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Working to protect habitat and conserve wildlife.The following comments were submitted to the
BLM, Beaverhead-Deerlodge, and Gallatin National Forests regarding their ongoing
management plans. |
| Objectives | |
Feb. 12, 2003
Tim
Bozorth, Field Manager
Becky Heath, Forest
Tom
Reilly, Forest Supervisor
Brad Powell, Regional Forester
Pat
Flowers, Region 3 Supervisor
Dan Gomez
Subject: Dillon Resource Area Bureau of Land Management (BLM) Resource Management Plan (RMP), Beaverhead-Deerlodge National Forest (B-DNF) Forest Plan (FP) and Gallatin National Forest (GNF) FP Land Use Planning Comments Dear Field Managers and Forest Supervisors: 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 (along with previous correspondence) and the cited scientific literature as significant reasons to modify and update the RMP and the FP for your respective agencies. Please also consider comments GWA sent to the Montana Department of Fish, Wildlife & Parks (FWP) on Jan. 12, 2003 regarding state-wide elk and sage grouse management plans as relevant to your decisions in land use planning. Copies of these comments are available at our web site at: http://www.cowboyhvn.com/GWA.htm
Paradigm Shift: We agree, significant change is needed at the landscape level (USFS 2002(a)). Does the BLM agree? We envision these Land Use Planning processes as an opportunity to shift paradigms at the landscape level. We suggest the agencies adopt the principle adhered to by the medical profession of: "First, do no harm". The "No Harm" principle offers an economical and logical foundation for a paradigm shift to fish and wildlife management areas and habitat conservation planning and future decision making on federal public lands in southwest Montana. Secondly, we encourage both the BLM and USFS to shift management emphasis from development and production (timber harvest, grazing AUMs, road building and mining) to habitat restoration and protection (soil, water, plants and air), fish and wildlife conservation, and restoration and tolerance of natural processes (flood, fire, drought, insects, severe winter and native herbivory). The public lands under your care in southwest Montana are nothing short of international treasures. We encourage you to think big. Think huge! These landscapes connect the Greater Yellowstone Ecosystem (GYE) with the Selway-Bitterroot in Idaho to the west and the Bob Marshal to the north. Their importance for fish and wildlife conservation can not be overstated. We view this as an historic event, and truly appreciate the opportunity to provide you are thoughts and ideas. Keep it Simple: Please, keep it simple. We know and fully understand the complex issues at debate here. However, we really feel the agencies have a responsibility outlined in law (reduction of paperwork and not more documents, but better decisions regarding the environment) to streamline the process and to work hard to inform the public of its intentions. Compare USFS (2002(a)) Draft Analysis of the Management Situation (AMS) for the B-DNF with the BLM’s RMP Digest: Description of the Existing Condition and Analysis of the Management Situation (BLM 2002(a)). We found the USFS draft AMS much more user friendly and informative, and we applaud the USFS for simplifying, without excluding, what it believes needs to be changed during this planning process. As well, we continue to be overwhelmed by the GNF Travel Management Planning Process. We see the GNF travel planning process to date to be a paper blizzard that is incomprehensible and disenfranchising to concerned publics to the detriment of the final plan. It is so unnecessarily complicated we do not even know how to cite it. Consequently, we have not been able to participate in the process to the degree we had hoped. We believe there is significant room for improvement. Again, we refer the reader to the B-DNF draft AMS as a prototype of thoughtful simplicity, with clarity. We especially appreciate the map based illustrations provided in USFS (2002(a)) regarding conceptual management areas. Such map based illustrations provide us with a better understanding of what the B-DNF is thinking, and thus we are better prepared to make useful comments to the process. We believe these types of map overlays can be produced to illustrate the existing condition for things like roads, trails, grazing allotments, timber sales, mining operations, fences, stock water tanks, and other developments or projects that have occurred on the land. We believe the degree of human intervention into these public lands is of critical importance to fish, wildlife and their habitat (soils, plants, water and air). We believe, if clearly illustrated in map overlay fashion we will see a "cancer" at work within an otherwise pristine landscape. Such map based planning will give agency planners and the interested public a simplified "aerial view" so to speak of the impacts that have been imposed on the various landscapes. We believe such a view will be enlightening and allow for informed discussion as to how to proceed. To be fair, we should point out we appreciate the BLM’s efforts to simplify and clarify some river issues through a largely map based presentation in the Draft Wild and Scenic River Eligibility Report (BLM 2002(c)). Although we feel a final determination on those rivers eligible for Wild and Scenic designation is premature (BLM 2002(d)), we appreciate the streamlined, map based features of this report as well. Why didn’t BLM issue a draft ACEC report? Will BLM be issuing a draft travel management planning report? How about a draft livestock grazing allotment management report? Map based presentations of the existing situations in both cases would be enlightening as to the impacts associated with both roads and livestock. A draft timber harvest report might be useful as well, illustrating the past timber harvests over the landscape. There might be other instances where draft reports might be useful prior to the draft RMP EIS Interdisciplinary Team Members, Decision-maker and Contact Personnel: We would like to know for each agency who the interdisciplinary team members and decision-maker are for these land use planning projects and how we may contact them by phone, address and email. We hope to initiate or maintain a meaningful dialogue with all of the pertinent agency staff members. Inter-Agency Cooperation and Coordination: At this writing, we are very disappointed with the lack of inter-agency cooperation and coordination occurring between the USFS, BLM, FWP, Department of State Lands (DSL), the U.S. Fish and Wildlife Service (USFWS) and the National Park Service (NPS). We have repeatedly made this comment to a variety of Forest, BLM and FWP personnel. We encourage you to reverse this trend, and begin a significant and meaningful process of interagency coordination and cooperation at the watershed and landscape level. For the purposes of our comments we envision the "project area" to include all Dillon BLM Resource Area lands, all B-DNF and GNF USFS lands, and all FWP Wildlife Management Areas, DSL lands and USFWS lands within and adjacent to the federal BLM and USFS lands. We feel these federal and state public lands should be considered available for conservation planning. Some private lands may also be available for conservation planning, for example, the Peter’s Ranch which has a partial conservation easement with the FWP. We do not include NPS lands within the project area, but feel coordination and cooperation with the NPS is critical on several fish and wildlife related habitat management and population conservation issues. We cite the following federal direction which outlines the agencies responsibilities to cooperate and coordinate their planning efforts: National Environmental Policy Act (NEPA), Title 40, Code of federal regulations, Sec. 1501.6 Cooperating agencies. The purpose of this section is to emphasize agency cooperation early in the NEPA process. Upon request of the lead agency, any other Federal agency which has jurisdiction by law shall be a cooperating agency. In addition any other Federal agency which has special expertise with respect to any environmental issue, which should be addressed in the statement may be a cooperating agency upon request of the lead agency. An agency may request the lead agency to designate it a cooperating agency. (a) The lead agency shall: 1.Request the participation of each cooperating agency in the NEPA process at the earliest possible time. 2.Use the environmental analysis and proposals of cooperating agencies with jurisdiction by law or special expertise, to the maximum extent possible consistent with its responsibility as lead agency. 3.Meet with a cooperating agency at the latter's request. (b) Each cooperating agency shall: 1.Participate in the NEPA process at the earliest possible time. 2.Participate in the scoping process (described below in Sec. 1501.7). 3.Assume on request of the lead agency responsibility for developing information and preparing environmental analyses including portions of the environmental impact statement concerning which the cooperating agency has special expertise. 4.Make available staff support at the lead agency's request to enhance the latter's interdisciplinary capability. 5.Normally use its own funds. The lead agency shall, to the extent available funds permit, fund those major activities or analyses it requests from cooperating agencies. Potential lead agencies shall include such funding requirements in their budget requests. (c) A cooperating agency may in response to a lead agency's request for assistance in preparing the environmental impact statement (described in paragraph (b)(3), (4), or (5) of this section) reply that other program commitments preclude any involvement or the degree of involvement requested in the action that is the subject of the environmental impact statement. A copy of this reply shall be submitted to the Council. Federal Land Policy and Management Act (FLPMA): While developing and revising land use plans as specified in the 1976 FLPMA, "the Secretary shall -
Management Areas (MA): The USFS assigns MAs as a basis for general management direction within a given unit. Can the BLM adopt a similar strategy? Interagency MAs should be established on a watershed, vegetative habitat type and fish and wildlife habitat basis, that are coordinated regardless of land ownership. Fish and wildlife MAs should be established on an ecological, biological and watershed basis to ensure viability of native species. We cite the USFS (2002(a)) as recognition that fish and wildlife needs within the area need management revision. With the exception of bighorn sheep, blue grouse and ruffed grouse, USFS (2002(a)) identifies many of the fish and wildlife that need special management provisions or habitat protections. We believe designation of fish and wildlife MAs is an excellent way to meet the mandates of the National Forest Management Act (NFMA), NEPA, FLPMA, the Clean Water Act, the Endangered Species Act and other relevant state and federal laws. As well, ecologically based MAs meet the intent of the Butte Resource Advisory Council Standards for Rangeland Health and Guidelines for Grazing Management (BLM 1997). We suggest developing a series of data map layers that can then be superimposed to facilitate habitat conservation planning and MA development as outlined by Murphy and Noon (1992) and suggested by Rieman and McIntyre (1993). For example, we suggest a map layer based on vegetation potential data be established for different unique rangeland, forest or habitat types. A good example within the project area is the foothill sagebrush type which is unique to southwest Montana (MSU 1973). Principle forage species include bluebunch wheatgrass, Idaho fescue, big sagebrush and a diversity of forbs, other grasses and shrubs or half-shrubs. The distinguishing feature is the sagebrush covered foothills (MSU 1973). This rangeland or habitat type provides critical wildlife forage and cover for elk, mule deer, moose, bison, antelope, sage grouse, large carnivores and other wildlife. The consequences of the loss or fragmentation of the sagebrush ecosystem and/or disruption of the natural fire regimes are significant (Knick 1999, Wisdom et al. 2002(a&b)). Livestock grazing