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Jan.
24, 2003
Mark
A. Petroni
District Ranger
5 Forest Service Rd.
Ennis, MT 59729
Subject: Antelope Basin/Elk Lake Revised
Allotment Management Plan Updates Environmental Assessment (EA).
Dear
Mark:
The
Gallatin Wildlife Association (GWA) is a non-profit wildlife conservation organization
representing concerned hunters and anglers in Southwest Montana and elsewhere. The GWA is an affiliate of the Montana Wildlife
Federation which is an affiliate of the National Wildlife Federation. We are volunteers working to protect habitat so fish and wildlife populations and
hunting and fishing opportunities can be conserved for future generations. GWA supports sustainable management of fish and
wildlife populations through fair chase regulation of public hunting and fishing
opportunities. Please keep the GWA informed
about all aspects of this proposal and all opportunities for public input along the way. Please consider these comments and the cited
scientific literature as significant reasons to modify and update the EA to an
Environmental Impact Statement (EIS).
The
Antelope Basin is a critical wildlife habitat and corridor for elk, mule deer, antelope,
bighorn sheep, bison, sage grouse, large carnivores and other wildlife. The Antelope Basin also provides headwaters habitat
for beaver, a keystone species, and arctic grayling and westslope cutthroat trout, locally
imperiled Forest Service Management Indicator Species for cold water fisheries. These headwaters flow to a change of lakes
eventually contributing to the world renown Madison River to the east and the Red Rock
Lakes National Wildlife Refuge and the Red Rock River to the west. The foothills sagebrush type of the Antelope Basin
provides a narrow connection between the Centennial Valley and the Madison Valley (MSU
1973). The foothill sagebrush type is unique to southwest Montana (MSU 1973). Principle forage species include bluebunch
wheatgrass, Idaho fescue, big sagebrush and a diversity of forbs, other grasses, shrubs
and half-shrubs. The distinguishing feature is
the sagebrush covered foothills, which is surrounded by coniferous and deciduous forests. It could be easily argued that the Forest Service
owns no finer piece of fish and wildlife habitat in the United States. This area is quite simply an International
Treasure.
EIS
Required - refer to Horse Butte cattle allotment analysis and controversy on the Gallatin
National Forest (GNF) where an EIS has been scoped for public comment. Along with the bison management controversy,
environmental degradation due to cattle grazing is a major issue of debate on Horse Butte. The Antelope Basin Plan is much more complex and
will likely be just as controversial.
Range
of Alternatives inadequate - the only alternative that prevents significant impacts to
fish, wildlife and native plants, soil and water is the no grazing alternative
(alternative C). The grazing alternatives (A
& B) do not sufficiently mitigate the effects of livestock grazing and related
developments for sage grouse (Hockett 2002). The
ecological costs associated with livestock grazing are significant (Fleischner 1994). Since cattle grazing has been identified as a major
factor in riparian habitat degradation on the project area and throughout the West (Belsky
et al. 1999), cattle grazing should cease on the riparian areas. Lusby (1970) tested the simple hypothesis that if
cattle were causing an erosion problem, then removal of cattle would cure the problem. Indeed it did.
Re-distributing the problem (cattle grazing) from riparian areas to the more
sensitive upland habitats just creates other significant impacts (Lusby 1970, Fleischner
1994, Hockett 2002). Antelope Basin meets the
extreme sensitivity rating described for riparian areas in Hockett and Roscoe
(1993) and should be managed under a different scenario than a domestic livestock
allotment(s).
Sage
grouse are a bird of climax vegetation. However,
in an attempt to develop a grazing alternative that might work for sage grouse and
riparian habitats please consider the following alternative.
