Comment on FR Doc # E8-21987 - Western Watersheds Project

To be considered for the Listing of Slickspot Peppergrass: Desertification, Climate Change/Global Warming Long before there was widespread scientific and public awareness of the dire effects of climate change and global warming processes on the planet, ecologists understood the serious adverse effects to arid landscapes of livestock grazing and trampling disturbance in causing desertification. Desertification processes include the adverse and interacting effects of depletion of protective plant and soil cover, accelerated soil erosion, impacts to drainage networks and riparian areas, and other deleterious effects. All of these factors combine to make landscapes hotter, drier and thus more desertified. Such desertification has greatly impacted grazed landscapes in Asia, the Middle East and other arid areas over millennia. Now, in only 150 years or so, the catastrophic effects of grazing on arid western North American lands have caused the very same effects through these interacting processes that promote desertified and hotter and drier lands with accompanying species losses and reductions in biodiversity. See Sheridan CEQ 191, Dregne 1986, Steineld et al. 2006. Such desertification often represents irreversible losses in soils, waters, native species and biodiversity. Agencies knowingly allowing harmful desertification to occur, and taking only minimal steps to stop harm and loss are allowing undue degradation of the public lands to occur. Livestock grazing and other disturbance-facilitated desertification and global warming processes should be a consideration in all agency actions. This is especially he case with livestock grazing, any vegetation “treatment” such as logging or thinning on arid lands, and including prescribed burns and herbicide application of/to native woody vegetation, as is currently being proposed to deforest juniper, pinyon and other arid forest lands. Global warming should be among the existing and reasonably foreseeable environmental effects that agencies always seriously examine in consideration of effects of management actions, as well as cumulative effects of processes relate to shrubsteppe-dependent species. Now with heightened scientific concern about these processes, grazing, treatment and other agency actions in arid public lands require preparation of an EIS to examine adverse effects. This EIS must also consider how ecosystem disturbance/disruption associated with grazing livestock in arid lands, along with the greenhouse gases released by livestock, will promote climate change and global warming processes. This EIS must analyze the ecological and climate change Footprint of: * Grazing, livestock facilities, road building linked to grazing activities, and management actions and other associated activities on all affected lands. A full inventory and analysis of all current grazing, facilities and management disturbance effects in promoting climate change must be provided. * Grazing, facilities and other associated activities part of, or foreseeably associated with, the livestock scheme. * Grazing and other activities linked to the livestock grazing operation here (including such effects as feeding hay on private lands) and the total footprint of he livestock operation. * Effects of existing and foreseeable vegetation treatment (forage, fuels, “wildlife”), mining, energy and other projects in promoting site drying and desertification ad losses in biodiversity, as well as in intensifying and amplifying grazing disturbance effects. In considering climate change, the cumulative impacts are likely (or at least more likely) to be very significant. In addition, agencies may not permit actions that would take or jeopardize listed or candidate T&E species. Agencies must also manage habitats for state and Federal sensitive species to prevent the need for Listing and to maintain viable populations. Listed species habitats must be managed to prevent any further losses and degradation – especially as many imperiled species now are facing threats that will be amplified by climate change. For example, grazing watersheds will promote erosion and sedimentation, which will add to effects of climate change temperature increases on salmonids in the river systems. Grazing will reduce capture and slow release of waters in the springs and streams of the affected lands, resulting in reduced perennial flows – and such effects will be amplified by reduced winter snowpack and rapid runoff due to climate change. Examining effects of climate change, including of agency actions promoting climate change, on sensitive and rare or imperiled species is critical to understanding the scale and severity of effects of an agency undertaking on habitats. This is critical to understanding the effects on populations and population viability over the short, mid and long-term. A federal court has recently held that FWS, a federal agency, must consider climate change in estimating effects of a water project on the delta smelt. Such analysis must be conducted to ensure compliance with sensitive species policies, MIS species concerns, and ESA and other regulations and policies, as well as state policies related to species protection, water quality, and climate change. Agencies clearly have the authority not to authorize actions that would exacerbate existing environmental conditions, just as they have authority to take actions to mitigate (help compensate for) the effects of climate change. A recent GAO report on climate change noted this. Further, a recent US Forest Service report, though obviously bland and politically muzzled to a large extent, warns that global warming now makes the outcomes of various land disturbances LESS predictable. See USDA USFS 2008 “Assessment of Status and trends of Forest and Rangeland Resources” 15 Key Findings. Land management agency actions not only contribute to global warming but also can help offset its impacts. A full rang of actions, and alternatives, to mitigate climate change effects, including on important and sensitive/imperiled species, must be analyzed here. Such alternatives include: permanent closure o lands currently being grazed to livestock grazing, significant reductions in disturbance across arid lands, a full range of passive restoration actions such as removal of harmful facilities or removal of livestock disturbance from remaining better condition habitats. We stress that the full environmental Footprint of current and foreseeable grazing disturbance, as well as other disturbances or uses of that may affect habitats or climate change processes, must be provided. Actions to be considered also include: Removal of grazing from