and other land use practices that remove perennial vegetation, disrupt soils, increase erosion, and help establish introduced exotics like cheatgrass synergistically increase the consequences of fire in the sagebrush steppe (Knick 1999, Wisdom et al. 2002(a&b)). However, sagebrush steppe habitat restoration, and in particular the grass-forb understory, is possible if both passive (significantly modifying or eliminating existing management activities, such as livestock grazing, range developments and roads) and active restoration efforts (appropriate wild fire suppression, prescribed fire, elimination or control of exotic species and/or seeding with native perennial plants) are initiated and coordinated (Wisdom et al. 2002(a&b)). To achieve population conservation, for example sage grouse, habitat restoration efforts must be applied on an ecological basis (Hockett 2002) that encompasses the seasonal habitat needs of the species in question (Murphy and Noon 1992, Rieman and McIntyre 1993, Wisdom et al. 2002(a&b)). Interspersed or adjacent coniferous forests, deciduous forests and riparian types complete a mosaic of habitat types that can be mapped and displayed as MAs at the landscape level (MSU 1973). Overlain on a topographic watershed map, a series of headwaters habitat can then be illustrated and delineated. Such maps, illustrating MAs based on habitat type and watershed principles would provide an excellent basis for identifying and managing simpler riparian based ecosystems that provide habitat for keystone species such as beaver, and locally imperiled USFS management indicator species (MIS) for cold water fisheries such as arctic grayling and westslope cutthroat trout. Map layers illustrating the seasonal habitat requirements of various key wildlife species (BLM 1980(b)) can be modified and developed to provide a better understanding of the more complex ecological and biological needs of terrestrial species capable of movements to and from various watersheds. We suggest utilizing and improving upon conservation planning and mapping principles outlined in Murphy and Noon (1992) to help delineate various MAs. It could be easily argued that the USFS and BLM own no finer piece of fish and wildlife habitat in the United States. Southwest Montana is quite simply an International Treasure, yet it is only a small piece of a much larger ecosystem. We suggest BLM and USFS establish coordinated MAs based on habitat types, watershed boundaries and the seasonal habitats of key fish and wildlife within the region. Coordinate BLM Areas OF Critical Environmental Concern (ACEC) and USFS Management Areas (MA): MAs should be habitat based and established for fish and wildlife on an ecological, biological and watershed basis, regardless of land ownership. In essence, if fish and wildlife habitat is protected, then fish and wildlife viability can be conserved for current and future generations to enjoy. We encourage BLM to embrace and coordinate the fish and wildlife MA concept with the USFS. However, given BLM does not currently apply the MA concept, we suggest ACECs could and should be coordinated with USFS MAs for fish, wildlife or various plant habitat types (USFS 2002(a)). ACECs: We are extremely disappointed with BLM’s Relevance and Importance Evaluations of ACEC Nominations report (BLM 2002(b)), and BLM’s reluctance to hear or discuss our concerns (BLM Correspondence dated Nov. 25, 2002 and Jan. 31, 2003). We find it quite incredible BLM has determined bighorn sheep, sage grouse, sagebrush plant communities and other wildlife within the DRA are not important on a regional, statewide or national level. We completely disagree and refer BLM to USFS (2002(a)) for a general discussion about wildlife management revision needs in the area. Please also see Wisdom et al. (2002(a&b)) and Hemstrom et al. (2002) which documents conditions necessary to support functional associations of sagebrush plant communities and viable populations of sage grouse must be assessed at the landscape scale. Clearly, habitat requirements for sage grouse may encompass large areas (Connelly et al. 2000), if not millions of hectares of sagebrush-steppe and interspersed riparian habitat (Wisdom et al. 2002(a&b), Hemstrom et al. 2002). In order to prevent further degradation of sagebrush-steppe, especially in the drier Wyoming big sagebrush types, broad-scale removal or reductions of livestock grazing along with active conservation and restoration strategies will be necessary (Hemstrom et al. 2002). Murphy and Noon (1992) outline concepts that are relevant to the ACEC process. As well, BLM found the DRA ACEC nomination submitted for fish and wildlife by the Gallatin Wildlife Association was not relevant merely because it was too broad (BLM 2002(b)). In fact, BLM’s own data (BLM 1980(a)) and maps show this nomination is quite relevant and likely not broad enough to support all the needs of the fish and wildlife using the area (BLM 1980(b)). Although the DRA includes nearly 900,000 acres (approximately 360,000 ha) (BLM 2002(b)), on an ecological or landscape scale, the BLM lands by themselves are likely incapable of supporting viable populations of many of the fish and wildlife that use the area, including sage grouse (Crowley and Connelly 1996, Roscoe 2002). USFS lands make up a significant component of the habitat required by fish and wildlife that use this area. Idaho also provides lands critical for wildlife in the area (Crowley and Connelly 1996, Hamlin and Ross 2002, Roscoe 2002). Private lands do as well, but for the sake of these planning processes we assume the private lands are, for the most part, unavailable for conservation planning. For perspective, the DRA landscape is only 6.5% the size of the area analyzed for sagebrush and sage grouse viability in the interior Columbia Basin, where 13.6 million ha or 33,605,600 acres were considered relevant and important to these species (Wisdom et al. 2002(a&b)). In fact, broad-scale application of various conservation and restoration strategies (special management) will be necessary to prevent further degradation of sagebrush-steppe (Hemstrom et al. 2002). We believe BLM has arbitrarily dropped the DRA ACEC nomination without an adequate analysis of the current science. The DRA ACEC nomination is quite relevant and important, not only to sage grouse and sagebrush plant communities, but to a variety of fish and wildlife on a regional, statewide and national basis. Furthermore, the Sage Grouse Habitat ACEC nominated by the National Wildlife Federation (approximately 887,000 acres), although considered relevant by BLM was not considered important, because there are sage grouse leks and habitat elsewhere in Montana and the region (BLM 2002(b)). However, is the BLM unaware that the sage grouse has been petitioned for listing under the Endangered Species Act throughout its entire range? Is BLM unaware that livestock grazing can significantly affect sagebrush-steppe, riparian habitats, fire regimes, herbaceous cover and forage and other aspects of sage grouse habitats? What about climax vegetation, fire or drought being issues that require special management attention for sage grouse? BLM failed to address the current conditions, population trends or threats for sage grouse or sagebrush plant communities in southwest Montana or elsewhere. We applaud the USFS (2002(a)) for recognizing the need to implement special management for sage grouse. However, BLM appears to have stuck its head in the sand in hopes that the problems associated with sagebrush and sage grouse habitat management will just go away. We view this as significant short coming on BLM’s part, and thus question BLM’s commitment to fulfilling its responsibilities under FLPMA, NEPA and other state and federal laws. We review the reader to Wisdom et al. (2002(b)) which points out an increasing concern about sage grouse viability throughout its range on both USFS and BLM lands. The need for cooperative and coordinated interagency pro-action at the landscape level is apparent for sagebrush communities and obligates such as sage grouse. While Wisdom et al. (2002(a)) and Hemstrom et al. (2002) document the benefits that can be achieved for sage grouse if special management considerations are implemented within the sagebrush-steppe, the long term outlook is bleak at best. While significant reductions or complete protection from livestock use (considered passive restoration) in conjunction with more active restoration measures including fire management, exotic plant control and/or reseeding with native plants if necessary, does provide some hope, these actions only constrained the future risk of extirpation to a moderate rather than high probability, on a very broad landscape (Wisdom et al. 2002(a)). We find the foothills sagebrush type in Montana to be unique to the southwest part of the State (MSU 1973). Within this area various sagebrush habitat types, and plants within them, are considered unique, rare and in need of special protection or restoration management (BLM 2002(b) - Sagebrush Creek and Big Sheep Creek ACEC nominations). The sage grouse ACEC nomination is both relevant and important to sage grouse viability within Montana and nationally throughout the sage grouse historic range. We remain confused about BLM’s reluctance to recognize these facts and act appropriately to establish the pro-active paradigm shift that ACEC designation provides. Model predictions reviewed by Wisdom et al (2002(b)) indicated that current conditions for sage grouse within the interior Columbia Basin are substantially degraded and associated with a high probability of extirpation (Raphael et al. 2001). Long-term (100 year) projections of conditions under all three federal land management alternatives indicated that currently degraded conditions would worsen (Raphael et al. 2001). The magnitude of negative effects projected by these models, the large land area analyzed (13.6 million ha) and the legal, social and economic implications that surface are significant (USFS and BLM 2000). Moreover, the USFS and BLM manage almost 70% of the land within the current range of sage grouse in the Columbia Basin, and this land base encompasses >25% of the species current range in western North America (Wisdom et al. 2002(b)). Management of USFS/BLM habitat in the basin therefore has a substantial effect on population viability of Greater Sage-Grouse (Wisdom et al 2002(b)). Greater Sage-Grouse habitat within the DRA (just over 800,000 acres) is clearly a much smaller, yet a substantially important component, of a larger, significantly degraded sagebrush-steppe. ACEC designation for sage grouse habitat protection within the DRA is clearly relevant and important. For bighorn sheep ACEC relevance and importance we refer the reader to Cuoey (1950), Suminski ( 1991) and Taylor (2001) for estimates of historic habitat in Montana and conflicts related to livestock management and disease transmission. USFS B-DNF, BLM and FWP monitoring reports including BLM (2002) document bighorn sheep die-offs in the Melrose area of the East Pioneers, the Madison Range and the Muddy Creek area of the Tendoy Mountains. Other major die-offs have occurred as well. Special management considerations are clearly needed to protect and enhance existing and historical bighorn sheep habitat within the DRA, B-DNF, GNF and FWP Wildlife Management Areas (WMA). A fundamental conflict exists where domestic sheep are grazed on historic bighorn sheep habitat. This must cease on state and federal public land bighorn sheep habitat. Bighorn sheep management revision and habitat protection is a glaring omission in the Draft USFS AMS wildlife revision section (USFS 2002(a)). Please address this in the Final AMS. Improving MA Direction: We appreciate and applaud the USFS for taking the bold risk of presenting larger, "more ecologically based" MAs. We are cautious, but optimistic the USFS is on the right track here and we encourage the BLM to join the effort. However, since BLM does not currently utilize the MA concept, we have recommended a series of large BLM ACECs in conjunction with USFS MAs for fish and wildlife. We provide the following ACEC-MA vision over a broad landscape, regardless of land ownership, based on the ecological needs of fish and wildlife for your joint consideration. FWP WMAs