "There is no single size of prairie dog colonies which 

is considered ideal for prairie dogs and their associated species".. Page 47- (BTPDCAS) (Underline and italics are mine to 

stress the importance of an issue) "In the Thunder Basin National Grassland each Category 2 Prairie Dog Habitat will contain 

a minimum of 1500 acres of active prairie dog colonies within a defined area. Combined, Category 2 prairie dog habitats 

should contain 9000 acres of active prairie dog colonies".. In the event that Category acreage exceeds 9000 acres control of 

colonies within Category 2 areas would be appropriate." (PAGE 46- BTPDCAS) The majority of the sage grouse core area in 

the Thunder Basin National Grassland is INSIDE of the proposed Cat. 1 and Category 2 Prairie Dog management areas. It 

would be an advantageous time to do a plan amendment on the sage grouse conservation and management and also to rewrite 

a plan amendment concerning the prairie dog management in the Thunder Basin National Grasslands. The Forest Service 

should redraw the Cat.1 and Cat.2 boundaries so the categorical areas do NOT include any more sage grouse habitat than 

possible and re-assess the need for so large an area for black tailed prairie dog colonization. This would alleviate many 

concerns over the increase of thousands of acres of prairie dogs within and next to core sage hen habitat in the same area.

22. It is well known that the prairie dogs will destroy the sage grouse habitat once the dogs are allowed to get densely populated. 

As referenced above: The prairie dog plan calls for NO management WITHIN the Category boundaries until a certain level of 

prairie dog population is acquired. This non-management will make the destruction of core sage grouse habitat 

UNAVOIDABLE within that specific categorical area. "Prairie dogs change both the amount and typed of vegetation found on 

their colonies (Agnew et a., 1986, Archer et al. 1987) .On the TBNG, the most common changes in vegetative condition is a 

shift from a mid-grass community dominated by western wheatgrass/blue grama or crested wheatgrass/blue grama to a 

community dominated by blue grama alone (Dan Svingen, pers. Obs) The percentage of bare ground typically increases with 

long-term prairie dog occupancy (ibid)." (PAGE 21 BTPDCAS)

WY USFS emc0050RM

23. There are no present effective methods proven to prevent encroachment from large densities of prairie dogs on the Thunder 

Basin National Grassland other than the use of rodenticide. A plan amendment is required to change the Black tailed Prairie 

Dog Management and Conservation Strategy in addition to a plan amendment to support the conservation of the threatened 

Sage Grouse. It makes good sense to do both amendments together for a win-win situation. If the boundaries of the Cat. 1 and 

Cat. 2 areas were redrawn and rodenticide treatments were used both outside and within the NEW boundaries then there 

would be a much more effective method to keep the prairie dogs from encroaching upon the limited habitat of the sage 

grouse. It is imperative to remember in the Shirley Basin and other federally managed areas of land with prairie dogs that: A 

good management plan is essential to prevent the prairie dogs from encroaching upon nearby sage grouse habitat.

WY USFS emc0050RM

24. There are a total of 553,000 acres in the TBNG. Potential sage-grouse habitat within the TBNG is estimated at about 438,500 

acres. `The Thunder Basin analysis used vegetation classified from the USDA Forest Service Pueblo Integrated Resource 

Inventory (IRI) Center. Each type was classified for prairie dog suitability. This model classified 405,000 acres 92% of Thunder 

Basin as potentially suitable habitat for prairie dog colonization. ‘(PAGE 14-TBPDCAS) THIS IS A VERY IMPORTANT 

POINT: The black tailed prairie dog can adapt and live in a variety of landscapes while the sage grouse is limited to a narrower 

landscape. It does not make sense to purposely set the sage grouse up for destruction when the movement of a line boundary, 

use of rodenticide on federal lands and lower acres of prairie dog colonization would help prevent this from happening. These 

species cannot cohabitate the same area because the prairie dog will destroy the sage grouse habitat!

WY USFS emc0050RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1029

Scoping Summary Report

Table C-7.D

Comments Related to Terrestrial Wildlife

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

25. In the particular case of the Casper area, overuse of sagebrush by big game and livestock is an important issue (BHSBLWG 

2006:13).

WY Both emc0343GB
C. Comments by Resource Planning Issue

C-1030 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.E

Comments Related to Special Status Wildlife

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

1. The special interest groups should look at how the sage grouse disappearance in certain areas can be very easily equated to 

forced introduction of such predators as wolves, mountain lions and bears.

All Both emc0148GB

2. BLM Manual 6840 BLM Manual 6840 (December 2008) establishes extensive policies and guidelines directing how to manage 

"Special Status Species" which includes listed, proposed, and candidate species. BLM has a special designation for candidate 

species called "BLM Sensitive Species". Chapter 2 of BLM Manual 6840 is devoted to desclibing BLM management policies to 

protect Sensitive Species. The policies in Manual 6840 for candidate species have guided the development of sage-grouse 

mitigation plans like that for the Mount Hope Project. Before implementing the policies recommended in the NTT Report, BLM 

should evaluate the effectiveness of existing policies, including those in BLM Manual 6840. Many operators of projects on 

BLM-administered lands, including Eureka Moly, have made substantial investments in planning their projects to accommodate 

the Sensitive Species policies in BLM Manual 6840. These investments have reduced and/or mitigated impacts to Sensitive 

Species, and the policies in BLM Manual 6840 are effective regulatory tools that should be evaluated in the proposed EIS. BLM

should not ignore or replace the existing regulatory tools it already has without demonsh'ating why the existing regulations are 

not functioning properly or are inadequate. The EIS documents should evaluate the directives in BLM Manual 6840 in the 

context of the No Action Alternative (see Section IV below) and discuss whether they are being fully and consistently 

implemented. BLM should not propose new or different regulatory mechanisms if any of the apparent shortcomings or gaps in 

the existing regulations are due mainly to uneven or incomplete implementation of existing policies. • Eureka Moly Scoping 

Issue No.2: Evaluate the effectiveness ofBLM Manual 6840, including a Gap Analysis - The EIS documents should assess whether 

the existing policies in Manual 6840 are adequate to provide protection to the greater sage-grouse. As part of this assessment, 

BLM should determine whether there are gaps that need to be filled, or improvements that need to be made, and whether the 

existing policies are being implemented in a complete and effective manner.

All Both emc0335GB

3. Take a multi-species, landscape-level, ecosystem focused approach We encourage the agencies to consider using the 

sage-grouse conservation planning effort as a vehicle to meet their ancillary policy obligations and secure necessary 

conservation gains for other sagebrush ecosystem associated species of conservation concern. In order to achieve these 

conservation efficiencies, the BLM and FS should optimize expenditure of time and resources on sage-grouse conservation by: 

(1) conducting requisite analyses and developing conservation strategies on a landscape basis and (2) also analyzing the potential 

conservation co-benefits that could be conferred on other species such as pygmy rabbit and Brewer’s sparrow by considering 

all species of concern associated with the sagebrush ecosystem as a part of the overall process of developing a conservation 

strategy for the sage-grouse. The associated environmental impact studies and analysis must ensure that individual 

Environmental Impact Statements prepared as a part of this overall strategy permit the public, state and federal agencies, and 

other stakeholders to understand the cumulative effects of management actions undertaken in accordance with this 

conservation strategy across the entire range of the sage-grouse. That is, when completed, these studies must provide a 

complete picture of how the alternative conservation strategies proposed under individual Environmental Impact Statements 

"add up to" a conservation strategy that will achieve the conservation objectives for the sage-grouse that are required to 

conserve the species. In addition, in each Environmental Impact Statement developed in accordance with this overall 

conservation strategy, we urge the BLM and FS to also analyze and consider alternatives that provide conservation benefits to 

other sagebrush steppe species of conservation concern. A targeted multispecies approach is more efficient than a narrow 

All Both emc0339GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1031

Scoping Summary Report

Table C-7.E

Comments Related to Special Status Wildlife

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

single-species approach, it takes advantage of the opportunity at hand, and provides the federal land management agencies 

added ecosystem and species-scale conservation benefits from work already being done.

4. One multi-species approach would be to use anticipated conservation benefits to other species as a positively weighted factor 

in the development, comparative analysis, and selection of sage-grouse conservation alternatives and development of 

conservation measures and reserve design. For example, alternatives which consider, in addition to targeted sage-grouse 

conservation standards, broad, habitat-based conservation measures that confer conservation benefits to other species could 

be given additional consideration in decision making as providing broad conservation opportunities for the sage brush 

ecosystem, not just one species. An example that could inform a multispecies approach is the BLM’s Threatened and 

Endangered Species Fund, which targets "low hanging fruit"projects where relatively cheap intervention can lead to downlisting 

and delisting of species. With only $2 million in its budget last year, the Fund worked toward delisting a dozen species. The 

decision making and targeting process that goes into management of the Fund could be used to determine affordable and easy 

ways to add on benefits that could be incorporated into this planning process moving forward.

All Both emc0339GB

5. Take a multi-species, landscape-level, ecosystem focused approach We encourage the agencies to consider using the 

sage-grouse conservation planning effort as a vehicle to meet their ancillary policy obligations and secure necessary 

conservation gains for other sagebrush ecosystem associated species of conservation concern. In order to achieve these 

conservation efficiencies, the BLM and FS should optimize expenditure of time and resources on sage-grouse conservation by: 

(1) conducting requisite analyses and developing conservation strategies on a landscape basis and (2) also analyzing the potential 

conservation co-benefits that could be conferred on other species such as pygmy rabbit and Brewer’s sparrow by considering 

all species of concern associated with the sagebrush ecosystem as a part of the overall process of developing a conservation 

strategy for the sage-grouse. The associated environmental impact studies and analysis must ensure that individual 

Environmental Impact Statements prepared as a part of this overall strategy permit the public, state and federal agencies, and 

other stakeholders to understand the cumulative effects of management actions undertaken in accordance with this 

conservation strategy across the entire range of the sage-grouse. That is, when completed, these studies must provide a 

complete picture of how the alternative conservation strategies proposed under individual Environmental Impact Statements 

"add up to" a conservation strategy that will achieve the conservation objectives for the sage-grouse that are required to 

conserve the species. In addition, in each Environmental Impact Statement developed in accordance with this overall 

conservation strategy, we urge the BLM and FS to also analyze and consider alternatives that provide conservation benefits to 

other sagebrush steppe species of conservation concern. A targeted multispecies approach is more efficient than a narrow 

single-species approach, it takes advantage of the opportunity at hand, and provides the federal land management agencies 

added ecosystem and species-scale conservation benefits from work already being done.

All Both emc0339GB

6. One multi-species approach would be to use anticipated conservation benefits to other species as a positively weighted factor 

in the development, comparative analysis, and selection of sage-grouse conservation alternatives and development of 

conservation measures and reserve design. For example, alternatives which consider, in addition to targeted sage-grouse 

conservation standards, broad, habitat-based conservation measures that confer conservation benefits to other species could 

be given additional consideration in decision making as providing broad conservation opportunities for the sage brush 

ecosystem, not just one species. An example that could inform a multispecies approach is the BLM’s Threatened and 

All Both emc0339GB
C. Comments by Resource Planning Issue

C-1032 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-7.E

Comments Related to Special Status Wildlife

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

Endangered Species Fund, which targets "low hanging fruit"projects where relatively cheap intervention can lead to downlisting 

and delisting of species. With only $2 million in its budget last year, the Fund worked toward delisting a dozen species. The 

decision making and targeting process that goes into management of the Fund could be used to determine affordable and easy 

ways to add on benefits that could be incorporated into this planning process moving forward.

7. The sage grouse is a good umbrella species, the protection of which would assist in the conservation of many other sagebrush 

obligate species that are currently declining (Rowland et al. 2006b). The plan amendments should therefore focus not just on 

sage grouse but on protecting the sagebrush ecosystem as a whole, at a landscape scale, which will also protect other BLM 

Sensitive Species such as the pygmy rabbit, white-tailed prairie dog, burrowing owl, ferruginous hawk, sage sparrow, sage 

thrasher, and Brewer’s sparrow. We encourage BLM to approach the sage grouse plan amendment with an eye toward 

protecting large core segments of high-quality habitat and also to establish connectivity between core areas to lessen the 

likelihood of extirpation through permitting interchange of sage grouse between core areas.

All Both emc0343GB

8. More than 350 species in sagebrush steppe (Wisdom et al. 2005a: 21 and App. 2)8—and as many as 630 species (Rich et al. 

2005: 590, citing unpublished data)—are of conservation concern. Approximately 20 percent of native flora and fauna in the 

Sagebrush Sea are considered imperiled (CSEE 2002). Sixty species, subspecies, and Distinct Population Segments of vertebrate 

species that use sagebrush and/or other habitat types in sagebrush steppe that are designated as “endangered,” “threatened” or 

candidate species under the ESA (see Appendix 2). Although sage-grouse are a useful umbrella species for the landscape, the 

planning process should account for specific habitat needs of other declining sagebrush dependent species, such as Brewer’s 

sparrow, pygmy rabbit, Wyoming pocket gopher, and myriad fishes, amphibians, plants and mollusks. Wisdom et al. (2005b) 

categorized habitat types within sagebrush steppe in the Great Basin and identified groups of vertebrate species that primarily 

use those habitats. They recommend managing sub-habitats using these species as focal species (Wisdom et al. 2006b). Others 

propose using a suite of bird species that represent the full spectrum of nesting guilds (ground nesting, in shrub canopies, 

woodland canopies, and in cavities) and use a variety of habitat types as focal species for conservation planning in sagebrush 

steppe (CalPIF 2005). Planning for a suite of sagebrush species now could avoid land use conflicts with conservation in the 

future. Planners should consult a newly published reference, Sagebrush Ecosystem Conservation and Management: Ecoregional 

Assessment Tools and Models for the Wyoming Basins (Hanser et al. 2011), to plan for multiple species in the Wyoming Basin 

ecoregion.

All Both emc0391GB

9. More than 350 species in sagebrush steppe (Wisdom et al. 2005a: 21 and App. 2)8—and as many as 630 species (Rich et al. 

2005: 590, citing unpublished data)—are of conservation concern. Approximately 20 percent of native flora and fauna in the 

Sagebrush Sea are considered imperiled (CSEE 2002). Sixty species, subspecies, and Distinct Population Segments of vertebrate 

species that use sagebrush and/or other habitat types in sagebrush steppe that are designated as “endangered,” “threatened” or 

candidate species under the ESA (see Appendix 2). Although sage-grouse are a useful umbrella species for the landscape, the 

planning process should account for specific habitat needs of other declining sagebrush dependent species, such as Brewer’s 

sparrow, pygmy rabbit, Wyoming pocket gopher, and myriad fishes, amphibians, plants and mollusks. Wisdom et al. (2005b) 

categorized habitat types within sagebrush steppe in the Great Basin and identified groups of vertebrate species that primarily 

use those habitats. They recommend managing sub-habitats using these species as focal species (Wisdom et al. 2006b). Others 

propose using a suite of bird species that represent the full spectrum of nesting guilds (ground nesting, in shrub canopies, 

All Both emc0391GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1033

Scoping Summary Report

Table C-7.E

Comments Related to Special Status Wildlife

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

woodland canopies, and in cavities) and use a variety of habitat types as focal species for conservation planning in sagebrush 

steppe (CalPIF 2005). Planning for a suite of sagebrush species now could avoid land use conflicts with conservation in the 

future. Planners should consult a newly published reference, Sagebrush Ecosystem Conservation and Management: Ecoregional 

Assessment Tools and Models for the Wyoming Basins (Hanser et al. 2011), to plan for multiple species in the Wyoming Basin 

ecoregion.

10. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective management of 

preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs informed by the 

following additional criteria: ACECs can be designated for habitat, but also for historic, cultural and scenic values. BLM should 

prioritize ACEC designation for lands that contain priority habitat and other vulnerable resources, such as wilderness 

characteristics, other endangered species, or cultural resources. This approach will allow BLM to ensure that ACECs maximize 

protection of multiple sensitive resource values benefiting a range of user groups.

CO BLM emc0070RM

11. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective management of 

priority habitat (which should include enough habitat to conserve at least 80-90% of the existing population), along with 

designation of ACECs informed by the following additional criteria: ACECs can be designated for habitat, but also for historic, 

cultural and scenic values. BLM should prioritize ACEC designation for lands that contain priority habitat and other vulnerable 

resources, such as wilderness characteristics, other endangered species, or cultural resources. This approach will allow BLM to 

ensure that ACECs maximize protection of multiple sensitive resource values benefiting a range of user groups.

East Both emc0089RM

12. Nye County has worked successfully with the US Fish & Wildlife Service, Nevada Division of Wildlife, Nevada Natural Heritage 

Program, BLM, and others to protect and enhance the habitat of the Amargosa Toad in Oasis Valley, Nevada and prevent its 

listing as a threatened or endangered species. This practical, science-based effort should be used as a model for efforts to 

protect the Sage Grouse, without the additional costs associated with the implementation of the IM. A copy of the conservation 

agreement is attached to these comments, and the listing decision announcement can be found at: 

http://www.biologicaldiversity.org/news/press_releases/2010/amargosa-toad-07-19-2010.html.

NVCA Both emc0147GB

13. It may also be helpful to the public to describe a case study of the August 29, 1980 listing of the Desert Tortoise, another 

landscape-scale species like the Sage Grouse, as threatened in the Mojave Desert and Case study and what happened. As I 

understand the process, BLM land use plans were amended to include the Desert Tortoise recovery plan requirements. Large 

ACECs were designated with the intent of protecting as much intact Desert Tortoise habitat as possible. Grazing allotments 

were closed and off-road vehicle use areas were limited. A $250/acre impact fee was charged and used to implement a 

Multi-Species Habitat Conservation Plan. What are the results of the land use plan Desert Tortoise conservation strategy in 

Nevada and elsewhere in the Desert Tortoise range? Have populations or trends increased or decreased? Has priority or 

critical Desert Tortoise habitat increased or decreased? Have habitat rehabilitation or restoration projects been successful or 

not? How much public funds have been spent on protecting Desert Tortoises or priority habitat on public lands? What 

monitoring of populations and habitats has been required? How much required monitoring has been implemented, annually and 

since 1980? We understand the Desert Tortoise experts are considering requesting Desert Tortoise status be raised from 

threatened to endangered because of failures to conserve large areas of habitat. Only 4 areas of over 1,000 square miles of 

intact functioning habitat were designated and appear insufficient to stop fragmentation and blocking of genetic linkages.

NVCA Both emc0283GB
C. Comments by Resource Planning Issue

C-1034 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. There is no mention of impacts and competition from elks, antelope, deer and other wildlife on vegetation and vegetative 

cover.

All Both cfc0006RM

2. There is little emphasis on treating and restoring range-land to bring it back to its full productive potential for sage grouse 

and all wildlife and livestock. There should be no retirement of Grazing Priveleges to achieve this.

All Both cfc0006RM

3. To prevent listing of Sage-grouse livestock grazing and vegetative management projects and programs must be modified to 

provide sufficient quality Sage-grouse habitat.

All Both cfc0016

4. If grazing privileges are retired, how will the agencies manage the health of the rangeland? It is common knowledge that 

semi-arid environments need grazing to keep the plants healthy. This is essential for the sage grouse that depend of these 

plants.

All Both cfc0024RM

5. Cattle graze grasses exposing forbs, which also are important for sage grouse survival. All Both cfc0030

6. Since Ogden trekked through, vegetation in the Great Basin has changed . Flood irrigated meadows and ground watered 

alfalfa transformed lands in private ownership while others in the public domain have changed from sage to grasslands. This 

has been the results of both fire and mechanical treatment.

All Both cfc0030GB

7. Crested wheat seedings, which were established on treated and burned over range lands, are returning , in part, to sage 

brush, an important food source and cover for sage grouse.

All Both cfc0030GB

8. Interpretation of old growth juniper needs to be reassessed - NRCS-SG funded projects need to be able to cut ALL trees 

in areas with over 2 million acres of juniper in the Modoc NF. It won't hurt to cut ALL the trees in the NCRS project 

areas.

All Both cfc0032GB

9. I believe that cutting a lot of the juniper trees in certain areas and replacing them with sagebrush will help the sage-grouse 

and the mule deer both.

All Both cfc0039GB

10. I am in process with NRCS SGI plan which includes fencing, pasture management, deferrment of pastures for greater 

stubble height. Reseeding pastures and rangeland with SG I grasses for better habitat. Doing Absolute best to grow the 

bird, but very frustrated.

All Both cfc0053GB

11. Forage and cover are needed and larger buffer zones around leks and breeding grounds, at least 3 miles, should be the 

policy.

All Both emc0012RM

12. I'd like to comment on the sage grouse strategy. I understand that during the 60's there were a great number of sage 

grouse in southwest montana. During this time period there was an active predator control going on. Sheep were being 

grazed in largenumbers. Also at this time, eagles, facons, hawks and the like were not protected and the no.s were down 

due to DDT. Cattle grazing was having a greater impact on the vegetation. Also in the 60's, large areas were sprayed to kill 

sagebrush and make more grass. I have dates of spraying but can't find dates and data of sage no.s for that time frame or 

after. I would like to see a comparison of no. of sage grouse before, during and after spraying to see if reduction in 

sagebrush had an effect on sage grouse no.s. Since then, grazing by sheep and cattle has been reduced. Making better 

riparian and vegetation overall. Some burning of sagebrush was done in the 80's but since that time, sagebrush treatment 

has been reduce greatly. So no change in sagebrush quality! Predator control has been reduced and the eagles, falcons, 

hawks, etc have been protected and increased.

All Both emc0013GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1035

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

13. The relationships between the plant and insect communities are understudied. What insects do grouse eat? What plants to 

those insects eat? What insects pollinate those plants? What insects benefit big sage brush? What do they eat? What insects 

harm big sage brush?

All Both emc0013RM

14. Pocket gophers churn the soil, providing greater moisture capture which leads to thicker plant growth. Pocket gophers

seem to be spreading. How will this impact the sage grouse?

All Both emc0013RM

15. I would think that juniper encroachment alone may be significant, as it has provided perches-nesting areas- cover for hawks, 

eagles and other predators for the last 80 years.

All Both emc0017

16. Historically, sagegrouse numbers were greater in this area during and after a period of extreme overgrazing. At that time, 

the federal government actively poisoned and paid bounties for furred predators. Winged predators were shot by 

homesteaders to protect their chickens. Sagegrouse took advantage of lower predation as did jackrabbits. In 1926, the 

Opheim paper published jackrabbit poisoning advice. In 1936, 12,500 rabbits were reported killed near Opheim

All Both emc0028RM

17. Curiously, grass may be a limiting factor to the sage grouse numbers. Sagebrush habitat is the ecological home of the 

greater sage grouse. So it is interesting to note, lands with an abundance of grass tend to have less sagebrush. Plus, grass 

encourages large wild land fires which are devastating to sage grouse habitat. We have read stories and seen pictures 

oflarge numbers of sage grouse in the early 1900's. Then, large numbers of livestock also grazed these federal lands. Grass 

was not in abundance then, as it is now. So, why have sage grouse numbers declined? The axiom--more cows = more sage

grouse--Iess cows = less sage grouse; may have merit.

All Both emc0029GB

18. Third pinon and juniper encroachment, sage dose not grow well under These tree. All Both emc0031GB

19. Sage-grouse habitat management directives prescribe conservation and restoration of high quality sagebrush plant 

communities suitable for the life cycle of the sage-grouse. Invasive pinion/juniper and cheatgrass in many areas have 

replaced the sagebrush ecosystem. Activities related to minerals exploration have potential to restore the sagebrush plant 

community.

All Both emc0042GB

20. Under 43 CFR 3809, earth-disturbing activities by exploration and mining companies must be reclaimed as near as possible 

to pre-existing landform and plant communities. Reclamation permits in areas of invasive pinion/juniper and cheatgrass do 

or can require reseeding with seed mixes appropriate for sage-grouse habitat. To the extent that earthdisturbing activities 

occur in pinion/juniper- and cheatgrass-invaded areas, reclamation can only improve habitat for sage-grouse.

All Both emc0042GB

21. Activities responsible for the loss or degradation of sagebrush habitats also may be used to restore these habitats. These 

activities include prescribed fire, grazing, herbicides, and mechanical treatments. Decisions on land treatments using these 

tools should be based on quantitative knowledge of vegetative conditions over an entire population’s seasonal range. 

Generally, the treatment selected should be that which is least disruptive to the vegetation community and has the most 

rapid recovery time. This selection should not be based solely on economic cost.

All Both emc0057GB

22. Manage breeding habitats to support 15-25% canopy cover of sagebrush, perennial herbaceous cover averaging >18 cm in 

height with (7 inches) >15% canopy cover for grasses and >10% for forbs and a diversity of forbs Habitats meeting these 

conditions should have a high priority for wildfire suppression and should not be considered for sagebrush control 

programs.

All Both emc0057GB
C. Comments by Resource Planning Issue

C-1036 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

23. Sagebrush and herbaceous cover should provide overhead and lateral concealment from predators. If average sagebrush 

height is >75 cm (29 inches), herbaceous cover may need to be substantially greater than 18 cm to provide this protection. 

There is much variability among sagebrush-dominated habitats and some Wyoming sagebrush and low sagebrush breeding

habitats may not support 25% herbaceous cover. In these areas, total herbaceous cover should be >15 % . Further, the 

herbaceous height requirement may not be possible in habitats dominated by grasses that are relatively short when mature. 

In all of these cases, local biologists and range ecologists should develop height and cover requirements that are reasonable 

and ecologically defensible. Leks tend to be relatively open, thus cover on leks should not meet these requirements.

All Both emc0057GB

24. The Report identifies several potential impacts to sage-grouse from grazing; however, the discussion, fails to put into 

perspective that many of these impacts are not just livestock related. Plant communities change over time, with or without 

grazing, and when the plant communities are not managed concomitantly with grazing, the changes discussed in the Report

can occur. BLM and the FS have the responsibility for managing vegetation on public lands, and vegetation management 

based on the ESDs, and State and Transition Models (STMs) for each ESD should be implemented as part of any 

conservation measures. Without appropriate vegetation management, the ability of the ecological sites to support 

sage-grouse populations will not be maintained.

All Both emc0084GB

25. Kane County definitively supports the improvement and restoration of sage grouse habitats and in the majority of 

circumstances proposes that by utilizing aggressive and enlightened vegetative management programs including juniper 

removal will greatly help in perpetuating sage grouse across its full range. Passive management of sage grouse habitats is not

an option - if the BLM and Forest Service are serious about conserving the sage grouse and its associated habitats.

All Both emc0106GB

26. The two most serious threats to sage grouse and its environs are over mature sagebrush and the juniper invasion caused 

by aggressive fire suppression and timidity in the face of each agencies not carrying out their responsibilities in work 

performance including conducting adequate, timely and comprehensive NEPA analysis for habitat restoration and 

vegetative management.

All Both emc0106GB

27. There already exists a large body of research and knowledge about western lands and the full range of habits and the 

associated wildlife species in residence in these environs. One key factor in the conservation of all of our public land based 

plant and animal species is the science of vegetative structures stages and the life cycles that each stage of plant growth

undergoes. Interestingly we already know about this from planting, growing and harvesting our gardens in and around our 

homes. Each new plant and group of plants requires some form of disturbance in order to perpetuate and establish each 

new cycle of diverse plants and associated functions. We simply can’t park our gardens very long before they need renewal

and restoration. Sage grouse also require healthily function habitats with a variety of plants, ages and conditions in which to 

forage, shelter and raise their young.

All Both emc0106GB

28. We would submit to you that in seeking scoping comments about sage grouse that you adequately consider in your 

anticipated conservation measures - guidance that is very critical when considering vegetative structural stages and that 

these measures must be included in any final conservation program.

All Both emc0106GB

29. Vegetation and Wildfire Suppression and Management We agree with the proposed vegetation management plans 

contained in BLM Instruction Memorandum No. 2012-043 (IM).

All Both emc0108GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1037

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

30. Rights-of-Way (ROW) The ROW recommendations proposed in the IM may create significant delays in permitting 

renewable energy projects. To recycle pending Right of Way (ROW) applications for additional alternatives analysis could 

add months or even years to the development of renewable energy projects. Also, the IM gives Field Offices the ability to 

defer processing ROW applications until the completion of the LUP process, which has the potential to stall development 

for up to three years.

All Both emc0108GB

31. We do not agree with the use of introduced grass or forb seeds under any circumstances. If native seed is not available, the 

disturbance or re-vegetation should not proceed until native seed is available (pg. 17);

All Both emc0109GB

32. Do not implement vegetation manipulations (e.g. Lawson aerator) unless clear objectives, rigorous monitoring, and 

intended results have high likelihood of success.

All Both emc0109GB

33. Do not implement vegetation manipulations (e.g. Lawson aerator) unless clear objectives, rigorous monitoring, and 

intended results have high likelihood of success.

All Both emc0109GB

34. Page 28 of the NTT Report states: "In fire prone areas where sagebrush seed is required for sage‐grouse habitat

restoration, consider establishing seed harvest areas that are managed for seed production (Armstrong 2007) and are a 

priority for protection from outside disturbances." In the 1980s there was a Bureau-wide effort to identify native plant seed 

reserves on public lands, including for lower-elevation sagebrush. From a historical perspective, it would be useful in the 

EISs to present their current status, how successful their protection from outside disturbances (including fire) has been, 

and the degree to which they have actually been used for procuring seed.

All Both emc0113GB

35. Stringent reclamation standards are in place for re-establishing rangeland and wildlife habitat on the postmining landscape. 

The coal mining industry has been progressive in developing reclamation techniques (Best Technology Currently Available 

- BTCA) for successful vegetation re-establishment. The increased availability of native plant materials in both kind and 

quantity has aided in this success. Sage-grouse use of reclaimed plant communities providing summer foraging and 

brood-rearing habitat has been documented at one of PPRO's mining operations.

All Both emc0122RM

36. The County is extremely supportive of active "integrated vegetation management" that maintain critical ecological 

processes. Focus should not be on trying to achieve the "reference state condition" that is extremely difficult, rather it 

should be maintaining the ecological processes of the reference state in order to prevent crossing thresholds such as 

establishment and dominance of invasive species. We are supportive of maintaining all possible tools (grazing, native and 

non-native plant species, etc.) to achieve these sorts of projects. These sorts of projects should include a robust monitoring 

component and be adaptive.

All Both emc0130GB

37. Over the years, the BLM has made great progress in improving vegetation composition, quality and ground cover. Range 

conditions have improved from poor/fair to good/excellent. When I first worked for the BLM in Wyoming and Montana, 

large numbers of sage-grouse were available and observed. As we improved range conditions, sage-grouse numbers 

diminished. A question that needs to be addressed "have improved range conditions adversely affected sage grouse 

populations”?

All Both emc0135GB

38. Because BLM’s underlying goal is to conserve greater sage-grouse and because time is of the essence, we suggest that 

predation and predation management receive consideration in the NEPA process. BLM and its cooperating agency partners 

may provide a more comprehensive analysis and enhance the potential for sage-grouse conservation success by addressing 

All Both emc0138GB
C. Comments by Resource Planning Issue

C-1038 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

these issues and questions when developing the environmental analyses: 1. Where and how has predation contributed to 

the decline of greater sage-grouse in the existing environment? How have habitat management and resource development

practices encouraged predation? What land use changes can alter habitats to deter or enhance predation? 2. What role 

would direct predation management play in a reasonable range of alternatives? Could BLM or its partners select these 

options to enhance project success? 3. What predation management research needs are being addressed? How effective 

has predation management been thus far? 4. How might predation management enhance the overall success of the 

proposed actions and alternatives to help BLM and its cooperating agencies achieve the goal of greater sagegrouse

conservation and avoidance of an ESA listing?

39. Regarding adequate residual plant cover, the regulations should reiterate that ecosystems, occupied habitat and greater 

sage-grouse populations vary and should not be managed by a “one-size-fits-all” approach, but rather by an approach that 

allows land managers, local working groups and grazing permittees to collaborate on management practices that benefit the 

resources affecting individual populations in small areas—not over the entire Western greater sage-grouse range. 

Structure objectives that are consistent with the multiple needs should then be developed. The above-mentioned decision 

makers should determine appropriate levels of grazing and grazing systems that will contribute to greater sage-grouse 

habitat in any given area. To develop habitat objectives for nesting habitat areas, they should consider factors such as the 

greater sage-grouse guidelines, present vegetation, site potential based on the ecological site description and other relevant 

factors, such as legally authorized land uses and the habitat needs of other species. It must be recognized that factors 

including snow load, rain, wind and other grazers (including insects) significantly impact residual plant cover, especially for 

the subsequent spring measurements. If residual plant cover is to be measured, all factors must be taken into consideration.

All Both emc0140RM

40. BLM is unclear on its habitat maps when identifying grassland, sage brush steppe and semi desert areas. On reviewing the 

maps, there are known areas that are large grasslands that are being identified as a sage brush steppe or a semi desert. BLM 

needs to identify the criteria used when making the break between grassland and a sage brush steppe in mapping units.

All Both emc0140RM

41. In conclusion the key to restoring Sage Grouse populations is early and full suppression of fires, restoration of the burnt 

area with native shrubs and grasses, and controlling predators like coyotes, foxes and wolves.

All Both emc0145GB

42. I believe you need to have one alternative address what happens if you only produce primarily grasslands in the future, due 

to fire occurrence and shrubs not surviving. You need to evaluate how frequent fire occurrence may mean you are not 

going to be successful in building shrub lands even through active intervention?

All Both emc0149GB

43. It is admirable to try to use native plants as you have over time. We all know there are limitations in cost and availability to 

use native plants. You need to be realistic in the use native plants, availability over the life of this effort and the capability to 

use other species. I have seen decisions to do nothing if native plants were not available. That can be an alternative in this 

decision making process, but the use of native plants needs to be addressed here. An alternative needs to address this issue.

All Both emc0149GB

44. Objectives, methodologies and terminology used in conducting inventories and monitoring varies within and among 

agencies and evolved over time (Natural Resources Council 1994; Wombolt et. al, 2002).). The original mandates for 

inventory of USDA Forest Service, and later USDI Bureau of Land Management, lands emphasized measurements of 

carrying capacity for livestock, as did early national surveys of federal rangelands (Box 1990, Rowley 1985). The USDA 

Forest Service currently uses a line intercept technique that over-estimates sagebrush canopy cover by including openings 

All Both emc0159GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1039

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

in crowns of individual shrubs as crown cover (U.S. Department of Agriculture 1993). This leads to issues about data quality 

compared to methods using more precise techniques considered appropriate for research. USDA Soil Conservation 

Service inventories were designed to measure soil erosion and the status of natural resources to aid in ranch management. 

Inventory systems developed by these agencies were based upon the succession status of the observed plant community 

relative to the historic climax plant community (Dyksterhuis 1949) or to a desired plant community. The systems differed 

in their classification of sites, evaluation of site status or condition, estimation of site potentials, determination of trend or 

the direction of change in vegetation (Wombolt et. al, 2002).

45. Maintenance of healthy sagebrush-dominated communities and landscapes centers upon management to protect or 

improve their physical and biotic resources and functions. To apply management to the landscape at the right time and in 

the right places requires efforts to not only protect sage grouse, but consideration of the other species using the same 

habitats. A balanced approach is needed to find the scale and time frame that will be required to sustain the rangelands and 

habitat based on current understanding. Careful interpretation of inventory and monitoring methods are needed to 

measure the quantity and quality of habitat followed with appropriate management techniques that will maintain or 

improve the habitat (Wombolt 2002).

All Both emc0159GB

46. Forbs are also a critical source of food for young chicks. During spring, important forb species include common dandelion 

(Taraxacum officinale), yellow salsify (Tragpopogon dubius), prairie pepperweed (Lepidium desiflorum), clover (Trifolium 

spp.), knotweed (Polygonum spp.), alfalfa (Medicago sativa), yarrow (Achillea spp.), sweet clover (Melilotus spp.), vetch 

(Vicia spp.), milk vetch (Astragulus spp.), and prickly lettuce (Lactuca serriola) (Schroeder et al. 1999).

All Both emc0159GB

47. Predation needs to be considered as a reasonable factor on the impact to sage grouse populations in the EIS. Based on 

observations by numerous local ranchers, the impact is a critical factor to consider. Where studies are lacking, the EIS 

should take into account what is available and give serious weight to the ODFW plan that states a rigorous data collection 

is needed in the sampling schemes for lek counts. The same is true for many areas of the sage grouse habitat and other 

wildlife issues. Discussing science is not the same as doing science. The basic principles of doing science requires a good 

study design, rigorous data collection, and analysis. - Population ecology - Understanding annual survival and seasonal 

mortality is critical and largely undocumented in Oregon. Similarly there is still a need to refine methods to estimate 

population sizes. Similarly, development of a probabilistic sampling scheme for lek counts is paramount to provide some 

level of rigor to the data collection. (Oregon Dept. Fish and Wildlife, April 2011. Greater Sage-­Grouse Conservation 

Assessment and Strategy for Oregon: A Plan to Maintain and Enhance Populations and Habitat). - Survival of 

sage-grouse is typically high with more than approximately 60% of a cohort surviving from year to year. - Of the 40% of 

a grouse population that succumbs to mortality during a year predation accounts for approximately 85% of reported 

non-hunting mortalities and 79% of nest failures (Bergerud 1988). - Specifically, predation on nests and young chicks can 

be high and affect populations (Gregg et al. 1994, Aldridge and Brigham 2001, Schroeder and Baydack 2001, Coates 2007). 

However, few studies have indicated that predation is a major limiting factor to sage grouse. - In Idaho, predation was the 

most common cause of death for radio-marked sage- grouse (83% of males and 52% of females) in a hunted population 

(Connelly et al. 2000a) where apparent survival was 71 and 68% for male and female sage- grouse, respectively. Coyotes 

(Canis latrans), badgers, (Taxidea taxus), bobcats (Felis rufus), and several species of raptors are common predators of 

All Both emc0159GB
C. Comments by Resource Planning Issue

C-1040 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

juvenile and adult sage-grouse throughout most of sage-grouse range (Hagen 2011). Additionally, coyotes, badgers, 

common ravens (Corvus corax), and blackbilled magpies (Pica pica) commonly prey on sage-grouse eggs (Hagen 2011).

48. Thousands of acres of decadent sage brush exist throughout BLM lands. Wildlife biologists claim that sage brush is needed 

by obligate species and wintering wildlife. I believe this to be true, but not to the extent and degree that sage brush exists 

today.

All Both emc0165GB

49. Objectives, methodologies and terminology used in conducting inventories and monitoring varies within and among 

agencies and evolved over time (Natural Resources Council 1994; Wombolt et. al, 2002).). The original mandates for 

inventory of USDA Forest Service, and later USDI Bureau of Land Management, lands emphasized measurements of 

carrying capacity for livestock, as did early national surveys of federal rangelands (Box 1990, Rowley 1985). The USDA 

Forest Service currently uses a line intercept technique that over-estimates sagebrush canopy cover by including openings 

in crowns of individual shrubs as crown cover (U.S. Department of Agriculture 1993). This leads to issues about data quality 

compared to methods using more precise techniques considered appropriate for research. USDA Soil Conservation 

Service inventories were designed to measure soil erosion and the status of natural resources to aid in ranch management. 

Inventory systems developed by these agencies were based upon the succession status of the observed plant community 

relative to the historic climax plant community (Dyksterhuis 1949) or to a desired plant community. The systems differed 

in their classification of sites, evaluation of site status or condition, estimation of site potentials, determination of trend or 

the direction of change in vegetation (Wombolt et. al, 2002).

All Both emc0179GB

50. Maintenance of healthy sagebrush-dominated communities and landscapes centers upon management to protect or 

improve their physical and biotic resources and functions. To apply management to the landscape at the right time and in 

the right places requires efforts to not only protect sage grouse, but consideration of the other species using the same 

habitats. A balanced approach is needed to find the scale and time frame that will be required to sustain the rangelands and 

habitat based on current understanding. Careful interpretation of inventory and monitoring methods are needed to 

measure the quantity and quality of habitat followed with appropriate management techniques that will maintain or 

improve the habitat (Wombolt 2002).

All Both emc0179GB

51. Forbs are also a critical source of food for young chicks. During spring, important forb species include common dandelion 

(Taraxacum officinale), yellow salsify (Tragpopogon dubius), prairie pepperweed (Lepidium desiflorum), clover (Trifolium 

spp.), knotweed (Polygonum spp.), alfalfa (Medicago sativa), yarrow (Achillea spp.), sweet clover (Melilotus spp.), vetch 

(Vicia spp.), milk vetch (Astragulus spp.), and prickly lettuce (Lactuca serriola) (Schroeder et al. 1999).

All Both emc0179GB

52. Predation needs to be considered as a reasonable factor on the impact to sage grouse populations in the EIS. Based on 

observations by numerous local ranchers, the impact is a critical factor to consider. Where studies are lacking, the EIS 

should take into account what is available and give serious weight to the ODFW plan that states a rigorous data collection 

is needed in the sampling schemes for lek counts. The same is true for many areas of the sage grouse habitat and other 

wildlife issues. Discussing science is not the same as doing science. The basic principles of doing science requires a good 

study design, rigorous data collection, and analysis. - Population ecology - Understanding annual survival and seasonal 

mortality is critical and largely undocumented in Oregon. Similarly there is still a need to refine methods to estimate 

population sizes. Similarly, development of a probabilistic sampling scheme for lek counts is paramount to provide some 

All Both emc0179GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1041

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

level of rigor to the data collection. (Oregon Dept. Fish and Wildlife, April 2011. Greater Sage-­Grouse Conservation 

Assessment and Strategy for Oregon: A Plan to Maintain and Enhance Populations and Habitat). - Survival of 

sage-grouse is typically high with more than approximately 60% of a cohort surviving from year to year. - Of the 40% of 

a grouse population that succumbs to mortality during a year predation accounts for approximately 85% of reported 

non-hunting mortalities and 79% of nest failures (Bergerud 1988). - Specifically, predation on nests and young chicks can 

be high and affect populations (Gregg et al. 1994, Aldridge and Brigham 2001, Schroeder and Baydack 2001, Coates 2007). 

However, few studies have indicated that predation is a major limiting factor to sage grouse. - In Idaho, predation was the 

most common cause of death for radio-marked sage- grouse (83% of males and 52% of females) in a hunted population 

(Connelly et al. 2000a) where apparent survival was 71 and 68% for male and female sage- grouse, respectively. Coyotes 

(Canis latrans), badgers, (Taxidea taxus), bobcats (Felis rufus), and several species of raptors are common predators of 

juvenile and adult sage-grouse throughout most of sage-grouse range (Hagen 2011). Additionally, coyotes, badgers, 

common ravens (Corvus corax), and blackbilled magpies (Pica pica) commonly prey on sage-grouse eggs (Hagen 2011).

53. Objectives, methodologies and terminology used in conducting inventories and monitoring varies within and among 

agencies and evolved over time (Natural Resources Council 1994; Wombolt et. al, 2002).). The original mandates for 

inventory of USDA Forest Service, and later USDI Bureau of Land Management, lands emphasized measurements of 

carrying capacity for livestock, as did early national surveys of federal rangelands (Box 1990, Rowley 1985). The USDA 

Forest Service currently uses a line intercept technique that over-estimates sagebrush canopy cover by including openings 

in crowns of individual shrubs as crown cover (U.S. Department of Agriculture 1993). This leads to issues about data quality 

compared to methods using more precise techniques considered appropriate for research. USDA Soil Conservation 

Service inventories were designed to measure soil erosion and the status of natural resources to aid in ranch management. 

Inventory systems developed by these agencies were based upon the succession status of the observed plant community 

relative to the historic climax plant community (Dyksterhuis 1949) or to a desired plant community. The systems differed 

in their classification of sites, evaluation of site status or condition, estimation of site potentials, determination of trend or 

the direction of change in vegetation (Wombolt et. al, 2002).

All Both emc0179GB

54. Maintenance of healthy sagebrush-dominated communities and landscapes centers upon management to protect or 

improve their physical and biotic resources and functions. To apply management to the landscape at the right time and in 

the right places requires efforts to not only protect sage grouse, but consideration of the other species using the same 

habitats. A balanced approach is needed to find the scale and time frame that will be required to sustain the rangelands and 

habitat based on current understanding. Careful interpretation of inventory and monitoring methods are needed to 

measure the quantity and quality of habitat followed with appropriate management techniques that will maintain or 

improve the habitat (Wombolt 2002).

All Both emc0179GB

55. Forbs are also a critical source of food for young chicks. During spring, important forb species include common dandelion 

(Taraxacum officinale), yellow salsify (Tragpopogon dubius), prairie pepperweed (Lepidium desiflorum), clover (Trifolium 

spp.), knotweed (Polygonum spp.), alfalfa (Medicago sativa), yarrow (Achillea spp.), sweet clover (Melilotus spp.), vetch 

(Vicia spp.), milk vetch (Astragulus spp.), and prickly lettuce (Lactuca serriola) (Schroeder et al. 1999).

All Both emc0179GB

56. Management of habitat for the greater sage-grouse occurs on a complex sagebrush dominated landscape with tremendous All Both emc0204GB
C. Comments by Resource Planning Issue

C-1042 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

variability locally and range wide. It is ecologically impossible to regulate for improved sage-grouse performance with 

species specific regulatory measures. Local citizens working together to resolve local and site specific issues offers the best 

chance for success. Considerable work has already been accomplished at the local level in planning for improved vegetative 

management. To date the agencies have failed to implement the majority of these planning efforts. Agencies should 

prioritize and implement these measures before increasing regulatory control that often paralyzes needed action.

57. I am a livestock producer based in the state of Nevada. Livestock grazing is a legal and valid use of public rangelands and is 

a vital component of my livelihood. The extensive encroachment of pinyon-juniper into sagebrush communities, coupled 

with vast expanses of decadent single aged sagebrush communities, has drastically decreased productive habitat for nesting 

and brood rearing sites for sage-grouse throughout the Great Basin and much of the West. The proposed range-wide 

guidelines do not recognize the variability of issues across the west and do not focus on or prioritize specific issues at the 

needed scale.

All Both emc0204GB

58. Objectives, methodologies and terminology used in conducting inventories and monitoring varies within and among 

agencies and evolved over time (Natural Resources Council 1994; Wombolt et. al, 2002).). The original mandates for 

inventory of USDA Forest Service, and later USDI Bureau of Land Management, lands emphasized measurements of 

carrying capacity for livestock, as did early national surveys of federal rangelands (Box 1990, Rowley 1985). The USDA 

Forest Service currently uses a line intercept technique that over-estimates sagebrush canopy cover by including openings 

in crowns of individual shrubs as crown cover (U.S. Department of Agriculture 1993). This leads to issues about data quality 

compared to methods using more precise techniques considered appropriate for research. USDA Soil Conservation 

Service inventories were designed to measure soil erosion and the status of natural resources to aid in ranch management. 

Inventory systems developed by these agencies were based upon the succession status of the observed plant community 

relative to the historic climax plant community (Dyksterhuis 1949) or to a desired plant community. The systems differed 

in their classification of sites, evaluation of site status or condition, estimation of site potentials, determination of trend or 

the direction of change in vegetation (Wombolt et. al, 2002).

All Both emc0209GB

59. Maintenance of healthy sagebrush-dominated communities and landscapes centers upon management to protect or 

improve their physical and biotic resources and functions. To apply management to the landscape at the right time and in 

the right places requires efforts to not only protect sage grouse, but consideration of the other species using the same 

habitats. A balanced approach is needed to find the scale and time frame that will be required to sustain the rangelands and 

habitat based on current understanding. Careful interpretation of inventory and monitoring methods are needed to 

measure the quantity and quality of habitat followed with appropriate management techniques that will maintain or 

improve the habitat (Wombolt 2002).

All Both emc0209GB

60. Forbs are also a critical source of food for young chicks. During spring, important forb species include common dandelion 

(Taraxacum officinale), yellow salsify (Tragpopogon dubius), prairie pepperweed (Lepidium desiflorum), clover (Trifolium 

spp.), knotweed (Polygonum spp.), alfalfa (Medicago sativa), yarrow (Achillea spp.), sweet clover (Melilotus spp.), vetch 

(Vicia spp.), milk vetch (Astragulus spp.), and prickly lettuce (Lactuca serriola) (Schroeder et al. 1999).

All Both emc0209GB

61. Predation needs to be considered as a reasonable factor on the impact to sage grouse populations in the EIS. Based on 

observations by numerous local ranchers, the impact is a critical factor to consider. Where studies are lacking, the EIS 

All Both emc0209GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1043

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

should take into account what is available and give serious weight to the ODFW plan that states a rigorous data collection 

is needed in the sampling schemes for lek counts. The same is true for many areas of the sage grouse habitat and other 

wildlife issues. Discussing science is not the same as doing science. The basic principles of doing science requires a good 

study design, rigorous data collection, and analysis. - Population ecology - Understanding annual survival and seasonal 

mortality is critical and largely undocumented in Oregon. Similarly there is still a need to refine methods to estimate 

population sizes. Similarly, development of a probabilistic sampling scheme for lek counts is paramount to provide some 

level of rigor to the data collection. (Oregon Dept. Fish and Wildlife, April 2011. Greater Sage-­Grouse Conservation 

Assessment and Strategy for Oregon: A Plan to Maintain and Enhance Populations and Habitat). - Survival of 

sage-grouse is typically high with more than approximately 60% of a cohort surviving from year to year. - Of the 40% of 

a grouse population that succumbs to mortality during a year predation accounts for approximately 85% of reported 

non-hunting mortalities and 79% of nest failures (Bergerud 1988). - Specifically, predation on nests and young chicks can 

be high and affect populations (Gregg et al. 1994, Aldridge and Brigham 2001, Schroeder and Baydack 2001, Coates 2007). 

However, few studies have indicated that predation is a major limiting factor to sage grouse. - In Idaho, predation was the 

most common cause of death for radio-marked sage- grouse (83% of males and 52% of females) in a hunted population 

(Connelly et al. 2000a) where apparent survival was 71 and 68% for male and female sage- grouse, respectively. Coyotes 

(Canis latrans), badgers, (Taxidea taxus), bobcats (Felis rufus), and several species of raptors are common predators of 

juvenile and adult sage-grouse throughout most of sage-grouse range (Hagen 2011). Additionally, coyotes, badgers, 

common ravens (Corvus corax), and blackbilled magpies (Pica pica) commonly prey on sage-grouse eggs (Hagen 2011).

62. Another thing that needs to happen is stop pasturising of the burn areas with crested wheat and grasses just for cattle 

grazing. All burn areas have to be returned to the native grasses that were there in the beginning especially sagebrush. 

Crested wheat should be classified as a noxious weed and get rid of it.

All Both emc0211GB

63. We encourage BLM to recognize and address the following in the EIS and in plan revisions: 1. The importance of addressing 

existing threats from wildfire and invasive species encroachment, particularly juniper encroachment.

All BLM emc0212GB

64. Objectives, methodologies and terminology used in conducting inventories and monitoring varies within and among 

agencies and evolved over time (Natural Resources Council 1994; Wombolt et. al, 2002).). The original mandates for 

inventory of USDA Forest Service, and later USDI Bureau of Land Management, lands emphasized measurements of 

carrying capacity for livestock, as did early national surveys of federal rangelands (Box 1990, Rowley 1985). The USDA 

Forest Service currently uses a line intercept technique that over-estimates sagebrush canopy cover by including openings 

in crowns of individual shrubs as crown cover (U.S. Department of Agriculture 1993). This leads to issues about data quality 

compared to methods using more precise techniques considered appropriate for research. USDA Soil Conservation 

Service inventories were designed to measure soil erosion and the status of natural resources to aid in ranch management. 

Inventory systems developed by these agencies were based upon the succession status of the observed plant community 

relative to the historic climax plant community (Dyksterhuis 1949) or to a desired plant community. The systems differed 

in their classification of sites, evaluation of site status or condition, estimation of site potentials, determination of trend or 

the direction of change in vegetation (Wombolt et. al, 2002).

All Both emc0222GB

65. Maintenance of healthy sagebrush-dominated communities and landscapes centers upon management to protect or All Both emc0222GB
C. Comments by Resource Planning Issue

C-1044 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

improve their physical and biotic resources and functions. To apply management to the landscape at the right time and in 

the right places requires efforts to not only protect sage grouse, but consideration of the other species using the same 

habitats. A balanced approach is needed to find the scale and time frame that will be required to sustain the rangelands and 

habitat based on current understanding. Careful interpretation of inventory and monitoring methods are needed to 

measure the quantity and quality of habitat followed with appropriate management techniques that will maintain or 

improve the habitat (Wombolt 2002).

66. Forbs are also a critical source of food for young chicks. During spring, important forb species include common dandelion 

(Taraxacum officinale), yellow salsify (Tragpopogon dubius), prairie pepperweed (Lepidium desiflorum), clover (Trifolium 

spp.), knotweed (Polygonum spp.), alfalfa (Medicago sativa), yarrow (Achillea spp.), sweet clover (Melilotus spp.), vetch 

(Vicia spp.), milk vetch (Astragulus spp.), and prickly lettuce (Lactuca serriola) (Schroeder et al. 1999).

All Both emc0222GB

67. Predation needs to be considered as a reasonable factor on the impact to sage grouse populations in the EIS. Based on 

observations by numerous local ranchers, the impact is a critical factor to consider. Where studies are lacking, the EIS 

should take into account what is available and give serious weight to the ODFW plan that states a rigorous data collection 

is needed in the sampling schemes for lek counts. The same is true for many areas of the sage grouse habitat and other 

wildlife issues. Discussing science is not the same as doing science. The basic principles of doing science requires a good 

study design, rigorous data collection, and analysis. - Population ecology - Understanding annual survival and seasonal 

mortality is critical and largely undocumented in Oregon. Similarly there is still a need to refine methods to estimate 

population sizes. Similarly, development of a probabilistic sampling scheme for lek counts is paramount to provide some 

level of rigor to the data collection. (Oregon Dept. Fish and Wildlife, April 2011. Greater Sage-­Grouse Conservation 

Assessment and Strategy for Oregon: A Plan to Maintain and Enhance Populations and Habitat). - Survival of 

sage-grouse is typically high with more than approximately 60% of a cohort surviving from year to year. - Of the 40% of 

a grouse population that succumbs to mortality during a year predation accounts for approximately 85% of reported 

non-hunting mortalities and 79% of nest failures (Bergerud 1988). - Specifically, predation on nests and young chicks can 

be high and affect populations (Gregg et al. 1994, Aldridge and Brigham 2001, Schroeder and Baydack 2001, Coates 2007). 

However, few studies have indicated that predation is a major limiting factor to sage grouse. - In Idaho, predation was the 

most common cause of death for radio-marked sage- grouse (83% of males and 52% of females) in a hunted population 

(Connelly et al. 2000a) where apparent survival was 71 and 68% for male and female sage- grouse, respectively. Coyotes 

(Canis latrans), badgers, (Taxidea taxus), bobcats (Felis rufus), and several species of raptors are common predators of 

juvenile and adult sage-grouse throughout most of sage-grouse range (Hagen 2011). Additionally, coyotes, badgers, 

common ravens (Corvus corax), and blackbilled magpies (Pica pica) commonly prey on sage-grouse eggs (Hagen 2011).

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68. Please look into improving the Sage Grouse sage brush habitat environment by re-vegetation measures after wild fires 

which are the main cause of the loss of the habitat. Immediate re-seeding of sage brush, bitter brush, etc., would help choke 

out the cheat grass which prevents the growth of the habitat plants the Sage Grouse needs.

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69. Vegetation treatments without improved management will be very short lived. Local Sage Grouse working groups should 

play a major role with respect to sage grouse habitat projects

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70. Increase grazing by cattle, sheep, and horses to bring the over abundant fuel load of cheat grass and other non-native All Both emc0241GB
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species of plants down to end the danger of catastrophic wildland fires. Managed and rotated grazing has beneficial effects 

for the sagegrouse by removing woofy dead grasses and stimulating softer forages.

71. The BLM should continue to encourage a wide range of vegetation management tools that have utility in the restoration or 

conservation of sage grouse habitat. Taking a hands-off approach to vegetation management is usually counter-productive.

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72. Indeed, human disturbances of all sorts, roads, railways, fences, reservoirs, towns, homesteads, farms, mines, etc. 

flourished in the early to mid 1900s, and so did the sage-grouse. The mere presence of human activity seems to have little 

biologically relevant connection to sage-grouse population trends. However, specific human activities appear to correlate 

positively with GSG population trends. Livestock grazing management, with its associated intensive development of 

meadows, hayfields, and surface water sources increased markedly in the Great Basin in the late 1800s and early 1900s, and 

GSG populations boomed. During this period, high livestock densities (both sheep and cattle) reduced fine wildfire fuel 

loads across the Great Basin, and wildfires were rare and small. High densities of livestock dung also supplied an abundance 

of insect activity, particularly in closely grazed meadows and riparian areas, and the close grazing stimulated succulent new

herbaceous growth and increased the forb component in these meadows and riparian areas, thereby increasing the 

quantity and quality of the forage supply for sage-grouse. At the same time, concerted predator control was practiced. In 

fact, predator control was encouraged, subsidized, and implemented on a vast scale by the Federal and State governments.

By the mid 1900s, Federal and State regulations were implemented and all of the grazing management practices discussed 

above were controlled and moderated. The GSG population boom moderated at about the same time. By the late 1960s, 

livestock numbers and grazing levels were significantly scaled back across the west, and predator control programs were 

largely curtailed. Fire fuel levels increased, and the incidence of large-scale wildfires rose exponentially. GSG population 

trends reversed and started to rapidly decline.

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73. Weed eradication is vital and manageable with education of users and volunteers (not just money and one sided weed 

programs). The answer to less and less weeds instead of the current trend or more and more weeds is education and 

volunteers from user groups and from litigating special interest groups would go far in solving the cheat grass and medusa 

head overpopulation. Cheat grass and medusa head are the two weeds with the most potential to take over and destroy 

sage grouse habitat and they are the closest and most accessible for spread by man and animal and machine. (Some 

individuals actually do not understand the workings of stewardship of nature. You must tend the garden to yield a product 

be it natural habitat or noxious invasive weeds each need man’s assistance.)

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74. There are also several cumulative effects that must be considered. For example, livestock grazing in combination with 

drought and climate change can have a severe impact on sagebrush communities. Fire risk to sagebrush habitats may also 

increase, as livestock consume native vegetation and spread noxious weeds and invasive plants. And when grazing is 

combined with other disturbances, sagebrush habitats may experience greater shrub loss and increase the chances of the 

introduction and spread of cheatgrass compared to landscapes having a single source of disturbance.

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75. The importance and impacts of grazing pressure, rest, and rotation on the condition of sagebrush landscapes and the 

capability of these sagebrush habitats to support sage-grouse are not fully understood, largely due to a lack of research and 

experimentation. Also, impacts to sage-grouse may be different depending on which season and stage of life is being 

considered: breeding, nesting, brood rearing, or wintering.

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C. Comments by Resource Planning Issue

C-1046 Greater Sage-Grouse LUPAs/EISs May 2012

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76. Habitat manipulations by land management agencies, including habitat alterations and land treatments, may lead to a decline 

in suitable sage-grouse habitat. For example, the use of herbicides and pesticides can kill plants and forbs necessary for 

sage-grouse survival. Habitat manipulations used to increase forage for domestic livestock or other ungulate wildlife species

include chemical and mechanical treatments to remove sagebrush, and is often followed by reseeding with nonnative plants. 

Such habitat manipulations alter the natural food web and chance the nutrient dynamics for sage-grouse. Additionally, such 

alterations in combination with other impacts may further negatively affect sage-grouse habitat. For example, the seeding of 

nonnative plants may spread beyond the boundaries of the treatment area. And in combination with fire and other 

disturbance regimes, sagebrush removal and reseeding with nonnative plants may seriously affect the vegetation structure 

used by greater sage-grouse. Climate change may also play a role in the expansion of nonnative plants and the recovery 

capacity of such areas to reestablish a healthy sagebrush ecosystem.

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77. Climate change will not only affect the distribution of wildlife but also affects vegetation and plant life. Although most plants 

respond positive to increased carbon dioxide levels, many invasive nonnative plants respond with greater growth rates than 

native plants, including cheatgrass. Similarly, field studies reveal that cheatgrass demonstrates significantly higher plant

density, biomass, and dispersed seeds at elevated carbon dioxide levels. Depending on the future precipitation regime, 

studies anticipate that cheatgrass is likely to move northwards, leading to expansion into Idaho, Montana, and Wyoming. 

This prediction, in conjunction with analyses suggesting large displacement and reduction of sagebrush habits as a result of 

climate change as early as 2030, increases the likelihood that climate change will negatively and potentially severely impact 

sage-grouse and sagebrush habitat. Additionally, cheatgrass invasion may also lead to an increase in the likelihood and 

severity of fires, causing further damage to an already weakened habitat.

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78. Similarly, the agencies should prohibit land treatments within priority sage-grouse habitat unless it can be demonstrated 

that such actions will result in a net benefit to sage-grouse in the short term and the long term. This is in line with the 

Technical Team Report’s directive to “[o]nly allow treatments that conserve, enhance or restore sage-grouse habitat.”32 

Such treatments include prescribed burns and use of pesticides and herbicides. The Technical Team Report’s proposed 

measures do not go far enough in respect to fuels management, often providing exceptions for allowing fires that may not 

protect sagebrush adequately in sage-grouse habitat.33 We suggest that the agencies revisit the criteria recommended by 

the Technical Team Report and strengthen requirements to ensure that land treatments, including fuels management, are 

not implemented unless they would not harm and would benefit sage-grouse in priority sage-grouse habitat. See infra 

Sections III.F & G for more information on the threats associated with prescribed burns and other habitat manipulations.

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79. Because invasive plants and noxious weeds can degrade and destroy sagebrush habitats, the agencies should focus on 

identifying known locations and areas of future risk for top priority invasive plant species and noxious weeds, including 

cheatgrass. Once these priority areas are identified, the agencies should develop and use a model to predict population 

outcomes and potential habitat changes as a result of potential changes in vegetation from invasive plant species or noxious 

weeds. All activities within sagebrush lands should be managed in a way that minimizes the potential for the introduction 

and/or spread of invasive plant species and noxious weeds.

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80. In our experience, well-designed reclamation of public lands impacted by mining can ultimately lead to higher value habitat 

than if the same lands were left unmanaged. We believe that this principle applies to sage-grouse habitat as well. For 

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example, it is generally accepted that noxious invasive species like Bromus tectorum (cheat grass) have significantly 

degraded vast areas of former sage-grouse habitat. Conversely, pinyonjuniper succession can lead to conversion of prime 

sage-grouse habitat into comparatively low-value woodlands. During mine reclamation, Barrick routinely restores such 

low-value habitats into prime potential sage-grouse habitat. Thus, when coupled with appropriate reclamation 

requirements, mining activi ty on public lands can play an important role in restoring sage-grouse and other species to 

long-term viability.

81. Barrick has conducted assessments of the ranches adjacent to some of its mining operations that may be useful to the 

agencies, particularly if the agencies are interested in evaluating the potential for mitigation projects or "banks" in these 

areas. These same type of assessments are being included in the baseline studies conducted on potential mine development 

sites. This information may be available for the NEPA analysis and may allow for determination of impacts and mitigation for 

the impacts. The existing information for the ranches provides guidance and opportunity for where off-site mitigation can 

be conducted within the vicinity of the impacts.

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82. • Habitat fragmentation: The definition of habitat fragmentation needs to be clearly defined to ensure that treatments that 

remove sagebrush in an effort to maintain the integrity of the ecological site with the eventual reestablishment of sagebrush 

on the site are not considered actions that fragment the habitat. The various phases of the ecological site plant community 

are not fragments, but parts of the overall landscape-scale habitat for sage-grouse. • Unfragmented habitats: The meaning 

of unfragmented habitats should be clearly defined. For example, if a wildfire breaks a large area of intact habitat into two

large areas, and the burned area converts to cheatgrass or other non-native annual species, then this burned area may be 

considered fragmented. However, if the area that burned realizes the establishment of native perennial grasses and forbs, 

then this is the first phase of the rehabilitation of the site back to sagebrush-grassland and the area may not be considered 

as being fragmented-the ecological site is still intact and will support sage-grouse habitat. Areas that have been burned or 

otherwise converted to non-native ranges may be considered for rehabilitation with the goal of re-establishing native 

perennial grasses and forbs, and eventually, big sagebrush.

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83. • Protection of intact sagebrush communities: "Protection of intact sagebrush communities" should recognize that the 

integrity of the ecological site may include various phases with little to no sagebrush, allowing sagebrush to reestablish in an 

appropriate time period. This type of management or vegetation treatment sustains the long-term maintenance of intact 

sagebrush communities. "Protecting" intact sagebrush communities from disturbance increases the risk of catastrophic 

fires in the shrub-dominated communities and increases the risk of conversion to non-native annual species, with the 

subsequent loss of sage-grouse habitat. The term "protection" should be replaced with "management" as these ecological 

sites are disturbance driven in the Great Basin.

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84. • Large intact sagebrush communities: The definition of large intact sagebrush communities needs to be clearly stated. In 

the context of the ESD and State and Transition Models, this means maintaining the integrity of the ecological site, which 

includes various phases of vegetation on the landscape such as a grass-forb phase, a grass-forb/shrub phase, a 

shrub/grass-forb phase, and shrub dominated phase. It does not mean that large areas of old, decadent sagebrush should be 

maintained on the landscape. Old, decadent sagebrush cannot be maintained on the landscape as lightning ignitions occur 

frequently in this vegetation condition and the large intact nature of such stands results in extremely large burned areas that 

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C. Comments by Resource Planning Issue

C-1048 Greater Sage-Grouse LUPAs/EISs May 2012

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bum with extreme intensity and result in high plant mortality.

85. Three percent anthropogenic disturbance restriction: Please provide the scientific basis for the 3% figure. What is the basis

for establishing a numerical threshold? How was the 3% figure identified? Were any other figures considered, and if so, why 

were they rejected? How is the boundary delineated? What would be considered acceptable mitigation to avoid the 

threshold? For example, if a burned area was reseeded with perennial grasses and shrubs, do the shrubs have to be 

established and 3 feet tall to be considered successful reclamation? If so, then this could take several years.

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86. • Seventy percent land cover for priority habitat: Please explain the recommendation to "manage or restore priority areas 

so that at least 70% of the land cover provides adequate sagebrush habitat to meet sage-grouse needs." This 

recommendation does not appear to take into account ecological sites that occur within these large areas that do not have 

the capacity to provide the cover requirements of sage-grouse. What is the scientific basis for the 70% figure? What is the 

basis for establishing any numerical threshold? How was the 70% figure identified? Were any other figures considered, and 

if so, why were they rejected?

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87. • Migration: The Technical Report provides that priority sagegrouse habitats should include "migration or connectivity 

corridors." Please explain why connectivity corridors are necessary when sage-grouse migration is completed by flight. 

Nonetheless, connectivity corridors are likely to exist when narrow strips of habitat link higher and lower elevation 

habitats. Such connectivity is generally broken by natural processes, such as encroachment by pinyon-juniper, not 

anthropogenic activities. What is the scientific basis for this designation? How will the agencies identify these corridors?

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88. • Mitigation: Absolute disturbance or land cover requirements (for example 3% anthropogenic activities or 70% land cover) 

eliminate the role and potential of on- and off-site mitigation to improve the area. For example, a project may be authorized 

that disturbs more than 3% of a given area. If the project includes mitigation of what is otherwise poor habitat within the 

area or off-site, there may be a net habitat benefit that would not otherwise occur without the development-mitigation 

relationship. How will the agencies provide for appropriate mitigation?

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89. The management plan revisions must comply with multiple use and sustained yield requirements Barrick's experience is 

that productive uses can co-exist with, and benefit, sagegrouse when coupled with appropriate conservation measures. 

Noxious weeds, wildfires, and pinyon-juniper encroachment have degraded vast areas of potential sage-grouse habitat. 

During mine reclamation, we routinely restore such low-value habitats into prime potential sage-grouse habitat. Our 

ranches also provide off-site restoration opportunities that possibly would not be available without their connection to 

mining operations. We believe the best way to provide for protection of the sage-grouse, while simultaneously allowing 

continued economic development, is for BLM to develop conservation measures in cooperation with the regulated 

community that include a strong but pragmatic mitigation program. Therefore, our comments request that the EISs 

recognize multiple use principles and feasible alternatives that include mitigation opportunities that will promote 

sage-grouse conservation.

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90. The management plan revisions must comply with multiple use and sustained yield requirements The agencies are 

required to manage for "multiple uses." However, the BLM Technical Team's conservation measures prioritize sage-grouse 

management to the exclusion of other uses. For example, as noted above, one measure would prohibit any disturbances 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1049

Scoping Summary Report

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affecting more than 3% of priority sage-grouse habitat. 17 That restriction seemingly would preclude any roads, 

transmission lines, substations, wind turbines, oil and gas wells, geothermal wells, pipelines, landfills, homes, mines, or other 

uses from affecting more than 3% of priority habitat. See id. BLM also proposes to withdraw priority habitat from mineral 

entry, threatening existing and future mining claims. 18 The scoping analysis should recognize that the proposed revisions 

must comply with the agencies' multiple use mandates.

91. We have seen positive effects on rangeland function and GSG from strategic vegetative treatments when done in 

conjunction with time-controlled, rotational grazing (see below).

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92. Please remember these landscapes often provide essential habitat to multiple species-some of which require old-age 

sagebrush canopies and others requiring early seral conditions. A well managed landscape is managed not to maximize 

value for any one specie (whether cattle or sage grouse) but rather maximizes overall value by ‘optimizing’, or maintaining 

viable habitat for multiple species (including wildlife and livestock, Danvir et al 2005).

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93. Our observations on sagebrush rangelands throughout the GSG range has been that the best way to create healthy GSG 

habitat and meet rangeland standards is to graze right - by implementing rotational grazing whereby plants experience 

periodic defoliation in a relatively short time period (generally 1 month or less) followed by a period of adequate growing 

season rest from grazing for plants to recover. If properly implemented, this practice will increase herbaceous plant cover 

and litter at the expense of bare ground-increasing soil moisture and plant productivity.

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94. Conversely, reducing stocking rates without shortening the grazing period and lengthening the rest-recovery period does 

little to improve rangeland health, increases fire intensity, and will continue to harm some herbaceous plant species.

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95. SRCA agrees that included with fire is the threat of invasive species. Livestock grazing should be used to reduce fine fuels. 

Grazing is by far the cheapest and most effective way to minimize wildfires while maintaining and or creating healthy 

ecosystems. Herbicides, diesel and man hours are expensive. (Smith et al., 2012) (USDA, 2006)

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96. Avoid vegetation treatments that reduce the amount and height of sagebrush, especially those that use drastic means such 

as tractors and chemicals.

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97. Another significant management factor that BLM in the Great Basin should not use in the Sage Grouse Management Plan in 

the Great Basin is the height of grass. At the hearing where Sage Grouse biologist Peter S. Coates made a presentation he 

said that grass height in most the areas of the Great Basin would not be appropriate to use for a management guideline. The 

use of Grass height is important in those ecosystems where grass was the predominant cover available for Sage Grouse to 

nest in.

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98. Measures that the BLM has the power to enact that will have the greatest benefit to sage grouse numbers are likely 

maintaining or increasing their access to reliable water sources, reducing wildfire number and severity, and increasing new 

herbaceous growth and forb diversity. Livestock grazing promotes all these aims.

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99. We do not advise large prescribed fire in GSG or big game winter ranges in Wyoming big sagebrush, particularly at low 

elevations and precipitation (less than 10 inches annual precipitation). However, our observations have consistently shown 

that smaller (25-200Ha) openings created in large (>500Ha) expanses of mountain and Basin big sagebrush in excess of 25% 

canopy coverage and above 2000m in elevation are used as brood habitat by GSG, and (based on increased lek attendance, 

lek persistence, and new lek development) can increase GSG populations. We have successfully implemented cool season 

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C. Comments by Resource Planning Issue

C-1050 Greater Sage-Grouse LUPAs/EISs May 2012

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burns, chemical, mechanical treatments to thin brush and release herbaceous vegetation (Oanvir 2005). The overall effect 

is early seral openings in a sagebrush sea. Hunnicutt 1992 clearly showed that hens selected nest sites in homogeneous 

sagebrush patches at least 300m in diameter for nesting, but immediately moved broods to highly heterogeneous areas 

having an interspersion of sagebrush cover and grass-forb dominated feeding areas. Pronghorn populations (Aoude and 

Oanvir 2002) showed similar production and population increases.

100. Please remember these landscapes often provide essential habitat to multiple species-some of which require old-age 

sagebrush canopies and others requiring early seral conditions. A well-managed landscape is managed not to maximize 

value for anyone species (whether cattle or sage grouse) but rather maximizes overall value by 'optimizing', or maintaining 

viable habitat for multiple species (including wildlife and livestock, Oanvir et al 2005).

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101. Page 8-"Coordinate BMPs and vegetative objectives with NRCS for consistent application across jurisdictions where the 

BLM and NRCS have the greatest opportunities to benefit Greater Sage-Grouse, particularly as it applies to the NRCS's 

National Sage-Grouse Initiative." We concur with this policy.

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102. We have found that by implementing multi-pasture grazing systems, having 5-15 pastures per herd, large herds, large 

pastures, allowing adequate periods for plant recovery (generally 12 or more months) and providing season long rest to 

approXimately 20% of pastures annually we see increased upland and riparian herbaceous vegetation and decreased bare 

ground while maintaining a healthy brush component (Danvir 2002, Danvir et al 2005).

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103. The terms "habitat fragmentation" and "unfragmented habitats must be clearly defined in the EIS as well as how these terms 

related to disturbances (i.e. fire) and to rehabilitation and natural plant succession.

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104. The EIS must clearly define "large intact sagebrush communities" as it relates to plant succession, the potential for wildfire 

and suitability for sage grouse habitat.

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105. The EIS must address how the BLM and the USFS will manage vegetation types over time considering natural plant 

succession. It is the responsibility of the land management agencies to ensure the proper management of current and future 

habitat and vegetation status to ensure the maintenance and improvement of habitat and population numbers given the 

ever-changing status of plant communities.

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106. EIS alternatives should include programs such as incorporation no net habitat loss. A current survey habitat in a proposed 

project area would allow for classification according to established standards. The proposed action could demonstrate 

avoidance whenever possible and mitigate any loss through an established or approved restoration program.

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107. The EIS and alternatives must analyze documented trends in pinion and juniper (PJ) succession on rangelands and sage 

grouse habitat including proposed measures to reduce PJ aerial extent and future migration. The EIS must also evaluate the 

impacts such efforts may have on other species of concern

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108. The introduction of non-native annual grasses to the fragile ecosystems in the west have caused massive ecosystem

transformation. Western Juniper has also become invasive to areas that did not historically have it - due to occasional fire 

- and has degraded much of prime sage grouse habitat at higher elevations. Many of the ecosystems/habitat in the West are 

dependent on occasional fire, to maintain ecosystem functionality

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109. Use ecosystem functionality as the prime strategy for rangelands management, for sage grouse and associated species, 

including for domestic livestock.

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C. Comments by Resource Planning Issue

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110. Reduce and reclaim areas of large scale prime habitat changes caused by Western Juniper proliferation. All Both emc0314GB

111. The use of herbicides to kill sagebrush and rabbitbrush is unacceptable to us for many insects such as important pollinators 

and prey base species, mammals, reptiles, and birds use these areas throughout the year.

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112. We believe Juniper "treatment" projects should be carefully planned because high numbers of sensitive bird species are 

often associated with juniper habitat. We believe the real problem is that livestock permittees and agencies often use 

juniper "invasion" as an excuse to open up land for grazing. If not done in a thoughtful manner, juniper removal may cause 

undesirable and, in most cases, irreversible impacts to a stable area by promoting the establishment of invasive grasses and 

weeds. Juniper "treatment" accomplished by machinery or fire, results in erosion, drying out and compaction of soil, 

higher ground-level temperatures, lack of shade and protection for wildlife. It exposes native plants and seeds (sometimes 

the only ones left in the area due to overgrazing) that sprout after snow or rain and are subsequently eaten and/or trampled 

by livestock. Many native plants, especially early forbs and grasses, are considered "dessert" by livestock and are the first to 

be utilized. The treatment areas are highly susceptible to invasion by weeds and grasses because of soil disturbance and 

higher temperatures, which create ideal conditions for germination and growth. This makes them susceptible to a vicious 

fire cycle that degrades the landscape. Fires, aided by higher fuel loads, blast through overgrazed and vulnerable mesic and 

riparian areas and create habitat suitable only for cheat grass, medusahead and halogeton etc.. We believe in most cases, 

livestock (overgrazing) are the reason for juniper invasion. Cows will not eat juniper (unless left to starve). However they 

will eat pretty much anything else. Left alone, with competition from native grasses and shrubs eliminated, juniper thrives. 

If the area was given ample time to stabilize, juniper projects done correctly, such as using a mosaic pattern, then juniper 

could be controlled in a way that would not be detrimental to Greater Sage-grouse or Juniper Titmice. We have the same 

concerns about sagebrush removal projects. The term "decadent" is often used as an excuse to chain, burn, spray, or Dixie 

harrow sagebrush to create more grazing opportunities.

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113. The goal of the conservation measures as indicated on page 6 of the NTT report is to "Maintain and/or increase 

sage-grouse abundance and distribution by conserving, enhancing, or restoring the sagebrush ecosystem upon which 

populations depend in cooperation with other conservation partners." There are a lot of concepts included in this goal that 

need clarification. For example, to increase sage-grouse abundance and distribution implies that other resource uses will be 

diminished and how will that decision be made? The sagebrush ecosystem is a disturbance based system in Nevada, where 

fire, floods, insect outbreaks, and drought have removed sagebrush from areas of the landscape for periods of time and 

perennial grasses and forbs dominate after the disturbance. This is followed by a period of time when grasses, forbs, and 

young shrubs are present, and as the shrubs increase in stature and abundance, the grasses and forbs decline until there is 

a sagebrush-dominated plant community, ready for the next disturbance. If "conserving, enhancing, or restoring the 

sagebrush ecosystem" means maintaining these various phases of the sagebrush community on the landscape, then many 

land uses can be accommodated. However, the report implies that only the sagebrush-dominated phase is important. I 

disagree and believe that a healthy ecosystem is one with many phases of the sagebrush ecosystem present on the 

landscape. This concept is much more in concert with the Ecological Site Descriptions and the State and Transition Models 

being developed by Natural Resource Conservation Service.

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C. Comments by Resource Planning Issue

C-1052 Greater Sage-Grouse LUPAs/EISs May 2012

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114. In addition, the list of "negative" aspects of herbivory does not recognize that many of these same conditions can be 

achieved in the absence of grazing. Plant dynamics of the various sagebrush ecological sites will result in shrub-dominated 

vegetation over time in the absence of disturbance. Therefore, the lateral cover necessary for nesting and the changes in 

sage-grouse habitat due to shrub-grass competitive dynamics create habitat conditions unfavorable to sage-grouse nesting, 

early brood habitat, and pre-laying habitat. While proper grazing management can be a beneficial tool, improper vegetation 

management can be a detriment to sage-grouse.

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115. The section on Treatments to Increase Forage for Livestock/Wild Ungulates, page 16 is very single-species oriented and 

does not uphold the principles of multiple-use management. The socio-economic impacts of these conservation measures 

should be analyzed in the EIS. In addition, many of the sagebrush ecological sites can only be maintained through periodic 

disturbance, releasing the perennial grasses and forbs before they become too scarce from competition with shrubs, and so 

scarce that non-native "invasive can establish on the site. Treatments of sagebrush are not always intended to .increase 

livestock forage, but are useful ways to maintain the integrity of the ecological site

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116. Our recommendations for management policies in sage-grouse habitat follow. Avoid sagebrush reduction/ treatments to 

increase forage in priority habitat and include plans to restore high-quality habitat in areas with invasive species.

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117. So called “habitat improvement” projects, such as mechanical sagebrush treatments and prescribed fire, can be detrimental 

to greater sage-grouse and other sagebrush obligate species. Scientifically defensible research is needed to determine 

which activities are beneficial. This information should be maintained in a single federal database.

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118. • IM 2012-043 o Designation of Preliminary Priority or Preliminary General Habitat Areas The IM defines preliminary 

priority habitat areas as those that have been identified as having the highest conservation value to maintaining sustainable

greater sage grouse populations, and include breeding, late brood-rearing and winter concentration areas. While the 1M 

states that these areas have been identified by BlM in coordination with state wildlife agencies, the public has had little or 

no input into the process of designating such areas. Furthermore, accurate maps that identify key habitat areas have not 

been provided. The January 10, 2012 Western Association of Fish and Wildlife Agencies habitat map, delineating these 

designated habitat areas, was used during the IM roll-out meetings at BlM offices. However, subsequent discussions with 

state and field office staff have determined that those delineations are already being significantly modified by state wildlife 

agencies. It is difficult for us to determine potential impacts or issues appropriate for scoping when the extent of the area 

is unknown. BlM must provide better maps identifying the designations as well as ensuring that designations are based on 

clear criteria and sound biological data. Many efforts to identify sage grouse habitat have incorporated "broad brush" 

analyses that do not appear to include adequate site specific field verification. For example, the mere presence of intact 

sagebrush habitat alone is not a sufficient indication of sage grouse habitat. Moreover, historic range is not an appropriate 

measure for identifying current sage grouse habitat or distribution. Some of the area currently mapped by the Nevada 

Department of Wildlife is occupied by cheatgrass and other non-native invasive annual species, pinyon-juniper woodlands, 

and salt desert shrub vegetation. These areas do not provide suitable sage grouse habitat, and thus do not warrant habitat 

designation. Accordingly, it is essential that any sage grouse habitat designations be based on clear criteria and sound 

biological data. Broad, over-inclusive geographic designations are inappropriate and may have substantial adverse effects on 

multiple use activities on federal lands while providing no benefits to the species. BlM should ensure that project 

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proponents have an opportunity to confirm the habitat designations based on site specific information at the time specific 

actions or projects are proposed. If site specific information (Le. the best scientific information available) demonstrates that 

previously designated habitat does not meet the criteria for general or priority habitat, then adjustments to those habitat 

boundaries and/or designations are appropriate and must be made by BlM without the need for a formal lMP or RMP 

amendment.

119. VI. BLM and USFS Must Evaluate a Reasonable Range of Alternatives In light ofthe different reasons for sage-grouse habitat 

decline from region to region, and the fact that there remains significant sagebrush habitat in Wyoming and Nevada, each 

sub-regional EIS should carefully evaluate a reasonable range of alternatives to the conservation measures and regulatory 

mechanisms proposed in the NTT Report. Some of the contemplated measures may not be necessary or effective in each 

region or sub-region. Examples of such alternatives include, but are not limited, to the following: E. The Improved Fuels 

Management and Fire Suppression Altemative The EIS should evaluate the impacts associated with more effective and 

better-funded fuels management measures and fire suppression measures when wild fires do occur. This is especially 

important for the ElS to be completed in the Great Basin Region, where wildfires are considered a primary factor in habitat 

fragmentation.

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120. In light of these statutory requirements, the BLM must consider the etfects of invasive species, such as cheatgrass, upon the 

ability to regenerate sagebrush after a fire or other disturbance. The BLM must analyze the effects of fire resistant species, 

such as kochia, upon the spread of wildfire, and the resultant protection of sagebrush.

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121. Climate change is projected to impact sagebrush habitats, and also to potentially impact sage-grouse survival and 

reproductive success. Despite this fact, climate change is not listed as a preliminary issue in the Notice of Intent for the 

greater sage-grouse planning process. This oversight has to be effectively remedied at the Draft EIS stage, the agency must 

include a comprehensive analysis of the predicted climate change impacts to sage-grouse and any proposed management 

regime must take into account the cumulative effect of climate change and other impacts and provide protections sufficient 

to recover and conserve the sage-grouse despite these threats. Climate change impacts that must be analyzed include, but 

are not limited to: · Increased temperature and increased precipitation allowing expansion of woody vegetation from 

higher elevations. · Increased temperature and decreased precipitation shifting the balance toward more drought-tolerant 

desert plants. · Alteration in fire regime from a warmer climate, which would be problematic for fire intolerant sagebrush.

· The spread of invasive annual grasses, such as cheatgrass, which have a very different growth form than the native bunch 

grasses and can lead to more severe fire. · Drought conditions, which have been shown to negatively impact nest success.

· West Nile virus, which may worsen with warmer summertime temperatures that speed the development of the virus 

within the vector mosquitoes.

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122. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: - The 

increase in the distribution and density of conifer woodlands is a significant threat to the sagebrush ecosystem.

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123. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: -

Site-adapted species of native plants are not available in the quantities needed to meet desired restoration program goals.

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124. Livestock grazing is considered the single most important influence on sagebrush habitats and fire regimes throughout the 

Intermountain West in the past 140 years (Knick et al. 2005: 68). Grazing is the most widespread use of sagebrush steppe 

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and almost all sagebrush habitat is managed for grazing (Connelly et al. 2004; Knick et al. 2003; Knick et al. 2011).6 

Livestock grazing disturbs the soil, removes native vegetation, and spreads invasive species in sagebrush steppe (Knick et al. 

2005). Cattle or sheep grazing in sage grouse nesting and brood-rearing habitat can negatively affect habitat quality; 

nutrition for gravid hens; clutch size; nesting success; and/or chick survival (Connelly and Braun 1997; Beck and Mitchell 

2000; Barnett and Crawford 1994; Coggins 1998; Aldridge and Brigham 2003). Livestock may directly compete with sage 

grouse for grasses, forbs and shrub species; trample vegetation and sage grouse nests; disturb individual birds and cause 

nest abandonment (Vallentine 1990; Pederson et al. 2003; Call and Maser 1985; Holloran and Anderson 2003; Coates 

2007).

125. The recovery of sagebrush “treatment” areas is further complicated by livestock grazing, which can hamper the 

establishment of native plants and spread the seeds of noxious weeds such as cheatgrass. Lambert (2005) recommended 

protecting re-seeded areas from livestock grazing for no less than 3 to 5 years. However, this standard is virtually never 

adhered to in practice in the West, where virtually every acre of public land falls within a grazing allotment.

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126. Finally, BLM needs to support efforts to improve rangelands by removing pi сand other undesirable brush. on juniper,

Pi сwetter sage brush sites has been part of the demise of summer sage on juniper encroachment on the upper elevation,

grouse habitat. This has been due primarily to the lack of fire on these wetter sites. The encroachment of these species has 

reduced prime sage brush habitat. Too often these projects are postponed.

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127. The use of prescribed fire to reduce fuels loads or enhance sage-grouse habitat must be addressed in the RMP 

amendments.

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128. The BLM should continue to encourage a wide range of vegetation management tools that have utility in the restoration or 

conservation of sage-grouse habitat. Taking a hands-off approach to vegetation management is usually counterproductive.

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129. In the semi-arid rangelands of the Great Basin, the unstable moisture occurrence results in drastic growth differences of 

many plant species. Along with the mmbinations of other various factors, this can and does strongly affect numerous animal 

species. Those species that can handle the severe up's and down of the Great Basin survive the best. Unfortunately the 

GSG does not handle those up's and downs well.

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130. Vegetation management. Issue: Past and current vegetation management has affected vegetation composition, height and 

cover to the detriment of sage-grouse. Issue: Past monitoring methods failed to establish baseline data for ecological site 

potential or habitat characteristics needed for sage-grouse. Issue: Current upland rangeland health assessment methods fail 

to include indicators required for sage-grouse habitat. Issue: Reference areas for upland ecological sites are too few or 

too small and as a result, dependent habitat assessments lack objectivity and verification.

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131. Conifer encroachment and recovery. Issue: Some native conifer species are encroaching on sagebrush steppe; other 

native conifers are reoccupying historic range. Both phenomenon affect sage-grouse, although management must address 

encroachment and recovery differently

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132. Federal agencies have historically treated sagebrush steppe to increase forage for livestock, which included seeding 

extensive areas with nonnative plants to support livestock production. More recently, land managers have employed 

various sagebrush treatment methods (e.g., prescribed fire, mechanical means such as Dixie Harrow, chemical applications, 

and all accompanied with seeding efforts) to attempt to create or enhance sage-grouse habitat, such as brood rearing 

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habitat. Unfortunately, there is a dearth of long-term, well-designed10 scientific studies that document whether these 

sagebrush treatments benefit nest success or fecundity. Vegetation management in sagebrush steppe is an area that 

requires additional, carefully planned research. Of the existing research, there are many cases where sagebrush treatments 

specifically done for sage-grouse have not produced intended results. For example, two and three years after sagebrush 

was mechanically treated and seeded to improve sage-grouse nesting and broodrearing habitat near Alton, Utah, the 

percentage of forbs/grass cover in the treatment areas were less than half of the percentage of cover in breeding habitat 

reference areas, and less than half of the percentage of shrub cover in reference areas (Frey 2010, presentation). In 

addition, the average forb/grass height was also twice as high in breeding reference areas than in the treated areas (Frey 

2010, presentation). Also during this period (2005-2007) sage grouse monitoring found that sage-grouse preferred the 

intact sagebrush stands to the treated areas (Frey and Heaton 2009, unpublished paper). BLM interim direction for 

sage-grouse management and planning (BLM Memo 2012-043) cites western Association of Fish and Wildlife Agencies 

(2009) as guidance for designing vegetation treatments in sagebrush steppe. WAFWA (2009: 1) states that “[i]n spite of 

considerable loss of functional sagebrush habitats from wildfire and other factors (e.g., energy development, agricultural 

conversion, and urban expansion), some natural resource professionals promote using different types of treatments to 

reduce sagebrush cover on remaining intact sagebrush habitats (Bunting et al. 1987, Wyoming Interagency Vegetation 

Committee 2002, Davies et al. 2008, McAdoo et al. unpublished report). These treatments include prescribed fire, 

mechanical alterations, herbicide applications and intensive, short-duration livestock grazing. Justification for these 

treatments have included the need to increase resiliency of sagebrush-grassland habitats to wildfire, improve forage for 

livestock grazing, diversify age-structure of sagebrush, reduce ‘decadent’ stands of big sagebrush, and enhance sage-grouse 

habitat (Wyoming Interagency Vegetation Committee 2002). We question the biological and ecological value of treatments 

that remove sagebrush in xeric sagebrush communities and are concerned about long-term negative impacts to 

sage-grouse.”

133. Some juniper (Juniperus spp.) and piñon (Pinus spp.) species have increased in abundance and/or expanded into sagebrush 

steppe, primarily at higher elevations (Miller et al. 2011). Since 1870, concurrent with the introduction of domestic 

livestock and the resultant exclusion of periodic fire, the occurrence of western juniper (Juniperus occidentalis 

occidentalis) in the sagebrush steppe has increased approximately ten-fold in Oregon, northeastern California,

northwestern Nevada, Idaho and Washington (Miller et al. 2005). Approximately 12 percent of the current distribution of 

sagebrush steppe is expected to be replaced, primarily by expansion of woody vegetation, with each 1° C increase in 

temperature (Miller et al. 2011). Sage-grouse habitat will be reduced as cheatgrass spreads at lower elevations and woody 

species eliminate sage-grouse habitat at higher elevations in sagebrush steppe (Miller et al. 2011). Natural Resources 

Conservation Service has recognized conifer encroachment as a threat to sage-grouse (e.g., NRCS 2009). The NTT report 

makes no specific prescriptions for addressing conifer encroachment

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134. Some juniper and piñon species are not encroaching on sagebrush steppe, but reoccupying areas from which they were 

removed by miners and settlers. Piñon-juniper were a source of fuel and fiber for communities, ranching and mining in 

some parts of the West in the Nineteenth Century Lanner 1981). With the end of widespread logging of these species, 

these piñon and juniper are returning to much of their historic distribution (Lanner 1981, Catlin et al. 2011, unpublished 

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research)

135. The Interim Management 1M provides for the use of Ecological Site Descriptions (ESDs) when designing vegetation 

treatments. Although in theory ESDs are potentially useful in guiding management decisions, ESDs are incomplete or 

unavailable in several states and therefore may be limiting in assessing or guiding management decisions. In addition, 

enhancing native plant communities to the native shrub reference state is highly impracticable and partly dependent on the 

current land use in that plant community. These concepts are extremely theoretical and very challenging to implement.

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136. BLM's RMP revisions should not require use of Ecological Site Descriptions but should provide flexibility to use ESDs or 

other appropriate metrics to evaluate the success of vegetation treatments and reclamation efforts. Although ESDs can be 

useful to provide a reference for vegetation treatments, treatment objectives should be designed to meet rangeland health 

standards, management decisions, the objectives of the land use plan, and site-specific conditions or limitations.

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137. The EIS and its alternatives should avoid requirements for habitat mitigation and maintenance in perpetuity. It must be 

recognized that vegetation types are constantly evolving and changing. Mitigation in perpetuity is inappropriate and fails to

recognize the realities and dynamic nature of vegetation communities and nature in general.

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138. Now BLM in this sage-grouse EIS is stating that it is indeed going to address allocations. As part of the process of amending 

the Land Use Plans in this EIS process, BLM must fully consider causal factors of weed invasions and fuels problems like 

grazing and the plethora of BLM’s own treatments in making these allocations. It must change allocations, like livestock 

grazing, that promote weeds and flashy fine fuels like cheatgrass. BLM must also adopt an integrated weed management 

strategy, rather than the current Spray and Walk Away approach that ignores causes of weeds and fails to provide 

integrated weed/invasive species management. BLM treatment relies overwhelmingly on futile use of expensive chemical 

herbicides.

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139. The primary, and often only, annual barometer of livestock use monitored by BLM is utilization. Utilization is based on 

aboveground biomass of grass plants, i.e. weight of the plant material and not height. Most of the weight of a native 

bunchgrass grass plant is towards the base of the plant. So 40% utilization often means that a plant that stands 12 inches tall 

can be grazed down to 3-4 inches in height and still be measured as having only 40% use. This height is too low to provide 

the necessary residual screening cover to conceal sage-grouse nests from visual and scent predators. Plus utilization is 

averaged across the landscape, so 40% average utilization means many plants receive much greater use. Those higher use 

levels are harmful to the crown of the bunchgrass plant, which is exposed to winter freezing and baking in hot sun. Harms 

to the plant from such use levels may be even worse during the active and critical growing period for the plant. Changes in 

species composition occur over time, and larger or grazing-sensitive grasses are depleted. Sheridan CEQ 1986, Mack and 

Thompson (1982), Anderson (1991), Jarbidge AMS (2007), U.S. Forest Service Utilization Gauge, Anderson 1991 BLM 

Technical Bulletin. In lands that have become depleted by historical grazing, and then are faced with continued annual

chronic grazing disturbance, many larger-statured grasses are missing. So the plant community composition has been 

altered and depleted - with smaller statured increaser species replacing larger grasses (a symptom of desertification, see 

Sheridan CEQ 1986). Yet BLM often overlooks the utilization of the smaller grasses such as small native bluegrasses Poa 

that greens up with fall rains, and measures use only on scattered remnant larger grasses. Plus, BLM typically averages 

utilization over 40 or 50 grass plants. This means that if the average utilization at a site is recorded as 40% - some plants are 

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likely grazed to levels of 70% or more, which is quite damaging and can lead to injury, weakening/lack of vigor or death of 

the plant.

140. BLM also practices forage mining through extending facilities and salt and supplements. Areas closer to watering sites, 

flatter terrain, or other areas frequented by livestock become depleted. But rather than cutting livestock numbers, BLM has 

instead incrementally extended water systems and thus extended degradation of sagebrush upland sites, built more fences 

to enable more intensive use in ncreasingly depleted lands, and also killed sagebrush and trees to try to produce more 

forage and maximize continued livestock grazing numbers. This has enabled more intensive livestock disturbance of 

remnant better condition areas of the sagebrush uplands across public lands. Meanwhile, there is minimal, if any, 

improvement in the depleted sites. Livestock facilities have intensified use in many areas in recent decades, while the areas

already highly impacted and depleted have not recovered. These sites are vulnerable to, and often are undergoing, weed 

invasions. Thus, this system of keeping as many cattle/sheep on the land as possible without cutting AUMs has resulted in 

incremental depletion equivalent to forage mining. Along with forage mining goes the need for ever more treatments. BLM 

has also aggressively manipulated and treated native communities rather than allowing passive restoration of damaged 

understories to occur. Rachel Carson in Silent Spring described the war on sagebrush that began in the late 1950s, and 

continued in the open for livestock forage for decades. This War continues to the present, papered over with misleading 

terms like fuels treatment, treatment of decadent sagebrush, habitat improvement project, but the end result is the same.

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141. Many newer land use plans have quite weak and uncertain goals, objectives, and provisions related to wildlife. Some of the 

newer BLM Land Use Plans have alarming provisions that are resulting in significant degradation of sagebrush and 

destruction of pinyon-juniper and other forested vegetation (including in areas of little importance to sage-grouse. Newer 

Ely BLM and Oregon Land Use Plans plans rely on large-scale manipulation and destruction of mature and old growth 

sagebrush communities - based on outdated claims of fire return/disturbance intervals and state and transition modeling 

that is used to justify removing sagebrush to generate flammable grass that then dries out quickly, becomes invaded by 

cheatgrass, and more readily carries frequent fires. Or they rely on use of fire or heavy equipment to treat trees. This 

results in destroying the sagebrush as well as making sites prone to cheatgrass and other weeds.

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142. Passive restoration includes reducing or removing disturbances to allow natural ecological processes to return by stopping 

activities that cause degradation or prevent recovery. Some active restoration will also be required in some sites. 

However, active restoration should rely on removal of disturbances, intrusions, and harmful developments that degrade 

and fragment habitats. Replanting with native species (local native ecotypes) in areas where sagebrush has been eliminated 

or greatly reduced must be a key component of active restoration.

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143. We are greatly concerned that BLM will conduct excessive prescribed fire disturbance in WSAs under the guise of sage 

grouse habitat or "fuels." "Treatments" and artificial human manipulation of wild lands must be constrained. Why is there 

no mention of Forest roadless lands? The same must be applied to identified USFS roadless areas, Wilderness, and other 

unroaded lands. Plus FWS and other lands, as well - for example, the WSAs on Sheldon.

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144. In practice, "desired future condition" has been code in agency speak for proposals that alter, disturb and destroy sagebrush 

or other woody vegetation in order to promote grass (often exotic) for livestock forage projects. The desired future 

condition should be intact native sagebrush vegetation communities.

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145. Agencies must also consider the threat of habitat loss and amount of risk of irreversible weed invasion and habitat 

fragmentation associated with treatment disturbance, and must fully consider the uncertainty that any substantial positive 

recovery may occur, and its pace. If agencies propose to kill, alter, thin, destroy mature of old growth sagebrush 

communities in vegetation manipulation projects, then how long will it take for a plant community with similar 

characteristics to recover? How does continued grazing disturbance slow, retard, or alter recovery for decades or 

centuries to come? How does continued grazing disturbance promote cheatgrass or other weeds, effectively truncating 

succession so that hoped-for recovery does not happen? Examples: Trampling seedlings, browsing/breakage of sagebrush 

cover, alteration of understory grasses and forbs, disruption of microbiotic crusts, etc. Current science-based recovery 

intervals must be used. So many of the existing projects including those of the past decade and continuing up to the present 

have been conducted based on false and now disprove claims of short historical disturbance intervals, and short claimed 

recovery intervals that had been erroneously promoted by Winward, Miller, and others with a range background. See 

Welch and Criddle (2003), Baker (2006), Baker Chapter in Knick and Connelly (2009). How many treatments exhibit much 

slower recovery of sagebrush, forb, microbiotic crust, and other community components than predicted?

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146. The reclamation actions are minimal, and given the time frame required for recovery of sagebrush, any recovery in the face 

of continued agency-sanctioned livestock grazing/trampling, weed infestations, climate change, etc. may not even be

possible at all (see Baker Chapter in Knick and Connelly 2009 describing long time frames). The long time frame for any 

recovery must be considered before effects can be determined. BLM cannot rely on "desired plant community" in 

reclamation. BLM typically allows non-natives and aggressive cultivars of natives seeded for livestock forage to be the 

"desired" veg in rehab (ostensibly to ward off weeds). but in reality because such species provide livestock forage and may 

require minimal rest to become established - in comparison to sensitive native species. BLM must analyze adverse impacts 

of using exotics and/or cultivars - rather than local ecotypes of naturally occurring species. This all appears aimed at 

maximizing forage - rather than ecological compatibility. "Irrigation" to establish vegetation is out of place in arid wild 

lands. Use local native ecotypes, and require re-seeding until it is successful. Remove livestock disturbance back to any 

existing pasture fences.

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147. There must be full and detailed analysis of adverse impacts of the expensive and often polluting and/or hazardous herbicides 

and all their components and breakdown products that BLM increasingly relies on. BLM must provide new and updated 

analysis of its herbicide use, as significant new information an adverse effects of herbicides has emerged. Plus BLM has no 

integrated weed management plan at all - the Weed EIS merely covered herbicide use. And refused to examine or limit 

livestock, roading, or other disturbances or address causal factors in any way.

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148. These provisions are weak and toothless. "Where appropriate ..design fuels projects to protect sage brush 

ecosystems..This leaves the door wide open to abuse by agency range staffers and managers to do whatever they want. 

Restore native plants and create patters[sic] which must benefit sage grouse."This enables further wanton destruction of 

sagebrush habitats under the guise of creating "patterns." In nearly all instances, the sagebrush landscape has a complexity 

of natural patterns - as well as many artificial human-caused patterns already. What patterns have been shown to 

significantly benefit sage-grouse -or pygmy rabbit? There is often natural heterogeneity in sagebrush landscapes that 

provides a complex natural mosaic. Plant communities arbitrarily deemed "decadent" by agencies have diverse age classes. 

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Grassier areas dry out quickly, and appear to be promoting many frequent fires both immense and small. Areas of grass and 

seedings are now burning at great frequency in sites across southern Idaho. For example: The 2010 300,000 acres Long 

Butte fire in the Jarbidge. See WWP Long Butte fire Appeal, describing fire flashing across 300,00 acres of exotic and 

post-fire seedings with hardly any sagebrush present - in 2-3 days! BLM must fully investigate the role of crested wheatgrass 

and its post-fire rehab seedings in promoting fire frequency and greatly altered fire cycles.

149. BLM is not going to be able to prevent large wildfire. Fuelbreaks will not do that, and often promote weeds that fuel 

frequent fires. And if BLM attempts to engineer a massive series of fuelbreaks, it will only further fragment the sagebrush 

ecosystem and hasten its demise. So as an alternative, BLM must manage lands to be in the best possible condition using 

native species. That way, if an area burns, it is naturally more resilient and better able to recover. Livestock grazing must be 

removed if recovery is to be effective, and to occur without significant risk of cheatgrass and other weeds. Removal of 

grazing also hastens the speed of recovery. Thus, passive restoration -both before and after fires - is essential to resiliency, 

and reducing and minimizing the adverse effects of fire on wild land sagebrush habitats. In some instances, active restoration 

(re-seeding with local native ecotypes) may be necessary. But this must be followed by long-term removal of livestock 

grazing disturbance.

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150. Treated lands continue to suffer intensive grazing or other disturbances, thus retarding or preventing altogether the 

recovery of sagebrush habitat components. "Mitigation" funds for new projects destroying sagebrush habitat (such as the 

wind farms, transmission lines, gas pipelines) may be used to deforest large areas, including sites. All such projects (past and 

continuing/foreseeable) must be evaluated honestly. It cannot be claimed that destruction of important sagebrush habitats 

can somehow be mitigated by cutting, chaining, or otherwise altering tree habitats until there is understanding and analysis 

of the ecological value of forests. Projects are being claimed to be sage-grouse projects in areas of minimal importance to 

sage-grouse. Funds are being diverted to these. Plus, if such projects make formerly forested areas more fire-prone -

through creating hotter, drier, windier sites, this is likely to exacerbate fire risks to adjacent or interspersed sagebrush 

habitats. Deforestation may affect local weather patterns, resulting in hotter, drier, weed-prone, harsher, windier sites 

more prone to frequent fires.

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151. Did IDFG datasets or BLM exclude leks that have since been lost, and thus underplay importance of habitats recently lost 

to fire like Murphy. See page 4. Makela and Majors tried to identify patterns of habitat and non-habitat using burn severity. 

They assumed areas of low burn severity maintained largely the same habitat as before the burn. But burn severity says 

nothing about the presence of sagebrush, and there is no evidence that sufficient sagebrush may remain in areas of low burn 

severity. Burn severity may also depend on the characteristics of the vegetation that was present pre-burn. In fact, it is our 

observations in some areas of the Jarbidge and elsewhere that areas of low burn severity typically had reduced or limited

sagebrush or other woody shrub structure over substantial areas pre-burn. This means that even if there are islands of 

unburned vegetation left in ow severity areas in a burn, the vegetation that is present may be primarily grass, or sparse 

shrubs not suitable for providing habitat essentials. It is unacceptable to map low severity burns as sagebrush habitat 

without ground-truthing. Because after all “low severity” still means the sagebrush burned, and is likely not providing 

sagebrush habitat essentials for sagegrouse. This is not to downplay the importance of any remaining unburned islands of 

sagebrush – but claiming that all of these areas are comprised of sagebrush helps agencies mask the severity of habitat loss 

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and fragmentation that has occurred. We find it very hard to believe that BLM did not have quite adequate veg data 

available, and/or did not make an effort to obtain, current high quality current information on sagebrush cover in burned 

areas so that a valid estimate of the remaining sagebrush within burn perimeters could be determined. In fact, it is our 

experience with the Murphy and other wildfires, that BLM uses a flush of fire funds associated with wildfires to immediately 

obtain detailed information about sagebrush persistence – often down to 5 to 10 acre polygons, or to even greater 

accuracy. Why wasn’t this information used? Why didn’t BLM collect at least current data on vegetation cover for this 

report that is now being used to segregate and doom some habitats? BLM claims that “due to our limited ability to 

effectively characterize “burn severity” in shrub systems, it is likely COH (Currently Occupied Habitat) in low severity is 

over-estimated”. There is no valid reason for BLM not obtaining high quality data, especially now that this report and its 

various models are being used to discard habitats. This lack of accurate information adds to the uncertainty of heaping 

modeling exercise upon modeling exercise to try to guess at the slice of landscape one can sacrifice and still have 

sage-grouse be present, and the importance of particular lands to a population. Unless BLM understands how little habitat 

it has left, it can’t understand how imperative protection and restoration are, or how it can possibly “sustain” habitats.

152. Conserving the Greater Sage 

habitat. And Sage ‐bru 

management.

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153. The sagebrush regions of the Great Basin and Rocky Mountain corridor are part of our great heritage as Westerners and 

Americans, still ‐vas 

habitat has been drastically impacted by invasive species such as cheatgrass, frequently exploitative use by grazing and 

mineral interests, and shortfalls in regulation and enforcement.

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154. In fact, as a scientist ‐cted in the sage botanist I have plant colle 

lost because of indiscriminate cattle ranching. Valuable plants and habitat as a whole must be protected so that we don't 

lose the biodiversity we have and become poorer in the process

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155. The effort for these birds should also be seen in a larger context of restoring the sagebush steppe habitat that has been 

hammered by over grazing, vehicle use, and other impacts. I ask you to manage these lands for ecosystem health and be 

more aggressive about land conservation.

All Both fld0003rm 

fld0003gb

156. Avoid vegetation treatments that reduce the amount and height of sagebrush, especially those that use drastic means such 

as tractors and chemicals

All Both flf0000gb 

flf0000rm

157. I urge you to consider consolidated plan ammendments that will: reduce livestock grazing in priority habitat and potential 

recovery areas to restore native plants that the sage grouse depend upon;

All Both flg0000gb 

flg0000rm

158. I urge you to consider consoliddated plan ammendments that would: avoid vegetation treatments that reduce the amount 

and height of sagebrush, especially those that use drastic means such as tractors and chemicals; and

All Both flg0000gb 

flg0000rm

159. Any EIS or SEIS must also explicitly recognize the following points:The extensive encroachment of pinion-juniper into 

sagebrush communities, coupled with vast expanses of decadent single aged sagebrush communities, has drastically 

decreased productive habitat for nesting and brood rearing sites for sage-grouse throughout the Great Basin and much of 

the West.

All Both fli0000gb
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1061

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

160. The extensive encroachment of pinyon-juniper into sagebrush communities, coupled with vast expanses of decadent single 

aged sagebrush communities, has drastically decreased productive habitat for nesting and brood rearing sites for 

sage-grouse throughout the Great Basin and much of the West. The proposed range-wide guidelines do not recognize the 

variability of issues across the west and do not focus on or prioritize specific issues at the needed scale.

All Both flj0000GB

161. The extensive encroachment of pinion Ѓof decadent single aged ]juniper into sagebrush 

sagebrush communities has drastically decreased productive habitat for nesting and brood rearing sites for greater 

sage Ѓt the Great Basin and much of ]grouse throughou the West. The proposed range 

the variability of issues across the west and do not focus on or prioritize specific issues at the needed scale.

All Both flj0002gb

162. 6) The NOI is silent on insuring that only allocalive andlor prescriptive standards (conservation measures to be imposed for 

any particul.tlr usc, vvill be predicaLed upon the existing vegetation and/or be within the ecological potential of a site. For 

example, BLM should not impose grazing restrictions based on herbaceous cover needed for nesting when there is not any 

existing sagebrush, which is also needed for nesting, within the area in questions. Also, BLM cannot mandate a particular 

residual grass cover height if the existing grasses do not have the potential to grow to the prescribed height and/or the 

prescribed heights are 110t within the ecological potential of the area in question.

All BLM fx0011gb

163. We have observed that well-rnanaged livestock grazing is an effective and sustairrable method for combating several of the 

most significant threats to sage grouse habitat including fuels reduction to mirrimize wild fires and to prevent or rlow 

invasive species and conifer proliferation. While the ESA does not provide for the cost of a mitigation strategy to preclude 

its implementation, funding to implement strategie,s is none the less rraturally limited. Our continued ability to serve a 

broad spectrum of multiple-use industries is crucial to maintaining their ability to provide beneficial habitat managerflent 

and their financial viability to implement appropriate mitigation ffieasure5. Mininrizing wild fires also protects our 

infrastructure from damage and reduces our need to mobilize drews and equipment to rehuild power lines irt areas which 

may be sage grouse habitat.

All Both fxc0006GB

164. Sound scientific research indicates that grazirrg is beneficial to the Ereater sage-grouse and other flora and fauna in multiple 

ways. Grazing reduces the instances and severity of wildfires" (Launchbaugh er al.2007). It improves greater sage-grouse 

habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et aI.1994, Evans 1996). [t has 

also been used to control invasive weeds (Olson and Lacey 1994, Walker et at.1994).

All Both fxc0006GB

165. Each potential vegetation state in Ecological Sitc Descl1ptions should include a rating of suitability for sage grouse habitat 

during each season, similar to Cagney et aL (2010).

All BLM fxc0011gb

166. Vegetation and land tTeatments must include pre~ and post-treatment monitoring of both vegetation and sage grouse 

populations, These data are needed to determine the elTects of treatments, evaluatc their Success in meeting 

l11<ll1agement goals, and improve suhsequent treatments and managcment decisions

All BLM fxc0011gb

167. Ecological Site Descriptions are based on Range Site data, which provide production by specics (lhs/a.cre). However, land 

managers monitor vegetation using cover measurements. Ecological Site Descriptions must also include cover data.

All BLM fxc0011gb

168. It has also been shown that increased use of meadows and riparian areas in mid-to late summer is common as herbaceous 

vegetation in upland habitat becomes desiccated. Potential for competition with Sage-Grouse young may be in proportion 

to the extent to which cattle select mesic/moist sites that are preferred foraging areas. Young birds seek out insects and 

All Both rmc0024GB
C. Comments by Resource Planning Issue

C-1062 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

succulent forbs in these habitats. Although the adult diet switches to forbs and insects in addition to sagebrush, developing 

young depend heavily upon insects for food. These habitats are critical brood-rearing and summer use areas in regions with 

low annual rainfall and during drought years.

169. Protect sage grouse spring, summer and fall ranges during periods of drought. Drought alone has been identi ied as a major 

factor contributing to the range-wide decline of sage grouse (Connelly and Braun 1997). Design adaptive management 

strategies to protect against the cumulative effects of grazing use on sage grouse forage and cover during drought. Livestock 

grazing of sagebrush ranges during years of unusually low precipitation and poor plant growth will cause an earlier than 

normal removal of grasses and forbs. This can have a serious impact on grouse dependent on forbs in that locality. Results 

suggest the timing and amount of moisture received were important to nest success...cool season grass growth during the 

preceding year (i.e., available as residual grass to nesting females) appeared to be important for overall greater sage grouse 

nesting success. The drought indicators from the National Climatic Data Center can give long term percent of normal 

precipitation forecasts that give forward looking projections of one, three, six and twelve months. Such information is 

critical to manage for sage grouse. The effects of low precipitation and drought are difficult for all wildlife and if grazing 

livestock are allowed in sage grouse habitat, the negative effects to sage grouse are well known. stocking at near-normal 

levels during periods of moderate to severe drought is probably the greatest cause of rangeland deterioration. Reduced 

stocking rates during drought, and for some time after drought, are necessary to minimize damage and hasten recovery of 

perennial vegetation.

All Both rmc0024GB

170. Have quantifiable data collected that show there is enough herbaceous cover (at least 18cm under and around sagebrush. 

This cover is to be a condition of grazing on public land.

All Both rmc0024GB

171. Use clear definitions of residual plant cover setting the standard by individual situation rather than one-size fits all for 

nesting habitat.

All Both rmc0032GB

172. In some areas, the establishment of pinyon juniper in sagebrush areas is a natural progression. Is it right or natural for public 

land managers to restrict the establishment of pinyon juniper, a native species?

All Both rmc0035GB

173. If pinyon juniper is restricted, will it later have a long term impact on other species (e.g., restricting raptor nesting habitat 

or reducing foraging lands?). The conservation of one species (e.g., sage grouse) should not have an impact on another 

species (e.g., raptors). These issues should be analyzed in the proposed EIS.

All Both rmc0035GB

174. How many AECS include areas where Juniper Encroachment exists and how much acreage is now proposed for treatment 

in these areas?

All Both rmc0036GB

175. What has been the actual cost ofthe SCS Juniper Management program in Oregon since 2002; and how many acres of 

Juniper have been treated on public and private land? What is the actual average cost/acre of the Juniper treatment in 

Oregon since 2002?

All Both rmc0036GB

176. Excessive grazing in particular has dramatically altered the vegetation community of semi-arid habitats through the Great 

Basin, for very little economic value in the forage utilized, representing a gross failure by the BLM to roughly balance the 

marginal values of competing uses. As a former resident of Utah and New Mexico, I was astounded by the willingness of the 

BLM to strip vast areas of desert, sagebrush, and semi-arid grassland of their very thin vegetation cover for an extremely 

meager biomass volume of livestock feed, supplementing the diet of an extremely small number of cattle for a 

All Both rmc0037RM, 

rmc0070GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1063

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

correspondingly minute number of ranchers. If the BLM is to uphold its mandate to provide an equitable and reasonable 

balance of values to the American people, it must protect these precious ecosystems and the Sage Grouse that lives among 

them, not strip them for the piddling bit of livestock-palatable biomass that provides their physical scaffolding.

177. Many permittees have voluntarily implemented adaptive grazing management strategies to encourage Sage-grouse 

Conservation on their allotments and private lands, and many of the recent permit renewals have included such measures. 

The Board requests that the BLM make every effort to work collaboratively with permittees to recognize and use grazing 

as a tool to enhance Sage-grouse conservation. For example, the use of grazing to reduce fine fuel loads and noxious species 

could greatly enhance efforts related to "integrated vegetation management" and "wildfire suppression and fuels 

management." Also, prescribed grazing can be used effectively to improve or enhance Sage-grouse habitat as noted in the 

Report.

All Both rmc0050GB

178. The Board is supportive of "implementing management actions after land health and habitat evaluations." However, 

managing" ... for vegetation composition and structure consistent with ecological site potential and within the reference 

state to achieve sage-grouse seasonal habitat objectives" is not practical. Historic management practices and landscape 

alterations, coupled with the introduction of noxious weeds and catastrophic wildfire have effectively eliminated the

"reference state" condition. The focus should be on maintaining vegetative resilience and resistance by maintaining critical 

ecological processes identified by the reference state, and avoiding the crossing of ecological thresholds. Every effort 

should be made to achieve this including the utilization of the best available indigenous science and knowledge combined 

with the use of all management tools, including grazing, herbicides, mechanical treatments, and nonnative adapted plant 

materials.

All Both rmc0050GB

179. A study needs to be completed which will confirm or discredit those advocating the use of livestock for the purpose of 

preventing plant stagnation or opening up canape cover for the benefit of wildlife.

All Both rmc0054GB

180. Before new policy is adopted for the management of sage grouse, studies need to be completed which will determine for 

certain whether leaving large amounts of standing grass within management areas is detrimental to sage grouse or not.

All Both rmc0054GB

181. Sage Grouse survival depends on some degree of removal of vegetative material. Green shoots that are both palatable and 

nutritious are necessary for a portion of the year. Survival also depends on sufficient habitat to nest in and sufficient habitat 

to survive the winter. Managed grazing by domestic cattle and sheep has provided these needs.

All Both rmc0057GB

182. The Meeker/White River and Parachute Piceance/Roan populations (Colorado Plateau MZ) are in the Uintah-Piceance 

geologic basin. These populations are small and isolated, and are threatened by demographic, genetic and environmental 

stochasticity due to small size and isolation. In addition, these populations are threatened by a suite of deterministic threats, 

including: housing and energy development, predation, disease, and conifer invasion. Based on projected habitat impacts 

(particularly energy development) under current management prescriptions, the FWS believes that all of the populations in 

the Colorado Plateau MZ will be reduced in size and isolated in the future.

CO BLM emc0070RM

183. The BLM should consider a ‘conservation alternative’ that: - Includes conservation measures recommended by the NTT 

Report, with improvements, including, but not limited to the following: o Avoid sagebrush reduction/ treatments to 

increase livestock or big game forage in priority habitat and include plans to restore high-quality habitat in areas with 

invasive species. o Implement range management practices outlined by the NTT, with addition of further conservation 

CO BLM emc0070RM
C. Comments by Resource Planning Issue

C-1064 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

measures, including avoiding new range and water developments that negatively impact sage-grouse and applying the 3% 

disturbance cap to certain range developments. o Design fuel treatments to protect existing sagebrush ecosystems 

(including avoiding such treatments where they will harm sagebrush ecosystems) and prioritize fire suppression to 

conserve the highest quality habitat. o Ensure that disturbance or uses that are permitted adjacent to priority habitat 

don’t negatively impact sage-grouse populations in priority habitat,31 thus negating the value of designated priority habitats. 

Include small or isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority 

habitat, and protect and enhance such populations with science-based prescriptions. - Combines this with designations of 

a subset of priority habitat as Areas of Critical Environmental Concern that receive a higher level of protection than that 

recommended by the NTT.

184. CPW recommends that the USFS work with allotment permittees to address any identified grazing management issues 

sage-grouse habitat as well as provide for deferment when vegetation restoration projects are in the early stages of

establishment.

CO USFS emc0072RM

185. (One of the most important NTT recommendations for Routt NF) "Do not reduce sagebrush canopy cover to less than 

15% ". Unless a fuels management objective requires additional reduction in sagebrush cover to meet strategic protection 

of priority sage‐grouse habitat and conserve habitat quality for the species." Id. at 26.

CO USFS emc0175RM

186. iv. The BLM and FS should analyze an alternative that provides more protection than that afforded by implementation of the 

National Technical Team’s Recommendations. The BLM and FS should consider an alternative that: - Includes 

conservation measures recommended by the NTT Report. - Combines this with designations of a subset of priority 

habitat as Areas of Critical Environmental Concern that receive a higher level of protection than that recommended by the 

NTT. - Incorporates improvements to the NTT’s recommendations, including the following: o Avoid sagebrush 

reduction/ treatments to increase livestock or big game forage in priority habitat and include plans to restore high-quality 

habitat in areas with invasive species. o Implement range management practices outlined by the NTT, with improvements,

including avoiding new range and water developments that negatively impact sage-grouse and applying the 3% disturbance 

cap to certain range developments. o Design fuel treatments to protect existing sagebrush ecosystems (including avoiding 

such treatments where they will harm sagebrush ecosystems) and prioritize fire suppression to conserve the highest quality 

habitat. o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t negatively impact 

sage-grouse populations in priority habitat,10 thus negating the value of designated priority habitats. o Include small or 

isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority habitat, and protect 

and enhance such populations with science-based prescriptions.

East Both emc0089RM

187. So called "habitat improvement" projects, such as mechanical sagebrush treatments and prescribed fire, can be detrimental 

to greater sage-grouse and other sagebrush obligate species. Scientifically defensible research is needed to determine 

which activities are beneficial. This information should be maintained in a single federal database.

East Both emc0089RM

188. Employ Best Practices for Juniper Management: BLM should identify a clear benefit to sage-grouse and a restoration plan 

with quantifiable objectives before practicing juniper removal. Planning should include careful post-removal management to 

prevent invasion by weeds and to establish a native sagebrush community that will support sage-grouse.

GB Both emc0355GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1065

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

189. Employ Restoration Planning: Resource management plans should incorporate alternatives that focus on restoring and 

maintaining native sagebrush and bunchgrass communities necessary for sage-grouse nesting and brooding.

GB Both emc0355GB

190. Management of wild and prescribed fires is considered an important issue in maintaining vital sagebrush habitat (Crawford 

et al., 2004).25 Historically, fire was the primary natural disturbance in sagebrush dominated ecosystems where 

sage-grouse evolved (Ibid.). The suppression of fire is believed to have changed historic sagebrush systems, encouraged the

spread of invasive vegetation, and contributed to the expansion of Western Juniper (Juniperus occidentalis)(Miller and 

Rose, 1999).26 Western Juniper expansion has changed historic sagebrush steppe habitat to predominately juniper 

woodland in many areas of the Great Basin, primarily in Oregon (Rowland, et al. 2010). Since 1930, juniper woodlands in 

Eastern Oregon expanded from 600,000 ha to over 2.6 million ha, resulting in fragmentation and loss of sagebrush habitat 

(Ibid.). As a result of juniper expansion, BLM has begun to take on projects to control the spread of woodlands into historic 

sagebrush systems. Availability of sagebrush at local and landscape scales is a requirement for Greater sage-grouse 

persistence (Johnson et al., 2009). All juniper treatments (including manual removal and prescribed fire) should be 

undertaken to minimize the spread of invasives, retain the maximum amount of sagebrush and associated native forbs and 

grasses. A few best practices, which have been used by BLM in Oregon to manage juniper through prescribed burns, 

include: 27 - Resting treated areas from grazing for a minimum of two grazing seasons - Closely monitoring grazing 

impacts after livestock are returned to allotments - Scheduling treatments to avoid breeding and nesting periods We 

encourage BLM to incorporate best practices and ensure that all steps are taken after burns for native vegetation to return. 

In addition, we recommend a vegetation monitoring program be implemented which includes control plots to exclude 

livestock grazing so that additional best practices can be established in a scientifically defensible manner. Habitat 

improvement projects frequently lack rigorous monitoring and evaluation plans, which undermines the ability of land 

managers and the public to quantify the benefits of management actions (Whisenant, 1999). Summary: BLM should 

identify a clear benefit to sage-grouse and a restoration plan with quantifiable objectives before practicing juniper removal. 

Planning should include careful post-removal management to prevent invasion by weeds and to establish a native sagebrush

community that will support sage-grouse.

GB Both emc0355GB

191. It is important that vegetative seeding facilitated by BLM does not harm sage-grouse habitat. According to the Technical 

Team, BLM should “Evaluate the role of existing seedings that are currently composed of primarily introduced perennial 

grasses in and adjacent to priority sage‐grouse habitats to determine if they should be restored to sagebrush or habitat of 

higher quality for sage‐grouse.” (Page 17) Summary: Resource management plans should incorporate alternatives that 

focus on restoring and maintaining native sagebrush and bunchgrass communities necessary for sage-grouse nesting and 

brooding.

GB Both emc0355GB

192. The BLM needs to be careful about using the term "dominance or dominated" when discussing sagebrush abundance or 

presence on the landscape. For example, on Page 6 of the December 21, 2011 report about National Greater Sage-Grouse 

Conservation Measures, the language infers that sagebrush dominated sites best meet the needs of sage-grouse. We urge 

caution when discussing the concept of ecological dominance because dominance concepts often are used interchangeably 

with abundance and the two are not the same. When sagebrush becomes the ecologically dominant species on a landscape 

that means it drives plant succession processes and outcomes, particularly following the inevitable disturbance from fire. 

GB Both rmc0067GB
C. Comments by Resource Planning Issue

C-1066 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

The outcome, particularly on sites with less than 12 inches of annual precipitation, is less perennial grass in the herbaceous 

understory, which facilitates an increase in cheatgrass, the single most significant threat to sage-grouse in the Great Basin 

region. Sagebrush should be present across much of the landscape, but more (higher density) on all parts of the landscape 

will result in adverse unintended and undesired outcomes.

193. Rangeland seedings established for Range Improvement objectives (largely 1950'2-70's) should remain as seedings and be 

managed to maintain high forage production, which results in the exclusion of invasive annual grasses and reduced spring 

use on adjacent native range. An evaluation of the Vale Project in southeastern Oregon clearly documented the success and 

of these seedings for overall rangeland management. Fire rehab seedings should be managed to initially establish a perennial 

grass state that largely excludes cheatgrass, but is capable of following successional pathways toward a perennial 

grass/shrub and shrub/perennial grass states that are resilient to the next large scale disturbance. Species selection for fire 

rehab seedings should be based upon the probability the species seeded will germinate and establish the first growing 

season and competitively exclude cheatgrass. On more arid sites this will mean the exclusive use of exotic perennial grasses 

instead of native grasses.

GB Both rmc0076gb

194. The Dillion Local Working Group identified 5 key issues in the area: 4. Conifer invasion IDMT Both rmc0028GB

195. Actions that reduce or minimize sage brush habitat include: -Eliminating sagebrush (including burning, plowing, mowing, or 

use of herbicides) as part of efforts to promote grass growth, or reduce fuels. -Wildfire

IDMT Both rmc0028GB

196. (identified as a priority issue in the Dillion Area) - conifer expansion IDMT Both rmc0028GB

197. There is no evidence that cattle have any impact on sagegrouse, either positive or negative. However, there is plenty of 

evidence that ranching has a strong positive impact on sagegrouse. Ranches need to be relatively large and usually in native 

vegetation. This protects against habitat fragmentation and the destruction of sagebrush for fields or lawns. Ranchers need 

vegetation and will control fires to some extent. Hot, late, uncontrolled fires will destroy large areas of big sagebrush, 

which takes over a century to recover from a burn of this kind. Ranches tend to have some degree of predator control, and 

predators are the largest negative impact on sagegrouse, following sagebrush destruction. Areas with healthy sagegrouse 

populations tend to have ranches, areas that have lost their ranches have also lost their sagegrouse. It is easy and popular 

to protect sagegrouse from cattle, but the cattle don't harm the sagegrouse. If you remove the cattle, you also remove the 

ranches, which are important to the sagegrouse. Sagegrouse can be protected into extinction just like rare orchids and 

desert pupfish.

MT-RM Both emc0023RM

198. The beneficial effects of predator control must be addressed in sage-grouse management strategies. Specifically, raven 

control could be beneficial to nest and chick survival. Nevada’s raven population has grown dramatically over the past 25 

years and it has been stated we currently have extremely drastic increase in ravens over historic levels.

NVCA Both emc0204GB

199. The Nevada Wilderness Project respectfully requests that you address the impacts to sage-­grouse and sage-­‐grouse 

habitat caused by feral horses, including removal of vegetational cover necessary for nesting and brood-­‐rearing, changes 

to vegetational composition that results from feral horse use, horse impacts to springs and other important free water 

sources utilized by sage-grouse, possible disturbance caused by feral horses during the nesting period, infrastructure used 

to mitigate horse impacts (e.g., fences) and how it may negatively affect sage-grouse, any connection to West Nile Virus as 

NVCA Both emc0243GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1067

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

that disease is recognized as affecting both horses and sage-grouse, and the potential for feral horse management actions to 

negatively affect sage-grouse and sage-grouse habitat.

200. What likely could be done to help sage grouse would be to keep cattle or sheep in areas suitable for sage grouse using good 

range management so grass and forbs would not be over used. Riparian areas should be carefully used so green grass would 

be there and the riparian areas would be more healthy for their own sake. Grass is healthier when cut or grazed

NVCA Both emc0253GB

201. What likely could be done to help sage grouse would be to keep cattle or sheep in areas suitable for sage grouse using good 

range management so grass and forbs would not be over used. Riparian areas should be carefully used so green grass would 

be there and the riparian areas would be more healthy for their own sake. Grass is healthier when cut or grazed.

NVCA Both emc0253GB

202. Pacific Rim compared the NDOW habitat map with field data for the Hog Ranch project area. Our comparison clearly 

demonstrates that both the NDOW and the derivative BLM-USFS maps are inaccurate and unreliable. The habitat 

categories shown on the NDOW map bear no resemblance whatsoever at all to the conditions on the ground. The 

attached map of the Hog Ranch area shows an enlargement of the NDOW Habitat Categorization Map for the Hog Ranch 

project area and superimposes the mining-related, on-theground features on the NDOW habitat map. As shown on the 

Hog Ranch map, the NDOW Habitat Characterization Map classifies this previously mined area as having significant and 

essential sagegrouse habitat. However, knowledge of the actual field conditions at Hog Ranch clearly reveals this

classification is wrong. The Hog Ranch area is not an area with high-value sage grouse habitat. In fact, the substantial amount 

of previously disturbed land that is shown on the Hog Ranch map provides very limited sage-grouse habitat. Thus it is 

readily evident from the Hog Ranch map that the NDOW map does not accurately categorize the habitat characteristics of 

the mined and disturbed areas at Hog Ranch. Previous operators reclaimed the Hog Ranch project area in the late 1990s 

and early 2000s. Although there is vegetation growing in the reclaimed areas it is sparse in many places. Moreover,

throughout the reclaimed areas, the vegetation that is growing is not the ideal vegetation species composition that 

comprises priority sage-grouse habitat (e.g., a sagebrush canopy with grassland and forbs understory).

NVCA Both emc0287GB

203. The NDOW map shows the southern portion of the Hog Ranch project area in yellow which is NDOW Habitat Category 

No. 1 - “Essential/Irreplaceable Habitat.” As can be seen from the Hog Ranch map, in reality, this is an area with extensive 

disturbance from previous exploration drilling and mining. A field examination readily confirms that this area is not priority 

sage-grouse habitat because it does not have the right kind of vegetation and is heavily disturbed. Thus the NDOW habitat 

categorization map for this area is incorrect.

NVCA Both emc0287GB

204. The NDOW map shows much of the Hog Ranch project area in green, thus classifying it as Habitat Category No. 3 -

“Habitat of Moderate Importance.” There is very little sagebrush growing on the reclaimed mine site; most of the area is 

sparsely revegetated. Thus the designation of most of the reclaimed mine site as “Habitat of Moderate Importance” does 

not fit the description of this NDOW habitat category (see NDOW’s white paper on the agency’s website1). Thus the 

NDOW habitat categorization map for this portion of the project area is incorrect.

NVCA Both emc0287GB

205. Grasses Dominate the Revegetated Area and are used Extensively for Grazing: Due to the predominance of grass species 

in the BLM-approved reclamation seed mix used to revegetate the mine site, grass is the dominant plant species growing on 

the reclaimed areas. These areas are highly utilized for grazing by cattle, horses and antelope. In addition, the private 

sections cover water sources and pasture lands heavily impacted by these larger animals. Large areas of cheat grass are 

NVCA Both emc0287GB
C. Comments by Resource Planning Issue

C-1068 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

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Agency CmtLtrCode

locally present, as well.

206. In the NTT document, livestock grazing is considered to be a diffuse disturbance (pressure is exerted over broad spatial or 

temporal scales). Livestock grazing, as well as wild horse and burro activity can greatly affect nest success on any 

ground-nesting bird as well as decimate any viable vegetation in the grazing area. Wild horse numbers have increased 

exponentially in the Rochester area and no gatherings have occurred to decrease population size. Since wild horses have 

different grazing patterns then cattle the magnitude of grazing increases across the entire landscape in the Rochester area. 

Damage to vegetation communities (i.e. reduction of grass, shrub, and forb cover and increases in unpalatable forbs and 

exotic plants as well as complete decimation of any vegetation community) is highly visible in the Limerick and Rochester 

canyon areas. If any mitigation efforts were made in or adjacent to Rochester mine's project area wild horses and cattle 

would have to be fenced out for any type of habitat restoration or sage grouse re-introduction to have a chance.