the most change-sensitive areas, removal from areas “at risk” of accelerated cheatgrass or other wed invasions, removal of grazing from all potential sage-grouse (or other species of significant conservation concern) habitats currently grazed, removal of grazing from all sage-grouse habitats in the area, restoration of natural spring flows in areas where existing livestock facility projects may have diverted or reduced water availability, and other actions all must be examined as part of any analysis. Many waters in the interior West, Great Basin, interior Columbia Basin, and Columbia Basin already do not support, or are on the verge of not supporting salmonids, other cold-water biota, or even warm water biota during the summer. Streams are becoming increasingly intermittent due to chronic livestock-caused degradation and desertification, as well as climate change. Climate change will promote not only rapid and compressed runoff with reduced infiltration, but also warmer water temperatures, and drier or less predictable climate patterns in many areas of the Wet. The majority of precipitation will switch from snow to rain. This means diminished flows earlier in the summer and much warmer water. This was explained in detail in scientific presentations at the Columbia Basin inter-agency climate change meeting in Boise, ID in June 2008. See: http://www.fws.govpacific/Climatechange/boiseworkshop.html Diminished water flows means livestock will concentrate more on remaining wetted areas of streams, springs, and seeps - with serious adverse effects – such as effects of concentrated trampling. Diminished water flows means that all possible care must be taken across the watershed – including the large upland areas – to retain water on-site. Grazing disturbance simplifies community structure. It removes protective shading, cooling and soil-stabilizing vegetation and microbiotic crusts. It promotes site hating and drying = desertification processes. It is typically accompanied by extensive road networks that creep outward across the landscape in association with facilities and management activities. Diminished flows means the effects of livestock water developments that alter, reduce, diminish or altogether cut off natural flows at springs will be even more extreme. Mesic and wetted riparian areas and local water tables will shrink even more Reliance on any livestock facilities dependent on such flows and foreseeably declining aquifer levels will be even more uncertain. The need for full consideration of aquifer characteristics and demands to understand the effects of any existing, proposed or foreseeable livestock developments will be even more important. The effects of grazing-promoted rapid runoff and site drying on water infiltration and aquifer recharge must also be examined. The interacting effects of heavy bank trampling, vegetation removal, and other livestock- concentration effects on remaining wetted areas of drainages, as well as increasingly intermittent and ephemeral waters, will exacerbate adverse effects. This may lead to loss of remaining perennial flows. See Sada et al. 2001, describing such effects of livestock trampling capping surface flows at springs. In streams, bank erosion, head-cutting and gullying will further reduce available surface waters. Plus, in arid landscapes, livestock consumption of water may place a significant demand on limited surface waters such as upland springs and seeps. Cattle drink 10 to as much as 0 gallons of water and day. They also excrete large amounts of waste, which often ends up polluting surface waters and may even infiltrate aquifers. Given the already very scarce surface waters in many portions of this landscape, this alone could reduce flows critical to native wildlife species, aquatic biota, etc. Necessary flow, infiltration, and other measurements must be conducted over all periods of the year to determine/predict if perennial or sustainable flows will exist throughout the life of the grazing, facility or other action. National Marine Fisheries Service talks often about "good" and "bad" Pacific Ocean conditions for anadromous salmonids (e.g., El Nino, Pacific Decadal Oscillation (10 year period was the norm). As the oceans change with climate change, more bad oceans will occur more frequently. Concurrent with poor ocean conditions due to a loss of upwelling and food for growing salmon and steelhead is also a weather pattern that leads to many areas of the Interior West with reduced snow-packs and looking at much longer growing seasons, more rain and long-term drought. Effects on aquatic biota will be significant. Grazing reduces or eliminates the cooling shade of riparian vegetation, and reduces vegetation to protect watersheds under predicted more violent and extreme runoff and other weather events. The use and reuse of irrigation water for growing hay for cattle (i.e. diversions) means even warmer than natural water temperatures. Especially with the added stressor of grazing, with climate changes/shifts in species composition of riparian areas to often less productive, and non-native species, will be exacerbated. Effects on sagebrush and arid-forest-dependent biota will e likewise severe – if agencies stay on their current course and do not act to halt or sufficiently mitigate grazing disturbances and other activities that promote desertification and climate change processes. For sage grouse, pygmy rabbit, loggerhead shrike, rare reptiles other sagebrush biota - this means doom as well. Vegetation zones will move upward in elevation, as will weeds like cheatgrass – especially with continued livestock grazing disturbances. With global warming, recovery times of sagebrush and arid forest communities (if recovery is possible at all) from disturbance such as grazing will take even longer. See USDI BLM Pellant Testimony 2007. Risk of irreversible effects of grazing disturbance in less resilient arid lands – such as accelerated wild land weed invasions – will become eve greater. Lower elevation sites are already highly vulnerable to cheatgrass and other weed invasion especially with livestock grazing and trampling disturbance of soils and microbiotic crusts. They also have lower resilience to disturbance. As they become hotter and drier, sagebrush and other arid communities will become more prone to fire and cheatgrass. Recovery times of sagebrush communities (if recovery is possible at all) from disturbance will take longer. See Pellant Testimony 007. Rainfall patterns are expected to be a further boon to cheatgrass See Pellant 2007 testimony. Any restoration efforts - once disturbance (grazing, fire, a combination) has led to significant cheatgrass/medusahead or other weed