are included where appropriate, as well as the USFWS Red Rock Lakes National Wildlife Refuge. Dillon Resource Area and Beaverhead portion of Beaverhead-Deerlodge National Forest ACEC-MA: We continue to assert that the entire DRA, although only about 360,000 ha, has fish and wildlife habitats and recreational values relevant and important enough to warrant ACEC designation. In this regard, please consider the alternative of establishing the entire DRA as an ACEC or special MA for fish and wildlife habitat protection in conjunction with the Beaverhead portion of the B-DNF. More species specific ACEC-MA alternative nominations are outlined below, but when you add them all up, the DRA and Beaverhead portion of the B-DNF makes sense as an ACEC-MA for fish and wildlife habitat in general. Many of the reasons these areas qualify and deserve special management designation are outlined in our previous comments to the BLM and the BLM 1979 Management Framework Plan Summary, BLM 1980 Mountain foothills grazing management program draft environmental impact statement and Map Supplement (BLM 1979, BLM 1980a,b). However, please also refer to the USFS Draft AMS (2002) and the specific citations provided for each individual fish or wildlife ACEC-MA nomination. Specific Fish and Wildlife Related Habitat Protections are Relevant and Important and require Special Management Considerations on USFS, BLM and FWP lands within Southwestern Montana: ACECs and MAs (or the appropriate BLM equivalent to a MA) should be established for 1) native fish, beaver, ruffed grouse, blue grouse and moose; 2) sage grouse and antelope; 3) mule deer and bighorn sheep; and 4) free ranging elk and wild bison within the Greater Yellowstone Ecosystem. Interagency coordination, especially between BLM, USFS and FWP is critical to meet the needs of these native species. See GWA (2003a,b) for comments to the FWP regarding state-wide sage grouse and elk management plans that are relevant to these land use planning decisions in southwest Montana. More site specific ACEC-MA nominations are outlined below. Clark Canyon Watershed ACEC-MA: Nominated for native fish, beaver, ruffed grouse, blue grouse and moose. Please note the Clark Canyon Watershed ACEC as outlined in Montana Dept. Fish, Wildlife & Parks (Undated(b)) has already been nominated for the protection and management of native fish and beaver habitat (Correspondence to BLM from Stu Levit, American Wildlands, August 2002). We would like to add moose as a native big game species in need of special management considerations within this nomination (Peek 1998) as well as ruffed and blue grouse (Mussehl 1960, Mussehl 1963, Zwickel et al. 1968, Zwickel 1972, Stauffer and Peterson 1985(a)&(b)). Special management of conifer, aspen, willow, upland shrub and riparian communities will be necessary to restore, improve or maintain historic native fish, beaver, ruffed grouse, blue grouse and moose habitat within the Clark Canyon watershed. Interagency cooperation will likely be necessary with the FWP and the Bureau of Reclamation to remove non-native competitors above the reservoir and to reintroduce both native fish and beaver. Moose, ruffed grouse and blue grouse should colonize habitat naturally as it is restored, beaver may as well. Beaver transplants may be necessary or useful to enhance the riparian recovery process. BLM has opted to wait until the year 2006 to hear this ACEC nomination. We encourage BLM to reconsider that decision and review this nomination during the current RMP and USFS land use planning process. Antelope and Sage Grouse ACEC-MA: Primarily the sagebrush habitat types and interspersed riparian areas in southwest Montana. See MSU (1973) which outlines the mountain foothills sagebrush type which is unique to southwest Montana and the intermountain valley grassland and meadow type. See also BLM (1980(b)) and BLM’s RMP web-site for maps of antelope and sage grouse habitat on BLM lands. BLM (1980(a)) outlines some of the features of these animals habitats and some of the impacts from livestock grazing. The boundaries of this ACEC nomination are shown as vegetative types 6 and 7 in MSU (1973) as they related to the DRA and B-DNF. Please consider the development of a Habitat Management Plan within this ACEC-MA nomination for sage grouse and antelope as a major issue during this planning process. Sage grouse should be considered a key indicator species for the health and function of the sagebrush-steppe riparian complex in and perhaps outside of the project area. Nesting and brood rearing habitats should be managed for maximum herbaceous vegetative cover (climax vegetation) and sage grouse spring, summer, fall forage production (forbs and insects) (Hockett 2002). This would include the sagebrush-steppe habitat and interspersed riparian-wetlands, springs and streams. The integrity of these types should be maintained which will involve special management considerations to produce and protect climax vegetation and may also involve special fire management/control prescriptions. Winter habitat may need to be reseeded to sagebrush. Breeding complexes as defined by Connelly et al. (2000) should be permanently closed to livestock use to provide dense herbaceous nesting cover (Beck and Mitchell 2000), protection from predators (Schroeder and Baydack 2001), mitigation against drought (Dusek et al 2002, Eustace 2002, Hockett 2002, Prellwitz 2002), and adequate brood cover and forage (Mussehl 1960, Mussehl 1963, Zwickel et al. 1968, Zwickel 1972, Stauffer and Peterson 1985(a)&(b), Hockett 2002). Special management actions as outlined above for sage grouse should also benefit antelope and other sagebrush obligates or near obligates, such as pygmy rabbits, brewers sparrows, sage sparrows and green-sided towhees. Bighorn Sheep and Mule Deer ACEC-MA: Refer to MSU (1973) where vegetative types 2, 4, 7 and 10 will likely meet the needs of these species. These vegetative type boundaries will serve as the initial boundary of this ACEC-MA nomination. Please consider a Bighorn sheep and Mule deer ACEC-MA nomination based on MSU (1979) and BLM data found in BLM (1979) and BLM (1980a,b). Cuoey (1950) gives a very conservative estimate of historic bighorn sheep distribution in southwest Montana which can be augmented by the experience of local wildlife biologists, archeologists and other resource professionals. Special management considerations for bighorn sheep are spelled out in Suminski (1991) and Taylor (2001), and for mule deer in (Rickard and Cushing 1982, Wood et al. 1989, Kie et al. 1991). The Greater Yellowstone Elk and Bison ACEC-MA. Both elk and bison have been found to have a serologic prevalence for brucellosis (MFWP undated(b), MDOL and MFWP 2000(a&b), Hamlin and Ross 2002). The spread of this disease to domestic cattle could have serious consequences for the state of Montana or Idaho. Many elk in the GYE migrate to and from YNP to and from USFS, BLM, FWP and private land outside the Park (MWFP undated(b), Hamlin and Ross 2002). The current elk management plan (MFWP 1992) does not outline any management actions that would minimize the risk of transmitting brucellosis between elk and cattle. As well, the Montana elk - brucellosis management plan (MFWP undated(b)) only looks at 3 elk management units near the Park (Madison, Gallatin, Emigrant). The intent of this ACEC-MA is to secure a habitat based free ranging special management area for elk and wild bison in the Montana portion of the GYE. Basically in Montana this would be all public lands north and west of YNP including the entire watershed above Clark Canyon dam, the Gravelly Mountain Range including the FWP owned Blacktail, Robb-Ledford and Wall Creek WMA, and the Madison Range to the Bear Creek WMA. ACEC-MA designation should be granted for all public lands in and around the Gallatin National Forest from the Porcupine WMA in the Gallatin Canyon and the Dome Mountain WMA in the Yellowstone or Paradise Valley south to the YNP border. The Emigrant elk management unit should also be included. Disease transmission, competition between non-native domestic livestock, recreational opportunities including hunting, and securing additional habitat for free ranging elk and wild bison are major reasons for establishing a Greater Yellowstone Elk and Bison ACEC-MA. The boundaries of this ACEC-MA are somewhat arbitrary as we are not sure the exact extent to which elk and bison do or will migrate from the Park. We believe the boundary could be modified to match the following FWP elk management units: Emigrant, Gallatin, Madison, Gravelly, Tendoy and Pioneer (MFWP 1992) or specific portions thereof that make sense to local biologists to encompass the majority of the elk migrating from YNP and to provide somewhat of a buffer zone. Principles outlined in Hamlin and Ross (2002) address a variety of reasons the Greater Yellowstone Elk and Bison ACEC-MA is a good idea. Hamlin and Ross (2002) also discuss a number of excellent ideas for special management that should be considered for large, free ranging ungulates such as elk and bison in the GYE. Although beyond the scope of these land use decisions, this ACEC-MA concept could and should be expanded to include federal and state public lands that provide habitat for migrating elk and bison in Idaho and Wyoming as well. Southwest Montana (FWP Administrative Region 3) is the major elk producing area in the state (Hamlin and Ross 2002). It includes about one fourth of all hunted elk habitat and about half of all elk hunters and harvest. In 2000, 51.2% of Montana’s total elk hunters and 58.5% of non-resident hunters hunted in Region 3. Of Montana’s bull and antlerless elk kill, 58.3% and 62.8% respectively, were in Region 3 (Hamlin and Ross 2002). This area is clearly relevant and important for elk. FWP has purchased 3 WMAs, primarily for elk winter range, in the Gravelly-Snowcrest Mountain area (Hamlin and Ross 2002). In 1960, the Wall Creek WMA (28.6 sq. km) on the east slope of the Gravelly mountains was acquired. The 70.5 sq. km Blacktail WMA on the west slope of the Snowcrest Mountains was purchased in 1972, and the 140 sq. km Robb-Ledford WMA, also on the west slope of the Snowcrest Range, was purchased in 1988. A total of 240 sq. km of elk winter range is owned by the FWP in the Gravelly-Snowcrest Mountains (Hamlin and Ross 2002), and a variety of different conservation interests and agencies continue to secure habitat for elk and other wildlife through conservation easements and acquisitions throughout the area (Personal Communications with the USFS Madison Ranger District, Region 3 FWP, the Rocky Mountain Elk Foundation, Gallatin Wildlife Association, Trout Unlimited and The Nature Conservancy, Montana Fish, Wildlife & Parks. 