NVCA Both emc0302GB

207. In Nevada, range surveys were done in recent decades. Foresters are questioning the conclusions of many of the soils 

surveys. There has been a strong bias in research done in Nevada towards a "range" perspective, and not towards a 

forestry perspective, and this is true in the soil surveys, too. Historical surveyor records contradict soil surveys -showing 

"Pine Nut Forest" and other vegetative descriptors on areas claimed by agencies relying on soils surveys to be sagebrush 

habitats. For example, in association with the Ely-Mount Wilson Vegetation Deforestation Project, WWP reviewed 

historical surveyor records from the 1870s that clearly showed "Pine Nut Forest" and large trees on lands claimed to be 

(Fite Ely-Mount Wilson Prject Historical Surveyor Records Searches. Recent papers contradict soil survey conclusion 

related to widespread pinyon-juniper "invasions." See Lanner and Frazier 2012. See also Lanner the Pinyon Pine, and Skip 

Ritter, forester pers. Comm. To Fite.

NVCA Both emc0411GB

208. Many areas, including significant portions of the Humboldt-Toiyabe Forest, still do not even have soil surveys. NVCA USFS emc0411GB

209. Regarding this statement: These areas include breeding habitat (lek sites and nesting habitat), brood-rearing habitat, winter 

range, and important movement corridors. PPH primarily consists of sagebrush, but may also include riparian communities, 

perennial grasslands, agriculturally-developed land, and restored habitat, including recovering burned areas. We request 

that NDOW, BLM and the Forest provide more detailed mapping that identifies all of the following seasonal habitats as well 

as sagebrush, riparian, perennial grasslands native must be identified separately from non-native, ag-developed land, and 

restored habitat successfully restored lands must be separated from treated lands, weedlands that have resulted from fuels 

treatments, etc. As we describe throughout just because an agency spent funds on projects does not mean that the 

claimed project benefits such as restoration or even successful rehab have actually been achieved on the ground. It is critical 

to identify areas of crested wheatgrass for removal, inter-seeding, etc. There is typically less suitable nesting cover, and 

crested wheatgrass limits forb and other native plant recovery. It is also very important to identify these areas to prevent 

federal agencies from proposing to mow or purge sagebrush when sagebrush has moved back in to some degree. 

Unfortunately, killing sagebrush in seedings, rather than acting to restore seedings, or at a minimum inter-seed seedings 

with less sagebrush has been proposed by Ely BLM and other offices in Nevada that seek to relentlessly alter, manipulate 

and destroy sagebrush and other woody vegetation communities.

NVCA Both emc0411GB

210. We are also concerned about targeting pinyon-juniper without an understanding of historical deforestation, and the fact NVCA Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1069

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

that in many areas, pinyon-juniper are in reality the climax vegetation on a site. It appears much easier for agencies to 

promote expensive tree killing projects, rather than address the extensive degradation caused by livestock grazing, roading, 

or other disturbances throughout Nevada’s sagebrush habitats.

211. As previously described, it is from our observations of BLM’s claimed “fuelbreaks” and vegetation treatments conducted 

across Nevada (Austin Fuelbreaks, Elko Owyhee Fuelbreaks, Ely Fuelbreak weedlands of Cherry Creek and Spring Valley 

treatments, etc.) that removal of shrub protective cover, or tree protective cover, results in hotter, drier sites that become 

dominated by cheatgrass several years following “treatment”. There is typically a 4-6 year lag period in sites that previously 

had little cheatgrass before being altered, which is longer than agencies typically monitor their “treatments”. So the 

cheatgrass is showing up after BLM quits monitoring.

NVCA Both emc0411GB

212. Establishing an across-the-board herbaceous cover requirement will eliminate the ability of a manager to Implement 

practices appropriate to some plant communities. In Nevada, some plant communities don't yield 7 inches of herbaceous 

growth and yet have a thriving sage grouse community. Again, managing herbaceous height for a single species Is 

shortsighted and inappropriate for our ecosystem. An herbaceous growth requirement may also increase fine fuel loads 

and more importantly. Fuel continuity, resulting In continued large scale fires. The sage grouse habitat loss we have 

experienced has nothing to do with grazing, invasive species, off-highway vehicle use, or even mineral development -

wildfires have decimated more habitat in our area than the other uses combined. By removing our ability to manage for 

site-specific herbaceous material, our ability to minimize the effects of these catastrophic wildfires is eliminated. There 

should be a balance between sage grouse cover needs and fine fuel loads.

NVCA Both fxc0010GB

213. Establishing an across-the-board herbaceous cover requirement will eliminate the ability of a manager to Implement 

practices appropriate to some plant communities. In Nevada, some plant communities don't yield 7 inches of herbaceous 

growth and yet have a thriving sage grouse community. Again, managing herbaceous height for a single species Is 

shortsighted and inappropriate for our ecosystem.An herbaceous growth requirement may also increase fine fuel loads and 

more importantly. Fuel continuity, resulting In continued large scale fires. The sage grouse habitat loss we have experienced

has nothing to do with grazing, invasive species, off-highway vehicle use, or even mineral development - wildfires have 

decimated more habitat in our area than the other uses combined. By removing our ability to manage for site-specific 

herbaceous material, our ability to minimize the effects of these catastrophic wildfires is eliminated. There should be a 

balance between sage grouse cover needs and fine fuel loads.

NVCA Both fxc0010gb

214. BLM needs to identify the scale of areas where resource concerns can be identified and confirmed through a 

well-developed empirical inventory. The BLM assessments using Standards of Rangeland Health has limitations in the 

elements that can be identified as a cause and effects impact to resource condition and lacks sufficient elements to serve as 

an inventory. The SRH methods are qualitative and lack rigorous sampling procedures to provide a credible study of the 

BLM plant community landscapes. The EA should carefully look at the issue of making meaningful provisions in the plan for 

an up-to-date inventory of the acres of different plant communities. Average production and appropriate height to weight 

relationship of the forb and grass plants. The District inventories in Oregon have not been up-dated in over 30 years and 

the older work will not provide a credible roadmap about the landscape. This work and information should be referred to

the Range programs where education, training, and experience with livestock grazing issues will compliment the work that 

OR Both emc0136GB
C. Comments by Resource Planning Issue

C-1070 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

needs to be done.

215. The scales at which the grazing alternatives are developed for management of vegetation communities need to be 

considered and carefully scrutinized. Wyoming big sage communities and other sagebrush species vary in ecological 

potential due to moisture and soil differences in Oregon and the western regions. Allotments and pastures arc a mosaic of 

sites located at different elevations on varying ecological surfaces. One size fits all prescriptions do not work and

consideration of the variability of different areas should be identified.

OR Both emc0136GB

216. Employ Best Practices for Juniper Management: BLM should identify a clear benefit to sage-grouse and a restoration plan 

with quantifiable objectives before practicing juniper removal. Planning should include careful post-removal management to 

prevent invasion by weeds and to establish a native sagebrush community that will support sage-grouse.

OR Both emc0385GB

217. Employ Restoration Planning: Resource management plans should incorporate alternatives that focus on restoring and 

maintaining native sagebrush and bunchgrass communities necessary for sage-grouse nesting and brooding.

OR Both emc0385GB

218. What will be the impacts or effects of the proposed juniper Encroachment management plan on Existing valued Visual and 

Aesthetic qualities and Management Objectives in regions now defined within Areas of Environmental Concern (AECS) in 

the Vale, Lakeview and BLM Districts?

OR Both rmc0036GB

219. What is the total number of AMU's now allotted within all the proposed "juniper Treatment" areas in eastern Oregon? OR Both rmc0036GB

220. The ODFW should determine what effect decreased sight lines in treated areas have on predation rates in Sage Grouse 

habitat.

OR Both rmc0036GB

221. The ODFW must justify in their proposed juniper Management strategy, answering the question: Why is a standing 

Juniper Tree in a Juniper Encroachment Area not good for Sage Grouse; but at the same time a dead juniper tree cut off at 

the stump and left lying on the ground in a treated Juniper Encroachment area, is somehow beneficial to the Sage Grouse, 

as proposed in EIS Management Recommendations?

OR Both rmc0036GB

222. The ODFW EIS does not provide any evidence that "Juniper Encroachment" is anything more than natural "Faunal 

Succession" and a recovery response in the Great Basin to improved grazing practices and land use changes over the last 80 

years. If such evidence exists the data and conclusions should be presented.

OR Both rmc0036GB

223. The ODFW EIS as written does not Demonstrate with "best science" that the Juniper Management Program of the SCS has 

been measurably successful at producing a "Net Benefit" to the Sage Grouse Population. Increasing the Sage Grouse 

population or effectively enhancing Sage Grouse use of rehabilitated terrain in Oregon or elsewhere, since the SCS 

program inception in 2002; must be demonstrated by the applicant before adoption of the proposed Juniper Management 

plan. The EIS must address this diffincey. On Page 3, the ElS states "The outcomes of each conservation action suggested 

must be evaluated for their effectiveness." Because the EIS does not provide any concrete evidence that Juniper 

Management as proposed has worked over the 2002-2010 period. It does not seem that the spirit of the words in written 

into the EIS have been followed to date.

OR Both rmc0036GB

224. Any EIS or SEIS must also explicitly recognize the following points:The extensive encroachment of pinion-juniper into 

sagebrush communities, coupled with vast expanses of decadent single aged sagebrush communities, has drastically 

decreased productive habitat for nesting and brood rearing sites for sage-grouse throughout the Great Basin and much of 

OR Both rmc0078GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1071

Scoping Summary Report

Table C-8.A

Comments Related to General Vegetation Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

the West.

225. The sage grouse habitat in our county is in need of some attention. There have been too many years of fire suppression and 

not enough brush control to create the type of landscape needed by sage grouse populations (too tall of brush and too 

dense of canopy). These activities, or lack of activities, have contributed too many places of juniper/pinion encroachment 

that are detrimental to sage grouse habitat. Something needs to be done to correct these issues.

UT Both emc0295GB

226. Emery County is concerned that the National Strategy is focused on "sagebrush habitat", and "sagebrush conservation", and 

the development of "new conservation measures" for sagebrush conservation. Such a broad focus on sagebrush 

conservation, rather than Greater Sage-grouse conservation, has the potential for new conservation measures to affect the 

management of numerous public land uses, and areas of Emery County, which are totally unrelated to Greater Sage-grouse. 

Emery County believes that the National Strategy should specifically address the conservation of Greater Sage-grouse, as 

the title of the project implies.

UT Both rmc0073GB

227. Emery County is firm in its position that the entire planning process, at all levels, must focus on issues and needs relevant 

to conservation of the Greater Sage-grouse and sagebrush habitat which is specifically related to the species, rather than 

the broader sagebrush vegetationcommunity issues.

UT Both rmc0073GB

228. Factors such as vegetation management, fire management, conflicting wildlife management, predation, subdivision and 

infrastructure development, and invasive plants are a higher priority in the Upper Snake River Basin Conservation Area 

(USRBCA) and include large areas that could be affected by project actions.

WY USFS emc0144RM
C. Comments by Resource Planning Issue

C-1072 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. We would like to see the BLM take more initiative on controlling noxious weeds, especially Leafy Spurge, on BLM ground 

within Sage Grouse habitat.

All Both cfc0001

2. Encroachments of forbs and bushes (Junipers, etc.) that could take over sage grouse habitat should be included in the plan and 

an action to not allow it to happen.

All Both cfc0004RM

3. I agree with the NTC recommendation about not controlling big sage in precip. Ares less than 12''. In fact, I would recommend 

that fire not be used in less than 15'' precip. Zones. Too much chance of cheatgrass invasion in low precip. Areas.

All Both cfc0017RM

4. When doing noxious weed control who wins sage grouse or weeds. All Both cfc0020RM

5. Looming on the horizon is the very real threat of invasive species. Much is made of cheatgrass and juniper encroachment but 

both are runners up to medusahead rye. The Idaho Fish and Game Department conducted a study with chuckers in three 

plots. One had a food supply of crested wheatheads, another with cheatgrass heads and the third with medusa head rye heads. 

The first two groups thrived and the third starved. The study concluded that medusahead rye had no protein value in its dry 

seed ripe condition. An official involved predicted that, unchecked, those areas infested with medusahead would become a 

biological desert within twenty years.

All Both cfc0030GB

6. At this writing, Oregon is under a court ordered injunction limiting use of herbicides on public lands. Currently Oregon BLM 

is requesting public comment on the ban with the goal of getting it lifted. In the meantime, the state will continue on as a seed 

source for invasive species.

All Both cfc0030GB

7. I believe the solution to resource issues and working toward resolving them can be found at home. Jordan Valley hosts what 

is known as the cooperative weed management area (CWMA). It encompasses roughly five million acres; four in Malheur 

County, Oregon and one in Owyhee County, Idaho. Coordinator, Eric Morrison, says, "What makes this group work is it is 

land-owner driven ." Representatives from the ranching community, irrigation district, state and federal agencies, counties, 

and environmental groups work together for the common goal of conducting a meaningful weed control program.

All Both cfc0030GB

8. Stop and eliminate the use of crested wheat. This is a non-native plant. All Both cfc0058GB

9. The plan must address the impact of noxious weeds on sage-grouse habitat and strive to get the weed conjunction lifted and 

the vegetation mgmt EIS approved.

All Both cfc0070GB

10. Also, stop planting crested wheatgrass and other non-native plants as part of fire rehabilitation. All Both emc0009RM

11. People who ride the range moving cattle or fixing fence have more opportunity to find noxious weed infestations, which 

reduces the amount of sage grouse habitat lost to non-native invasive plants. If economic and political forces remove riders 

from an allotment, the habitat becomes less resistant to invasive plants.

All Both emc0013RM

12. With the introduction of non-native grasses and species, you may be best to designate several large blocks of land specifically 

and totally to the sage grouse.

All Both emc0017

13. In addition to energy development and disease, sagebrush-steppe habitat quality may be impacted by grazing practices, invasive 

species and resulting changes in the frequency and severity of fires.

All Both emc0034RM

14. Decreases in the quality of habitat may have direct impacts on greater sage-grouse populations. WWF encourages the BLM to 

address the potential impacts of climate change on the spread of invasive plants, particularly cheatgrass (Bromus tectorum), 

All BLM emc0034RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1073

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

which may highly alter the quality of habitat by outcompeting native grasses and forbs and causing increased frequency and 

severity of wildfires, which are detrimental to fire-intolerant sagebrush species.

15. How has the spread of weeds and other invasive species affected sage grouse and its habitat? 1) What factors promote the 

spread of the various exotic species? 2) What ecological changes/problems do these invasive species impose on sage grouse?

All Both emc0041GB

16. Your graph shows the invasive species is the greatest threat but the direction to fix things is always more ”takings” from the 

tax payers and yet the other side of the government stops the use of a weed spray that will help control cheat grass which is 

one of the sage grouse habitat’s worse enemies. How about going after the EPA and getting in their pocket and not ours. In 

other words push to have all the governmental agencies play in same sand box together.

All Both emc0045GB

17. Cheatgrass (Bromus tectrorum) will often occupy sites following disturbance, especially burning. Repeated burning or burning 

in late summer favors cheatgrass invasion and may be a major cause of the expansion of this species . The ultimate result may

be a loss of the sage grouse population because of longterm conversion of sagebrush habitat to rangeland dominated by an 

annual exotic grass. Historic and scientific evidence indicates that livestock grazing did not increase the distribution of 

sagebrush but markedly reduced the herbaceous under story over relatively large areas and increased sagebrush density in 

some areas

All Both emc0057GB

18. Noxious weeds are a huge problem and need attention in this scoping process. The federal and state land management 

agencies certainly have not adequately addressed this threat in proportion to their ownership of lands in the west. Everyone 

is responsible for control, but the private landowner and federal lessee is critical in weed control. It is naïve to think we can 

accomplish our task with herbicides alone. We must use biological control and grazing when appropriate and realistic. The 

landowner and his county government contemporaries can get funding to control weeds on intermingled lands that have little 

federal funding. The stewardship responsibility of land ownership is huge and the agencies are using the management of the 

lessee to accomplish this. If we regulate the lessee off the land, who will assume the agencies responsibilities, especially for 

weed control?

All Both emc0070GB

19. Livestock-free portions of our Greater Sage-Grouse range may be necessary to ensure viable populations are maintained in 

otherwise disturbed landscapes, particularly in conservation priority (core) areas. We believe that closing these areas to 

livestock grazing through the permanent retirement of existing grazing permits should protect them from the risk of 

overgrazing, greatly reduce the risk of invasion by undesirable vegetation (invasive plants), and enable federal land managers to 

compare these lands to other grazed areas, enabling them to better evaluate the effects of livestock grazing on these 

sagebrush ecosystems and Greater Sage-Grouse populations.

All Both emc0074GB

20. Invasive plant species are becoming more widespread throughout our federal public lands as a result of disturbances from 

livestock grazing, livestock feeding operations, roads and energy developments, increased traffic on roads and trails, and other 

land uses. While there are numerous invasive species that may occur across the sagebrush steppe, those most important over 

large areas include cheatgrass, juniper and pinyon pine. Control or elimination of these exotic species should have the highest 

priority, particularly in conservation priority (core) areas for Greater Sage-Grouse.

All Both emc0074GB

21. Recommendation # 6 - We recommend that control or elimination of cheatgrass, juniper, and pinyon pine infestations have 

the highest priority among management actions on our federal public lands, particularly in conservation priority (core) areas 

for Greater Sage-Grouse.

All Both emc0074GB
C. Comments by Resource Planning Issue

C-1074 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

22. ISSUE: The proposed Conservation Measures fail to address pinyon-juniper (woodland) encroachment into sagebrush / sage 

grouse habitat as an important issue needing specific recommendations for the Great Basin and Colorado Plateau 

physiographic areas. Woodland encroachment is one of the most intractable problems facing sage grouse habitat management 

in the Great Basin and Colorado Plateau. There is an extensive body of research and research publications concerning the 

history of woodlands in the Great Basin and Colorado Plateau physiographic areas. Climate / carbon cycle changes, 

interruption of natural fire cycles, changes in class of grazing livestock and historic recovery of fuel wood areas have all 

contributed to an increase in the stocking rate and acreage dominated by woodlands. Grey science points to there having 

been higher, normally fluctuating numbers of sage grouse when woodland areas were being heavily harvested for fuel wood. 

The problems for water sources and understory vegetation in encroaching woodland areas has been researched and 

documented for many years. Woodland encroachment into sage grouse nesting / brooding (riparian area) habitat and 

connective habitat continues to make these areas less than ideal to unusable for sage grouse. Although USFS and BLM to a 

lesser extent have programs for woodland management, i.e. harvesting etc., treatment is expensive and fraught with 

regulation on larger areas. The LUP amendments need to include woodland treatments, not just scattered trees in fuels 

reduction projects.

All Both emc0083GB

23. In many parts of the western United States, fire and non-native, invasive species are primary threats to sage-grouse habitat. 

Consequently, the BLM and FS's efforts to develop sage-grouse conservation measures should focus on addressing these 

causes of habitat diminution. For example, the BLM should consider the extent to which fuels management programs and 

rehabilitation of fire-impacted areas may provide benefits for sage-grouse habitat. In addition, modification of suppression and 

fire management strategies and practices should be considered.

All Both emc0084GB

24. Although the wildfire effects of climate change from anthropogenic carbon emissions could not be directly projected, USFWS 

also determined that sage‐grouse habitat degradation would accelerate due to encroachment from nonnative invasive species 

that are highly responsive to increased carbon concentrations.

All Both emc0110GB

25. Arter reviewing the food habits of pre-laying hens and chicks it appears there are a number of introduced, invasive species 

plants that are heavil}' lIsed during the sage grouse life stages. Vegetation management objectives, including objectives for 

managing noxious weeds and invasive species (i ncluding identifi cation of desired future condition for specific areas), needs to 

focus on how preferred species arc treated whether they arc invasive or native (sec Torell et al. 2002 reference below).

All Both emc0136GB

26. Noxious Weeds. Noxious weeds are recognized within the sage grouse areas ofIron County as a serious problem by the Iron 

County Weed Department, BLM, and USFS, and can have negative impacts on sage grouse. Iron County maintains records of 

the location, extent, and severity of weed establishment, and actively works to control the spread and establishment of weeds. 

In January 1996, the BLM published Partners Against Weeds (PAW), an action plan for the Weed Management program in the 

BLM. The PAW plan lists seven goals, the first being to develop a prevention and early detection program. The PAW 

recommends developing and enforcing a policy to "ensure seeds, seed mixtures, hays, grains and straws are free of weed seed" 

as a prevention and detection strategy. Utah's BLM Resource Advisory Council developed a guideline requiring certified weed 

free forage to be used on BLM lands by anyone having the need to take forage with them when using BLM public lands. Both 

the Utah State BLM Director and the Secretary of the Interior approved the guidelines in 1997. Since 2002, users of all federal 

lands and trust lands in Utah are required to use only certified noxious weed –free hay, straw, or mulch. The USFS is also 

All Both emc0142GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1075

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

committed to a campaign against the spread of invasive species. Iron County encourages that the planning strategy recognizes 

the problems associated with sage grouse and noxious weeds, and adopt the seven goals in the PAW.

27. Study the effects of noxious weeds encroachment inot sage-grouse habitat. All Both emc0153GB

28. After reviewing some of the food habits of pre-­‐laying hens and chicks it appears there are a number of introduced, invasive 

species plants that are heavily used during the sage grouse life stages. Vegetation management objectives, including objectives 

for managing noxious weeds and invasive species (including identification of desired future condition for specific areas), needs 

to focus on how preferred species are treated whether they are invasive or native (see Torell et al. 2002 reference below).

All Both emc0159GB

29. Pinion/Juniper encroachment and decadent sage brush needs to be treated. In the past 10 years, in my area the BLM has 

completed around 10,000 acres of pinion/juniper encroached rangeland with hand cutting or bull hogging the P/J. These efforts

are excellent and noteworthy. Hand cutting has been fairly effective and low cost, but bull hogging (mulching of standing trees) 

is extremely costly, $300-500/acre. These high cost treatments would never be conducted on adjoining private lands because 

they do not provide a cost effective return

All Both emc0165GB

30. After reviewing some of the food habits of pre-­‐laying hens and chicks it appears there are a number of introduced, invasive 

species plants that are heavily used during the sage grouse life stages. Vegetation management objectives, including objectives 

for managing noxious weeds and invasive species (including identification of desired future condition for specific areas), needs 

to focus on how preferred species are treated whether they are invasive or native (see Torell et al. 2002 reference below).

All Both emc0179GB

31. After reviewing some of the food habits of pre-­‐laying hens and chicks it appears there are a number of introduced, invasive

species plants that are heavily used during the sage grouse life stages. Vegetation management objectives, including objectives

for managing noxious weeds and invasive species (including identification of desired future condition for specific areas), needs

to focus on how preferred species are treated whether they are invasive or native (see Torell et al. 2002 reference below).

All Both emc0179GB

32. The extensive encroachment of pinyon-juniper into sagebrush communities, coupled with vast expanses of decadent single 

aged sagebrush communities, has drastically decreased productive habitat for nesting and brood rearing sites for sage-grouse 

throughout the Great Basin and much of the West. The proposed range-wide guidelines do not recognize the variability of 

issues across the west and do not focus on or prioritize specific issues at the needed scale.

All Both emc0202GB

33. After reviewing some of the food habits of pre-­‐laying hens and chicks it appears there are a number of introduced, invasive 

species plants that are heavily used during the sage grouse life stages. Vegetation management objectives, including objectives 

for managing noxious weeds and invasive species (including identification of desired future condition for specific areas), needs 

to focus on how preferred species are treated whether they are invasive or native (see Torell et al. 2002 reference below).

All Both emc0209GB

34. 4. Carefully consider the juniper mastication work performed in Owyhee County as a preferred alternative for controlling 

invasive juniper.

All Both emc0212GB

35. the extensive encroachment of pinion-juniper into sagebrush sites, coupled with vast expanses of decadent single aged 

sagebrush communities has drastically decreased productive habitat for nesting and brood rearing sites for greater 

sage-grouse throughout the Great Basin and much of the West. The proposed range-wide guidelines do not recognize the 

variability of issues across CD the west and do not focus on or prioritize specific issues at the needed scale.

All Both emc0215GB

36. After reviewing some of the food habits of pre-­‐laying hens and chicks it appears there are a number of introduced, invasive All Both emc0222GB
C. Comments by Resource Planning Issue

C-1076 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

species plants that are heavily used during the sage grouse life stages. Vegetation management objectives, including objectives 

for managing noxious weeds and invasive species (including identification of desired future condition for specific areas), needs 

to focus on how preferred species are treated whether they are invasive or native (see Torell et al. 2002 reference below).

37. We kindly request that any future Juniper removal in our area of operations, by any means, be conducted in a manner that 

leaves several "islands" of Juniper trees at least 5-10 acres in size. In addition, as we have to provide water for our clients from 

an out of area source and delivered by vehicle we also request that these "islands" be no more than 100-200 yards from 

existing roads.

All Both emc0235GB

38. Invasive Weeds: Within the boundaries of the proposed ACEC, special management is required to limit the spread of invasive 

weeds such as cheat grass (Bromus tectorim). Cheat grass significantly alters fire regimes, shortening fire frequencies and 

increasing fire intensities in ways which permanently alter the climax sagebrush vegetation Sage- Grouse require. Presently 

cheat grass is not classified as a “noxious weed” in Montana and as such receives no state, federal or local resources to control 

or limit its spread.

All BLM emc0248GB

39. Reduced availability of forbs and insects -- the latter a high-protein food that chicks must have -- are caused by the yearly 

stripping of vegetation from an area by livestock. Sage-grouse need to eat, but they are literally being starved to death because 

the biomass that they need simply is not available in many places. Many areas under BLM management are grazed from May to 

October, every single year. This level of use does not allow native vegetation to recover. When I walk through these areas, I 

see much bare ground, which encourages the invasion of cheatgrass and knapweed, the seeds of which are carried by livestock 

and vehicles. These then spread if there is a wildfire. But livestock grazing was the beginning of the problem.

All Both emc0268GB

40. Livestock grazing also causes numerous indirect effects that can negatively impact sage-grouse. For example, in addition to 

direct competition with sage-grouse for rangeland resources, livestock may also create similar competition for other species 

such as mule deer, white-tailed deer, elk, pronghorn, and bison. This competition may alter the distribution of these species,

which may be particularly important when management for one species is in potential conflict with sage-grouse. One example 

would be the removal of sagebrush for improvement of elk range. Additionally, livestock can often indirectly spread invasive 

species or weeds, such as cheatgrass, which can negatively impact sagebrush survival and alter the fire-risk of an ecosystem

All Both emc0276GB

41. Invasive, nonnative plants and the spread of noxious weeds pose a direct threat to sage-grouse habitat. Invasives alter natural 

plant community structure and composition, productivity, nutrient cycling, and hydrology, and may cause declines in native 

plant populations through competitive exclusion and displacement. As a result, invasive plants may reduce or eliminate native

vegetation that sage-grouse require for food and cover, resulting in habitat loss and fragmentation.

All Both emc0276GB

42. Cheatgrass is the primary invasive threat to sagebrush habitat. For example, one study estimates that approximately 80 

percent of land in the Great Basin Ecoregion (MZs III, IV, and V) is vulnerable to displacement by cheatgrass within 30 years. 

Furthermore, the Technical Team Report notes that cheatgrass and other exotic plant species tend to invade low elevation

Wyoming big sagebrush systems following wildfires, resulting in significant habitat loss.13 Encroachment of pinyon-juniper into 

sagebrush habitats has also been an increasing threat. The expansion of pinyon-juniper has been attributed to the reduced role 

of fire, domestic livestock grazing, climate change, increases in global carbon dioxide concentrations, and alterations during

recovery from past disturbance. There exist a variety of both regulatory and nonregulatory mechanisms to control invasive 

plants, but it is unclear how effective these measures and efforts have been and will be in the future. Estimates show that 

All Both emc0276GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1077

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

noxious weeds are spreading at a rate of 931 hectares (2,300 acres) per day on BLM lands, amounting to 339,815 hectares 

(839,500 acres) per year. While it is not clear whether this estimate is limited to noxious weeds or also includes other 

invasives, it is nevertheless an estimate of great concern.

43. There are currently ongoing efforts to restore or rehabilitate sage-grouse habitats affected by invasive plants. Restoration, 

however, can be complex, expensive, and sometimes unsuccessful. Where restoration is possible, it can often take decades or 

longer to see results. Because meaningful restoration must include large expanses of sagebrush habitat, it requires 

partnerships across multiple landowners that are sometimes difficult to form.

All Both emc0276GB

44. The BLM's westwide planning strategy should recognize that the most important existing threats to sage‐grouse are wildfire 

and invasives (particularly juniper encroachment).

All BLM emc0298GB

45. We have planned 18,525 acres of Juniper removal to expand and restore sage grouse habitat. All Both emc0300GB

46. That is not to say that all post-colonization changes were beneficial; in particular the introduction of Bromus tectorum (cheat 

grass) was unambiguously harmful, as may have been also in some cases over-aggressive control of Artemisia (sagebrush) and 

similar shrub species. However, the only option with respect to Bromus now is to control it through grazing (it is much too 

widespread, and the control options have too any deleterious side-effects, to hope to eradicate or even significantly reduce its 

hold on the West), and Artemisia now thrives throughout the West.

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47. Evaluate sagebrush habitat for the presence of invasive plant species - cheat grass, etc. Develop an aggressive strategy to 

eliminate invasive species in critical sage grouse habitats. Address the introduction, expansion, and persistence of invasive 

species in the sagebrush ecosystem.

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48. Evaluate the synergistic effects of climate on invasive annual grasses and altered fire regime. All Both emc0305GB

49. NEI recommends that sage grouse habitat be accurately mapped through sound environmental assessment and that more 

focus be given to proven threats to sage grouse viability, such as invasive species and fires.

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50. Reduce and reclaim areas of large scale habitat changes due to invasive annual grasses. All Both emc0314GB

51. Any EIS or SEIS must also explicitly recognize the following points: The extensive encroachment of pinion-juniper into 

sagebrush communities, coupled with vast expanses of decadent single aged sagebrush communities, has drastically decreased 

productive habitat for nesting and brood rearing sites for sage-grouse throughout the Great Basin and much ofthe West.

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52. Conservation measures need to focus on real and substantial threats such as wildfire, noxious weeds, and other large scale 

conversions when they specifically threaten a population seasonal segment. Changes in land-use should not be rigidly 

restricted or prevented from occurring because many times those changes can have secondary benefits such as breaking up or 

reducing the risk of catastrophic change particularly wildfire.

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53. VI. BLM and USFS Must Evaluate a Reasonable Range of Alternatives In light ofthe different reasons for sage-grouse habitat 

decline from region to region, and the fact that there remains significant sagebrush habitat in Wyoming and Nevada, each 

sub-regional EIS should carefully evaluate a reasonable range of alternatives to the conservation measures and regulatory 

mechanisms proposed in the NTT Report. Some of the contemplated measures may not be necessary or effective in each 

region or sub-region. Examples of such alternatives include, but are not limited, to the following: The Better Non-Native and 

Invasive Species Eradication and Control Altemative The ElS should evaluate the impacts associated with better funded and 

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C. Comments by Resource Planning Issue

C-1078 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

more effective programs to eradicate and control the growth of invasive and non-native species that impede the

reestablishment and growth of sagebrush vegetation ecosystems that provide sage-grouse habitat.

54. In addition to the issues listed in the accompanying informationJ I encourage the evaluation4f1h,s of the following in all analyses 

of the environmental impacts of actions on federal lands:Vast acreages of lands have been heavily impacted by invasive species. 

f2>6LfI--Fs ill vc,.-wv Focus a significant amount of analysis on recovery of areas of sage grouse habitat impacted by invasive 

species such as cheat grass

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55. An inevitable consequence of any large, ground-disturbing project is the increased risk of colonization by invasive, non-native 

species. In the sagebrush-steppe community, in addition to the slow regeneration of sagebrush, the biggest threat is the 

invasion of cheatgrass. Cheatgrass has the potential to completely alter the ecosystem it invades, increase fire frequency, and 

prevent the establishment of sagebrush and native grass and forb understory. When cheatgrass becomes a dominant presence 

on the landscape it can change the fire regime over a very broad area, causing hotter and more frequent fires that destroy 

nearby sagebrush plants that were not impacted by the original construction project. Even assuming revegetation was 

successful, there is an increased risk of predation on nests by newly accommodated synanthropic predators. Raven, coyotes 

and other opportunistic predators will benefit from an open corridor, putting sage-grouse at further risk. The introduction of 

aggressive fauna and flora invasive species are often linked to human disturbances, such as new roads and construction of 

facilities associated with any proposed wind project in sagegrouse habitat.

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56. Grazing additionally reduces the instances and severity of wildfires (Launchbaugh et al. 2007); improves Sage Grouse habitat 

by increasing the quality and accessibility of forbs for sage grouse (NeeI1980, Derner et al. 1994, Evans 1996); and can be used 

to control invasive weeds (Olson and Lacey 1994, Walker et al. 1994).

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57. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: -Invasive 

plants, especially cheatgrass, are having major impacts on ecosystem function in sagebrush habitats

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58. Native vegetation communities in Great basin sagebrush steppe did not evolve with grazing pressure (Mack and Thompson 

1982). Excessive livestock grazing by domestic livestock during the late 1800s and early 1900s had significant impacts on 

sagebrush steppe and those effects persist today (Knick et al. 2003). Grazing (in addition to other factors) is implicated in the 

encroachment of conifers in sagebrush steppe, including western juniper (Juniperus occidentalis) (Kerr and Salvo 2007). 

Decades of livestock grazing have altered plant communities and soil and reduced productivity in sagebrush steppe (Knick et 

al 2003). Cattle grazed at “conservative” levels in sagebrush steppe in the northern Great Basin initially selected bunchgrasses 

in interspaces between sagebrush plants (France et al. 2008). The removal of native species from interspaces by cattle, in 

conjunction with other factors, appears to facilitate invasion by cheatgrass (Bromus tectorum) into these areas (Reisner 

2010). The spread of cheatgrass and other invasive plants into degraded rangelands has accelerated the natural fire cycle and

threatens to convert enormous areas of sagebrush habitat into annual grasslands (Wisdom et al. 2005; Miller et al. 2011).

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59. Baker (2006) reviewed the fire history of sagebrush ecosystems and found natural fire to be a rare event, suggesting a fire 

rotation 325-450 years in length. However, overgrazing across many of the Great Basin states has led to the invasion of 

cheatgrass, a highly flammable noxious weed that accelerates the fire cycle to less than five years destroying the sagebrush 

upon which sage grouse rely for food and cover. Approximately 36 percent of the greater sage grouse range is invaded by 

cheatgrass (Lebbin et al. 2010). Because sagebrush requires at least 15 years (and up to 50) to reoccupy burned sites, restoring 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1079

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

invades areas is a difficult and slow process. Preventing further spread into intact sagebrush should be prioritized.

60. Biological invasions, especially invasion by exotic annual grasses such as cheatgrass, are consistently cited as among the most 

important challenges to maintenance of healthy sagebrush communities (Miller et al. 2011; Wisdom et al. 2005; Suring et al. 

2005). At least 46 exotic plants occur in sagebrush steppe (Pyke 2000). Estimates of the rapid spread of weeds in the West 

include 2,300 acres per day on BLM lands and 4,600 acres per day on all western public lands (See 65 Fed. Reg. 54544).

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61. Cheatgrass, an invasive annual grass, is now the dominant species on 100 million acres (158,000 square miles) in the 

Intermountain West (Rosentreter 1994: 170, citing Mack 1981). It was estimated in 1999 that 25 percent of the original 

sagebrush ecosystem has been converted to cheatgrass/medusa-head rye (Taeniatherum caput-medusae) annual grassland, 

and an additional 25 percent of sagebrush steppe has only cheatgrass as understory vegetation (West 2000). Cheatgrass is 

estimated to spread at a rate of 14 percent annually in the United States (Duncan et al. 2004: 1412, table 1). The conversion 

of sagebrush steppe to exotic annual grassland has been described as “massive” (Allen 2003) and is expected to continue 

(Miller et al. 2011; Hemstrom et al. 2002).7 Cheatgrass thrives in disturbed, and especially burned, areas. It can increase fire 

frequency, favoring itself and potentially inhibiting perennial seedling establishment (Miller et al. 2011). Cheatgrass incursion 

into sagebrush habitat can lead to an eventual conversion of sagebrush/grass (perennial) community to sagebrush/grass 

(annual) or annual grass rangeland. In some cases, cheatgrass invasion encourages other exotic species such as medusa-head 

rye, knapweed and thistle. It was observed in 1979 that annual-dominated communities in sagebrush steppe appears to have 

crossed a threshold and created its own new equilibrium (Hanley 1979) from which restoration to functional sagebrush 

steppe would be very costly and difficult (if not impossible) to achieve (Billings 1990).

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62. Sage grouse do not use cheatgrass. Invasive species was identified as a threat to sage grouse by three expert panels and in 

recent reviews (Connelly et al. 2011, Table 1). One panel listed cheatgrass as the most important threat to sage grouse in the 

western portion of its range (70 Fed. Reg. 2267), where it has invaded much of the lower elevation, xeric sagebrush habitat 

(Miller et al. 2011). Land uses such as livestock grazing (Reisner 2010), off-road vehicle use, and coalbed methane development 

(Bergquist et al. 2007), can facilitate cheatgrass incursion in sagebrush steppe.

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63. The spread of cheatgrass, which thrives in the wake of fire (both natural and humancaused) further complicates post-fire 

sagebrush recovery. Once cheatgrass invasion begins, fires result in pure stands of cheatgrass, which tends to burn on a 2-5 

year cycle, preventing the re-establishment of native vegetation. Biologists have observed, “Under current, altered fire 

regimes, natural re-establishment of sagebrush after burning (especially basin big sagebrush and Wyoming big sagebrush) is 

unlikely” (WAFWA 2006b: 66). Fires and subsequent cheatgrass invasion were a cause of major habitat loss in many of the 

sage grouse units in northern Nevada, and risk of large-scale habitat loss was high even in areas that had not experienced 

major problems in the past.

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64. Invasive Plants • Restrict activities on public land that facilitate the spread of invasive plants. • Rapidly restore burned or 

disturbed sagebrush steppe to prevent incursion of invasive plants. • Develop and implement methods for prioritizing and 

recovering sagebrush steppe invaded by nonnative plants.

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65. At minimum, the NEPA analysis should address the following: • Evaluating the impact of invasive weeds (especially 

cheatgrass) on sage grouse habitats, and providing a management framework to reduce or (better yet) eliminate them over 

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C. Comments by Resource Planning Issue

C-1080 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

time.

66. Any conservation strategy needs to increase support for control of non-native vegetation, which is primarily carried by wind, 

wildlife, and birds, as well as wild horses and to increase cooperation with state and local government agencies;

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67. The Technical Team Report incorrectly assumes that travel is the primary vector for invasive species. In fact wind, wildlife and 

birds, all of which are present on public lands in abundance, are the primary vectors. BLM WY-040-EA10-111, Environmental

Assessment Jim Bridger Power Plant 3-D Seismic and Electromagnetic Surveys, p. 9. The failure of the team to recognize this 

basic fact again shows the bias of the Technical Team Report. That is not to say that invasive species are not a significant 

problem. The invasives problem that BLM needs to focus on is cheat grass encroachment on burn sites on the drier end of the 

sage brush zone. In fact, this has been recognized as the most significant adverse impact to sage grouse habitat west-wide. Ex. 

1 p. 3 (effects of land conversion). Similarly, current reclamation policies have been ineffectual in controlling non-native 

species. Halogeton can be seen at most reclamation sites and often goes untreated. CLG, working as part of a group with the 

State of Wyoming, BLM and University of Wyoming, has recommended steps intended to better address these invasions in 

the context of reclamation. The steps involve early site stabilization and use of non-native sterile seed mixes to give native 

plants the time to be re-established while discouraging invasive plants.

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68. Invasive plants. Issue: Invasion by exotic plants, particularly annual grasses, may permanently alter vegetative composition and 

fire ecology in sagebrush steppe to the detriment of sage-grouse.

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69. Contributions of Livestock Grazing to Cheatgrass Incursion Livestock grazing appears to spread cheatgrass through multiple 

effects (Chambers 2008b) and grazing is probably not effective to control cheatgrass in preparation for restoring sagebrush

steppe (Hempy-Mayer and Pyke 2008). Other information suggests that there are simply not enough livestock available to 

graze at the preferred locations, at the preferred intensity, at the preferred times during the year, to control cheatgrass at a 

landscape-level (McAdoo et al., undated, factsheet). The number of livestock and grazing intensity required to control 

cheatgrass would also probably have additional negative effects on native vegetation, soil, and other resources in sagebrush 

steppe that could outweigh any benefits from cheatgrass control. The removal of herbaceous perennials by grazing may 

increase water and nitrate availability to cheatgrass, and less perennial herbaceous cover may increase cheatgrass invasion 

(Chambers et al. 2007). The removal of cheatgrass by grazing may also increase cheatgrass seed production the following year 

(Chambers et al. 2007). Cheatgrass invasibility is lowest on sites with relatively high cover of perennial herbaceous species 

(Chambers et al. 2007). Cheatgrass incursion in sagebrush steppe began in the 1850s with the introduction of domestic

livestock, which trampled the biological soil crust that occupied the interspaces between native vegetation (Mack 1981) and 

facilitated the species’ spread. Intact, lichen-dominated biological soil crusts can significantly inhibit germination and root 

penetration of cheatgrass (Deines et al. 2007), while the presence of cheatgrass can negatively affect biological soil crust 

richness and cover (Ponzetti et al. 2007). Moss-dominated biological soil crusts may also effect germination of annual grasses, 

including cheatgrass (Serpe et al. 2006). The diversity, cover and resiliency of biological crusts are positively correlated to low 

abundance of cheatgrass, low level of soil disturbance and high moss cover (Ponzetti et al. 2007). Shinneman et al. (2008) 

discovered that herbaceous and biological soil crust cover and species richness and diversity were generally greater on 

ungrazed than grazed areas in semi-arid shrubsteppe in western Colorado. The recent proclamation by Davies et al. (2011: 3) 

that “livestock grazing per se is not a stressor threatening the sustainability of the [sagebrush] ecosystem”—that did not 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1081

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

account for the direct and indirect contributions of grazing to the spread of cheatgrass—is without merit. The authors failed 

to consider the role of livestock grazing in altering the outcome of competitive interactions between bunchgrasses and 

cheatgrass, or the role of disturbance in succession and community assembly in sagebrush steppe (see Reisner 2010). Similarly, 

even if sagebrush steppe in the Wyoming Basin evolved with moderate herbivory (Mack and Thompson 1982), grazing

prescriptions in sage-grouse habitat in Wyoming (e.g., Cagney et al. 2010) that fail to recognize the increasing presence of 

cheatgrass in the state (Smith and Enloe 2006, factsheet) may inadvertently contribute to its spread.

70. Biological invasions, especially invasion by exotic annual grasses, is consistently cited as among the most important challenges 

to maintenance of healthy sagebrush communities (Miller et al. 2011; Wisdom et al. 2005c; Suring et al. 2005). At least 46 

exotic plants occur in sagebrush steppe (Pyke 2000). Estimates of the rapid spread of weeds in the West include 2,300 acres 

per day on BLM lands and 4,600 acres per day on all western public lands (65 Fed. Reg. 54544). Cheatgrass, an invasive annual 

grass, is now the dominant species on 100 million acres (158,000 square miles) in the Intermountain West (Rosentreter 1994: 

170, citing Mack 1981). It was estimated in 1999 that 25 percent of the original sagebrush ecosystem has been converted to

cheatgrass/medusa-head rye (Taeniatherum caput-medusae) annual grassland, and an additional 25 percent of sagebrush 

steppe has only cheatgrass as understory vegetation (West 2000). Cheatgrass is estimated to spread at a rate of 14 percent 

annually in the United States (Duncan et al. 2004: 1412, Table 1). The conversion of sagebrush steppe to exotic annual 

grassland has been described as “massive” (Allen 2003) and is expected to continue (Miller et al. 2011; Hemstrom et al. 

2002).13 Cheatgrass thrives in disturbed, and especially burned, areas. It can increase fire frequency, favoring itself and 

potentially inhibiting perennial seedling establishment (Miller et al. 2011). Cheatgrass incursion into sagebrush habitat can lead 

to an eventual conversion of sagebrush/grass (perennial) community to sagebrush/grass (annual) or annual grass rangeland. In

some cases, cheatgrass invasion facilitates establishment of other exotic species such as medusahead rye, knapweed and 

thistle. It was observed in 1979 that annual-dominated communities in sagebrush steppe appeared to have crossed a threshold 

and created a new equilibrium (Hanley 1979) from which restoration to functional sagebrush steppe would be very costly and 

difficult (if not impossible) to achieve (Billings 1990). Invasive species was identified as a threat to sage-grouse by three expert 

panels and in recent reviews (Connelly et al. 2011b (Table 1)). One panel listed cheatgrass as the most important threat to 

sage-grouse in the western portion of its range (70 Fed. Reg. 2267), where it has invaded much of the lower elevation, xeric 

sagebrush habitat (Miller et al. 2011). Land uses such as livestock grazing (Reisner 2010), off-road vehicle use, and coalbed 

methane development (Bergquist et al. 2007), can facilitate cheatgrass incursion in sagebrush steppe.

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71. Non-native Seed. The NTT Report requires use of native seed for restoration, but does allow for consideration of non-native 

seed where the probability of success or adapted seed availability is low, as long as the non-native seed supports greater 

sage-grouse habitat objectives. We encourage BLM to analyze the effects of non-native plants in its EISs and SEISs and to 

amend its LUPs to allow non-native seeds where such seeds support greater sage-grouse habitat. PCW has restored a natural 

bum area on private land within its project site with dryland alfalfa (Medicago falcata). Observational reports are that dryland 

alfalfa provides suitable habitat for greater sage-grouse by increasing available forage and cover. PCW has developed a study

design to monitor the utilization of dryland alfalfa areas within its project area for consideration liS an effective conservation 

measure for greater sage-grouse.

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72. Wildfire, invasion of non-native plant species and livestock grazing work synergistically. Yet BLM and other agencies All Both emc0411GB
C. Comments by Resource Planning Issue

C-1082 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

repeatedly try to point to fire and invasive species as threats divorced from livestock grazing disturbance, the most pervasive 

ecological stress across all parts of the sage-grouse range. Fires are occurring more frequently, and the size and intensity of 

fires are increasing. Fires reduce or eliminate shrubs, disturb soils, destroy microbiotic crusts, and release nutrients that allow 

cheatgrass and other weeds to thrive. The end result in grazed landscapes is a paucity of shrub cover, few forbs, a shorter 

period of green plant material (as fires result in hotter, drier sites with little vegetation to trap snow, shade ground, and block 

wind), and a longer fire season.

73. Cheatgrass germinates and dries up earlier, and outcompetes native plants for water and nutrients – leading to further altered 

fire regimes, nutrient loss, altered microclimates, and increased erosion. In 2004, it was already known that 80% of the lands 

in the Great Basin are susceptible to cheatgrass invasion. Earlier ICBEMP analysis had highlighted the severe threat posed by 

cheatgrass across much of Idaho, Oregon, portions of Utah and northern Nevada. Cheatgrass known over a decade ago to be 

the dominant vegetation community on 25 million acres (1/3 of the Great Basin).

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74. Cattle evolved in, and are adapted, to, cool, moist climates and are not native to the arid West (Mack and Thompson 1982). 

Cattle feed preferentially on native grasses and forbs reducing or eliminating critical components of sage-grouse habitats. 

Historic and chronic ongoing livestock grazing eliminates or reduce food, nesting cover and cover from predators. Livestock 

and management activities disturb and displace sage-grouse including in lek, nesting and winter habitats.Through degradation 

of the native plant communities, and trampling, displacement, compaction, erosion, of soils and microbiotic crusts, the 

livestock create ideal sites for weed infestation. Livestock are also vectors of weed spread. Weeds thrive in livestock manure 

nutrients (Belsky and Gelbard 2000). Impacts are intensified by livestock facilities like fences, water troughs, supplemental 

feeding/salting sites, yet agencies promote all of these actions, and continue to tout these actions as beneficial and include 

them in laundry lists of BMPs. Many of these actions are conducted with minimal or piecemeal NEPA. In reality, such practices 

are overwhelmingly beneficial only to livestock, and serve to shift and intensify disturbance into remnant less grazed areas.

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75. And a basic question: Where was sagebrush present at the time of the older Plan RODs compared to the present? Where did 

BLM treat lands for forage, fuels, other purposes and what is their condition now? What existing treatments or seedings had 

been identified in LUPs, and what is their condition now? Following fire: Where, when and how did BLM rehab/restore/treat 

sagebrush under the Plan? Detailed mapping and analysis must be provided. Where was cheatgrass present, and in what 

percentage cover? How has this changed in both burned and unburned lands? How soon did BLM allow livestock grazing to 

disturbance to resume following fire rehab, and what was the outcome? A solid baseline must include all of this type of 

information.

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76. If cheatgrass was not present pre-treatment, then opening up the plant community through radical treatment disturbance, 

promotes its increase through creating of a hotter, drier micro-climate once shrubs are removed. Then chronic livestock 

disturbance with minimal rest after any treatment favors weed increase and retards recovery. There is often a bit of a lag time 

(4 to 6 years) when cheatgrass and other weeds appear in significant amounts in sites where they were not present 

pre-disturbance.

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77. Weeds destroy the ability of the native species to recover, especially with any continued disturbance. Disturbances like 

grazing must be removed so sagebrush communities can withstand invasive species and the unraveling that ensues following 

cheatgrass/medusahead dominance. This is supported by the ICBEMP science of over a decade ago that has been ignored by 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1083

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

federal agencies.

78. The Notice states that the BLM and FS will develop "vegetation management objectives including objectives for managing 

noxious weeds and invasive species (including identification of desired future condition for specific areas) within greater 

sage-grouse habitat." What does this mean? More massive pinyon-juniper killing and sagebrush killing that will make little if any 

difference to sage-grouse populations subjected to relentless chronic grazing disturbance and where ongoing disturbances will 

continue near status quo and even more development would be allowed?

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79. For the past couple of years, agencies have been using another category to try to separate out populations, and minimize the 

importance of losses to the sagebrush habitats. This is the effort to segregate greater sage-grouse into eastern vs. western 

portions of the range on the basis of claims that grouse face different threats in different parts of their range. USFWS used this 

artifice in defending its toothless Warranted but Precluded Finding in litigation, and took it to absurd lengths in its arguments 

there. First, many of the same threats occur across the range - livestock grazing, roads no matter what the cause, invasive 

species, mining. Second, increasingly renewable energy threats with many of the same impacts as oil and gas are accelerating 

in the western portion of the species range, and mining is exploding in northern and central Nevada and some other western 

areas. Plus hundreds of thousands of acres are now being leased for oil and gas development all over Nevada. Renewable 

energy examples: Major industrial wind farm on Steens Mountain Oregon and new transmission lines, major new transmission 

lines like Gateway and MSTI, geothermal development often by foreign entities (McGinness Hills and other areas), massive 

geothermal leasing proposals are appearing - for over 500,000 acres on Bridgeport Ranger District lands and elsewhere in NV. 

Mining is expanding into new areas where sage-grouse populations are already barely hanging on, and new mining is proposed 

in areas with larger populations, as well. In the east, weeds like cheatgrass are increasing (see WBEA Assessment 

discussion). New and expanded mining, new transmission lines, and oil and gas harms are far exceeding those agencies claimed 

would occur from these new or recently expanded developments. See 2012 Yubanet article on failures of Wyoming Core 

Model in the Powder River Basin.

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80. BLM merely lists washing vehicles to limit invasive species, a standard practice for decades now. BLM ignores integrated weed 

management actions like removing livestock disturbance that spreads weeds crosscountry affecting a landscape much beyond 

the bulldozed disturbance area weed infestation footprint of a typical energy project and its associated roading and other 

disturbances.

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81. The NTT at 18 admits that Energy and Minerals development poses risks including: Direct disturbance, displacement, or 

mortality of grouse; Direct loss of habitat, or loss of effective habitat through fragmentation and reduced habitat patch size and 

quality; and cumulative landscape-level impacts. However, the NTT and IM provide minimal, uncertain, non-mandatory and 

ineffective BMPs that mirror those for fluid mineral development. These are basically common sense, and what a developer 

may need to do anyway to avoid prosecution for littering. For example: "Clean up refuse." "Control the spread and effects 

of non-native plants." This is meaningless. How will this be effectively done in landscapes suffering often multiple forms of 

disturbances all of which promote invasive species? Is it even feasible without eliminating livestock disturbance to disturbed 

sites and adjacent sagebrush areas? What battery of chemicals may be used? BLM has no integrated weed strategy, so it is 

impossible for this to even be applied.

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C. Comments by Resource Planning Issue

C-1084 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

82. Power washing vehicles does nothing to stop transport from roads accessing sites. When is BLM going to start "power 

washing" livestock - i.e. conducting integrated weed management to minimize transport and spread of weeds? Through 

quarantining animals for weed seeds to pass through guts, prohibiting turnout into lands without weed problems when 

livestock are coming from a weedy area, prohibiting knowing turnout onto weedy area until weed infestation is addressed, 

etc.?

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83. The language here (p. 71 fuels) is "key" habitats - such as give priority for implanting sage grouse habitat restoration projects 

in annual grasslands to areas adjacent to or surrounded by key sage grouse habitats. So how is BLM going to do this - when it 

has discarded the whole Key area concept, and cast aside other areas long identified for restoration with its flawed PPH 

mapping? Other provisions here appear to promote bulldozing of fire lines - which often an damage cultural and other 

resources, and wild land areas. BLM must place a moratorium on its destructive and expensive "fuels" projects in the Interim 

- until a comprehensive plan with mandatory and rock solid safeguards is developed. It must conduct a comprehensive and full 

evaluation of all existing treatments from 1950 to the present must be provided for each BLM/Forest District. Risk of weed 

infestation resulting from treatment must be assessed for all areas, as well. This must include full examination of cheatgrass 

risk, which may have a 5-6 year lag period from the initial BLM disturbance if limited cheatgrass was present pre-treatment. 

The NTT reads like BLM fire rehab plans from 30 years ago. It allows BLM to continue to use exotic species like the many 

millions of acres of supposed "placeholder" crested wheatgrass that has been planted, and which now is burning with great 

regularity and that BLM has refused to remove, restore with native, or even interseed to any significant degree. How many 

areas have had some crested wheatgrass seeded on them -over all periods of time- for livestock forage and/or fire purposes? 

Please map these, and overlay mapping of fires and fire frequency.

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84. The Fire Management BMPs are just SOPs - and have been for over a decade. They have been largely ineffective - as BLM has 

used "fuels" concerns to alter, fragment and destroy critical sage-grouse habitats, promoting weeds and grassy hotter, drier 

desertified sites that also serve to allow intensified livestock impacts. BLM must fully evaluate the habitat losses and 

fragmentation that have occurred as a result of its projects- and that have spread of cheatgrass and other weeds as a result.

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85. Scientific research indicates that grazing is beneficial to the greater sage-grouse and to a host of other wildlife. Grazing can 

improve sage-grouse habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and also aids in 

the control of invasive plant species

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86. The EIS and SEIS revi,sioils should clarify that multiple-une management concepts should be used to reduce the risk of 

catastrophic wildfire, improve forage. refilove invasive species and provide open space. We strongly encourage the agencie.r 

to prioritize theit focus on public land use, or disuse, which poses a real threat to the greater sage-grduse and its habitat

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87. There is almost no research on inva<;ive plants, evcn cheatgrass, and sage grouse (Rowland and Wisdom 2002). Ecological 

Site Descriptions must describe the susceptibilities of different vegetation states to inva.;;ive plants after various weather

pattems, types of disturbance, and management actions.

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88. I feel the biggest detriment to habitat for cattle and wild life is club moss. Many people look out over their pastures and see 

sagebrush as a threat to their pastures. We did too until we started looking under the sagebrush. The real culprit is club moss. 

This cannot be removed by reducing cattle numbers. On one range field trip we examined and exclosure that had not one 

head of cattle on it for the last 40 years. It had as much club moss inside the fence as outside of it. A range expert told me once 

All Both rmc0003RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1085

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

that he had placed a clump of club moss in a box up on a shelf in his office. Six months later he took it down and poured water 

on it. The club moss turned green and started to grow. There are a few ways to kill club moss. Chemicals do not work very 

well and are expensive. The best luck we have had on our own land is: (1) winter feeding on it. You will find no club moss on 

your winter feed grounds. Even rolling one round bale off a hillside will show benefits years later. The heavy concentration of 

cattle urine kills the moss. Rotating winter feed grounds with summer or fall pasture really improves them. (2) Spiking and 

drag harrowing the pasture. Gouging up the moss and throwing dirt over it will kill the moss. Just once over with spikes leaves 

enough sagebrush intact for the grouse. The more club moss that can be killed the more understory will grow among the 

sagebrush benefiting the sage grouse. Once killed, rotation grazing will keep the club moss from returning. (3) Concentrating 

a large enough number of cattle in a small enough area will trample the moss. This is difficult to do over a large area. We put 

salt and mineral out in areas of the worst club moss infestation. No matter where you put out the salt or how far it is from 

water the cattle will find it.

89. Avoid livestock water developments and salt grounds in traditional sage grouse spring, summer, and fall habitats. These 

developments significantly concentrate livestock and increase forage use, trailing, and soil compaction that fragment sagebrush 

habitat. These heavy-use areas may extend up to 0.8 km away from the site providing a niche for noxious weeds and other 

undesirable or unpalatable vegetation to take hold.

All Both rmc0024GB

90. Targeted grazing should be allowed and encouraged as a tool for creating fire breaks, controlling weeds, and improving 

habitat. In some cases, fencing can help facilitate the success of a Targeted Grazing project. Electric and net wire fencing should 

not fall under the same specifications as other high-impact problem fencing.

All Both rmc0025GB

91. The Board supports aggressive "integrated vegetation management" and believes that livestock and local permittees could 

serve as the best means of implementing such activities. The Board does have serious concern with the statement "When 

necessary, analyses the use of non-native species that do not impede long-term reestablishment goals of native plant 

communities and Greater Sage-grouse habitat." Based on the "best available science" carefully selected and adapted non-native 

species are often times the only species that are effective at maintaining key ecological processes and preventing sites from 

crossing an ecological threshold due to invasion by undesirable species. Non-native plants should not be a second or 

alternative option; rather, they should be used in combination with native plants where applicable to compete against invasive 

species. This is particularly true of the Great Basin where native species are especially difficult to establish and often require 

two or more years for establishment.

All Both rmc0050GB

92. Risk to Sage-grouse from Cheatgrass- Finally, Dr. Holloran noted the risk of the infiltration of Cheatgrass and other grasses 

as a result of oil and gas disturbance that would negatively impact the sagebrush obligate sage-grouse. This would limit the 

population, eliminate nesting and early brood-rearing habitat and reduce winter and severe winter range. !d. at 7.

CO BLM emc0057RM

93. CPW believes the following range-wide threats pose the greatest risk to greater sage-grouse populations and their habitats 

(not in order of risk): Prescribed fire as management tool may be appropriate in limited conditions; however, introduction 

and invasion of exotic weeds resulting from a burn is a major concern for sage-grouse. The long-lasting effects of fire on 

sagebrush regeneration and growth form and thus, impacts to sage-grouse nesting and winter habitats also need to be 

carefully considered prior to implementing prescribed fire in sagebrush systems.

CO Both emc0072RM
C. Comments by Resource Planning Issue

C-1086 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

94. CPW believes the following range-wide threats pose the greatest risk to greater sage-grouse populations and their habitats 

(not in order of risk): Cheatgrass and pifion-juniper encroachment in the sagebrush biome reduces the value of the habitat 

to greater sage-grouse. The PRMP should contain language that recognizes the value of proactive restoration projects and 

should prioritize projects that enhance or restore habitat. Properly designed proactive habitat restoration projects should not 

be precluded because of potential disturbance factors or predetermined metric thresholds.

CO Both emc0072RM

95. Recent modeling studies have shown the possible expansion of cheatgrass in the Eastern Region under various climate-change 

scenarios (Bradley 2009).

East Both emc0034RM

96. i. Lander, WY RMP Because of the aggressive nature of invasive species, such as cheatgrass, we support flexibility for 

treatment of invasive species. Managers should be permitted to use chemical treatments in extreme conditions, as noted for 

Alternative D, understanding that prevention is the most effective approach. The value of avoiding unnecessary soil 

disturbances and implementing aggressive reclamation where needed cannot be emphasized enough. The use of chemical

treatments should be minimally used and only after thorough consideration of other measures and a comprehensive review 

of potential impacts to existing resources (plant, wildlife, water sources, etc from chemical use. For example, the DEIS notes 

that broad-spectrum insecticides should not be used in grouse brood-rearing areas because of the adverse impacts to 

non-targeted insects that are critical to young grouse. (DEIS at 865).

East Both emc0089RM

97. iii. Strong components of Wyoming’s approach Wildfire, a major form of disturbance that often is followed by the invasion 

of non-native species, is being addressed through active fire suppression in core areas. Operators are required to control 

noxious and invasive weed species, including cheatgrass.

East Both emc0089RM

98. Any conservation strategy needs to increase support for control of non-native vegetation, which is primarily carried by wind, 

wildlife, and birds, as well as wild horses and to increase cooperation with state and local government agencies;

East Both emc0155RM

99. The Technical Team Report incorrectly assumes that travel is the primary vector for invasive species. In fact wind, wildlife and 

birds, all of which are present on public lands in abundance, are the primary vectors. BLM WY-040-EA10-111, Environmental

Assessment Jim Bridger Power Plant 3-D Seismic and Electromagnetic Surveys, p. 9.. The failure of the team to recognize this 

basic fact again shows the bias of the Technical Team Report. That is not to say that invasive species are not a significant 

problem. The invasives problem that BLM needs to focus on is cheat grass encroachment on burn sites on the drier end of the 

sage brush zone. In fact, this has been recognized as the most significant adverse impact to sage grouse habitat west-wide. Ex. 

1 p. 3 (effects of land conversion). Similarly, current reclamation policies have been ineffectual in controlling non-native 

species. Halogeton can be seen at most reclamation sites and often goes untreated. VRLP, working as part of a group with the 

State of Wyoming, BLM and University of Wyoming, has recommended steps intended to better address these invasions in 

the context of reclamation. The steps involve early site stabilization and use of non-native sterile seed mixes to give native 

plants the time to be re-established while discouraging invasive plants. Finally, BLM needs to support efforts to improve 

rangelands by removing piñon juniper, and other undesirable brush. Piñon juniper encroachment on the upper elevation,

wetter sage brush sites has been part of the demise of summer sage grouse habitat. This has been due primarily to the lack of 

fire on these wetter sites. The encroachment of these species has reduced prime sage brush habitat. Too often these projects 

are postponed.

East Both emc0155rm
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1087

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

100. I am a livestock producer based in the state of Nevada. Livestock grazing is a legal and valid use of public rangelands and is a 

vital component of my livelihood. The extensive encroachment of pinyon-juniper into sagebrush communities, coupled with 

vast expanses of decadent single aged sagebrush communities, has drastically decreased productive habitat for nesting and 

brood rearing sites for sage-grouse throughout the Great Basin and much of the West. The proposed range-wide guidelines 

do not recognize the variability of issues across the west and do not focus on or prioritize specific issues at the needed scale.

GB Both emc0304GB

101. The Board supports aggressive "integrated vegetation management" and believes that livestock and local permittees could 

serve as the best means of implementing such activities. The Board does have serious concern with the statement "When 

necessary, analyses the use of non-native species that do not impede long-term reestablishment goals of native plant 

communities and Greater Sage-grouse habitat." Based on the "best available science" carefully selected and adapted non-native 

species are often times the only species that are effective at maintaining key ecological processes and preventing sites from 

crossing an ecological threshold due to invasion by undesirable species. Non-native plants should not be a second or 

alternative option; rather, they should be used in combination with native plants where applicable to compete against invasive 

species. This is particularly true of the Great Basin where native species are especially difficult to establish and often require 

two or more years for establishment.

GB Both rmc0050GB

102. In addition to these goals, the Group has identified key threats to sage grouse in the Jarbidge Planning Area that they believe 

deserve special attention and consideration. These key threats include fire and invasive species, with fire having recently 

damaged a significant portion of the sage-grouse habitat in the Jarbidge Planning Area.

IDMT Both emc0158GB

103. The next generation of analyses to direct conservation action should be two fold. First, there is a need to support 

implementation of core regions with studies that document seasonal habitat use and migration patterns of radio-marked 

sage-grouse (Aldridge and Boyce 2007, Doherty et al. 2008) to ensure identified priority landscapes meet all seasonal habitat 

needs. Second, incorporation of future modeling of other relevant risks, such as cheatgrass (Bromus tectorum) invasion, to 

core regions will ensure gains in conservation will not be offset by unevaluated risks. Well, there is nothing in the Makela and 

Majors Idaho White Paper about risk of cheatgrass, is there? Yet ID set about chopping off habitats with this score scheme, it 

appears without assessing risk. It does not appear that Nevada assessed risk, either. So habitat segregation is occurring in lands 

most vulnerable to cheatgrass without assessing risk. Precautionary management requires that agencies do these studies first 

– before sacrificing habitat to the oil and gas, wind or other industries. There is no going back, and replacing habitat sacrificed 

under the core or priority scheme models. Regarding cheatgrass – this already has been done- for example, in the embargoed 

WBEA, Great Basin, and Nevada Ecoregional Assessment reports. If cheatgrass is a concern, it makes no sense to write off 

areas currently with less cheatgrass – as has been done in ID Pahsimeroi, Little Lost, Lemhi. Agencies can amend or alter 

rights-of-ways or leases.

IDMT Both emc0411GB

104. It appears that the agency has overlooked many of the benefits that the continuance of livestock grazing provides. These 

include: Preservation of open space; Noxious weed and invasive species eradication and containment; Production of forb 

growth that is preferred by greater sage-grouse to non‐grazed areas; Wildfire prevention and controlled burn efforts; 

Development of wildlife watering sources, including placement of bird ladders in troughs; and Predator control. Rather than 

undertaking an attitude of restricting livestock, the agencies should utilize grazing as a tool to manage for the U.S. Fish &

Wildlife Service's list of primary threats affecting sage grouse in Idaho including fires and invasive weeds.

IDMT Both flh0000GB
C. Comments by Resource Planning Issue

C-1088 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

105. The Dillion Local Working Group identified 5 key issues in the area: 1. invasive plant species IDMT Both rmc0028GB

106. The County is also very supportive of targeting PI encroachment into Sagebrush ecosystems, including within Wilderness 

Areas. Policies should encourage, and not restrict, use of all tools (stewardship contracts, utilization of products to expand 

treatments, temporary access to treatment areas to minimize costs, etc.) to accomplish these projects in Priority and General

Habitat in Lincoln County.

NVCA Both emc0130GB

107. Invasive weeds have been identified by the USFWS and others as a major factor in the loss, degradation, and fragmentation of 

Sage Grouse habitats, both directly and as a critical part of the fire-weeds-fire syndrome. We have provided comments on the 

need to strengthen weed control objectives in some agency program areas, but weeds are a problem in all uses of the public 

lands. Funds for managing weeds is intermittent but the spread of weeds is inexorable. Millions of acres of sagebrush habitat 

have been lost to fires and millions more acres have been degraded when cheatgrass and other weeds replace a healthy native 

understory os still intact sagebrush country. This threat to Sage Grouse and its habitat cannot be overstated and needs the 

best conservation measures we can devise to be included in the EIS on amending land use plans.

NVCA Both emc0283GB

108. Grazing can improve sage-grouse habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and 

also aids in the control of invasive plant species.

NVCA Both emc0304GB

109. The next generation of analyses to direct conservation action should be two fold. First, there is a need to support 

implementation of core regions with studies that document seasonal habitat use and migration patterns of radio-marked 

sage-grouse (Aldridge and Boyce 2007, Doherty et al. 2008) to ensure identified priority landscapes meet all seasonal habitat 

needs. Second, incorporation of future modeling of other relevant risks, such as cheatgrass (Bromus tectorum) invasion, to 

core regions will ensure gains in conservation will not be offset by unevaluated risks. Well, there is nothing in the Makela and 

Majors Idaho White Paper about risk of cheatgrass, is there? Yet ID set about chopping off habitats with this score scheme, it 

appears without assessing risk. It does not appear that Nevada assessed risk, either. So habitat segregation is occurring in lands 

most vulnerable to cheatgrass without assessing risk. Precautionary management requires that agencies do these studies first 

– before sacrificing habitat to the oil and gas, wind or other industries. There is no going back, and replacing habitat sacrificed 

under the core or priority scheme models. Regarding cheatgrass – this already has been done- for example, in the embargoed 

WBEA, Great Basin, and Nevada Ecoregional Assessment reports. If cheatgrass is a concern, it makes no sense to write off 

areas currently with less cheatgrass – as has been done in ID Pahsimeroi, Little Lost, Lemhi. Agencies can amend or alter 

rights-of-ways or leases.

NVCA Both emc0411GB

110. The table labeled "Threats to Sage Grouse and Habitat" lists invasive species as the greatest threat. We assume this includes 

cheat grass, which is becoming more prevalent on the Jim Sage Mountain each year as it crowds out native vegetation and 

increases the threat of wildfires.

NVCA Both rmc0064GB

111. We are appalled at the generally poor condition of the public lands in Central Oregon. It would appear that the public lands 

have been overgrazed for so many years that there aren't many grasses or shrubs left to provide food and shelter for the 

grouse, antelope, or other native species. Wherever we hike, cheat grass is outcompeting the native grasses. Why? Because 

cheat grass sprouts early in the spring, and goes to seed by May or June. Guess when the cattle are set lose on the land? Not

when the cheat grass is growing strong, but later in the year when the native bunch grasses are trying to put up seeds. The 

OR Both emc0152GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1089

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

"management" practices of the high desert BLM land have been encouraging cheat grass and juniper growth, and therefore 

have upset the balance of all the native plants. The current practices continue to worsen the available fodder for the livestock 

set out to graze them. These practices have got to stop. You need to manage the BLM lands in a manner that can continue to 

sustain both the native plants and animals, which will also improve the grazing for livestock. You cannot continue to allow the 

cattle and sheep to graze the same sparse terrain every year. Give it a rest. Let the bunch grasses and native flowers go to seed 

for a couple of years before allowing the livestock back. Or change the time of year you allow grazing to March - April because 

there is plenty of cheat grass to eat. And they will eat it when it's green.

112. The most common problem in mountain big sagebrush plant communities is conifer encroachment leading to reduced or lost 

understory plant production. Management treatment of this issue has largely been worked out and restoration is limited only 

by available restoration dollars.

OR Both emc0192GB

113. Livestock Grazing is today by far the largest area land use throughout eastern Oregon. Grazing activity at almost any intensity 

can be shown to product Invasive Weed problems that require use of Vegetation Treatments detrimental to Sage Grouse 

productivity.

OR Both rmc0036GB

114. in the one million acre Upper Sevier Watershed, we have approximately 400,000 acres of P/J. Granted all these acres of P/J 

would not merit treatment, but treatment of 1,000 acres/year is not even keeping pace with the conversion to P/J. My point 

is that we need to be aggressively treating P/J and right now we're doing a great job, but were not keeping up with the slow 

conversion process. The BLM needs to treat more acres with the same budget which is possible with the current technology.

UT Both emc0165GB

115. Blue Mt. has fallen victim to the thought that fire isn't a good thing (the aggressive Smokey Bear era) and could benefit from 

the use of controlled or prescribed burns since there is way too much large sagebrush and too thick of populations of sage for 

sage grouse to flourish. The absence of fire has also allowed pinion and juniper to encroach into the sage brush, this 

encroachment needs to be addressed and also other methods of sage brush control need to be investigated

UT Both emc0406GB

116. Agency Land Management Policies - BLM and Forest Service policies related to invasive species. Wildfires and predators along 

with strategic livestock grazing should be reassessed pertaining to Sage Grouse habitat. Reduced livestock grazing and reduced 

chaining of pinyon-juniper coupled with wildfire policy have allowed invasive plant species to expand across the West. 

Including on Sage Grouse habitat. Short duration, heavy grazing on invasive cheatgrass areas when palatable for livestock as a 

management tool could help return healthy livestock grazing land and Sage Grouse habitat with little or no government 

expenditure. Policies that don't allow chemical treatments of predators and invasive species on federal lands need 

reevaluation.

UT Both rmc0003GB

117. Garfield County requests detailed analysis regarding management of invasive species as it relates to Sage Grouse Habitat. 

Federal agencies have recently taken the position that state listed noxious weeds cannot be controlled because they provide 

habitat for federally listed sensitive species. Garfield County requests that this conflict be evaluated in the plan.

UT Both rmc0006GB

118. Treatment of weeds and pests must remain a source of available management. Neither treatment usually occurs during 

courting or nesting time frames. These management tools must not be removed due to disturbance concerns. After the 

nesting period any sage grouse flushed while doing treatments will return as the treatment activity does not cause a major 

disturbance and is not a continual ongoing disruption to the daily lives of the sage grouse.

WY Both emc0050RM
C. Comments by Resource Planning Issue

C-1090 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.B

Comments Related to Weeds/Invasive Species

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

119. ‘Activities excepted by the State plan from the conductance of a DDCT calculation’ (page 7 letter) What about herbicide and 

pesticide use that occurs on the rangeland away from roads, locations, pipelines and ROWs---? The treatment of pests and 

noxious and exotic invasive grass species are important to help any habitat improve. If the treatment will not disturb a specific 

area for more than 1 hour in a 24 hour period and will not reduce the sagebrush canopy as per the WGFD protocol then 

these treatments should be exempt as well. And so noted.

WY Both emc0050RM

120. ‘Avoid the use of prescribed fire in areas of Wyoming big sagbrush and or within areas of less than 12 inches of annual 

precipitation.’(page 12 letter) Treatment for cheatgrass or downy brome is important and burns are tool that is used. More 

specificity is needed here-treatments will continue with burns for cheatgrass if the canopy of sagebrush is not reduced a 

certain %. There are many areas where downy brome can be burned without harming the sage brush and will bring in better 

forage post treatment. The rainfall limitation will prevent many areas of the state from prescribed burns because of the lack

of water. Place this limitation on a case by case basis as there are several areas with invasive weeds or grasses that would 

benefit from a good burn but the rainfall limitation of 12 inches makes this a no go.

WY Both emc0050RM

121. i. Lander, WY RMP Because of the aggressive nature of invasive species, such as cheatgrass, we support flexibility for 

treatment of invasive species. Managers should be permitted to use chemical treatments in extreme conditions, as noted for 

Alternative D, understanding that prevention is the most effective approach. The value of avoiding unnecessary soil 

disturbances and implementing aggressive reclamation where needed cannot be emphasized enough. The use of chemical

treatments should be minimally used and only after thorough consideration of other measures and a comprehensive review 

of potential impacts to existing resources (plant, wildlife, water sources, etc from chemical use. For example, the DEIS notes 

that broad-spectrum insecticides should not be used in grouse brood-rearing areas because of the adverse impacts to 

non-targeted insects that are critical to young grouse. (DEIS at 865).

WY Both emc0089RM

122. iii. Strong components of Wyoming’s approach Wildfire, a major form of disturbance that often is followed by the invasion 

of non-native species, is being addressed through active fire suppression in core areas. Operators are required to control 

noxious and invasive weed species, including cheatgrass.

WY Both emc0089RM

123. 9) Prevent the introduction of invasive plants in sage grouse habitat and promote control of infestations. WY USFS emc0144RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1091

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Not all sagebrush is equal in value- some stands are so thick & dense that they are of very little use. All Both cfc0018RM

2. If population has been declining for 100 years keep in mind 100 years ago the density of sagebrush was lots less also All Both cfc0031GB

3. It states sagebrush takes many years to recover - FALSE - if burned, sprayed, farmed and not not overgrazed, sagebrush still 

recovers within 10 years.

All Both cfc0031GB

4. Where sagebrush is allowed to thrive and never burned or sprayed it sucks all the moisture from the soil - push out other 

healthy plant species. Where sage is over 2' tall you don't see sagehens. It will grow 15' tall.

All Both cfc0031GB

5. In 2008-2009 leks were cut in half, agriculture caused reductions in leks as did a lot of roads. Sage-grouse were found to be 

half as likely to maintain their nests in Silver Sage as in Big Sage. North Dakota saw a tremendous drop in bird populations.

All Both emc0012RM

6. l read that the down turn of the sagegrouse is due to habitat loss. The habitat and it's quality have changed. As sagebrush 

matures, it prevents seedlings from gr?wing. Not until the sagebrush starts to deterioriate does it allow seedlings. Most 

sagebrush is in the 30-40 yr range. It needs to be disturbed to allow seedlings to grow.

All Both emc0013GB

7. I feel that the decline in sagegrouse no.s is not JUST habitat loss/change, it is habitat quality, predator control and birds of 

prey. Sagebrush needs to be disturbed, burned most likely. The govt. needs to tell the public that we can't have everything. 

If we have birds of prey and coyotes we most likely l won't have no.s of sagegrouse and other birds. If we want more 

sagegrouse, we need to improve the sagebrush habitat, not just lock it up and do nothing to it. And we need to reduce our 

predatory animals and birds. Can't have it all.

All Both emc0013GB

8. I am a plant ecologist with decades of field experience and the architect of a fair bit of revegetation including 

sagebrush-steppe. I believe that your ability to constructively change community structure or composition on a scale 

approaching significance at a regional scale is approximately zero. Work on the more easily manipulated factors including 

some I haven’t mentioned. Catering to permittees isn’t going to impress court review if it comes to that.

All Both emc0038GB

9. First, there is no shortage of sagebrush habitat in the west, which is the principle habitat for sage grouse. All Both emc0043GB

10. My point is: there is no shortage of sage brush habitat in the west! There are still hundreds of millions of acres of sagebrush 

in federal, state and private ownership throughout the west. Lets stop using a small decline in the sage brush type as an 

excuse for excessive bureaucratic regulations.

All Both emc0043GB

11. The second point I would like to make is that the sagebrush type has changed in the past 100 years. All Both emc0043GB

12. To bring the population back to somewhere near what it used to be, or at least is sustainable, I believe we should manage 

the sage type closer to its historical condition; that is, more open, with fewer and smaller sagebrush plants and more bunch 

grass and forbs. That can be done by mechanical means, prescribed fire, or sheep grazing, or some combination of all three. 

Budget-wise we cannot treat every acre of sagebrush in the west, but we can identify the core sagebrush grouse habitat and 

start there.

All Both emc0043GB

13. In summary, we have lots of sagebrush in the west, but it is not in an acceptable condition for sage grouse. We need to 

replicate the historic condition of sagebrush (ie, open stands of sage with grass and forbs in between the sagebrush). Do 

that, and I believe we will have viable populations of sage grouse for a long time to come.

All Both emc0043GB

14. Public lands are for public use, and that means public lands must be managed for multiple use. I am definitely in favor of All Both emc0043RM
C. Comments by Resource Planning Issue

C-1092 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

conservation measures for sage-grouse such as managing for sagebrush, water developments to improve habitat, proper 

planned grazing, etc. However, we must be careful to not manage the public lands for one species or one purpose. For 

example, to eliminate livestock grazing in favor of sage-grouse conservation would not only be a bad biological decision (i.e. 

poor plant health, increased fire risk, etc); it would also go against the basic theory of multiple use.

15. I will state state the Gage -Grouse will be listed as an endangered species soon because the BLM can not change any grazing 

or oil and gas practices. There is over 50 years of study on the decline of Sage-Grouse and Sagebrush and every grazing 

allotment and gas EA or EIS have been successful of leaving out all requirement for stubble height and Sagebrush 

requirement. For example the Monument Resource Management Plan had all stubble heights/sagebrush taken out of the 

document by the local county commissioner Carl Seilstad who strong armed t members of the BLM ID team developing the 

RMP for the Monument.

All Both emc0057GB

16. We advocate the creation of sagebrush reserves, preserving the best remaining habitat, and a voluntary program for 

ranchers to turn in their grazing permits in exchange for compensation paid for by conservation groups.

All Both emc0068GB, 

emc0020rm

17. This scoping is important to identify how intact, diverse and compromised sage-brush habitats need to be managed to 

enhance this resource’s ecologic sustainability that supports dependent species and provides the economic incentive for 

resident land stewards to remain engaged and on the landscape.

All Both emc0070GB

18. The most important issue to be considered by this scoping is a realistic long term management strategy that includes the 

players that are necessary to accomplish the task of enhancing the remaining sagebrush ecosystems on federal lands in the 

west. Management must be based on the site specific characteristics of each viable unit and the identification of short and 

long term management strategies to keep the resource sustainable. The key person in this process is a resource ecologist 

that understands the development stages of site specific sagebrush communities and what short term tools are needed to 

accomplish the changes necessary to keep the community productive and sustainable in the long term. This is complicated 

because of the differences in site conditions such as species of brush, forbs, and grasses, weeds, perennial grasses and 

encroachments of all kinds and vegetative thresholds that have been compromised.

All Both emc0070GB

19. The ability to actively manage the sagebrush ecosystem is the biggest challenge the agencies have. Noxious weeds and 

wildfire are two of the biggest threats to sagebrush habitats

All Both emc0070GB

20. As you scope the management of the sagebrush ecosystems in the west that support sagegrouse, be careful not to 

compromise the agencies’ responsibility and ability to continue developing scientific and object management strategies that 

promote the sustainability of this resource. The BLM and FS are responsible for the sustainability of the sagebrush 

landscape on federal lands. The landowner who uses the range resource as an economic unit provides most of the land 

management activity and funding. We must keep the sagebrush habitat in the west a working landscape to achieve adequate 

management of this resource. Be careful in this process. You can easily regulate the rancher and livestock off the western 

ranges. Will the regulations you devise to satisfy the FWS save the sagegrouse and keep the sagebrush ecosystem in a 

working landscape? The future of sustainable sagebrush ecosystems and their successful management is in your hands.

All Both emc0070GB

21. ISSUE: The proposed Conservation Measures fail to describe the crucial difference between sagebrush habitats that is in

good ecological condition vs. sagebrush habitat in poor ecological condition. All of the recommendations concerning 

managing or restoring the sagebrush habitat type talk about achieving a minimum 50-70% cover for the sagebrush. Some 

All Both emc0083GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1093

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

mention is made of sagebrush communities, but this is never described adequately, even in the Appendix. There can be two 

areas with the correct sagebrush species and minimum cover; one with the remaining 30-50% in quality grasses, forbs and 

other shrubs, the other with 30-50% bare ground and exotics such as cheatgrass. One will support healthy sage grouse 

numbers, the other won’t. It’s much stronger for a federal biologist to have this information in a nutshell in an LUP when 

persuading a manager or industry project proponent that all sagebrush or understory communities aren’t equal.

22. ISSUE: The proposed Conservation Measures fail to convey a difference in sagebrush habitat that is in good ecological 

condition vs. sagebrush habitat in poor ecological condition. See overview discussion.

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23. You probably heard all this before and that your not allowed to do it on the land. Twenty years ago Dr Alma Winward said 

to create sage grouse habitat ,get a fifth of wiskey and have a equipment operator drink it ,then get in a grader and plow in 

the sage brush in a mosic fashon or something that resembles a hoilstine cow. End result tour looking for is more 

grass,more woody plants with flowers .It just might bring more insects,young grouse need them to live.

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24. The preliminary statement in the four pages devoted to this factor, declares that ten percent of historic sagebrush range 

has been converted to agricultural use since the onset of EuroAmerican settlement. Edge effects entail an additional 

effective encroachment on sage grouse habitat, but bear tempering by anecdotal evidence of significant sage grouse 

persistence within active farmland near Ely, Nevada (Carpenter, 2012).

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25. Sagebrush growth and habitat rehabilitation takes time. Certainly more time than a couple of years allotted before listing 

the Sage Grouse as endangered. But if you don't start now it’s going to take a lot more time until you improve the habitat.

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26. We have witnessed ourselves the change in the habitat in the area. We feel many of those changes aren't all that has been 

blamed for the decline of the sage grouse. For some reason, the "experts" feel that more sagebrush is better for the survival

of the grouse. We feel that smaller areas of brush, around 30% mixed with clear grass areas, or farm areas support much 

larger populations of birds. We ride both horses and motorbikes frequently, and we witness the birds feeding out in the 

open and taking cover and nesting in the brush area, and that brush area is usually small brush, not old growth brush. Hence 

we feel fire areas, when they aren't too large, are very helpful to the birds. It provides them with fresh feeding areas. 

Conni's Grandfather said there didn't used to be any brush from Dubois to Medicine Lodge, but yet there were many 

grouse.

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27. Monitoring and reclamation will be a key component to the recovery of the sage-grouse. Increasing pressures on the 

sage-brush steppe continue to threaten the recovery of the sage-grouse: successful reclamation could successfully alleviate 

some of this pressure. The database recommended under the communications portion should include information about 

reclamation attempts including failures and successes. Each alternative should include a matrix describing thresholds at 

which more stringent management must be implemented.

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28. Conservation of sagebrush communities. The BLM has recognized the value of sagebrush communities to sage grouse and 

are now implementing practices to restore and enhance those areas. We encourage these practices to continue in 

partnership with landowners, livestock producers, and interested groups.

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29. As we all know if fire returns, you set your expectations back the similar number of years since the last fire or if they have 

occurred often enough, to the point it can't come back without significant human intervention and funds. Your impact 

section needs to address this clearly for the reader. It also needs to address the impacts of agencies planting sagebrush, the 

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C. Comments by Resource Planning Issue

C-1094 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

success they have had or not and issues about it and how to protect those new plants in the short and long-term from fire. 

Protection here is from subsequent fires that may kill plants or hinder their ability to reproduce.

30. Professional opinion is inadequate and should not serve as a substitute for intensive site investigations leaving BLM with an

arbitrary decision. Wyoming big sage communities and other sagebrush species vary in ecological potential due to moisture 

and soil differences in Oregon and the western regions. Allotments and pastures are a mosaic of sites located at different 

elevations on varying ecological surfaces. One size fits all prescriptions do not work and consideration of the variability 

of different areas should be identified.

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31. Treatment of decadent stands of sage brush in mosaic patterns is critical for sustainability of wildlife populations and range 

land health. Sage brush rangeland must be treated to preserve it for future generations. Several treatments exist for 

restarting the sage brush cycle including: fire, mechanical and chemical treatments. These three treatments should be used 

to treat sage brush, because each has its time and place·

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32. Professional opinion is inadequate and should not serve as a substitute for intensive site investigations leaving BLM with an

arbitrary decision. Wyoming big sage communities and other sagebrush species vary in ecological potential due to moisture 

and soil differences in Oregon and the western regions. Allotments and pastures are a mosaic of sites located at different 

elevations on varying ecological surfaces. One size fits all prescriptions do not work and consideration of the variability 

of different areas should be identified.

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33. In areas where sagebrush steppe has become fragmented by perennial grassland seedings, invasion of annual grassland 

following fire, agricultural development, or infrastructure development (including all transmission lines not just the larger 

ones and wind development) it will be important to develop ways to reconnect these fragmented sagebrush steppe areas. 

Understanding both how sage-grouse now use these areas as well as how they traditionally used them before 

fragmentation will be key to recovering sage-grouse. Therefore, all infrastructure development must be mapped and their 

management coordinated to prevent continued habitat fragmentation.

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34. Finally, I recommend that all sagebrush steppe, and perennial grassland and annual grassland adjacent to or surrounded by 

sage-grouse habitat be placed into an undetermined status and managed for sage-grouse. Some of these areas may be used 

by low numbers of sage-grouse now but become vitally important to sage-grouse in the future as populations recover. If we 

continue to exclude these areas it may become impossible to maintain a recovered greater sage-grouse species in the 

future.

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35. Please push back against those who would lobby for land use plans that would degrade the fragile shrub-steppe. All Both emc0183GB

36. I'm a big proponent of habitat enhancement for this bird species via prescribed burns that stimulate historic natural fire 

patterns, along with other measures, such as light-on-the-land, sustainable grazing methods (or complete cow restriction in 

some fragile areas). The type of land stewardship will of course also benefit many other native lifeforms in our region's 

sagebrush steppelands.

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37. Using state‐and‐transition models to link ecosystem function and sage‐grouse habitat management in southeast Oregon

Building on the above discussion we can think of different potential states for plant community composition within a 

particular elevation. For example, in low to mid elevation Wyoming big sagebrush habitat of southeast Oregon, potential 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1095

Scoping Summary Report

Table C-8.C

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states could include A) co-dominance by shrubs, perennial grasses and forbs with limited annual grasses; B) co‐dominance 

by perennial grasses, forbs and annual grasses; C) annual grass dominance, or D) co‐dominance of shrubs and annual 

grasses (Figure 2). Applying what we know of the ecology of these systems, we can begin to assign ecological processes and 

management practices to movement between states and the result might look something like Figure 2. Movement from 

one vegetation state to another is referred to as a “transition” and the variables causing that transition are known as 

“transition factors”. The model depicted in Figure 2 recognizes both passive transitions, which occur in the absence of 

management inputs, and active transitions, which require management input. The transitions associated with arrows 

moving away from a desired state represent threats to sage‐grouse habitat, while transitions associated with arrows 

moving from undesired to desired states represent conservation opportunities. By knowing the ecology behind these 

transitions, we can begin to partition how and where to focus limited management resources.

38. Professional opinion is inadequate and should not serve as a substitute for intensive site investigations leaving BLM with an

arbitrary decision. Wyoming big sage communities and other sagebrush species vary in ecological potential due to moisture 

and soil differences in Oregon and the western regions. Allotments and pastures are a mosaic of sites located at different 

elevations on varying ecological surfaces. One size fits all prescriptions do not work and consideration of the variability 

of different areas should be identified.

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39. Professional opinion is inadequate and should not serve as a substitute for intensive site investigations leaving BLM with an

arbitrary decision. Wyoming big sage communities and other sagebrush species vary in ecological potential due to moisture 

and soil differences in Oregon and the western regions. Allotments and pastures are a mosaic of sites located at different 

elevations on varying ecological surfaces. One size fits all prescriptions do not work and consideration of the variability 

of different areas should be identified.

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40. In addition, the list of "negative" aspects of herbivory does not recognize that many of these same conditions can be 

achieved in the absence of grazing. Plant dynamics of the various sagebrush ecological sites will result in shrub-dominated 

vegetation over time in the absence of disturbance. Therefore, the lateral cover necessary for nesting and the changes in 

sage-grouse habitat due to shrub-grass competitive dynamics create habitat conditions unfavorable to sage-grouse nesting, 

early brood habitat, and pre-laying habitat. While proper grazing management can be a beneficial tool, improper vegetation 

management can be a detriment to sage-grouse.

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41. Impacts from livestock grazing can be so great that the affected sagebrush system is often unable to be returned to an 

undisturbed state. This problem is compounded by the fact that restoration of sagebrush habitat by itself presents a 

challenge, and once alteration of vegetation, nutrient cycles, topsoil, and cryptobiotic crusts have exceeded recovery 

thresholds, restoration may be impossible. Even if restoration was more successful, however, true restoration efforts may 

take decades and thus often is considered cost-prohibitive.

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42. There are currently ongoing efforts to restore or rehabilitate sage-grouse habitats affected by invasive plants. Restoration, 

however, can be complex, expensive, and sometimes unsuccessful. Where restoration is possible, it can often take decades 

or longer to see results. Because meaningful restoration must include large expanses of sagebrush habitat, it requires 

partnerships across multiple landowners that are sometimes difficult to form.

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C. Comments by Resource Planning Issue

C-1096 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

43. We have successfully implemented cool season burns, chemical, mechanical treatments to thin brush and release 

herbaceous vegetation (Danvir 2005). The overall effect is early seral openings in a sagebrush sea. Hunnicutt 1992 clearly 

showed that hens selected nest sites in homogeneous sagebrush patches at least 300m in diameter for nesting, but 

immediately moved broods to highly heterogeneous areas having an interspersion of sagebrush cover and grass-forb 

dominated feeding areas. Pronghorn populations (Aoude and Danvir 2002) showed similar production and population 

increases.

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44. Sage-grouse habitat is much of the sage brush dominated areas of North America. To classify areas of the west as general 

habitat and restrict the problem to anthropogenic related causes is an over simplification of management issues. We are 

concerned that it could lead to restrictions of extremely large portions of the public lands resulting in denied access.

All BLM emc0313GB

45. Sage-grouse are a group of three separate species of grouse dependent, at least in part, on sagebrush ecosystems in the 

Western United States. As these ecosystems/habitats differ widely across the entire range, and even more so over the 

historical range, understanding their function is imperative in any plan or strategy to help protect, or enhance them. Other 

species of wildlife are also dependent on the same rangeland, and are further reason that single-species management, in lieu 

of ecosystem management for all species, should not be the management criteria for all dependent species. Sage grouse and 

related species also cross all classes of land ownership, and management. An all lands strategy should be implemented for 

the protection of the species, economic activities, dependent communities, and rangeland health.

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46. The historic ranges of all three sage grouse species, which require sage/steppe ecosystems for optimum survival have been 

reduced and/or fragmented primarily through land use changes on a landscape scale. Non-compatible land uses further 

effect sage grouse habitat, annual life cycle movement, and support.

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47. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: -

Vegetation structure and composition in the sagebrush ecosystem have undergone major changes since European 

settlement in part due to humaninduced changes in fire regime

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48. Doherty (2008:51, internal citations omitted) pointed to the potential adverse impacts of sagebrush removal projects, 

stating “My results indicate habitat treatments in the PRB should avoid removing areas with high-density sagebrush,” 

further noting, “Many papers indicate that sagebrush removal can adversely impact sage-grouse, but there appears to be no 

peer-reviewed research showing that burning, spraying, or mechanically removing sagebrush has substantial positive 

impacts to grouse.”

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49. Off-site mitigation is no substitute for on-site habitat conservation A great many vegetation manipulation projects are 

being undertaken in the name of sage grouse habitat improvement. In Wyoming, some of the more widespread programs 

are being undertaken by sage grouse Local Working Groups, the Wyoming Landscape Conservation Initiative (a federal 

project), the Sagebrush Conservation Initiative (an industry initiative), the Jonah Interagency Office (a joint 

industry/government operation), and the Wyoming Wildlife and Natural Resource Trust Fund (funded through the state 

legislature). These projects are being pursued in the name of maximizing the number of acres treated for sage grouse (and 

often more primarily, livestock) benefit, without regard to whether the vegetation manipulations undertaken improve sage 

grouse habitat in the short or long term, result in short-and/or long-term impacts to sage grouse habitats and populations, 

or have no effect at all.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1097

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

50. We are concerned that many, if not most, of these projects are actually harming sage grouse habitat in the long term and 

that the remainder will cause short-term impacts to sage grouse populations that contribute to the multiple serious threats 

to their existence. The scientific basis for many such projects (which include prescribed burns and mechanical or herbicidal 

thinning or removal of sagebrush) is extremely shaky, and given the lack of familiarity of the project proponents with basic 

sage grouse habitat requirements, such projects may unintentionally cause additional damage to sage grouse habitats. The 

impacts of such projects are starting to be rigorously tested, and in general they have been found to have long-term 

negative consequences for sage grouse. Holloran and Belinda (2009) was able to document negative impacts of sagebrush 

removal projects in the Bighorn Basin at very low levels of disturbance (less than 3.5% of the overall landscape). According 

to Rhodes et al. (2010), prescribed fire results in a loss of sagebrush cover, but also an increase in perennial grasses and 

invasive forbs, while native forbs did not increase in yield or nutritional value as a result of burns. Beck et al. (2009) found 

that some important features of sage grouse habitat did not recover to pre-burn levels even after 14 years post-fire. Beck 

et al. (2011) surveyed a number of rigorous tests of the effects of prescribed fire on sage grouse habitats, and 

recommended against burning in Wyoming big sagebrush habitats and observed that only limited short-term value in 

burning mountain big sagebrush. “In particular,” concluded these researchers, “prescribed burning leads to a pronounced 

negative response in sagebrush cover that lasts for at least a few decades.” Rhodes et al. (2010) concluded, “prescribed fire

will not improve habitat characteristics for sage-grouse in Wyoming big sagebrush steppe where the community consists of 

shrubs, native grasses, and native forbs.”

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51. BLM needs to rigorously evaluate all sagebrush habitat treatment projects to determine how exactly they will impact sage 

grouse populations prior to counting such projects as assets toward sage grouse recovery or threats to sage grouse 

persistence. The parameters of these projects should be compared to scientifically established habitat requirements for the 

grouse: for example, is thinning being implemented in sagebrush stands that exceed the canopy cover preferences of grouse 

for that type of habitat, or is canopy cover already optimal or too sparse for sage grouse habitat needs? According to one 

WAFWA commentor, “Some of these proposals are of questionable value, and may actually be detrimental, in terms of 

impact on sage-grouse conservation” (WAFWA 2006b:13). BCA received a funding proposal from the Bighorn Basin LWG 

for sage grouse thinning and removal, which proposed to remove sagebrush from stands already at 15% canopy cover, the 

lower edge of sage grouse habitat preference. An independent expert evaluated the proposal and found it to be 

counterproductive for the needs of sage grouse. We suspect that many (if not most) such habitat enhancement projects 

are also prescribing treatments which will harm rather than help sage grouse habitat quality, but instead of being vetted by 

review from independent scientists, they are proceeding forward in the absence of any critical evaluation of their end 

effects. Braun et al. (2005) and Rowland (2004) provide basic reviews of sage grouse habitat requirements from a vegetative 

perspective. The most frequently cited “study” used to justify such projects is an unpublished report prepared for the 

Deseret Land and Cattle Company, which notes positive results for sage grouse but which lacks either spatial or temporal 

controls to determine whether sage grouse population response was the result of the treatment applied or a happy 

circumstance of climactic conditions that would have produced sage grouse population growth in the absence of habitat 

manipulation. In any case, the Deseret Ranch example is part of a very costly and intensive combination of mechanical and 

grazing treatments; this ranch (unlike most rangelands in the sage grouse range) is not being managed to maximize livestock 

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C. Comments by Resource Planning Issue

C-1098 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

production, but instead trophy elk hunting is the primary management priority (Clait Braun, pers. comm.). Sagebrush 

“enhancement” projects being implemented across the range if the sage grouse are not replicating all aspects of the 

Deseret program.

52. Prescribed fire is commonly employed putatively to improve sage grouse habitat (such projects are often supported by 

livestock operators, who typically are primarily concerned with eliminating sagebrush with the misguided belief that this 

will result in a net increase in forage for livestock). For instance, the Upper Snake LWG reported that the 1,100-acre 

prescribed burn in the Cherry Creek watershed would benefit sage grouse by improving brood rearing habitat. Sagebrush 

recovery following such fires takes decades, and can take more than 100 years, causing an immediate reduction in habitat 

effectiveness for sage grouse in pursuit of some eventual increase in habitat effectiveness at some point in the (distant) 

future. The net result is that immediate welfare of the sage grouse today is being mortgaged for eventual habitat 

improvements that are speculative at best. However, unlike pheasants, sage grouse are known to respond poorly if at all to 

habitat enhancement projects.8 In the WAFWA forum participants noted, “It’s important for people to understand that 

if we are doing habitat projects, it often takes a matter of 10, 20, even 30 years to restore shrub habitat. Habitat treatments 

that put money on the ground today are speculating on the long-term success of the treatment, and of the sagegrouse 

response to those treatments. So we’ll have to find a way to figure this much longer time frame into our calculations” 

(WAFWA 2006b: 13). In the absence of rigorous scientific evidence supporting the translation of habitat enhancement 

projects into increased sage grouse population numbers, the BLM should not consider such projects under its RMPs.

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53. The role of fire in the sagebrush ecosystem, and how (or if) it drives the patch dynamics of the system, is poorly understood 

at present. A landscape mosaic of burns may not meet the nesting habitat needs of sage grouse (Nelle et al. 2000), and may 

also fail to meet grouse habitat requirements during other seasons (Wamboldt et al 2002). Large fires of high frequency can 

extirpate sage grouse populations (Pedersen et al. 2003). In Idaho, reduction of 57% of sagebrush canopy cover resulted in 

sage grouse population reductions (Connelly et al. 2000b). Thus, it is far from clear that projects which reduce sagebrush 

density or extent actually benefit sage grouse in the short or long term.

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54. Many sagebrush “control” projects are undertaken based on the perception that sagebrush stands that are dense or tall 

produce less forage for livestock and also are poor sage grouse habitat; these habitats are based on entrenched myths that 

conflict with the scientific evidence at hand (Welch and Criddle 2003). Cooper et al. (2007) found no increase of desirable 

forbs for sage grouse following prescribed fire, but did find a significant increase in exotic forb and grass species following 

burns.

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55. Once sagebrush is eliminated from the landscape through habitat projects, its recovery can be problematic. 

Re-establishment of big sagebrush is particularly problematic, as drought stress is particularly acute and seedlings may only 

become established in unusually wet years or microhabitats. (Lysne 2005, Shaw et al. 2005). While Beck and Mitchell (1997) 

recommended against sagebrush control projects when canopy cover is less than 20 percent, and recommend against any 

sagebrush control within 2 miles of leks, projects have been put forward in the name of habitat improvement when canopy 

cover is less than this threshold, and where the proposed treatment is closer to lek sites.

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56. And a basic question: Where was sagebrush present at the time of the older Plan RODs compared to the present? Where 

did BLM treat lands for forage, fuels, other purposes and what is their condition now? What existing treatments or seedings 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1099

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

had been identified in LUPs, and what is their condition now? Following fire: Where, when and how did BLM 

rehab/restore/treat sagebrush under the Plan? Detailed mapping and analysis must be provided. Where was cheatgrass 

present, and in what percentage cover? How has this changed in both burned and unburned lands? How soon did BLM 

allow livestock grazing to disturbance to resume following fire rehab, and what was the outcome? A solid baseline must 

include all of this type of information.

57. Agency manipulation (“treatment”) of sagebrush that is aimed at altering, reducing, and/or destroying sagebrush in anyway 

must be prohibited in the Interim until agencies fully and fairly evaluate the impacts of all that has been done in the past, as 

well as in recent years. Tens of millions of acres have been altered in the past, continuing up to 2012. Many of these sites 

are undergoing weed invasion, and claimed benefits to sage-grouse are simply not materializing. They have reduced and 

fragmented sagebrush habitats. The BLM’s efforts (and other agencies including the Forest Service funding of tens of 

millions of dollars through the USDA) in continuing the public land livestock industry’s War on Sagebrush must be ended. 

See Rachel Carson, Silent Spring description of the aerial herbicide War on sagebrush, Braun 1998, Welch and Criddle 

(2003), Connelly et al. 2004, and many recent studies showing few if any positive benefits for sage-grouse of removal of 

sagebrush, and many negative effects.

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58. Under fire prescriptions that minimize undesirable effects on veg or soils (i.e. minimize mortality of "desirable" plant 

species). an ID team #4 is just Standard Operating procedure. BLM is supposed to have been following #5 all along, and has 

failed to do so. "Where applicable" incorporate roads as fuelbreaks. These are all standard operating procedure, or

common sense. The overarching problem here is the continued effort by BLM to justify burning, mowing, herbiciding and 

otherwise altering and destroying sagebrush habitats. Long-term habitat losses and weed invasions are the regrettable 

consequences of BLM continuing current ineffective SOPs - which is really all Appendix F of the NTT contains.

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59. Dead sagebrush provides less shading cover to help hold moisture on-site longer. It is reasonable to assume that areas with 

significant dead sagebrush dry out sooner, and be hotter and drier sites more prone to cheatgrass invasion. Especially in the 

case of chronic grazing disturbance continuing to disturb microbiotic crusts and understories in these same areas. There is 

the combined effect of a reduced ability of the systems to hold moisture on site due to loss in effective shrub cover coupled 

with continued grazing disturbance.

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60. Only by requiring the strongest protective measures when considering new development proposals in sage-grouse habitat 

will you be able to ensure survival of this spectacular species. To that end, I ask that you require the following conservation 

measures in the relevant Resource Management Plans and Land Management Plans. - Identify and protect important and/or 

intact greater sage-grouse habitats and identify locations of priority areas on which to focus conservation actions to 

maintain the function of sagebrush ecosystems (priority sage-grouse habitat).

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61. Identify and protect important and/or intact greater sage-grouse habitats and identify locations of priority areas on which 

to focus conservation actions to maintain the function of sagebrush ecosystems (priority sage-grouse habitat).

All Both flb0000gb and rm

62. Sage brush is evident and we understand that new growth on sagebrush is their primary food source and it is critical to a 

thriving Sage Grouse population. Research data has demonstrated that vegetation management practices that stimulate 

new growth of sage brush are responsible for dramatic increase in grouse population. We request that this condition be 

attained through grazing, where possible, and with other mechanical or chemical methods as alternatives for old growth 

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C. Comments by Resource Planning Issue

C-1100 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

sagebrush.

63. Many sage grouse studies do not include the subspedes, or even species, of sagebrush studied (Rowland and Wisdom 

2002). Vegetation and wlldlife researchers should record the ecological gite and current vegetation state in fueir research 

reports. This will allow us to extend results to the appropriate sites_

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64. Recent studies, sueh as those in Knick and Connelly (2011), have modeled and mapped sagebrush habitklts across 

landscapes. However, there are no landscape approadles to restOJing sagebmsb habitats. If the public decides to restore 

these areas, we mm:t be able to map and understand the pattern of different ecological sites across landscapes and to

develop techniques for restoring these siteslhut are cost-etfective. The sugge~iion of "restoring sagebrush habitats" 

without consideration of the cost is both impractical and imprudent. For example, BLM may have the technology to 

convert a lTIonoculture of a perennial grass like crested-wheat grass, to a mix of native perennial gra~s, forb, and shrub 

species, hut the question is, is it worth the cost and time to do so, particularly given the $15 trillion dollar deficit that the 

United States cnrrentiy has? In n.early every ca')e, we contend the answer is "no"_ BLM must balance these cost 

considerations in its analysis of "regtoring sagebrush habitats".

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65. Sagebrush and sagebrush-grassland habitats provide important food and cover values for sage grouse and other wildlife. Big 

sagebrush was common on western rangelands prior to man's settlement and is climax dominant on much of Montana 

rangeland. The species is successfully reproducing and sustaining itself. Grass and forbs exist with sagebrush in a 

multi-storied plant community. On properly managed rangelands, grasses can increase under sagebrush canopies. 

Sagebrush stands are an important facet of diverse habitat landscapes that can include grasslands, riparian areas and timber 

stands for example. Keys to management of sagebrush and sagebrush grassland habitats are maintaining expansive stands 

of sagebrush especially varieties of big sagebrush with abundant forbs in the understory, particularly during spring; 

undisturbed and relatively open sites for leks; and healthy perennial grass and forb stands intermixed with sagebrush for 

brood rearing. Within suitable habitats, areas should have 15 to 25% canopy cover of sagebrush 30 to 80 cm tall for nesting, 

and 10 to 25% canopy cover from 40 to 80 cm tall for brood rearing (Connelly et al. 2000). A Montana study showed 27% 

canopy cover to be the most successful for sage grouse. In winter habitats, shrubs should be exposed 25 to 35 cm above 

snow level and have 10 to 30% canopy cover exposed above snow. In nesting and brood-rearing habitats, understory 

habitats with adequate cover of grasses (>15%) and forbs (>10%) at least 18 cm tall are needed (Connelly et al. 2000).

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66. Livestock grazing is compatible with sage-grouse where the habitat characteristics needed for breeding and wintering can 

be consistently maintained. It is paramount that only light grazing be permitted on important sage grouse wintering areas, 

because during winter, sage grouse often use tall, dense stands of sagebrush which remain relatively exposed through deep 

snow. Light grazing produces mosaics in vegetation and an increase in herbage production that are favorable for 

Sage-Grouse nesting and brood-rearing habitat. Riparian areas and wet meadows used for brood rearing are especially 

sensitive to grazing by livestock. Protecting sage grouse nesting and brood-rearing habitat from livestock use also 

encourages climax vegetative conditions. If this is not feasible, limit grazing to the month of July. Defer grazing until after the 

peak of the growing season with the intent of providing herbaceous cover and forage for the majority of the nesting, 

hatching, and early brood-rearing. Cessation of grazing by 1 August is designed to minimize livestock concentrations in wet 

meadows and riparian areas with open water by avoiding "hot season" use and to allow a 30-day regrowth period before 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1101

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

the first killing frost. Additionally, late summer-early fall regrowth is important for carbohydrate storage in roots and stem 

bases of cool season grasses. This enhances plant vigor while allowing residual vegetation to accumulate cover for nesting 

and early brood-rearing the following spring.

67. Data shows that successful grazing systems were found to have significantly (p=0.01) less grazing during the ''hot season'' 

(July through early September) (12.5 d) than unsuccessful systems with 33 .4d. Likewise, the duration of all livestock 

treatments was significantly (p=0.001) shorter in successful systems (28.2d) compared to 59.3 d in unsuccessful systems. 

Given the reluctance of cattle to disperse from riparian areas, the duration of grazing treatments becomes a key factor in 

determining the severity of impacts such as trampling and mechanical damage, soil compaction, and utilization. A 

combination of longer duration and more frequent fall grazing deteriorated woody species vigor and regeneration, 

contributing to diminished floodplain function and reduded riparian dependent values.

All Both rmc0024GB

68. Also, during times of drought, cattle are attracted to moist areas. Failure to adequately manage for these periods may result

in greater impact in the form of reduced vegetative cover. Brood-rearing habitats for sage-grouse are typically mosaics of 

upland sagebrush and other habitats (e.g., wet meadows, riparian areas) that together provide abundant insects and forbs 

for hens and chicks. Although the adult diet switches to forbs and insects in addition to sagebrush, developing young 

depend heavily upon insects for food.

All Both rmc0024GB

69. Have quantifiable data collected that shows there is adequate canopy cover of sagebrush (height and percentage of cover) 

-27% canopy cover appears to be the most successful in Montana. This canopy cover must be contiguous.

All Both rmc0024GB

70. ( b) Sage Brush Types: Sage brush is site specific. There are sites where it can't be eliminated. If burned, it will return 

stronger than ever (usually Mountain Big Sage). There are sites, that when burned, especially repeatedly, result in a total 

loss of sage brush, (usually Wyoming Big Sage), and there are sites in the middle of these extremes. Understanding sage 

brush and how it responds or fails to respond to rehabilitation and management is only half of the picture. Probably more 

important is to know what sage grouse prefer or require over a full year period. Past efforts such as twelve years of work 

by the "Nevada Page 14 Governors Team" for Sage grouse should be salvaged and updated as a starting point.

All Both rmc0057GB

71. Pages 16 and 17 in the NTT report suggest that BLM only allow treatments that conserve, enhance or restore sage-grouse 

habitat. An analysis should be conducted to evaluate the need for age-class diversity in sagebrush communities. We also 

request that the BLM consider allowing other treatments that are designed to achieve alternative objectives as long as they 

do not negatively impact sagegrouse habitat. Page 26 recommends that fuels management allow no treatments in winter 

range. Recommending no treatments in winter range is not realistic for PPH in the North Park basin.

CO BLM emc0060RM

72. I think that we need to be able to do sage brush treatments. This will enhance and or restore sage grouse habitat and keep 

the grass in good health for grazing.

CO Both emc0077RM

73. The desire to manage ecological sites so they are within the reference state is not an achievable goal at the landscape scale. 

The reference state of ecological sites typically is a mid to early late seral state of the vegetation, along the continuum of 

early to later seral composition. On sagebrush-grass rangelands in the Great Basin, the reference state of most sagebrush 

ecological sites is approximately half shrub (mostly sagebrush) and half perennial herbaceous (mostly grasses). Sagebrush 

does not sprout and can take years to re-establish after a fire or other large scale disturbance (e.g. aroga moth); thus, large 

areas of perennial bunchgrasses are possible and should be expected. Since it is impossible to remove natural disturbances 

GB Both rmc0076gb
C. Comments by Resource Planning Issue

C-1102 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

from the sagebrush system, attempting to keep all areas at the reference state is impossible. The goal should be to manage 

the soil-vegetation complex so that post-disturbance succession always has the ability to move toward and achieve the 

reference state. Management of areas that have progressed too far down the successional scale (moving toward poor 

resilience - too few perennial grasses) also should not be mandated for return to only the reference state conditions. That 

can be costly and such states may be short-lived in productive areas. Patch size and shape are important, and perhaps more 

important than trying to keep the majority of the landscape at the reference state

74. BLM provided no map that showed the historic extent of sagebrush habitat in Idaho (or western Montana). In order to 

understand the degree and severity of sagebrush and sage-grouse habitat and population loss, thorough and detailed 

mapping of all historic sagebrush habitat is necessary. The changes that occurred over time must be displayed. This is 

essential to show how the Priority habitat scheme slices off a considerable amount of what remains of the already greatly 

reduced habitat. We note that at least one isolated population of sage-grouse in western Montana appeared missing from 

BLM mapping entirely.

IDMT BLM emc0411GB

75. NDOW White Paper March 2012: The paper describes the five categories of habitat, plus non-habitat. It has no category 

for historical habitat that has been lost. At a minimum, habitat of moderate importance and transitional range, as well as low 

value habitat that has mature or old growth sagebrush present, must be included as high value, or key, habitat. It is of great 

concern that human land-use development will be allowed to proceed, but detailed site-specific studies are not required. 

While sage-grouse may be broadly distributed, the habitat is peppered with holes, and often is highly degraded as well. 

There is extensive natural fragmentation all the Great Basin mountain ranges as well as salt desert habitats in valley 

bottoms. On top of this is a plethora of livestock, mining, energy, agency treatment, and fire disturbance adversely 

impacting remaining habitat quality and quantity. While sage-grouse may be considered an umbrella species by some, in 

Nevada the agency attitude (for example Ely BLM and ag interests supporting ranchers who seek continued destruction of 

sagebrush) towards mature and intact sagebrush communities is causing big leaks in the umbrella. In fact, the umbrella is 

collapsing in many areas as cheatgrass and other weeds sweep Ely treatments claimed to be for sage-grouse. Sage-grouse 

are being used as an excuse to radically alter sagebrush, and destroy old growth and mature pinyon-juniper as well as trees 

re-colonizing historic ranges. In fact, the Ely RMP proposes manipulation of fully 2/3 of the native vegetation communities 

an action likely to result in tremendous desertification and habitat loss for both sagebrush and pinyon-juniper dependent 

species. We are concerned that the NDOW report claims sage-grouse are an umbrella species for the pygmy rabbit when 

in fact, NDOW will promote Ely and Elko BLM and Forest Service projects like in the Santa Rosa RD projects that 

purposefully alter, reduce destroy denser sagebrush required by the pygmy rabbit. This is in part justified by claiming that 

sagebrush with good microbiotic crust understories and denser Wyoming sagebrush cover is somehow deficient based on 

biased soil inventories and then added onto this are claims that the community is decadent and only destroying it will 

somehow save it. When in fact, these are very important habitats that often support high densities of pygmy rabbit, sage 

sparrow, etc. NDOW also supports (as in the Montana Mountains) band-aid fencing projects of riparian or stringer 

meadow areas rather than an integrated hard look at livestock impacts. For sage-grouse in Nevada to be an umbrella 

species, NDOW needs to start sticking up for wildlife values, and not taking the easy route out by endorsing projects that 

alter sagebrush, destroy it in the process of a general purging of trees, or that serve to shift and intensify harmful livestock 

NVCA BLM emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1103

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

impacts in other areas as the agency currently is doing.

76. The NDOW paper mentions the 35-100 years for possible recovery of mountain big sagebrush communities, It does not 

mention the much longer sagebrush community return intervals for low sagebrush, black sagebrush, and Wyoming big 

sagebrush i.e. intervals of 100-200 years or more. It is critical to state this as it shows how very long it will take for full 

recovery, and highlights the critical importance of taking the best possible care of remaining unburned sagebrush 

communities. It also shows that mitigation is often not possible.

NVCA Both emc0411GB

77. NDOW makes assumptions about understory recover – but fails to consider recovery of understories if passive 

restoration was allowed to occur, and livestock grazing disturbance and impacts were removed. It is not acceptable for 

agencies assume that the only way to “improve” conditions is to radically alter, reduce and kill sagebrush. Removal of 

livestock provides for passive recovery, helps prevent cheatgrass and weed increase and expansion, and helps protect 

structural integrity of sagebrush that ids in providing winter habitat as well as nesting cover.

NVCA Both emc0411GB

78. We are glad to see NDOW admit that understory composition is difficult to identify using ESI and soil survey info, and “the 

accuracy of the R-1 and R-2 classifications was variable. We are very concerned that NDOW will support federal agencies 

writing off habitat because it does not contain ideal nesting characteristics but may be important in winter, and be the best 

remaining nesting habitat, or receive significantly less livestock disturbance during nesting, all of which may serve to make

these sites very important habitats of high concern.

NVCA Both emc0411GB

79. We support the idea of linking management of ecological processes to improved long-term quality and abundance of 

sage‐grouse habitat. To that end we propose that BLM and USFS begin their National Sage‐Grouse Planning Strategy by 

assembling state‐and‐transition models that broadly describe sage‐grouse habitat, and the ecological and management 

factors which influence change. This need not be an overly detailed exercise; for example, a generalized model for 

Wyoming big sagebrush would be pertinent to tens of millions of acres of sagegrouse habitat. These generalized efforts 

could then be linked to more specific models at state and local levels that would serve as working blueprints to promote 

actions which cause plant communities to move in a direction consistent with sage‐grouse habitat management objectives. 

We have appended a list of references which we feel encapsulate the breadth of what we know, don’t know, and need to 

know regarding the ecology and management of sagegrouse habitat throughout the range of the species. These references 

(and references cited therein) could be used as building blocks to construct and/or reinforce an ecologically‐based

approach to management of sage‐grouse habitat that recognizes both the complexity of ecosystem challenges as well as 

opportunities for iterative improvement of sage‐grouse habitat resources.

OR Both emc0192GB

80. In Figure 1 we depict management issues impacting Oregon sage-grouse habitat along a continuum from low to high 

elevation. From this figure we can begin to construct management priorities. The first priority is to avoid state‐level 

changes in acceptable habitat (i.e., habitat “conservation”), given that this is generally the most cost effective, highest 

probability management approach. The second priority would be to restore non‐intact plant communities.

OR Both emc0192GB

81. Of those plant communities in need of restorative treatment, the higher elevation mountain big sagebrush plant 

communities are generally the most productive expenditure of logistical and capitol resources. This is because these 

systems have relatively high resource inputs (i.e., precipitation) and are thus more resilient (i.e., more likely to return to a 

OR Both emc0192GB
C. Comments by Resource Planning Issue

C-1104 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

desirable state with a given amount of management input).

82. In lower elevation sagebrush plant communities, the dominant restoration problem is that of invasion by non‐native annual 

grasses such as cheatgrass. Once these species reach a threshold level of abundance, change back to a more desirable state 

is difficult because a) annual grasses promote increased fire frequency that is not conducive to maintenance of perennial 

vegetation and b) our ability to establish desired perennial vegetation from seed is severely limited at present. Restoration 

in low elevation annual grass-invaded sagebrush plant communities is most limited by a lack of knowledge regarding proper 

restoration techniques for re–establishing desired perennial vegetation, as opposed to capitol limitations at higher 

elevations

OR Both emc0192GB

83. The take‐home point in the above discussion is that invasion of exotic annual grasses and encroachment of juniper 

represent the largest threats to sage-grouse habitat in Oregon (Hagen 2011).

OR Both emc0192GB

84. While management options exist for juniper-dominated sites, annual‐dominated plant communities are nearly impossible 

to restore with current restoration technologies. Thus, preventing transition to annual grassdominated states should be a 

high management priority in Wyoming big sagebrush habitats.

OR Both emc0192GB

85. The Oregon sage-grouse strategy (Hagen 2011) broadly classifies suitability of potential sagegrouse habitat based on 

canopy cover of sagebrush and, to a lesser extent, associated understory herbaceous vegetation. Using this system, habitat 

with < 5% sagebrush canopy Shrubs Forbs Perennial grasses Some annual grasses Shrubs Forbs Perennial grasses Annual 

grasses Annual grasses only Shrubs Forbs Perennial grasses Annual grasses A B C D t3 t2 t1 t4 t5 t6 t7 t8 t1 = Periodic fire

t2 = Seeding or transplant of desirable shrub species t3 = Lack of fire over time with sufficient seed source for shrub 

population expansion t4 = Increased fire t5 = Use of fire to create bare ground for application of pre‐emergent herbicide 

followed by seeding of desirable perennial grasses and forbs t6 = Fire t7 = Abusive grazing t8 = Mechanical shrub reduction 

with seeding of desirable grasses and forbs 5 cover is considered non‐habitat and areas with > 5% sagebrush cover are 

considered sagegrouse habitat. Within the “habitat” category, year‐round habitat is characterized by a complex vegetation 

structure, while those sites with less diverse structure can be thought of seasonal habitat. Applying this concept to Figure 

2, state “C” is non‐habitat, state “A” is year‐round habitat, and states “B” and “D” are seasonal habitat (e.g., State B may 

provide habitat for brooding and nesting but lacks sufficient sagebrush cover for winter habitat, while state D may lack 

sufficient herbaceous cover for nesting and brooding but provides ample sagebrush for winter habitat). While Figure 2 

applies specifically to low elevation Wyoming big sagebrush plant communities, a similar technique could be used to model 

vegetation dynamics and management actions in higher elevations communities. The acceptable landscape‐scale ratio of

suitable habitat (which includes both year‐round habitat and seasonal habitat) to non‐suitable habitat has been addressed 

via the State‐level planning effort in the Oregon sage‐grouse strategy (Hagen 2011).

OR Both emc0192GB

86. Hard winters are a fact of life. There are times that the snow is so deep there is no protection from predators for the sage 

grouse. The sagebrush in several areas of the state is not tall but will protect sage grouse during most normal winters.

WY Both emc0050RM

87. BLM’s indirect effects section should consider impacts and benefits to other sagedependent species The decline of the 

greater sage-grouse is just one symptom of a much larger problem – the decline of the sagebrush ecosystem. Sage-grouse 

is just one of many species that uses the sagebrush habitat and it has been used an indicator species of sagebrush ecosystem 

WY BLM emc0129RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1105

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

health. See, e.g. Steven E. Hanser and Steven T. Knick, Greater Sage-Grouse as an Umbrella Species for Shrubland Passerine 

Birds: a Multiscale Assessment, ECOLOGY AND CONSERVATION OF GREATER SAGE-GROUSE: A LANDSCAPE 

SPECIES AND ITS HABITATS, USGS, Nov. 2009, at 18: (“Management to benefit Greater Sage-Grouse may benefit the 

broader community of birds that use sagebrush steppe habitats”). Sagebrush ecosystem conservation may also benefit 

sage-dependent large game like pronghorn and mule deer. BLM should disclose the indirect benefits (or impacts) of its 

proposed action and alternatives on other species and the sagebrush ecosystem itself.

88. 1) Manage vegetative communities to provide for nesting and early brood rearing, late brood rearing and winter habitat. 

Conduct landscape-scale analysis when evaluating sagebrush habitat for management needs and potential treatments.

WY USFS emc0144RM

89. 6) Promote healthy sagebrush communities with native species diversity. WY USFS emc0144RM

90. 7) Restore degraded or disturbed sites to native vegetation including sagebrush and native forbs. WY USFS emc0144RM

91. Doherty et al. (2008) found that sage grouse in the Powder River Basin selected sagebrush stands that were large and 

unfragmented by development, on gentle topography. Additionally, sage grouse use stands of taller sagebrush, as sagebrush 

that protrudes above the snow is the key winter food source. Such stands of taller sagebrush are often viewed as 

“decadent” by range managers and targeted for sagebrush “control” projects. Doherty et al. (2008) concluded, “As 

remaining winter habitats are developed, and sage-grouse can no longer avoid CBNG, it is unclear whether birds will be 

able to adapt to a disturbance of this magnitude.”

WY Both emc0343GB

92. We are concerned that many, if not most, of these projects are actually harming sage grouse habitat in the long term and 

that the remainder will cause short-term impacts to sage grouse populations that contribute to the multiple serious threats 

to their existence. The scientific basis for many such projects (which include prescribed burns and mechanical or herbicidal 

thinning or removal of sagebrush) is extremely shaky, and given the lack of familiarity of the project proponents with basic 

sage grouse habitat requirements, such projects may unintentionally cause additional damage to sage grouse habitats. The 

impacts of such projects are starting to be rigorously tested, and in general they have been found to have long-term 

negative consequences for sage grouse. Holloran and Belinda (2009) was able to document negative impacts of sagebrush 

removal projects in the Bighorn Basin at very low levels of disturbance (less than 3.5% of the overall landscape). According 

to Rhodes et al. (2010), prescribed fire results in a loss of sagebrush cover, but also an increase in perennial grasses and 

invasive forbs, while native forbs did not increase in yield or nutritional value as a result of burns. Beck et al. (2009) found 

that some important features of sage grouse habitat did not recover to pre-burn levels even after 14 years post-fire. Beck 

et al. (2011) surveyed a number of rigorous tests of the effects of prescribed fire on sage grouse habitats, and 

recommended against burning in Wyoming big sagebrush habitats and observed that only limited short-term value in 

burning mountain big sagebrush. “In particular,” concluded these researchers, “prescribed burning leads to a pronounced 

negative response in sagebrush cover that lasts for at least a few decades.” Rhodes et al. (2010) concluded, “prescribed fire

will not improve habitat characteristics for sage-grouse in Wyoming big sagebrush steppe where the community consists of 

shrubs, native grasses, and native forbs.”

WY Both emc0343GB

93. In Wyoming, Wyoming big sagebrush dominates the vast majority of sage grouse habitat throughout the state, both in the 

Wyoming Basins Ecoregion and on the Great Plains. Natural fire return intervals in Wyoming big sagebrush average 

WY Both emc0343GB
C. Comments by Resource Planning Issue

C-1106 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.C

Comments Related to the Vegetation on the Sagebrush Steppe

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

100-240 years (Baker 2007). Wyoming big sagebrush recovers slowly after fires, which typically result in 100% sagebrush 

mortality; recovery to pre-fire canopy cover takes over 100 years (Cooper et al. 2007). Baker (2007) examined the same 

issue and projected that Wyoming big sagebrush recovery following fire ranges from 50 – 120 years; for mountain big 

sagebrush, the recovery period was estimated at 35 – 100 years. Prescribed fire can result in a loss of sagebrush dominance 

for 25-45 years, and may also result in increased erosion (Sedgwick 2004). Cooper et al. (2007) projected the full recovery 

of Wyoming big sagebrush canopy cover would take 625 years based on their observed recovery rates following 

prescribed fire (a biologically improbable outcome), and no recovery at all was recorded following prescribed fire on 17 of 

24 sites. Close proximity to seed sources and moister conditions did not accelerate recovery in this study. These 

researchers concluded, “Wyoming big sagebrush recovery takes so long that managers considering prescriptive burns need 

to have a long-term view of the landscape before eliminating a sagebrush habitat that will not return for at least a century” 

(Cooper et al. 2007:12).
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1107

Scoping Summary Report

Table C-8.D

Comments Related to Special Status Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Please use range ecology science for restoring healthy native sagebrush and healthy native species understory rangewide! All Both cfc0022GB

2. Professional opinion is inadequate and should not serve as a substitute for intensive site investigations leaving BLM with an

arbitrary decision. Wyoming big sage communities and other sagebrush species vary in ecological potential due to moisture 

and soil differences in Oregon and the western regions. Allotments and pastures are a mosaic of sites located at different 

elevations on varying ecological surfaces. One size fits all prescriptions do not work and consideration of the variability of 

different areas should be identified.

All Both emc0179GB

3. The EIS and alternatives must analyze documented trends in pinion and juniper (PJ) succession on rangelands and sage 

grouse habitat including proposed measures to reduce aerial PJ extent and future migration. The EIS must also evaluate the 

impacts such efforts may have on other species of concern.

All Both emc0310GB

4. Sage-grouse populations are dependent upon healthy sagebrush ecosystems. Reclaiming or recovering sagebrush habitats is 

extremely challenging. The BLM and FS should direct efforts toward improving our ability to effectively reclaim degraded 

habitat, which requires gathering site-specific baseline (pretreatment) data to adequately evaluate success. Reclamation 

should be a mandatory stipulation for all development in sage-grouse habitat and managers must recognize that methods for 

achieving success vary by region and are site-specific. Reclamation efforts should be monitored and results maintained in a 

single database to improve public understanding and effectiveness of efforts. The agencies should establish a process to 

identify and address failed reclamation projects.

All Both emc0329GB

5. I definitely support protection of endangered or threatened plants and animals over domestic grazing. BLM land is for all 

citizens and should be managed primarily for ITS HEALTH.

All Both fld0007rm, 

fld0007gb

6. monitoring of sage grouse and sagebrush habitats: Monitoring is critical to assess whether public uses are meeting required 

population and habitat objectives, including those for Sage Grouse, whether restoration projects are effective or not and 

even whether our conservation efforts or objectives are adequate or should be changed. Yet, it is unclear how much 

monitoring is actually being conducted annually by the federal agencies on public lands and national forests. We know that 

state wildlife agencies conduct annual lek counts and wing collections after hunting seasons to assess population trends and 

Sage Grouse distributions, which may fluctuate annually due to weather and other factors and may be subject to cyclic 

influences. On the other hand, habitat status also fluctuates annually due to wildfires and weed invasions, grazing impacts, 

development impacts and over the long term due to successful rehabilitation and restoration projects. Unfortunately, 

monitoring is the first thing eliminated due to inadequate agencies' budgets. And, if not done and done properly, the lack of

monitoring results in the waste of habitat restoration funds and the undercutting of the agencies' Sage Grouse conservation 

strategies. The EIS should discuss how required agencies' monitoring can be accomplished and be reported effectively to the 

public every year. a. the agencies should acknowledge that monitoring does not simply consist of counting numbers of Sage 

Grouse projects, dollars spent, acres treated, with no quantification of benefits to Sage Grouse or priority habitats. b. the 

agencies should use monitoring to objectively evaluate the effectiveness of conservation measures and projects, both 

positive and negative. c. the agencies should use adaptive management to more closely match habitat improvement projects 

to projects which successfully meet population and habitat restoration objectives. d. the agencies' required monitoring 

should track sagebrush cover and maturity and the preservation of key seasonal habitats, including: 1. how did the plant 

communities respond 2. how response relates to structural and other habitat requirements 3. how Sage Grouse populations 

NVCA Both emc0283GB
C. Comments by Resource Planning Issue

C-1108 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.D

Comments Related to Special Status Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

respond 4. the collection of quantitative data over time required for substantial changes e. the agencies should require 

monitoring of projects both for site-specific results as well as PMU or regional results. F. the agencies should coordinate 

with state wildlife agencies to monitor responses of Sage Grouse populations and trends to habitat restoration projects. G. 

the agencies' should disclose in the EIS that funding for monitoring is not assured as it is subject to annual agencies' budgets.

7. We are very concerned about the following statement: PGH provides some benefit to greater sage-grouse populations but, 

in many instances, lacks a key component, such as adequate shrub height or density or sufficient herbaceous understory In 

fact, nearly all the lands in many Priority Habitat sagebrush communities. For example, vast areas of all the PMUs in

northeastern Nevada (Gollaher, Snake, O’Neil, North Fork, Tuscarora, Desert for example. If agencies are going to make 

this claim – which has long been an excuse used by Ely BLM and others to manipulate, alter, fragment and destroy sagebrush 

habitats critical to pygmy rabbit, sage sparrow loggerhead shrike, and sage-grouse, then all the data used in making these 

determinations in the mapping must be provided. Under this description,lands where Ely BLM treated by crushing and 

mowing sagebrush thus greatly reducing shrub cover would not be found suitable. Nor would the large areas of Elko BLM 

lands with a large amount of cheatgrass in the understory - such as in the Salmon River or Owyhee allotments that are 

mapped as being Priority habitat. There seems to be a high degree of bias and arbitrariness in how this was applied. Plus what 

this seems most aimed at is promoting massive treatment alteration and destruction of the expanses of intact little-weeded 

Wyoming big sagebrush communities that have good microbiotic crusts, but may have less grass/forbs than the idealized 

NRCS description. We are concerned that this description is being used to sacrifice occupied habitats to unlimited new 

industrial development as well as a likely battery of forage/fuels “treatments

NVCA Both emc0411GB

8. Even though the various R Habitat category values are described, NDOW later admits: Therefore, R-3 landscape patches 

should be evaluated on a case by case basis to determine the true potential for meeting future sage-grouse needs. A key 

component of high quality sage-grouse habitat is the understory composition of sagebrush communities (Connelly et. al. 

2000). The R-value mapping effort attempted to identify understory quality using the existing vegetation cover and the 

ecological site potential identified in the United States Department of Agriculture soil surveys. However, over the course of

this project, it was determined the accuracy of the R-0 vs. R-2 classifications was variable. Further refinement of the 

Sage-Grouse Map should include a more robust method for determining sagebrush understory composition and 

quality.Burned areas often dramatically alter the quality and composition of the landscape Where are the mature or old 

growth sagebrush communities in occupied sage-grouse habitat that are placed in this category? These are communities that 

in periods of extreme winter weather may be essential for sage-grouse survival. They are also critical to a host of other rare 

and declining wildlife species.