dominance – will be much more difficult in lower moisture regimes, and landscapes faced with increasingly unpredictable weather events, more frequent droughts, etc. Alternative Use of Public Lands Must Be Considered to the Maximum Extent Possible: habitat and Carbon Sequestration A recent excellent summary of the value of un-grazed wildlands for carbon sequestration is found at: http://wolves.worpress.com/2008/07/29/public-land-use-lobal-warming/ Post is attached to these comments). Alternatives in this process must examine use of the federal lands for sage grouse and other shrubsteppe species wildlife and rare plant habitat restoration, and carbon sequestration. Grazing and Cheatgrass/Fire Increasing desperation by agencies to justify arid lands grazing (often for political reasons), now grasps at the straw of claiming livestock reduce fuel loads. Any reliance in stocking public lands based on livestock consumption of cheatgrass or other weeds, or for reductions of any fuel loads, is folly. It violates federal regulations that require AUMs be based on sustainable perennial forage, not the vagaries of wildly fluctuating annuals. Plus, removal of vegetation to levels necessary to “control” a fire is not sustainable. We certainly hope that this process does not fall victim to the current livestock industry myth that grazing in a changing climate is “needed” to control weeds. Recent studies so that grazing does not effectively control cheatgrass setting seed. See Hempy-Mayer and Pyke 2008. Any grazing event severe enough to “control” cheatgrass will only prime new and expanded sites for cheatgrass and other weed, including invasive mustards, medusahead, bulbous bluegrass, bur buttercup and the like). Plus such intensive grazing will differentially impact the more palatable remaining native species that are critical to persistence of native wildlife species in the area. In the end, such severe grazing disturbance will only increase wildfire likelihood in this landscape, and cut further into remaining habitats for important, sensitive and imperiled species. See Whisenant 1991, Billings (1994) Further, news articles (Idaho Statesman pasted below) show that cheatgrass (and likely other weeds fostered by grazing or aggressive “treatment” disturbances) will become even less palatable as climate change progresses. So what appears in many current decisions to be a policy of Graze No Matter What the Consequences Because There Will Be at Least Be Cheatgrass for Livestock to Eat has no validity. Additional Weed, Desertification, Climate Change, Global Warming Concerns Agencies refuse to act based on science. It is time to act on science, and not the delusions of “renewable” use spun by the livestock industry and enablers in various Land rant Range Departments – who ignore ecological principles and studies (see for example Leischner 1994) in efforts to justify continued livestock damage to western arid lands. As part of ALL Rangeland Analyses and Grazing Decision processes, and any “treatment” proposals, agencies must provide data and analysis that establishes a clear baseline of weed infestation and risk of expansion, desertification and global warming processes already occurring in the affected landscape. A full range of alternatives to minimize such processes and adverse effects must be undertaken – especially with focus on passive restoration actions, and active removal of facilities and other sources of watershed disturbance and de-stabilization. Only then can Integrated Weed and other management and most effective treatment occur. Maintaining and recovering microbiotic crusts – a key front line of defense against invasive species – should be a primary component of all grazing analyses and decision-making. To achieve this, rest or removal of livestock disturbance, as well as crust-specific measurable standards of upland trampling-specific damage/disturbance should be Keystones of livestock grazing decisions and other decisions that involve arid lands. Full and adequate baseline surveys of microbiotic crusts across all affected lands must be conducted, measurements and analysis of effects of current and foreseeable grazing and other disturbances on crusts must be provided. Where are “old growth” crusts present? How long will crust community take following disturbance if grazing is significantly reduced or if grazing disturbance does not occur/is eliminated, or if lands are “treated”? What are the cumulative effects of grazing disturbance and any “treatment” disturbance? Even agriculture/range science has long recognized the critical role of microbiotic crusts, and their susceptibility to grazing destruction or disturbance. See, for example: http://www.soils.usdagov/sqi/management/files/micro_crusts.pdf. See also Belnap et al. 2001,USDI BLM Technical Bulletin. Unfortunately, most agency analyses that we review downplay, or ignore, serious data collection and analysis related to these key components of arid lands ecosystems. This appears to be done so that the agency project of the moment (be it authorizing high numbers of cattle or burning or applying herbicide to trees/shrubs) can be moved forward with minimal consideration of adverse environmental consequences and serious risks of such disturbances. Recent studies in the Mojave and the Chinese deserts are now revealing the importance of intact microbiotic rusts in sequestering carbon. See Wohlfarhrt et al. 2008, Ertz 2008. Recent studies in Washington State show the key role of microbiotic crust recovery in reducing cheatgrass following fire disturbance. This shows the adverse effects of livestock disturbance to crust recovery. See Ponzetti et al. 2007. See also Deines et al. 2007, and Rosentreter t al. 2007 describing the diversity of microbiotic crusts that are fragile and critical components of arid lands especially shrubsteppe and pinyon-juniper and those that extend into higher elevation sites. As part of any grazing and/or vegetation treatment analysis, the degree and severity of livestock and/or treatment disturbance in disrupting carbon sequestration (thus promoting global warming) must be analyzed and provided to the public. Agencies must manage ecosystems and watersheds as integrated systems, rather than as a series of disconnected Upland and Riparian areas. Fencing cows away from some portions of natural water and intensifying use on uplands based on water developments will only lead to further problems across the uplands and adversely affect watershed processes. Adverse effects include microbiotic crust losses, desiccation and erosion, drying and heating of uplands. Integrated management must be employed. Mitigation actions must focus on disturbance reduction and removal, and