2001). Restoration of free ranging wild bison herds in the GYE is important ecologically, economically and culturally to America and Montana because bison are wildlife and a keystone species which significantly affect the ecosystem in which they roam. Unfortunately, wild bison remain ecologically extinct in Montana, with historic populations ranging from 60-70 million on the Great Plains to only about 3,000-4,000 individual wild bison in Yellowstone National Park at present. Bison were an important historic influence in the area (Lommasson 1948, Hamlin and Ross 2002, and Personal Communications with BLM, USFS, FWP and USBR personnel). A population level of 3,000 is a current but flexible or adaptable government threshold for wild bison in the GYE (MDOL & MFWP 2000(a&b)). Under the existing Interagency bison management plan, unmitigated government slaughter of bison can occur outside of the Park at certain times of the year when bison herds exceed 3,000 animals. This costly slaughter by government agents has created significant controversy and is one of many reasons a habitat based management solution is needed for bison in the GYE. We also believe in the long term public hunting is a natural process that should be restored within the context of a habitat based conservation plan for bison. We believe public hunting will prove the most cost effective and humane management alternative available for bison in the GYE. However, current management of bison herds is leading towards domestication of the species. This threatens their wild character and limits important natural selection processes. State and Federal agencies have prevented or limited the natural dispersal of wild bison into Montana from Yellowstone National Park because of conflicts with domestic cattle relating to perceived disease transmission issues (MFWP et al. 1990, MDOL and MDFWP 2000(a)&(b), USDI NPS 2000). On public lands these conflicts are avoidable, not inevitable. However, special management plans will need to be developed that significantly reduce or eliminate the risk of disease transmission to cattle on public and private land elk and bison range within the Greater Yellowstone Elk and Bison ACEC-MA. Wild bison are of great historic, current and future value to the people of Montana and this Nation. Indeed, no other wild animal is more symbolic of the American west and freedom than the bison. The Lewis and Clark expedition noted this importance in their journals and were dependent upon bison for food and materials when exploring Montana. The Lewis and Clark bicentennial in Montana will be 2005-2006. Restoration of wild bison to an area traversed by Lewis and Clark would be a living tribute to these early pioneers and an event that will make history. Wild bison continue to provide great economic, cultural and spiritual importance to Montana’s people. Cooperative habitat and population management plans for wild bison would help restore and preserve these traditional values over a broader and more ecological based landscape. As we understand it, the legal status of wild bison in Montana today is: wild bison in Montana are recognized as a game animal [Montana Statutes 87-2-101 subsection (6)] and also as a species in need of management (ibid. 87-1-216). Bison originating from Yellowstone national park are designated as a species requiring disease control [ibid. 87-1-216 (1)(a)] while other wild bison are designated as a species in need of management [ibid. 87-1-216 (1)(b)]. The GYE offers the best opportunity to restore free roaming, genetically pure, wild bison herds to Montana with minimal government intervention. Therefore, free-roaming wild bison herds in the GYE should be allowed access, like elk and other wildlife, through natural migration corridors to public lands in Montana that have provided historic habitat for bison. Because bison are a species requiring special management their access to private land is more problematic and may be limited to areas that are ecologically, economically and socially acceptable. Private land acquisition and/or conservation easements should be part of the special management direction for this ACEC-MA to expand the amount of land available for conservation planning. We recommend State and Federal agencies develop a long range, habitat based management plan for the restoration and management of free roaming, wild bison herds, including public hunting, on suitable private and public lands. We also believe the demographics of private land ownership and management in the GYE has significantly changed and continues to evolve towards land owners more tolerant, if not welcoming to wildlife, including wild bison. We offer the Black Butte, Sun, Carroll and Elk Meadows Ranches as examples of this changing demographic. Restoring historical bison migration corridors and access to habitat on public land in the GYE will truly be an historic event, worthy of all our creative thinking and cooperation. We honor all those among us dedicated to working tirelessly to make this happen. We know someday these efforts will prove fruitful for both hunters and other wildlife enthusiasts around the world. Carnivore ACEC-MA: The three headliners here are grizzly bears, gray wolves and the Canada Lynx (USFS 2002(a)). We suggest the carnivore ACEC mimic the Greater Yellowstone elk and bison ACEC-MA. This is not to say these critters will not be important outside these ACEC-MA boundaries, however special management priority should be given to ensure the viability of these species within these core ACEC-MA designations. Domestic sheep and cattle grazing would likely need to be eliminated or greatly reduced in either time or space to prevent relentless wild predator-domestic prey conflicts, and to provide for the native prey based needed by these predators. The USFS (2002(a)) anticipates the grizzly bear will be de-listed prior to completion of the Forest Plan revision. This may also occur for the gray wolf, however is doubtful for the Canada Lynx. We anticipate that these large predators, once de-listed, will be managed by the FWP just like any other big game wildlife species with the opportunity for regulated human harvest through public hunting and possibly trapping in the case of the Lynx. We believe this will be the best long term population management alternative both within and outside of any special management area or ACEC-MA. Mitigation Measures in previous Land Use Plans and the 1980 Mountain Foothills Environmental Impact Statement (MFEIS) are Inadequate. Mitigation measures, especially as they relate to livestock grazing, have failed to reverse trends for sensitive species and some USFS MIS (BLM 2002(a), USFS 2002(a)). Livestock grazing is a dominate use of USFS (B-DNF) and BLM lands within southwest Montana, 75% and 95% respectively. The GNF grazes livestock, but to a lesser degree spatially. Livestock can be an important source of lethal or debilitating diseases to wildlife (Suminski 1991; Fleischner 1994, Taylor 2001; Hamlin and Ross 2002). Livestock compete with native wildlife for food, space and water, sometimes to the exclusion of native species (Cuoey 1950, Brown 1982, Bock et al. 1993, Fleischner 1994, Hamlin and Ross 2002). Livestock can also degrade or remove herbaceous or woody cover important for fish and wildlife (Armour et al. 1991, Fleischner 1994, Beck and Mitchell 2000). Livestock grazing can significantly disrupt natural processes such as plant succession (coniferous forest, deciduous forest, rangeland and riparian health), soil formation, erosion, run-off, water infiltration, fire, floods, drought, and predator-prey relationships (DeByle and Winokur 1985, Arno and Gruell 1986, Fleischner 1994, Belsky and Blumenthal 1997, Belsky et al. 1999, Holechek et al. 1999, Belsky and Gelbard 2000, Corning 2002, Davis et al. 2002). Livestock also contribute to noxious weed infestations and spread (Fleischner 1994, Belsky and Gelbard 2000, Davis et al. 2002). Livestock use can also degrade water quality and water quantity, as well as degrade habitat for a variety of fish, wildlife and plants (Brown 1961, DeByle and Winokur 1985, Elmore and Beschta 1987, Armour et al. 1991, Fleischner 1994, Beck and Mitchell 2000, Belsky et al. 1999, Benke and Zarn 1976, BLM. 1980a, Bock et al. 1993, Chaney et al. 1990, Clary et al. 1996, Clary and Webster 1989, Connelly and Braun 1997, Connelly et al. 2000, Corning 2002, Davis et al. 2002, Hockett and Roscoe 1993, Hockett 2002, Hobbs 2001, Kauffman and Krueger 1984, Kovalchik and Elmore 1992, Meehan 1991, Mussehl 1960, Mussehl 1963, Myers 1989, Overton et al. 1994, Patterson 1952, Peterson 1995, Platts 1991, Pyrah 1987, Rieman and McIntyre 1993, Schroeder and Baydack 2001, Siegel et al. 2002, Stauffer and Peterson 1985(a), Stauffer and Peterson 1985(b), Stoddart et al. 1975, USFS 1995, Wood et al. 1989, Wyoming Game and Fish Department 1993, Zwickel et al. 1968, Zwickel 1972). Some plant and wildlife species show no tolerance at all for livestock use (Bock et al. 1993, Fleischner 1994). In extreme cases this can lead to localized extinction on a landscape grazed by livestock (Bock et al. 1993, Fleischner 1994, Suminski 1991, Hamlin and Ross 2002, Wisdom et al. 2002 (a&b)). Monitoring or managing livestock utilization or impacts is problematic (Gillen et al. 1984, Harrison and Thatcher 1970, Hockett 2002) and thus some areas are best managed without livestock if the needs of fish, wildlife, native plants, sensitive soils and water are important (Mussehl 1963, Zwickel et al. 1968, Zwickel 1972, Stauffer and Peterson 1985(a), Stauffer and Peterson 1985(b), Myers 1989, Chaney et al. 1990, Schultz and Leininger 1990, Bock et al. 1993, Rieman and McIntyre 1993, Wyoming Game and Fish Department 1993, Hockett and Roscoe 1993, Fleischner 1994, Overton et al. 1994, Corning 2002, Davis et al. 2002, Hockett 2002). Fences can increase predation of pronghorn fawns (USFWS 1993) and stock tanks and salt grounds can significantly degrade and fragment sage grouse habitat (Hockett 2002). Predation of pronghorn fawns (USFWS 1993) or ground nesting and foraging grouse (Schroeder and Baydack 2001) may be a limiting factor on marginal or degraded habitat due to removal of cover and food by livestock grazing. Predation may also limit pronghorns where predators are high in relation to pronghorn numbers (USFWS 1993). Removal of wolves from a landscape can lead to a significant increase in other predators such as coyotes (Hamlin and Ross 2002) which alters predator-prey relationships. However, predator control programs are very seldom effective in boosting prey numbers, especially over the long term (USWFS 1993, Schroeder and Baydack 2001). Improving rangeland (habitat) conditions and providing suitable habitat each year is the key to balanced predator-prey relationships (USWFS 1993, Schroeder and Baydack 2001). Increased predation is a cumulative effect associated with degraded habitat quality (USFWS 1993, Schroeder and Baydack 2001). Habitat quality and quantity can be degraded annually independent of the timing of the livestock grazing treatment prescribed (Brown 1982). For example, grazing utilization levels of 46-50% appear marginal for maintaining ground nesting and foraging bird populations in any given year (Brown 1982). Grazing effects are compounded if utilization is relatively uniform. This has negative implications for the common range management goal of achieving uniform distribution of livestock use across the landscape through the use of "range improvements" such as stock water tanks, salt grounds and fences (Hockett 2002). Removal of herbaceous grass cover though grazing has significant negatives effects for ground nesting (Beck and Mitchell 2000) and foraging birds even though grass removal may result in a substantial increase in their food (Brown 1982). This is related to the loss of security cover provided by the grass while foraging (Brown 1982) and nesting (Beck and Mitchell 2000). Brown (1982) found locations consistently grazed below 35% utilization by weight were dominated by taller, climax bunchgrasses. Sage grouse, blue grouse, and ruffed grouse nesting is often initiated before regrowth of new vegetation occurs in the spring, thus these birds must rely on residual vegetation from the previous growing season to have adequate herbaceous nesting cover. Removal of herbaceous grass cover can degrade breeding habitat and decrease use of the area by breeding populations (Brown 1982, Mussehl 1960, Mussehl 1963, Zwickel et al. 1968, Zwickel 1972, Stauffer and Peterson 1985(a&b)). Lack of escape or hiding cover discourages mated pairs from establishing initially and/or makes it impossible for them to survive if they do establish (Brown 1982). Brown (1982) found most of the variation in quail pair density was accounted for by varying utilization levels. The authors concluded that the degree of utilization by livestock is the overriding factor limiting Mearns quail pair density and the inherent productivity of an area. Ninety-five percent of the mated pairs studied were found on areas having utilization levels of 45% by weight or less for their entire home range and 98% occurred in areas of 50% or less utilization. Although about 50% of the area was grazed at >50% utilization by weight, only 2% of the pairs encountered occurred in these areas (Brown 1982). As utilization levels decreased, habitat quality increased. Tall herbaceous cover is critical for hiding cover for grouse because the initial reaction to danger is to "freeze" (Patterson 1952, Brown 1982, Mussehl 1963, Zwickel 1972). Although effective in dense cover, this escape mechanism is useless and even detrimental once grass cover has been seriously reduced. Brown (1982) found eighty three percent of the suspected avian predation events occurring on his study site took place in areas heavily grazed by livestock. Three of these were in feeding areas that were only 18.3 m from adequate cover which the quail had left during foraging activities. From the standpoint of maintaining breeding populations of ground nesting and foraging birds such as grouse and quail, excessive livestock use (50% or more utilization by weight) which develops at one time of the year can be equally as detrimental to those developed at another (Brown 1982). 