Using principles outlined in Mussehl (1963), Zwickel et al. (1968), Myers
(1989), Hockett and Roscoe (1993), Bock et al. (1994), USDA Forest Service
Beaverhead-Deerlodge National Forest and Montana Department of Fish, Wildlife & Parks
Region 3 (1998), Beck and Mitchell (2000), Connelly et al. (2000), Galt et al. (2000) and
Hockett (2002) please consider managing sage grouse seasonal nesting and brood rearing
habitat as climax vegetation management areas. If these seasonal habitats must be grazed
by domestic livestock, do so only during the month of July.
Livestock utilization should be limited to 25% in key riparian and sage
grouse habitats during this July grazing period to allow for native herbivory, watershed
protection (Galt et al. 2000), drought and adequate herbaceous food and cover for sage
grouse during the spring, summer and fall (Hockett 2002).
Cessation of grazing by August 1 should minimize livestock concentrations in
wet meadows and riparian areas (Myers 1989) that are preferred by brood rearing sage
grouse (Connelly 2000, Hockett 2002). Cessation
of grazing by August 1 may also allow for a 30 day regrowth period for riparian vegetation
(Myers 1989) and climax cool season grasses. Late
summer and early fall regrowth is important for carbohydrate storage in roots and stems of
cool season grasses (Stoddart et al. 1975) such as bluebunch wheatgrass, basin wildrye,
Idaho fescue, Indian ricegrass and the needlegrasses.
Any residual herbaceous vegetation that accumulates in the late summer and
fall will provide critical cover for sage grouse nesting (Beck and Mitchell 2000),
protection from predators (Schroeder and Baydack 2001) and early brood rearing the
following spring (Hockett 2002). Please
consider all sagebrush habitats below 8,000 feet in elevation suitable habitat for sage
grouse nesting and all sagebrush habitats within 0.5 miles of riparian habitats preferred
areas for brood rearing. All livestock water
developments and salt grounds within key sage grouse nesting and brood rearing seasonal
habitat should be removed, as these developments concentrate livestock use creating areas
of intensive livestock utilization and trampling which lead to earth scars, soil erosion,
soil compaction, noxious and other weed infestations and sacrifice areas (Valentine 1947,
Hockett 2002). These impacts are not only
evident on the project area, they are prevalent.
Inadequate
Mitigation - grazing systems with range improvements and moves based on utilization
standards have proven ineffective for management indicator species, and other plants,
soils, natural waters, natural processes (droughts, floods and fires) and fish and
wildlife. The prescribed grazing season is too long to allow for riparian recovery (Myers
1989) and range improvements for livestock fragment and degrade sage grouse
habitat (Hockett 2002). Fifty to fifty five
percent utilization by cattle is too high (Holechek 1999, Galt et al. 2000), especially in
an area so rich in native wildlife. Achieving
uniform utilization is also problematic in a mountainous environment and significant
resource damage (over utilization of certain plants and sites) will occur year after year
(Gillen et al. 1984). Livestock grazing
is an important factor in forest health issues (Belsky and Blumenthal 1997). Livestock grazing at levels proposed in
alternatives A & B has disrupted natural fire regimes by significantly removing fine
fuels which leads to coniferous forest, deciduous forest, upland shrub, big sagebrush and
riparian health dysfunction. Fire suppression
also plays a cumulative role in disrupting natural processes and ecological function, but
specific fire suppression activities on the project area were not disclosed (USFS AMS
2002). Prescribed fire (man induced) can also
have significant consequences for various fish and wildlife habitats, especially big
sagebrush communities and the animals that use them (Personal Communication Bob Brannon
and Joel Peterson FWP). The Montana Department of Fish, Wildlife & Parks does not
support the assertion that fire is necessary to create habitat diversity in mature
sagebrush stands.(Peterson 1995).
Bison,
beaver, grayling, cutthroat trout, sage grouse, bighorn sheep and pygmy rabbit habitat
remains unoccupied. Electric fencing to
protect riparian habitats has proven ineffective (see photos available from the author). Livestock water tanks, pipelines, fences and salt
grounds (so call range improvements) have left earth scars, severely trampled
areas, soil erosion, soil compaction, weed infestations, severe trailing erosion and
severe grazing impacts including nearly complete removal of herbaceous vegetation
important to sage grouse, bighorn sheep and other wildlife (see photos available from the
author). These earth scars fragment and
degrade otherwise excellent fish and wildlife habitat.