NVCA Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1109

Scoping Summary Report

Table C-8.E Comments Related to Forestry

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

1. As usual the BLM and USFS will propose an alternative to "remove encroaching conifer trees on sage-grouse habitat." The 

strategy must not include commercial logging. There are thousands of square miles of suitable habitat. The USFS thinks all 

ecosystem problems (real or concocted) can best be solved by commercial logging.

All Both emc0016GB

2. OFS is concerned that protection measures could severely limit the ability of farmers and foresters to effectively manage 

their lands.

All Both emc0221GB
C. Comments by Resource Planning Issue

C-1110 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.F

Comments Related to Wetland and Riparian Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Water can be a critical factor in determining the abundance and distribution of wildlife, especially in arid western ecosystems; 

although the impacts vary by species, habitat, and season. Over the past 150 years, the availability and distribution of water 

have been drastically altered by both natural processes and human actions. By some estimates, 95 percent of natural riparian 

ecosystems (those associated with water features) and wetlands in the arid West already have been degraded or lost. We 

believe the loss of natural water resources threatens Greater Sage-Grouse population viability, but we realize domestic 

livestock also require water to survive. Federal public-land managers and ranchers have improved existing water supplies 

and developed new water systems for livestock and wildlife. Hundreds-of-thousands of these water developments are 

scattered across the western U.S. Water developments increasingly replace or augment diminishing natural sources in many 

areas and have become crucial for many species, especially Greater SageGrouse when stressed by drought, high 

temperatures or rearing young. These water sources and associated moist-soil (riparian) habitats are critical for Greater 

Sage-Grouse survival and reproduction. Springs, wetlands, seeps, wet meadows, bogs, fens, ephemeral and permanent 

streams, rivers, ponds, stock tanks and lakes all serve as or are surrounded by crucial habitats for Greater Sage-Grouse and 

other wildlife in the arid West. We believe that all water sources and associated moist-soil habitats on federal public lands 

should be protected from the effects of livestock disturbance and grazing. In most cases, livestock drinking water can be 

transported away from water sources and riparian habitats to sites that are not in limited supply and that are more 

compatible with livestock disturbance and grazing.

All Both emc0074GB

2. Recommendation #3 - We recommend that the BLM and USFS require all administrative units to protect all water sources 

and associated moist-soil (riparian) habitats from the effects of domestic livestock disturbances and grazing on federal public 

lands under their prevue.

All Both emc0074GB

3. Although livestock grazing is the highest and best use for much BLM land, many areas of public land managed by BLM grazing 

land could easily be better managed for wildlife. On some BLM land, decades of livestock use has continued to depress game 

habitat as clearly evidenced by adjacent right of way and sometimes adjacent private land sagebrush, greasewood, and habitat 

cover. Habit studies have rarely appeared to change actual use. Certainly cost feasibility prohibits fencing off or separating 

many small areas of riparian or other critical habitat. However, many areas exist where habit can be significantly protected 

without major effects on livestock permit numbers and, in considering minimal grazing fees, certainly without significantly 

impacting income from public lands. I also believe that through the years the oversight and field reviews by range staff has 

varied greatly between different BLM areas.

All Both emc0082RM

4. Although any increase in grazing costs will meet with objections, a moderate raise is so long overdue that it is difficult to

imaging a sound basis for continued objection. Better care of public high wildlife habitat value and riparian areas including 

some additional fence and water development with emphasis on wildlife habitat will also encounter some objections. 

Although I believe that sage grouse numbers remain well above the threshold of endangerment or seriously threatened 

species and will remain so, the simple suggestion alone that such designation is possible should be a great embarrassment to 

an agency trusted with management of the public's lands. It is time for simple and logical management adjustments, not 

studies.

All Both emc0082RM

5. PFC surveys are also qualitative assessments conducted to determine how well streams are functioning or not functioning 

under a 25 year storm event. PFC is not a replacement for a measured, data intensive inventory, but is an appropriate starting 

All Both emc0159GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1111

Scoping Summary Report

Table C-8.F

Comments Related to Wetland and Riparian Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

point for determining and prioritizing the type and location of quantitative inventory or monitoring necessary (TR 1737-­‐9, 

1993). Both the PFC and SRH assessments should be reviewed as part of the BLM information for the EIS. Some PFC 

surveys are not up to date and may need to be assessed by experienced and trained personnel. PFC cannot act as a surrogate 

for the SRH watershed criteria (Wyman 1999, Prichard et. al 1998).

6. PFC surveys are also qualitative assessments conducted to determine how well streams are functioning or not functioning 

under a 25 year storm event. PFC is not a replacement for a measured, data intensive inventory, but is an appropriate starting 

point for determining and prioritizing the type and location of quantitative inventory or monitoring necessary (TR 1737-­‐9, 

1993). Both the PFC and SRH assessments should be reviewed as part of the BLM information for the EIS. Some PFC 

surveys are not up to date and may need to be assessed by experienced and trained personnel. PFC cannot act as a surrogate 

for the SRH watershed criteria (Wyman 1999, Prichard et. al 1998).

All Both emc0179GB

7. PFC surveys are also qualitative assessments conducted to determine how well streams are functioning or not functioning

under a 25 year storm event. PFC is not a replacement for a measured, data intensive inventory, but is an appropriate starting

point for determining and prioritizing the type and location of quantitative inventory or monitoring necessary (TR 1737-­‐9,

1993). Both the PFC and SRH assessments should be reviewed as part of the BLM information for the EIS. Some PFC surveys

are not up to date and may need to be assessed by experienced and trained personnel. PFC cannot act as a surrogate for the 

SRH watershed criteria (Wyman 1999, Prichard et. Al 1998).

All Both emc0179GB

8. PFC surveys are also qualitative assessments conducted to determine how well streams are functioning or not functioning 

under a 25 year storm event. PFC is not a replacement for a measured, data intensive inventory, but is an appropriate starting 

point for determining and prioritizing the type and location of quantitative inventory or monitoring necessary (TR 1737-­‐9, 

1993). Both the PFC and SRH assessments should be reviewed as part of the BLM information for the EIS. Some PFC 

surveys are not up to date and may need to be assessed by experienced and trained personnel. PFC cannot act as a surrogate 

for the SRH watershed criteria (Wyman 1999, Prichard et. al 1998).

All Both emc0209GB

9. Please consider giving priority to restoring riparian habitats where this species lives from the overgrazing of livestock All Both emc0219GB

10. PFC surveys are also qualitative assessments conducted to determine how well streams are functioning or not functioning 

under a 25 year storm event. PFC is not a replacement for a measured, data intensive inventory, but is an appropriate starting 

point for determining and prioritizing the type and location of quantitative inventory or monitoring necessary (TR 1737-­‐9, 

1993). Both the PFC and SRH assessments should be reviewed as part of the BLM information for the EIS. Some PFC 

surveys are not up to date and may need to be assessed by experienced and trained personnel. PFC cannot act as a surrogate 

for the SRH watershed criteria (Wyman 1999, Prichard et. al 1998).

All Both emc0222GB

11. At page 16, Riparian Areas and Wet Meadows, managing for proper functioning condition of these sites within sage-grouse 

priority habitats should include grazing. As indicated above, grazing of meadows improves the nutrition of the forbs used by 

sage-grouse and sage-grouse demonstrate a preference for grazed versus ungrazed meadows. This needs ot be included in 

the EIS analysis.

All Both emc0239GB

12. The trend in water developments is to convey the water away from the spring area so that livestock will not congregate in 

the area of saturated soil, and also to return overflow to the spring drainage. These types of water developments are benefit 

All Both emc0239GB
C. Comments by Resource Planning Issue

C-1112 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.F

Comments Related to Wetland and Riparian Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

to sage-grouse by maintaining the riparian vegetation, and avoiding the trampling effects of livestock on wet spring meadows. 

Therefore, such water developments should be encouraged, not restricted.

13. Development of springs and alternative water sources is essential to creating habitats for the sagegrouse that will be 

protected and long lasting. Coupled with the increased grazing, sagegrouse would then have the opportunity to flourish in 

these revitalized riparian areas.

All Both emc0241GB

14. Limiting ranchers' ability to develop water sources for fear of increasing mosquitos that might carry West Nile is 

counteractive to increasing sage grouse numbers. Lifting restrictions and allowing ranchers to develop water sources, fence 

and protect meadows, and allowing regulated shooting of the raven would help boost sage grouse numbers.

All Both emc0244GB

15. Fenced riparian seems a obvious negative factor to sage grouse health with its old decadent growth eliminating fresh green 

growth that the grouse thrive on. Non use is also a negative for them.

All Both emc0253GB

16. We have found that by implementing multi-pasture grazing systems, having 5-15 pastures per herd, large herds, large 

pastures, allowing adequateperiods for plant recovery (generally 12 or more months) and providing season long rest 

toapproximately 20% of pastures annually we see increased upland and riparian herbaceous vegetation and decreased bare 

ground while maintaining a healthy brush component (Danvir 2002, Danvir et al 2005).

All Both emc0281GB

17. The dry conditions on our mountains the past years have allowed sagebrush to squeeze into the tiny wet meadows where 

the hens take their young chicks to forage. These small wet meadows need some help in stopping sagebrush encroachment. 

Another recent impact that is happening to these wet meadows, especially, on Blue Mt. is that there has been an explosion 

of elk numbers and their uncontrolled grazing is having an impact on these wet areas.

All Both emc0295GB

18. At page 16, Riparian Areas and Wet Meadows, managing for proper functioning condition of these sites within sage-grouse 

priority habitats should include grazing. As indicated above, grazing of meadows improves the nutrition of the forbs used by 

sage-grouse and sage-grouse demonstrate a preference for grazed versus ungrazed meadows. This needs to be included in 

the EIS analysis.

All Both emc0322GB

19. The potential conflict between livestock grazing and sage grouse intensifies near water sources due to the importance of 

these areas to sage grouse, particularly during early brood rearing. Heavy cattle grazing near springs, seeps, and riparian areas 

can remove grasses used for cover by grouse (Klebenow 1982). According to Call and Maser (1985:17), “rapid removal of 

forbs by livestock on spring or summer ranges may have a substantial adverse impact on young grouse, especially where forbs 

are already scarce.”

All Both emc0343GB

20. Riparian management. Issue: Many riparian areas fail to meet habitat conditions that sage-grouse require. Issue: There is a lack 

of appropriate standards and guidelines to restore habitat to reference conditions. Issue: Existing methods used to assess 

riparian areas (lentic and lotic) fail to include habitat requirements for sage-grouse. Issue: Reference riparian areas required 

in most agency assessments are too few and often too small in size to provide a basis for comparison.

All Both emc0391GB

21. Wetlands and riparian areas, including the upland habitat and groundwater resources required to protect the integrity of 

seeps, springs, streams or wetlands;

All Both emc0407GB

22. Reduce livestock grazing in order to restore the grasses and other flowering plants that sage grouse need. Give priority to 

restoring riparian areas from overgrazing.

All Both flf0000gb 

flf0000rm
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1113

Scoping Summary Report

Table C-8.F

Comments Related to Wetland and Riparian Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

23. The loss of riparian areas due to the restriction of grazing in wet meadows and lack of hot season grazing in upland areas has 

led to rangeland conditions that are unfavorable sagegrouse habitat.

All Both flj0003gb

24. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations. Private land productivity, particularly wet 

meadow maintenance, is extremely important to sagegrouse survivability.

All Both flj0003gb

25. Water Resources As alternatives are developed, we encourage the inclusion of measures which conserve, enhance and 

restore riparian areas and wetlands. Also, because of the aridity of greater sage-grouse habitat, we recommend that the EISs 

analyze potential impacts to ephemeral water bodies.

All Both rmc0020RM

26. It has also been shown that increased use of meadows and riparian areas in mid-to late summer is common as herbaceous 

vegetation in upland habitat becomes desiccated. Potential for competition with Sage-Grouse young may be in proportion to

the extent to which cattle select mesic/moist sites that are preferred foraging areas. Young birds seek out insects and 

succulent forbs in these habitats. Although the adult diet switches to forbs and insects in addition to sagebrush, developing

young depend heavily upon insects for food. These habitats are critical brood-rearing and summer use areas in regions with 

low annual rainfall and during drought years.

All Both rmc0024GB

27. Limit grazing in riparian areas. During low precipitation years, livestock should not be in riparian areas. All Both rmc0024GB

28. (a) Riparian Zones- Past efforts to fence and protect riparian areas have resulted in drastic changes in vegetation. Some areas 

have been converted to shrub zones from meadows. Long periods of rest had resulted in rank growth of grass and shrubs. 

This stagnant mix may favor some species; however Sage Grouse seek out riparian zones where fresh young green vegetation 

is available. Management of riparian zones needs to include "sage grouse preference" where sage grouse exist.

All Both rmc0057GB

29. i. Lander, WY RMP Alternative B addresses the important protection of natural functions in riparian-wetland areas,

providing important benefits to sage-grouse. In the arid western states, the value of riparian wetland communities is inversely 

proportional to their physical extent - supporting the greatest diversity of plant and animal life of all habitat types (DEIS 343, 

DEIS 351). Actions that improve riparian-wetlands would improve habitats for special status wildlife species, especially

increasing the quantity and quality of riparian-wetland vegetation and insects. Riparian-wetland areas are a component of 

brood-rearing habitat for greater sage-grouse because they provide needed forbs and insects necessary for chick survival. 

Alternative B prohibits surface disturbing activities within 1,320 feet (0.25 mile) of surface water, riparian-wetland areas, 

playas, and 100- year floodplains where mapped (except for areas of high and moderate oil and gas potential), and provides 

important protections for this habitat type.

East Both emc0089RM

30. i. Lander, WY RMP Alternative B stipulates light livestock grazing levels in areas typically preferred by cattle, such as 

riparian-wetland areas, adjacent upland areas, and around salt and mineral supplements and water troughs and developments. 

Also, Alternative B prohibits salt or mineral supplements within 0.5 mile of riparian-wetland habitats to prevent livestock 

congregation at water sources. Alternative B prohibits the placement of salt or mineral supplements within 0.6 mile of 

greater sage-grouse leks. All these provisions would protect important sage-grouse habitats (foraging areas, breeding areas, 

nesting areas) from livestock trampling and the impacts of heavy plant utilization.

East Both emc0089RM
C. Comments by Resource Planning Issue

C-1114 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-8.F

Comments Related to Wetland and Riparian Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

31. We question whether the only criteria for new water development of springs and seeps should be if sagegrouse habitat 

benefits from the development. These developments could be neutral for sage-grouse but benefit other land uses (livestock, 

other wildlife, recreation) but not harm sage-grouse. Actions that have no adverse effect upon sage-grouse should not be 

prohibited solely because they do not provide a positive benefit.

GB Both rmc0076gb

32. In a cottonwood grove survey of the upper Missouri River, Kudray et al. (2004) compared cattle-inaccessible river islands 

with accessible cottonwood groves on similar sites. They found no correlation between accessibility and any of their 

ecological measures. In other words, their analysis of the data supports the hypothesis that current grazing practices have no 

effect on riparian vegetation. The study devotes many paragraphs to the hypothesis that cattle are responsible for a decline 

of red-osier dogwood and chokecherry along the Missouri River. Because the study measured these species only once, it is 

not possible for it to reveal whether these species are increasing or declining. Furthermore, the experiment that was 

performed indicated that cattle did no harm. Why did the authors devote paragraphs to this hypothesis but only one 

sentence to the actual results of their experiment? Because they were trained to believe that cattle harm riparian 

ecosystems. A more careful analysis of the data might have noted that all the cattle-inaccessible river islands had 90% 

non-native herb cover, while some of the cattle-accessible sites were much better. But the idea that cattle could be benefiting 

native plants apparently did not occur to these researchers.

MT-RM Both emc0013RM

33. The Nevada Wilderness Project respectfully requests that you address the impacts to sage-­grouse and sage-­‐grouse habitat 

caused by feral horses, including removal of vegetational cover necessary for nesting and brood-­‐rearing, changes to 

vegetational composition that results from feral horse use, horse impacts to springs and other important free water sources 

utilized by sage-grouse, possible disturbance caused by feral horses during the nesting period, infrastructure used to mitigate 

horse impacts (e.g., fences) and how it may negatively affect sage-grouse, any connection to West Nile Virus as that disease 

is recognized as affecting both horses and sage-grouse, and the potential for feral horse management actions to negatively 

affect sage-grouse and sage-grouse habitat.

NVCA Both emc0243GB

34. Interestingly, Barrick's ranches may provide unique opportunities for mitigation of impacts from its mining operations. As 

operating ranches, these off-site restoration opportunities, including restoration of habitat on fee land, would likely be 

unavailable without their connection to the mining operations. Creating new riparian vegetation or wetlands to mitigate for 

potentially impacted wetlands, improving degraded habitats to replace impacted areas, and developing water sources when 

access to water is prevented due to safety fencing are just a few examples of off-site mitigation that potentially could be 

available on Barrick's ranch lands.

NVCA Both emc0277GB

35. Manage riparian areas and wet meadows for proper functioning conditions within priority sage grouse habitats - Within 

priority and general sage‐grouse habitats, manage wet meadows to maintain a component of perennial forbs with diverse 

species richness relative to site potential (e.g., reference state) to facilitate brood rearing. Also conserve or enhance these 

wet meadow complexes to maintain or increase amount of edge and cover within that edge to minimize elevated mortality 

during the late brood rearing period (Hagen et al. 2007, Kolada et al. 2009, Atamian et al. 2010). What will be the 

management technique used for this conservation measure? If fencing techniques are to be used in this instance, this measure 

needs to further assess the implications of fencing on greater sage-grouse.

NVCA Both emc0328GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1115

Scoping Summary Report

Table C-8.F

Comments Related to Wetland and Riparian Vegetation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

36. Where riparian areas and wet meadows meet proper functioning condition, strive to attain reference state vegetation 

relative to the ecological site description. - For example: Within priority sage‐grouse habitat, reduce hot season grazing on 

riparian and meadow complexes to promote recovery or maintenance of appropriate vegetation and water quality. Utilize 

fencing/herding techniques or seasonal use or livestock distribution changes to reduce pressure on riparian or wet meadow 

vegetation used by sage‐grouse in the hot season (summer) (Aldridge and Brigham 2002, Crawford et al. 2004, Hagen et al. 

2007). Properly functioning condition means the vegetation and water quality is already meeting standards and should not 

need further assessment.

NVCA Both emc0328GB

37. Indeed wet meadows riparian areas are important – but how does NDOW reconcile a no net loss; policy with endorsing 

spring development/re-development and de-watering projects accompanied by band-aid piecemeal fencing? This only serves 

to further reduce flows at affected project sites, thus often reducing meadow areas as well as intensifying adverse impacts in 

all unfenced areas leading to further reductions there, as well. Examples: Hubbard Vinyard, where NDOW sided with 

livestock interests to support livestock water developments specifically to benefit one of its former Commissioners.

NVCA Both emc0411GB

38. 'Work to address and prevent overuse areas by managing for good livestock distribution’.(pg. 3 attachment 8). Part of good 

distribution of livestock is the availability of water in harder to access areas. Livestock will not walk any farther than necessary 

to reach water. All wells and other water resources such as develop springs and reservoirs placed away from natural riparian 

areas will help protect those riparian areas. Authorize new water development for diversion from spring or seep source only 

when priority sage-grouse habitat would benefit from the development(page 16 National) The more water available in a 

pasture the less use any one watering place will have and the less damage to sage grouse habitat in the area. There needs to 

be several areas of water available to prevent one part of a pasture from being overused.

WY Both emc0050RM

39. i. Lander, WY RMP Alternative B addresses the important protection of natural functions in riparian-wetland areas,

providing important benefits to sage-grouse. In the arid western states, the value of riparian wetland communities is inversely 

proportional to their physical extent - supporting the greatest diversity of plant and animal life of all habitat types (DEIS 343, 

DEIS 351). Actions that improve riparian-wetlands would improve habitats for special status wildlife species, especially

increasing the quantity and quality of riparian-wetland vegetation and insects. Riparian-wetland areas are a component of 

brood-rearing habitat for greater sage-grouse because they provide needed forbs and insects necessary for chick survival. 

Alternative B prohibits surface disturbing activities within 1,320 feet (0.25 mile) of surface water, riparian-wetland areas, 

playas, and 100- year floodplains where mapped (except for areas of high and moderate oil and gas potential), and provides 

important protections for this habitat type.

WY Both emc0089RM

40. i. Lander, WY RMP Alternative B stipulates light livestock grazing levels in areas typically preferred by cattle, such as 

riparian-wetland areas, adjacent upland areas, and around salt and mineral supplements and water troughs and developments. 

Also, Alternative B prohibits salt or mineral supplements within 0.5 mile of riparian-wetland habitats to prevent livestock 

congregation at water sources. Alternative B prohibits the placement of salt or mineral supplements within 0.6 mile of 

greater sage-grouse leks. All these provisions would protect important sage-grouse habitats (foraging areas, breeding areas, 

nesting areas) from livestock trampling and the impacts of heavy plant utilization.

WY Both emc0089RM
C. Comments by Resource Planning Issue

C-1116 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. I do not support closures Rds. as this will allow an increase in predators. All Both cfc0007GB

2. 3% disturbance is a lot, especially considering the past 14 years. 10% would be more realistic. No more than 1 

disturbance per section is not realistic either due to changing landscapes. There should be mitigation allowances made. 

Erusting used roads and large/medium reservoirs should not be counted.

All Both cfc0025RM

3. Avid ATVer - I'm ok with nesting closure times for a few weeks - total closure would just beg non-compliance with 

fellow riders.

All Both cfc0057GB

4. I would hope that recreational horseback riding on established trails through the habitat would be a permitted use. 

Anything to the contrary would have to be based on a lot of good science.

All Both emc0002RM

5. 1) Since BLM maintains more than half of the available sage grouse habitat, the strongest possible protections should be 

made available without hesitation. Especially restrictions from access by motor vehicles into sage grouse habitat. Off 

highway vehicles, including ATV's, motorcycles, and four-wheel drive automobiles cause extensive damage to BLM 

Lands. This is obvious upon visiting any BLM controlled lands. Roads also are the root cause of the habitat 

fragmentation, which starts the decline of the sage grouse.

All BLM emc0011GB

6. In 2008-2009 leks were cut in half, agriculture caused reductions in leks as did a lot of roads. Sage-grouse were found to 

be half as likely to maintain their nests in Silver Sage as in Big Sage. North Dakota saw a tremendous drop in bird 

populations.

All Both emc0012RM

7. Each proposed conservation measure in the EIS should be analyzed in terms of how much it costs and how much the 

grouse population will benefit. The following conservations measures should be included in this analysis: - Various 

methods of coyote control. - Various methods of raptor control. - Various methods to reduce danger from fences. -

Various methods to reduce danger from vehicle traffic. - Various methods to protect grouse from disease. - Various 

methods to limit exposure to pesticides. Each method should be rated according to two measures: 1. Number of 

grouse saved per dollar spent on materials and labor. 2. Number of grouse saved per laborer-hour of time spent. 

When considering these measures, the EIS should analyze costs from three different viewpoints: 1. When the BLM 

employs the person doing the labor; 2. When the BLM contracts with a third party to do the labor; 3. When the BLM 

encourages ranchers or other partners to perform the labor. Ranchers' time and BLM funds are limited. The RMP 

should focus on conservation measures that provide the highest return for the time and money invested.

All Both emc0013RM

8. The RMP should include plans for a study of how roads impact winter forage opportunities for sage grouse. Specifically: 

Why do grouse like to congregate on gravel roads, and how would road closures negatively impact the species?

All Both emc0013RM

9. The RMP should include plans for a study of how lek location correlates to roads. All Both emc0013RM

10. In areas where sage grouse currently thrive, the RMP should make no changes to current grazing, road use, and 

fire-suppression practices.

All Both emc0013RM

11. We are loosing the sage-grouse species for one reason they are being killed by humans. Any effective strategy will 

reduce the opportunity for humans to harass and kill these birds. Roads should be closed to major sage-grouse habitat. 

Signs should be erected that discourage hunting. ORVs disturb the birds. The BLM and USFS should erect signs (and 

monitor use) that tell people ORV use is discouraged.

All Both emc0016GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1117

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

12. In a recent book edited by S. T. Knick and J. W Conmelly on Sage-Grouse research it was stated that most attempts to 

restore sagebrush habitats have been unsuccessful. In fact a noted grouse expert, Dr. Clait E. Braun, stated, "I know of 

no areas where Sage-Grouse have re-established their distribution over significant areas of former habitat," (The 

Wilson Journal of Ornithology, Vol. 123, p 655). What this effort will require will be for you to put Sage-Grouse 

management above all other uses on public lands. This means that grazing of livestock and fences should be eliminated 

in core Sage-Grouse areas. All types of land fragmentation, such as roads, power lines, wind farms, oil and gas drilling, 

etc. will have to be secondary to the management of Sage-Grouse. I do not have much faith that your agencies will be 

capable of such a drastic turn-around. In fact, BLM planned to study ecological trends in much of the 260 million acre of 

the West’s grazing allotments, but told the scientists not to consider livestock grazing, due to "anxiety from 

stakeholders." Such attitudes will absolutely have to change if there is any hope to save Sage-Grouse and their habitat. 

The only real solution that I see is buying out willing ranchers who graze in core Sage-Grouse areas. As said, both your 

agencies will have to put the grouse first.

All Both emc0021RM

13. I do not believe motorcycles or atvs will have an affect on sage-grouse. All Both emc0024GB

14. As an outdoor enthusiast who lives in Idaho and hikes, hunts and rides ATV's, I ask that you don't close any roads or 

restrict access to anyone because of the Sage Grouse. In the last ten years or so there has been an increase in the 

number of BLM and U.S.F.S. roads that are being closed, all in the pretense of trying to protect some kind species that 

somebody claims is endangered. We have seen these tactics used with ground squirrels, caribou and now the sage 

grouse. The fact is, there is no real proof that vehicles kill or do real hard to these so called endangered species. All this 

is, is a ploy to restrict citizens from gaining access to their public lands.

All Both emc0036GB

15. How does road density affect sage grouse lek function/occupancy and brood rearing success? 1) in areas with only lightly 

used, widely spaced recreational roads. 2) in areas with the routine movement of livestock using horses, ATVs, etc. 3) 

in areas with utility corridors and their maintenance (including unauthorized traffic) 4) in areas with oil and/or gas well 

development

All Both emc0041GB

16. Why so many Predators? a) Between all the rules of the USFS, BLM, DOW, State, it has become so complex that 

hunters of predators can never assume he/she is adhering to the regulations of each group. In other words "Keep it 

simple". b) Fewer people hunt predators because: Roads have been closed or are planned to be closed. There is an 

anti-hunting attitude exuded by the above groups. Cost of hunting (Equipment, travel, fees) Older hunters (60+) find 

previous access methods unusable and current long walking is difficult so they quit. The DOW statistics will substantiate 

fewer hunters as the old guys are not mentoring new young kids.

All Both emc0052RM

17. The sage grouse population is NOT impacted by grazing, current roads, or energy factors. (I never saw a cow kill a 

grouse).

All Both emc0052RM

18. We also recommend developing guidelines for off-road vehicle use, to include seasonal or year-round bans on use in 

vital habitat.

All Both emc0068GB, 

emc0020rm

19. With regards to roads around both priority and general Greater Sage Grouse habitats, no new roads or ROW’s should 

be allowed or granted within a 5.5 mile radius of a lek site. With regards to priority habitats, the BLM should further 

All BLM emc0074RM
C. Comments by Resource Planning Issue

C-1118 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

include mandatory limited and or no usage of such roads that pass within a 5.5 mile radius of a lek site during mating and 

hatching seasons.

20. When considering the necessity for habitat preservation, all priority sites will be designated high priority and 

mandatorily set aside from any new or further oil and gas development, as well as road and other leasing development.

All BLM emc0074RM

21. When considering the necessity for habitat preservation, all linkages between any site and a priority site will also be 

designated high priority and mandatorily set aside from any new or further oil and gas development, as well as road and 

other leasing development.

All Both emc0074RM

22. When considering the necessity for habitat preservation, all general habitat sites will be designated medium priority 

sites, with a mandatory evaluation of their protection from oil and gas development, and road development, and other 

leasing development. It will be mandatory for the BLM to act upon new information provided regarding lek locations, 

regardless of their activity status, and to install protective measures in the middle of the finalized land usage plan. These

measures will follow the regulations of all high priority, priority and general habitats, as well as mandatory exemptions 

from oil and gas development, road and other leasing developments as other Greater Sage Grouse habitats have 

undergone.

All Both emc0074RM

23. The ODFW strategy does not address the full suite of threats to sage grouse, such as road densities. This Sage Grouse 

Conservation EIS must address opportunities to close and decommission little-used roads as a way to reduce 

fragmentation and improve sage grouse habitat quality.

All Both emc0078GB

24. RECREATION ISSUE: The proposed Conservation Measures fail to address impacts of individual OHV trails and

subsequent two-track roads that impact sage grouse and sage grouse habitat. Discrete anthropogenic disturbance via 

highways and gravel roads has been identified as an important issue for sage grouse habitat in the Conservation 

Measures. Overall objectives talk about limiting roads and specific objectives talk to limiting road disturbance to 3%. The 

Conservation Measures entirely overlook the impact of OHV trails left by individuals using public and USFS 

administered lands. Are these really to be categorized as diffuse disturbances, along with livestock grazing? Individual 

user OHV trails mechanically damage sagebrush, disturb nesting and brooding, destroy riparian vegetation and drain wet 

areas through capillary action. In lowmid elevation areas, OHV trails lace every drainage and ridgeline. Low elevation 

lands are a web of fragmented, small polygon areas that can’t function as sage grouse habitat. Nearly every low-mid 

elevation riparian area in Nevada potentially used by sage grouse for brooding is impacted by individual use OHV trails 

on BLM lands and USFS administered lands. OHV trail mileage is expanding exponentially on BLM land. When use is 

controlled on USFS administered lands through “closed unless posted open” designations, OHV users come to BLM 

lands where everything is open except a few areas posted as closed. Seemingly harmless one-time passes through an 

area by OHV’s go on to become full-blown roads in a few short months that are accessible to vehicles. Individual OHV 

trail / roads systems force the issue of discussion on patch size. The case can’t be made that webs of OHV trails and 

two-track roads don’t impact sage grouse and sage grouse habitat no matter which label, discrete or diffuse, these fall 

under. Measures must be amended into the LUPs that would manage OHV trail proliferation.

All Both emc0083GB

25. RIGHTS of WAY ISSUE: The proposed Conservation Measures fail to address ROW maintenance roads becoming

roads for the general public. Most low and mid-elevation powerline / gas line / communications line ROW’s become 

All Both emc0083GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1119

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

OHV trails and eventually roads for the general public. See discussion on individual OHV use under Travel and 

Transportation. The only mitigation available is signage stating that a maintenance road is closed to public travel; the 

signage is universally ignored. Because the Measures identified ROW’s as potential discrete disturbances, the use of the 

ROW road by the individual public OHV user must also be a discrete disturbance.

26. One of the most effective management tools is suspension of road and ATV trail proliferation in the sage sea. This action 

alone would severely restrict the potential for new development of fossil, solar, and wind energy, all of which may have 

serious negative impacts on sage grouse. Stop the roads, stop the invasion of the sage sea. Then, when better habitat 

information is available, allow construction that is minimally invasive and located in minimum impact areas. There are 

other places to extract or generate energy, but sage grouse grow only here.

All Both emc0083RM

27. Limits on road access do not necessarily reduce cattle grazing, and grazing reduces floristic diversity that supports sage 

grouse. In addition to road limitation, therefore, cattle grazing limitation is needed until areas of poor grouse habitat 

quality are identified, at which time grazing may be allowed or re-allowed in these areas. There are other places to grow 

cows, but sage grouse grow only here.

All Both emc0083RM

28. Exclude offroad vehicles from BLM lands used as critical habitat by sage-grouse, including leks, nesting and rearing 

habitat, and winter habitat. BLM should consult ornithologists and wildlife biologists for recommendations on an 

effective distance from a lek that would prevent ORVs from interrupting breeding activities.

All Both emc0085GB, 

emc0029rm

29. Due to the grouse's seasonal nesting habits and large habitat range, only if absolutely necessary should current/historic 

roads and trails be rerouted and/or considered for temporary/seasonal closures instead of permanent or blanket area 

closures.

All Both emc0114GB

30. The OHV community understands that certain measures need to be taken to protect the Sage Grouse population, 

however the Agency (blm, usfs, etc) must not allow this action to be used as a means for unnecessary and unwarranted 

land closures and/or restrictions. The Agency must use sound science when considering measures to protect the 

species and not agenda-driven speculation.

All Both emc0115GB

31. The OHV community is opposed to unnecessarily having the greater Sage Grouse population divided into sub species 

and/or separate groups in order to further an anti-access/anti land-use agenda. The Agency must use sound science 

when considering measures to protect the species.

All Both emc0115GB

32. Should sound science dictate that land-use restrictions are necessary, the Agency must consider minimizing these 

restrictions when it is prudent to do so, including but not limited to seasonal/temporary closures instead of permanent 

closures and rerouting of routes/trails instead of unnecessary full closures.

All Both emc0115GB

33. Off-Highway Vehicle Use: The BOA is opposed to unregulated OHV use. That being said the restrictions on OHV travel 

that prevents the firewood collector from departing the road more than the length of their vehicle to load firewood is

counterproductive. For as long as anyone knows the road departure limit has been 300 feet. This distance was 

acceptable to most forest users. The assault on citizen access to public lands is of major concern to this organization. 

We have never advocated building new roads, however we are adamantly opposed to the closure of existing roads. The 

urban view of what constitutes a road and what we outdoors enthusiasts call a road are eons apart. Stop placing 

restrictions on how we use the existing roads. Snowmobiles, which are defined as OHV’s are losing millions of acres of 

All Both emc0133GB
C. Comments by Resource Planning Issue

C-1120 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

recreational land every year. The snowmobile running over several feet of snow does no damage to the environment. 

All areas closed to snowmobile use in the past twenty years need to be reopened.

34. Recreation: Every single recreational experience begins with a motor vehicle. The most rabid environmentalist will drive 

as far as possible before hiking, skiing, or mountain biking. From the 2009 Table of Wilderness Visits to Montana 

National Forests versus Multiple-use Visits the reader will learn that only 3.02% of visits were to wilderness areas. This 

statistic proves the need to keep all existing roads open rather than closing them.

All Both emc0133GB

35. A plan to expand existing utility corridors must be implemented. The BOA recognizes the Nations need for more

electricity but prefers to contain transmission lines in existing corridors.

All Both emc0133GB

36. "Grouse are tolerant of automobiles and may be watched from fairly close range if the observers do not leave their 

vehicle" (Call and Maser 1986). Signage near a lek can be used to warn visitors to remain in their vehicles and not create 

disturbances that cause sage grouse to leave the lek. Road closures are not necessary except in some cases where the 

road is too close to a lek. In that case, the road should be rerouted or seasonally closed until breeding season is over.

All Both emc0139GB

37. "Cattle do not commonly cause abandonment of nest or trampling of nest and may be grazed during any season as long 

as sagebrush and forb components do not deteriorate as a result of such activity" (Call and Maser 1986)

All Both emc0139GB

38. Livestock "grazing management may be used to help create the plant structure and composition desired for sage grouse" 

(Call and Maser 1986).

All Both emc0139GB

39. I am an atv rider and belong to the Canyon County ATV Club. I have been riding in Owhyee County for about 8 years 

now, and believe that there are enough roads closed to protect the grouse. I have also seen 5 or 6 flocks of up 100 birds 

(this is just a guess) in them in my riding around. And also smaller flocks of them. The point is that they seem to be doing 

just great in Owhyee county as things stand right now. I believe that the county has been closed to sage grouse hunting 

for several years now. If you are worried about the habitat you might want to take a look at the mining and cattle grazing 

in this area.

All Both emc0140GB

40. Transportation systems within critical sage grouse breeding areas (leks) should be analyzed based on current use 

(amount of use, time of use, and user groups) and impacts or disturbances on sage grouse during critical periods. Iron 

County questions how much of an impact two track roads that are seldom traveled during the critical breeding period 

contribute to fragmentation. This issue should be adequately addressed in the strategy.

All Both emc0142GB

41. Closure of roads and trail, and elimination of grazing (both of which have been around long before the Sage Grouse 

popUlation were in trouble) is not the answer to restoration of the Grouse populations.

All Both emc0145GB

42. First, I think you need to consider that a vehicle full of people, be it a power company or casual use recreationists at the 

same time in or around an active lek will have the same or similar impacts, no matter what their activity is. Therefore, 

when you complete this EIS you need to have more restrictions, authorizations and/or permitting practices that cover 

everybody similarly. For instance, if you have very restrictive regulations on the power company vehicle, you may 

threaten to pull or alter their permit for a single or a series of impacts or actions. But you may have the same or similar 

impacts from casual use recreationists. You cannot turn a blind eye to them. They both need similar restrictions and 

consequences to their potential impacts or actions.

All Both emc0149GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1121

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

43. ODOT wants to reiterate that we support and recognizes the importance and value in environmental review of 

projects to assure that issues such as greater sage-grouse habitat is identified, evaluated and, if necessary, mitigated. But 

for projects that are necessary to maintain a safe and efficient transportation system, there needs to be processes in 

place to allow for project specific evaluation and approval without always requiring an RMP amendment via an EA or EIS. 

Greater sage-grouse and their habitats are important, but in addressing transportation improvement or maintenance 

projects or materials needed for these projects, it should not take years of effort and hundreds or thousands of dollars 

to obtain approvals to move forward. By developing the above mentioned recommendations, it should allow individual 

BLM Districts across the west to implement land management strategies for improved greater sage-grouse habitat 

without having to struggle to address Federal, State and Local Transportation projects and needed material sources.

All Both emc0155GB

44. Although the BLM is pressured by many separate entities, it is imperative that strong efforts are made and followed to 

enhance, preserve habitat and prevent those areas from being exposed to development or to off road vehicles. 

Although not all ATVers are harmful many do not stay on designated trails and they make their own trails over time.

All Both emc0169RM

45. Closing the established OHV trails will only stop the law abiding people from going out in those areas. It will NOT stop 

the poachers or others that are causing problems with the wildlife and habitat. Allowing the ATV riders to continue 

using the trails, they might keep the poachers out of the area for fear of being caught. And they can and will report any 

problems that they see to the proper officials.

All Both emc0175GB

46. I believe that motorized off highway use threatens sage grouse and it's habitat and motorized access should be curtailed, 

not expanded.

All Both emc0184GB

47. I am very concerned about the impact on sage-grouse of the rapid growth of gas and oil development in the West. The 

scientific report prepared for the BLM last year, 'Report on National Greater Sage- Grouse Conservation Measures', 

made it clear that many changes in current practices need to be made. These include protecting sage-grouse habitat 

from large scale disturbances, limiting disturbance to one per section with less than 3% of the section's surface area, 

reducing road density, only permitting transmission lines away from the critical habitat, etc.

All Both emc0185rm

48. Regarding recreation, the plan amendments should direct local land managers to cooperate and coordinate with local 

governments and affected stakeholders to establish achievable goals for protection of the Grouse (lek /nest disturbance, 

wintering areas and sage habitat degradation) and to mitigate potential affects upon recreation through closure of 

existing, inventoried and managed routes.

All Both emc0199GB

49. The amendments should recognize that local agency recreation planners and managers are the best suited to work with 

motorized stakeholders to establish a manageable, designated, user and nature friendly route network for motorized 

access. This includes access roadways away from paved highways; high clearance routes for pickups, jeeps and other 

4WD vehicles; that can be shared under mixed-use by other OHV categories such as trail bikes, ATV/UTV and/or OSV 

in the winter. Just as important to the motorized community are rural 2 track routes, ATV width trails, and trail bike 

singletrack width routes.

All Both emc0199GB

50. Any plan amendment should include adequate site-specific analysis on anticipated impacts of motorized and 

non-motorized recreational activities, which often have little to no impact on wildlife. The impacts of motorized and 

mountain bike routes that are primarily used for recreation should not be "lumped in" with highways and other 

All Both emc0199GB
C. Comments by Resource Planning Issue

C-1122 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

highspeed access roads.

51. The same has been shown for motorized access and use. For example, Grouse leks are concise, well-established, 

historic areas that can last for decades. Add to this that leks are mostly in use for strutting/mating during crepuscular 

hours and that motorized recreation is generally NOT undertaken during those hours...the two can be successfully 

separated.

All Both emc0199GB

52. The analysis should include the fact that the BLM, Forest Service, state, county, local and tribal land management 

agencies are moving towards a "limited to designated route" paradigm. This process should prioritize areas where such 

planning has not yet occurred. I strongly believe that the goals, objectives and new paradigm can be met without 

severely limiting or restricting responsible, managed motorized recreation uses within the planning area.

All Both emc0199GB

53. Because ATV use has increased dramatically in the past several years, there needs to be an aggressive training and 

enforcement policy to reduce illegal ATV use. Legal roads need to be clearly marked and illegal roads need to be 

barricaded. Enforcement efforts need to be increased, especially during the hunting seasons to reduce the damage being 

done by ATV's.

All Both emc0217GB

54. BRC has reviewed all the relevant literature and issues concerning the current planning process undertaken by the BLM 

and its National Greater Sage-Grouse Planning Strategy (Charter). We have also reviewed current OHV/ORV 

literature and statistics from the USDA Forest Service as it applies to use trends and to management on the ground. 

These trends cross directly over to the BLM and can be used to justify sound management techniques for motorized 

recreation regardless of the differing Code of Federal Regulations (CFR’s) that govern each agency.

All Both emc0227GB, 

emc0092rm

55. In reviewing the available literature and studies listed above, BRC has also noted there is scant to little information 

anywhere related to the effects of motorized recreation on the Grouse and there are no definitive studies to that effect 

cited anywhere in the database. Particularly considering the intense scrutiny and collective scientific energy expended 

on this species, BRC concludes that motorized recreation in any of its forms is not a significant effect/impact on the

Grouse. The USFWS listing petition decision supports this as well. Motorized recreation and/or OHV/ORV is barely 

mentioned and mostly anecdotal in nature. However, BRC does understand that OHV-related site-specific research 

may be needed to fine tune vehicle-based recreation on roads, trails, and areas so that future Grouse-friendly 

motorized access is assured.

All Both emc0227GB, 

emc0092rm

56. The production of a National Environmental Policy Act (NEPA) document and subsequent Environmental Impact 

Statement/Supplemental Environmental Impact Statement (EIS/SEIS), when completed, will guide future management 

decisions for the Grouse and its sage based habitat. Because of the size of the landmass involving current Grouse habitat 

and distribution, the BRC considers the production of this NEPA document to be a major landscape level decision. The 

subsequent Final Environmental Impact Statement (FEIS) and Record of Decision (ROD) will affect motorized 

recreation in the 11 states where the Grouse currently occurs (both East and West planning units).

All Both emc0227GB, 

emc0092rm

57. In addition the BLM has published 2 Instruction Memorandums (IM) dated 12/22 and 12/27 2011 that will provide 

“interim conservation policies and procedures for BLM field level operations”. These will also have the potential to 

greatly affect/impact all aspects of motorized recreation, from traditional camping, hunting and fishing access to access 

All Both emc0227GB, 

emc0092rm
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1123

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

for photography, bird watching, mountain bicycling, boating, cross country skiing and wilderness areas. Most of all, these 

IM’s could have a serious negative impact on casual OHV use and permitted special events such as enduros, trials, 

hare-scrambles and dual sport rides to name a few. All forms and aspectsof motorized recreation...off-highway/off road 

motorcycle, dual sport/adventure sport motorcycle, ATV, SBS, OSV, 4WD and even all street legal vehicles...may be 

affected if the IM’s are interpreted in the wrong manner in a “one size fits all” decision. This has occurred in the past 

when elements of the motorized recreation community were not included in the planning process. BRC is very 

concerned that may well be the final outcome if motorized recreation community members are not involved in this 

planning process from the beginning. We also believe that rather than the broad sweep of the brush as thusly painted in 

the most recent IM’s and summaries of said, a more “common sense” approach (already suggested for adoption by BLM 

in other Grouse Management Strategy documents) needs to be implemented in order to minimize the affects/impacts 

on both the Grouse and the recreating public.

58. In order to accomplish this “common sense” approach to management, local land managers at the Resource Area Office 

level need to be heavily involved with the motorized public to establish achievable goals for protection of the Grouse 

(Lek /nest disturbance, wintering areas and sage habitat degradation) and to mitigate potential affects upon recreation 

through closure of existing, inventoried and managed routes. These types of closures should always be viewed as the 

most extreme measure to undertake after all other management techniques and measures have failed. Under the IM’s, 

the BRC believes that sound, proven OHV management techniques can allow the agency to protect the Grouse and 

habitat and to provide for responsible, family oriented OHV/ORV recreation, regardless of which form it takes

All Both emc0227GB, 

emc0092rm

59. Part of this process is to determine time and use regulations that minimize real conflicts between the recreating public 

and the Grouse. BRC notes that hunting of the Grouse is still allowed in at least 8 of the 11 states where it is found and 

that by setting reduced seasons and bag limits, the Grouse is not considered at risk and that hunting can still occur. The 

same can be said for motorized access and use. For example, Grouse Leks are concise, well-established, historic areas 

that can last for decades. Add to this that the Leks are mostly in use for strutting/mating during crepuscular hours and 

that motorized recreation is generally NOT undertaken during those hours...the two can be successfully separated. 

BRC also notes the BLM, like the Forest Service, state, county, local and tribal land management agencies is also moving 

towards a mostly “designated route” planning effort for use of roads and trails that are compatible for motorized 

recreation use and we support that concept. Except for OSV winter use, where snowpack allows, BRC recognizes that 

unauthorized/unmanaged cross country travel can be damaging to both wildlife and habitat.

All Both emc0227GB, 

emc0092rm

60. The local Resource Area recreation planners and managers are the best suited to work with the motorized 

stakeholders to establish a manageable, designated, user and nature friendly route network for motorized access. This 

includes access roadways away from paved highways, highclearance routes for pickups, jeeps and other 4WD vehicles 

that can be shared under combined use by other OHV/ORV categories such as trail bikes, ATV/SBS and or OSV in the 

winter. Lesser used but just as important to the motorized community are rural 2 track routes that may see little use 

throughout the year, ATV width trails and trail bike single track width routes. Routes that are duplicitous or fill no need 

or are illegally established may be considered for closure and rehab. The desired condition is an adequate 

system/mixture of routes of suitable length and skill levels that follow Best Management Practices (BMP) established by 

All Both emc0227GB, 

emc0092rm
C. Comments by Resource Planning Issue

C-1124 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Best Available Science (BAS).

61. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: Minimization of route networks and closures to motorized use or limiting motorized use to 

designated routes;

All Both emc0234GB

62. Roadless sagebrush habitat will also become increasingly important to facilitate species' adaptation to climate change All Both emc0234GB

63. BLM should put the following management prescriptions in place for L WCs at a minimum: Closed to motorized use or 

limited to motorized use on designated route

All Both emc0234GB

64. On page 11 of the NTT report the conservation measures for Travel and Transportation call for limiting motorized 

travel to designated roads, primitive roads, and trails at a minimum. While we respect the need for not creating roads 

haphazardly, going off-road to retrieve game should not be restricted. These one-time cross-country travel trips should 

be permitted.

All Both emc0239GB

65. The evaluation of the need for permanent roads or seasonal road/area closures should include public input as part of the 

evaluation. Many of these roads that receive limited use are important to ranchers for getting to water developments, 

distributing salt or supplements, and towing horse trailers to the ends of the roads to initiate riding to move livestock. 

Effective livestock grazing, which can benefit sage-grouse, depends on the continued use of such roads and trails. There 

seems to be some conflict when a rancher uses a road that is adjacent to a lek, but agency biologists don't recognize a 

conflict when they travel to these same sites several times each spring to do lek counts, at which time they stop and get 

out of their vehicles. Closure of these roads impacts members of the NOGA, limits mineral exploration, and others 

that use public lands. Closure should be a last resort, and seasonal restrictions need to be evaluated with public input.

All Both emc0239GB

66. "During activity level planning, where appropriate, designate routes with current administrative/agency purpose or need 

to administrative access only" (page 11, third bullet under Priority sage-grouse habitat areas). This implies that if the 

agency folks determine that they need a road to remain open to do their job, then it will remain, but be restricted to 

their use only. But others that identify a need to use a road to do their jobs (ranchers, geologists, guides/outfitters, etc.) 

are basically out of luck. We would like this double standard to be evaluated in the EIS.

All Both emc0239GB

67. "Allow no upgrading of existing routes that would change route category.." (page 12, first bullet). Many of the roads that 

are established by repeated travel over the same trail require upgrading to prevent erosion. Installation of water bars, 

sediment traps, and berms to prevent run-on are the types of upgrades that limit erosion. Without these upgrades, 

habitat damage can occur, especially on slopes.

All Both emc0239GB

68. "Conduct restoration of roads, primitive roads, and trails not designated in travel management plans..(page 12, second 

bullet). The travel management plans need to be developed with public input and the decision to "conduct restoration" 

(i.e., road closure) also needs to include public input.

All Both emc0239GB

69. Off road vehicles used for either recreational or hunting use can interfere with the birds twelve months out of the year All Both emc0241GB

70. We are concerned that amendment of federal plans could have an impact on local transportation plans and RS 2477 

access rights. Such potential impacts must be fully analyzed in the NEPA process. The state and counties will not accept 

the closure of roads that have historically provided access to public land resources and remain important today.

All Both emc0242GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1125

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

71. Sage grouse habitat conservation measures should not preclude the use of certain BLM lands for OHV recreation. Any 

losses of OHV recreational lands should be mitigated by provision of additional lands outside of priority habitat and 

enhanced recreational facilities.

All Both emc0242GB

72. Specifically, management prescriptions for this proposed ACEC should implement the conservation measures 

recommended by the Sage-Grouse National Technical Team in December, 2011 (SGNTT, 2011). Recent publications 

have exhaustively documented the special conservation actions needed to sustain Greater Sage-Grouse in the American 

West (SAB 2011). Because this proposed ACEC includes priority/core sage grouse habitat, we recommend the

following special management to address activities that will fragment the sage-steppe habitats upon which the greater 

sage-grouse depends: Travel management: Within the proposed ACEC, motorized recreation should be limited to 

designated roads and trails. The BLM should review current travel management plans and evaluate the need for 

permanent or seasonal road and area closures to protect Sage-Grouse (SGNTT, 2011). Roads and trails not designated 

for motorized recreation within the ACEC should be obliterated and restored to native vegetation to improve 

Sage-Grouse habitat.

All BLM emc0248GB

73. 4) By and large road densities on BLM lands are so low as to be not a factor and keeping access points open as shared

roads with much difficulty to travel are essential for management of fire suppression and livestock and wildlife guzzlers

and weed control and animal and hunter and gatherer activities. Combined cross country travel be it man on foot,

wheeled ‐ 

from the standpoint of increasing weed spread or potential to start fires. (Shared roads interpreted by me are current

existing historical places where wheels ‐ 

little bird feet travel those roads, trails, ways and routes for gravel, or small stones, water from rancher’s troughs,

different cover or watching for predators.)

All Both emc0257GB, 

emc0104rm

74. All existing US, State, County, BLM and USFS roads and right of ways should not have any traffic restrictions placed on 

them. Your Lek site maps already demonstrate that either your data is defective in not making SG lek site observations 

greater than a 1,000 feet or so feet from a road, or roads enhance SG habitats and do not degrade SG populations.

All Both emc0260GB

75. All existing US, State, County, BLM and USFS roads and right of ways should not have any traffic restrictions place on 

them for accessing private lands or mining claims. These are existing rights that have generally been used for decades 

and coexist with SG popu lations/habitat.

All Both emc0260GB

76. The rights of land owners and mining claim owners should be protected to the fullest extent possible as they have 

existing property and access rights. Inhibiting access will cause unnecessary litigation and I believe such limitation will not 

improve SG populations.

All Both emc0260GB

77. I would like a section discussing the access rights of private land owners and mining claim owners across BLM lands and 

what the BLM's view of these rights are and the limitations of the law to restrict access. I want to see specific language 

guidance on what limitations, if any, the BLM believes it is under in restricting access rights of private property and 

mining claim owners of preexisting rights of way.

All Both emc0262GB 

emc0107rm

78. On page 11 of the Conservation Measures, the Travel and Transportation section lists how road and highway networks 

may adversely affect sage-grouse and its habitat, and lists methods of minimizing the effects that roads and highways may

All Both emc0271GB
C. Comments by Resource Planning Issue

C-1126 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

have on sage-grouse and its habitat. Many of the methods listed are already requirements of existing federal regulations, 

and most likely State and local regulations that define road and highway construction and maintenance on the public 

lands. The Travel and Transportation section also addresses restoration (reclamation, closure) of roads, primitive roads 

and trails not designated in travel management plans. It is Kane County’s position that the County should be consulted 

prior to restoration (reclamation, closure) of any roads and trials within its boundaries.

79. Finally, roads may cause very similar impacts to sage-grouse as well as threatening to cause unique harm to sage-grouse 

and associated habitat. Surveys reveal that approximately 95 percent of all sage-grouse habitat is within 1.5 miles of a 

mapped road. As with other infrastructure discussed herein, impacts from roads may include direct habitat loss, direct 

mortality, barriers to migration corridors or seasonal habitats, facilitation of predators and spread of invasive vegetative 

species, and other indirect influences such as noise. Roads also increase human access to sage-grouse habitat, thus 

causing indirect effects from human presence, including avoidance, disturbance, stress, and vulnerability to hunting and 

poaching. Use of roads may also lead to pollution, as oil is released onto the road and/or waterways, and dust and fine 

particulate matter rises from impact with dirt roads. This dust not only pollutes the air, but can damage vegetation 

through interference with photosynthetic activities. Roads also may provide open corridors for predators, and thus 

sage-grouse may avoid these uncovered pathways. Because of all these associated impacts, it is no surprise that 

sage-grouse tend to avoid roadways and areas close to roads. This behavior can severely fragment their habitat and limit 

their willingness to travel to different habitats required for year-round survival, or alternatively requiring them to travel 

long distances to find secure habitat for breeding, nesting, brood-rearing, and wintering. In fact, studies have revealed 

that areas now extirpated have a 25 percent higher density of roads than currently occupied areas.

All Both emc0276GB

80. For the same reason, we appreciate the Technical Team Report’s suggestion to evaluate the need for permanent or 

seasonal road or area closures.28 Additionally, new roads should only be built in priority sage-grouse habitat when 

absolutely necessary for agency or administrative purposes or for motorist safety. We agree with the Technical Team 

Report’s suggestion to exclude new Right of Way permits in priority sage-grouse habitat subject to valid existing 

rights.29 We also support the Report’s directive to remove powerlines where possible and reclaim right-of-way sites 

no longer in use and relocating or undesignating unauthorized rights-of-way

All Both emc0276GB

81. EI Paso maintains and operates numerous facilities within sage-grouse habitat; our operations staff need to access 

portions of our right-of-ways to conduct emergency repairs, address safety concerns and perform routine maintenance 

activities. On page 11 of the NIT Conservat ion Measures document, the second bullet of the Travel and Transportation 

section indicates that "Travel managemen/ should evalua/e the need for permanent or seasonal road area closures." 

Provisions must to be made in the conservation measures to allow year- round access to the ROW for both safety and 

maintenance issues. In the event roads arc sched uled for closu re, the BLM/FS must be required to coordinate any road 

or area closures with the public and all affected parties such as EI Paso prior to any permanent or seasonal closures to 

see how thcse closures would impact pipeline safety.

All Both emc0278GB

82. Any new conservation measures should allow for va ryi ng degrees of impact within lhe PPH areas. The third bullet on 

Page 23 of 74 of the NTT Conservation Measures document addresses this issue as it pertains to Leased Federal Fluid 

Mineral Estate . The conservation measure stales " ... Any development to be placed at the most distal part of the lease 

All Both emc0278GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1127

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

from Ihe lek, or, depending on lopography and other habitat aspects, in an area that is less demonstratably harmful to 

sagegrouse." While an absolute requirement that sage-grouse preservation should trump all other siting considerations 

is obviously not palatable, the concept of considering the distance and terrain between disturbance and the sage-grouse 

habitat to be protected is very appropriate. As the distance increases from a known breeding location or complex of 

locations, increased levels of disturbance should be allowed. For example, roads that intercept the edge of a PPH should 

be available for use during the breeding season. Impacts from this level of disturbance would be minimal and still allow 

for projects to move forward.

83. Suggest that –on Page 11. Priority sage-grouse habitat areas bullet #1. “Limit motorized travel to designated roads and 

close and re-vegetate primitive roads and trails”. Suggest that this sentence be removed which would encourage 

voluntary conservation.

All Both emc0291GB, 

emc0055RM, 

emc0119RM

84. Outline criteria for travel management planning to minimize impacts of off-road vehicle use in sage grouse habitat and 

lek areas.

All Both emc0305GB

85. On page 11 of the NTT report the conservation measures for Travel and Transportation call for limiting motorized 

travel to designated roads, primitive roads, and trails at a minimum. While I respect the need for not creating roads 

haphazardly, going off-road to retrieve game should not be restricted. These one-time cross-country travel trips should 

be permitted.

All Both emc0322GB

86. The evaluation of the need for permanent roads or seasonal road/area closures should include public input as part of the 

evaluation. Many of these roads that receive limited use are important to ranchers for getting to water developments, 

distributing salt or supplements, and towing horse trailers to the ends of the roads to initiate riding to move livestock. 

Effective livestock grazing, which can benefit sage-grouse, depends on the continued use of such roads and trails.

All Both emc0322GB

87. Closure of these roads impacts me, limits mineral exploration, and others that use public lands. Closure should be a last 

resort, and seasonal restrictions need to be evaluated with public input.

All Both emc0322GB

88. "During activity level planning, where appropriate, designate routes with current administrative /agency purpose or 

need to administrative access only" (page 11, third bullet under Priority sage-grouse habitat areas). This implies that if 

the agency folks determine that they need a road to remain open to do their job, then it will remain, but be restricted 

to their use only. But others that identify a need to use a road to do their jobs (ranches, geologists, guides/outfitters, 

etc.) are.basically out of luck. I would like this double standard to be evaluated in the EIS.

All Both emc0322GB

89. "Allow no upgrading of existing routes that would change route category .. " (page 12, first bullet). Many of the roads 

that are established by repeated travel over the same trail require upgrading to prevent erosion. Installation of water 

bars, sediment traps, and berms to prevent run-on are the types of upgrades that limit erosion. Without these upgrades, 

habitat damage can occur, especially on slopes.

All Both emc0322GB

90. "Conduct restoration of roads, primitive roads, and trails not designated in travel management plans ... (page 12, second 

bullet). The travel management plans need to be developed with public input and the decision to "conduct restoration" 

(ie., road closure) also needs to include public input.

All Both emc0322GB

91. On page 25, Wildfire Suppresion, Fuels Management and Fire Rehabilitation section of the NTT report indicates that 

wildfire has resulted in significant habitat loss for sage-grouse. Yet quick response to fires is critical in managing the size 

All Both emc0322GB
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of the fires and the intensity of the fires, and the BLM and USFS want to close roads that would facilitate quick response. 

The conservation measure to close roads in high priority sage-grouse habitats (page 11) is in direct conflict with 

effective wildfire suppression. This is just one of the many conflicting issues in this document.

92. We are concerned that the Notice specifically calls out off-highway vehicle (OHV) management and recreation as a 

preliminary issue, particularly as supporting documents from the U.S. Fish and Wildlife Service (FWS) cite other factors 

as the primary threats to the species. For example the FWS Fact Sheet on Endangered Species Act Listing Decision for 

the Greater Sage-Grouse dated March 5, 2010 notes; "The Service analyzed potential factors that may affect the habitat 

or range of the greater sage-grouse and determined that habitat loss and fragmentation resulting from wildfire, energy 

development, urbanization, agricultural conversion, and infrastructure development are the primary threats to the 

species." While we understand that on the localleve! there may need to be consideration of how OHV trails and areas 

impact the sage-grouse on a case-by- case basis, there seems to be little science supporting OHV use as a substantial 

factor affecting overall sage-grouse populations.

All Both emc0330GB

93. Clearly all forms of recreational users utilize roads, trails, campsites, facilities and other features/amenities on public 

lands. What is the purpose for singling out OHV use when, again, there is little if any scientific evidence that OHV 

recreation poses any more of a threat than other forms of recreation?

All Both emc0330GB

94. o Roads The NTT Report suggests several broad-scale prohibitions on various land-use activities such as road building, 

which are over-inclusive and unnecessary. For example, the Report suggests that all off-road travel be prohibited in 

priority habitat and no new rights-of-way be allowed in priority habitat, except in limited circumstances such as 

accessing valid existing rights. Similarly, the Report suggests that all existing roads in Wilderness Study Areas and lands 

with wilderness characteristics be closed and restored. The use of such blunt prohibitions, rather than more narrowly 

tailored management prescriptions should be avoided. Periodic use of most such roads would not likely have an adverse 

effect on sage-grouse populations.

All Both emc0331GB

95. Furthermore, in its Warranted but Precluded decision FWS identified power lines as directly affecting greater 

sage-grouse and outlined the possible threats: collision and electrocution hazard; decrease in lek recruitment; increase 

in predation; fragmentation of habitat; and facilitation of the invasion of exotic annual plants. Additionally, sage-grouse 

could be impacted through a direct loss of habitat and human activity (especially during construction periods). 

Transmission corridors pose a serious threat to the wide ranging sage-grouse and should be analyzed thoroughly in this 

process. The impacts of fragmentation from transmission lines and the tendency of greater sage-grouse to avoid large 

infrastructure like power lines should lead to the establishment of strong standards that guide transmission corridors to 

appropriate areas that avoid impacts to sage-grouse.

All Both emc0339GB

96. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: -

Placement, use, construction, and maintenance of roads and railroads in greater sage grouse habitat may lead to negative 

impacts

All Both emc0343GB

97. In winter, sage grouse select large expanses of sagebrush with gentle topography and avoided conifer, riparian, and 

energy development (Doherty 2008). Well density had an additional effect in this study (id.). Sage grouse were 30% 

more likely to use winter habitat if CBM development was not present (id.). There was a landscape-scale effect of 

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habitat selection, with areas with greater sagebrush at a 4 km2 scale receiving greater winter use (id.). Carpenter et al. 

(2010) found a similar relationship in Alberta, and found that grouse avoided oil and gas wells by 1.9 km and also showed

some avoidance of jeep trails. Bruce et al. (2011) found that sage grouse moved widely across winter habitats, using an 

area of 1,480 km2, and recommended setting aside large reserves for winter habitats. According to Doherty (2008:22), 

“Identifying and setting aside areas of undeveloped, high-quality habitat within the project area should be top priority.” 

Doherty (2008:22) asserted, “My spatially explicit winter habitat model can be used to identify areas in the PRB that 

provide the best remaining habitat for sage-grouse in winter.” BLM should apply this model to the Powder River Basin 

and place areas predicted to be the best remaining sage grouse winter habitat off-limits to future oil and gas leasing, in 

addition to placing strong restrictions on the level of development that is allowed on existing leases. Similar protocols 

should be developed and followed throughout the remainder of the sage grouse range.

98. In his 2008 study, Doherty found that distance to roads and distance to wells were good predictors of sage grouse 

nesting; since distance to roads and distance to wells were moderately autocorrelated and roads were a more highly 

predictive modeling variable, distance to wellpads was dropped from the model. According to Doherty (2008:49), “The

coefficient for distance to road ( β-grouse distroad = 0.0002) suggested that n may avoid CBNG roads.” 

Model validation later caused distance from roads to be dropped from the model. Notably, in the Powder River Basin 

study area, CBM access roads could be either constructed roads or two-tracks. Apparently, distance from wells was not 

tested during model validation, despite being a predictor of nest distribution. Thus, the results of Doherty (2008) can 

best be characterized as inconclusive with respect to the influence of distance to well on nest site selection. Impact of 

distance to well on breeding male population on the lek was not tested by this study. This portion of the study also 

found nest site selection on larger habitat scales, indicating once more that the availability of large tracts of suitable 

habitat had a positive influence on nest site selection.

All Both emc0343GB

99. Leks must be buffered from wellfield roads Road construction related to energy development is a primary impact on 

sage grouse habitat from habitat fragmentation and direct disturbance perspectives. Rowland et al. (2006: 5-10) 

modeled sage grouse distribution, and reached the following conclusions: “The secondary road network is a highly 

significant factor influencing processes in this landscape and is being developed and expanded rapidly across much of the 

WBEA. Secondary roads are being built as part of the infrastructure to support non-renewable energy extraction. For 

example, within the Jonah Field in the Upper Green River Valley, >95% of the area had road densities >2 i/mi2.” 

(Internal citations omitted). Furthermore, “The dominant feature affecting output of the sage-grouse disturbance 

model was secondary roads, which occupy nearly 8% of the study area (Table 5.2) and are presumed to negatively 

influence an even larger extent.” Pp. 6-15 through 16. Holloran (2005) found significant impacts of road traffic on sage 

grouse habitat use in the Pinedale Anticline gas field, concluding that habitat effectiveness declined in areas adjacent to 

roads with increasing vehicle traffic, documenting the secondary effect referenced by Rowland et al (2006). Roads 

should be restricted from being built within 2 miles of leks. For already-existing roads, a seasonal “lock-out/gate-out” 

policy should be enforced between March and July. There is precedent for the in the Bill Barrett Big Porcupine CBM 

Field on the Thunder Basin National Grassland, in which by Settlement Agreement roads within 2 miles of leks are 

closed each spring, and operator access during this period is via bicycle. The Lander Resource Management Plan Draft 

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EIS has similar restrictions in the agency’s Preferred Alternative, under which Timing Limitation Stipulations apply not 

only to drilling and construction activities but also to all disruptive activities throughout the life of the field.

100. Road construction related to energy development is a primary impact on sage grouse habitat from habitat fragmentation 

and direct disturbance perspectives. Rowland et al. (2006) modeled sage grouse distribution, and reached the following 

conclusions: “The secondary road network is a highly significant factor influencing processes in this landscape and is 

being developed and expanded rapidly across much of the WBEA (Thomson et al. 2005). Secondary roads are being 

built as part of the infrastructure to support non-renewable energy extraction (Chapters 2, 4). For example, within the 

Jonah Field in the Upper Green River Valley, >95% of the area had road densities >2 mi/mi2 (Thomson et al. 2005).” p. 

5-10. Furthermore, “The dominant feature affecting output of the sage-grouse disturbance model was secondary 

roads, which occupy nearly 8% of the study area (Table 5.2) and are presumed to negatively influence an even larger 

extent.” Pp. 6-15 through 16. Holloran (2005) found significant impacts of road traffic on sage grouse habitat use, 

concluding that habitat effectiveness declined in areas adjacent to roads with increasing vehicle traffic, documenting the 

secondary effect referenced by Rowland et al.

All Both emc0343GB

101. At minimum, the NEPA analysis should address the following: • Prioritizing roads for closure to minimize road 

densities inside sage grouse Core areas. • Providing seasonal closures for existing roads within 2 miles of sage grouse 

leks.

All Both emc0343GB

102. Notice of Intent (NOI) states: The BLM and FS will consider allocative and/or prescriptive standards to conserve 

greater sage-grouse habitat, as well as objectives and management actions to restore, enhance, and improve greater 

sage-grouse habitat Both agencies must consider the respective roles of program and project-level planning. As applied 

to the recreation context, if the agencies consider plan amendments that conduct a “open, close or restrict” allocation 

decision they must comply with applicable law, including NEPA and the 2005 Travel Management Rule (“TMR”). The 

TMR requires that changes from the existing management prescriptions must be analyzed through advance notice and 

public comment “consistent with agency procedures under [NEPA].” 36 CFR § 212.52(a). If plan amendments make 

“zoning” changes that would alter existing management prescriptions, the agencies must conduct site-specific analysis 

sufficient to comply with the NEPA.

All Both emc0345GB

103. The use of sound modeling and optimization of road design in sage grouse habitat could greatly reduce the need for the 

proposed conservation measures in priority habitat. Recent innovation and research has shown that more efficient use

of roads (e.g. minimizing crew rotations, and where logistically and economically feasible piping rather than hauling 

produced water and condensate) can greatly reduce traffic and subsequent impacts to sage grouse. This approach has 

been intentionally undertaken by a number of API members, and has resulted in significant reduction of truck traffic up 

to 85% in some cases, compared to conventional development scenarios. A collaborative approach with industry to 

optimize road design and road use is more likely to reduce overall impacts to sage grouse than the proposed blanket 

surface disturbance thresholds (which inappropriately assume an equal level of effect across all road types, topography, 

and levels of use or the same type of development and disturbance for projects).

All BLM emc0346GB

104. We are concerned that amendment of federal plans could have an impact on local transportation plans and RS 24 77 

access rights. Such potential impacts must be fully analyzed in the NEP A process. Uintah County will not accept the 

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closure of roads that have historically provided access to public land resources and remain important today.

105. The BLM has a multiple use mandate under Federal Land Policy and Management Act (FLPMA). The existing Resource 

Management Plans (RMPs) were developed after many years of analysis and public input, resulting in land use plans that 

struck an acceptable balance between multiple uses. Yet, this latest effort illustrates the continued threat of political

vagaries potentially shifting that balance in a manner that is detrimental to energy development, grazing, fuel and 

vegetation management, mineral development and recreation. Any selected alternative must minimize the .restrictions 

placed on these legitimate and important land uses. We encourage the BLM to follow through on its commitment to 

protect valid, existing rights; such as grazing and energy leases and RS 24 77 access rights. We encourage the BLM to 

look not only at habitat availability, but also habitat suitability given the energy and mineral potential and other multiple 

use potential of preliminary priority sagegrouse habitat areas. The adoption of sound consistent land use areas insures 

there is no risk of sage-grouse conservation efforts hampering the energy industry's ability to produce domestic natural 

resources

All Both emc0376GB

106. Roads and off-highway vehicles. Issue: Roads fragment sage-grouse habitat, and vehicle use on and off-road disturbs 

sagegrouse and can contribute to sage-grouse population declines.

All Both emc0391GB

107. Less than 5 percent of sage-grouse current range is >2.5 km (>1.55 mi) from a mapped road (Knick et al. 2011). Roads 

have multiple impacts on sage-grouse (SGNTT 2011: 11, citing others; Braun 1998). Sage-grouse are killed in collisions 

with vehicles and may be affected by roads up to 6.9 km (4.2 miles) away (Connelly et al. 2004: 13-21, Table 13.1). 

Off-highway vehicles can disturb sage-grouse, fragment habitat, and spread nonnative plants in sagebrush steppe (Knick 

et al. 2011). The BLM has affirmative duties to evaluate existing authorizations and uses (including travel management) 

and take steps to protect natural resources, including sage-grouse (BLM Memo IM 2012-043).

All Both emc0391GB

108. BLM must characterize and map all roads and trails that are found in sagebrush habitats. It must require that no off-road 

use occur, and no widening and blading of road shoulders intrude into, and extend weeds into, occupied habitats. Place 

after place from Ely Forest Service to the Montana Mountains to the Pahsimeroi, we are seeing side blading of roads and 

these road verges and water bars providing a corridor for cheatgrass expansion. Some of this is being done under claims 

of a need for fire access and fire breaks when in fact the spread of cheatgrass from the road blading is increasing the 

likelihood of fire.

All BLM emc0411GB

109. In Elko County, the Wells and Elko RMPs leave nearly all lands wide-open to OHV use, crosscountry mining, oil and gas, 

geothermal and all manner of other exploration – including industrial wind or other energy roading. This process cannot 

just allow the current nightmare of roading in many areas of sage-grouse habitat to continue. BLM must act to identify 

roads for seasonal closure, or active restoration removal to limit disturbance during sensitive periods, and to recover 

and restore disturbed road area weed corridors. This will help provide habitat security and protection for sagebrush 

habitats and sage-grouse during sensitive seasons of the year. Motorized grazing permittee use must be limited. 

Ranchers have horses, and can conduct activities in wild lands using horses.

All Both emc0411GB

110. BLM should identify some roads for closure and rehab under this process - to limit weeds, disturbance, predator travel 

corridors, etc

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111. The Plan amendments "will be limited to making land use plan decisions specific to the conservation of sage-grouse." 

This will only serve to cause more conflict. Many inadequate mining, energy, visual, transportation/OHV and other 

provisions of Land Use Plans come into direct conflict with sage-grouse habitat protection requirements, and it is very 

hard to understand just how BLM will split hairs here. See WWP Jarbidge RMP comments, explaining how weak VRM 

standards, lack of mineral withdrawals, energy accommodations and other RMP provisions would adversely affect 

management of sage-grouse habitats for sustainable populations. It will also serve to put more species in jeopardy - as 

sagebrush-dependent species with differing habitat requirements to some degree than sage-grouse get impacted as 

agencies shift and intensify all manner of degrading and disturbing uses (such as livestock) into the Sacrifice General 

occupied habitats or non-grouse areas.

All BLM emc0411GB

112. For the past couple of years, agencies have been using another category to try to separate out populations, and minimize 

the importance of losses to the sagebrush habitats. This is the effort to segregate greater sage-grouse into eastern vs. 

western portions of the range on the basis of claims that grouse face different threats in different parts of their range. 

USFWS used this artifice in defending its toothless Warranted but Precluded Finding in litigation, and took it to absurd 

lengths in its arguments there. First, many of the same threats occur across the range - livestock grazing, roads no 

matter what the cause, invasive species, mining. Second, increasingly renewable energy threats with many of the same 

impacts as oil and gas are accelerating in the western portion of the species range, and mining is exploding in northern 

and central Nevada and some other western areas. Plus hundreds of thousands of acres are now being leased for oil and 

gas development all over Nevada. Renewable energy examples: Major industrial wind farm on Steens Mountain Oregon 

and new transmission lines, major new transmission lines like Gateway and MSTI, geothermal development often by 

foreign entities (McGinness Hills and other areas), massive geothermal leasing proposals are appearing - for over 

500,000 acres on Bridgeport Ranger District lands and elsewhere in NV. Mining is expanding into new areas where 

sage-grouse populations are already barely hanging on, and new mining is proposed in areas with larger populations, as 

well. In the east, weeds like cheatgrass are increasing (see WBEA Assessment discussion). New and expanded mining, 

new transmission lines, and oil and gas harms are far exceeding those agencies claimed would occur from these new or 

recently expanded developments. See 2012 Yubanet article on failures of Wyoming Core Model in the Powder River 

Basin.

All Both emc0411GB

113. The lists of Conservation Measures that provide part of the basis for the Federal Register information and this whole 

process, is limited and uncertain. BLM is not serious about making significant changes. For example with roads - BLM 

plans merely to limit travel to existing roads - not question whether any existing road is actually needed no matter what 

the road density may be.

All BLM emc0411GB

114. Road BMPs includes: Restrict traffic to only "authorized users" on new roads. This effectively privatizes the road and the 

public lands to benefit developers. It cuts off public access to public lands - so that the public cannot see what industry 

is doing to them and to sage-grouse habitats. This would allow wind developers, oil and gas and other interests to cut 

off public access to sites. It would give priority to users who profit from public lands - at the expense of the public. We 

note that the China Mountain DEIS contained just such a provision to block public access, and prevent the public from 

seeing the environmental damage (and avian and bat mortality) that development and operation of industrial wind 

All BLM emc0411GB
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May 2012 Greater Sage-Grouse LUPAs/EISs C-1133

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facilities causes. This benefits developers who don't want the public to report dead golden eagles or dead sage-grouse 

killed by industrial wind or other energy facilities. Plus public lands ranchers who are abusing public lands have long 

sought to restrict public access (albeit at the same time that the rural county they are in is claiming every goat trail as an 

RS 2477 right of way). There is not even a requirement that an equal number of roads to those being built must be 

closed - for example. All these same old standard BLM BMPs do is to enable more disturbance to tear apart a landscape. 

There is no requirement for removal of existing disturbances from higher quality or other important habitats. Closing 

and rehabbing "duplicate" roads only does not reduce road density.

115. Regarding recreation, the plan amendments should direct local land managers to cooperate and coordinate with local 

governments and affected stakeholders to establish achievable goals for protection of the Grouse (lek /nest disturbance, 

wintering areas and sage habitat degradation) and to mitigate potential affects upon recreation through closure of 

existing, inventoried and managed routes.

All Both flb0000gb

116. The amendments should recognize that local agency recreation planners and managers are the best suited to work with 

motorized stakeholders to establish a manageable, designated, user and nature friendly route network for motorized 

access. This includes access roadways away from paved highways; high clearance routes for pickups, jeeps and other 

4WD vehicles; that can be shared under mixed-use by other OHV categories such as trail bikes, ATV/UTV and/or OSV 

in the winter. Just as important to the motorized community are rural 2 track routes, ATV width trails, and trail bike 

single-track width routes.

All Both flb0000gb

117. The analysis should include the fact that the BLM, Forest Service, state, county, local and tribal land management 

agencies are moving towards a "limited to designated route" paradigm. This process should prioritize areas where such 

planning has not yet occurred. I strongly believe that the goals, objectives and new paradigm can be met without 

severely limiting or restricting responsible, managed motorized recreation uses within the planning area.

All Both flb0000gb

118. I also believe thrill-seeking ORV enthusiasts should confine their activities to well-managed courses and tracks, and do 

not merit access to the greater wilderness in any way.

All Both fld0005rm, fld0005gb

119. I support closing roads to motorized vehicles when it they are likely to be destructive to the land. All Both fld0007rm, fld0007gb

120. Closing access to OHVs may not impact Grouse populations at all, but it will severely impact the lives of families that 

recreate on OHVs

All Both fle0002gb

121. I understand the value of the Sage Grouse and the threat of extinction. However, I do not believe that there is any 

credible evidence to suggest that motorized recreation or mountain biking have a significant impact on Sage Grouse 

populations. If motorized recreation impacts on the Sage Grouse are found, the impact areas should be well defined and 

alternative recreational routes developed to maintain or increase recreational activities available.

All Both fle0007gb

122. The motorized recreation and mountain biking community have lost too many routes. Greater numbers of users are 

sharing fewer trails increasing the impact on those trails. I support policies that responsibly increase the availability of 

motorized and mountain biking trails to the benefit of the people with a sustainable impact on the land.

All Both fle0007gb

123. Reduce overall road density All BLM fln0000rm

124. The lead agency will divulge and explain any impacts on state and county transportation plans and routes. They will also All Both rmc0004GB
C. Comments by Resource Planning Issue

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allow for management coordination with the state and county on travel restrictions on all roads throughout the 

resource area undergoing plan amendments.

125. The plan should include protection of habitat from energy developmetn and road building All Both rmc0008RM

126. The Organizations are very concerned that the 2010 Conservation Measures proposed do not accurately reflect the 

priority or significance of particular threats to the Grouse that were identified in the FWS listing decision. A review of 

the Conservation Measures and related documents could easily allow the conclusion that all BLM planning was found 

insufficient to protect the grouse. The FWS listing decision specifically noted that only oil and gas exploration and fire 

suppression were areas where current BLM management was insufficient. The FWS listing decision notes that moving to 

a designated trail system, as BLM is already doing nationally, is one of the largest and most important protections for 

grouse habitat involving recreational activity. The failure to properly prioritize threats and management priorities will

result in inconsistent management, which may target issues that will generate significant costs and economic impacts and 

generate little benefit to the grouse.

All Both rmc0033GB

127. The 2010 Grouse Conservation Measures propose management standards for federal lands that do not allow for 

management flexibility to address the range of impacts from various levels of road usage. The 2010 Conservation 

Measures specifically identify that all roads will generate similar impacts to the grouse and define roads in a very broad 

manner regardless of the speed or volume of usage on the roadway. This standard is simply not supported by relevant 

Grouse research and the Organizations are aware that the presence of a high speed arterial road can be a significant 

impact to wildlife in the area. The Organizations are also aware that a low speed two track road, that may not be used 

for days at a time, often has little to no impact on wildlife. These low speed low volume forest service roads are often 

access points for numerous activities for all forest users that are not involved in grouse management. If these low 

volume low speed roads are closed, these opportunities will be lost and little benefit to the grouse will be achieved, 

while the lost recreation will result in significant negative economic impacts to communities. This negative economic 

impact will directly undermine any support from the public regarding grouse management. Given the range of issues and 

need for private lands to be involved in grouse management, this loss of public support will directly impair conservation

measures taken.

All Both rmc0033GB

128. The 2010 Conservation Measures proposes a single standard for all road management, which is summarized as follows:

liThe Travel and Transportation program is principally focused on road networks within the sage-grouse range. Roads 

can range from state or interstate highways to gravel and two-track roads."l While the level of road usage is not directly 

addressed in the listing decision, the Organizations believe this lack of discussion evidences the low priority that 

recreational trail usage is for sage grouse management. As noted elsewhere in these comments recreational usage of 

grouse habitat has been specifically identified as a minimal threat to the grouse, by both the US Fish and Wildlife Service 

and the Colorado Department of Wildlife. The Organizations are very familiar with the fact that an interstate highway 

or arterial road has significantly more impact on wildlife than dispersed motorized recreation in the backcounty, given 

the intensity of high speed use on the arterial road. This position is based on a large body of scientific works addressing 

many types of wildlife, that conclude: "Several studies have shown that traffic volume was positively correlated with

animal mortality on roads (Fahrig et al 1995, Joyce and Mahoney 2001). For example, Inbar and Mayer (1999: p. 865) 

All Both rmc0033GB
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stated that ((Of all the traffic volume data sets, mean nighttime traffic generated the only significant correlation with 

road kill".Vehicle speed also has long been implicated in animal mortality on roads (Dickerson 1939). Case {1978} and 

Rolley and Lehman {1992} reported that vehicle speed was significantly correlated with road mortality."s

129. Grouse have also exhibited the same avoidance of high traffic high volume roads. Researchers have again noted:

"Gunnison sage-grouse also exhibit a clear avoidance of paved, high traffic volume roads during nesting at the patch 

scale, in addition to prior avoidance of higher density 2-wheel drive accessible roads at the landscape scale. 

Landscapelevel response may reflect selection for less fragmented areas. However, the direct avoidance of high volume 

roads in patch-scale models reinforces that Gunnison sage-grouse are selecting for resources hierarchically... ... This

corresponds with a lek analysis in Wyoming and Utah which found that greater sage-grouse leks within 7.5 km of 

Interstate 80 appear to have declined at a much faster rate than those further away." 9 (Internal Citations omitted.)

Rather than address the significantly different impacts to wildlife from arterial roads and two track roads, the Report 

classifies all roads under a similar standard of impact: "The effect of roads can be expressed directly through changes in 

habitat and sage-grouse populations and indirectly through avoidance behavior because of noise created by vehicle 

traffic." 10 The failure to distinguish between the different levels of impacts to wildlife that result from the various levels 

of road development carries through the 2010 Conservation Measures to the proposed management standards for 

roads. The 2010 Conservation Measures proposed a single conservation measure for all roads as: ". Limit motorized 

travel to designated roads, primitive roads, and trails at a minimum. Travel management should evaluate the need for 

permanent or seasonal road or area closures."

All Both rmc0033GB

130. While the distinction between impacts of arterial roads and trails is significantly different when impacts to wildlife are 

assessed, the varying levels of impacts simply are not addressed in the 2010 Conservation Measures. Unfortunately, the 

2010 Conservation Measures propose to manage all roads under a similar standard. This is simply not supported by any 

research and will result in significant negative economic impacts that simply will achieve little to no benefit to the grouse. 

The Organizations believe this oversight will directly impair the performance of the 2010 Conservation Measures in 

terms of protecting grouse and must be remedied.

All Both rmc0033GB

131. 2b. Confusion on the impact of low usa&e roads already exists for sa&e lUouse mana&ement The Organizations believe 

the identification and development of consistent management standards to accurately reflect the possible impact to 

wildlife of each route is a critical portion of the 2010 Conservation Measures. This lack of consistent accurate 

management of low speed low volume routes is already an issue for travel management planning in BLM field offices,

when field office RMP proposals are compared. Recent proposed RMPs from two field offices in Colorado highlight the 

conflicting management standards involving grouse management. While the Kremmling and Colorado Valley Field 

Offices are almost directly contact each other and encompass significant grouse habitat, the proposed RMP's propose 

management standards that are significantly different. The Kremmling Field Office's RMP proposes to erroneously limit 

all routes and travel in sage grouse habitat as follows: "Within the Planning Area, reduction of human disturbance and 

fragmentation is needed in order to protect the remaining sage-grouse habitat. Limiting new roadways, 

decommissioning unnecessary roads, and reclaiming illegal trails, will help reduce habitat fragmentation and protect the 

birds and their habitat from human disturbance."11 The Colorado River Valley Office proposed RMP did not include any 

All Both rmc0033GB
C. Comments by Resource Planning Issue

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Table C-9.A

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restrictions for road development or usage, while significant fire mitigation and oil and gas development regulations

were proposed. The Colorado Valley proposal appears to propose managing in conformity with the priority issues in 

sage grouse habitat as identified in the 2010 FWS listing decision. Unfortunately, the Kremmling offices RMP targets 

issues that are not a priority in the 2010 FWS listing decision. The inconsistency of these standards could be resolved 

with the 2010 Conservation Measures accurately addressing the priority of issues that are impacting the grouse. This 

consistency will lead to lower costs, more effective management and greater public support as management will be 

effectively protecting the grouse at a minimal cost.

132. While the 2010 FWS listing decision did change the status of the grouse on the Endangered Species list, the threats and 

issues discussed in the listing decision were not a significant change from the existing body of grouse research. The 

existing body of research, by both State and federal scientific partners of the BlM, indicates low-use roads and trails 

simply are not an issue for grouse survival or habitat

All Both rmc0033GB

133. This research indicates that the transition to a designated trail system for summer usage is of significant benefit to the 

grouse compared to open riding area designations. While this change has already been implemented in many field 

offices, the positive benefits to the grouse that result from this change are simply not addressed in the Conservation 

Measures, which seek to designate all roads as a negative impact to the grouse. This position is simply not supported

when current designated route systems are compared to an open riding designation. The impact of the designated route 

system for summer use should be addressed in the Conservation Measures in insure the benefits to the grouse from this 

change are properly identified by field offices in making multiple use decisions involving grouse habitat.

All Both rmc0033GB

134. The wide range of issues impacting the sage grouse are also discussed in the 2010 Fish and Wildlife Service listing 

decision regarding the sage grouse and CDOW management strategies for the sage grouse. 15 Recreational activities 

were specifically found to be of minimal concern in sage grouse management in the 2010 USFWS listing decision, which 

stated: "Although we anticipate use of pesticides, recreational activities, and fluctuating drought conditions to continue 

indefinitely, we did not find any evidence that these factors, either separately, or in combination are resulting in local or 

range-wide declines of greater sage-grouse.,,16 While the FWS findings cited above do not specifically identify 

motorized recreation, they provide an extensive discussion of possible motorized recreational impacts prior to 

concluding that recreation has a minimal impact on the sage grouse. The 2010 USFWS listing decision again stated that 

adoption of a designated trail system for recreational purposes is of significant benefit to the sage grouse. The 2010 

USFWS listing decision discussed changes to designated trails on USFS lands as follows: liAs part of the USFS Travel 

Management planning effort, both the HumboldtToiyabe National Forest and the Inyo National Forest are revising road

designations in their jurisdictions. The Humboldt-Toiyabe National Forest released its Draft Environmental Impact 

Statement in July, 2009. The Inyo National Forest completed and released its Final Environmental Impact Statement and 

Record of Decision in August 2009 for Motorized Travel Management. The ROD calls for the permanent prohibition on 

cross country travel off designated authorized roads." 17

All Both rmc0033GB

135. As we have seen in the past, any listing triggers an overreaction to restrict many human activities, access to public lands, 

and road closures.

All Both rmc0047GB, 

rmc0013rm

136. Before new policy is adopted regarding the preservation and protection of sage grouse and sage grouse habitat, the All Both rmc0054GB
C. Comments by Resource Planning Issue

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issue of road closure needs to be studied and analyzed to a much greater extent than has happened to this time.

137. The amendments should recognize that local agency recreation planners and managers are the best suited to work with 

motorized stakeholders to establish a manageable, designated, user and nature friendly route network for motorized 

access. This includes access roadways away from paved highways; high clearance routes for pickups, jeeps and other 

4WD vehicles; that can be shared under mixed-use by other OHV categories such as trail bikes, ATV/UTV and/or OSV 

in the winter. Just as important to the motorized community are rural 2 track routes, ATV width trails, and trail bike 

single-track width routes.

All Both rmc0061GB, 

rmc0035RM

138. Any plan amendment should include adequate site-specific analysis on anticipated impacts of motorized and 

non-motorized recreational activities, which often have little to no impact on wildlife. The impacts of motorized and 

mountain bike routes that are primarily used for recreation should not be "lumped in" with highways and other 

high-speed access roads.

All Both rmc0061GB, 

rmc0035RM

139. The analysis should include the fact that the BLM, Forest Service, state, county, local and tribal land management 

agencies are moving towards a "limited to designated route" paradigm. This process should prioritize areas where such 

planning has not yet occurred. We strongly believe that the goals, objectives and new paradigm can be met without 

severely limiting or restricting responsible, managed motorized recreation uses within the planning area.

All Both rmc0061GB, 

rmc0035RM

140. As discussed above, North Park has a very stable sage-grouse population. Anthropogenic land uses have occurred on 

the BLM in the past and we have been able to maintain a healthy sagegrouse population. We have had oil and gas 

development (e.g. the McCallum Oil Field), strip mining, gravel pits, power lines and limited amount of road 

development. Sage-grouse are present even though there has been historical anthropogenic disturbance. We are 

requesting that analyses be conducted to show how the current BLM regulations are not adequate to maintain 

sage-grouse in North Park. We recommend that the BLM analyze disturbance through time, possibly through historic 

aerial photographs, in conjunction with historical sage-grouse population data to determine the historical amount of 

anthropogenic disturbance in North Park that has been consistent with the maintenance of a stable sage-grouse 

population.

CO BLM emc0060RM

141. Where these WMAs are created, if current roads and trails exist that are used for access to surrounding areas and 

these roads or trails are the only source of access by motorized use, new roads or trails must be provided around these 

WMAs or at a minimum the lek area, for continued access to the surrounding area.

CO BLM emc0067RM

142. Speed restrictions or other measures such as seasonal closures as deemed necessary through the WMAs could be 

implemented for further limits of intrusion.

CO BLM emc0067RM

143. It has been proved time and again that animals can adapt to many "encroachments" to their habitat. Fragmentation 

caused only by a road or trail is only a minor inconvenience to animals. Having a plowed field or some such obstruction 

of great width would be more likely to inhibit a sage grouse. The need to immediately close roads or trails should be 

extremely minimal with the exception of roads or trails directly through the middle of lek areas. In most areas of sage 

brush covered land, rerouting a road or trail around a proven lek area should not be overly cost intensive nor difficult 

from a terrain standpoint. Public access by motorized means is a resource as well and should be treated with equal 

CO BLM emc0067RM
C. Comments by Resource Planning Issue

C-1138 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

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weight to other resources.

144. The following recommendations must be analyzed as a starting point for effective conservation: Reduce overall road 

density to improve habitat function by applying Technical Team recommendations.

CO BLM emc0070RM

145. (One of the NTT recommendations most important for Routt NF) 3. Conservation measures. The following measures 

are especially appropriate for the Routt National Forest: "Limit motorized travel to designated roads, primitive roads,

and trails at a minimum" in priority habitat areas. Id. at 11. Restore "roads and trails not designated in travel management 

plans". Id. at 12.

CO USFS emc0175RM

146. V. AMEND THE ROUTT PLAN VIA MECHANISMS THAT WILL BEST HELP CONSERVE GSG. The current Forest

Plan direction potentially applicable to GSG conservation (SRC at 5-6) is inadequate to ensure survival and recovery of 

the species. None of the measures are specifically geared toward protecting GSG, and none of the oil-gas lease

stipulations apply year-round. In order to ensure the highest likelihood of conserving GSG, the Forest Service will have 

to limit human uses of GSG habitat and surrounding areas. It will be especially important that no oil-gas leasing or 

mineral development be allowed on any GSG habitat and some adjacent land. No road construction can be allowed in 

GSG habitat, subject to valid existing rights. Livestock grazing may have to be adjusted. Also, as is discussed in part 3 

below, the current management prescription assigned to the draft core areas is not appropriate for ensuring the 

protection of GSG. Thus new Forest Plan direction is needed to incorporate the recommendations outlined by the 

National Technical Team and ensure the best chances for recovery of GSG populations. The agency should amend the 

Routt Land and Resource Management Plan via the following methods, using point 1 alone, or preferably, in combination 

with points 2 and/or 3:

CO USFS emc0175RM

147. It is critical for BLM to consider implementing the following technical team recommendations as minimum standards:

Reduce overall road density.

CO BLM fll0000RM

148. Reduce overall road density CO Both flm0000RM

149. The following recommendations must be analyzed as a starting point for effective conservation: Reduce overall road 

density to improve habitat function by applying Technical Team recommendations.

East Both emc0089RM

150. iii. Strong components of Wyoming’s approach Within core areas, stipulations on BLM, FS, Wind River Indian 

Reservation, and State of Wyoming lands limit the number of projects and the amount of allowed disturbance (no more

than 5%13) allowed per square mile or 640 acres. Surface disturbance is prohibited within a 0.6 mile buffer around active 

leks (no surface occupancy - NSO), which includes roads during the breeding, nesting and brood-rearing periods 

(mid-March through end of June). In addition, a March 15 to June 30 timing limitation stipulation is required within 

nesting habitat within 4 miles of leks. Main roads used to transport production and/or waste products must be more 

than 1.9 miles from the perimeter of occupied grouse leks. Other roads used for access or maintenance must be more 

than 0.6 miles from the perimeter of occupied leks. Noise levels at the perimeter of a lek should not exceed 10 dBA 

above ambient noise from 6 pm to 8 am, so as not to disturb breeding activities (March 1 - May 15). Finally, proponents 

of new projects are expected to coordinate with the permitting agency and WGFD biologists to determine which leks

need to be monitored and what data should be collected/reported. The Executive Order clearly identifies thresholds 

East Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1139

Scoping Summary Report

Table C-9.A

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and outline adaptive management responses if declines in sage-grouse numbers occur14. However, in non-core areas, 

the EO recommends a 2-mile seasonal buffer around occupied leks and a 0.25 mile NSO buffer around active leks. 

Research has shown that the latter stipulation is inadequate and scientifically without merit. In addition, a surface 

disturbance cap is lacking from non-core area stipulations

151. The majority of sage-grouse habitat is within 2.5 km of a mapped road (Knick et al. 2011) and many secondary and 

unmapped roads and trails traverse BLM lands. Roads create both direct and indirect influences on sage-grouse; 

including: habitat loss, mortality resulting from collisions with vehicles, creation of barriers to migration corridors or 

seasonal habitats, facilitation of predators, spread of invasive vegetative species, and noise (Forman and Alexander 

1998). Off ‐ent habitat, create corridors for spread of exotic plant species trail recreation by OHV users can fragm

(Knick et al. 2011), distribute refuse, disturb and displace wildlife, increase animal mortality, and simplify plant 

communities (Boyle and Samson 1985). A study of OHV impacts to rangelands in Montana found long-term (2 years) 

reductions in sagebrush shrub canopy cover as the result of repeated trips in the area (Payne et al., 1983). Eckert et al 

(1979) observed increased sediment production and decreased soil infiltration rates after disturbance by motorcycles 

and four-wheel drive trucks on two desert soils in southern Nevada. The Technical Team suggests the following best 

management approaches for priority sage ‐grouse habitat areas: "Limit motorized travel to designated roads, 

primitive roads, and trails at a minimum.  Travel management should evaluate the need for permanent or seasonal 

road or area closures.  Complete activity level plans within five years of the record of decision. During activity level 

planning, where appropriate, designate routes with current administrative/agency purpose or need to administrative 

access only.  Limit route construction to realignments of existing designated routes if that realignment has a minimal 

impact on sage ‐grouse Use 

existing roads, or realignments as described above to access valid existing rights that are not yet developed. If valid 

existing rights cannot be accessed via existing roads, then build any new road constructed to the absolute minimum 

standard necessary, and add the surface disturbance to the total disturbance in the priority area. If that disturbance 

exceeds 3 % for that area, then make additional, effective mitigation necessary to offset the resulting loss of 

sage ‐grouse habitat."

East Both emc0167RM

152. I would like to add my comments regarding the Great Basin Region - National Greater Sage-Grouse Planning Strategy. 

I appreciate the need to protect our lands through resource management plans, but I believe the plans tend to side on 

the environmentalist side and not on the users of the land such as I. I am a senior (over 55 years) ATV rider and I 

appreciate the ability to see our land with ease, but I do not damage our lands. When I hear the goal is to protect 

sage-grouse, I believe this means closures to lands I want to visit. Please do not take the sage-grouse to the point that 

existing ATV trails are closed.

GB Both emc0182GB, 

emc0078RM

153. Address Impacts of Roads: Roads and trails impact sage-grouse habitat through weed invasions, habitat fragmentation, 

and increased activity. To improve sage-grouse habitat, BLM must prioritize limitations on roads and restoration of 

unused or harmful roads.

GB Both emc0355GB

154. The majority of sage-grouse habitat is within 2.5 km of a mapped road (Knick et al. 2011), and many unmapped roads 

and ORV trails crisscross BLM lands. Roads can influence the spread of roadside weed infestations into neighboring 

GB Both emc0355GB
C. Comments by Resource Planning Issue

C-1140 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

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lands. Many studies show that the number of weed species in an area increases dramatically with the density of roads. 

Invasive weeds are not a food source for grouse, these weeds can outcompete sagebrush and make habitat more prone 

to fire. The risk that weeds like this will spread from roads and ORV trails into adjacent ecosystems varies depending on 

the site. It is highest where ORVs leave designated trails and disturb plants and soils, especially on deeper and more 

fertile soil types, which tend to be most susceptible to invasion. In addition to the impacts from roads on the spread of 

noxious vegetation, roads can also directly impact birds though collisions and fragmentation of habitat. The NTT 

suggests the following best management approaches for priority sage ‐areas: grouse habitat o “Limit motorized travel 

to designated roads, primitive roads, and trails at a minimum. o Travel management should evaluate the need for 

permanent or seasonal road or area closures. o Complete activity level plans within five years of the record of decision. 

During activity level planning, where appropriate, designate routes with current administrative/agency purpose or need 

to administrative access only. o Limit route construction to realignments of existing designated routes if that 

realignment has a minimal impact on sage-grouse habitat, eliminates the need to construct a new road, or is necessary 

for motorist safety o Use existing roads, or realignments as described above to access valid existing rights that are not 

yet developed. If valid existing rights cannot be accessed via existing roads, then build any new road constructed to the 

absolute minimum standard necessary, and add the surface disturbance to the total disturbance in the priority area. If 

that disturbance exceeds 3 % for that area, then make additional, effective mitigation necessary to offset the resulting 

loss of sage-grouse habitat.” Summary: Roads and trails impact sage-grouse habitat through weed invasions, habitat

fragmentation, and increased activity. To improve sage-grouse habitat, BLM must prioritize limitations on roads and 

restoration of unused or harmful roads.

155. No new roads should be permitted in priority habitats. GB Both emc0404GB

156. Statements that 95% of mapped sagebrush habitats are within 1.55 miles of a mapped road probably are accurate but 

also very misleading, particularly for much of the northern Great Basin. Many of these "mapped roads" are rarely if ever 

used during the breeding and early brood rearing season. Snow and mud make them non-usable for much of this period 

in most years. Furthermore, there is little use of many areas during this period, because most use occurs in the summer 

and fall during hunting seasons or pre-hunt scouting trips. The primary exception is discrete mines which impact a small 

portion of most areas. Seasonal activity levels are important and must always be considered in management decisions. 

Mere presence or absence is only part of any equation.

GB Both rmc0067GB

157. We become concerned by general statements such as "Roads have multiple impacts on wildlife in terrestrial 

ecosystems". While true, the focus should remain on known, documented impacts to sagegrouse, their probability of 

occurrence and the effects on population size and persistence, not the effect on individuals. There appears to be very 

limited documentation about collisions between vehicles and sagegrouse and that single paper did not provide any 

information about the context of the situations where collisions occurred. The conditions may have been quite specific 

and may not exist in many areas. A one size fits all rule would be inappropriate.

GB Both rmc0067gb

158. Many of the people or groups that petition the government to add various species to the endangered species list don't 

even live in Idaho or in the West for that matter. Please keep Idaho lands free from needless travel restrictions and 

reject those that try to use these blatant tactics of preventing Idaho citizens of accessing their public lands.

IDMT Both emc0036GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1141

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159. More road and trail closures in Southern Idaho is not necessary to protect Sage Grouse & their habitat. I want to point 

out that saving our wildlife resources is just as important to us as it is to The BLM but not if it means we can't enjoy the 

area too.

IDMT Both emc0122GB

160. I have been riding in Southern Idaho for the past 30 plus years and I haven't finish exploring the area either. I strongly 

believe more road and trail closures in Southern Idaho are not necessary to protect Sage Grouse & their habitat.

IDMT Both emc0122GB

161. Road densities and traffic in Sage Grouse areas are low, but roads that exist are important to access recreation, 

sightseeing, and cultural opportunities.

IDMT Both emc0122GB

162. In Southern Idaho, the Forest Service has mostly completed it's Travel Management Plans (TMPs). In South-western 

Idaho the BLM has completed their Travel Management Plan for the areas most popular with OHVs. Addressed in those 

TMPs were the issues with Sage Grouse habitat and appropriate roads and trails were closed or subject to seasonal 

closure. We do not need additional roads/trails to be closed!

IDMT Both emc0122GB

163. First, in Idaho the Forest Service (FS) has completed Travel Management Plans (TMPs) for nearly all the National Forest 

lands in the state, and most neighboring states are doing the same. These TMPs addressed issues that OHVs and their 

continued use of roads, trails, and areas might have on all plants and animals in the ecosystem. Where the FS deemed it 

appropriate, roads, trails, and areas were closed to OHV use to protect sensitive species.

IDMT Both emc0124GB

164. The BLM has also completed TMPs for the areas in northern Owyhee County in southwest Idaho that are most popular 

with Off-Highway Vehicle (OHV) users. These areas (in part known locally as the Owyhee Front) also saw roads and 

trails closed, as well as subject to seasonal closures, specifically to avoid disturbance of Sage-Grouse leks. The Owyhee 

front does not have a high amount of Sage-Grouse habitat, the terrain being made up of sand washes, rocky hills and

relatively few open flat areas suitable for leks. However southern Owyhee County is more wide-open and has a much 

higher number of Sage-Grouse and leks. This area receives much less OHV traffic as it is very remote and far from large 

population centers. Southern Owyhee County also recently saw the creation of roughly half a million acres of new 

Wilderness areas. The legislation that created the Wilderness areas closed many miles of historically accessible roads to 

all mechanized vehicles. The roads and trails that remain open in the Owyhee desert have been on the ground for years 

and are important to access cultural and historical sites, as well as scenic opportunities.

IDMT Both emc0124GB

165. My overall point is that while I agree that keeping the Sage-Grouse off of the Endangered Species list is very important 

for both the Sage-Grouse and the people who live in and visit public lands in the region, I do not feel that further 

closures of roads, trails, and/or areas to OHV use is warranted. I do not feel that OHV use is responsible for the decline 

in Sage-grouse populations or the loss of their habitat and that the current TMPs and other regulations currently in 

effect are sufficient to keep OHVs from impacting Sage-Grouse and their habitat. Thank you very much for the 

opportunity to comment on this issue.

IDMT Both emc0124GB

166. We do not believe that more road and trail closures and eliminating will restore Sage Grouse to the Southern Idaho 

area.

IDMT Both emc0145GB

167. The National Forests and the BLM in these areas have completed Travel Management Plans (TMPs) that limit access and 

cross country travel by OHVs. The roads that remain are very important to access recreation, sightseeing, hunting, and 

cultural opportunities. Issues with Sage Grouse habitat were addressed in those TMPs and roads and trails that affect

IDMT Both emc0145GB
C. Comments by Resource Planning Issue

C-1142 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

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the Grouse were closed or were subject to seasonal closures. All of the remaining roads and trail have established for 

decades and have historical use long before Sage Grouse populations were an Issue.

168. Actions taken to-date and proposed by the Dillon LWG The Dillon LWG, in addition to holding regular meetings, has 

undertaken several actions to assist sage-grouse conservation: - encouraged the BLM to implement some road closures 

and rehabilitation, and fence removals and marking in the Reservoir Creek allotments

IDMT Both rmc0028GB

169. In the CMR NWR draft CCP and EIS (2010), a map on page 223 identifies sage grouse leks on the CMR Refuge. A map 

on page 305 identifies roads. These maps correlate. The RMP should propose a study to determine if leks are 

statistically more likely to be within a mile of a road.

MT-RM Both emc0013RM

170. travel and transportation: Roads contribute to habitat loss and fragmentation of Sage Grouse habitat. We recommend 

that the EIS incorporate conservation measures to address this threat. No new roads should be permitted in priority 

habitats. And redundant or unneeded roads should be closed and rehabilitated. The agencies should impose seasonal 

restrictions on road travel close to leks and other priority habitats where disturbance is harming Sage Grouse or 

damaging habitats. And the agencies should permit vehicular travel only on designated roads and trails in all habitats.

NVCA Both emc0283GB

171. The Area is Crisscrossed by Frequently Used Roads: The Hog Ranch project area has a very dense road network that 

is utilized by ranchers, hunters, off-road ATV and other recreationalist. During the spring through the fall seasons, many 

people camp here because the area has excellent access. It is even accessible for 2-wheel drive vehicles. The significant

level of human activity in the Hog Ranch area likely deters significant sage-grouse inhabitation.

NVCA Both emc0287GB

172. We are also concerned about targeting pinyon-juniper without an understanding of historical deforestation, and the fact 

that in many areas, pinyon-juniper are in reality the climax vegetation on a site. It appears much easier for agencies to 

promote expensive tree killing projects, rather than address the extensive degradation caused by livestock grazing, 

roading, or other disturbances throughout Nevada’s sagebrush habitats.

NVCA Both emc0411GB

173. Considering the miles of highway that ODOT is responsible for and how road rights-of-ways are addressed in the 

ODFW report, it should be obvious that ODOT is very concerned with how existing and future highway facilities and 

material sources will be addressed within this management plan. Based on the findings from several recognized studies, 

ODOT believes highway related activities within existing rights-of-way should be exempted from added scrutiny based 

solely on habitat for greater sage-grouse.

OR Both emc0155GB

174. Sage-grouse generally do not prefer to occupy habitat near high volume roads (Lyon and Anderson 2003, Connelly et al. 

2004, Aldridge and Boyce 2007). The majority of ODOT managed transportation facilities are major highways and 

freeways with relatively high traffic noise (up to 90 decibels). Connelly et al. (2004) indicated there were no active 

sage-grouse leks within 2 kilometers (km) of Interstate 80 across southern Wyoming and only 9 leks were known to 

occur between 2 and 4 km of I-80. ODOT biologist have conducted numerous environmental reviews and surveys over 

the years for transportation projects and associated material sources and have not encountered greater sage-grouse or 

identified areas of active use by these birds. Over the course of the last decade ODOT has been collecting data on 

collisions between wildlife and motor vehicles. Over this period no incident of sage-grouse killed by vehicles along 

ODOT transportation facilities has been recorded. ODOT believes that existing traffic, noise and disturbance along 

these transportation corridors generally precludes sage-grouse presence within the existing highway right-of-way and 

OR Both emc0155GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1143

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likely the areas immediately adjacent. Therefore, ODOT transportation corridors and their associated right-of-way 

should be exempt from any sage-grouse restrictions or exclusions.

175. In the Plan, the threat of road densities is addressed only indirectly. Again, ODFW should have used the best available 

science to study the impacts of roads and road densities with respect to habitat fragmentation. On BLM lands, 

Oregon-based groups and individuals have documented numerous miles of unnecessary primitive routes that are not in 

regular use, but continue to impact sage grouse habitat—BLM should incorporate this information into land use 

planning.

OR Both emc0385GB

176. Address Impacts of Roads: Roads and trails impact sage-grouse habitat through weed invasions, habitat fragmentation, 

and increased activity. To improve sage-grouse habitat, BLM must prioritize limitations on roads and restoration of 

unused or harmful roads.

OR Both emc0385GB

177. The area between the Little Sahara Rec. area and the mountains to the north has been used for years by the OHV 

community. The trail density is quite high there. I really feel that this area would not be good habitat for Sage Grouse. 

The even more alarming part is that there are not any Sage Grouse in the area, so I'm a bit confused as to why this area 

is even being considered.

UT Both emc0111GB

178. Garfield County possesses numerous valid existing transportation rights on federal lands. Inasmuch as federal plans are 

to be consistent to the maximum extent allowed by law with local plans and are subject to valid existing rights, Garfield 

County requests inventory, evaluation and consideration of transportation rights as part of the plan.

UT Both rmc0006GB

179. Under Utah State statute, Garfield County has jurisdiction and management responsibilities for off-highway vehicle 

management and recreation. Garfield County requests that its plans, program and policy be addressed as part of the 

analysis and that the Sage Grouse Plan be brought into consistency with the local plan to the maximum extent allowed 

by law.

UT Both rmc0006GB

180. If road closures for a time period during the year is considered then the lease holder and local landowners must be 

allowed to travel the areas roads as needed for maintenance and livestock needs. Their travel cannot be limited to 

certain times of the year if they have ranching requirements that must be met. The same must be taken into 

consideration for trailing, branding, docking, feeding, calving and lambing of livestock, as well as irrigation and summer 

hay cutting. These ranching activities all occur with regularity within the time frame of the courting and nesting of the 

sage grouse(March 1-June 30) The ability of the landowner and lease holder to adequately calve or lamb and take care 

of their livestock must be placed in the forefront as well. It is possible to take into the consideration the management 

and conservation of a species without causing undue hardship on landowners living in the area. Landowners are limited 

by area landscapes and habitats as well when it comes to adequately protecting newborn livestock. Their livestock 

management plans are made well in advance each year and for the most part cannot be easily changed. Corrals, barns 

and other facilities needed for livestock cannot be transported to far away pastures for shelter and convenience. Some 

pastures are used at the same time each year for the specific reason that they will help provide nourishment and shelter 

to a landowner’s livestock from storms during the spring of the year.

WY Both emc0050RM

181. Patrol during hunting season to prevent (OHV) vehicle use in core sage grouse habitats. The hunting seasons are the 

time of the year when most off road activity occurs. Post signs as well stating no off-road use during the rest of the year 

WY Both emc0050RM
C. Comments by Resource Planning Issue

C-1144 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

in specific areas. Make the fines for purposely traveling off road through - (well posted areas using-maps and signs) core 

habitat for sage grouse be significant. A $300 dollar fine is not nothing to many people whereas $500 or more then 

people will take notice.

182. iii. Strong components of Wyoming’s approach Within core areas, stipulations on BLM, FS, Wind River Indian 

Reservation, and State of Wyoming lands limit the number of projects and the amount of allowed disturbance (no more

than 5%13) allowed per square mile or 640 acres. Surface disturbance is prohibited within a 0.6 mile buffer around active 

leks (no surface occupancy - NSO), which includes roads during the breeding, nesting and brood-rearing periods

(mid-March through end of June). In addition, a March 15 to June 30 timing limitation stipulation is required within 

nesting habitat within 4 miles of leks. Main roads used to transport production and/or waste products must be more 

than 1.9 miles from the perimeter of occupied grouse leks. Other roads used for access or maintenance must be more 

than 0.6 miles from the perimeter of occupied leks. Noise levels at the perimeter of a lek should not exceed 10 dBA 

above ambient noise from 6 pm to 8 am, so as not to disturb breeding activities (March 1 - May 15). Finally, proponents 

of new projects are expected to coordinate with the permitting agency and WGFD biologists to determine which leks

need to be monitored and what data should be collected/reported. The Executive Order clearly identifies thresholds 

and outline adaptive management responses if declines in sage-grouse numbers occur14. However, in non-core areas, 

the EO recommends a 2-mile seasonal buffer around occupied leks and a 0.25 mile NSO buffer around active leks. 

Research has shown that the latter stipulation is inadequate and scientifically without merit. In addition, a surface 

disturbance cap is lacking from non-core area stipulations

WY Both emc0089RM

183. In winter, sage grouse select large expanses of sagebrush with gentle topography and avoided conifer, riparian, and 

energy development (Doherty 2008). Well density had an additional effect in this study (id.). Sage grouse were 30% 

more likely to use winter habitat if CBM development was not present (id.). There was a landscape-scale effect of 

habitat selection, with areas with greater sagebrush at a 4 km2 scale receiving greater winter use (id.). Carpenter et al. 

(2010) found a similar relationship in Alberta, and found that grouse avoided oil and gas wells by 1.9 km and also showed 

some avoidance of jeep trails. Bruce et al. (2011) found that sage grouse moved widely across winter habitats, using an 

area of 1,480 km2, and recommended setting aside large reserves for winter habitats. According to Doherty (2008:22), 

“Identifying and setting aside areas of undeveloped, high-quality habitat within the project area should be top priority.” 

Doherty (2008:22) asserted, “My spatially explicit winter habitat model can be used to identify areas in the PRB that 

provide the best remaining habitat for sage-grouse in winter.” BLM should apply this model to the Powder River Basin 

and place areas predicted to be the best remaining sage grouse winter habitat off-limits to future oil and gas leasing, in 

addition to placing strong restrictions on the level of development that is allowed on existing leases. Similar protocols 

should be developed and followed throughout the remainder of the sage grouse range.

WY Both emc0343GB

184. I have worked very hard with my local BLM Office, Blaine County and other stakeholders on a new Travel Plan for the 

Shoshone District. I hope that a Blanket Policy to protect Sage Grouse does not affect all of the work we have put into 

our Travel Plan.

WY BLM fle0004gb
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1145

Scoping Summary Report

Table C-9.A

Comments Related to Travel Management

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

185. As a Wyoming resident, some of the recommendations concern me greatly. Here in WY, the outdoors isn't just for 

recreation, but it is our way of life. We all recognize that we share the area with all endemic species, but to risk the loss

of use of OUR land because of some questionable "science" is an outrage and a folly. According to available literature 

and studies there is little information related to the effects of motorized recreation on the Grouse. Based on current 

science it appears that motorized recreation in, any of its forms, does not have an significant impact on the Grouse.

WY Both fle0012gb, 

fle00009rm
C. Comments by Resource Planning Issue

C-1146 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. 3) Sage grouse protection areas should also be "No Shooting" zones, or at the least, ban the use of lead-based 

ammunition in those areas. Since insects and forbs are important during a sage grouse brood's first month of life, they 

obviously forage on the ground for ants and beetles. It would be likely they would be susceptible to lead poisoning from 

lead shot or other lead based ammunition. You need healthy broods to stabilize the sage grouse population.

All Both emc0011GB

2. In a time when fewer and fewer people are getting out and recreating on our public lands, (proportionately) it seems a 

moot point to close lands to the public for possible protection of a hardy species. Closures are the easy solution. The 

trick is coexistence with man and his machines. How about rationing? Power sports on even numbered dates only? 

Weekdays only? Cant we compromise for solutions which protect and preserve for fauna and flora as well as 

recreationists.

All Both emc0041RM

3. If man and his machines are abusive, and I as one I do hear stories, why do I see such a lack of patrols? If you are forced 

by the political process to keep your lands open to us "barbarians" why not get out from your desks and do some 

patroling to protect? The private timber companies have simply closed us out due to abuses by people. You on the other 

hand are mandated as a public land manager. So I challenge you to get creative. And PLEEZE do not tell me "no funds". 

That just makes me think you are shallow and unimaginative and "institutionalized" beyond hope.

All Both emc0041RM

4. My concern is that if grazing is restricted unreasonably on BLM or Forest Service lands then grazing permittees and 

private landowners may sell out to recreational users whose activities may be more detrimental to sage grouse than 

grazing.

All Both emc0054GB

5. RECREATION ISSUE: The proposed Conservation Measures fail to address impacts of individual OHV trails and 

subsequent two-track roads that impact sage grouse and sage grouse habitat. Discrete anthropogenic disturbance via 

highways and gravel roads has been identified as an important issue for sage grouse habitat in the Conservation 

Measures. Overall objectives talk about limiting roads and specific objectives talk to limiting road disturbance to 3%. The 

Conservation Measures entirely overlook the impact of OHV trails left by individuals using public and USFS 

administered lands. Are these really to be categorized as diffuse disturbances, along with livestock grazing? Individual 

user OHV trails mechanically damage sagebrush, disturb nesting and brooding, destroy riparian vegetation and drain wet 

areas through capillary action. In lowmid elevation areas, OHV trails lace every drainage and ridgeline. Low elevation 

lands are a web of fragmented, small polygon areas that can’t function as sage grouse habitat. Nearly every low-mid 

elevation riparian area in Nevada potentially used by sage grouse for brooding is impacted by individual use OHV trails 

on BLM lands and USFS administered lands. OHV trail mileage is expanding exponentially on BLM land. When use is 

controlled on USFS administered lands through “closed unless posted open” designations, OHV users come to BLM 

lands where everything is open except a few areas posted as closed. Seemingly harmless one-time passes through an 

area by OHV’s go on to become full-blown roads in a few short months that are accessible to vehicles. Individual OHV 

trail / roads systems force the issue of discussion on patch size. The case can’t be made that webs of OHV trails and 

two-track roads don’t impact sage grouse and sage grouse habitat no matter which label, discrete or diffuse, these fall 

under. Measures must be amended into the LUPs that would manage OHV trail proliferation.

All Both emc0083GB

6. ISSUE: Use of “No Shooting” Designations on large tracts of land. The USFWS has stated that hunting isn’t an identified 

threat to sage grouse. Although species of wildlife hunted and hunting seasons are within the authority of the state’s 

All Both emc0083GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1147

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

wildlife agencies, there has been a move in several states by federal land management agencies to enact “no shooting” 

regulations on large areas of public and USFS administered land, not just in urban interface areas. This type of regulation 

is being done to end or severely curtail hunting on public / USFS administered lands. Large areas subjected to this 

regulation could eliminate the opportunity for significant state DOW funds used for census and for federal / state 

matching funds for sage grouse. In some states, these significant funds are critical for Challenge Cost Share matches with 

federal land management agencies. The substantial Pittman-Robertson funds available to state wildlife agencies are based 

on hunting license sales for game species of wildlife. State wildlife agencies must be able to spend these funds on census 

and habitat improvement on public lands. Funds spent on habitat improvement for sage grouse or other game species 

act an umbrella to benefit a wide variety of game and non-game wildlife species including sage grouse. LUP amendments 

should include a recommendation for the conservative use of and interdisciplinary team review of “no shooting” 

designations.

7. We understand the need to amend your land use plans for sage grouse. We do have concern on the impacts to 

recreation particularly equestrian use. As you can see from our purposes listed above we are dedicated toward low 

impact on the land (Leave No Trace).We strive to educate equestrian users on the safe and wise use of horses as well 

as how we can limit impacts on the resources. We would comment that we have not been able to find any research that 

would show that equestrian use is detrimental to sage grouse and any limit on this use should be determined from sound 

research. We would like to be included on your mailing list so that we can continue to contribute to this public process

All Both emc0094GB

8. Please consider the needs & concerns of the OHV Community in your decision making process All Both emc0134GB

9. Recreation impact activities on public lands including hunting and off-road vehicles needs to be looked at closely All Both emc0135GB

10. Recreation. The effects of off-highway vehicle (OHV) on sage-grouse behavior and populations are poorly understood. 

With the advent of deer and elk antler collecting, important winter sage grouse areas are seeing increased impacts 

primarily from OHV usage. The planning strategy should address recreational uses and provide guidance in critical sage 

grouse ranges.

All Both emc0142GB

11. am very concerned that people could be criminally prosecuted by simply utilizing their own private land or for accessing 

public lands. It appears that people who enjoy off-roading would face the brunt of greatly reduced access or completely 

denied access to such lands.

All Both emc0144GB

12. Your maps showed recreation sites and National Historic and Scenic trails. You need to address what you are going to 

do about dispersed recreation, eco-tours, etc. over the years to come, as recreation and tourism and their impacts 

keeps expanding. I feel there will be more impacts there in the future, then at the existing recreation sites.

All Both emc0149GB

13. As a quiet human powered form of recreation bicycles have impacts on wildlife that are comparable to any human 

activity. Studies involving bison, mule deer, pronghorn antelopes, desert bighorn sheep, European alpine chamois and 

American bald eagles suggest that mountain bicycles and hiking have similar impacts on wildlife.1 The 2010 

Determination for the Gunnison Sage-Grouse as a Threatened or Endangered Species indicated that all recreational 

activities have potential to adversely effect the species and habitat, but that did not pose a significant threat. We concur 

in this statement. Unmanaged always has the potential to create adverse impacts to our natural environment and the 

All Both emc0150RM
C. Comments by Resource Planning Issue

C-1148 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

wildlife that inhabits it. However, thoughtful management can avoid those potential effects while still allowing the public 

to experience these environments.

14. In the case of the Greater and Gunnison Sage-Grouse mitigation measures such as seasonal and or time of day 

limitations can avoid disturbing the lekking process. Careful attention to trail routes can avoid fragmentation of critical 

habitat and avoid leks. Trail construction techniques can be used as a framework for enticing/encouraging trail users to 

conform their behavior to the desired conditions. All of these measures should be considered prior to resorting to 

outright prohibitions.

All Both emc0150RM

15. Americas public lands are the core of the outdoor recreation economy and tourism industries. The wildlife that inhabits 

them are an essential component of what makes them special. Careful management and planning can ensure that these 

places and creatures are protected while still allowing people to experience them.

All Both emc0150RM

16. Closing the established OHV trails will only stop the law abiding people from going out in those areas. It will NOT stop 

the poachers or others that are causing problems with the wildlife and habitat. Allowing the ATV riders to continue 

using the trails, they might keep the poachers out of the area for fear of being caught. And they can and will report any 

problems that they see to the proper officials.

All Both emc0175GB

17. I was born and raised here in Idaho. I love my state. Do you know why? Because I like to get out, and I have the ability 

to head for the mountains or desert almost every weekend of the year either, hiking, mtn biking, hunting, fishing, 

camping, motorcycle riding, snowmobiling, etc. My family and I love being outside whether it be backpacking into a 

pristine backcountry lake or blazing down the trail on my dirt bike to the next check point. Recreationalists like myself 

are the best conservationists of the land, and we are always respectful of other people and especially the animals that live 

here. Integrity, doing what is right...Educate the uneducated, do not limit peoples rights to recreate how they choose on 

Federal Public Land.

All Both emc0185GB

18. According to available literature and studies there is little information related to the effects of motorized recreation on 

the Grouse. Based on current science it appears that motorized recreation in, any of its forms, does not have any 

significant impact on the Grouse.

All Both emc0199GB

19. Because ATV use has increased dramatically in the past several years, there needs to be an aggressive training and 

enforcement policy to reduce illegal ATV use. Legal roads need to be clearly marked and illegal roads need to be 

barricaded. Enforcement efforts need to be increased, especially during the hunting seasons to reduce the damage being 

done by ATV's.

All Both emc0217GB

20. More specifically we need land to recreate in. these are all our lands and only a few young, strong folks can get out and 

hike. I am 60 and we choose to ride OHV as a FAMILY to enjoy our land

All Both emc0224GB

21. The NOGA members operate under the conditions provided in their Special Recreation Permits (SRPs) and we would 

like to be included in any decisions that determin which SRPs have neutral or beneficial affects to priority habitat areas. 

Most of our activity is focused on summer and fall recreation; therefore, it does not occur during breeding or nesting 

periods.

All Both emc0239GB, 

emc0095RM

22. Significant sage grouse habitat overlaps with BLM special designations. The plan amendment process must include a 

No-Action alternative, which recognizes the fact that federal land use plans contain existing direct and indirect 

All Both emc0242GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1149

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

protections of sage-grouse habitat (including wilderness areas, national parks and monuments, wilderness study areas, 

areas of critical environmental concern, special recreation management areas, roadless areas, wild and scenic rivers, 

NSO areas and others). The EIS must examine the extent to which such existing protections, or modification of such 

protections, can accomplish the purpose and need for the plan amendments.

23. Sage grouse habitat conservation measures should not preclude the use of certain BLM lands for OHV recreation. Any 

losses of OHV recreational lands should be mitigated by provision of additional lands outside of priority habitat and 

enhanced recreational facilities.

All Both emc0242GB

24. 5) Consider the effect of recreational use on grouse and their habitats. The random hikers with their unleashed friends, 

the loosed camp dog from a mountain bike camp, the family with campfire, hot dogs and 22’s target practicing or casual 

groups taking pictures or just exploring with their Labradors afoot to the horse camp with blue healers beating the sage 

brush: education on what a grouse is and where it lives and what a few loosed dogs from a Subaru station wagon can do 

to a nesting hen and her not yet or newly hatched chicks is called for. The kiosks at trails heads, campgrounds to 30 

second blurbs on TV, school programs and information placed on maps, web sites and publications. Who is a sage 

grouse and where does he live? Why wouldn’t I turn my dog loose in a high desert floor? These and other secrets need 

to be shared to protect the sage grouse habitat. Ignorance of the public is at fault but lack of information dissemination 

lies in the agency’s lap.

All Both emc0257GB, 

emc0104rm

25. In the Recreation section, page 12, there is discussion of recreational activities in sage brush habitats. While it may seem 

counter-intuitive, in order for these areas to be avoided, there needs to be notice to the public of which areas to avoid. 

The statement is made that “Off-trail users can fragment habitat and create corridors for spread of exotic plant species.” 

Federal, State and local regulations already prohibit off-trail uses by OHV’s, except in special circumstances.

All Both emc0271GB

26. Recreational use of sagebrush lands can have negative impacts on sage-grouse. The use and increasing fascination with 

off-highway vehicles (“OHVs”) is of great concern, and has led directly to sage-grouse habitat loss and fragmentation. It 

also poses a threat to vegetation, an increase in noise causing stress and possibly extirpation, and direct mortality from 

collisions. Indeed, recreational use of OHVs is one of the fastest-growing outdoor activities. As an example of how this 

new form of recreation has been affecting wildlife, the Fish and Wildlife Service states that use of OHVs has been a 

primary factor of concern in 13 percent of species listed or proposed for listing under the Endangered Species Act.

All Both emc0276GB

27. Indirect effects of OHV use include facilitating the spread of invasive species. Additionally, all recreational use of 

sagebrush lands leads to an increase in human presence, which can lead to stress, avoidance, and impacts on sage-grouse 

populations and overall survival rates. Additionally, although OHV use is legally limited to roads or trails on some public 

lands, illegal cross-country use is a reasonably foreseeable impact of considerable concern.

All Both emc0276GB

28. The effects of OHV use on sagebrush and sage-grouse have not been directly studied, and thus there is a lack of 

information on how to best control and avoid impacts associated with OHV use. This lack of information also makes it 

extremely difficult to estimate the impacts of OHV use on sage-grouse habitat and populations.

All Both emc0276GB

29. With the increased popularity of ATV recreation and the interest of gathering shed antlers many people and family pets 

(dogs) are impacting the nesting area of these birds.

All Both emc0295GB
C. Comments by Resource Planning Issue

C-1150 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

30. Further, arterial roads can have significant impact on wildlife, whereas low speed two track trails and single track trails 

usually has little or no impact on wildlife. In this case if low volume low cost roads and/or trails are closed, opportunities 

for recreation will be lost with little or no benefit to the grouse. Livestock producers will lose grazing opportunities. 

Hunters and fishermen will lose their favorite spots. Off-highway vehicle users will lose riding opportunities. Industries 

in rural areas that tend to be productive support local economies will close. Western small communities with their 

ranch, tourism and natural resource economies would be hard pressed to support these efforts even though they enjoy 

sage grouse with parameters that could be so far reaching. As most wildlife managers know, public support is vital to 

completing their mission.

All BLM emc0313GB, 

emc0127RM

31. For example, if OHV trails or recreation areas face closure due to the sage-grouse conservation efforts, we hope the 

agencies will engage with local OHV organizations before finalizing any plans. Having a dialog with these groups in an 

effort to minimize such closures and to explore suitable alternatives for OHV recreation will facilitate acceptance and 

compliance with new land management restrictions

All Both emc0324GB

32. We note that BLM's own documents identify the common threats to the sage-grouse habitat. In the Great Basin Region 

it is the threat of wildfires and in the Rocky Mountain Region it is energy development. OHV recreation does not 

provide a threat and therefore it should not serve as a remedy in dealing with this issue.

All Both emc0324GB

33. We are concerned that the Notice specifically calls out off-highway vehicle (OHV) management and recreation as a 

preliminary issue, particularly as supporting documents from the U.S. Fish and Wildlife Service (FWS) cite other factors 

as the primary threats to the species. For example the FWS Fact Sheet on Endangered Species Act Listing Decision for 

the Greater Sage-Grouse dated March 5, 2010 notes; "The Service analyzed potential factors that may affect the habitat 

or range of the greater sage-grouse and determined that habitat loss and fragmentation resulting from wildfire, energy 

development, urbanization, agricultural conversion, and infrastructure development are the primary threats to the 

species." While we understand that on the local level There may need to be consideration of how OHV trails and areas 

impact the sage-grouse on a case-by- case basis, there seems to be little science supporting OHV use as a substantial 

factor affecting overall sage-grouse populations.

All Both emc0330GB

34. Further, we question why OHV recreation would be called out as a preliminary issue, despite not being a primary threat 

to the species as noted above, instead of simply identifying recreation, motorized or non-motorized.

All Both emc0330GB

35. Lastly, we cannot help but question a notice that caIls out OHV recreation as a preliminary threat to a species that 

warrants endangered species protection, but does not even mention that hunting of that species remains legal in some 

impacted states. If this species can be protected while it is being lawfully hunted we respectfully submit that it can be 

protected without wholesale closures of public lands to multiple uses.

All Both emc0330GB

36. The BLM must also consider the effects of its decisions upon the ability to produce oil and gas, and to create a viable oil 

shale industry, and upon the tourism industry and recreational pursuits of those who live in Utah.

All Both emc0337GB

37. In addition to the issues listed in the accompanying informationI encourage the evaluation of the following in all analyses 

of the environmental impacts of actions on federal lands. When looking at the impacts of recreation, consider the impact 

of lek viewing activities. With expanding interest in sage grouse, over-zealous viewers and photographers frequently 

disturb birds

All Both emc0338GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1151

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

38. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: -

Greater sage grouse and habitat used by the species can be negatively impacted by dispersed recreational activities.

All Both emc0343GB

39. Sage grouse do not use cheatgrass. Invasive species was identified as a threat to sage grouse by three expert panels and 

in recent reviews (Connelly et al. 2011, Table 1). One panel listed cheatgrass as the most important threat to sage 

grouse in the western portion of its range (70 Fed. Reg. 2267), where it has invaded much of the lower elevation, xeric 

sagebrush habitat (Miller et al. 2011). Land uses such as livestock grazing (Reisner 2010), off-road vehicle use, and 

coalbed methane development (Bergquist et al. 2007), can facilitate cheatgrass incursion in sagebrush steppe.

All Both emc0343GB

40. General Comments on the December 21, 2011 report from the Sage-grouse National Technical Team A Report on 

National Greater Sage-Grouse Conservation Measures An alternative based on the Report will go far beyond what is 

required by the Purpose and Need. The Report fails to adequately incorporate the successful efforts by the local sage 

grouse working groups and may stop effective efforts that are currently underway. It places arbitrary and capricious 

limits on recreational activities (roads and trails) as well as water developments. It would also direct the agencies to 

retire grazing allotments, which is currently prohibited by law. Additional alternatives should be developed to respond 

to these and other concerns

All Both emc0345GB

41. Sage-grouse habitat conservation measures should not preclude the use of certain BLM lands for Off Highway Vehicle 

(OHV) recreation. Any losses of OHV recreational lands should be mitigated by provision of additional lands outside of 

priority habitat and enhanced recreational facilities.

All Both emc0376GB

42. Only by requiring the strongest protective measures when considering new development proposals in sage-grouse 

habitat will you be able to ensure survival of this spectacular species. To that end, I ask that you require the following 

conservation measures in the relevant Resource Management Plans and Land Management Plans.Manage dispersed 

recreational activities to avoid, reduce and, where possible, eliminate displacement of greater sage-grouse or negative 

impacts to greater sage-grouse habitat.

All Both flb0000gb

43. Regarding recreation, the plan amendments should direct local land managers to cooperate and coordinate with local 

governments and affected stakeholders to establish achievable goals for protection of the Grouse (lek /nest disturbance, 

wintering areas and sage habitat degradation) and to mitigate potential affects upon recreation through closure of 

existing, inventoried and managed routes.

All Both flb0000gb

44. The amendments should recognize that local agency recreation planners and managers are the best suited to work with 

motorized stakeholders to establish a manageable, designated, user and nature friendly route network for motorized 

access. This includes access roadways away from paved highways; high clearance routes for pickups, jeeps and other 

4WD vehicles; that can be shared under mixed-use by other OHV categories such as trail bikes, ATV/UTV and/or OSV 

in the winter. Just as important to the motorized community are rural 2 track routes, ATV width trails, and trail bike 

single-track width routes.

