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Comments on Robb-Ledford Grazing Environmental Assessment GWA President
Glenn Hockett prepared the following voluminous scientific analysis
of the affects of livestock grazing on the WMA. |
| Objectives | |
Montana Fish, Wildlife & Parks Subject: Attachment A to GWA Comments – In Depth Scientific Analysis of the Draft EA for the Robb-Ledford Wildlife Management Area Grazing Lease. Dear FWP: The Gallatin Wildlife Association (GWA) is a non-profit volunteer wildlife conservation organization representing hunters and anglers in Southwest Montana and elsewhere. Our mission is simply to protect habitat and conserve fish and wildlife. GWA supports sustainable management of fish and wildlife populations through fair chase public hunting and fishing opportunities that will ensure these traditions are passed on for future generations to enjoy. Please consider supplementing the EA with this in depth scientific analysis regarding livestock impacts on the Robb-Ledford WMA. Background: The 28,097-acre Robb-Ledford WMA is an important elk and big game winter range, which lies on the east side of the Snow Crest Mountain Range in southwest Montana. This land was purchased in 1987 by the Rocky Mountain Elk Foundation for $1.82 million supported by a $500,000 donation from Anheuser-Busch Companies, Inc. And then, as we understand it, RMEF transferred the property to the FWP in 1988 for $1.99 million of Sportsmen’s dollars (Habitat Montana - HB 526). However, the actual purchase price was not revealed in the EA, an important omission. This was the first major habitat purchase of the RMEF and the first major acquisition of the FWP with Habitat Montana funds. The Robb-Ledford WMA provides important habitat for a variety of native fish, wildlife and plants, including elk and other big game species and sensitive species such as westslope cutthroat trout and sage grouse. This was a significant habitat purchase and was celebrated by sportsmen in Montana as well as nation-wide. As part of the purchase agreement with RMEF, livestock use was to be continued for 3 years until November 1 1990, at which time a comprehensive wildlife management plan was to be developed. However, a wildlife management plan has still not been written for the WMA. Instead, political pressures forced the Montana Fish, Wildlife & Parks (FWP) to maintain domestic livestock use from 1991 until present, a period of 18 years. FWP management of the Robb-Ledford WMA focused on annual livestock use plans from 1991 through 1998 and then FWP committed to a 10 year rest-rotation livestock use plan in 1999. FWP intended on allowing 500 cow/calf pairs to use the WMA starting in 1999 but political pressure from the grazing permittees upped the number to 1100 pairs, which is 2200 cattle total (cows and calves). In an attempt to address the impacts of past and proposed livestock use, FWP agreed to divert water from Kelly Springs into a costly 40 mile long buried pipeline and livestock water development that feeds 42 stock tanks along wind blown ridges that are prime elk, mule deer and antelope winter range. This was supposed to mitigate the impacts of livestock use to sensitive riparian areas, which are critical habitat for native fish, wildlife and plants however, the unacceptable livestock impacts persist. However, only a few of these impacts have been revealed in the EA. The Robb-Ledford WMA has never been rested from livestock since its purchase, and it has a history of livestock use prior to the FWP acquiring the property. FWP has also forgone opportunities to restore native big game species to the WMA such as bighorn sheep and bison during this livestock use period and we believe other big game species including elk, mule deer, antelope and moose have bee adversely impacted by the ongoing presence of domestic livestock. Rare or sensitive species such as sage grouse and native westslope cutthroat trout and keystone species such as beaver have also been impacted from the livestock management regimes imposed on the WMA. We contend a full accounting of the economic and environmental impacts of past and proposed livestock use has not been displayed in the EA The 1999 livestock grazing plan committed over $617,000 sportsmen’s/wildlife dollars to livestock mitigation projects such as fences, water diversion, pipelines, water tanks, cattle guards, etc. Most of these livestock use projects were completed by 2008 according to the draft EA and some $486,936.32 has been spent to date. These livestock management activities and facilities, fragment fish and wildlife habitats, disturb important wetlands and uplands, concentrate livestock use into areas seldom used otherwise and/or divert/alter important water sources critical for native fish, wildlife and plants. We are unable to ascertain the exact impact of all these projects because they are not adequately mapped/displayed in the EA. Prior to the first 10 year commitment by the FWP back in 1999 to utilize livestock as a “tool” to enhance fish and wildlife habitat on the WMA, we asked that the fragile stream banks of Rock Creek, a 100% genetically pure westslope cutthroat trout stream, and important brood rearing habitat for sage grouse be protected from livestock concentrations. However, public land livestock politics won out and fish and wildlife habitat and sportsmen lost out as a result. We previously submitted a photo to FWP of the impacts of livestock use to the Upper Rock creek spawning habitat taken on Sept. 9, 2009. Antelope, mule deer, moose, elk, black bears, wolves and a variety of non-game also use this WMA, but the potential for wildlife research and management and public hunting opportunities have been undermined by a focus on intensive livestock production. We are concerned that the FWP still does not adequately understand the impacts of livestock use on the WMA to the ecology of the sage grouse, westslope cutthroat trout or even the elk, moose, mule deer, antelope, black bear, wolves, grizzlies and non-game species using the area. We believe some of this lack of understanding relates to misplaced priorities. That the EA fails to mention that bighorn sheep and bison are locally extinct (Hamlin and Ross 2002) is a reflection of these misplaced priorities. The EA also fails to mention the FWP is searching for suitable locations to transplant bison that are currently languishing in the quarantine compound near Gardiner Montana. Furthermore, bighorn sheep will never roam this landscape again unless FWP addresses the conflicts associated with domestic sheep trailing through the WMA. We suggest these are important omissions in the EA. We encourage FWP to re-evaluate its priorities for the WMA and act to restore these native big game species before committing to a domestic livestock use program. We propose such an alternative at the end of these comments and ask that it be thoroughly analyzed in the final EA. Insufficient Economic and Environmental Analysis: We are disappointed in the analysis of all the alternatives considered, especially the No Action or no livestock use alternative (alternative E). We feel the analysis as written is without sufficient literature review, onsite documentation and financial accountability. There is a general lack of scientific literature review in the EA into the impacts livestock may impose directly or indirectly on a variety of native species and processes (DeByle and Winokur 1985; Jacobs 1991; Fleischner 1994; Belsky et al.1999; Donahue 1999; Beck and Mitchell 2000; Hockett 2002; Wuerthner and Matteson 2002). For example, FWP’s own studies in Montana have documented that livestock can displace antelope from preferred habitats and reduced fawning rates due to competition with cattle have been documented (Pyrah 1987). And in Oregon, Stewart et al. (2002) found cattle were generalists with respect to habitat selection and that mule deer and elk avoided areas used by cattle. Furthermore, numerous peer reviewed articles have discussed adverse impacts from livestock use on sage grouse populations and their habitats (Hamerstrom and Hamerstrom 1961; Mussehl and Howell 1971; Beck and Mitchell. 2000; Connelly and Braun 1997; Connelly et al. 2000; Hockett 2002) as well as blue grouse (Mussehl 1960; Mussehl 1963; Zwickel et al. 1968; Martinka 1972; Zwickel 1972). These impacts were not adequately addressed in the EA and many sportsmen and other members of the public likely do not understand the consequences of administering livestock use on the WMA. Furthermore, the EA has a theme of continually implying that if the FWP doesn’t allow livestock use at the level acceptable to the Ledford Grazing Association then “over grazing” might result on adjacent U.S. Forest Service, BLM and/or DNRC public lands. This theme is repeated in particular for the McGuire DNRC lease, which is a 3,600 acre State in holding within the WMA. However, the EA fails to reveal the USFS, BLM and/or DNRC have a desire and indeed a responsibility to take care of the public lands, water and vegetation under their purview. DNRC authorities in particular could just as easily suggest the McGuire piece by grazed early one year, late the next year and rested the third year in a system that might even prove superior to the proposed action by FWP. DNRC has staff to recommend sound management of their land, water and vegetation under rest-rotation livestock use, if that is desirable. However, the EA has an inherent bias toward alternative A, which appears to be the alternative most acceptable to the Ledford Grazing Association. We feel this emphasis on livestock production has unfairly burdened the Department and sportsmen with excessive financial costs associated with livestock mitigation measures and planning ($486,936.32, EA page 5). As well, the ecological costs of these activities are poorly documented in the EA. We also believe the range of alternatives considered lacks sufficiency and creativity. Thus, we suggest additional alternatives and peer reviewed science be considered in detail, some of which we present here. More Promises, But Where is the Data from the Last 20 years of Livestock Use?: While we appreciate FWP committing to a rigorous monitoring plan for game as well as non-game species for the Robb-Ledford and Blacktail WMA’s this commitment is 20 years too late. What have been the consequences of livestock use over the past 20 years of FWP ownership to all these species as compared to focusing on fish and wildlife conservation? If you can’t show us the data over the last 20 years how will you come up with it in the next 3 years? While we also appreciate FWP’s intentions to develop a statistically sound sampling plan for small mammals, songbirds, raptors, amphibian and aquatic reptile surveys, again this sounds like the same song and dance we heard 10 years ago. Where is the monitoring data for the last 10 year’s livestock use plan, which promised us everything would be just fine? We also appreciate the additional efforts FWP will make to conduct surveys for long-billed curlew, sage grouse, waterfowl, and furbearers, in particular beaver. As well, we appreciate the more intensive sampling planned for Robb and Ledford Creeks to assess the value of these riparian areas for wildlife. We suggest methods discussed by Rich (2002) should be incorporated for monitoring habitat conditions and the potential breeding land-bird community on the WMA. The current EA suggests this work will be conducted only through 2012 and in conjunction with a livestock use alternative. We suggest this work should be an ongoing FWP priority well into the future regardless of the alternative selected. And, as far as we can tell all the livestock use alternatives are void of any significant onsite controls, which should have been established when the FWP bought the WMA back in 1988 (Bock et al. 1993). Bock et al. (1993) suggests setting aside 20-25% of any given livestock use area and we suggest doing so on a watershed level if possible would be best. While we suggest the WMA be managed primarily for the benefit of native fish and wildlife, if any livestock use alternative is selected it should include a significant control area that is protected from livestock use impacts to provide a comparison area. The adjacent Blacktail WMA may serve as this control. However the EA was silent on any comparisons studies of the two WMAs. Future Research, Demonstration and Education Efforts: In general, we suggest if FWP wants to study, demonstrate and educate the public about the impacts of livestock use to fish, wildlife and their habitat, they use the Robb-Ledford WMA as a control area to compare to other lands that are subjected to various livestock use systems. For example, there are numerous examples of livestock grazed lands on nearby BLM, USFS, DNRC and/or private lands. The concept of establishing large controls to better understand the impacts of livestock use to native fish, wildlife and plants is supported by Bock et al. (1993), Fleischner (1994), Noss et al, (1997), Belsky et al. (1999), Hockett (2002), Wuerthner and Matteson (2002), Freilich et al. (2003) and others. We suggest the WMA is best used to restore and promote native fish, wildlife and plant research, demonstration projects, educational and biological programs, personnel training in wildlife management (MCA 87-1-210) and public hunting and fishing. There is much to be learned and “showcased” from adoption of alternative E. In the mean time, we remain concerned the FWP is perpetuating and promoting a situation that has not yielded harmonious relations between the hunting public and landowners (MCA 87-1-201) nor has it proven to be a “showcase for cooperative management between ranching and wildlife interests” as suggested in the EA, page 3. Furthermore, as far as we can tell from the 2009 Region 3 Block Management Hunting Access Guide only one of the four current members of the Ledford Grazing Association are enrolled in Block Management, is that correct? Furthermore, under the need for the proposed action on page 5 of the EA the 3rd objective states a desire to “showcase the WMA as an area demonstrating where wildlife and livestock can co-exist while maintaining a healthy rangeland.” In order to do this, FWP may have to keep domestic livestock and certain wildlife species separate (for example domestic sheep and bighorn sheep or perhaps cattle and bison). Thus alternative E may be the only alternative capable of fulfilling this objective on the larger landscape. We also disagree that alternative E does not “…honor and respect the idea of conservation of natural resources on landscapes where people live, work, and recreate” (EA page 8). Indeed, that is the essence of alternative E. While we appreciate FWP’s desire to get along with the interests’ of the livestock industry, we suggest significant change is needed to restore the public’s trust in fish and wildlife management on this WMA and we offer our suggestions below. Domestic Sheep Trailing is an Incompatible Use of the WMA: Especially troubling to use and other bighorn sheep advocates/hunters is that domestic sheep continue to be allowed to trail through the Robb-Ledford WMA in the spring and fall each year on their way to and from public lands on the Beaverhead-Deerlodge National Forest in the Gravelly Mountain Range. This domestic sheep trailing has been authorized without a proper EA required by the Montana Environmental Policy Act, and more recently without the required commercial use permit. We understand that the administrative rules related to commercial uses on FWP lands have been in effect since December 14, 2006 (ARM 12.14.101-170)(Montana FWP 2008). But more importantly, this commercial domestic sheep trailing is incompatible with the management objectives of the WMA and the public’s use of this area, which should include the restoration and conservation of native bighorn sheep. Public hunting and wildlife viewing opportunities are being sacrificed because the presence of domestic sheep on the WMA makes the habitat unsuitable for bighorn sheep. Bighorns can not commingle with domestic sheep without potentially serious consequences to the bighorn sheep population (Montana FWP 2009). FWP has postponed a decision on this issue, while we suggest it is a significant cumulative effect of not only the proposed livestock use alternatives being considered in this EA, but also the no action alternative. Indeed, any bighorn sheep attempting to emigrate from the Greenhorn Mountains into the Ruby Mountains, Gravelly Mountains, Snow Crest Mountains and/or the Robb-Ledford WMA have and will continue to be removed by the FWP due to this conflict and the now infamous Greenhorn MOU (USDA Forest Service et al. 2002). We know of at least 16 bighorns which have even been lethally removed by FWP due to this conflict with domestic sheep and the resulting Greenhorn MOU (Aug. 5, 2009 Correspondence from FWP). We contend the Greenhorn MOU has not been effective policy for bighorn sheep and sportsmen (Montana FWP 2009) and that reasonable alternatives exist to the continued trailing of domestic sheep across the WMA. Rest-Rotation Cattle grazing is a Livestock Production System: FWP appears sold on rest-rotation livestock use as the best way to improve fish and wildlife habitat as all the action alternatives are limited to some form of this system. As well, the EA keeps implying the proposed rest-rotation livestock use systems are designed for fish and wildlife habitat improvement. To the contrary, it should be noted that rest-rotation livestock use as described by Hormay (1970), which is the nearly 40 year old basis for the FWP proposal, is a livestock production system first and foremost. Other highly limited uses of livestock would likely yield much better results for fish and wildlife, however no such options are analyzed in the EA. From our perspective, it doesn’t appear the alternatives reviewed are really all that different. Thus we question whether the EA evaluates a sufficient range of alternatives. It should be noted in the EA that range condition and wildlife habitat quality and quantity are not the same (USFWS 1985). It is an incorrect assumption to equate the two. Good range condition does not equate to habitat quantity or quality. Differentiation is critical to an understanding that range condition merely looks at plant species composition at different seral stages of development (low, mid, late, climax or poor, fair, good, excellent condition). Whereas habitat quantity has to do with the amount of food, space, cover, water and clean air available to any particular species during any particular season. Habitat quality involves the interspersion of these factors in such a way that productivity is maximized around a dynamic equilibrium. The carrying capacity of high quality habitat will fluctuate with natural disturbances such as drought, severe winters, floods, fire, competition with other species and predation. Seasonal domestic livestock influences can disrupt both quality and quantity of habitat for wildlife regardless of the current or projected desired future condition of the range. Habitat components overlooked by range condition or seral stage ratings include the amount of residual cover, forage, water and space (clean air is not usually limiting in a rangeland environment) available at any given time or place. Annual livestock grazing treatments can and often do acutely impact any or all of these habitat components. Range condition ratings are also silent as to the proper or optimal interspersion of habitat components or seasonal habitats at any given time or place. Range condition says nothing about habitat fragmentation by things such as agricultural conversion, roads, fences, buildings, range developments, livestock water tanks and salting areas. As well, “good” range conditions may be highly and variably fragmented or degraded by various annual grazing impacts. Examples include spatial competition or social displacement between livestock and native species; disease issues either to or from domestic livestock; significant trampling and utilization of annual herbaceous growth through selective overgrazing of micro-sites such as wet meadows within drier uplands; soil compaction, trampling, erosion, increased runoff and sedimentation; water quality and quantity degradation (temperature, turbidity, instream or shoreline trampling, sedimentation); degradation or depletion of security, foraging, nesting, calving, fawning, hiding or thermal cover; degradation or depletion of winter habitat or forage; degradation or depletion of water sources through outright consumption, trampling and compaction of wetland soils and overuse of riparian vegetation (USFWS 1985). Eroded streambanks and compacted riparian areas lead to lower watertables, increased runoff and decreased water quantity and habitat quality for fish and other aquatic species. Furthermore, many wildlife species show fidelity for seasonal habitats. To provide for the well being of these species, their seasonal habitats must be identified and protected, temporally and spatially. Rotational grazing systems lead to acute effects in grazed pastures. Key habitat components must be provided for during the appropriate season of use, for example 7 inches or more herbaceous cover during the nesting season for sage grouse will require a build up of residual cover the previous fall, while a lush forb growth early in the growing season will require protection from grazing in the spring. We question the ability of the proposed rest-rotation grazing systems to address the specific habitat needs of a variety of native fish and wildlife that use the WMA on any given year. Species composition of the plant community does play an important role in the potential of the site to provide various habitat components such as residual herbaceous cover and forage. Climax bunchgrasses and forbs are typically more productive and taller than “increaser” species (plants that thrive under livestock use). However, even a site in climax condition can be annually degraded from livestock use in terms of the condition of the various seasonal habitat components depending on the grazing treatment prescribed and the timing of this use. Repeated use also leads to shifts to plant species more tolerant of grazing such as Kentucky bluegrass, an introduced exotic well adapted to close grazing. Such species are capable of vegetative reproduction through the production of underground stems called rhizomes. Grasses that increase under livestock pressure tend to be shorter, shallow rooted and less likely to produce tall seed producing culms, which provide erect vertical herbaceous cover and forage. These plant community species composition changes in conjunction with annual grazing impacts can lead to significant degradation of winter ranges, nesting habitats and other seasonal habitat components. Also, under fair to good range conditions upland shrubs such as big sagebrush or other species unpalatable to domestic livestock can increase to the point of significantly limiting herbaceous cover and forage production (USFW 1985; USFWS 1993). Furthermore, Eckert and Spencer (1986) questioned the effectiveness of rest-rotation livestock systems on rangelands where species unpalatable to cattle such as sagebrush are important components in stands of palatable grasses and forbs. This study found no improvement in the frequency and cover of “decreaser” bunchgrasses on a majority of sites after 7 to 10 years of 3 pasture rest-rotation livestock use. In fact, they documented