The
Grazing alternatives merely redistribute the problems identified in moist riparian areas
to more arid and sensitive uplands. Aspen
habitats are also being degraded from livestock use (see photos available from the
author). Summer grazing also adversely impacts
sage grouse, blue grouse and ruffed grouse brood rearing habitat, removing important
plants used for both cover and forage (Patterson 1952, Mussehl 1963, Zwickel et al. 1968,
Zwickel 1972, Stauffer and Peterson 1985(a), Stauffer and Peterson 1985(b), Hockett 2002) These birds show fidelity to seasonal habitats
preferring to use the same sites year after year (Patterson 1952, Mussehl 1960, Zwickel et
al. 1968, Zwickel 1972, Berry and Eng 1985, Stauffer and Peterson 1985(a), Stauffer and
Peterson 1985(b), Connelly et al. 2000, Hockett 2002).
Rotational grazing systems may result in significant impacts to these
seasonal habitats (Eckert Jr. and Spencer 1986), and thus bird populations (Beck and
Mitchell 2000), depending on the grazing treatment (Gjersing 1975). Combined with drought, the effects of grazing in
any given year can be devastating for ground nesting bird production (Patterson 1952,
Connelly and Braun 1997, Connelly et al. 2000, Dusek et al. 2002, Eustace 2002, Hockett
2002).
Inadequate
Analysis - Historical analysis is inadequate. The
EA claims the majority of the analysis area does not have known sage grouse or their
habitat (Revised EA - 152). This statement
runs contrary to personal communications with FWP Wildlife Biologists Joel Peterson and
Bob Brannon and Montana Dept. Fish, Wildlife & Parks (2001) and Montana State
University (1973). The Revised EA has failed
to review historical information about sage grouse use in and around the project area
(FWP, BLM and USFWS Monitoring Data on file with these respective agencies). The EA fails to mention the historical impacts
livestock grazing and related developments and land and plant manipulation treatments have
had on native fish and wildlife, plants, soil and water.
Historically, the sagebrush habitat type has been reduced by over half
(Harrington 2002) and possibly as high as 98% of the sagebrush/grassland has been altered,
degraded or converted to other uses (Apa 2001). The
sagebrush-riparian habitats within the antelope basin are currently not supporting many
historically present native species including bison, beaver, fish, sage grouse, bighorn
sheep and pygmy rabbit. Continued livestock
grazing and related range developments (stock tanks, pipelines, salt grounds, roads, and
fences) may preclude the natural reoccupation of this area by native species. Complete eradication of important big sagebrush
habitats on other private and public lands was not adequately analyzed (USFS AMS 2002).
Livestock
grazing is an important factor in forest health issues (Belsky and Blumenthal 1997). Livestock grazing at levels proposed in
alternatives A & B has disrupted natural fire regimes by significantly removing fine
fuels which leads to coniferous forest, deciduous forest, upland shrub, big sagebrush and
riparian health dysfunction. These effects
were not adequately analyzed in the EA.
Cumulative
Effects - droughts, floods, fire, severe winters, livestock grazing, stock tanks,
pipelines, salt grounds, roads, burning, spraying, plowing, subdivision, hunting, disease,
etc. all pose potentially series side effects for native plants, soils, water, fish, sage
grouse and other wildlife. These cumulative
effects were not adequately analyzed in the EA.