All Both flb0000gb

45. Any plan amendment should include adequate site-specific analysis on anticipated impacts of motorized and 

non-motorized recreational activities, which often have little to no impact on wildlife. The impacts of motorized and 

mountain bike routes that are primarily used for recreation should not be "lumped in" with highways and other 

high-speed access roads.

All Both flb0000gb
C. Comments by Resource Planning Issue

C-1152 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

46. The analysis should also disclose impacts of the hunting of the Grouse, which is still allowed in at least 8 of the 11 states 

where it is found. Importantly, Sage Grouse conservation efforts such as seasonal restrictions and bag limits have been 

quite successful in maintaining healthy populations. The same has been shown for motorized access and use. For 

example, Grouse leks are concise, well-established, historic areas that can last for decades. Add to this that leks are 

mostly in use for strutting/mating during crepuscular hours and that motorized recreation is generally NOT undertaken 

during those hours...the two can be successfully separated.

All Both flb0000gb

47. Manage dispersed recreational activities to avoid, reduce and, where possible, eliminate displacement of greater 

sage-grouse or negative impacts to greater sage-grouse habitat.

All Both flb0000gb and rm

48. Only by requiring the strongest protective measures when considering new development proposals in sage-grouse 

habitat will you be able to ensure survival of this spectacular species. To that end, I ask that you require the following 

conservation measures in the relevant Resource Management Plans and Land Management Plans.

All Both fle0000gb

49. I strongly oppose components of the 2010 Conservation Measures that lack the flexibility to adapt to local management 

issues. The plan should recognize the importance of Off-Highway Vehicle (OHV) recreation to the local economy, the 

local and outside populations desire for OHV recreation, and the minimal impact that slow moving OHVs have on 

wildlife.

All Both fle0000gb

50. While the 2010 FWS listing decision specifically identifies fire suppression and oil and gas development as issues that are 

in need of regulatory improvements, the listing decision specifically identifies that recreational activities are of minimal 

impacts to sage grouse habitat. The Decision clearly states: "Although we anticipate use of pesticides, recreational 

activities, and fluctuating drought conditions to continue indefinitely, we did not find any evidence that these factors, 

either separately, or in combination are resulting in local or rangewide declines of greater sage-grouse.,,6

All Both rmc0033GB

51. As noted elsewhere in these comments, the FWS listing decision does not take issue with the placement of viewing 

trailers in the vicinity of active grouse lek, despite the possibility of disturbance and the increase in motor vehicle traffic 

on roads adjacent to the viewing trailers. While the placement of a viewing trailer may cause disturbance, the FWS did 

not find this low level of disturbance a significant threat to the grouse.

All Both rmc0033GB

52. The 2010 FWS listing decision discussed Colorado and Montana State policies to position viewing trailers adjacent to 

active grouse leks in order to allow for public viewing of mating and reproduction activities. Given the direct impact that 

a trailer with active visitor activity and associated motor vehicle traffic on arterial roads adjacent to active leks could 

have , if there were a concern regarding the recreational impact on grouse, it would have been raised in this discussion. 

The FWS states the placement of trailers in these locations is not a significant concern for the grouse.1S

All Both rmc0033GB

53. The minimal impact of recreational activities on sage grouse activities is also specifically addressed in the 2006 Colorado 

Department of Wildlife's Greater Sage Grouse Workshop Committee Report, which identifies the top priority threats 

to the sage grouse as being Housing/Urbanization; Grazing; Predation; Hunting and Energy Development. 19 This report 

repeatedly classified possible recreational impacts to the sage grouse as a low priority/low risk issue.

All Both rmc0033GB

54. Given the significant bodies of research that are available expressly addressing the limited impact that dispersed 

recreation has on the Grouse, the Organizations vigorously assert that the Conservation Measures must separate the 

impacts of arterial roads from the lack of impact from a dispersed trail system. This distinction is critical in resolving 

All Both rmc0033GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1153

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

erroneous application of the currently proposed standard in a manner that will not benefit the grouse.

55. I understand that the Department of Wildlife (NDOW) will make public maps identifying the location of critical sage 

grouse habitat and sage grouse leks. The publication of these maps will provide hunters and the general public "target" 

areas where they will focus their recreational activities. These critical sage grouse habitat areas (and the sage grouse 

within them) will become even more impacted by unregulated off road use, increased public visitation, and disturbance 

by associated pets (e.g. domesticated unleashed dogs will become a nuisance to grouse). The EIS needs to identify the 

ramifications of the publication of sage grouse habitat and lek maps and estimate the additional damage to the habitat and 

harm to the species that will be created as a result.

All Both rmc0035GB

56. According to available literature and studies there is little information related to the effects of motorized recreation on 

the Grouse. Based on current science it appears that motorized recreation in any of its forms does not have an 

significant impact on the Grouse.

All Both rmc0061GB, 

rmc0035RM

57. Regarding recreation, the plan amendments should direct local land managers to cooperate and coordinate with local 

govemments and affected stakeholders to establish achievable goals for protection of the Grouse (Iek /nest disturbance, 

wintering areas and sage habitat degradation) and to mitigate potential affects upon recreation through closure of 

existing, inventoried and managed routes.

All Both rmc0061GB, 

rmc0035RM

58. Any plan amendment should include adequate site-specific analysis on anticipated impacts of motorized and 

non-motorized recreational activities, which often have little to no impact on wildlife. The impacts of motorized and 

mountain bike routes that are primarily used for recreation should not be "lumped in" with highways and other 

high-speed access roads.

All Both rmc0061GB, 

rmc0035RM

59. The Proposed Planning Strategy indicates a potential for loss of access historically available for recreation, is a direct 

loss. There are also indirect impacts that would result should this Proposed Planning Strategy be approved and 

implemented causing further displacement of recreational activities. Those cost include, but are not limited to : (1) the 

increased enforcement required at other sites when displaced recreational users seek out other areas that may be 

poorly identified as wildlife preserves or other resource-rich areas; (2) the loss of biological resources or habitat at 

other sites that displaced recreational users may utilize; (3) the loss of nature education, (4) the loss of outdoor 

recreation opportunities, (5) the loss of outdoor access and experiences for children in the community; (6) the loss of 

familial traditions, custom, and culture of recreational and nature-oriented activities in the region ; and (7) the loss of the 

region's history and traditions, specifically with respect to mining and recreational activities.

All Both rmc0061GB, 

rmc0035RM

60. There are competing pressures for use of public lands. The Proposed Planning Strategy is one of several that 

cumulatively have a negative impact on the public's ability to partake in recreational opportunities on public lands. The 

Proposed Planning Strategy should adequately evaluate and mitigate the cumulative losses of land for recreational 

opportunities, including but not limited to cumulative closures or limitations on public lands managed by Bureau of Land 

Management, the U.S. Forest Service, and other federal agencies.

All Both rmc0061GB, 

rmc0035RM

61. Specifically, the data fails to support its claims that various recreational activities (e.g. , off-highway vehicle use, camping) 

pose significant threats to the Greater Sage Grouse. Such claims are highly speculative and based on little or no reliable 

All Both rmc0061GB, 

rmc0035RM
C. Comments by Resource Planning Issue

C-1154 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

data. Studies often cited in support of these claims, such as they are, were conducted many years ago and are outdated. 

Worse, those same studies either fail to stand for the statements attributed to them, or they violate basic rules of 

scientific analysis. That is, they (1) are biased in their methodology, (2) draw conclusions based inadequate sample size, 

(3) were conducted without sufficient "control" groups, (4) cannot be verified or repeated, and/or (5) are too small or 

localized to support the area-wide or population-wide extrapolations set forth in the subject document. A review of 

the underlying technical data for the Greater Sage Grouse reveals two things: First, no study so far conducted has 

established a causal connection between recreation activities and any perceived declines in the population. At most, the 

technical data show that some recreational activities, in some areas, have the potential to displace some species on a 

very local level. However, this cannot establish that recreational activities pose a substantial threat to an entire 

population or subpopulation of a particular species.

62. Middle Park Identified Issues The working group requests that the EIS analyze recreational impacts and conservation 

measures at a greater level than what was included in the NTT report. Grand County is advertised as ‘Denver’s 

Backyard’. This description captures the amount of recreational activity that occurs from residents and non-residents of 

Grand County. The NTT states recreational activities are benign unless they are excessive; however excessive use is 

occurring in Grand County and should be addressed in the EIS. Recreational activities identified by the MPSGWG as 

having potential negative impact (if not properly managed) to sage-grouse includes off-road vehicle travel, snowmobiling, 

hiking with dogs off leash, shed-hunting and lek viewing. The frequency, intensity and especially the timing of these 

activities will have the effect of disturbing birds, which can increase predation risk, increase risk of collisions with fences 

or power lines, and force birds into less desirable habitats. See the MPSG Plan on page 17 and the CCP document on 

page 191 for information pertaining to potential recreational impacts in Middle Park and Colorado. Recreational 

activities on BLM lands should be analyzed to determine if and where problems exists. Some recommendations to BLM 

to address the concerns of recreation may include but are not limited to focusing on lands identified for recreational 

activities or where BLM staff, CPW employees or landowners thinks a conflict may be occurring with sage-grouse 

habitat. If BLM is uncertain if a conflict between recreational users and sage-grouse are occurring they can deploy data 

loggers to users (White River National Forest West Vail Pass Lynx Study), conduct user surveys, or patrol an area to 

record user activities and numbers. If a problem is identified BLM could educate the users of the habitat sensitivity, put 

signs up explaining allowed uses, apply timing limitations or close areas that need protection. The dog off leash issue may 

be very site specific, however in Middle Park the working group believes that in certain areas (sites just northeast of 

Kremmling and a now inactive site near Granby) leks have been negatively impacted by pets, either under owner 

supervision or at large. Disturbance from dogs is also referenced in the MP Plan under the Predation and Urban 

Development sections. The CCP provides references to lek disturbance involving humans with dogs at the bottom of 

page 154 and the top of page 172. If specific sites are identified then the following actions could be proposed during the 

breeding season: place signs in the area to encourage dog owners to control their pets, increase patrol around identified 

sites or place wildlife closures to include human foot traffic. In addition, CPW has the legal authority to destroy dogs 

identified in the act of harassing wildlife if a problem persists and the pet owner does not take responsibility to control 

their dogs. This issue does not include working ranch dogs. Although BLM does not have the ability to direct 

CO Both emc0063RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1155

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

management on adjacent lands, the cumulative actions of other landowners will influence the behavior of the birds over 

the long-term, which may affect how they use BLM lands. This, in turn, may elevate the importance of maintaining 

suitable and quality habitat on BLM lands. For instance, increased housing development, one of the Tier-1 threats 

identified in the MPSG Plan and ranked issues table (Appendix I), may eliminate leks or destroy habitat, therefore adding 

pressure on adjacent BLM lands and making BLM lands even more important for protection. Recommendations to 

detect problem areas may include but are not limited to conducting an analysis using demographic data or county 

assessor data to identify housing pressures within some specified distance and density surrounding BLM lands.

63. Recreation: Viewing of leks should be discouraged if not prohibited and lek disturbance by government agencies should 

be held to a minimum.

CO Both emc0069RM

64. The EIS should also consider impacts from predation and other uses such as ATV s, recreational 4X4s, mountain bikes, 

camping, hiking, horseback riding, and other recreation uses.

CO Both rmc0050RM

65. Keeping the area open to ATVs/OHVs, especially organized clubs, may have a policing effect which can have a positive 

effect on the Sage Grouse and the historical artifacts in the area. All of our ATV Clubs promote proper behavior on our 

public lands and their involvement on our public lands helps police the behavior of others! Rather than shutting us out, 

in an attempt to help the Sage Grouse, ask for our help. We can and would help plant vegetation for the Grouse or help 

in other ways if you would just ask.

IDMT Both emc0122GB

66. Agencies also issue permits for everything from OHV races that may intrude on and disturb sagegrouse habitats (Ely 

BLM Jake’s Wash area for example) as well create new routes and promote erosion and gullying. There are various 

outfitting and commercial Wilderness adolescent rehab businesses that may disturb and impact sage-grouse throughout 

sensitive periods of the year, or degrade habitats in remote areas that are used often. Bennett Hills Idaho is an example

of an area of concern for this disturbance.

IDMT Both emc0411GB

67. New risk factors include: - increased recreation activity IDMT Both rmc0028GB

68. The County benefits tremendously from public lands recreation that includes, Special OHV Events to hunting, fishing, 

geocaching and touring of the public lands. We support maintaining these activities and are willing to coordinate with the 

BLM to ensure these activities are maintained in concert with conservation of the Sage grouse

NVCA Both emc0130GB

69. recreation: The USFWS listing decision did not identify recreational uses of sagebrush country, including hunting, as a 

significant threat to Sage Grouse. However, it acknowledged that some recreational uses may have site-specific impacts 

on local populations. The EIS should include conservation measures to avoid or minimize harmful recreational impacts 

on either the bird or its habitat. Minimally, we recommend: a. the agencies issue no special recreation permits and 

impose seasonal/timing closures to protect leks and other priority habitats. B. the agencies should permit no off-road 

vehicular travel in priority habitats and exercise their authority to modify or cancel recreational permits in order to to 

avoid or minimize adverse impacts to Sage Grouse and priority habitats.

NVCA Both emc0283GB

70. Agencies also issue permits for everything from OHV races that may intrude on and disturb sagegrouse habitats (Ely 

BLM Jake’s Wash area for example) as well create new routes and promote erosion and gullying. There are various 

outfitting and commercial Wilderness adolescent rehab businesses that may disturb and impact sage-grouse throughout 

NVCA Both emc0411GB
C. Comments by Resource Planning Issue

C-1156 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-9.B

Comments Related to Recreation

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

sensitive periods of the year, or degrade habitats in remote areas that are used often. Bennett Hills Idaho is an example 

of an area of concern for this disturbance.

71. If the ODFW can provide a blanket exemption to the livestock grazing industry which does not apparently adversely 

impact Sage Grouse habitat, why can't they provide an exemption for future mining operations and permitting process 

which disturb less than 100 acres and Dispersed non-motor oriented recreation and all other activities which have not 

been shown as a Listing Factor?

OR Both rmc0036GB

72. Seasonal Closures in the spring and summer, as proposed in the EIS must be considered carefully in order not to drive 

the Recreationist away. If I can go out to the desert only in the hot, dry dust of summer and late fall in east Oregon, then 

why would I choose it as a destination and place to play?

OR Both rmc0036GB

73. With the increased popularity of ATV recreation and the interest of gathering shed antlers many people and family pets 

(dogs) are impacting the nesting area of these birds.

UT Both emc0296GB

74. With the increased popularity of ATV recreation and the interest of gathering shed antlers many people and family pets 

(dogs) are impacting the nesting area of these birds.

UT Both emc0406GB

75. Under Utah State statute, Garfield County has jurisdiction and management responsibilities for off-highway vehicle 

management and recreation. Garfield County requests that its plans, program and policy be addressed as part of the 

analysis and that the Sage Grouse Plan be brought into consistency with the local plan to the maximum extent allowed 

by law.

UT Both rmc0006GB

76. Garfield County requests a detailed cost-benefit analysis be conducted in evaluating the decision's impact on 

development of fluid minerals, coal mining, hard rock mining, mineral materials, community mineral pits, recreation, off 

road vehicle use, and other land uses. Naturally, this will require evaluation of social and economic benefits/costs of 

current Sage Grouse populations and their impact on resource issues cited above.

UT Both rmc0006GB

77. Patrol during hunting season to prevent (OHV) vehicle use in core sage grouse habitats. The hunting seasons are the 

time of the year when most off road activity occurs. Post signs as well stating no off-road use during the rest of the year 

in specific areas. Make the fines for purposely traveling off road through - (well posted areas using-maps and signs) core 

habitat for sage grouse be significant. A $300 dollar fine is not nothing to many people whereas $500 or more then 

people will take notice.

WY Both emc0050RM

78. 12) Manage recreation impacts on sage grouse where these activities are concentrated in important habitat. WY USFS emc0144RM

79. 13) Promote appropriate grazing practices which maintain or improves sage-grouse habitat. WY USFS emc0144RM

80. Recreation, pesticides, parasites and disease are considered to be low priority factors at this time, but may become 

more important in the future as we come to understand the ecology of these small populations.

WY USFS emc0144RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1157

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. My concern is the economic impact the sage grouse reorganization of habitat will have on several states. All Both cfc0003RM

2. As the Department of the Interior moves forward with planning strategies, it is imperative to keep in mind the economics 

of the region. We as well as our constituents have been facing some tough economic times over the past few years. We 

will be monitoring any actions by the federal government that will have an adverse impact on jobs, energy development, 

grazing, mining or any other industry on public lands. With over 2.765.000 + acres in Fergus County and over a quarter of 

those acres being owned by governmental agencies, this causes us to be concerned on implementations that couid effect 

our economy and the way of life for our constituents.

All Both cfc0004RM

3. Our communities need the revenue created from the agriculture and oil and gas exploration. All Both cfc0005RM

4. It is good for the tourist industry and will get better. All Both cfc0008RM

5. While it's impossible to gauge just how much the grouse's endangered species listing could cost the energy industry, many 

experts, including Interior Secretary Gale Norton, say the economic impact could be enormous. Stop the listing and have 

the BLM start managing MY land.

All Both cfc0017GB

6. A federal judge instigated an uproar in 1989 when he issued an injunction on federal timber sales to protect many forests 

where spotted owls live.

All Both cfc0017GB

7. NEPA was written to protect the "Human Environment" This forthcoming EIS must be written to protect the human 

environment. Economic and social impacts must be covered in depth protecting our livlihoods and our use of FEDERAL 

LANDS. Sec 1508.25 scope Scope consist of the range of actions, alternative and impacts to be considered in an EIS. Sec 

1508.14 Human Environment "When an EIS is prepared and economic or social and natural or physical environmental 

effects are interrelated, then the EIS will discuss all of these effects on the HUMAN ENVIRONMENT."

All Both cfc0021RM

8. Retirement of grazing privileges is not in the interest of securing the nation's food supply. All Both cfc0024RM

9. The Taylor Grazing Act's goal of stabilization has been superseded by the Endangered Species Act which raises the 

question: Is a candidate species more important than economic and social vitality or can they exist together?

All Both cfc0030GB

10. First and foremost it is imperative that all applicable laws must be considered when proposing Sage Grouse management 

measures. Social and economic impacts must be considered and given priority to changes made strictly for grouse.

All Both cfc0032RM

11. As this planning strategy moves through its process it needs to maintain a clear focus that the people who live in these 

areas with the sage gouse need consideration as well.

All Both cfc0035GB

12. The destruction of the ranching and mineral extraction industries destucts communities and weakens our nation. Our 

natural resources are the life blood of our rural communities in most of the west. Locking up our resources with the 

expectation that we can just buy them from our nation is killing our country.

All Both cfc0035GB

13. I fear that this endeavor is to create another "spotted owl" which is intended to cripple the rural economies of the western 

U.S. "shovel-ready" projects on public lands (e.g. mining, geothermal, etc.) already face a seemingly insurmountable 

challenge of environmental obstacles that kill or delay projects indefinitely. It appears that we are going to have more of 

the same. Job Killers...

All Both cfc0048GB

14. Any changes that decrease or restrict multiple use will have a very negative economic ijmpact on our county residents. All Both cfc0061GB
C. Comments by Resource Planning Issue

C-1158 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

15. I hope you will consider and take into account that if cattle grazing is regulated or restricted, this will have a huge impact 

on many rancher's lives and livelihoods. It could mean that ranchers that graze on public land would be forced out of 

business. That would be a sad event.

All Both cfc0069GB

16. I support development of new energy sources in the United States, including the oil and gas reserves in Wyoming and 

Montana. But, I think we need to come up with some type of development fees in exchange for development rights, that 

could be imposed on property owners selling or leasing their lands for energy development, and imposed on the energy 

companies themselves that profit from this development. The money collected from these fees could be used to purchase 

other land to be set aside in perpetuity as habitat for species such as the sage grouse. (Also, these fees could be used to 

mitigate groundwater pollution that appears to be a result of the fracking process). If imposition of these development fees 

would require listing the sage grouse as an endangered species, I would be in favor of that too. The bottom line here is, we 

need new energy sources, and we need businesses to profit to maintain the economy and create jobs, but we also need to 

protect the environment. In exchange for profit, business and land owners must be held responsible for the costs of 

mitigation for harm to the environment.

All Both emc0001GB

17. Much of sage grouse habitat is on private land. If economic and political factors encourage the ranch to try farming, this 

habitat will be lost to the plow.

All Both emc0013RM

18. Whenever the RMP considers a course of action that could reduce the economic viability of a ranch, it should also 

consider whether that course of action would harm sage grouse by increasing the likelihood that the ranch would plow 

prairie, overgraze, or sell land to developers to compensate for the lost revenue.

All Both emc0013RM

19. I strongly urge the Department of Interior and our Congressional Delegation to move in a direction to mitigate any 

interference in our rural commerce occasioned by endangered species, with major emphasis on the sage grouse, a bird 

that will florish despite any marginal economic development in Nevada where the highest unemployment rate in the nation 

is prevalent

All Both emc0023GB

20. .. "the world population is seven billion and growing. Global agriculture production needs to continue growing at a 

significant pace to keep up with demand." so states the 2011 Global Agricultural Report. The report states that we need 

to double agriculture output in the next forty years. What does this mean to federal and state agencies managing our state 

and federal lands? The mind-set of limiting livestock grazing on federal lands need to be reviewed. Pressure will mount to 

harvest as much protein as possible. We need to do our share feeding the people of our world!

All Both emc0029GB

21. The petition for listing the Greater Sage Grouse as an endangered species specifically targets two important western 

industries in particular. The energy industry, and the agricultural industry. Both of these industries are vitally important to 

the economy of our western states and vitally important to our small local economies as well. This fact cannot be 

emphasized enough. While both of these industries bear responsibility to manage their operations to provide for 

conservation of natural resources, we maintain that these industries have demonstrated that they are doing so. The 

regulatory environment in which these industries exist must retain flexibility in order for these industries to survive. The 

regulatory environment must also allow industry leaders and federal agencies the flexibility to develop adaptive 

management strategies to achieve the appropriate balance between the increasing demand for resources and conservation 

objectives.

All Both emc0032RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1159

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

22. I favor "economic" impacts/benefits over any & all "environmental" restrictions to preserve this species. You should be 

investing your time (and our tax dollars) on more significant species and issues...

All Both emc0052GB

23. Although it appears from preliminary mapping that Mesa County includes very little, if any, priority habitat for the bird, as 

the economic regional center for western Colorado and Eastern Utah we are concerned about the potential negative 

socio-economic impacts of the measures suggested in "A report on National Greater Sage-Grouse Conservation 

Measures" produced by the Sage-grouse National Technical Team dated December 21,2011. Those conservation 

measures will have severe impacts on multiple uses of BLM lands and resources in the region that directly and indirectly 

impact the Mesa County economy, including energy development, tourism, recreation, grazing, etc.

All Both emc0053RM

24. We ask the BLM to include a detailed and thorough socio-economic impacts analysis of alternative conservation measures 

in the EIS. All recommended conservation measures must be supported by research based science in order for the EIS to 

be a credible document.

All Both emc0053RM

25. You also need to strongly consider the real economic impacts of your decisions. Your decisions impact much more than 

local jobs, tax revenues, schools, infrastructure, etc. You need to consider the cumulative impact your decisions have on 

creating perceptions about resource development in the region. The United States as a whole (and Colorado in 

particular), are gaining a global reputation as being anti-development and anti-business. This reputation comes from 

endless efforts to create new regulations, protect more and more land, and companies constantly fighting lawsuits from 

wealthy environmental groups. Companies are deciding they would rather develop resources in other regions of the 

World, rather than fight the environmentalists and regulators in the United States. That has real-life socio-economic 

impacts. One only needs to look to Canada who has a more progressive natural resources policy to see that development 

and environmental protection can co-exist - and create a positive, growing economic environment and low 

unemployment.

All Both emc0054RM

26. As a general and introductory comment, Garfield County (the County) agrees with and appreciates the desire by the BLM 

to ensure the continued persistence of greater sage-grouse and aid in the recovery of the species; however, the County 

cannot support the approach the BLM is suggesting in the GSGCM report, and further questions the purpose and need for 

another lengthy NEPA process, when there are already regulatory mechanisms and extensive sage-grouse protection and 

management plans in place for the appropriate management and assurances for persistence and recovery of the species. 

After reviewing the GSGCM report and supporting literature, we believe that the GSGCM report's recommended 

conservation measures exclude a balancing of resources and preempts existing permitted activities by state or local 

government(s), and would have significant undue hardships on private landowners and other key stakeholders including 

energy companies, which are vital for our local economies. While we understand the goals of protecting and restoring 

sage-grouse habitats, the Conservation Measures would be an extreme hardship on our constituents, and appears to 

exclude other viable alternatives to habitat management and goes beyond what the cited scientific literature has indicated 

as necessary for the continued existence of a health population of this species. Further, with existing NEPA requirements 

for any action on federal lands or for projects with a federal nexus, there are already guidance documents and required 

review by the US Fish and Wildlife Service, as well as Colorado Parks and Wildlife for projects which may impact 

sagegrouse. Introducing additional lengthy planning and uncertainty to our constituents at this time is unfair and will cause 

All BLM emc0058RM
C. Comments by Resource Planning Issue

C-1160 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

negative impacts to industry, our economies, and our ability to utilize the public and private resources within Garfield 

County and northwestern Colorado.

27. Range Management / Grazing Range Management or Grazing (domestic livestock and wild ungulate) is a very important 

component of Garfield County's traditional ranching heritage and wildlife herd management which requires working 

together with our public lands. In preparation of the EIS, Garfield County recommends the BLM work closely with the 

Cattleman's Association and the Wool Growers Association for both Colorado and other states which are also affected 

by the EIS to gain their valuable input into this process.

All Both emc0058RM

28. Additionally, economic viability nationally such as pipelines, mining, commercial activity, renewable and other energy 

development, in these trying times, should take priority over sage grouse habitat to preserve the human species.

All Both emc005GB

29. Judging by the habitat maps available at this time, multiple-uses of lands throughout the western United States will be 

affected by the proposed conservation measures. Our members currently have operations within the affected area, and 

future exploration and development of mineral resources, as well as the thousands of associated direct and indirect jobs, 

will undoubtedly be significantly impacted.

All Both emc0067GB

30. Current and relevant socio-economic data regarding the community impacts near sage grouse habitat needs to be 

provided, preferably by a credible third party contractor, in the development of all alternatives considered in the EISs.

All Both emc0068RM

31. In summary, CLUB 20 encourages careful consideration of: - Local community sage grouse planning efforts; - Broad and 

scientifically based management alternative considerations; - A fully developed social and economic impact analysis 

related to all communities that may be impacted; and - The development of an EIS that relies on local knowledge and 

adaptive management.

All Both emc0068RM

32. The federal agencies must keep in mind that regulations designed solely to address the needs of a single species and not the 

habitat, could lead to the loss of the economic viability of the captive managers the agencies currently have on the public 

landscape. If lost, you will never get them back.

All Both emc0070GB

33. Since passage of the National Environmental Policy Act (NEPA) of 1969, environmental impact assessments have become 

the key component of land use planning and decision making for public lands in the United States. Although agency 

planners and decision makers have recognized a need for better understanding the social consequences of projects, 

programs and policies, to our knowledge there has never been an EIS or EA prepared with an adequate analysis of the 

social impacts included. This is true even though an Inter-organizational Committee on Guidelines Principles for Social 

Impact Assessment (SIA) has existed for many years. Their purpose has been out-lining a set of guidelines and principles 

that could and should have assisted agencies and private interest in fulfilling their obligations under NEPA, related 

authorities and agency mandates. The Sage Grouse EIS should consider their process and set them as the basis to 

accomplish a true analysis of social AND economic impacts as one of the priority outcomes to be included in the EIS.

All Both emc0071GB

34. Social impacts can be defined as the consequences to human populations of any public actions that alter the ways in which 

people live, work, play, relate to one another, organize to meet their needs and generally cope as members of society. 

Defining social impacts also includes cultural impacts involving changes to the norms, values, and beliefs that guide and 

rationalize their cognition of themselves and their society. The Sage Grouse EIS that is now seeking scoping comments 

should consider the social consequences or impacts that are likely to follow from any changes to policy actions (including 

All Both emc0071GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1161

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

programs and the adoption of new polices), and specific government actions particularly in the context of the U.S. National 

Environmental Policy Act of 1969 or "NEPA" (P.L. 91-190, 42 U.S.C. 4371 et seq.). A central requirement of NEPA is that

before any agency of the federal government may take "actions significantly affecting the quality of the human environment" 

that agency must first prepare an Environmental Impact Statement (or EIS). We believe that preparing this EIS or 

completing any of the unfinished various RMP’s across the Sage Grouse range requires the integrated use of the social 

sciences.

35. In hindsight, it is most apparent that the impacts of the listing of the spotted owl as an endangered species and the 

subsequent EIS/EA’s which have guided land use decisions had an incredibly detrimental impact on the social aspects of 

hundreds of rural communities. Little or no forethought regarding social impacts was put into that effort. A prime example 

is the community of Harney County. Land use decisions as a result of the spotted owl listing are the direct cause of federal 

actions guided by EIS’s which conducted only a narrow analysis of the potential social impacts federal actions would cause. 

Our communities may not be able to remain in existence should this EIS not conduct a complete analysis of those social 

impacts. Obviously any alternative chosen to address those impacts must provide mitigation strategies or define ways that 

communities are part of the solution rather than ignored. In conclusion the position of the Harney County Court is that 

this EIS MUST be completed with a true analysis of Social impacts and it MUST address those impacts with the same level 

of sensitivity as environmental impacts are handled.

All Both emc0071GB

36. Most EIS’s to this date are focused on threats; will any opportunities or strengths regarding habitat or benefits of 

community to the habitat be analyzed? This is the basis for our county’s request to look to the positive and may be a way 

to strengthen the social and economic connections to environment.

All Both emc0071GB

37. How will the plan analyze social impacts from the changes to regulatory mechanisms and other areas included in the plan? 

How will these impacts be shown to be different than any economic impacts? Will the plan suggest ways to mitigate the 

social impacts for the affected communities? The Harney County Court realizes the difficulties of this but offers that any 

plan written without a complete determination of impacts to the social fabric of the community in and around sage-grouse 

habitat stands the chance of "undoing" extremely fragile islands of humanity, our community. The Court will do everything 

in its power to assist in this analysis but strongly urge an early focus in the EIS process on this issue. (NOTE: as described 

earlier if the analysis includes strengths and opportunities rather than just threats it would add significantly to ties with 

local communities!)

All Both emc0071GB

38. How will the plan analyze economic impacts from the regulatory mechanisms included in the plan? Will the plan suggest 

ways to mitigate the economic impacts for the affects communities?

All Both emc0071GB

39. In many cases grazing permitee’s Taylor Grazing dollars or other non-federal funds have paid for range improvements. 

What analysis will be included in the EIS to assure the continued availability of these funds are not prohibited or reduced 

by the outcome of the EIS?

All Both emc0071GB

40. A possible new strategy to include for analysis might be to do a complete review of the positive impacts that ranching, 

grazing, Taylor Grazing projects, Boy Scout projects and etc. have on the ground to the benefit of Sage Grouse habitat and 

include them in the EIS. This may provide the opportunity to expand on this type of project in any alternative at the end 

of this work.

All Both emc0071GB
C. Comments by Resource Planning Issue

C-1162 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

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41. Please be very careful of adding unnecessary restrictions that are costly to both the government and those of us what have 

to make a living here.

All Both emc0082GB

42. Mining and livestock grazing contribute substantially to local communities in northern Neveda and throughout the western 

United States. Newmont supports the BLM's efforts to take measures that will avoid the potential listing of Greater 

sage-grouse under the Endangered Species Act; however, it is essential that the BLM carefully considers the impacts of 

potential conservation measures on mining and grazing activities, and that BLM develops a balanced approach that will 

avoid or minimize the socio-economic effects such measures will have on local communities and business interests.

All Both emc0084GB

43. 11th and 12th bullets: In considering the economic situation- tracking alternative scenarios- to maintain healthy 

ecosystems, the economic value of wildlife populations must also be considered. Such values include wildlife viewing, 

hunting, and more.

All Both emc0099GB

44. A full analysis of the socio-economic impacts of conservation measures need to be considered in the EIS for all alternatives. 

The analysis of socio-economic impacts must include a detailed analysis of the cumulative impacts of conservation 

measures.

All Both emc0103GB

45. We are a hard rock mining company with patented mineral reserves on private land and mining claims on public lands 

within the state of Nevada and as such are a stakeholder in this process. We are concerned about the fate of the regulatory 

framework associated with sage-grouse habitat conservation and its effect on mining and exploration and the associated 

economic impact to the state of Nevada.

All Both emc0103GB

46. The land management agencies must cooperate with State and local governments and coordinate with existing local plans. 

Livestock producers’ ability to graze livestock on BLM and FS managed lands is critical to many of Wyoming’s counties and 

rural economies. Local and county governments should play an active role in land use planning

All Both emc0106RM

47. It is extremely important that a stable economic environment be sustained and enhanced so that our members may assist 

in the conservation of rangeland for the greater sagegrouse. We appreciate the opportunity to comment on the NOI 

regarding development of EISs and SEISs for management of the greater sage-grouse and its habitat

All Both emc0106RM

48. Furthermore, the Act stipulates “... when an EIS is prepared "and economic or social and natural or physical 

environmental effects are interrelated, then the environmental impact statement will discuss all of these effects on the 

human environment" (40 CFR 1508.14). The EIS's are thus intended to provide a kind of fulldisclosure procedure for 

federal decision-makers, who are then expected to consider the negative as well as the positive implications of potential 

courses of action, and the unintended as well as the intended consequences, before they proceed. b. Therefore any 

alternative that significantly reduces grazing in the Custer Lemhi County area will have a dramatic soci-economic impact 

affecting the economy and cultural way of life, thus the most important alternative should be the consolidation of adjoining

allotments into grazing associations.

All Both emc0112GB

49. The BLM must analyze the potential economic impacts that additional restrictions on oil and gas operations and other uses 

of the public lands will have upon local and regional economics. Such an analysis must be prepared on a local, planning level, 

not a single national or regional analysis. Only site-specific economic impact analysis will demonstrate the potential 

economic consequences of additional restrictions to public lands users and local governments. Such an economic analysis 

is specifically required by the BLM Land Use Planning Handbook. BLM Manual H-1601-1, Land Use Planning Handbook, 

All BLM emc0116GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1163

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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Appendix D (Rel. 1- 1693 03/11/05).

50. Address the full economic impacts to existing and future mineral development of fee surface and mineral estates. In areas 

of mixed land ownership patterns, application ofBLM's rule-of-reason may have significant impact on timely and efficient 

development of those resources. Briefly, the rule-of-reason states that "BLM will limit its responsibility for ... protection of 

(plant and wildlife) on lands outside the administrative jurisdiction of the Bureau, according to the degree to which Bureau 

decisions condition or control the location of surface disturbing activities on those lands" (BLM I.M. 99-24). Under the 

rule-of-reason, damages to fee mineral interests could occur where BLM management decisions preclude reasonable 

access or limit facility siting opportunities.

All Both emc0125RM

51. It also needs to be noted that we the stewards/owners of the lands need to have some consideration. If we cannot 

continue to make a living from the land, we won't have to worry about conserving animals anymore; we'll need to worry 

about surviving ourselves. We need to use good common sense in the management of the land and the animals. We have 

to stop the attitude that we can't save every animal, or perhaps every species.

All Both emc0128GB

52. All federal decisions should be directly addressed substantively in writing by the lead agency and based on scientific 

peer-reviewed data. Every EIS and SEIS should be accompanied by a complete economic analysis and an analysis of the 

impacts of all proposed alternatives on other multiple uses within the planning area, so as to avoid unnecessary and 

unreasonable socio-economic impacts.

All Both emc0140RM

53. Specifically, wherever grazing allotments exist, analyses must address the positive impacts of livestock grazing to greater 

sage-grouse habitat, as well as the potential loss of those benefits, should grazing be reduced or eliminated. One major loss 

should public lands grazing be curtailed, for example, would be the open space provided by private ranch lands, which is 

critical to greater sage-grouse habitat. Every federal grazing allotment in the West is held by a rancher who owns 

accompanying private “base” property. In fact, these ranchers own nearly120 million acres of primarily rangeland. Most of 

these ranchers’ ability to stay in business is dependent on their ability to continue grazing public lands. The unintended 

consequences of decisions that negatively impact those ranchers will also impact the greater sage-grouse, by encouraging 

the conversion of private rangelands into farmland, urban development, or other uses not conducive to greater 

sage-grouse habitat. As indicated by the Sage Grouse Initiative (SGI), this fact has been recognized by NRCS; fortunately,

the agency has indicated its commitment to its relationship with the ranchers that make greater sage-grouse conservation 

possible.

All Both emc0140RM

54. Alternatives The NOI states: “The BLM and FS will address socio-economic impacts of the alternatives. Socioeconomic

analysis will use an accepted input-output quantitative model such as IMPLAN or RIMSII, and/or JEDI for renewable energy 

analysis.” This includes any direct or indirect economic impact on rural economies due to negative impacts on grazing. We 

agree that BLM should consider not only the environmental consequences in the NEPA analysis, but also the impacts to the 

human environment and economy, including grazing, mining, oil and gas, and other multiple-use industries. We strongly 

encourage the agencies to consult economists from Western Land Grant universities when developing the models 

(variables, assumptions, data) for use in the abovementioned programs.

All Both emc0140RM

55. It is imperative that a stable economic environment be sustained and enhanced so that our members may assist in the All Both emc0140RM
C. Comments by Resource Planning Issue

C-1164 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

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conservation of rangeland for the greater sage-grouse.

56. And what is to become of cattle ranchers and their cattle if you kick them off their grazing lands? It will disrupt the 

economic progress and put many ranchers out of business.

All Both emc0141GB

57. All Draft Environmental Impact Statements the BLM has issued or will issue/approve included biological surveys that would 

have identified impacted sage grouse habitats and populations, and should have taken into account impacts on sage grouse 

and applied necessary mitigation measures. Requiring after-the-fact implementation of additional policies and procedures 

can have significant monetary and timeline impacts to projects (e.g. mining, grazing, etc.), potentially making them 

economically infeasible. This could cause current proponents and lease holders to lose funding sources and/or incur 

economic costs which could result in the loss or withdrawal of the application, and have a significant socio-economic 

impact on surrounding communities.

All Both emc0147GB

58. Garkane Energy Cooperative provides electric power to the communities and facilities within south central Utah and 

northem Arizona and the decisions made as part of this planning strategy will directly affect our ability to provide reliable 

power at reasonable rates to our service area.

All Both emc0150GB

59. The BLM must analyze the potential impacts that additional restrictions on oil and gas operations, and other uses of the 

public lands, will have upon local and regional economics. Such an analysis must be prepared on a local, planning level, not 

a single national or regional level. Only with site-specific economic impact analysis will public lands users and local

governments understand the potential economic consequences of additional restrictions. Such an economic analysis is 

specifically required by the BLM Planning Regulations and the BLM Land Use Planning Handbook. 43 C.P.R. §§ 1610.4-4(g), 

1610.4-6; BLM Manual H-1601-1, Land Use Planning Handbook, Appendix D (Rel. 1-1693 03/11/05).

All BLM emc0166GB

60. The BLM has historically been very successful in developing strategies to mitigate the environmental effects of mining and 

mineral exploration while simultaneously facilitating a productive industry in accordance with multiple-use policies. 

Wholesale withdrawal oflarge areas of Nevada to mining and mineral exploration, an industry which is vital to the local and 

national economies, is an extraordinarily unimaginative and uncreative approach to addressing the impacts of this activity 

on sage grouse habitat.

All Both emc0168GB

61. Some manageable issues, ideas and options that should be addressed in and EIS can be broken down into the following 

principal points. 4. Economic

All Both emc0200GB

62. The economic aspect related to any proposed action relating to sage grouse must be carefully taken into account and goes 

far beyond the cost of administration. Proposals have been tabled by some parties to severely limit or eliminate 

commercial grazing. This would have a devastating effect on many western cattle ranching and an equally devastating effect 

on rural communities and counties.

All Both emc0200GB

63. Hunting for sage grouse is a very significant draw for many rural areas during the hunting season. Closing the hunting 

season as some would propose, would significantly reduce the number of hotel rooms rented the number of meals 

purchased, the local supplies purchased and severly damage rural economies. Closing the hunting season would also 

suggest that sage grouse would not be elligible for as much support from hunting licenses as huntable game species. This 

would have the potential unintended effect of increasing illegal hunting though reduced law enforcement and monitoring.

All Both emc0200GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1165

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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64. The conservation of rangelands for livestock production is extremely important, not only to the sustainable production of 

food and fiber for the United States and worldwide markets, but also to providing quality habitat to support wildlife 

populations.

All Both emc0202GB

65. I am extremely concerned about the impact that the above referenced notice of intent will have on the range livestock 

industry in Nevada. Economically viable ranching operations provide both stewardship of public lands and economic 

stimulus and viability to local and regional communities.

All Both emc0215GB

66. While the team members appear to have expertise in sage-grouse habitat, there seems to be little expertise in oil and gas 

exploration, development and operation practices. Prior to implementing additional conditions and stipulations BLM 

should engage in good faith discussion with industry representatives on such measures. BLM's analysis should also include 

the economic effect of any new stipulations as they will limit access to precious oil and gas reserves

All Both emc0228GB

67. In rural counties of the Western United States, the effect of a no-grazing alternative would be devastating to the local 

customs/culture/economics with a great multiplying effect.

All Both emc0233GB

68. Characteristics of wilderness-quality lands such as naturalness, roadlessness, and primitive settings are also valuable 

characteristics of important sage-grouse habitat. Protecting lands with wilderness characteristics can support the 

principles for protecting and managing sage-grouse habitat as outlined in BLM's National Strategy and reiterated in IM 

2012-043, namely protecting unfragmented habitats and minimizing habitat loss and fragmentation

All Both emc0234GB

69. Page 12, Lands/Realty section indicates that rights-of-way (ROWs) should not be permitted in high priority sage-grouse 

habitats, with a few exceptions. The socio-economic impact of this conservation measure needs to be analyzed in the EIS. 

Restricting the new ROWs to be co-located entirely within an existing ROW is too restrictive (page 13, first bullet). The 

temporary, short-term use of a laydown yard or staging areas that is too large to be co-located entirely within an existing 

ROW should not be sufficient reason for denying the use of the ROW. However, such short-term temporary use should 

be followed by reclamation to prevent non-native invasive species from establishing and re-establishing perennial 

vegetation.

All Both emc0239GB

70. On page 14, Proposed Land Withdrawals section, the first conservation measure bullet proposes that "lands within 

priority sage-grouse habitat areas for mineral withdrawal." The socio-economic impacts of this conservation measure 

need to be evaluated in this EIS.

All Both emc0239GB

71. The socio-economic impacts of the three conservation measures at the top of page 15 need to be analyzed in the EIS. 

These measures are examples of single-species management and deviate from the multiple-use principles that BLM is 

required to follow.

All Both emc0239GB

72. On page 17, Retirement of Grazing Privileges, the planning note at the bottom of the page indicates that BLM and USFS will 

target specific allotments for permanent retirement of grazing privileges. The authority for this use of BLM and USFS action 

needs to be identified in the EIS and the socio-economic impacts of this type of action need to be analyzed in the EIS.

All Both emc0239GB

73. The socio-economic impacts of the minerals-related conservation measures need to be analyzed in the EIS. The restrictive 

nature of the conservation measures does not allow for mitigation to offset impacts created by mineral exploration and 

development. The NOGA believes that the best way to provide for protection of the sage-grouse, while simultaneously 

allowing continued economic development, is for BLM to develop conservation measures in cooperation with the 

All Both emc0239GB
C. Comments by Resource Planning Issue

C-1166 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

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regulated community that include a strong but pragmatic mitigation program.

74. The BLM must ensure that that sage grouse conservation measures can be enacted in a manner that will not adversely 

impact local and state economies. The state and counties will not accept over-reaching conservation measures, such as 

were enacted in the Pacific Northwest for the Northern Spotted Owl, which devastated the timber industry, led to 

numerous mill closures and resulted in the loss of countless jobs and economic activity that timber towns have yet to fully

recover from. The EIS must include a sufficient socio-economic impact analysis and a cost-benefit analysis that can help 

decision makers determine whether the benefits of conserving sage grouse habitat outweigh the socio-economic costs of 

doing so.

All Both emc0242GB

75. The BLM must consider the impact of sage grouse conservation measures on local and state tax and royalty receipts. All Both emc0242GB

76. Cattle ranching is a mainstay of Nevada (the state most heavily impacted by the threatened sage grouse), and the 

livelihoods of thousands of American citizens could be extinct due to the restrictions placed on ranchers by the Interim 

Policy.

All Both emc0244GB

77. The requirements that could ultimately be Incorporated In the RMPs will undoubtedly Impact future development and 

corresponding socio-economic benefits across the range of the GSG. As part of the RMP amendment process, BLM should 

address the soclCH!COnomlc Impacts of applying more restrictive sage grouse management requirements, factOring in 

the projected reduced level of activity Inside PPH areas.·' Specifically, BLM must analyze the potential economic Impacts 

that additional restrictions on 011 and gas operations, and other uses of the public lands, such as grazing and recreation 

actMties, will have upon local and regional economics. This analysiS should focus on local, regional, and national Impacts. 

An adequate soclo-economlc analysis will Inform state and local stakeholders of the economic effects of additional 

restrictions for GSG and Is necessary for BLM to adequately assess which management strategy is the most viable to 

protect the species while allowing for continued multiple use of the public lands.

All BLM emc0246GB

78. The oil and gas industry contributes significantly to the local, state, and national economy, providing billions of dollars each 

year in royalties, bonuses, and severance taxes, besides other benefits of direct capital investment to local economies and 

high paying Jobs. Accordingly, BLM needs to analyze the effect on the local, state and national governments from the loss 

revenue that will arise from the Implementation of the new sage-grouse policies. The analysis should also include but not 

be limited to the loss of jobs and the increase of unemployment compensation.

All BLM emc0246GB

79. To threaten thousands of jobs and families (that produce food and fiber for our country) throughout eleven western states 

is, to me, almost criminal.

All Both emc0249GB

80. Please include an economic analysis of each regulatory option that is being considered. The impacts should be specific to 

every economic area impacted by the proposed action. In other words, if a proposed restrictive rule would prohibit 

grazing, logging, mining or recreational activity, how much damage would that do to the local economy.

All Both emc0260GB

81. The proposed remedies for the birds’ recovery are aimed straight at the heart of our County’s economic stability. 

Converse County depends heavily on our coal mines, oil and gas wells, and wind farms, along with their various 

transmission lines, haul roads, and pipelines for our diversified economy. Our ranchers depend on the allotment of the 

BLM and USFS lands to graze their livestock. All of these activities sustain our County with good paying jobs and a myriad 

All Both emc0266GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1167

Scoping Summary Report

Table C-10.A

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of tax benefits. These endeavors can work in consort with the sage grouse if we are careful. If you chose to close these and 

all other human activity in the core areas, how are we to pay for your recovery actions?

82. In the rare event that a mine is created the wealth contributed to the state and federal governments is large. The suggested 

removal of vast acreages would have a highly material impact on the potential future tax base.

All Both emc0272GB

83. The comments presented here are aimed at conserving the Greater Sage-Grouse (sage-grouse) while allowing EI Paso's 

and others' necessary natural gas development projects to be permitted and implemented in an efficient and cost-effective 

manner.

All Both emc0278GB

84. Construction and permitting delays can be cost ly to EI I>aso and its customers. Beyond economic costs, such delays 

underm ine the ind ustry's abi lity to provide safe, secure and rel iable energy supplies needed to support economic growth 

while protect ing both human health and environmental concerns. As wi th other regulatory approval processes, 

compliance with the BLM Resource Management Pl ans is a key factor in accomplishing effic ient perm itting and 

implementation of natural gas projects.

All Both emc0278GB

85. In addition to adhering to its long-standing multiple-use policy, the BLM must also analyze the economic impacts of the 

restriction of energy development and infrastructure as wel l as traditional uses such as grazing through the 

implementation of sage-grouse conservation measures. Many local and regional economics are dependent upon the 

multiple lIses of the public lands and as such deserve a comprehensive economic evaluation of the economic impact of any 

large-scale, range-wide conservation measures.

All Both emc0278GB

86. The BLM allotments and associated private lands in sagebrush country provide habitat for diverse wildlife species as well 

as providing the economic base for these rural counties.

All Both emc0281GB

87. However, as described above, fences can provide time-control, and proper grazing can significantly improve rangeland 

function and GSG habitat, improving vital rates and increasing populations. If used properly, fence benefits to rangeland 

function outweigh the negative effects. Large herds and large pastures are preferential than small herds and small pastures 

from and economic and ecological perspective

All Both emc0281GB

88. BLM should consider not only the environmental consequences in the NEPA analysis, but also the impacts to the human 

environment and economy, including grazing, mining, oil and gas and other multiple-use industries.

All Both emc0284GB

89. Every EIS and SEIS should be accompanied by a complete economic analysis and an analysis of the impacts of all proposed 

alternatives on other multiple uses within the planning area, so as to avoid unnecessary and unreasonable socio-economic 

impacts.

All Both emc0284GB

90. If grazing permits are reduced as a result of this effort, the negative economic impact to rural communities would be 

significant and it is important that the EISs and SEISs acknowledge this.

All Both emc0284GB

91. Suggest that –Page 22 Fluid Minerals and Solid Minerals sections. The language in the entire area of both of these sections 

should be edited to reflect the attitude of possible cooperative efforts to manage sage-grouse habitat and develop the 

energy types located in these areas. Removing energy exploration and development completely from these areas will have 

a severe impact on our local economy and also impact other areas of the country where habitat may be fragile but not 

regulated because of its effect on plant or animal species. This common sense approach would help our federal 

government continue to provide affordable energy to it’s people.

All Both emc0291GB, 

emc0055RM, 

emc0119RM
C. Comments by Resource Planning Issue

C-1168 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

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92. The economic impacts of a possible listing would be devastating to the west. Those groups pushing for a listing are only 

interested in removing cattle from the range and are willing to destroy an industry to meet their goals. Science will not 

support that agenda.

All Both emc0292GB

93. The second major point is that unnecessary sage-grouse conservation measures that have and will negatively impact all 

economic activities across the species entire range. Increasing the regulatory cost and burden to conduct natural resource 

related activities and significantly reducing or virtually eliminating such activities.

All Both emc0294GB 

emc0120rm

94. Secondly: Because the listing is not warranted by terms of the Endangered Species Act itself then the Proposed Interim 

Managment proposes unnecessary sage-grouse conservation measures that have and will negatively impact all economic 

activities across the species entire range, increasing the regulatory cost and burden to conduct natural resource related 

activities and significantly reducing or virtually eliminating such activities. History has shown that many of the management

tools being used over the past 30 years are not improving but rather diminishing wildlife habitat. Two examples are 

reduced stocking levels which has lead to heavy fuel loads causing more large fires and the fire managment policy of pulling 

off fires at night which has cause hundreds of thousands of acres to be burned unnecessarily. I personally saw where the 

Windemere Hills fire North of Wells could have been put out the first night if they would have stayed on it but instead it 

was allowed to burn over 80,000 acres in the end. When the government fire fighters went off the fire in the evenings two 

cowboys who were running cattle in a private pasture I leased road their motorcycles with shovels over their sholders and 

they almost had it put out that night but didn't. The fire crews had a fire meeting at 7 am and by the time it was done and 

they were back on the fire the wind was comming up and it was starting to roar again. Another managment practice that 

has negatively impacted Sage Grouse is fencing of riparian areas without grazing as part of the annual managment. These 

riparian areas were historically used by Sage Grouse when cattle had grazed them down and the feed was more succulent 

and the cow feces was creating a natural fertilizer and medium for bugs and worms. The stringer meadow with long edge 

lines were a perfect Sage Grouse feeding trough as long as it were grazed . If grazing of the riparian areas is used as a tool 

to keep the course grass and brush down so the feed is desirable Sage Grouse will start using these enclosures again unless 

they are heavily treed. Even if the Sage Grouse don't use them if they are treed other wildlife will use them more. As the 

cattle leave it the Fall have them use the Riparian areas before they go.

All Both emc0299GB

95. The EIS must include an extensive and detailed socioeconomic evaluation of each proposed alternative in terms of direct, 

indirect and cumulative social and economic impacts to individuals, industrial sectors, state and local governments and the 

public who use, may use or rely on public lands. The range of alternatives must be technically and economically feasible, and 

the scope of the socioeconomic cumulative effects analysis must be sufficiently robust to quantify the potential impact on 

the economic viability of communities in the sub-region (eg: loss of wages, business, sales, and employment taxes, mining 

proceeds payments, transportation of goods and services, lost jobs in other parts of the US that provide goods and 

services to the industry, raising the tax burden on other residents, decline in public services funded by these tax revenues,

etc.).

All Both emc0310GB

96. The EIS must specifically identify what economic indicators and thresholds will be used when comparing the impacts of 

sage grouse habitat protection measures verses the socioeconomic costs to business, industry, governments and the 

public.

All Both emc0310GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1169

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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No.

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97. The requirements that could ultimately be incorporated in the RMPs will undoubtedly impact future development and 

corresponding socio ‐of the GSG. As part of the RMP amendment process, BLM economic benefits across the range

should address the socioeconomic impacts of applying more restrictive sage grouse management requirements, factoring 

in the projected reduced level of activity inside PPH areas. Specifically, BLM must analyze the potential economic impacts 

that additional restrictions on oil and gas operations, and other uses of the public lands, such as grazing and recreation 

activities, will have upon local, regional, and national economics. An adequate socio ‐analysis will inform local economic

stakeholders of the economic effects of additional restrictions for GSG and is necessary for BLM to adequately assess 

which management strategy is the most viable.

All BLM emc0312GB

98. The AMA advocates responsible motorized recreation on public lands for its members in the western part of the United 

States. On behalf of our membership we want to see our members and their friends and families continue to enjoy the 

American outdoors. Motorized recreation has a substantial growing economic impact on many small communities in the 

West. We feel it is important that the management of sage grouse be adequately defined so that we avoid unnecessary 

restrictions being placed on America's motorized outdoor recreation causing an adverse economic impact on the small 

business sector of rural communities.

All BLM emc0313GB

99. Any EIS or SEIS must also explicitly recognize the following points: In the Great Basin, and much ofthe western United 

States, livestock operations are highly dependent upon the combined use of private and public lands. Regulatory actions 

that make public lands grazing economically unsustainable will not only negatively impact individual ranch owners, but also 

entire rural communities that largely depend on ranching to maintain businesses and tax base.

All Both emc0315GB

100. Our organization is concerned that the protection measures and restrictions included in the Interim Guidance IM and the 

National Technical Team’s Report on National Greater Sage-Grouse Conservation Measures (the “Report”) are 

excessively restrictive for a species that is not currently listed as threatened or endangered under the ESA, and we are 

deeply concerned about the economic impact of implementing such a plan will have on our region, particularly as we 

attempt to recover from a long-term recession

All Both emc0319GB

101. We request that socio-economic impacts of applying more restrictive GSG management requirements be addressed in the 

study. As an organization of primarily small businesses we think this is imperative. Specifically, BLM must analyze the 

potential economic impacts that additional restrictions on oil and gas operations, and other uses of the public lands, such 

as grazing and recreation activities, will have upon our local and regional economics.

All Both emc0319GB

102. The first thing I would like you to consider is this: With the National debt going up at the rate of a million dollars 

approximately every 30 to 3S seconds (as of yesterday), who is going to pay for your plan of operation? All of us are taxed 

to where it is becoming more and more difficult to make a living or even maintain.

All Both emc0320GB

103. To shut down the natural raw industries, whether it be mining, subsurface extraction of either oil & gas or geothermal, 

surface use of ranching and farming, seems to me that you are cutting future revenue for your own existence as an agency 

to manage the Public Lands as well as that of the State of Nevada, along with the other Western States for generations to 

come.

All Both emc0320GB

104. We also have concerns about the impact of the proposed conservation measures on our members with mineral resources 

or projects on private lands. BLM’s materials state the conservation measures would be applied regardless of surface 

All Both emc0321GB
C. Comments by Resource Planning Issue

C-1170 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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ownership (emphasis added). For example, see the 12/27/11 press release: human-caused disturbance in priority habitat 

would be limited to less than 2.5% of the species’ total habitat, regardless of surface ownership. It is essential BLM and 

USFS carefully consider the impacts of potential conservation measures on mining and grazing activities, and that both 

agencies develop a balanced approach that will avoid or minimize the socio-economic effects such measures will have on 

mining, grazing, other multiple-use activities and local communities.

105. There are a number of current federal, state, and local management and conservation measures to improve and protect 

sage-grouse habitat. Many of these have been in effect for a decade or more. The ongoing implementation of these 

measures should be evaluated in the No Action Alternative to provide the baseline against which all other alternatives are 

compared and measured. The EIS documents prepared for each sub-region must include a substantive and detailed analysis 

of the Continuation of Existing Conservation Measures/No Action Alternative. Specifically, this analysis should examine, in 

addition to complete or better implementation of Manual 6840, the following potential outcomes that would result from 

the Continuation of Existing Conservation Measures/No Action Alternative:  Assess the economic benefits that would 

likely occur if the current Land Use Plans (LUP’s) remain in effect allowing future mineral exploration and development, oil 

and gas exploration and development, rights-of-way (ROW) development, grazing, and other multiple-uses of public lands 

with sage-grouse habitat compared to the economic hardships that would likely occur as a result of implementing the land 

use restrictions and prohibitions recommended in the December 2011 NTT Report.

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106. Page 12, Lands/Realty section indicates that rights-of-way (ROWs) should not be permitted in high priority sage-grouse 

habitat, with a few exceptions. The socio-economic impact of this conservation measure needs to be analyzed in the EIS. 

Restricting the new ROWs to be co-located entirely within an existing ROW is too restrictive (page 13, first bullet). The 

temporary, short-term use of a laydown yard or staging area that is too large to be co-located entirely within an existing 

ROW should not be sufficient reason for denying the use of the ROW. However, such short-term temporary use should 

be followed by reclamation to prevent non-native invasive species from establishing and re-establishing perennial 

vegetation.

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107. On page 14, Proposed Land Withdrawals section, the first conservation measure bullet proposes that "lands within 

priority sage-grouse habitat areas for mineral withdrawal." The socio-economic impacts of this conservation measure 

need to be evaluated in the EIS.

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108. The socio-economic impacts of the three conservation measures at the top of page 15 need to be analyzed in the EIS. 

These measures are examples of single-species management and deviate from the multiple-use principles that BLM is 

required to follow.

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109. The section on Treatments to Increase Forage for Livestock/Wild Ungulates, page 16 is very single-species oriented and 

does not uphold the principles of multiple-use management. The socio-economic impacts of these conservation measures 

should be analyzed in the EIS.

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110. On page 17, Retirement of Grazing Privileges, the planning note at the bottom of the page indicates that BLM and USFS will 

target specific allotments for permanent retirement of grazing privileges. The authority for this use of BLM and USFS action 

needs to be identified in the EIS and the socio-economic impacts of this type of action need to be analyzed in the EIS.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1171

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Table C-10.A

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111. The socio-economic impacts of the minerals-related conservation measures need to be analyzed in the EIS. The restrictive 

nature of the conservation measures does not allow for mitigation to offset impacts created by mineral exploration and 

development. I believe that the best way to provide for protection of the sage-grouse, while simultaneously allowing 

continued economic development, is for BLM to develop conservation measures in cooperation with the regulated 

community that include a strong but pragmatic mitigation program.

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112. In closing, I support the concept of enhancing sage-grouse populations and habitat. But the conservation measures in the 

NTT report create real concerns that socio-economic and ecological impacts will occur by implementing these 

conservation measures, but very few gains in sage-grouse populations or habitat will be realized by implementing these 

conservation measures.

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113. Also, the proposal should allow flexibility for the agencies to develop conservation measures in cooperation with the 

regulated community that include a strong but pragmatic mitigation program while simultaneously allowing continued 

economic development.

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114. Our family business is in the cattle business and our community and many local businesses are dependent upon livestock 

grazing on public lands - arbitrary changes to land-use plans could seriously damage our local economy, private businesses 

and sagegrouse populations in our area. The assumption of many managers inside and outside BLM and other agencies is 

that because of the proposed listing of sage-grouse, that something different in land use or management needs to be done 

when the opposite should be the starting point for sage-grouse conservation measures and they need to be site specific.

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115. The proposed land use restrictions and proposed withdrawal of lands from mineral entry for areas with high-priority 

sage-grouse habitat will substantially hann NVMRA members that have exploration projects in these areas. However, 

beyond the immediate impact the proposed land use restrictions, prohibitions, and withdrawals will have on NVMRA 

member companies, we are concerned that a significant reduction in the amount of land open to operation of the U.S. 

Mining Law will hurt Nevada's economy - especially in rural Nevada. Such a withdrawal will also hann the nation at large 

because it will increase the country's reliance on foreign sources of minerals that support the U.S. economy, are needed 

to build our infrastructure, and are critical to our national defense.

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116. As BLM moves forward with the EIS, BLM should strive to avoid or minimize disruption of mineral development as 

minerals are the building blocks of our society, playing a vital role in innovation, national security and economic growth. 

And abundant and affordable coal is the backbone of our nation's power, supplying nearly half of the nation's electricity. 

The 1.8 million jobs supported by U.S. mining generate billions of dollars in economic activity. According to government 

statistics, the value added from industries consuming the $64 billion in raw materials from U.S. minerals mining translates 

into $2.1 trillion, or 14 percent, of our GOP, and approximately $100 billion in coal-based electricity generation. BLM 

must ensure that the nation's need for minerals and affordable energy is properly reflected in the EIS. While economic 

factors cannot be considered by the Fish and Wildlife Service when making a determination whether to list a species, the 

same is not true of BLM in its efforts to design measures to preclude a listing. NMA believes that BLM can and should adopt 

a balanced approach to sage grouse conservation that recognizes the agency's multiple use mandate while also being 

designed to avoid or minimize adverse socio-economic impacts. Specific issues that BLM should consider in the EIS to 

ensure a balanced approach are outlined below.

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C. Comments by Resource Planning Issue

C-1172 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-10.A

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117. Continuation of Existing Management and Conservation Measures - (The No Action Alternative) - Must Be Thoroughly 

Evaluated The continuation of existing management and conservation measures and existing regulatory policies including 

the directives in BLM Manual 6840 define the No Action Alternative. As is the case for all NEPA documents, the No Action 

Alternative provides the baseline against which all other alternatives must be compared and measured. The No Action 

Alternative analysis in each sub-regional EIS should quantify the impacts associated with ongoing implementation of the 

many existing local, state, and federal conservation measures and the existing BLM and USFS policies to protect 

sage-grouse habitat. Some of the impacts that could result from continuation of the existing regulatory framework and

conservation measures that should be evaluated in the EIS documents include the following: The economic benefits to 

States and local governments that would likely occur if the current Land Use Plans remain in effect allowing future mineral 

exploration and development, oil and gas exploration and development, rights-of-way ("ROW") development, grazing, and 

other multiple uses of public lands with sage grouse habitat rather than implementing the land use restrictions and 

prohibitions recommended in the December 2011 NTT Report.

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118. Eureka Moly Scoping Issue No.4: Thoroughly Evaluate the No Action Alternative -The EIS documents must include a 

detailed discussion of the habitat conservation improvements currently being achieved under the existing policies, the 

socioeconomic benefits that would result from continued private-sector authorized uses of public lands with sage-grouse 

habitat, and the possibility that in light of the numerous habitat conservation measures already in place, the USFWS will 

detennine that the sage-grouse should maintain its status as a Warranted but Precluded, candidate species.

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119. Simply because these analyses will focus upon protection of Sage-grouse does not lessen the importance of a sound, 

comprehensive economic impact analysis. The BLM must analyze the potential economic impacts that additional 

restrictions on oil and gas operations, and other uses of the public lands, such as grazing and recreation activities, will have 

upon local and regional economics. Such an analysis must be prepared on a local, planning level, rather than focusing on a 

single national or regional analysis. Only with site-specific economic impact analysis will BLM have the tools to adequately 

assess which management strategy is most viable and it will allow public lands users and local and state governments 

understand the potential economic consequences of additional restrictions.

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120. Although the request for scoping comments notes that socio-economic considerations will be included in the EIS process, 

such considerations must be made on a local basis considering the local economic impacts of any proposed action. WACD 

objects to any social or economic analysis that reviews impacts on a national or state-wide scale. The management oflocal 

BLM and Forest Service lands will have immediate fiscal and community (social) impacts in local areas, and those local area 

impacts must be fairly and equally considered, and not skewed by comparing local impacts to a national scale. Additionally, 

while the courts have recognized that a modeling process like IMPLAN may be used, it is important to ground-truth any 

data being fed into the model. The quality ofthe data used within the model will impact the quality of the result. Thus any 

data being fed into any model must comply with the requirements of the Data Quality Act.

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121. • The scale of the core area protection approach and its blanket exclusion of wind development compromises state and 

Federal renewable energy and economic development objectives.

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122. F. EIS’s Socioeconomic Impacts Analysis NEPA implementing regulations state that “[w]hen an environmental impact 

statement is prepared and economic or social and natural or physical environmental effects are interrelated, then the 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1173

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Table C-10.A

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environmental impact statement will discuss all of these effects on the human environment.”144 More specifically, the 

incremental socioeconomic impacts of the proposed action and each alternative should be evaluated in the cumulative 

effects section of the EIS.145 Therefore, the EIS should address the local, regional, and national socioeconomic effects 

related to wind energy on: 1) Employment; 2) Economic Development; and 3) Taxable Income. Based on our calculation, 

6,814 MW of wind energy development, representing over $13 billion in investment, would be put in jeopardy if the 

sage-grouse policy continues as it stands today. Such information should be fully developed and considered by BLM and FS 

in making their land management decisions.

123. F. The Scale of the Core Area Protection Approach and its Blanket Exclusion of Wind Development Compromises State 

and Federal Renewable Energy and Economic Development Objectives The sage-grouse conservation documents that 

the NOI states will inform the RMP amendment process adopt an approach whereby important environments for 

sage-grouse preservation are identified and subsequently established as core areas in which development activities are 

prohibited. For example, there is a blanket prohibition on wind energy development in PPH areas in which a 3 percent 

disturbance threshold has already been met.196 Another related core area protection measure requires that PPH areas be 

managed or restored so that at least 70 percent of the land cover provides sagebrush habitat for the sage-grouse.197 

Given that the sage-grouse occupies an expansive range across the western United States, much of which overlaps with 

the nation’s regions that possess the greatest potential for wind energy development, such a rigid conservation framework 

has the potential to bring wind energy development on public lands to a halt. AWEA has analyzed the PPH and PGH 

sage-grouse areas designated within different states and how they overlap witheach state’s capacity for wind development. 

According to our analysis, restricting development in the designated areas would result in the loss of 82.2 percent of all 

lands suitable for wind development in Wyoming, 55 percent for Nevada, 53 percent for Montana, 52.1 percent for Idaho, 

38.4 percent for Oregon, and 9 percent for Utah.198 Considering the magnitude of these percentages, adopting a core 

area approach premised on blanket wind development exclusions would significantly derail the nation’s energy, 

environmental, and job creation objectives associated with renewable energy, and prioritized by the Obama 

Administration.

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124. The BLM may want to consider a "balance of harms approach" to minimize negative consequences of conservation 

measures to local communities. This is particularly important in cases where there is scientific uncertainty about the 

information being used in decision-making. For example, in the precedent setting case on delta smelt, Judge Wanger (2010) 

wrote, "Congress has not nor does TVA v. Hill elevate species protection over the health and safety of humans and Judicial 

deference is not owed to arbitrary, capricious, and scientifically unreasonable agency action." That decision effectively 

imposed limits on how far an agency could go in protecting species at the expense of local communities.

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125. Two narrow alternatives are presented, Alternative A: closing priority sage grouse habitat areas to fluid mineral leasing, 

and Alternative B: allowing leasing when there is checkerboard ownership and a mitigation plan developed that will bring 

long-term population increases. Alternative B, does not acknowledge that it may not be possible to meet the condition 

that the sage grouse population in the proposed lease area be increased through mitigation above its current number (i.e. 

because it is already high, prior to leasing). A more reasonable set of alternatives would include a range of population level 

responses that take into account natural population fluctuations (e.g. an expected percentage of change over current 

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C-1174 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

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number over the life of the field). Also, alternatives are needed that address not only population and habitat variables but 

also the socioeconomic impacts associated with reduced oil and natural gas production from the federal mineral estate.

126. 2. Role of Soils in Potential Sage Brush Habitat The NOI and the Technical Team Report omit entirely the variation of soils 

and relation of soils to sage brush habitat. By way of example, much of southwestern Wyoming has alkaline or sodic soils, 

which will not support sage brush. This and other limitations will apply throughout the Rocky Mountain and western 

rangelands. No EIS should be written without a Level III analysis of the soils.

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127. Listing the sage grouse on the endangered species list, or enacting inhibitive rules upon western range lands will be 

extremely detrimental to my family’s livelihood and our way of life. Though I was raised on a ranch in northern Nevada, 

I recently returned to the area with my husband and two year-old daughter, after purchased a ranch last year. The ranch, 

like most in the area, is dependent upon public range land for cattle grazing. Without grazing access on rangelands, our 

newly purchased ranch is no longer a viable business.

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128. The BLM must consider the impact of sage-grouse conservation measures on local and state tax and royalty receipts All BLM emc0376GB

129. We have read the Notice of Intent and have reasonable concern regarding the extension of greater sage-grouse 

conservation measures on BLM lands. The US Fish and Wildlife Service’s own documents show that the greater 

sage-grouse is not legally qualified for listing under the Endangered Species Act. Conservation measures to protect greater 

sage-grouse from listing are unnecessary and would negatively impact all economic activities across the species’ range.

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130. Much like Nevada as a whole, Eureka County is composed of a large federal land holding. Eighty-one percent of Eureka 

County’s land area is made up of federally administered land, primarily Bureau of Land Management and Forest Service. 

Eureka County is primarily driven by mining, farming and ranching. Nearly all of Eureka County’s employment is in the 

natural resources sector and the community’s viability is largely dependent on business and recreational activities 

conducted on or in concert with federal lands. Since private land makes up only 13% of Eureka County’s total land area, 

dependency on federally administered land limits and is often detrimental to our long-term socioeconomic stability and 

viability. This threat to our viability is only exacerbated by the layers of regulatory burden that are placed upon multiple 

uses of these federal lands and a general lack of effort by the federal land management agencies to coordinate their land 

management decisions with the local plans, policies, and desires of affected counties. This works to undermine sound land 

management and creates often adversarial relationships between the agency, counties, and proponents of projects on 

public land.

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131. We look forward, as a Cooperating Agency, to help develop the EIS and not be merely relegated to review and comment. 

We hope to play an important role is directing the products that will evolve out of this proposed planning process and 

strongly recommend that the proposals we've already offered be included for further pursuit. Our strongest contention 

remains that any GSG conservation problem must have economic solutions in order to work. A more effective route 

would be real, actual planning and conservation actions taking place on the basis of local collaboration for economic benefit 

and specific needs as opposed to top-down, one-size-fits-all planning that this proposed land use planning approach 

appears to be taking. We further contend that that the Bureau of Land Management has sufficient regulatory control

mechanisms to address healthy rangeland conditions and that piling up more regulations for the sake of having more 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1175

Scoping Summary Report

Table C-10.A

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regulations should satisfy the U.S. Fish and Wildlife without any improvement in actual on-the-ground management.

132. In addition, should ranchers find it economically unviable to remain ranching, private land will likely go on the market and 

quite possibly exit the agriculture sector. As urbanization has been the trend, It would be a shame for more prime 

agricultural land to go into housing development.

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133. Bottom line...because our livelihood depends on public land grazing we CARE about public lands. Because our livelihood 

depends on public land grazing we are very willing to work with efforts aimed at wildlife conservation, including that of the 

greater sage-grouse. Removing livestock from the public rangeland would be detrimental to wildlife, the general public, 

ranching, and the local economy.

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134. Every EIS and SEIS should be accompanied by a complete economic analysis and an analysis of the impacts of all proposed 

alternatives on other multiple uses so that unnecessary and unreasonable socio-economic impacts can be avoided. The 

socio-economic analysis should be guided by a recognized input-output quantitative model.

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135. It is imperative that a stable economic environment be sustained and enhanced so that our members may assist in the 

conservation of rangeland for the greater sage-grouse.

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136. However BLM must exercise caution that these measures are developed with prudence to ensure that protecting the Sage 

Grouse is not done by elimination of legitimate and economically viable land uses that are essential to sustain rural 

communities and provide quality high paying jobs

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137. Many of our long-term clients and prospective new clients have been or will be affected by the proposed project to amend 

land use plans to incorporate sage-grouse conservation measures. In fact, the conservation measures you propose will 

negatively impact most economic interests across the species entire range, increasing the regulatory cost and burden to 

conduct natural resource related activities, both commercial and recreational, and significantly impeding or virtually 

eliminating such activities, and will severely impact other businesses important to the western economy.

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138. Making the vast areas of the West able to produce income and thus able to provide an income to be good stewards is 

essential. Something needs to provide the income to pay for the projects and expertise.

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139. A methodology to translate the impacts into dollars, i.e. A mitigation investments; this must include sufficient funding to 

manage and monitor the mitigation investments. A. Seek to use an existing, transparent, consistent methodology for 

translating impacts into dollars from all resource projects. B. Commit to a science-based stakeholder-driven process to

identify, modify, and get buy-in on a specific methodology. C. The costs of management and monitoring of mitigation

investments are the responsibility of the project developer.

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140. We discovered that the US Fish and Wildlife Service’s own determinations show that the greater sage-grouse is not legally 

qualified for listing under the Endangered Species Act. Yet the BLM is now proposing, and implementing under their 

December 2011 Instruction Memorandums, unnecessary sage-grouse conservation measures that have and will negatively 

impact all economic activities across the species entire range, increasing the regulatory cost and burden to conduct natural 

resource related activities and significantly reducing or virtually eliminating such activities. If nothing else, comment on 

these two facts.

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141. We fimlly believe the continued preservation of Sage Grouse to be of prime importance to prevent its listing under the All Both emc0410GB
C. Comments by Resource Planning Issue

C-1176 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

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Endangered Species Act (ESA) but believe that this can be accomplished successfully without undue burdens that could 

inhibit the ability of recreation. grazing and industry to continue to operate on federal lands and to extract and or use our 

natural resources to the benefit of the American people and the continued economic viability of our citizens and local 

businesses.~

142. The continued exploration and production of OiL Gas and other resources is an important factor in keeping the social and 

economic infrastructure on our local area and of this country intact. But further, we firmly believe their partnerships with 

other entities in the private sector and with govermnent agencies are crucial to the success of this endeavor. The funding 

these companies have provided will assist in funding research and direct on-the-ground Sage Grouse habitat 

improvements. The research can increase better understanding of the bini's habits and traits in and around the areas that 

these projects are located. Cooperative actions such as just described will detinitely help to keep funds available which is 

very important to sustain longterm projects to increase the sustainability of sage grouse habitat.

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143. Even if this process results in lofty words on paper, there is a whole agency culture that must be changed. This culture 

enables all existing uses to continue at damaging levels and resources to continually be sacrificed to try to keep grazing, 

mining, and roading all other "multiple uses" heaped into sage-grouse habitats at the high levels. Part of the socioeconomic 

analysis has to consist of an honest critique of the agency’s own culture and how that culture hinders applying sound 

environmental protections. This includes agency culture that tends to try to perpetuate a bloated bureaucracy by 

conducting disturbance project after disturbance project. It must address the typical BLM ID "Teams" - where range 

staffers typically end up trumping biologists, ecologists and cultural specialists. The agencies must change internal 

processes to break their old industry enabling molds.

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144. Socioeconomic impacts: This must include analysis of resources being lost and alternative uses foregone by allowing 

damaging activities to continue. It must include an honest analysis of the cost to taxpayers of continuing chronic 

disturbance activities like livestock grazing. Typically, it costs 5-6 times the amount returned in grazing fees just to 

administer permits and deal with a little of the damage caused (Moskowitz and Romaniello 2002). The Moskowitz and 

Romaniello analysis does not include the value of spring water flows wasted, polluted, reduced, or lost forever due to 

erosion and degradation of chronic grazing disturbance - and thus sage-grouse brood habitat losses, the costs of herbicides 

applied to futilely try to stop weeds spread by grazing from choking understories vital for sage-grouse nesting, and 

innumerable harmful grazing "mitigation" actions from fences to re-seedings. It must also examine the fire rehab values 

destroyed as grazing resumes within two years or less of rehab and sufficient recovery of species has not occurred, and the 

must estimate the millions of dollars of seeding and fire recovery efforts lost to cheatgrass in grazed landscapes. An 

example of the drain on taxpayers is public lands ranching in the Humboldt-Toiyabe National Forest land of the Ely 

Westside EIS area. In a good year, the Forest might get $10,000 in grazing fees from the grazing Actual Use that occurs 

across 500,000 acres of Forest lands. Yet the money spent by the Forest on trying to monitor, build even more livestock 

facilities, spray weeds, and other actions - greatly exceeds the miniscule agency return on grazing fees which is scarcely 

enough to put gas in a pick-up to travel the long distances to try to monitor these allotments - let alone pay for equipment 

and year-round staff time and all the efforts to try to deal with weeds, meadow degradation and loss, Wilderness 

impairment, and other harms caused by grazing disturbance.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1177

Scoping Summary Report

Table C-10.A

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145. Potential permittee use of permits to get bank loans based on ungrazable AUMs must be addressed in the socioeconomic 

discussion. Part of the reason agencies refuse to cut AUMs appears to be bank loans that have been made on AUMs on 

permits that far exceed the capacity of the land to withstand grazing. Ranchers may get loans based on the number of 

livestock on the permit, not the number of livestock that have actually been able to be grazed. This is a concern, since 

public lands permits are used all the time as collateral for bank loans.

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146. Agencies will very likely claim various benefits to a small elite group of local ranching interests. But often, across areas like 

Nevada, gold mines and other revenue completely dwarf the very minor to miniscule revenue from grazing. In other areas, 

retirees and people who live in the West because of its open space and wildlife amenities dwarf ranching in economic 

effects.

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147. Exploitation of poor workers, including workers here on foreign visas must be examined as part of the human toll and 

human rights cost of continuing public lands sheep ranching and other livestock grazing across the sagebrush biome. See 

for example: http://www.capitalpress.com/print/djw-CNTRH2Asheep-021012 .

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148. The losses to the public of Wilderness and all recreational uses and enjoyment, including enjoying natural biological values 

like sage-grouse in a wild land setting, must be analyzed across all of a range of alternatives. A recent study 6/21/11 on the 

Department of Interior Economic contributions shows the minimal economic contribution of grazing.

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149. As part of any economic analysis, the full benefits of protection of sagebrush habitats without using the Core/sacrifice 

model and the derivative Priority habitat model that pushes impacts onto other habitats must be examined. Loss of birds 

and bats, for example, poses a threat to agriculture and may affect human health, too– as bats (and birds) eat insects that 

damage crops or that cause diseases like West Nile virus. Protection of these species helps to preserve a very important 

recreational use of public lands and of the West’s human residents enjoyment of their own home sites and local natural 

areas –i.e. enjoyment of birds.

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150. The BLM and USFS have anticipated sage grouse conservation efforts and highly restrictive conditions aiming at conserving 

sage grouse are already being written into mining permits. The current socio-economic impacts of sage grouse 

conservation efforts are much greater than anyone is acknowledging. I believe that many people are hesitant to 

acknowledge this because they fear retribution in the form of costly delays in permitting. It is difficult, if not impossible, to 

relax policies once they are in place, especially if those policies are included in land-use plans. The socio-economic impacts 

of these policies have not been studied. I request that an economic baseline study inclusive of all socio-economic impacts 

due to land-use restrictions for sage grouse conservation be completed and incorporated into the Final Environmental 

Impact Statement (FEIS). This should be a standard baseline study conducted by scientific experts in the field of economics.

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151. We are interested and concerned about the contractor who will be selected to perform the economic analysis. We 

request that the BLM ensure the contractor has a proven track record of providing balanced analysis of all the 

socia-economic Impacts related to sage grouse restrictions, valid existing lease rights and other multiple uses of public 

lands. In addition, we are concerned about the use of subjective, focus group or "willingness to pay" research by some 

socio-economic consultants to attempt to quantify the value of conservation by the general public. We do not believe 

these scenarios provide factual, socio-economic information to compare to actual socio-economlc data provided by 

stakeholders and local and state governments, such as tax revenues from all multiple users and employment figures based 

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on BLM's EIS alternatives to be analyzed for these RMP amendments.

152. ln addit ion to the standard comment below, I'd just like you to know that I am making the trip to Colorado this April 

specifically to see th is bird! Meaning, there is a financial incentive (tourism, local economies) for you to continue to protect 

this bird!!!

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153. I can tell you that This species is very popular with my clients and represents a real economic impact for me in addition to 

the recreational value to the millions (yes we are in the millions) of birders in the US and visitors from foreign countries

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154. The magnificant bird has historic significance as a food source for the native americans and those crossing the prairie in 

covered wagons

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155. Our family loves the western states and their bounty of natural areas that contain amazing wildlife like these birds. We 

travel every year out west and spend our money in these natural areas. Please consider that there is a revenue source that 

is generated by these natural areas, it is a clean, consistent source of capital that needs no loans or financing.

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156. My company Rekluse Motor Sports, makes automatic clutches for off-road motorcycles that are widely used on BLM lands. 

Availability of motorized recreation trails supports 40+ jobs in Boise and growing. More importantly, BLM motorized trails 

provide an amazing recreational opportunity that provide fulfillment to tens of thousands of users each year. When 

considering measures to save the Sage Grouse, please also consider motorized and mountain biking users. I hope my 

children have the same opportunities I’ve had to enjoy BLM lands.

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157. I strongly oppose components of the 2010 Conservation Measures that lack the flexibility to adapt to local management 

issues. The plan should recognize the importance of Off-Highway Vehicle (OHV) recreation to the local economy, the 

local and outside populations desire for OHV recreation, and the minimal impact that slow moving OHVs have on wildlife.

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158. Economically viable ranching operations provide both stewardship of public lands and economic vitality to local and 

regional communities. The continuation of livestock production on Oregon’s public lands is extremely important, not only 

for the sustainable production of food and fiber for the United States and worldwide markets, but also for the long-term 

success of sagegrouse conservation.

All Both fli0000gb

159. Finally, please complete a thorough socioeconomic analysis of implementing NTT report recommendations on 

landowners and local communities.

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160. While the impacts of other users, both positive and negative. ar€ peripheral to our operations, the costs of mitigation 

measure$ are of grcat doficern. Our ratepayers gfow weflry of bearing the vast majority of the cost of salmon and 

steelhead mitigation while sportslrlen and commercial fishirrg contribute very little to species recovery

All Both fxc0006GB

161. Every EIS and $EIS should be accompanied by a complete economic analysis and afl analysis af the impacts of ail proposed 

alternatives on other multiple uses so that unnecessary and unreasonable socio-ecortornic irnpacts carr be avoided. The 

socio-economic analysis should be guided by a recognized input-output quantitative model. Collaboration with local

universities could provide valuable insights into the ramifications of the alternatives under consideration.

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162. It is imperative that a stable economic environment be sustained and enhanced so that our mernbers may assist in the 

conserva.tion of rangeland for the greater $age-grouse. We appreciate the opportunity to comment on the development 

of EI$s and SEISs for management of the greater sage-grouse and itn habitat. We believe that we support a wide variety of 

All Both fxc0006GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1179

Scoping Summary Report

Table C-10.A

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users who may all assist in this conservation effort.

163. This plan is equal only to the plan for Spotted Owl, which ties up all of the federal timberland in the Western United States

forcing us to import building material from Canada to construct a home. This plan would cripple the livestock business and 

the mining and manufacturing industries in the west and make us, even more than we are now, totally dependent upon 

foreign third world countries to supply our basic needs.

All Both fxc0015GB

164. New money only can come from one place - The crust of the earth. If we are ever to make this nation the successful, rich 

nation that it once was, we will need responsible mining. manufacturing, and a well managed livestock business.

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165. My ranches produce about 800,000 pounds of beef every year. That is enough to feed every person in the State of Nevada 

for several days. To put an actual food producing operation in jepordy because of an unfounded environmentalist driven 

act would be unconscionable. Support any action on your part.

All Both fxc0017GB

166. Keeping ranches economically viable is crucial to the continued success of the Sage Grouse. All Both rmc0007RM

167. In addition to its economic significance, livestock grazing provides irreplaceable environmental and social values. These 

values contribute irreplaceable wildlife habitat, open spaces, ranchland buffers between federal lands and developments, 

scenic vistas, visual beauty, and the traditional image and heritage of the historic rural landscapes of Wyoming and the 

West. Losses of these essential environmental, historic, and social values of livestock grazing to users and visitors of the 

area and residents of impacted communities should be included in the scope of the EISs/SEISs.

All Both rmc0010RM

168. The BLM should conduct a cost/benefit analysis on both the environmental AND economic impacts of each alternative. All BLM rmc0021GB

169. MWGA's membership strongly recommends that BLM analyze and examine both the environmental impacts AND impacts 

to multiple-use activities of changed sage grouse management practices and plans; -This analysis must include an economic 

cost/benefit analysis for each alternative; - This analysis must address and account for potential negative financial impacts 

to grazing, energy development, and other multiple-uses of public lands, as well as the economic impact to businesses that 

support these uses; - Having participated in and reviewed numerous government environmental review documents, 

MWGA is aware that the socio-economic impact of federal wildlife management policies on local communities is rarely 

analyzed in detail; - As such, MWGA's membership requests strongly that the preliminary and final decisions on the EIS 

should be both timely and completely reported to cooperating agencies and to the public, and should be accompanied by 

a full, detailed, and complete economic cost/benefit analysis on the impact of federal sage grouse management policies and 

associated public land use restrictions.

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170. Conservation and management recommendations, such as the withdraw of activities in critical and/or general sage grouse 

habitats, will result in significant harm and irreversible hardship to numerous industries. The EIS should include an 

extensive and detailed socioeconomical study identifying direct, indirect, cumulative, and financial impacts to all individuals 

and industries affected by the proposed listing of the sage grouse. The EIS should identify the economic impact to 

individuals, industries, and State Governments. The EIS should identify what the personal cost is to individuals in the 

mining, oil and gas, and other industries should the sage grouse be listed and industries are halted from operation. The EIS 

should identify how many jobs would be lost and how many industry actions would be halted or reduced should the sage 

grouse be listed.

All Both rmc0027GB
C. Comments by Resource Planning Issue

C-1180 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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171. Mitigation of impacts to sage grouse habitat by a proposed project must be included if the government is serious about

considering the socioeconomic impacts of their actions. Creating new habitat or relocating habitat to where past habitat 

had been previously destroyed would appear to be a win-win scenario for both the sage grouse and those that utilize public 

lands. If the results of mitigation equate to no net decrease or even an increase in sage grouse habitat wouldn't that benefit 

both the bird and our society as a whole?

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172. Implementation of a statewide mitigation bank, for all entities to donate to, might be beneficial. Such a statewide bank 

might centralize funding so that more effective habitat restoration can be implemented (because it is implemented on a 

larger scale rather than piecemeal projects). All mitigation requirements, whether it is a statewide bank or individual 

mitigation, needs to be affordable by all entities using public lands (from the local rancher, large or small mining operator, 

exploration company, recreationist, renewable energy company, etc.).

All Both rmc0027GB

173. Each sub-regional EIS document should thoroughly evaluate a No Action Alternative to quantify the impacts associated 

with ongoing implementation of the many existing local, state, and federal conservation measures and the existing BLM and 

USFS policies to protect sage-grouse habitat. Specifically, the EIS documents should evaluate the following: Future Habitat 

Improvements: The future, long-term habitat improvements that could occur with ongoing implementation of the existing 

greater sage-grouse habitat conservation measures in Nevada and elsewhere. Future Economic Benefits: The economic 

benefits to state and local governments that would likely occur if the current Land Use Plans remain in effect allowing 

future mineral exploration and development, oil and gas exploration and development, rights-of-way ("ROW") 

development, grazing, and other multiple uses of public lands and national forests with sage grouse habitat rather than 

implementing the land use restrictions and prohibitions recommended in the December 20 11 NTT Report. The Greater 

Sage-Grouse is Not Listed in 2015: The impacts that would occur if the USFWS decides to maintain the "Warranted but 

Precluded" status because there are other higher priority species that need to be listed by 2015, or determines that listing 

the greater sagegrouse is not warranted because the existing conservation measures in Nevada and elsewhere are having 

sufficient success to make listing unnecessary. USFWS Lists the Sage-Grouse in 2015: The possibility that the USFWS will 

list the greater sage-grouse despite the conservation measures that BLM and USFS develop in conjunction with this EIS 

process.

All Both rmc0029RM, 

rmc0060GB

174. The EIS documents must quantify the adverse impacts to mineral exploration and development and to the availability of 

domestic minerals that would occur from implementing the recommendations in the NTT Report. The EIS documents 

must fully consider alternatives that would comply with FLPMA, MUSYA, and the U.S. Mining Law and thus eliminate

inconsistencies with these laws. The EIS documents must provide a detailed discussion of how the Proposed Action, 

Agency Preferred Alternative, and Alternatives Considered in Detail would allow mineral development or discourage -

and in the case of withdrawals from mineral entry - prohibit mineral development. This evaluation should measure the 

impacts on a state-by-state basis and on both a national scale.

All Both rmc0029RM, 

rmc0060GB

175. The agencies should consider not only the environmental consequences in the NEP A analysis but also the impacts to the 

human environment and economy, including grazing, mining, oil and gas and other multiple uses.

All Both rmc0032GB

176. The Organizations are very concerned that possible negative economic impacts from the Conservation measures simply

have not been addressed in the preparation of the proposal, which has allowed the proposal of numerous absolute 

All Both rmc0033GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1181

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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standards in the Conservation Measures. While the Conservation Measures are not technically proposing designation of 

critical habitat areas for the grouse, the measures are proposing a management structure that is very similar. Federal 

statutes and regulation require that BLM must always address economic impacts in all planning processes as follows: U(c) 

In the development and revision of land use plans, the Secretary shall- (2) use a systematic interdisciplinary approach to 

achieve integrated consideration of physical, biological, economic, and other sciences; ... " Under relevant statutes and 

guidelines for endangered species, the USFWS must address economic impacts when designating critical habitat for a listed 

species. These statutes provide: (2) The Secretary shall designate critical habitat, and make revisions thereto, under 

subsection (a)(3) of this section on the basis of the best scientific data available and after taking into consideration the 

economic impact, the impact on national security, and any other relevant impact, of specifying any particular area as critical 

habitat. The Secretary may exclude any area from critical habitat if he determines that the benefits of such exclusion 

outweigh the benefits of specifying such area as part of the critical habitat, unless he determines, based on the best 

scientific and commercial data available, that the failure to designate such area as critical habitat will result in the extinction 

of the species concerned. While these statutes do not provide any categories of management activity that may be

performed without economic impact analysis, the Conservation measures fail to provide for any flexibility to address 

disproportionate economic impacts from the absolute standards proposed for the management of roads and habitat areas. 

The Organizations believe these standards will result in numerous negative economic impacts that must be addressed 

under Federal statutes and regulations. The failure to address these impacts would be a violation of the above statutes and 

numerous other guidelines.

177. Is the economic loss to individuals, industries, local and state governments worth the federal listing of sage grouse? What 

is the economic threshold when a species should be listed? Should a species be federally listed if it results in undue harm, 

significant hardship, and economic devastation to multiple industries across multiple states? Is the listing of the species 

worth the detrimental long term loss to individuals and industry? These issues should be addressed and analyzed in the 

proposed EIS.

All Both rmc0035GB

178. Should the sage grouse become listed, or should restrictive conservation measures be placed on the species and its habitat, 

it will cause irreversible damage and significant economic loss across the western U.S. Listing of the sage grouse would 

personally affect me and significantly limit my ability to obtain employment in the State of Nevada. If industry is limited 

(either by the land where they can operate, hours of operation, or imposed with unreasonable or unaffordable mitigation), 

they will reduce operations within the state and they will not need professionals like me to assist them with environmental 

permitting. The full socioeconomic impacts of the decision to list (to individuals and industry), and the implementation of 

restrictive conservation measures to industry need to be fully analyzed and disclosed in the EIS (direct, indirect, and 

cumulative impacts). The decision to list (or not to list and manage in accordance to existing BLM IMs) the species needs 

to take all socioeconomic ramifications into consideration

All Both rmc0035GB

179. The EIS must examine the negative economic impacts to Renewable Energy in detail; such as publically subsidized tax 

breaks to developers; and loss to visual amenities (both day and nighttime) and viewscapes will have on regional tourism 

and recreation. For example, in Union and Baker counties there has been no significant increase in employment owing to 

the wind farm near Telocaset. There has been no significant rural development related to the Renewable Energy project, 

All Both rmc0036GB
C. Comments by Resource Planning Issue

C-1182 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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other than the wind farm and transmission lines.

180. The Economic analysis should estimate potential increased costs for fire suppression related to Juniper treatment areas. All Both rmc0036GB

181. What has been the actual cost ofthe SCS Juniper Management program in Oregon since 2002; and how many acres of 

Juniper have been treated on public and private land? What is the actual average cost/acre of the Juniper treatment in 

Oregon since 2002?

All Both rmc0036GB

182. Anticipating the complex interconnections between man, the environment and the potential economic impact that 

changes in land use plans could have on the county's economic base, the plan at AG19 includes, "The County advocates 

grazing policies on Federal and state lands which support the economic viability of related private livestock operations 

while maintaining the long-term productivity of rangeland ecosystems. Proposed changes in resource management policies 

regarding rangeland use need to consider and mitigate potential economic, social and cultural impacts to Lassen County 

citizens and communities, and impacts to related private lands in Lassen County."

All Both rmc0038GB

183. I am writing this as a concerned citizen regarding the debate over listing or even considering the sage grouse as threatened 

or endangered. Like the spotted owl case, a listing on the ESA would impact millions of residents, and hundreds of 

thousands of jobs directly and indirectly.

All Both rmc0047GB

184. Along with this, there is the personal impact on every family's cost of living, through higher energy prices, as well as higher 

expenditures on meat products as a result of reduced grazing opportunities.

All Both rmc0047GB

185. The Proposed Planning Strategy is largely silent on the economic impacts. In light of declining budgets and increasing 

national debt, careful consideration needs to be given to management strategies that can be implemented and not 

adversely impact agency budgets, national debt and local economies. Many local economies depend on access to public 

lands within the proposed planning areas as an economic engine. We recommend that a complete economic analysis of the 

management actions proposed be studies from the aspect of 1) What is the impact of the proposed activity on the agency 

budget; and 2) What is the impact of the proposed activity on the local communities.

All Both rmc0061GB, 

rmc0035RM

186. Economic viability of properly managed livestock grazing operations depends upon the integration of BLM, and often, 

Forest Service allotment lands. Otherwise, private grazing lands essential to sage-grouse will be more likely to be 

converted to other uses, usually to the detriment of sage-grouse.

All Both rmc0063GB

187. Range Management / Grazing Range Management or Grazing (domestic livestock and wild ungulate) is a very important 

component of Garfield County's traditional ranching heritage and wildlife herd management which requires working 

together with our public lands. In preparation of the EIS, Garfield County recommends the BLM work closely with the 

Cattleman's Association and the Wool Growers Association for both Colorado and other states which are also affected 

by the EIS to gain their valuable input into this process.

CO Both emc0058RM

188. Socio-economic Impact It is understood the National SGS Report is not intended to address the socio-economic impact

of the prohibitions/conservation measures it suggests such as the 4-mile NSO buffer and 3% disturbance limit. The County 

strongly recommends the BLM carefully consider the structure of the EIS such that it contains a section devoted to a 

credible analysis of current and likely future conditions in the region's energy extraction industry. More to the point, 

Garfield County challenges the apparent approach the BLM is taking in the GSGCM report to increase its regulatory 

CO BLM emc0058RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1183

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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No.

Comment SubRegion

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controls over the oil and gas industry and other development which will have the adverse effect of reducing employment 

and further eroding the County's economic base; to the contrary, Garfield County believes the BLM should be a leader in 

encouraging responsible multiple use and resource development opportunities to stimulate economic growth which is 

vital to our economy and that of northwest Colorado. This EIS should document and consider the dramatic economic 

changes that have transformed the region's economy in recent years. Garfield County has experienced a pronounced 

downturn in economic activity, which has significantly altered the economic relationships between activities on public 

lands and the local economy. These changes, evident now for more than three years, must be more accurately 

characterized and more reasonably considered in all of the proposed management alternatives that are to be presented in 

the EIS. In recent years, the economics of natural gas permitting, production and compliance have changed, dramatically 

leaving Garfield County producers competitively disadvantaged and very sensitive to cost of production changes. The EIS 

needs to include a contemporary and accurate socioeconomic analysis that acknowledges this industry reality.

189. Garfield County's concerns, more simply put, are that BLM's potential implementation of Conservation Measures from the 

GSGCM report are not warranted in Colorado, and such an approach would result in a virtual moratorium on energy 

development severely impacting the economy of the County and northwest Colorado, further exacerbating an already 

economically depressed and challenged area. NOTE: This comment includes Table 3: Impacts to Lease Sections in 

Garfield County

CO BLM emc0058RM

190. A very common concern from industry and private land owners in northwest Colorado is not the need or requirement to 

protect the environment, but is the repeated changes in regulatory guidance and unknown potential impacts from long, 

drawn-out environmental planning processes. Because of this, Garfield County has seen many operators and private 

markets/investors hold off or postpone projects and investments in capital and hiring of employees given the length of time 

and uncertainties given NEPA processes and almost inevitable litigation. Additionally, during our review of the greater 

sage-grouse issue for this scoping effort, we were quite surprised at the amount of literature and planning documents all 

recently completed for this species, and we again raise the concern over repetitive planning processes which introduce 

uncertainty to our constituents and industry. To briefly review the guidance documents which are all designed to provide 

a "management plan" for the public and industry to plan around, we have observed and reviewed the following: 1. A 

Report on National Greater Sage-Grouse Conservation Measures (BLM 2011) 2. Colorado greater sage-grouse 

conservation plan (CPW, 2008) 3. Conservation assessment of greater sage-grouse and sagebrush habitats (Western 

Association of Fish and Wildlife Agencies, 2004). 4. Conservation of Greater Sage-Grouse on Public Lands in the Western 

U.S. Implications of Recovery and Management Policies (Policy Analysis Center for Western Public Lands, 2002) 5. 

Greater sage-grouse comprehensive strategy (WAFWA, 2006) 6. Greater Sage-Grouse Conservation Plan: 

Parachute-Piceance-Roan (BLM, CPW and others 2008) 7. Greater Sage-Grouse: ecology and conservation of a landscape 

species and its habitats (2011) 8. Guidelines to manage sage-grouse populations and their habitats (Connelly et al. 2000) 9. 

National Sage-Grouse Habitat Conservation Strategy (BLM 2004) 10. US Fish and Wildlife Service 12 Month Findings for 

Petitions to List the Greater SageGrouse (2010) These reports are in addition to the volumes of scientific articles on 

sage-grouse ecology, indeed sage-grouse is likely one of the more studied species, and there is a large amount of scientific 

literature available. Garfield County contends that there are already existing and approved plans for greater sage-grouse 

CO Both emc0058RM
C. Comments by Resource Planning Issue

C-1184 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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within northwest Colorado, and having the public, industry and cooperating agencies enter into yet again another "planning 

effort" immediately on the heels of recently completed planning efforts is an undue burden on already taxed public 

resources, and will again provide another reason for industry and private enterprise to seek other areas for doing business.

191. Jackson County remains an agricultural county. Our custom and culture is based on the agricultural lifestyle. Grazing on 

the BLM is essential to maintain our agricultural community as well as the important products that we produce (e.g. hay 

and beef). We request that the BLM conduct a thorough socioeconomic analysis when considering any actions 

recommended in the NTT report that would prioritize sage-grouse over livestock grazing. Specifically, the study of this EIS 

should consider the social effect upon young men and/or women in Jackson County who wish to consider production 

agriculture as a career. When these young people look at the area affected by PPH in Jackson County, they may choose not 

to pursue a career in production agriculture. Currently 30% - 35% of the 60 students attending North Park High School 

are enrolled in Agriculture education classes. Of these 30% - 35%, many (20%) would choose to ranch if there was a way 

for them to enter the ranching business. The other 80% may enter agriculture support careers. Therefore, the BLM 

Sage-Grouse EIS should measure the effect on the potential future ranching population in Jackson County.

CO BLM emc0060RM

192. The NTT report does not adequately address lek viewing. Lek viewing is an important seasonal recreational use in North 

Park. The local NPSGWG North Park Conservation Plan does address this impact and recommends allowing lek viewing 

provided that lek viewers follow appropriate lek viewing etiquette. Lek viewers bring a substantial amount of money into 

Jackson County in April - a time when almost no other recreationists are coming to the county. If the BLM is not going to 

allow commercial permits for lek viewing, then we would request that this economic loss be included in the 

socioeconomic evaluation of the sage-grouse EIS. Please also include an analysis of removing the opportunity for wildlife 

viewing for a growing segment of the public.

CO BLM emc0060RM

193. Finally, and most importantly, Jackson County has an extremely small assessed value compared to neighboring counties in 

sage-grouse range in Colorado. The socioeconomic analysis in the Kremmling Field Office Draft Resource Management 

Plan acknowledges that small changes to BLM land use may have disproportionate economic impacts. Because of the small 

assessed value of community, negative impacts to the recreation, agriculture, oil & gas, and mineral industries which drive 

the local economy could be devastating. The NPSGWG requests that an extremely thorough socioeconomic analysis be 

conducted of the impacts from the NTT Recommendations on the economic viability of Jackson County.

CO BLM emc0060RM

194. Because of constantly improving technology utilized by the oil and gas companies, the language of 20 or 40 acre spacing is 

quickly becoming archaic. With directional drilling and dependent on depth and subsurface geology, producers can and do 

approach or exceed effective 20 acre spacing off of one pad in a section. It is not uncommon to see well pads with 24 

individual wells and even some with up to 32. Horizontal drilling and sequential fracing techniques are game changers, the 

impact of which we are just beginning to appreciate. Any discussion of restrictions of surface occupancy or development 

thresholds should include the new reality of being able to continue to extract the oil and gas resource from the areas being 

developed through new technology. This may take a portion of the economic sting out of NSO restrictions.

CO Both emc0061RM

195. We would ask that you remember that sage grouse habitat is also human habitat and that alternatives cannot be developed 

considering only the bird. While we understand the dire economic consequences of having the greater sage grouse 

becoming a listed species, we ask that the impacts on the people that live and work in our County be considered while 

CO Both emc0061RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1185

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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No.

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developing the alternatives in the EIS. Thank you for the opportunity to comment on this EIS scoping.

196. The proposed EIS and SEIS will cover a significant portion of Western Colorado’s counties; the center of which are Moffat 

and Jackson counties, there is major impact in Garfield, Rio Blanco, Grand and Routt Counties as well as a more limited 

impact in Mesa and Summit Counties. Ranching, natural resource development and tourism are major economic drivers 

for the communities and residents of these counties. For decades, these communities have worked with BLM to develop 

responsible RMP’s to protect the public lands in these areas while working with organizations to allow for reasonable 

economic growth and stimulation.

CO Both emc0068RM

197. Ranching has a long, rich history in the Northwestern Colorado. Ranches in Western Colorado rely on public land grazing 

leases for survival and to make a contribution to the nation’s food supply. Grazing and sage grouse habitat are inextricably 

related. Properly managed, grazing will enhance sage grouse habitat; indeed there is a direct correlation to reduction in 

grazing and reduction in the number of sage grouse.

CO Both emc0068RM

198. CLUB 20 believes that local, state, and range-wide plans should work in cooperation with existing land uses to manage sage 

grouse and sage grouse habitat. Due to interdependence between varying land uses, it is imperative that sage grouse 

management does not take an overriding role and is balanced with existing land uses. Successful grouse conservation is 

dependent upon the mutual well-being of the human communities that live in Western Colorado. Sage grouse 

conservation goals must sustain the social, cultural, and economic lives of the citizens of Western Colorado, as grouse and 

humans are mutually dependent upon the habitat.

CO Both emc0068RM

199. Socio-Economic Impacts Must Be Considered in Designing Alternatives - A cursory review of a Greater Sage-grouse 

Priority Map for Northwest Colorado indicates that a major portion of our region is included in either preliminary priority 

habitat or preliminary general habitat. Virtually all of Moffat County is included, as well as significant portions of Routt 

County that overlap known mineral resources that would support existing and future coal mining. This area's rural 

economy is based on coal mining, oil and gas production, agriculture, and seasonal hunting. These two counties, along with 

portions of Rio Blanco County, are responsible for over half of Colorado's coal production. If only three percent of high 

priority areas can be disturbed, it would appear that Moffat County in particular can have little or no expanded economic 

development to support its citizens, and current economic activity on the land may be threatened as well. This approach 

drives a draconian result; therefore alternatives presented in an EIS should be crafted with due regard for human 

inhabitants of habitat areas as well as the greater sage-grouse.

CO Both emc0071RM

200. In conclusion, Twentymile Coal, LLC urges a balanced approach in preparing an Environmental Impact Statement which 

presents a wide range of alternatives that recognize and give effect to not only conservation of the sage grouse, but allow 

for continued economic activity in Northwest Colorado. This region contains a high percentage of federal lands, but also 

is heavily dependent on the use of those lands for mining, oil and gas development, grazing, and recreation to sustain the 

population that lives in the area. We appreciate the opportunity to comment on this proposal, and urge your careful and 

thoughtful consideration of the considerations outlined in this letter as you move forward.

CO Both emc0071RM

201. Moffat County encourages a thorough analysis, including multiplier effects, that specifically quantify dollar estimates of the 

impacts of alternatives being considered in this EIS. While the development of traditional federal agency planning 

CO BLM emc0076RM
C. Comments by Resource Planning Issue

C-1186 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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documents is very limited on the social and economic analysis, especially when it comes to quantifying dollar estimates of 

impacts, the Little Snake Resource Management Plan is significantly better than traditional documents. It specifically 

identifies dollar figures associated with impacts of each alternative in the RMP. Furthermore, it categorizes dollar impacts 

regarding each sector of land use. This is a result of tremendous local involvement and hiring Colorado State University to 

conduct the social economic impact of alternatives in the Little Snake Resource Management Plan. Moffat County uses this 

example to encourage BLM in the development of the Sage-grouse EIS to not fall into traditional federal agency social 

economic analysis methods where merely general impacts are described in words, with little analysis occurring regarding 

specific dollar impacts. Moffat County requests BLM place realistic dollar figures, including dollar figures of multiplier 

effects and tax base, by the restriction of energy development and removal of grazing privileges if the Technical Report 

were implemented, in addition to all other alternatives considered in the EIS.

202. First of all, I think that an economic impact study has to be done on any proposal that would affect Jackson County. 

Negative impacts on agriculture, oil and gas and recreation that drive the local economy could be devastating to Jackson 

County

CO Both emc0077RM

203. Colorado's mining industry, according to a study by independent accounting and auditing firm PriceWaterhouscCoopers, 

was responsible for 9,000 direct jobs and supported 48.000 jobs overall. Mining accounted for over $6 billion in direct 

contributions to Colorado's gross domestic product. Labor income of $3.2 billion. And tax contributions of more than 

$1.5 billion. In 2008. Most of these jobs arc located in Western Colorado and will be directly and adversely impacted; thus 

great care must be given in structuring a conservation plan.

CO Both emc0143RM

204. A cursory review of a Greater Sage-grouse Priority Map for Nmthwest Colorado indicates that a major portion of that 

area includes either preliminary priority habitat or preliminary general habitat. Virtually all of Moffat County is included as 

well as portions of Routt County critical for existing and future coal mining. This rural economy is based on coal mining. 

Oil and gas production. Agriculture. And seasonal hunting. These two counties. Along with portions of Rio Blanco County, 

are responsible for over half of Colorado's coal production. Lf only 3% of high priority areas can be disturbed, it would 

appear that Moffat County in particular can have little or no expanded economic development to support its citizens, and 

current economic activity on the land may be threatened as well. We have similar concerns for affected lands in Garfield 

County. This approach drives a draconian result; therefore alternatives presented in an EIS should be crafted with due 

regard for human inhabitants of habitat areas as well as the greater sage-grouse.

CO Both emc0143RM

205. In conclusion, the Colorado Mining Association urges a balanced approach in preparing an Environmental Impact 

Statement which presents a wide range of alternatives that recognize and give effect to not only conservation of the sage 

grouse, but allows for continued economic activity in Northwest Colorado. This region contains a high percentage of 

federal lands, but also is heavily dependent on the use of those lands for mining, oil and gas development, grazing, and 

recreation to sustain the population that lives in the area.

CO Both emc0143RM

206. Local social and economic impacts must be analyzed for Northwest Colorado. The Little Snake RMP includes an in-depth 

analysis of these impacts in cooperation with Colorado State University. The Districts respectfully request that this EIS 

utilize the Little Snake RMP data and analysis rather than do the minimal analysis that is typically conducted within an EIS.

We also strongly encourage this type of data collection and analysis to be conducted for the remainder of the Northwest 

CO Both emc0178RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1187

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

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Colorado within the EIS.

207. Natural areas that are habitat for sage-grouse also support some our state’s largest and most prized big game herds, and 

more than 350 other kinds of animals and plants. Protecting these areas will help conserve Colorado’s wildlife, including 

deer, antelope, and songbirds. I enjoy the outdoor recreation opportunities that these natural areas provide. I also feel that 

conserving these natural wildlife areas is important to the success of wildlife related recreation and tourism, which 

provides good jobs and is important to our economy.

CO BLM fll0000RM

208. The BLM should put mandatory standards in place to safeguard sage-grouse. Because inappropriately located oil and gas 

development has been formally recognized by U.S. Fish & Wildlife Service as being a major threat to sage-grouse in 

Colorado (and throughout the eastern range), the Resource Management Plans cannot rely on voluntary standards to 

minimize the negative impacts of oil and gas drilling. BLM should require companies to act responsibly to protect greater 

sage-grouse. I respectfully ask that the BLM put important safeguards in place in its long-term management plans, to save 

the sage-grouse and conserve our land, water and wildlife for future generations to enjoy. Thanks for your consideration.

CO Both flm0000RM

209. Southern Routt County and much of northern Eagle County remains an agricultural landscape. Ranchers provide much of 

the private land habitat for sage-grouse. The majority of the Southern Routt portion of the NESR sage-grouse population 

area is private land. The NESRWG requests that the BLM EIS analyze the potential negative impacts of making it more 

difficult for ranchers to make a living. Located between the Vail Valley and Steamboat Springs, the Northern 

Eagle/Southern Routt area is under pressure for increasing housing development. If ranchers are no longer able to make a 

living, more of them will sell their land and some it will likely be subdivided for housing development.

CO Both fxc0003RM

210. Oil and gas operators in the Piceance Basin, including Oxy, as well as the economic viability and livelihood of employees, 

contractors, and communities in the area could be significantly impacted by the action proposed by BLM

CO BLM rmc0021RM

211. Finally, the VRLP urges BLM and the Forest Service to proceed with caution in implementing the prescriptions for sage 

grouse management found in the 2011 Technical Team Report. The majority of these conservation measures lack 

supporting data and many will cause harm to rangeland resources and destroy local communities and their economies.

BLM is on the verge of making the same errors that occurred with the Northern Spotted Owl. The listing decision and 

subsequent designation of critical habitat for the spotted owl destroyed the logging and sawmill industries for three states 

based on the premise that logging of old growth timber was causing the decline of spotted owl populations. Comments 

submitted in 1989 on the listing decision suggested that predation by the barred owl was causing undetermined levels of 

mortality but this was brushed aside. Twenty years later, much of the designated critical habitat has burned, taking the old

growth habitat and the owls with it. Notwithstanding no logging for 20 years, the spotted owl status is unchanged. Now 

DOI proposes to shoot barred owls given the rates of predation on the remaining spotted owls, 77 Fed. Reg. 14036 (Mar. 

9, 2012), while doubling the critical habitat that will be closed to logging, 77 Fed. Reg. 14062 (Mar. 8, 2012); c.f. 77 Fed. Reg. 

12985 (Presidential memorandum directing USFWS to consider economic impacts, including some logging in the 

expanded critical habitat). The sage grouse debate is also similar to the spotted owl in that just as the owl was a pretext to 

stop logging, the sage grouse is a pretext to stop energy and mineral development and livestock grazing. Sound data and 

objective analysis would have avoided a listing of the spotted owl then and should preclude a listing of the sage grouse now. 

The spotted owl experience provides a profound lesson on the severe consequences that a listing decision can have on a 

East Both emc0155rm
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region. When it is done with incomplete data, the outcome is no better for the species despite the generation-changing 

human and social costs. BLM has one chance to avoid a similar debacle but it must return to scientific principles that 

require objective evaluation of a sound data.

212. We would ask that the BLM thoroughly evaluate the socio ‐will result from economic and periph 

additional habitat conservation measures and restrictions imposed on uses and users of the BLM lands in the Western 

Region. These include, but are not limited to recreation, mining, logging, livestock, infrastructure developments etc. It is 

our belief that GSG numbers are currently well above levels that would further habitat restrictions and that those numbers 

will never fall to a truly biologically unsustainable number in the foreseeable future.

GB Both emc0384GB

213. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined 

use of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations.

GB Both flj0001gb

214. All decisions should be directly addressed by the lead agency and based on independently verified data. Every EIS and SEIS 

should be accompanied by a complete economic analysis and an analysis of the impacts of all proposed alternatives on 

other multiple uses so that unnecessary and umeasonable socio-economic impacts can be avoided. The socio-economic 

analysis should be guided by a recognized input-output quantitative model. Collaboration with local universities could 

provide valuable insights into the ramifications of the alternatives under consideration. Alternatives which are the least 

restrictive to multiple-use activities should be give top priority.

GB Both rmc0056GB

215. As you consider grazing allotments please keep in mind the agriculture based economy in the Magic Valley and the possible 

negative impact that the reduction of grazing rights will have on the base economy in Twin Falls County.

IDMT Both cfc0021GB

216. My livelihood, as well as many other family ranching businesses across the Western United States, depends on the ability 

to graze livestock on public and private lands. As such, it is in ranchers' best interest that the lands are managed to 

optimum condition, which is both ecologically and economically beneficial. I am concerned that the pending effort to 

significantly amend the land use plans will create unnecessary restrictions on ranchers' ability to graze livestock and will 

result in unintended consequences that will be more harmful than helpful to sage

IDMT Both flh0000GB

217. It is imperative that a stable economic environment be sustained and enhanced so that ranchers and other stakeholders 

may continue to assist in the conservation of rangeland for the greater sage ‐grouse

IDMT Both flh0000GB

218. Livestock grazing is compatible and beneficial to greater sage-grouse habitat conservation. This has been proven by 

independent, peer-reviewed scientific analysis, much of which was conducted in our own state. Ranchers are the stewards 

of the greater sage-grouse habitat on both the private and public range lands. Allowing ranchers the continued use of 

public lands without unnecessary restrictions due to the potential listing of a species with such a large habitat encourages 

stewardship and prevents fragmentation through development. It is imperative that a stable economic environment be 

sustained and enhanced so that our members may assist in the conservation of rangeland for the greater sage-grouse.

MT-RM Both emc0157RM

219. It should also be constantly reiterated, that Montana and Wyoming have, what are considered to be, sustainable sage 

grouse populations. BLM and the state agencies need to keep this at the forefront, when deboerating this issue. It is 

imperative, that you avoid hurting our livestock operations. These ranches are extremely important to the local economy, 

and are a good, safe source of food for our nation. It is also worth noting that this food source is grown from an 

MT-RM Both rmc0012RM, 

rmc0022RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1189

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ecologically healthy, renewable resource.

220. Our county has formally agreed to be a cooperating agency with BLM, regarding the sage grouse issue. We appreciate the 

opportunity to provide input specific to this important issue. Judith Basin County has a strong agricultural economy, with 

over $31 million generated from livestock and livestock products, and it very important to this community that the agency 

works directly with the local landowners to ensure both sage grouse and family ranchers are sustainable.

MT-RM Both rmc0023RM

221. Moreover, I believe that the economic benefits to our State, Nevada, from mining development, energy development, 

expanded cattle ranching, farming and so on in areas where habitat designations have been made are primary as they 

provide subsistence benefits to the human species over any consideration for.preservation of "so called" sage grouse 

habitat.

NVCA Both emc0023GB

222. Churchill County Board of County Commissioners passed a resolution in December 2011, adopting the "Policy Plan for 

Public Lands" (Plan) of the Churchill County Master Plan. The Plan is a guide, developed by the citizens and local 

government regarding the use of public lands in Churchill County. The Plan addresses federal land use management issues 

and is intended to be used as a positive guide for federal land management agencies in their development and

implementation of federal land plans and management actions. The Plan outlines expectations and desires of the people of 

Churchill County and requires consultation prior to decisions that affect public lands within the County's boundaries. 

Churchill County is desirous of cooperation from the Bureau of Land Management and other federal agencies. If the U.S. 

government (under any agency) intends to change uses or availability of resources on public lands in a way that will impact 

current historical and cultural uses, input from the citizens of the County is required and the Board of County 

Commissioners will be consulted. The multi-use nature of public lands requires that management decisions be made with 

the public's interest at the forefront and careful consideration to maintaining a sustainable economy and sustainable 

resources for future generations.

NVCA Both emc0151

223. I am extremely concerned about the impact the above referenced Notice of Intent will have on the range livestock 

industry in Nevada. Economically viable ranching operations provide both stewardship of public lands and economic 

stimulus and viability to local and regional communities.

NVCA Both emc0202GB

224. Restricting oil and gas leasing on public lands (BLM lands) for sage grouse habitat (or even “potential” habitat areas has 

already cost the state of Nevada over $1,000,000. if this policy continues, it will not only result in lost revenue to the state 

of Nevada but will adversely impact my profession (and all other geologists) working in the state of Nevada.

NVCA Both emc0245GB

225. Considering that Sage Grouse are not at risk in the state of Nevada, has the BLM contemplated any impact of potential 

lawsuits relevant to loss of income from the State of Nevada or other professionals (geologists) as a result of the BLM 

restricting leasing and or exploration under false assumptions that leasing (or exploration) adversely impacts the Sage 

Grouse population in Nevada.

NVCA Both emc0245GB

226. The rare minerals that occur on these lands are a valuable national asset. Exploration for these minerals is one of many 

valid multiple uses that is an important part of the economy of Nevada and its rural areas. The loss of large areas of 

prospective land due to the proposed Sage-grouse Conservation Measures would drastically reduce long-term

exploration and mining activity in Nevada. The consequence of this reduction would be the significant impoverishment of 

NVCA Both emc0272GB
C. Comments by Resource Planning Issue

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rural communities and certain business sectors of Reno and Las Vegas that presently enjoy a robust business climate 

yielding hundreds of millions of dollars in taxable revenue to the state and counties of Nevada. The value of these 

resources must be weighed very carefully against an accurate assessment of the sage-grouse habitat and population trends.

227. Ranching, mining, hunting and recreation are a huge part of Nevada's economy. Listing the sage grouse would cause a great 

hardship on Nevada and all of the western United States' already suffering economy.

NVCA Both emc0273GB

228. In particular, Barrick is concerned that some of the policiesincluding locatable minerals withdrawals and disturbance 

prohibitions in priority habitat-could result in unnecessary lost jobs, wages and tax revenues in Nevada, a state that is 

already under severe economic distress.

NVCA Both emc0277GB

229. vii. Socioeconomic impacts Precious metals are a non-renewable resource; therefore sustain ability of the direct and 

indirect mining workforce is dependent on the continued expansion of mines and the exploration and development of new 

deposits. Mineral resources are only located where specific geologic conditions and events occurred; they are site-specific. 

Consequently, mineral deposits that occur in sage-grouse habitat must be developed in sage-grouse habitat. Moving to 

non-habitat is not an option. Thus, it is no overstatement to say that overly restrictive sage-grouse protections that 

preclude mineral development would be devastating to mining workers, local communities, and the State of Nevada. The 

mining industry is a significant component of Nevada's economy as a whole and the economic foundation of many 

communities in rural Nevada. Nevada accounts for nearly 80% of gold production in the United States and gold represents 

nearly 90% of the value of the total output of the mineral industry in Nevada. Barrick produces approximately 60% of all 

the gold produced in Nevada, with 2011 production of over three million ounces valued at $3.8 billion dollars. In addition 

to investing over $3.6 billion dollars in building the infrastructure associated with these world class mining operations, 

Barrick spent over $41 million dollars in 2011 to explore for additional mineral resources in Nevada and will continue to 

invest at this level in future years. The mining industry has been the only bright spot in a state economy which has 

declined dramatically due to the economic downturn. No other sector of the economy has increased its contribution to 

state services, education and local governments more than the mining industry in the last four years-in fact nearly all other 

major sectors' contributions have declined.32 Barrick's mining operations in Nevada provide the largest percentage of the 

mining sector's contributions to Nevada in these areas. In 2011 Barrick employed over 3,950 Nevadans directly and is 

estimated to have generated over 20,600 jobs in businesses in Nevada which supply goods and services to support its 

mining and mineral exploration activities.33 Jobs in the mining industry are on average the highest paid in the state. 

Barrick's purchases of goods and services in the state of Nevada amounted to over $900 million in 2010. Direct taxes paid 

by Barrick, which included the Net Proceeds of Mines Tax, Sales and Use Tax, Property Tax, and Modified Business Tax, 

amounted to $194 million in 2011. Approximately 40% of these tax payments stay with local government and fund city and 

county operations, local education expenditures, and other important public services. In a number of cases, this tax 

revenue is the most significant revenue received by local governments near Barrick's mine sites. Mining is vital to the 

economy of northern Nevada. For example, the population of Elko, Nevada increased, primarily from mining related 

activity, from approximately 5,500 in 1980 to approximately 18,000 at the 2010 census. Without expansion and new 

discoveries on public lands, which comprise nearly 85% of the state of Nevada, the mining jobs that support Elko and 

surrounding areas cannot be sustained. Furthermore, the impacts of lost mining and mine support jobs would then spread 

NVCA Both emc0277GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1191

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to the public sector (including law enforcement, fire fighters, teachers, and regulatory jobs), medical, retail, wholesale, real 

estate, and other sectors of the local economy. Although mining has historically been a cyclical industry, downturns are 

typically related to lack of economic mineral resources or the means to acquire and process the minerals, not regulatory 

restrictions on mineral entry opportunities. It is therefore absolutely critical that the agencies act cautiously before 

creating a "bust" when mineral availability and processing technology are sufficient to carry the mining boom for many 

more years. It is also critical that the EIS process fairly consider these potentially devastating economic impacts.

230. The Soils in this Geothermal Area are not Suitable for Plant Growth: The Hog Ranch deposit was formed by a very shallow 

hydrothermal system (i.e., a hot spring) that produced soils and rock types that are not favorable environments for plant 

growth. Consequently, there are many areas of very sparse vegetation probably due to naturally occurring toxic minerals 

related to hot springs fumaroles and general degassing of the hot-springs level geothermal system that deposited the gold 

at Hog Ranch.

NVCA Both emc0287GB

231. Economically viable ranching operations provide both stewardship of public lands and economic stimulus and viability to 

local and regional communities. The conservation of rangelands for livestock production is extremely important, not onlj' 

to the sustainable production offood and fiber for the United States and worldwide market.

NVCA Both emc0304GB

232. I am writing in regard to the withdrawals of Public Lands to implement the 2011 Greater Sage-Grouse Conservation Plan. 

I have great concern for myself and my fellow workers here in Nevada. Sir, we need jobs.

NVCA Both emc0320GB

233. To shut down the natural raw industries, whether it be mining, subsurface extraction of either oil & gas or geothermal, 

surface use of ranching and farming, seems to me that you are cutting future revenue for your own existence as an agency 

to manage the Public Lands as well as that of the State of Nevada, along with the other Western States for generations to 

come.

NVCA Both emc0320GB

234. Scoping Issue No.5 The EIS Documents Must Evaluate Ways to Minimize Risks to Mining Claims Owners who Have Made 

Significant Investments on their Claims Prohibiting mineral exploration and development on the lands shown in magenta 

on the BLM - USFS habitat map would result in significant economic hann to the State of Nevada and the many companies, 

including NVMRA members, whose mineral projects are located in priority habitat areas. Field studies to determine the 

actual presence of sage-grouse habitat and the potential for mineral resources in these areas are the only way to identify 

and quantify the scope of the resource conflicts that would result from withdrawing these lands from mineral entry. The 

EIS document for Nevada must discuss and quantify the adverse effect on companies, rural mining communities, and the 

economy of Nevada of the proposed mineral withdrawals. The EIS document must also present alternatives that minimize 

these impacts and assess the cumulative impacts associated with landscape-scale land use restrictions and mineral 

withdrawals.

NVCA Both emc0327GB

235. Given this risk, the EIS documents must quantify how the proposed withdrawals would interfere with the investments that 

NVMRA members and other similarly-situated companies have projects on lands that may be withdrawn, and evaluate 

ways to minimize jeopardizing investment-backed expectations of claim owners on lands proposed for withdrawal. This 

analysis should also disclose and quantify the potential impact to U.S. taxpayers from the regulatory takings claims that 

could arise in response to implementing the land use restrictions and withdrawals recommended in the NTT Report at 

projects where these measures will interfere with substantial investments.

NVCA Both emc0327GB
C. Comments by Resource Planning Issue

C-1192 Greater Sage-Grouse LUPAs/EISs May 2012

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236. Secondly, the grass-roots exploration conducted by NVMRA member companies and other Nevada exploration 

companies in areas that have significant mineral potential as well as sage-grouse habitat is critical to the future of mining in 

Nevada. Mineral exploration represents the entrepreneurial, Research & Development (R&D) arm of mining. Mineral 

exploration today discovers tomorrow's mines. Thus, the mineral deposits that are being explored throughout Nevada -

including deposits that are within the gold trends and sage-grouse habitat areas shown on the attached map - are essential 

to creating and maintaining a robust pipeline of projects that can become future projects that create high-paying jobs, 

generate revenue for state and local governments, and help meet the Nation's needs for domestic minerals. NVMRA 

member companies, other small mineral exploration companies and individuals conduct much of this exploration work.

NVCA Both emc0327GB

237. Withdrawing all or some of the lands where Nevada's mineral deposits and gold trends are located from mineral entry will 

have a devastating effect on Nevada's mining future. Withdrawing these lands from mineral entry would put some of the 

best mineral exploration terrain in the world off-limits to exploration and development. This will dramatically diminish the 

odds of making discoveries of valuable mineral deposits that can ultimately become a mine. This will stifle job creation and 

impede Nevada's economic recovery. Increasing the Nation's reliance on foreign sources of minerals also threatens our 

national security.

NVCA Both emc0327GB

238. The EIS documents must attempt to quantify the socioeconomic impacts of the lost discovery opportunities that would 

result from withdrawing lands with known world-class mineral deposits in highly prospective gold trends in areas where 

geologists continue to explore for and find new deposits. This analysis should compare and contrast the impacts associated 

with the No Action Alternative, the Proposed Action, the Agency Preferred Alternative, and Alternatives Considered in 

Detail. The NVMRA strongly encourages BLM and USFS to select an Agency Preferred Alternative that does not ruin 

Nevada's mineral economy by placing a significant portion of Nevada's mineralized lands off-limits to exploration and 

development.

NVCA Both emc0327GB

239. Much of Nevada has struggled for the last several years to meet the challenges of the prolonged economic downturn and 

record unemployment rates. However, in rural mining counties, mining has kept unemployment well below the 

double-digit rates that have plagued the rest of the state. The State cannot afford to lose mining as the principal economic 

engine in these rural mining counties where sage-grouse habitat is also located.

NVCA Both emc0327GB

240. The health and safety of the greater sage-grouse population is an issue that gravely concerns the agriculture industry. As 

agriculture is the longest standing and third largest industry in Nevada, we in the industry feel that an in-depth analysis of 

the social economic impacts not only to rural communities but to the State of Nevada as a whole needs to be completed 

alongside the NEPA analysis of the environmental impacts. The livestock industry of Nevada works hard to create 

environmentally stable as well as economically viable operations and one such contributing component is the ability to 

graze on private and public land. The Association strongly urges the deciding entities, the federal agencies, to consider a 

conservation strategy that feasibly allows ranching operations to continue to be economically stable. Being that the Bureau 

of Land Management (BLM) is comprised of specialists relating to each natural resource field, we encourage the BLM to 

seek further assistance in assessing the social economic impacts to Nevada, from specialists in business and economics’ 

fields. As clarified in the Endangered Species Act (ESA), "The 1978 amendments oblige the Secretary to consider the 

economic impact of designating critical habitat" and the Association requests that this part of the assessment be 

NVCA Both emc0328GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1193

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thoroughly reviewed. Also stated in 76 FR 77008-77011, "the BLM and FS will address socioeconomic impacts of the 

alternatives," we strongly support this statement and urge these agencies to explore all methods of analysis. As the BLM 

is a multiple use agency and the Association strongly supports this method of management, we suggest this analysis of the 

social economic impacts should include not only the agriculture and livestock industries but also, mining, oil and gas 

developments, and other multiple-use industries. The stability of the State of Nevada’s economy should be just as 

important of a component in the conservation strategy as the environmental analysis. The Association also believes that 

coordination with local and state governments is imperative for this effort alongside state and federal agencies. 76 FR 

77008-77011 states, "The BLM and FS will coordinate and communicate with State, local and tribal governments to ensure 

that the BLM and FS consider provisions of pertinent plans, seek to resolve inconsistencies between State, local and tribal 

plans, and provide ample opportunities for State, local and tribal governments to comment on the development of 

amendments or revisions." The Association strongly encourages the federal agencies to coordinate and communicate with 

said governments throughout the development of the amendments or revisions to the federal land use plans and ensure 

that these plans are consistent with existing land use plans of local governments.

241. A balanced approach to public land management is especially important to states like Nevada with valuable mineral 

resources and to companies like Eureka Moly that have made substantial investments in developing valuable mineral 

deposits. Because the location of mineral resources is determined by geology; mineral deposits can only be developed 

where they are found. Consequently, the withdrawal of mineral areas with high-priority sage-grouse habitat would result 

in significant economic harm to the State of Nevada and any company whose mineral deposit is located in a high-priority 

habitat area.

NVCA Both emc0335GB

242. I am a livestock producer based in the state of Nevada. Livestock grazing is a legal and valid use of public rangelands and is 

a vital component of my livelihood.

NVCA Both flj0000GB

243. Our ranching operation is highly dependent on the combined use of private and public lands. Regulatory actions that 

restrict use of public rangelands will negatively impact private land productivity and diversity as well as the economic 

viability of our ranching operation.

NVCA Both rmc0065GB

244. SNWA respectfully requests that the EIS consider and discuss the following: fully evaluate the economic impact of 

additional or revised sage grouse measures on grazing, power, and the water industry.

NVCA Both rmc0069GB

245. ODOT is concemed that the social-economic issues may not be adequately considered when this land management plan 

and guidance is developed, and for how this plan is then subsequently implement by the Districts for federal lands in 

Oregon. With all of the competing interest and the obvious focus for the long term stability of the greater sage-grouse 

numbers and desired increase in suitable or rehabilitated habitat, it would be very easy to develop a plan that is out of 

balance between the variety of beneficial land use categories by discounting the importance of the social-economic issues.

OR Both emc0155GB

246. Grazing is essential to the economic sustainability of OSGA members and the communities of which they are a part. The 

benefits that grazing provides to the economy include not only direct economic impacts, but also the economic multiplier 

effects that result from livestock production. As the agency proceeds to study this issue and consider the potential 

economic impacts of various regulatory actions, OSGA encourages the agency to take into account the adverse effect that 

certain regulatory actions may have on the economic multiplier effect that results from grazing dependent livestock 

OR Both emc0309GB
C. Comments by Resource Planning Issue

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production.

247. In summary, the best available scientific evidence shows that public grazing is important for sage-grouse conservation. In 

addition, public grazing maintains the economic sustainability of livestock producers and provides substantial economic 

benefits to the communities in which they live and the economy of Oregon as a whole. In turn, by maintaining the 

economic sustainability of livestock producers, public grazing protects sage-grouse habitat by reducing the need for 

ranchers to sell or develop their private property in a manner that is detrimental to sage-grouse habitat.