real restoration of depleted lands. Without concerted action at the local, regional and national level, global warming is a certainty and with it the progression of desertification if grazing disturbance is inflicted as a stressor on this system. The environmental baseline has worsened and there is little to no freeboard for deleterious Federal, state or other agency actions. In ESA Terms, watersheds are approaching jeopardy status, and without compensating mitigation and minimizing the effects and disturbance caused by livestock, there will be no more room for Federally permitted livestock grazing, logging, mining, and water diversions. Upstream actions on federal lands related to continued status quo mindset grazing may kill or reduce necessary domestic water, irrigation or other flows, as well as aquifer recharge, taking a serious toll on water supplies that affect entire regions. A 2007 climate conference in Bali indicates that the Bush administration will continue to delay and drag its feet in honestly addressing Global Warming, with expanding unchecked environmental damage and climate change effects. See 12/12/07 Washington Post article by Julie Eilperin. The environmental baseline will only be getting worse – at least in the short-term, under such a mindset. The full adverse effects of such Neanderthal foot-dragging in making an already bad situation in arid lands even worse, must be fully examined in agency processes as well so that the full severity of climate change processes remaining unaddressed can be understood. Such head-in-the-sand behavior increases the need for more drastic management actions in the foreseeable future, after the current administration goes away. We see striking parallels between the current administration’s foot-dragging on climate decisions that may affect industry - and public land management agency foot-dragging on instituting modern day management based on ecological science on these public lands, and not livestock industry myths. Undue degradation of these lands will certainly occur if public lands are not managed on best available science. Risks of continuing on this path that disregards science must be honestly addressed here. Climate change is another factor that was only minimally considered by USFWS in past Listing Determinations, and by agencies in various Biological Opinions, BAs/BEs, rangeland health processes, and other consultation or analyses. Now, for species in this region, not only will climate change need to be duly considered, the effects of continued, or shifted grazing disturbance in these watersheds must also undergo consultation. We also stress that a series of relatively recent USGS and other agency Ecoregional Assessments ICBEMP (Interior Columbia Basin Ecosystem Management Project) Wyoming Basin Ecoregional Analysis (WBEA), Great Basin Ecoregional Assessment, Nevada Ecoregional Assessment– several of which have been suppressed for political reasons) have not fully addressed the severe array of effects to these arid landscapes that are tied to livestock grazing on public lands. Plus, the data sets used in these ecoregional assessments are not known to be already outdated in predictions of where cheatgrass and other weeds will invade. See, for example, Peterson (2007), analysis of cheatgrass moving into areas of the tri-state Owyhee region once thought immune to such invasion. Plus, livestock disturbance is thrusting weeds into areas once believed immune. WWP has recently observed cheatgrass growing at over 9000 ft. in the Jarbidge Mountains in ridge areas chronically disturbed by domestic sheep grazing and bedding. Not only does grazing disturbance (trampling, manure) prime sites for weed invasion, livestock are well-known vectors of weeds – transporting seeds in fur, mud on hooves, and in their guts. See Belsky and Gelbard (2000). Pasted below are several relevant documents and recent scientific and other articles on livestock and climate change, and the role of public and other wild lands and habitats in reducing effects of global warming through carbon sequestration a “service” (in agency speak) that the public lands can provide. The adverse effects of grazing and/or treatment disturbance in reducing or destroying the ability of the public lands to provide this “service” must be considered under a valid rangeland health and NEPA alternatives analysis. The costs to the public in the LOSS of the public land’s ability to provide services (clean air, clean and abundant water, carbon sequestration, recreational and aesthetic uses) due to grazing and other disturbances must be fully considered and analyzed. Please carefully review the 2006 United Nations Report on Livestock and Climate Change (Steinfeld et al. 2006) and incorporate this data and analysis into the EIS process that must be conducted here. The recent GAO Report can be found at: http://www.gao.gov/new.items/d07863.pdf. Please also review the recent sage-grouse literature (Connelly et al. 2004, Holloran 2005, Naugle et al. 2006) and recent Ecoregional Conservation Assessments that explain some of the adverse effects of infrastructure development, fragmentation and human disturbances on sage grouse and other important and imperiled arid lands wildlife. BLM’S Duty Under FLPMA BLM is required under FLPMA to consider present and potential uses of the public lands, and the scarcity of values involved. The sagebrush sea, salt desert shrub, aspen pockets, mahogany thickets, playas, scarce streams, springs and seeps, clear air, and wild roadless lands of the Planing area are important examples of the wide-open country that once characterized the American West. Recent scientific assessments conducted under the Interior Columbia Basin Ecosystem Management Project (ICBEMP) such as Wisdom et al. 2000 recognize the importance of protecting and enhancing native plant communities for the long-term persistence of sagebrush biota, as well as the grave threats of growing exotic species invasions that could ultimately doom these lands. (Wisdom et al. 2002). These studies are now buttressed by a number of comprehensive new analyses (Knick et al. 2003, Connelly et al. 2004, Dobkin and Sauder 2004) that likewise highlight the need to protect, enhance, and reconnect fragmented areas of sagebrush-steppe. The public lands provide great opportunities for BLM to actually fulfill its duties under FLPMA, and act to stop further ecological harm from occurring to relatively intact landscapes; to undertake meaningful conservation actions to enhance and restore damaged or degraded sites within these lands (i. e. restore damaged drainage networks and vast uplands including failed seedings and weedlands; control and obliterate