a shift from tall, productive bunchgrasses to short and less productive plants. The ecological range condition on the study area ranged from early to mid seral, which equates to poor and fair range conditions. As well, a downward trend in range condition was also noted at sites where either bluebunch wheatgrass or Thurber needlegrass were the potential dominant bunchgrasses within the big sagebrush plant communities they studied. However, Johnson (1969) found bunchgrasses in sagebrush grasslands increased from 24% of the total grass and sedge production to 60% (2.5 times as much) after 15 years or rest (1951-1966). Although this research primarily looked at the response of sagebrush to spraying and grazing, exclosures were established which revealed a significant benefit to bunchgrasses vs. sod-forming grasses in un-grazed areas. This change occurred on both the sprayed and unsprayed sagebrush communities within the exclosures, and the authors attributed the change primarily due to the cessation of livestock grazing. It is important to note that many wildlife, riparian and/or livestock use researchers have found it is not the system of grazing that is important as it is what is left over after the proposed grazing treatments are imposed (Mussehl 1963; Clary and Webster 1989; Hockett and Roscoe 1993; Clary 1995; Connelly et al. 2000; Hockett 2002; Pelster et al. 2004). Werner and Urness (1998) also question the ability of a rest-rotation livestock grazing system to achieve range management goals in areas where elk merely shift their use to the rest pastures. Furthermore, FWP has recognized the degraded riparian areas along Robb Creek despite nearly 20 years of FWP livestock grazing administration under some form of rest-rotation system. This and other riparian areas on the WMA will require protection from livestock use to recover and provide optimal benefits to fish and wildlife. Clary et al. (1996) found this to be the case as well in a depleted sagebrush steppe riparian system they studied. However, under the proposed livestock use alternatives outlined in the EA there is no assurance that adequate cover for riparian stream bank protection and/or ground nesting and brood rearing birds will be afforded in any of the grazed pastures. Many upland game birds including blue, ruffed and sage grouse are specialists (Stauffer and Peterson 1985; Stauffer and Peterson 1985(a); Connelly and Braun 1997) and show high fidelity to seasonal habitats (Buss 1960; Mussehl 1960; Dalke et al. 1963; Zwickel et al. 1968; Berry and Eng 1985; Connelly et al. 2000; Hockett 2002). While generalists like elk (Skubinna and Van Dyke 1991) may be able to avoid acute impacts from rotational grazing systems by shifting their habitat use to rest pastures, specialists are unlikely to shift their use of preferred/required habitats. Thus, while livestock use impacts may generally appear to not be a problem, localized impacts to say nesting habitat for ground nesting birds like blue, ruffed and sage grouse may be significant in any given year. These impacts are compounded by the effects of drought, which is beyond the manager’s control. In addition, trailing and/or herding of livestock can also cause sage grouse nest desertion (Patterson 1952; Call 1974) regardless of the rotational grazing system in place. Even though some pastures are not scheduled for use, livestock must be trailed through them to get to the pasture that is scheduled for use that year. Another example of potentially significant impacts in any given year of livestock use would be the westslope cutthroat trout population in Rock creek. These fish can not get up and move to Ledford creek the year Rock creek is being trampled and impacted by livestock use. And in the case of fisheries habitat, one year’s damage from sedimentation will not be cured from a year of rest the following year. Thus, some habitats and species may be especially susceptible to the impacts of livestock use in any given year, especially in the presence of drought, which by itself can be a significant limiting factor for native grouse (Connelly and Braun 1997; Connelly et al. 2000; Dusek et al. 2002; Eustace 2002; Hockett 2002). Big Game Conflicts: Livestock compete directly with elk, antelope, mule deer, moose bighorn sheep, bison, and other big game species for food, space and water (Hansen and Reid 1975; DeByle and Winokur 1985; Pyrah 1987; Hamlin and Ross 2002; Boyd 2003; Beecham et al. 2007). Thomas and Toweill (1982) note that elk and cattle are primary competitors pointing out that elk compete more with cattle than any other large domestic herbivore because of their strong diet similarities. As well, FWP’s own studies in Montana have documented that livestock can displace antelope from preferred habitats and reduce fawning rates due to competition with cattle (Pyrah 1987). Mule deer and elk can also be displaced by cattle from preferred habitats (Loft et al. 1991; Stewart et al. 2002). Bighorn sheep also compete poorly with livestock for food, space and water (Beecham et al. 2007; Montana FWP 2009). Localized competition for forage, space, and water between bighorn sheep and domestic livestock is a potential limiting factor for many bighorn populations (Beecham et al. 2007). Furthermore, many of the livestock management techniques that are discussed in the EA such as water developments, salting, fences, or other grazing practices/structures that concentrate cattle in or near female bighorn home ranges are not recommended (Taylor 2001). Bighorn Sheep and Bison: Bighorn sheep and bison were known to occupy the Blacktail-Snowcrest-Gravelly ranges (Hamlin and Ross 2002; Montana FWP 2009; Montana FWP 2009(a)). Market hunting and the introduction of domestic livestock also adversely impacted these two species and bighorn sheep were eventually displaced by domestic sheep (Montana FWP 2009) and bison were extirpated in the late 1880’s (Hamlin and Ross 2002). We suggest the Robb-Ledford and Blacktail WMAs provide a solid foundation for transplants of these native big game species. Yet no such efforts have been undertaken on either of these WMAs. Clearly how the WMA is managed in the future, in particular the degree which resources are committed to domestic livestock production (domestic cattle and sheep) has a significant impact to these native big game species. Numerous peer reviewed research articles discuss the impacts domestic livestock (both cattle and sheep) may have on bighorn sheep and/or their habitat, including disease transmission and competition for food, space and water (Helvie 1971; Thorne et al. 1979; Jessup 1981; Foreyt and Jessup 1982; Goodson 1982; King and Workman. 1984; Jessup 1985; Parker and Scott 1989; Smith et al. 1991; Suminski 1991; Taylor et al. 1998; Toweill and Geist 1999; Monello et al. 2001; Schommer and Woolever 2001; Singer et al. 2001; Singer et al. 2001(A); Taylor 2001; Dubay et al. 2003; Beecham et al. 2007; Western Association of Fish & Wildlife Agencies 2007; Montana FWP 2009). None of these impacts from livestock use to bighorn sheep or their habitat were discussed in the EA. This is a significant omission as livestock management decisions may have significant consequences to the future reintroduction and/or natural immigration of bighorn sheep onto or even near the WMA. The same is true for bison. The American bison is ecologically extinct outside Yellowstone National Park and has a much reduced range of free-roaming herds (Montana FWP 2009(a)). A goal of the Montana Comprehensive Fish and Wildlife Conservation Strategy is to establish free-ranging, disease-free American bison populations in suitable grassland habitats outside Yellowstone National Park where they can function ecologically and operate as keystone species to restore grassland systems (Montana FWP 2009(a)). Moreover, the Conservation Strategy proposes to create populations of wild bison that can be harvested and provide economic and social benefits to Montana. We support these goals. Efforts are currently being explored to isolate a brucellosis-free population with acceptable genetics in order to establish free-ranging herds outside Yellowstone National Park (Montana FWP 2009(a)). We suggest the Robb-Ledford and Blacktail WMAs and surrounding landscape offer a perfect place to achieve this goal. Establishing this type of herd would require extensive cooperation from various federal and state agencies and private partners. If successful, these herds could serve to help restore the ecology of many community types in greatest need of conservation, such as grassland complexes, mixed shrub/grass associations, woody draws, and mixed broadleaf forests. Along with the restoration of these community types, many associated species in greatest need of conservation could benefit (Montana FWP 2009(a)). Therefore, the EA should recognize the absence of these important big game species and evaluate the biological suitability of restoring native bison and bighorn sheep to the WMA in the context of the various livestock management alternatives being considered as well as the no action alternative. Elk: The most substantial early impact on elk in the Blacktail-Snowcrest-Gravelly ranges may have been market hunting, but the most important long-term impact was probably livestock grazing (Hamlin and Ross 2002). Although livestock grazing occurred earlier, most of the increase in livestock use started in the 1880’s. Indeed, elk were so depleted from the Blacktail-Snowcrest-Gravelly ranges by the late 1800’s they were transplanted to the area in 1937 (Hamlin and Ross 2002). Furthermore, Ewing (1990) documented in an interview with FWP personnel that removal of cattle from various WMAs in southwest Montana resulted in significant increases in elk numbers. For example, the Blacktail WMA was purchased in 1972 and the FWP shifted management from a cattle operation to a focus on elk winter range. The Blacktail WMA went from 400-600 elk to 1700 elk, twelve years after cattle were removed. The Fleecer WMA went from 200 to 1000 elk once the cattle were removed, and the Wall Creek WMA went from 200 to 1400 elk (Ewing 1990). Hamlin and Ross (2002) also discuss the benefits of acquiring many of these WMAs, in particular for elk habitat. Although some of these WMAs are grazed by livestock now, the removal of cattle was the stimulus that initially increased elk numbers. And, any increase in the elk herd using the Robb-Ledford WMA is more a function of reduced hunter access on neighboring private lands than as a result of continued livestock use on the WMA (Montana FWP 2004). Elk also compete with cattle for food, space and water (Morris 1956; Cole 1958; Thomas and Toweill 1982; Hamlin and Ross 2002) and the greatest competition occurs on foothill ranges (Morris 1956) like the Robb-Ledford WMA. Furthermore there has been some concern expressed by the FWP in the 2004 Montana Elk Management Plan that reduced elk harvests in this area (hunting district 324) has resulted in increased elk numbers during winter and this may put elk numbers at or above the capacity of the public winter ranges (Montana FWP. 2004 p. 223). Cattle compete with elk for forage and Chadde and Kay (1991) documented the disappearance of tall willow communities and related animal habitats such as beaver on Yellowstone Park’s northern range due to heavy browsing by native ungulates alone, primarily elk. Adding cattle to the mix seems contrary to the purpose of acquiring and conserving the area for native wildlife, especially when the full compliment of native big game species are not yet present on the WMA. Given this situation, why would FWP propose to administer domestic livestock use on Robb-Ledford WMA? Others have looked for ways to use cattle as a “tool” to improve rangelands or wildlife habitat. Skovlin et al. (1983) reviewed ways to increase winter use by elk in the Blue Mountains on Pacific bunchgrass foothill range in southeastern Washington. However, what they found regarding livestock use in the spring in an attempt to promote re-growth for elk did not increase elk use. In fact, cattle grazing decreased winter elk use by 28% in 1 of the 3 years of the study. As well, elk use during the other 2 winters also appeared to be less on ranges grazed by cattle than on un-grazed range, but these differences were not significant. The authors concluded that if forage supplies exceed the winter needs of elk, and range condition is acceptable, light cattle grazing in spring or early summer might be maintained without adverse effects. Nevertheless, the authors point out, their findings showed cattle grazing diminished winter elk use significantly in 1 of 3 years. Furthermore, the idea that cattle remove “older forage” and that this may help establish a higher quality of feed for elk the following spring is highly suspect if not misleading (p. 22 EA citing Frisina 1992). Cattle and elk are primary competitors (Thomas and Toweill 1982). Furthermore, cattle prefer and select green vegetation over dry and leaves over stems (Reppert 1960), which are the most nutritious parts of the plants. Reppert (1960) also documented that forage species selected by cattle were not necessarily in proportions to their abundance. Cattle are highly selective and they prefer “ice cream” plants, removing the most lush and palatable species first. I have personally looked inside the rumen of fistulated cattle and seen that the entire stomach contents were made up of green, leafy material, not old dry forage as the EA implies. As well, cattle use the WMA during the growing season and/or throughout the summer and early fall. It has been well documented in the riparian literature cited in these comments that as upland herbaceous vegetation cures cattle seek out the moist, green riparian sites and spend a disproportionate amount of time in these critical fish and wildlife habitats. Thus, cattle are not consuming old, dry growth rather they are consuming green leafy growth which is prevented from growing tall and becoming residual standing vegetation that might otherwise provide cover for ground nesting birds and organic matter to the soil the following spring. The EA further asserts that grazing by domestic livestock has been shown to improve accessibility, palatability, and nutritive quality of forage plants preferred by wild herbivores citing Jourdonnais and Bedunah (1990) (p. 22 EA). Again, this is misleading. While cattle use of green leafy vegetation during one growing season may lead to earlier green up and increased palatability of the heavily used plants/areas the following spring, from the plants perspective, additional use of these same plants/areas the following spring by big game is merely a cumulative impact to the overall health of the plant. Such repeated use can not be sustained over the long haul, especially to native bunchgrasses and sedges such as bluebunch wheatgrass and elk sedge. Furthermore, elk have been repeatedly observed to prefer rested units within rest-rotation grazing systems in Montana (Werner and Urness 1998, citing Frisina (1992) and Knowles and Campbell (1981); Hockett personal observation while hunting in southwest Montana). Werner and Urness (1998) felt that due to the logistics, financial investments and maintenance costs of implementing a rest-rotation grazing system, elk herbivory in rested pastures is a potential source of conflict with rangeland management goals. Given the potential overlap of elk and cattle diets (Thomas and Toweill 1982), Hormay’s principles regarding the restoration of plant vigor due to rest may be negated by elk use in rested units. This does not include the additional cumulative herbivory from other big game species such as mule deer and antelope that also tend to avoid areas being used by cattle. Krueger and Winward (1974) studied the influence of cattle and big game grazing on understory structure of a Douglas fir-Ponderosa pine-Kentucky bluegrass community Grazing by big game alone had no significant impact on the frequency of perennial grasses or sedges. The frequency of Elk sedge however was significantly lower, with a value of 8%, in the area grazed by both big game and cattle as compared to treatments grazed only by big game. On areas grazed only by big game or completely protected from big game and cattle, elk sedge frequency was 5 to 6 times higher at 42% and 50%, respectively. These values, 42% and 50%, were not significantly different. These researchers concluded that some native perennial bunchgrasses and sedges (prairie junegrass and elk sage) were substantially reduced or completely removed by cattle and big game use as compared to big game use only. This appeared to perpetuate and promote a dominance of the exotic invader Kentucky bluegrass even though it was a preferred forage species. Generally, the impact on the herbaceous vegetation was greatest where cattle and big game grazed in common. Grazing by big game alone (mule deer and elk) resulted in minor impacts on the herbaceous component of the understory. However, this does not imply that the herbaceous vegetation was not important forage for big game. The small component of browse, only 2% of annual forage production, was significantly reduced by both the cattle and big game and big game only treatments. Under these conditions the authors felt the browse component would be suppressed by big game alone, regardless of livestock management programs. Mule Deer: While elk are emphasized in the EA, summer forage conditions can be critical as well for deer fawn survival, body growth and condition, and accumulation of fat reserves among adult deer (Wood et al. 1989). Kie et al. (1991) found mule deer spent more time feeding and less time resting with increased cattle stocking rates. Companion studies cited by Kie et al. (1991) also indicated deer home ranges were larger (Loft 1988) and hiding cover for fawns was reduced (Loft et al. 1987) with cattle use. Although various livestock grazing systems were discussed as a means of mitigating the adverse impacts associated with cattle use on preferred mule deer habitat, protecting preferred mule deer habitats especially in the spring and early summer provided the best fawning habitat and conditions for mule deer in general. As well, female mule deer demonstrate high fidelity to traditional herd ranges (Wood et al. 1989), so localized impacts associated with livestock use may have acute impacts to annual mule deer production whether or not the overall grazing system is benefiting range conditions in general. Furthermore, Loft et al. (1991) found in the absence of cattle, female mule deer used meadow-riparian habitats as a greater proportion of their home range than when cattle use occurred. Mule deer were especially displaced from aspen stands during periods of cattle use. Mule deer only preferred these important habitats in the absence of cattle and Loft et al. (1991) documented a strong cattle preference for riparian-meadow and aspen habitats within the areas they used. The greatest effect of cattle use on habitat selection by female mule deer occurred during late summer when forage and cover were at a minimum in preferred habitats. Female mule deer were especially displaced by cattle use at this time, shifting their habitat use from areas preferred by cattle to areas avoided by cattle. Mule deer use of meadow-riparian habitat was positively correlated with standing herbaceous vegetation in meadow areas and hiding cover in willows. Cattle use had a negative influence on these variables. Kovalchik and Elmore (1992) also discuss in detail both historic and more recent adverse impacts of livestock use to willow communities. Loft et al. (1991) documented significant reductions in willow cover occurred in late summer as cattle moved into willow stands to forage within the canopy when herbaceous forage had been depleted in open meadow areas. Under these circumstances, forage conditions were most limiting on the summer range for mule deer, and deer responded with their greatest reduction in selection of preferred meadow-riparian habitat (Loft et al. 1991). . However, unlike meadow-riparian habitat, Loft et al. (1991) found aspen habitat was avoided almost immediately by mule deer once livestock use was initiated and mule deer did not return to these important habitats. The researchers noted herbaceous vegetation in meadow-riparian habitat exhibited some re-growth following initial defoliation by cattle due to the moist nature of these areas while there was little re-growth in aspen habitats. This was due primarily to the aspen habitats slightly drier site conditions, the apical dominance growth form of many of the plants found there, and the repeated trampling and soil compaction that took place due to the preference of cattle to use aspen stands for resting and shade. Once aspen habitats had been used by cattle for a few weeks, there was little forage or hiding cover available for mule deer and mule deer essentially quit using these habitats. However, cattle continued to use aspen habitat during the late summer for shade, especially near meadow-riparian habitats. Other Big Game: Moose habitat can also be degraded by livestock use (DeByle and Winokur 1985) and grizzly bears and wolves often find conflict when they interact with domestic livestock, especially domestic sheep. Thus, we question the implication by FWP that rest-rotation livestock use somehow benefits elk, other big game species and/or other fish and wildlife species/habitat for that matter. The FWP has not produced any data that indicates the past 10-20 years of livestock management on the WMA has benefited fish and wildlife habitat, especially as compared to no action. The EA also makes questionable claims that are not supported by onsite data or literature review such as (p. 22 EA): “The distribution of grazed and ungrazed pastures has created a mosaic of habitats that have accommodated a wider variety of species with different habitat requirements. Resident wildlife species as well as transient animals have benefited from the increased food and cover that has occurred from the efforts of the 2000 grazing agreement and the implementation of the coordinated grazing management system as compared to the health of the habitat under previous ownership.” These statements are not supported with specific data. Furthermore, they compare current livestock management to past livestock management rather than a comparison to no action, which is likely both cheaper and better for fish and wildlife generally. This is a fundamental flaw of the EA. For example, how would the WMA look had FWP decided to forgo livestock use 10 years ago or 18 years ago when they took over management responsibilities in 1991? These important questions remain unanswered and the EA does not adequately review the benefits of the no action alternative as supported by science in general. Rather, scientific studies reveal time and time again there are significant consequences to domestic livestock use in western North America (Leopold 1924; BLM 1980; Platts 1981; Fleischner 1994; Belsky et al. 1999; Wuerthner and Matteson 2002; Hockett 2002; Freilich et al. 2003). The EA is largely silent on most of these impacts in its review of the livestock use alternatives. Fleischner (1994) takes a comprehensive look at the issue, reviewing information from 171 literature citations. These issues related to livestock use should be openly and frankly displayed in the EA. Examples of ecological costs of livestock use include competition for forage, space and water, disease transmission, loss of biodiversity, lowering