Brucellosis
- Elk have apparently transmitted brucellosis to cattle in Idaho (Governor Martz Expresses
Concern Over Idaho's Confirmation of Brucellosis Infection in Cattle Herd; dated 4/19/2002
and found at: http://www.discoveringmontana.com/gov2/css/pr.asp?ID=62). As well, predators are capable of and indeed are
moving dead body tissues that may harbor the disease (GYIBC Meeting, Jan. 16, 2003
Bozeman, MT). YNP is only 20 air miles from
the Antelope Basin. Elk migrations to and from
the Antelope Basin area are common, and Antelope Basin is critical calving and summer
habitat for elk. Cattle grazing in this area
in the summer put Montanas and Idahos brucellosis free status at risk.
Elk
in the Montana portion of the Greater Yellowstone Ecosystem have a brucellosis infection
rate of about 1-1.5%, whereas elk on some of
the feed grounds in Wyoming have infection rates of 25% or more (Personal Communication
with Ken Hamlin FWP Jan. 20, 2003). The EA
notes that elk calve and summer in the Antelope Basin, thus placentas are shed along with
other body fluids that may contain brucellosis. Wolves,
coyotes and other predators, including birds, use the Antelope Basin. These predators chase, stress and kill elk
throughout the region. Traditional telemetry
equipment is inadequate for monitoring specific elk movements to and from the Park
(Personal Communication with Ken Hamlin FWP Jan. 20, 2003) as well as entire wolf pack
emigrations (Bozeman Daily Chronicle, Nez Perce wolf pack missing from the Park, Jan. 21,
2003). Elk often migrate so fast, that
traditional monitoring equipment fails to illustrate their migration routes, simply
picking them up in the Park during one monitoring event and then, for example, in the
Gravelly mountain range 30-50 miles away during the next monitoring period. Elk herds, infected to some degree with
brucellosis, spend the spring, summer and fall within the Antelope Basin. Elk also calve, are killed by predators and die
from other causes within the Antelope Basin. Elk
prefer many of the same habitats preferred by cattle for foraging and watering. There is potential for significant interaction and
consequences on shared ranges.
Bison,
a nomadic animal by nature, walking at 2 miles per hour could easily leave the Park in the
afternoon or evening and be in the Antelope Basin before sunrise. These are remote, mountainous landscapes, with
limited vehicular access. Free ranging
wildlife could conceivably remain unnoticed for weeks if not months. Since the Antelope Basin is historic habitat for
bison, we would anticipate continued relentless attempts by wild bison to reoccupy this
suitable habitat, especially as carrying capacity within the Park is exceeded. Zone 2 of the Interagency Bison Management Plan is
only about 12 miles from the border of the Antelope Basin at its closest point. Bison have migrated as far as 22 miles from
Yellowstone National Park (YNP) along the Madison River corridor. While grazing along the edge of the Antelope Basin
during the winter of 1997 these bison were gunned down by government officials; executed
by government agents acting on behalf of the livestock industry, because they apparently
posed a threat of brucellosis transmission to domestic cattle (Witnesses horrified
by bison shoot - Bozeman Chronicle Jan. 30, 1997).
If this were to occur, there would be significant costs and consequences to
the States livestock industry.
This
federal action to consider authorizing domestic livestock use in historic and currently
desirable bison habitat is a major federal decision with significant ramifications and
consequences for both native wildlife and livestock. Native,
wild bison would likely take up residence in the Antelope Basin where they were historic
inhabitants, given the chance. There are
currently approximately 4,000 bison in the Greater Yellowstone herd. This number will likely expand significantly next
year, especially if this mild winter continues. The
pressure for bison to migrate from depleted winter ranges near the Park will be even
greater next year. Although the Interagency
Bison Management Plan (IBMP 2000) does not currently recognize the Antelope Basin as
habitat available for bison, this plan is based on adaptive management principles. The fact that the Forest Service is contemplating
either grazing or not grazing this significant piece of historical bison habitat so close
to Yellowstone National Park with domestic livestock is truly significant for both
wildlife and the States livestock industry. The
Forest Service is attempting to avoid this point by merely pointing the finger toward the
IBMP (2000) assuming this plan is not flexible, and then claiming bison migrations to the
Antelope Basin area are not foreseeable (G-11 in the revised EA).