unneeded livestock-facility or activity-spawned roading that has grown up without authorization as livestock projects or activities have occurred, such as roads to salting sites); remove harmful livestock projects that may be fragmenting sage grouse or other habitats and may be serving as epicenters of weed invasion; and to restore composition, structure and function of sagebrush communities. Given the acknowledged national significance of the lands in the vast ecosystem that spans state boundaries, and relatively intact salt desert shrub, and montane island communities, BLM can not undertake a typical BLM livestock-centered planning process. Accommodating public lands grazing and rubber-stamping the status quo can not be the primary force in this effort. BLM needs to make clear at the very beginning of the process that there are a host of other important and significant public lands values in these lands, so that protection and enhancement of these values will drive the EIS effort and a range of reasonable alternatives, its land management decisions, and habitat enhancement or restoration actions. BLM must focus on management to protect intact landscapes of sagebrush plateaus and uplands and canyon to provide unfragmented core habitat for sage grouse, raptors sagebrush- obligate migratory birds, pygmy rabbit, and other sagebrush obligates such as pronghorn. BLM must also protect rare and endemic plant and animal communities, cultural sites, and other important sites. BLM must recognize the current and potential value of portions of these lands more remote from livestock facility impacts as reference sites in scientific research, and as minimally fragmented ecosystems for species restoration and long-term population viability. In the increasingly developed US, the value of such lands as an enclave of solitude and open space is great. While recognizing, protecting, and enhancing special status species habitats and other important values, BLM must also grapple with ongoing livestock grazing degradation of riparian areas and uplands in portions of these allotments; invasive species (primarily caused or extended by livestock disturbance, facilities and/or roading); fragmentation caused by grazing installations/livestock facilities, fire and other factors; OHV use exacerbated by livestock facility-associated roading; and other impacts of livestock grazing that are increasingly fragmenting sagebrush habitats. The diminishment, degradation and often disappearance of surface waters in drainage networks, springs and other surface waters in the Owyhee ecosystem is a serious and expanding threat to the persistence of native biota. It also results in pollution of downstream waters with sediment, algae, coliform bacteria. Large volumes of water with significant erosive force runoff the high plateau in drainage networks in a very brief period of time in late winter-early spring. BLM must honestly assess and documents these conditions and the role of livestock degradation and depletion across uplands and to drainages in accelerating erosion, runoff and increasing downstream pollution. Importance of Collecting Baseline Data for Developing Alternatives and Analyzing Outcomes BLM must systematically collect CURRENT adequate baseline biological data on wildlife habitats and populations and vegetation and other ecological conditions in the Garat lands. This will require a minimum of two years of intensive effort, and must include new on-the-ground inventories for special status species and analysis of habitat conditions for these species. This information must be thoroughly and systematically collected, as it will be used in developing the plans that will govern management here for the next decade or longer. Good Maps Maps are not only important in the assessment effort, but for users of the document in future years to understand management constraints - or goals - on specific land areas when agency projects are proposed, and when new threats arise. Maps need to be detailed, and provide ready geographic frames of reference so that a reader can more easily orient themselves on landmarks such as drainages, and understand locations. A blank grid of sections is not sufficient. With the GIS capabilities available today, BLM can overlay values or threats such as cheatgrass domination of understories, old seedings, understories lacking forbs, areas that have undergone or are threatened by wind or water-caused erosion, relatively intact native vegetation communities, etc. and produce maps that clearly show important lands, threats, etc. Grazing Suitability, Carrying Capacity, Productivity and Other Analyses BLM is required under the Taylor Grazing Act to set forth its criteria and assessments for grazing suitability determinations. The TGA was passed to “stop injury to the public lands by preventing overgrazing and soil deterioration”, and to determine that land is “chiefly valuable” for grazing. FLPMA requires that BLM undertake an exhaustive and continuous inventory of the public lands and use this inventory to develop land use plans. This process is an opportunity to conduct this analysis. NEPA requires that an agency provide a “full and fair discussion” of significant environmental impacts, take a “hard look” at the environment and impacts of various alternatives, and that statements shall be supported by evidence that the agency has made the necessary environmental analyses. NEPA also requires the use of sound science. BLM must provide a two-part grazing capability and suitability analysis that: 1) Catalogues and describes lands that are not capable of supporting grazing due to lack of herbaceous vegetation “production”; distance from natural water sources; slope, rockiness (much of these allotments); existing environmental damage (downcut gullies, wet meadows with shrinking wetted areas due to livestock damage, lands “at risk” to weed invasion); lands so seriously depleted that they are no longer able to support livestock grazing on a sustainable basis; and lands that are “at risk” of weed invasion and/or dominance, and crossing thresholds (due to livestock degradation) from which recovery to native vegetation communities will not be possible due to dominance of exotic species. 