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. Nest production for waterfowl in Montana also exhibited these fluctuations related to rest-rotation grazing impacts, and production was severely limited when adequate residual herbaceous vegetation was lacking in the spring due to the previous years grazing treatment (Gjersing 1975). In eleven of 12 instances, complete rest or grazing only during the spring and early summer, resulted in an increase in the number of waterfowl broods the following spring. In five of eight instances, grazing during the summer and fall resulted in a decrease of broods the following spring (Gjersing 1975). Clearly, fifty to fifty five percent utilization by weight from livestock is detrimental to a variety of wildlife habitats, and this level of use is considered "heavy" and will not result in upland rangeland improvement (Holechek et al. 1991). Galt et al. (2000) recommend a 25% harvest coefficient on arid and semi-arid rangelands with up to 35% for the more humid Great Plains states. The 1997 B-DNF FP Riparian Amendment modified overall Forest direction for management of riparian areas. The Riparian Amendment states: "Riparian-wetland areas across the BNF Planning Area are, at a minimum, in proper functioning condition." and "Immediately adjust land management practices, where needed, so they contribute to the restoration or enhancement of Upper Missouri westslope cutthroat trout populations." and "Restore and maintain suitable habitat for riparian-wetland associated threatened, endangered and sensitive (TES) species, management indicator species (MIS) and beaver by accomplishing vegetation objectives (emphasis added)." and "Where such site-specific DFC has been determined and existing condition is less than DFC, establish upward trends in vegetation functions within 3-5 years, and in physical functions in 5-10 years. Upward trend must be sustained toward either proper functioning condition of DFC." and "Recover and maintain the composition and structure of native riparian plant communities achievable within existing site potential, sufficient to achieve and maintain DFC." Grazing livestock at 50-55% use by weight from public lands is not consistent with these goals and objectives. Replace Allotment Management Planning (AMP) with Habitat Management Planning (HMP): The AMP paradigm is outdated, focuses on the needs of exotic species and a few permittees (many are absentee landowners or out of region permittees), and is neither ecologically or watershed based. AMP is not responsive to the needs of the general public, soils, water, plants, air quality (prescribed burning to create forage for livestock) or fish and wildlife habitat protection and population conservation. We suggest the various agencies develop a map based draft report illustrating the existing AMP situation such as the BLM did for wild and scenic rivers (BLM 2002(c)). Conflicts with the current grazing situation can then be discussed and debated, such as domestic sheep in bighorn sheep habitat, and a final report which minimizes or eliminates the adverse effects associated with livestock use program can be produced that can then be carried forward to each respective draft land use plan EIS. We also suggest BLM, USFS and the FWP establish a protocol for HMP within given MAs at the watershed level for fish and on a habitat basis for wildlife. We suggest the model applied by Murphy and Noon (1992) as suggested by Rieman and McIntyre (1993) is an excellent starting point for land use planning decisions. Models discussed by Wisdom et al (2002(a&b)) and Hemstrom et al. (2002) are also good planning tools for the sagebrush-steppe ecosystem. Domestic livestock grazing should not be emphasized on public lands in the new land use plans, rather allowed from time to time, if specific circumstances provide an opportunity for use without resource conflict. Fish and Wildlife: We support watershed level, vegetative habitat type and habitat based land use planning that encompasses the seasonal needs of fish and wildlife first. Habitat (soils, plants, water and air) must be protected so fish and wildlife can be conserved. As mentioned earlier, we believe the best way to achieve thriving and sustainable populations of fish and wildlife is to establish management areas based on their habitat needs. Clearly, status quo and mitigation is insufficient for threatened and endangered species. For sensitive species such as sage grouse, pygmy rabbit, westslope cutthroat trout and fluvial arctic grayling, status quo and/or mitigation is also insufficient for habitat recovery. Status quo and/or mitigation is also insufficient for locally extirpated species such as bison, bighorn sheep, beaver and aspen. Proactive identification of seasonal habitats along with passive and active restoration and protection strategies will need to be implemented to recover these species (Murphy and Noon 1992, Rieman and McIntyre 1993, Wisdom et al. 2002(a&b), Hemstrom et al. 2002) and make sense for the conservation of other species such as deer, antelope, moose and elk. Habitat is the key to fish and wildlife population conservation over the long term. We suggest the concepts outlined by Murphy and Noon (1992) and Hemstrom et al. (2002) can be successfully applied for antelope, moose, elk, bison, bighorn sheep, mule deer, beaver, grouse, westslope cutthroat trout, fluvial arctic grayling and other species. This will require a significant paradigm shift, however, in current USFS, BLM and FWP management priorities. Management Indicator Species (MIS): Please list all current MIS, the habitats they represent and the current and long term trends for these species. The MIS concept seems sound, and unless someone has a better idea should be retained, improved upon and expanded to BLM and FWP lands. The MIS concept can be improved by identifying and securing at the watershed or habitat based level the needs of MIS species up front. We suggest MIS seasonal habitats be identified to eliminate or significantly avoid human induced habitat degradation within key habitats for these native species. This is preferable to the established AMP paradigm that ignores watershed boundaries and the ecological needs of native species. The AMP revolves around the needs of an exotic ungulate that is confined within a fence. This paradigm results in a piecemeal, fragmented planning process, both temporally and spatially. Resource managers are forced to mitigate the impacts of proposed actions and serve a permitted few, rather than proactively enhance and protect the seasonal habitats of native species. Recovery and conservation of fish and wildlife populations thus becomes problematic, as seasonal habitats remain fragmented, degraded and in a constant state of disrepair. MIS should be identified that best represent the health and function of various watersheds, ecological processes or habitat types and their interspersions. Examples include beaver as a keystone component and indicator of riparian-wetland function; ruffed grouse as an indicator for aspen community types; sage grouse as an indicator of the sagebrush-bunchgrass-riparian complex; spruce grouse as an indicator of spruce forest health; westslope cutthroat trout and fluvial arctic grayling as instream fisheries and aquatic habitat indicators, including water quantity and quality; Canada lynx or an owl as an interior forest health indicator; bighorn sheep as an upland shrub-bunchgrass rangeland indicator (and as a barometer of disease outbreaks); and a large carnivore such as the grizzly and/or wolf as a predator-prey indicator and a barometer of habitat connectivity. Sensitive Species: The Forest Service Manual (2670.15) defines Sensitive Species as "those plant and animal species identified by a Regional Forester for which population viability is a concern as evidenced by significant current or predicted downward trend in numbers or density" and..."habitat capability that would reduce a species existing distribution" (emphasis added). "While most species are provided for by managing diverse habitats, Endangered, Threatened and Sensitive Species receive specific Biological Evaluations for the effects of management activities on National Forest system land. Conservation measures are incorporated for endangered, threatened and sensitive species and the adverse effects of management activities are either eliminated or mitigated. " Three of the current MIS identified in the 1987 FP and relevant for this landscape (grayling, cutthroat trout and sage grouse) are also USFS designated sensitive species. All three have been petitioned for listing under the Endangered Species Act. Mitigation is not good enough. Proactive habitat restoration and protection is needed. Exotic Plant Species and Weeds: Please list which plants you have identified as weeds, their locations on a map, what the rationale is for considering them weedy and what if any control efforts will be conducted. Please also list any exotic species that are determined not to be weeds, where they are located and why they occur and will continue to or not occur on this landscape. We are concerned that the agencies intend on spending a great deal of time, money and effort on chemical weed control. We are also concerned that a recent B-DNF EIS on weed control did not receive adequate public review. How many interested publics commented on this EIS? What are the three major causes leading to exotic species establishment and spread? Although some chemical weed control is probably warranted it is symptomatic, and often leads to other resource problems such as impacts to non-target species and water quality. We feel a better long term approach is to adopt the "first, do no harm" paradigm of preventative medicine in large doses. Examples include, closing highly erosive roads, illegally created roads, timely trail maintenance, eliminating livestock disturbances (stock tanks, salt licks and fences) and abandonment of other ground disturbing activities. Adopting a preventative or do no harm management approach will eventually result in an opportunity to reduce government spending while at the same time improving habitat and water quality. Roads: We believe there are too many roads fragmenting and degrading important fish and wildlife habitat within the project area. By the early 1950’s, it was recognized and documented that too many roads and/or too much off road vehicle travel had significantly degraded and fragmented sage grouse habitat and contributed to the sage grouse’s demise in Wyoming (Patterson 1952). Roads, especially on BLM lands, continue to be a significant and expanding problem in sage grouse and other wildlife habitats on the project area (Personal Communication with BLM and USFS personnel). Too many roads dissect and fragment currently occupied and historic bighorn sheep habitat as well (Current USFS/BLM Travel Management Maps). Roads also adversely affect elk security habitat in Gravelly Mountains (Hamlin and Ross 2002) and elsewhere on the Forest and BLM lands. Therefore, we suggest the respective agencies produce a map based draft road report that illustrate the existing situation such as the BLM did for wild and scenic rivers (BLM 2002(c)). Then specific road conflicts, closures, rehabilitation and/or seasonal management can be identified, discussed and debated. A final report which significantly reduces the amount of roads and road conflicts can then be forwarded for inclusion in the respective land use plan draft EIS. As hunters, we do not agree that roads should be managed to accommodate hunter harvest of wild game, rather roads should be managed and closed to promote wildlife security on public lands, while still providing reasonable public access. Backcountry areas provide quality walk-in hunting experiences and important core wildlife security habitat. We suggest the agencies do not wait to respond to proposals for managing motorized travel on public lands, but rather act proactively to