OR Both emc0309GB

248. On behalfofthe Oregon Cattlemen's Association's Public Lands Committee, we are extremely concerned that the 

proposed amendments to incorporate measures for sage-grouse conservation into land use plans could have a damaging 

impact on rural communities, businesses, families, the environment in Oregon.

OR Both emc0315GB

249. Economically viable ranching operations provide both stewardship of public lands and economic vitality to local and 

regional communities. The continuation of livestock production on Oregon's public lands is extremely important, not only 

for the sustainable production of food and fiber for the United States and worldwide markets, but also for the long-term 

success of sage-grouse conservation.

OR Both emc0315GB

250. The ODFW EIS needs to identify and analyze all potential socio-economic impacts related to Private Industries and Public 

Works projects which now require permits that are developed in consultations with the ODFW through the 

Environmental Assessment (EA) or EIS processes. Examples include the Mining Industry and large scale public works and 

improvements that rely on Federal Mineral and Rock materials for completion (ie. Development of New Irrigation Canals 

or Water Improvements).

OR Both rmc0036GB

251. The socio-economic Profile provided in the ODFW EIS is wholly inadequate to provide any basis for comprehensive 

analysis of potential effects of this Mitigation Plan. As a consequence, any analysis and conclusions drawn from it in its 

current form will be misleading.

OR Both rmc0036GB

252. 1. Major Economic activities within the "Region of Sage Grouse Strategy", in addition to the three activities already stated 

in the EIS; must include Mining and Recreation. Recreation in the form of Hunting, Fishing, and Wildlife Viewing are 

touched upon, but must be expanded to include all other types of recreation that people participate in throughout the 

year.

OR Both rmc0036GB

253. The EIS list of Socio-economic Factors should be expanded to include: - Ranching - Recreation - Mining - Renewable 

Energy

OR Both rmc0036GB

254. 2. The EIS should examine employment statistics available on-line at the Oregon Department of Revenue and Employment 

jDivision to expand the scope of analysis to potential effects of this Mitigation Plan on employment in in these four sectors 

in the 8 county region of eastern Oregon.

OR Both rmc0036GB

255. The EIS analysis should examine potential impacts of mine permitting and Seasonal Closures on the Recreation industry; 

both in relation to the regional economy and long term employment.

OR Both rmc0036GB

256. The ODFW EIS needs to identify and analyze all potential socio-economic impacts related to Private Industries and Public 

Works projects which now require permits that are developed in consultations with the ODFW through the 

Environmental Assessment (EA) or EIS processes. Examples include the Mining Industry and large scale public works and 

OR Both rmc0036GB
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improvements that rely on Federal Mineral and Rock materials for completion (ie. Development of New Irrigation Canals 

or Water Improvements).

257. The presentation of Ranching, on page 202 and 3 is difficult to read and crams too much information together in a large 

run-on paragraph. The EIS should present all data in a clear and understandable manner. This section needs revision for 

clarity.

OR Both rmc0036GB

258. The estimate of value of travel generated and local recreation expenditures by Dean Bunyan and Associates in Table 1 

mayor may not include all types of recreation. But it does show in part the value of the regional recreation industry.

OR Both rmc0036GB

259. In the Renewable Energy Section ofAppendix VI, the EIS cites a Northwest Economic Associates, 2003 study of wind farms 

economic impacts. More current information is available on the negative impacts from the northeast Oregon wind farms 

in Baker Co.

OR Both rmc0036GB

260. The Calico Grassy Mountain Project will be a small underground mine. It will create up to 150 badly needed jobs during 

construction, and possibly as many as 100 permanent full-time jobs during operations. These are high-paying, year-round 

positions which will be comparable in pay to similar jobs in nearby Nevada (Dobra, 2011), which average nearly 

$85,OOO/year. We believe that conservation measures guided by an implementation strategy involving land owners, 

other land developers and local land managers is the appropriate approach to guiding future responsible land management 

policy and regulation in the western U.S. This should be the "guiding light" going forward.

OR Both rmc0074GB

261. Many of Kingston's citizens rely on using public lands to provide an income for their families and most of Kingston's citizens 

use public lands for recreation and hunting. Our right to use these lands is continually being challenged. Most of those 

wanting to limit public use of these lands are not concerned about the impact on the local population and they find any 

issue they can to drive their agenda.

UT Both emc0176GB

262. The district believes future listing of this species would ultimately be a major detriment to continuing voluntary incentive 

based conservation projects, planning and the local economy. Farmers and ranchers in Southern Utah rely heavily on 

maintaining federal grazing allotments to sustain their livestock operations and livelihoods in the district's local 

communities.

UT Both emc0178GB

263. BLM is required, under the provisions of the National Environmental Policy Act, to analyze the effects of its proposals on 

the social and economic infrastructure within Utah. BLM must, therefore, as part of the social and economic impact 

portion of the EIS, analyze the impact of each of the alternatives upon the cooperative structure for the protection of sage 

grouse found in Utah.

UT Both emc0337GB

264. Sage grouse habitat is naturally fragmented by the natural topography and conditions ofthe sagebrush environment in Utah, 

and has been further altered by human needs and activities. Given these facts, the BLM must consider, analyze, and provide 

evidence of the BLM's capability to contribute to the needs of the species, especially with reference to the other 

multiple-use requirements of the BLM which significantly contribute to the economy of Utah and the nation

UT Both emc0337GB

265. The Notice ofIntent indicates that the BLM will be conducting an analysis of the social and economic impacts of the 

alternatives within the EIS, and that this analysis will employ one of several computer programs, such as IMPLAN, which 

can calculate dollar values for direct and indirect economic effects. The state is very familiar with these programs, using 

them itselffor various economic calculations. The primary issue with such calculations is to insure that the input data is as 

UT Both emc0337GB
C. Comments by Resource Planning Issue

C-1196 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

realistic and accurate as possible, in order to produce meaningful results. The state requests the opportunity to be an 

active partner in the process to review and select the input data for these calculations.

266. Livestock production tied directly to access and use of the federal lands is the backbone of Utah's agriculture Industry, 

contributing more than 65 percent of our state's $1.5 billion in farm gate sales. This contribution and its economic ripple 

effect are significant to the state of Utah and of critical importance to rural communities. It has been estimated that more 

than 70 percent of Utah's cattle and sheep utilize the public lands for some portion of the grazing year. Sustainable grazing

practices, harvesting renewable forage, provides value to all Americans, enhances rangeland resources and controls dead 

grass and brush helping control deadly Wildfires.

UT Both rmc0003GB

267. Agriculture is important to all Utahns, not only because we all eat, but because of its economic impact. Utah State 

University recently released an economic study related to the contribution of food and agriculture industry. Farming and 

ranching is the foundation to nearly $15 billion in economic activity, 70,000 jobs and contributes as much as 14 percent of 

the Gross State Product.

UT Both rmc0003GB

268. Resource Management Plans - The agencies, state and local governments as well as affected parties participated in the 

previous RMP process. Long term plans are in place related to these RMPs that major decisions and investments have been 

made in community infrastructure, job growth, education funding, grazing and other multiple use activities.

UT Both rmc0003GB

269. More than 90% of the land in Garfield County is under federal ownership, and less than 5% of the land in Garfield County 

is in private ownership. Garfield County requests a detailed social, cultural and economic analysis including custom, 

culture, land uses, economic viability, impacts to human populations, impacts to school populations, environmental justice 

considerations to Garfield County's low income population, and impacts to the health and well-being of Garfield County 

visitors and residents be considered in the plan. Garfield County specifically requests that this analysis conform to Data 

Quality Act guidelines and is not a general over simplification attributed to professional opinion.

UT Both rmc0006GB

270. More than 90% of the land in Garfield County is under federal ownership, and less than 5% of the land in Garfield County 

is in private ownership. Garfield County requests a detailed social, cultural and economic analysis including custom, 

culture, land uses, economic viability, impacts to human populations, impacts to school populations, environmental justice 

considerations to Garfield County's low income population, and impacts to the health and well-being of Garfield County 

visitors and residents be considered in the plan. Garfield County specifically requests that this analysis conform to Data 

Quality Act guidelines and is not a general over simplification attributed to professional opinion.

UT Both rmc0006GB

271. A considerable portion of the economy of Manti City is dependent on agricultural endeavors. The farmers and ranchers in 

Manti rely on the forest as well as BLM lands for grazing if they are to remain a viable part of our local economy. In the 

course of developing a plan we certainly encourage the idea of a cooperative management strategy that would account for 

those farmers and ranchers use grazing permits in the study areas.

UT Both rmc0045GB

272. The Aquarius Plateau includes Wayne and parts of Piute and Garfield counties. 97 per cent of the land is owned by the 

Federal Government. Statistical report from the Governor Herbert's office shows that agriculture contributes 87 percent 

of the county's revenue, any change in grazing would be devastating to the economy of Wayne county.

UT Both rmc0062gb

273. Agriculture on and around Wayne and Piute Counties has been identified as the number one supplier of earned income 

and source of new dollars generated by the multiplier impact. Efforts of the PARM group have led to significant increases 

UT Both rmc0066GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1197

Scoping Summary Report

Table C-10.A

Comments Related to Socioeconomics

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

in grouse inventories and habitat improvement without handicapping livestock production and the local economy.

274. Grazing on public lands represents a vital economic value to agricultural producers and to local communities. Impacts on 

this economic activity need to be included in the study. We urge BLM and FS officials to coordinate with the Department 

of Agricultural and Applied Economics located in the University of Wyoming, College of Agriculture. They have conducted 

several studies about the impact of policy upon agriculture throughout the state. The studies include the importance of 

Animal Unit Months (AUMs), the significance of input and output of state agriculture, and the costs and revenues to 

counties of agriculture compared to development. These EISs/SEISs will directly affect the continuation of livestock grazing 

and other agricultural operations on federal and private lands within and adjacent to the planning area and these 

evaluations of economic impacts upon agriculture need to be included.

WY Both rmc0010RM

275. Secondly, I question strongly the notion that AUM cuts on grazing allotments will have any effect. If grazing is truly a factor, 

why were sage grouse so plentiful from the 1950's through the 1970's? This is a time frame when, typically, turnout dates 

were earlier and grazing allotments were not near so closely monitored, further, stubble height should not be used as a 

benchmark for sage grouse habitat, adjacent to leks. Soil type, in this instance is critical I am familiar with two leks in our 

area (on private land) that are located on white hardpan, which would never have sufficient srubble height on an

exceptional year. Stubble height requirements, in my view, could be used in an arbitrary and capricious way to force AUM 

cuts, without any corresponding benefit to sage grouse populations.

WY Both rmc0012RM, 

rmc0022RM

276. further con'ideration 'hould be made for Ih",e families thathve and work w,thin the area of the lBNG. There a,e many 

ranche, that coexist with National Forest administered lands, Several l ea~e land, for Ihei. ope,ations. Ihose that use TBNG 

to travel upon or over to reach either their own priv~te properties Or Ihe!' allotments should not be rest.lcted beyond 

'e~,onable 10 continue their da,ly activ,tie, for survival Every possoble care and consideration for normal act,vity is 

necessary to secure the su.vival of OUr <peeies as well. Members of the ranching community are the most considerate and

cooper alive individuals and should be treated with respect as their respect for animal. ~nd wildl ife is forefront to them 

al,o.

WY Both rmc0043RM
C. Comments by Resource Planning Issue

C-1198 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-10.B

Comments Related to Tribal Interests and Native American Religious Concerns

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. The BLM has a trust responsibility to treaty tribes which includes protection of culturally important species such as sage 

grouse and sharptail grouse. The BLM can do this by not allowing any wind turbines to be built within five miles of any sage 

grouse and sharptail leks.

All Both emc0009RM

2. Disregarding this decision, the Bureau of Land Management has proceeded to transfer land to extractive industries and 

energy developers with little regard for Shoshone culture, spiritual/religious rights, gathering rights, or concern for the 

plants and wildlife upon which they depend, including the sage grouse and its habitat

All Both emc0170GB

3. Illegal hunting must be controlled more effectively. In at least one case I am aware of, many years ago, a population of sage 

grouse was virtually exterminated by local indians exercising their "indigenous rights" to hunt out of season. They continued

hunting the population off season until there was no longer a viable breeding population left. State fish and game departments 

are generally to afraid of the back lash to enforce hunting regulations for indians. This deplorable situation must be stopped. 

Indigenous rights should be limited to historical hunting techniques, and not allow the use of high power rifles and shotguns 

out of normally set hunting season. Sage grouse habitat should be monitored more closely for illegal hunting, especially 

during the non-hunting season when much of the poaching takes place.

All Both emc0200GB

4. The greater sage-grouse is culturally significant to tribes, many of which have traditional ceremonies, treaty rights, and 

conservation activities associated with the bird. Thus, tribes have a stake in the national sage-grouse planning strategy. Tribes 

care deeply about the preservation of this iconic species and portions of the species’ historic and current range cover tribal 

lands. It is vital that the federal government conduct effective government-to-government consultation with the tribes and 

encourage tribal members to actively engage in this planning process.

All Both emc0329GB

5. We support full Tribal consultation, which involves much more than BLM’s mailing letters to Tribal Chairs and holding a 

meeting or two. BLM should use this process to implement much more stringent requirements for itself during consultation 

processes Westwide. One concern: BLM states this will occur "within greater sage-grouse habitats." But what about the 

areas BLM - arbitrarily - doesn’t even give any status to? Like significant areas of Idaho that only a few years ago were 

sage-grouse habitats, and now are dropped altogether from BLM mapping and that should be identified for restoration, or 

that provide critical habitat during hard winters, or that will be essential to provide connectivity?

All Both emc0411GB

6. The declining conservation status of the greater sage-grouse is of great concern to me, particularly since it is important 

culturally to many of our Indigenus Nations, including my own, the Lakhota.

All Both fld0009rm, 

fld0009gb

7. Tribal and Cultural Resources The BLM's NOI states that, "The BLM and FS will consult with Indian tribes to identify sites, 

areas, and objects important to their cultural and religious heritage within greater sage-grouse habitats.” We support this 

approach. For clarity and to ensure consistency with Executive Order 13175, we recommend that the EIS present 

information about the consultations according to the phases of the consultation process: identification, notification, input, 

and, follow-up. We have found this approach to be useful as we consider consultation for the EPA's actions. For more detail, 

see "EPA Policy on Consultation and Coordination with Indian Tribes."9

All Both rmc0020RM

8. I am an archaeologist doing research on the prehistoric significance of the Sage-grouse to Indigenous peoples of Western 

Colorado. I have evidence that "traditional sage-grouse habitat" has been in existance for thousands of years unchanged. The 

BLM has worked hard to conserve the sage-grouse habitat and that’s how it should be, for not only future generations to 

observe and study, but as part of a Native cultural tradition for generations to come. It was an important food source and 

CO Both flm0003RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1199

Scoping Summary Report

Table C-10.B

Comments Related to Tribal Interests and Native American Religious Concerns

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

played a role in myths and inspiration for ceremonial dances. The greater sage-grouse is an important part of the web of life 

in sagebrush country. Future generations should have the opportunity to visit natural areas and see the fascinating mating 

dance of the sage-grouse.

9. These beautiful birds need to be protected, or soon they will no longer exist at the rate they are declining. Sage-Grouse are 

very important to Yomba’s Native American culture. Because these birds are such an important part of Yomba Shoshone’s 

culture, they would like to be consulted and informed on any and all issues that are being addressed.

NVCA Both emc0104GB
C. Comments by Resource Planning Issue

C-1200 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Make sure all federal lands are included in the conservation plan. Use the best available conservation biology science. All Both cfc0015

2. The fight over the grouse is about more than a bird. It symbolizes a larger dispute over the future of the West and the 

region's vast network of public land. Many expect the bird to touch off an ecological battle not seen since the feud over the 

northern spotted owl in the 1990s that ended up devastating the timber industry in the Pacific Northwest.

All Both cfc0017GB

3. Areas with fewer populations on gov't ground could be blamed upon: ground not as fertile/productive, heavier population of 

weeds, more predators, where wild horses overgrazed, too heavy of population of sage so not healthy ecosystem.

All Both cfc0031GB

4. Let us protect the leks, control the predators and actually manage the land, not lock the area up and call that good 

management!

All Both cfc0035GB

5. I feel multiple use of federal lands benefit the entire community. All Both cfc0060GB

6. On behalf of the residents of oneida county we go on record of maintaining the current status of the BLm and Forest Service 

land that now has multiple use in place.

All Both cfc0061GB

7. In a recent book edited by S. T. Knick and J. W Conmelly on Sage-Grouse research it was stated that most attempts to 

restore sagebrush habitats have been unsuccessful. In fact a noted grouse expert, Dr. Clait E. Braun, stated, "I know of no 

areas where Sage-Grouse have re-established their distribution over significant areas of former habitat," (The Wilson Journal 

of Ornithology, Vol. 123, p 655). What this effort will require will be for you to put Sage-Grouse management above all 

other uses on public lands. This means that grazing of livestock and fences should be eliminated in core Sage-Grouse areas. 

All types of land fragmentation, such as roads, power lines, wind farms, oil and gas drilling, etc. will have to be secondary to 

the management of Sage-Grouse. I do not have much faith that your agencies will be capable of such a drastic turn-around. 

In fact, BLM planned to study ecological trends in much of the 260 million acre of the West’s grazing allotments, but told the 

scientists not to consider livestock grazing, due to "anxiety from stakeholders." Such attitudes will absolutely have to change 

if there is any hope to save Sage-Grouse and their habitat. The only real solution that I see is buying out willing ranchers who 

graze in core Sage-Grouse areas. As said, both your agencies will have to put the grouse first.

All Both emc0021RM

8. lThe EIS must identify and evaluate the impacts of any and all proposed land use management practices to be imposed on all 

public lands users. Such practices must be feasible, practical and cost effective to all users.

All Both emc0031GB

9. This is nothing more than a "land grab" by small groups that simply do not want people on public lands. They want use of 

public lands on their terms only. They represent a small minority. If the real issue is the Sage Grouse, let's set up hatcheries 

in every effected state and breed Sage Grouse.

All Both emc0035GB

10. In my view, many of the efforts to protect sage grouse is simply motivated to stop resource development on our public lands. 

Sage grouse habitat is very extensive across the West. As a result, environmental groups are using the sage grouse as a 

vehicle to stop most oil, gas, and mineral development - and force their agendas on the rest of us.

All Both emc0054RM

11. Sage-grouse, pygmy rabbits and the full suite of sage obligate flora and fauna will make their last stand on the national public 

lands. State lands will continue to be largely managed for maximum return to state coffers by law.

All Both emc0058GB

12. If healthy, robust populations of sage species are to be retained, national public lands must be managed as though they will be 

the only areas of sage habitat remaining large enough to matter. In many areas they already are that, and in all likelihood that 

will become more and more the case in the future. This means managing sage habitat for native species must become the 

All Both emc0058GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1201

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

dominant paradigm on national lands.

13. What remains of good or restorable native habitat on our national lands must be managed for their intrinsic values first and 

foremost and uses which detract from that objective must be phased out.

All Both emc0058GB

14. As one drives through the millions of acres of open space in the west, you wonder who takes care of all this land. It is neither 

the government nor the environmental community; it is the rancher whose house is out of the wind and out of site. The west 

does not have another management option. Be careful of what you regulate as a result of this scoping process.

All Both emc0070GB

15. How will the BLM coordinate the different County Comprehensive Land Use Plans into the EIS? Understanding that each 

county is required by state law to have its own plan and that being designed locally means all are unique to a respective 

county.

All Both emc0071GB

16. With regards to roads around both priority and general Greater Sage Grouse habitats, no new roads or ROW’s should be 

allowed or granted within a 5.5 mile radius of a lek site. With regards to priority habitats, the BLM should further include 

mandatory limited and or no usage of such roads that pass within a 5.5 mile radius of a lek site during mating and hatching 

seasons.

All BLM emc0074RM

17. The majority ofour member companies are reliant upon public lands and their associated federal management in order to 

conduct their operations.

All Both emc0077GB

18. The EIS should address how BLM plans to honor the valid existing rights companies hold within what is assumed will be 

designated Priority Habitat Areas.

All Both emc0103GB

19. The conservation measures in the “A Report on National Greater Sage-Grouse Conservation Measures” take the approach 

that typical uses of public lands negatively impact the sage grouse and immediately seek to limit or withdraw public use as a 

means of conservation. These are stipulations, not conservation measures. This approach should be changed to fully analyze 

all potential proposed actions. A matrix should be developed identifying the issues associated with various typical 

components of each type of proposed action and delineate a full range of alternatives and mitigation measures in different 

levels of habitat.

All Both emc0103GB

20. There are at least several places in BLM’s materials that say the conservation measures would be applied regardless of 

surface ownership. For example, in the December 27, 2011 BLM press release: “human-caused disturbance in priority 

habitat would be limited to less than 2.5% of the species’ total habitat, regardless of surface ownership”. The EIS should 

address only the management of public lands.

All Both emc0103GB

21. When revising the existing RMPs, the BLM must also acknowledge existing rights, including oil and gas lease rights. Once the 

BLM has issued a federal oil and gas lease without no surface occupancy stipulations, and in the absence of a nondiscretionary 

statutory prohibition against development, the BLM cannot completely deny development on the leasehold. See, e.g., 

National Wildlife Federation, et al., 150 IBLA 385, 403 (1999). Only Congress has the right to completely prohibit 

development once a lease has been issued. Western Colorado Congress, 130 IBLA 244, 248 (1994). Further, the BLM 

cannot adjust Devon's valid and existing rights. Congress made it dear when it enacted FLPMA that nothing therein, or in the 

land use plans developed thereunder, was intended to terminate, modify, or alter any valid or existing property rights. See 

43 U.S.C. § 1701 (2006). In order to effectuate this purpose, the BLM promulgated policies regarding the contractual rights 

All BLM emc0116GB
C. Comments by Resource Planning Issue

C-1202 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

granted in an oil and gas lease. BLM Instruction Memorandum 92-67 states that U[t]he lease contract conveys certain rights 

which must be honored through its term, regardless of the age of the lease, a change in surface management conditions, or 

the availability of new data or information. The contract was validly entered based upon the environmental standards and 

information current at the time of the lease issuance." As noted in the BLM's Instruction Memorandum, which is binding 

upon the agency, the lease constitutes a contract between the federal government and the lessee which cannot be 

unilaterally altered or modified by the BLM.

22. Because, the authority conferred in FlPMA is expressly made subject to valid existing rights, 43 U.S.C. § 1701, an RMP 

prepared pursuant to FlPMA, after lease execution and after drilling and production has commenced, is likewise subject to 

existing rights. See Colorado Environmental Coal, et 01., 165 IBLA 221, 228 (2005). The RMPs, when revised, cannot defeat 

or materially restrain Devon's valid and existing rights to develop its leases through conditions of approval or other means.

See Colorado Environmental Coal, et al., 165 IBLA 221, 228 (2005) (citing Colorado Environmental Coal., 135 ISLA 356, 360 

(1996) aff'd, Colorado Environmental Coal. V. Bureau of Land Management, 932 F.Supp. 1247 (D.Colo. 1996).

All BLM emc0116GB

23. BLM recognized the need to address mixed estate ownership in its December 2011, "Report on National Greater-Sage 

Grouse Conservation Measures" (Report). That Report proposes exceptions to closing leasing in mixed ownership lands 

containing priority habitats specifically in cases where land ownership is inconsistent section-by-section resulting in a 

"checkerboard" ownership pattern. Anadarko owns mineral and surface use interests in such checkerboard areas. Anadarko 

therefore recommends that in areas of mixed ownership reasonable exceptions are provided to conservation measures.

All Both emc0125RM

24. Recognition of the challenging resource management aspect of mixed ownership is also stated in BLM's document Winning 

Challenges o/the Future -A Road Map to Success in 2016 (BLM 2010). BLM notes: "Our checkerboard landscape and 

management of the subsurface mineral estate that is sometimes located under different surface owners has integrated 

managing and mitigating necessary impacts and, ultimately, good communication into everything we do." The document 

continues: "Mitigation measures will need to be coordinated based on resource impacts, rather than land ownership." 

Consistent with the above tenets, Anadarko requests that BLM not limit our company to only providing scoping or NEP A 

document comments, but more fully engage mineral owners in these proposed land management changes. As the planning 

process progresses, a productive on-going dialogue with the mineral and surface use owners on the checkerboard lands is 

essential.

All Both emc0125RM

25. So I guess what we ask as residents of Clark County, and as land owners of sage property in Clark County, and as users of 

public lands in Clark County, is To Whom it May Concern We would like to comment on the Greater Sage Grouse Planning 

Strategy that you work with us in the County to find plans that will allow us to continue to live and take care of the land here, 

including it's other residents the animals. We all are conservationists in one-way or another, or we wouldn't still be here on 

the land. The Indians proved this by burning off areas every so many years to provide fresh food for the game that they 

needed to survive. We too need to survive.

All Both emc0128GB

26. The County supports the continued access to public lands and maintenance of valid multiple uses. We would ask that a local 

workshop be held with inclusion of our Commission, local NDOW representatives and BLM District / Field Office to 

review, discuss and cooperate on designation of priority habitat within Lincoln County.

All Both emc0130GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1203

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

27. Impacts to sage grouse should have been analyzed in all National Environmental Policy Act (NEPA) documents required for 

every right-of-way (ROW) permit on BLM land. Requiring additional review for previously authorized ROWs requiring 

amendment or renewal places undue burden and expense on the permit holder and can significantly and adversely impact 

current operations, such as mining, grazing, recreation, etc. and the communities that support those activities.

All Both emc0147GB

28. The statement, “Unless the BLM determines, in coordination with the respective state wildlife agency, that the proposed 

ROW and mitigation measures would cumulatively maintain or enhance Greater Sage-Grouse habitat, the proposed ROW 

decision must be forwarded to the appropriate BLM State Director, State Wildlife Agency Director, and FWS representative 

for their review,” implies ROW applications will be approved or denied based on impacts to sage grouse alone. ROW 

applications must take into account beneficial as well as detrimental socio-economic impacts, biological impacts, visual

impacts, etc. A balanced approach is the goal of NEPA review. Also, moving the decision point reduces the authority of the 

field offices and consideration of local issues.

All Both emc0147GB

29. Another consideration you must make is with land tenure. With the various ages of your land use plans and various land 

tenure priorities, you need to decide if it is going to be a priority to acquire or protect sage grouse habitat via sale, exchanges 

or easements. If it is, the process needs to be fixed to be accomplished in a cheaper, easier and faster way for sage grouse and 

their habitat. At least one alternative needs to address this issue.

All Both emc0149GB

30. ODOT recognizes that this BLM / USFS plan is likely not going to be highly detailed or specific. Rather it is likely intended to 

provide broad over arching guidance that the individual Districts will utilize when they craft or modify District level 

management plans. Many of the issues of concern that ODOT has related to transportation facilities and sources of material 

located on federal land are likely to be similar in other Western States paliicipating in this planning effort. The following 

recommendations are not Oregon specific and would seemingly be appropriate for this larger planning effort. ODOT 

recommends that through this higher level planning effort: Guidance to the Districts is developed stating that in all District 

level planning efforts existing federal, state and local transportation facilities, rights-of-ways and serialized federal material 

sites within the planning area need to be clearly identified and documented in their management plans

All Both emc0155GB

31. ODOT recognizes that this BLM / USFS plan is likely not going to be highly detailed or specific. Rather it is likely intended to 

provide broad over arching guidance that the individual Districts will utilize when they craft or modify District level 

management plans. Many of the issues of concern that ODOT has related to transportation facilities and sources of material

located on federal land are likely to be similar in other Western States paliicipating in this planning effort. The following 

recommendations are not Oregon specific and would seemingly be appropriate for this larger planning effort. ODOT 

recommends that through this higher level planning effort: Guidance is developed that the Districts can implement that 

provides exceptions or buffers for existing rights-of-way or easements to allow for the continued and unimpeded use of 

these lands for transportation related purposes. Highway related activities within existing rights-of-way should be exempted 

from added scrutiny based on greater sage-grouse habitat.

All Both emc0155GB

32. ODOT recognizes that this BLM / USFS plan is likely not going to be highly detailed or specific. Rather it is likely intended to 

provide broad over arching guidance that the individual Districts will utilize when they craft or modify District level 

management plans. Many of the issues of concern that ODOT has related to transportation facilities and sources of material 

located on federal land are likely to be similar in other Western States paliicipating in this planning effort. The following 

All Both emc0155GB
C. Comments by Resource Planning Issue

C-1204 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

recommendations are not Oregon specific and would seemingly be appropriate for this larger planning effort. ODOT 

recommends that through this higher level planning effort: Guidance is developed for the Districts, out lining an expedited 

process for gaining necessary approvals if the identified projects (highway or material sources) will impact greater 

sage-grouse habitat outside existing highway or material site rights-of-way.

33. ODOT wants to reiterate that we support and recognizes the importance and value in environmental review of projects to 

assure that issues such as greater sage-grouse habitat is identified, evaluated and, if necessary, mitigated. But for projects that 

are necessary to maintain a safe and efficient transportation system, there needs to be processes in place to allow for project 

specific evaluation and approval without always requiring an RMP amendment via an EA or EIS. Greater sage-grouse and their 

habitats are important, but in addressing transportation improvement or maintenance projects or materials needed for 

these projects, it should not take years of effort and hundreds or thousands of dollars to obtain approvals to move forward. 

By developing the above mentioned recommendations, it should allow individual BLM Districts across the west to implement 

land management strategies for improved greater sage-grouse habitat without having to struggle to address Federal, State 

and Local Transportation projects and needed material sources.

All Both emc0155GB

34. Please allow the people that love this country to continue to enjoying it, don't close us out of the areas we enjoy. All Both emc0175GB

35. Case in point, the National Greater Sage-Grouse Planning Strategy is designed to categorize Sage-Grouse as a species 

requiring government intervention to ensure their survival. When this designation occurs, here comes the regulation and 

there goes public land use and access.

All Both emc0176GB

36. I am opposed to any use of this issue to close more public lands to access or development. All Both emc0177GB

37. I would like to add my comments regarding the Great Basin Region - National Greater Sage-Grouse Planning Strategy. I 

appreciate the need to protect our lands through resource management plans, but I believe the plans tend to side on the 

environmentalist side and not on the users of the land such as I. I am a senior (over 55 years) ATV rider and I appreciate the 

ability to see our land with ease, but I do not damage our lands. When I hear the goal is to protect sage-grouse, I believe this 

means closures to lands I want to visit. Please do not take the sage-grouse to the point that existing ATV trails are closed.

All Both emc0182GB

38. It is necessary to remove as much critical habitat as possible from development. This means both buying out some leases and 

trading others in critical habitat for those in less important areas. Clearly, some areas are simply not appropriate for 

development.

All Both EMC0185RM

39. I don't feel there is any reason to close public land to the public. The is no reason the sage grouse and humans can't use the 

same area.

All Both emc0188GB

40. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the econoimic viability of ranching operations.

All Both emc0202GB

41. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations. Wildlife populations including Greater 

sagegrouse benefit from the productivity of these private lands.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1205

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

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Agency CmtLtrCode

42. Public lands (especially BLM property) should be managed for multiple uses. Traditional uses should get priority over newer 

uses such as ATV trails and wilderness designation. National Parks and National Forests should be managed for fewer 

activities and can be set aside for Wilderness designation.

All Both emc0217GB

43. Because hunting and ranching are the traditional use of most of the public land, management should be tailored for these 2 

activities but other activities should be included as long as hunting and ranching is not affected.

All Both emc0217GB

44. Every effort should be made to consolidate public lands and reduce the checkerboard situation caused by the railroad. 

Isolated parcels that have no public access should also be reduced. Efforts should be made to trade or sell BLM controlled 

property that is isolated and mixed with private property.

All Both emc0217GB

45. Any proceeds made from the sale of public land, should be used to purchase land and expand our existing National Parks and 

Forests which will provide larger buffer areas for future development.

All Both emc0217GB

46. Most BLM land does not need to be included as Wilderness designation but it does need to be protected to prevent illegal 

activities from happening. If the BLM is going to maintain management of these lands, then they need to increase enforcement 

of existing laws and regulations. Without increased enforcement efforst, sage grouse habitat will continue to be affected.

All Both emc0217GB

47. I am against restricting the use of federal land for the public to use in recreation, logging, mining, ranching, farming and other 

uses.

All Both emc0229GB

48. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: Closed to leasing or NSO with no exceptions, modifications or waivers.

All Both emc0234GB

49. BLM should put the following management prescriptions in place for L WCs at a minimum: Closed to leasing or NSO with 

no exceptions, waivers or modifications;

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50. Page 12, Lands/Realty section indicates that rights-of-way (ROWs) should not be permitted in high priority sage-grouse 

habitats, with a few exceptions. The socio-economic impact of this conservation measure needs to be analyzed in the EIS. 

Restricting the new ROWs to be co-located entirely within an existing ROW is too restrictive (page 13, first bullet). The 

temporary, short-term use of a laydown yard or staging areas that is too large to be co-located entirely within an existing 

ROW should not be sufficient reason for denying the use of the ROW. However, such short-term temporary use should be 

followed by reclamation to prevent non-native invasive species from establishing and re-establishing perennial vegetation.

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51. Under the Land Tenure Adjustment section (page 13) the conservation measure calls for retaining "public ownership of 

priority sage-grouse habitat." We find this offensive as it implies only the government can benefit and manage sage-grouse. 

The record over the last 60 years in Nevada would not support this implication.

All Both emc0239GB

52. For example, BLM may impose NSO restrictions on active leases or require certain BMPs as Conditions of Approval (COAs) 

for permits within priority habitats. BLM cannot legally impose new NSO stipulations or COAs on existing leases rights that 

differ from those entered under the original contractual terms.

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53. The Report recommends that BLM close priority sage-grouse habitats to future leasing, except in areas that are not entirely 

federally owned. A decision to discontinue leasing in all preliminary priority habitats (PPH) areas that are not entirely 

federally owned would unreasonably block access to Significant energy resources on thousands of acres of public lands, 

potentially force operators to abandon projects outside of PPH areas if they are unable to lease adjacent or nearby parcels 

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C. Comments by Resource Planning Issue

C-1206 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

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within those areas, and deprive state and federal coffers of significant revenue from leasing and the subsequent development 

of those leases.

54. The terms of leases held on public land must be honored and existing rights integrated into the proposed action. Leases are 

obtained and held through significant expense. The terms of all geothermal and other energy leases specifically provide for 

exploration and development of resources. This includes access to that property as well as transport of the product from 

the property. Rights of way and access roads must be considered for each leasehold.

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55. COMMENTS ON Interim conservation Measures and Policies for Preliminary Priority Habitat, No. 2012-043 (IM) As the 

interim policy and program guidance in the IM: These comments are consistent with and applicable to the strategic 

suggestions above for the proposed action. Rights-of-Way (ROW) The ROW recommendations proposed in the IM may 

create significant delays in permitting renewable energy projects. To recycle pending ROW applications for additional 

alternatives analysis could add months or even years to the development of renewable energy projects. Also, the IM gives 

Field Offices the ability to defer processing ROW applications until the completion of the LUP process, which has the 

potential to stall development for up to three years.

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56. COMMENTS ON Interim conservation Measures and Policies for Preliminary Priority Habitat, No. 2012-043 (IM) As the 

interim policy and program guidance in the IM: These comments are consistent with and applicable to the strategic 

suggestions above for the proposed action. Authorizations on Existing Leases In the all other Proposed Authorizations 

section, the IM suggests suspending non-producing leases in instances where mitigation would not adequately protect the 

integrity of Greater Sage‐Grouse habitat. We feel that it is difficult, if not impossible, to determine the adequacy of mitigation 

for actions which have not yet been fully defined or analyzed through a NEPA process. Suspending such leases would deprive 

leaseholders of the potential benefits of continuing development without compensating them for the value invested obtaining 

or exploring the leases.

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57. COMMENTS ON "A Report on National Greater Sage-Grouse Conservation Measures" produced by the Sage-Grouse 

National Technical :Team (NTT) Rights of Way The NTT Report suggests possibly removing, burying, and modifying 

existing power lines that are within PPH areas. Burying transmission lines is an extremely costly venture, and may make many 

projects uneconomical. We feel that this mitigation should only be used in extreme circumstances in which studies indicate 

that there is very high value in burying such transmission lines in very localized cases, and in exchange for this mitigation, 

proponents receive high value in other proposed actions within the PMU. For example, a proponent could offer to bury an 

existing power line segment through high-value PPH as mitigation to a new proposed impact. The mitigation should more 

than offset the impact of the proposed new development.

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58. The rights of land owners and mining claim owners should be protected to the fullest extent possible as they have existing 

property and access rights. Inhibiting access will cause unnecessary litigation and I believe such limitation will not improve SG 

populations.

All Both emc0260GB

59. I would like a section discussing the access rights of private land owners and mining claim owners across BLM lands and what 

the BLM's view of these rights are and the limitations of the law to restrict access. I want to see specific language guidance

on what limitations, if any, the BLM believes it is under in restricting access rights of private property and mining claim 

owners of preexisting rights of way.

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1207

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

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60. County governments feel strongly that significant and unwarranted impacts to multiple use of public lands will occur, if the 

Greater Sage Grouse is listed as a T&E species at this time.

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61. Although previous sections have discussed potential impacts from infrastructure associated with energy development and 

mining, it is important to highlight that infrastructure by itself poses a serious threat to sage-grouse populations. Such 

infrastructure may include powerlines, communication towers, railroads, roads, and fences. Most authors note that the most 

significant impact from infrastructure overall is habitat fragmentation. Fragmentation of sagebrush habitats has been cited as 

a primary cause of the decline of sage-grouse populations, and documented negative effects may include impacts on lek 

persistence, lek attendance, winter habitat use, recruitment, yearling annual survival rate, and female nest site choice.

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62. Powerlines, which are common to many of the land uses discussed herein, are a particularly significant barrier to sage-grouse 

movement. Sage-grouse may avoid areas with powerlines as a result of the electromagnetic fields, and thus the impact from 

the powerline is greater than its actual footprint. Additionally, powerline construction threatens to spread invasive species 

and noxious weeds, and additionally can create hunting posts for predators to utilize.

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63. In November 2009, nine federal agencies signed a Memorandum of Understanding seeking to expedite the construction of 

new transmission lines on federal lands. If these transmission lines cross sage-grouse habitat, sage-grouse will likely be 

negatively impacted. The Gateway West Transmission Project, for example, will include ten power line segments and is 

expected to cut across 1,100 miles in southeastern Idaho and northern Wyoming, with approximately 500 miles of 

powerlines proposed on BLM lands. It is anticipated that this project may significantly impact sage-grouse habitat in those 

areas.

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64. Communication towers also cause similar negative impacts to sage-grouse. Close to 10,000 new communications towers 

have been constructed within sage-grouse habitats in recent years. Towers will cause similar effects as those associated with 

powerlines, especially with regard to habitat fragmentation and sage-grouse avoidance behavior.

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65. A major threat to sage-grouse habitat is direct conversation of sagebrush lands for other land management activities, 

including perhaps most predominantly conversion for agricultural use. Studies have noted that given the distribution of 

agricultural activities across the sagebrush range, nearly three quarters of all sagebrush lands once suitable for sage-grouse 

have been influenced by agricultural activities. Notably, in a study aimed at identifying environmental factors associated with 

extirpation of sage-grouse, authors noted that areas still occupied by sage-grouse have three times less area in agriculture 

than extirpated areas. In addition to conversion of sagebrush lands for growing traditional crops, there has been an increased 

interest in the development of crops for use as biofuels, which could increase the desire to convert land for agricultural use. 

An increase in land conversion for biofuels is anticipated to negatively impact sage-grouse populations.

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66. Land has also been converted for development across the West. As population increases, development becomes more 

prominent. The Fish and Wildlife Service predicts, for example, that given the current demographic and economic trends in 

the Rocky Mountain West, rates or urbanization will continue increasing, resulting in further habitat fragmentation and 

degradation and decreasing probability of long-term sage-grouse persistence.

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67. Conversion of land for agriculture or development also carries with it indirect effects to sage-grouse. For example, 

agricultural activities or infrastructure associated with development may open up land and provide corridors or perches for 

predators. An increase in predators, of course, can lead to a decrease in breeding, nesting, and brood rearing success. 

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C. Comments by Resource Planning Issue

C-1208 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

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Additionally, loss of habitat to agriculture and development may also lead to an increase in human presence, causing stress, 

mortality (accidental or purposeful), and extirpation. As with many of these land disturbing activities affecting sage-grouse, 

habitat fragmentation is a serious by-product of all land conversions.

68. The agencies should also prohibit conversion of sagebrush habitat to any other use within priority sage-grouse habitat. 

Direct conversion of land for agriculture, development, and other purposes deprives sage-grouse of habitat necessary to 

survive. This direct loss of habitat is inevitably seriously harmful to a species already struggling to survive across its current, 

and already seriously reduced, range. Remaining priority habitat must be protected, as this species can hardly endure further 

loss. See infra Section III.H for more information on the threats associated with conversion of sage-grouse habitat. Because 

direct conversion is a real threat when public lands are sold to private interests, we agree with the Technical Team Report’s

directive to retain public ownership of priority sage-grouse habitat and to seek sand acquire state and private lands where 

possible to best conserve sage-grouse habitat.

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69. EI Paso is regulated by the Department of Transportation (DOT) and the Pipe line and Hazardous Materials Safety 

Administration (PHMSA) for the conveyance of natural gas. As a result, safely regulations stipulate that EI Paso maintain 

various safety facilities (i.e. block valves) and have access to our facilities on a regular basis. The spacing of these facilities is 

mandated by the DOT and may on occasion fall within a mapped Preliminary Priority Habitat (" PPH") or Preliminary 

General Habitat ("PGH") sage-grouse area. Any new conservation measures must allow for the location of these facilities 

within habitat areas. In addition, some facilities such as compressor stations and meter stat ions have to be located at certain 

points along an existing or new right-of-way (“ROW"). The locations of these facilities are, at limes, restricted due to 

engineering constraints and safety issues. Any conservation measures should allow the placement of operations and 

maintenance facilities within sage-grouse PPH and PGH habitat.

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70. On page 9 of 74, No. 3 Right-of-Way - Lands/Realty, the document addresses the need for offsite mitigation if disturbances 

exceed the 3 percent threshold. If mitigation is required to offset disturbance within sage-grouse habitat, the BLM needs 

develop a consistent policy across the sage-grouse range that identifies specific and defined mitigation ratios and the process 

used to identify suitable mitigation measures. This needs to include input from state and local working groups, state wildlife 

agencies, industry, ranchers, and other affected groups.

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71. On page 13 of 74, the first bullet states "Make priority sage-grouse habitat areas exclusion areas for new ROWs permits. 

Consider the following exceptions. Within designated ROW corridors encumbered by existing ROW authorizations: new 

ROWs may be co·localed only if the entire footprint of the proposed project (including construction and staging), can be 

completed within the existing disturbance associated with the authorized ROWs." Compliance with this conservation

measure is unrealistic due to safety concerns. When constructing new facilities, EI Paso's strives to maintain a safe working 

distance from existing natural gas pipelines, powerlines and other infrastructure to prevent unintentional incidents involving 

contact with our lines. This offset combined with the amount of construction ROW that is required to safely construct new 

projects might effectively prohibit collocation with existing natural gas pipelines. This measure further eliminates the 

potential for placement of any new ROW corridors within identified grouse habitats and virtually eliminates the potential for 

any new energy infrastructure throughout the range of the sage-grouse. EI Paso would agree that through the use of seasonal 

timing restrictions and careful route selection, disturbances to these areas could be reduced or eliminated. However, a 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1209

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

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Agency CmtLtrCode

complete elimination of new rights-of-way does not adhere to the BLM policy of multiple-use of the public lands.

72. The BLM should amend applicable land use plans to allow voluntary retirement of grazing permits, energy leases or other 

potentially-disturbing activities conducted under license, lease or permit on BLM lands at the request of the permit or lease 

holder.

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73. The BLM should rely on the best available science concerning sage-grouse behavior, habitat needs, and conservation 

best-practices when developing land use guidelines.

All BLM emc0308GB

74. Public lands must be managed to provide for multiple use including "the Nation's need for domestic sources of minerals, 

food, timber and fiber from public lands". land management must strive for a "sustainable yield" requiring "the achievement 

and maintenance in perpetuity of a high level annual or regular periodic output of the various renewable resources of the 

public lands consistent with multiple uses. Mineral exploration and extraction, grazing and other productive uses must be 

considered on equal footing with sage grouse management.

All Both emc0310GB

75. If validity patent exams or buy-outs are proposed in any of the EIS alternatives, the scientific and legal basis must be provided 

for such actions. Such actions are inconsistent with Congress' repeated recognition that public lands must generally remain 

open to mineral entry and development. Additionally, if such measures are proposed, the EIS must address the provisions 

of Section 204 of FLPMA and the procedures that the Department of Interior must follow in order to withdraw public lands 

from mining, as well as fully consider socioeconomic and cumulative effect impacts related to these actions.

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76. In the document "A Report on National Greater Sage -Grouse Conservation Measures" the typical approach is to 

immediately seek to limit or withdraw public use as a means of conservation. The approach in the EIS and its alternatives 

should move away from such "stipUlations" and fully analyze the full array of all potential actions

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77. The EI5 must ciearly define and justify the baseline for both species population and habitat, further designated by public 

versus private ownership. This is critical to evaluate the need, extent, and associated impacts of any proposed new public 

land use restrictions. Absent this critical review, it is conceivable that the hard rock mining industry could suffer an undue 

burden of restrictive land use measures, despite being ranked near the bottom of the USFWS list of sage grouse threats.

All Both emc0310GB

78. Sage-grouse habitat is much of the sage brush dominated areas of North America. To classify areas of the west as general 

habitat and restrict the problem to anthropogenic related causes is an over simplification of management issues. We are 

concerned that it could lead to restrictions of extremely large portions of the public lands resulting in denied access.

All Both emc0313GB

79. Moreover, public lands ranchers own a significant portion of high-quality lowland brood rearing habitat as deeded property. 

According to the USDA Natural Resources Conservation Service (NRCS), "[a]pproximately 40 percent of sage-grouse 

habitat that supports populations occurs on privately owned lands." However, if regulatory measures on public lands make 

ranching operations economically unsustainable, these operations are subject to sale and development, leading to

fragmentation and loss of key habitat. It is therefore essential that the preferred alternative incorporates explicit steps to 

ensure that sage-grouse conservation measures do not undermine the viability of public lands ranches.

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80. Any EIS or SEIS must also explicitly recognize the following points: In the Great Basin, and much of the western United 

States, livestock operations are highly dependent upon the combined use of private and public lands. Regulatory actions that 

make public lands grazing economically unsustainable will not only negatively impact individual ranch owners, but also entire 

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C. Comments by Resource Planning Issue

C-1210 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

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rural communities that largely depend on ranching to maintain businesses and tax base.

81. About including private lands into the 3% calculation for disturbance in priority habitats. Many of the private lands will have 

disturbances and management of sage brush habitat that will skew the 3% calculation and reduce the allowed disturbance on 

federal land designated as priority habitat

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82. That future leasing in and around GSG habitat could be unreasonably delayed, or not occur at all, due to the bureaucratic 

decision-making process laid out in the IM.

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83. Rather than withdrawing the land to where there is no income coming into your agency by fees for exploration acres, both 

in the mining sector as well as the oil, gas & geothermal sectors, would it not have been more beneficial for you to allow the 

sale of the deferred leases and allowed the operators to aid in mitigating this problem in regard to the Sage Grouse? It seems 

to me the mining companies have done an excellent job in restoration projects throughout this State.

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84. VI. The EIS Must Evaluate Ways to Minimize Adversely Affecting Private Property Rights Federal land management agencies 

must properly define and protect valid existing rights as part of their planning processes. A number of the conservation 

measures and regulatory mechanisms recommended in the NTT Report have significant potential to diminish landowners’ 

rights to develop their private property. The EIS must evaluate ways to minimize interfering with private property rights –

including the rights associated with owning patented mining claims and fee mineral estates. BLM’s proposal to recognize 

Valid Existing Rights (VERs) on valid claims (e.g., claims with a discovery of a valuable mineral deposit) does not go far enough 

to protect the property rights associated with patented mining claims and fee land because it restricts the analysis of the 

VERs to the four corners of a patented mining claim or the boundaries of the fee land. Instead, BLM and USFS must evaluate 

the substantially adverse consequences of making it impossible to develop private lands if the adjacent unpatented mining 

claims without a discovery are withdrawn from development. Similarly, if public lands needed for ROWs for roads, power 

lines, pipelines, etc. are no longer available for development, the patented claims, fee lands, and associated private property 

rights could be rendered worthless.

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85. VIII. The EIS Should Evaluate Whether the Conservation Measures and Regulatory Mechanisms in the NTT Report are 

Consistent with FLPMA Mandates to Take a Balanced Approach to Managing Public Lands FLPMA is premised on the 

overarching principle to use a balanced approach in managing the public lands. In enacting FLPMA in 1976, Congress directed 

the Secretary of the Interior to consider a broad range of resource issues, land characteristics and public needs and values 

in determining how public lands should be managed. Thus, FLPMA directs BLM to manage public lands for multiple-uses and 

to consider a wide array of resource values – including the need to protect wildlife – in the context of the Nation’s needs for 

minerals, energy, food, fiber, and other natural resources. FLPMA does not authorize the subordination of any of these uses 

in preference for a single land use such as sage-grouse habitat conservation (emphasis added). FLPMA, Section 102(a)(7) 

establishes multiple-use and sustained yield land management directives and requires the Secretary to develop: ... goals and 

objectives [that are] established by law as guidelines for public land use planning, and that management be on the basis of 

multiple use and sustained yield unless otherwise specified by law (U.S.C. 1701(a)(7)) In defining the term “multiple use” 

FLPMA § 103(c) directs the Secretary to ensure: ...management of the public lands and their various resource values so 

that they are utilized in the combination that will best meet the present and future needs of the American people; making the

most judicious use of the land for some or all of these resources...to conform to changing needs and conditions; the use of 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1211

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

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some land for less than all of the resources; a combination of balanced and diverse resource uses that takes into account the

long-term needs of future generations for renewable and nonrenewable resources, including, but not limited to, recreation, 

range, timber, minerals, watershed, wildlife and fish, and natural scenic, scientific and historical values. 43 U.S.C § 1702(c). 

Therefore, under the multiple-use and sustained yield requirement, BLM must strike an appropriate balance between 

potentially competing interests and land management objectives. This balance is to be achieved in the Section 102 land use 

planning process and the resulting RMPs. The EIS must evaluate whether and how the conservation measures and regulatory 

mechanisms recommended in the NTT Report achieve the required balance in managing the public lands. It also is 

incumbent on the agencies, when balancing the environmental analysis, to give equal consideration to the social and 

economic factors and not presume that environmental harm will outweigh all other considerations. Accordingly, the Ninth 

Circuit Court of Appeals in Lands Council v. McNair, 537 F.3d 981, 1005 (9th Cir. 2008) (en banc), stated: “Our law does 

not...allow us to abandon a balance of harms analysis just because an environmental injury is at issue.” Given the current 

state of the U.S. economy, it is more important than ever to adhere to that statutory and judicial mandate so our 

communities and country remain healthy and vibrant.

86. BLM’s proposed conservation measures would place lands with high-priority sage-grouse habitat off-limits to both mineral 

leasing and to locating mining claims. This is inconsistent with and in direct violation of the General Mining Laws (30 U.S.C. 

§§ 21, et. seq.) and FLPMA (43 U.S.C. 1701 et. seq). FLPMA lists twelve policies with respect to the public lands of the United 

States. Section 102(a)(12) states that it is the policy of the United States that: the public lands be managed in a manner 

which recognizes the Nation’s need for domestic sources of minerals, food, timber and fiber from the public lands including 

implementation of the Mining and Minerals Policy Act of 1970 (30 U.S.C. 21a) as it pertains to the public lands; The Mining 

and Minerals Policy Act of 1970 declares, in part: [t]hat it is the continuing policy of the Federal Government in the national 

interest to foster and encourage private enterprise in (1) the development of economically sound and stable domestic 

mining, minerals, metal and mineral reclamation industries, .... This policy of protecting the rights of the public to explore 

for and develop locatable minerals was expressly incorporated into the current BLM land-use planning framework 

established under FLPMA. Congress expressly provided that the land-use planning directives under FLPMA shall not “in any 

way amend the Mining Law of 1872 or impair the rights of any locators or claims under that Act, including, but not limited 

to, rights of ingress and egress” to public lands for mineral exploration and development. 43 U.S.S. § 1732(b). Consistent 

with these legal mandates, the sage-grouse EIS’s should carefully consider the effects that potential sage-grouse conservation 

measures may have on mineral exploration and mining activities, and ensure that the adopted measures avoid or minimize 

adverse impacts on these types of activities. FLPMA does not authorize BLM to manage the public lands for sage-grouse 

conservation to the exclusion of other authorized multiple-uses. The Multiple-Use and Sustained Yield Act of 1960 

(MUSYA) (16 U.S.C. 528) and the National Forest Management Act of 1976 contain similar policy declarations for the USFS. 

The Multiple-Use and Sustained-Yield Act directed the Forest Service to manage the National Forests according to the 

principle of “multiple-use” and “sustained yield.” Significantly, in MUSYA, as in the Forest Service’s Organic Act, Congress 

warned that “nothing” in the Act “shall be construed so as to affect the use or administration of the mineral resources of 

national forest lands . . . ” 16 U.S.C. § 528. Specifically, section 4 of MUSYA defines “multiple use” as: the management of 

all the various renewable surface resources of the national forests so that they are utilized in the combination that will best 

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C. Comments by Resource Planning Issue

C-1212 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

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meet the needs of the American people; making the most judicious use of the land for some or all of these resources or 

related services over areas large enough to provide sufficient latitude for periodic adjustments in use to conform to changing 

needs and conditions; that some land will be used for less than all of the resources; and harmonious and coordinated 

management of the various resources, each with the other, without impairment of the productivity of the land, with 

consideration being given to the relative values of the various resources, and not necessarily the combination of uses that will 

give the greatest dollar return or the greatest unit output. 16 U.S.C. § 531. The EIS documents must evaluate how the 

proposed measures comply with the "harmonious and coordinated management of the various resources" directive in 

Section 531 of MUSYA. Clearly, withdrawing national forest lands from operation of the Mining Law in preference for 

sage-grouse habitat conservation is not a "harmonious or coordinated" way in which to manage these lands. As 

appropriately concluded by the U.S. Court of Appeals for the Seventh Circuit, the Forest Service does not have the 

discretion to ignore the multiple-use mandate to focus solely on environmental and recreational resources. That court held, 

“the national forests, unlike national parks, are not wholly dedicated to recreational and environmental values." Cronin v. 

United States Department of Agriculture, 919 F.2d 439, 444 (7th Cir. 1990). Thus, it is essential BLM and USFS carefully 

consider the impacts of potential conservation measures on mining and grazing activities, and that both agencies develop a 

balanced approach that will avoid or minimize the socio-economic effects such measures will have on mining, grazing, other 

multiple-use activities and local communities.

87. Page 12, Lands/Realty section indicates that rights-of-way (ROWs) should not be permitted in high priority sage-grouse 

habitat, with a few exceptions. The socio-economic impact of this conservation measure needs to be analyzed in the EIS. 

Restricting the new ROWs to be co-located entirely within an existing ROW is too restrictive (page 13, first bullet). The 

temporary, short-term use of a laydown yard or staging area that is too large to be co-located entirely within an existing 

ROW should not be sufficient reason for denying the use of the ROW. However, such short-term temporary use should be 

followed by reclamation to prevent non-native invasive species from establishing and re-establishing perennial vegetation.

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88. Under the Land Tenure Adjustment section (page 13) the conservation measure calls for retaining "public ownership of

priority sage-grouse habitat." I find this offensive as it implies only the government can benefit and manage sage-grouse. The 

record over the last 60 years in Nevada would not support that implication.

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89. Public lands ranchers own a significant portion of high-quality habitat as deeded property and that deeded property is 

managed and used in conjunction with public grazing permits for the mutual benefit of protecting sage-grouse habitat, 

populations and major risks. According to the USDA Natural Resources Conservation Service (NRCS), "[a]pproximately 40 

percent of sage-grouse habitat that supports populations occurs on privately owned lands." The continued viability of

livestock operations and beneficial role public land grazing plays and benefits sustainable livestock businesses needs to be 

emphasized in any national guidance.

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90. We sincerely hope the agencies will explore seasonal closures for defined, specific areas before resorting to widespread 

closures affecting thousands and perhaps millions of acres of land for extended periods of time. Many times, less is better if 

done in a targeted way

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91. Ideally, the agencies will designate areas of contiguous sage-grouse habitat not currently subject to valid existing rights for 

long-term or permanent protection. Where important sage-grouse habitat is subject to valid existing rights, the agencies can 

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increase the amount of protected priority habitat by aggressively pursuing available tools, including fluid mineral lease 

retirements, voluntary grazing permit retirement (where beneficial), mineral withdrawal, coal unsuitability findings, and 

mineral claim buyouts. These remaining refugia can provide the intact, diverse, high quality sagebrush habitat that is vital to 

sage-grouse and obligate species in the sagebrush ecosystem.

92. Our recommendations for management policies in sage-grouse habitat follow. Fully protect priority habitat from 

large-scale disturbances (e.g., transmission lines, oil and gas wells, graded roads, etc.), as well as any type of development that 

affects population distribution and abundance at any level. Direct development to areas with low conflicts with greater 

sage-grouse conservation. Direct new development to pre-disturbed areas. If priority habitat cannot be fully protected 

from energy development due to valid existing rights, minimize impacts by limiting permitted disturbances to one per section 

with no more than 3% surface disturbance. Ensure that small scale disturbances do not cumulatively disturb more than 3% 

of each priority area. Agencies should not issue new leases or right-of-way permits within any priority area that is not 

currently subject to valid existing rights. Increase and enhance the amount of protected priority habitat by aggressively 

pursuing available tools, including fluid mineral lease retirements, voluntary grazing permit retirement (where beneficial), 

mineral withdrawal, coal unsuitability findings, and mineral claim buyouts. In priority habitat, establish goals for enhancing 

habitat and building sage-grouse populations. In these identified areas, the agencies should work to reduce overall road 

densities, remove fences and enhance nesting cover, and take other steps y to improve habitat function. Establish priority 

habitat exclusion areas for new ROW permits.

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93. Clearly all forms of recreational users utilize roads, trails, campsites, facilities and other features/amenities on public lands. 

What is the purpose for singling out OHV use when, again, there is little if any scientific evidence that OHV recreation poses 

any more of a threat than other forms of recreation?

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94. Lastly, we cannot help but question a notice that caIls out OHV recreation as a preliminary threat to a species that warrants 

endangered species protection, but does not even mention that hunting of that species remains legal in some impacted 

states. If this species can be protected while it is being lawfuIly hunted we respectfuIly submit that it can be protected without 

wholesale closures of public lands to multiple uses.

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95. Multiple Use Mandate Both the major federal land management agencies engaged in developing the EIS, BLM and the Forest 

Service, have a statutory-based multiple use mandate that recognizes public lands are an important source of minerals. • 

BlM's Multiple Use Mandate Section 302 of the Federal land Policy and Management Act (FlPMA) provides that "[t]he 

Secretary shall manage the public lands under principles of multiple use and sustained yield." 42 U.S.C. § 1732(a). 

Furthermore, FlPMA requires management of the public lands "in a manner which recognizes the Nation's need for domestic 

sources of minerals." 43 U.S.C. § 1701 (11 )-(12). Similarly, BlM's 2006 Energy and Non-Energy Mineral Policy highlights the 

importance of mining on public lands and endorses "multiple use" as a guiding principle for land use management. The policy 

states BlM land use planning and multiple use management decisions will recognize that, with few exceptions, mineral 

exploration and development can occur concurrently or sequentially with other resource uses and further indicates that the 

least restrictive stipulations that effectively accomplish the resource objectives or uses will be used. See BlM 2006 policy at 

p. 2 • Forest Service's Multiple Use Mandate Congress established the national forest system through the OrganiC 

Administration Act of 1897, 30 Stat. 11 (June 4, 1897). By operation of the Transfer Act of 1905, 33 Stat 628 (February 1, 

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1905), stewardship of the national forests was transferred from the Department of the Interior to the Department of 

Agriculture. There followed over the ensuing decades a series of enactments in which Congress consistently and clearly 

specified that stewardship over the national forests would be guided by the principles of multiple use and sustained yield, i.e., 

the Multiple Use Sustained Yield Act of 1960, 16 U.S.C.§§ 528-31 (MUSYA); the Forest and Rangeland Renewable Resources 

Planning Act of 1974,16 U.S.C. §§1600-14; and the National Forest Management Act of 1976 (NFMA), 16 U.S.C. § 1600 et 

seq. These statutes consistently endorse multiple use and sustained yield. Specifically, section 4 of the MUYSA defines 

"multiple use" as: the management of all the various renewable surface resources of the national forests so that they are 

utilized in the combination that will best meet the needs of the American people; making the most judicious use of the land 

for some or all of these resources or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use to conform to changing needs and conditions; that some land will be used for less than all of the 

resources; and harmonious and coordinated management of the various resources, each with the other, without impairment 

of the productivity of the land, with consideration being given to the relative values of the various resources, and not 

necessarily the combination of uses that will give the greatest dollar return or the greatest unit output. 16 U.S.C. § 531 . As 

appropriately concluded by the U.S. Court of Appeals for the Seventh Circuit, the Forest Service does not have the 

discretion to ignore that mandate to focus solely on environmental and recreational resources. That court held, "the national 

forests, unlike national parks, are not wholly dedicated to recreational and environmental values." Cronin v. United States 

Department of Agriculture, 919 F.2d 439, 444 (7th Cir. 1990).

96. o Discretion to Delay Approvals The IM provides that field offices retain the discretion to reject, deny or defer approvals for 

proposed activities, such as mineral leasing or rights of ways, in preliminary priority habitat areas. BLM offices are already 

deferring major projects based on the IM provisions.1 NMA believes it is procedurally incorrect to delay projects for two 

years while RMPs are revised to reflect new conservation measures for sage grouse. Sage grouse need to be addressed 

through the National Environmental Policy Act process for proposed projects and conservation measures incorporated into 

issued permits.

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97. History demonstrates throughout the west that, in many resource arenas, a decision to restrict access to federal lands for 

various reasons, simply leads to further use and development of the resource on state and private lands

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98. Furthermore, in its Warranted but Precluded decision FWS identified power lines as directly affecting greater sage-grouse 

and outlined the possible threats: collision and electrocution hazard; decrease in lek recruitment; increase in predation; 

fragmentation of habitat; and facilitation of the invasion of exotic annual plants. Additionally, sage-grouse could be impacted 

through a direct loss of habitat and human activity (especially during construction periods). Transmission corridors pose a 

serious threat to the wide ranging sage-grouse and should be analyzed thoroughly in this process. The impacts of 

fragmentation from transmission lines and the tendency of greater sage-grouse to avoid large infrastructure like power lines 

should lead to the establishment of strong standards that guide transmission corridors to appropriate areas that avoid 

impacts to sage-grouse.

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99. Furthermore, in its Warranted but Precluded decision FWS identified power lines as directly affecting greater sage-grouse 

and outlined the possible threats: collision and electrocution hazard; decrease in lek recruitment; increase in predation; 

fragmentation of habitat; and facilitation of the invasion of exotic annual plants. Additionally, sage-grouse could be impacted 

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through a direct loss of habitat and human activity (especially during construction periods). Transmission corridors pose a 

serious threat to the wide ranging sage-grouse and should be analyzed thoroughly in this process. The impacts of 

fragmentation from transmission lines and the tendency of greater sage-grouse to avoid large infrastructure like power lines 

should lead to the establishment of strong standards that guide transmission corridors to appropriate areas that avoid 

impacts to sage-grouse.

100. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: - The 

placement of energy corridors and associated facilities may lead to negative impacts to greater sage grouse and their habitats.

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101. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: - Placement, 

use, construction, and maintenance of roads and railroads in greater sage grouse habitat may lead to negative impacts

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102. Wind and Transmission Inside Core Areas • No wind energy development • Transmission lines should be buried 

underground or limited to existing electrical transmission corridors of • mile maximum width. Outside Core Areas • Wind 

farms and transmission lines sited at least 5 miles from active sage grouse leks and at least 3 miles from identified winter 

habitats. • Transmission lines allowed along existing electrical transmission corridors of ... mile maximum width.

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103. At minimum, the NEPA analysis should address the following: • Excluding transmission lines from Core Areas, pursuant to 

the new BLM nationwide sage grouse IM.

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104. C. Renewable Energy Development on Federal Public Lands is an Appropriate and Accepted Land Use under the 

Multiple-Use Mandates Renewable energy is unquestionably among the diverse multiple uses that Congress intended for 

the public lands. Not only are renewable energy sources, like wind, a "renewable resource" as mentioned directly in the 

definition of "multiple use" under FLPMA and NFMA,37 but they are also an appropriate use of public lands explicitly 

envisioned by Congress. In the Energy Policy Act of 2005, Congress called for approval of non-hydropower renewable 

energy projects located on the public lands with a generation capacity of at least 10,000 megawatts of electricity within ten

years of the enactment of the Act.38 Furthermore, on May 18, 2001, President Bush issued Executive Order (E.O.) 13212, 

"Actions to Expedite Energy-Related Projects," establishing the policy that federal agencies should take appropriate actions, 

consistent with applicable law, to expedite projects to increase the production, transmission, or conservation of energy.

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105. Renewable energy development thus is an appropriate use of the federal public lands pursuant to the multiple-use and 

sustainable-yield mandates under FLPMA and NFMA. Nevertheless, the new sage-grouse management policy substantially 

limits opportunities for renewable energy growth given the limitation of all discrete anthropogenic disturbances on just 3 

percent of sage-grouse habitat across all land ownerships. This means that the renewable energy industry will have to 

compete with all other sources of anthropogenic disturbance for access to 3 percent or less of federal public lands containing 

sage-grouse habitat and, in some cases, this threshold may likely already have been met; in other words, no new uses may 

occur beyond what already exists in the landscape today.

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106. V. BLM Lacks the Authority under FLPMA and its Special Status Species Manual to Amend the Procedures for Obtaining a 

ROW Without Engaging in a Rulemaking BLM uses several sets of regulations to implement FLPMA and other laws. Most 

of the regulations that may affect BLM management guidance concerning sage-grouse management are found in section 43 of 

the Code of Federal Regulations, although some, such as the Council of Environmental Quality regulations, are found in 

other portions of the CFR. The relevant regulations are listed below: • 43 C.F.R. Subpart C, Minerals Management 3000 

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Series, contains regulatory authority for BLM operations, enforcement and reclamation of minerals actions on public lands. 

• 43 C.F.R. Subpart 4120, Grazing Management, contains the regulatory authority for grazing administration, use 

authorizations, permit terms and conditions for achieving resource condition objectives. Subparts 4140-4170 outline 

prohibited acts, enforcement, and penalties. Subpart 4180 is an example of how regulations provide direction for 

sage-grouse conservation. Within the scope of these grazing regulations, 43 CFR 4180.2(d), are included specific direction to 

the BLM State Directors to develop standards that among other things would address: o “(4) Habitat for endangered, 

threatened, proposed, candidate, or special status species; and; (5) Habitat quality for native plant and animal populations and 

communities...” In addition, Subpart 4180.2(e) requires development of guidelines to address: o “(9) Restoring, 

maintaining or enhancing habitats of Federal proposed, Federal candidate, and other special status species to promote their 

conservation.” These regulations, however, pertain to mineral management and grazing, not BLM’s consideration of ROWs 

for energy development. Therefore, these provisions cannot be relied upon to justify BLM’s authority to issue the IMs with 

respect to wind energy development, without going through notice and comment. While FLPMA does give BLM discretion 

to deny ROWs for renewable energy development based on the public interest, it does not provide a general definition of 

“public interest,”43 nor does it define the term within the ROW context. Rather, the statute provides some guidance when 

discussing the consideration of a ROW application, however. Under FLPMA, when determining whether an exchange of land 

is in the public interest, the Secretary must “[g]ive full consideration to better Federal land management and the needs of 

State and local people, including needs for lands for the economy, community expansion, recreation areas, food, fiber, 

minerals, and fish and wildlife. . . .”44 The terms and conditions that each ROW must contain also provide additional 

guidance as to what Congress meant when it directed BLM to consider the “public interest.” FLPMA directs BLM to include 

terms and conditions that “minimize damage to scenic and esthetic values and fish and wildlife habitat and otherwise protect 

the environment.”45 The statute also directs the Secretary to require such terms and conditions as he or she deems 

necessary to “protect Federal property and economic interests.”46 As these requirements illustrate, what constitutes the 

public interest requires a balancing of multiple factors. To balance these factors, BLM has promulgated regulations, which 

state: It is BLM’s objective to grant rights-of-way . . . to any qualified individual, business, or government entity and to direct 

and control the use of rights-of-way on public lands in a manner that: (a) Protects the natural resources associated with 

public lands and adjacent lands . . . ; (b) Prevents unnecessary or undue degradation to public lands; (c) Promotes the use of 

rights-of-way in common considering engineering and technological compatibility, national security, and land use plans; and 

(d) Coordinates . . . all BLM actions . . . with state and local governments, interested individuals, and appropriate quasi-public 

entities.47 BLM’s discretionary ability to apply such terms and conditions pertains even after a ROW has been granted.48 

The agency’s discretion is limited in that the “stipulations [may not be] either inconsistent with or tend to unreasonably 

encumber the proposed . . . project[].”49 For instance, in Shell Pipe Line Corp., BLM granted Shell a ROW that was 

subject to review after 20 years. Shell’s argument that FLPMA did not grant BLM broad enough authority to modify or revise 

a ROW once granted was rejected by the Interior Board of Land Appeals (IBLA).50 The IBLA concluded that “clear[ly] . . . 

BLM may grant the right-of-way upon certain terms, conditions, and stipulations,” reasoning that the agency must “balance 

the interests of right-of-way applicants with other interests requiring consideration.”51 In another case, the IBLA noted that 

the stipulations imposed could not be unreasonably burdensome, but found that stipulations requiring prevention of water 
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pollution and protection of fish did not impose an unreasonable burden.52 AWEA thus recognize that BLM has relatively 

broad discretionary authority to deny a ROW. In particular, the agency also has the statutory authority to impose terms and 

conditions on an application before it is approved as well the authority to modify the terms and conditions after approval. 

And, these modifications may include mitigating impacts to the environment. The scope of these modifications is limited, 

however, and there is nothing in the statute that allows an outright revocation of permit for any of the reasons specified in 

the IMs and the NTT Report. Moreover, the statute does not allow the type of generic limitations adopted in these 

documents, such as the 3 percent exclusion area, but rather permits terms and conditions to be imposed on an

application-by-application basis. Therefore, as the IMs add a substantive requirement to BLM’s existing authority under 

FLPMA and limit BLM’s existing discretionary authority under that act, BLM was required to follow the APA’s 

notice-and-comment procedures before making them effective. BLM also appears to justify its new procedures for 

considering ROW applications based on its policy set forth in a guidance document, the Special Status Species Management 

Manual (Special Species Manual).53 For instance, in the March 2010 IM, BLM states that “greater sage-grouse are BLM 

sensitive species that are to be managed to promote their conservation and to minimize the need for listing under the ESA, 

in accordance with the BLM’s special status species policy.”54 The Special Species Manual aims “to provide policy and 

guidance, consistent with appropriate laws, for the conservation of special status species of plants and animals, and the 

ecosystems upon which they depend.”55 While the sage-grouse’s “warranted but precluded” status falls within the bounds 

of the manual’s ambit, the manual is merely an agency guidance document that cannot trump the duties imposed by the 

BLM’s own organic statute—FLPMA. As discussed, BLM public lands must be managed “on the basis of multiple use and 

sustained yield unless otherwise specified by law”56 and a guidance document cannot alter that statutory mandate. The 

Special Species Manual itself requires that its guidance be applied so as to be “consistent with appropriate laws,” further 

affirming that the BLM cannot rely on this policy statement as a means of ignoring its directive to manage public lands for a 

myriad of beneficial land uses. In other words, BLM cannot rely on its own agency guidance document to elevate 

single-species management above its statutorily imposed duty to promote multiple uses.

107. We concur that it is preferable to co-locate corridors whenever possible, however, the proposed exclusion of new 

corridors and the "undesignation" of corridors in sage grouse priority habitat, along with avoidance in areas of general 

habitat, virtually eliminates any new development except along existing ROWs. This proposed conservation measure does 

not take into account that all ROW corridors cannot be assumed to have an equal impact on sage grouse (i.e. infrastructure 

that is buried vs. on the surface) and therefore, should not be treated as having the same impact on local sage grouse 

populations. Nor does it take into account technological improvements that can reduce impacts in ROWs. A more effective 

and efficient strategy for sage grouse and industry would seek to minimize impacts in ROWs and utilize tradeoffs to minimize 

or eliminate impacts of existing infrastructure /ROWs as part of the mitigation for new ROW use.

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108. BLM and Forest lands should not be expected to provide all needed sage-grouse habitat to meet such benchmarks. Private, 

state and tribal lands contribute a good share of sage-grouse habitat now and will continue to do so in the future. The State 

of Utah, in consultation with Uintah County, and private land owners have taken great strides to enhance sage-grouse habitat 

in the Diamond Mountain area, recognizing that this is not a marginal or insupportably small sage-grouse population.

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109. While the BLM’s IM allows for the ongoing operation of existing facilities, it seems to place impediments in the way of access All Both emc0378GB
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to those facilities. Problematic is the recommendation that additional mitigation might be required for existing access roads

and/or previously authorized access ROWs that might not have been constructed or improved to-date, if this improvement 

would exceed the proposed three percent disturbance threshold. The ability of electricity providers to safely 

access/maintain existing electrical facilities is crucial to reliability of the Western grid.

110. I believe that habitat plans should be site specific and not a state wide blanketed plan. We have already have had and are in

the middle of Sage Grouse habitat vegetation projects on public and private lands in our allotment and county. A lot of 

private land in this area has some preferred use for Sage Grouse, taking livestock off the public range will result in over use 

of the private which in some areas more preferred to the Sage Grouse.

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111. We strongly encourage the agencies to prioritize their focus on public land use, or disuse, which poses a real threat to the 

greater sage-grouse and its habitat

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112. Preserving access to lands, both public and private, for those users without unnecessary restrictions due to the potential 

listing of a species with such a large habitat fosters this stewardship.

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113. The Interim Management IM provides that BLM when renewing or amending ROWs, assess the impacts of ongoing use of the 

ROW to greater sage-grouse habitat and minimize such impacts to the extent allowed by law. This would seem a clear 

violation ofBLM's multiple use mandate which provides for the multiple use and sustained yield of the public lands. 

Presumably the project has already undergone environmental analysis as required under NEPA, and the BLM has already 

considered its purpose and need and the ROW grant holder's interest and objectives in issuing a ROD or Finding of No 

Significant Impact. If minimization of impacts to greater sagegrouse results in the diminishment ofthe valid, existing rights of 

the ROW grant holder or is contrary to the grant holder's interest and objectives, then it would seem the BLM has acted

arbitrarily and capriciously.

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114. BLM's RMP revisions should consider the valid, existing rights of the ROW grant holder, as well as the grant holder's interest 

and objectives, when renewing or amending existing ROW grants to minimize impacts to greater sage-grouse and greater 

sage-grouse habitat.

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115. In reviewing RO W applications, BLM must follow the CEQ regulations and consider a range of reasonable alternatives 

appropriate to BLM's purpose and need and the applicant's interest and objectives, and not engage in single species 

management. This fundamental NEP A principle should be incorporated into BLM's land use decision making process.

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116. However, many regions within the area encompassed by the proposed EIS's may not have sufficient private land (of the

quality and size necessary) to meet all the mitigation needs for projects or activities on BLM or USFS-administered lands. 

Thus compensatory off-site mitigation actions are frequently proposed for public lands, e.g. enhanced conservation 

management, restoration, or additional protections, in lieu of private land acquisition.

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117. Likewise we also believe that all other uses on our public lands need not be curtailed as adequate planning can mitigate and 

in some cases promote the habitat that is conducive to Sage Grouse use and preservation.

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118. Is BLM just using public lands to fuel energy developer speculation schemes and exploration disturbance - and promoting the 

parties obtaining leases potentially bilking investors? Or is there a real threat of Oil and Gas? Detailed mapping of oil and gas 

leases, geothermal leases, wind and solar rights-of-ways and other leases/rows must be provided, so these questions can be 

answered. So must a map of mine claims. See: 

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http://www.blm.gov/nv/st/en/info/newsroom/2012/march/nevada_state_office0.html. This was met by County 

Commissioners with anger. 

Http://elkodaily.com/news/local/sage-grousecause-of-delay-for-oil-gas-leases/article_180cf38c-6a09-11e1-8325-0019bb296

3f4.html#.T2YYZY79o6E

119. It is essential that all ongoing activities, all leases /ROWs already issued - all get reviewed, altered, changed, amended and/or 

terminated where conflicts are identified with habitats in the interim and immediately upon completion of this process. 

Existing leases, rights-of-way, etc. must be immediately amended to at least comply with the terms of IMs that must be 

greatly strengthened and that should not be based on segregating habitat. This can be readily done. Simply overlay the land 

records of leases, rights-of-way, grazing permits, etc. with mapped habitats, and inform the lease/permit holder of new 

protective provisions.

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120. Another BMP is: "Place new utility developments, power lines, pipelines, etc. - and transportation routes in existing utility or 

transportation corridors." This is the same BMP that BLM has been using for decades, and that the agency routinely ignores. 

BLM violates this BMP all the time. This is continuing - for example with Gateway EIS proposed routes added by BLM in Idaho 

on the Nevada border and along the northern and other areas of the South Hills. These areas contain important sage-grouse 

habitats. Why did the public suffer through the Westwide Energy Corridor DOE EIS process -when just about every 

developer that comes along seeks a different gas pipeline or electric transmission line route, and BLM obliges them and 

accommodates this? Such bundling of new developments into existing developed corridors must be mandatory - not just a 

"BMP" readily cast aside.

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121. The section “Calculating the Density of Disturbance within Key Habitat” describes conducting an “additional site-specific 

analysis of disturbance” after alternatives and a preferred alternative have been selected. Intensive site-specific information 

needs to be collected and analyzed to guide the development of alternatives and a Preferred Alternative before putting out 

a DEIS. This has not been done. Several potential route segments that BLM is allowing to be put forward are the dead 

opposite of col-locating or bundling lines.

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122. Only by requiring the strongest protective measures when considering new development proposals in sage-grouse habitat 

will you be able to ensure survival of this spectacular species. To that end, I ask that you require the following conservation 

measures in the relevant Resource Management Plans and Land Management Plans. - Prohibit conversion of sagebrush 

habitat to any other use within priority sage-grouse habitat.

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123. It is also necessary that the preferred alternative explicitly recognize the key importance of public lands ranching operations 

to the success of sage-grouse conservation. Scientific research has repeatedly shown that properly managed grazing is 

beneficial to the greater sage-grouse and to a host of other wildlife species. Well-managed grazing can improve sage-grouse 

habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and also aids in the control of 

invasive plant species. Moreover, public lands ranchers own a significant portion of high-quality lowland brood rearing habitat 

as deeded property. According to NRCS, “[a]pproximately 40 percent of sage-grouse habitat that supports populations 

occurs on privately owned lands. However, if regulatory measures on public lands make ranching operations economically 

unsustainable, these operations are frequently subject to sale and development, leading to fragmentation and loss of key 

habitat. It is therefore essential that the preferred alternative incorporates explicit steps to ensure that sage-grouse 

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conservation measures do not undermine the viability of public lands ranches.

124. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations.

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125. Direct right-of-way permits (e.g. for transmission lines) to areas outside of priority habitat All BLM fln0000rm

126. is critical for BLM to consider implementing the following technical team recommendations as minimum standards: Use 

available tools to increase the amount of protected habitat (e.g. retiring oil and gas leases, buying out mineral claims

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127. The Conservation Measures provide the following objectives for the management of sage-grouse habitat: II To maintain or 

increase current populations, manage or restore priority areas so that at least 70% of the land cover provides adequate 

sagebrush habitat to meet sage-grouse needs ..... Manage priority sage-grouse habitats so that discrete anthropogenic

disturbances cover less than 3% of the total sage-grouse habitat regardless of ownership. Anthropogenic features include but 

are not limited to paved highways, graded gravel roads, transmission lines, substations, wind turbines, oil and gas wells, 

geothermal wells and associated facilities, pipelines, landfills, homes, and mines. In priority habitats where the 3% disturbance 

threshold is already exceeded from any source, no further anthropogenic disturbances will be permitted by BLM until 

enough habitat has been restored to maintain the area under this threshold (subject to valid existing rights). While this 

standard is acceptable in theory, implementation of these standards on the ground will be problematic. Land managers will 

be forced to restrict activities that have been found to have little to no impact on the grouse in the FWS listing decision, in 

an attempt to achieve compliance with the standard. This is not good management and will directly impair public support for 

any initiative.

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128. The proposed EIS should identify the actual acreage of land that industry occupies (by type of industry) vs. the amount of land 

designated as sage grouse habitat. Due to the small fraction of land occupied by industry, industry should not be restricted 

in areas designated as sage grouse habitat (whether it's critical or general habitat). Restrictions placed on industry should be 

equivalent to the percentage of habitat that they occupy.

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129. The EIS identifies the BLM/FS land manager and Local Implementation Group that will determine the direction of 

Management. The Local Implementation group will apparently be made up BLM/FS and "Land Owners".

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130. As proposed in the EIS, the local implementation team (landowners) is by nature EXCLUSIVE. All Both rmc0036GB

131. Will it be possible for a land owner, to cultivate the private land in a way not compatible with the EIS plan, say for production 

of high protein alfalfa for overseas export; while grazing cattle in another county on their allotment and still be EXEMPT? An 

example would be the ZX Ranch in Lake County. In general it is very poor policy indeed that begins by arbitrarily 

EXEMPTING some activity from a holistic Mitigation Plan. I recommend the grazing operation exemption either be 

eliminated from the EIS; or all mining and permitting operations and recreation modes not identified in the EIS be exempted 

from the Mitigation Plan as well.

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132. There are competing pressures for use of public lands. The Proposed Planning Strategy is one of several that cumulatively 

have a negative impact on the public's ability to partake in recreational opportunities on public lands. The Proposed Planning 

Strategy should adequately evaluate and mitigate the cumulative losses of land for recreational opportunities, including but 

All Both rmc0061GB, 

rmc0035RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1221

Scoping Summary Report

Table C-11.A

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Comment 

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not limited to cumulative closures or limitations on public lands managed by Bureau of Land Management, the U.S. Forest 

Service, and other federal agencies.

133. The interdependence of private and public lands, especially BLM, but in some instances, Forest Service is a major issue. In 

Shoshone Basin and other areas, sage-grouse habitat includes a mixture of BLM and private lands. Management decisions 

affecting BLM or Forest Service lands can directly impact management options and land uses on associated private lands. 

Frequently, private lands make up a majority of acres within a BLM, grazing allotment. Because private components often 

originated through Homesteads, water rights and associated springs and wet meadows critical to sage grouse are mostly 

located on private lands. Private lands usually include the deeper, more productive soils with greater potential for favorable 

responses to habitat management.

All Both rmc0063GB

134. The Meeker/White River and Parachute Piceance/Roan populations (Colorado Plateau MZ) are in the Uintah-Piceance 

geologic basin. These populations are small and isolated, and are threatened by demographic, genetic and environmental 

stochasticity due to small size and isolation. In addition, these populations are threatened by a suite of deterministic threats, 

including: housing and energy development, predation, disease, and conifer invasion. Based on projected habitat impacts 

(particularly energy development) under current management prescriptions, the FWS believes that all of the populations in 

the Colorado Plateau MZ will be reduced in size and isolated in the future.

CO BLM emc0070RM

135. Each alternative should designate areas of contiguous sage-grouse habitat, not currently subject to mineral leases or other 

valid existing rights for permanent protection. These remaining refugia can provide intact, diverse, high quality sagebrush 

habitat, vital to sage-grouse and other sagebrush obligate species. Colorado BLM should identify contiguous areas of habitat 

that are not subject to valid existing rights in Colorado and set these areas aside from development, in all alternatives 

(Wyoming BLM proposed a similar action in Instruction Memorandum WY-2010-013).26 Colorado BLM could identify a 

minimum size for a contiguous area that should be set-aside from development, such that set-aside areas are large enough to 

be used by greater sage-grouse. This should be done in consultation with Colorado Parks and Wildlife and U.S. Fish and 

Wildlife Service. Colorado has relatively small and fragmented populations, and few large contiguous areas that are not 

developed or subject to valid existing rights. In Colorado, it may be necessary to set all areas not subject to valid existing

rights aside from development, in order to conserve small isolated populations and provide refugia adjacent to areas likely to 

be developed. These identified, contiguous areas of undeveloped land should be considered for designation as Areas of 

Critical Environmental Concern in all alternatives. (See Section 8 on ACECs for further discussion). The plan amendment 

should ensure that ACECs will be managed appropriately.

CO BLM emc0070RM

136. In addition, each plan should preserve options to set areas that are currently subject to valid existing rights, but not 

intensively developed, aside from future development. All alternatives should include this provision in areas of contiguous 

priority habitat that have not yet been intensively developed. For example, all alternatives in each plan should specify that, 

when valid existing rights in contiguous priority habitat areas that are not intensely developed, expire (e.g. existing oil and gas 

leases), these areas will be set-aside from future development. This is especially important in areas where a substantial 

proportion of the priority habitat is under valid existing rights.

CO BLM emc0070RM

137. Recommendations: All action alternatives must include adequate baseline protections, including the following: 1) limit 

development to areas which have low conflicts with sage-grouse conservation, 2) full, permanent protections for contiguous, 

CO BLM emc0070RM
C. Comments by Resource Planning Issue

C-1222 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

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undeveloped priority habitat, 3) strong protections for other key habitat if some development might be allowed, 4) designate 

Areas of Critical Environmental Concern and provide assurances that they will be managed appropriately, 6) preserve 

options to set priority habitat currently under valid existing rights aside from development in the future, 7) address any 

concerns stated by CPW and FWS in their comments on the current or draft preferred alternative in each plan, and 7) 

provide scientifically valid protections for priority and general habitat and linkages. All alternatives should advance 

sage-grouse conservation and establish a comprehensive regulatory framework to prevent the need to list the greater 

sage-grouse under the ESA.

138. The following recommendations must be analyzed as a starting point for effective conservation: Establish priority habitat 

exclusion areas for new ROW permits.

CO BLM emc0070RM

139. (One of the NTT recommendations most important for Routt NF) Make general sage‐grouse habitat areas "avoidance areas" 

for new rights-of-way. Id. at 13.

CO USFS emc0175RM

140. It is critical for BLM to consider implementing the following technical team recommendations as minimum standards: Direct 

right-of-way permits (e.g. for transmission lines) to areas outside of priority habitat

CO BLM fll0000RM

141. is critical for BLM to consider implementing the following technical team recommendations as minimum standards: Use 

available tools to increase the amount of protected habitat (e.g. retiring oil and gas leases, buying out mineral claims

CO BLM flm0000RM

142. Direct right-of-way permits (e.g. for transmission lines) to areas outside of priority habitat. CO Both flm0000RM

143. As you may be aware, the Colorado State Land Board owns approximately I 80,000 surface and subsurface acres of Public 

School Trust lands within Moffat County, much of which may be impacted by this decision. These School Trust Lands were 

granted to the State of Colorado by the United State Congress and pursuant to the Colorado Enabling Act of 1875 and the 

Colorado Constitution, they are managed for the long-term benefit of Colorado's public schools. As the entity entrusted 

with the responsibility to manage these lands, the Colorado State Land Board needs to have the ability to manage the trust 

assets in a manner that allows it to meet its ficuciary obligations. (Note, attachment to letter- map)

CO Both rmc0050RM

144. The protection of prior existing rights and the rights of ingress and egress to State Trust lands for both surface uses and 

development of the mineral estate as currently stated in the Little Snake RYlP need to be considered in the process.

CO Both rmc0050RM

145. i. Lander, WY RMP The establishment of ROW corridors, similar to the Designated Development Areas in Alternative D, 

would ensure that major ROWs occurred in areas of existing disturbance to the greatest extent possible. We also support 

co-locating communication facilities with existing sites to reduce new ground disturbances and cluster vertical disturbances. 

Reducing the number, size, and extent of disturbances would reduce habitat loss and fragmentation, maintain habitat

connectivity, and ensure that large patches of habitat are available for greater sage-grouse (DEIS at 881-882).

East Both emc0089RM

146. Each alternative should designate areas of contiguous sage-grouse habitat not currently subject to mineral leases or other 

valid existing rights for permanent protection. These remaining refugia can provide intact, diverse, high quality sagebrush 

habitat, vital to sage-grouse and other sagebrush obligate species. In Instruction Memorandum WY-2010-013, the Wyoming 

BLM proposed 11 contiguous square miles or sections as an appropriate minimum size for an area of habitat to qualify for 

being set-aside from development.6 The Wyoming BLM recognized these large unleased contiguous blocks as opportunities 

for grouse conservation. This number should be scaled to allow for protecting smaller contiguous areas in states with smaller 

East Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1223

Scoping Summary Report

Table C-11.A

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populations than Wyoming’s, or in areas where there are few remaining contiguous 11-square-mile areas that are not 

subject to valid existing rights. These identified, contiguous areas of undeveloped land should be considered for 

designation as Areas of Critical Environmental Concern in all alternatives. (See Section 8 on ACECs for further discussion)

147. The following recommendations must be analyzed as a starting point for effective conservation: Establish priority habitat 

exclusion areas for new ROW permits.

East Both emc0089RM

148. iii. Strong components of Wyoming’s approach Within core areas, stipulations on BLM, FS, Wind River Indian Reservation, 

and State of Wyoming lands limit the number of projects and the amount of allowed disturbance (no more than 5%13) 

allowed per square mile or 640 acres. Surface disturbance is prohibited within a 0.6 mile buffer around active leks (no surface 

occupancy - NSO), which includes roads during the breeding, nesting and brood-rearing periods (mid-March through end of 

June). In addition, a March 15 to June 30 timing limitation stipulation is required within nesting habitat within 4 miles of leks. 

Main roads used to transport production and/or waste products must be more than 1.9 miles from the perimeter of 

occupied grouse leks. Other roads used for access or maintenance must be more than 0.6 miles from the perimeter of 

occupied leks. Noise levels at the perimeter of a lek should not exceed 10 dBA above ambient noise from 6 pm to 8 am, so 

as not to disturb breeding activities (March 1 - May 15). Finally, proponents of new projects are expected to coordinate with 

the permitting agency and WGFD biologists to determine which leks need to be monitored and what data should be 

collected/reported. The Executive Order clearly identifies thresholds and outline adaptive management responses if declines 

in sage-grouse numbers occur14. However, in non-core areas, the EO recommends a 2-mile seasonal buffer around 

occupied leks and a 0.25 mile NSO buffer around active leks. Research has shown that the latter stipulation is inadequate and 

scientifically without merit. In addition, a surface disturbance cap is lacking from non-core area stipulations

East Both emc0089RM

149. iii. Strong components of Wyoming’s approach For transmission lines, 2-mile wide transmission corridors have been 

identified in an effort to collocate disturbances. Construction is prohibited between March 15 and June 30 (or between

December 1 and June 30 in winter concentration areas) and within 0.5 miles on either side of the existing transmission lines. 

If new lines are proposed for core area, they must be either buried or outfitted with raptor per deterrents to minimize avian 

predation pressure on sage-grouse.

East Both emc0089RM

150. Overall, maintaining migration corridors and habitat connectivity across jurisdictional boundaries (including state lines) will 

play an essential role in successful conservation strategies. Care must be taken to ensure that each proposed ROW project 

is informed by adequate site-specific impacts analysis including cumulative impacts of multiple lines and current information

on habitat and other ecological values.

East Both emc0089RM

151. Recommendation: The BLM and FS should use range-wide planning as an opportunity to provide input on how zoning could 

help direct both wind turbines and transmission away from sage-grouse and other sensitive wildlife habitats, including 

designating zones and/or providing detailed guidelines for designation.

East Both emc0089RM

152. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations.

GB Both emc0304GB

153. The EIS and SEIS revisions should clarify that multiple-use management concepts should be used to reduce the risk of 

catastrophic wildfire, improve forage, remove invasive species and provide open space. We strongly encourage the agencies 

GB Both rmc0056GB
C. Comments by Resource Planning Issue

C-1224 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

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to prioritize their focus on public land use, or disuse, which poses a real threat to the greater sage-grouse and its habitat.

154. Further, we believe that each industry, indeed each project, should bear the cost of the mitigation it requires. Conversely, 

each industry or project that improves habitat or increases population should be rewarded with additional opportunities to 

utilize resources. For example, if a developer plans to construct wind turbine generation which will negatively impact the 

sage grouse population, those impacts could be offset by the concurrent construction of a bio-fuels generation facility which 

utilizes sustainable pinyon and juniper harvesting. In contrast, a proposed project should not be permitted to offset its 

impacts by eliminating another existing use unless the affected user is justly compensated. For instance, mitigation measures 

for a wind farm should not include relocation of an existing power line unless the wind farm developer absorbs the 

construction costs of the new line, including permitting and design, and demolition costs of the existing line.

GB Both rmc0056GB

155. The NOI states, "The RMP and LMP amendments/revisions will recognize valid existing rights." We concur that revisions to 

RMPs and LMPs must recognize valid existing rights.

GB Both rmc0056GB

156. Scheduling or restricting the timing of multiple-use activities should be flexible to account for unusual weather conditions or 

variations in sage grouse occupancy. Adherence to rigid dates or times of day should be tempered by on-the-ground 

observations and monitoring.

GB Both rmc0056GB

157. Land acquisition (private to federal) is often mentioned as one approach to conserving sage grouse (and other sensitive 

species). This should not be a goal in counties that are predominately public lands and federally administered. Further 

increases in public lands severely limits economic opportunity and many rural counties cannot survive with additional limits 

imposed on their potential for economic growth.

GB Both rmc0067gb

158. If we have a viable population, then remove Lemhi County from the designated area completely IDMT Both emc0045GB

159. Clark County is 75% publicly owned. If we allow an animal to shut down the use of that public owned property, it could mean 

the shutting down of our county and it's residents. Scientists seem to keep doing studies on wildlife in the area without the 

input of the residents, especially those who have lived here all their lives and know the patterns and cycles of the animals 

better than the scientist who passes through for a few months in a certain year. We as residents have also witnessed that 

these scientists re-invent the wheel every time they do a study, never communicating the last study. How sound of science 

is that?

IDMT Both emc0128GB

160. The Group has developed a sage-grouse conservation plan for Jarbidge Planning Area, which includes the goals outlined 

below. We ask that the BLM consider these goals as they finalize the Sage-Grouse Planning Strategy. -Encourage cooperation 

between private, State, and Federal landowners

IDMT Both emc0158GB

161. I am writing to show my support for permanently withdrawing the remaining land parcels in Nye County that are being 

considered for lease options to oil and gas companies.

NVCA Both emc0019GB

162. The Churchill County Board of County Commissioners passed a resolution in December 2011, adopting the "Policy Plan for 

Public Lands" (Plan) of the Churchill County Master Plan. The Plan is a guide, developed by the citizens and local government 

regarding the use of public lands in Churchill County. The Plan addresses federal land use management issues and is intended 

to be used as a positive guide for federal land management agencies in their development and implementation of federal land 

plans and management actions. The Plan outlines expectations and desires of the people of Churchill County and requires 

NVCA Both emc0151GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1225

Scoping Summary Report

Table C-11.A

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consultation prior to decisions that affect public lands within the County's boundaries. Churchill County is desirous of 

cooperation from the Bureau of Land Management and other federal agencies. If the U.S. government (under any agency) 

intends to change uses or availability of resources on public lands in a way that will impact current historical and cultural uses, 

input from the citizens of the County is required and the Board of County Commissioners will be consulted. The multi-use 

nature of public lands requires that management decisions be made with the public's interest at the forefront and careful 

consideration to maintaining a sustainable economy and sustainable resources for future generations.

163. lands/realty: Agencies' conservation measures must be robust to address one of the two greatest threats identified for Sage 

Grouse and its sagebrush habitat - habitat loss, degradation and fragmentation, many of which have occurred because of the 

agencies lands and realty programs. The Ruby gas pipeline, which cut through over 300 miles of remote relatively intact 

sagebrush habitat from the Utah border to the California/Oregon border, is the poster child of what not to do for Sage 

Grouse conservation in Nevada. A map shows the pipeline route selected by the project proponent which appears to 

maximize adverse impacts on Sage Grouse leks and other priority habitats in Nevada and other western states. The ROW 

was approved despite the substantial impacts to Sage Grouse and its habitat and the pollyanna promises of mitigation and 

restoration. Required mitigation has failed to reclaim pipeline construction impacts and this huge swath of now fragmented 

Nevada's sagebrush country is covered with weeds.

NVCA Both emc0283GB

164. The worst potential example of habitat destruction and fragmentation and lack of regulatory controls - the Clark, Lincoln, 

and White Pine Counties Groundwater Development Project, proposed by the Southern Nevada Water Authority, has 

been examined in a draft EIS, but has not yet been approved by the BLM. While the EIS did disclose general impacts on 

wildlife, the approach which the BLM used did not result in specific information on how many acres of Sage Grouse habitat 

would be lost, degraded or fragmented by the proposal. Likewise, BLM's "regulatory" authority did not extend to requiring 

avoidance or minimization of, or compensation for, severe adverse impacts to Sage Grouse and its habitat, just some BMPs 

for pipeline construction and operation impacts,. Instead, it appears that the BLM is going to accept voluntary mitigation 

proposed (promised) by the ROW proponent for the massive adverse impacts of the groundwater mining and exportation 

proposal. These impacts include dropping of water tables, drying springs, creeks, and wet meadows or subsidence on public 

lands critical for Sage Grouse and priority habitats over 4000 square miles or 2,600,000 acres of public and private lands in 

eastern Nevada and western Utah. See: http://www.blm.gov/nv/st/en/prog/planning/groundwater_projects.html

NVCA Both emc0283GB

165. We strongly recommend that conservation measures in the EIS contain, as a minimum, the following recommendations, 

largely based on National Technical Team guidelines: a. the agencies must retain all priority habitat areas in public 

ownership. They should also evaluate the potential negative impacts on Sage Grouse conservation of disposing of public 

lands in general habitat areas and retain general habitat areas which have good potential for restoration and which may 

replace priority habitats destroyed by stochastic events. b. the agencies should acquire private lands in priority habitats, 

general habitats, and restoration habitats, through purchase, donation, or exchange or through conservation easements in 

cooperation with NRCS and other federal agencies private land programs. c. the agencies should initiate land withdrawals 

from mining and military uses in all priority habitats. d. the agencies should affirm its regulatory discretion to reject ROW 

permit applications because of substantial adverse impacts of the proposal to Sage Grouse and priority habitats, other 

national priorities and Congressional directions not-withstanding. e. the agencies should designate ROW exclusion areas in 

NVCA Both emc0283GB
C. Comments by Resource Planning Issue

C-1226 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

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priority habitats and avoidance areas in general habitats in each PMU. f. the agencies should require co-location of utilities in 

existing ROWs. g. the agencies should require burial, removal or modification of power lines in priority habitats h. the 

agencies should reclaim unused ROWs or relocate them outside of priority habitats i. the agencies should require bonds 

sufficient for full reclamation and restoration of utility corridor disturbances to priority habitats. j. the agencies should charge 

impact fees for any unavoidable loss or degradation of priority habitats because of development impacts. k. the agencies 

should cooperate with NRCS and state and private land owners to implement Sage Grouse conservation measures on 

state-owned and privately-owned lands in priority habitat areas. l. the agencies should designate Sage Grouse management 

areas or Areas of Critical Concern to protect priority habitats (as well as some general and restoration habitats to 

compensate for annual unavoidable habitat losses) and dense populations (not populations in constrained or isolated 

communities), with enforceable protections to conserve Sage Grouse habitats. Such reserves should be selected to sustain 

biological processes, maintain intact sagebrush habitat, recover species, buffer against climate change effects and land uses, 

including weed invasions and wildfires, protect connectivity, have good potential for restoration, and achieve the goals of

biological representation and ecological redundancy and resiliency within the sagebrush ecosystem. These special Sage 

Grouse areas should be withdrawn from all mineral entry and closed to new fluid mineral development and ROWs and 

unavoidable surface disturbances should be avoided or minimized or compensated. m. the agencies should develop 

management plans for these special Sage Grouse areas sufficient to mandate protection of Sage Grouse and its habitat and 

are enforced. Without more regulatory authority from the land use plan, the designation of an ACEC is not sufficient for 

actual protection and conservation of Sage Grouse. For example, the Proposed Action for the Groundwater Development 

project draft EIS (see comments on pages 3 and 5) include plans for a non-conforming buried water reservoir in the Coyote 

Springs ACEC, which was designated by the BLM in 1998 as part of the Desert Tortoise recovery plan.

166. Other agency-controlled use of public lands such as the Federal Highway Administration and the Federal Energy Regulatory 

Commission must be subject to Sage Grouse conservation measures added to land use plans, or disasters like the Ruby gas 

pipeline project in Nevada (see comments on page 3) will undercut and negate the BLM and USFS Sage Grouse conservation 

initiative.

NVCA Both emc0283GB

167. Likewise, Sage Grouse Conservation measures added to land use plans should also apply to military uses of public lands, both 

on-the-ground disturbances and aerial uses which cause noise, and release toxic chemicals or bombs in Sage Grouse habitat.

NVCA Both emc0283GB

168. Likewise, Sage Grouse Conservation measures added to land use plans should also apply to military uses of public lands, both 

on-the-ground disturbances and aerial uses which cause noise, and release toxic chemicals or bombs in Sage Grouse habitat.

NVCA Both emc0283GB

169. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the combined use 

of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact private land 

productivity and diversity as well as the economic viability of ranching operations.

NVCA Both emc0304GB

170. BLM and USFS already have rules and policies in place to ensure that mineral exploration projects protect sage-grouse 

habitat. NVMRA members have first-hand experience operating under and complying with these rules and policies. The BLM 

Notices and BLM and USFS Plans of Operations that authorize our exploration activities on BLM-administered public lands 

and on USFS-administered national forest lands contain numerous permit conditions and stipulations pertaining to 

sage-grouse habitat protection. These measures include seasonal restrictions on when and where we can operate and defme 

NVCA Both emc0327GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1227

Scoping Summary Report

Table C-11.A

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sage-grouse habitat areas (primarily leks and a surrounding buffer zone) that are off-limits to our activities. Because these 

existing rules and policies already provide substantial protection to sage-grouse habitat, the proposed land use prohibitions 

and withdrawals are excessive and completely unnecessary.

171. In making investments to locate claims and explore for minerals on public lands, NVMRA member companies have also relied 

on the RMPs that BLM district offices have developed to govern management of these lands. These RMPs clearly identify 

lands with special management considerations and lands that are open to location under the Mining Law and available for 

other multiple uses.

NVCA Both emc0327GB

172. In enacting in FLPMA in 1976, Congress directed the Secretary of the Interior to consider a broad range of resource issues, 

land characteristics, and public needs and values in determining how public lands should be managed. FLPMA directs BLM to 

manage public lands for multiple uses and to consider a wide range of resource values - including the need to protect wildlife 

- in the context of the Nation's needs for minerals, energy, food, fiber, and other natural resources.

NVCA BLM emc0327GB

173. The multiple use and sustained yield directives in FLPMA require BLM to strike an appropriate balance between potentially 

competing interests and land management objectives. This balance is to be achieved in the Section 102 land use planning 

process and the resulting RMPs. FLPMA does not authorize the subordination of any of these uses in preference for a single 

land use such as sage-grouse habitat conservation. The EIS must evaluate how the land use restrictions, prohibitions, and 

withdrawals recommended in the NTT Report achieve the required balance in managing the public lands. This evaluation 

cannot be reasonably completed without appropriate, up-to-date and accurate data. It is equally impossible to analyze the 

effectiveness of the proposed sage-grouse conservation measures or make a meaningful comparison of the effectiveness of 

other alternatives if the underlying baseline data is inaccurate, stale or otherwise unreliable.

NVCA Both emc0327GB

174. NVMRA contends that the land use restrictions and prohibitions - especially the proposed withdrawal of high-priority 

sage-grouse habitat areas from mineral entry are not consistent with FLPMA's multiple use mandate or the specific directive 

pertaining to minerals in FLPMA § 102(a)(12): " ... the public lands [shall] be managed in a manner that recognizes the 

Nation's need for domestic sources of minerals, food, timber, and fiber from the public lands including the implementation 

of the Mining and Minerals Policy Act of 1970 [at] 30 U.S.C. 2la ... " [(43 U.S.C. l70l(a)(12)] The proposed restrictions and 

withdrawals from mineral entry outlined in the NTT Report directly conflict with FLPMA's requirement that the Secretary 

must manage public lands to respond to the Nation's needs for minerals.

NVCA Both emc0327GB

175. BLM's proposed conservation measures and regulatory mechanisms must not conflict with FLPMA or USFS laws. The EIS 

documents must provide a detailed discussion of how the Proposed Action, Agency Preferred Alternative, and Alternatives 

Considered in Detail comply with the mandates in FLPMA and USFS laws to achieve the appropriate balance between a 

variety of public land use objectives that include sage-grouse habitat conservation - but not at the expense or exclusion of 

other uses of public lands.

NVCA Both emc0327GB

176. Unfortunately, the land use restrictions, prohibitions, and withdrawals recommended in the NIT Report deem sage-grouse 

habitat preservation the highest and best use of the public lands. Adopting this single-use perspective would be a sea change 

in the way in which BLM manages public lands and USFS manages the national forests. This draconian change conflicts with 

the underlying multiple-use concepts in FLPMA and USFS laws.

NVCA Both emc0327GB
C. Comments by Resource Planning Issue

C-1228 Greater Sage-Grouse LUPAs/EISs May 2012

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Table C-11.A

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177. NVMRA member companies embrace all reasonable efforts on the federal, state, and local levels to protect and enhance 

greater sage-grouse habitat. The sage-grouse conservation measures in place at NVMRA member companies' exploration 

projects demonstrate our members' commitment to sage-grouse protection. However, the land use restrictions, 

prohibitions, and withdrawals in the NTT Report go too far and conflict with BLM's FLPMA responsibilities to manage public 

lands with a balanced approach the recognizes the importance of a wide range of resource issues on public lands and the 

need for domestic sources of minerals.

NVCA Both emc0327GB

178. SNWA respectfully requests that the EIS consider and discuss the following: effects of implementation of additional or 

revised greater sage-grouse conservation measures on issuance of pending, and future rights-of-way;

NVCA Both rmc0069GB

179. SNWA respectfully requests that the EIS consider and discuss the following: effects of implementation of additional or 

revised greater sage-grouse conservation measures on issuance of pending, and future rights-of-way;

NVCA Both rmc0069GB

180. How will the EIS review and coordinate Oregon’s Comprehensive Land Use statutes? Knowing that Oregon has the most 

restrictive land use plans in the nation may provide an easy resolution for "more adequate regulatory mechanisms".

OR Both emc0071GB

181. ODOT recognizes the challenge that the BLM / USFS will face in developing a comprehensive land management plan that 

effectively addresses the many concems and interest while attempting to focus on the greater sage-grouse and habitat 

improvement. The demand on public lands is diverse. In reviewing the Jan 10, 2012 News Release, initiating the planning 

process and identifying the public meeting schedule to be conducted around Oregon, it was encouraging to see that a list of 

issues or concerns had already been identified including: mineral materials and rights-of-way. How mineral material sites and 

highway rights-of-way are identified and dealt with in this plan is of great concem for ODOT.

OR Both emc0155GB

182. In the ODFW Greater Sage-Grouse Conservation Assessment and Strategy of Oregon: A Plan to Maintain and Enhance 

Populations and Habitat, it states that greater sage-grouse currently occupy habitats in Baker, Crook, Deschutes, Hamey, 

Lake, Malheur and Union Counties. BLM is identified as the primary land manager of greater sage-grouse habitat, controlling 

70% of the habitat in Oregon. The BLM web site indicates that in Oregon BLM manages 15.7 million acres, with 12.5 million 

acres lying within the 7 counties shown as containing greater sage-grouse. In these 7 counties, ODOT is responsible for 

nearly 2000 miles of Federal and State transpoliation system. Within the identified 7 counties, the local road depmiments are 

responsible for more than 6000 miles of county road system. In addition to the highway system, in these counties ODOT has 

been granted long term use of 195 material source propeliies located on federal land. The ODFW report in discussing 

Road Rights-of-Ways, states: "Disturbance from high volume roads can lead to avoidance of otherwise suitable habitat or 

direct mortality of birds. Minimize the construction of new roads through occupied sage-grouse habitat, especially lel{, 

nesting and brood-rearing areas." In addition to the statement shown above the ODFW report includes text and mapping 

associated with what has been identified in the report as "Core Areas". The report states that "core areas" are based on 

biological information with a focus on breeding areas. Included on the ODFW habitat maps for the "core areas" they have 

also mapped areas identified as "Low Density". A review of the maps associated with these habitat areas, shows that most of 

the state transportation facilities cross through areas mapped as either "Core Areas" or "Low Density". Text in the report 

states ODFW would recommend "avoidance of impacts to sage-grouse habitat that occur in Core Areas, and mitigation at 

no net loss with net benefit for sage-grouse habitat that occur in Low Density Areas". Not all Federal, State and County 

road miles within these 7 counties are located on federal land. In addition, not all transportation facilities on federal land pass 

OR Both emc0155GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1229

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

through identified greater sage-grouse habitat. But with over 8000 miles of Federal, State and Local transportation system 

crisscrossing these 7 counties and with 195 ODOT controlled federal land material sources, there is a high probability of 

conflict here in Oregon between greater sage-grouse habitat management and transportation facilities.

183. Considering the miles of highway that ODOT is responsible for and how road rights-of-ways are addressed in the ODFW 

report, it should be obvious that ODOT is very concerned with how existing and future highway facilities and material 

sources will be addressed within this management plan. Based on the findings from several recognized studies, ODOT 

believes highway related activities within existing rights-of-way should be exempted from added scrutiny based solely on 

habitat for greater sage-grouse.

OR Both emc0155GB

184. Sage-grouse generally do not prefer to occupy habitat near high volume roads (Lyon and Anderson 2003, Connelly et al. 

2004, Aldridge and Boyce 2007). The majority of ODOT managed transportation facilities are major highways and freeways 

with relatively high traffic noise (up to 90 decibels). Connelly et al. (2004) indicated there were no active sage-grouse leks 

within 2 kilometers (km) of Interstate 80 across southern Wyoming and only 9 leks were known to occur between 2 and 4 

km of I-80. ODOT biologist have conducted numerous environmental reviews and surveys over the years for transportation 

projects and associated material sources and have not encountered greater sage-grouse or identified areas of active use by 

these birds. Over the course of the last decade ODOT has been collecting data on collisions between wildlife and motor 

vehicles. Over this period no incident of sage-grouse killed by vehicles along ODOT transportation facilities has been 

recorded. ODOT believes that existing traffic, noise and disturbance along these transportation corridors generally 

precludes sage-grouse presence within the existing highway right-of-way and likely the areas immediately adjacent. 

Therefore, ODOT transportation corridors and their associated right-of-way should be exempt from any sage-grouse 

restrictions or exclusions.

OR Both emc0155GB

185. As the agency proceeds in this matter, it is important to consider the implications that regulation may have on private land 

ownership. Many ranchers own private property that supports sage-grouse habitat but depend on public grazing to maintain 

the economic viability of their operations. If overregulation causes ranching operations to become unsustainable, ranchers 

may have no choice to sell or develop their private property, resulting in the loss of critical sage-grouse habitat.

OR Both emc0309GB

186. In summary, the best available scientific evidence shows that public grazing is important for sage-grouse conservation. In 

addition, public grazing maintains the economic sustainability of livestock producers and provides substantial economic 

benefits to the communities in which they live and the economy of Oregon as a whole. In turn, by maintaining the economic 

sustainability of livestock producers, public grazing protects sage-grouse habitat by reducing the need for ranchers to sell or 

develop their private property in a manner that is detrimental to sage-grouse habitat.

OR Both emc0309GB

187. Do I as a homeowner in La Grande with a 30 year mortgage on .3 acres, have the same status and chance of participation in 

program planning and oversight, as the Corporation (say the Simplot Family Trust) that owns or controls more than a million 

acres; and the ZX Ranch, the largest grazing allotment holder in eastern Oregon?

OR Both rmc0036GB

188. The ODWF EIS should take the words of the expert it cites, and adopt the BLM RAC model for developing Local 

Implementation groups; which will insure the opportunity for all stakeholders to participate in the process. If not, I fear the 

ODFW will continue the long history of contentiousness between competing interests, that has plagued the public and 

clogged the courts with environmental cases since the 1970's. The ODFW EIS should implement its own recommendation 

OR Both rmc0036GB
C. Comments by Resource Planning Issue

C-1230 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

to other agencies first; following the recommendations for full participation as envisioned by Burkes (2004).

189. The ODFW EIS needs to identify and analyze all potential socio-economic impacts related to Private Industries and Public 

Works projects which now require permits that are developed in consultations with the ODFW through the Environmental 

Assessment (EA) or EIS processes. Examples include the Mining Industry and large scale public works and improvements that 

rely on Federal Mineral and Rock materials for completion (ie. Development of New Irrigation Canals or Water 

Improvements).

OR Both rmc0036GB

190. The ODFW EIS should also include an analysis of potential increased costs to Public Works and Improvement projects that 

rely on "Free" rock and mineral material from rock quarries located on federal lands in Sage Grouse country. For instance, 

many road projects now depend on road armor or base materials mined from sometimes long inactive borrow pits that have 

partially vegetated with Sage during long periods of activity. If located in Category 1 or 2 areas or migration corridors, these 

borrow pits may require an EIS to reopen. Otherwise a more distant source for rock must be found; increasing 

transportation and logistical costs to public funded projects.

OR Both rmc0036GB

191. It is also necessary that the preferred alternative explicitly recognize the key importance of public lands ranching operations 

to the success of sage-grouse conservation. Scientific research has repeatedly shown that properly managed grazing is 

beneficial to the greater sage-grouse and to a host of other wildlife species. Well-managed grazing can improve sage-grouse 

habitat by increasing the quality and accessibility of forbs and other beneficial vegetation and also aids in the control of 

invasive plant species. Moreover, public lands ranchers own a significant portion of high-quality lowland brood rearing habitat 

as deeded property. According to NRCS, "[a]pproximately 40 percent of sage-grouse habitat that supports populations 

occurs on privately owned lands." However, if regulatory measures on public lands make ranching operations economically 

unsustainable, these operations are frequently subject to sale and development, leading to fragmentation and loss of key 

habitat. It is therefore essential that the preferred alternative incorporates explicit steps to ensure that sage-grouse 

conservation measures do not undermine the viability of public lands ranches.

OR Both rmc0078GB

192. Any EIS or SEIS must also explicitly recognize the following points: In the Great Basin, and much of the western United 

States, livestock operations are highly dependent upon the combined use of private and public lands. Regulatory actions that 

make public lands grazing economically unsustainable will not only negatively impact individual ranch owners, but also entire 

rural communities that largely depend on ranching to maintain businesses and tax base.

OR Both rmc0078GB

193. Many of Kingston's citizens rely on using public lands to provide an income for their families and most of Kingston's citizens 

use public lands for recreation and hunting. Our right to use these lands is continually being challenged. Most of those 

wanting to limit public use of these lands are not concerned about the impact on the local population and they find any issue 

they can to drive their agenda.

UT Both emc0176GB

194. Lands and Realty issues such as preservation of energy corridors for pipelines and overhead power lines must be addressed 

in the RMP amendments. Existing energy corridors and proposed Energy Gateway South and TransWest Express corridors 

should be recognized and considered for exclusion from sage grouse preliminary priority or preliminary general habitat 

designation.

UT Both emc0242GB

195. Lands and Realty issues such as preservation of energy corridors for pipelines and overhead power lines must be addressed UT Both emc0376GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1231

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

in the RMP amendments. Existing energy corridors and proposed Energy Gateway South and Trans West Express corridors 

should be recognized and considered for exclusion from sage-grouse preliminary priority or preliminary general habitat 

designation.

196. There are several legal documents that uphold the right of landowners and livestock owners to use trails, pasture and 

reservoirs on federally managed lands. One of these is the MCKELVEY VS. US where the Supreme Court ruled that a stock 

trail 3 miles in width established in local custom was equally as legitimate as an SRHA stock trail. Cattle owners or their 

employees who have such ROWs(rights-of ways) are the owners of such ROWs and cannot be held guilty of trespass by the 

use of such ROWs. (Curtin vs. Benson 1911). "Land to which right and claims of others exist is not public land" -upheld by 

the U.S. Supreme Court.

WY Both emc0050RM

197. The BLM has control of minerals UNDER many private land parcels in the state. This split estate concept does NOT give 

BLM the constitutional right to assume, require, threaten, or otherwise maintain the federal agency has control over 

management of the private land on the surface. If BLM believes otherwise they need to show where in the Constitution and 

within the Individual State this is an established law. Private property surface rights are separate from minerals rights under 

the soil surface.

WY BLM emc0050RM

198. It would be much more efficient if the BLM would also sell isolated parcels to the public with the lease holder and /or 

neighboring land owners having final bid rights to purchase the land. Isolated parcels are not manageable for the federal 

agency, land sales would give them more money for managing the land they do have and selling isolated parcels would allow 

the neighboring landowners and or lease holder to buy something that would work within their operations. Selling isolated 

parcels would be a win-win for everyone. A neighboring landowner might be willing to trade ownership for land of equal or 

greater appraisal if it fit into their management operation better. The checkerboard pattern makes it very difficult for all 

involved to manage effectively.

WY BLM emc0050RM

199. i. Lander, WY RMP The establishment of ROW corridors, similar to the Designated Development Areas in Alternative D, 

would ensure that major ROWs occurred in areas of existing disturbance to the greatest extent possible. We also support 

co-locating communication facilities with existing sites to reduce new ground disturbances and cluster vertical disturbances. 

Reducing the number, size, and extent of disturbances would reduce habitat loss and fragmentation, maintain habitat

connectivity, and ensure that large patches of habitat are available for greater sage-grouse (DEIS at 881-882).

WY Both emc0089RM

200. Each alternative should designate areas of contiguous sage-grouse habitat not currently subject to mineral leases or other 

valid existing rights for permanent protection. These remaining refugia can provide intact, diverse, high quality sagebrush 

habitat, vital to sage-grouse and other sagebrush obligate species. In Instruction Memorandum WY-2010-013, the Wyoming 

BLM proposed 11 contiguous square miles or sections as an appropriate minimum size for an area of habitat to qualify for 

being set-aside from development.6 The Wyoming BLM recognized these large unleased contiguous blocks as opportunities 

for grouse conservation. This number should be scaled to allow for protecting smaller contiguous areas in states with smaller 

populations than Wyoming’s, or in areas where there are few remaining contiguous 11-square-mile areas that are not 

subject to valid existing rights. These identified, contiguous areas of undeveloped land should be considered for designation 

as Areas of Critical Environmental Concern in all alternatives. (See Section 8 on ACECs for further discussion)

WY Both emc0089RM
C. Comments by Resource Planning Issue

C-1232 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.A

Comments Related to Lands and Realty on Public Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

201. iii. Strong components of Wyoming’s approach Within core areas, stipulations on BLM, FS, Wind River Indian Reservation, 

and State of Wyoming lands limit the number of projects and the amount of allowed disturbance (no more than 5%13) 

allowed per square mile or 640 acres. Surface disturbance is prohibited within a 0.6 mile buffer around active leks (no surface 

occupancy - NSO), which includes roads during the breeding, nesting and brood-rearing periods (mid-March through end of 

June). In addition, a March 15 to June 30 timing limitation stipulation is required within nesting habitat within 4 miles of leks. 

Main roads used to transport production and/or waste products must be more than 1.9 miles from the perimeter of 

occupied grouse leks. Other roads used for access or maintenance must be more than 0.6 miles from the perimeter of 

occupied leks. Noise levels at the perimeter of a lek should not exceed 10 dBA above ambient noise from 6 pm to 8 am, so 

as not to disturb breeding activities (March 1 - May 15). Finally, proponents of new projects are expected to coordinate with 

the permitting agency and WGFD biologists to determine which leks need to be monitored and what data should be 

collected/reported. The Executive Order clearly identifies thresholds and outline adaptive management responses if declines 

in sage-grouse numbers occur14. However, in non-core areas, the EO recommends a 2-mile seasonal buffer around 

occupied leks and a 0.25 mile NSO buffer around active leks. Research has shown that the latter stipulation is inadequate and 

scientifically without merit. In addition, a surface disturbance cap is lacking from non-core area stipulations

WY Both emc0089RM

202. iii. Strong components of Wyoming’s approach For transmission lines, 2-mile wide transmission corridors have been 

identified in an effort to collocate disturbances. Construction is prohibited between March 15 and June 30 (or between

December 1 and June 30 in winter concentration areas) and within 0.5 miles on either side of the existing transmission lines. 

If new lines are proposed for core area, they must be either buried or outfitted with raptor per deterrents to minimize avian 

predation pressure on sage-grouse.

WY Both emc0089RM

203. It is also of great concern that areas with impending oil and gas leases in Wyoming were often purposefully excluded from 

Core Area mapping. Oil and gas, geothermal leases, and wind and other rights-of-way are being gobbled up by industry and 

speculators across the West – including in areas that to date have had very little oil and gas or other energy development. 

Agencies must provide a map of all existing leases/rights-of-way – so the public and decision makers can understand the very 

large numbers of these leases that are held. Agencies must also provide detailed maps of additional areas where leasing is 

foreseeable. The same must be done for mining. This is necessary to understand the huge number of leases and claims that 

currently exist. In many areas of Nevada, for example, there is hardly an acre that does not have mine claims, and increasingly 

does not have geothermal or oil and gas leases. And we wonder - can multiple kinds of leases occur, one on top of another, 

in the same landscapes?

WY Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1233

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. A supporting reason to ask for an additional 60 days is the lack of promised sage grouse priority habitat maps so that 

the stakeholders using public lands will know which areas may be impacted by any proposed actions by the BLM.

Both rmc0027GB

2. Are there any programs that we can get in on our private land to help with the grouse, this may help with the Forest 

Service lease if we get our private land in a management program.

All USFS cfc0023RM

3. In Malheur Co, Oregon lots of the "stable" populations of sage-grouse are on private land. Take notes on what is being 

done in those areas that has been successful. These are probably areas with healthy ecosystems: variety of plant 

species, grazed by cattle but not where it hurts the grass population, fenced areas, limited hunting, variety of activities 

(cropping, grazing), predator control.

All Both cfc0031GB

4. Whenever the RMP considers a course of action that could reduce the economic viability of a ranch, it should also 

consider whether that course of action would harm sage grouse by increasing the likelihood that the ranch would plow 

prairie, overgraze, or sell land to developers to compensate for the lost revenue.

All Both emc0013RM

5. We are also concerned about the impact the management plan could have on private property rights of local farmers 

and ranchers. Private land and state land is often contiguous to BLM lands. If the management plan and EIS creates buffer 

zones around the BLM lands, you will be infringing upon the rights of private property owners.

All BLM emc0024RM

6. And in spite of some incentive programs for private land habitat preservation through the NRCS and other sources, 

private land owners will ultimately need to manage their land for profit and in many cases that will be to the detriment 

of sage habitat.

All Both emc0058GB

7. I question whether FWS knows what regulations would be efficacious, but the litigants are sure to force regulations 

that will lead to the demise of public land grazing and the private stewards that provide the hands on manage of federal 

lands in the west. The extremists promote a no management agenda which relieves them of any management 

responsibility or consequences.

All Both emc0070GB

8. Much of the rangeland in sagebrush habitat is made up of intermingled ownerships fashioned into functional grazing 

units via the Taylor Grazing Act and more recently NRCS programs. The management of these lands can only be 

successful if the private landowner is included. They have the work ethic, the physical contact with the land, the 

knowledge of site specificity, the longevity and ability to work a management plan, and can serve as a vehicle to secure 

many kinds of funding that the federal government is not eligible for as a single entity.

All Both emc0070GB

9. BLM recognized the need to address mixed estate ownership in its December 2011, "Report on National Greater-Sage 

Grouse Conservation Measures" (Report). That Report proposes exceptions to closing leasing in mixed ownership 

lands containing priority habitats specifically in cases where land ownership is inconsistent section-by-section resulting 

in a "checkerboard" ownership pattern. Anadarko owns mineral and surface use interests in such checkerboard areas. 

Anadarko therefore recommends that in areas of mixed ownership reasonable exceptions are provided to 

conservation measures.

All Both emc0125RM

10. Recognition of the challenging resource management aspect of mixed ownership is also stated in BLM's document 

Winning Challenges o/the Future -A Road Map to Success in 2016 (BLM 2010). BLM notes: "Our checkerboard 

landscape and management of the subsurface mineral estate that is sometimes located under different surface owners 

has integrated managing and mitigating necessary impacts and, ultimately, good communication into everything we do." 

All Both emc0125RM
C. Comments by Resource Planning Issue

C-1234 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

The document continues: "Mitigation measures will need to be coordinated based on resource impacts, rather than 

land ownership." Consistent with the above tenets, Anadarko requests that BLM not limit our company to only 

providing scoping or NEP A document comments, but more fully engage mineral owners in these proposed land 

management changes. As the planning process progresses, a productive on-going dialogue with the mineral and surface 

use owners on the checkerboard lands is essential.

11. As private land owners we provide important habitat for sage grouse on private lands adjacent to the BLM and FS 

grounds where we also graze our cattle. We have an active, sage grouse plan and are implementing projects to improve 

their habitat within our operation.

All Both emc0127GB

12. Work with Private Land Owners on Individual area concerns, not on a National one size fits all approach. All Both emc0137GB

13. The maps that show the priority habitat appear to have incorporated private lands that are adjacent to BLM lands that 

have sage-grouse habitat. Many of the private lands are agricultural lands that are not and will not be sage 

brush/sage-grouse habitat. Is BLM going to refine its habitat boundaries and remove the private lands that are within the 

priority habitat boundaries?

All Both emc0140RM

14. There needs to be mechanisms (funding, conservation easements, management plan conditions, technical assistance 

and consulting) to ensure that private lands are managed consistent with protections for sagebrush obligate species 

over the long term.

All Both emc0169GB

15. C. While BLM acknowledges that private landowners or administrators play an important role in managing wildlife and 

habitat, BLM does not provide for coordination and cooperation with landoWllers beyond that afforded to the general 

public. The site specific on ground knowledge and often historic knowledge oflandowners should carry a very high value 

throughout this process. This is especially true in some areas (e.g. Owyhee County) where so much of the highest value 

water and meadow habitat are located on private land used by ranchers in conjunction with the public lands.

All BLM emc0212GB

16. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the 

combined use of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact 

private land productivity and diversity as well as the economic viability of ranching operations. Wildlife populations 

including Greater sagegrouse benefit from the productivity of these private lands.

All Both emc0215GB

17. Every effort should be made to consolidate public lands and reduce the checkerboard situation caused by the railroad. 

Isolated parcels that have no public access should also be reduced. Efforts should be made to trade or sell BLM 

controlled property that is isolated and mixed with private property.

All Both emc0217GB

18. Pursuant to the Federal Land POlicy Management Act (FLPMA), all BLM actions, such as authorization of Resource J 

Management Plans, are "subject to valid existing rights." 43 U.S.C. § 1701 note (h); see a/50 43 C.F.R. § 1610.S-3(b) (BLM 

is required to recognize valid existing lease rights). Thus, pursuant to federal statute, the BLM cannot terminate, modify, 

or alter any valid or existing property rights through a RMP amendment. Id.

All BLM emc0246GB

19. We are concerned about including private lands into the 3% calculation for disturbance in priority habitats. Many of the 

private lands will have disturbances and management of sage brush habitat that will skew the 3% calculation and reduce 

the allowed disturbance on federal land designated as priority habitat

All Both emc0246GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1235

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

20. As discussed previously, economically viable coal reserves are not mobile and as such the imposition of restrictive 

buffer zones or creation of "no disturbance" corridors will likely lead to unanticipated negative Impacts on Greater Sage 

Grouse populations. The most likely manifestation of this condition would probably be in the form of large private land 

holdings being divested by energy development companies to urban development interests. Colowyo does not believe 

this scenario would be isolated to industry private landholders but would also manifest itself within the agricultural 

community as well if the ability to economically utilize public lands in concert with their private land is curtailed.

All Both emc0270GB

21. unanticipated negative impacts on Greater Sage Grouse populations. The most likely manifestation of this condition 

would probably be in the form of large private land holdings being divested by energy development companies to urban 

development interests. Colowyo does not believe this scenario would be isolated to industry private landholders but 

would also manifest itself within the agricultural community as well if the ability to economically utilize public lands in 

concert with their private land is curtailed.

All Both emc0270GB

22. The BLM allotments and associated private lands in sagebrush country provide habitat for diverse wildlife species as 

well as providing the economic base for these rural counties.

All Both emc0281GB

23. One major loss should public lands grazing be curtailed, for example, would be the open space provided by private 

ranch lands, which is critical to greater sage-grouse habitat. Every federal grazing allotment in the west is held by a

rancher who owns accompanying private “base” property. In fact, these ranchers own nearly120 million acres of 

primarily rangeland, west-wide. Most of these ranchers’ ability to stay in business is dependent on their ability to

continue grazing public lands. The unintended consequences of decisions that negatively impact those ranchers will also 

impact the greater sage-grouse, by encouraging the conversion of private rangelands into farmland, urban development, 

or other uses not conducive to greater sage-grouse habitat.

All Both emc0284GB

24. Suggest that –Page 28 – 31. The wording should include evidence that governmental agencies involved with the 

management and conservation of the sage-grouse, are seeking and will embrace the cooperative work and knowledge 

currently held with the private land owner adjacent to these priority habitat areas. As stated in #5 pages 30 – 31, 31% 

of the land ownership is in the hands of private land owners.

All Both emc0291GB, 

emc0055RM, 

emc0119RM

25. It is also very likely that the increasing suburbanization of many areas in the Grer.t Basin, with the complete habitat 

destruction that suburbanization creates, has a highly negative effect on nearby populations of sage grouse. This 

problem, however, is not one that the BLM can solve.

All Both emc0301GB

26. In several places in BLMs supporting documentation and associated materials for the EIS it is stated that conservation 

measures would be applied regardless of surface ownership. Conservation measures applied to private lands is of great 

concern to the industry. The EIS and alternatives must fully address and describe how such a policy will be applied and 

the associated impacts, including cumulative impacts.

All Both emc0310GB

27. The EIS must address how BLM and the USFS plan to honor the valid existing rights companies hold I within what is now 

and may be in the future designated Priority Habitat Areas.

All Both emc0310GB

28. We request that BLM clarify whether private and state lands will be included in the density restriction calculations and 

whether the four mile NSO buffer is from the center or the edge of the lek and whether the restrictions apply to 

historic or active leks, or both.

All BLM emc0312GB
C. Comments by Resource Planning Issue

C-1236 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

29. Private landowners, in cooperation with public land management agencies, continue to work cooperatively, to 

maintain, restore or enhance ecosystem functioning and management on a landscape-scale, which will provide sage 

grouse optimal life cycle habitat conditions. Private landowners are critical to the condition of all rangeland habitats, and 

therefore to sage grouse and other associated species, healthy working and economic environments for the ranching 

communities are imperative.

All Both emc0314GB

30. Provide protection for private and public landowners to deter possible major transformation if sage-grouse are listed. All Both emc0314GB

31. Provide methods to secure that longevity, and healthfulness of the ranching industry. Agreements, easements, 

cooperative projects, and funding for necessary infrastructure with the agencies should be available.

All Both emc0314GB

32. About including private lands into the 3% calculation for disturbance in priority habitats. Many of the private lands will 

have disturbances and management of sage brush habitat that will skew the 3% calculation and reduce the allowed 

disturbance on federal land designated as priority habitat

All Both emc0319GB

33. VI. The EIS Must Evaluate Ways to Minimize Adversely Affecting Private Property Rights Federal land management 

agencies must properly define and protect valid existing rights as part of their planning processes. A number of the 

conservation measures and regulatory mechanisms recommended in the NTT Report have significant potential to 

diminish landowners’ rights to develop their private property. The EIS must evaluate ways to minimize interfering with 

private property rights – including the rights associated with owning patented mining claims and fee mineral estates. 

BLM’s proposal to recognize Valid Existing Rights (VERs) on valid claims (e.g., claims with a discovery of a valuable 

mineral deposit) does not go far enough to protect the property rights associated with patented mining claims and fee 

land because it restricts the analysis of the VERs to the four corners of a patented mining claim or the boundaries of the 

fee land. Instead, BLM and USFS must evaluate the substantially adverse consequences of making it impossible to 

develop private lands if the adjacent unpatented mining claims without a discovery are withdrawn from development. 