Which
of the three alternatives best serve the interests of the Interagency Bison
Management Plan (IBMP 2000) which emphasizes measures to maintain a free ranging bison
herd, and temporal and spatial separation between bison and cattle? It seems apparent that alternative C best meets the
goals of the IBMP. The risks associated with
alternatives A & B warrant an EIS, given that elk, bison and the predators that eat
them including birds, wolves and coyotes are potential vectors (organisms that carry
pathogens from one host to another) or bridges for transmission of brucellosis. Even if the Forest Service does not foresee bison
using the Antelope Basin area (G-11 in the revised EA), the Forest Service must not ignore
the risks of brucella aborta being transported to the Antelope Basin via other means. Significant consequences warrant an EIS.
Cattle
impacts to predator-prey relationships were not adequately analyzed. Cattle compete with elk, moose, deer, antelope,
bighorn sheep, bison, sage grouse and other wildlife for plants used for both forage and
cover. These animals provide the prey base for
wolves, grizzlies, other carnivores and human hunters.
Cattle-wolf and/or grizzly bear conflicts were not adequately analyzed. There are at least two confirmed wolf dens/packs in
the Gravelly Mountain Range (PC Ken Hamlin, FWP, Jan. 20, 2003). Wolf-cattle conflicts have occurred in the area
resulting in the death of both cattle and wolves. Cattle
also remove herbaceous understory plants critical for a variety of small mammals that
provide a prey base for a variety of predators that may otherwise prey on sage grouse.
Management
Indicator Species (MIS): It is apparent the Forest Service has no intention of enhancing
sage grouse habitat, a Forest Plan MIS for sagebrush, as the purpose of this proposal is
to graze cows (G-7 in the revised EA). This is
especially disheartening given the fact the Forest Service recognizes problems with sage
grouse habitat exist to the point it is anticipating appeals, lawsuits, etc. (USFS
Analysis of Management Situation on the Beaverhead-Deerlodge National Forest 2002). What better time then now to change? The current Forest Plan can be amended if
necessary.
The
Forest Service has not adequately disclosed or reviewed relevant data it is required to
collect regarding MIS. However, we know that
the Missouri Flats lek near the Forest in the Madison valley has been abandoned and the
Fish Creek lek near the Forest in the Centennial Valley is still occupied (Personal
Communication with Bob Brannon, FWP Wildlife Biologist).
Therefore, without further information, at least 50% of the breeding
complexes of the area have been lost. Connelly
et al. (2000) recommends in areas of large scale habitat loss (>40% of original
breeding habitat) protect all remaining habitats from additional loss or degradation. Connelly and Braun (1997) discuss livestock
grazing as one of the primary factors that may lead to habitat fragmentation, loss and
deterioration, which in turn leads to population declines.
The authors suggest the development of Conservation Strategies for the
protection and rehabilitation of sagebrush rangelands to halt the decline of sage grouse
and initiate recovery.
Livestock
grazing, weather patterns (primarily drought) and fire were the only known factors
occurring throughout most of the range of sage grouse that could be related to wide-spread
population declines through deterioration, loss or fragmentation of habitat (Connelly and
Braun 1997). However, predation can be a
significant problem when nesting habitat, which is enhanced by a dense tall herbaceous
understory within the sagebrush community, is in poor condition (Gregg 1991). Predation can also become a problem for prairie
grouse in highly fragmented habitats (Schroeder and Baydack 2001), such as currently
exists within the Antelope Basin project area. Beck
and Mitchell (2000) identified livestock grazing as a factor associated with the
widespread decline and degradation of sage grouse habitat.