identify and reverse road created conflicts in important wildlife habitats, especially sage grouse, elk and bighorn sheep habitat. Inter-agency standards for roads and road closures should be established and presented in the Draft Plan(s). Travel Management (Any and all motorized vehicles including ATVs and motorbikes): In general, from our perspective there are too many roads and too much motorized access, especially during hunting season, in what would otherwise be excellent elk and mule deer security habitat. Without the time to get specific, many roads within public land elk and mule deer habitat should be closed either seasonally or permanently to enhance the suitability (quantity) and quality of habitat, as well as the hunting experience. This should be applied where elk and/or mule deer security habitat is limiting or adversely affecting elk and mule deer movements during the hunting season (for example, mass migrations onto private land). This may be especially practical and appropriate on the FWP WMAs. This is true on many BLM and B-DNF lands and some GNF lands as well. AS HUNTERS, WE ASSERT THERE ARE TOO MANY OPEN ROADS DURING HUNTING SEASON. Roads should be considered closed unless signed or marked as open on an interagency travel management map. Road management would go a long ways to improving wildlife security habitat and elk just might stay on some of the public lands. There might be a way to administer/allow access on certain otherwise closed roads for game retrieval during hunting season, maybe at night? Motorized access, on existing otherwise closed roads, strictly for game retrieval is an option FWP should consider on its WMAs and perhaps recommend on key USFS/BLM lands. However, such a proposal would likely fail without adequate and timely administration. Please discuss road or motorized vehicle access conflicts and opportunities on the project area on an FWP Elk Management Unit basis and for sensitive species such as sage grouse and bighorn sheep. Natural Processes: We encourage both the BLM and USFS to anticipate and manage for natural processes such as floods, fire, drought, insects, plant succession, native herbivory, nutrient cycling, severe winters, predation, etc.. These natural processes shape a healthy functioning ecosystems. Restoring natural processes should be a major revision topic. Attempting to disrupt these processes through management may sound good and provide some short-term political benefit, such as fire suppression or flood control, but eventually the ecological bills come due. We believe managing natural fire is the biggest challenge here, and we are happy to see the USFS has listed fire suppression as a major revision topic (USFS 2002(a)). Does BLM agree that fire suppression needs to be revised at the landscape level? While fire ecology needs to be reviewed in detail, we feel there is much confusion about a perceived "lack" or "absence" of fire on this landscape. We also feel there is room for significant debate and education as to what are the causative factors leading to the symptom of fire "absence" . We suggest addressing the causative factors influencing natural fire regimes (fire suppression and livestock removal of fine fuels) (Belsky, and Blumenthal 1997, Peterson, J.G. 1995), rather than endless pursuing symptomatic "lack of fire" effects with more costly and intrusive government intervention (Gruel et al. 1986, Wambolt et al. 2001). Fire Ecology: There appear to be at least 4 major factors influencing fire ecology on the forest-rangeland interface: 1) Removal of herbaceous vegetation (fine fuels) through domestic livestock grazing; 2) Infestations of noxious annual grasses and perennial exotic forbs; 3) Fire suppression activities; and 4) Logging. These factors may work independently or synergistically to create significant disruptions in natural fire regimes, to the point that fire is no longer an important part of a functioning ecosystem but instead a driving force contributing to ecological dysfunction and extirpation of native species, both plant and animal (Wisdom et al. 2002(a&b)). We feel factor number 1 - removal of herbaceous vegetation by livestock grazing is the most significant factor leading to a disruption in fire ecology on grazed landscapes (Arno and Gruell 1986, Gruell et al. 1986, Belsky, and Blumenthal 1997, Peterson, J.G. 1995, Hemstrom et al 2002, Wisdom et al, 2002(a&b)). Often overlooked, annual livestock use leads to removal of fine fuels that prevents or creates a "lack" or "absence" of periodic natural fire. Removal of herbaceous vegetation from grazing leads to succession processes that further modify the plant communities and fire regimes (Arno and Gruell 1986, Gruell et al. 1986, Belsky, and Blumenthal 1997, Peterson, J.G. 1995, Hemstrom et al 2002, Wisdom et al, 2002(a&b)). Eventually, thresholds may be crossed resulting in forest health, sagebrush health, riparian health and aspen health issues that can not be corrected without significant management intervention (Arno and Gruell 1986, Gruell et al. 1986, Belsky, and Blumenthal 1997, Peterson, J.G. 1995, Hemstrom et al 2002, Wisdom et al, 2002(a&b)). Ecological processes, including natural fire regimes and plant succession, have been significantly disrupted under "properly grazed" (45-55% utilization by weight), intensively managed, rest-rotation livestock grazing plans within the project area (USFS 2002(b)). The USFS (2002(b)) outlines that approximately 12,000 acres of sagebrush, grassland and aspen plant communities are being colonized by Douglas-fir within the grazed portion of the Antelope Basin. Conifer forest habitats are also likely affected by the disruption of natural fire regimes due to grazing (Arno and Gruell 1986, Gruell et al. 1986, Belsky, and Blumenthal 1997). Thus, BLM and USFS grazing management necessitates the perceived need for prescribed fire management intervention (Arno and Gruell 1986, Gruell et al. 1986, Belsky, and Blumenthal 1997, Peterson, J.G. 1995, Wambolt et al. 2001, Hemstrom et al 2002, Wisdom et al, 2002(a&b)). Other costly and intrusive vegetation eradication and control methods, including chemical applications to control both native plants (Wyehtia and sagebrush) and noxious weeds are also often perceived necessary to maintain upland range conditions (USFS 2002(b)). The perceived forest, sagebrush, riparian and aspen health problems are associated with a lack of fire, but the cause has not been adequately articulated - removal of fine fuels through prescribed livestock grazing and other government prescribed fire suppression activities. This is further validated by the fact that prescribed fires will not ignite and successfully achieve objectives without first resting the specific management unit from livestock grazing in order to allow for enough fine fuels to carry a fire (personnel communications USFS Madison Ranger District, Gruel et al. 1986). The significant costs to tax payers and the environment warrant a critical review and revision of the livestock management program in the context of the fire management revision section. Aggressive government fire suppression or control activities must be viewed with a critical eye, and steps must be taken to restore and allow for natural fire regimes, especially in backcountry settings. Too often, the disruption of perceived "catastrophic" natural processes leads to the need for more government intervention, which leads to the need for more government management, creating an endless spiral of unnecessary government spending. Supposedly, because the agencies aggressively attempt to put out natural fires, they then need to prescribe fires at a later date (personnel communications USFS Madison Ranger District). We believe, and we believe the science clearly shows, the lack or absence of natural fire is a function of authorized government management activities (fire suppression and grazing) that disrupt natural fire regimes. Livestock grazing is clearly the most prevalent federal and state government management activity on this landscape that artificially removes fine fuels to the point of disrupting natural fire regimes, fire patterns, fire intensities and eventually forest, riparian and rangeland health. Please discuss this matter in detail in your respective EIS’s and outline how each agency will address restoration of natural processes such as natural fire. A thorough economic analysis should detail the costs/benefits of letting most fires burn, as compared to aggressive, costly and often ineffective fire suppression activities. As a part of this discussion, a map based geographic information data layer should be produced that illustrates the date, location and size of all natural fires or "wild" fires that were effectively put out by the respective agency during the historic record that is available. What is the average annual fire suppression budget/cost for each agency? What benefits do these activities provide? Additional map based data layers should illustrate all prescribed fires, and any other vegetation manipulation treatments perceived as necessary to restore ecosystem health due to a lack of fire. For example, please document and illustrate on map data layers all sagebrush chemical control activities, weed or "encroachment" control activities, livestock grazing allotments, pastures within those allotments and any logging projects initiated to restore native aspen, native shrub, riparian area or "forest health" problems for the historical period of record. Drought: Drought is common in Montana (NOAA Paleoclimatology Program Instrumental Data 1895-1995). Drought usually results in significant adverse impacts to sage grouse habitat and populations throughout their range (Connelly and Braun 1997), and is believed to be a significant factor in sage grouse populations declines in Montana (Dusek et al. 2002, Eustace 2002). Drought significantly limits herbaceous cover and forage available for sage grouse (Patterson 1952). Livestock grazing is cumulative to the adverse effects of drought (Patterson 1952, Hockett 2002) and livestock grazing has been identified as a major factor in the range wide decline of sage grouse (Connelly and Braun 1997). Establishing and managing for productive climax vegetation every year in known nesting and brood rearing areas for sage grouse would serve to mitigate the inevitable effects of drought on a regional basis (Beck and Mitchell 2000, Hockett 2002, Prellwitz 2002). We feel this is an excellent idea for sage grouse and other fish and wildlife in southwest Montana. Please analyze and discuss the pros and cons of establishing climax vegetation at the landscape level on an ecological or watershed basis as an alternative in the Plan(s). As an example, on Bowdoin National Wildlife Refuge, even though greater sage grouse (Centrocercus urophasianus) habitat may be less than optimal due to a low density of plains silver sagebrush (Artemisia cana cana), sage grouse use of the refuge during spring, summer and fall appears stable (Prellwitz 2002). Most of the refuge has been ungrazed by livestock since the mid 1970’s. However, pronghorn antelope (Antilocarpa americana) heavily browse much of the plains silver sagebrush annually. Prellwitz (2002) attributes the survival of chicks to the abundance and proximity or moist areas where lush forbs and insects are available for food. During the severe drought of 1988, a sage grouse nest was found on the refuge with seven eggs in dense grass cover beneath one of only a few plains silver sagebrush plants in the area. The nest hatched at least four eggs by June 27, 1988 during one of the hottest months on record. Daytime high temperatures were >32C on 22 days with nine of those days exceeding 38C (1988 was a severe drought year across the northern great plains in Montana). Several nests of other ground nesting species dehydrated and were lost during the same time period. Total precipitation in 1988 was 24.4 cm, far below the long-term average of 31.9 cm (Prellwitz 2002). The sage grouse choosing to breed and nest on Bowdoin NWR appear to be productive with good survival of chicks, despite no big sagebrush (Artemisia tridentata) and less than optimal cover of plains silver sagebrush (Prellwitz 2002). The refuge is located about 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. Prellwitz (2002) suggests