of population densities for a wide variety of taxa, disruption of ecosystem functions, including nutrient cycling and succession, change in community organization, and change in the physical characteristics of both terrestrial and aquatic habitats. The deleterious effects of livestock use have been observed in all vertebrate classes (Fleischner 1994). These aren’t our words they are the words of peer reviewed scientists. Clearly, there are potential significant consequences to big game species and thus sportsmen to maintaining livestock use on the WMA as compared to removal of those discretionary impacts. And this indeed is the question that should be evaluated in the EA – how does livestock use compare to no action. Rather the EA tries to justify the proposed rest-rotation livestock use alternatives as compared to past livestock use. We assert adverse impacts to native fish, wildlife and plants as well as public hunting, fishing, camping, photography and wildlife viewing opportunities will continue on the Robb-Ledford WMA under rest-rotation livestock use. As we understand it, rest-rotation livestock use to varying degrees has been the preferred method of livestock management implemented by the FWP over the life of their ownership. This experiment has been going on for over 20 years and what do we have to show for it? Many of these consequences have not been adequately reviewed in the EA, thus we discuss many of these potential impacts below. We assert a sufficient analysis of the environmental and economic consequences of livestock use, especially as compared to a thorough analysis of protection from such livestock impacts, has not been properly conducted in the EA. Riparian Areas and Fisheries: Fisheries, beaver, moose, waterfowl, upland birds, non-game birds and a variety of wetland species/habitats are important natural resources on the Robb-Ledford WMA. All of these species and their habitats can be adversely affected by livestock use and these effects were not adequately revealed in the EA (Kauffman and Krueger 1984). For example, Belsky et al. (1999) found that livestock grazing has damaged approximately 80% of stream and riparian ecosystems in the western United States. Small streams/fisheries such as those found on the WMA are especially susceptible to livestock use impacts (Gillen et al. 984; Armour and Elmore 1991). The EA does identify at least some important fisheries (Robb, Ledford and East Fork Blacktail Deer creeks) including at least three westslope cutthroat trout streams (East Fork Blacktail Deer, Robb and Rock creeks) that are being adversely impacted by livestock use (EA, page 17). However, a number of streams have yet to be surveyed for fish populations and habitat conditions. Crows Nest, Taylor, Swamp, and Indian creeks have not been surveyed and their status as fisheries is unknown (EA, page 18). This is troubling given that Benke and Zarn (1976) identified livestock grazing as the greatest threat to the integrity of trout stream habitat in the Western United States. Maintenance of westslope cutthroat trout populations at levels documented in the EA (page 17) is not an adequate goal. The habitat and population of this sensitive species needs to be significantly improved (Young 1995). The current distribution and abundance of westslope cutthroat trout appear to be severely restricted compared to historical conditions and declines are probably continuing in much of the remaining range (Young 1995). We suggest FWP consider adopting the core habitat conservation approach discussed by Rieman and McIntyre (1993). While this technical report focuses on bull trout we feel the principles apply to the recovery and conservation of westslope cutthroat trout on the WMA. As well, FWP is not following its own recommendations regarding Rock creek, which is one of the very few known 100% genetically pure westslope cutthroat trout streams still in existence (Montana FWP 1998; Montana FWP 1999). From Page 4&5 in Montana FWP (1998): In Montana, westslope cutthroat trout populations are restricted to headwater streams with over 75% of remaining populations occurring on waters flowing from federal public lands. To meet the goals and objectives of this agreement, interested parties are instructed to protect important westslope cutthroat trout habitats from additional degradation and to restore any degraded habitats to meet the cold, clear, pristine water requirements these fish demand. At a minimum the pasture containing the important westslope cutthroat trout fishery should be protected from the degradation associated with domestic livestock use (Armour et al. 1991;). The only alternative that contemplates such protection is alternative E, no action. Also the EA, Appendix H, page 11 of the 2000 Grazing Plan stated: “Along with the important rest periods provided for in the rest-rotation system, livestock herding, pasture layout and the development of upland water sources (i.e. water tanks) will be important components of the R/L System to assure riparian areas improve and stay healthy. These methods have proven effective in riparian management systems (Ehrhart and Hansen 1997, and Ehrhart and Hansen 1998). Fence locations and the removal of narrow water gaps will help reduce livestock concentrations in these areas. Vegetation monitoring will be set up to assure the system is heading in the right direction so that adjustments can be made where necessary. Continued monitoring will be especially important on the WCT stream, Rock Creek. Any significant degradation attributable to livestock will be handled through necessary adjustments in AUM’s, grazing patterns or whatever means FWP feels necessary to correct the situation.” Rock creek has not improved and may even be in worse condition than back in 2000. As well, three of the alternatives proposed in the 2009 EA propose to build a riparian fence with water gaps on Robb creek because cattle use is still causing problems there, while the 2000 EA noted water gaps were removed because they concentrated cattle use and caused problems with fish. And we can find no vegetation monitoring data in the 2009 EA that has assured the system is heading in the right direction. The EA, page 17 just states without providing any supporting data: “Historic livestock and farming uses have influenced stream and riparian conditions, but all the riparian corridors have responded positively since the implementation of the R/L System with the exception of small portions of Robb Creek.” Perhaps more important, this discussion of “improvement” is relevant to past livestock use rather than protection from livestock use. This is like saying smoking 1 pack a day is better than smoking 2 packs a day. The statement may be true, but neither option is good for you. The real question FWP needs to be answering is the effect of livestock use vs. no action or protection from livestock impacts. This is what really matters to the fish and to our organization as fishermen. As well, from the EA page 18: “No new [fish] surveys have been completed within Blacktail, Ledford, Robb, and Rock creeks since 1990’s.” How can the FWP claim improvement for the fisheries with no data to support such claims? Indeed the scientific literature related to this matter indicate that livestock use can adversely impact trout habitat, in particular water quality, water temperature and siltation rates (Platts and Raleigh 1984; Armour et al. 1991; Overton et al. 1994; Loftus and Flather 2000). Sediment inputs degrade water quality for both fish and invertebrates (Platts and Raleigh 1984). Impacts to aquatic habitat include siltation on spawning substrate, increased water temperature, nuisance vegetation, low dissolved oxygen levels, and unstable stream flows. In one case study reviewed in Loftus and Flather (2000), removal of cattle from the stream and adjacent riparian areas in conjunction with reestablishing native vegetation on the stream banks and improving in-stream habitat lead to significant decreases in water temperature. Following these modifications, the average water temperature was reduced by 9.4ºC, dropping from an average of 21.7ºC in 1986 to 12.3ºC in 1994. Bank stability, which affects sediment loads, markedly improved in four of seven segments of stream, slightly improved in two areas, and declined in one area. The average stream depth increased in all areas and the average rating of pool habitat quality increased in five of the areas while remaining the same in two areas. These findings have important implications for livestock use of important and/or sensitive fisheries such as Ledford creek, Robb creek and Rock creek on the WMA. Maloney et al. (1999) looked at the effects of three different range management strategies of increasing intensity to summer stream temperatures on 12 different forested watersheds near John Day Oregon. The strategies reviewed were: 1) no livestock, 2) light grazing (7.7 ha/AUM) and 3) intensively managed livestock use (2.8 ha/AUM). Streams with greater than 75% stream shade maintained acceptable stream temperatures for rainbow trout and Chinook salmon. Lowest temperatures were observed in streams from ungrazed watersheds and the highest temperatures were observed in the most intensively managed watersheds (2.8 ha/AUM). The effect of range management strategy in this study was not definitive, however, because it was confounded by watershed characteristics and about 100 years of livestock use prior to initiation of the study. However, shade provided by riparian vegetation is one of the most important regulators of temperature in small streams such as Rock creek and other streams found on the WMA. When riparian vegetation is removed by livestock use or other means the stream surface is exposed to direct solar radiation, and stream temperatures increase. Elimination of streamside vegetation and removal of overhanging streambanks are two of the leading causes for decline of native trout in Western streams (Behnke and Zarn 1976). Cattle are one of the major causes of this problem because they tend to concentrate in riparian zones for the high quality forage and readily available water (Belsky et al. 1999). Cattle consume grasses, forbs, and new growth from many shrubs and trees, in particular willows and aspen. Severe alteration of composition, structure and productivity of vegetation in riparian zones has been a common result (Kauffman and Krueger 1984). Cattle may crush overhanging streambanks and physically disturb the streambed, causing increases in sediment, turbidity, and water temperature (Clary and Webster 1989; Armour et al. 1991; Overton et al. 1994). Protection of streams from livestock grazing has resulted in improvement in abundance of riparian vegetation, stream surface shade, and channel morphology (Platts 1981; Overton et al. 1994). Improvements in vegetation and stream channel morphology have generally taken 10 years or more after exclusion of cattle (Overton 1994; Maloney et al. 1999). In some areas, however, the cumulative effects of past grazing use have caused sufficient damage to require even longer term recovery efforts after protection from livestock use (Clary et al. 1996). Platts (1981) took an in depth look at the impacts of livestock use to various fisheries in western North America. This paper documented the current knowledge at the time (28 years ago) on interactions of livestock and fish habitat. Although incompatibility and compatibility between livestock grazing and fisheries were both discussed, an overwhelming majority of the literature reviewed estimated the consequences of livestock grazing as being detrimental to fisheries habitat. The author points out the historical shift in values of rangelands as food for livestock to the many other uses, including fish and wildlife habitat, they are managed for today. The author reviews a history of “overgrazing” and the struggle of rangeland managers to recognize the influences of livestock grazing on riparian and aquatic ecosystems, as well as the impacts to upland vegetation and the surrounding watershed. Both published and unpublished “cutting edge” science and opinion of the day is cited. For example, Leopold (1974), at the West Yellowstone Wild Trout Symposium was cited from unpublished data as saying livestock grazing may have cumulative ecological ill effects on productivity of both lands and waters. Benke and Zarn (1976) were cited as identifying livestock grazing as the greatest threat to the integrity of trout stream habitat in the Western United States. Other fisheries biologists have questioned whether grazing systems, especially certain forms of rest-rotation grazing, are providing adequate maintenance or improvement of the aquatic habitat (Skovlin 1984). In southwest Montana, grazing systems which only consider upland plant growth requirements will generally not meet stream riparian site requirements (Myers 1989). Myers (1989) summarized his recommendations where stream riparian maintenance or recovery is the objective:
How has FWP documented the compliance with past efforts at administering livestock use on the WMA? When we toured the area on Sept. 9, 2009 we observed cattle in at least 3 different pastures on the WMA and many of these cattle were in or near riparian areas. As well, Rock creek, especially upper Rock creek appears extremely susceptible to livestock use impacts and we contend this westslope cutthroat trout spawning habitat is too frail to withstand repeated livestock use. Has/will FWP assure that at least 6” of herbaceous cover is present in riparian habitats after livestock use any given pasture? Without this type of commitment to managing and monitoring any of the proposed livestock use alternatives we feel as pointed out by Myers (1989) that little progress will be made to improve existing habitat conditions on the WMA. As well, none of the livestock use alternatives provide for removal of livestock by early August to protect sensitive riparian areas. Livestock use can impact runoff rates and sedimentation as well. Lusby (1970) studied the impacts of livestock use as compared to no livestock use on hydrologic and biotic factors in various watersheds near Grand Junction Colorado. Measurements of precipitation, runoff, erosion, and vegetation were made on paired grazed vs. ungrazed watersheds. Runoff in the watersheds subjected to livestock use was about 30 percent higher than the runoff recorded in the watersheds protected from livestock use. Sediment yield was about 45 percent higher in the watersheds subjected to livestock use. Chaney et al. (1990), BLM (1991) and Chaney et al. (1993) show many photographic examples of degraded riparian areas due to livestock use and this can happen regardless of the grazing system used. These publications also discuss how significantly reduced and intensively monitored livestock use and/or complete protection from livestock provide an opportunity for riparian habitat recovery. Clary (1999) found that light (20-25%) to moderate (35-50%) levels of use by livestock limited to the spring only allowed for riparian areas to slowly recover from past livestock use. In his study a residual herbaceous cover of at least 10-14 cm (4-5.5”) was required to provide most, but not all, streamside variables to move closer to those beneficial for salmonid fisheries. Livestock use in late June on the cold mountain meadow riparian system in his study prevented livestock concentrations in lowland riparian areas. However, the majority of livestock impacts were merely moved to mesic meadows within drier upland landscapes, which are often important habitats for ground nesting and foraging birds such as sage and blue grouse. Cattle showed a high preference for these mesic meadow sites within the drier uplands (Clary 1999). Livestock use was abandoned before upland meadows matured, in order to avoid the inevitable shift of livestock preference to lush riparian areas and fisheries habitat. Thus, summer, fall and “hot season” use were avoided in order to provide very slow riparian and fisheries habitat recovery in the presence of light to moderate spring only livestock use. Still, protection from livestock use achieved the fastest shift and greatest magnitude of improvements for riparian and fisheries values in the Clary (1999) study. Complicating the riparian management issue in the presence of livestock, Gillen et al. (1984) found that small riparian meadows were the most preferred plant communities selected by cattle, even though these sites occurred on only 3-5% of the landscape they studied. The characteristics of the mountain rangeland Gillen et al. (1984) studied would appear similar to the Robb-Ledford WMA situation in that riparian areas make up a small, but critical component of the overall landscape. The authors cite other studies which also reveal cattle tendencies to selectively “overgraze” riparian areas with utilization levels reaching 75-80% on gentling sloping drainages while steep slopes only 150 m away received 5% use or less (Phillips 1965 from Gillen et al. 1984). We found this to be the case on Sept. 9, 2009 when we toured the WMA (previous comments to FWP – GWA Field Trip). As well, many studies document that late or “hot” season grazing increases cattle use and preference of riparian meadows. The extreme preference cattle exhibited for meadow communities in the study conducted by Gillen et al. (1984) agrees with research from other mountain rangelands they reviewed (Bryant 1982, Long and Irwin 1982, Roath and Krueger 1982 all from Gillen et al. 1984). During the late season grazing period, cattle were found to prefer areas with less than 10% slope nearly 75% of the time, and cattle spent about 2/3 of their time in these areas even during the early grazing period. Clearly, cattle prefer riparian areas and the presence of these important habitats on the Robb-Ledford WMA makes them the major factor influencing livestock distribution regardless of the grazing system employed. Schulz and Leininger (1990) looked at the differences in riparian vegetation structure in Sheep Creek, a montane riparian zone in northcentral Colorado that had been previously heavily grazed by cattle. Riparian vegetation was measured in three 30 year cattle exclosures established in the mid 1950’s (2 exclosures were constructed in 1956 and 1 was constructed in 1959) and from an adjacent area with continued, but significantly reduced, grazing pressure. On the grazed side, cattle use was reduced from 1900 AUM’s in 1939 to 600 AUM’s at the date of the study (a 68.5% reduction). Photographs taken along Sheep Creek before fencing and Parker 3 step USFS data from 1959 indicated no differences in vegetative cover or composition and bare ground estimates across the entire riparian area. Therefore, changes in the riparian vegetation documented by this study, the authors concluded, can be assigned to the result of 30 years of livestock exclosure and 30 years of reduced stocking levels. Native wildlife, including deer and elk were not excluded from using the grazed or ungrazed riparian zones. The grazed area in this study showed increased herbaceous vegetation cover with reduced stocking rates, while the Sheep Creek exclosures showed significantly increased woody and herbaceous vegetation coverage and biomass. Photo plots and other data showed a considerable increase in aspen and willow growth in the exclosures between 1959 and 1964 (the first 5-8 years of livestock exclusion), while grazed plots with reduced stocking rates showed no difference between both years. This study showed greater density and 5.5 times more shrub canopy coverage in protected areas compared with areas receiving continued, but significantly reduced cattle grazing pressure. Canopy coverage of willow species was 8.5 times greater in the exclosures compared with the areas managed under significantly reduced grazing pressure. The authors concluded that woody plant species can increase rapidly when riparian areas are protected from livestock grazing. This was not the case, however, under continued livestock grazing use, even with significantly reduced stocking rates. Although rest is probably needed to reestablish healthy stands of shrubs such as willows in degraded riparian areas, the authors noted that considerable recovery can take place after only 5 years of livestock exclusion from the riparian zone. They cited Skovlin (1984) who recommended a 5 year rest followed by “proper” livestock management as a means of riparian area recovery. Proper livestock management, however, was not defined. The authors also cited work in Montana that found shrub production to be 13 times greater in control areas when compared to riparian sites grazed by cattle. The authors pointed to other studies that documented riparian ecosystems can improve relatively quickly, even after being degraded by heavy livestock use, if livestock are removed (Rickard and Cushing 1982). The authors also noted studies pointing to the value of intact aquatic ecosystems with abundant streamside vegetation that insure healthy fish populations (Kauffman and Krueger 1984). Livestock use, on the other hand, can increase erosion and reduce plant vigor, resulting in lower forage production and altered plant age structure and species composition (Knopf and Cannon 1982, Kauffman and Krueger 1984). Twenty nine years after fencing out cattle, abundant riparian vegetation within the exclosures concealed the stream channel of Sheep creek from view. The authors described Sheep creek as a typical headwater stream (4-5m width) in the Western United States. Litter cover in the protected areas was nearly 2 times that of the grazed plots, and the grazed areas had approximately 5 times as much bare ground as did the exclosures. Kentucky bluegrass, an exotic, rhizomatous invader, was favored by the grazing treatment as cover of Kentucky bluegrass was 4 times greater in the grazed areas as compared to the exclosures. The authors noted other values that had benefited from the exclusion of cattle from the riparian zone of Sheep Creek. They cited studies that showed non-game wildlife and fisheries habitat had changed as a result of cattle exclusion along Sheep Creek and that trout biomass and fishing opportunities were higher in the exclosures when compared to the grazed sections of Sheep Creek. The improvement in the woody structural component of the vegetation is essential for wildlife species that are obligate inhabitants of willow thickets such as the Wilson’s warbler. The recovery of the woody component also improved the fish habitat by increasing the hiding cover for fish and stabilizing the streambanks of Sheep creek. Schulz and Leininger (1990) concluded that extended rest from livestock grazing, on a previously degraded headwaters riparian area and trout stream, was shown to be an effective management practice for restoring woody vegetation, especially willow species. Stream bank stability, trout biomass and fishing opportunities were shown to increase with the recovery of the woody riparian vegetation. Continued livestock grazing, even with significantly reduced stocking levels (68.5% reduction), did not allow for woody vegetation recovery along Sheep Creek and the associated benefits of increased fish and wildlife habitat. This is critical research relevant to the decision on whether or not to subject degraded woody riparian areas on the WMA to reduced livestock impacts. Beaver: Beaver are a keystone riparian species (Naiman et al. 1986; Kay 1988; Wyoming Game and Fish Department 1993) and they have been extirpated from much of their former range (Kay 1988) including many areas within the WMA. Beaver created ponds and wetlands conserve water, prevent flooding, improve riparian vegetation and maintain water flows thus improving water quantity and quality (Skinner et al. 1984). Beaver still do exist on the WMA along limited portions of Robb and Ledford creeks but what of their historic distribution and ecological contribution to the area? This should be thoroughly reviewed in the EA because the number of beaver ponds alone may cause differences in stream flow and water quality (Skinner et al. 1984). More ponds yield more water flow and less bacterial counts thus leading to improved water quality (Skinner et al. 1984). Moreover, the impacts of cattle use to the beaver’s current and historic habitats have not been adequately reviewed in the EA. For example, the disappearance of beaver can dramatically affect riparian vegetation (Elmore and Beschta 1987) as well as a variety of bird species (Douglas et al. 1992). While reintroduction of beaver and protection from livestock use can dramatically benefit a number of riparian-wetland species (Kay 1988). As well, Clary and Medin (1990) documented significantly less grass biomass and height, more non-willow large shrub biomass and more soil compaction as the most obvious effects of cattle use within the riparian plant community they studied as compared to an area protected from livestock use for 11 years. “Heavy” cattle use had a major impact on aspen regeneration and stand structure. We are concerned that the scattered patches of aspen and serviceberry found in areas of higher moisture on the WMA (p. 13 EA) will be highly susceptible to heavy trampling and grazing by livestock even within a “properly” managed rest-rotation grazing system. We observed these circumstances on our field trip through the WMA on September 9th, 2009 (previous comments to FWP) and the impacts to fish and wildlife habitats were certainly not beneficial. How will the FWP account for these heavy use areas that are inevitable under any livestock use proposals? Furthermore, livestock use concentrated in riparian areas may disrupt the natural cycle between aspen and beaver by limiting or preventing aspen reproduction (Clary and Medin 1990; Kay 2001), which is a major food source for beaver. Indeed, DeByle and Winokur (1985) estimate that it takes about 200 aspen to support one beaver for one year. Interestingly, beavers are restricted to aspen and/or other species in the family Salicaceae, primarily willow for almost their entire winter food supply (DeByle and Winokur 1985). And, Clary and Medin (1990) found willow biomass was reduced by over 60% under a moderate livestock grazing regime as compared to the area protected from livestock use for 11 years. Thus, “proper” livestock grazing systems often result in the degradation of critically important fish and wildlife habitats that are localized on the landscape, but may have significant consequences to keystone species such as beaver. Beaver restoration and the habitats they create should be a priority on the Robb-Ledford WMA and livestock use can clearly be detrimental to achieving this goal. For example, Smith and Flake (1983) and Dieter and McCabe (1989) found grazing by domestic livestock on a prairie stream not only eliminated woody vegetation but also negatively impacted beaver populations as well. The combination of early trapping of beaver and livestock concentrations along riparian areas has lead to a conversion from native woody vegetation like willow, aspen, alder, dogwood and cottonwood (and herbaceous sedges and rushes) to more drought resistant exotic species such as Kentucky bluegrass, dandelion, and cheatgrass (Elmore and Beschta 1987). Some of these degraded conditions are still evident on the WMA, yet the EA implies more livestock use will heal past livestock use impacts. Schulz and Leininger (1990) did not find this to be the case with even a 68.5% reduction in livestock use over a 30 year time period. Aspen and Willow: Aspen is a key indicator of ecological conditions and aspen and other riparian communities provide a disproportionate amount of biological diversity relative to their abundance on the landscape (Thomas et al. 1979; DeByle and Winokur 1985; Mueggler 1988; White et al. 1998; Belsky et al. 1999; Jean et al. 2002; Hockett 2002; Wuerthner and Matteson 2002). Moose can actually markedly retard of even prevent the loss of aspen stands through their aggressive browsing of sub-alpine fir seedlings and saplings (DeByle and Winokur 1985). Sub-alpine fir is one of the major conifer species capable of invading and ultimately replacing seral aspen stands. The presence of moose may actually retard this conifer succession due to their selective browsing on sub-alpine fir trees (DeByle and Winokur 1985). However, moose can also damage aspen stands if heavy aspen browsing is allowed to occur year after year (Peak 1998). Thus the combination of summer, fall and hot season use of aspen/willow riparian areas by domestic cattle followed by additional winter browsing by moose (and elk for that matter) is a potentially significant consequence of all the proposed livestock use alternatives. These concerns should be reviewed and addressed in the EA and the selected alternative should avoid these cumulative effects to these critical wildlife habitats. Willows constitute the major forage source for moose across most of their range, and taller willows are often preferred, although virtually all species are eaten (Peek 1998). On Western ranges, willow bottoms provide important forage sources, and dogwood appears to be especially palatable. Grasses are not used substantially, but forbs may be highly preferred in some areas including southwest Montana. Throughout their range in North America, moose most commonly browse on birch, cottonwood, willow, aspen and balsam fir. They often consume serviceberry, mountain ash, honeysuckle and dogwood (Peek 1998). However, the physiological effect on woody plants is different if they are browsed during the growing season rather than while dormant. Removal of a significant portion of the plant early in the growing season, just after full leaf growth, would have the greatest impact on a shrub or tree seedling (DeByle and Winokur 1985). This is the time that cattle will be entering the WMA, while elk, moose and mule deer largely migrate off the WMA to higher elevations in the Snowcrest Mountains and elsewhere. Carbohydrate reserves are lowest at this time of year and repeated browsing of re-growth later in the same growing season would further weaken the plant (DeByle and Winokur 1985). Again, this will be the case for the scheduled livestock use periods. Whether the browsing occurs from beaver, mule deer, elk, moose, cattle or a combination of these mammals the effect to the plant is the same (Kay and Bartos 2000). Repeated browsing during the growing season is cumulative and when it occurs to aspen suckers it can limit or completely eliminate regeneration of aspen clones (DeByle and Winokur 1985). Domestic livestock browse aspen with increasing pressure and preference through summer and early fall (DeByle and Winokur 1985). This browsing can be severe, especially on young and succulent sprouts (DeByle and Winokur 1985). Livestock grazing also tends to shift plant species composition in the aspen understory to those of lower palatability. Direct effects of grazing include immediate removal of plant cover (an acute effect) and long term alteration of the plant community over time due to selective grazing pressure on the most desirable species in the mix. Both acute and long term grazing effects alter wildlife habitat in the aspen community type (DeByle and Winokur 1985) and these impacts can occur to the herbaceous and/or woody component. These impacts were not adequately reviewed in the EA and many sportsmen likely do not understand all the consequences of administering livestock use on the WMA. Furthermore, Kay (2001) has personally measured or otherwise evaluated
more than 40 aspen exclosures in the western U.S. and Canada. In all
cases where aspen has been protected from excessive browsing, aspen
has successfully regenerated and formed multi-aged stands without
fire or other disturbance. Schulz and Leininger (1990) also documented
that extended rest from livestock grazing, on a previously degraded
headwaters riparian area and trout stream was shown to be an effective
management practice for restoring woody vegetation, especially willow
species. Stream bank stability, trout biomass and fishing opportunities
were shown to increase with the recovery of the woody riparian vegetation.
Continued livestock grazing, even with significantly reduced stocking
levels (68.5% reduction), did not allow for woody vegetation recovery
along Sheep Creek and the associated benefits of increased fish and
wildlife habitat. However, many aspen stands in the absence of fire, are replaced by grass, forbs, shrubs or conifers (DeByle and Winokur 1985). Also, almost all even-aged stands of aspen in the West appear to be the result of severe fire, whether or not aspen is climax on the site. Aspen sites do not readily burn and aspen stands will commonly not burn at all. However, dated fire scars, historical records, and other evidence indicate before and during the 19th century, much larger acreages or aspen burned than have burned since. Clearly, there has been a great reduction in the rate of fire rejuvenation of aspen in the West (DeByle and Winokur 1985). This has resulted in a major and continuing change in the ages and structures of aspen stands and young stands of aspen are not common in the West (DeByle and Winokur 1985). Livestock grazing has been credited as the cause of major fuel reductions under aspen stands in the late 19th and early 20th century, when fire suppression activities were much less effective than they are today (Baker 1925 from DeByle and Winokur 1985). Domestic sheep can be especially hard on the understory of aspen stands. However, cattle and/or sheep grazing still annually reduce the supply of fine fuels in most of the western aspen forest land. In the absence of domestic livestock grazing, aspen stands typically support a heavy understory of herbaceous vegetation. Without these fine herbaceous fuels, fire will seldom burn through the aspen forest, resulting in older, even-aged stands that become derelict (DeByle and Winokur 1985). Although aspen and willow stands may be greatly limited in their abundance on the WMA they are critical fish and wildlife habitats that we encourage FWP to recognize and manage accordingly. The potential impacts from livestock use are probably not well understood by many sportsmen and other members of the public and these impacts should be revealed in the EA. For example, are the aspen and willow stands on the WMA expressing their native potential or are they being limited by livestock use during the growing season? The wildlife that depend on these wetland habitats are also adversely impacted by livestock use. Movements of ruffed grouse broods, for example, from areas grazed by livestock to areas protected from livestock use in aspen ranges have been documented by Robertson (1976). Ruffed grouse are listed as an occasional user of the WMA (p. 21, EA), thus an opportunity to improve the habitat for ruffed grouse appears to exist on the WMA. Sage grouse, especially young broods depend on interspersed riparian areas throughout the sagebrush grasslands (Hockett 2002) and other ground nesting birds can be adversely impacted by livestock grazing prior to or during the nesting season. Above ground small mammal habitat can also be severely depleted by livestock use as well. Cover and forage for the native grazers in the small mammal community can be severely depleted and predation made easier. These effects of grazing livestock may alter populations and relative species abundance in the small mammal and bird communities (DeByle and Winokur 1985). FWP has not analyzed these effects in the EA and thus biases the review in favor of domestic livestock over native wildlife. Sagebrush Health and Conifer Encroachment: Livestock use can also impact natural fire regimes and thus forest succession and conifer encroachment into sagebrush and/or aspen habitats (DeByle and Winokur 1985; Arno and Gruell 1986). Selective livestock grazing, especially during the spring and summer can also reduce climax bunchgrasses within sagebrush ranges and promotes soil disturbance that is favorable for sagebrush to increase in abundance and encroach into adjacent grassland and riparian-wetland sites (Gruell et al. 1986). Some of the sagebrush-grassland sites we observed on the WMA appeared to be heavily dominated by sagebrush to the point of limiting productivity for birds like sage grouse. What is the density of sagebrush stands in areas used by livestock? Dense sagebrush stands also provide favorable microsites for regeneration of Douglas-fir seedlings. Sagebrush and Douglas-fir plants are generally and relatively unpalatable to livestock, therefore gaining a competitive advantage on grazed ranges. On the edges of climax conifer sites, trees become established and encroach into sagebrush-grasslands due to lack of competition from bunchgrasses and because fine fuels have been consumed by livestock, effectively removing natural fire as a controlling agent (Gruell et al. 1986). Are conifers encroaching into sagebrush grasslands anywhere on the WMA? Robertson (1971) documented that 30 years of rest from livestock use (1940 - 1970) enabled an eroded tract of sagebrush-grass range in northern Nevada to increase all life forms of vegetative cover. The total cover of perennial forbs increased the most at 85% and was described as “spectacular”. Important perennial bunchgrasses also increased with percent cover of Thurber needlegrass increasing 7 fold (726%) while bluebunch wheatgrass also reestablished naturally into areas it had been absent. A number of native perennial forbs, which were so scarce in 1940 they were not even estimated by species, showed significant benefit from protection from grazing livestock. These included false yarrow, tapertip hawksbeard, fleabane, desert parsley, stony-ground lupine and aster. Other forb species that showed up in 1970 in trace amounts included wild onion, sego lily, thistle, wild lettuce and foothill death camas. Vigorous bunches of bluebunch wheatgrass were apparent in 1970 and were considered a significant indicator of upland trend, suggesting this excellent forage species was originally prominent on the site. As well the significant increase in perennial forbs and decrease in annual forbs was believed to reflect a continuing process of secondary succession in which the former balance among life forms is being restored since the cessation of domestic livestock use. The authors noted the doubling in area of the mat forming phlox as an “ecological salve” for a sore soil. The plot data monitored by Roberston (1971) for 30 years clearly indicated forage cover on a depleted sagebrush range can be significantly improved by long term rest from livestock use. This improvement occurred for native perennial grasses, forbs and shrubs. The native grass species that increased with cessation of grazing were the more productive, taller species. However, if forage production for livestock is the only goal, ranges cleared of shrubs (big sagebrush), native forbs and grasses and then seeded to crested wheatgrass were far superior in grass forage production over native rangelands. Sage Grouse: Sage grouse are a bird of climax vegetation (Patterson 1952; Peterson 1995; Hockett 2002) and livestock use in sagebrush grasslands removes important herbaceous vegetation critical for nesting cover and forage, especially for young broods (Patterson 1952; Call 1974; Connelly and Braun 1997; Connelly et al. 1999; Beck and Mitchell 2000; Hockett 2002). Braun (1987) documented that across its range the majority of sage grouse habitat is grazed by domestic livestock while areas protected from livestock impacts are lacking (Braun 1998). Long-term population declines of sage grouse in southwest Montana have been documented for some time, but habitat quality and distribution have not been adequately investigated (Roscoe 2002). We are concerned that many sagebrush grasslands on the WMA and elsewhere have been degraded from climax conditions due to historic livestock use and perhaps other means (historical spraying, fire, mechanical removal, plowing, and water diversion/irrigation) (Roscoe 2002). Sometimes these stands may have too much sagebrush and other times not enough, if any. Both of these conditions can adversely impact sage grouse and other wildlife dependent on the sagebrush grassland community. These impacts and conditions are often the result of current or historical livestock use and they were not adequately researched and reviewed in the EA. For example was basin big sagebrush an historic component of lowland sagebrush habitats that has largely been removed due to past farming/haying operations? What efforts in the past have been used to control/eradicate sagebrush from the WMA? As well, what effects have livestock use had on the density of sagebrush stands in areas preferred by livestock? Livestock preference for the herbaceous component within the sagebrush grasslands can significantly impact the overall makeup of the community over time (Mueggler 1950; Laycock 1967; Johnson 1969; Anderson and Holte 1981; Knick 1999; Bunting et al. 2002; Hockett 2002; Wuerthner and Matteson 2002; Welch 2005) and these impacts should be analyzed in the EA. Klebenow (1969) found the densest stands of sagebrush on his study site in southeastern Idaho were not used by broods, probably because few if any of the preferred forbs the young grouse fed upon were present. Only 3 of 98 broods were discovered in areas with greater than 31% shrubby cover. As the summer progressed, broods moved up in elevation following a gradient of green herbaceous food plants. What is the makeup of the dense sagebrush stands on the WMA? Has the FWP mapped out the various habitat types to get a sense of what is possible versus what is currently present on the WMA (Passey and Hugie 1963)? Klebenow (1969) also found that grasses had a significantly higher (P<0.10) percent basal area on sage grouse nesting sites than on non-nesting sites. Large bunch grasses and forbs growing adjacent to shrubs (three-tip and big sagebrush in this case) provided additional cover for sage grouse nests. Arrowleaf balsamroot and tailcup lupine were specifically mentioned as forbs that provided supplemental nesting cover in conjunction with shrub overstory. The percent of litter was also greatest on nesting sites. The author believed that grouse may select nesting areas within sagebrush sites with denser than normal herbaceous plant cover. Has the livestock use program on the WMA resulted in these desired sage grouse habitat conditions in preferred nesting areas? Does the FWP even now where the preferred sage grouse nesting areas are on the WMA? Importantly, Prellwitz (2002) documents that sage grouse continue to persist at Bowdoin National Wildlife Refuge even though sage grouse habitat may be less than optimal due to a low density of plains silver sagebrush in grassland habitats. Interestingly, most of this refuge has been protected from livestock since the mid 1970’s. However, pronghorn antelope heavily browse much of the plains silver sagebrush annually. The sage grouse choosing to breed and nest on Bowdoin NWR appear to be productive with good survival of chicks, despite no big sagebrush and less than optimal cover of plains silver sagebrush. The refuge is located 32 km (19.8 miles) from prime big sagebrush and plains silver sagebrush habitat. Sage grouse strutting grounds have been documented within 32 km of the refuge. The author suggested that sage grouse may be dispersing from those large blocks of sagebrush to better nesting conditions on the ungrazed refuge. Predation rates on prairie grouse habitats are impacted by livestock use because this use affects the amount of herbaceous cover available for hiding both during the season of use and potentially during the following spring (residual cover for nesting). Gregg (1991) documented that predation can become a significant problem when nesting habitat for sage grouse, which is enhanced by a tall dense herbaceous understory within the sagebrush community, is in poor condition. Connelly et al. (1991) also recognized the importance of dense herbaceous cover to nesting sage grouse hens. The authors concluded that herbaceous cover may be more important to nesting hens than previously thought, even to the point of enticing sage grouse to utilize non-sagebrush nest sites if herbaceous cover is lacking under sagebrush plants. Patterson (1952) noted that sage grouse prefer to squat and hide when danger is close at hand and numerous authors have pointed out the importance of residual herbaceous cover in the presence of sagebrush stands for secure nesting habitat (Klebenow 1969; Gregg 1991; Gregg et al. 1994; Connelly et al. 1999; Beck and Mitchell 2000; Hockett 2002). Schroeder and Baydeck (2001) point out the consequences of predation on the population dynamics of prairie grouse are often considered to be substantial enough that the effective management of prairie grouse requires the direct and indirect [meaning habitat] manipulation of predation pressure. They concluded though habitat management has been a dominant tool to manage effects of predators on populations of prairie grouse in North America, with documented success. Determination and provision of key habitat components to meet seasonal requirements for local populations of individual species has been shown to be an effective and efficient management strategy. Schroeder and Baydeck (2001) never recommended predator control as a substitute for habitat management; predator control is clearly not a preferred alternative. They suggested management of habitats of sufficient quantity, quality, and integrity offers the best long-term opportunity to support viable populations of prairie grouse. Indeed, Connelly et al. (2000) recommends a minimum of 18 cm (7”) of herbaceous forb and grass cover in breeding habitats for sage grouse, which are characterized as having a canopy of 15-25% sagebrush, 40-80 cm (16-31”) in height. Similar herbaceous cover recommendations were made for blue grouse brood rearing habitat in southwest Montana (Mussehl 1963) and Brown (1961) documented that sharp-tailed grouse preferred areas with 11” of average herbaceous cover on the brood range he studied in eastern Montana. As well, Brown (1982) documented detrimental effects of commonly accepted livestock grazing systems on Mearns quail in southeastern Arizona. The authors felt general herbaceous cover requirements were critical for hiding cover because the Mearns quail initial reaction to danger is to “freeze”. This behavior has also been documented for sage grouse (Patterson 1952). Although effective in dense cover, this escape mechanism is useless and even detrimental once grass cover has been seriously reduced. This has negative implications for grazing systems such as rest-rotation that alter seasons of use in an attempt to manage vegetation, but may not take into the acute effects to ground dwelling/nesting birds. Klott et al. (1993) provides insight into the potential conflicts associated with rotational grazing systems on important seasonal habitats used by sage grouse as well as a regionally important winter