2) Catalogues and describes lands unsuitable for grazing based on their important values to rare and declining species, recreational uses, cultural sites, aesthetic value, and other legitimate uses and values of public lands that are harmed or degraded by the chronic effects of livestock grazing. We are unaware of any such past science-based capability or suitability analyses that have been conducted in these lands. If they exist, please provide them for public review as part of this process, and use best available science, and collect on-the-ground information necessary to up-date them. Old adjudication claims can in no way be considered “current”, nor can they reflect current scientific knowledge of suitability of many of these lands for livestock grazing in the face of dire threats posed by weed invasions and habitat loss. In reality, the old “adjudication” process grossly over-estimated the suitability, capability and production of the affected lands. Gross exaggerations in lands made in adjudication processes were largely carried forward in the outdated land use plans. Given the ongoing depletion, loss and desertification of many areas, with only scant Poa or Squirreltail, or cheatgrass dominance as primary “forage”, loss of large-sized native bunchgrasses, etc.), and weed invasions resulting in wildly fluctuating and unreliable annual forage production, current suitability and other assessments are urgently needed. BLM must abandon the mindset that endless forage exists to support the grossly inflated permitted AUMs, and stop carving up the landscape with new livestock projects that will harm refugia of better condition habitats for native species in an attempt to support these unsustainable numbers of cattle and sheep. A key part of this is determining lands that are not capable, are not suitable, or are “at risk” of becoming weedlands, lands that still provide pygmy rabbit habitat, etc. and cutting AUMs accordingly, as well as determining facilities of projects that are harming important habitats, and scheduling their removal. The new assessment/inventory of acres of lands suitable and unsuitable for livestock grazing, and capable and not capable, must be based on scientifically accurate criteria, be comprehensive, and include collection of on-the-ground data on condition and health of soils, microbiotic crusts, native vegetation (quality, quantity, production), habitat values and quality, and effects of depletion or fragmentation on special status species, the relative scarcity of values, etc. Examples: * Across large areas, greatly depleted Wyoming big sagebrush require 10 acres or more to support a single AUM. Plus, these lands are increasingly being invaded by cheatgrass, bur buttercup, halogeton and other weeds as livestock further deplete and trample vegetation and soils. Yet grazing that one AUM across dozens of acres differentially impacts the remnant native grasses (Oryzopsis, Stipa, Agropyron), weakens or kills winterfat and other shrubs, tramples soils creating ideal conditions for weed establishment, removes plant materials necessary for food and cover for special status species and other important components of the food chain– such as raptor species small bird, mammal and lizard prey. This results in further depletion of remaining native vegetation communities and tramples and destroys remnant microbiotic crusts (especially since that one AUM has to roam over large areas to find enough to eat. In these lower elevation lands under current management and in its proposed action, BLM appears to be managing FOR cheatgrass and halogeton, and doing all it can to foster continued harm. In this effort, BLM must admit that portions of these lands (some with stocking rates of 10 or more acres per AUM) are NOT suitable for grazing, remove livestock and reduce AUMs. Once productivity drops below a certain level, lands should not be available for grazing use. * Less fragmented and relatively intact lands are essential for maintenance and recovery of sage grouse, raptor prey, migratory bird, pygmy rabbit and other important or special status species populations, and where these values are being harmed by the grazing of large numbers of AUMs and/or threatened by new livestock facilities or vegetation treatments should be found unsuitable for grazing – giving the increasing importance of these competing values. The solution is not to juggle seasons of use - but to determine, when weighing relative values, if livestock grazing is not a compatible use of this land, or if should be withdrawn from grazing. * Depleted seedings that have lost productivity should be identified for restoration to native vegetation, and removed from the “forage” base. If ranchers did not take care of seedings, the public deserves to have the lands restored and taken out of the forage base. Such depletion shows the unsustainability of grazing livestock on them. Please review and provide actual use figures over the past decades, to see where even this “honor system” method reveals “paper cows and sheep” AUM numbers/stocking rates far above those actually grazed. By failing to adjust stocking rates to reflect the suitability, capability, sustainability and productivity of lands for livestock use, BLM is artificially inflating and propping up the sale values of public land grazing permits, plus keeping the door open for the livestock industry to exert political pressure to graze livestock far in excess of sustainable levels, and casting aside other values of public lands. Lands in the Garat area must also be assessed for suitability in comparison with/weighing against their other uses by society (rare species habitats, scientific reference area value, recreational uses, etc.). BLM “Range”/Vegetation Data At present, BLM has provided old, flawed, and deeply consultant-biased information on ecological conditions - and the health of native plant communities across the landscape.BLM has conducted a limited and narrow FRH assessment. Please provide a usable map and other information that very carefully details each site where data was collected, and the type of data, and how each site was selected, and who selected it (consultant vs. BLM). BLM must revisit all sites where ESI data has been collected in the past, revisit all of those sites, and determine how conditions have changed. Please provide a map and summary information for each ESI site in the Garat. After the new survey, please provide comparative information in detail so that the public can understand changes over time at specific ecological sites. Typical BLM Key Area sites are located in only the most accessible areas, and are clustered in particular areas of the allotments in better condition and purposefully placed some distance from any livestock facility impact – thus biasing analysis towards the “better” condition remnant areas. This leaves vast land areas with no monitoring information at all collected, and whose degraded condition is simply not factored into an ecological analysis by BLM. BLM also failed to collect necessary data on degradation of soils, microbiotic crusts, native vegetation, etc. caused by livestock facilities and management