GWA Horse Prairie Comments

Jan. 10, 2003

Field Manager
Bureau of Land Management
Dillon Resource Area
1005 Selway Dr.

Dillon, MT 59725

Subject: BLM Horse Prairie Project Level Planning - Scoping Comments

Dear BLM Field Manager:

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 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. Thank you for taking the time to meet with us in Bozeman on Friday Jan. 10, 2003 to discuss the BLM’s planning process in general, and specifically the project level planning activities that are currently underway in the Horse Prairie watershed. We would appreciate your additional consideration of the following written comments and scientific literature regarding potential management actions in the Horse Prairie watershed.

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 climax vegetation management 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). We feel this is an excellent idea for sage grouse and other fish and wildlife in the Horse Prairie watershed. Please analyze and discuss the pros and cons of such an alternative in the environmental assessment (EA). Are there currently any areas within the Horse Prairie watershed where BLM is managing for climax vegetation and processes?

The following is a basic outline of a climax management area alternative that recognizes the majority of the Horse Prairie watershed will continue to be grazed by domestic livestock. We are curious as to how many animal unit months (AUMs) of livestock forage would be lost if the following steps were taken. Could you please display these results in the EA?

Climax Management Area Alternative

1. We suggest the preferred alternative establish climax riparian, fish and wildlife management areas: There appears to be a fundamental conflict between livestock access to streambanks and fisheries habitat/water quality protection (See attached literature citations including work by Belsky, Fleischner, Clary, Hockett/Roscoe, Kauffman Lusby, Maloney, Myers, Overton, and others). There appears to be an inverse relationship between riparian health and time livestock are allowed access to streambanks. Riparian areas are critical habitat for fish and wildlife (Thomas et al. 1979). Grazing impacts are magnified and cumulative during periods of drought. Climax management areas offer a refuge for fish and wildlife during periods of drought and other natural disturbances such as floods, severe winters, etc..

2. We suggest westslope cutthroat trout streams and non-functioning stream segments or watersheds be protected from livestock impacts. Climax management areas will promote soil and vegetation recovery, water quality protection, long term climax vegetative productivity and all the processes that go with it (nutrient cycling, flood control, fire, water quality, wildlife forage and cover, etc.). Livestock grazing and trampling contributes to vegetation removal, soil erosion, soil compaction, sedimentation and water quality and quantity degradation. Please manage these areas for climax vegetation to restore native species and processes.

3. We suggest expanding the Everson Creek climax management area to include the upstream USFS lands on a watershed basis. Establishing and maintaining such a control watershed will help build accountability and scientific credibility by providing a comparison area (Lusby 1970, Braun 1998, Bock et al. 1999, Beck and Mitchell 2000, Hockett 2002) to adjacent grazed watersheds on both BLM and USFS lands. We understand that the USFS is currently considering project level planning in this area at this very time. The opportunity to consider such interagency coordination is timely. The Gallatin Wildlife Association would like to partner with the BLM, USFS, FWP and the permittee to establish and maintain this native plant, fish, wildlife, water and soil management area.

Within this watershed, there may be an opportunity and/or need to develop partnerships that focus on more intensive management intervention. Such actions are probably beyond the scope of this decision, but we would like to briefly outline some of our ideas for potential cooperative projects. Potential projects could include management actions that stimulate and at least temporarily protect aspen clones, riparian communities and big sagebrush habitats to improve conditions for species such as beaver, ruffed grouse, blue grouse, sage grouse, antelope, moose, elk and mule deer may be necessary or desirable. Bighorn sheep, beaver and native fish re-introductions may also be opportunities to help restore ecosystem function. Restoring natural fire regimes (establishing a let burn or manage burn policy) and the important processes that follow (conifer or forest health issues and aspen/woody sprouters) could become an interagency cooperative priority. The Gallatin Wildlife Association would welcome such partnerships.

4. We suggest managing the sage grouse nesting and early brood rearing habitat within 3 miles radius of the existing lek as climax vegetation. A tall, dense, diverse herbaceous component is essential for sage grouse nesting and brood rearing (Connelly et al. 2000). Drought which reduces herbaceous vegetation and water availability adversely affects sage grouse production (Patterson 1952; Connelly and Braun 1997; Dusek et al. 2002; Eustace 2002). Grazing appears to have similar effects to herbaceous vegetation as drought, except that grazing impacts are selective, often impacting the most desirable herbaceous species first (Hockett 2002). Cumulatively, grazing and drought can be disastrous in any given year, resulting in long term impacts that may be virtually irreversible, such as the invasion of cheatgrass brome or Kentucky bluegrass.

We believe these changes can be implemented with little or no financial harm to the permittee or BLM. Pat Fosse mentioned in a phone conversation with our president that some areas may be “under grazed” on the project area. Where are these areas and how many AUMs are available in the under used areas? Depending on where these areas are and the resources present, consider exchanging use near leks and streams by redistributing livestock use to these under utilized areas. As well, there are a variety of potential funding programs from FWP that could be utilized to implement changes benefiting wildlife. Some of these sources include the Upland Game Bird Enhancement Program ($650,000 annually), the Sikes Act ($75,000 annually, specifically for habitat enhancement on federal public land with FWP lead), the moose permit auction receipts ($4,000 - $20,000 annually), bighorn sheep permit auction receipts ($61,000 - $300,000 annually) and the future fisheries program ($750,000 per year).

We have an established partnership with the BLM, USFS and FWP regarding sage grouse monitoring in the area. We would like to expand this partnership, if necessary, to pursue additional funding programs to enhance fish and wildlife habitat specifically in aspen, riparian, big sagebrush and old growth Douglas Fir habitats. Funds could be used to minimize any economic hardship to the current permittee that might result as a consequence of management actions taken to enhance fish and wildlife habitat, such as establishment and maintenance of the Everson Creek enclosure on a watershed basis. We see opportunity here to improve habitat conditions for sage grouse, blue grouse, ruffed grouse, beaver, moose, bighorn sheep, elk, mule deer, antelope and fish, to name just a few of the “headliners”.

We appreciate your consideration of an alternative that expands the Everson Creek enclosure to a watershed level, and that provides for climax vegetation and processes on certain other fish, wildlife and streamside habitats. Please review the attached literature citations, 1992 video and more recent photographs we provided at the Jan. 10, 2003 meeting as evidence supporting the benefits of establishing and maintaining climax management areas such as the Everson Creek enclosure. If you have any questions regarding this letter or our meeting in January, feel free to contact our current president at his home phone or email address shown below.

Sincerely,

Glenn Hockett
President, GWA
Home Phone: (406) 586-1729
Email: glhockett@mcn.net