range. The plant list compiled by Klott et al. (1993) from nesting, brood rearing and random sites showed an incredible diversity of forb species with over 85 species identified, 19 different grasses and 10 different shrub species. In brood rearing areas, the number of herbaceous species and plant species richness were greater than at random sites. Sage grouse nesting occurred where grazing utilization levels were slight and livestock were not present. Sage grouse brood rearing occurred where livestock use levels were light or less, however no movements by sage grouse with broods away from areas with livestock were detected. Livestock use of wet meadow, riparian and aspen habitat types was high. The remaining uplands fell into the moderate use category, revealing the tendency of domestic livestock to selectively concentrate their use in riparian and mesic sites in the summer and fall even within “proper” grazing systems. Utilization categories were described as none, slight, light, moderate, heavy and severe. Areas with livestock present in Wyoming big sagebrush and low sagebrush habitats had less grass cover, less grass height, lower numbers of herbaceous species, less litter, lower Robel pole readings (a method for measuring cover effectiveness) and more bare ground. The authors concluded that low utilization levels in nesting and brood rearing habitat allowed for adequate residual herbaceous vegetation for nesting cover, however more research on the impacts of both grazing season of use and utilization levels on sage grouse habitat is needed. Klebenow (1969) also concluded the condition of the understory affects the suitability of an area for nesting. Broods need herbaceous food sources in addition to cover, therefore management actions that remove food sources even though shrubs remain can be expected to eliminate sage grouse broods. Sage grouse did not nest in, nor did broods occupy, areas of tall, dense sagebrush with little understory. The author concluded that areas of tall, dense sagebrush with depleted understories were of no value to nesting hens and young broods. When food plants dried, broods either migrated up in elevation to more mesic summer brood rearing habitat or moved daily to green vegetation along a creek that flowed through the area. Sage grouse were definitely responding to their need for succulent, green vegetation during the summer months. When these foods were no longer available they left in search for food. The author noted the more mesic sites (slight drainages and depressions) were the most productive brood rearing sites for sage grouse and he recommended these areas be left undisturbed. He also recognized these sites as being preferred areas by livestock indicating that careful management was in order in areas used by livestock. Field examinations in early July indicated these moist sites within the overall sagebrush landscape still had green, succulent forbs after surrounding upland vegetation had cured. The author felt sage grouse preferred sagebrush ranges which provided a relatively open stand of sagebrush, good understory of perennial grasses and diversity of forbs, abundant forage, well-protected soils and “climax” cover. Has the livestock use program provided these conditions over the past 10 years in the primary areas of sage grouse use? We refer FWP to Ross and Hunter (1976) for a discussion on climax plant communities in Montana. Dobkin (1995) and Hockett (2002) note the importance of interspersed riparian habitats as critical components of sage grouse habitats and the potential deleterious effects of livestock use. According to Dobkin (1995) the most critical seasonally required habitat type for sage grouse by virtue of its loss throughout the geographic range of the species is brood habitat. Restoration of this type of habitat would achieve the greatest benefit not only for sage grouse but for a wide array of other wildlife species, as well. Restoration should include modification of former range improvements, in order to provide livestock-free wet meadows where natural springs previously existed (Dobkin 1995 and Hockett 2002). And even though Crowley and Connelly (1996) have documented long term downward trends for sage grouse in this region FWP has yet to complete adequate local population and habitat surveys for native sage, blue (dusky), sharp-tailed and ruffed grouse as well as the variety of non-game birds using the WMA. While this lack of wildlife work begs for consideration, FWP has committed years of effort, hundreds of thousands of sportsmen’s dollars and numerous hours and field time attempting to develop a workable livestock grazing proposal. We believe an economic and ecologic FWP priority check is in order. For example, we are concerned FWP has not effectively monitored the trends for increasingly rare upland game birds on the WMA. FWP has owned the WMA for over 20 years and the emphasis still seems to be on livestock management and/or mitigation. What has the hunter harvest data for sage grouse on the WMA been over these years? We are concerned about the decline/loss of hunting opportunity for all native upland grouse, but in particular sage grouse. Upland Game Bird Harvest Data: Blue grouse, sage grouse, occasional ruffed grouse, and Hungarian partridge occur on the WMA, but no population estimates have been made for these species (EA, page 21). We suggest ongoing surveys for these upland game birds need to be started on the WMA. The U.S. Fish & Wildlife Service (1992) documents hundreds if not thousands of sage grouse used to occupy the Red Rock Lakes National Wildlife Refuge in the nearby Centennial Valley at various times of year. Some data we found on upland game bird harvest trends in Montana came from Montana FWP (1991). This report presented to the Montana Fish and Game Commission focused on upland game bird harvest management in Montana. On page 56 of this report the dramatic decline in sage grouse harvest in Montana from 1958 to 1989 is graphically illustrated. A high of approximately 100,000 birds were harvested in the 1960’s, while a low near 10,000 birds harvested is shown for the mid 1980’s. Dramatic declines in ruffed grouse harvest are shown as well. On page 53 high harvest estimates for ruffed grouse approximate 90,000 birds in the mid 1960’s dropping to lows of around 20,000 birds in the early 1980’s. Idaho Department of Fish and Game data since 1950 show a long term population decline for number of active leks, number of males displaying on leks, and numbers of sage grouse harvested by hunters (Klott et al. 1993). A look at sage grouse peak harvest data from the area shows a dramatic 92% decline from 1950 to 1990 (1950 (2,832), 1970 (739), 1979 (472), and 1990 (221)). Since 1985 the harvest data has remained low even though the hunting season has increased from 9 to 30 days. The majority of this sage grouse habitat in Idaho is grazed by domestic livestock (Klott et al. 1993). Other Birds: Douglas et al. (1992) concluded that what appear as subtle changes to riparian areas from activities such as cattle grazing, timber harvest or water diversion may have severe impacts on the bird community. Indeed, dramatic vegetation successional changes can occur when the stress of livestock grazing is removed from riparian ecosystems (Leege et al. 1981; Kauffman et al. 1983; Clary and Medin 1990). If habitat deterioration is not severe, herbaceous vegetation can greatly increase within several growing seasons (Platts and Nelson 1984). Krueper et al. (2003) found that removing cattle impacts from riparian habitats in the Arizona can have profound benefits for breeding birds. The general findings of this paper indicate the protection of areas previously grazed by domestic livestock resulted in increases in all groups of birds studied (insectivores, granivores, omnivores, short-distant migrants, long-distance migrants, Neotropical migrants, residents, open cup nesters and cavity nesters). Insectivores and Neotropical migrants showed the greatest increase in response to protection from grazing, but all categories showed highly significant increases. Several bird species of high conservation concern showed positive responses to protection from cattle grazing. As well, the density of herbaceous vegetation increased four to six fold in riparian and upland grassland communities which has significant implications for watershed protection and biological diversity of other species. While Krueper et al. (2003) found little change in the density of shrubs or trees in any of the plant communities they studied others have documented woody vegetation can recover dramatically within 5 to 10 years of livestock protection (Rickard and Cushing 1982, Skovlin 1984). Krueper et al. (2003) found the speed, magnitude and extent of the recovery through protection from livestock impacts was surprising and suggests even severely degraded systems, at least in some cases, can recover quickly just by removing livestock impacts. However, severe habitat deterioration can require protection from livestock for decades or more (Knopf and Cannon 1982; Platts and Raleigh 1984). Taylor (1986) studied the effects of cattle grazing and exclosures to passerine birds (perching song birds) and their habitat on the Malheur National Wildlife Refuge (MNWR) in southeast Oregon. Nine transects were established along the Blitzen River with different histories of cattle grazing. The riparian habitat was characterized as having shrubby stringers of willow along various waterways including the Blitzen River. Increased frequency of grazing on an annual basis correlated significantly with decreases in bird abundance, shrub volume, and shrub heights. The longer the time since a transect was last grazed correlated significantly with increases in bird abundance, shrub volume and shrub height. Bird abundance increased significantly with increased shrub volume and taller shrub heights. Bird species richness decreased with increased grazing. Bird counts were 5-7 times greater on an ungrazed area protected since 1940 then on 2 areas grazed annually until 1980 and then fenced off. The ungrazed area also supported 11-13 times more birds than on a severely disturbed site that was excessively grazed and dredged. The area protected from livestock grazing for 40 years had 10 times as much shrub volume as the four most heavily grazed areas. Shrub volume had a significant negative correlation with frequency of grazing, and the time since a transect was last grazed was positively and significantly correlated with shrub volume. The amount of tall shrubs were also much higher on the areas protected from grazing, including the area protected for 40 years, an area protected for 10 years and an area protected for 5 years (except one year of winter grazing). The only bird that may have benefited from disturbance of willows by grazing was the killdeer. Bird species that were more abundant or limited to undisturbed or rarely grazed areas included the great horned owl, eastern kingbird, willow flycatcher, yellow warbler, red-winged blackbird, brown-headed cowbird, and northern oriole. The data in this paper clearly showed that undisturbed willow riparian areas with tall and voluminous shrubs support large populations and more species of birds. Bird populations and species richness increased with shrub heights and greater volume, and birds and shrubs both decreased with grazing. These results compare favorably with Duff (1979), who found that after 4 years raptors and passerines increased by 350% within an exclosure versus adjacent grazed areas. This large increase was associated with the reestablishment of a middle story of willow. Disruption of Hunting, Camping and Fishing Seasons: All livestock use alternatives begin either in June or July and extend at least through October 15th. These livestock use periods conflict with prime fishing and camping seasons as well as archery big game seasons, upland game bird seasons and the opening weekend of antelope rifle season. In two grazing alternatives, cattle would be on the WMA until 2 days before the regular big-game season, which conflicts with the opening week to 10 days of antelope rifle season. We have found cattle use to be concentrated in otherwise prime camping and picnic locations. We have also observed concentrated cattle use in some of our favored fishing and hunting locations. As well, livestock degrade habitats important to antelope, mule deer, elk and moose and the hunting experience during the early fall archery season. None of the livestock use alternatives mitigate these negative impacts to summer and early fall hunting, camping and fishing opportunities. Livestock Management Infrastructure: All infrastructures needed to “properly” manage livestock should be clearly displayed on a map in the EA so the public can get a sense of the degree of complexity/development on the WMA related to livestock use. Vegetation communities can be significantly impacted around roads, fences, water, corrals, salting areas and stock trailing lanes (Stoddart et al. 1975). Such developments increase livestock concentrations, forage use, trailing and soil compaction, and in the case of stock water developments these impacts often occur up to a distance of about 0.8 km (0.5 miles) from the tank (Valentine 1947). Non-native plants often invade and dominate such sites, but there may be extensive areas of bare ground as well. Thus, the locations of these livestock developments should be mapped for public disclosure and reviewed thoroughly in the EA. Water Diversions/Developments for Livestock: There has been a significant amount of water diversion/development infrastructure required in an attempt to mitigate the impacts of cattle use in sensitive riparian areas. The 1999 livestock grazing plan committed over $617,000 sportsmen’s/wildlife dollars to livestock mitigation projects such as fences, water diversion, pipelines, water tanks, cattle guards, etc. Most of these livestock use projects were completed by 2008 according to the draft EA and some $486,936.32 has been spent to date. These livestock management activities and facilities, fragment fish and wildlife habitats, disturb important wetlands and uplands, concentrate livestock use into areas seldom used otherwise and/or divert/alter important water sources critical for native fish, wildlife and plants. For example, FWP agreed to divert water from Kelly Springs in the Robb creek watershed into a costly 40 mile long buried pipeline and livestock water development that feeds 42 stock tanks along wind blown ridges that are critical elk, mule deer and antelope winter range. This was supposed to mitigate the impacts of livestock use to sensitive riparian areas, which are critical habitat for native fish, wildlife and plants however, the unacceptable livestock impacts persist. Know we are told FWP needs to spend an additional $43,271 on riparian fencing in Robb creek to prevent cows from trampling the stream. Many other such impacts, such as the heavy cattle use in Rock creek and various aspen/willow habitat types spread throughout the WMA have not been revealed in the EA. There are also important questions related to water rights that have not be answered in the EA. The EA (p. 17) notes: “FWP acquired 22 water rights consisting of one stock watering right and 21 irrigation rights when it purchased the property in the late 1980’s. The sources for the irrigation rights are Ledford, Robb, Warm Springs creeks and a tributary spring to the W. F. Ruby Creek.” However, Kelly Springs used to be a tributary to Robb creek, and it is unclear how much water is diverted into pipelines and stock tanks for livestock in other drainages as a result of the Kelly Springs water diversion project. Who owns and controls the water rights to Kelly Spring? Is FWP being compensated for the use of this water by cattle? And, since the hunting public was told the primary purpose of spending hundreds of thousands of dollars of sportsmen’s money to build the Kelly Springs water diversion was to protect important riparian and fish habitats, how does FWP continue to justify this project when Robb, Ledford and Rock creeks and numerous aspen and willow riparian areas are still being trampled by cattle? Furthermore, most of this effort to distribute livestock into upland habitats, which are critical winter ranges for big game and important seasonal habitats for other wildlife just creates new problems where none existed before. Sage grouse, blue grouse, antelope, elk and mule deer are resident to the WMA and redistributing livestock into upland habitats via water developments, salting, herding and/or fencing to protect streams has its impacts on these species as well. The ecological costs of livestock water developments to wildlife, wildlife habitat, natural hydrologic function, soils and accelerated erosion, native plant communities, and even predation can be locally significant (Austin 2003). Such developments designed to draw livestock into upland habitats and ridges can be especially detrimental to sage grouse (Dobkin 1995; Hockett 2002), bighorn sheep (Taylor 2001), antelope (Pyrah 1987), mule deer (Kie et al. 1991), elk (Morris 1956; Thomas and Toweill 1982) and other wildlife (Fleischner et al. 1994). Heavy use of vegetation around watering points is well documented; two long-term studies show that forage production is most severely reduced in the zone within 0.5 mi (0.8 km) of water (Valentine 1947; Fusco et al. 1995). This concentrated livestock use around stock tanks becomes a sore spot for weeds and other exotic plants to establish a foothold on the WMA. These impacts were not adequately mapped and addressed in the EA. Fences: It should be clearly stated that all the fences present on the WMA are needed to control/mitigate the impacts of livestock use. In others words without the livestock presence on the landscape we would not need the fences. We assert there are no good fences for wildlife and many of the existing fences would not be needed if the no action alternative were selected. While some fences are less intrusive and/or threatening to wildlife, wildlife generally are better off without them. For example, antelope did not evolve with fences they evolved in areas where they can run 50 miles an hour to escape threats. Fences fragment their habitat and can increase predation of pronghorn (antelope) fawns (U.S. Fish and Wildlife Service 1993). Other sources of known wildlife fatalities attributed to fences on the Hart Mountain Wildlife Refuge in Nevada include waterfowl, prairie falcon and sage grouse. Fences on bighorn sheep range can restrict movements and cause mortality. Rams are more often affected than ewes because of horn size (U.S. Fish and Wildlife Service 1993). Whithorn (2001) shows a photograph taken in April 1959 of a full curl bighorn ram, which died after struggling to free itself from a barbed wire fence in the Paradise Valley. Elk and mule deer also can get tangled up in fences and die. How many wildlife die or are adversely impacted by fences on the Robb-Ledford WMA? Jack Jones from Butte has a tremendous amount of information on fence impacts to wildlife and this was a major point of concern/discussion at a field trip on the WMA back in 2004. GWA members attended that tour and we agree with Jack that there are significant fence related wildlife impacts on the WMA. These consequences of fences related to livestock management should be fully analyzed in the EA. A map of all the fences needed for each alternative should be displayed in the EA. As well, if the no action alternative is selected all the internal fences and a majority if not all the boundary fences between the Robb-Ledford WMA and the Blacktail WMA could and should come down, improving the habitat and migration routes for wildlife. How many miles of fence would that be and where is it currently located? Furthermore the EA implies that a whole bunch of fencing would be required to implement the no action alternative and this would come at a very high cost ($172,500). The Ea on page 28 states: “This alternative [no action] will not have the new construction costs related to the water gap fence along Robb Creek, but this alternative would require FWP to install a fence along the McGuire property border to keep the Association’s cattle from grazing on the WMA. This boundary fence could cost as much as $120,000 for its 12-mile length. Additionally, there is no boundary fence separating BLM and WMA lands in the Taylor Creek Drainage. Assuming BLM continues to graze this area, FWP would likely need to install 5.25 miles of additional boundary fence. This cost would be approximately $52,500.” We disagree with this assessment and contend numerous alternatives exist to address these potential boundary issues, including retiring the BLM allotment, exchange of use agreements, temporary electric fence or other good neighbor solutions. Regardless, FWP has and will continue to spend hundred’s of thousands of dollars trying to manage and monitor fenced livestock use on the WMA under the grazing alternatives, so spending a little to protect the habitat for fish and wildlife seems pretty reasonable, if it is truly needed. However if fencing is necessary to protect the integrity of the WMA, then the no action alternative (alternative E) should evaluate the cost and feasibility of utilizing a “wildlife friendly” one or two strand temporary electric fence as outlined in the FWP brochure developed by Paige (2008). The elevated cost of permanent fences unfairly portrays the no action alternative as unreasonably expensive, especially when these fences may not even be needed. Furthermore, temporary electric fence is much cheaper and is more wildlife friendly than permanent barbed wire fencing. It would also only be needed while the cows are on the adjacent pastures of concern and then it could be taken down so it does not interfere with wildlife movements across the area during the rest of the year. FWP could also use this opportunity to observe the differences between fenced livestock use and free roaming wildlife use. This might prove educational on a number of fronts. Additionally, we oppose the riparian fence proposed in alternatives A, B & C for portions of Robb creek, which will cost at least another $43,721 of sportsmen’s dollars not to mention the maintenance costs and wildlife costs (entanglement) down the road. This is just one of many riparian areas that have been adversely impacted by livestock use on the WMA. It is a band-aid approach to a much bigger problem. The proposed rest-rotation livestock use system will just keep distributing these acute impacts around the WMA at various times of year. Long term recovery is needed and has not resulted from the last 18 years of livestock management on the WMA, especially as compared to no action. Thus, FWP needs to reevaluate the need for livestock use on the WMA. It has also been our experience over the years that fences in big game wildlife habitat seldom hold up very long and trespass livestock use results anyway. We refer you to Duff (1979) where riparian habitat along Big Creek in Utah recovered dramatically to 4 years of protection from livestock grazing only to return to pre-rest, degraded conditions after only 6 weeks of trespass livestock use. While we agree the protection of the riparian areas like Robb creek from congregated livestock use will likely yield dramatic results, fencing just Robb creek ignores the overriding issue of livestock impacts to riparian-wetland areas in general throughout the WMA. Roads: There is an