activities. Current, comprehensive data on condition of soils vegetation, and habitats must be systematically collected. Plus, BLM can not ignore evidence that its limited old data does show - i. e, only a small fraction of larger size grasses are present in most sites that should be dominated by larger-sized species and native forbs. Thus, “production” is greatly less than that of good or better condition sites, and this is typical of nearly all sites. BLM must also tie water developments, water hauling, salting, mineral placement, or other livestock management practices to site depletion and alteration of species structure and composition. As part of this process, BLM must revisit its limited monitoring sites, and must also establish a series of new ESI and monitoring sites across theselands, in all vegetation types, and that represent levels of livestock use that occurs across these lands. BLM must also conduct comprehensive FRH assessments, in representative sites grazed by livestock across all areas of the allotments. Myriad Harmful Impacts of Livestock Projects The focus of this assessment process must be to remove projects to facilitate restoration of native plant communities. Projects that serve to control livestock use and distribution can be replaced with specific stubble height and trampling standards that serve as triggers for livestock removal. Active herding should substitute for fences and projects. Ranchers should be required to have at least 1 herder for every 100 cattle grazed on public lands. Livestock Grazing Causes A Broad Array of Harmful and Ecologically Calamitous Impacts Often Downplayed by Agencies There has long been a tendency by agencies to mask or ignore the severity of the impacts of livestock grazing to native wildlife habitats. The internal alteration, simplification, fragmentation and destruction of big sagebrush by livestock has been given lesser prominence and concern than vegetation conversion. Nearly all BLM lands suffer significant livestock grazing impacts/mechanical treatment on an annual basis (Braun 1998), and face chronic and cumulative damage. When grazing has been discussed – it is typically referred to as “overgrazing”, or “intensive” grazing without an acknowledgment that what is being termed “over” grazing are the standard stocking and grazing practices on public lands. The drastic alteration of sagebrush structure caused by livestock is readily visible when even the most gross visual comparisons are made between untrespassed exclosures or ungrazed road right-of-ways, and grazed sites. Stark visual contrasts exist between battered, broken, and structurally altered big sagebrush growing in grazed areas and the full and deep canopied, structurally diverse unbattered shrubs in long-time ungrazed sites. BLM must move away from blind acceptance of myths put forth by commodity-driven range scientists often tied to western land grant universities. BLM must use best available science, not driven by commodity- production minded researchers. Where are all exclosures or ungrazed reference areas located in this allotment or surrounding lands? Public lands grazing is increasingly dominated by huge corporate entities (see San Jose Mercury News 1999), including the Garat permittee, and political pressures on range and agency scientists to ignore harmful impacts of livestock grazing can only be expected to increase. Please provides full and detailed analysis of public lands livestock grazing in Idaho and Nevada by Petan, the permittee here. How does grazing in other areas affect the environmental setting? How have you factored such analysis into full and fair consideration of the economic costs of grazing this allotment, and any changes in AUMs that might result from this process? Adverse effects of livestock management activities include sagebrush control efforts, effects on predator distribution and density through the use of artificial watering or supplemental nutrition and feeding sources for livestock, structural damage to dense stands of sagebrush, removal of current herbaceous growth or residual cover of native grasses and forbs by livestock for forage, and increases in the density or distribution of various invasive weed. Besides scientific journal articles (Mack and Thompson 1982, Fleischner 1994, Freilich 2003, Connelly et al. 2004 and others), we urge BLM to review the wealth of scientific and factual information and photographs presented in both Waste of the West (Jacobs 1991) and Welfare Ranching: The Subsidized Destruction of the American West (Wuerthner and Matteson, eds. 2002) and also Debra Donahue’s (1999) The Western Range Revisited in fully evaluating the colossal threats posed by livestock grazing to pygmy rabbits across the Intermountain and Great Basin region. Global Warming and Desertification Processes We want to call your attention to a new United Nations report on the role of livestock in causing and exacerbating global warming, desertification, loss of biodiversity, etc. Here is a link to this document: Please see new U N Report available at: You can download the full report at: http://www.virtualcentre.org/en/library/key_pub/longshad/A0701E00.pdf . What range of alternative actions and mitigations will be employed to decrease or mitigate global warming effects of livestock grazing here? What levels of desertification exist in the Garat, and where? Domestic livestock grazing has significant adverse effects to terrestrial wildlife. These include: • Loss of breeding, foraging and cover habitats • Increased animal displacement and loss • Reduction in prey availability • Reduction in overall biodiversity • Loss of genetic diversity • Reduction in regional carrying capacity • Possible population declines BLM must fully assess all impacts of domestic livestock grazing in such adverse effects to habitats and populations. Grazing causes incremental habitat loss and incremental extirpation of native species. Please see the United Nations Report, Connelly et al. 2004, Dobkin and Sauder 2004, Knick et al. 2003 to understand the significance and irreversible nature of the habitat alteration through fire, weed invasion and other disturbance from livestock grazing and facilities on the Forest. These effects must be openly and honestly analyzed in an EIS. Domestic livestock grazing leads to accelerated and increased rates of loss of critical ecological components of public lands. You must analyze all direct, indirect and cumulative impacts to soils, microbiotic crusts, vegetation, watersheds, water quality and quantity, native vegetation communities, wildlife habitats and populations, biodiversity, aquatic species, rare plants, recreational and scientific uses of these lands. Information