Overall, livestock grazing appears to most affect productivity of sage
grouse populations (Beck and Mitchell 2000). Residual
grass cover is essential to conceal sage grouse nests from predators (Beck and Mitchell
2000, Schroeder and Baydack 2001). Grazing
probably most affects nesting success of sage grouse because nests in sagebrush areas with
greater residual cover of herbaceous plants have a greater likelihood of success. Suitable nesting habitat for sage grouse should be
found within the sagebrush-grasslands at elevations at or below 8,000 feet. This describes a majority of the
sagebrush-grasslands within the Antelope Basin.
Water
developments and salt grounds significantly concentrate livestock and increase forage use,
trailing and soil compaction that fragment sagebrush habitat (Stoddart et al. 1975). 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 miles (0.8 km) of water (Valentine 1947, Fusco et al.
1995). These heavy use areas may extend up to
0.5 miles (0.8 km) away from the site (Valentine 1947) providing a niche for noxious weeds
and other undesirable or unpalatable vegetation to take hold. Such developments should only be considered if
accompanied with climax management areas that are free of livestock impacts (Hockett
2002). The existing landscape is dotted and
severely fragmented with such developments, including fences, and the proposed action
contemplates more of the same (revised EA). This
is a nightmare for sage grouse viability. It
is no wonder that sage grouse have been virtually extirpated from this landscape. The good news is though, all of these government
transgressions are removable or reversible. However,
cattle grazing in mountainous terrain will inevitably lead to severely grazed areas, even
within so called properly grazed ranges (Gillen et al. 1984). This is clearly no place for cows, unless
significant impacts to soil, water, plants, fish and wildlife are acceptable.
Connelly
et al. (2000) - The USFS has failed to develop Conservation Strategies for sage grouse as
outlined in Connelly and Braun (1997) and Connelly et al. (2000) or to protect the
remaining habitat in areas experiencing a >40% loss of breeding habitat by
establishing ungrazed comparison areas (Beck and Mitchell 2000, Hockett 2002). There are at least two documented leks, or sage
grouse breeding grounds near the project area, one of which that has apparently been
abandoned. This loss of breeding habitat has
significant consequences for sage grouse populations and thus management guidelines as
outlined by Connelly et al. (2000). This loss
of breeding habitat has been downplayed or ignored by the Forest Service (Revised EA-152).
The
proposal to graze domestic livestock while adding to the already intensive fragmentation
brought on by fencing, stock water distribution and salting areas will at best maintain
status quo. There has been a significant
departure or loss of native biological diversity from this landscape including local
extirpations of, but not limited to, native plants, native fish, sage grouse, beaver,
bighorn sheep, bison and large carnivores. Many
of these species are climax species that are capable of self-regeneration in the absence
of disturbance. Domestic livestock, and the
related intensive management developments that have been imposed on this landscape have
significantly disturbed the habitats of these species, leading to localized extirpations. Only alternative C can remove or reverse these
significant developments.
Most
livestock exclosure studies suggest that, in fact, livestock operate as a keystone species
in rangeland ecosystems (Bock et al. 1993). Although
the authors state the presence of domestic livestock usually does not preclude native
vegetation or wildlife, livestock frequently determine which species will thrive and which
will diminish. The Forest Service is
apparently intending on applying some of this knowledge to portions of the identified
grayling habitat by protecting them from livestock impacts.
Thank you. What about westslope
cutthroat trout and sage grouse habitat?
Maintaining
viability of native species is paramount to the Forest Services mission under the
National Forest Management Act. Neither
alternative A or B provide for that opportunity, instead allocating critical resources
(soil, water and vegetation) to an exotic domestic farm animal that imposes significant
disturbances to the landscape, and essentially replaces native climax species and disrupts
climax processes in a wildland environment. In
the absence of an alternative that will meet the needs of sage grouse and other fish and
wildlife, we encourage the Forest Service to adopt alternative C and begin the process of
removing past disturbances and restoring fragmented and degraded fish and wildlife
habitats.
Sincerely,
Glenn
Hockett
President, Gallatin Wildlife Association
P.O. Box 5276
Bozeman, MT 59717
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