Similarly, if public lands needed for ROWs for roads, power lines, pipelines, etc. are no longer available for 

development, the patented claims, fee lands, and associated private property rights could be rendered worthless.

All Both emc0321GB

34. VII. The EIS Must Evaluate Ways to Minimize Adversely Affecting Private Property Rights The land use restrictions, 

prohibitions, and withdrawals recommended in the NTT Report have significant potential to diminish landowners' 

rights to develop their private property. The EIS must evaluate ways to minimize interfering with private property 

rights - including the rights associated with owning patented mining claims and fee mineral estates. BLM's proposal to 

recognize Valid Existing Rights ("VERs") on valid claims (e.g., claims with a discovery of a valuable mineral deposit) does 

not go far enough to protect the property rights associated with patented mining claims and fee land because it restricts 

the analysis of the VERs to the four comers of a patented mining claim or the boundaries of the fee land. Instead, BLM

and USFS must evaluate the substantially adverse consequences of making it impossible to develop private lands if the 

adjacent unpatented mining claims without a discovery are withdrawn from development. Similarly, if public lands 

needed for ROWs for roads, powerlines, pipelines, etc. are no longer available for development, the patented claims, 

fee lands, and associated private property lights could be rendered worthless. • Eureka Moly Scoping Issue No.7: 

Minimize Impacts to Private Property Rights - The EIS documents must evaluate alternatives that minimize adverse

impacts to private property rights and disclose and quantify any adverse effects to property rights that would result

All Both emc0335GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1237

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

from implementation of the Agency Preferred Alternative.

35. The legal rights of adequate access to private property and use must be recognized and protected as part of the Sage 

Grouse SEIS.

All Both emc0342GB

36. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: - the 

effects of fencing, power lines, road fragmentation, and disturbance from human dwellings and activities associated with 

exurban development render much of it inhospitable to sage grouse

All Both emc0343GB

37. The proposed conservation measures assume that non-federal land management (private or state lands) is inferior to 

federal land management. This view is contrary to what has been espoused as the “new paradigm” of cooperative 

conservation (and is in fact reflected in a recent FWS solicitation for public comments on the subject of incentives for 

voluntary conservation actions under the ESA, at Federal Register Volume 77, Number 51 (Thursday, March 15, 2012) 

at Pages 15352-15354. The transfer of private lands to federal ownership also reduces the property tax base, thus 

impacting local communities.

All BLM emc0346GB

38. These property rights are entitled to the full protections of the Fifth Amendment to the Constitution, which provides 

that no person shall "be deprived oflife, liberty, or property, without due process oflaw; nor shall private property be 

taken for public use, without just compensation." Such protection of private property is one of the most essential and 

fundamental roles of government. To wantonly disregard it in the name of an expedient protection of the Sage Grouse 

and its habitat is a gross affront to our founding principles.

All Both emc0347GB

39. As a result of this clear contradiction between the proposed plan and basic Constitutional principles, I request that in 

the preparation of the final plan, the Bureau make appropriate changes necessary to ensure that private property rights 

are not trampled upon in the pursuit of your objectives.

All Both emc0347GB

40. While evaluating the ramifications of possible curtailment of livestock grazing use, consideration should take into 

account the linkage between private ranch lands and federal land permits. Although we don't agree with the perspective 

that curtailment of properly-managed livestock grazing will have a beneficial result, we do want to stress the potential 

negative consequences for GSG habitat on private lands, if a livestock grazing permit is not allowed to be used. In order 

to maintain business operations, possible conversion of private land holdings may result from not being able to make 

use of federally-managed lands. More intensive land use of these private resources could result in a negative outcome 

for habitat located on private land. In areas where private lands and federally-managed lands are found in alternating 

sections (i.e., “checkerboard” lands) or where private lands make up a significant portion of large tracts of habitat, this 

increase in fragmentation would undoubtedly be far more of a problem and impact on GSG.

All Both emc0383GB

41. I believe that habitat plans should be site specific and not a state wide blanketed plan. We have already have had and are 

in the middle of Sage Grouse habitat vegetation projects on public and private lands in our allotment and county. A lot 

of private land in this area has some preferred use for Sage Grouse, taking livestock off the public range will result in 

over use of the private which in some areas more preferred to the Sage Grouse.

All Both emc0389GB

42. Preserving access to lands, both public and private, for those users without unnecessary restrictions due to the 

potential listing of a species with such a large habitat fosters this stewardship.

All Both emc0396GB
C. Comments by Resource Planning Issue

C-1238 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

43. It must reflect varying availabilitles of private land All Both emc0407GB

44. Additional Compensatory Mitigation Program Recommendations The Nature Conservancy recommends acquisition of 

suitable et"tA-" private lands of the size and quality needed to meet mitigation offset requirements for ecological 

impacts on BLM or USFS administered lands as the first strategy for accomplishing off-site mitigation

All Both emc0407GB

45. Concomi tantly, endowments should be established to provide sufficient funding for the long-term management and

monitoring of private lands acquired as mitigation to address ecological impacts on BLM or USFS-administered lands. 

These acquired lands should also be clearly designated as withdrawn from other uses and for the sole purpose (and use) 

of conserving Greater Sage-Grouse, via immediate revision or amendment to the relevant RMP or LMP.

All Both emc0407GB

46. It is undoubtedly true that many private lessees hold grazing permits on federal lands which function as integral parts of 

private ranches and must be managed on a collective basis across both private and federal lands. This cooperation 

should be focused in geographic areas that are considered Priority Habitat or core areas by BLM and USFS and that are 

priorities for SGI.

All Both emc0407GB

47. Split-estate. How will BLM address impacts of split estate development to public surface status lands and resources - for 

example to aquifers that may supply waters for springs critical to sage-grouse brood rearing habitat? The wording of the 

Scoping notice is confusing. Agencies must be honest about the true impacts of activities authorized on split estate 

lands- like fracking on private lands, gold mining aquifer drawdown of brood rearing habitat, noise intrusion from 

compressors, visual intrusions of development activity and many other adverse effects. BLM must also make sure it 

does not shift impacts to enable development to sites important to the sage-grouse population - whether it is split 

estate, or not. Indirect, cumulative and synergistic adverse impacts of activities on split-estate lands must be considered. 

There are serious pollution, contamination, water table depletion and other adverse impacts of energy and other 

developments to people, too. How will BLM consider the direct, indirect and cumulative adverse impacts of activities 

occurring on private, state, FWS, Bureau of Reclamation, military, or other lands in sagebrush habitats in this process?

All BLM emc0411GB

48. BLM will, in reality, be unable to control development on private lands. So it is hard to understand why BLM lumped 

private land development in with BLM development. The NTT’s wording has antagonized private landowners. Perhaps 

that is its intention. Stir up resistance to sage-grouse listing by making private landowners angry. Is this too part of the 

Core Model from Wyoming –-perhaps with split estate mineral development in mind?

All BLM emc0411GB

49. Agencies must focus strongly on public land for mitigation, and outright purchase of private lands. Throwing large sums 

of money at conservation easements on private lands provides little acreage for great expense. Outright purchase of 

private lands should be pursued, rather than paying ranchers or other parties who had no intention of developing 

condos in an area not under threat of condo development millions of dollars not to develop condos for a conservation 

easement. Under the terms of most conservation easements, status quo grazing disturbance and land and watershed 

degradation, harmful fences, harmful management schemes, lethal predator control, and other activities continue 

unabated all the while on the conservation easement.

All Both emc0411GB

50. Only by requiring the strongest protective measures when considering new development proposals in sage-grouse 

habitat will you be able to ensure survival of this spectacular species. To that end, I ask that you require the following 

All Both flb0000gb
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1239

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

conservation measures in the relevant Resource Management Plans and Land Management Plans- No new fences, 

power lines, pipelines, roads, motorized trails, communications towers, water developments, or other infrastructure 

should be permitted in priority sage-grouse habitat.

51. One has to consider that public lands are likely the only place where sage grouse will have a chance to survive. Private 

land owners are going to do what they need with their lands to make a profit and taking into consideration the needs 

of sage grouse are unlikely to be top priority.

All Both flb0045gb

52. Any EIS or SEIS must also explicitly recognize the following points: In the Great Basin, and much of the western United 

States, livestock operations are highly dependent upon the combined use of private and public lands. Regulatory actions 

that make public lands grazing economically unsustainable will not only negatively impact individual ranch owners, but 

also entire rural communities that largely depend on ranching to maintain businesses and tax base.

All Both fli0000gb

53. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the 

combined use of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact 

private land productivity and diversity as well as the economic viability of ranching operations.

All Both flj0001gb

54. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the 

combined use of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact 

private land productivity and diversity as well as the economic viability of ranching operations. Private land productivity, 

particularly wet meadow maintenance, is extremely important to sage-grouse survivability.

All Both flj0003gb

55. (18) Very little to no discussion has been made on management practices to be prescribed on BLM/ USFS lands that are 

isolated and surrounded by private lands. These isolated parcels have frequently been described as; "custodial range)' 

whereupon the agencies, In (he past, have been reluctant to impose overly restrictive tet111S on grazing permits. Will 

this policy remain in place in the future'!

All Both fxc0011gb

56. 19) BLM must consider the affect increased grazing restrictions on public land will have on management of private land. 

In numerous cases, public land use restrictions result in increased use of private land. Such shift-to-use often times 

results in less favorable overall conditions for sage grouse and will effectively negate "landscape scale" planning efforts.

All BLM fxc0011gb

57. We believe the management of federal lands must provide for both sage-grouse and livestock grazing as well as be made 

compatible with people and other resource uses. The large acreage ranching/farming operations are essential to 

protect sage grouse habitat from land use changes, such as housing developments. That means grazing permits must 

continue to be issued that enhance the economic viability of these livestock operations. This county and our 

neighboring county have seen small, often marginal ranch operations converted to second homes and other uses that 

destroyed critical habitat or enhanced predator opportunities resulting in substantial reductions in all wildlife numbers. 

It is extremely important that this interspersed ranchland holding foster grazing use and retention of ownerships that 

supports sage-grouse and the ecosystem they use. Our county has a limited private land tax base. The retention of 

economically viable operations such as ranching and forestry operation are far less costly to the county than the 

infrastructure and the safety and support facilities that come from second home and other such developments. In order 

to provide information and interact with the agencies as this program goes forward we would like to be granted 

coordinating government to government status.

All Both rmc0032GB
C. Comments by Resource Planning Issue

C-1240 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

58. Regulations must foster a need for ranchers that can provide the needed space and defense against fire and invasive 

species. Without the integrated large private holdings the impacts would be much more detrimental.

All Both rmc0032gb

59. The 2010 Conservation Measures also seek to address urbanization of private lands with management standards taken 

on adjacent public lands, which could result in significant costs and closures to areas where public lands are simply 

insufficient in size to provide quality grouse habitat.

All Both rmc0033GB

60. The findings of the Colorado Department of Wildlife research indicate that Urbanization of grouse habitat is a 

significant issue in certain areas, and this issue simply is not directly addressed in the Conservation Measures. Rather 

the impact of Urbanization is classified as many other issues in the Conservation measures. Researchers have 

consistently found: "Development in the Gunnison Basin is becoming increasingly exurban. This type of development 

results in a highly fragmented landscape as the number of roads and buildings (Theobald et al. 1996, Mitchell et al. 2002) 

in previously contiguous patches of sagebrush increases, clearly reducing nesting habitat quality for Gunnison 

sage-grouse. High density residential development was avoided at a landscape scale, and nesting females chose to place 

nests farther away from any single development at the patch scale. This avoidance was not linear, with a threshold at 

approximately 2.5 km (Fig. Sf). The joint effects of roads and residential developments within sagebrush habitats will 

have negative consequences on Gunnison sage-grouse nesting habitat. With future developments on the horizon for 

the Gunnison Basin, housing and associated road developments within 2.5 km of identified crucial habitat should be

evaluated cautiously, due to the potential direct and functional loss of nesting habitat" While Urbanization of Sage 

Grouse habitat is a significant concern, excluding all uses on federal lands in areas that are designated grouse habitat 

simply will not counter the impacts of Urbanization on adjacent private lands. Management of development of private 

lands is not a federal public lands management issue, it is a local zoning issue. The Organizations have to note that 

development of accurate zoning regulations, in partnership with local governments, simply is never addressed in the 

Conservation Measures, despite the fact that zoning regulations are specifically developed to address these type of 

issues on private lands. Excluding public access to public lands will undermine public support for the management

proposal and objectives in the long run and directly contradict mitigation activities taken through public/private 

partnerships or attempts to manage private land development with zoning regulations. In certain areas, these 

public/private partnership tools will play a key role in protecting grouse habitat. The Organizations believe management 

of federal lands must have flexibility to address local management issues and to allow flexibility to maintain activities

already developed at significant expense to the agency, such as visitor centers, bathrooms, camping facilities, and kiosks.

All Both rmc0033GB

61. review of Colorado Department of Wildlife research regarding comparative levels of ownership of grouse habitat in 

Colorado identifies significant portions of the designated habitat where achieving compliance with this standard will be 

problematic given the low percentages of public lands owned, such as the habitat around Meeker, Colorado. The 

comparatively low levels of federal land ownership is evidenced in other grouse habitat areas as well. While only these 

two areas are identified in these comments, CDOW analysis finds similar comparative land ownership allocations in 

many areas of the state of Colorado. Department of Wildlife has taken in protecting the sage grouse. Rather than 

address management with absolute standards that may not be achievable, CDOW has stimulated private/public 

partnerships in an effort to bring more total lands into conformity with grouse management needs. The Organizations 

All Both rmc0033GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1241

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

believe the current proposal will directly undermine these efforts and not benefit the grouse in the long run as public 

usage will be barred from grouse habitat but yield little true benefit to the grouse, as most usage of public lands

generates little to no impact on the grouse.

62. Question: "Subject: Greater Sage-Grouse Habitat Management Policy on Wyoming Bureau of Land Management (BLM) 

Administered Public Lands lncluding the Federal Mineral Estate." also "and regardless of land ownership patterns. " 

When referring to the Federal Mineral Estate and regardless of land ownership patterns is the BLM saying that our 

split-estate lands will be subject to the guidelines of this document? Will the BLM or the Forest Service be dictating 

how, when and where we will be grazing our livestock on our private surface estate? This must be clarified immediately.

All Both rmc0034rm

63. The Board encourages development and/or alteration of range improvements provided it is completed in a cooperative 

manner and in respect of private property rights - including water rights.

All Both rmc0050GB

64. While evaluating the ramifications of possible curtailment of livestock grazing use, consideration should take into 

account the linkage between private lands and federal land permits. Although we don't agree with the perspective that 

curtailment of properly-managed livestock grazing will have a beneficial result, we do want to stress the potential 

negative consequences for Sage-Grouse habitat on private lands, if a livestock grazing permit is not allowed to be used. 

In order to maintain business operations, possible conversion of private land holdings may result from not being able to 

make use of federally-managed lands. More intensive land use of these private resources could result in a negative 

outcome for habitat located on private land. In areas where private lands and federally-managed lands are found in 

alternating sections or where private lands make up a significant portion of large tracts of habitat, this increase in 

fragmentation would undoubtedly be far more of a problem than providing for continued use of federally-managed 

lands.

All Both rmc0058GB

65. In preparing the draft EIS, we insist that the agency document the considerations given to private property rights 

connected to the federally-managed lands, especially those related to livestock water rights and rights of way to access 

these water rights. For pending plans which seek to restrict the ability to use these private property assets, we 

anticipate that the draft EIS will include the required Takings Assessment as required under Executive Order 12630. 

Further, the documentation should include the methods by which property right owners will be compensated for 

planned government takings.

All Both rmc0058GB

66. The interdependence of private and public lands, especially BLM, but in some instances, Forest Service is a major issue. 

In Shoshone Basin and other areas, sage-grouse habitat includes a mixture of BLM and private lands. Management 

decisions affecting BLM or Forest Service lands can directly impact management options and land uses on associated 

private lands. Frequently, private lands make up a majority of acres within a BLM, grazing allotment. Because private 

components often originated through Homesteads, water rights and associated springs and wet meadows critical to 

sage grouse are mostly located on private lands. Private lands usually include the deeper, more productive soils with 

greater potential for favorable responses to habitat management.

All Both rmc0063GB

67. The NPSGWG also requests that the EIS conduct a thorough analysis of the potential impacts of applying NTT 

measures prioritizing sage-grouse over livestock management and structural range improvements because if measures 

designed to improve habitat for sage-grouse end up making it impossible for ranchers to make a living, then some of 

CO BLM emc0060RM
C. Comments by Resource Planning Issue

C-1242 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

them may end up having to subdivide their land. Housing development scattered throughout North Park would have 

detrimental impacts to sage-grouse.

68. Production agriculture is also important in maintaining some of the late summer habitat found in irrigated hay meadows 

and other moist areas. The agricultural producers in North Park are effectively maintaining sage-grouse habitat by 

keeping the vast majority of North Park undeveloped. We would request thorough analysis of the impacts of removing 

production agriculture on the overall quantity and quality of sage-grouse habitat.

CO BLM emc0060RM

69. The North Eagle/South Routt habitat map needs to be re-defined. A large percentage of the area covered by priority 

habitat is irrigated meadows and/or private lands. If land owners are denied the ability to operate, the grouse will be the 

losers as more of their habitat will become fragmented by housing.

CO Both emc0069RM

70. How will BLM/USFS evaluate and address threats/impacts from adjacent, off-property sites (for example residential 

subdivision development on private lands adjacent to BLM land)? It is unclear to CPW if it is within the scope of the 

PRMP to coordinate with county governments and enter into Memoranda of Understanding that require shared

coordination of land use discussions and decisions when they occur across administrative boundaries in PPH and PGH 

areas designated in the PRMP. This type of coordination would be critical because of the high percentage of private land 

in NW Colorado, and within the planning boundaries of the 5 BLM Field Offices.

CO Both emc0072RM

71. Energy development on private land is also a potential off-property direct and indirect threat/impact. Several large coal 

mines are also operating in NW Colorado on privately owned land.

CO Both emc0072RM

72. It is critical for BLM to consider implementing the following technical team recommendations as minimum standards: 

Use available tools to increase the amount of protected habitat (e.g. retiring oil and gas leases, buying out mineral 

claims).

CO BLM fll0000RM

73. In the Great Basin, and much of the western United States livestock operations are highly dependent upon the 

combined use of private and public lands. Regulatory actions that restrict use of public rangelands will negatively impact 

private land productivity and diversity as well as the economic viability of ranching operations. Wildlife populations 

including Greater sage-grouse benefit from the productivity of these private lands.

GB Both flj0002gb

74. I noticed that you had the city of Salmon and Leadore included in you areas of impact or habitat, is this for real or a 

mapping ere, and you may want to fix your maps. Also What is the reason you have private land marked on your map, 

I have talked to some of the local ranchers/land owners who are not in favor of you classifying their property and 

possibly putting them in jeopardy with some Federal agency when they don’t believe or have they seen any sage grouse 

on their property in the last 20‐30 years plus. Just some thoughts.

IDMT Both emc0045GB

75. The Group has developed a sage-grouse conservation plan for Jarbidge Planning Area, which includes the goals outlined 

below. We ask that the BLM consider these goals as they finalize the Sage-Grouse Planning Strategy. -Encourage 

cooperation between private, State, and Federal landowners

IDMT Both emc0158GB

76. The Group has developed a sage-grouse conservation plan for Jarbidge Planning Area, which includes the goals outlined 

below. We ask that the BLM consider these goals as they finalize the Sage-Grouse Planning Strategy. -Conduct work on 

private land only with the landowner's cooperation

IDMT Both emc0158GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1243

Scoping Summary Report

Table C-11.B

Comments Related to Lands and Realty on Private Lands

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

77. New risk factors include: -Potential threats from increasing use of rural areas for residential development IDMT Both rmc0028GB

78. Actions that reduce or minimize sage brush habitat include: -subdivisions and housing development IDMT Both rmc0028GB

79. Will it be possible for a land owner, to cultivate the private land in a way not compatible with the EIS plan, say for 

production of high protein alfalfa for overseas export; while grazing cattle in another county on their allotment and still 

be EXEMPT? An example would be the ZX Ranch in Lake County. In general it is very poor policy indeed that begins 

by arbitrarily EXEMPTING some activity from a holistic Mitigation Plan. I recommend the grazing operation 

exemption either be eliminated from the EIS; or all mining and permitting operations and recreation modes not 

identified in the EIS be exempted from the Mitigation Plan as well.

OR Both rmc0036GB

80. BLM and Forest lands should not be expected to provide all needed sage-grouse habitat to meet such benchmarks. 

Private, state and tribal lands contribute a good share of sage-grouse habitat now and will continue to do so in the 

future. The State of Utah, in consultation with Uintah County, and private land owners have taken great strides to 

enhance sage-grouse habitat in the Diamond Mountain area, recognizing that this is not a marginal or insupportably

small sage-grouse population.

UT Both emc0376GB

81. It would be much more efficient if the BLM would also sell isolated parcels to the public with the lease holder and /or 

neighboring land owners having final bid rights to purchase the land. Isolated parcels are not manageable for the federal 

agency, land sales would give them more money for managing the land they do have and selling isolated parcels would 

allow the neighboring landowners and or lease holder to buy something that would work within their operations. 

Selling isolated parcels would be a win-win for everyone. A neighboring landowner might be willing to trade ownership 

for land of equal or greater appraisal if it fit into their management operation better. The checkerboard pattern makes 

it very difficult for all involved to manage effectively.

WY BLM emc0050RM

82. Manage priority sage-grouse habitats so that discrete anthropogenic disturbances cover less than 3% of the total 

sage-grouse habitat regardless of ownership. (Page 7 National) The BLM does not have constitutional authority to 

dictate to private landowners how they will manage their private land. The BLM needs to do what they can to make 

their federally managed lands better. The whole landscape can be viewed but not dictated to. Communication is the key 

here to let the landowner know of any concerns across the fence upon federally managed lands.

WY BLM emc0050RM

83. Maintain retirement of grazing privileges as an option in priority sage-grouse areas when base property is transferred or 

the current permittee is willing to retire grazing on all or part of an allotment (Crawford et al. 2004 page 17 National) 

People buy base property with the expectation that the grazing leases will follow the land. The new purchaser should 

have the option to use the grazing lease and if they decline and the land in question is part of a grazing association then 

the grazing lease must go to the association for others to use. Grazing is not a privilege but a federally mandated right 

as part of multiple use of federally managed lands.

WY Both emc0050RM

84. Factors such as vegetation management, fire management, conflicting wildlife management, predation, subdivision and 

infrastructure development, and invasive plants are a higher priority in the Upper Snake River Basin Conservation Area 

(USRBCA) and include large areas that could be affected by project actions.

WY USFS emc0144RM
C. Comments by Resource Planning Issue

C-1244 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. There needs to be a study done comparing Wilderness habitat and multiple use habitat to compare grouse population. All Both cfc0007GB

2. The fourth problem is wilderness. If we keep making wilderness, making it harder for people to use the land we just won't 

care anymore.

All Both emc0031GB

3. Conduct under burns in the pine and fir stands to reduce the fuel load within the Mt. Dome Area of Critical Environmental 

Concern. This will aid in preventing catastrophic fires on the mountain top and losing the entire stand of timber used by 

nesting and wintering Bald Eagles in the Klamath and Tule Lake basins.

All Both emc0061GB

4. We suggest the BLM make full use of the land use categories available to it, such as wilderness recommendations and areas 

of critical environmental concern.

All Both emc0068GB

5. Ideally, BLM should designate all of the area within the 75% core areas delineated by Doherty et al. (2011), plus any 

additional seasonal habitats that are needed to protect 75% of the existing population, as ACECs that are set-aside from all 

threats with potential to negatively impact greater sage-grouse populations, and managed to permanently maintain and 

enhance populations. In states with small, peripheral populations, BLM should designate ACECs to include the area needed 

to protect 100% of the population (100% cores delineated by Doherty et al. (2011) plus any additional seasonal habitats 

used by the population). The Dakotas and Utah, as well as parts of Colorado, include these small, isolated populations 

where sage-grouse population are particularly vulnerable to extirpation. However, we recognize that legal, social and 

political factors (particularly around energy development), may make this difficult for BLM to achieve across the entire 

eastern/Rocky Mountain range.

All Both emc0089RM

6. I would like to see some land protection measures, though not necessarily wilderness, which precludes management. But 

I strongly oppose efforts to remove current wilderness study areas from that designation at this time. I believe those efforts 

are aimed at opening these wild lands that benefit so many people and wildlife to development that would forever destroy 

their character and value.

All Both emc0107GB

7. 16) Comment: Areas of Critical Environmental Concern designations. ! Planning guidance explicit to the consideration of 

such ACECs in RMP/EIS development should be provided. The only mention I found of ACECs in the Strategy, Charter, or 

NTT Report is in the Plan of Operations definition in the NTT Report, and it has nothing to do with addressing the 

suitability of designating sage-grouse or sagebrush ACECs in RMPs. I have previously advocated designating large tracts of 

sage-grouse habitat as ACECs, in some cases spanning planning unit, field office, and/or state boundaries. Section 202(c)3 of 

FLPMA stipulates: " (c) In the development and revision of land use plans, the Secretary shall --- (3) give priority to the 

designation and protection of areas of critical environmental concern; ...". The FLPMA language does not constrain such 

designations to within one planning unit or one state.

All BLM emc0113GB

8. As a part of the planning process the BLM scoping notice invites the public "to nominate or recommend areas on public 

lands for greater sage-grouse and their habitat to be considered as Areas of Critical Environmental Concern [ACEC]" 76 

Fed. Reg. 77011. WWF encourages the BLM to continue analyzing proposed ACECs as better mapping of sage-grouse 

habitat is made available from each state.

All Both emc0128RM

9. ACECs should encompass priority habitat including breeding, late-brood rearing, and winter concentration areas, and 

migration and connectivity corridors.

All Both emc0128RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1245

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

10. WWF encourages the BLM to consider ACEC designations incorporating the following criteria: - Coordinate with the 

Wyoming Game and Fish Commission to transition any commission owned Wildlife Habitat Management Areas with high 

sage-grouse habitat values to ACECs. - Coordinate with the Wyoming Game and Fish Department to identify those areas 

within sagegrouse core areas that are most crucial and should be designated ACEC - Evaluate areas with high biological 

value and are currently undeveloped, have a low potential for energy development, and do not contain existing leases. -

Consider areas with lower biological values and are currently undeveloped, have a low potential for energy development, 

and do not contain existing leases. These areas could be used maintain connectivity both between core regions and 

adjacent states. Additionally BLM could work to improve the value of this habitat for sage-grouse.

All Both emc0128RM

11. Wilderness Characteristics: All public lands which exhibited wilderness characteristics have been designated as such by 

Congress. No further lands should be incorporated into the Wilderness System. The same holds true for all special

designations. All land not already designated as a special use area by Congress should be returned to multiple-use and 

managed as such for the good of the Nation.

All Both emc0133GB

12. Revisions to greater sage-grouse management plans should not be used to elevate “wilderness characteristics” above all 

other multiple uses. Multiple use of federal lands is mandated under the Federal Land Policy and Management Act of 1976 

(FLPMA) and other statutes. Only Congress, by designating Wilderness Areas and Wilderness Study Areas-Inventoried 

Roadless Areas (WSAs-IRAs) under discrete authority of the Wilderness Act of 1964, may elevate the importance of 

“wilderness characteristics.”

All Both emc0140RM

13. Areas of Critical Environmental Concern The NOI invites the public “to nominate or recommend areas on public lands for 

greater sage-grouse and their habitat to be considered as ACEC as part of this planning process.” Similarly to the PPH and 

PGH comments above, we believe public notice and opportunity for comment should be required before any such areas 

are designated.

All Both emc0140RM

14. The similarity between wilderness regulatory restrictions and the rules proposed to protect sage grouse, and the ability of 

existing wilderness areas to provide for the minimum sustainable populations of sage-grouse (a total of 5,000 birds) is an 

issue that needs to be evaluated.

All Both emc0160GB

15. When it comes to a conflict between a potential endangered specie and land with wilderness characteristics, the perches 

need to be cut. It is very disappointing as a rancher to pay for the labor to provide off-site watering for cattle, only to find 

that the perches around the targeted playas carmot be SMA removed due to the land having wilderness characteristics

All Both emc0172GB

16. As a side note, on the maps of sage grouse habitat, I noticed that there were no wilderness areas or wilderness study areas 

included that I was familiar with.

All Both emc0172GB

17. Public lands (especially BLM property) should be managed for multiple uses. Traditional uses should get priority over newer 

uses such as ATV trails and wilderness designation. National Parks and National Forests should be managed for fewer 

activities and can be set aside for Wilderness designation.

All Both emc0217GB

18. 1. BLM should designate ACECs to protect important sage-grouse habitat and require robust, consistent management 

prescriptions. a. ACECs are an important tool to designate and protect important sage-grouse habitat areas.

All BLM emc0234GB

19. Therefore, ACECs are an appropriate tool for delineating areas to be managed for sage-grouse protection, as weIl as for 

developing special management approaches for a broader suite of resources.

All Both emc0234GB
C. Comments by Resource Planning Issue

C-1246 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

20. BLM's scoping notice invites the public "to nominate or recommend areas on public lands for greater sage-grouse and their 

habitat to be considered as Areas of Critical Environmental Concern as a part of this planning process." 76 Fed.Reg. 77011. 

We support this approach and encourage BLM to consider ACEC nominations that are submitted in response to this 

planning process, to develop its own proposals, and to look at ACECs that were submitted and/or previously evaluated but 

not designated in RMPs that will be amended by this process.

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21. Criteria for designating ACECs to conserve and enhance priority habitat for sage-grouse should be developed consistent 

with the National Technical Team's recommendations and the most recent scientific research. Several draft RMPs recently 

released for public review and comment evaluated sage-grouse ACECs that should be considered as part of this process, 

including Lander (Wyoming), Bighorn Basin (Wyoming) and Colorado River VaIley (Colorado). AdditionaIly, we previously 

submitted ACEC nominations for the Cedar City (Utah) and Jarbidge (Idaho) RMP revisions that we believe merit 

evaluation as part of this process.

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22. In evaluating ACECs as part of this planning process, BLM should also consider whether there are additional, coexisting 

values that can be managed as part of ACECs over an overlapping area or areas. For example, the Nine Mile Canyon ACEC, 

designated in the Vernal RMP, is managed to protect special status species as weIl as scenic qualities and cultural resources 

(Vernal Approved RMP and ROD, p. 36). Similarly, the Fort Stanton ACEC, designated in the RosweIl RMP, is managed to 

protect biological, archeological and scenic values (Roswell Approved RMP, p. 67). Both of these ACECs also provide 

recreation opportunities. We encourage BLM to designate ACECs for sage-grouse protection that provide the 

opportunity to manage and protect other additional values such as cultural, scenic and biological resources and 

backcountry recreation experiences

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23. Recommendations: BLM should designate ACECs to protect and enhance important sage-grouse habitat, considering new 

ACEC nominations as weIl as ACECs that were previously nominated and/or evaluated in affected RMPs. BLM should give 

careful consideration to ACECs that possess additional values that can be managed and protected commensurately with 

sage-grouse habitat conservation. A broader approach will fulfill FLPMA's mandate to prioritize protection and designation 

of ACECs and to manage the mUltiple uses of the public lands, while also making the most of this opportunity to manage 

the sagebrush ecosystem at a landscape level.

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24. b. BLM must ensure management prescriptions for designated ACECs are adequate to protect sage-grouse habitat and 

consistently applied.

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25. If BLM intends to rely on ACEC designation for protecting and enhancing sage-grouse habitat, this planning process must 

establish robust, consistent management prescriptions for ACECs. As stated above, designating ACECs is one ofBLM's 

obligations under FLPMA. However, historically, ACEC designation has been a tool that is full of potential but frequently 

fails to provide appropriate protections for the relevant and important values that BLM identifies as meriting ACEC 

designation

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26. The BLM's ACEC Manual (1613) requires that management prescriptions for ACECs are to be "fully developed" in RMPs or 

amendments and sets out useful factors for consideration in developing such prescriptions (1613.22). If these factors and 

directions for incorporating management prescriptions into plans were followed, then ACECs might be sufficiently

protected. Unfortunately, the ACEC Manual also defines the agency's mandatory requirements inadequately for actual 

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May 2012 Greater Sage-Grouse LUPAs/EISs C-1247

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protection ofthe relevant and important resources that the BLM has identified as needing special management attention, 

stating: "At least one prescription for each potential ACEC must be developed which provides special management 

attention" (1613.22). Further, the ACEC Manual has not been updated in so long that it is not even available on BLM's 

Electronic Reading Room with all the other agency manuals and handbooks. As a result, the agency lacks any recent 

guidance on ACEC management or even on designation, and management prescriptions for ACECs may be wholly 

inadequate.

27. To ensure that ACEC designation is successful relative to this planning process and protection of relevant and important 

values managed by the agency more broadly, we recommend BLM issue guidance on ACEC management immediately and 

also begin updating the ACEC Manual. The immediate guidance should mandate that BLM develop and incorporate a basic 

set of key management prescriptions into plans, even if additional management may be developed through a subsequent, 

ACEC-specific activity plan. Both immediate guidance and an updated ACEC Manual are necessary to demonstrate the 

agency's commitment to protect relevant and important values through ACEC designation as required by FLPMA and to 

ensure that ACECs designated through this process will meaningfully protect sage-grouse habitat and other important 

resources.

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28. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: Minimization of route networks and closures to motorized use or limiting motorized use to 

designated routes;

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29. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: Mineral withdrawal, both immediate under Section 204 ofFLPMA and recommendation for 

permanent withdrawal (per Manual 1613.33.C);

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30. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: ROW exclusion (such as electric transmission and fluid mineral pipelines

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31. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: Closed to renewable energy development;

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32. Specific management prescriptions that should be mandatory for ACECs designated for sage-grouse protection should 

include, at a minimum: Closed to leasing or NSO with no exceptions, modifications or waivers.

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33. Recommendations: This planning process must establish specific, mandatory management prescriptions for ACECs 

designated to protect and enhance sage-grouse habitat. BLM should issue an Instruction Memorandum and/or other 

guidance immediately that details the agency's requirements and expectations for ACEC management, and should also 

update the ACEC Manual to reflect updated management requirements and ensure this tool adequately protects the

important and relevant values it is intended to safeguard.

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34. 2. BLM should inventory lands with wilderness characteristics as part ofthis planning process and consider protecting 

inventoried lands to benefit sage-grouse. a. FLPMA and BLM's current guidance require the agency to inventory lands for

wilderness characteristics in major planning efforts

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35. BLM's mandate of multiple use and sustained yield, as well as other relevant law and the agency's current guidance, provide 

for inventory and protection of wilderness values, which should also form a part of this land use planning process.

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36. Wilderness character is a resource for which BLM must keep a current inventory and must address in land use planning. As 

the U.S. Court of Appeals for the Ninth Circuit held: ... wilderness characteristics are among the 'resource and other 

values' of the public lands to be inventoried under § 1711. BLM's land use plans, which provide for the management of these 

resources and values, are, again, to "rely, to the extent it is available, on the inventory ofthe public lands, their resources, 

and other values." 43 U.S.C. § 1712(c)(4). Oregon Natural Desert Ass 'n v. Bureau of Land Management, 531 F.3d 1114, 

1119 (9th Cir. 2008). Therefore, BLM is required to consider "whether, and to what extent, wilderness values are now 

present in the planning area outside of existing WSAs and, if so, how the Plan should treat land with such values." [d. at 

1143.

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37. Sage-grouse habitat clearly is a supplemental value of lands with wilderness characteristics and therefore should be 

evaluated as part of the inventory process

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38. Recommendations: BLM should complete wilderness characteristics inventories for the RMPs that will be amended 

through this planning process in compliance with 1M 2011-154, and document where sage-grouse habitat is a supplemental 

value of an inventoried area. b. Protecting lands with wilderness characteristics can benefit sage-grouse.

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39. BLM should consider whether and how protecting lands with wilderness characteristics woulJ contribute to protecting and 

recovering sage-grouse, and those potential benefits should influence BLM's decision to protect inventoried lands with 

wilderness characteristics (LWCs).

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40. Furthermore, Wilderness Study Areas may provide important intact habitat for sage-grouse. As part of this planning 

process, BLM should analyze whether WSAs are or could provide crucial sage-grouse habitat and recommend those WSAs 

for Wilderness designation to ensure they provide enduring protection for the species.

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41. BLM should evaluate whether and how protecting inventoried lands with wilderness characteristics and WSAs can benefit 

sage-grouse, and use that analysis to inform decisions on managing L WCs for protection and recommending WSAs for 

designation.

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42. As stated in the 15-Year Strategy for the Conservation Lands, BLM will "maintain or increase habitat connectivity with 

other important habitat areas to provide for sustainable populations of native species." I5-Year Strategy, GoaI2A(2). The 

Strategy also states that BLM will develop maps identifying key habitat linkages among the Conservation Lands to meet 

broad-scale conservation goals as well as serve as an information resource for exploring possible new designation to the 

Conservation Lands. I5-Year Strategy, Goa12C. These strategic actions should be directly applied to BLM's efforts to avoid 

listing of the sage grouse under the ESA.

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43. Ecosystem-based management ofthe Conservation Lands extends beyond the borders to the important and sensitive lands 

and waters that provide habitat for sage grouse and other wildlife on public lands that may not have adequate management 

prescriptions in place to allow for the species to survive. BLM has committed to conservation of sage grouse and its habitat 

and should use Conservation Lands as a tool to achieving those conservation goals and recommend the addition of more 

conservation areas to BLM's Conservation Lands portfolio in order to facilitate the survival of the species.

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44. Recommendation: In order to adequately protect and recover sage-grouse populations, BLM should help protect 

landscapes that are either threatened by development or ecologically healthy and biologically diverse by recommending 

that Congress or the president use authority under law to established new conservation designations such as national 

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May 2012 Greater Sage-Grouse LUPAs/EISs C-1249

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monuments, wilderness areas, national conservation areas or other designations as appropriate.

45. Among the 15 issues covered in the joint letter, we particularly look forward to the opportunity to work with both the 

BLM and FS to identify important habitats and areas for special designations. Our organization has skills and expertise on 

sage-grouse, their habitats, and the best landscapes that deserve protection to benefit the species.

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46. and that these areas, when designated, provide clear and specific management requirements that will adequately manage, 

reduce or eliminate development and landuse activities that threaten the persistence of sage-grouse on the landscape.

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47. We realize the designation of ACEC's for sage grouse protection is an otion BLM has to manage in an area which meets the 

criteria for ACEC desi&nation. We also appreciate the additional requirement that these ACEC nominations be analyzed 

within the RMP amendment process so that we can provide BlM with additional input on the impacts any of these 

nominations may have in areas where we having value existlns rights. We request that these same ACEC nominations be 

analyzed within the "State IM" alternative to compare the impacts of each of these GSG protection strategies to make a 

"least restrictive environment" land use determination on these areas.

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48. Samson asks that the BLM refrain from including and evaluating the Citizen's Proposed Wilderness Areas (CPWA) as 

wilderness for GSG habitat protection as they have not been designated by Congress as such at this time. Many of these 

CWPA's have active 011 and gas leases and associated exploration and production activities at this time. Acknowledging 

any type of wilderness deSignation within the RMP amendment process for the further protection of the GSG would not 

be appropriate for inclusion In any of the EIS alternatives. The focus should be kept on the GSG and should not provide an 

opportunity to further advance the protection of the CPWA's within the RMP amendments until Congress acts on these 

proposed designations.

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49. Relevance: Criteria 2: A fish and wildlife resource (including but not limited to habitat for endangered, sensitive or 

threatened species, or habitat essential for maintaining species diversity). The Greater Sage-Grouse is the largest North 

American grouse and depends upon a variety of sage-steppe habitats during their lifecycle. In 2010, the US Fish and Wildlife 

Service found that the Sage-Grouse warranted listing under the Endangered Species Act in recognition of the myriad 

threats confronting sage-grouse populations across its range (Fed. Reg. 3/4/10). As a sagebrush obligate species, the 

Greater Sage-Grouse depends upon large, healthy connected stands of sagebrush for their survival and are very vulnerable 

to changes in habitat. Sagebrush steppe habitats are considered among the most imperiled ecosystems in North America 

(Knick et al. 2003, p. 612). ACEC designation is an important tool to protect priority habitats for Sage-Grouse. This 

nominated ACEC encompasses all core habitats within the BLM Dillon Resource Area and will contribute to the 

conservation of Sage-Grouse in Management Zone IV. This ACEC contains ACEC Nomination, Greater Yellowstone 

Coalition & Montana Audubon , March 2012 approximately fifty active and historic breeding leks as well as winter, nesting, 

and brood rearing habitats.

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50. The lands nominated for ACEC designation “have substantial significance and values,” and specifically meet criteria 1-3. 1. 

Has more than locally significant qualities: The lands included in the proposed ACEC represent a relatively large contiguous 

area of high biological value for sage-grouse. These lands are largely un-developed and un-encumbered by valid existing 

leases (see enclosed map: “Beaverhead Headwaters/ Centennial Valley Sage Grouse Core Areas”). If managed for 

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Sage-Grouse and the requisite plant communities needed to sustain Sage- Grouse through an ACEC designation, these 

lands could substantially contribute to the conservation of this sensitive and candidate species in Management Zone IV. 2. 

Has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, exemplary, endangered, threatened or 

vulnerable to adverse change: At least a portion of southwest Montana’s Sage-Grouse population is migratory, moving 

between separate breeding areas in Montana and wintering areas in eastern Idaho (MDFWP 2005, p. 25). This unusual 

characteristic makes this population particularly sensitive to activities that would lead to habitat fragmentation. Sources of 

habitat fragmentation which could be managed through the special management attention of an ACEC include: energy

exploitation and transmission; road building and season of access; ORV use; extra efforts to limit noxious weed invasions; 

properly designed wildfire defense plans; modification to fencing specifications and densities; and improved designs for 

water infrastructure. In addition, the relatively high elevations and cool temperatures of southwest Montana’s priority 

Sage-Grouse habitats may be considered irreplaceable in that they appear to provide refugia from widespread, episodic 

occurrence of West Nile virus (WNv) at present, and may continue to as climate change increases temperatures. 

Sage-Grouse appear to have no resistance to WNv, which has caused extreme mortality events in some Sage-Grouse 

populations at lower elevations and warmer habitats in southeast Montana, eastern Oregon, southwest Idaho and 

elsewhere. In contrast, there has never been a documented infection or mortality of Sage-Grouse from WNv in 

Beaverhead or Madison counties, which are encompassed by this ACEC nomination. Summer temperatures likely affect 

WNv viremia (Naugle et al. 2005). Braust (1991) suggested a mean daily temperature below 21 C degrees reduces 

autogeny in Culex tarsalis, the principle mosquito vector of this virus. 3. Has been recognized as warranting protection in 

order to satisfy national priority concerns or to carry out the mandates of FLPMA: The significant amount of attention paid 

to Greater Sage-Grouse research, monitoring, and conservation, as well as explicit statements by federal and state 

agencies, demonstrates that the species is a national priority. State and federal agencies have been working for over a 

decade to implement conservation strategies to maintain Sage-Grouse populations, as reflected in Montana’s Sage-Grouse 

Conservation and Management Plan and the BLM Dillon Area Resource Management Plan (BLM RMP 2006). In 2010, the 

US Fish and Wildlife Service found that listing of the Greater Sage-Grouse was warranted due to “the present or 

threatened destruction, modification, or curtailment of its habitat, and the inadequacy of existing regulatory mechanisms to 

address such threats” (Fed. Reg. 3/4/10).

51. The lands nominated for ACEC designation “have substantial significance and values,” and specifically meet criteria 1-3. 1. 

Has more than locally significant qualities: The lands included in the proposed ACEC represent a relatively large contiguous 

area of high biological value for sage-grouse. These lands are largely un-developed and un-encumbered by valid existing 

leases (see enclosed map: “Beaverhead Headwaters/ Centennial Valley Sage Grouse Core Areas”). If managed for 

Sage-Grouse and the requisite plant communities needed to sustain Sage- Grouse through an ACEC designation, these 

lands could substantially contribute to the conservation of this sensitive and candidate species in Management Zone IV. 2. 

Has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, exemplary, endangered, threatened or 

vulnerable to adverse change: At least a portion of southwest Montana’s Sage-Grouse population is migratory, moving 

between separate breeding areas in Montana and wintering areas in eastern Idaho (MDFWP 2005, p. 25). This unusual 

characteristic makes this population particularly sensitive to activities that would lead to habitat fragmentation. Sources of 

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May 2012 Greater Sage-Grouse LUPAs/EISs C-1251

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habitat fragmentation which could be managed through the special management attention of an ACEC include: energy

exploitation and transmission; road building and season of access; ORV use; extra efforts to limit noxious weed invasions; 

properly designed wildfire defense plans; modification to fencing specifications and densities; and improved designs for 

water infrastructure. In addition, the relatively high elevations and cool temperatures of southwest Montana’s priority 

Sage-Grouse habitats may be considered irreplaceable in that they appear to provide refugia from widespread, episodic 

occurrence of West Nile virus (WNv) at present, and may continue to as climate change increases temperatures. 

Sage-Grouse appear to have no resistance to WNv, which has caused extreme mortality events in some Sage-Grouse 

populations at lower elevations and warmer habitats in southeast Montana, eastern Oregon, southwest Idaho and 

elsewhere. In contrast, there has never been a documented infection or mortality of Sage-Grouse from WNv in 

Beaverhead or Madison counties, which are encompassed by this ACEC nomination. Summer temperatures likely affect 

WNv viremia (Naugle et al. 2005). Braust (1991) suggested a mean daily temperature below 21 C degrees reduces 

autogeny in Culex tarsalis, the principle mosquito vector of this virus. 3. Has been recognized as warranting protection in 

order to satisfy national priority concerns or to carry out the mandates of FLPMA: The significant amount of attention paid 

to Greater Sage-Grouse research, monitoring, and conservation, as well as explicit statements by federal and state

agencies, demonstrates that the species is a national priority. State and federal agencies have been working for over a 

decade to implement conservation strategies to maintain Sage-Grouse populations, as reflected in Montana’s Sage-Grouse 

Conservation and Management Plan and the BLM Dillon Area Resource Management Plan (BLM RMP 2006). In 2010, the 

US Fish and Wildlife Service found that listing of the Greater Sage-Grouse was warranted due to “the present or 

threatened destruction, modification, or curtailment of its habitat, and the inadequacy of existing regulatory mechanisms to 

address such threats” (Fed. Reg. 3/4/10).

52. Special Management Attention: To receive ACEC designation, “an area must require special management attention to 

protect the important and relevant values.” (BLM Manual). This proposed ACEC requires management guidance so that 

sage-grouse conservation is the primary objective. BLM lands within the proposed ACEC can be permanently set-aside 

from large-scale development and managed with emphasis on maintaining and enhancing southwest Montana’s Greater 

Sage-Grouse population.

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53. Specifically, management prescriptions for this proposed ACEC should implement the conservation measures 

recommended by the Sage-Grouse National Technical Team in December, 2011 (SGNTT, 2011). Recent publications have 

exhaustively documented the special conservation actions needed to sustain Greater Sage-Grouse in the American West 

(SAB 2011). Because this proposed ACEC includes priority/core sage grouse habitat, we recommend the following special 

management to address activities that will fragment the sage-steppe habitats upon which the greater sage-grouse depends:

1. Fluid Minerals/ Oil and gas: The Sage-Grouse National Technical Team recommends that unleased federal fluid minerals 

be closed to leasing in priority sage grouse habitat. Upon expiration or termination of existing leases no new nominations/ 

expressions of interest should be accepted. The lands within the proposed Dillon Resource Area ACEC are almost entirely 

unleased (see attached map: “Beaverhead Headwaters/ Centennial Valley Sage Grouse Core Areas”). Management 

prescriptions for this ACEC should implement the Technical Team’s recommendation, closing these lands to future leasing.

This would include all of the federal mineral estate within the boundaries of the ACEC, regardless of surface land 

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ownership. The current Dillon Resource Management Plan requires only a јaround sage grouse mile NSO stipulation

leks. More recent research reflected in the National Technical Team’s report indicates that “applying NSO or other buffers 

around leks at any distance is unlikely to be effective. Even if this approach were to be continued, it should be noted that 

protecting even 75 to >80% of nesting hens would require a 4-mile buffer.” SGNTT, 2011, pp 20-21). Given the current 

lack of interest in oil and gas within the boundaries of the proposed ACEC, special management provisions should be put 

in place now to protect Sage-Grouse habitat and provide for enhanced and resilient populations in southwest Montana.

54. Specifically, management prescriptions for this proposed ACEC should implement the conservation measures 

recommended by the Sage-Grouse National Technical Team in December, 2011 (SGNTT, 2011). Recent publications have 

exhaustively documented the special conservation actions needed to sustain Greater Sage-Grouse in the American West 

(SAB 2011). Because this proposed ACEC includes priority/core sage grouse habitat, we recommend the following special 

management to address activities that will fragment the sage-steppe habitats upon which the greater sage-grouse depends:

Wildfire and fuels management: Because the proposed ACEC includes priority Sage- Grouse habitat, the Technical Team’s 

recommendations with regard to fuels management and fire operations should be implemented within the boundaries of 

the ACEC (SGNTT 2011).

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55. Specifically, management prescriptions for this proposed ACEC should implement the conservation measures 

recommended by the Sage-Grouse National Technical Team in December, 2011 (SGNTT, 2011). Recent publications have 

exhaustively documented the special conservation actions needed to sustain Greater Sage-Grouse in the American West 

(SAB 2011). Because this proposed ACEC includes priority/core sage grouse habitat, we recommend the following special 

management to address activities that will fragment the sage-steppe habitats upon which the greater sage-grouse depends:

Travel management: Within the proposed ACEC, motorized recreation should be limited to designated roads and trails. 

The BLM should review current travel management plans and evaluate the need for permanent or seasonal road and area

closures to protect Sage-Grouse (SGNTT, 2011). Roads and trails not designated for motorized recreation within the 

ACEC should be obliterated and restored to native vegetation to improve Sage-Grouse habitat.

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56. Invasive Weeds: Within the boundaries of the proposed ACEC, special management is required to limit the spread of 

invasive weeds such as cheat grass (Bromus tectorim). Cheat grass significantly alters fire regimes, shortening fire 

frequencies and increasing fire intensities in ways which permanently alter the climax sagebrush vegetation Sage- Grouse 

require. Presently cheat grass is not classified as a “noxious weed” in Montana and as such receives no state, federal or local 

resources to control or limit its spread.

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57. Structural Range improvements: Water infrastructure and fences to manage livestock can pose increased mortality risk to 

sage grouse. Within the boundaries of the ACEC, development or modification of water infrastructure should be done in 

a way that minimizes the potential propagation of West Nile virus. (SGNTT 2011). Existing and new fencing should be 

marked, modified or removed to reduce sage-grouse strikes and mortality, particularly near leks, in known flight paths, in 

concentrated winter range, or where fence strikes have been documented.

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58. Less than 1.5% of the current GSG breeding population needs to be conserved to support a minimum effective population 

as high as 5,000 birds. Because the species is heavily concentrated in high-quality portions of its occupied range (see 

Doherty6), less than 0.25% of the total acreage in the highest breeding density portions of the occupied range needs to be 

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conserved to support the minimum effective population (see calculations in footnote 6). Likely, far more than 5,000 GSG, 

and more than 0.25% of the species high quality breeding habitat, are located within existing Wilderness Areas, National 

Wildlife Refuges, National Parks, and National Conservation Areas. Thus, these nationally designated areas likely already 

support more GSG than the minimum effective population needed to safeguard the species from extinction. Further, these 

nationally designated areas are already managed under special regulatory mechanisms that in many instances mirror the 

proposed mechanisms that current sage-grouse planning strategies recommend for conservation of the species and its 

habitat. These nationally designated areas have the potential to protect a minimum effective population of GSG under the 

type of regulatory mechanisms that the FWS claims will provide them with sufficient protection from human disturbances 

and development. Thus, the EIS process needs to first analyze greater sage-grouse population levels and trends in these 

nationally designated areas to determine how many GSG they contain, and the extent to which their habitats are sufficient 

to sustain the minimum effective population of 5,000 birds under the regulatory mechanisms that are already in place. If 

analysis of these nationally designated areas confirms that they currently support more than 5,000 greater sage-grouse, and 

demonstrates that their populations have been maintained or have increased under the regulatory mechanisms already

implemented, then there is no need to implement additional conservation measures anywhere else in the bird’s occupied 

range. In such case, the GSG does not need to be listed under the ESA because its existence and trend in these nationally 

designated areas alone is sufficient to safeguard it from extinction. In contrast, if analysis demonstrates that greater 

sage-grouse population trends in these nationally designated areas are similar to trends elsewhere in their currently 

occupied range, then the entire line of reasoning regarding the factors responsible for GSG population declines must be 

reevaluated. If GSG population declines have occurred in these nationally designated areas that received such recognition 

because of their expansive, wild, undisturbed characteristics, and have been largely protected from human disturbance and 

development since their designation, then factors other than habitat loss, destruction, and fragmentation due to man’s 

activities must be driving the GSG population declines. Likewise, if greater sage-grouse populations have declined in these 

nationally designated areas despite the regulatory/policy mechanisms that constrain their use, all recommendations to 

implement similar regulatory restrictions across vast additional acreages of the GSG range need to be rejected entirely.

59. If regulatory/policy controls to minimize human disturbance have failed to allow GSG populations to flourish within the vast 

wilderness areas and other nationally designated conservation areas, then it is unreasonable to apply such draconian 

control measures to broad landscapes beyond the boundaries of these areas in the vain hope that such regulation will 

somehow work in other locations. To implement regulatory mechanisms that are certain to severely interfere with other 

valid existing uses of the landscape and negatively impact local and regional economies in the face of evidence that such

mechanisms did not reverse the plight of the GSG in these nationally designated areas would be unreasonable, irrational, 

and counter-productive. Instead, if the minimum effective population of GSG necessary to protect the species from 

extinction cannot be supported within such nationally designated areas, then management practices that were in place 

when greater sage-grouse populations dramatically increased from the mid 1800s to early 1900s need to be identified and 

implemented again in other areas, including increased livestock grazing to reduce wildfire fuel loads, and concerted

predator control practices

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60. No Action Alternative As discussed above, the current GSG population exceeds the minimum effective population by 70 to All Both emc0251GB
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107 times. Current GSG populations and habitats located within existing Wilderness Areas, National Wildlife Refuges, 

National Parks, and National Conservation Areas likely far exceed the minimums needed to safeguard the species against 

extinction. These nationally designated areas already impose regulatory mechanisms that mirror those that are thought to 

provide protections for GSG. Thus, it is likely that a well reasoned, detailed analysis of the current situation will

demonstrate that no additional action is necessary because GSG do not legally qualify for listing under the ESA based upon 

their current population size and slow rates of change in recent times. Further, their existence and trend in existing 

nationally designated areas alone likely prevents the GSG from meeting the legal qualifications for listing under the ESA.

61. If analysis of the current situation determines that no existing habitat area(s) provide large enough interconnected habitat 

with sufficient management protections to support a minimum effective population as high as 5,000 interbreeding adults 

into the foreseeable future, the EIS process must consider alternatives to establish adequate habitat areas, such as the 

alternatives discussed below. Contiguous Habitat Block Alternative If it is determined that no nationally designated special 

areas currently provide a contiguous habitat block to support a minimum effective population as high as 5,000 breeding 

adults, the EIS process must evaluate the extent to which adjacent habitat could be incorporated into a special management 

area to establish such a habitat block. For example, if an existing wilderness area only lacks some winter habitat to provide 

for the year-long needs of the minimum effective population, and such winter habitat exists on nearby lands, it is entirely 

reasonable to develop an alternative to incorporate that adjoining winter habitat into a special management area and 

impose any necessary protections on such winter habitat to establish a contiguous habitat block to support the minimum 

effective population. If such contiguous habitat block is established to meet the needs of the minimum effective population, 

no additional GSG conservation measures are needed across the remainder of the species range to safeguard GSG from 

extinction and avoid the presumed need for listing under the ESA.

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62. Proximate Habitat Alternative If it is determined that no nationally designated special areas currently provide proximate 

habitats to support the free flow of genetic information among a minimum effective population as high as 5,000 breeding 

adults, the EIS process must evaluate the extent to which nearby habitats could be incorporated into a management 

network to establish such proximate habitats. For example, there may be two nationally designated areas, say a wilderness 

area and a wildlife refuge, that each support a population of 3,000 GSG, but are distant enough from each other to prevent 

the free flow of genetic information between them. Existing GSG habitat located between these areas could be managed to 

establish a proximate habitat network that allows the free flow of genetic information among a combined GSG population 

that exceeds a minimum effective population as high as 5,000 breeding adults.

All Both emc0251GB

63. 2) Roadless and “wilderness” areas affect all of the habitat issues negatively. Negative effects to sage grouse habitat will still 

be present with wilderness designation, yet the ability to address those habitat issues will be severely restricted with a 

wilderness designation. (I.e. Wilderness does not solve the problem, it makes it worse.)

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64. As noted elsewhere in these comments, sage-grouse typically inhabit large, interconnected expanses of sagebrush. While 

there is a seasonal component to their habitat requirements, sagegrouse rely year-round on sagebrush-dominated 

landscapes with varying sagebrush canopy covers, densities and heights, age classes, patch sizes, and moisture availability. 

Sage-grouse are a landscape species, meaning they use these large, ecologically diverse sagebrush-steppe habitats and are 

particularly vulnerable to land-use and resource-harvesting practices that alter this habitat. In 2010, the U.S. Fish and 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1255

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Wildlife Service determined that the greater sage-grouse warranted listing under the Endangered Species Act due to past 

destruction and degradation of habitat, as well as ongoing threats to their remaining habitat. In particular, the Service found, 

based on its review of the best information available, that existing ‘regulatory mechanisms’—that is, laws, regulations, 

strategies and guidance at the federal, state, and local levels—are inadequate to protect sage-grouse from extinction. The 

Service then determined that the absence of adequate regulatory mechanisms is a significant threat to the species, now and 

in the foreseeable future. However, the Service determined that listing at that time was precluded by higher priority listing

actions. Conversion of sagebrush habitat for agriculture, intensive ranching operations (including associated fencing and 

water developments), invasive weeds, fires, and, oil and gas development along with the infrastructure required for that 

development (roads, pipelines, powerlines, etc.), have all factored significantly in sage-grouse declines. Based on these facts 

and the criteria noted above, GYC is nominating at a minimum two areas of land in Idaho and one area of land in Montana 

as ACECs for sage-grouse protection purposes. This full nominations are attached as Exhibits 1 & 2.

65. Areas of Critical Environmental Concern (ACECs) are an important tool to protect key areas: ACECs should be 

designated to protect priority habitats from development and other disturbances in each Resource Management Plan 

(RMP). In states with particularly precarious populations, ACECs should encompass all or a substantial proportion of

remaining priority habitat and can also protect wilderness-quality lands and other species on these same lands.

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66. We are concerned however that field offices may feel compelled to include alternatives which have much higher impacts to 

resources other than PPH or are longer or less constructible simple because they appear to have less impact to PPH.

All Both emc03

67. Administrative designations, such as Areas of Critical Environmental Concern (ACEC) and/or Research Natural Areas 

(RNA), should be used to protect priority sage-grouse habitat on BLM lands.

All BLM emc0308GB

68. The Department of the Interior should independently consider the current amount of "protected" sage grouse habitat in 

existing Wilderness Areas, National Wildlife Refuges, National Parks, and National Conservation Areas to support the

minimum effective Sage Grouse population. These nationally designated areas are already managed under special regulatory 

mechanisms that in many instances mirror the proposed mechanisms that current sage-grouse planning strategies 

recommend for conservation of the species and its habitat. Sage Grouse management should not be used as a guise to 

management for wildlands; lands with wilderness characteristics; wilderness study areas; or other single use lands.

All Both emc0342GB

69. Each Field Office should bring forward at least two sage grouse Area of Critical Environmental Concern candidate areas, 

and the sage grouse Plan Amendment EIS is the most appropriate vehicle (rather than concurrent RMP revisions) to 

consider such ACEC nominations. ACECs are an integral part of the overall sage grouse conservation package for each 

Plan, and the overall sufficiency of the sage grouse protection package as a whole should be up for evaluation under the Sage

Grouse Plan Amendments EIS. With this in mind, the Rock Springs Field Office’s stated intention to withdraw its candidate 

sage grouse ACECs from the Plan Amendment process and instead pursue it in the RMP revision is a misguided one.

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70. We recommend that all sage grouse ACECs be withdrawn from oil and gas leasing and recommended for withdrawal of all 

leasable and locatable surface minerals from mining.

All BLM emc0343GB

71. We have attached a map of proposed Sage Grouse Areas of Critical Environmental Concern, a selection of the 

highest-density sage grouse populations with the most pristine and defensible habitat. We believe that all high-density sage 

grouse lek complexes meet the relevance and importance criteria for ACEC designation as a wildlife resource, due to the 

All BLM emc0343GB
C. Comments by Resource Planning Issue

C-1256 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

BLM Sensitive Species status and current trend toward listing, and the strong fidelity of these birds to particular breeding,

nesting, and wintering habitats. These areas also feature habitat for an entire sagebrush ecosystem encompassing a variety 

of other sagebrush-obligate species including sage sparrow, sage thrasher, Brewer’s sparrow, pygmy rabbit, and 

white-tailed prairie dog, as well as other species such as swift fox, ferruginous hawk, Wyoming pocket gopher, and 

burrowing owl, further underscoring their importance and relevance as a wildlife resource.

72. Sage Grouse Reserves In addition to designating Core Areas, a system of sage grouse reserves should be designated 

where no harm to the species would be allowed. This could include restrictions on road construction, grazing, and off-road 

vehicle use, and which are withdrawn from future oil and gas leasing and other mineral entry. We recommend the 

establishment of several sage grouse Areas of Critical Environmental Concern (ACECs) in each Field Office where 

sage-grouse occur to serve this purpose. We have mapped our recommended sage grouse ACECs in Attachment 7 to 

these comments.

All Both emc0343GB

73. In addition, a sage grouse Long-Term Ecological Research (LTER) area should be established to serve as a research and 

reference area for scientific study. We recommend the lands to the south of Green Mountain in the Red Desert as a 

potential LTER site.

All Both emc0343GB

74. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage-­ ‐Provide for viable populations grouse.

over time. Allow for integrated management to prevent further fragmentation, and to implement passive and active 

restoration and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the 

verge of being lost al together in this very arid landscape. Provide habitat security for sage-grouse during lekking and nesting 

periods. Limit disturbance, stress and displacement of birds from winter habitats. Relevant Values. The Proposed ACEC 

meets the criteria of having Relevant values. Significant wildlife and other resources are found here. These are significant 

and substantial values. The qualities are of more than local significance. They are of special worth, consequence, 

distinctiveness and cause for concern. NDOW identified these lands as important for populations of sage-­ 

values of the Proposed ACEC are greatly threatened by livestock disturbance and livestock associated vegetation 

treatments and infrastructure. Livestock disturbance, facilities and vegetation treatments promote weed invasion, 

especially cheatgrass. Livestock water facilities and trampling promote West Nile virus. Livestock presence and facilities 

subsidize nest and egg predators. Livestock disturbance romote further dsertification add to stresses caused by climate 

change which are predicted to adversely impact the Great Basin and this land area. Climate change is expected to amplify 

adverse impacts of livestock grazing, further stress waters, and promote cheatgrass and other invasive species. See 

Fleischner (1994), Belsky and Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and 

Connelly (2009) Studies in Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented 

livestock grazing and facility actions, have torn apart the fabric of the sagebrush landscapein many areas, including very 

important sage-­ ‐g 

communities are critical for sage-­ 

critical for wintering habitats. The fragile, small streams, springs and seeps, and associated sagebrush habitats, provide 

essential sage-grouse brood rearing habitat. These, and higher elevation mountain big sagebrush communities, are all 

greatly threatened by continued livestock grazing disturbance which occurs at high levels during sensitive periods that 

All Both emc0348GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1257

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

conflict with sage- grouse needs for habitat security. These high levels of grazing are also degrading soils and microbiotic 

crusts which are essential as a frontline defense to prevent invasive species like cheatgrass. These high levels of grazing also 

degrade native vegetation structure, composition and function, deplete forbs, reduce essential native bunchgrass nesting 

cover, and cause other adverse impacts. Invasion of cheatgrass is alarming. Unfortunately disturbance and desertification

associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and overstocking. 

These lands are of local, regional and national significance for conservation and recovery of sage grouse and other rare and 

sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive Restoration 

for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are jeopardized by 

grazing practices and now climate change In the past, agencies have treated sagebrush and other upland areas as throwaway 

landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. Uplands have been 

carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies have adopted a 

disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must be withdrawn 

from locatable, leasable and fluid mineral development. New rights-of-way will not be allowed for energy, transmission or 

other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased out of occupied 

habitats over a period of three years. In any areas where grazing might continue longer, Appendix A practices will be 

applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other harmful facilities

will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native ecotypes of 

shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, where 

natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream flows 

will be restored to their natural condition to the maximum extent possible as developments are removed through active 

and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand-­ 

where they are shown to conflict with sage-grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel 

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage-grouse EIS process.

75. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being

lost altogether in this very arid landscape. Provide habitat security for sage-grouse during lekking and nesting periods. Limit

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause

for concern. NDOW identified these lands as important for populations of sage-grouse. The values of the Proposed ACEC

are greatly threatened by livestock disturbance and livestock-associated vegetation treatments and infrastructure.

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water

All Both emc0350GB
C. Comments by Resource Planning Issue

C-1258 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators.

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage-grouse

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for

sage-grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage-grouse brood rearing

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage-grouse needs for habitat

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure,

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on

important and essential sage-grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally

significant values. They are essential habitat for the existing declining population of sage-grouse. They provide critical

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and

populations. Loss of this PMU would further isolate sage-grouse in neighboring areas. There are identified leks within the

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water

flows. Large-scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining

lands, waters, and sage-grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross-country motorized

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994,

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1259

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long-term Viability for

Sage-grouse and Other Sagebrush-dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance.

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must

be withdrawn from locatable, leasable and fluid mineral development. New rights-of-way will not be allowed for energy,

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration,

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream

flows will be restored to their natural condition to the maximum extent possible as developments are removed through

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand-cutting of conifers only in

areas where they are shown to conflict with sage-grouse needs will be allowed. Mastication, chaining, and other treatments

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained.

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2.

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage-grouse EIS process.

76. ACEC Proposal: Gollaher, Snake PMU’s Combined ACEC Proposal BLM must designate ACECs that protect occupied 

sage-grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain 

viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal 

agency) lands together provide critical linked habitat, special designations must span artificial administrative unit 

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

All Both emc0352GB

77. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage-grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

All Both emc0352GB
C. Comments by Resource Planning Issue

C-1260 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage-grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock-associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage-grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage-grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage-grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage-grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage-grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage-grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage--‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large--‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1261

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

lands, waters, and sage-grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross-country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long-term Viability for 

Sage-grouse and Other Sagebrush-dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights-of-way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand-cutting of conifers only in 

areas where they are shown to conflict with sage-grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage-grouse EIS process.

78. ACEC Proposal: Limbo, Nightingale, Sahwave, Majuba, Trinity, Eugenes, Humboldt, East Range, Sonoma, Battle Mountain, 

Fish Creek PMU’s Combined ACEC Proposal BLM must designate ACECs that protect occupied sage-grouse habitats 

across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain viable populations in the 

short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal agency) lands together 

provide critical linked habitat, special designations must span artificial administrative unit boundaries. The Forest too must 

designate RNAs, Reserves or Conservation Areas.

All Both emc0357GB

79. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over All Both emc0357GB
C. Comments by Resource Planning Issue

C-1262 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage-grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage-grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock-associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage-grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage-grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage-grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage-grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage-grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage-grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage-grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1263

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large-scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage-grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross-country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long-term Viability for 

Sage-grouse and Other Sagebrush-dependent Species. vasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights-of-way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand-cutting of conifers only in 

areas where they are shown to conflict with sage-grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage-grouse EIS process.

80. ACEC Proposal: Lone Willow PMU ACEC Proposal BLM must designate ACECs that protect occupied sage-grouse 

habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain viable 

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C. Comments by Resource Planning Issue

C-1264 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal 

agency) lands together provide critical linked habitat, special designations must span artificial administrative unit 

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

81. ACEC Proposal: Steptoe-Cave, Lincoln, Spring-Snake Valley PMU’s Combined ACEC Proposal BLM must designate ACECs 

that protect occupied sage-grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their 

seasonal needs to sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or 

USFWS or other federal agency) lands together provide critical linked habitat, special designations must span artificial 

administrative unit boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas. FLPMA directs the 

secretary of the Interior to “prepare and maintain on a continuing basis an inventory of all public lands and their resources 

and other values ... giving priority to ACECs ...”.

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82. ACEC Proposal: South Fork, Ruby Valley PMU’s Combined ACEC Proposal BLM must designate ACECs that protect 

occupied sage-grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to 

sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other 

federal agency) lands together provide critical linked habitat, special designations must span artificial administrative unit 

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

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83. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage-grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage-grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock-associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage-grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage-grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage-grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1265

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage-grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage-grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage-grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage--‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large-scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage--‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a 

frontline defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross-country 

motorized disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 

1994, Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed 

ACEC should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the 

mandate of FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long-term 

Viability for Sage-grouse and Other Sagebrush-dependent Species. Invasion of cheatgrass is alarming. Unfortunately 

disturbance and desertification associated with livestock grazing has continued, and has been intensified by facilities 

disturbance, salting, and overstocking. These lands are of local, regional and national significance for conservation and 

recovery of sage grouse and other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage 

Grouse Habitats Require Passive Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall 

water quality and quantity are jeopardized by grazing practices and now climate change In the past, agencies have treated 

sagebrush and other upland areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued 

chronic grazing disturbance. Uplands have been carved with new fences. Livestock spring developments, water pipelines 

have proliferated. Agencies have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. 
C. Comments by Resource Planning Issue

C-1266 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Management Actions This ACEC must be withdrawn from locatable, leasable and fluid mineral development. New 

rights-of-way will not be allowed for energy, transmission or other infrastructure or developments. Existing ROWS will be 

amended. Livestock grazing will be phased out of occupied habitats over a period of three years. In any areas where grazing 

might continue longer, Appendix A practices will be applied. Livestock infrastructure, including fences, spring 

developments, pipelines, stock ponds and other harmful facilities will be removed (active restoration). Livestock and other 

disturbed areas will be seeded with local native ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation 

communities will undergo passive restoration, where natural processes return as a result of stopping activities that degrade 

them or prevent recovery. Spring and stream flows will be restored to their natural condition to the maximum extent 

possible as developments are removed through active and passive restoration. Sagebrush manipulation/treatment is 

prohibited. Selective hand-cutting of conifers only in areas where they are shown to conflict with sage-grouse needs will be 

allowed. Mastication, chaining, and other treatments involving use of large machinery are prohibited. (Active restoration). 

Ownership of all public lands will be retained. Travel will be restricted to designated roads. No utility corridors will be 

designated. Existing utility corridors may be retained. Maintenance activity for these areas will be carried out with minimal

disturbance. All lands will be managed as VRM 1 or 2. We request a meeting with BLM to discuss this ACEC proposal, and 

its incorporation into this Sage-grouse EIS process.

84. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage-grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage-grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock-associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage-grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage-grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage-grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

All Both emc0369GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1267

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage-grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage-grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage-grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage-grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large-scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage-grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross-country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long-term Viability for 

Sage-grouse and Other Sagebrush-dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 
C. Comments by Resource Planning Issue

C-1268 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

be withdrawn from locatable, leasable and fluid mineral development. New rights-of-way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand-cutting of conifers only in 

areas where they are shown to conflict with sage-grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel 

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage-grouse EIS process.

85. Significant sage-grouse habitat overlaps with BLM special designations. The plan amendment process must include a 

No-Action alternative, which recognizes the fact that federal land use plans contain existing direct and indirect protections 

of sage-grouse habitat (including wilderness areas, national parks and monuments, wilderness study areas, areas of critical 

environmental concern, special recreation management areas, roadless areas, wild and scenic rivers, No Surface 

Occupancy (NSO) areas and others). The Environmental Impact Statement (EIS) must examine the extent to which such 

existing protections, or modification of such protections, can accomplish the purpose and need for the plan amendments.

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86. BLM roadless areas provide unfragmented habitat for fish and wildlife, including sage grouse. These lands also provide 

hunters and anglers with unparalleled opportunities for high quality recreation. The BLM currently manages thousands of 

acres of important contiguous and scattered roadless areas with sage grouse habitat, including breeding and winter habitat 

and migration areas. If we don’t keep these important public lands intact, the fate of the sage grouse will remain in question.

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87. To meet its obligations under Section 202 of FLPMA, the BLM employs administrative designations that facilitate the 

conservation of high value lands, such as Areas of Critical Environmental Concern and Research Natural Areas. While 

these existing designations provide the necessary tools to conserve lands and can effectively conserve sage grouse habitat, 

the titles and terminology of these designations are often not understood by people who live near and use these public 

lands. Rural Westerners and sportsmen often are suspicious of these designations, and communicating their meaning 

requires considerable time and effort. As a result, the long-term success of preexisting administrative designations has been 

limited to a small number of areas and acres. We believe that a new conservation designation that speaks to the values of 

people using and living near BLM lands would benefit from significant support and would conserve a larger number of 

valuable acres of key habitat than would be conserved under the status quo. The TRCP recommends creating a 

“Backcountry Conservation Area” (BCA) designation for the BLM to consider and use during the land-use planning process 

that would conserve unfragmented fish and wildlife habitat to benefit sage grouse and other species, such as mule deer, 

bighorn sheep and native trout. This designation would seek to maintain the characteristics of roadless core areas and 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1269

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

would represent a multiple-use framework that allows for reasonable vegetation management exceptions to benefit fish 

and wildlife habitat and protect people from wildfire, while ensuring that unfragmented BLM lands maintain their

undeveloped character. The BCA administrative designation should be included in the land use planning handbook to be

implemented through the land use planning process to protect unfragmented sage grouse core areas from development 

activities. This designation should simultaneously allow vegetation management and mitigation activities that benefit fish and 

wildlife. The BCA designation would seek to maintain the characteristics of unfragmented fish and wildlife habitat and would 

represent a multiple-use conservation framework with reasonable vegetation management exceptions to benefit fish and 

wildlife. Most sage grouse researchers agree that sage grouse declines are due to the loss of sage brush habitat from various 

forms of development including oil and gas activity, urban expansion and grazing. A BCA designation would allow for sage

brush habitat restoration projects that would greatly benefit sage grouse. This framework would also allow for vegetation 

management as it relates to protecting communities from wildfire, while all along ensuring that the surface values of these

already undeveloped BLM lands maintain their backcountry character.

88. Lands considered for backcountry conservation designation should include the following: (1) High-quality fish and wildlife 

habitat or primitive or backcountry classifications for recreation opportunities; and (2) One of the following applies: a. The 

area is a roadless area with 5,000 or more contiguous acres of BLM lands or; b. The area is a roadless areas of fewer than 

5,000 acres of contiguous BLM lands and is contiguous with national forest inventoried roadless areas, national recreation 

areas or other roadless federal lands, or; c. The area is of sufficient size as to make practicable its conservation. Lands 

considered do not require a minimum acreage, but should have physical features that make it possible to delineate area 

boundaries and manage the area for conservation purposes.

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89. We recommend the BCA designation incorporate the following management principles: · This designation will conserve 

specific, unfragmented BLM backcountry areas with highquality fish and wildlife habitat and/or significant sporting 

opportunities. · Designated areas will remain open to public hunting, fishing and trapping, and state fish and wildlife agencies 

will retain management authority over fish and wildlife populations. · This designation will maintain existing authorized and 

permitted motorized routes that are important for sportsmen to access backcountry areas for hunting and fishing. · The 

construction of new motorized routes within designated backcountry areas will be restricted to conserve unfragmented 

habitat and hunting and fishing opportunities. · Vegetation management will be limited to projects that improve fish and 

wildlife habitat, control noxious weeds and reduce the risk of wildfire, such as projects to control cheat grass and restore 

sage brush. · Prescribed burning and the installation and maintenance of water guzzlers will be allowed within designated 

areas. · Chainsaws, helicopters and mechanical devices, such as game carts, will be allowed within designated areas. · This 

designation will conserve unfragmented habitat by requiring that utility corridors, pipelines and conventional and renewable

energy development be located outside the boundaries of designated areas. This requirement will not be waived. · This 

designation will not affect valid existing rights, public lands grazing allotments or the ability of ranchers to maintain 

agriculture improvements.

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90. The initial planning notice invited commenters to recommend areas on BLM lands for designation as ACECs (76 Fed. Reg. 

77011) and, while the recovery alternative recommends designating a system of ACECs on BLM land to conserve 

sage-grouse and other sagebrush dependent species, we request the BLM extend the comment deadline for the public to

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C. Comments by Resource Planning Issue

C-1270 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

nominate ACECs as part of the planning process. ACECs should be central to the BLM’s sage-grouse conservation strategy. 

The public should have additional time to identify and nominate ACECs, particularly since key information, such as maps of 

priority and general sage-grouse habitat, are not yet publicly available, like in Utah (see BLM Memo 2012-144).

91. The sage-grouse planning process should identify and designate a system of sagebrush reserves to conserve sage-grouse 

and other sagebrush-dependent species. In the planning process, these reserves take the form of special land use 

designations. Some (perhaps most) priority habitat on public land should be designated as sagebrush reserves. These areas 

should receive even greater protection than priority habitat. The reserve system would be the basis for sage-grouse 

recovery and long-term persistence in the face of climate change and continuing land uses on remaining sage-grouse 

priority and general habitat. Reserves on BLM land should be designated as areas of critical environmental concern. 

Similarly, the USFS should administratively designate sagebrush conservation areas to protect sage-grouse and other 

sagebrush-dependent species (36 CFR § 219.27). Both agencies should also establish additional RNAs as appropriate in 

sagebrush steppe.

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92. The USFS may “adopt special designations through plan amendment or revision” to conserve natural resources (36 CFR § 

219.27). The USFWS should administratively designate sagebrush conservation areas (SCAs) in the current planning 

process with similar purpose and management as BLM ACECs to conserve sage-grouse and other sagebrush dependent 

species on National Forest System lands.

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93. The BLM and USFS should each designate Research Natural Areas (RNAs) in sagebrush steppe (43 CFR § 8223.0-1 -

8223.1; 36 CFR § 251.23, respectively). Both agencies have promulgated regulations to administratively establish RNAs to 

permanently protect species, ecosystems and natural conditions on public land for the purposes of conserving biological 

diversity, conducting non-manipulative research and monitoring, and fostering education. RNAs are commonly designated 

to preserve high quality examples of widespread ecosystems; unique ecosystems or Sage-Grouse Recovery Alternative Ï

Page 31 of 121 ecological features; and rare or sensitive species of plants and animals and their habitat. RNAs can help 

protect biological diversity at the genetic, species, ecosystem and landscape scales. These areas are managed to maintain 

the natural features and processes for which they were established, and so detrimental land uses are typically prohibited.

The Forest Service Chief is specifically directed to “establish a series of research natural areas sufficient in number and size 

to illustrate adequately or typify for research or education purposes, the important forest and ranges in each forest region, 

as well as other plant communities that have special or unique characteristics of scientific interest and importance” (36 CFR 

§ 251.23). USFS has already designated numerous RNAs in sagebrush steppe, although relatively few in Nevada, and none 

in Wyoming (see Appendix 6), where the agency manages significant sagegrouse habitat. The agency should designate 

additional RNAs in sagebrush steppe as part of the proposed planning process in accordance with applicable law.

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94. d. Guidelines for Designating Sagebrush Reserves 1. Protect Large Expanses of Sagebrush Steppe Greater Sage-grouse are 

a landscape species (Connelly et al. 2011a). Migratory populations have large annual ranges that can encompass >2,700 km2 

(1,042 mi2/667,184 ac) (Knick and Connelly 2011b, citing Dalke et al. 1963; Schroeder et al. 1999; Leonard et al. 2000) (the 

species may use up to 2,500 mi2 per population (Rich and Altman 2001)). Large-bodied birds are generally more strongly 

affected by habitat loss and fragmentation (Winter et al. 2006). Although conclusive data on minimum patch size is 

unavailable (Connelly et al. 2011a), conserving large expanses of sagebrush steppe is the highest priority to conserve 

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C. Comments by Resource Planning Issue

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sage-grouse (Aldridge et al. 2008; Connelly et al. 2011b). Knick and Hanser (2011) identified ten lek complexes that were 

>5,000 km2 (1,930 mi2/1,235,526 ac) (range 5,395–100,288 km2) and 8 of them contained >100 leks (range 143– 1,139) 

(see Map 9). Some sagebrush-dependent species use different habitat composition, structure or succession than 

sage-grouse prefer. Protecting large blocks of habitat will also help preserve a mosaic of different habitats of varying 

successional stages used by sage-grouse and other sagebrush-dependent species.

95. 2. Protect Small Areas and Connectivity in Sagebrush Steppe Protecting small habitat patches can help connect larger areas. 

Conservation strategies for sagegrouse should preserve networks of populations and/or habitat patches, including 

connecting smaller lek complexes within 18 km that could serve as intermediary islands of habitat for dispersing 

sage-grouse (Knick and Hanser 2011). Protecting small habitat patches is also important to conserve smaller birds and 

maintain avifaunal diversity (Winter et al. 2006). Sage-grouse may move long distances between seasonal habitats (Connelly 

et al. 1988). Annual movements of 40-160 km (24.8-99.4 mi) by sage-grouse along established routes have been reported 

(Dalke et al. 1963; Connelly 1982; Leonard et al. 2000). Although much is still unknown about the distribution, 

configuration, and characteristics of sage-grouse migration corridors (Connelly et al. 2011a), Beck et al. (2006) 

recommended conserving habitat corridors to facilitate easier movement for migratory sage-grouse.

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96. 3. Protect Sage-Grouse Leks, and Nesting and Brood-rearing Habitats The loss and degradation of nesting and 

brood-rearing habitats, which leads to reduced nesting success and increased chick mortality, appears to be a primary cause 

of declining Greater Sagegrouse populations rangewide (Aldridge and Boyce 2007; Holloran et al. 2005). Most sagegrouse

nesting and brood-rearing habitat is found near sage-grouse leks. Sage-grouse conservation strategies should focus on 

protecting leks and associated habitat. • Conservation of sagebrush within 5 km (3.1 miles) of sage-grouse leks was

recommended to maintain most nesting and early brood-rearing habitat used by nonmigratory populations, whereas 18-km 

radii (11.2 miles) have been recommended for migratory populations (Wakkinen et al. 1992; Connelly et al. 2000; Holloran 

and Anderson 2005). • Braun (2006, unpublished report) recommended restricting surface occupancy and construction of 

new roads within 5.5 km (3.4 mi) of active sage-grouse leks. • A 4-mile (6.4 km) lek buffer encompassed 74-80 percent of 

sage-grouse nests in Montana and Wyoming (Moynahan 2004; Holloran and Anderson 2005). • Doherty et al. (2010b), in 

mapping breeding densities of Greater Sage-grouse rangewide, buffered leks by 8.5 km (5.3 mi), identified by Holloran and 

Anderson (2005: 746) as an area of interest (see Map 10). • A majority (~90%) of nesting and brood-rearing habitat was 

within 10 km (6.2 miles) of active leks in Alberta (Aldridge and Boyce 2007); 97 percent of nests were found within 6.2 miles 

of leks where females were marked in the Powder River Basin in Montana and Wyoming (Doherty et al. 2010a). • 

Sage-grouse nesting habitat was accurately predicted up to 20 km (12.4 mi) from leks in the Powder River Basin in Montana 

and Wyoming (Doherty et al. 2010a). • Effects of gas and oil drilling on sage-grouse were noticeable out to 12.4 miles from 

leks (Taylor et al. 2012). • Movements from lek sites to nesting locations can exceed 25 km (15.5 mi) (Holloran and

Anderson 2005). • Characteristics of sagebrush steppe within 54 km (33.6 miles) of sage-grouse leks might influence 

seasonal movements and also incorporate habitats used outside the breeding season (Swenson et al. 1987; Leonard et al. 

2000). GIS modeling can identify sage-grouse habitat, but only at a larger scales (Doherty et al. 2010a). Within areas 

identified by GIS modeling as nesting habitat, there is some local variability in which sites are actually suitable for nesting 

(Doherty et al. 2010a). For example, sage-grouse nests may be clumped in one area, but not other areas the same distance 

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from a lek.

97. 4. Protect Other Seasonal Habitats Conservation strategies focused on conserving sage-grouse nesting and brood-rearing 

habitats that fail to address other important seasonal habitats may not yield intended benefits for sagegrouse (Connelly et 

al. 2000; Doherty et al. 2008). For example, sage-grouse consume forbs in summer found at mesic sites (e.g., wet meadows, 

riparian areas) and/or at higher elevations (Connelly et al. 2011a, citing others). A lack of mesic sites (for example, during 

dry years) can be limiting on sage-grouse due to lack of summer food sources (Aldridge 2000). Conservation strategies 

should seek to protect and restore mesic sites in sage-grouse habitat. The availability of winter habitat is also important to 

sage-grouse persistence. The quality of winter habitat appears to influence the abundance and condition of female 

sage-grouse and their nesting effort and clutch sizes in spring (Moynahan et al. 2007). The species depends almost

exclusively on sagebrush exposed above the snow for food and shelter (Connelly et al. 2011a, citing others). Suitable winter 

habitat is often on wind swept ridges, south-facing slopes or in protected draws (Braun et al. 2005) (although research in 

Canada also identified winter habitat is less rugged areas and away from energy development and two-tracked roads 

(Carpenter et al. 2010)). These landscape features may be limited in some areas (e.g., Beck 1977). Winter habitat should be 

locally identified and conserved (Braun et al. 2005, citing Connelly et al. 2000 and others; Moynahan et al. 2007).

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98. 5. Protect a System of Reserves A system of reserves must conserve a large proportion of habitat to sustain biological 

processes and conserve species. The commonly cited goal of conserving 10 percent of a given landscape lacks basis in 

science (Soulé and Sanjayan 1998; Svancara et al. 2005). Much larger areas, perhaps 50 percent of rangewide distribution, 

may be necessary to conserve biodiversity and ecosystem integrity (Soulé and Sanjayan 1998). Conservation sites identified 

by experts to protect diverse habitats and species (including sage-grouse) in the Great Basin covered 40 percent of the 

region (Nachlinger et al. 2001, unpublished report). A system of reserves must be large enough to achieve the goals of 

biological representation, and ecological redundancy and resiliency within an ecosystem (Svancara et al. 2005). The 

percentage area needed to conserve biodiversity and ecosystem processes should emerge from the biological 

requirements of species. Braun (2006, unpublished report) recommended conserving large blocks of sagebrush steppe (in

excess of 20 mi2), one per Township (36 mi2), in fragmented habitat to conserve sage-grouse. A system of reserves should 

protect centers of species abundance on the landscape. Doherty et al. (2010b) found that, while sage-grouse occupy large 

areas, their breeding distribution is aggregated in relatively small areas. Areas representing 25 percent of the known 

sage-grouse population were 3.9 percent of the species range, and 75 percent of sage-grouse were within 27 percent of the 

species range (Doherty et al. 2010b) (see Map 10). A system of reserves should protect peripheral and/or genetically 

distinct populations of species. Peripheral populations are often located at the ecological limits of a species range, where 

species are exposed to environmental circumstances that may later become prevalent in central populations, such as effects 

from climate change. Such testing of the periphery can act to stabilize the entire species in the face of environmental change 

(Lesica and Allendorf 1995). Genetically distinct populations increase genetic diversity in a species and expand the genetic

background against which natural selection occurs (Lesica and Allendorf 1995). Reserves should be designated to protect 

the Columbia Basin and Bi-State distinct population segments of Greater Sage-grouse in Washington (Wisdom et al. 2005c) 

and eastern California/southwestern Nevada, respectively. A system of reserves should prioritize preservation of areas 

have moderate or high potential to be maintained or restored in the face of climate change, cheatgrass incursion, unnatural 

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fire and effects from historic and current land uses (see Wisdom et al. 2005c). In general, most areas with high potential to 

maintain or restore sagebrush communities are concentrated in Wyoming, eastern Idaho and northern Nevada. Areas with 

very low, low, or moderate potential to maintain or restore sagebrush are concentrated in Washington, Oregon, western 

Idaho and much of Nevada (Wisdom et al. 2005c). The recovery alternative includes criteria for designating ACECs (and 

SCAs) based on these guidelines and applies them to Utah and Wyoming to demonstrate how BLM should designate

ACECs rangewide (see Maps 12 and 14).

99. While we understand that BLM has certain obligations, set by legislation, regarding the management of feral horses, such 

obligations should not take precedence over management and conservation of a native species, such as greater sage-grouse.

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100. The Interim Management 1M applies to ongoing and proposed BLM actions, including use authorizations, within Preliminary 

Priority Habitat (PPH) and Preliminary General Habitat (PGH). PCW has concerns with the agencies identification of PPH 

and development of PPH and PGH maps. In developing its Sage-Grouse Core Area maps, the Wyoming Sage-Grouse

Implementation Team first established standards for protecting the greater sage-grouse ropulation (initially 67%), and then 

used a consultative process to involve interested stakeholders including industry and non-governmental organizations, the 

local sage-grouse working groups, and other interested members of the public to identify habitats and areas of connectivity 

important to sustaining greater sage-grouse populations, leading to enhanced protection of over 83% of the greater 

sage-grouse population in Wyoming. By contrast, the Preliminary Priority Habitat maps that have been developed for other 

states appear to use different methods in each state. For example, Nevada's map is clipped to federal and state lands and 

appears to be delineated by sagebrush land cover. Idaho, southwestern Montana and Colorado appear to be driven 

primarily by lek densities. Because of these inconsistencies, BLM should open the maps up for additional public comment, 

scientific review, and independent analysis prior to moving forward with the planning process. The outcome of the planning 

processes that BLM is completing will determine the types of activities that can occur in Priority Habitat for greater 

sage-grouse. Arbitrary or inconsistent definition of these Priority Habitat areas could present management and regulatory 

challenges that may be avoided with appropriate review of the maps and methods used to develop the Priority Habitat 

areas

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101. BLM and the USFS must establish an open, public process for identifying Priority Habitat and General Habitat maps for the 

EISs and SEISs and consult with interested stakeholders, including local sage-grouse working groups and industry groups. 

The maps must be based upon best available science, account for local habitat conditions and knowledge, and recognize 

valid existing rights and consider reasonably foreseeable future action~

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102. The BLM should also establish standards for assessing and identifying Priority Habitat and General Habitat. All Both emc0399GB

103. Administrative designation would include Areas of Critic~l Environmental Concern (for BLM lands) or Research Natural 

Areas (for both BLM and USFS lands). Since these designations are typically made during the land use planning process, it is 

entirely appropriate and necessary that these designations be considered at this point in time, as the plans are revised. 

These areas could be defined as the 75% core areas plus a buffer, as defined in Doherty et al. (2011), and should include 

management guidelines focused on protection of sagegrouse and their habitat. Ideally, the designated areas should also be 

as large, intact and unfragmented as possible and be connected with other habitat blocks.

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104. In the past across the sagebrush biome, BLM has been loathe to consider sagebrush habitats of any significant or effective 

size for ACECs. This is despite the fact that, in areas like the Interior Columbia Basin Ecosystem Project analysis area, the

need to protect important habitats at the landscape level has long been recognized. But significant Reserves have not been 

created. Very few significant ACECs have been created. Instead, ACECs have focused on small bits of land typically related 

to small occurrences of rare plants or some cultural areas. BLM had methods all along to protect habitats, but refused to 

do so. Time after time, it has allowed industry to de-rail protections. Example: WWP Bennett Hills Sagebrush Sea ACEC 

proposal. Even though Shoshone BLM was conducting a Plan amendment, and the ACEC was endorsed by IDFG at the 

time, the BLM slammed the door on landscape management of this critically important area as an ACEC. The Forest has 

only designated very small RNAs, typically sites in higher elevation areas. Next to nothing has been done to protect 

sage-grouse habitats that we are aware of. In fact, in current grazing analyses, the Intermountain Region appears hellbent on 

authorizing and extending grazing across Vacant allotments in rugged inhospitable arid terrain, and even opening longclosed

allotments, or allowing illegal grazing in Closed Allotments, as has been occurring on Ely Forest Service lands in the 

Grant-Quinn Range. See WWP EWE EIS Appeal.

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105. As part of this sage-grouse process, BLM should conduct a new WSA inventory. It has time to amend Land Use Plans to 

protect from any additional roading or road upgrading intrusion into significant areas of unroaded or little-roaded lands. 

Keeping roads from expanding or being “improved” would also limit human disturbances and help prevent increasingly 

motorized livestock management activity from further degrading and intruding into habitats. Unroaded areas in the 2012 

setting often have very significant natural and biological values. There is high public appreciation of unroaded wild scenery, 

too. Unroaded sagebrush lands that are now present occur in a landscape that has become increasingly fragmented since 

the old Wilderness inventories treated sagebrush as a disposable landscape, and used excuses about boring scenery to cast 

these lands aside. Today, sagebrush wild lands are very precious, and sought out by the recreational public for aesthetic 

enjoyment, nature study, scientific study, hiking, camping, backpacking, photography and many other recreational pursuits. 

There remain, for example, in Idaho, Nevada, Oregon, Utah and other areas, scenically magnificent wild sagebrush lands 

juxtaposed with rugged mountain ranges. Understanding how these lands coincide with sage-grouse habitats and 

populations, which would be an important Biological Feature of wilderness-worthy lands is also essential. New and current 

inventories that fully recognize such biological and aesthetic values must be conducted. Unroaded sagebrush wild lands in 

Wyoming are under great assault by energy developers.

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106. Then the real analysis would come with establishing a valid current baseline of ecological conditions so that critically 

important conservation measures and restoration actions could be applied, and in drawing boundaries and integrating 

management for large ACECs that encompass habitats necessary to conserve, enhance and restore populations. Current 

sage-grouse abundance and distribution must be expanded. In these areas, BLM must require that ongoing disturbance be 

minimized, and that disturbance be eliminated in sensitive areas. The ACECs must also encompass restoration areas and 

specific actions necessary to support populations that can expand and be viable over the mid and long term. Passive 

restoration, such as removing livestock grazing disturbance, which produces benefits very rapidly and is much less 

expensive over large areas than risky manipulation schemes, must be conducted in areas with remaining native sagebrush 

vegetation components occupied by sage-grouse. Active restoration must focus on removal and rehab of fences, water 

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lines and troughs, linked roading, and numerous other disturbances, and seeding sagebrush and other native species to 

expand habitats.

107. BLM must provide the public with high quality information as a baseline to fully prepare ACECs, and the comment period 

for fully detailing these proposals must be extended to allow this.

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108. BLM pays lip service to WSA Interim Management measures. BLM must identify sources of degradation and impairment in 

WSAs and Wilderness related to livestock grazing, water developments, fences, salting/supplement feeding, roading, 

seasons of use interfering with sage-grouse nesting and native plant health, and other disturbances and degradation. It must 

act to remove these as part of this process, as livestock facilities and roading adversely impact sagebrush communities and 

thus sage-grouse habitats and populations. BLM must fully recognize that the values of sagebrush landscapes are now much 

greater than at the time the old BLM Wilderness inventories were conducted. BLM must carefully determine how the 

natural values of WSAs are enhanced and elevated by the WSA supporting thriving populations of sage-grouse. Sage-grouse 

management complements management for wild untrammeled landscapes. BLM must identify actions to promote this. 

What livestock facilities were present when the WSA was inventoried? How does this compare to those now present? 

Which facilities are harming natural and other values - and which must be removed due to degradation and 

harms/impairment including of natural features, and sage-grouse habitats and populations?

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109. We are greatly concerned that BLM will conduct excessive prescribed fire disturbance in WSAs under the guise of sage 

grouse habitat or "fuels." "Treatments" and artificial human manipulation of wild lands must be constrained. Why is there no 

mention of Forest roadless lands? The same must be applied to identified USFS roadless areas, Wilderness, and other 

unroaded lands. Plus FWS and other lands, as well - for example, the WSAs on Sheldon.

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110. Appropriate ACECs must be designated to provide for viable, recovering populations that increase the distribution and 

abundance of the populations.

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111. Landscapes must be conserved in large ACECs, due to sagegrouse sensitivity to disturbance, and given the sensitivity of 

sage-grouse to disturbance, these habitats must be buffered.

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112. BLM roadless areas, commonly called backcountry, provide unfragmented habitat for many species of fish and wildlife, 

including sage grouse. These lands also provide hunters and anglers with unparalleled opportunities for high quality 

recreation. The BLM currently manages thousands of acres of contiguous and scattered roadless areas which provide key 

sage grouse habitat, including breeding and winter habitat and migration corridors. If we don’t keep these important public 

lands intact, the fate of the sage grouse will remain in question.

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113. Another key provision should be the creation of sagebrush reserves that protect the best remaining habitat from harmful 

land uses

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114. BLM should also designate a system of sagebrush reserves as Areas of Critical Environmental Concern to protect the 

highest quality remaining habitat from degrading land uses

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115. Administrative designations, such as Areas of Critical Environmental Concern (ACEC) and/or Research Natural Areas 

(RNA), should be used to protect priority sage-grouse habitat on BLM lands.

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116. The BLM should recognize that some areas are not appropriate for development. Each plan should permanently protect 

some natural areas that are high priority sage-grouse habitat from activities that have been documented to be harmful to 

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grouse populations. Large-scale development activities, such as drilling and mining, should be directed away from the most 

important sage-grouse habitat. Areas of Critical Environmental Concern should be designated to protect a large amount of 

priority habitat from major disturbances.

117. If Sage Grouse determination on lands in existing WSAs, ACECs and T&E areas are redundant and or duplicative those 

restrictions will not be assessed.

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118. Use of the Sage Grouse Strategy to change the multiple use mandate of so called. Wilderness Characteristic areas with uses 

already prescribed in exiting LUP's or to create Wildland areas within established or ongoing LUP's will constitute an 

agency fiat of an action reserved by Congress and shall be reported to the Chairman of the House Natural Resources 

Committee.

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119. So will designation of a system of sagebrush reserves as Areas of Critical Environmental Concern (to protect the highest 

quality remaining habitat from degrading land uses) and retirement of grazing permits in the West.

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120. Don't use this project to identify "wilderness character lands" leave that issue to the appropriate planning time frame and 

the implementation to Congress.

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121. If this EIS management plan is adopted will the existing AEC Management plans be abandon or significantly modified? All Both rmc0036GB

122. How many AECS include areas where juniper Encroachment exists and how much acreage is now proposed for treatment 

in these areas?

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123. Similarly, the NOI invites the public "to nominate or recommend areas on public lands for Greater SageGrouse and their 

habitat to be considered as Areas of Critical Environmental Concern as part of this planning process." Such designations 

should follow a stand-alone process for establishing Areas of Critical Environmental Concern, providing public notice and 

opportunity for comment BEFORE any such Areas are designated. These should not be rolled into and hidden within the 

actions associated with Sage-Grouse actions.

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124. addition, on December 13, 200 l we submitted a nomination for the Tyler Mountain ACEC and such nomination and the 

reports are incorporated by reference (ACEC Nomination), See also BLM's administrative record for the August 2011 

lease sale for comment letters from federal, state and local governments describing the important wildlife habitat and water 

resource values on Pinto Valley Ranch: L Sidener, Colorado Department of Wildlife (CDOW) (February 17, 2011) 

attached toR, Watson's Comment Letter as Exhibit 3; Grand County Commissioners (February 1, 2011) attached to R,

Watson's Comment Letter as Exhibit 4; Colorado River Water Conservation District (March 24, 2011) attached toR, 

Watson's Comment Letter as Exhibit 4; R Timberman, U,S, Fish and Wildlife Service (USFWS) (March 22, 2011) attached 

thereto as Exhibit 5; and M, Volt, U,S, Department of Agriculture, Natural Resource Conservation Service (NRCS) (March 

22, 2011) attached toR, Watson's Comment Letter as Exhibit 6 (all of the foregoing comments are incorporated by 

reference),

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125. Fmihermorc, as previously requested, BLM should designate and protect the areas owned by Wingspread West LLC, 

McGee Resources LLC, Tyler Mountain LLC, Casdorf Holdings LLC, Ingram Homestead LLC and Shawkemo Enterprises 

Inc (collectively, Stolz) subject to a BLM split estate and depicted on the map attached to the ACEC Nomination as Exhibit 

2 (Proposed Tyler Mountain ACEC), The Proposed Tyler Mountain ACEC deserves special management attention because 

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it contains large continuous unfragmented critical habitat for endangered, sensitive and threatened plant and animal species 

(including habitat essential for maintaining species diversity), rare, sensitive and endangered plant communities, rare 

geological and paleontological resources, cultural resources and original homestead and other historic structures,

significant scenic values that contain more than locally significant qualities and circumstances that make it fragile, sensitive, 

rare, irreplaceable, exemplary, unique, endangered, threatened and vulnerable to adverse change, Each of these factors

individually warrants special management attention but, when taken together, the totality of the area resources provides 

even more compelling justification for an ACEC designation for the Proposed Tyler Mountain ACEC due to the cumulative 

and overlapping resources, As compared to other similarly situated areas that have been designated or proposed as ACECs 

(in particular, the Kremmling PCA ACEC and the Kremmling Ammonite ACEC which are in the same immediate area as 

the Proposed Tyler Mountain ACEC and contain resources similar, if not inferior, to those on the Proposed Tyler 

Mountain ACEC), the Proposed Tyler Mountain ACEC requires at least the same special management designation in order 

to protect and prevent irreparable damage to important paleontologic, historic, cultural, and scenic values; plant and

wildlife resources; and other natural ecosystems or processes.

126. BLM is obligated to manage the sage-grouse, a BLM "special status" species and ESA candidate species, to prevent its listing 

under the ESA. Dr. M. Holloran, a sage grouse expert whose research is cited extensively by BLM throughout the 

DRMP/DEIS, based on his expertise, investigation and site-visits to the Proposed Tyler Mountain ACEC, has concluded that 

the "sagebrush dominated areas on [Proposed Tyler Mountain ACEC] have special worth, significance, distinctiveness and 

substantial values for sage-grouse and the sagebrush habitats on the [ProposedTyler Mountain ACE C) are significant and

critical for management of the species in Colorado." Dr. M. Holloran Cover Memo to Report, "Identification of 

Sage-Grouse Occupied Habitats on Split-Estate Portion of Pinto Valley Ranch, Grand County, Colorado" (November 

2011), Exhibit II to R. Watson's Comment Letter. (emphasis added). Dr. Holloran concludes that to properly protect the 

sage-grouse and its habitat, the Proposed Tyler Mountain ACEC's split-estate parcels should be closed to oil and gas 

development ~ that the suggested timing restrictions in the DRMP/DEIS Altemative B for these split-estate lands are 

inadequate.

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127. The sage-grouse on the Proposed Tyler Mountain ACEC are part of the Middle Park population on the eastem border of 

the bird's range in northwest Colorado. In 1999, the Middle Park Greater Sage-grouse Working Group 4 was formed and 

with the assistance of state and federal agencies including USFWS, the U.S. Geological Survey (USGS) and CDOW 

completed the Middle-Park Greater Sage-Grouse Conservation Plan (Middle Park Plan) in 200 l. 5 The Middle Park Plan 

specifically recognizes the important and critical contribution of private lands to the area sage-grouse since private surface 

provides a substantial portion - some 26% - of the sage-grouse habitat in Middle Park. BLM is a formal signatory and a 

committed participant in the implementation of the Colorado Greater Sage-grouse Conservation Plan (March 2008) ("CO 

Sage-Grouse Plan")6 BLM committed "to work with private landowners ... to implement necessary conservation actions to 

maintain or enhance Greater Sage-grouse habitat." See CO Sage-Grouse Plan Signature Page. There is at least one 

identified lek (Castle lek) on the Proposed Tyler Mountain ACEC and additional leks are found on adjacent properties. See 

Exhibit I at Er. D-1. D-3 toR. Watson's Comment Letter. There is also evidence of additional leks on the Proposed Tyler 

Mountain ACEC. !d.; see also EXhibit 7 at 1-2; Exhibit 9 at I to R. Watson 's Comment Letter.

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128. For Special Status Species, like the sage-grouse, "habitat loss and fragmentation have been, and remain, the primary cause 

of their imperiled status." DRMP/DE!S, Ch. 3 at 3- 100. BLM recognizes that "[l]arge contiguous areas of habitat have been 

shown to support aud maintain Greater sage-grouse populations, and are necessary in order to provide lower densities of 

nesting hens." !d. Ch. 4 at 4-283. Given the highly specific requirements of sage-grouse nesting and wintering habitat, any 

disruption is detrimental to sage-grouse populations. !d. at 4-283. Thus, BLM recognizes it is crucial to preserve large blocks 

of un-fragmented sagebrush habitat. Considering only the Castle lek, all of the split estate parcels on the Proposed Tyler

Mountain ACEC are within 2-3 miles of a lek. Furthermore, this split estate surface provides important nesting, brood 

rearing and winter habitat for a resident population of sage-grouse. Exhibit I at Ex. Bto R. Watson's Comment Letter (Dr. 

Holloran report,March 22, 2011 ). A more recent on-site survey confirms that these sage-grouse occupy 88% of the split 

estate parcels on the Proposed Tyler Mountain ACEC. 7 Exhibit11 toR. Watson's Comment Letter. Dr. Holloran has 

concluded that "sagebrush habitats on [Proposed Tyler Mountain ACEC] are suitable for sage-grouse; all sagebrush 

dominated areas of [Proposed Tyler Mountain ACEC] that were surveyed during field efforts are used by sage-grouse; and 

all sagebrush habitats on [Proposed Tyler Mountain ACEC] that were surveyed during field efforts should be protected as 

core sage-grouse habitat as established in the Colorado greater sage-grouse conservation plan ... the[se} sagebrush 

dominated areas on [Proposed Tyler Mountain ACEC} have special worth, significance, distinctiveness and substantial 

values for sage-grouse ... " Exhibit II Cover Memo atl to R. IVatson ·s Comrnent Letter (emphasis added). See also Holloran 

in Stolz EA Comments (Ex. 1) at Exhibit Band Maps at Exhibit D-1 to D-3. His expert conclusion is that the Proposed Tyler 

Mountain ACEC, including split-estate parcels subject to federal oil and gas development, hosts a largely sedentary, 

non-migratory population of sagegrouse that enjoy unfragmented access to all their seasonal habitat needs and that need to

be protected as core sage-grouse habitat. !d.

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129. The CDOW has also identified the Proposed Tyler Mountain ACEC split-estate parcels as important sage-grouse habitat. 

According to biologists with CDOW, the Middle Park sage-grouse population is one of only two populations in Colorado 

not influenced by oil and gas development. ld, Cover Memo at 1. The CDOW recommended the deferral of the Proposed 

Tyler Mountain ACEC parcels from leasing and emphasized that the CO Sage-Grouse Plan calls for "expansion of current 

greater sage-grouse protections (e.g., 0.6 mile no surface occupancy (NSO) around leks, expansion of nesting habitat timing

limitations to 4-mile radii)." See Aug 20 II Lease Sale Comments, L. Sidener, CDOW, (February 17, 2011 ). Thus, this 

CDOW recommendation would include all the Ranch split estate parcels which are 3-4 miles or less from the Castle lek. 

!d. CDOW also strongly recommended that BLM defer leasing on CDOW core area on both federal and fee surface. Jd. 

The CDOW concluded its comments on the Proposed Tyler Mountain ACEC sage grouse by noting that "base[ d] on radio 

collard data, all the parcels ... had sage grouse activity." !d.

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130. Dr. Holloran's March 20 I I report (Exhibit I, Ex. B) provides detailed support of his conclusion that for this sedentary, 

non-migratory sage-grouse population, the habitat on the Proposed Tyler Mountain ACEC is priority habitat that should be 

protected from leasing under the terms of the Sage-grouse JM. This conclusion was strongly confirmed with the results of 

the 2011 survey. Exhibit Il to R. Watson's Comment Letter. Dr. Holloran's conclusion is that oil and gas development, will 

negatively influence the sagegrouse population that is reliant on habitats surrounding the active lek. Sage-grouse breeding, 

nesting, early brood-rearing, and late brood-rearing/summering, and wintering habitats may be directly impacted by

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development of these parcels. !d. at 2. In sum:

131. Sage-grouse Nesting and Early Brood-Rearing Habitats ··- There is potential nesting and early brood-rearing habitat within 

8 km of known lek as identified through the Colorado Vegetation Classification Project data. CDOW documented

sage-grouse use of all parcels, supporting the conclusion that suitable habitat exists in the parcels. Sagebrush dominant 

habitats within 5.5 km of a lek have a higher probability of use for nesting and early brood-rearing. Female sage-grouse avoid 

nesting within 1 km of oil and gas infrastructure and have a lower annual survival. Chick survival decreases within l km of 

visible wells. !d. at 2.

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132. Sage-grouse Late Brood-Rearing and Summer Habitats -Potential suitable sagegrouse late brood-rearing habitats exist 

within all of BLM split estate parcels. Important sage-grouse brooding habitat generally includes wet areas such as

meadows, springs, ponds and streams plus a 200-m zone around these water features. The mesic cover classes from the 

Colorado Vegetation Classification Project support a professional conclusion that the parcels include potential late

brood-rearing habitat. Female sage-grouse breeding or nesting near oil and gas development have decreased summer 

survival. Brood-rearing female sage-grouse avoid areas with high densities of visible wells within 1 km. Chick survival also

decreases. ld. at 2.

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133. Risk to Sage-grouse from Cheatgrass- Finally, Dr. Holloran noted the risk of the infiltration of Cheatgrass and other grasses 

as a result of oil and gas disturbance that would negatively impact the sagebrush obligate sage-grouse. This would limit the 

population, eliminate nesting and early brood-rearing habitat and reduce winter and severe winter range. !d. at 7.

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134. Dr. Holloran concludes that, "research suggests that oil or gas development within sagebmsh habitats on or near [Proposed 

Tyler Mountain ACEC) would fall within the spatial scale where persistence of sage-grouse populations residing on the 

[Proposed Tyler Mountain ACEC] would likely be jeopardized." Exhibit 11, Cover Memo at 1-2 to R. Watson's Comment 

Letter. Oil and gas development on one of only two areas in the State that host sage-grouse populations not influenced by 

oil and gas makes no sense given BLM 's policy to treat the sage-grouse as listed and to maintain and improve habitat.

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135. significant problem for BLM's analysis and proposed mrtrgation for sage-grouse habitat is that the CDOW map of 

sage-grouse habitat upon which BLM has relied, is not accurate for site-specific management. !d. at 2. The CDOW 

sage-grouse core areas were developed at statewide spatial scales and were never intended by CDOW to be utilized for 

site-specific consideration as BLM has done in the DRMP/DEIS. Jd. The CDOW maps simply do not accurately reflect the 

habitats occupied by sage-grouse as is made abundantly clear by Dr. Holloran's on-site survey. Exhibit II. The conclusions of

CDOW (L. Sidenar, CDOW Comment, February 17, 201 0) and Dr. Holloran support moving the occupied area boundary 

line further west and closing the area to oil and gas leasing and including the greater area in the ACEC. See Exhibit II at 2; 

see also Stolz EA Comments (Ex. 1) at Ex. B.

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136. As discussed by Dr. Holloran (Exhibit II, Cover Memo), in the DRMP/DEIS Appendix S, the Kremmling Potential 

Conservation Area is recommended as an ACEC by BLM because the "area contains important core habitat for greater 

sage-grouse . . ." DRMP/DEIS, App. Sat E-11-12. Yet, the Kremmling PCA is located within core sagegrouse habitat 

associated with the Castle lek, the identified lek, on the [Proposed Tyler Mountain ACEC]. Exhibit II, Cover Memo at 2. As 

Dr. Holloran points out: without protection of the population of sage-grouse that breeds on the lek located on [Proposed 

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Tyler Mountain ACEC], the Kremmling PCA ACEC will provide no value for sage-grouse because there will be no 

sage-grouse to use the area. . . Given that habitats on (Proposed Tyler Mountain ACEC} have special worth, significance, 

distinctiveness and substantial values, it is my opinion that sagebrush habitats on [Proposed Tyler Mountain ACEC} are 

worthy of at/east the same protections as those afforded the Kremmling PCA ACEC. Exhibit 11, Cover Memo at 2. 

(emphasis added). The fact that BLM has proposed to protect the sage-grouse habitat in the Kremmling PCA ACEC and the 

sage-grouse and paleontological resources in the Kremmling Ammonite ACEC should provide strong and compelling 

precedent for a special management designation for the same resources that are found over the BLM's interest in the 

Proposed Tyler Mountain ACEC.

137. In summary, Dr. Holloran states "it is safe to conclude that a large, non-migratory population of sage-grouse inhabits 

[Proposed Tyler Mountain ACEC] and that habitats found on the [Proposed Tyler Mountain ACEC] are used by 

sage-grouse during all lifehistory stages." I d. In his opinion, "the sagebrush-dominated areas on (Proposed Tyler Mountain

ACE C) have special worth, significance, distinctiveness and substantia/values for sage-gmuse and that sagebrush habitats on 

the [Proposed Tyler MountainAC~C} are significant and critical for management of the species in Colorado." Exhibit 11,

Cover memo. (emphasis added). It is also Dr Holloran's opinion that "sagebrush habitats on [Proposed Tyler Mountain 

ACEC] are worthy of at least the same protections as those afforded the Kremmling PCA ACEC." ld. Further, Dr 

Holloran's concludes that "[Proposed Tyler Mountain ACECJ should be designated an ACEC because, among other things, 

protection of the [Proposed Tyler Mountain ACEC]'s sagebrush habitats is essential to maintaining the Kremmling PCA 

ACEC's value to sage-grouse." Jd. (emphasis added). Accordingly, the Proposed Tyler Mountain ACEC possesses important 

and relevant resources that require special management warranting an ACEC designation.

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138. The BLM should consider a ‘conservation alternative’ that: - Includes conservation measures recommended by the NTT 

Report, with improvements, including, but not limited to the following: o Avoid sagebrush reduction/ treatments to 

increase livestock or big game forage in priority habitat and include plans to restore high-quality habitat in areas with 

invasive species. o Implement range management practices outlined by the NTT, with addition of further conservation 

measures, including avoiding new range and water developments that negatively impact sage-grouse and applying the 3% 

disturbance cap to certain range developments. o Design fuel treatments to protect existing sagebrush ecosystems 

(including avoiding such treatments where they will harm sagebrush ecosystems) and prioritize fire suppression to 

conserve the highest quality habitat. o Ensure that disturbance or uses that are permitted adjacent to priority habitat 

don’t negatively impact sage-grouse populations in priority habitat,31 thus negating the value of designated priority habitats. 

Include small or isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority 

habitat, and protect and enhance such populations with science-based prescriptions. - Combines this with designations of 

a subset of priority habitat as Areas of Critical Environmental Concern that receive a higher level of protection than that 

recommended by the NTT.

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139. 7. BLM should designate ACECs to protect priority habitat. BLM’s scoping notice invites the public "to nominate or 

recommend areas on public lands for greater sage-grouse and their habitat to be considered as Areas of Critical 

Environmental Concern [ACEC] as a part of this planning process." 76 Fed.Reg. 77011. Initially, we urge the BLM to provide 

additional time for submission of ACEC nominations to allow for receiving meaningful, comprehensive recommendations 

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to further range-wide conservation efforts. Alternatively, BLM can commit to fully analyze ACECs proposed after the 

scoping period. This is particularly important in Colorado, as information on the location of preliminary priority habitat is 

critical to informed ACEC nominations, and the CPW maps of preliminary priority habitat have only been available to the 

public for a short time.

140. a. ACECs are an appropriate tool for protecting priority sage-grouse habitat. The Federal Land Policy and Management 

Act (FLPMA) obligates the BLM to "give priority to the designation and protection of areas of critical environmental 

concern.” 43 U.S.C. § 1712(c)(3). ACECs are areas "where special management is required to protect and prevent 

irreparable damage to important historic, cultural, or scenic values, fish and wildlife resources, or other natural systems or 

processes." 43 U.S.C. § 1702(a). BLM’s ACEC Manual (1613) provides additional detail on the criteria to be considered in 

ACEC designation, as discussed in the applicable regulations, as well. See, Manual 1613, Section .1 (Characteristics of 

ACECs); 43 C.F.R. § 8200. An area must possess relevance (in that it has significant value(s) in historic, cultural or scenic 

values, fish & wildlife resources, other natural systems/processes, or natural hazards) and importance (in that it has special 

significance and distinctiveness by being more than locally significant or especially rare, fragile or vulnerable). In addition, the 

area must require special management attention to protect the relevant and important values (where current management 

is not sufficient to protect these values or where the needed management action is considered unusual or unique), which 

is addressed in special protective management prescriptions. In the context of this planning effort, BLM and USFWS have 

already essentially determined that sage-grouse habitat meets these criteria.

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141. Pursuant to BLM’s ACEC Manual, for potential ACECs, management prescriptions are to be "fully developed" in the plan 

and an ACEC is to be as large as is necessary to protect the important and relevant values. Manual 1613, Section .22. BLM 

should identify key areas to be protected as ACECs and designate them with specific management prescriptions.

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142. b. Criteria for designating ACECs. BLM should consider designation of ACECs as a tool to achieve the goal of maintaining 

and enhancing greater sage-grouse populations. Designations should be applied with strict management guidance so that 

sage-grouse conservation is the primary objective.

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143. For the purposes of the discussion below, we assume that priority habitat for the purposes of this planning process, in a 

given Field Office, will include all of the area managed by the Field Office delineated as preliminary priority habitat by 

Colorado Parks and Wildlife. The NTT’s recommendations should be used as a starting point for achieving effective 

conservation in priority habitats. BLM should strive to implement them to the fullest extent possible as range-wide 

standards in each RMP, while refining them further to better address specific issues (such as vegetation management and 

energy development) consistent with the best available science. ACECs should prescribe maximum protections for, and 

comprehensive monitoring of, sage-grouse populations.

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144. We suggest that BLM use the criteria outlined below to identify areas of high biological value for sage-grouse that can be 

set-aside from large-scale development and managed with emphasis on maintaining and enhancing greater sage-grouse 

populations. Areas that meet the criteria will also meet BLM’s relevance and importance criteria for ACEC designation. 

BLM should also identify actions necessary to allow permanent protection of these areas, as well as other "interim" 

measures to maximize protection in the meantime. Doherty et al. (2011) developed a framework for conservation 

planning to maximize greater sage-grouse conservation while balancing this need with ongoing energy development. 

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Doherty et al.’s methodology sets forth a useful framework, with incorporation of some additional criteria, to identify areas

to be protected from development and designated as ACECs through this planning process.

145. BLM should delineate areas of particularly high biological value for greater sage-grouse. In Colorado, the preliminary 

priority habitat delineated by Colorado Parks and Wildlife should be considered to be of high biological value, and be used 

as a starting point for identifying areas that meet the criteria for ACEC designation. The approach of delineating areas of 

high biological value as a starting point for conservation planning is outlined in Doherty et al. 2011.32 Ideally, BLM should 

designate 100% of the preliminary priority habitat delineated by Colorado Parks and Wildlife as ACECs that are set-aside 

from all threats with potential to negatively impact greater sage-grouse populations. These areas should then be managed 

to permanently maintain and enhance populations. This may be especially important in parts of Colorado with small, 

isolated populations that are particularly vulnerable to extirpation. However, we recognize that legal, social and political 

factors (particularly around energy development), may make this difficult for BLM to achieve across Colorado.

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146. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: Prioritize ACEC designation of the high biological value areas that are 

necessary to sustain at least 50% of the existing population. Prioritize areas within the Northwest Colorado and North 

Park Population that have historically supported high densities of breeding birds. For the remaining small, isolated 

populations, consider protecting the area needed to sustain a higher proportion of the overall population (up to 100%).

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147. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: Prioritize ACEC designation in relatively large contiguous areas that are: 1) 

within areas of high biological value, 2) currently undeveloped, and 3) unencumbered by valid existing rights, and/or have 

low potential for development (e.g., low wind or oil and gas potential)33. These areas where high biological value intersects

with low energy development potential identify low conflict areas on which to immediately focus ACEC designation.

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148. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: Consider ACEC designation in high biological value areas that, although 

encumbered by valid existing rights, are not yet developed. This may be particularly feasible where actual development 

potential is low despite the existence of valid existing rights (e.g., due to speculative leasing in areas of low energy potential). 

It may also be feasible in areas where other constraints (e.g., lack of infrastructure, other resource conflicts) will make 

development relatively difficult and costly. Management of ACECs designated in such areas could include aggressive pursuit 

of available tools to increase the amount of protected habitat, including fluid mineral lease retirements, voluntary grazing 

permit retirement (where beneficial), mineral withdrawal, coal unsuitability findings, and mineral claim buyouts. This is 

important, as Doherty et. al. (2011) found that 1/3 of the 25% core areas have been leased for oil and gas development. 

Further, 44% of areas with high biological value are at risk for energy development.34

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149. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

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informed by the following additional criteria: Consider Audubon’s Important Bird Areas for ACEC designation or other 

high level habitat protection that ensures no to minimal disturbance.35

150. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: Consider prioritizing areas that meet the previous criteria and are near high 

biological value areas that are likely to be developed, to promote resilience of populations disturbed by development.

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151. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: Consider including relatively large contiguous acreages of lower biological 

value areas that currently are undeveloped, are unencumbered by valid existing rights, or have low potential for 

development. This may be important when such areas increase the size and continuity of the areas described above, or 

where there are limited areas that meet the previous criteria. Doherty et al. (2011) suggest that these areas represent low 

conflict opportunities for sage-grouse, and note that such areas may be important, for example, to maintain connectivity 

between high value core regions within Montana as well as between Montana and adjacent states.

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152. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: Once the above areas have been mapped, work to maximize the spatial 

continuity and size of designated ACECs.

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153. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: ACECs can be designated for habitat, but also for historic, cultural and scenic 

values. BLM should prioritize ACEC designation for lands that contain priority habitat and other vulnerable resources, such 

as wilderness characteristics, other endangered species, or cultural resources. This approach will allow BLM to ensure that 

ACECs maximize protection of multiple sensitive resource values benefiting a range of user groups.

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154. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of preliminary priority habitat delineated by Colorado Parks and Wildlife, along with designation of ACECs 

informed by the following additional criteria: Prioritize providing resources to ACEC designation, plan development and 

plan implementation.

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155. c. Specific ACECs already being evaluated in CO RMP amendment processes should be considered for designation through 

this process. Certain CO RMPs currently undergoing revision are evaluating proposed ACECs that would protect 

priority habitat for the greater sage-grouse. These ACECs should be specifically considered for designation through this EIS 

process.

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156. Recommendations: BLM should provide additional time for submission of ACEC nominations, make full use of this 

important tool, and consider both general criteria for identifying areas for designation and ACECs already under evaluation.

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157. 8. BLM should designate Research Natural Areas. In addition to ACEC designations, BLM should determine appropriate 

sites for Research Natural Area (RNA) designation which is intended to: (1) preserve examples of all significant natural 

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ecosystems for comparison with those influenced by man; (2) to provide educational and research areas for ecological and 

environmental studies; and (3) to preserve gene pools of typical and endangered plants and animals. RNAs are intended to 

represent the diversity of North American ecosystems with their biological communities, habitats, natural phenomena, and 

geological and hydrological formations. RNAs can help BLM and other agencies maintain current data and records of 

sage-grouse habitat and population changes. RNAs are largely used for non-manipulative research and baseline data 

gathering on relatively unaltered community types. In addition to the benefits RNAs could provide researchers and 

managers, these protected areas also safeguard essential habitat types that will be preserved in their natural state for future 

generations.

158. Recommendations: BLM should consider designating Research Natural Areas through this process. CO BLM emc0070RM

159. The BLM should recognize that some areas are not appropriate for development. Each plan should permanently protect 

some natural areas that are high priority sage-grouse habitat from activities that have been documented to be harmful to 

grouse populations. Large-scale development activities, such as drilling and mining, should be directed away from the most 

important sage-grouse habitat. Areas of Critical Environmental Concern should be designated to protect a large amount of 

priority habitat from major disturbances.

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160. 3. The BLM should recognize that some areas are not appropriate for development. Each plan should permanently protect 

some natural areas that are high priority sage-grouse habitat from activities that have been documented to be harmful to 

grouse populations. Large-scale development activities, such as drilling and mining, should be directed away from the most 

important sage-grouse habitat. Areas of Critical Environmental Concern should be designated to protect a large amount of 

priority habitat from major disturbances.

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161. Each alternative should designate areas of contiguous sage-grouse habitat not currently subject to mineral leases or other 

valid existing rights for permanent protection. These remaining refugia can provide intact, diverse, high quality sagebrush 

habitat, vital to sage-grouse and other sagebrush obligate species. In Instruction Memorandum WY-2010-013, the 

Wyoming BLM proposed 11 contiguous square miles or sections as an appropriate minimum size for an area of habitat to 

qualify for being set-aside from development.6 The Wyoming BLM recognized these large unleased contiguous blocks as 

opportunities for grouse conservation. This number should be scaled to allow for protecting smaller contiguous areas in 

states with smaller populations than Wyoming’s, or in areas where there are few remaining contiguous 11-square-mile 

areas that are not subject to valid existing rights. These identified, contiguous areas of undeveloped land should be 

considered for designation as Areas of Critical Environmental Concern in all alternatives. (See Section 8 on ACECs for

further discussion)

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162. Each alternative should designate areas of contiguous sage-grouse habitat not currently subject to mineral leases or other 

valid existing rights for permanent protection. These remaining refugia can provide intact, diverse, high quality sagebrush 

habitat, vital to sage-grouse and other sagebrush obligate species. In Instruction Memorandum WY-2010-013, the 

Wyoming BLM proposed 11 contiguous square miles or sections as an appropriate minimum size for an area of habitat to 

qualify for being set-aside from development.6 The Wyoming BLM recognized these large unleased contiguous blocks as 

opportunities for grouse conservation. This number should be scaled to allow for protecting smaller contiguous areas in 

states with smaller populations than Wyoming’s, or in areas where there are few remaining contiguous 11-square-mile 

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areas that are not subject to valid existing rights. These identified, contiguous areas of undeveloped land should be 

considered for designation as Areas of Critical Environmental Concern in all alternatives. (See Section 8 on ACECs for

further discussion)

163. iv. The BLM and FS should analyze an alternative that provides more protection than that afforded by implementation of the 

National Technical Team’s Recommendations. The BLM and FS should consider an alternative that: - Includes 

conservation measures recommended by the NTT Report. - Combines this with designations of a subset of priority 

habitat as Areas of Critical Environmental Concern that receive a higher level of protection than that recommended by the 

NTT. - Incorporates improvements to the NTT’s recommendations, including the following: o Avoid sagebrush 

reduction/ treatments to increase livestock or big game forage in priority habitat and include plans to restore high-quality 

habitat in areas with invasive species. o Implement range management practices outlined by the NTT, with improvements,

including avoiding new range and water developments that negatively impact sage-grouse and applying the 3% disturbance 

cap to certain range developments. o Design fuel treatments to protect existing sagebrush ecosystems (including avoiding 

such treatments where they will harm sagebrush ecosystems) and prioritize fire suppression to conserve the highest quality 

habitat. o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t negatively impact 

sage-grouse populations in priority habitat,10 thus negating the value of designated priority habitats. o Include small or 

isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority habitat, and protect 

and enhance such populations with science-based prescriptions.

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164. 7. BLM SHOULD DESIGNATE ACECS TO PROTECT PRIORITY HABITAT BLM’s scoping notice invites the public “to 

nominate or recommend areas on public lands for greater sage-grouse and their habitat to be considered as Areas of 

Critical Environmental Concern [ACEC] as a part of this planning process.” 76 Fed.Reg. 77011. Initially, we urge the BLM 

to provide additional time for submission of ACEC nominations to allow for receiving meaningful, comprehensive 

recommendations to further rangewide conservation efforts. Alternatively, BLM can commit to fully analyze ACECs 

proposed after the scoping period.

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165. i. ACECs are an appropriate tool for protecting priority sage-grouse habitat The Federal Land Policy and Management Act 

(FLPMA) obligates the BLM to "give priority to the designation and protection of areas of critical environmental concern." 

43 U.S.C. § 1712(c)(3). ACECs are areas "where special management is required to protect and prevent irreparable damage 

to important historic, cultural, or scenic values, fish and wildlife resources, or other natural systems or processes." 43 

U.S.C. § 1702(a). BLM’s ACEC Manual (1613) provides additional detail on the criteria to be considered in ACEC

designation, as discussed in the applicable regulations, as well. See, Manual 1613, Section .1 (Characteristics of ACECs); 43 

C.F.R. § 8200. An area must possess relevance (in that it has significant value(s) in historic, cultural or scenic values, fish & 

wildlife resources, other natural systems/processes, or natural hazards) and importance (in that it has special significance 

and distinctiveness by being more than locally significant or especially rare, fragile or vulnerable). In addition, the area must 

require special management attention to protect the relevant and important values (where current management is not 

sufficient to protect these values or where the needed management action is considered unusual or unique), which is 

addressed in special protective management prescriptions. In the context of this planning effort, BLM and USFWS have 

already essentially determined that sage-grouse habitat meets these criteria.

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166. Pursuant to BLM’s ACEC Manual, for potential ACECs, management prescriptions are to be "fully developed" in the plan 

and an ACEC is to be as large as is necessary to protect the important and relevant values. Manual 1613, Section .22. BLM 

should identify key areas to be protected as ACECs and designate them with specific management prescriptions.

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167. ii. Criteria for designating ACECs BLM should consider designation of ACECs as a tool to achieve the goal of maintaining 

and enhancing greater sage-grouse populations. Designations should be applied with strict management guidance so that 

sage-grouse conservation is the primary objective.

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168. As we have not yet seen maps of priority habitat for most states, it is difficult to comment on how ACECs should be 

designated in relation to priority habitat. Ideally, priority habitat will be delineated to encompass breeding, late-brood 

rearing and winter concentration areas, as well as migration and connectivity corridors - consistent with the NTT’s Report. 

Priority protected habitat areas must be large enough to maintain and increase current sage-grouse abundance and

distribution. For the purposes of the discussion below, we assume that priority habitat will encompass sufficient habitat to 

maintain at least 80-90% of the current sage-grouse population in each state. If priority habitat is of sufficient size, then 

ACECs may be a subset of priority habitats in most states. The NTT’s recommendations should be used as a starting point 

for achieving effective conservation in priority habitats. BLM should strive to implement them to the fullest extent possible 

as range-wide standards in each RMP, while refining them further to better address specific issues (such as vegetation 

management and energy development) consistent with the best available science. ACECs should prescribe maximum 

protections for, and comprehensive monitoring of, sage-grouse populations.

East Both emc0089RM

169. We suggest that BLM use the criteria outlined below to identify areas of high biological value for sage-grouse that can be 

set-aside from large-scale development and managed with emphasis on maintaining and enhancing greater sage-grouse 

populations. Areas that meet the criteria will also meet BLM’s relevance and importance criteria for ACEC designation. 

BLM should also identify actions necessary to allow permanent protection of these areas, as well as other "interim" 

measures to maximize protection in the meantime. Doherty et al. (2011) developed a framework for conservation 

planning to maximize greater sage-grouse conservation while balancing this need with ongoing energy development. 

Doherty et al.’s methodology sets forth a useful framework, with incorporation of some additional criteria, to identify areas 

to be protected from development and designated as ACECs through this planning process.

East Both emc0089RM

170. As a starting point, BLM should delineate areas of particularly high biological value for greater sage-grouse, which may be a 

subset of the priority habitat, depending on how priority habitat is delineated in each state and on the overall size of the 

populations in a given state. Doherty et al. (2011) identified core regions of sage-grouse abundance by estimating the 

smallest area necessary to contain 25, 50, 75, and 100% of the breeding population within 5, 12, 30, and 60% of the 

eastern/Rocky Mountain region sage-grouse range. The authors define an area as having high biological value with respect 

to conservation planning if the area is in the top three groupings of breeding densities: 25, 50, and 75% core regions, as 

these groups contained 75% of the regional breeding population, in only 30% of the eastern sage-grouse distribution. They

defined areas in North and South Dakota as having high biological value even in 100% core regions, because these fringe 

populations experience the highest risk of extirpation. Even with the inclusion of 100% of the core regions in North and 

South Dakota, this results in the classification of only 31% of the eastern/Rocky Mountain sage-grouse distribution as high

biological value. These areas should be used as a starting point for identifying areas that meet the criteria for ACEC 

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designation. Because Doherty et al. (2011) did not have information on other seasonal habitats, this methodology is 

based only on nesting/breeding habitat. Thus, particularly in states that have relevant information on other seasonal habitats 

(from mapping of seasonal habitats and use of radio-marked birds to document seasonal habitat use, such as winter range, 

and migration), areas of high biological value with respect to meeting all seasonal habitat needs should also be identified and 

considered for ACEC designation.

171. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Prioritize ACEC designation 

of the high biological value areas that are necessary to sustain 50% of the existing population. 16

East Both emc0089RM

172. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Prioritize ACEC designation in 

relatively large contiguous areas that are: 1) within areas of high biological value, 2) currently undeveloped, and 3) 

unencumbered by valid existing rights, and/or have low potential for development (e.g., low wind or oil and gas

potential)17. These areas where high biological value intersects with low energy development potential identify low conflict 

areas on which to immediately focus ACEC designation.

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173. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Consider ACEC designation in 

high biological value areas that, although encumbered by valid existing rights, are not yet developed. This may be 

particularly feasible where actual development potential is low despite the existence of valid existing rights (e.g., due to 

speculative leasing in areas of low energy potential). It may also be feasible in areas where other constraints (e.g., lack of 

infrastructure, other resource conflicts) will make development relatively difficult and costly. Management of ACECs 

designated in such areas could include aggressive pursuit of available tools to increase the amount of protected habitat, 

including fluid mineral lease retirements, voluntary grazing permit retirement (where beneficial), mineral withdrawal, coal 

unsuitability findings, and mineral claim buyouts. This is important, as Doherty et. al. (2011) found that 1/3 of the 25% core 

areas have been leased for oil and gas development. Further, 44% of areas with high biological value are at risk for energy 

development18.

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174. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Consider prioritizing areas 

that meet the previous criteria and are near high biological value areas that are likely to be developed, to promote 

resilience of populations disturbed by development.

East Both emc0089RM

175. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Consider including relatively 

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large contiguous acreages of lower biological value areas that currently are undeveloped, are unencumbered by valid 

existing rights, or have low potential for development19. This may be important when such areas increase the size and 

continuity of the areas described above, or where there are limited areas that meet the previous criteria. Doherty et al. 

(2011) suggest that these areas represent low conflict opportunities for sage-grouse, and note that such areas may be 

important, for example, to maintain connectivity between high value core regions within Montana as well as between 

Montana and adjacent states.

176. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Once the above areas have 

been mapped, work to maximize the spatial continuity and size of designated ACECs.

East Both emc0089RM

177. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: ACECs can be designated for 

habitat, but also for historic, cultural and scenic values. BLM should prioritize ACEC designation for lands that contain 

priority habitat and other vulnerable resources, such as wilderness characteristics, other endangered species, or cultural 

resources. This approach will allow BLM to ensure that ACECs maximize protection of multiple sensitive resource values 

benefiting a range of user groups.

East Both emc0089RM

178. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Prioritize providing resources 

to ACEC designation, plan development and plan implementation.

East Both emc0089RM

179. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: Consider Audubon’s 

Important Bird Areas for ACEC designation or other high level habitat protection that ensures no to minimal disturbance.

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180. iii. Specific ACECs already being evaluated Certain RMPs currently undergoing revision are evaluating proposed ACECs 

that would protect priority habitat for the greater sage-grouse. These ACECs should be specifically considered for

designation through this EIS process. Examples include: - Government Draw/Upper Sweetwater Sage-Grouse ACEC. 

Draft RMP for the Lander Field Office at 208-09.21 - Twin Creek ACEC. Draft RMP for the Lander Field Office at 38, 

208-09. - Chapman Bench ACEC. Draft RMP for Bighorn Basin22 at 2-22 and 2-23, Appendix F at F-8. - Clarks Fork 

Canyon ACEC. Draft RMP for Bighorn Basin at 2-22 and 2-23, Appendix F at F-9. - McCullough Peaks/YU Bench ACEC. 

Draft RMP for Bighorn Basin at 2-22 and 2-23, Appendix F at F-9.

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181. Recommendations: BLM should provide additional time for submission of ACEC nominations, make full use of this 

important tool, and consider both general criteria for identifying areas for designation and ACECs already under evaluation. 

While the FS lacks this specific management tool, the FS can designate reserves or Research Natural Areas to achieve 

similar results.

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182. 8. THE AGENCIES SHOULD DESIGNATE RESEARCH NATURAL AREAS In addition to ACEC designations, BLM and 

FS should determine appropriate sites for Research Natural Area (RNA) designation which is intended to: (1) preserve 

examples of all significant natural ecosystems for comparison with those influenced by man; (2) to provide educational and

research areas for ecological and environmental studies; and (3) to preserve gene pools of typical and endangered plants 

and animals. RNAs are intended to represent the diversity of North American ecosystems with their biological 

communities, habitats, natural phenomena, and geological and hydrological formations. RNAs can help BLM and other 

agencies maintain current data and records of sage-grouse habitat and population changes. RNAs are largely used for 

non-manipulative research and baseline data gathering on relatively unaltered community types. In addition to the benefits 

RNAs could provide researchers and managers, these protected areas also safeguard essential habitat types that will be 

preserved in their natural state for future generations.

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183. Recommendations: The FS should consider the following three mechanisms, in no order of priority, to provide adequate 

regulatory mechanisms in Land Management Plans to conserve greater sage-grouse: 1) designating Research Natural Areas 

in areas with high priority greater sage-grouse habitat and intact sagebrush ecosystems (see section 8 of these comments); 

2) developing and applying a new management prescription focused on conservation of greater sage-grouse and sagebrush 

ecosystems, which implements the National Technical Team recommendations as minimum standards; and 3) developing 

and applying new forest-wide standards that implement the recommendations of BLM’s National Technical Team as 

minimum standards for protecting and recovering habitat for the species. In addition, the agency must help protect 

sage-grouse populations by carefully managing activities and projects on national forest lands that are adjacent to lands with 

occupied sage grouse habitat in other ownerships, using any or all of the above mechanisms, as appropriate for site-specific 

areas.

East USFS emc0089RM

184. Therefore, in order to maximize conservation benefit given other competing values, we recommend protective 

management of priority habitat (which should include enough habitat to conserve at least 80-90% of the existing 

population), along with designation of ACECs informed by the following additional criteria: ACECs can be designated for 

habitat, but also for historic, cultural and scenic values. BLM should prioritize ACEC designation for lands that contain 

priority habitat and other vulnerable resources, such as wilderness characteristics, other endangered species, or cultural 

resources. This approach will allow BLM to ensure that ACECs maximize protection of multiple sensitive resource values 

benefiting a range of user groups.

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185. I. BLM Should Designate Areas of Critical Environmental Concern Where Appropriate Areas of Critical Environmental 

Concern (ACECs) - an administrative designation made within the BLM through land use planning - highlight areas where 

special management attention is needed to protect, and prevent irreparable damage to important historical, cultural, and 

scenic values, fish, or wildlife resources or other natural systems or processes; or to protect human life and safety from 

natural hazards (BLM Manual 1613). This designation should be applied to important priority habitats from development 

and other anthropogenic disturbances with potential to negatively impact sage-grouse in each RMP planning area in the 

Eastern region.

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186. Based on these facts and the criteria noted above, GYC encourages the BLM to use the ACEC designation as a regulatory 

mechanism to conserve sage grouse and sage habitat throughout the Eastern region where appropriate.

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187. Incorporate Special Designations: Apply designations such as Areas of Critical Environmental Concern and Research 

Natural Areas to protect critical habitat.

GB Both emc0355GB

188. The Secretary of the Interior must give priority to the designation and protection of Areas of Critical Environmental 

Concern (ACEC). See 43 U.S.C. §1712(c)(3) This designation should be applied to protect important priority habitats from 

development and other anthropogenic disturbances with potential to negatively impact sage-grouse. In some states with 

peripheral populations and fewer birds, this could include all or a substantial proportion of priority habitat. Such 

designations should be applied with strict management guidance so that sagegrouse conservation is the primary objective.

ACECs are an administrative designation made by BLM through a land use plan—therefore this is an appropriate 

designation to incorporate within RMP revisions and BLM Land Use Planning. The ACEC designation is unique to BLM and 

it can be applied to areas with important natural or historic characteristics. Areas with important fish and wildlife 

resources, including but not limited to habitat for endangered, sensitive, or threatened species, or habitat essential for

maintaining species diversity, are available for nomination and designation.9 Summary: BLM should use the criteria outlined 

below to identify areas of high biological value for sage-grouse that can be permanently set-aside from large-scale 

development and managed with emphasis on not only maintaining, but enhancing greater sage-grouse populations. Areas

that meet the criteria outlined below also meet BLM’s relevance and importance criteria for ACEC designation.

GB Both emc0355GB

189. As a starting point, BLM should delineate areas of particularly high biological value for greater sage-grouse, which may be a 

subset of the priority habitat, depending on how priority habitat is delineated in each state, and on the overall size and 

distribution of the populations in a given state. Doherty et al. (2009) identified core regions of sage-grouse abundance by 

estimating the smallest area necessary to contain 25, 50, 75, and 100% of the breeding population within 5, 12, 30, and 60% 

of the eastern sage-grouse range. They define an area as having high biological value with respect to conservation planning 

if the area is in the top 3 groupings of breeding densities: 25, 50, and 75% core regions, as these groups contained 75% of 

the regional breeding population, in only 30% of the eastern sage-grouse distribution. They defined areas in North and 

South Dakota as having high biological value even in 100% core regions, because these fringe populations experience the 

highest risk of extirpation. Even with inclusion of 100% core regions in North and South Dakota, this results in classification 

of only 31% of the eastern sage-grouse distribution as high biological value. These high biological value areas could be used 

as a starting point for identifying areas that meet the criteria for ACEC designation. This methodology for identifying areas 

of particularly high biological value is focused only on nesting/breeding habitat, because Doherty et al. (2009) did not have 

information on other seasonal habitats.10 Thus, particularly in states that have relevant information on other seasonal 

habitats (from mapping of seasonal habitats, and use of radio-marked birds to document seasonal habitat use and 

migration), areas that are of high biological value withrespect to meeting all seasonal habitat needs should also be identified 

and used as a starting point for ACEC designation. Ideally, BLM should designate all of the area within the 75% core areas 

delineated by Doherty et al. (2009), plus any additional seasonal habitats that are needed to protect 75% of the existing 

population, as ACECs that are permanently set-aside from large-scale development and other activities with potential to 

negatively impact greater sage-grouse populations. These ACEC’s should be managed with the goal of not only maintaining, 

but enhancing greater sagegrouse populations. In some states, where there are small, peripheral populations, BLM should

designate ACECs to include the area needed to protect 100% of the population (100% cores delineated by Doherty et al. 

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(2009) plus any additional seasonal habitats used by the population).

190. At a minimum, we recommend protective management of priority habitat (which should ideally include the area needed to 

conserve 90-100% of the existing population), along with designation of ACECs according to a combination of the following 

additional criteria, in order to maximize conservation benefit: - Prioritize ACEC designation in relatively large contiguous 

areas that are: 1) within areas of high biological value, 2) currently un-developed, and 3) un-encumbered by valid existing 

rights, and/or have low potential for development.11,12 In Wyoming, areas with no existing leases comprising at least 

eleven contiguous sections are specially protected from new leases . This number could be used as a starting point, but 

should be scaled such that smaller contiguous areas are considered in states with smaller populations than Wyoming, as 

well as in areas where there are few remaining 11 contiguous square mile areas that are not subject to valid existing rights. 

- Consider including relatively large contiguous acreages of lower biological value areas that currently are un-developed, 

and un-encumbered by valid existing rights, and/or have low potential for development. This may be important when such 

areas increase the size and continuity of the areas described above, or where there are limited areas that meet the previous 

criteria. Doherty et al. (2009) suggest that these areas represent low conflict opportunities for sage-grouse, and note that 

such areas may be important, for example, to maintain connectivity to other high value core regions. - Once the above 

areas have been mapped, work to maximize the spatial continuity and size of designated ACECs. - As noted previously, 

ACECs can be designated for habitat, but also for historic, cultural and scenic values. Prioritize areas that incorporate 

priority habitat and other vulnerable resources, such as wilderness characteristics, other endangered species, or cultural

resources. By using this approach, BLM can assure that designation and management of ACECs will maximize protection of 

the many resources that the agency is obligated to manage. Consider Audubon’s Important Bird Areas for ACEC 

designation or other high level habitat protection that ensures no to minimal disturbance.13

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191. In addition to ACEC designations, BLM and FS should determine appropriate sites for Research Natural Area (RNA) 

designation which is intended to: (1) preserve examples of all significant natural ecosystems for comparison with those 

influenced by man; (2) to provide educational and research areas for ecological and environmental studies; and (3) to 

preserve gene pools of typical and endangered plants and animals. RNAs are intended to represent the diversity of North 

American ecosystems with their biological communities, habitats, natural phenomena, and geological and hydrological 

formations. RNAs can help BLM and other agencies maintain current data and records of sage-grouse habitat and 

population changes. RNAs are largely used for non-manipulative research and baseline data gathering on relatively 

unaltered community types. In addition to the benefits RNAs could provide researchers and managers, these protected 

areas also safeguard essential habitat types that will be preserved in their natural state for future generations.

GB Both emc0355GB

192. The Greater Yellowstone Coalition and Montana Audubon nominate all BLM lands identified as core sage grouse habitat by 

Montana Fish, Wildlife and Parks within the BLM Dillon Resource Area as an Area of Critical Environmental Concern 

(ACEC) (See enclosed map: “Proposed ACEC Boundaries to Protect Core Sage Grouse Areas”). This potential ACEC is in 

Sage- Grouse Management Zone IV and in large part encompasses all of the seasonal habitats supporting southwest 

Montana’s population of Sage-Grouse. While much of the population can be found yearlong in the proposed ACEC, in 

extreme winters some portion of the population also migrates south to Idaho in areas not covered by this nomination. 

Management Zone IV contains one of the highest reported densities of Greater Sage-Grouse (Fed. Reg. 3/4/10 ).

MT-RM BLM emc0248GB
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193. As a starting point, BLM should delineate areas of particularly high biological value for greater sage-grouse, which may be a 

subset of the priority habitat, depending on how priority habitat is delineated in each state and on the overall size of the 

populations in a given state. Doherty et al. (2011) identified core regions of sage-grouse abundance by estimating the 

smallest area necessary to contain 25, 50, 75, and 100% of the breeding population within 5, 12, 30, and 60% of the 

eastern/Rocky Mountain region sage-grouse range. The authors define an area as having high biological value with respect 

to conservation planning if the area is in the top three groupings of breeding densities: 25, 50, and 75% core regions, as 

these groups contained 75% of the regional breeding population, in only 30% of the eastern sage-grouse distribution. They

defined areas in North and South Dakota as having high biological value even in 100% core regions, because these fringe 

populations experience the highest risk of extirpation. Even with the inclusion of 100% of the core regions in North and 

South Dakota, this results in the classification of only 31% of the eastern/Rocky Mountain sage-grouse distribution as high

biological value. These areas should be used as a starting point for identifying areas that meet the criteria for ACEC 

designation. Because Doherty et al. (2011) did not have information on other seasonal habitats, this methodology is 

based only on nesting/breeding habitat. Thus, particularly in states that have relevant information on other seasonal habitats 

(from mapping of seasonal habitats and use of radio-marked birds to document seasonal habitat use, such as winter range, 

and migration), areas of high biological value with respect to meeting all seasonal habitat needs should also be identified and 

considered for ACEC designation.

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194. ACEC Proposal: Bi-State PMU’s ACEC Proposal BLM must designate ACECs that protect occupied sage-grouse habitats 

across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain viable populations in the 

short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal agency) lands together 

provide critical linked habitat, special designations must span artificial administrative unit boundaries. The Forest too must 

designate RNAs, Reserves or Conservation Areas. FLPMA directs the secretary of the Interior to “prepare and maintain on 

a continuing basis an inventory of all public lands and their resources and other values ... giving priority to ACECs ...”. 

ACECs are to be designated in areas “where special management attention is needed to protect and prevent irreparable 

damage to important historic, cultural and scenic values; fish, wildlife resources or other natural systems or processes; or 

to protect human life and safety from natural hazards.” (43 USC § 1702(a) 43 CFR 1601.0-­‐5a).

NVCA Both emc0348GB

195. ACEC Proposal: Butte-Buck-White Pine PMU ACEC Proposal BLM must designate ACECs that protect occupied 

sage-grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain 

viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other 

federal agency) lands together provide critical linked habitat, special designations must span artificial administrative unit

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0350GB

196. ACEC Proposal: East Valley, Schell-Antelope PMU’s Combined ACEC Proposal BLM must designate ACECs that protect 

occupied sage-grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to 

sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other 

federal agency) lands together provide critical linked habitat, special designations must span artificial administrative unit 

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0351GB

197. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over NVCA Both emc0351GB
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time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage-grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. The Proposed East Valley, Schell-Antelope ACEC 

meets the criteria of having Relevant values. Significant wildlife and other resources are found here. These are significant 

and substantial values. The qualities are of more than local significance. They are of special worth, consequence, 

distinctiveness and cause for concern. NDOW identified these lands as important for populations of sage-grouse. The 

values of the Proposed ACEC are greatly threatened by livestock disturbance and livestock-associated vegetation 

treatments and infrastructure. Livestock disturbance, facilities and vegetation treatments promote weed invasion, 

especially cheatgrass. Livestock water facilities and trampling promote West Nile virus. Livestock presence and facilities 

subsidize nest and egg predators. Livestock disturbance promote further desertification and add to stresses caused by 

climate change which are predicted to adversely impact the Great Basin and this land area. Climate change is expected to 

amplify adverse impacts of livestock grazing, further stress waters, and promote cheatgrass and other invasive species. See 

Fleischner (1994), Belsky and Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and 

Connelly (2009) Studies in Avian Biology. Poor management decisions by agencies, and a series of deeply flawed 

segmented livestock grazing and facility actions, have torn apart the fabric of the sagebrush landscape in many areas, 

including very important sage‐grouse habitats of the ACEC. The uplands, including mature and old growth Wyoming big 

sagebrush communities are critical for sage-grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at 

times critical for wintering habitats. The fragile, small streams, springs and seeps, and associated sagebrush habitats, provide 

essential sage-grouse brood rearing habitat. These, and higher elevation mountain big sagebrush communities, are all 

greatly threatened by continued livestock grazing disturbance which occurs at high levels during sensitive periods that 

conflict with sage-grouse needs for habitat security. These high levels of grazing are also degrading soils and microbiotic 

crusts which are essential as a frontline defense to prevent invasive species like cheatgrass. These high levels of grazing also 

degrade native vegetation structure, composition and function, deplete forbs, reduce essential native bunchgrass nesting 

cover, and cause other adverse impacts. Agencies have also allowed mining exploration and development, and energy 

development to intrude on important and essential sage-grouse seasonal habitats. The complexly interspersed sagebrush 

habitats have nationally significant values. They are essential habitat for the existing declining population of sage-grouse. 

They provide critical connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further 

degradation by livestock and any intensified mining, energy or other development will increase fragmentation and serve to 

further isolate birds and populations. Loss of this PMU would further isolate sage-grouse in neighboring areas. There 

are identified leks within the Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing

during lekking season may disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors 

which prey on breeding sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape 

cover used by breeding sage grouse. Important Values The Proposed ACEC meets the criteria of having important 

values. The Proposed ACEC has more than locally significant qualities which give it special worth, consequence, meaning, 

distinctiveness, or cause for concern especially when compared to any similar resource. The Proposed ACEC has 
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qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or

vulnerable to adverse change. These lands have suffered 150 years of livestock grazing disturbance. This has resulted in 

large losses of riparian area and water flows. Large-scale historical mining disturbance, and deforestation and other impacts 

have also occurred. Uplands have suffered large amounts of soil erosion, reducing site potential. Any continued livestock 

grazing disturbance occurs in a landscape that has been altered by historical uses - so adverse impacts of even smaller 

amounts of disturbance to remaining lands, waters, and sage-grouse habitats may be amplified. The Proposed ACEC has 

microbiotic crusts, which are a frontline defense against weed invasion, are very fragile and readily damaged by livestock 

trampling and cross-country motorized disturbance. Their disturbance promotes invasive species that alter natural 

processes and fire cycles. Whisenant 1994, Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on 

microbiotic crusts. The Proposed ACEC should be recognized as warranting protection in order to satisfy national 

priority concerns or to carry out the mandate of FLPMA. Benefits of the Protection of Relevant and Important Values 

Habitat Recovery Will Provide Long-term Viability for Sage-grouse and Other Sagebrush-dependent Species. sion of 

cheatgrass is alarming. Unfortunately disturbance and desertification associated with livestock grazing has continued, and 

has been intensified by facilities disturbance, salting, and overstocking. These lands are of local, regional and national 

significance for conservation and recovery of sage grouse and other rare and sensitive species populations. Fragmented 

and Disconnected Habitat; Sage Grouse Habitats Require Passive Restoration for Recovery. Springs, springbrooks, 

intermittent drainages, and overall water quality and quantity are jeopardized by grazing practices and now climate change. 

In the past, agencies have treated sagebrush and other upland areas as throwaway landscapes. Sagebrush has been "treated" 

and subjected to continued chronic grazing disturbance. Uplands have been carved with new fences. Livestock spring 

developments, water pipelines have proliferated. Agencies have adopted a disjointed, piecemeal approach, and treated 

uplands as sacrifice area. Management Actions This ACEC must be withdrawn from locatable, leasable and fluid mineral 

development. New rights-of‐way will not be allowed for energy, transmission or other infrastructure or developments. 

Existing ROWS will be amended. Livestock grazing will be phased out of occupied habitats over a period of three years. 

In any areas where grazing might continue longer, Appendix A practices will be applied. Livestock infrastructure, 

including fences, spring developments, pipelines, stock ponds and other harmful facilities will be removed (active 

restoration). Livestock and other disturbed areas will be seeded with local native ecotypes of shrubs, grasses and forbs. 

Native upland and riparian vegetation communities will undergo passive restoration, where natural processes return as a 

result of stopping activities that degrade them or prevent recovery. Spring and stream flows will be restored to their 

natural condition to the maximum extent possible as developments are removed through active and passive restoration. 

Sagebrush manipulation/treatment is prohibited. Selective hand-cutting of conifers only in areas where they are shown to 

conflict with sage-grouse needs will be allowed. Mastication, chaining, and other treatments involving use of large 

machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel will be restricted 

to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. Maintenance 

activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. We 

request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage-grouse EIS process.

198. ACEC Proposal: Islands, O'Neil Basin PMU’s Combined ACEC Proposal BLM must designate ACECs that protect occupied NVCA Both emc0353GB
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sage--‐grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain 

viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal 

agency) lands together provide critical linked habitat, special designations must span artificial administrative unit 

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

199. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage‐grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

NVCA Both emc0353GB
C. Comments by Resource Planning Issue

C-1296 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1297

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

200. ACEC Proposal: Kawich PMU ACEC Proposal BLM must designate ACECs that protect occupied sage--‐grouse habitats 

across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain viable populations in the 

short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal agency) lands together 

provide critical linked habitat, special designations must span artificial administrative unit boundaries. The Forest too must 

designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0354GB

201. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. The complexly interspersed sagebrush habitats have nationally significant values. They are essential habitat for the 

existing declining population of sage‐grouse. They provide critical connectivity with neighboring PMU’s and opportunity for 

genetic interchange. Their further degradation by livestock and any intensified mining, energy or other development will 

NVCA Both emc0354GB
C. Comments by Resource Planning Issue

C-1298 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

increase fragmentation and serve to further isolate birds and populations. Loss of this PMU would further isolate 

sage‐grouse in neighboring areas. There are identified leks within the Proposed ACEC. These areas are critical for the 

survival of the birds and livestock grazing during lekking season may disrupt breeding activities. Livestock associated 

infrastructure may provide perches for raptors which prey on breeding sage grouse. Livestock disturbance of vegetation 

may reduce the quality and quantity of escape cover used by breeding sage grouse. Important Values The Proposed ACEC 

meets the criteria of having important values. The Proposed ACEC has more than locally significant qualities which give it 

special worth, consequence, meaning, distinctiveness, or cause for concern especially when compared to any similar 

resource. The Proposed ACEC has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, exemplary, 

unique, endangered, threatened or vulnerable to adverse change. These lands have suffered 150 years of livestock grazing 

disturbance. This has resulted in large losses of riparian area and water flows. Large‐scale historical mining disturbance, and 

deforestation and other impacts have also occurred. Uplands have suffered large amounts of soil erosion, reducing site 

potential. Any continued livestock grazing disturbance occurs in a landscape that has been altered by historical uses – so 

adverse impacts of even smaller amounts of disturbance to remaining lands, waters, and sage‐grouse habitats may be 

amplified. The Proposed ACEC has microbiotic crusts, which are a frontline defense against weed invasion, are very fragile 

and readily damaged by livestock trampling and cross‐country motorized disturbance. Their disturbance promotes invasive 

species that alter natural processes and fire cycles. Whisenant 1994, Belsky and Gelbard (2000), USDI BLM Belnap et al. 

2001 Technical Bulletin on microbiotic crusts The Proposed ACEC should be recognized as warranting protection in order 

to satisfy national priority concerns or to carry out the mandate of FLPMA. Benefits of the Protection of Relevant and 

Important Values Habitat Recovery Will Provide Long‐term Viability for Sage‐grouse and Other Sagebrush‐dependent 

Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and desertification associated with livestock grazing 

has continued, and has been intensified by facilities disturbance, salting, and overstocking. These lands are of local, regional 

and national significance for conservation and recovery of sage grouse and other rare and sensitive species populations. 

Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive Restoration for Recovery. Springs, 

springbrooks, intermittent drainages, and overall water quality and quantity are jeopardized by grazing practices and now 

climate change In the past, agencies have treated sagebrush and other upland areas as throwaway landscapes. Sagebrush has 

been “treated” and subjected to continued chronic grazing disturbance. Uplands have been carved with new fences. 

Livestock spring developments, water pipelines have proliferated. Agencies have adopted a disjointed, piecemeal approach,

and treated uplands as sacrifice area. Management Actions This ACEC must be withdrawn from locatable, leasable and fluid 

mineral development. New rights‐of‐way will not be allowed for energy, transmission or other infrastructure or 

developments. Existing ROWS will be amended. Livestock grazing will be phased out of occupied habitats over a period of 

three years. In any areas where grazing might continue longer, Appendix A practices will be applied. Livestock 

infrastructure, including fences, spring developments, pipelines, stock ponds and other harmful facilities will be removed 

(active restoration). Livestock and other disturbed areas will be seeded with local native ecotypes of shrubs, grasses and 

forbs. Native upland and riparian vegetation communities will undergo passive restoration, where natural processes return 

as a result of stopping activities that degrade them or prevent recovery. Spring and stream flows will be restored to their 

natural condition to the maximum extent possible as developments are removed through active and passive restoration. 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1299

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in areas where they are shown to 

conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments involving use of large 

machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel will be restricted to 

designated roads. No utility corridors will be designated. Existing utility corridors may be retained. Maintenance activity for 

these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. We request a meeting 

with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

202. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

NVCA Both emc0358GB
C. Comments by Resource Planning Issue

C-1300 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1301

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

203. ACEC Proposal: Santa Rosa, Desert, Eden Valley PMU’s Combined ACEC Proposal BLM must designate ACECs that 

protect occupied sage-grouse habitats across the landscape that are necessary for sage‐grouse to fulfill all their seasonal 

needs to sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS 

or other federal agency) lands together provide critical linked habitat, special designations must span artificial administrative 

unit boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0359GB

204. Sage-grouse ACECs: Protect the complex of seasonal habitats required by sage‐grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

NVCA Both emc0359GB
C. Comments by Resource Planning Issue

C-1302 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1303

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM o discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

205. ACEC Proposal: Quinn PMU ACEC Proposal BLM must designate ACECs that protect occupied sage-grouse habitats 

across the landscape that are necessary for sage‐grouse to fulfill all their seasonal needs to sustain viable populations in the 

short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal agency) lands together 

provide critical linked habitat, special designations must span artificial administrative unit boundaries. The Forest too must 

designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0360GB

206. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

NVCA Both emc0360GB
C. Comments by Resource Planning Issue

C-1304 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1305

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

207. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

NVCA Both emc0361GB
C. Comments by Resource Planning Issue

C-1306 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1307

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

208. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

NVCA Both emc0363GB
C. Comments by Resource Planning Issue

C-1308 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1309

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

209. ACEC Proposal: Shoshone, Cortez, Three Bar, Diamond PMU’s Combined ACEC Proposal BLM must designate ACECs 

that protect occupied sage‐grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their 

seasonal needs to sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or 

USFWS or other federal agency) lands together provide critical linked habitat, special designations must span artificial 

administrative unit boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0364GB

210. ACEC Proposal: Stillwater, Clan Alpine, Desatoya PMU’s Combined ACEC Proposal BLM must designate ACECs that 

protect occupied sage‐grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal 

needs to sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS 

or other federal agency) lands together provide critical linked habitat, special designations must span artificial administrative 

unit boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0365GB

211. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

NVCA Both emc0365GB
C. Comments by Resource Planning Issue

C-1310 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1311

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

212. ACEC Proposal: Toiyabe, Reese River, Monitor PMU’s Combined ACEC Proposal BLM must designate ACECs that 

protect occupied sage‐grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal 

needs to sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS 

or other federal agency) lands together provide critical linked habitat, special designations must span artificial administrative 

unit boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0366GB

213. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

NVCA Both emc0366GB
C. Comments by Resource Planning Issue

C-1312 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1313

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

214. ACEC Proposal: Virginia‐Pahrah PMU ACEC Proposal BLM must designate ACECs that protect occupied sage‐grouse 

habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to sustain viable 

populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other federal 

agency) lands together provide critical linked habitat, special designations must span artificial administrative unit 

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0367GB

215. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

NVCA Both emc0367GB
C. Comments by Resource Planning Issue

C-1314 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1315

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

216. ACEC Proposal: Tuscarora, North Fork PMU’s Combined ACEC Proposal BLM must designate ACECs that protect 

occupied sage‐grouse habitats across the landscape that are necessary for sage-grouse to fulfill all their seasonal needs to 

sustain viable populations in the short, mid and long term. In areas where BLM and the Forest Service (or USFWS or other 

federal agency) lands together provide critical linked habitat, special designations must span artificial administrative unit 

boundaries. The Forest too must designate RNAs, Reserves or Conservation Areas.

NVCA Both emc0368GB

217. Sage‐grouse ACECs: Protect the complex of seasonal habitats required by sage-grouse. Provide for viable populations over 

time. Allow for integrated management to prevent further fragmentation, and to implement passive and active restoration 

and rehab to recover essential habitats like springs that provide critical brood rearing habitat that are on the verge of being 

NVCA Both emc0368GB
C. Comments by Resource Planning Issue

C-1316 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

lost altogether in this very arid landscape. Provide habitat security for sage‐grouse during lekking and nesting periods. Limit 

disturbance, stress and displacement of birds from winter habitats. Relevant Values The Proposed ACEC meets the criteria 

of having Relevant values. Significant wildlife and other resources are found here. These are significant and substantial 

values. The qualities are of more than local significance. They are of special worth, consequence, distinctiveness and cause 

for concern. NDOW identified these lands as important for populations of sage‐grouse. The values of the Proposed ACEC 

are greatly threatened by livestock disturbance and livestock‐ associated vegetation treatments and infrastructure. 

Livestock disturbance, facilities and vegetation treatments promote weed invasion, especially cheatgrass. Livestock water 

facilities and trampling promote West Nile virus. Livestock presence and facilities subsidize nest and egg predators. 

Livestock disturbance promote further desertification and add to stresses caused by climate change which are predicted to 

adversely impact the Great Basin and this land area. Climate change is expected to amplify adverse impacts of livestock 

grazing, further stress waters, and promote cheatgrass and other invasive species. See Fleischner (1994), Belsky and 

Gelbrad (2000), Connelly et al. 2004, USDI Pellant 2007 Congressional Testimony, Knick and Connelly (2009) Studies in 

Avian Biology. Poor management decisions by agencies, and a series of deeply flawed segmented livestock grazing and 

facility actions, have torn apart the fabric of the sagebrush landscape in many areas, including very important sage‐grouse 

habitats of the ACEC. The uplands, including mature and old growth Wyoming big sagebrush communities are critical for 

sage‐grouse nesting. The black sagebrush, along with Wyoming big sagebrush, is at times critical for wintering habitats. The 

fragile, small streams, springs and seeps, and associated sagebrush habitats, provide essential sage‐grouse brood rearing 

habitat. These, and higher elevation mountain big sagebrush communities, are all greatly threatened by continued livestock 

grazing disturbance which occurs at high levels during sensitive periods that conflict with sage‐ grouse needs for habitat 

security. These high levels of grazing are also degrading soils and microbiotic crusts which are essential as a frontline 

defense to prevent invasive species like cheatgrass. These high levels of grazing also degrade native vegetation structure, 

composition and function, deplete forbs, reduce essential native bunchgrass nesting cover, and cause other adverse 

impacts. Agencies have also allowed mining exploration and development, and energy development to intrude on 

important and essential sage‐grouse seasonal habitats. The complexly interspersed sagebrush habitats have nationally 

significant values. They are essential habitat for the existing declining population of sage‐grouse. They provide critical 

connectivity with neighboring PMU’s and opportunity for genetic interchange. Their further degradation by livestock and 

any intensified mining, energy or other development will increase fragmentation and serve to further isolate birds and 

populations. Loss of this PMU would further isolate sage‐grouse in neighboring areas. There are identified leks within the 

Proposed ACEC. These areas are critical for the survival of the birds and livestock grazing during lekking season may 

disrupt breeding activities. Livestock associated infrastructure may provide perches for raptors which prey on breeding 

sage grouse. Livestock disturbance of vegetation may reduce the quality and quantity of escape cover used by breeding sage 

grouse. Important Values The Proposed ACEC meets the criteria of having important values. The Proposed ACEC has 

more than locally significant qualities which give it special worth, consequence, meaning, distinctiveness, or cause for 

concern especially when compared to any similar resource. The Proposed ACEC has qualities or circumstances that make 

it fragile, sensitive, rare, irreplaceable, exemplary, unique, endangered, threatened or vulnerable to adverse change. These 

lands have suffered 150 years of livestock grazing disturbance. This has resulted in large losses of riparian area and water 
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1317

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

flows. Large‐scale historical mining disturbance, and deforestation and other impacts have also occurred. Uplands have 

suffered large amounts of soil erosion, reducing site potential. Any continued livestock grazing disturbance occurs in a 

landscape that has been altered by historical uses – so adverse impacts of even smaller amounts of disturbance to remaining 

lands, waters, and sage‐grouse habitats may be amplified. The Proposed ACEC has microbiotic crusts, which are a frontline 

defense against weed invasion, are very fragile and readily damaged by livestock trampling and cross‐country motorized 

disturbance. Their disturbance promotes invasive species that alter natural processes and fire cycles. Whisenant 1994, 

Belsky and Gelbard (2000), USDI BLM Belnap et al. 2001 Technical Bulletin on microbiotic crusts The Proposed ACEC 

should be recognized as warranting protection in order to satisfy national priority concerns or to carry out the mandate of 

FLPMA. Benefits of the Protection of Relevant and Important Values Habitat Recovery Will Provide Long‐term Viability for 

Sage‐grouse and Other Sagebrush‐dependent Species. Invasion of cheatgrass is alarming. Unfortunately disturbance and 

desertification associated with livestock grazing has continued, and has been intensified by facilities disturbance, salting, and 

overstocking. These lands are of local, regional and national significance for conservation and recovery of sage grouse and 

other rare and sensitive species populations. Fragmented and Disconnected Habitat; Sage Grouse Habitats Require Passive 

Restoration for Recovery. Springs, springbrooks, intermittent drainages, and overall water quality and quantity are 

jeopardized by grazing practices and now climate change In the past, agencies have treated sagebrush and other upland 

areas as throwaway landscapes. Sagebrush has been “treated” and subjected to continued chronic grazing disturbance. 

Uplands have been carved with new fences. Livestock spring developments, water pipelines have proliferated. Agencies 

have adopted a disjointed, piecemeal approach, and treated uplands as sacrifice area. Management Actions This ACEC must 

be withdrawn from locatable, leasable and fluid mineral development. New rights‐of‐way will not be allowed for energy, 

transmission or other infrastructure or developments. Existing ROWS will be amended. Livestock grazing will be phased 

out of occupied habitats over a period of three years. In any areas where grazing might continue longer, Appendix A 

practices will be applied. Livestock infrastructure, including fences, spring developments, pipelines, stock ponds and other 

harmful facilities will be removed (active restoration). Livestock and other disturbed areas will be seeded with local native 

ecotypes of shrubs, grasses and forbs. Native upland and riparian vegetation communities will undergo passive restoration, 

where natural processes return as a result of stopping activities that degrade them or prevent recovery. Spring and stream 

flows will be restored to their natural condition to the maximum extent possible as developments are removed through 

active and passive restoration. Sagebrush manipulation/treatment is prohibited. Selective hand‐cutting of conifers only in 

areas where they are shown to conflict with sage‐ grouse needs will be allowed. Mastication, chaining, and other treatments 

involving use of large machinery are prohibited. (Active restoration). Ownership of all public lands will be retained. Travel

will be restricted to designated roads. No utility corridors will be designated. Existing utility corridors may be retained. 

Maintenance activity for these areas will be carried out with minimal disturbance. All lands will be managed as VRM 1 or 2. 

We request a meeting with BLM to discuss this ACEC proposal, and its incorporation into this Sage‐grouse EIS process.

218. ACEC Proposal: Vya, Sheldon, Massacre, Buffalo‐Skedaddle, Black Rock, Pine Forest PMU’s Combined ACEC Proposal 

BLM must designate ACECs that protect occupied sage-grouse habitats across the landscape that are necessary for 

sage‐grouse to fulfill all their seasonal needs to sustain viable populations in the short, mid and long term. In areas where 

BLM and the Forest Service (or USFWS or other federal agency) lands together provide critical linked habitat, special 

NVCA Both emc0369GB
C. Comments by Resource Planning Issue

C-1318 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

designations must span artificial administrative unit boundaries. The Forest too must designate RNAs, Reserves or 

Conservation Areas.

219. Much of the intact habitat for sage-grouse in Nevada is in Wilderness, WSAs, and roadless areas NVCA BLM emc0401GB

220. It is important to do everything possible to keep those big unspoiled areas as intact as possible NVCA BLM emc0401GB

221. So much of the decline in number of birds is due to the loss, degradation and fragmentation of sagebrush habitat. When you

look at NDOW’s Greater Sage-Grouse Categorization Map, one of the striking things is that the largest blocks of 

“essential/irreplaceable” and “important” habitat are largely found in Wilderness, BLM and US Fish and Wildlife Service 

WSAs, and/or Forest Service Roadless areas. A good example of this is the northwestern portion of Nevada in Washoe 

County and northwest Humboldt County. Large portions of the Sheldon National Wildlife Refuge were recommended by 

the Service for wilderness; BLM in Nevada has numerous wilderness study areas from Sheldon Contiguous, Massacre Rim, 

Wall Canyon, Poodle Mountain, Buffalo Hills, Twin Peaks, etc.; and of course, all of BLM’s designated wilderness High Rock 

Canyon region. These large protective designations have helped hold a strong core of habitat together. I hope the EIS will 

look at the role designated wilderness and proposed and future wilderness can play in the long-term effort to protect 

sage-grouse.

NVCA BLM emc0401GB

222. When you look at some of the WSAs in northwestern Nevada (information pulled directly from the BLM website) you can 

see that many of the WSAs in "essential/irreplaceable" and "important’ sage-grouse habitat would lose some of the 

strongest protection measures possible if legislation like this is passed due to their "non-suitable" recommendation. One of 

the largest factors in the "non-suitable" recommendation of many of these areas was the number of private inholdings 

within the WSA boundary. Over the past decade, most of these inholdings have been acquired. As this EIS moves forward, 

I hope that there will be an opportunity for the BLM to look at the values to sage-grouse from these "non-suitable" WSAs, 

and what could be lost with HR1581-type legislation. NOTE: this letter includes 3 tables, as referenced, from the BLM 

website.

NVCA BLM emc0401GB

223. In the recent Douglas County Public Lands bill process, the Douglas County Commission ecognized the importance of the 

Burbank Canyons WSA to the bi-state population of the sage-grouse, and despite BLM’s "non-suitable" recommendation, 

the commission is supporting this area for wilderness to help protect sage-grouse.

NVCA BLM emc0401GB

224. Incorporate Special Designations: Apply designations such as Areas of Critical Environmental Concern and Research 

Natural Areas to protect critical habitat.

OR Both emc0385GB

225. What will be the impacts or effects of the proposed juniper Encroachment management plan on Existing valued Visual and 

Aesthetic qualities and Management Objectives in regions now defined within Areas of Environmental Concern (AECS) in 

the Vale, Lakeview and BLM Districts?

OR Both rmc0036GB

226. As a starting point, BLM should delineate areas of particularly high biological value for greater sage-grouse, which may be a 

subset of the priority habitat, depending on how priority habitat is delineated in each state and on the overall size of the 

populations in a given state. Doherty et al. (2011) identified core regions of sage-grouse abundance by estimating the 

smallest area necessary to contain 25, 50, 75, and 100% of the breeding population within 5, 12, 30, and 60% of the 

eastern/Rocky Mountain region sage-grouse range. The authors define an area as having high biological value with respect 

SD Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1319

Scoping Summary Report

Table C-12

Comments Related to Special Management Areas

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

to conservation planning if the area is in the top three groupings of breeding densities: 25, 50, and 75% core regions, as 

these groups contained 75% of the regional breeding population, in only 30% of the eastern sage-grouse distribution. They

defined areas in North and South Dakota as having high biological value even in 100% core regions, because these fringe 

populations experience the highest risk of extirpation. Even with the inclusion of 100% of the core regions in North and 

South Dakota, this results in the classification of only 31% of the eastern/Rocky Mountain sage-grouse distribution as high

biological value. These areas should be used as a starting point for identifying areas that meet the criteria for ACEC 

designation. Because Doherty et al. (2011) did not have information on other seasonal habitats, this methodology is based 

only on nesting/breeding habitat. Thus, particularly in states that have relevant information on other seasonal habitats (from 

mapping of seasonal habitats and use of radio-marked birds to document seasonal habitat use, such as winter range, and

migration), areas of high biological value with respect to meeting all seasonal habitat needs should also be identified and 

considered for ACEC designation.

227. The BLM must also consider the effects of restrictive management, such as lands with wilderness characteristics or ACECs 

against the need for proactive projects such as those promoted by the Utah Partners for Conservation and Oevelopment.

UT BLM emc0337GB

228. History has shown that in the case of Resource Management Plan revisions in Wyoming’s BLM Pinedale Field Office, several 

publicly nominated ACEC’s (Wind River Front, The Mesa, The Cottonwood Areas) were not included in alternatives 

within the 2008 draft RMP. The agency cites in an evaluation of ACECs that these areas met relevance criteria but did not 

meet importance criteria (BLM Pinedale, 2007). As sage grouse management EISs proceed, GYC strongly recommends a 

review of the importance criteria for these and other potential ACECs in the Eastern region; it should be clear that 

"importance criteria 1" (locally significant qualities) and "importance criteria 3" (national priority concerns) are now 

applicable to these areas. As noted elsewhere in these comments, sage-grouse require large, interconnected expanses of 

sagebrush. While there is a seasonal component to their habitat requirements, sage-grouse rely year-round on 

sagebrush-dominated landscapes with varying sagebrush canopy covers, densities and heights, age classes, patch sizes, and 

moisture availability. Sage-grouse are a landscape-scale species, meaning they use these large, ecologically diverse 

sagebrush-steppe habitats and are particularly vulnerable to land-use and resource-harvesting practices that alter this 

habitat.

WY Both emc0167

229. Each Field Office should bring forward at least two sage grouse Area of Critical Environmental Concern candidate areas, 

and the sage grouse Plan Amendment EIS is the most appropriate vehicle (rather than concurrent RMP revisions) to 

consider such ACEC nominations. ACECs are an integral part of the overall sage grouse conservation package for each 

Plan, and the overall sufficiency of the sage grouse protection package as a whole should be up for evaluation under the Sage

Grouse Plan Amendments EIS. With this in mind, the Rock Springs Field Office’s stated intention to withdraw its candidate 

sage grouse ACECs from the Plan Amendment process and instead pursue it in the RMP revision is a misguided one.

WY Both emc0343GB

230. In addition, a sage grouse Long-Term Ecological Research (LTER) area should be established to serve as a research and 

reference area for scientific study. We recommend the lands to the south of Green Mountain in the Red Desert as a 

potential LTER site.

WY Both emc0343GB

 
C. Comments by Resource Planning Issue

C-1320 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Fire and nesting and breeding are the biggest threats to sage-grouse funther decline. All Both cfc0002GB

2. Couple this with grazing cuts and increased fires since 1980 and there you have simple statistical analysis of the 3 reasons 

for sage-grouse decline.

All Both cfc0002GB

3. Fire will need to be addressed in the plan. The plan should have a very aggressive approach to fire in sage grouse habitat. All Both cfc0004RM

4. I agree with the NTC recommendation about not controlling big sage in precip. Ares less than 12''. In fact, I would 

recommend that fire not be used in less than 15'' precip. Zones. Too much chance of cheatgrass invasion in low precip. 

Areas.

All Both cfc0017RM

5. National Tech Recommendation of retiring grazing permits would be very counter- productive from many standpoints. 

Most importantly from the s. grouse perspective- there would be many more fires that would wipe out sagebrush -Duh!

All Both cfc0018RM

6. To help preserve the sagebrush, you should strongly consider mowing, burning, etc. strips - to make it easier to control 

wildfires. That way the whole area would be lost.

All Both cfc0018RM

7. Veg Management #2 Fire- can probably live with that. Need to consider "wildfire" management. All Both cfc0025RM

8. #2 Failure to maintain grass and brush in low enough density (through livestock grazing) to prevent huge fires. All Both cfc0041

9. Science- proves there was fewer acres burned in Nevada in 1950-1970 why? The obvious answer, livestock grazed the fire 

fuel off. Yes, there is a balance.

All Both cfc0046GB

10. Since wildfire is the#1 threat to sage-grouse and their habitat -Please include grazing with cattle and sheep in the strategy 

plan to help reduce the fire threat.

All Both cfc0050GB

11. One of the most important thing the BLM has to do is the "pasturizing" of the burn areas. Return the burn areas to the 

same native plants.

All Both cfc0058GB

12. But complete 100% native plant restoration in burn areas is critical. All Both cfc0058GB

13. First of all, since fire is the #1 destroyer of sage-grouse habitat, I think that we should figure how to prevent desert fires. 

One of the best ways to prevent fires would actually be to more intensively graze the forage with sheep and cattle. The BLM 

has so many regulations on the grazers that don’t allow the livestock to be on the grass long enough to take it down to a 

less fire hazardous length. Better management of the land could do a lot to prevent fires. Also I have heard that BLM 

workers actually go start fires on the desert. That is rediculous!

All Both cfc0068GB

14. My comments are going to be directed towards sage-grouse and cattle grazing co-habitation. I feel that they co-habitation. 

I feel that they co-habitat very well, and if cattle are not allowed to graze on BLM land, there will be an increase in fires due 

to the amount of dry grass which fuel huge fires.

All Both cfc0069GB

15. The plan must address the impact of wildfire on sage-grouse habitat and prescribe ways to reduce wildfire occurrence and 

improve control techniques

All Both cfc0070GB

16. Also, stop planting crested wheatgrass and other non-native plants as part of fire rehabilitation. All Both emc0009RM

17. The presence of a ranching community using BLM allotments increases the chances of catching a wildfire when it starts, 

which reduces the amount of big sage brush habitat lost. If economic and political forces undermine this community, they 

All Both emc0013RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1321

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

also undermine grouse habitat.

18. Because big sage brush can be permanently destroyed by fire, any change in grazing should take into account the increased 

risk of fire.

All Both emc0013RM

19. In areas where sage grouse currently thrive, the RMP should make no changes to current grazing, road use, and 

fire-suppression practices.

All Both emc0013RM

20. I am really concerned about the total devistation caused by the enormous wild fires over the past several years. I'm not 

seeing any of the usual animals that generally frequent these areas jackrabbits, cottontails, etc). Nor am I seeing the 

gamebirds that frequented the waterholes and scrubbrush . As far as sage grouse are concerned , can they be re-introduced 

into their former destroyed habitat?

All Both emc0027GB

21. Radio news tells me that policies removing cattle grazing have resulted in the destruction by fire of over 75% of the 

sagegrouse habitat in states to the west of us. The judge responsible for trying to protect sagegrouse by removing grazing 

has decided some grazing may be necessary, but it is a little late. Big sage can take more than 100 years to recover from fire. 

Do not make that mistake!

All Both emc0028RM

22. It is possible the overgrazing may have helped the sagegrouse by protecting big sage from fire. It certainly did not seem to 

depress sagegrouse numbers. This overgrazing due to roving graziers of "free grass" was the main reason the Taylor 

Grazing Act was enacted. Next, the BLM was formed and has worked with established ranchers to create the conditions we 

have today. It is a success story that should not be ignored. Do not repeat the mistakes made in surrounding states and 

destroy sage grouse habitat.

All Both emc0028RM

23. Encourage livestock grazing to keep the range from being burned out due to the build up of fire fuels All Both emc0032GB

24. In addition to energy development and disease, sagebrush-steppe habitat quality may be impacted by grazing practices, 

invasive species and resulting changes in the frequency and severity of fires.

All Both emc0034RM

25. Decreases in the quality of habitat may have direct impacts on greater sage-grouse populations. WWF encourages the BLM 

to address the potential impacts of climate change on the spread of invasive plants, particularly cheatgrass (Bromus 

tectorum), which may highly alter the quality of habitat by outcompeting native grasses and forbs and causing increased 

frequency and severity of wildfires, which are detrimental to fire-intolerant sagebrush species.

All BLM emc0034RM

26. When sagebrush burns now the resulting fires tend to be very hot and intense, burning almost all of the sage and associated 

vegetation, leaving little habitat for sage grouse in the scorched areas. It can be 20 years before the burned sites return to 

sagebrush and are suitable for grouse again. Or, as a result of fire suppression in the last 50 years, the sage is a monoculture 

of old and stagnant plants, occupying 50 - 70 percent of the site, or more. There are few grass and forb plants because they 

are out-competed by the older sagebrush plants. Consequently there is little food for hens and chicks in this environment, 

and they suffer. When the hens and chicks suffer, the whole population suffers. Either way (scorched earth or protected 

from fire) the resulting habitat is not suitable for sage-grouse.

All Both emc0043GB

27. Your paper work shows fire as the biggest threat, well then leaves the roads alone as they make fire breaks and access to 

put fires out if started.

All Both emc0045GB

28. Using fire to reduce sagebrush has become more common In contrast, following a 9-year study, indicated that prescribed All Both emc0057GB
C. Comments by Resource Planning Issue

C-1322 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

burning of Wyoming big sagebrush during a drought period resulted in a large decline (>80%) of a sage grouse breeding 

population in southeastern Idaho. Additionally, documented loss of leks from fire reported that burning mountain big 

sagebrush stands had long-term negative impacts on sage grouse nesting and brood-rearing habitats. Canopy cover in

mountain big sagebrush did not provide appropriate nesting habitat 14 years after burning.

29. Manage breeding habitats to support 15-25% canopy cover of sagebrush, perennial herbaceous cover averaging >18 cm in 

height with (7 inches) >15% canopy cover for grasses and >10% for forbs and a diversity of forbs Habitats meeting these 

conditions should have a high priority for wildfire suppression and should not be considered for sagebrush control 

programs.

All Both emc0057GB

30. no more prescribed burns unless they clearly and specifically are initiated and designed to enhance native wildlife habitat. All Both emc0058GB

31. Conduct under burns in the pine and fir stands to reduce the fuel load within the Mt. Dome Area of Critical Environmental 

Concern. This will aid in preventing catastrophic fires on the mountain top and losing the entire stand of timber used by 

nesting and wintering Bald Eagles in the Klamath and Tule Lake basins.

All Both emc0061GB

32. Wildfire and its extent are directly related to fuel loading and the absence of fuelbreaks. The only realistic tool the agencies 

have in reducing the fuel load is through a well managed grazing program. Wildlife will not adequately harvest fuels and 

manual removal is cost prohibitive. Grazing public land is essential if wildfire is to be minimized. Prescriptive grazing can be 

a tool that could be used to break up fuel loads. There are lots of grazing options. Designed fuel breaks using existing 

infrastructure and promoting fire resistant vegetation that is strategically located is important.

All Both emc0070GB

33. Fragmentation is listed as a focus. Will there be an analysis of where, when and how fragmentation on public lands is 

occurring? If wildfire is determined to be a major cause of fragmentation how will it be controlled by regulation? How will 

any new wildfire regulation be coordinated with the many other regulations on fire? It would seem that if man’s activities 

are the cause of fragmentation that a projection of planned or possible projects might help in the analysis.

All Both emc0071GB

34. Fire - USFWS notice indicates that increased regulatory mechanism’s need to be in place to adequately address the effects 

of wildfires or invasive plants. We are confused as to how a regulatory mechanism will be developed that requires BLM staff 

to target the protection of key sage-grouse habitats and at the same time protect the safety of fire fighters? How can or will 

this be addressed in a balanced manner in the EIS?

All Both emc0071GB

35. Restoring ecosystems will require a new approach to natural disturbance processes. In particular, BLM and FS must change 

they way they manage ecosystems before, during and after fire.

All Both emc0078GB

36. FIRE Fuels ISSUE: The proposed Conservation Measures fail to address post restoration management in sage brush habitat 

experiencing woodland encroachment. Many contracted woodland treatment areas don’t have post treatment in the form 

of prescribed burn or mechanical whip removal due to cost and/or a lack of understanding of pinyon-juniper ecology. When 

the larger trees are cut, it releases the smaller and the effect of the woodland on the understory returns within a few years. 

Post treatment in woodlands needs to be listed as a strategy or BMP.

All Both emc0083GB

37. Fire Operations ISSUE: The proposed Conservation Measures fail to address the need for improved coordination between 

Type III, II and I teams during a wildfire handoff When a wildfire is handed off from a Type III to a Type II or Type I team, 

discussions of guidelines related to a particular species and habitat like sage grouse occur only in a scattered manner, often 

All Both emc0083GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1323

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

as a downplayed after thought. Local federal biologists sometimes have to work very hard to give input into a changeover 

briefing and often are left out of the loop entirely because whether that discussion occurs is up to the IC who may or may 

not allow it to be held. Having a dedicated sage grouse advisor won’t necessarily change this fact

38. ISSUE: The proposed Conservation Measures fail to address the fact that non-federal fire personnel who are involved in 

BLM / USFS wildland fires may be in command positions. Federal agency fire personnel are pretty good about trying to use 

agency program guidelines when they can during a wildfire on their home units and other places when they’re made aware. 

However, many wildfires now involve state and even local volunteer firefighters. These people are often in command 

positions; coordination with them on something like sage grouse guidelines may not occur. Non-federal personnel often 

just order things done like the immediate use of bulldozers and don’t coordinate with federal firefighters – even on federal 

lands. They often don’t know and don’t care about Conservation Measures the federal agency is mandated to use. Even if 

coordination does occur, the state and locals don’t incur the risk and challenges of ESA listing that the federal agencies do; 

there is no downside for ignoring these

All Both emc0083GB

39. HABITAT RESTORATION ISSUE: Use of late seral vegetation typing as the standard for land management agencies ISSUE 

: Use of vegetation mapping that has too coarse a filter to pick up crucial riparian microsites Good condition mid-seral and 

low / early seral vegetation are as important to sage grouse as high / late seral vegetation to supply all of their life cycle 

needs. However, for example, Natural Resource Conservation Service (NRCS) soil / vegetation mapping has typically been 

used as a standard for rangeland management in BLM. NRCS vegetation typing is done using high / late seral vegetation as 

the standard. It is generally silent on describing low / early and mid seral vegetation that is important for grouse and 

important for habitat enhancement objectives. Are we sure that the greatest abundance of forbs and insects needed by sage 

grouse isn’t produced in a good condition / low seral vegetation community? References like NRCS don’t break out the 

thousands of small acreage riparian areas that are crucial to sage grouse for brood rearing and connectivity habitat in more 

arid areas. Federal biologists need to be able to use any reference available, that gives assistance on describing seral 

vegetation communities; the LUP must state that NRCS, USGS references will be used, but so other sources can also be 

used.

All Both emc0083GB

40. In many parts of the western United States, fire and non-native, invasive species are primary threats to sage-grouse habitat. 

Consequently, the BLM and FS's efforts to develop sage-grouse conservation measures should focus on addressing these 

causes of habitat diminution. For example, the BLM should consider the extent to which fuels management programs and 

rehabilitation of fire-impacted areas may provide benefits for sage-grouse habitat. In addition, modification of suppression 

and fire management strategies and practices should be considered.

All Both emc0084GB

41. In the Form, fire appears to be considered a subordinate factor in sage grouse survival (6 pp). Grouse loss through 

elimination of food and shelter is noted, but immediate deaths from burning and suffocation receive no discussion. Other 

research and observation indicates immediate fire losses may be significant (Strickler, 2012). From the view of a taxpayer, 

the agencies apparently do not encourage grazing down fuel loads, nor do they assess wildlife loss due to wildfires.

All Both emc0087GB

42. By agency policy ravens are now provided subsidized hyperpredation of sage grouse. By agency policy, fire potential cannot 

be substantially reduced since grazing down fuel loads requires lengthy bureaucratic permission rather than a rancher’s 

immediate seasonal decision.

All Both emc0087GB
C. Comments by Resource Planning Issue

C-1324 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

43. Predation control through either poisoned bait (eggs) or small bore firearms can be immediately effective. Fire control 

through free-market grazing decisions of cattlemen or sheep growers can be effective in protecting sage grouse within one 

climate season. Bureaucratic habitat control will take no less than multiple budget cycles, and personnel reviews, before any 

agency even begins to be an effective advocate for the benefit of sage grouse.

All Both emc0087GB

44. The apparent agency refusal to seriously consider predation and fire in the survivability of the sage grouse assures not only 

the endangered species listing of the sage grouse, but in fact the actual endangerment of the species. Extinction will not be

the fault of the rancher nor the hunter nor the industrial worker. Sage grouse extinction will be the fault of the 

politically-correct scientist and the politically-correct bureaucrat.

All Both emc0087GB

45. In actuality, from my observations the primary loss of Sage Grouse population in northeastern Nevada is due to loss of 

habitat caused by the many range fires over the past years. This has had nothing to do with mining. If you drive along I-80 

you can see tens of thousands of acres that are now covered by cheat grass instead of sage and forbs. In comparison mining 

operations take up only a tiny fraction of this acreage.

All Both emc0091GB

46. Lastly, I am an environmentalist at heart. I believe we need to be good stewards of our environment. I believe we should do 

what we can to assist nature in restoring the habitat that has been burned by wild fires

All Both emc0091GB

47. There are numerous USFS allotments that are within Sage Grouse habitat or adjacent to that have huge fuel loads due to 

the Western Pine Beetle. The FS has failed to address any location except in the near proximity of housing. These areas 

need to have controlled burns or selective thinned to reduce the potential for devastating fires on or near habitat. The 

funding for restoration is primarily spent for administrative with limited funding for ‘on the ground’ efforts. The habitat 

studies should include any and all potential fuel loading threats, regardless of whether they are BLM, USFS, IDL, INEL, and 

etc.

All Both emc0112GB

48. Page 28 of the NTT Report states: "In fire prone areas where sagebrush seed is required for sage‐grouse habitat

restoration, consider establishing seed harvest areas that are managed for seed production (Armstrong 2007) and are a 

priority for protection from outside disturbances." In the 1980s there was a Bureau-wide effort to identify native plant seed 

reserves on public lands, including for lower-elevation sagebrush. From a historical perspective, it would be useful in the 

EISs to present their current status, how successful their protection from outside disturbances (including fire) has been, and 

the degree to which they have actually been used for procuring seed.

All Both emc0113GB

49. The County supports utilizing more Fuels Management funding to address at-risk priority habitat using all possible means 

(herbicide, mechanical treatments, grazing, stewardship contracting, etc.).

All Both emc0130GB

50. The County supports fire suppression efforts and focus should target protection of high quality enact sage-brush habitat as 

a priority immediately after protection of life and property.

All Both emc0130GB

51. Use fire and brush control and renovation to improve habitat. All Both emc0137GB

52. Sage brushes greatest threat is not cattle, it is fire. And what fuels fire and spreads it besides wind? Grass. If cattle are not 

allowed to graze the land, the grass will only get thicker providing more fuel for a fire. Thus resulting in more sage brush 

being burnt and the habitat of sage hens being destroyed. Cattle are the best friend of sage hens and sage brush. It’s merely

common sense

All Both emc0141GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1325

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

53. Fire ManagementlReseeding. Fire has increased in Iron County as invasive species (cheat grass) increases. More and more 

habitat is burned each year. The BLM has a good fire suppression policy, and are quick to reseed before the coming winter 

so that native grasses and forbs can become established before noxious weeds. The Utah Division of Wildlife Resources 

provides seed in the critical sage grouse habitat areas through a cooperative program. Iron County recommends that the 

BLM not change the current program of fire suppression and reseeding, but look at it as a model other areas of the country 

can use.

All Both emc0142GB

54. In conclusion the key to restoring Sage Grouse populations is early and full suppression of fires, restoration of the burnt 

area with native shrubs and grasses, and controlling predators like coyotes, foxes and wolves.

All Both emc0145GB

55. The two biggest threats to sage grouse habitat areas are wild fires and large ever expanding prairie dog towns. The USFS 

and the BLM are both very negligent in their efforts to control the destruction of sage grouse habitats by the wild fires and 

they have made no attempt to control the complete obliteration of sage grouse habitat areas caused by the expanding

number of prairie dogs.

All Both emc0148GB

56. Over time, the federal government has been changing how they prioritize WUI projects near private or non-federal 

ownership properties. Therefore, protecting private property from fires from public lands and public lands from activities 

on private land is needed again to be evaluated here to become regulatory in nature to get credit, especially when dealing 

with sage grouse habitat. At least one alternative needs to address this issue.

All Both emc0149GB

57. WUI priorities need to be addressed in this EIS. WUI projects need more local decisions to be made as to where is the best 

place to spend the available funds versus decisions made from across the country. At least one alternative needs to address 

this issue.

All Both emc0149GB

58. The idea of fire rehabilitation and restoration efforts and proximity of private or non-federal ownership lands is also a 

concern. One alternative needs to address the needs to do more rehabilitation and restoration efforts along those 

boundaries as a way to protect those properties in the future and protect public land resources from fires originating on 

those properties. This would be a good place to use fire retardant species. With the way wildfires have been growing in size 

and intensity, this would be a good place for protecting sage grouse habitat away from their actual locations.

All Both emc0149GB

59. Use of fire retardant species need to be clearly and fully evaluated in this process. This is especially true to break the 

increasing fire size and intensity trends.

All Both emc0149GB

60. If fire is the number one threat, then you need to do more than make it a national priority. As long as life and property are 

the number one priorities and a rural fire department asks for help, you need to address whether you are going to respond 

to their fires that are threatening life and property or stay on a sage grouse habitat priority fire. Readers need to see in the 

DEIS how you plan to respond to multiple fire starts in your proposed plan, especially in this scenario. Remember, you 

cannot plan or afford to have enough fire fighters and trucks or other equipment to come out of this predicament alone. 

For the benefit of all taxpayers, you need to plan for average fire years and not extremes.

All Both emc0149GB

61. To reduce fire impacts will require partners. Don't alienate those that want to help. Think out of the box here. At least one 

alternative needs to address how to increase the training and capability of rural fire departments, volunteers, partners, etc. 

over the life of these plans and to be regulatory enough to be counted as a positive impact for sage grouse and their habitat.

All Both emc0149GB
C. Comments by Resource Planning Issue

C-1326 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

62. As you indicated in your handouts, sagebrush can take 25-120 years to return. That is if you can stop fire right now and 

invasive species in the short-term. You need to address the reality of fire intervals in the past, present and expected in the 

future. That will lead you to address what the fire interval impacts are if they stay the same or get even shorter in years to 

come.

All Both emc0149GB

63. As we all know if fire returns, you set your expectations back the similar number of years since the last fire or if they have 

occurred often enough, to the point it can't come back without significant human intervention and funds. Your impact 

section needs to address this clearly for the reader. It also needs to address the impacts of agencies planting sagebrush, the 

success they have had or not and issues about it and how to protect those new plants in the short and long-term from fire. 

Protection here is from subsequent fires that may kill plants or hinder their ability to reproduce.

All Both emc0149GB

64. You need to address various widths and types of fire breaks in your alternatives. We all know narrow breaks cannot stop 

a fire that is roaring towards it from miles away, but it can stop or slow a fire that starts adjacent to it for crews to work 

from.

All Both emc0149GB

65. If you want to help the sage grouse, you have to recover the habitat. Sometimes that means letting a fire burn out some of 

the invasive juniper, etc.

All Both emc0157GB

66. The County supports emergency stabilization of habitat areas affected by wildfire; however, maintenance of critical 

ecological processes should be a higher priority than simply re-planting native species only.

All Both emc0160GB

67. I have multiple suggestions for the BLM to integrate into their Sage Grouse Plan. They include: 1) Wildfire policy. Although 

a let it burn policy works well in most forest fire instances, sage brush steppe isin a steep decline due to large fires and 

invasive weeds. It is imperative that we try to minimize wildfires on range land by increased fire suppression action as well 

as developing fuel breaks around all existing key

All Both emc0164GB

68. From your presentation, it seems that the critical issue is habitat (sagebrush) loss due to fire. With that in mind, I suggest 

you review your management of wildfires. Most of these are, were and have always been started naturally by lightning 

strikes. What has changed in modern times is the control of grazing and regulation of fire fuel. I know this played a critical 

role in the fire that nearly burnt Tuscarora this year. Fuel and fires can be better managed. If this is the critical factor in 

sage‐grouse habitat, this should be the focus.

All Both emc0174GB

69. I'm a big proponent of habitat enhancement for this bird species via prescribed burns that stimulate historic natural fire 

patterns, along with other measures, such as light-on-the-land, sustainable grazing methods (or complete cow restriction in 

some fragile areas). The type of land stewardship will of course also benefit many other native lifeforms in our region's 

sagebrush steppelands.

All Both emc0189GB

70. Wild fires are always a possibility and we have had a number of them through the years. It has only been in the last 25 years 

that a wild fire in our area would burn overnight. Now in the last 10 years we have had numerous fires that have burned for 

days and are burning 25,000 to 68,000 acres at a time. If they take the cattle off the range there will be a great deal of fine 

fuel and it will not be if it burns, but when and how much. These fires will be hotter and larger than the fires that we have 

now and that will not help the sage grouse much either.

All Both emc0207GB

71. Livestock grazing has the benefit to the rangeland of reducing the fine fuels load to help with fire prevention and control. If 

grazing is halted or significantly reduced there will be absolutely nothing to keep the rangelands from turning into an inferno 

All Both emc0208GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1327

Scoping Summary Report

Table C-13

Comments Related to Fire Management

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ID

Agency CmtLtrCode

that has never been witnessed before. This scenario will be of great harm to all wildlife.

72. We encourage BLM to recognize and address the following in the EIS and in plan revisions: 1. The importance of addressing 

existing threats from wildfire and invasive species encroachment, particularly juniper encroachment.

All BLM emc0212GB

73. While we in the West will never be able to be free from wild land fires that impact not just the public lands but the private 

lands as well, we can look at "bottom up· assessments of local areas driven by State fish and wildlife and grazing users in

cooperation with local BLM districts and their range cons to assess the most appropriate management approaches on an 

area by area basis to truly achieve habitat improvement

All Both emc0213GB

74. I know more habitat can be saved with minimal changes in fire suppression policy. I saved some areas on our ranch with a 

little effort with my dozer. I witnessed BLM back-burning to create a buffer that in my opinion was overkill and resulted in 

large areas of habitat that were burned that did not need to be.

All Both emc0215GB

75. The documented Preliminary Analysis published by the USGS suggests that the decrease of sagegrouse populations in the 

Virginia Mountains of NW Nevada is due to frequent wildfires which has altered the habitat by destroying the sage brush 

and other perennial grasses that are used by the sage grouse for cover. Wildfires negatively affect our cattle operations as 

well as the sage-grouse survival

All Both emc0232GB

76. On page 25, Wildfire Suppression, Fuels Management and Fire Rehabilitation section of the NTT report indicates that 

wildfire has resulted in significant habitat loss for sage-grouse. Yet quick response to fires is critical in managing the size of 

the fires and the intensity of the fires, and the BLM and USFS want to close roads that would facilitate quick response. The 

conservation measure to close roads in high priority sage-grouse habitats (page 11) is in direct conflict with effective 

wildfire suppression. This is just one of the many conflicting issues in this document. Grazing as a fuel reduction tool can be 

useful where grasses are the fuel that carries fires, but limiting grazing in sage-grosue habitats conflicts with the 

conservation measures of reducing fuels.

All Both emc0239GB

77. Increase grazing by cattle, sheep, and horses to bring the over abundant fuel load of cheat grass and other non-native 

species of plants down to end the danger of catastrophic wildland fires. Managed and rotated grazing has beneficial effects 

for the sagegrouse by removing woofy dead grasses and stimulating softer forages.

All Both emc0241GB

78. Keeping the wildfires to manageable sizes can help sagebrush stands develop faster and sustain communities longer. All Both emc0241GB

79. The use of prescribed fire to reduce fuels loads or enhance sage grouse habitat must be addressed in the RMP amendments. All Both emc0242GB

80. Cooperative conservation measures should focus on restoration of rangelands that have been negatively affected by 

catastrophic fires, along with well‐designed and well‐managed grazing plans.

All Both emc0247GB

81. Specifically, management prescriptions for this proposed ACEC should implement the conservation measures 

recommended by the Sage-Grouse National Technical Team in December, 2011 (SGNTT, 2011). Recent publications have 

exhaustively documented the special conservation actions needed to sustain Greater Sage-Grouse in the American West 

(SAB 2011). Because this proposed ACEC includes priority/core sage grouse habitat, we recommend the following special 

management to address activities that will fragment the sage-steppe habitats upon which the greater sage-grouse depends:

Wildfire and fuels management: Because the proposed ACEC includes priority Sage-Grouse habitat, the Technical Team’s 

recommendations with regard to fuels management and fire operations should be implemented within the boundaries of 

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the ACEC (SGNTT 2011).

82. Indeed, human disturbances of all sorts, roads, railways, fences, reservoirs, towns, homesteads, farms, mines, etc. flourished 

in the early to mid 1900s, and so did the sage-grouse. The mere presence of human activity seems to have little biologically

relevant connection to sage-grouse population trends. However, specific human activities appear to correlate positively 

with GSG population trends. Livestock grazing management, with its associated intensive development of meadows, 

hayfields, and surface water sources increased markedly in the Great Basin in the late 1800s and early 1900s, and GSG 

populations boomed. During this period, high livestock densities (both sheep and cattle) reduced fine wildfire fuel loads 

across the Great Basin, and wildfires were rare and small. High densities of livestock dung also supplied an abundance of 

insect activity, particularly in closely grazed meadows and riparian areas, and the close grazing stimulated succulent new

herbaceous growth and increased the forb component in these meadows and riparian areas, thereby increasing the quantity 

and quality of the forage supply for sage-grouse. At the same time, concerted predator control was practiced. In fact, 

predator control was encouraged, subsidized, and implemented on a vast scale by the Federal and State governments. By 

the mid 1900s, Federal and State regulations were implemented and all of the grazing management practices discussed 

above were controlled and moderated. The GSG population boom moderated at about the same time. By the late 1960s, 

livestock numbers and grazing levels were significantly scaled back across the west, and predator control programs were 

largely curtailed. Fire fuel levels increased, and the incidence of large-scale wildfires rose exponentially. GSG population 

trends reversed and started to rapidly decline.

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83. Thus, intensive livestock management which diminished the frequency and size of wildfires, and concerted predator control 

which greatly reduced GSG loses to these killers, are management actions in the Great Basin that seem to be highly relevant 

to the biology of the GSG and help explain the trajectory of their populations over time. As shown in Figure 1 on page 17 

herein, it is reasonable to assume that a return to effective management to increase livestock grazing levels, reduce fire fuel 

loads and wildfire impacts, and increase predator control would result in another significant upward trend in GSG 

populations. In contrast, proposed GSG conservation measures to provide heavier cover levels through further livestock 

grazing reductions, and the lack of conservation measures to address ever increasing predation levels, are a prescription to 

assure that GSG populations will ultimately decline. Heavier cover for GSG translates to higher fire fuel loads across the 

landscape, and substantial fuel loads make large-scale wildfires inevitable in many sagebrush communities. Repeat burns 

increase the likelihood that plant communities will shift toward cheatgrass dominance, which in turn increases wildfire 

frequency, eliminating the ability of sagebrush communities to re-establish. Thus, conservation measures that intend to 

benefit GSG by providing them with more hiding cover will ultimately harm the species by converting significant swaths of 

existing habitat to annual grasslands that provide no habitat value for GSG. This will concentrate the remaining birds in an 

ever shrinking area, making them more vulnerable to poorly controlled predator populations.

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84. Enhance Current Populations Alternative Given the fact that current GSG populations exceed the minimum effective 

breeding population by 70 to 107 times, it is clear that GSG are not at imminent risk of extinction, and therefore do not 

legally qualify for listing as “endangered” under the ESA. The FWS Findings express concerns regarding rapidly declining 

GSG populations between the late 1960s and late 1980s, and continued downward population trends (although at a slower 

rate) from the late 1980s to the present. The FWS Findings fret that such downward trends in GSG populations may 

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threaten the species with extinction at some point in the future. Given the recent (1985 – 2007) rate of decline of 1.4% 

annually (FWS Findings, 3 page 13922), it would take 300 to 330 years for the current greater sage-grouse population

(350,000 to 535,000 birds) to shrink to the minimum effective population (as high as 5,0000 birds). Theorizing about what 

might happen three centuries from now reaches well beyond the foreseeable future. Thus, the FWS Findings expression of 

concern about long-term outcomes from the continuation of recent GSG population trends does not rise to a 

determination that the species is threatened with extinction in the foreseeable future. A concern that populations may 

reach levels small enough to put them at risk of extinction at some point in the future does not meet the legal requirement

to allow listing under the ESA unless the risk is likely in the foreseeable future. Given current circumstances, any such risk 

for GSG is likely 300 or more years distant, so the species does not legally qualify for listing as “threatened” under the ESA 

at this time. Nevertheless, it is reasonable to consider an alternative that would facilitate an increase in GSG populations, 

so long as that alternative does not negatively impacting existing socioeconomic uses occurring on BLM and FS 

administered lands. An analysis of the past management history within the Great Basin indicates that GSG flourished when

livestock grazing levels were significantly higher than they are now. During this same period, large wildfires in the region 

were very infrequent (likely due to lower wildfire fuel levels as a result of close grazing), and concerted predator control 

measures were practiced. These management actions could be put into practice again to benefit GSG without harming the 

existing socioeconomic climate, but rather enhancing it. In fact, it is reasonable to argue that the FWS Findings get it 

wrong when they conclude that there is a lack of regulatory mechanisms in place to protect the GSG. Instead, many of the 

regulatory mechanisms currently in place are harming the species. For example, regulations restricting livestock numbers 

and use levels increase fire fuels across the Great Basin, and these regulations have resulted in a dramatic increase in large 

wildfires in the region in recent decades, which has destroyed GSG habitat to the detriment of the species. Repeated fire 

has led many sagebrush communities to convert to cheatgrass dominance, which assures that the habitat will remain unfit 

for GSG into the foreseeable future. Rules restricting predator control, regulating the use of poisons and baits, and

protecting ravens have resulted in excessive GSG loses due to predation. Whenever a species like the GSG with a relatively 

low reproduction rate (FWS Findings, 3 page 13916) loses the vast majority of its eggs to predation, and can trace more 

than 80% of the mortality of those individuals that manage to hatch to predation (FWS Findings, 3 pages 13930, 13971, and 

13972), its populations can be expected to decline. Again, it appears that existing rules are harming GSG populations, not 

a lack of adequate rules.

85. 1) Fire suppression and fire management to protect sagebrush habitats will be critical to protecting sage grouse populations 

(the high desert conditions are what they are we cannot undo a campfire gone wrong maintaining access to the sage 

grouse’s habitat is vital and necessary

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86. In the memory of older ranchers, many more cattle and sheep grazed the range lands than are allowed to today due to the 

many restrictions placed on ranchers. During this time, there were also many more sage grouse. At that time, grazing kept 

wild fires from destroying millions of acres of wildlife habitat. Fires have become a devastating problem in recent times, due 

to drastically restricted grazing and a huge build-up of un-used forage that creates fuel for these massive fires. Not only do 

fires destroy the necessary habitat and coverage for the nesting areas, they also kill any birds or wildlife in their path. A less 

restrictive approach to livestock grazing would greatly aid in saving the lands that the sage-grouse live on as well as all other 

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animals that use the areas as well.

87. 2.4. Fire In the Form, fire appears to be considered a subordinate factor in sage grouse survival (6 pp). Grouse loss through 

elimination of food and shelter is noted, but immediate deaths from burning and suffocation receive no discussion. Other 

research and observation indicates immediate fire losses may be significant (Strickler, 2012). From the view of a taxpayer, 

the agencies apparently do not encourage grazing down fuel loads, nor do they assess wildlife loss due to wildfires.

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88. Fire has been a continual threat to sagebrush ecosystems across the West. Both wildfires and prescribed burns have taken 

a toll on sagebrush habitat, and have led to extirpations of sage-grouse from otherwise suitable habitat. Although some 

authors have suggested that fire may benefit sage-grouse, there is virtually no empirical evidence supporting these claims. 

Most studies have concluded, rather, that fire can have devastating impacts on sage-grouse habitat and survival.

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89. Because wildfires kill many of the native vegetative species of sagebrush-steppe ecosystems, wildfires have been identified 

as a primary factor associated with sage-grouse population declines. For example, one author has suggested that range fires 

destroyed approximately 30 to 40 percent of sage-grouse habitat in southern Idaho (MZ IV) in a five-year period. 

Sage-grouse are so sensitive to fire, in fact, that sage-grouse have been documented extirpating leks within 33.6 miles (54 

km) of a fire. The threat of wildfires is ongoing and likely to continue indefinitely.

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90. Management agencies also use prescribed fire in sagebrush habitat, which can lead to negative impacts on greater 

sage-grouse. Prescribed fire is often used to control annual grasses, to facilitate growth of grasses and forbs, to reduce 

density of sagebrush, and to control juniper and pinyon woodland expansion into sagebrush habitats, largely with the aim of 

benefitting other wildlife species. Because prescribed fires often take a toll on habitats available for greater sage-grouse and 

other sagebrush-dependent species, it is not surprising that use of prescribed fire is one of the most contentious issues in 

management of sagebrush habitats. At least one author has reported that between 1997 and 2006, prescribed fire was used 

on more than 370,000 hectares (914,000 acres) of public lands, mostly in Idaho and Oregon. The amount of sagebrush 

habitat lost due to prescribed fires is relatively minor when compared to loss incurred by wildfires, but considering the

fragility of the declining populations of the greater sage-grouse, the rationale for using prescribed fire warrants a closer look 

at whether the benefits really outweigh the negative effects.

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91. Additionally, fires have cumulative effects that lead to more detrimental effects on sagebrush habitats. For example, fire may 

increase the spread of invasive plants which may then persist over native plants that would provide necessary understory 

for sage-grouse. The spread of invasive plants is intensified by other activities, including the use of mechanical and chemical

treatment on lands, domestic livestock grazing, fencing and other infrastructure, recreational use of lands including use by 

off-highway vehicles, and climate change.

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92. Recovery of sagebrush lands impacted by fire is long-term and may often take decades or even centuries. Species 

composition, pre-burn site conditions, fire size and intensity, fire frequency, and availability of seed sources all play a role in 

the ability of sagebrush habitats to recover. Additionally, site specific variable such as soil characteristics, previous 

disturbance history, pre- and post-fire patterns of precipitation, climate, and the presence of other activities such as

domestic livestock grazing may affect recovery capacity. Due to this complexity, the dynamics of recovery following fires 

may differ between natural and prescribed fires and are extremely difficult to predict. Without readily available sagebrush 

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habitat, most sites affected by fire are of little to no value to sage-grouse prior to recovery.

93. • Protection of intact sagebrush communities: "Protection of intact sagebrush communities" should recognize that the 

integrity of the ecological site may include various phases with little to no sagebrush, allowing sagebrush to reestablish in an 

appropriate time period. This type of management or vegetation treatment sustains the long-term maintenance of intact 

sagebrush communities. "Protecting" intact sagebrush communities from disturbance increases the risk of catastrophic fires 

in the shrub-dominated communities and increases the risk of conversion to non-native annual species, with the subsequent 

loss of sage-grouse habitat. The term "protection" should be replaced with "management" as these ecological sites are 

disturbance driven in the Great Basin.

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94. • Large intact sagebrush communities: The definition of large intact sagebrush communities needs to be clearly stated. In the

context of the ESD and State and Transition Models, this means maintaining the integrity of the ecological site, which 

includes various phases of vegetation on the landscape such as a grass-forb phase, a grass-forb/shrub phase, a 

shrub/grass-forb phase, and shrub dominated phase. It does not mean that large areas of old, decadent sagebrush should be 

maintained on the landscape. Old, decadent sagebrush cannot be maintained on the landscape as lightning ignitions occur 

frequently in this vegetation condition and the large intact nature of such stands results in extremely large burned areas that 

bum with extreme intensity and result in high plant mortality.

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95. We do not advise large prescribed fire in GSG or big game winter ranges in Wyoming big sagebrush, particularly at low 

elevations and precipitation (less than 10 inches annual precipitation)

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96. We have successfully implemented cool season burns, chemical, mechanical treatments to thin brush and release 

herbaceous vegetation (Danvir 2005). The overall effect is early seral openings in a sagebrush sea. Hunnicutt 1992 clearly 

showed that hens selected nest sites in homogeneous sagebrush patches at least 300m in diameter for nesting, but 

immediately moved broods to highly heterogeneous areas having an interspersion of sagebrush cover and grass-forb 

dominated feeding areas. Pronghorn populations (Aoude and Danvir 2002) showed similar production and population 

increases.

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97. Conversely, reducing stocking rates without shortening the grazing period and lengthening the rest-recovery period does 

little to improve rangeland health, increases fire intensity, and will continue to harm some herbaceous plant species.

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98. Livestock grazing is one of the best tools to improve sage grouse habitat and reduce the danger of fire. All Both emc0286GB

99. Residual cover is a very fine line. Too much residual cover increases the severity of wildfires. Grazing can help immensely 

to decrease the severity of wildfires. SRCA agrees, "Proper livestock management (e.g. timing, location, and intensity) can 

assist in meeting sagegrouse habitat objectives and reduce fuels."

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100. SRCA agrees that TNR should be a tool land managers can use. But these decisions need to be made on a yearly basis since 

there is no science available to predict future precipitation or temperature. Flexibility in grazing permits needs to happen. 

The NEPA process is too slow when decisions on the ground need to happen quickly. After TNR was set aside, wildfires

became more intense and severe due to fuel buildup (e.g. Murphy Complex Fire, West Basin Fire). SRCA feels that the 

West Basin Fire damage was disastrous due to the restricted use in SRCA's Willow Creek Pasture; this scenario could-be 

true of all fires on the Snake River Plain in Idaho_ Lack of flexibility within grazing permits has adverse impacts on 

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sage-grouse in relation to wildfire. It's not rocket science. On years where there is 150% of normal precipitation with 

favorable growing temperatures, decisions determining use need to be made on the ground or else utilization of fine fuels 

and other grasses remains 0-5%. This in turn creates high probabilities for extreme hot and devastating fires, thus changing 

whole ecosystems and burning sagebrush.

101. We agree there would be adverse impacts in eliminating grazing. These adverse impacts include invasive species after 

wildfires. Wildfires occurring where grazing did not occur would be very intense. The Murphy Complex Fire is a prime 

example. TNR was taken from this area several years ago which led to a devastating fire due to fuel buildup. How many 

acres of sagebrush burned? SRCA does not agree that permanent retirement of grazing privileges would ever be potentially 

beneficial.

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102. Livestock grazing is a legal and valid use of public rangelands and is a vital component to the balance of nature. If one looks 

at the statistics, more rangeland has burned in the past 10-15 years because of the restrictions on the rangeland. If ranchers 

can’t utilize the feed on BLM and Forest Service properties because of this sage-grouse issue, then it will be like adding fuel 

to an already burning fire. More vegetation will just make a bigger fire! Historical evidence indicates a positive correlation 

between livestock numbers and sage grouse populations. Grazing keeps the fuel down so there isn’t so much vegetation to 

burn. Sage-grouse don’t like to live in burned out areas either. They prefer to live in an area where nature is balanced.

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103. Wildfires have affected sage grouse habitat in recent years. Any reduction in grazing will only leave more fire fuel on the 

range making the situation worse.

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104. The BLM states fire as the greatest threat to the birds and grazing is the most effective management tool that is available to 

help control fuels to prevent wildfires.

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105. Limit the use of prescribed fire in priority sage grouse habitat. All Both emc0297GB

106. The BLM's westwide planning strategy should recognize that the most important existing threats to sage‐grouse are wildfire 

and invasives (particularly juniper encroachment).

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107. The planning strategy should recognize that juniper mastication is more effective than prescribed burning for improving 

sage‐grouse habitat in many areas. To date, most juniper mastication has been conducted on private lands. The RMP 

amendments should encourage streamlining the clearance procedures to allow and encourage juniper mastication on public 

lands.

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108. The decrease in large fires associated by adequate grass grazing by cattle, and the stimulation of new herbaceous growth 

and increased forb component that grazing promotes.

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109. Measures that the BLM has the power to enact that will have the greatest benefit to sage grouse numbers are likely 

maintaining or increasing their access to reliable water sources, reducing wildfire number and severity, and increasing new 

herbaceous growth and forb diversity. Livestock grazing promotes all these aims.

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110. We do not advise large prescribed fire in GSG or big game winter ranges in Wyoming big sagebrush, particularly at low 

elevations and precipitation (less than 10 inches annual precipitation). However, our observations have consistently shown 

that smaller (25-200Ha) openings created in large (>500Ha) expanses of mountain and Basin big sagebrush in excess of 25% 

canopy coverage and above 2000m in elevation are used as brood habitat by GSG, and (based on increased lek attendance, 

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lek persistence, and new lek development) can increase GSG populations. We have successfully implemented cool season 

burns, chemical, mechanical treatments to thin brush and release herbaceous vegetation (Oanvir 2005). The overall effect 

is early seral openings in a sagebrush sea. Hunnicutt 1992 clearly showed that hens selected nest sites in homogeneous 

sagebrush patches at least 300m in diameter for nesting, but immediately moved broods to highly heterogeneous areas 

having an interspersion of sagebrush cover and grass-forb dominated feeding areas. Pronghorn populations (Aoude and 

Oanvir 2002) showed similar production and population increases.

111. Whereas fire and other disturbance are part of the natural ecosystem and whereas the natural fire cycle is altered by human 

intervention, we encourage BLM to consider historical rates of fire and disturbance and allow for controlled measures to 

replicate or simulate this vital element of our ecosystem. We are concerned that as more focus is turned to GSG, beneficial 

practices such as controlled burns will be reduced in areas that would benefit. The loss of these practices will lead to 

decreased forage production, decreased water infiltration, decreased water quality, increased fuel loads and more 

catastrophic fire events that ultimately harm GSG and are detrimental to other uses of the land.

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112. Evaluate sagebrush habitat for its susceptibility to wildfire. Develop and implement a plan to address the prevention of 

massive wildfire in critical sage grouse habitat. In areas previously impacted by wildfire, develop and implement a 

reclamation strategy focused on native, non-invasive species.

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113. Evaluate the synergistic effects of climate on invasive annual grasses and altered fire regime. All Both emc0305GB

114. NEI recommends that sage grouse habitat be accurately mapped through sound environmental assessment and that more 

focus be given to proven threats to sage grouse viability, such as invasive species and fires.

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115. The EIS and its alternatives must address and quantify the effectiveness and positive impacts modified fire suppression and 

fire management strategies will have on current and future sage grouse habitat.

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116. It is recognized by USFWS that fire has the greatest detrimental impact to sage grouse habitat. The EIS must specifically 

address wildland fire prevention, fire-fighting methods, and the ability to restore fire damaged habitat before implementing 

other land use prohibitions & restrictions.

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117. The introduction of non-native annual grasses to the fragile ecosystems in the west have caused massive ecosystem 

transformation. Western Juniper has also become invasive to areas that did not historically have it - due to occasional fire 

- and has degraded much of prime sage grouse habitat at higher elevations. Many of the ecosystems/habitat in the West are 

dependent on occasional fire, to maintain ecosystem functionality

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118. Re-introduce fire to ecosystem functioning and management, once large amounts of accumulated fuels are reduced. All Both emc0314GB

119. Overwhelmingly, the conservation measures identified in the NTT report focus on limiting or restricting the use of federal 

public lands. The agencies should focus on active management of habitats in a manner that will allow for other land uses. It 

is well-known that fire, not resource development, poses the greatest threat to sage-grouse habitat. BLM Director Robert 

Abbey admitted same in testimony before the House Energy and Mineral Resources Subcommittee on March 201, 2012. 

Therefore, fire suppression efforts throughout the habitat range should receive the highest priority. In addition, agencies 

should focus their efforts on supporting what is currently working on the ground rather than solely on "regulatory 

mechanisms."

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120. On page 25, Wildfire Suppresion, Fuels Management and Fire Rehabilitation section of the NTT report indicates that 

wildfire has resulted in significant habitat loss for sage-grouse. Yet quick response to fires is critical in managing the size of 

the fires and the intensity of the fires, and the BLM and USFS want to close roads that would facilitate quick response. The 

conservation measure to close roads in high priority sage-grouse habitats (page 11) is in direct conflict with effective 

wildfire suppression. This is just one of the many conflicting issues in this document.

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121. Grazing as a fuel reduction tool that can be useful where grasses are the fuel that carries the fire, but limiting grazing in 

sage-grouse habitats conflicts with the conservation measure of reducing fuels.

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122. Conservation measures need to focus on real and substantial threats such as wildfire, noxious weeds, and other large scale 

conversions when they specifically threaten a population seasonal segment. Changes in land-use should not be rigidly 

restricted or prevented from occurring because many times those changes can have secondary benefits such as breaking up 

or reducing the risk of catastrophic change particularly wildfire.

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123. Our recommendations for management policies in sage-grouse habitat follow. Design fuel treatments to protect existing 

sagebrush ecosystems (including avoiding such treatments where they will harm sagebrush ecosystems) and prioritize fire 

suppression to conserve habitat.

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124. As sage-grouse habitat becomes further fragmented by the increasing frequency of wildfires, restoration will become more 

important. Sage-grouse have evolved in habitat that has extremely infrequent wildfires, and benefit from the presence of 

mature sagebrush stands. Habitat fragmentation and alteration due to fire may influence distribution (including lek

abandonment) or migratory patterns. We suggest that a funded program be dedicated to identifying sagebrush landscapes 

that are at risk from fire and that field offices be prepared with a response plan to avoid the conversion of compromised 

landscapes to ones that are dominated by invasive species following fires.

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125. Livestock grazing on public and private land contributes to the Sage grouse habitats by managing the optimum use of the 

forage, therefore less dry fuels for wild fires. The EIS and SEIS revisions should clarity that grazing should be used to reduce 

the risk of catastrophic wild fires and improve forage.

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126. VI. BLM and USFS Must Evaluate a Reasonable Range of Alternatives In light of the different reasons for sage-grouse habitat 

decline from region to region, and the fact that there remains significant sagebrush habitat in Wyoming and Nevada, each 

sub-regional EIS should carefully evaluate a reasonable range of alternatives to the conservation measures and regulatory 

mechanisms proposed in the NTT Report. Some of the contemplated measures may not be necessary or effective in each 

region or sub-region. Examples of such alternatives include, but are not limited, to the following: The Accelerated Fire 

Restoration Alternative For regions and sub-regions where recent fires have compromised sage-grouse habitat, the ElS

should evaluate an Accelerated Fire Restoration Alternative that assesses the impacts associated with implementing 

better-funded and more effective fire restoration measures. This is especially important for the ElS to be completed in the 

Great Basin Region, where wildfires are considered a primary factor in habitat fragmentation.

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127. VI. BLM and USFS Must Evaluate a Reasonable Range of Alternatives In light of the different reasons for sage-grouse habitat 

decline from region to region, and the fact that there remains significant sagebrush habitat in Wyoming and Nevada, each 

sub-regional EIS should carefully evaluate a reasonable range of alternatives to the conservation measures and regulatory 

mechanisms proposed in the NTT Report. Some of the contemplated measures may not be necessary or effective in each 

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region or sub-region. Examples of such alternatives include, but are not limited, to the following: E. The Improved Fuels 

Management and Fire Suppression Alternative The EIS should evaluate the impacts associated with more effective and 

better-funded fuels management measures and fire suppression measures when wild fires do occur. This is especially 

important for the ElS to be completed in the Great Basin Region, where wildfires are considered a primary factor in habitat 

fragmentation.

128. Climate change is projected to impact sagebrush habitats, and also to potentially impact sage-grouse survival and 

reproductive success. Despite this fact, climate change is not listed as a preliminary issue in the Notice of Intent for the 

greater sage-grouse planning process. This oversight has to be effectively remedied at the Draft EIS stage, the agency must 

include a comprehensive analysis of the predicted climate change impacts to sage-grouse and any proposed management 

regime must take into account the cumulative effect of climate change and other impacts and provide protections sufficient 

to recover and conserve the sage-grouse despite these threats. Climate change impacts that must be analyzed include, but 

are not limited to: · Increased temperature and increased precipitation allowing expansion of woody vegetation from 

higher elevations. · Increased temperature and decreased precipitation shifting the balance toward more drought-tolerant 

desert plants. · Alteration in fire regime from a warmer climate, which would be problematic for fire intolerant sagebrush.

· The spread of invasive annual grasses, such as cheatgrass, which have a very different growth form than the native bunch 

grasses and can lead to more severe fire. · Drought conditions, which have been shown to negatively impact nest success.

· West Nile virus, which may worsen with warmer summertime temperatures that speed the development of the virus 

within the vector mosquitoes.

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129. Grazing additionally reduces the instances and severity of wildfires (Launchbaugh et al. 2007); improves Sage Grouse habitat 

by increasing the quality and accessibility of forbs for sage grouse (NeeI1980, Derner et al. 1994, Evans 1996); and can be 

used to control invasive weeds (Olson and Lacey 1994, Walker et al. 1994).

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130. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: - Vegetation 

structure and composition in the sagebrush ecosystem have undergone major changes since European settlement in part 

due to human-induced changes in fire regime

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131. Native vegetation communities in Great basin sagebrush steppe did not evolve with grazing pressure (Mack and Thompson 

1982). Excessive livestock grazing by domestic livestock during the late 1800s and early 1900s had significant impacts on 

sagebrush steppe and those effects persist today (Knick et al. 2003). Grazing (in addition to other factors) is implicated in 

the encroachment of conifers in sagebrush steppe, including western juniper (Juniperus occidentalis) (Kerr and Salvo 2007). 

Decades of livestock grazing have altered plant communities and soil and reduced productivity in sagebrush steppe (Knick 

et al 2003). Cattle grazed at “conservative” levels in sagebrush steppe in the northern Great Basin initially selected 

bunchgrasses in interspaces between sagebrush plants (France et al. 2008). The removal of native species from interspaces 

by cattle, in conjunction with other factors, appears to facilitate invasion by cheatgrass (Bromus tectorum) into these areas

(Reisner 2010). The spread of cheatgrass and other invasive plants into degraded rangelands has accelerated the natural fire 

cycle and threatens to convert enormous areas of sagebrush habitat into annual grasslands (Wisdom et al. 2005; Miller et 

al. 2011).

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132. Baker (2006) reviewed the fire history of sagebrush ecosystems and found natural fire to be a rare event, suggesting a fire All Both emc0343GB
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rotation 325-450 years in length. However, overgrazing across many of the Great Basin states has led to the invasion of 

cheatgrass, a highly flammable noxious weed that accelerates the fire cycle to less than five years destroying the sagebrush 

upon which sage grouse rely for food and cover. Approximately 36 percent of the greater sage grouse range is invaded by 

cheatgrass (Lebbin et al. 2010). Because sagebrush requires at least 15 years (and up to 50) to reoccupy burned sites, 

restoring invades areas is a difficult and slow process. Preventing further spread into intact sagebrush should be prioritized.

133. Cheatgrass, an invasive annual grass, is now the dominant species on 100 million acres (158,000 square miles) in the 

Intermountain West (Rosentreter 1994: 170, citing Mack 1981). It was estimated in 1999 that 25 percent of the original 

sagebrush ecosystem has been converted to cheatgrass/medusa-head rye (Taeniatherum caput-medusae) annual grassland, 

and an additional 25 percent of sagebrush steppe has only cheatgrass as understory vegetation (West 2000). Cheatgrass is 

estimated to spread at a rate of 14 percent annually in the United States (Duncan et al. 2004: 1412, table 1). The conversion 

of sagebrush steppe to exotic annual grassland has been described as “massive” (Allen 2003) and is expected to continue 

(Miller et al. 2011; Hemstrom et al. 2002).7 Cheatgrass thrives in disturbed, and especially burned, areas. It can increase fire 

frequency, favoring itself and potentially inhibiting perennial seedling establishment (Miller et al. 2011). Cheatgrass incursion 

into sagebrush habitat can lead to an eventual conversion of sagebrush/grass (perennial) community to sagebrush/grass 

(annual) or annual grass rangeland. In some cases, cheatgrass invasion encourages other exotic species such as medusa-head 

rye, knapweed and thistle. It was observed in 1979 that annual-dominated communities in sagebrush steppe appears to have 

crossed a threshold and created its own new equilibrium (Hanley 1979) from which restoration to functional sagebrush 

steppe would be very costly and difficult (if not impossible) to achieve (Billings 1990).

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134. Prescribed fire is commonly employed putatively to improve sage grouse habitat (such projects are often supported by 

livestock operators, who typically are primarily concerned with eliminating sagebrush with the misguided belief that this will 

result in a net increase in forage for livestock). For instance, the Upper Snake LWG reported that the 1,100-acre prescribed 

burn in the Cherry Creek watershed would benefit sage grouse by improving brood rearing habitat. Sagebrush recovery 

following such fires takes decades, and can take more than 100 years, causing an immediate reduction in habitat 

effectiveness for sage grouse in pursuit of some eventual increase in habitat effectiveness at some point in the (distant) 

future. The net result is that immediate welfare of the sage grouse today is being mortgaged for eventual habitat 

improvements that are speculative at best. However, unlike pheasants, sage grouse are known to respond poorly if at all to 

habitat enhancement projects.8 In the WAFWA forum participants noted, “It’s important for people to understand that 

if we are doing habitat projects, it often takes a matter of 10, 20, even 30 years to restore shrub habitat. Habitat treatments 

that put money on the ground today are speculating on the long-term success of the treatment, and of the sage-grouse 

response to those treatments. So we’ll have to find a way to figure this much longer time frame into our calculations” 

(WAFWA 2006b: 13). In the absence of rigorous scientific evidence supporting the translation of habitat enhancement 

projects into increased sage grouse population numbers, the BLM should not consider such projects under its RMPs.

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135. The role of fire in the sagebrush ecosystem, and how (or if) it drives the patch dynamics of the system, is poorly understood 

at present. A landscape mosaic of burns may not meet the nesting habitat needs of sage grouse (Nelle et al. 2000), and may 

also fail to meet grouse habitat requirements during other seasons (Wamboldt et al 2002). Large fires of high frequency can 

extirpate sage grouse populations (Pedersen et al. 2003). In Idaho, reduction of 57% of sagebrush canopy cover resulted in 

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sage grouse population reductions (Connelly et al. 2000b). Thus, it is far from clear that projects which reduce sagebrush 

density or extent actually benefit sage grouse in the short or long term.

136. The spread of cheatgrass, which thrives in the wake of fire (both natural and humancaused) further complicates post-fire 

sagebrush recovery. Once cheatgrass invasion begins, fires result in pure stands of cheatgrass, which tends to burn on a 2-5 

year cycle, preventing the re-establishment of native vegetation. Biologists have observed, “Under current, altered fire 

regimes, natural re-establishment of sagebrush after burning (especially basin big sagebrush and Wyoming big sagebrush) is 

unlikely” (WAFWA 2006b: 66). Fires and subsequent cheatgrass invasion were a cause of major habitat loss in many of the 

sage grouse units in northern Nevada, and risk of large-scale habitat loss was high even in areas that had not experienced 

major problems in the past.

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137. Many sagebrush “control” projects are undertaken based on the perception that sagebrush stands that are dense or tall 

produce less forage for livestock and also are poor sage grouse habitat; these habitats are based on entrenched myths that 

conflict with the scientific evidence at hand (Welch and Criddle 2003). Cooper et al. (2007) found no increase of desirable 

forbs for sage grouse following prescribed fire, but did find a significant increase in exotic forb and grass species following 

burns.

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138. In addition, an alternative should be developed that emphasizes fire suppression and predator control. All Both emc0345GB

139. It could be construed that the NTT may be putting the goal of sage grouse habitat preservation above the creation of fuel 

breaks that serve as defensible space to protect human safety and infrastructure. Before the BLM adopts this strategy they 

may wish to consider the social, economic, and environmental implications of a similar requirement that led to the loss of 

dozens of homes in Stephen’s kangaroo habitat during a wildfire in 1993. Fuel breaks can also prevent the spread of fire 

from developed areas to sage grouse habitat, thus fuel breaks can serve as important conservation measures.

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140. The use of prescribed fire to reduce fuels loads or enhance sage-grouse habitat must be addressed in the RMP amendments. All Both emc0376GB

141. Fire. Issue: Unnatural fire has damaged large areas of sage-grouse habitat in recent years. Prescribed fire and post-fire 

restoration fail to support sage-grouse conservation.

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142. Natural fire intervals in sagebrush steppe range from 35-450 years (Baker 2006), depending on sagebrush type, elevation, 

aspect, etc., although fire may return more frequently to a given watershed during productive periods (Miller and Tausch 

2001). However, a combination of fire suppression and the spread of highly flammable nonnative plants has drastically 

altered the natural fire regime throughout much of the sagebrush steppe (Baker 2011). Wildfires now burn larger, hotter, 

and more frequently in lower elevation basin and Wyoming big sagebrush habitats. Little remains in the wake of these fires, 

and burned areas are often vulnerable to reinvasion by cheatgrass, which can completely occupy a burned site (Chambers 

et al. 2007; Brooks et al. 2004). Paradoxically, the removal of fine fuels (e.g., by livestock) in higher elevation mountain

sagebrush habitats may deprive those sites of natural fire for many years, permitting conifer encroachment in some cases 

(Miller and Rose 1999). The fire regime in sagebrush steppe has been altered by cheatgrass incursion and harmful land uses, 

and habitat loss and fragmentation from fire is likely to accelerate (Wisdom et al. 2005c). More than 12 million acres of 

sagebrush steppe burned in sage-grouse historic range between 1996-2010 (WildEarth Guardians data). Fires, prescribed 

and natural, have long-term effects (>10 yr) and sage-grouse may continue to avoid burned areas even after sagebrush has 

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recovered (Nelle et al. 2000). Sagebrush may return to preburn occurrence within 15 to 20 years after fire if conditions are 

favorable (e.g., proximate seed sources, quick seedling establishment, conducive weather, etc.). If not, various sagebrush 

varieties may require between 30 to 50 years to reoccupy a burned site (Baker 2006; Knick et al. 2005). Wildfire was 

identified as a threat to sage-grouse by two expert panels and three recent reviews (Connelly et al. 2011: 555-556, Tables 

24.1, 24.2). Prescribed fire was also identified as a threat to sage-grouse (Connelly et al. 2011: 556, Table 24.2). Fire within 

54 km of sage-grouse leks was associated with lek abandonment—in fact, the probability of abandonment increased 800

percent for each unit increase in fire within 54 km of a lek (Knick and Hanser 2011). While small, infrequent fires can 

maintain a mosaic of successional habitats that benefit sage-grouse, ecological modeling indicates that frequent, large fires 

in sagebrush steppe may lead to extirpation of the species (Aldridge et al. 2008). Prescribed fire was not shown to improve

habitat characteristics for sage-grouse in Wyoming big sagebrush steppe that was already comprised of shrubs, native 

grasses and forbs (Rhodes et al. 2010).

143. Minimizing wild fires also protects our infrastructure from damage an reduces our need to mobilize crews and equipment 

to rebuild power lines in areas which may be sage grouse habitat

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144. Probably fire is greatest danger to the sage grouse: controlled grazing is the greatest protection for controlling fire. All Both emc0403GB

145. Blue Mt. has fallen victim to the thought that fire isn't a good thing (the aggressive Smokey Bear era) and could benefit from 

the use of controlled or prescribed burns since there is way too much large sagebrush and too thick of populations of sage 

for sage grouse to flourish. The absence of fire has also allowed pinion and juniper to encroach into the sage brush, this 

encroachment needs to be addressed and also other methods of sage brush control need to be investigated

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146. Wildfire, invasion of non-native plant species and livestock grazing work synergistically. Yet BLM and other agencies 

repeatedly try to point to fire and invasive species as threats divorced from livestock grazing disturbance, the most 

pervasive ecological stress across all parts of the sage-grouse range. Fires are occurring more frequently, and the size and 

intensity of fires are increasing. Fires reduce or eliminate shrubs, disturb soils, destroy microbiotic crusts, and release 

nutrients that allow cheatgrass and other weeds to thrive. The end result in grazed landscapes is a paucity of shrub cover, 

few forbs, a shorter period of green plant material (as fires result in hotter, drier sites with little vegetation to trap snow, 

shade ground, and block wind), and a longer fire season.

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147. And a basic question: Where was sagebrush present at the time of the older Plan RODs compared to the present? Where 

did BLM treat lands for forage, fuels, other purposes and what is their condition now? What existing treatments or seedings 

had been identified in LUPs, and what is their condition now? Following fire: Where, when and how did BLM 

rehab/restore/treat sagebrush under the Plan? Detailed mapping and analysis must be provided. Where was cheatgrass 

present, and in what percentage cover? How has this changed in both burned and unburned lands? How soon did BLM allow 

livestock grazing to disturbance to resume following fire rehab, and what was the outcome? A solid baseline must include 

all of this type of information.

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148. For over a decade, WWP has been asking BLM not to build post-wildfire fences that enable livestock grazing on nearly 

every unburned acre. The agency should instead close existing partially burned pastures entirely. Sage-grouse have just lost 

critical habitats in a fire. Then the grouse, in the remaining habitat they have left, suffer grazing disturbance (often 

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May 2012 Greater Sage-Grouse LUPAs/EISs C-1339

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intensified) as well as new lethal fences off so that intensive disturbance is perpetuated. Agencies must adapt to fire by 

providing more ungrazed, undisturbed habitat.

149. Fire and Fuels WO IM 2011-138 and Appendix F of NTT These provisions are weak and toothless. "Where appropriate 

.. design fuels projects to protect sage brush ecosystems..This leaves the door wide open to abuse by agency range staffers 

and managers to do whatever they want. Restore native plants and create patterns[sic] which must benefit sage 

grouse."This enables further wanton destruction of sagebrush habitats under the guise of creating "patterns." In nearly all 

instances, the sagebrush landscape has a complexity of natural patterns - as well as many artificial human-caused patterns 

already. What patterns have been shown to significantly benefit sage-grouse -or pygmy rabbit? There is often natural 

heterogeneity in sagebrush landscapes that provides a complex natural mosaic. Plant communities arbitrarily deemed 

"decadent" by agencies have diverse age classes. Grassier areas dry out quickly, and appear to be promoting many 

frequent fires both immense and small. Areas of grass and seedings are now burning at great frequency in sites across 

southern Idaho. For example: The 2010 300,000 acres Long Butte fire in the Jarbidge. See WWP Long Butte fire Appeal, 

describing fire flashing across 300,000 acres of exotic and post-fire seedings with hardly any sagebrush present - in 2-3 days! 

BLM must fully investigate the role of crested wheatgrass and its post-fire rehab seedings in promoting fire frequency and 

greatly altered fire cycles.

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150. Under fire prescriptions that minimize undesirable effects on veg or soils (i.e. minimize mortality of "desirable" plant 

species). an ID team #4 is just Standard Operating procedure. BLM is supposed to have been following #5 all along, and has 

failed to do so. "Where applicable" incorporate roads as fuelbreaks. These are all standard operating procedure, or

common sense. The overarching problem here is the continued effort by BLM to justify burning, mowing, herbiciding and 

otherwise altering and destroying sagebrush habitats. Long-term habitat losses and weed invasions are the regrettable 

consequences of BLM continuing current ineffective SOPs - which is really all Appendix F of the NTT contains.

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151. The language here (p. 71 fuels) is "key" habitats - such as give priority for implanting sage grouse habitat restoration projects 

in annual grasslands to areas adjacent to or surrounded by key sage grouse habitats. So how is BLM going to do this - when 

it has discarded the whole Key area concept, and cast aside other areas long identified for restoration with its flawed PPH 

mapping? Other provisions here appear to promote bulldozing of fire lines - which often an damage cultural and other 

resources, and wild land areas. BLM must place a moratorium on its destructive and expensive "fuels" projects in the 

Interim - until a comprehensive plan with mandatory and rock solid safeguards is developed. It must conduct a 

comprehensive and full evaluation of all existing treatments from 1950 to the present must be provided for each 

BLM/Forest District. Risk of weed infestation resulting from treatment must be assessed for all areas, as well. This must 

include full examination of cheatgrass risk, which may have a 5-6 year lag period from the initial BLM disturbance if limited 

cheatgrass was present pre-treatment. The NTT reads like BLM fire rehab plans from 30 years ago. It allows BLM to 

continue to use exotic species like the many millions of acres of supposed "placeholder" crested wheatgrass that has been 

planted, and which now is burning with great regularity and that BLM has refused to remove, restore with native, or even 

interseed to any significant degree. How many areas have had some crested wheatgrass seeded on them -over all periods 

of time- for livestock forage and/or fire purposes? Please map these, and overlay mapping of fires and fire frequency.

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152. The Fire Management BMPs are just SOPs - and have been for over a decade. They have been largely ineffective - as BLM All BLM emc0411GB
C. Comments by Resource Planning Issue

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has used "fuels" concerns to alter, fragment and destroy critical sage-grouse habitats, promoting weeds and grassy hotter, 

drier desertified sites that also serve to allow intensified livestock impacts. BLM must fully evaluate the habitat losses and 

fragmentation that have occurred as a result of its projects- and that have spread of cheatgrass and other weeds as a result.

153. BLM is not going to be able to prevent large wildfire. Fuelbreaks will not do that, and often promote weeds that fuel 

frequent fires. And if BLM attempts to engineer a massive series of fuelbreaks, it will only further fragment the sagebrush 

ecosystem and hasten its demise. So as an alternative, BLM must manage lands to be in the best possible condition using 

native species. That way, if an area burns, it is naturally more resilient and better able to recover. Livestock grazing must be 

removed if recovery is to be effective, and to occur without significant risk of cheatgrass and other weeds. Removal of 

grazing also hastens the speed of recovery. Thus, passive restoration -both before and after fires - is essential to resiliency, 

and reducing and minimizing the adverse effects of fire on wild land sagebrush habitats. In some instances, active restoration 

(re-seeding with local native ecotypes) may be necessary. But this must be followed by long-term removal of livestock 

grazing disturbance.

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154. NTT Report "Diffuse Disturbance" Category Is An Effort by BLM to Again Avoid Examining or Controlling Livestock 

Disturbance The NTT report would allow 3% new disturbance in Core Areas. The NTT does not include "diffuse" 

disturbances. It is hard to understand how a fence is "diffuse" disturbance, or herds of several hundred cows imposed on 

nesting sage-grouse are "diffuse" disturbance. These are real damaging disturbances to and disruption of physical space. 

Under this reasoning, exploration for Oil and Gas, or Geothermal, would be a "diffuse" disturbance. After all, the heavy 

equipment moving cross country crushing vegetation is having an effect similar to a herd of grazing sheep or cattle. There 

is direct physical intrusion into space, as well as flushing, disturbing and displacing birds and damage to nests from both. 

The NTT describes livestock grazing and fire as "diffuse disturbances." This makes no sense at all. Fires burn a discrete area, 

and removes sagebrush cover required by sage-grouse. The effects are long-lasting. They are persistent. They alter, degrade 

and destroy habitats. This is not a diffuse disturbance, but a discrete, able to be mapped, long-term disturbance. Grazing 

involves discrete infrastructure and developments that alter habitats in specific, mapable locations. Grazing alters habitat 

components in specific, measurable ways. It imposes disturbance of livestock and management actions on discrete areas 

(pastures) for specific periods of time. Intensity of use can be mapped with use pattern mapping and other methods. 

Agencies apply various typically excessive use standards that are supposed to govern some measurable ways in which 

grazing alters habitats annually. Agencies measure ecological site inventories, rangeland health assessments, etc. to examine 

qualitative and at times quantitative ways in which grazing alters sagebrush systems and thus sage-grouse habitats. It cannot 

merely be considered a generally benign, diffuse disturbance as the IMs and NTT do. Management activities such as 

placement of salt or minerals, or any other activities that concentrate livestock, can cause long-term disruption and loss of 

sagebrush that can take hundreds of years to recover, even with a one-time substance placement. See Fite Jarbidge 

Declaration, with photos showing destruction of mature and old growth big sagebrush due to placement of mineral 

supplements on BLM lands, for example. This is typically followed by weed invasion. All of this is not diffuse disturbance. 

Over the course of just one grazing season, dozens if not hundreds of such damaged sites pepper the landscape. Mature and 

old growth sagebrush is killed, and soils are severely trampled and disturbed. Copious amounts of weed-promoting manure 

are deposited. The site is primed for weed invasion. Further, livestock trailing to concentrate on watering or other sites 

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C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1341

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Table C-13

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break sagebrush, destroy microbiotic crusts, and where slopes are present, trailing may cause incipient gullying that 

worsens over time.

155. Treated lands continue to suffer intensive grazing or other disturbances, thus retarding or preventing altogether the 

recovery of sagebrush habitat components. "Mitigation" funds for new projects destroying sagebrush habitat (such as the 

wind farms, transmission lines, gas pipelines) may be used to deforest large areas, including sites. All such projects (past and 

continuing/foreseeable) must be evaluated honestly. It cannot be claimed that destruction of important sagebrush habitats 

can somehow be mitigated by cutting, chaining, or otherwise altering tree habitats until there is understanding and analysis 

of the ecological value of forests. Projects are being claimed to be sage-grouse projects in areas of minimal importance to 

sage-grouse. Funds are being diverted to these. Plus, if such projects make formerly forested areas more fire-prone -

through creating hotter, drier, windier sites, this is likely to exacerbate fire risks to adjacent or interspersed sagebrush 

habitats. Deforestation may affect local weather patterns, resulting in hotter, drier, weed-prone, harsher, windier sites 

more prone to frequent fires.

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156. Were the large-scale fires of 2007 in northern Nevada and southern Idaho fueled/exacerbated by large areas of hotter, 

drier dead sagebrush, increasingly with cheatgrass in understories? On top of which very dry conditions and very strong July 

winds played out? The Jarbidge AMS, which was finalized right before the 2007 Murphy blaze, included information from a 

comprehensive Ecological Site Inventory – the only one that BLM has ever conducted in recent decades. It found that 

cheatgrass had advanced in many areas of the Jarbidge prior to the Murphy blaze. We can’t look back and clearly separate 

out all the factors involved – but what the Murphy and other unpredictable large fires show is that areas which would under 

this sage-grouse habitat protection prioritization scheme would have, pre-July 2007 been classified as Core/Priority habitat, 

can be radically altered by an unpredictable lightning storm. And myriad factors caused by degradation or natural events can 

also affect habitat and habitat trajectories.

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157. Only by requiring the strongest protective measures when considering new development proposals in sage-grouse habitat 

will you be able to ensure survival of this spectacular species. To that end, I ask that you require the following conservation 

measures in the relevant Resource Management Plans and Land Management Plans-Prohibit prescribed burning within 

priority sage-grouse habitat unless it can be demonstrated that such actions will result in a net benefit to sage-grouse in the 

short term and long term.

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158. Prohibit prescribed burning within priority sage-grouse habitat unless it can be demonstrated that such actions will result 

in a net benefit to sage-grouse in the short term and long term.

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159. Don't prescribe fire in priority sage-grouse habitat All Both flf0000gb 

flf0000rm

160. I urge you to consider concolidated plan amendments that will: limit the use of prescribed fire in priority sage grouse habitat All Both flg0000gb 

flg0000rm

161. We have had 2 major wildfires on our ranch in the last 12 years. I have personally been involved in the suppression efforts 

on these fires. I know more habitat can be saved with minimal changes in fire suppression policy. I saved some areas on our 

ranch with a little effort with my dozer. I witnessed BLM back-burning to create a buffer that in my opinion was overkill and

resulted in large areas of habitat that were burned that did not need to be.

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162. We have observed that well-rnanaged livestock grazing is an effective and sustairrable method for combating several of the 

most significant threats to sage grouse habitat including fuels reduction to mirrimize wild fires and to prevent or rlow 

invasive species and conifer proliferation. While the ESA does not provide for the cost of a mitigation strategy to preclude 

its implementation, funding to implement strategie,s is none the less rraturally limited. Our continued ability to serve a 

broad spectrum of multiple-use industries is crucial to maintaining their ability to provide beneficial habitat managerflent 

and their financial viability to implement appropriate mitigation ffieasure5. Mininrizing wild fires also protects our 

infrastructure from damage and reduces our need to mobilize drews and equipment to rehuild power lines irt areas which 

may be sage grouse habitat.

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163. Sound scientific research indicates that grazirrg is beneficial to the Ereater sage-grouse and othef flora and fauna in multiple 

ways. Grazing reduces the instances and severity of wildfires" (Launchbaugh er al.2007). It improves greater sage-grouse 

habitat by increasing the quality and accessibility of forbs for sage grouse (Neel 1980, Derner et aI.1994, Evans 1996). [t has 

also been used to control invasive weeds (Olson and Lacey 1994, Walker et at.1994).

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164. The EIS and SEIS revi,sioils should clarify that multiple-une management concepts should be used to reduce the risk of 

catastrophic wildfire, improve forage. refilove invasive species and provide open space. We strongly encourage the 

agencie.r to prioritize theit focus on public land use, or disuse, which poses a real threat to the greater sage-grduse and its 

habitat

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165. We have seen devastating fires in Northern Nevada that have destroyed sage grouse habitat and surely destroyed many 

birds. Fire control needs to be more proactive and fires need to be controlled before they devastate millions of acres of 

habitat.

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166. Controlled burns by the Forest Service and BlM would be beneficial to help create a healthier habitat for Sage grouse and 

other shrub steppe dependent species by providing a mixed age class of sage brush, shrubs) with a healthy understory. 

Controlled fires wouldn't be as devastating and destructive as the wildfires we have seen the past few years.

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167. Sage Grouse don't survive wild fire too well and if that much dry grass is left standing on all of the western ranges you will 

have a beautiful black charred landscape.

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168. I really think that if the BLM and the Forest Service would make a concentrated effort to suppress the big fires in the 

sagebrush and develop and repair water sources, particularly waterholes, that the sage grouse would come back to their 

former numbers better than if they were listed, which probably wouldn't help them at all.

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169. Targeted grazing should be allowed and encouraged as a tool for creating fire breaks, controlling weeds, and improving 

habitat. In some cases, fencing can help facilitate the success of a Targeted Grazing project. Electric and net wire fencing 

should not fall under the same specifications as other high-impact problem fencing.

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170. Over the past 30 years the west has encountered wildland fires that have destroyed millions of acres of public and private 

lands. The wildland fires have destroyed not only sage-grouse habitat but other wildlife and wildlife habitat. Elko County 

believes that the changes in public land grazing policies that have been implemented in recent years has directly contributed

to the catastrophic fires and degradation of much of the public lands in the west. These fires have directly contributed to 

the loss of wildlife and wildlife habitat including the Greater Sage-Grouse habitat. In 2006 in northern Nevada alone over 11 

million acres of public and private lands along with wildlife habitat was lost to wildland fire. These catastrophic fires were 

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May 2012 Greater Sage-Grouse LUPAs/EISs C-1343

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not prevalent nor as severe in the west during the period of time that cattle and sheep livestock grazing was at its peak. The 

consistent removal, restriction or limiting of livestock grazing has promoted decadent dry fuels that are easily ignited and 

become enormous wildland fires destroying all in its way.

171. The beneficial effects of grazing on sage-grouse and its flora and fauna must be made clear. Deal especially with fire effects, 

plus forbs community enhancement.

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172. The Organizations have to question the basic accuracy of the 2010 Charter's summary as only two specific areas under BLM 

regulatory authority were identified as issues possibly impacting the sage grouse. Reviewing the 2010 Conservation Charter 

without reviewing the FWS listing decision could easily lead to the conclusion that all BLM planning was found to be equally

insufficient in the listing decision. This simply is not the case. The inaccuracy of the Charter will create further confusion of 

priority regulatory issues and allow targeting of low priority management issues, as the 2010 Conservation Measures are 

applied at the field office level. The FWS listing decision specifically states: "However, a regulatory mechanism that requires 

BLM staff to target the protection of key sage-grouse habitats during fire suppression or appropriate fuels management 

activities could help address the threat of wildfire in some situations ..... however, a long-term mechanism is necessary given 

the scale of the wildfire threat and its likelihood to persist on the landscape in the foreseeable future,"

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173. The EIS should identify how much sage grouse habitat has been affected by wildfire vs. how much has been recently directly 

affected or impacted by industry (e.g., oil and gas, mining, energy developments, geothermal).

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174. Prior to restricting industry on public lands, the government should make an effort towards restoring fire-damaged areas 

and restoring sage grouse habitat. Such efforts cannot be piecemeal, but a combined effort across the western U.S.

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175. In fact the use of Prescribed Fire on the range is a Federal Land Management action to clear lands and make them more 

productive for the Grazing Industry. It's a practice that has been used for the last 20 years that is now recognized as 

producing unwanted effects in Sage Grouse habitat.

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176. The Economic analysis should estimate potential increased costs for fire suppression related to Juniper treatment areas. All Both rmc0036GB

177. Sage grouse in the West must be evolutionarily adapted to wildfire, as wildfire is integral to sagebrush habitat ecology. 

Therefore wildfire risk reduction should not be a major focus of sage grouse conservation planning.

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178. Many permittees have voluntarily implemented adaptive grazing management strategies to encourage Sage-grouse 

Conservation on their allotments and private lands, and many of the recent permit renewals have included such measures. 

The Board requests that the BLM make every effort to work collaboratively with permittees to recognize and use grazing 

as a tool to enhance Sage-grouse conservation. For example, the use of grazing to reduce fine fuel loads and noxious species 

could greatly enhance efforts related to "integrated vegetation management" and "wildfire suppression and fuels 

management." Also, prescribed grazing can be used effectively to improve or enhance Sage-grouse habitat as noted in the 

Report.

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179. Under "Wildfire Suppression and Fuels Management" The BLM PElS should analyze developing flexibility in grazing permits 

or a new means of providing flexibility to remove residual or excess fine fuels on years of high productivity in order to 

protect enacted Sage-grouse habitat. The same is true in use or selection of planned grazing systems. Complete rest over 

a given year can result in excessive buildup of fine fuel thereby greatly increasing the risk of especially damaging wildfires.

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C. Comments by Resource Planning Issue

C-1344 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

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ID

Agency CmtLtrCode

180. NINTH Persons responsible for public lands management must address the fire issue. How badly have sage grouse been 

hurt since the late 1970's when the Forest Service and Bureau of Land Management began reducing livestock use on public 

lands which actions in term have led to ever increasing wildfire frequency and intensity, which in turn has led to the needless 

destruction of wildlife and wildlife habitat? What percentage of sage habitat important to sage grouse and pygmy rabbits has 

been lost during the last 20 to 25 years because of increases in wildfire?

All Both rmc0054GB

181. The presence of livestock owners and their employees on the land is a major factor in early detection of invasive species 

and fires. During fire season, owners are on constant watch.

All Both rmc0063GB

182. Another major issue is the interrelationship of responsible livestock grazing and wildfire management and prevention. All Both rmc0063GB

183. Pages 16 and 17 in the NTT report suggest that BLM only allow treatments that conserve, enhance or restore sage-grouse 

habitat. An analysis should be conducted to evaluate the need for age-class diversity in sagebrush communities. We also 

request that the BLM consider allowing other treatments that are designed to achieve alternative objectives as long as they 

do not negatively impact sagegrouse habitat. Page 26 recommends that fuels management allow no treatments in winter 

range. Recommending no treatments in winter range is not realistic for PPH in the North Park basin

CO BLM emc0060RM

184. Many of the best leks are located on old fire scars and yet there are no positive statements about the effects of fire on sage 

grouse habitat in the Report on Conservation Measures. Fire in the habitat systems across the west is one of the most 

important factors in keeping that habitat vibrant and productive. The misguided and ill informed, decades long, attempts at 

fire suppression have led to encroachment by woody plants, basins of decadent over-grown sage, and the occasional 

uncontrollable catastrophic blaze that sterilizes thousands of acres and in turn facilitates invasive species establishment. Fire 

needs to be considered as the restorative agent that it is.

CO Both emc0061RM

185. The BLM should consider a ‘conservation alternative’ that: - Includes conservation measures recommended by the NTT 

Report, with improvements, including, but not limited to the following: o Avoid sagebrush reduction/ treatments to 

increase livestock or big game forage in priority habitat and include plans to restore high-quality habitat in areas with 

invasive species. o Implement range management practices outlined by the NTT, with addition of further conservation 

measures, including avoiding new range and water developments that negatively impact sage-grouse and applying the 3% 

disturbance cap to certain range developments. o Design fuel treatments to protect existing sagebrush ecosystems 

(including avoiding such treatments where they will harm sagebrush ecosystems) and prioritize fire suppression to 

conserve the highest quality habitat. o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t 

negatively impact sage-grouse populations in priority habitat,31 thus negating the value of designated priority habitats. 

Include small or isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority 

habitat, and protect and enhance such populations with science-based prescriptions. - Combines this with designations of 

a subset of priority habitat as Areas of Critical Environmental Concern that receive a higher level of protection than that 

recommended by the NTT.

CO BLM emc0070RM

186. CPW believes the following range-wide threats pose the greatest risk to greater sage-grouse populations and their habitats 

(not in order of risk): A principal feature of landscape-scale wildfires in sagebrush habitat includes an extreme I y long time 

frame (25-120 years, depending on habitat type) before the habitat again has the vegetation structure necessary to support 

CO Both emc0072RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1345

Scoping Summary Report

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nesting and wintering sage-grouse.

187. CPW believes the following range-wide threats pose the greatest risk to greater sage-grouse populations and their habitats 

(not in order of risk): Prescribed fire as management tool may be appropriate in limited conditions; however, introduction 

and invasion of exotic weeds resulting from a burn is a major concern for sage-grouse. The long-lasting effects of fire on 

sagebrush regeneration and growth form and thus, impacts to sage-grouse nesting and winter habitats also need to be 

carefully considered prior to implementing prescribed fire in sagebrush systems.

CO Both emc0072RM

188. (One of the most important NTT recommendations for Routt NF) "Allow no [fuels] treatments in known winter range 

unless the treatments are designed to strategically reduce wildfire risk around or in the winter range and will maintain 

winter range habitat quality." Ibid.

CO USFS emc0175RM

189. (One of the most important NTT recommendations for Routt NF) "Monitor and control invasive vegetation post‐[fuel] 

treatment. Ibid.

CO USFS emc0175RM

190. (One of the most important NTT recommendations for Routt NF) "Make re‐establishment of sagebrush cover and 

desirable understory plants (relative to ecological site potential) the highest priority for restoration efforts." Id. at 28.

CO USFS emc0175RM

191. Fire in the west is one of the most important factors in keeping grouse and other wildlife habitat vibrant and productive. 

Therefore, the value of fire management on the sage grouse habitat should definitely be evaluated within the EIS.

CO Both emc0178RM

192. iv. The BLM and FS should analyze an alternative that provides more protection than that afforded by implementation of the 

National Technical Team’s Recommendations. The BLM and FS should consider an alternative that: - Includes 

conservation measures recommended by the NTT Report. - Combines this with designations of a subset of priority 

habitat as Areas of Critical Environmental Concern that receive a higher level of protection than that recommended by the 

NTT. - Incorporates improvements to the NTT’s recommendations, including the following: o Avoid sagebrush 

reduction/ treatments to increase livestock or big game forage in priority habitat and include plans to restore high-quality 

habitat in areas with invasive species. o Implement range management practices outlined by the NTT, with improvements,

including avoiding new range and water developments that negatively impact sage-grouse and applying the 3% disturbance 

cap to certain range developments. o Design fuel treatments to protect existing sagebrush ecosystems (including avoiding 

such treatments where they will harm sagebrush ecosystems) and prioritize fire suppression to conserve the highest quality 

habitat. o Ensure that disturbance or uses that are permitted adjacent to priority habitat don’t negatively impact 

sage-grouse populations in priority habitat,10 thus negating the value of designated priority habitats. o Include small or 

isolated populations (such as those along the periphery of the greater sage-grouse’s range) in priority habitat, and protect 

and enhance such populations with science-based prescriptions.

East Both emc0089RM

193. iii. Strong components of Wyoming’s approach Wildfire, a major form of disturbance that often is followed by the invasion 

of non-native species, is being addressed through active fire suppression in core areas. Operators are required to control 

noxious and invasive weed species, including cheatgrass.

East Both emc0089RM

194. As the large landscapes required to sustain grouse populations, become further fragmented by the increasing frequency of 

wildfires, focus on restoration will become more important. Sage-grouse have evolved in habitat that has extremely 

infrequent wildfires, and benefit from the presence of mature sagebrush stands. Habitat fragmentation and alteration due to 

East Both emc0089RM
C. Comments by Resource Planning Issue

C-1346 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

Comments Related to Fire Management

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fire may influence distribution (including lek abandonment) or migratory patterns. We suggest that a funded program be 

dedicated to identifying sagebrush landscapes that are at risk from severe fire and that field offices be prepared with a 

response plan to avoid the conversion of compromised landscapes to ones that are dominated by invasive species following 

fires.

195. So called "habitat improvement" projects, such as mechanical sagebrush treatments and prescribed fire, can be detrimental 

to greater sage-grouse and other sagebrush obligate species. Scientifically defensible research is needed to determine which 

activities are beneficial. This information should be maintained in a single federal database.

East Both emc0089RM

196. Management of wild and prescribed fires is considered an important issue in maintaining vital sagebrush habitat (Crawford 

et al., 2004).25 Historically, fire was the primary natural disturbance in sagebrush dominated ecosystems where 

sage-grouse evolved (Ibid.). The suppression of fire is believed to have changed historic sagebrush systems, encouraged the

spread of invasive vegetation, and contributed to the expansion of Western Juniper (Juniperus occidentalis)(Miller and 

Rose, 1999).26 Western Juniper expansion has changed historic sagebrush steppe habitat to predominately juniper 

woodland in many areas of the Great Basin, primarily in Oregon (Rowland, et al. 2010). Since 1930, juniper woodlands in 

Eastern Oregon expanded from 600,000 ha to over 2.6 million ha, resulting in fragmentation and loss of sagebrush habitat 

(Ibid.). As a result of juniper expansion, BLM has begun to take on projects to control the spread of woodlands into historic 

sagebrush systems. Availability of sagebrush at local and landscape scales is a requirement for Greater sage-grouse 

persistence (Johnson et al., 2009). All juniper treatments (including manual removal and prescribed fire) should be 

undertaken to minimize the spread of invasives, retain the maximum amount of sagebrush and associated native forbs and 

grasses. A few best practices, which have been used by BLM in Oregon to manage juniper through prescribed burns, 

include: 27 - Resting treated areas from grazing for a minimum of two grazing seasons - Closely monitoring grazing 

impacts after livestock are returned to allotments - Scheduling treatments to avoid breeding and nesting periods We 

encourage BLM to incorporate best practices and ensure that all steps are taken after burns for native vegetation to return. 

In addition, we recommend a vegetation monitoring program be implemented which includes control plots to exclude 

livestock grazing so that additional best practices can be established in a scientifically defensible manner. Habitat 

improvement projects frequently lack rigorous monitoring and evaluation plans, which undermines the ability of land 

managers and the public to quantify the benefits of management actions (Whisenant, 1999). Summary: BLM should 

identify a clear benefit to sage-grouse and a restoration plan with quantifiable objectives before practicing juniper removal. 