unusually large amount of roads generally trending north and south on the WMA with a number of cut acrosses that connect these main roads. These roads are used as a part of the livestock management operation as well as the domestic sheep trailing through the Notch. Roads have a number of potential impacts to fish (Loftus and Flather 2000) and wildlife habitat, including adversely impacting elk vulnerability (Leptich and Zager 1991; Marcum and Edge 1991; Moroz 1991; Hamlin and Ross 2002). The extent and importance of road impacts to fish and wildlife were not adequately analyzed in the EA. A map of all the roads should be displayed in the EA. Exotic Plants: “Weeds” are identified generally as a problem and/or a management challenge on the WMA, but specific details are lacking. The native plant communities associated with sagebrush/grassland habitat type are extremely susceptible to exotic plant invasion as well (Harrington 2002). Cheatgrass in particular can be a significant problem in many sagebrush communities (Davis et al. 2002). Cheatgrass is an introduced annual grass that invades disturbed sites and many of the livestock management practices and infrastructures (trailing, herding, fences, roads, stock tanks, corrals, etc.) contribute to the spread of this non-native species. While there is some discussion about noxious weeds, the impacts of livestock use specifically on the perpetuation of weed problems on the WMA are not discussed adequately. For example, Belsky and Gelbard (2000) conducted a scientific literature review of the relationship of livestock grazing to the invasion of non native plant species in the arid and semi-arid lands west of the Rocky Mountains. “At the landscape and regional scales, livestock grazing is one of several factors causing and enhancing the invasion of alien weeds into grasslands, shrubland and woodland communities; but at the community scale, livestock may be the major factor causing these invasions. Most studies find that plant communities grazed by domestic livestock contain a greater density, frequency, or cover of nonindigenous plants than ungrazed communities. A few studies document positive, but only temporary, reductions of weed numbers by sheep and goats, but most weedy species are avoided by cattle.” The EA (p. 6) notes: “Non-native plants are present on the WMA but in small amounts and are not causing a negative shift in plant compositions.” We find this assertion to be an over simplification of the actual condition of many riparian areas on the WMA (See Appendix E of the EA). We suggest the EA lists all the non-native plants that can be found on the WMA and their whereabouts characterized as best as possible. In particular the presence of Kentucky bluegrass, timothy, Canada thistle, dandelion, hound’s tongue, spotted knapweed, whitetop, common tansy, ox-eye daisy and a variety of annual plants appeared nearly ubiquitous in areas disturbed by livestock and they represent a serious alteration of habitat and loss of native bio-diversity (Appendix E, EA; Noss et al. 1997). Branson and Lommasson (1958) conducted an “improved” livestock grazing study on the east slope of the Bridger Mountains near Bozeman Montana which had been heavily grazed by both sheep and cattle prior to 1926. The study lasted 23 years and although total forage yields increased greatly at the three lower elevation sites it was primarily due to invasion by livestock tolerant exotic species like Kentucky bluegrass, timothy, Canada thistle and common dandelion. Native forbs did not appear to benefit from improved grazing management as most native forbs decreased over the 23 year grazing period. The percent of total forbs decreased by over half at the lowest elevation site, by nearly half at the mid elevation site and remained static at the two higher elevation sites. This study illustrates the extremely competitive nature of exotic invaders such as Kentucky bluegrass, timothy, Canada thistle and common dandelion under “properly grazed” and seasonally regulated grazing systems. These exotic species are prevalent in cattle use areas on the WMA. How will the proposed alternatives affect these exotic species? The EA further notes on page 6: “Noxious weeds that have been identified on the WMA include: spotted knapweed, Canadian thistle, field scabiosa, blackleaf henbane, hound’s tongue, musk thistle, and mullen. The largest and most dispersed infestation of noxious weed is hound’s tongue. The other varieties are found in smaller amounts, and no leafy spurge has been identified on the WMA.” It has been our experience and it has been well documented in the literature that both noxious weeds and other exotic plants establish themselves in areas of concentrated livestock disturbance (Fleischner et al. 1994; Belsky et al. 1999; Wuerthner and Matteson 2002). Again, we suggest it is extremely relevant to the question of whether livestock management is appropriate on the WMA to map out the locations of the noxious weed infestations as best as possible to get a sense if they are at all related to the presence and/or concentration of livestock use or the infrastructures necessary to properly manage livestock use. The EA notes on page 15: “The spread of noxious weeds within the WMA is controlled and managed primarily through the application of herbicides per the guidance of the 2008 Integrated Noxious Weed Management Plan and the regional weed management plan. Through annual inventories and strategic applications, spotted knapweed is contained and limited to specific areas. Other noxious weed infestations continue to challenge WMA staff, especially along riparian areas where the application of herbicides is difficult to use.” Herbicide applications can impact non-target species and have other unintended consequences to fish and wildlife. These annual weed inventories and strategic herbicide application sites should be displayed in the EA. Exotic species such as spotted knapweed, hounds tongue, Canada thistle, cheatgrass, Kentucky bluegrass, Timothy, dandelion and other non-native plants can have a dramatic impact on native plant communities and the fish and wildlife that depend on them. Kentucky bluegrass in particular is very resistant to livestock use and thrives in heavy use areas (Roath and Krueger 1982). We have personally observed over the years that these and other non-native plants often increase, sometimes dramatically, when lands are subjected to livestock use impacts. We would like to see the department promote the restoration and conservation of native plants, fish and wildlife species on the WMA, while also promoting properly functioning riparian-wetland areas and clean, cool water. We think the department should pick the alternative that best serves these goals. Exotic Livestock Diseases: Grazing associations are notorious for increased disease issues in livestock as numerous herds are mixed together enhancing the probability of disease transmission between animals. Livestock diseases are a significant problem for bighorn sheep (Montana 2009) as well as bison and may pose additional problems for other wildlife. We find the disease mitigation measures on page 6 of the EA insufficient in ensuring wildlife are protected from livestock diseases that may be imported onto the WMA with any of the livestock use alternatives as well as the domestic sheep trailing. We suggest any and all domestic livestock entering the WMA be tested and determined disease-free before being allowed to enter. Cattle and domestic sheep both carry numerous exotic diseases that can be transferred to and have been found in native wildlife (Hamlin and Ross 2002; Dubay et al. 2003; Montana 2009). These effects and consequences of administering a livestock use program on the WMA were not and should be reviewed in the EA. Forest Health: Livestock use can also disturbs soils and adversely influence forest dynamics of upland pine and mixed conifer forests (Belsky and Blumenthal 1997) as well as adjacent mountain grasslands (Arno and Gruell 1986). Conifer encroachment into mountain grasslands has negative implications for historic bighorn sheep habitat (Montana FWP 2009). Livestock alter forest dynamics by (1) reducing the biomass and density of understory grasses and sedges, which otherwise out-compete conifer seedlings and prevent dense tree recruitment, and (2) reducing the abundance of fine fuels, which formerly carried low-intensity fires through forests (Belsky and Blumenthal 1997). Grazing by domestic livestock has thereby contributed to increasingly dense western forests and to changes in tree species composition. In addition, exclosure studies have shown that livestock alter ecosystem processes by reducing the cover of herbaceous plants and litter, disturbing and compacting soils, reducing water infiltration rates, and increasing soil erosion (Belsky and Blumenthal 1997). Small Mammals: No population estimates have been made for small mammal populations on the WMA (EA, page 21). This should be completed because livestock use can affect small mammal population density, species richness and species diversity even under proper grazing management (Medin and Clary 1989). Small mammals have significant influences on vegetation and soils, exert predatory pressure on insects and other small mammals, and provide an important prey base for mammalian, reptilian, and avian predators (Medin and Clary 1989). As well, protection from livestock use can benefit many small mammal populations. Omissions: The EA is silent on wild bison, wolves, grizzly bear, black bear, mountain lions and mountain goats with very little discussion about bighorn sheep. All of these species represent potential hunting/viewing opportunity on or from the WMA either at present or at some time in the future. We believe all these species are native to this landscape and the opportunities to restore those that are missing through natural emigration and/or direct re-introduction should be a priority for the WMA and discussed in the context of the alternatives reviewed. Domestic livestock use of the WMA (cattle and sheep) pose significant consequences/conflicts for these native species and these impacts were not analyzed in the EA. As we understand it wolves, black bears and mountain lions are already utilizing the WMA to some extent and bighorn sheep from the Greenhorn reintroduction have or at least attempted to use the WMA at certain times of the year. What is the situation for grizzly bears on the WMA and/or the surrounding landscape? Have there been any documented conflicts between livestock and large predators on or near the WMA? If so, what were the consequences of these conflicts? Grizzly bears suffer consequences when they come into contact with domestic livestock and the Forest Service has taken steps to avoid such conflicts (U.S. Forest Service 2006). We suggest FWP should be planning for the presence of grizzly bears on or near the WMA and plan accordingly. Wolves are a preeminent predator and/or a keystone species, which significantly effects biological diversity by their presence or absence. For example, wolves can have a significant impact on the regeneration of aspen (White et al. 1998). Wolves also suffer consequences when they come into contact with domestic livestock. We point this out because the EA failed to do so. What is the current wolf situation on the WMA? If a large predator and livestock conflict occurs as a result of any of the proposed livestock use alternatives for the WMA, what will be the FWP response? We assume mountain goats primarily use Forest Service lands along the crest of the Snowcrest Range. Is that accurate? The presence or absence of Grizzly bears should also be discussed as domestic sheep in particular lead to conflict on occupied grizzly bear habitat. And the suitability of this WMA and the surrounding landscape for wild bison should be discussed as wild bison could be reintroduced as a part of the FWP’s bison quarantine project. Thus, the consequences from the presence of livestock and the needed infrastructure to manage them (fences, water diversions, stock tanks, salting, human presence, motorized use, etc.) should be discussed in the context of all of these native species. We also believe the moose habitat would be substantially improved under alternative E, although a long term commitment to wildlife habitat improvement would likely be necessary to significantly improve the riparian areas for moose. As well, the EA touches on the presence of domestic sheep trailing taking place each spring and fall through the WMA but it fails to disclose the cumulative impact of this use on the large predators using the area, the ground nesting birds, and bighorn sheep habitat suitability (Montana FWP 2009), instead deferring that discussion to a later date. In our opinion the decision FWP is contemplating for the commercial use of the WMA for domestic sheep trailing is a significant cumulative effect and that decision will likely affect a variety of different wildlife species and/or their habitats. What is the history of predator/livestock conflicts in and around the WMA? Weren’t 120 some domestic sheep just killed by wolves in the summer of 2009 on land near the WMA? How will future livestock use proposals on the WMA effect native predator/prey relationships, especially the presence of wolves, mountain lions, black and grizzly bears? Compliance Record: Please review the amount of trespass livestock use that has occurred in the past, including privately owned bison. These impacts were not revealed in the EA. Please also reveal in the final EA the year by year monitoring and cost accounting of the actual livestock use since FWP took over responsibility for managing the livestock use in 1991. How did FWP actually verify compliance with the various livestock management systems employed over the years? Please display these compliance records in the EA. It appears that nearly every time we visit the WMA during the livestock use period cattle have been in numerous pastures at the same time and thus it does not appear that the rest-rotation system is being followed. Cost/Benefit Analysis: We believe sportsmen and wildlife have not benefited from the livestock use programs administered by FWP since the department took over management responsibilities in 1991. Please conduct a full cost/benefit analysis in this regard. Montana FWP (2002) documents that over $1 billion is spent each year in Montana on hunting, fishing and wildlife viewing activities. The article discusses how it is a challenge for the FWP to maintain the supply of public fish and wildlife to keep up with the demand. In 2001, fishing brought in $422 million, wildlife watching $391 million and hunting $300 million which equates to $1,113,000,000. This article goes on to note: Though diseases are a grave concern, the biggest threat to fish and wildlife populations is habitat loss and mismanagement. The “bull” market for hunting, fishing and wildlife viewing can not continue without habitat protection and effective fish and wildlife management. We believe the Robb-Ledford WMA is currently being mismanaged and that costs exceed benefits as compared to no action. Please outline the financial commitments under each alternative, the revenues and the net gain or loss as it relates to better fish and wildlife habitat? The EA also needs to clarify what the FWP receives in terms of dollars/AUM. Lease Agreements with Federal and State Partners need to be clarified: The lease agreements between the FWP and the DNRC, USFS and BLM need to be clarified. Is the WMA considered the base property for the USFS and BLM leases? Can the FWP negotiate an exchange of use agreement regarding some of the WMA DNRC leases and the McGuire lease? Can these other state and federal public lands be rested for conservation purposes under alternative E? Regardless, when do the permits for these grazing leases expire and what environmental review process will be undertaken? Are the federal lands divided into different fenced pastures and are these federal lands ever rested as part of the proposed rest-rotation grazing system? It appears in Appendix B of the EA these federal allotments are grazed every year. Important Alternatives to Consider: 2). Time Out for Recovery Alternative: We suggest the next best fish, wildlife and economic alternative is to take a time out and rest the Robb-Ledford WMA from domestic livestock use impacts for three years to allow the soils, water, native vegetation and fish and wildlife to recover from both the long and short term impacts of historic livestock use. This will preclude the need to build the riparian fence in the short term anyway and at the end of the 3 years FWP can evaluate whether this alternative meets the needs of the native vegetation, fish and wildlife. Anderson and Holte (1981) found that protecting sagebrush-grasslands from historic livestock use impacts benefited native perennial grasses and important upland shrubs such as big sagebrush. If fencing is needed to keep livestock off the WMA during this 3 year rest period (adjacent BLM lands or the McGuire in-holding) we suggest using temporary single, double or triple strand let down electric fence as described in (Paige 2008) only while the cattle are present to avoid the costs of building permanent fence. We believe this will greatly reduce the potential costs of fencing, as outlined in the EA under alternative E, if it is needed at all. 3). The Good Neighbor Alternative: If the FWP Commission would like to proceed with a livestock use alternative we suggest they instruct the Department to review a “good neighbor” alternative. We suggest FWP consider allocating one pasture a year or approximately 1/6th of the overall WMA on a five year rotational basis for use by the neighboring landowner (John Anderson) who is enrolled in the Block Management Program. The sixth pasture will serve as a control. We suggest the livestock use should be allowed from July 15th through August 15th at a rate of 400 AUMs (400 AUs/month) @ $20/AUM = $8,000 in exchange for his participation in the Block Management program. This scenario assumes a reasonable pay out for his participation in Block Management is $8,000/year. 4). Ledford Grazing Association Use: If FWP thinks livestock use by the Ledford Grazing Association is politically inevitable on the WMA, then we suggest a combination of alternatives C & D is the least damaging of the livestock use alternatives reviewed in the EA. Alternative C allows the least amount of cattle at 500 animal units and alternative D has the shortest use period (3 months from July 15 – Oct 15). Alternative D also does not require the construction of the riparian fence along Robb Creek, which is a savings of $43,721 sportsmen’s dollars not to mention the maintenance costs and wildlife costs (entanglement) down the road. 5). Cattle for Sheep Exchange of Use Alternative: We are concerned the FWP is proceeding with a decision regarding the leasing of the WMA for domestic cattle use before the Department decides whether a commercial use permit will be issued to continue domestic sheep trailing through the WMA each spring and fall. We contend such use by domestic sheep is incompatible with the purposes of acquiring a WMA and significant environmental impacts will result to the long term suitability of the WMA for bighorn sheep, antelope, bison, wolves, grizzly bears and perhaps other species. However, should FWP decide or be told to issue a commercial use permit for continued domestic sheep trailing through the WMA, then we suggest FWP should consider a domestic sheep grazing plan as an alternative to the historic cattle grazing and domestic sheep trailing plan. Given such a scenario, we suggest FWP work with the Ledford Grazing Association, the USFS and the domestic sheep permittees to negotiate an exchange of use agreement whereby the cattle are moved to the current domestic sheep allotments in the Gravelly Range in exchange for domestic sheep use of the Robb-Ledford WMA. This would prevent the need to trail domestic sheep through miles of public land in the Snowcrest Mountains, the upper Ruby River country and into the Gravelly Mountains securing some of these public lands for reintroduction of bighorn sheep. We feel this is a complex alternative that needs serious review if the FWP proposes to issue a commercial use permit for domestic sheep trailing across the WMA. The other option would be to sell the WMAs and pick up other habitat where wildlife can be the number one priority. Summary: The FWP has spent nearly $500,000 in sportsmen’s dollars over the last 10 years and the Ledford Grazing Association has had over 20 years to demonstrate their livestock stewardship. The actual costs are actually a lot more when you consider all the time FWP, sportsmen and others have put into this planning and monitoring effort over the years. Many of these costs are not evident in the EA and such information should be presented to get a true accounting of what is required to mitigate the presence of domestic livestock. We contend this experiment has not worked well and given the costs associated with livestock mitigation efforts and the uncertainties of the consequences biologically/ecologically, resting the WMA for the next 3 years is a reasonable and cost effective alternative. As sportsmen we suggest the FWP manage the Robb-Ledford and adjacent Blacktail WMAs primarily for the benefit of big game species, including bighorn sheep and bison. Management should err on the side of native big game species, but also consider the needs of increasingly rare upland game birds such as sage, blue (dusky) and ruffed grouse, beaver, westlope cutthroat trout, native plants and cool clear water. Thus based on our science based review of the impacts of domestic livestock use, we advise the FWP to select the no action alternative and make the appropriate recommendation to the FWP Commission. We contend the FWP has yet to complete a sufficient analysis of the various impacts of livestock use of the WMA and thus the draft EA must be supplemented significantly for the public and the FWP Commission to fully understand the probable consequences of committing to further livestock use, either cattle or domestic sheep. We offer these comments and the attached list of literature citations as evidence that further economic and environmental analysis is needed before serious consideration is given to any possible livestock use alternative. Thank you for the opportunity to comment on this proposal. Sincerely,
Literature Cited Anderson, J.E., and K.E. Holte. 1981. Vegetation development over 25 years without grazing on sagebrush-dominated rangeland in southeastern Idaho. J. Range. Manage. 34:25-29. Armour, C.L., D.A. Duff, and W. Elmore. 1991. The effects of livestock grazing on riparian and stream ecosystems. Fisheries 16(1):7-11. Arno, S.F. and G.E. Gruell. 1986. Douglas-fir encroachment into mountain grasslands in southwest Montana. J. Range Manage. 39(3):272-276. Austin, M. L. 2003. Water developments and wildlife: violating the public trust. Red Willow Research Inc., Twin Falls, ID. 126 pp. Bailey, J. A. 2009. Petition to list plains bison as threatened under the ESA. Petition submitted to U.S. Fish and Wildlife Service, currently assigned to its Cheyenne regional office. 33 pp. Beck, J.L., and D.L. Mitchell. 2000. Influences of livestock grazing on sage grouse habitat. Wildl. Soc. Bull. 28(4):993-1002. Beecham, J.J., P.C. Cameron, and T. D. Reynolds 2007. Rocky Mountain
Bighorn Sheep(Ovis canadensis): A Technical Conservation Assessment.