that sage grouse may be dispersing from those large blocks of sagebrush to better nesting conditions on the ungrazed refuge. Climax Management Areas (CMAs) should be a part of the Proposed Action as both a Best Management Practice (BMP) and Conservation Measure to protect critically important seasonal habitats for sensitive species. CMAs can also be established to restore degraded soils, enhance riparian-wetland water quality and quantity and to provide for the needs of climax species. An example on the project area is the Everson Creek watershed. We suggest the B-DNF and BLM manage the public lands within Black Canyon and the north and south forks of Everson Creek as CMAs. We would encourage the FWP to work very closely with the adjacent private land owner (Dragging Y Cattle company) to manage the conservation easement on the downstream sections of these watershed to enhance and protect instream flows, water quantity and quality and fish and wildlife habitat. Many of the slopes of the Black Canyon watershed are very steep and inappropriate for livestock use. This leaves livestock little choice but to camp on the ridges and drainages, resulting in localized overuse of both. The ridges provide critical season long elk range and Black Canyon creek and its tributaries provide critical elk, moose and fish habitat. Mesic habitats (springs and meadows) also tend to get over used by livestock due to their limited nature and desirable characteristics. Blue, spruce, ruffed grouse and sage grouse use many of the mesic habitats in the area to raise broods. Beaver may be a missing component, as well as westslope cutthroat trout from the riparian areas. Aspen stands at the head of Everson Creek are being overused by the combination of native herbivory and livestock use. Portions of the Everson Creek watershed, including big sagebrush-bunchgrass rangelands and riparian habitat for westslope cutthroat trout, have been essentially protected from domestic livestock use for about 10 years. Native herbivores, browsers and other wildlife continue to use the area, at times extensively. In the past, the combination of livestock use and native herbivory was devastating for this riparian area (See Video from 1992 provided to BLM Jan. 10, 2003). Beaver were historically present in this watershed, however habitat conditions were severely degraded and beaver appear extirpated from this area. The viability of the fishery remains at risk, especially if subjected to future livestock impacts. This example of a CMA should be maintained into perpetuity. We believe the site currently protected from livestock use is starting to reveal the potential characteristics of a climax big sagebrush-bunchgrass-forb type. As well, riparian-wetland area recovery is evident but not yet complete. Historically (10 years ago), beaver were a keystone component of this watershed. Their recovery is discussed as a goal of the USFS 1997 Riparian Amendment to the Forest Plan. We view their eventual return as further evidence of riparian habitat recovery, improving dynamic stability and restoration of properly functioning ecosystems. There are at least two compelling scientific reasons for the establishment of CMAs. First, CMAs provide for the inevitable effects of natural processes including drought, floods, fire, insects, severe winters and native herbivory, and second, CMAs provide a baseline control for monitoring any proposed grazing mitigation standards applied within any designated livestock management areas. CMAs would meet many if not all of the special habitat management actions compatible with BLM ACEC nominations for bighorn sheep, sage grouse, native fish, beaver, sagebrush habitat types, etc.. CMAs meet the USFS Management Direction provided in the USFS Natural Resource Agenda and the Northern Region Overview as described on pages I-2,3&4 of the Horse Prairie, Maiden Creek, Section 29 allotments EA. Goals include:
CMAs are appropriately applied as BMPs on non-functioning streams or watersheds as outlined in the 1997 Riparian Amendment (ROD p. 15). CMAs would protect or enhance fishery habitat, riparian areas, recreation and other forest uses while allowing grazing on properly functioning riparian areas (II-10). We suggest CMAs be applied on a watershed or ecologically based scale. Missing Components: Both BLM and USFS lands in southwest Montana have many locally extirpated species. Some examples include bighorn sheep, native fish (westslope cutthroat trout, arctic grayling, others?), bison, beaver, sage grouse, spruce grouse, ruffed grouse and aspen. Other examples surely exist and should be discussed in your respective EIS’s. We encourage both the BLM and USFS to outline alternatives that will seek to restore many if not all of the native missing components. Some of these species like beaver and bison might just come back on their own, given the chance and adequate habitat. 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. Bison skulls have been found in the Horse Prairie watershed, Muddy Creek, Antelope Basin and elsewhere, documenting their historical presence on the landscape. Rock carans still line the shores of wetland-bogs along the Red Rock River (many of which are now under water at Clark Canyon Reservoir) where native Americans herded and hunted bison to their death. Bison stuck in the wetland muck were easy prey for native hunters. Clearly these animals were historic inhabitants, and given the chance, they have shown the desire and ability to migrate in a manner similar to elk. Apparently, elk in Idaho transmitted brucellosis to cattle in 2002. These elk migrate to and from YNP. This disease outbreak resulted in the entire affected cattle herd being destroyed and an emergency situation that resulted in a series of testing and vaccination protocols for a variety of different cattle in Idaho. Although subsequent tests came up negative, another outbreak of brucellosis in Idaho will cost this state its brucellosis-free status. This would have a significant affect on the States economy and may result in significant consequences for both domestic and wild ungulates. Elk also migrate from YNP north and west into Montana. Some of these animals likely take up residence in the Gravelly Range, Madison Range, Gallatin Range, Antelope Basin and the Clark Canyon Watershed including the Centennial Valley. As well, it has been documented that predators, including wolves and birds, have been transporting brucellosis infected body tissues throughout the area (Keith Aune, FWP Wildlife Veterinarian, Jan. 16, 2003, Progress Report to GYIBC). BLM, USFS, USFWS, FWP and DSL planning should anticipate and allow for the natural migration and emigration of wild bison from YNP to public lands that historically provided habitat for wild bison. Should the opportunity present itself, inter-agency planning should provide for the needs and management of a resident herd, including fair chase regulated hunting. In fact these opportunities are being currently explored by the Montana legislature (LC1657 - Sport hunting of bison as a management tool - Draft is being reviewed by requester, Gary Perry and LC1750 - which provides for buffalo hunting in certain areas - Draft on hold Sponsor: Steven Gallus). The GWA supports the goal of a habitat based, free ranging wild bison herd in the Greater Yellowstone area, including management through public hunting administered by FWP. These are future foreseeable actions important to the BLM and USFS Land Use Planning process. Other missing components may not readily pioneer into historic habitat and may need reintroduction assistance from the FWP. Agency Land Use plans should recognize these opportunities and outline steps to achieve them as a priority for restoring ecosystem function. Non-functioning and Functioning at Risk (FAR) riparian areas should be protected from further management induced disturbance until proper function is established and to enhance downstream WQLS. The USFS is prescribing significant cattle caused impacts to sensitive springs, wetlands, streambanks and fisheries. Soil trampling and compaction is a major concern. Water quality and quantity is another significant concern. These impacts can be eliminated by implementing Conservation Measures that excluded livestock use of these sites. Water Quality Limited Streams (WQLS): Please note all the WQLS on the project area and what work has and will be done to develop a recovery and monitoring program. We suggest cooperation and coordination with the Montana Department of Environmental Quality (DEQ) is way over due. We cite project level analyses from the BLM’s Upper Horse Prairie Watershed Assessment Determination (BLM 2003) and the USFS Antelope Basin Revised EA (USFS 2002(b)) where water quality impacts are either ignored or not sufficiently analyzed. We suggest coordinated watershed level planning with DEQ must take place before project level decisions that may impact water quality and quantity are finalized on federal public lands. A standardized water quality and quantity sampling and monitoring protocol should be outlined in the appropriate land use plans that can be effectively applied to project level decisions. Acute Effects from Grazing: Livestock grazing will result in significant acute effects to fish and wildlife habitats, including soils, vegetation, water quality and quantity. The water quality and quantity of some of the springs and streams our members have used for drinking water have been degraded by various seasonal grazing treatments on both the Forest and BLM lands, even when the agency has found these lands to be "properly" grazed. These acute effects from annual grazing and trampling prescriptions can degrade not only non-functioning and FAR sites, but also properly functioning sites or uplands in "good" (high seral) or even climax condition. Acute grazing effects, combined with the inevitable impacts of drought, flood (severe thunderstorms), fire and native herbivory, can lead to significant cumulative effects which degrade fish and wildlife habitats annually and thus populations seasonally or long term. Proactive Conservation Measures are necessary to reverse the trends for sensitive species and MIS in down trends on the project area. The acute effects of the grazing proposal on sensitive species can be largely eliminated by implementing Conservation Measures that protect important seasonal habitats that are used each year, such as westslope cutthroat spawning habitat or nesting and brood rearing areas near leks or breeding territories for ground dwelling birds such as sage grouse. This fidelity for seasonal habitats may preclude the need to protect wide expanses of herbaceous vegetation. Water Quality and Quantity What type of water monitoring plan does BLM and USFS have in place and how will it be improved? Livestock use of BLM and USFS lands is currently degrading water quality in many areas and also decreasing water quantity available for plants and wildlife. How will BLM and USFS mitigate or change this situation? Rest-rotation: The Plan should define rest-rotation grazing. Rest-rotation grazing is a livestock production system that takes many different forms and yields many different results. Rest-rotation livestock grazing often involves fences, stock tanks and salt licks all of which can lead to "sacrifice areas" (Hockett 2002). These so called "range improvements" often fragment and degrade sage grouse habitat (Connelly et al. 2000, Hockett 2002). We suggest the agencies adhere to the definition of rest-rotation grazing to mean 3 pastures utilized in a manner outlined by Hormay (the citation for this paper is available from FWP). Additional Livestock Management Alternatives: Management Areas approved for livestock grazing should include cessation of grazing by Aug. 1 or during the "hot season" as a conservation measure for properly functioning riparian area maintenance, protection and/or improvement, cool season bunchgrass recovery (improved vigor/height and seed production) and improved residual cover the following spring for nesting and brood rearing cover for ground dwelling birds. Also, an alternative that caps livestock utilization at 25%, allows 25% for native herbivores and the remaining 50% for resource protection within livestock management areas should be considered in detail for areas deemed suitable and capable of producing livestock without resource conflict (Holechek et al. 1999, Galt et al. 2000). Such a reduction may be necessary in grazed watersheds in order manage for the inevitable effects of droughts and floods and to provide for the needs of indigenous fish and wildlife (food and cover). Best Management Practices (BMPs): Consider the following as potential BMPs to mitigate livestock grazing impacts: 1. Extended rest or CMA; 2. Cessation of grazing by Aug. 1 or "hot season"; 3. Removal of traditional "range improvements" - fences, stock tanks, salt grounds; 4. Reintroduction’s of native species: fish, bighorn sheep, beaver; 5. Removal of non-natives (domestic sheep) 6. Reductions in the amount of permitted livestock. 