Planning should include careful post-removal management to prevent invasion by weeds and to establish a native sagebrush

community that will support sage-grouse.

GB Both emc0355GB

197. The one-size fits all approaches discussed on page 26 of the report are not appropriate. Fuels treatments (at least in our 

area) largely consist of linear green strips designed to eliminate heavy fuels in narrow corridors. This reduces fire severity 

when it bums into the fuel strip and increases the probability for a successful direct attack. It is difficult and probably costly 

to implement treatments that only reduce sagebrush cover to about 15%. Also, the lifespan of such treatments often will be 

short. Initial treatment will be costly and largely ineffective.

GB Both rmc0076gb

198. In many areas, winter habitat is some of the most widespread and contiguous habitat. Much of it is one large fire away from 

the functional loss of all sagebrush. Fuel treatments composed of linear strips that remove the shrubs and promote 

GB Both rmc0076GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1347

Scoping Summary Report

Table C-13

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perennial bunchgrasses are the only realistic approach to breaking up these large continuous landscapes. We have concerns 

that this type of management imposed disturbance may be prohibited because of the limit of3% discrete disturbance in sage 

grouse priority habitat. Management actions should focus on the overall management goals, threats and risks, and the 

actions needed to achieve those goals and reduce threats and risks. Stringent numeric triggers that guide whether an action 

is or is not implemented should be avoided.

199. Controlled fire burns in habitat areas where graze - Are these being done? IDMT Both cfc0009GB

200. In Lemhi County we don’t have the burn out situation as southern Idaho and don’t have the private land loss of habitat from 

fire and such. My comment on this is don’t make one size fit all‐don’t put Lemhi County in/under same law/control as areas 

that have had the greater losses. Don’t punish us for issues that have happened somewhere else.

IDMT Both emc0045GB

201. Categories for planning issues: Fire/Fuels management. Having lived through the last thirty (30) years of Forest Service 

management that has resulted in the loss of what were a robust timber industry, a pine beetle epidemic, and forests choked 

with overgrowth and brush we are now facing a catastrophic fire season. The Forest Service in Montana has done little to 

reduce fuel loading but has put in place impediments to the personal use firewood collector. The only group trying to

remove fuels from the forest has been ham strung in their efforts. The only forested acres in the East Pioneer Mountains 

that are green are those which were clear cut 25-30 years ago. Clear cuts don’t burn and are more resistant to pine beetle

infestation

IDMT Both emc0133GB

202. In addition to these goals, the Group has identified key threats to sage grouse in the Jarbidge Planning Area that they believe 

deserve special attention and consideration. These key threats include fire and invasive species, with fire having recently 

damaged a significant portion of the sage-grouse habitat in the Jarbidge Planning Area.

IDMT Both emc0158GB

203. It appears that the agency has overlooked many of the benefits that the continuance of livestock grazing provides. These 

include: Preservation of open space; Noxious weed and invasive species eradication and containment; Production of forb 

growth that is preferred by greater sage-grouse to non-grazed areas; Wildfire prevention and controlled burn efforts; 

Development of wildlife watering sources, including placement of bird ladders in troughs; and Predator control. Rather 

than undertaking an attitude of restricting livestock, the agencies should utilize grazing as a tool to manage for the U.S. Fish 

& Wildlife Service's list of primary threats affecting sage grouse in Idaho including fires and invasive weeds.

IDMT Both flh0000GB

204. The Dillion Local Working Group identified 5 key issues in the area: 2. the adverse affects of wildfire or prescribed fire IDMT Both rmc0028GB

205. Actions that reduce or minimize sage brush habitat include: -Eliminating sagebrush (including burning, plowing, mowing, or 

use of herbicides) as part of efforts to promote grass growth, or reduce fuels. -Wildfire

IDMT Both rmc0028GB

206. Although fire disturbance can have positive effects on some prairie species, it should be noted that big sage brush is 

incredibly slow to recover from fire, which means a wildfire can eliminate sage grouse habitat and forage for decades. 

Ranchers and ranching communities provide a look-out and first-response system that absentee owners do not. The BLM 

and the counties have historically done a very good job of partnering with the local ranches to keep summer wildfires

controlled. Furthermore, grazing is effective at fire prevention.

MT-RM Both emc0013RM
C. Comments by Resource Planning Issue

C-1348 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

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207. There is no evidence that cattle have any impact on sagegrouse, either positive or negative. However, there is plenty of 

evidence that ranching has a strong positive impact on sagegrouse. Ranches need to be relatively large and usually in native 

vegetation. This protects against habitat fragmentation and the destruction of sagebrush for fields or lawns. Ranchers need 

vegetation and will control fires to some extent. Hot, late, uncontrolled fires will destroy large areas of big sagebrush, which 

takes over a century to recover from a burn of this kind. Ranches tend to have some degree of predator control, and 

predators are the largest negative impact on sagegrouse, following sagebrush destruction. Areas with healthy sagegrouse 

populations tend to have ranches, areas that have lost their ranches have also lost their sagegrouse. It is easy and popular

to protect sagegrouse from cattle, but the cattle don't harm the sagegrouse. If you remove the cattle, you also remove the 

ranches, which are important to the sagegrouse. Sagegrouse can be protected into extinction just like rare orchids and 

desert pupfish.

MT-RM Both emc0023RM

208. We belive the biggest threat to sage-grouse in the Virginia Range was due to a devasting fire in the Virginia range about 12 

years age. As a result of this fire almost all sage brush was burned and to date very little sagebrush has come back.

MT-RM Both emc0232GB

209. In recent years the amount and size oftires is Southern Idaho and Northern Nevada has been higher than we can ever 

remember. We feel this is the biggest threat to the Sage Grouse because of loss of prime and necessary habitat, and the loss 

of prime food source for the birds.

NVCA Both emc0145GB

210. Wildfire Suppression and Rehabilitation: We are concerned with the significant amount of sage-grouse habitat that has been 

lost from wildland fires. Our concerns are that restoration has not been very successful and has not occurred in a manner 

that benefits wildlife. NBU acknowledges that site stabilization is essential following to a wildland fire event; however, land 

management agencies may be able to restore habitat in a manner that will be more beneficial to wildlife than those tactics 

currently being used. NBU favors restoration efforts that rehabilitate habitat in a manner that promotes wildlife use during 

its initial stages and throughout its successional stages. We also think that fire management plans need to rank wildlife 

habitat, including sage-grouse, as a more critical resource. We understand that fire suppression is very dynamic requiring 

multiple variables to be considered for each individual incident; however, policies need to be in place that allow interagency 

fire suppression efforts, especially initial attack, to be more effective.

NVCA Both emc0180GB

211. wildfire suppression, fuels management, and fire rehabilitation: There is a lot of disagreement between federal agencies and 

state wildlife agencies on any proposals to burn sagebrush or otherwise poison or mechanically destroy sagebrush for fuel 

breaks. Burning or otherwise destroying sagebrush results in direct habitat losses to Sage Grouse, both priority and general 

and risks of uncontrolled prescribed fires burning outside the project areas. In addition, there is insufficient scientific 

verification that the benefits of burning sagebrush to Sage Grouse or priority habitats outweigh the costs of increasing 

destruction, degradation, and fragmentation of intact sagebrush habitats or risks of uncontrolled prescribed fires. Fire 

rehabilitation also is also problematical, as fires can and do lead to expansions of invasive weeds and other vegetation 

undesirable to meet habitat requirements for Sage Grouse and other wildlife and rehabilitation often fails. Conservation 

measures are needed to address the threats of the fire management program to Sage Grouse and its habitats. a. the 

agencies should prioritize Sage Grouse priority habitats for wildfire prevention and suppression. b. the agencies should 

determine that proposed fuels suppression/management projects have greater benefits than costs to Sage Grouse. c. the 

agencies should design fuels projects to protect existing sagebrush ecosystems, including meeting specified objectives for 

NVCA Both emc0283GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1349

Scoping Summary Report

Table C-13

Comments Related to Fire Management

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sagebrush cover in priority habits. d. the agencies should apply apply seasonal restrictions for fuels projects. e. the agencies 

should not allow fuels projects in winter range or in <12 inch precipitation zones or in any areas with high potentials for 

weed invasions. f. the agencies should monitor and control invasive weeds, following fires and fuels projects. g. the agencies 

should require rest from grazing until restoration objectives are met. h. the agencies should require the use of native seeds 

and prioritize their use in rehabilitation of damaged priority habitats. i. the agencies should modify grazing management to 

sustain long term persistence of native plants. j. the agencies should evaluate any proposed use of livestock to reduce 

weeds, such as cheat grass, against grazing damage to native perennials. k. the agencies should consider the effects of 

droughts and climate change on potential restoration of burned areas.

212. CRI operates the Rochester Mine which is located 23 miles northeast of Lovelock on the southern end of the Humboldt 

Mountain Range in Pershing County, Nevada. Sage grouse summer, winter, and breeding habitat has been identified by 

past Nevada Division of Wildlife (NDOW) maps in Rochester mine's project area. NDOW has not, however, indentified 

any active leks or viable sage grouse populations around the project area. According to NDOW's Nevada Sage Grouse 

Conservation Project Report (December 2011 Final Performance Report): "The Pershing County portion of this planning 

unit has suffered tremendous losses of sagebrush habitats due to wildfire over the last decade with some mountain ranges 

burning almost completely (e.g. Eugene Mountains). The most viable population within the county is the Sonoma PMU. 

Twenty-four leks were surveyed in this PMU in 2011 with only 6 being active. A peak total of 52 males were observed 

resulting in an average of 8.7 males per active lek. This is a 7% decline from the previous year where the average attendance 

was 9.4 males. The long-term viability of PMUs such as the Eugene, Majuba, East Range, and Humboldt PM Us is considered 

very low, with some of these populations potentially extirpated already.'

NVCA Both emc0302GB

213. It is especially important for BLM and USFS to prepare new maps using current data for Nevada because the Landsat 

imagery from 2001 - 2005 provide a snapshot of the state that does not represent current conditions due to the wildfires 

that swept through northern Nevada in the early 2000s. These fires destroyed a portion of the sage brush ecosystem in 

northern Nevada that is an important component of sage-grouse habitat. It is widely recognized that damage due to these 

fires is a principal reason for sage-grouse habitat reduction in Nevada.

NVCA Both emc0327GB

214. It is inappropriate to base important policy decisions on maps that show sage brush communities and sage-grouse habitat 

that no longer exist due to wildfires. The NEP A analysis in Nevada must not be based on anachronistic data that do not 

provide accurate infonnation on the current location and extent of sage-grouse habitat.

NVCA Both emc0327GB

215. Although it is truly unfortunate that there were wildfires that burned sage brush and destroyed sage-grouse habitat in 

northern Nevada, that is the reality in Nevada. The NEPA analysis must use a habitat distribution map that reflects these 

baseline conditions - not a map that inaccurately shows more habitat than currently exits - and will not provide a basis for 

meaningful analysis or the agency to rigorously explore and objectively evaluate all reasonable alternatives as NEP A 

requires. Indeed, alternatives and impacts cannot be reasonably or reliably evaluated if the data relied upon is stale and/or

inaccurate.

NVCA Both emc0327GB
C. Comments by Resource Planning Issue

C-1350 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

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216. Furthermore, the Association would like to address the threat of wildfire to greater sage-grouse habitat. As one of the top 

five threats to the greater sage-grouse, improvements to wildfire pre-suppression methods to preserve the sagebrush 

communities in which greater sage-grouse reside and restoration strategies to replace deteriorated rangelands due to 

wildfire should be further researched. One such presuppression method the Association would like to suggest is the use of 

livestock grazing to produce fire breaks and maintain undesirable upland species. Research directly indicates that livestock 

grazing reduces the instances and severity of fires. The Association strongly believes that management for the conservation 

of greater sage-grouse and other sagebrush dependant species must focus on the health and resilience of the sagebrush 

ecosystem and should assess all available strategies to achieve healthy sagebrush ecosystems.

NVCA Both emc0328GB

217. Design and implement fuels treatments with an emphasis on protecting existing sagebrush ecosystems. - Do not reduce 

sagebrush canopy cover to less than 15% (Connelly et al. 2000, Hagen et al. 2007) unless a fuels management objective 

requires additional reduction in sagebrush cover to meet strategic protection of priority sage‐grouse habitat and conserve 

habitat quality for the species. Closely evaluate the benefits of the fuel break against the additional loss of sagebrush cover 

in the EA process. - Allow no treatments in known winter range unless the treatments are designed to strategically reduce 

wildfire risk around or in the winter range and will maintain winter range habitat quality. (Found under Fire Operations) In 

priority sage‐grouse habitat areas, prioritize suppression, immediately after life and property, to conserve the habitat. - In 

general sage‐grouse habitat, prioritize suppression where wildfires threaten priority sage‐grouse habitat. - Follow Best 

Management Practices (WO IM 2011‐138, see appendix E.) The Association strongly supports pre-suppression method of 

fuels management and striving to support a healthy sagebrush ecosystem to maintain a viable greater sage-grouse 

population. The above referenced measures do not allow for flexible fuels management techniques that would better 

support pre-suppression methods nor does the Association feel that the above referenced measures support striving to 

support a healthy sagebrush ecosystem.

NVCA Both emc0328GB

218. We have experienced firsthand the wildfires that have raged through northern NV in the last decade. As a result we have 

lost AUM’s for years at a time. We have also fenced areas of burned range in order for it to rehabilitate. Some of the areas 

that burned quite frankly needed burning as they were overgrown with old decadent sage that was taller than a person

horseback and choked the feed that could be growing beneath it. In some burn areas the feed came back more lush and 

thick than ever...some of those areas were seeded, others were not. In other areas you saw an immense invasion of noxious 

weeds...some of those areas were seeded, others were not. Obviously sage-grouse habitat also burned in these huge fires. 

Hundreds of sagegrouse had to have died as well.

NVCA Both emc0390GB

219. It is hard to understand claims made in the report that appear aimed at minimizing the impacts of the 1999-2007 fires. Even 

though significant portions of Elko County burned ... this planning unit continues to harbor some of the largest and most 

contiguous sage-grouse populations in Nevada. This describes NDOW mainly focusing on trend leks, while BLM directs 

efforts towards checking leks associated with burned areas or that have little historic data. There appear to be omissions 

of sampling important sites like the Islands area. Are there no Trend leks in small PMUs? If not, why not? Some should be 

established. All does not appear to be well in other areas suffering significant losses in the 1999-2007 fires. Example: 

Gollaher:124 known leks, with 33 leks surveyed. Yet just 6 were active. This includes portions of the extremely degraded 

Salmon River allotment, Goose Creek, and other areas – and these lands have suffered significant losses during many 

NVCA Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1351

Scoping Summary Report

Table C-13

Comments Related to Fire Management

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Agency CmtLtrCode

wildfires. Of the 124 known leks – how many are urrently active? Where are active leks in relation to fires? Where are 

inactive leks? This is the kind of information that is essential for understanding the impacts of fires, or other habitat changes 

or developments. What has happened to trend leks in or near areas that have burned? What is the habitat like surrounding 

leks that continue to have birds, vs. leks that do not. In O’Neil, 43 leks were surveyed, yet only 15 were active. This area 

too has suffered large-scale fire. And of course – in the contiguous Islands PMU, no leks were surveyed. Why is no mapping 

or other information provided to portray what is occurring, and show the leks that were sampled and active vs. inactive?

220. As previously described, it is from our observations of BLM’s claimed “fuelbreaks” and vegetation treatments conducted 

across Nevada (Austin Fuelbreaks, Elko Owyhee Fuelbreaks, Ely Fuelbreak weedlands of Cherry Creek and Spring Valley 

treatments, etc.) that removal of shrub protective cover, or tree protective cover, results in hotter, drier sites that become 

dominated by cheatgrass several years following “treatment”. There is typically a 4-6 year lag period in sites that previously 

had little cheatgrass before being altered, which is longer than agencies typically monitor their “treatments”. So the 

cheatgrass is showing up after BLM quits monitoring.

NVCA Both emc0411GB

221. Wildfire is listed as the 3rd largest threat, and we agree it is a big problem, worsened by invasive species that come in after 

the fire. Large fires, over 1,000 acres in size eliminate most beneficial sage brush species that Sage Grouse depend on.

NVCA Both rmc0064GB

222. An issue not mentioned in Assemblyman Hansen's article which is also of great importance is fire management. The 

degradation of sage brush communities by frequent fires due to the intrusion of cheat grass has greatly impacted 

sage-grouse populations. Livestock grazing can be used as a tool to reduce cheat grass and fuel loads as shown by recent 

studies conducted by the University of Nevada Reno (Reducing fuel load of key cheatgrass dominated range sites by the use 

off cattle grazing by Lee Schmelzer). Other fire management practices such as planting of Forage Kochia and fire road 

maintenance are critically important for the suppression of fire.

NVCA Both rmc0065GB

223. Habitat loss in the Beaty Butte unit is due to past BlM prescribe burning that got out of control. However, those losses are 

localized although severe due to the size of the burns. Overall, through personal observations, sage populations are 

improving but are suppressed by an ever increasing avian population of raptors, ravens and crows, and coyotes, cougars, 

bobcats, and badgers.

OR Both emc0139GB

224. Employ Best Practices for Fire Management and Seeded Treatments: BLM should use the most recent science to create 

effective planning around fire management and seeded treatments that will help maintain long-term sagebrush plant 

communities and sage-grouse habitat.

OR Both emc0385GB

225. My personal observations of "Treated" juniper Encroachment areas on private lands throughout the Lakeview District 

show that in modest density stands it creates a high potential for Fire adjacent to public lands; it effectively decreases the 

sightlines increasing the likelihood of Sage Grouse predation; decreases private land productivity and impedes movement; 

and generally creates a visual eyesore. Before adoption of the EIS management plan, all agencies involved in Fire Fighting 

must conduct an inventory of all treated lands and determine the Fire Risk factors and potential limitations posed to 

firefighter access and safety; fuel loading and potentials for catastrophic fire conditions, and dangers to public land and 

Private Property.

OR Both rmc0036GB
C. Comments by Resource Planning Issue

C-1352 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-13

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226. Blue Mt. has fallen victim to the thought that fire isn’t a good thing (the aggressive Smokey Bear era) and could benefit from 

the use of controlled or prescribed burns since there is way too much large sage brush and too thick of populations of sage 

for sage grouse to flourish. The absence of fire has also allowed pinion and juniper to encroach into the sage brush, this 

encroachment needs to be addressed and also other methods of sage brush control need to be investigated.

UT Both emc0296GB

227. The position that the threat of possible Sage Grouse listing has placed our citizens, western land states and their local 

government entities in, we view as a direct result of years of federal regulatory onus. Carbon Comity shall take a willing role 

in working to remedy this issue but believe that until the federal agencies and our national leadership recognizes that; 

reducing grazing AUM's west wide consistently for over 50 years, listing under ESA the natural predators of the grouse 

species, outlawing the use of poisons used to prevent predation and the promotion of fuel/biomass buildup by interrupting 

natural fire regimes have hosted the consequences we and the bird now endure.

UT Both rmc0026RM

228. ‘Avoid the use of prescribed fire in areas of Wyoming big sagebrush and or within areas of less than 12 inches of annual 

precipitation.’(page 12 letter) Treatment for cheatgrass or downy brome is important and burns are tool that is used. More 

specificity is needed here-treatments will continue with burns for cheatgrass if the canopy of sagebrush is not reduced a 

certain %. There are many areas where downy brome can be burned without harming the sage brush and will bring in better 

forage post treatment. The rainfall limitation will prevent many areas of the state from prescribed burns because of the lack

of water. Place this limitation on a case by case basis as there are several areas with invasive weeds or grasses that would 

benefit from a good burn but the rainfall limitation of 12 inches makes this a no go.

WY Both emc0050RM

229. There should be no prescribed burning of forage within sage grouse core areas unless it is for ditch cleaning or similar 

maintenance. When prescribed burns occur within core areas that presents a disturbance that counts towards the total 5% 

surface disruption. The managing federal agency can then come back and cut the AUMs in that area because there has been 

too much surface disturbance—due to the burn. A planned burn by any federal agency should occur outside of the core 

areas for this reason. Lease holders should not be punished by a drop in AUMs because the federal agency decided to do 

a burn within a core sage grouse area.

WY Both emc0050RM

230. iii. Strong components of Wyoming’s approach Wildfire, a major form of disturbance that often is followed by the invasion 

of non-native species, is being addressed through active fire suppression in core areas. Operators are required to control 

noxious and invasive weed species, including cheatgrass.

WY Both emc0089RM

231. 8) Consider sage grouse habitat needs in the management of wild land and prescribed fire which recognizes the limited 

extent of important habitats in these mountain valleys. Scale and location are important considerations. Suppression of 

wildfires in important sage-grouse habitat (nesting, early brood rearing, and winter habitat) should be a priority.

WY USFS emc0144RM

232. Stop the burns for prairie dog habitat in core sage grouse areas so that it is never included in any percentage of disturbance. WY Both emc0176RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1353

Scoping Summary Report

Table C-13

Comments Related to Fire Management

Comment

No.

Comment SubRegion

ID

Agency CmtLtrCode

233. In Wyoming, Wyoming big sagebrush dominates the vast majority of sage grouse habitat throughout the state, both in the 

Wyoming Basins Ecoregion and on the Great Plains. Natural fire return intervals in Wyoming big sagebrush average 

100-240 years (Baker 2007). Wyoming big sagebrush recovers slowly after fires, which typically result in 100% sagebrush 

mortality; recovery to pre-fire canopy cover takes over 100 years (Cooper et al. 2007). Baker (2007) examined the same 

issue and projected that Wyoming big sagebrush recovery following fire ranges from 50 – 120 years; for mountain big 

sagebrush, the recovery period was estimated at 35 – 100 years. Prescribed fire can result in a loss of sagebrush dominance 

for 25-45 years, and may also result in increased erosion (Sedgwick 2004). Cooper et al. (2007) projected the full recovery 

of Wyoming big sagebrush canopy cover would take 625 years based on their observed recovery rates following prescribed 

fire (a biologically improbable outcome), and no recovery at all was recorded following prescribed fire on 17 of 24 sites. 

Close proximity to seed sources and moister conditions did not accelerate recovery in this study. These researchers 

concluded, “Wyoming big sagebrush recovery takes so long that managers considering prescriptive burns need to have a 

long-term view of the landscape before eliminating a sagebrush habitat that will not return for at least a century” (Cooper 

et al. 2007:12).

WY Both emc0343GB
C. Comments by Resource Planning Issue

C-1354 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

1. I would like to see documentation and numbers on sage grouse dying from crashing into fences. They may be stupid, but they 

aren't that dumb. I have travelled thousands of miles down fence lines and have never seen a dead grouse by a fence, and 

neither has any of the dozens of permittees I've talked to.

All Both cfc0018RM

2. Hunting sagegrouse doesn’t make a lot of sense anymore. If it is continued- all license $ collected should go towards projects 

providing water for the grouse, which is a limiting factor given short shrify.

All Both cfc0018RM

3. 3% disturbance is a lot, especially considering the past 14 years. 10% would be more realistic. No more than 1 disturbance 

per section is not realistic either due to changing landscapes. There should be mitigation allowances made. Erusting used 

roads and large/medium reservoirs should not be counted.

All Both cfc0025RM

4. West Nile virus, which is linked to standing water associated with some forms of energy development and agricultural water 

use, also poses a threat to greater sage-grouse in the Eastern Region. Naugle et al. (2004) showed that up to 25% of a 

population may die due to West Nile virus. The BLM produced an Information Bulletin (MT-2011-033) regarding best 

management practices to reduce the availability of breeding grounds for mosquitoes that carry West Nile virus. We 

recommend that these best management practices be implemented across BLM lands and particularly in sage-grouse core 

areas to prevent the death of this species. WWF has also produced, along with partners at the University of Wyoming, a 

spatially explicit map showing where West Nile virus is most likely to become prevalent under climate change conditions 

(Schrag et al. 2011). Areas with a high threat of West Nile virus (areas coded in yellow, orange and red in the figure below)

that are located within core areas should be prioritized for reduction of standing water and other factors that increase the 

likelihood of becoming Culex mosquito breeding grounds.

*Included an attachment (Figure 4)

All Both emc0034RM

5. West Nile virus, which is linked to standing water associated with some forms of energy development and agricultural water 

use, also poses a threat to greater sage-grouse in the Eastern Region. Naugle et al. (2004) showed that up to 25% of a 

population may die due to West Nile virus. The BLM produced an Information Bulletin (MT-2011-033) regarding best 

management practices to reduce the availability of breeding grounds for mosquitoes that carry West Nile virus. We 

recommend that these best management practices be implemented across BLM lands and particularly in sage-grouse core 

areas to prevent the death of this species. WWF has also produced, along with partners at the University of Wyoming, a 

spatially explicit map showing where West Nile virus is most likely to become prevalent under climate change conditions 

(Schrag et al. 2011). Areas with a high threat of West Nile virus (areas coded in yellow, orange and red in the figure below) 

that are located within core areas should be prioritized for reduction of standing water and other factors that increase the 

likelihood of becoming Culex mosquito breeding grounds. *Included an attachment (Figure 4)

All Both emc0034RM

6. Public lands are for public use, and that means public lands must be managed for multiple use. I am definitely in favor of 

conservation measures for sage-grouse such as managing for sagebrush, water developments to improve habitat, proper 

planned grazing, etc. However, we must be careful to not manage the public lands for one species or one purpose. For 

example, to eliminate livestock grazing in favor of sage-grouse conservation would not only be a bad biological decision (i.e. 

poor plant health, increased fire risk, etc); it would also go against the basic theory of multiple use.

All Both emc0043RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1355

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

7. As a long time (40+ years) hunter/fisher/experienced outdoor observer in Colorado, the basic answer to the sage grouse 

population is simple: Predators, cycles and water supplies. But mainly Predators.

All Both emc0052RM

8. Water can be a critical factor in determining the abundance and distribution of wildlife, especially in arid western ecosystems; 

although the impacts vary by species, habitat, and season. Over the past 150 years, the availability and distribution of water 

have been drastically altered by both natural processes and human actions. By some estimates, 95 percent of natural riparian 

ecosystems (those associated with water features) and wetlands in the arid West already have been degraded or lost. We 

believe the loss of natural water resources threatens Greater Sage-Grouse population viability, but we realize domestic 

livestock also require water to survive. Federal public-land managers and ranchers have improved existing water supplies 

and developed new water systems for livestock and wildlife. Hundreds-of-thousands of these water developments are 

scattered across the western U.S. Water developments increasingly replace or augment diminishing natural sources in many 

areas and have become crucial for many species, especially Greater SageGrouse when stressed by drought, high 

temperatures or rearing young. These water sources and associated moist-soil (riparian) habitats are critical for Greater 

Sage-Grouse survival and reproduction. Springs, wetlands, seeps, wet meadows, bogs, fens, ephemeral and permanent 

streams, rivers, ponds, stock tanks and lakes all serve as or are surrounded by crucial habitats for Greater Sage-Grouse and 

other wildlife in the arid West. We believe that all water sources and associated moist-soil habitats on federal public lands 

should be protected from the effects of livestock disturbance and grazing. In most cases, livestock drinking water can be 

transported away from water sources and riparian habitats to sites that are not in limited supply and that are more 

compatible with livestock disturbance and grazing.

All Both emc0074GB

9. Recommendation #3 - We recommend that the BLM and USFS require all administrative units to protect all water sources 

and associated moist-soil (riparian) habitats from the effects of domestic livestock disturbances and grazing on federal public 

lands under their prevue.

All Both emc0074GB

10. We are also concerned that this process must not be viewed as establishing a high-water mark and fulfilling all conservation 

duties. There are still serious unaddressed issues with federal management of watersheds and aquatic ecosystems.

All Both emc0078GB

11. As another example of how the numerous land-use prohibitions set forth in Report are overreaching and fail to define a 

reasonable balance of multiple uses, the Report (p. 16) suggests that new water development for diversion from spring or 

seep sources be authorized only when priority sage-grouse habitat would benefit from the development. It is inappropriate 

to suggest that water rights may be exercised on the public lands only where such uses provide a net benefit to sage grouse.

All Both emc0084GB, 

emc0026rm

12. Work through county or watershed area organizations. All Both emc0137GB

13. Developing water sources in the more arid areas to reduce predation is critical. Predators congregate around water 

sources. Having more choices to water keeps predators guessing and reduces predation.

All Both emc0139GB

14. Developed water sources should be recognized for the benefit they provide to the greater sage-grouse (bird ladders are 

required for all public land water troughs). Further, according to NEPA, existing water developments are exempt from NEPA 

review. Thus, maintenance of water developments should not be hindered by greater sage-grouse management activities.

All Both emc0140RM, 

emc0382GB, 

emc0075RM

15. In many instances the BLM has huge expanses of land booming with excellent wildlife habitat. Unfortunately, there is little or 

no water. The BLM should develop watering sources every 2-3 square miles

All Both emc0165GB
C. Comments by Resource Planning Issue

C-1356 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

16. The BLM should focus efforts on developing watering sources for wildlife. All Both emc0165GB

17. According to the Reno Gazette Journal, the Southern Nevada Water Authority yesterday asked for 46,000 thousand more 

acre-feet of water to be transferred to Las Vegas, an 80% increase. The Ruby Pipeline natural gas line through northern 

Nevada purchased scores of water rights and uses water to purge its pipes. Gold mines and copper mines use tremendous 

amounts of water per minute. Individual Environmental Impact Statements do not take into consideration the cumulative 

impacts of all of these projects together, the current drought situation, and their effect on water through the next years. 

Water affects all plant and wildlife species.

All Both emc0170GB

18. Water developments do not rate very high on the "threats to sage grouse" graph but availability of surface water and 

distribution of water sources and moist sites is likely very important to grouse in this area relative to the large expanses of 

xeric habitat

All Both emc0173GB

19. Evidence is mostly anecdotal but my observations suggest that surface water is a huge attractant to sage grouse during 

summer and fall. During this period livestock tank overflows in grouse areas are almost always discovered and used heavily 

by sage grouse as are temporary pools on desert roads. These tank overflows also produce isolated areas of moist soil 

habitats which appear to be heavily used by grouse, especially when not used by livestock.

All Both emc0173GB

20. Water: Ranching in this area offers significant opportunities for water enhancements for sage grouse. Much of the key 

grouse habitat is on BLM and private land and buried pipelines are common. Currently water is pumped to tanks to meet 

livestock needs and not grouse needs. There would be an opportunity to pump water to meet grouse needs especially 

after cattle are moved off BLM and up to higher pastures. In some instances dedicated storage tanks could be installed to 

provide water if pipelines must be shut off for the season. In certain instances longer term water flows could provide moist

soil sites in key brood use areas.

All Both emc0173GB

21. Habitat Loss is much more difficult. Sage grouse populations have existed side by side with commercial grazing for 150 years.

What sage grouse populations have never before had to deal with is large population of uncontrolled horses. It seems more 

than coincidental that wide spread problems with declining grouse populations coincide closely with implementation of 

protection of "wild" horses ranging almost uncontrolled over large swaths of the American west. The horse populations have 

had sever adverse effects on not only sage grouse, but also on deer, elk and rabbit populations where the horses, in addition

to uncontrolled year long overgrazing of critical habitat tend to trample many spring areas, destroying the open spaces 

necessary for water flow and effectively closing the spring, permanently destroying water sources for sage grouse as well as 

other game species.

All Both emc0200GB

22. On February 6, 2012 Judge Windmill indicated that actions such as fencing spring to prevent trampling by cattle were 

unacceptable , since they ”ensure(s) that this potential critical habitat cannot be used by the sage grouse.” The springs, that 

I have seen fenced off, were done with barbed wire and the sage grouse could go under or over the wire to get into the 

enclosure. Some of the very small ones 10 feet by10 feet are done just around the spring were done with woven wire or 

chicken wire still have hole that a sage grouse could get in. The excess water that does not get piped to the tanks and ponds 

comes out under the enclosures fence and produces green grass and mud for the insects to live in. I have never seen where 

a sage grouse has flown into a fence and gotten caught there.

All Both emc0207GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1357

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

23. Water development (springs and guzzlers) and protection of critical riparian areas should be a high priority effort especially 

in Sage Grouse areas.

All Both emc0217GB

24. We all know that where livestock are grazed, the owners help to develop water sources. No specie can live without water. 

By maintaining a healthy and active water source, sage grouse along with other game bird species have a viable habitat.

All Both emc0237GB

25. Limiting ranchers' ability to develop water sources for fear of increasing mosquitos that might carry West Nile is 

counteractive to increasing sage grouse numbers. Lifting restrictions and allowing ranchers to develop water sources, fence 

and protect meadows, and allowing regulated shooting of the raven would help boost sage grouse numbers.

All Both emc0244GB

26. Limiting ranchers' ability to develop water sources for fear of increasing mosquitos that might carry West Nile is 

counteractive to increasing sage grouse numbers. Lifting restrictions and allowing ranchers to develop water sources, fence 

and protect meadows, and allowing regulated shooting of the raven would help boost sage grouse numbers.

All Both emc0244GB

27. Limiting ranchers' ability to develop water sources for fear of increasing mosquitos that might carry West Nile is 

counteractive to increasing sage grouse numbers. Lifting restrictions and allowing ranchers to develop water sources, fence 

and protect meadows, and allowing regulated shooting of the raven would help boost sage grouse numbers.

All Both emc0244GB

28. Water developments are another problem. Upland springs are frequently developed into sources of water for cattle, to try 

to keep them away from streams. But this involves building a water trough that then is surrounded by a barren area, ripe for

invasion by noxious weeds and cheatgrass. At the same time, the spring itself is fenced off to keep cattle out. Sage-grouse 

hens thus have to run a gauntlet of a wide-open area plus a fence on which raptors might perch in order to lead their chicks 

to an area with accessible water, forbs, and insects. If the spring had not been developed and the livestock was not there, 

these problems would not exist.

All Both emc0268GB

29. Water quality and quantity may also be negatively affected by energy development. Water is often depleted from natural 

sources for activities associated with the development, including drilling or suppression of dust pollution. Cumulative effects 

to water quality and quantity may also result from oil and gas drilling activities. For example, by pushing wildlife and livestock 

out of the area, animals become concentrated at remaining water sources, thus leading to unnatural levels of competition 

for limited water resources. This unnatural concentration of species may also increase habitat degradation near remaining 

water sources, as livestock and wildlife trample vegetation and forage on shrubs in the area.

All Both emc0276GB

30. Additionally, sagebrush lands used for grazing often are subject to unnatural habitat modifications, including prescribed fire 

and herbicide use. These alterations are generally used to eradicate sagebrush to create more grass for domestic livestock. 

Additionally, water provided for livestock can become incubators for West Nile virus, the biggest disease threat to 

sagegrouse. Water troughs may also cause direct mortality through drowning when escape ramps are not provided. 

Development of springs and other water sources to support livestock can also artificially concentrate domestic livestock 

and wild ungulates in important sage-grouse habitats, thereby exacerbating grazing impacts in those areas.

All Both emc0276GB

31. West Nile virus seems to be currently the only disease of concern with regard to sage-grouse populations. When an 

outbreak of West Nile virus occurs in greater sage-grouse populations, it becomes a significant mortality factor due to the 

species’ lack of resistance and the ongoing proliferation of water sources through the species’ range. Currently, however, 

studies only reveal a patchy distribution of the disease and minimal impacts to sage-grouse populations. The prevalence of 

West Nile virus is likely to increase across the species’ range. Climate change resulting in higher temperatures may also 

All Both emc0276GB
C. Comments by Resource Planning Issue

C-1358 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

exacerbate the frequency and occurrence of this disease. Notably, coal bed natural gas development may have a cumulative 

effect on sagegrouse as ponds created by the development may increase the risk of West Nile virus mortality in late 

summer.14

32. Successful livestock operations plan at least one year in advance, and the most successful plan for contingencies such as 

drought. Reducing stocking rate during the first year of a drought can be devastating to producers, and is often marginally 

beneficial to the land. However, with advance notice and consultation, operators can generally find alternatives allowing 

them to reduce stocking rate in subsequent years of a multi-year drought, and especially during the first ‘Normal” rainfall 

year following a drought.

All Both emc0281GB

33. The include the development of increased water resources and irrigated meadow. All Both emc0301GB

34. The EIS must specifically address water development on public lands. It is improper and short sighted to authorize and 

manage such activities for a single species or land use. Additionally, the EIS must address the role of the states in approving 

water development on public lands and how state and federal interests and authorities will be coordinated as they relate to 

water.

All Both emc0310GB

35. The trend in water developments is to convey the water away from the spring area so that livestock will not congregate in 

the area of saturated soil, and also to return overflow to the spring drainage. These types of water developments are benefit

to sage-grouse by maintaining the riparian vegetation, and avoiding the trampling effects of livestock on wet spring meadows. 

Therefore, such water developments should be encouraged, not restricted.

All Both emc0322GB

36. Climate change is projected to impact sagebrush habitats, and also to potentially impact sage-grouse survival and 

reproductive success. Despite this fact, climate change is not listed as a preliminary issue in the Notice of Intent for the 

greater sage-grouse planning process. This oversight has to be effectively remedied at the Draft EIS stage, the agency must 

include a comprehensive analysis of the predicted climate change impacts to sage-grouse and any proposed management 

regime must take into account the cumulative effect of climate change and other impacts and provide protections sufficient 

to recover and conserve the sage-grouse despite these threats. Climate change impacts that must be analyzed include, but 

are not limited to: · Increased temperature and increased precipitation allowing expansion of woody vegetation from 

higher elevations. · Increased temperature and decreased precipitation shifting the balance toward more drought-tolerant 

desert plants. · Alteration in fire regime from a warmer climate, which would be problematic for fire intolerant sagebrush. 

· The spread of invasive annual grasses, such as cheatgrass, which have a very different growth form than the native bunch 

grasses and can lead to more severe fire. · Drought conditions, which have been shown to negatively impact nest success. 

· West Nile virus, which may worsen with warmer summertime temperatures that speed the development of the virus 

within the vector mosquitoes.

All Both emc0339GB

37. Livestock water developments, such as ponds and guzzlers, may also benefit wildlife, including Sage Grouse, by providing 

water where none may naturally exist

All Both emc0342GB

38. In its list of Problem Statements, WAFWA (2006) outlined a daunting list of threats to sage grouse persistence: 

-Human-caused impediments to natural water drainage can reduce the input of water, nutrients and sediments, which help to 

sustain and recruit sagebrush.

All Both emc0343GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1359

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

39. At minimum, the NEPA analysis should address the following: • Analyzing the degree of threat of West Nile virus and 

assessing the impact of BLMpermitted activities in increasing that threat.

All Both emc0343GB

40. At minimum, the NEPA analysis should address the following: • Requiring underground injection of produced water to 

prevent the construction of reserve pits that serve as breeding grounds for Culex spp. mosquitoes that are carriers of West 

Nile virus.

All Both emc0343GB

41. Water Availability: The CCC's development of water holes and reservoirs in the late 1930's was followed by continually 

increased construction of water holes and reservoirs throughout the arid desert areas from 1948 to the 1990's. Some of 

these afford water yearlong in areas where very little, if any, existed previously. This increase in availability of water 

throughout the year benefited many species, some greater than others.

All Both emc0388GB

42. West Nile virus. Issue: West Nile virus, a disease that is usually fatal to sage-grouse, is spread by the Culex mosquito that will 

use anthropogenic water sources as habitat.

All Both emc0391GB

43. West Nile virus. Issue: West Nile virus, a disease that is usually fatal to sage-grouse, is spread by the Culex mosquito that 

will use anthropogenic water sources as habitat.

All Both emc0391GB

44. West Nile virus (WNv) is an exotic disease that was discovered in Greater Sage-grouse in 2003 (Naugle et al. 2004). 

Sage-grouse are highly susceptible to WNv infection (Walker et al. 2007). WNv is usually fatal to sage-grouse, resulting in 

death within six days of infection (Dierauf/USGS bulletin 2006). WNv has had a significant negative impact on local 

populations of sage-grouse (Walker et al. 2004; Naugle et al. 2004). The species’ resistance to the disease is expected to 

increase slowly over time (Walker and Naugle 2011). WNv-related sage-grouse mortality rates vary widely and occur in 

areas with and without coalbed methane (CBM) development (Naugle et al. 2004). However, ponds created from CBM 

development were deemed responsible for a 75 percent increase in mosquito breeding habitat in the Powder River Basin 

and appear to facilitate the spread of WNv into otherwise semi-arid sage-grouse habitat (Zou et al. 2006).12 CBM 

wastewater reservoirs were found to “significantly increas[e] the overall population of [WNv] vector mosquitoes in the 

[Powder River Basin]” and “[coalbed natural gas] ponds and associated habitats enhance mosquito abundance and may 

serve to increase pathogen transmission in an otherwise arid ecosystem” (Doherty 2007: ix). WNv has been discovered 

in all 11 states and two Canadian provinces where sage-grouse still occur (Kilpatrick et al. 2007), and sage-grouse 

mortalities from the disease have been documented in 10 states and one province (Walker and Naugle 2011). Naugle et al. 

(2004: 711) stated that the “emergence of WNv further complicates the difficult task of conserving sagegrouse in western 

North America.” Sage-grouse populations are becoming increasingly fragmented and the threat of WNv to small, isolated 

populations of sage-grouse is cause for concern (Naugle et al. 2004). Warming temperatures that result from climate 

change are expected to facilitate the spread of the Culex mosquito that carry WNv (Gould and Higgs 2009). Scientists 

recommend reducing the spread of WNv by avoiding development new anthropogenic water sources, and eliminating 

current sources, that support vector mosquitoes (Naugle et al. 2004; Walker et al. 2007; Walker and Naugle 2011).

All Both emc0391GB

45. The BLM list of proposed Agency Plan amendments omits several key components of Land Use Plans and management 

activities conducted by federal agencies that must also be considered in this process. These include:Energy or other 

rights-of-way for Wind MET towers and any other energy devices or activities including oil and gas pipelines. Renewable 

energy and oil and gas development are not even listed. Communication towers, and other tall structures or developments 

All Both emc0411GB
C. Comments by Resource Planning Issue

C-1360 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

are omitted. Such intrusions can have a huge Footprint ncluding visual, access roads, etc. Water pipelines and rights-of-way 

are not listed. This includes irrigation diversions that remove water from streams, ditches, and aquifer mining proposals like 

the Southern Nevada Water Authority’s massive proposed pipeline for removal/mining and export of ground water from 

desert aquifers. The SNWA aquifer mining pipeline, for example, has a host of ancillary disturbance facilities associated with 

it. Right now in Idaho and Nevada, immense communications towers are being proposed. In Idaho, a tower over 700 ft. tall 

would be placed in wintering habitat for a very small and declining population of sage-grouse also threatened by wind energy 

development.

46. This contains a list of BMPs on"how to make a pond." However, there is no accounting for how tens of thousands of 

improperly built livestock and other ponds currently exist, inevitable leaks and spills in pipe or other water systems, or the 

role of livestock trampling of riparian or pond margins in creating mosquito habitat. There is also no accounting for water 

troughs - and pipelines extending waters and thus mosquitoes into areas remote from water. There is no analysis of any 

kind of the adverse impacts of building ponds in plugging intermittent or ephemeral drainages - and the extensive livestock 

sacrifice zone that typically results. Prolonging water presence in ponds often prolongs and exacerbates intensive livestock 

degradation of large surrounding areas. Many thousands of ponds have been dug into portions of springs and wetlands in 

sage-grouse range as livestock "improvements." These improvements destroy the functionality of the spring, meadow, seep 

or drainage. They promote desiccation and desertification of the spring/meadow/riparian area, and loss of essential 

sage-grouse brood rearing habitat. There is no analysis of the impacts of livestock watering at ponds trampling and pocking 

shoreline depressions that serve as breeding spots for mosquitoes. Why isn't BLM requiring removal of ponds, and real 

restoration of functioning riparian systems and watersheds? Instead, just as with the greatly flawed Core and Priority 

schemes, BLM focuses on expanding habitat degradation and loss. Where is BLM guidance on How to Remove a Pond and 

Restore Watershed Processes? BLM must prohibit more ponds in sensitive areas altogether, and greatly reduce the 

existing number of energy, livestock, mining and other impoundments. BLM must also address the full Footprint and 

impacts of tens of thousands (if not more) of livestock troughs and associated water spillover areas in promoting West Nile 

virus acres uplands of the sagebrush biome.

All Both emc0411GB

47. How does directional and horizontal drilling affect aquifers and the spring and riparian areas whose surface expression is 

linked to them? How will water tables be impacted? Will waters essential for wildlife or human uses be polluted? How does 

punching pond after pond into areas with shallow water tables or aquifers, as described in the previous Appendix disrupt 

hydrological systems?

All BLM emc0411GB

48. Why is there no discussion about protecting flows of all springs, seeps and streams affected by energy and mining activity? For 

example, cyanide heap leach mining causes aquifer declines and aquifer drawdown of springs/streams. Water sources critical 

for wildlife may be severely altered by mining activity, and watershed by associated surface disturbance. These systems in arid 

western lands are typically already under significant stress from degradation by ubiquitously grazed livestock, and livestock

water developments that remove water from spring sources to promote livestock use, as well as gouge stock ponds in 

springs or drainages. See Sada et al. BLM Technical Bulletin 2003. This alters and disrupt drainage networks, flow patterns, 

and extent of riparian and meadow habitats. There is serious risk of declines in water levels or cessation of flows altogether 

due to combined effects of mining, roading, grazing disturbances - all serving to desertify landscapes. Why are there no 

All Both emc0411GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1361

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

protections for such threats, especially given the breakneck speed of mining development in already fragmented areas of 

Nevada and other western states?

49. need for land in production uses up the water in dry areas. These birds are use to the climate and are an asset All Both fla0095gb

50. I really think that if the BLM and the Forest Service would make a concentrated effort to suppress the big fires in the 

sagebrush and develop and repair water sources, particularly waterholes, that the sage grouse would come back to their 

former numbers better than if they were listed, which probably wouldn't help them at all.

All Both rmc0017GB

51. Water Resources As alternatives are developed, we encourage the inclusion of measures which conserve, enhance and 

restore riparian areas and wetlands. Also, because of the aridity of greater sage-grouse habitat, we recommend that the EISs 

analyze potential impacts to ephemeral water bodies.

All Both rmc0020RM 

rmc0077gb

52. It is advisable to avoid and eliminate man-made water sources that support breeding mosquitoes known to vector the West 

Nile Virus. This infectious disease is known to exist in the sage grouse ranges in Montana.

All Both rmc0024GB

53. It is advisable to avoid and eliminate man-made water sources that support breeding mosquitoes known to vector the West 

Nile Virus. This infectious disease is known to exist in the sage grouse ranges in Montana.

All Both rmc0024GB

54. The DEIS should discuss potential approaches for managing the new occurrence of West Nile virus, and land and water 

management strategies that may minimize disease prevalence and population impacts.

All Both rmc0028GB

55. The DEIS should discuss potential approaches for managing the new occurrence of West Nile virus, and land and water 

management strategies that may minimize disease prevalence and population impacts.

All Both rmc0028GB

56. These tough decisions must start with rejecting the Southern Nevada Water Authority's request to run a pipeline across 

300 miles of BLM lands to mine the groundwater of the Great Basin, thereby facilitating the biological liquidation of a 

significant portion of the Sage Grouse's ecosystem. The BLM, if it were to approve this pipeline, would repudiate whatever 

pretense of intent to conserve the Sage Grouse may be presented in the conservation guidelines it is currently developing, 

and virtually ensure that it must relinquish the Sage Grouse to the Endangered Species Act. Ultimately, the BLM must face the 

cold and plain reality that certain "no" decisions must be issued to those interests and parties wishing to appropriate the 

resources upon which the Sage Grouse r elies, and it is out of time to make this policy correction.

All Both rmc0037rm, 

rmc0070GB

57. After further research on an area identified on the Manti-LaSal National Forest above Fairview, we note that there is a FEIS 

being prepared for possible publishing in the Federal Register this year concerning the building of a dam and reservoir called 

the Narrows Project. The proposed dam and reservoir does have a mitigation plan for the Greater Sage-Grouse that should 

have bearing on the planning processes for the Manti-LaSal Forest LUP. We would strongly encourage a review of this FEIS 

regarding the Greater Sage-Grouse as addressed in anticipation of the completion of this project.

All Both rmc0043GB

58. Additionally, Sanpete County is a predominately agriculture county. Our farmers and ranchers rely on the Forest as well as 

the BLM lands for grazing. It was hard to determine exactly from the maps who will be impacted by conservation measures 

included in the BLM and Sanpitch Mountain Range LUPs specific to our county, but we would hope that a cooperative 

management strategy would be proposed for those farmers and ranchers who use grazing permits in those areas.

All Both rmc0043GB

59. BLM and FS should put in place a "net conservation benefit" requirement for the mitigation of impacts to resources and 

values. BLM should ensure that any loss of resources or values on a development site is compensated with the addition and 

East Both emc0089RM
C. Comments by Resource Planning Issue

C-1362 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

protection of equivalent or better resources and values offsite with appropriate assurances that conservation values will be 

maintained for at least as long as project impacts persist. BLM and FS should also make a determination about the value of 

the habitat to be impacted and adopt direction for mitigation requirements for the specific habitat types impacted. For 

example, for high quality habitat which is relatively scarce or becoming scarce on a national basis or in the ecoregion section 

28, BLM policy should ensure a net gain of in-kind habitat value. Additions of lands and resources should exceed the value 

of any resources lost. Additions could be gained through restoration and research efforts to improve the quality and 

quantity of equivalent resources and values off-site. Mitigation for impacts to water resources could be addressed by 

purchase and retirement of water rights to offset groundwater pumping by the project.

60. The attention on the sage grouse and its allegedly dwindling populations coincided with the spread of West Nile Virus into 

Wyoming. It was first documented in 1999 and well-established by 2002. Invasion Biology Introduced Species Summary 

Project - West Nile ... http://www.columbia.edu/itc/cerc/danoff-burg/invasion_bio/inv_spp.... Most avian deaths are 

unreported because the remains are eaten by scavengers. It is, thus, impossible to determine the number of sage grouse 

affected by West Nile Virus. But given the virtual elimination of all song birds for the initial years when West Nile Virus 

infested urban areas and the number of human infections, it is reasonable to assume that West Nile Virus exacted a similar 

toll on sage grouse. Ex. 1 p. 3.

Western Wyoming also suffered a severe drought during the same time frame which reduced insects necessary to feed the 

brood during the nest rearing phase. The combined impacts of disease and drought depressed bird numbers during the same

time period and it is likely that other estimates, which attribute bird population declines to land uses err by omitting the 

cumulative effects of predation, disease and drought.

East Both emc0155rm

61. The attention on the sage grouse and its allegedly dwindling populations coincided with the spread of West Nile Virus into 

Wyoming. It was first documented in 1999 and well-established by 2002. Invasion Biology Introduced Species Summary 

Project - West Nile ... http://www.columbia.edu/itc/cerc/danoff-burg/invasion_bio/inv_spp.... Most avian deaths are 

unreported because the remains are eaten by scavengers. It is, thus, impossible to determine the number of sage grouse 

affected by West Nile Virus. But given the virtual elimination of all song birds for the initial years when West Nile Virus 

infested urban areas and the number of human infections, it is reasonable to assume that West Nile Virus exacted a similar 

toll on sage grouse. Ex. 1 p. 3. Western Wyoming also suffered a severe drought during the same time frame which 

reduced insects necessary to feed the brood during the nest rearing phase. The combined impacts of disease and drought 

depressed bird numbers during the same time period and it is likely that other estimates, which attribute bird population 

declines to land uses err by omitting the cumulative effects of predation, disease and drought.

East Both emc0155RM

62. Address Impacts of Water Developments: BLM should recognize the problems created by water developments and 

associated West Nile virus transmission, and should avoid new water developments and consider removal of water 

developments in priority habitat.

GB Both emc0355GB

63. New water developments create intense habitat degradation due to the high density of livestock use they attract, and 

should be avoided in key sage-grouse habitat. West Nile virus (WNv) can have deleterious impacts on small and isolated 

populations of Greater Sage-grouse (Walker and Naugle 2011). Water developments should incorporate designs that 

GB Both emc0355GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1363

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

reduce the growth of mosquitoes by reducing shallow stagnant water from accumulating and take steps to reduce 

sedimentation and vegetation growth. The focus should remain on controlling mosquito populations in close proximity to 

sage-grouse leks, and should not be interpreted as an endorsement of broad scale use of adulticides. Ultimately, no level of 

control will eliminate mosquitoes from the landscape, nor is such an outcome ecologically desirable (Clark et al. 2006, 

Doherty 2007, Walker and Naugle 2011). Impacts of WNv should be factored into sagegrouse population models, and 

continued research should be devoted to build a better understanding of how sage-grouse populations are impacted by 

WNv and other diseases. The NTT cites Doherty (2007) in Appendix C and outlines best management practices for 

limiting mosquito presence. Some of these management practices related to ponds include: size of ponds Increasing 

 Creating steep shorelines  Maintaining a muddy shoreline that is unfavorable habitat for mosquito larvae  Avoid 

flooding terrestrial vegetation in flat terrain or low lying areas e 

seepage or overflow 

pipe, and lining the overflow spillway with crushed rock  

ungulates that trample and disturb shorelines (all cited from Appendix C) Summary: BLM should recognize the problems 

created by water developments and associated West Nile virus transmission, and should avoid new water developments 

and consider removal of water developments in priority habitat.

64. (identified as a priority issue in the Dillion Area) Adequate seasonal habitat -Drought and other factors can affect forb and 

insect production, both of which are important food sources for young sage grouse -water availability (especially during 

drought)

IDMT Both rmc0028GB

65. DEQ Twin Falls Regional Office (TFRO) covers an area in South-Central Idaho that includes the counties of Twin Falls, 

Cassia, Minidoka, Lincoln, Jerome, Gooding, Camas, Blaine, and portions of Power, Owyhee, and Elmore. As described in 

BLM's "A Report on National Greater Sage-Grouse Conservation Measures" (December 21,2011), "management actions by 

BLM in concert with other state and federal agencies, and private land owners playa critical role in the future trends of 

sage-grouse populations." To this end, DEQ TFRO can provide technical assistance to BLM relative to water quality issues on 

those water bodies where sage grouse and their associated habitat may have residence.

IDMT Both rmc0031GB

66. The Greater Sage-Grouse conservation efforts commonly include activities that may have an impact to water sources either 

directly or indirectly. DEQ TFRO respectfully requests that the BLM consider this when developing their draft document for 

the National Greater Sage-Grouse Planning Stiategy. Within the region there are multiple Total Maximum Daily Load 

(TMDL) plans developed to protect and enhance surface water within the applicable watershed(s). A link to the TMDL 

documents that the State ofIdaho has developed can be found here: 

http://www.deq.idaho.gov/water-quality/surface-water/tmdls.aspx . DEQ TFRO can provide BLM with technical assistance in 

this area where approved TMDLs may define the water bodies that are presently listed; as well as the support status of 

those water bodies.

IDMT Both rmc0031GB

67. In addition, the Idaho DEQ develops a biennial report for the surface water sources in the state called the "Integrated 

Water Quality Monitoring and Assessment Report" (Integrated Report). DEQ is required by the federal Clean Water Act 

(CWA) to conduct a comprehensive analysis of Idaho's water bodies to determine whether they meet state water quality 

standards and support beneficial uses or if additional pollution controls are needed. A link to this report can be found here: 

IDMT Both rmc0031GB
C. Comments by Resource Planning Issue

C-1364 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

http://www.deq.idaho.gov/water-quality/surface-water/monitoring-assessmentlintegratedreport. Aspx. Idaho's most 

recent approved version is its 2010 Integrated Report. This document will guide DEQ's water quality management 

decisions until a 2012 Integrated Report is completed by DEQ and approved by U. S. Environmental Protection Agency 

(EPA). DEQ TFRO can provide BLM with technical assistance in this area where sage grouse may reside within the 

watershed of concern where best management practices are needed.

68. On the other hand, the oil and gas companies have a documented history of destroying/raping our lands with chemicals that 

are polluting our lands, waters and air. It is beyond the scope of this letter to detail all of the findings of the land abuse these 

companies have hurled on Americans in recent years, however, if you do require details, I'll be delighted to oblige you with 

a list/document.

NVCA Both emc0019GB

69. The Nevada Wilderness Project respectfully requests that you address the impacts to sage-grouse and sage-grouse habitat 

caused by feral horses, including removal of vegetational cover necessary for nesting and brood-‐rearing, changes to 

vegetational composition that results from feral horse use, horse impacts to springs and other important free water sources 

utilized by sage-grouse, possible disturbance caused by feral horses during the nesting period, infrastructure used to mitigate 

horse impacts (e.g., fences) and how it may negatively affect sage-grouse, any connection to West Nile Virus as that disease 

is recognized as affecting both horses and sage-grouse, and the potential for feral horse management actions to negatively 

affect sage-grouse and sage-grouse habitat.

NVCA Both emc0243GB

70. For example, the headwater springs, seeps, streams in northern Nevada and southern Idaho are already under great stress 

from historical and chronic ongoing livestock grazing disturbance. In areas suffering mining disturbance, aquifer drawdown 

processes are causing flow reductions, and springs are drying up altogether. The Core Model uses sage-grouse to essentially 

marginalize all non-sage-grouse habitat lands. Yet mining, energy or other development and/or continued livestock 

degradation of the nonsage- grouse or “lesser importance” lands would disrupt watershed processes, and lead to further 

declines in perennial surface flows – resulting in losses of essential sage-grouse brood rearing habitats. Use of this flawed 

approach is likely to endanger many other species.

NVCA Both emc0411GB

71. Another serious threat to sage-grouse habitat in the Great Basin is posed by the proposed Southern Nevada Water 

Authority's groundwater development and pipeline project. The planned monitoring and mitigation plans are woefully 

inadequate to protect the bird and its habitat from long-term impacts due to this project.

NVCA Both fld0010rm, 

fld0010gb

72. With regards to habitat changes, there were at least 6 small ranches which were later absorbed into Quinn River Ranch 

which had small irrigated meadows which would have historically provided habitat to Sage Grouse. These ranches included 

the Houghland Place, Harness Place, Virgin Creek, Bramlett Station, Mud Creek, and Wilder Ranch. All of these smaller 

irrigated meadows have not been irrigated in many years as they are no longer economically viable. While it's no longer 

practical to irrigate these small fields, it must be a factor in the decline of the sage-grouse population in our immediate area. 

There are many similar operations which have fallen into disuse in the Great Basin with a resultant impact on the 

sage-grouse population. While sage-grouse are rarely sighted on our irrigated fields at the headquarters, they were 

historically present there also. It's critically important that the remaining irrigated meadows in the Great Basin be 

maintained so as to provide wildlife habitat for many species, including sagegrouse.

NVCA Both rmc0065GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1365

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

73. With regards to water development, we have enhanced and increased water development on our range in recent years so 

as to provide more viable year round water supplies for both livestock and wildlife. This has included building new pipelines 

and water troughs, repairing existing ones that had fallen into disuse, as well as refurbishing existing springs and water 

troughs that were in disrepair. I believe all of these improvements will enhance wildlife and sage-grouse habitat over time. 

It should be noted that the new improvements, while beneficial to wildlife, were opposed by an environmental group 

opposed to Public Lands grazing. The continued maintenance of these year round water developments which are so 

important to wildlife will depend upon the economic viability of Quinn River Ranch.

NVCA Both rmc0065GB

74. Address Impacts of Water Developments: BLM should recognize the problems created by water developments and 

associated West Nile virus transmission, and should avoid new water developments and consider removal of water 

developments in priority habitat.

OR Both emc0385GB

75. Policy Statement 7: West Nile Virus: ‘ Artificial water impoundments will be managed to the extent of BLM’s authority for the

prevention and/or spread of West Nile Virus...This may include..(c) building steep shorelines to reduce shallow water and 

emergent aquatic vegetation; (d)maintaining the water level below rooted vegetation; (i) restricting access of ponds to 

livestock and wildlife (Doherty 2007).The BLM mentions several instances where they would regulate reservoir use by 

fencing out, making the banks too steep for livestock use, keep water level low: The reservoirs on federally managed lands are 

for the wildlife as well as livestock use. If the reservoirs are fenced out, banks made too steep or the reservoir is unfit for 

livestock to use; the water will also be unfit for wildlife use. Young elk, pronghorn and deer will not be able to get out of

steeply sloped reservoirs any more than sheep or cattle. You are not allowing yourselves to look at the whole picture. 

Multiple use means wildlife and livestock. The use of larvicide is a good recommendation if used according to the label.

WY BLM emc0050RM

76. The BLM could make it a point to distribute the B.t.i. Briquets within 3 miles of nesting and lek areas on standing large bodies 

of water. These are not poisonous to wildlife (if directions are followed) and should only be distributed on waters not for 

human consumption. An incorrect use of these might cause litigation of mismanagement due to animal illness. The Briquet 

will prevent the mosquito larvae from thriving and help decrease the chance of spreading West Nile.

WY BLM emc0050RM

77. Policy Statement 7: West Nile Virus: ‘ Artificial water impoundments will be managed to the extent of BLM’s authority for the 

prevention and/or spread of West Nile Virus...This may include..(c) building steep shorelines to reduce shallow water and 

emergent aquatic vegetation; (d)maintaining the water level below rooted vegetation; (i) restricting access of ponds to 

livestock and wildlife (Doherty 2007).The BLM mentions several instances where they would regulate reservoir use by 

fencing out, making the banks too steep for livestock use, keep water level low: The reservoirs on federally managed lands are 

for the wildlife as well as livestock use. If the reservoirs are fenced out, banks made too steep or the reservoir is unfit for 

livestock to use; the water will also be unfit for wildlife use. Young elk, pronghorn and deer will not be able to get out of

steeply sloped reservoirs any more than sheep or cattle. You are not allowing yourselves to look at the whole picture. 

Multiple use means wildlife and livestock. The use of larvicide is a good recommendation if used according to the label.

WY BLM emc0050RM

78. Policy Statement 7: West Nile Virus: ‘ Artificial water impoundments will be managed to the extent of BLM’s authority for the 

prevention and/or spread of West Nile Virus...This may include..(c) building steep shorelines to reduce shallow water and 

emergent aquatic vegetation; (d)maintaining the water level below rooted vegetation; (i) restricting access of ponds to 

livestock and wildlife (Doherty 2007).The BLM mentions several instances where they would regulate reservoir use by 

WY BLM emc0050RM
C. Comments by Resource Planning Issue

C-1366 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

fencing out, making the banks too steep for livestock use, keep water level low: The reservoirs on federally managed lands are 

for the wildlife as well as livestock use. If the reservoirs are fenced out, banks made too steep or the reservoir is unfit for 

livestock to use; the water will also be unfit for wildlife use. Young elk, pronghorn and deer will not be able to get out of 

steeply sloped reservoirs any more than sheep or cattle. You are not allowing yourselves to look at the whole picture. 

Multiple use means wildlife and livestock. The use of larvicide is a good recommendation if used according to the label.

79. Fencing out is a bad idea because if an animal is thirsty enough they will crawl over and then either be caught in the fence or 

unable to get back out to graze. Eventually the fence will be down and be a hazard with loose wires to entangle animals. This 

applies for wildlife as well as livestock.

WY Both emc0050RM

80. The BLM could make it a point to distribute the B.t.i. Briquets within 3 miles of nesting and lek areas on standing large bodies 

of water. These are not poisonous to wildlife (if directions are followed) and should only be distributed on waters not for 

human consumption. An incorrect use of these might cause litigation of mismanagement due to animal illness. The Briquet 

will prevent the mosquito larvae from thriving and help decrease the chance of spreading West Nile.

WY BLM emc0050RM

81. In Steptoe Live Stock Co. V. Gulley, 295 P. 772 (1931) the Supreme Court of Nevada held that the establishment of 

livestock trails providing access to water sources was sufficient to constitute a valid appropriation and establishment of 

water rights. There are numerous other precedents set by several courts showing that a livestock owner has a right to use 

the water on federally managed lands. BLM does not have complete authoritarian control over the federally managed land for 

right of water usage. The water is for multiple use not just wildlife.

WY Both emc0050RM

82. Irrigation from reservoirs and dirt work systems that are in place on Federal lands should be allowed to continue. Sage 

grouse still need the grassy areas for food and shelter. The irrigation of the sparse grasslands ecosystems in the landscape will 

slow down the encroachment of the prairie dog and allow forage for more than one species survival in the area.

WY Both emc0050RM

83. Work to address and prevent overuse areas by managing for good livestock distribution’.(pg. 3 attachment 8). Part of good 

distribution of livestock is the availability of water in harder to access areas. Livestock will not walk any farther than necessary 

to reach water. All wells and other water resources such as develop springs and reservoirs placed away from natural riparian 

areas will help protect those riparian areas. Authorize new water development for diversion from spring or seep source only 

when priority sage-grouse habitat would benefit from the development(page 16 National) The more water available in a 

pasture the less use any one watering place will have and the less damage to sage grouse habitat in the area. There needs to 

be several areas of water available to prevent one part of a pasture from being overused.

WY Both emc0050RM

84. Reduce the potential for West Nile Virus by eliminating surface discharge of produced water for oil and gas. BLM should 

implement policies that reduce and eliminate the discharge of produced water on the surface in order to reduce the breeding 

environment for the culex mosquito which is the carrier of West Nile Virus.

WY BLM emc0129RM

85. Reduce the potential for West Nile Virus by eliminating surface discharge of produced water for oil and gas. BLM should 

implement policies that reduce and eliminate the discharge of produced water on the surface in order to reduce the 

breeding environment for the culex mosquito which is the carrier of West Nile Virus.

WY BLM emc0129RM

86. The problems that sage grouse are having in the Powder River Basin have been compounded by the proliferation of CBM 

wastewater impoundments, which serve as habitat for mosquito larvae and increase the incidence of West Nile Virus (WNv). 

Naugle et al. (2004) reported that WNv was a dominant cause of mortality for certain sage grouse populations between 1998 

WY Both emc0343GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1367

Scoping Summary Report

Table C-14.A

Comments Related to Water Resources

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtrCode

and 2002. Taylor et al. (2012) found that as well densities increase to 8 wells per square mile in the Powder River Basin of 

Wyoming, a single West Nile virus outbreak is predicted to reduce active sage grouse leks from 360 to 6.

87. A collateral impact of coalbed methane development is increased threat of West Nile virus, which is deadly to sage grouse 

(Naugle et al. 2004). Coalbed methane (“CBM”) wastewater ponds are known to provide ideal habitat for the Culex spp. 

mosquitoes which carry the WNv and infect sage grouse. Mosquito infection with WNv associated with Powder River Basin 

CBM wastewater ponds was demonstrated by Naugle et al. (2004). While West Nile virus has been a lesser cause of 

mortality for sage grouse over the last two years, this does not guarantee that a major outbreak will not sweep across the 

sage grouse range at some time in the near future, as illustrated by the repeated outbreaks of similarly non-native Yersinia 

pestis in black-tailed prairie dogs. West Nile virus is a significant threat to sage grouse, and has contributed to population 

declines (Naugle et al. 2004, 2005). In laboratory experiments, the demonstrated ability of sage grouse to develop immunity 

to this disease has been shown to be very poor (Clark et al. 2006), and resistance to the disease in wild grouse populations 

is very low (Walker et al. 2007). Coalbed methane development in some parts of the sage grouse range has been associated 

with surface disposal of produced water, which typically entails the construction of infiltration reservoirs or local flooding, or 

both. Coalbed methane wastewater ponds have been shown to increase habitat for the Culex spp. Mosquitoes which carry 

the WNv and infect sage grouse (Doherty 2007). In the Powder River Basin, the interaction of West Nile virus with 

standard-density coalbed methane development has been predicted to result in the “functional extirpation” of the population 

(Taylor et al. 2012, see Attachment 2). Indeed, according to these researchers, “if development continues, future viability of 

the already small sage-grouse populations in northeast Wyoming will be compromised.” To add to the problem, reservoirs 

attract sage grouse predators, and as a result Dzialek et al. (2011) recommended siting reservoirs and other water features 

more than 200m from nesting habitat.

WY Both emc0343GB
C. Comments by Resource Planning Issue

C-1368 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-14.B

Comments Related to Soils

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. Comment: Soil productivity ! Soil productivity needs to be explicitly addressed when considering EIS alternatives, activity plan 

development, and plans of operation. Burying of lines, constructing roads, installing livestock facilities, and many other 

infrastructure activities seek to exploit the deepest, most productive soils which often results in disproportionate degradation 

of habitat. Similarly, livestock management regimes have historically targeted the most productive rangelands for grazing, with 

disproportionately large impacts to habitat. Addressing soil productivity in conjunction with potential changes in livestock

grazing will better inform decision makers about not only what changes might result from altering livestock use. It will also 

identify areas where reductions in grazing could be expected to yield disproportionate positive responses in the rate and 

amount of habitat improvement.

All Both emc0113GB

2. Livestock grazing is considered the single most important influence on sagebrush habitats and fire regimes throughout the 

Intermountain West in the past 140 years (Knick et al. 2005: 68). Grazing is the most widespread use of sagebrush steppe and 

almost all sagebrush habitat is managed for grazing (Connelly et al. 2004; Knick et al. 2003; Knick et al. 2011).6 Livestock 

grazing disturbs the soil, removes native vegetation, and spreads invasive species in sagebrush steppe (Knick et al. 2005). 

Cattle or sheep grazing in sage grouse nesting and brood-rearing habitat can negatively affect habitat quality; nutrition for 

gravid hens; clutch size; nesting success; and/or chick survival (Connelly and Braun 1997; Beck and Mitchell 2000; Barnett and 

Crawford 1994; Coggins 1998; Aldridge and Brigham 2003). Livestock may directly compete with sage grouse for grasses, 

forbs and shrub species; trample vegetation and sage grouse nests; disturb individual birds and cause nest abandonment 

(Vallentine 1990; Pederson et al. 2003; Call and Maser 1985; Holloran and Anderson 2003; Coates 2007).

All Both emc0343GB

3. Recovery of microbiotic crusts must be a goal for rehab/reclamation/restoration from disturbance. All Both emc0411GB

4. We need a source of ecological site maps, derived from NRCS soils data, overlain with data on fires and vegetation and land 

treatments to predict vegetation states across landscapes. These should be maintained at both a fine scale, using SSURGO 

soils data, and a broader scale, Llsing STATSGO soils data Wurk at different scales could u..<:;e the appropriate data.

All BLM fxc0011gb

5. Data shows that successful grazing systems were found to have significantly (p=0.01) less grazing during the ''hot season'' (July 

through early September) (12.5 d) than unsuccessful systems with 33 .4d. Likewise, the duration of all livestock treatments 

was significantly (p=0.001) shorter in successful systems (28.2d) compared to 59.3 d in unsuccessful systems. Given the 

reluctance of cattle to disperse from riparian areas, the duration of grazing treatments becomes a key factor in determining 

the severity of impacts such as trampling and mechanical damage, soil compaction, and utilization. A combination of longer 

duration and more frequent fall grazing deteriorated woody species vigor and regeneration, contributing to diminished 

floodplain function and reduced riparian dependent values.

All Both rmc0024GB

6. Avoid livestock water developments and salt grounds in traditional sage grouse spring, summer, and fall habitats. These 

developments significantly concentrate livestock and increase forage use, trailing, and soil compaction that fragment sagebrush 

habitat. These heavy-use areas may extend up to 0.8 km away from the site providing a niche for noxious weeds and other 

undesirable or unpalatable vegetation to take hold.

All Both rmc0024GB

7. i. Lander, WY RMP Because of the aggressive nature of invasive species, such as cheatgrass, we support flexibility for 

treatment of invasive species. Managers should be permitted to use chemical treatments in extreme conditions, as noted for 

Alternative D, understanding that prevention is the most effective approach. The value of avoiding unnecessary soil 

East Both emc0089RM
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1369

Scoping Summary Report

Table C-14.B

Comments Related to Soils

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

disturbances and implementing aggressive reclamation where needed cannot be emphasized enough. The use of chemical

treatments should be minimally used and only after thorough consideration of other measures and a comprehensive review of 

potential impacts to existing resources (plant, wildlife, water sources, etc from chemical use. For example, the DEIS notes that 

broad-spectrum insecticides should not be used in grouse brood-rearing areas because of the adverse impacts to 

non-targeted insects that are critical to young grouse. (DEIS at 865).

8. The NOI and the Technical Team Report omit entirely the variation of soils and relation of soils to sage brush habitat. By way 

of example, much of southwestern Wyoming has alkaline or sodic soils, which will not support sage brush. This and other 

limitations will apply throughout the Rocky Mountain and western rangelands. No EIS should be written without a Level III 

analysis of the soils.

East Both emc0155rm

9. i. Lander, WY RMP Because of the aggressive nature of invasive species, such as cheatgrass, we support flexibility for 

treatment of invasive species. Managers should be permitted to use chemical treatments in extreme conditions, as noted for 

Alternative D, understanding that prevention is the most effective approach. The value of avoiding unnecessary soil 

disturbances and implementing aggressive reclamation where needed cannot be emphasized enough. The use of chemical

treatments should be minimally used and only after thorough consideration of other measures and a comprehensive review of 

potential impacts to existing resources (plant, wildlife, water sources, etc from chemical use. For example, the DEIS notes that 

broad-spectrum insecticides should not be used in grouse brood-rearing areas because of the adverse impacts to 

non-targeted insects that are critical to young grouse. (DEIS at 865).

WY Both emc0089RM

10. In Wyoming, Wyoming big sagebrush dominates the vast majority of sage grouse habitat throughout the state, both in the 

Wyoming Basins Ecoregion and on the Great Plains. Natural fire return intervals in Wyoming big sagebrush average 100-240

years (Baker 2007). Wyoming big sagebrush recovers slowly after fires, which typically result in 100% sagebrush mortality; 

recovery to pre-fire canopy cover takes over 100 years (Cooper et al. 2007). Baker (2007) examined the same issue and 

projected that Wyoming big sagebrush recovery following fire ranges from 50 – 120 years; for mountain big sagebrush, the 

recovery period was estimated at 35 – 100 years. Prescribed fire can result in a loss of sagebrush dominance for 25-45 years, 

and may also result in increased erosion (Sedgwick 2004). Cooper et al. (2007) projected the full recovery of Wyoming big 

sagebrush canopy cover would take 625 years based on their observed recovery rates following prescribed fire (a biologically 

improbable outcome), and no recovery at all was recorded following prescribed fire on 17 of 24 sites. Close proximity to seed 

sources and moister conditions did not accelerate recovery in this study. These researchers concluded, “Wyoming big 

sagebrush recovery takes so long that managers considering prescriptive burns need to have a long-term view of the landscape 

before eliminating a sagebrush habitat that will not return for at least a century” (Cooper et al. 2007:12).

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1. Decreases in the quality of habitat may have direct impacts on greater sage-grouse populations. WWF encourages the BLM to 

address the potential impacts of climate change on the spread of invasive plants, particularly cheatgrass (Bromus tectorum), 

which may highly alter the quality of habitat by outcompeting native grasses and forbs and causing increased frequency and 

severity of wildfires, which are detrimental to fire-intolerant sagebrush species.

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2. The sage grouse plans must include scenario plans for climate change. The sage-steppe is predicted to be vulnerable to climate 

change and may already be experiencing the effects such as altered fire regimes, invasion by exotic plants, expansion of juniper 

woodlands, reduced surface water availability. The plans should explicitly include policies to help hedge against uncertainty. 

One way to do this is to recognize climate change (and the effects described above) as stressors on the species, and to plan 

for ways to accommodate these new stressors be reducing other stressors such as those caused by habitat fragmentation and 

modification resulting from livestock grazing, OHVs, energy development, and weeds.

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3. Climate change (i.e. increased temperatures) is declared as a given and projected as a significant influence on grouse 

survivability. There are four pages in the Form explicitly discussing how government scientists are studying this phenomenon 

on behalf of sage grouse.

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4. Lastly, the effects of climate change should be addressed in reference to how they may impact future habitat management 

decisions. Contemporary attempts to protect and manage greater sage-grouse habitats may prove futile, if climatic changes 

dramatically alter these environments making them unsuitable for greater sage-grouse.

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5. Plans should address the many uncertainties related to climate change. All Both emc0169GB

6. Although there is little we can do to effect the changing climate, we do need to recognize it. Last year was very wet. The desert 

was full of forage. I saw more sage grouse than I had in a long time. This year has been very mild and dry. I expect to see few 

sage grouse. When determining whether one treatment was successful or not we need to always be mindful of the weather's 

impact-good or bad.

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7. Weather has a definite effect on bird mortality, but that is minor when compared to the predator load All Both emc0208GB

8. Roadless sagebrush habitat will also become increasingly important to facilitate species' adaptation to climate change All Both emc0234GB

9. 4. BLM should coordinate and utilize all of the data available from its Rapid Ecoregional Assessments to address the impacts of 

climate change.

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10. In particular, the REAs will contain important information on the impacts of climate change, which BLM has a duty to analyze 

and will be incredibly important in crafting a recovery strategy for sage-grouse. Secretarial Order (S.O.) 3289 unequivocally 

mandates all agencies within the Department of interior to "analyze potential climate change impacts when undertaking 

longrange planning exercises, setting priorities for scientific research and investigations, developing multi-year management 

plans, and making major decisions regarding potential use of resources under the Department's purview." S.O. 3289, 

incorporating S.O. 3226. The sage-grouse process falls squarely under this guidance and BLM must assess impacts from the 

proposed actions that may directly, indirectly, or cumulatively result in exacerbating climate change within this document

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11. In addition to evaluating the impacts of climate change to sage-grouse habitat, BLM has the authority to manage and plan for 

emerging issues and changing conditions that climate change is having an effect on. Under FLPMA, multiple use management 

requires BLM to look at the longterm future needs and conditions of the public lands and future generations and adjust

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management accordingly. 43 U.S.C. § 1702(c). Additional pertinent requirements of FLPMA that specifically apply to land use 

planning include using "a systematic interdisciplinary approach to achieve integrated consideration of physical, biological, 

economic, and other sciences; consider[ing] relative scarcity of the values involved; and weigh[ing] long-term benefits to the 

public against short-term benefits. /d. FLPMA also provides that BLM must "take any action necessary to prevent unnecessary 

or undue degradation to managed resources." 43 U.S.c. § I 732(b). Collectively, the provisions of FLPMA highlighted above 

necessitate on the- ground implementation of climate change policies.

12. Further, a vigilant science-based monitoring system should be set out in the sage-grouse process in order to address 

unforeseeable shifts to the ecosystem. "Such intervals and standards shall be based on the sensitivity of the resource to the 

decisions involved and shall provide for evaluation to determine whether mitigation measures are satisfactory, whether there 

has been significant change in the related plans of other Federal agencies, State or local governments, or Indian tribes, or 

whether there is new data of significance to the plan." 43 C.F.R. § 1610.4-9. Such vigilant monitoring is absolutely necessary in 

order to create an effective adaptive management framework in the face of climate change.

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13. Recommendations: BLM should use information derived from the Rapid Ecoregional Assessments, when completed, to infonn 

management options for the protection and recovery of the greater sage-grouse. This includes using the REAs to analyze and 

address the impacts of climate change on sage-grouse habitat and crafting solutions to allow habitat to adapt to and minimize 

adverse effects of climate change. Science-based monitoring should be incorporated into the sage-grouse EIS process in order 

to make adjustments to respond to climate change and other stressors.

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14. BLM should make recommendations for the expansion of the National Landscape Conservation System to conserve, protect 

and enhance sagebrush ecosystems in the face of climate change.

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15. b. The National Conservation Lands provide BLM with a laboratory to manage public lands at the landscape-level in the face 

of climate change. BLM is in a unique position among public land agencies to lead a coordinated response to global climate 

change across the West. A shift to landscape-level planning and management could begin by utilizing the National Landscape 

Conservation System (National Conservation Lands) as a laboratory. As an innovative and evolving system of landscape 

conservation, the National Conservation Lands should drive the integration of science and management and help connect

western lands and waters in a manner that helps these systems adapt to stressors that will be exacerbated by climate change

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16. The BLM Conservation Lands are to be managed at a "landscape-level." These lands are surrounded by a sea of state, private, 

and other federal lands that must be integrated with the diverse classifications ofBLM lands when considering management 

actions. When viewed at the landscape level and incorporating and coordinating across other public land jurisdictions, climate

change adaptation can involve a coordinated effort of connected landscapes across the West. There is no other agency with 

this type of massive landscape-level climate laboratory at its disposal to help address climate change. This laboratory will prove 

to be incredibly valuable for sustaining sage grouse populations on BLM lands in the face of climate change.

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17. Recommendations: BLM should actively research the impacts of climate change and other stressors on sage grouse habitat as 

part of the strategy to recover populations. BLM's plan should include specific direction for the role that the National 

Conservation Lands and science can play in addressing and mitigating the impacts of climate change.

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18. The criterion to ensure compliance with air quality laws and to include consideration of climate change seems to be beyond 

the scope of the sage grouse plan amendments.

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19. Air Quality and Climate Change should not be a planning issue during this process. The RMP amendments should focus only 

on the analysis of sage grouse habitat protection and refrain from revising other elements of existing RMPs.

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20. 7) Climate has never been static. The decades have cycled warmer and cooler for the entirety of earth’s questionable

existence. We are now coming out of a small ice age and according to new data entering back into another. Managing for 

climate’s varied and unknown patterns would be like managing volcanoes. Please do not waste time and monies on a political 

tool called global warming or climate change.

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21. Climate change (i.e. increased temperatures) is declared as a given and projected as a significant influence on grouse 

survivability. There are four pages in the Form explicitly discussing how government scientists are studying this phenomenon 

on behalf of sage grouse.

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22. There are also several cumulative effects that must be considered. For example, livestock grazing in combination with drought 

and climate change can have a severe impact on sagebrush communities. Fire risk to sagebrush habitats may also increase, as 

livestock consume native vegetation and spread noxious weeds and invasive plants. And when grazing is combined with other 

disturbances, sagebrush habitats may experience greater shrub loss and increase the chances of the introduction and spread 

of cheatgrass compared to landscapes having a single source of disturbance.

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23. Climate change is a growing concern that is currently being recognized by land management agencies across the country as an 

impact that must be considered in making land management and project decisions. The Intergovernmental Panel on Climate 

Change has concluded that warming of the climate is unequivocal, and that continued greenhouse gas emissions at or above

current rates will cause further warming. Climate change predictions may affect greater sage-grouse populations as the 

impacts of climate change interact with other stressors to exacerbate negative effects on sage-grouse populations.

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24. As the climate warms, associated climate impacts such as shifts in timing and amount of precipitation and changes in seasonal 

high, low, and average temperatures may significantly alter distributions of individual species and ecosystems. For example, 

some species that can only survive in cooler weather may be pushed further north or higher in altitude to seek cooler

climates. This shift may affect all plant and animal species, as the equilibrium of predator and prey species shifts and the natural 

balance of ecosystems is altered.

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25. Climate change will not only affect the distribution of wildlife but also affects vegetation and plant life. Although most plants 

respond positive to increased carbon dioxide levels, many invasive nonnative plants respond with greater growth rates than 

native plants, including cheatgrass. Similarly, field studies reveal that cheatgrass demonstrates significantly higher plant density, 

biomass, and dispersed seeds at elevated carbon dioxide levels. Depending on the future precipitation regime, studies 

anticipate that cheatgrass is likely to move northwards, leading to expansion into Idaho, Montana, and Wyoming. This 

prediction, in conjunction with analyses suggesting large displacement and reduction of sagebrush habits as a result of climate 

change as early as 2030, increases the likelihood that climate change will negatively and potentially severely impact sage-grouse 

and sagebrush habitat. Additionally, cheatgrass invasion may also lead to an increase in the likelihood and severity of fires, 

causing further damage to an already weakened habitat.

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26. Climate change may also exacerbate stressors such as disease. For example, temperature and precipitation both directly 

influence the potential spread and infection of West Nile virus, the most serious disease affecting sage-grouse. Increased 

temperatures associated with climate change could directly increase the prevalence of West Nile virus, threatening the 

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likelihood of an increase in the presence of the disease across sage-grouse populations.

27. Climate change may also exacerbate stressors such as disease. For example, temperature and precipitation both directly 

influence the potential spread and infection of West Nile virus, the most serious disease affecting sage-grouse. Increased 

temperatures associated with climate change could directly increase the prevalence of West Nile virus, threatening the 

likelihood of an increase in the presence of the disease across sage-grouse populations.

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28. Resting pastures during a year with average or above average growing-season precipitation provides a better opportunity for 

plants to recover health (since they are actively growing) than rest during drought (as the plants are dormant). Please consider 

prescribing rest from drought in this manner, as to minimize economic hardship and maximize plant recovery.

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29. Cattle, mule deer, pronghorn, pygmy rabbits, sagebrush passerines, cut-throat trout and cattle can all thrive. This type of 

rotational grazing strategy (providing rest for recovery) meets all four rangeland health guidelines, and provides a ‘drought 

reserve’ in that if needed pastures planned to be rested season-long may be grazed late in the year (during dormancy) if 

drought occurs.

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30. Page 7-"If periods of drought occur, where appropriate evaluate the season of use and stocking rate and adjust through 

coordination and annual billings processes." The BLM allotments and associated private lands in sagebrush country provide 

habitat for diverse wildlife species as well as providing the economic base for these rural counties. Successful livestock 

operations plan at least one year in advance, and the most successful plan for contingencies such as drought. Reducing stocking 

rate during the first year of a drought can be devastating to producers, and is often marginally beneficial to the land. However, 

with advance notice and consultation, operators can generally find alternatives allowing them to reduce stocking rate in 

subsequent years of a multi-year drought, and especially during the first 'Normal" rainfall year following a drought. Resting 

pastures during a year with average or above average growing-season precipitation provides a better opportunity for plants to 

recover health (since they are actively growing) than rest during drought (as the plants are dormant). Please consider 

prescribing rest from drought in this manner, as to minimize economic hardship and maximize plant recovery.

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31. Cattle, mule deer, pronghorn, pygmy rabbits, sagebrush passerines, cutthroat trout and cattle can all thrive. This type of 

rotational grazing strategy (providing rest for recovery) meets all four rangeland health guidelines, and provides a 'drought 

reserve' in that if needed pastures planned to be rested season-long may be grazed late in the year (during dormancy) if 

drought occurs.

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32. Evaluate the synergistic effects of climate on invasive annual grasses and altered fire regime. All Both emc0305GB

33. Factor in climate change in all land-use decisions in sage grouse habitat. All Both emc0305GB

34. Determine the interactive effects of climate change and sagebrush production of toxins. All Both emc0305GB

35. The BLM must account for the significant impacts of climate change at regional scales, and work to develop connections and 

corridors to ensure long-term habitat connectivity for sage-grouse.

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36. The EIS must specifically identify the types of impacts from climate change on sage grouse habitat, and provide quantifiable 

scientific data and analysis to support those conclusions.

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37. Climate change is projected to impact sagebrush habitats, and also to potentially impact sage-grouse survival and reproductive All Both emc0339GB
C. Comments by Resource Planning Issue

C-1374 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-15

Comments Related to Drought Management and Climate Change

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success. Despite this fact, climate change is not listed as a preliminary issue in the Notice of Intent for the greater sage-grouse 

planning process. This oversight has to be effectively remedied at the Draft EIS stage, the agency must include a comprehensive 

analysis of the predicted climate change impacts to sage-grouse and any proposed management regime must take into account 

the cumulative effect of climate change and other impacts and provide protections sufficient to recover and conserve the 

sage-grouse despite these threats. Climate change impacts that must be analyzed include, but are not limited to: · Increased 

temperature and increased precipitation allowing expansion of woody vegetation from higher elevations. · Increased 

temperature and decreased precipitation shifting the balance toward more drought-tolerant desert plants. · Alteration in fire 

regime from a warmer climate, which would be problematic for fire intolerant sagebrush. · The spread of invasive annual 

grasses, such as cheatgrass, which have a very different growth form than the native bunch grasses and can lead to more severe 

fire. · Drought conditions, which have been shown to negatively impact nest success. · West Nile virus, which may worsen 

with warmer summertime temperatures that speed the development of the virus within the vector mosquitoes.

38. Neilson et al. (2005) compared nine climate models, and found that the probability of sage grouse habitat persistence was 

greatest in south-central and southeast Wyoming. Schrag et al. (2011) preformed a similar, more recent analysis and came to 

a similar conclusion. These researchers point to southwestern Wyoming as a hotspot for Wyoming big sagebrush persistence, 

and in light of the increased risk of major West Nile virus outbreaks in projections based on climate models, they recommend 

focusing extra conservation attention on this region, calling sage grouse habitats in southwestern Wyoming “important core 

refugia.”

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39. Neilson et al. (2005) compared nine climate models, and found that the probability of sage grouse habitat persistence was 

greatest in south-central and southeast Wyoming. Schrag et al. (2011) preformed a similar, more recent analysis and came to 

a similar conclusion. These researchers point to southwestern Wyoming as a hotspot for Wyoming big sagebrush persistence, 

and in light of the increased risk of major West Nile virus outbreaks in projections based on climate models, they recommend 

focusing extra conservation attention on this region, calling sage grouse habitats in southwestern Wyoming “important core 

refugia.”

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40. At minimum, the NEPA analysis should address the following: • Evaluating the impact of climate change on the likely future 

distribution of sage grouse habitats, and setting forth a framework for maintaining sage grouse populations in the event of 

spatial shuifts in habitat availability and/or quality.

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41. At minimum, the NEPA analysis should address the following: • Assessing the impact of air pollution on the health and fitness 

of sage grouse, and requiring green completions to reduce smog creation.

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42. The NOI mentions climate change as a major factor. So little is known about how climate change will affect rangeland habitat 

that this will be an exercise in speculation. CLG suggests that the EIS process focus on site specific issues instead.

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43. We have reviewed the Preliminary Planning Criteria for the National Greater Sage-Grouse Strategy, dated January 2012 and 

offer the following comments: The criterion to include consideration of climate change seems to be beyond the scope of the 

sage-grouse plan amendments.

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44. We have reviewed the Preliminary Planning Criteria for the National Greater Sage-Grouse Strategy, dated January 2012 and 

offer the following comments: Air Quality and Climate Change should not be a planning issue during this process. The RMP 

amendments should focus only on the analysis of sage-grouse habitat protection and refrain from revising other elements of 

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existing RMPs.

45. We have reviewed the Preliminary Planning Issues dated January 2012 and offer the following comments: Air Quality and 

Climate Change should not be a planning issue during this process. The RMP amendments should focus only on the analysis of 

sage-grouse habitat protection and refrain from revising other elements of existing RMPs.

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46. In semi-arid rangeland regions vast extremes in precipitation often occur, especially during the major growing season for 

forbs, which is late March to early July. This variation can be as high as 300% between seasons, years, and groups of years. The 

resulting variation in production of plant species, especially annual and perennial forbs, can cause extreme variability of 

Greater Sage Grouse (GSG) reproduction levels.

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47. The BLM and USFS should also analyze the effects of climate change on sagebrush steppe, a recognized threat to sage-grouse 

(Connelly et al. 2011: 556, Table 24.2) that is predicted to have deleterious impacts on sagebrush steppe (Neilson et al. 2005; 

see Map 6). Climate change effects should be assessed individually and cumulatively with other land uses, such as livestock 

grazing. For example, Catlin et al. (2011) evaluated BLM grazing management in sagebrush steppe, illustrating the importance 

of achieving ecosystem potential to buffer against the effects of climate change and documenting problems with BLM 

monitoring and management that prevent improvement in conditions. The Secretary of Interior has directed each bureau and 

office to “consider and analyze potential climate change impacts when undertaking long-range planning exercises...[and] 

developing multi-year management plans, and making major decisions regarding the potential use of resources under the 

Department’s purview” (Secretary of the Interior Order no. 3289, Amendment no. 1). The proposed comprehensive, 

multi-year planning effort for sage-grouse should analyze potential climate change impacts in accordance with the Secretary’s 

order.

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48. Up to 80 percent of remaining sagebrush steppe could be lost to the direct or indirect effects of global warming (Wisdom et

al. 2005c: 206, citing Neilson et al. 2005). Average temperature has already increased 0.6 - 1.1° F in the last 100 years in the 

Great Basin (Chambers 2008a). Raupach et al. (2007) discovered that the growth rate in anthropogenic CO2 emissions 

increased more rapidly between 2000 and 2004 than even predicted by the highest growth rate (i.e., “worst case”) scenario 

developed by a leading intergovernmental organization in the late 1990s. Drought may also contribute to increased 

atmospheric CO2 by reducing the amount of CO2 that is annually taken up by terrestrial vegetation (Peters et al. 2007). 

Increased CO2 may, in turn, favor invasive, annual grasses, including cheatgrass (Smith et al. 2000). Climate change could be a 

significant threat to Greater Sage-grouse (van Kooten et al. 2007). Moynahan et al. (2007) reported that drought effects 

sage-grouse nesting probability. Holloran et al. (2005) noticed that annual sage-grouse nest success rates were positively 

correlated with the precipitation in the previous year. Increased temperatures are expected to dry out sagebrush steppe and 

may intensify the effects of other threats to sage-grouse, such as livestock grazing, invasive species and fire frequency (Alridge 

et al. 2008). Increased temperature may extend the fire season in the western United States and increase total area burned in 

some regions (McKenzie et al. 2003; Baker 2011). The World Wildlife Fund modeled predicted effects of climate change on 

Wyoming big sagebrush and silver sagebrush in Wyoming, Montana, North Dakota, and South Dakota (Schrag and Forrest 

2008, unpublished data). Results suggested a decrease in distribution of Wyoming big sagebrush by approximately 76-81 

percent and a decrease in silver sagebrush of 71-80 percent by 2030 (Schrag and Forrest 2008, unpublished data). The authors 

contended that increased temperatures will also lead to the increased spread of WNv and these factors, combined with 

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C. Comments by Resource Planning Issue

C-1376 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-15

Comments Related to Drought Management and Climate Change

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habitat loss and degradation from continued land uses, may threaten sage-grouse with extinction (Schrag and Forrest 2008, 

unpublished data).

49. Climate change. Issue: Degraded habitat has less resilience and this loss of resilience amplifies the negative impacts of climate 

change on sage-grouse and sagebrush steppe.

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50. For instance, the CCSM Project, which is estimated to produce enough clean electricity to power approximately 1 million 

households, will result in a reduction in C02 emissions of7 million to 11 million tons a year, equivalent to the emissions of over 

1 million automobiles. C02 has been identified as a major contributor to greenhouse gases, which are believed to contribute 

to global climate change. Global climate change threatens the survival of all species, not just greater sagegrouse

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51. We recommend that the goal of the landscape-scale assessment should be to contribute to the persistence, distribution and

diversity of the ecoregional biota and all its natural components and processes today and in the future, while accommodating 

other land uses, activities or project its and importantly, adapting to climate change.

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52. Landscape-level biological linkage areas required for the continued functioning of biological and ecological processes and 

allowing for long-term shifts in distribution of native species in response to climate change;

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53. Biodiversity of native species is a significant issue that must be considered. A new and important paper in science 

demonstrates that "preservation of plant biodiversity is crucial to buffer negative effects of climate change and desertification 

in drylands." BLM must fully analyze the adverse impacts on biodiversity of imposing sacrifice areas on large areas of what 

remains of the West’s sagebrush habitats. Sage-grouse, and certainly not many actions claiming to “improve” conditions for 

sage-grouse, are not an adequate umbrella for protection of many species. Further, sagebrush lands, and interfacing biome 

areas with the Mojave region, are proposed to be sacrificed for large-scale remotely-sited industrial solar developments. 

These lands may be crucial for migrating sagebrush biome birds, and preservation of biodiversity.

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54. It’s hard to understand how sacrificing large and significant sagebrush areas by imposing a Core Model, plus then allowing even 

more development to occur within Core Areas, could be considered biologically tenable conservation planning. This also 

assumes at least in part a fairly constant unchanging environment in the chosen core areas. But natural disturbances are 

unpredictable, and habitat conditions, especially with climate change, may occur quickly. Disease outbreaks are unpredictable. 

Aroga sagebrush defoliating moth outbreaks are unpredictable. Weeds emanate outward from disturbed areas (caused by 

grazing degradation, roading, other disturbances). Weeds then adapt to local conditions, and then explode across landscapes. 

Climate change is likely to amplify the adverse impacts of weed invasions and likely increase the slow recovery time for lower 

elevation sagebrush communities where many leks are located. So the habitat quality/suitability of lower elevation nesting 

habitats - if continued weed expansions and chronic grazing and other disturbances and climate change and desertification 

processes continue are very likely to continue to decline. Vegetation communities pass the point of no return with 

cheatgrass/medusahead, or other exotic annual grass invasion. We know no successful known large scale restoration of 

cheatgrass/medusahead. Many changes that are occurring across the sagebrush biome are long-term or irreversible.

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55. The value of each grid cell is a function of the number and proximity of leks in the surrounding landscape. We attributed each 

cell with counts of males at leks within a radius of 6.4 km (4.0 mi). We chose this distance because nesting females distribute 

their nests spatially in relation to lek location with 79% of nests located within a 6.4 km (4.0 mi) radius from lek-of capture 

(Table B-1 in Colorado Division of Wildlife 2008). In some other areas, distances are much greater, and birds move over vast 

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Table C-15

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areas. Where is the modeling that shows what happens to a population if, in Colorado DOW instance cited here, 21% of the 

nesting habitat and all the wintering habitat outside this circle is developed? It ignores the different movement and landscape 

use characteristics of populations. It ignores that leks are typically located on snow-free areas, which are relatively lower 

elevation. Relatively lower elevation areas are most susceptible to cheatgrass and other weed invasions, and more difficult to 

recover. Just protecting nesting habitats closest to currently more abundant leks may be a large mistake as grazing-facilitated 

cheatgrass and climate change act synergistically to promote cheatgrass dominance of understories at lower elevations. It 

ignores analysis of climate change effects where snow-free areas may increasingly extend to higher elevations. Thus a shift in 

lek sites over time may occur and is very likely – but if the higher elevations are near the periphery or outside the little core 

lek circles altogether, the Doherty Core and BLM PPH modeling will have already sacrificed away these very habitats that are 

needed for sage-grouse population resiliency in the face of climate change.

56. One major threat to the sagebrush steppe ecosystem that was neglected in your Notice of Intent is climate change. The 

Environmental Impact Statements should analyze and develop alternatives that will benefit the integrity of the sagebrush 

ecosystem and associated species of conservation concern, as well as develop strategies to address climate impacts

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57. Also, please include the impacts of global climate change in the EIS. And - as is appropriate in every EIS - please include the 

"contributions" of livestock grazing and emissions to climate change. While the facts may upset the livestock industry, the 

scientific analyses for which you are responsible must no longer bow to political pressure.

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58. The BLM must account for the significant impacts of climate change at regional scales, to ensure long-term habitat connectivity 

for sage-grouse.

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59. Climate Change Ongoing climate change research as summarized by the United Nations Intergovernmental Panel on 

Climate Change (IPCC) concludes that climate is already changing and that the change will accelerate. Some degree of future 

climate change will occur regardless of future greenhouse gas emissions. Adapting to or coping with climate change will 

become necessary in certain regions and for certain ecological systems. We recommend that the EISs describe how 

proposed conservation measures would account for climate change considerations. We recognize the challenge that climate 

change adaptation presents and suggest the following resources to assist in your climate change analysis and adaptation efforts. 

Resources for doing this include: • The Council on Environmental Quality's Draft "NEPA Guidance on Consideration of the 

Effects of Climate Change and Greenhouse Gas Emissions "5 • The 2011 background paper, "National Fish, Wildlife and Plants 

Climate Adaptation Strategy Shrub land Ecosystems"6 • The University of Washington Climate Change Sensitivity Database's 

summaries of the inherent climate change sensitivities of cheatgrass and greater sage-grouse The Wildlife Habitat 

Connectivity Working Group's August 20 II report, "Washington Connected Landscapes Project: Climate-Gradient Corridor 

Report"

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60. The EIS should evaluate and analyze whether the decline of sage grouse is related to climate change and provide scientific data 

and analysis to support any conclusions made. The natural cycle in wildlife populations is well known. The EIS should analyze 

the natural cycle of wildlife populations and how it relates to sage grouse.

All Both rmc0035GB

61. Climate Change: This item must be removed from the discussion of any management policy change. The earth’s climate has 

been changing since the dawn of time.

CO Both emc0133GB
C. Comments by Resource Planning Issue

C-1378 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-15

Comments Related to Drought Management and Climate Change

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtr 

Code

62. Recent modeling studies have shown the possible expansion of cheatgrass in the Eastern Region under various climate-change 

scenarios (Bradley 2009).

East Both emc0034RM

63. The NOI mentions climate change as a major factor. So little is known about how climate change will affect rangeland habitat 

that this will be an exercise in speculation. VRLP suggests that the EIS process focus on site specific issues instead.

East Both emc0155rm

64. Nielson et al. (2005) have cited sagebrush-steppe as one of the ecotypes most vulnerable to the impacts of climate change. 

Under bioclimatic model scenarios, sagebrush is simulated to shift northward with a significant contraction of its current range 

by 2099. Sagebrush is limited by summer moisture stress. Likewise, increases in the frequency of fires under future climate 

scenarios would facilitate simulated potential range contraction because of sagebrush’s long recovery periods following fire.

Other potential outcomes of increasing carbon dioxide levels and a warming climate include: accelerated invasion by exotic 

plants, conifer encroachment, loss of surface waters, and spread of West Nile virus. The Secretary of Interior has directed 

each bureau and office to "consider and analyze potential climate change impacts when undertaking long-range planning 

exercises...[and] developing multi-year management plans, and making major decisions regarding the potential use of 

resources under the Department’s purview" (Secretary of the Interior Order no. 3289, Amendment no. 1). The proposed 

comprehensive, multi-year planning effort should analyze potential climate change impacts to sage-grouse and sagebrush 

habitat, both individually and cumulatively with other impacts, in accordance with the Secretary’s order. Land use plans 

should address not only current habitat, but also the best future refugia for sagebrush-steppe habitats and sage-grouse 

population in relation to key climate-driven factors. Nielson projects that, based on the area of agreement between nine 

climate change models, south-central and southwestern Wyoming may be the most likely places in the nation to retain the 

sagebrush habitat in the face of changing climate (Nielson, 2005).

East Both emc0167RM

65. Account for Climate Change: Land use plans should identify not only current habitat, but also the best future refugia for 

sagebrush-steppe habitats and sage-grouse populations in relation to key climate-driven factors like exotic plant and woodland

expansion, increased fire frequency, desertification, and West Nile virus occurrence.

GB Both emc0355GB

66. Sagebrush-steppe is one of the most diverse and important rangeland types and habitats for the native flora and fauna of the 

American West, and it has also been identified as one of the ecotypes most vulnerable to the effects of climate change 

(Neilson, et al. 2005). Altered fire regimes, accelerated invasion by exotic plants, woodland expansion, loss of surface waters, 

and spread of disease have all been cited as potential outcomes of increasing carbon dioxide levels and a warming climate 

(Chambers, 200815; Neilson, et al. 2005). Sensitive species such as sage-grouse are vulnerable to regional extirpation as the 

effects of climate change degrade sagebrush-steppe across the West (Chambers, 2008), and as warming temperatures allow 

diseases like West Nile virus to spread into habitats formerly inhospitable to the Culex mosquito(Gould and Higgs, 2008)16. 

Land use plans should address these likelihoods by identifying not only current habitat, but also the best future refugia for

sagebrush-steppe habitats and sage-grouse populations in relation to key climate-driven factors like exotic plant and woodland 

expansion, increased fire frequency, desertification, and West Nile virus occurrence. Potential changes in climate can disrupt 

sage-grouse habitat (Miller et al. 2011) and BLM must consider climate when proposing land use actions including post‐fire 

seedings. According to the NTT (page 28), BLM should consider native plants and consider seed collections from the warmer 

areas within a species’ current range for selection of native seed (Kramer and Havens 2009). Summary: Land use plans 

should identify not only current habitat, but also the best future refugia for sagebrush-steppe habitats and sage-grouse 

GB Both emc0355GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1379

Scoping Summary Report

Table C-15

Comments Related to Drought Management and Climate Change

Comment 

No.

Comment SubRegion 

ID

Agency CmtLtr 

Code

populations in relation to key climate driven factors like exotic plant and woodland expansion, increased fire frequency,

desertification, and West Nile virus occurrence.

67. Severe Winters: The 1964/65 winter of north central Montana greatly reduced all wildlife numbers in that area. IDMT Both emc0388GB

68. During drought periods, prioritize evaluating effects of the drought in priority sage‐grouse habitat areas relative to their needs 

for food and cover. Since there is a lag in vegetation recovery following drought (Thurow and Taylor 1999, Cagney et al. 2010), 

ensure that post‐drought management allows for vegetation recovery that meets sage‐grouse needs in priority sage‐grouse 

habitat areas. This statement does not specify between conservation measures to be taken in different habitats of greater 

sage-grouse. Elevation and site specific conservation measures need to be clarified when addressing drought periods for 

greater sage-grouse habitat.

NVCA Both emc0328GB

69. Account for Climate Change: Land use plans should identify not only current habitat, but also the best future refugia for 

sagebrush-steppe habitats and sage-grouse populations in relation to key climate-driven factors like exotic plant and woodland 

expansion, increased fire frequency, desertification, and West Nile virus occurrence.

OR Both emc0385GB

70. The 1992/93 winter in Eastern Oregon resulted in a large setback of many wildlife species in that given area. OR Both emc0388GB

71. The past dry years have allowed sagebrush to squeeze into the tiny wet meadows where the hens take their young chicks to 

forage. These small wet meadows need some help to get the sage out. Another recent impact that is happening to these wet 

meadows is on Blue Mt. there has been an explosion of elk numbers and their uncontrolled grazing is having an impact on 

these wet areas.

UT Both emc0296GB

72. Limiting factors such as climate may have the most influence on sage-grouse populations, but we no control over weather. WY USFS emc0144RM

73. Climate is an important factor affecting sage grouse populations (South-Central Local Working Group 2007:15). Climate 

change scenarios in the sagebrush ecosystem predict that the largest area of sagebrush that will persist in the future is in 

southern and southwest Wyoming, between the northern and central Rocky Mountains (Neilson et al. 2005) According to 

Rowland et al. (2006:vi), this is the very area of greatest ecological diversity and high risk for future habitat degradation in the 

Wyoming Basins Ecoregion: “Species richness of sagebrush-associated vertebrates of concern was greatest in southwestern 

Wyoming, where as many as 36 of the 40 vertebrate species of concern cooccur. Moreover, some of the areas identified as 

most affected by anthropogenic disturbance, as estimated by our human footprint model, are also those that have the greatest 

species richness. Human activities occurring in southwestern Wyoming are expected to have disproportionately and 

substantially greater effects on a larger number of species of concern compared to other portions of the WBEA area.”

WY Both emc0343GB
C. Comments by Resource Planning Issue

C-1380 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

1. The plan must address the impact of wild horse on sage-grouse habitat and direct that wild horse AML's be met annually - Also 

should address lowering AML's in some HMA's and consider removing horses entirely from some HMA's.

All Both cfc0070GB

2. I believe that the top priority in protecting the sage grouse in the West is to bring the horse herds to levels that do not 

interfere with game birds, other indigenous game and cattle grazing areas

All Both emc0005GB

3. Second, the ferrel horse dose nothing but destroy sage grouse habitat, they ruin water sources eat then stomp out the roots. All Both emc0031GB

4. Where wild horses have depleted sage-grouse habitat, they should be removed or reduced to a stocking rate compatible with 

good sage-grouse habitat

All Both emc0085GB

5. I would also like to see plans made to manage wild horses on areas where sage grouse occur. We cannot continue to pretend 

that these two species live on different planets and do not intersect.

All Both emc0088RM

6. I would also like to see plans made to manage wild horses on areas where sage grouse occur. We cannot continue to pretend 

that these two species live on different planets and do not intersect.

All Both emc0088RM

7. Wild Horse and Burro Management The IM does not provide the justification for established Appropriate Management Levels 

(AML) nor does it require agencies to evaluate the negative impacts of wild horse and burro populations to the Greater 

Sage-Grouse or its habitat when developing or maintaining AML. As recommended by the National Technical Team report, 

wild horse and burro impacts to the Greater Sage-Grouse and its habitat should be analyzed and, where these impacts are 

found to be negative, the wild horse and burro AML should be reduced to a level where negative impacts no longer occur, and 

rangeland improvements should be implemented to address the direct and indirect effects to Greater Sage-Grouse 

populations and habitat.

All Both emc0108GB

8. The County supports active removal of wild horses and burros in an effort to achieve AML. The BLM should also re-evaluate 

AML within priority and general habitat to ensure that it is in-line with encouraging desired habitat conditions.

All Both emc0130GB

9. Further clarity should be brought to the agencies’ policy regarding greater sage-grouse conservation efforts and wild horse 

and burro management, as well. IM 2012-043 provides that BLM is directed to manage wild horses and burros within 

Appropriate Management Levels (AML) and that excess horses and burros are to be removed. Department of the Interior 

policy on wild horse and burro management, in fact, is moving in the opposite direction. Current and proposed policy is to 

manage for a certain number of animals in holding pens and leave excess numbers on the rangelands. Management levels are 

the numbers in pens, not the number on the rangelands. This apparent internal inconsistency needs to be resolved or clarified 

before any greater sagegrouse management options can be defined.

All Both emc0140RM

10. On a positive note, we commend the report’s recognition that wild horses and burros have an impact “by reducing grass, 

shrub, and forb cover and increasing unpalatable forbs and exotic plants including cheatgrass.” We agree that “wild equids 

have different grazing patterns than domestic livestock, thus increasing the magnitude of grazing across the entire landscape.” 

As noted below, we encourage proper management of wild horses and burros as a means to improve greater sage-grouse 

habitat and range health, generally.

All Both emc0140RM

11. I would like to see the impacts of feral horses and burros considered in the evaluation of sage grouse habitat destruction. 

These non-native species have no place in our high desert ecosystem, and because they have no natural predators, their

populations have exceeded the carrying capacity of the habitat, and they are outcompeting native wildlife species for forage 

All Both emc0163GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1381

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

and precious water. Their large hooves also are destroying the fragile high desert flora and damaging riparian areas

12. Wild Horse Management: Wild horse management on public lands has been unacceptable and we urge the BLM to control 

Horse Management Areas (HMAs) at Appropriate Management Levels (AMLs). Due to wild horses, a lack of responsible 

pasture management and irresponsible riparian and meadow management is present. We insist the BLM control wild horses 

at AMLs on all HMAs and especially those interfacing sage-grouse habitat.

All Both emc0180GB

13. Habitat Loss is much more difficult. Sage grouse populations have existed side by side with commercial grazing for 150 years. 

What sage grouse populations have never before had to deal with is large population of uncontrolled horses. It seems more 

than coincidental that wide spread problems with declining grouse populations coincide closely with implementation of 

protection of "wild" horses ranging almost uncontrolled over large swaths of the American west. The horse populations have 

had sever adverse effects on not only sage grouse, but also on deer, elk and rabbit populations where the horses, in addition 

to uncontrolled year long overgrazing of critical habitat tend to trample many spring areas, destroying the open spaces 

necessary for water flow and effectively closing the spring, permanently destroying water sources for sage grouse as well as 

other game species.

All Both emc0200GB

14. Part and parcel of that local assessment is to keep the feral horse populations in check to minimize the well-documented 

destruction of water holes that all wildlife requires for their existence.

All Both emc0213GB

15. Feral horse populations are not being adequately controlled and are negatively impacting sage grouse habitat. Horses have a 

grazing style unlike native species that has not been properly taken into account with their ever‐increasing populations.

All Both emc0216GB

16. On page 18, Wild Horse and Burro Management, this is the one program for which BLM is the agency in charge and the party 

responsible for the management of this resource. There is no mention that the BLM will manage these animals at Appropriate 

Management Levels (AMLs), but only that the BLM will develop and amend herd management plans to incorporate 

sage-grouse habitat objections; BLM will prioritize the evaluation of all AMLs; BLM will coordinate with other resources to 

conduct rangeland health assessments; and BLM will address the direct and indirect effects of wild horse and burros on 

sage-grouse populatins and habitats in the NEPA process for range improvements for wild horses and burros. Again the 

double standard that exists when BLM is responsible as compared to when private entities have responsibility is clear and 

needs to be evaluated in the EIS. Managing wild horses to AML in Nevada would be more beneficial than all of the developing 

and amending, incorporating, prioritizing, coordinating, and addressing that BLM indicates it would do with respect to wild 

horses and burros.

All Both emc0239GB

17. On page 19, Minerals section, second paragraph, there is mention of abandonment of leks by male sage-grouse if leks are 

repeatedly disturbed by raptors perching on power lines near leks. The mitigation measure or conservation measure should 

include anti-perching devices on these structures and not prevent mining or energy development. Similarly, predator control 

of ravens, crows, and magpies (corvids) is possible in identified nesting areas where power lines provide perches for corvids 

to watch for sage-grouse hens to leave the nest.

All Both emc0239GB

18. The Nevada Wilderness Project respectfully requests that you address the impacts to sage-­grouse and sage-­‐grouse habitat 

caused by feral horses, including removal of vegetational cover necessary for nesting and brood-­‐rearing, changes to 

vegetational composition that results from feral horse use, horse impacts to springs and other important free water sources 

All Both emc0243GB
C. Comments by Resource Planning Issue

C-1382 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

utilized by sage-grouse, possible disturbance caused by feral horses during the nesting period, infrastructure used to mitigate 

horse impacts (e.g., fences) and how it may negatively affect sage-grouse, any connection to West Nile Virus as that disease is 

recognized as affecting both horses and sage-grouse, and the potential for feral horse management actions to negatively affect 

sage-grouse and sage-grouse habitat.

19. COMMENTS ON Interim conservation Measures and Policies for Preliminary Priority Habitat, No. 2012 ‐As the 043 (IM

interim policy and program guidance in the IM: These comments are consistent with and applicable to the strategic 

suggestions above for the proposed action. Wild Horse and Burro Management The IM does not provide the justification for 

established Appropriate Management Levels (AML) nor does it require agencies to evaluate the negative impacts of wild horse 

and burro populations to the Greater Sage ‐when developing or maintaining AML. As recommended by Grouse or its habitat

the National Technical Team report, wild horse and burro impacts to the Greater Sage ‐habitat should be Grouse and its

analyzed and, where these impacts are found to be negative, the wild horse and burro AML should be reduced to a level where 

negative impacts no longer occur, and rangeland improvements should be implemented to address the direct and indirect 

effects to Greater Sage ‐Grouse populations and habitat.

All Both emc0254GB

20. Please do not insist on additional provisions in land use plans to further limit grazing management options. Standards and 

guidelines for livestock grazing and protocols for evaluating rangeland health are well established. Wild horse and burro use

must be recognized in land use plans. Their grazing use must not exceed standards and guidelines and appropriate 

management levels must be adhered to.

All Both emc0307GB

21. With regard to wild horses and burros, the EI5 should note and quantify the presence of wild horses and burros in all sage 

grouse habitat areas, and quantify the impacts of horses and burros on habitat and bird populations

All Both emc0310GB

22. The wild horse and burro population in the State of Nevada is estimated by the ELM to be 19,057 (17,710 horses and 1,347 

burros I). The ELM has determined that the Appropriate Management Level (AML) for Nevada is 12,688 animals. It is 

concerning that, despite the fact that the population of wild horses and burros is at one hundred fifty-one percent (151 %) of

AML, the management of wild horse and burros nor the excess population is not listed as a primary issue of concern in the 

NO!. This is interesting given the concern expressed regarding damage to sage-grouse habitat caused by livestock grazing.

All Both emc0318GB

23. On page 18, Wild Horse and Burro Management, this is the one program for which BLM is the agency in charge and the party 

responsible for the management of this resource. There is no mention that the BLM will manage these animals at Appropriate 

Management Levels (AMLs), but only that the BLM will develop and amend herd management plans to incorporate 

sage-grouse habitat objectives; BLM will prioritize the evaluation of all AMLs; BLM will coordinate with other resources to 

conduct rangeland health assessments; and BLM will address the direct and indirect effects of wild horse and burros on 

sage-grouse populations and habitats in the NEPA process for range improvements for wild horses and burros. Again the 

double standard that exists when BLM is responsible as compared to when private entities have responsibility is clear and 

needs to be evaluated in the EIS. Managing wild horses to AML in Nevada would be more beneficial than all of the developing 

and amending, incorporating, prioritizing, coordinating, and addressing that BLM indicates it would do with respect to wild 

horses and burros.

All BLM emc0322GB

24. Given that wild horses and burros also graze BLM managed lands, often in populations far greater than those allowed under 

the Wild Horse and Burros Act, the BLM's SEIS must consider management options for those populations as well.

All Both emc0342GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1383

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

25. BLM needs to resolve internal policy initiative conflicts within the Department of the Interior (DOI), as they apply to 

renewable energy development and wild horse management. These land uses are DOI priorities even though they have the 

same or greater adverse impacts to sage grouse habitat as do other land uses that BLM now proposes to end or restrict;

All BLM emc0371GB

26. B. Wild Horse Management and Sanctuaries All of the discussion of wild horses in the Technical Team Report omits the 

important facts regarding wild horse use of sage grouse habitat. Wild horses graze the rangelands year-long. Wild horses not 

only use the riparian areas heavily but they aggressively defend the water sources against wildlife. Their numbers increase by 

18% to 23% a year. They trail in such a way that they leave permanent routes with the attendant impacts on soils, vegetation 

and water quality due to increased erosion from runoff. BLM, with the approval of the Interior Secretary, continues to 

promote wild horse sanctuaries on public lands. The sanctuaries are a central element in the national strategy adopted in 

2011. The creation of sanctuaries, such as the one proposed in Nevada, will destroy sage grouse habitat since they are not 

subject to gathers or other management limits. As is documented in the Sheldon Wildlife Refuge, where grazing ended 17 

years ago, ungathered wild horse populations damage wildlife habitat and vegetation. A wild horse sanctuary in lieu of managed 

cattle will have far greater impacts on rangeland resource vegetation, soils, and by extension sage brush habitat. The failure of 

the IM to address these policy conflicts is manifest. The EIS must do so. The BLM national wild horse strategy also reduced the 

number of wild horse gathers for the next several years. The cut in wild horse gathers comes at a time when few, if any, wild 

horse herd management areas are within their appropriate management levels (AMLs). BLM’s failure to manage for AML since 

1971 when Congress adopted the Wild Horse Act is well-documented as are the adverse impacts of too many wild horses on

rangeland resources. The cumulative impact of the failure to consistently manage to AML must be calculated over the 40 years 

that the Wild Horse Act has been in effect. Thus, this BLM policy continues the documented damage to rangeland resources 

and any management of habitat for sage grouse must disclose and resolve the contradictory policies being pursued.

All BLM emc0371GB

27. the list of preliminary issues, identified in the Federal Register Notice of Intent to Prepare Environmental Impact Statement, 

it is noteworthy that "Wild Horse and Burro Management" is not included as a preliminary issue. Perhaps because the BLM 

fails to meet its own obligations for appropriate management levels, this is not being considered as a matter for action. Almost 

as an afterthought in the Director's, December 22, 2011 Memorandum, "Wild Horse and Burro Management" is covered very 

briefly, stating that Ongoing Authorizations/Activities will: • Manage wild horses and burro population levels within established 

Appropriate Management Levels (AML) • Wild Horse Herd Management Areas will receive priority for removal of excess 

horses • Wild horses and burros remaining in Herd Management Areas where the AML has been established as zero will 

receive priority for removal • When developing overall workload priorities for the upcoming year, prioritize horse gathers 

except where removals are necessary in non-PPH to prevent catastrophic herd health and ecological impacts. Given the actual 

performance record of BLM in Nevada and the exceedingly over-abundance and out-ofcontrol numbers, how will the actual 

correction be brought about? Beyond excuses for not having enough resources, what confidence can there be that BLM will 

not continue to practice the management process of "do as we say, not as we do"? BLM should not “target” the uses of public 

land that are easy-picking without first addressing the mismanagement of the uses that are under the primary jurisdiction of 

the BLM itself. The Herd Management Areas in Eureka County are currently an average of 250% of AML while statewide the 

population numbers are 150% of AML.

All Both emc0383GB

28. Wild Horses: Large numbers of wild horses existed in the GSG habitat in the 1800's and early 1900's. Wild horse populations All Both emc0388GB
C. Comments by Resource Planning Issue

C-1384 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

were the lowest when GSG populations were high from 1930 to 1970. After the Wild Horse Act was passed in 1971, horse 

numbers increased rapidly (i.e. in the Beaty Butte area of south central Oregon, horse numbers went from 250 in 1971 to over 

1,100 in 1977, and during that same period GSG numbers decreased drastically. Also, during that period 1972-1977 growing 

season precipitation was lower than the worst five years in the 1930's). A high level of competition for forage and water at 

springs and seeps was a resulting factor.

29. I believe that this plan should have some predator management and horse management, the BLM has historically fallen short 

of maintaining the horses AML's in this state, horses have a greater impact on the habitat through their repeated use of areas 

unlike livestock were they are only in a area for short periods and are controlled.

All Both emc0389GB

30. We have been unable to ascertain whether or not feral horse and burro populations are considered "invasive species." While 

litigation continues to hamper appropriate removal of excess horses and burros for sage grouse habitat, the detrimental 

impact of overpopulation must certainly be addressed. Funds expended to keep excess horses and burros in containment

facilities would be far better invested in improving sage grouse habitat

All Both emc0396GB

31. In addition to our previous comments, submitted 7 February 2012, we would like to bring attention to the apparent conflict 

between conservation of native greater sage-grouse ri"\ (Centrocercus urophasianus) and BLM's management of feral horses 

and burros

All Both emc0398GB

32. Feral horses are an exotic species in North America. Exotic, or non-native, species are among the most widespread and 

serious threats to the integrity of native wildlife populations because of their potential to invade and degrade native 

ecosystems. Exotic plant and animal species present special challenges for wildlife managers because their impacts on the 

native biota are poorly understood by the general public, and many people regard them as a component of the natural

ecosystem. As a result, some exotic species have advocacy groups that promote their continued presence in landscapes 

where they are not native, and few policies and laws deal directly with their control. Feral horses (Equus caballus) that roam 

freely across western North America are examples of such species: they are iconic and much-loved by some, but damage 

wildlife habitat and require constant management through population reduction activities.

All Both emc0398GB

33. Herds of feral horses cause significant damage to the environment. Currently, estimates suggest that these herds, along with 

burros (E. asinus), range across more than 45 million acres in 10 states in the American west and 2 Canadian provinces

All Both emc0398GB

34. Large herbivores (both native and non-native) can disturb landscapes by trampling soils and vegetation, selectively grazing and 

over utilizing palatable plants, and altering the distribution of nutrients in the ecosystem

All Both emc0398GB

35. When horses are added to an ecosystem, little native habitat, from grassy plains to steeper rockier areas, is left undisturbed. 

Studies in the Great Basin have shown that areas inhabited by feral horses tend to have fewer plant species and less plant cover

than areas without horses, as well as more invasive plant species such as cheatgrass, which itself is widely known as poor 

wildlife habitat

All Both emc0398GB

36. Given the effects that feral horses can have on greater sage-grouse habitat, we are concerned about how BLM will integrate 

management of sage-grouse with management of feral horses. We encourage BLM to examine use by feral horses in 

sage-grouse habitat and take appropriate actions to ensure that feral horses do not further contribute to the decline in 

sage-grouse numbers.

All BLM emc0398GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1385

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

37. Any analysis of feral horse management actions in priority sage-grouse habitat should include a thorough review of the 

possible direct and indirect effects on sage-grouse.

All Both emc0398GB

38. Any herd Management Areas (HMAs) within or containing priority habitat should be kept below established Appropriate 

Management Levels (AML)

All Both emc0398GB

39. While we understand that BLM has certain obligations, set by legislation, regarding the management of feral horses, such 

obligations should not take precedence over management and conservation of a native species, such as greater sage-grouse.

All Both emc0398GB

40. NTT at 18, and IM at 7 regarding Wild Horses: BLM must evaluate AMLs for horses at the same time as it addresses livestock 

grazing permits. These must be based on balancing needs of horses for food, cover and space including natural band structure, 

and analyzing adverse impacts of livestock grazing disturbance on all aspects of the thriving natural ecological balance. This 

must be done fairly.

All Both emc0411GB

41. We have been unable to ascertain whether or not feral horse and burro populations are considered "invasive species." While 

litigation continues to hamper appropriate removal of excess horses and burros for sage grouse habitat- the detrimental 

impact of overpopulation must certainly be addressed. Funds expended to keep excess horses and burros in containment

facilities would be far better invested in improving. Bage grouse habitat

All Both fxc0006GB

42. The EIS should identify if the presence of wild horses is one factor contributing to the decline of sage grouse populations. The 

fact that wild horses are not a native species should be addressed in the EIS. Wild Horses are utilizing (and competing for) the 

same habitat as sage grouse.

All Both rmc0035GB

43. The Board finds the section on "Wild Horse and Burro Management" to be inadequate. For as much detail as was included in 

the "Range Management" section, there is very little in this section. Proper Range Management includes ALL large herbivores 

whether they are domestic stock, wildlife or wild horses and burros. The domestic stock is already highly regulated and the

management of wild horses and burros should be held to the same standards! To hold wild horses and burros to a lesser or 

different standard is completely unacceptable.

All Both rmc0050GB

44. In the list of preliminary issues, identified in the Federal Register Notice of Intent to Prepare Environmental Impact Statement, 

it is noteworthy that "Wild Horse and Burro Management" is not included as a preliminary issue. Perhaps because the BLM 

fails to meet its own obligations for appropriate management levels, this is not being considered as a matter for action. Almost 

as an afterthought in the Instruction Memorandum No. 2012-043, "Wild Horse and Burro Management" is covered very 

briefly, stating that Ongoing Authorizations/Activities will: • Manage wild horses and burro population levels within established 

Appropriate Management Levels (AML) • Wild Horse Herd Management Areas will receive priority for removal of excess 

horses • Wild horses and burros remaining in Herd Management Areas where the AML has been established as zero will 

receive priority for removal • When developing overall workload priorities for the upcoming year, prioritize horse gathers

except where removals are necessary in non-PPH to prevent catastrophic herd health and ecological impacts. Beyond the 

details associated with managing horses at their appropriate management levels, there also needs to be consideration given to

the impact of wild horses and burros on designated Sage-Grouse habitat. In those cases where, on-the-ground substantiation 

points to wild horses and burros being issues in the condition of Sage-Grouse habitat, actions should be instituted immediately 

to deal with the damage. In the short term, reductions should be made and for the long term, appropriate management levels 

should be adjusted to take into account the inability for these critical resources to sustain the impacts caused by wild horses 

All Both rmc0058GB
C. Comments by Resource Planning Issue

C-1386 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

and burros. Given the actual performance record of BLM in Nevada and the exceedingly over-abundance and out-ofcontrol 

numbers, how will the actual correction be brought about? Beyond excuses for not having enough resources, what confidence 

can there be that BLM will not continue to practice the management process of "do as we say - not as we do "?

45. Special attention needs to be given in the Sage-grouse priority areas overlapping Herd Management Areas for feral horses that 

are protected by law.

CO Both emc0178RM

46. All of the discussion of wild horses in the Technical Team Report omits the important facts regarding wild horse use of sage 

grouse habitat. They graze the rangelands year-long. Wild horses not only use the riparian areas heavily but they aggressively

defend the water sources against wildlife. Their numbers increase by 18% to 23% a year. They trail in such a way that they 

leave permanent routes with the attendant impacts on soils and vegetation and water quality due to increased erosion from 

runoff. BLM, with the approval of the Interior Secretary, continues to promote wild horse sanctuaries on public lands. The 

sanctuaries are a central element in the national strategy adopted in 2011. The creation of sanctuaries, such as the one 

proposed in Nevada, will destroy sage grouse habitat since they are not subject to gathers or other management limits. As is 

documented in the Sheldon Wildlife Refuge, where grazing ended 17 years ago, ungathered wild horse populations damage 

wildlife habitat and vegetation. A wild horse sanctuary in lieu of managed cattle will have far greater impacts on rangeland 

resource vegetation, soils, and by extension sage brush habitat. The failure of the IM to address these policy conflicts is 

manifest. The EIS must do so. The BLM national wild horse strategy also reduced the number of wild horse gathers for the 

next several years. The cut in wild horse gathers comes at a time when few if any wild horse herd management areas are 

within their appropriate management levels (AMLs). BLM's failure to manage for AML since 1971 when Congress adopted the 

Wild Horse Act is well-documented as are the adverse impacts of too many wild horses on rangeland resources. The 

cumulative impact of the failure to consistently manage to AML must be calculated over the 40 years that the Wild Horse Act 

has been in effect. Thus, this BLM policy continues the documented damage to rangeland resources and any management of 

habitat for sage grouse must disclose and resolve the contradictory policies being pursued.

East Both emc0155rm

47. We have been unable to ascertain whether or not feral horse and burro populations are considered "invasive species." While 

litigation continues to hamper appropriate removal of excess horses and burros for sage grouse habitat, the detrimental 

impact of overpopulation must certainly be addressed. Funds expended to keep excess horses and burros in containment 

facilities would be far better invested in improving sage grouse habitat.

GB Both rmc0056GB

48. It is bewildering that the BLM's technical specialists consider domestic livestock a potential threat for trampling nests but not 

wild horses. In this respect, all four-legged, hooved animals, should be treated somewhat equal until documented otherwise.

GB Both rmc0076gb

49. wild horse and burro management: Where wild horses and burros exist in Nevada and eastern California, they can impact 

Sage Grouse and its habitat by excessive numbers and resulting degradation of sagebrush habitats. To our knowledge, the 

agencies do not currently consider these adverse impacts to Sage Grouse and its habitats in setting numbers or in designating 

or managing use areas or in selecting gather sites. The EIS should incorporate conservation measures for Sage Grouse in the 

agencies' wild horse and burro program. A. the agencies must consider Sage Grouse habitat requirements in setting 

Allowable Management Levels (AMLs) and Herd Management Areas (HMAs). B. the agencies should prioritize land health 

assessments in each HMA with priority Sage Grouse habitat and develop quantifiable vegetation objectives to meet habitat 

requirements. C. the agencies should amend AMLs and HMA management plans to meet specific Sage Grouse population 

NVCA Both emc0283GB
C. Comments by Resource Planning Issue

May 2012 Greater Sage-Grouse LUPAs/EISs C-1387

Scoping Summary Report

Table C-16

Comments Related to Wild Horses and Burros

Comment 

No.

Comment SubRegion

ID

Agency CmtLtrCode

objectives and to meet specific habitat requirements in priority habitats. D. the agencies should prevent grazing by wild horses 

and burros of burned areas until vegetation recovery objectives have been met

50. In the NTT document, livestock grazing is considered to be a diffuse disturbance (pressure is exerted over broad spatial or 

temporal scales). Livestock grazing, as well as wild horse and burro activity can greatly affect nest success on any 

ground-nesting bird as well as decimate any viable vegetation in the grazing area. Wild horse numbers have increased 

exponentially in the Rochester area and no gatherings have occurred to decrease population size. Since wild horses have 

different grazing patterns then cattle the magnitude of grazing increases across the entire landscape in the Rochester area. 

Damage to vegetation communities (i.e. reduction of grass, shrub, and forb cover and increases in unpalatable forbs and exotic 

plants as well as complete decimation of any vegetation community) is highly visible in the Limerick and Rochester canyon 

areas. If any mitigation efforts were made in or adjacent to Rochester mine's project area wild horses and cattle would have 

to be fenced out for any type of habitat restoration or sage grouse re-introduction to have a chance.

NVCA Both emc0302GB

51. The Association would like to also address the management of wild horses and burros most especially in areas of critical 

habitat. The impacts from over populations of wild horses to rangelands and lack of compliance of Appropriate Management 

Levels (AML) by the BLM have had impacts on greater sagegrouse habitat. Further clarification should be brought to the 

agencies’ policies regarding greater sagegrouse conservation efforts and wild horse and burro management. IM 2012-043 

states that BLM is directed to manage wild horses and burros within appropriate management Levels (AML) and that excess 

horses and burros are to be removed. Currently, this is not the management strategy employed and the Association feels that 

this inconsistency needs to be resolved or it needs to be clarified before any greater sage-grouse conservations measures can 

be defined.

NVCA Both emc0328GB

52. Prioritize gathers in priority sage‐grouse habitat, unless removals are necessary in other areas to prevent catastrophic 

environmental issues, including herd health impacts. Will this measure be evaluated for an entire Herd Management Area 

(HMA) or will it address specific habitat requirements for greater sage-grouse? The Association believes that additional 

clarification of this statement is needed to address habitat requirements for greater sage-grouse.

NVCA Both emc0328GB

53. Since the tum of the century the area has been grazed by cattle and wild horses and burros. The wild horse and burro 

population got out of control in the 80's and 90's but by that time most of the sage hen were gone.

NVCA Both rmc0044GB
C. Comments by Resource Planning Issue

C-1388 Greater Sage-Grouse LUPAs/EISs May 2012

Scoping Summary Report

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