Prepared for USDA Forest Service, Rocky Mountain Region, Species Conservation
Project by TREC, Inc., 4276 E. 300 North Rigby, Idaho 83442. Online
at: Belsky, A.J. and D.M. Blumenthal. 1997. Effects of livestock grazing on stand dynamics and soils in upland forests of the interior west. Cons. Biology 11(3):315-327. Belsky, A.J., A. Matzke, and S. Uselman. 1999. Survey of livestock influences on stream and riparian ecosystems in the western United States. J. Soil and Water Cons. 54:419-431. Belsky, A.J and J.L. Gelbard. 2000. Livestock grazing and weed invasions in the arid west. Oregon Natural Desert Association. 31 pp. Benke, R.J., and M. Zarn. 1976. Biology and management of threatened and endangered western trouts. USDA. USFS. Rocky Mtn. For. and Range Exp. Sta., Fort Collins, CO., Gen. Tech. Rep. RM-28. 45p. Berry, J.D. and R.L. Eng. 1985. Interseasonal movements and fidelity to seasonal use areas by female sage grouse. J. Wildl. Manage. 49(1):237-240. BLM. 1980. Mountain foothills grazing management program draft environmental impact statement. USDI, BLM 308 pp. BLM. 1991. Riparian-wetland initiative for the 1990’s. USDI, BLM 50 pp. Bock, C.E., J.H. Bock and H.M. Smith. 1993. Proposal for a system of federal livestock exclosures on public rangelands in the western United States. Cons. Biol. 7(3):731-733. Boyd, D.P. 2003, Conservation of North American Bison: status and recommendations. MS Thesis, Faculty of Environmental Design, University of Calgary, Calgary Alberta. 222 pp. Branson, F.A. and T. Lommasson. 1958. Quantitative effects of twenty-three years of controlled use on mountain range. J. Range Manage. 11(2):67-70. Braun, C.E. 1987. Current issues in sage grouse management. Proc. Western Assoc. of Fish and Wildl. Agencies. 67:134-144. Braun, C.E. 1998. Sage grouse declines in western North America: what are the problems? Proc. Western Assoc. Fish and Wildl. Agencies. 78:000-000 Brown, R.L. 1961. Effects of land use practices on sharp-tailed grouse. Montana Fish, Wildlife & Parks, MSU library, Bozeman, MT. Small game Res. Rpt. W-91-R-3, Job No. II-F. 12 pp. Brown, R.L. 1982. Effects of livestock grazing on Mearns quail in southeastern Arizona. J. Range Manage. 35(6):727-732. Bunting, Stephen C., Kingery, James L., Hemstrom, Miles A., Schroeder, Michael A., Gravenmier, Rebecca A., and Hann, Wendel J. 2002. Altered rangeland ecosystems in the interior Columbia basin. USDA Forest Service, Pacific Northwest Research Station, Portland, OR. Gen. Tech. Rep. PNW-GTR-553. 71 p. Buss, I.O. 1960. Blue grouse of big blue buck mountain. Naturalist 11(2):3-9. Call, M.W. 1974. Habitat requirements and management recommendations for sage grouse. USDI, BLM. Tech. Note 1220-5. 37 pp. Chadde, S.W. and C.E. Kay. 1991. Tall-willow communities on Yellowstone’s northern range: a test of the “natural regulation” paradigm. In: The Greater Yellowstone Ecosystem Redefining America’s Wilderness Heritage. Yale University Press. 430 pp. Chaney, E., W. Elmore, and W.S. Platts. 1990. Livestock grazing on western riparian areas. EPA, NW Res. Info. Center, Inc., Eagle, ID. 45 pp. Chaney, E., W. Elmore, and W.S. Platts. 1993. Managing change: livestock grazing on western riparian areas. EPA, NW Res. Info. Center, Inc., Eagle, ID. 31 pp. Clary, W.P. and B.F. Webster. 1989. Managing grazing of riparian areas in the intermountain region. USDA, USFS, Intermtn. Res. Sta. Gen. Tech. Rpt. INT-263 11 pp. Clary. W.P., and D.E. Medin. 1990. Differences in vegetation biomass and structure due to cattle grazing in a northern riparian ecosystem. USDA. Forest Service, Int. Res. Sta., Res. Paper INT-427. 10 p. Clary, W.P. 1995. Vegetation and soil responses to grazing simulation on riparian meadows. J. Range Manage. 48(1):18-25. Clary, W. P., N.L. Shaw, J.G. Dudley, V.A. Saab, J.W. Kinney, and L.C. Smithman. 1996. Response of a depleted sagebrush steppe riparian system to grazing control and woody plantings. USDA Forest Serv., Intermountain Research Station, INT-RP-492, 32pp. Clary, W.P. 1999. Stream channel and vegetation responses to late spring cattle grazing. J. Range Manage. 52:218-227. Cole, G.F. 1958. Big game-livestock competition on Montana’s mountain rangelands. Mont. Wildl. 1958:24-30. Connelly, J.W., W.L. Wakkinen, A.D. Apa and K.P. Reese. 1991. Sage grouse use of nest sites in southeastern Idaho. J. of Wildl. Manage. 55:521-524. Connelly, J.W. and C.E. Braun. 1997. Long-term changes in sage grouse Centrocercus urophasianus populations in western North America. Wildl. Biology. 3:229-234. Connelly, J.W., M.A. Schroeder, A.R. Sands, and C.E. Braun. 2000. Guidelines to manage sage grouse populations and their habitats. Wildlife Soc. Bull. 28(4):967-985. Crowley, C. M. and J.W. Connelly, 1996. Sage grouse population and habitat trends in southeastern Idaho and southwestern Montana. Idaho Dept. of Fish and Game. Pocatello, ID 1996. 203 pp. Dalke, P.D., D.B. Pyrah, D.C. Stanton, J.E. Crawford and E.F. Schlatterer. 1963. Ecology, productivity, and management of sage grouse in Idaho. J. of Wildl. Manage. 27(4):811-841. Davis, J.N., A.D. Green, and M.E. Farmer. 2002. The status of sagebrush range in Utah: current trends problems and future implications. In: WAFWA Sage and Columbian Sharp-tailed Grouse Symposium. Bicknell UT. DeByle, N.V. and R.P. Winokur. 1985. Aspen: ecology and management in the western United States. USDA, USFS, Rocky Mtn. Forest and Range Exp. Sta. GTR RM-119. 283 pp. Dieter, C.D. and T.R. McCabe. 1989. Factors influencing beaver lodge-site selection on a prairie river. Am. Midl. Nat. 122:408-411. Dobkin, D.S. 1995. Management and conservation of sage grouse, denominative species for the ecological health of shrubsteppe ecosystems. USDI, BLM, Portland, OR. 26 pp. Donahue, D.L. 1999. The western range revisited - removing livestock from public lands to conserve native biodiversity. Univ. Oklahoma Press. Norman, OK. 388 pp. Douglas, D.C., J.T. Ratti, R.A. Black, and J.R. Alldredge. 1992. Avian habitat associations in riparian zones of Idaho’s centennial mountains. Wilson Bull. 104(3): 485-500. Dubay, S., H. Schwantje, and J. Devos. 2003. Bighorn sheep (Ovis
canadensis) diseases: a brief literature review and risk assessment
for translocation. Duff, D.A. 1979. Riparian habitat recovery on Big Creek, Rich county, Utah - a summary of 8 years of study. In: Proceedings of the Forum - Grazing and Riparian/Stream Ecosystems. Denver, CO. pp. 91-92. Dusek, G.L., C.D. Eustace, and J.G. Peterson. 2002. The ecology and status of sage grouse in Montana. Intermtn. J. Sci. 8(2):67-81. Eckert Jr., R.E. and J.S. Spencer. 1986. Vegetation response on allotments grazed under rest-rotation management. J. Range Mange. 39(2):166-174. Elmore, W. And R.L. Beschta. 1987. Riparian areas: perceptions in management. Rangelands 9(6):260-265. Eustace, C.D. 2002. Sage grouse hatching success and chronology for south-central Montana. Intermtn. J. Sci. 8(2):82-93. Ewing S. 1990. The range. Mountain Press Publishing Company, Missoula, MT. 284 pp. Fleischner, T.L. 1994. Ecological costs of livestock grazing in western North America. Conservation Biology. 8(3):629-644. Foreyt, W.J. and D.A. Jessup. 1982. Fatal pneumonia of bighorn sheep following association with domestic sheep. J. Wildl. Diseases 18(2):163-168. Freilich, J.E., J.M. Emlen, J.J. Duda, D.C. Freeman, and P.J. Cafaro. 2003. Ecological effects of ranching: A six-point critique. BioScience 53 (8):759-765. Fusco, M., J. Holechek, A. Tembo, A. Daniel, and M. Cardenas. 1995. Grazing influences on watering point vegetation in the Chihuahuan desert. J. Range Manage. 48:32-38. Gillen, R.L., W.C. Krueger and R.F. Miller. 1984. Cattle distribution on mountain rangeland in northeastern Oregon. J. Range Manage. 37(6):549-553. Goodson, N.J. 1982. Effects of domestic sheep grazing on bighorn sheep populations: A review. In Biannual Symposium Northern Sheep and Goat Council. (3):287-313. Gregg, M.A. 1991. Use and selection of nesting habitat by sage grouse in Oregon. Thesis. Oregon State Univ., Corvallis, USA. Gruell, G.E., J.K. Brown, and C.L. Bushey. 1986. Prescribed fire in grasslands invaded by Douglas-fir: state of the art guidelines. USDA, Forest Service, Intermtn. Res. Sta. Gen. Tech. Rpt. INT-198. 19 pp. Hamerstrom, F. And F. Hamerstrom. 1961. Status and problems of North American grouse. Wilson Bull. 73(3):284-294. Hamlin, K.L. and M.S. Ross. 2002. Effects of hunting regulation changes on elk and hunters in the Gravelly-Snowcrest Mountains, Montana. Montana Dept. Fish, Wildlife & Parks, Helena, MT, Fed. Aid Project W-120-R-Apr. 2002. 237 pp. Hansen, R.M. and L.D. Reid. 1975. Diet overlap of deer, elk, and cattle in southern Colorado. J. Range Manage. 28(1):43-47. Harrington, R.D. 2002. A historical perspective of Montana’s sagebrush. Intermtn. J. Sci. 8(2):60-66. Helvie, J.B. 1971. Bighorns and fences. Desert Bighorn Sheep Council Transactions 15:53-62. Hockett, B. L. and J.W. Roscoe. 1993. Livestock management guidelines for grazing in southwest Montana riparian-wetland areas. Workshop on Western Wetlands and Riparian Areas: Public/Private Efforts in Recovery, Management, and Education. Thorne Ecological Institute. P. 102-106. Hockett, G.A. 2002. Livestock impacts on the herbaceous components of sage grouse habitat: a review. Intermtn. J. Sci. 8(2):105-114. Hormay, A. L. 1970. Principles of rest-rotation grazing and multiple use land management. U.S. Forest Service Training Text No. 4 (2200), US Government Printing Office, 19700-385-056. 25 pp. Jacobs, L. 1991. Waste of the West: public lands ranching. Lynn Jacobs, Tucson, AZ. 602 pp. Jean, C., P Hendricks, M. Jones, S. Cooper, and J. Carlson. 2002. Ecological communities on the Red Rock Lakes National Wildlife Refuge: Inventory and review of aspen and wetland systems. Report to the Red Rock Lakes National Wildlife Refuge. MT Nat. Heritage Program, Helena, MT. 33 pp. plus appendices. Jessup, D.M. 1981. Pneumonia in bighorn sheep: effects on populations. Cal-Neva Wildlife Society Transactions, pp. 72-78. Jessup, D.A. 1985. Diseases of domestic livestock which threaten bighorn sheep populations. Desert Bighorn Council 1985 Transactions (29):29-33. Johnson, W.M. 1969. Life expectancy of a sagebrush control in central Wyoming. J. Range Manage. 22(3):177-182. Kauffman, J.B., W.C. Krueger, and M, Vavra. 1983. Effects of late season cattle grazing on riparian plant communities. J. Range. Mange. 36(6):685-691 Kauffman, J.B., and W.C. Krueger. 1984. Livestock impacts on riparian ecosystems and streamside management implications...A review. J. Range. Mange. 37(5):430-438. Kay, C. 1988. Leave it to beavers - stream rehab specialists. Montana Magazine. 89:15-16. Kay, C. E. and D. L. Bartos. 2000. Ungulate herbivory on Utah aspen: assessment of long-term exclosures. J. Range Manage. 53:145-153 Kay, C.E. 2001. The condition and trend of aspen communities on BLM administered lands in central Nevada - with recommendations for management. Final Report to Battle Mountain BLM, Battle Mountain, NV. from Wildlife Management Services, Providence, UT. 152 pp. Kie, J.G., C.J. Evans, E.R. Loft and J.W. Menke. 1991. Foraging behavior by mule deer: the influence of cattle grazing. J. Wildl. Manage. 55(4):665-674. King, M.M. and G.W. Workman. 1984. Ecological relationships between desert bighorn sheep and cattle in southeastern Utah. Northern Wild Sheep and Goat Council 4:167-179. Klebenow, D.A. 1969. Sage grouse nesting and brood habitat in Idaho. Journal of Wildl. Manage. 33(3):649-662. Klott, J.H., R.B. Smith, and C.Vullo. 1993. Sage grouse habitat use in the Brown’s bench area of south-central Idaho. USDI BLM Tech. Bull. No. 93-4. 14pp. Knick, S.T. 1999. Requiem for a sagebrush ecosystem. NW. Sci. Forum. 73(1): 53-57. Knopf, F. L. and R. W. Cannon. 1982. Structural resilience of a Salix community to changes in grazing practices. Proceedings of the Wildlife-Livestock Relationships Symposium 10::198–207. Kovalchik, B.L. and W. Elmore. 1992. Effects of cattle grazing systems on willow-dominated plant associations in central Oregon. In Proceedings - Symposium on ecology and management of riparian shrub communities. USDA, USFS, Intermtn. Res. Sta., Gen. Tech. Rpt. INT-289. pp. 111-119. Krueger, W.C. and A.H. Winward. 1974. Influence of cattle and big game grazing on understory structure of a Douglas fir-Ponderosa pine-Kentucky bluegrass community. J. Range Manage. 27(6):450-453. Krueper, D., J. Bart, and T.D. Rich. 2003. Response of vegetation and breeding birds to the removal of cattle on the San Pedro River, Arizona (U.S.A.). Cons. Biol. 17(2):607-615. Laycock, W.A. 1967. How heavy grazing and protection affect sagebrush-grass ranges. J. Range Manage. 20:206-213. Leege, T.A., D.J. Herman, and B. Zamora. 1981. Effects of cattle grazing on mountain meadows in Idaho. J. Range Mange. 34(3):324-328. Leopold, A. 1924. Grass, brush, timber and fire in southern Arizona. J. Forestry (from The River of the Mother of God: p 114-122.). Leptich, D.J. and P. Zager. 1991. Road access management effects on elk mortality and population dynamics. In: Proceedings of a symposium on elk vulnerability. MSU, Bozeman, MT. pp. 126-131. Loft, E.R., J.W. Menke, and J.G. Kie. 1991. Habitat shifts by mule deer: The influence of cattle grazing. J. Wildl. Manage. 55(1):16-26. Loftus, A.J. and C.H. Flather. 