7. Limit livestock utilization to 25% across the board. Livestock Improvements: Livestock improvements such as fences, water developments, stock tanks, pipelines, salt grounds, etc. are often referred to as "range improvements". This is misleading, because these structures can often create conditions extremely detrimental to range and wildlife resources by concentrating livestock use in certain areas (Stoddart 1975, Hockett 2002). In fact they can be lethal. We have witnessed animals that apparently drowned in a stock tanks on the B-DNF. Sage grouse, mule deer, elk, moose and other animals have been entangled in fences on the forest and died or been severely wounded. Fences act as barriers, fragmenting habitat for antelope and other wildlife. Salt grounds and water tanks concentrate livestock in a small area and may attract bighorn sheep or other wildlife that are susceptible and vulnerable to livestock diseases. Soils and vegetation are often completely trampled, compacted and killed near these "range improvements". These sites become open sores vulnerable to erosion, noxious weed or other undesirable plant infestations. Please thoroughly discuss these aspects of "range improvements" so the public can see these for what they are. We encourage you to avoid building or repairing any of these structures unless they are designed in conjunction with climax management areas that are protected from livestock use. The range will likely be improved for native plants and animals if existing livestock structures are removed and the grazing capacity is adjusted accordingly. This should be an alternative the BLM and USFS consider in detail, removing so called range improvements. Please detail in the EIS how many, what type and the location of all current range improvements on the project and cumulative effects analysis area in tabular and map form. Ecological Costs of Livestock Use: Please refer to Fleischner (1994) for a comprehensive review of information from over 170 literature citations regarding the ecological costs associated with livestock grazing in western North America. Examples of ecologically costs include 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. This paper notes that livestock tend to congregate in riparian ecosystems. Because riparian areas are among the biologically richest habitats in arid and semiarid regions, the ecological costs of grazing are magnified in these sites. This has proven to be the case on the project area, thus an alternative that protects these areas from livestock use should be considered in detail. Major Issues: There is a need to address wild bison management as a major driving issue in these Land Use Planning decisions. Wildlife and domestic livestock disease management is also a major issue, including brucellosis in elk, bison and other wildlife, Chronic Wasting Disease, Mad Cow Disease and the numerous domestic livestock diseases that affect bighorn sheep and other wildlife including IBR, BVD, pasturella and others. Add suitability and capability of livestock use and livestock management as major issues for the DRA RMP and USFS FP. Competition with native ungulates for food, space and water, predator prey relationships and disease are major concerns. Establishing Climax Management Areas to promote and protect native plants and processes should also be a major driving issue. Medical health and diet should be considered a major issue in terms of the nutritional value of free ranging wildlife and the opportunity to hunt these animals for human consumption (Newsweek, Jan. 20, 2003 - The Perfect Diet). These lands have exceptional potential to produce leaner, free-ranging big game animals and other fish and wildlife suitable for human consumption on a sustainable basis. Elk, bison, mule deer, antelope, moose, bighorn sheep, mountain goats, mountain lions, black bear, grizzly bear, grouse, waterfowl and fish are among some of the free-ranging animals using the project area. Wild and Scenic Rivers Please recommend the Gallatin, Yellowstone, Jefferson, Madison, Beaverhead, Big Hole, Red Rock, Upper Ruby, West Fork of the Madison, West Boulder and Boulder rivers along with Big Sheep Creek for designation by Congress as Wild and Scenic Rivers. Research Natural Areas (RNAs): What if any RNAs are being proposed. Coordination How is this planning effort being coordinated with the U.S. Fish & Wildlife Service, Red Rock Lakes National Wildlife Refuge, Department of State Lands, Montana Department of Fish, Wildlife & Parks, Madison, Beaverhead and Gallatin Counties, private landowners, Targhee & Salmon National Forests in Idaho, the BLM in Idaho, the Idaho Department of State Lands, the U.S. Sheep Experiment Station and the Idaho Fish and Wildlife Department? We suggest coordination occur on a watershed and habitat connectivity basis (ecologically and biologically) on both the landscape and local planning levels. Coordination between these agencies and landowners may prove critical for the survival and successful management of several fish and wildlife species and habitat complexes, including sage grouse and the sagebrush-steppe habitat complex. The plight of sage grouse populations in Montana is often assumed a result of winter habitat destruction in Idaho and Montana. Where and how has this winter habitat specifically been altered or destroyed and what winter habitat remains on public and private lands within the sage grouse breeding complex that uses habitat in both Montana and Idaho? What other wildlife may be dependent on habitat in Idaho, Wyoming, private lands or on other public lands? Open Space: Are there any conservation easements on private lands within the adjacent planning area? If any private lands will be maintained for open space as a result of this project please identify their location and owner. Maps and Photographs: Please includes maps and photographs of the various resources on the project area in the appropriate EIS. Some items that would be very useful in map form include land ownership, topography, riparian areas, vegetation (potential habitat types and existing community types), soils, wildlife habitats, open water, roads, fences, salt grounds, sheep bedding grounds, corrals, stock tanks, pipelines, water developments or diversions, wells, range conditions, sagebrush control efforts, seedings, noxious weed locations, exotic plant locations, logged areas, historic fire locations, oil/gas developments, farm locations, ranch locations, subdivisions, etc.. Please include photographs of illustrating resource damage where it is occurring and selected monitoring locations. VEGETATION: Please develop a vegetation map of the project area highlighting the presence of key native plant species and exotic species. Both a habitat type and existing vegetation map data layer should be produced in the EIS. Some of our suggestions are: I. Native species A. Trees Aspen and cottonwood (Populus sp.): Critical for a variety of wildlife. Agencies should consider these trees keystone plants and manage for mixed age stands that ensure their long term survival. White bark pine (Pinus albilcaulis): Key component of grizzly habitat B. Shrubs Big sagebrush (Artemesia tridentata): a non fire sprouter and key indicator of sage grouse, antelope habitat and other sagebrush obligate species. Please distinguish the three main sub-species: Basin, Wyoming and Mountain big sagebrush. Three-tip sagebrush (Artemisia tripartita): a fire sprouter and an important component of sage grouse habitat Low sagebrush (Artemesia arbuscula): an important component of sage grouse habitat Silver sagebrush (Artemesia cana): a fire sprouter and mesic indicator Red-osier dogwood (Cornus stolonifera): A key decreaser in areas grazed by livestock Antelope bitterbrush (Purshia tridentata): A key decreaser in areas grazed by livestock Curlleaf mountain mahogany (Crecocarpus ledifolius): A key decreaser in areas grazed by livestock Geyer willow (and other willow species) (Salix sp): Key decreasers in areas grazed by livestock Serviceberry (Almelanchier alnifolia): A key decreaser in areas grazed by livestock Chokecherry (Prunus virginiana): A key decreaser in areas grazed by livestock Winterfat (Eurotia lanata): A key decreaser in areas grazed by livestock C. Grasses Bluebunch wheatgrass (Agropyron spicatum): A key decreaser in areas grazed by livestock Thickspike wheat grass and western wheatgrass (Agropyron sp.) Green needlegrass and Columbia needlegrass (Stipa sp): key decreasers in areas grazed by livestock Richardson’s needlegrass (Stipa richardsonii): may show variable response to grazing Rough Rescue (Festuca scrabrella): A key decreaser in areas grazed by livestock Brookgrass (Catabrosia aquatica): A key decreaser in areas grazed by livestock Basin wildrye (Elymus cinereus): an awesome plant Idaho fescue (Festuca idahoensis): usually an increaser in areas grazed by livestock D. Forbs Long-leaved evening-primrose (Camissonia subacaulis): Moist meadow habitats Hairy arnica (Arnica mollis): Along streams, seeps and springs Orange arnica (Arnica fulgens): found in big sagebrush uplands Arrow-leaf balsam root (Baslamorhiza sagittata): often associated with three-tip or big sagebrush Columbines (Aquilegia sp.): Along streams, seeps and springs Orange mountain dandelion (Agoseris aurantiaca): an important food for sage grouse Tailcup lupine (Lupinus caudatus): found in big and three-tip sagebrush Hawksbeard (Crepis sp.): an important food for sage grouse Longleaf phlox (Phlox longifolia): an important food for sage grouse Desert parsley (Lomatium sp.): an important food for sage grouse Milkvetch: (Astragalus sp.): found in sagebrush uplands Tall larkspur (Delphinium occidentalis) Unique and Rare native species identified by BLM, USFS, FWP, USFWS or other resource agencies. II. Exotic Species Over-grazing of native bunchgrasses in the sagebrush/grasslands near the turn of the 20th century is well documented (Harrington 2002). The native plant communities associated with sagebrush/grassland habitat type are extremely susceptible to alien plant invasion (Harrington 2002). Invasion of exotic plants into the sagebrush/grasslands, such as downy brome, can permanently change the ecology of this habitat type (Harrington 2002). Other exotic species of concern include but are not limited to: Crested wheatgrass, Kentucky bluegrass, timothy, smooth brome, quackgrass, redtop, orchard grass, tall fescue, creeping meadow foxtail, bulbous bluegrass, yellow sweetclover, alfalfa, dandelion, spotted knapweed, leafy spurge, Canada thistle, Dalmatian toadflax, houndstongue, common tansy, cheatgrass brome, Japanese brome, ripgut brome, downey brome, crabgrass, barnyardgrass, medusahead, sulfur cinquefoil and others. Please map these exotic species invasions for public review. We believe prevention is the best cure for exotic species invasion. Economics: The value of hunting, fishing, hiking and wildlife viewing is substantial to the state of Montana’s economy (Montana Fish, Wildlife & Parks. 2002). The demand for these recreational opportunities and amenities continues to grow and exceeded $1 billion in 2001 (Montana Fish, Wildlife & Parks. 2002). Managing the supply of fish and wildlife is dependent on habitat protection. Without habitat, fish and wildlife populations can not be conserved, and the opportunities to enjoy them will be lost. We encourage the adoption of Land Use Plans that recognize and protect habitat, while allowing for conservation of fish and wildlife. Thank you for reviewing these comments. Sincerely,
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