2000. Fish and other aquatic resource trends in the United States: A technical document supporting the 2000 USDA Forest Service RPA Assessment. Gen. Tech. Rep. RMRS-GTR-53. Ft. Collins, CO. 50 pp. Lusby, G.C. 1970. Hydrologic and biotic effects of grazing vs. non-grazing near Grand Junction, Colorado. J. Range Manage. 23(4):256-260. Maloney, S.B., A.R. Tiedemann, D.A. Higgins, T.M. Quigley, and D.B. Marx. 1999. Influence of stream characteristics and grazing intensity on stream temperatures in eastern Oregon. USDA. USFS. PNW-GTR-459. 19 p. Marcum, C.L. and W.D. Edge. 1991. Sexual differences in distribution of elk relative to roads and logged areas in western Montana. In: Proceedings of a symposium on elk vulnerability. MSU, Bozeman, MT. pp. 142-148. Martinka, R.R. 1972. Structural characteristics of blue grouse territories in southwestern Montana. J. Wildl. Manage. 36(2):498-510. Medin, D.E. and W.P. Clary. 1989. Small mammal populations in a grazed and ungrazed riparian habitat in Nevada. USDA, USFS, Intermtn. Res. Sta. Res. Paper, INT-413. 6 pp. Monello, R.J., D.L. Murray, and E.F. Cassirer. 2001. Ecological correlates of pneumonia epizootics in bighorn sheep herds. Can. J. Zool. 79:1423-1432. Montana Fish, Wildlife & Parks. 1991. Upland game bird harvest management in Montana. A report to the Montana Fish and Game Commission. 64 pp. Montana Fish, Wildlife & Parks. 1998. Draft conservation agreement and management plan for westslope cutthroat trout (Oncorhunchus clarki lewisi) in Montana. FWP, Helena, MT. 101 pp. Montana Fish, Wildlife & Parks. 1999. Memorandum of understanding and conservation agreement for westslope cutthroat trout (Oncorhunchus clarki lewisi) in Montana. FWP, Fisheries Division, Helena, MT. 28 pp. Montana Fish, Wildlife & Parks. 2002. Cash register conservation. Montana Outdoors, Helena, MT. Nov./Dec. 2002. 33(6):19-23. Montana Fish, Wildlife & Parks. 2004. Montana elk management plan. FWP, Wildlife Division, Helena, MT. 397 pp. Montana Fish, Wildlife & Parks. 2008. Commercial use management plan for wildlife management areas – Draft. Montana FWP, Helena, MT. 24 pp. Montana Fish, Wildlife & Parks. 2009. Montana Bighorn Sheep Conservation Strategy. Wildlife Division, Helena MT. pp 311. Montana Fish, Wildlife & Parks. 2009. Montana’s Comprehensive Fish and Wildlife Conservation Strategy. Available online at: http://fwp.mt.gov/specieshabitat/strategy/fullplan.html. See Component III Species of Greatest Conservation Need (Tier 1 Species) at: http://fwp.mt.gov/content/getItem.aspx?id=26528 and for Bison refer to pp 403- 405 of this section. Moroz. 1991. Managing access to affect elk vulnerability. In: Proceedings of a symposium on elk vulnerability. MSU, Bozeman, MT. pp. 138-141. Morris, M.S. 1956. Elk and livestock competition. J. Range Manage. 9(1):11-14 Mueggler, W.F. 1950. Effects of spring and fall grazing by sheep on vegetation of the upper snake river plains. J. Range Manage. 3:308-315. Mueggler, W.F. 1988. Aspen community types of the intermountain region. Gen. Tech. Rpt. INT-250. USDA, Forest Service, Intermtn. Res. Sta. Ogden, UT. 135 p. Mussehl, T.W. 1960. Blue grouse production, movements, and populations in the Bridger mountains, Montana. J. Wildl. Manage. 24(1):60-68. Mussehl, T.W. 1963. Blue grouse brood cover selection and land-use implications. J. Wildl. Manage. 27(4):547-554. Mussehl, T.W. and F.W. Howell. 1971. Game management in Montana. Montana Fish and Game Department, Game Management Division, Helena, MT. Federal Aid Project W-3-C. pp 238. Myers, L.H. 1989. Grazing and riparian management in southwest Montana. In: Practical approaches to riparian resource management: an educational workshop. Billings, MT, USDI, BLM, pp. 117-120. Naiman, R.J., J.M. Melillo, and J.E. Hobbie. 1986. Ecosystem alteration of boreal forest streams by beaver (Castor canadensis). Ecology 67:1254-1269. Noss, F.R., M.A. O’Connell, and D.D. Murphy. 1997. The science of conservation planning. Island Press, Washington, D.C. 246 pp. Overton, K.C., G.L. Chandler, and J.A. Pisano. 1994. Northern/Intermountain region’s fish habitat inventory: Grazed, rested and ungrazed reference stream reaches, silver king creek, California. USDA, Forest Service, Int. Res. Sta. Gen. Tech. Report INT-GTR-311. 27 p. Paige, C. 2008. A Landowner’s Guide to Wildlife Friendly Fences. Landowner/Wildlife Resource Program, Montana Fish, Wildlife and Parks, Helena, MT. 44 pp. Passey, H.B. and V.K. Hugie. 1963. Some plant-soil relationships on an ungrazed range area of southeastern Idaho. J. Range Manage. 16(3):113-118. Patterson, R.L. 1952. The sage grouse of Wyoming. Sage Books. Denver, CO. 341 pp. Pelster, A.J., S. Evans, W.C. Leininger, M.J. Trlica, and W.P. Clary. 2004. Steer diets in a montane riparian community. J. Range Manage. 57:546-552. Peterson, J.G. 1995. Sagebrush: ecological implications of sagebrush manipulation. Montana Dept. Fish, Wildlife & Parks, Wildlife Manage. Div. 49 pp. Platts, W.S. 1981. Influence of forest and rangeland management on anadromous fish habitat in western North America: Effects of livestock grazing. USDA. USFS. PNW-GTR-124. 26p. Platts, W.S. and R.F. Raleigh. 1984. Impacts of grazing on wetlands and riparian habitat. In: Developing strategies for rangeland management. Boulder, CO, Westview Press: 1105-1117. Prellwitz, D.M. 2002. Greater sage grouse at Bowdoin National Wildlife Refuge, Montana. Intermtn. J. Sci. 8(2):115-116. Pyrah, D.B. 1987. American pronghorn antelope in the yellow water triangle, Montana: a study of social distribution, population dynamics, and habitat use. Montana Dept. Fish, Wildl. and Parks in cooperation with USDI, BLM. 121 pp. Reppert, J.N. 1960. Forage preference and grazing habits of cattle at the eastern Colorado range station. J. Range Mange. 13(2):58-65. Rich, T.D. 2002. Using breeding land birds in the assessment of western riparian systems. Wildlife Society Bulletin. 30(4):1128-1139. Rickard, W.H. and C.E Cushing. 1982. Recovery of streamside woody vegetation after exclusion of livestock grazing. J. Range Manage. 35(3):360-361. Roath, L.R. and W.C. Krueger. 1982. Cattle grazing influence on a mountain riparian zone. J. Range Manage. 35(1):100-103. Robertson, J.H. 1971. Changes on a sagebrush-grass range in Nevada ungrazed for 30 years. J. Range Manage. 24(5):397-400. Robertson, R. L. 1976. Ruffed grouse habitat preferences and effects of livestock grazing on habitat utilization. M.S. thesis. Utah State Univ., Logan, UT. 71 pp. Roscoe, J.W. 2002. Sage grouse movements in southwestern Montana. Intermtn. J. Sci. 8(2):94-104. Ross, L.R. and H.E. Hunter. 1976. Climax vegetation of Montana: based on soils and climate. USDA, SCS, Bozeman, MT. 64 pp. Schommer, T and M. Woolever. 2001. A process for finding management solutions to the incompatibility between domestic sheep and bighorn sheep. USDA Forest Service, Washington, DC. 62pp. Schroeder, M.A. and R.K. Baydack. 2001. Predation and the management of prairie grouse. Wildlife Society Bull. 29(1):24-32. Schulz, T.T., and W.C. Leininger. 1990. Differences in riparian vegetation structure between grazed areas and exclosures. J. Range Manage. 43(4):295-299. Singer, F.J., E. Williams, M.W. Miller and L.C. Zeigenfuss 2001. Population Growth, Fecundity, and Survivorship in Recovering Populations of Bighorn Sheep. Restoration Ecology, Vol.8:75-84. Singer, F.J., C.M. Papouchis, and K.K. Symonds 2001(A). Translocations as a Tool for Restoring Populations of Bighorn Sheep. 2001. Restoration Ecology. Vol. 8:3-6 Skinner, Q.D., J.E. Speck, Jr., M. Smith, and J.C. Adams. 1984. Stream water quality as influenced by beaver within grazing systems in Wyoming. J. Range Manage. 37(2):142-146. Skovlin, J.M., Edgerton P.J., and B.R. McConnell. 1983. Elk use of winter range as affected by cattle grazing, fertilizing, and burning in southeastern Washington. Journal of Range Management 36(2):184-189. Skovlin, J.M. 1984. Impacts of grazing on wetlands and riparian habitat: a review of our knowledge. In: Developing strategies for rangeland management. Boulder, CO. Westwood Press: pp. 1001-1103. Skubinna, J.P. and F.G. Van Dyke. 1991. Range of expansion strategies of colonist elk in south-central Montana. In: Proceedings of a symposium on elk vulnerability. MSU, Bozeman, MT. pp. 149-158. Smith, R.L., and L.D. Flake. 1983. The effects of grazing on forest regeneration along a prairie river. Prairie Nat. 15:41-44. Smith, T.S., J.T. Flinders, and D.S. Winn. 1991. A habitat evaluation procedure for Rocky Mountain bighorn sheep in the intermountain west. The Great Basin Naturalist 51(3):205-225. Stauffer, D.F. and S.R. Peterson. 1985. Ruffed and blue grouse habitat use in southeastern Idaho. J. Wildl. Manage. 49(2):459-466. Stauffer, D.F. and S.R. Peterson. 1985(a). Seasonal micro-habitat relationships of ruffed grouse in southeastern Idaho. J. Wildl. Manage. 49(3):605-610. Stewart, K.M., R.T. Bowyer, J.G. Kie, N.J. Cimon, and B. K. Johnson. 2002 Temporospatial distributions of elk, mule deer, and cattle: resource partitioning and competitive displacement. J. Mammalogy. 83(1):229–244. Stoddart, L.A., A.D. Smith, and T.W. Box. 1975. Range management. McGraw-Hill Book Co. 532 pp. Suminski, R. 1991. Bighorn/livestock interaction - issues and management strategies. USDA, USFS, Intermtn. Region. 24 pp. Taylor, D.M. 1986. Effects of cattle grazing on passerine birds nesting in riparian habitat. J. Range Manage. 39(3):254-258. Taylor, E., J. Klott, and R.B. Smith. 1998. California bighorn sheep habitat evaluation. Idaho BLM, Tech. Bull. No. 98-6. 39 pp. Taylor, E. 2001. Effects of spring cattle grazing on bighorn sheep habitat use. Final Job Report, U.S. Geological Survey, Forest and Rangeland Ecosystem Science Center, Snake River Field Station, Boise, ID. 10 pp. Thomas, J.W., C. Maser, and J.E. Rodiek. 1979. Wildlife habitats in managed rangelands - the great basin of southeastern Oregon: riparain zones. USDA, Forest Service, Gen. Tech. Rpt. Pacific NW Forest and Range Exp. Sta. GTR-PNW-80. 18 p. Thomas, J.W. and D.E. Toweill. 1982. Elk of North America: ecology and management. Wildlife Manage. Institute and USDA Forest Service. Stackpole Books, Harrisburg, PA. 698 pp. Thorne, T., G. Butler, T. Varcalli, K. Becker, and S. Hayden-Wing. 1979. The status, mortality and response to management of the bighorn sheep of Whiskey Mountain. Wyoming Game and Fish Dept., Game and Fish Research Lab., Wildlife Tech. Rpt. Number 7. Toweill, D.E. and V. Geist. 1999. Return of royalty - wild sheep of North America. Boone and Crocket Club, Foundation for North American Wild Sheep, Missoula, MT. 214 pp. U.S. Fish and Wildlife Service. 1985. Final environmental impact statement for the management of Charles M. Russell National Wildlife Refuge. USDI, USFWS, Regional Office, Denver, CO. 453 pp. U.S. Fish and Wildlife Service. 1992. Historical review of sage grouse in Centennial Valley based on information in Red Rock Lakes National Wildlife Refuge (RRLNWR) files - late 1930’s to present. USDI, RRLNWR, Lima, MT. 3 pp. U.S. Fish and Wildlife Service. 1993. Hart Mountain National Antelope Refuge comprehensive management plan draft environmental impact statement. USDI, USFWS, Region 1, Portland, OR. Vol. 1:1-274 Vol. 2:Appendices A-L. U.S. Forest Service, Bureau of Land Management, Montana Fish, Wildlife & Parks, Rebish and Helle Montana Partnership, and Rebish and Konen Montana Livestock Limited Partnership. 2002. Memorandum of Understanding. Forest Service Agreement #02-MU-11010206-003. 5 pp. U.S. Forest Service. 2006. Forest Plan Amendment for Grizzly Bear Habitat Conservation for the Greater Yellowstone Area National Forests, Record of Decision, 2006. Beaverhead-Deerlodge National Forest, Bridger-Teton National Forest, Caribou-Targhee National Forest, Custer National Forest, Gallatin National Forest, Shoshone National Forest. pp. 36 with Appendices. Valentine, K.A. 1947. Distance from water as a factor in grazing capacity of rangeland. J. Forestry. 10:749-754. Welch, B.L. 2005. Big sagebrush: A sea fragmented into lakes, ponds
and Werner, S.J. and P.J. Urness. 1998. Elk forage utilization within rested units of rest-rotation grazing systems. J. Range Manage. 51:14-18. Western Association of Fish & Wildlife Agencies. 2007. Recommendations for Domestic Sheep and Goat Management in Wild Sheep Habitat. 27pp. White, C.A., C.E. Olmsted, and C.E. Kay. 1998. Aspen, elk, and fire in the Rocky Mountain national parks of North America. Wildl. Soc. Bull. 26(3):449-466. Whithorn, D. 2001. Images of America Paradise Valley on the Yellowstone. Arcadia. 128 pp. Wood, A.K., R.J. Mackie, and K.L. Hamlin. 1989. Ecology of sympatric populations of mule deer and white-tailed deer in a prairie environment. Montana Dept. Fish, Wildlife & Parks. Wildlife Division. Bozeman, MT. 97 pp. Wuerthner, G. and M. Matteson. 2002. Welfare ranching. The subsidized destruction of the American West. Island Press. 346 pp. Wyoming Game and Fish Department. 1993. The role of beaver in riparian habitat management. Habitat Extension Bulletin, Jan. 1993. No. 38. pp. 1-8 Young, M.K. 1995. Conservation assessment for inland cutthroat trout. USDA, Forest Service, Rocky Mtn. Forest and Range Exp. Sta., Fort Collins, CO. Gen. Tech. Rpt. RM-GTR-256. 61 pp. Zwickel, F.C., O.B. Irven, and J.H. Brigham. 1968. Autumn movements of blue grouse and their relevance to populations and management. J. Wildl. Manage. 32(3):456-468. Zwickel, F.C. 1972. Some effects of grazing on blue grouse during
summer. J. Wildl. Manage. 36(2):631-634.
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