from new studies conducted in Wyoming related to the impacts of disturbance and energy development on sage grouse and other sagebrush-dependent species must be fully incorporated in your analysis. Energy-development studies include study of the effects of roads, developments, noise, human activity, etc. and so are very relevant to the effects of livestock grazing activities on these lands, plus potential disturbance associated with gas pipeline corridor. See Holloran 2005, for example and other studies available on-line at: http://www.voiceforthewild.org/SageGrouseStudies/index.html .Please incorporate all of this information into your decisionmaking process, analysis of effects, and development of appropriate mitigation. This information also discusses West Nile virus. In the Garat process, you must assess the role of livestock and livestock facilities and livestock trampling promoting standing stagnant water, in transmission and spread of West Nile or other diseases. What livestock, energy, other development or exploration may result in cumulative disturbance impacts to these lands? Livestock Grazing Causes Behavioral Disturbance of Wildlife, Removes Protective Cover Livestock movement may disturb foraging or resting wildlife, increasing their vulnerability to predation, or increasing stress during winter, harsh weather or other critical periods. This may cause mortality. Grazing removes and alters vegetative cover, including shrub cover important for visual screening and avoidance of special status species like the pygmy rabbit, and protection from attack by aerial and ground predators. Taller grasses also provide possible scent screening from ground predators. Livestock Trampling Compacts Soils and Alters Soil Structure at Burrow Sites BLM succinctly described impacts of livestock grazing on soils in the “Permit Renewal EA for WBW allotment” in the upper Little Lost (Idaho Falls BLM WBW allotment 2003). “Continued cattle traffic on livestock trails and watering areas[s] will increase soil compaction. Soil compaction by heavy objects, including trampling by cattle, penetrates and compact [s] soil material to depths of 15 to 20 inches. The surface 4 to 6 inches is usually released from compaction by frost action. The deeper soil compaction that is not affected by frost action may remain in the soil for years. Deep soil compaction restricts root growth, reduces soil productivity and contributes to water and soil erosion. Deep soil compaction can increase over time”. BLM must assess impacts of livestock on soils throughout these lands, as part of this assessment process. Plus, BLM typically collects information during mid to late summer, and never assesses the full impact of trampling damage to soils. http://www.westernwatersheds.org/facts_photos/lepa/lepa.html Please see WWP Website to view photos on trampling of slickspot peppergrass habitats. These same impacts occur across the Owyhee-Bruneau Region – yet are never measured by BlM. Livestock Trampling Collapses Burrows and May Injure or Kill Pygmy Rabbits There is resounding evidence of the harmful impacts of livestock trampling on pygmy rabbit burrows, and the burrows of other small mammals. USFWS in 68 FR 43 states that cattle can directly damage pygmy rabbit burrow systems through trampling. Austin (2002) documented cattle trampling of active burrows in the Shoshone Field Office. Burrows were subsequently abandoned. FWS has recognized that trampling is a form of direct take, causing injury or mortality (68 FR 43). Cattle can also trample and destroy migratory birds. BLM must assess alternatives that minimize harm to ground-dwelling mammals, as well as prohibit all livestock grazing during nesting periods for migratory birds. Livestock Grazing and Trampling Causes Widespread Erosion of Soils and Loss of Microbiotic Crusts Leading to Weed Invasion Soils in many areas have suffered large-scale erosion, and are continuing to erode away in grazed, trampled, burned or mining or road-disturbed sites. Trampling by domestic livestock harms or destroys microbiotic crusts in arid climates (Fleischner 1994 Belnap et al. BLM Technical Bulletin 2000). Microbiotic crusts are indicators of ecological health – they fix carbon and nitrogen, absorb incoming energy, stabilize soils inhibiting germination of non-native seeds, produce a rough microtopography that helps slow runoff, and unambiguously act to reduce wind erosion of soil surfaces. Biological crust loss occurs under heavy grazing on sandy soil sites. Loss of microbiotic crusts increases soil erosion in both coarse and fine-textured soils. BLM routinely accepts large amounts of soil erosion as the norm. BLM must not routinely authorize domestic livestock grazing on lands with heavy to severe erosion hazards, or vulnerable soils. In this effort, BLM must act to restore damaged soils on arid lands, and prevent new disturbance-related erosion from occurring. Preventing soil damage and erosion must be a key restoration goal. Livestock Grazing Destroys Composition of Big Sagebrush Communities Daubenmire (1970) described the lower resilience of sagebrush plant communities to grazing. Mack and Thompson (1982), in a classic paper “Evolution in steppe with few large, hooved mammals”. This seminal paper discusses the myriad harmful impacts of livestock grazing to Intermountain and Great Basin sagebrush communities that evolved in the absence of large herds of hooved mammals like domestic livestock. Fleischner (1994) and Belsky et al. (2000) review the many harmful impacts of livestock grazing to arid western lands, including alteration of plant community composition and structure. Extensive literature documents the impacts of domestic livestock grazing in alteration of understory composition. Anderson and Holte (1981) describe the significant increases in perennial grass and shrub cover that occurred after 25 years without grazing on sagebrush lands in southeastern Idaho. Cover of perennial grass increased exponentially, and shrub cover was 154% greater. Shrub cover increase was a result of increased canopy cover of sagebrush plants, and not shrub density increases. Livestock Grazing Radically Alters Shrub Structure Land that is intensively grazed by domestic herbivores often has relatively low structural complexity. In areas of deeper soils, cattle often differentially congregate on deeper soil sites for shade, wind protection, etc. and damage shrubs. Grazing can break down sagebrush cover and thus make it unusable. Grazing disturbance disrupts sagebrush communities by breaking down individual plants and opening interstitial spaces. Grazing breaks down shrub cover, leading to loss of native grasses and forbs and invasions of exotic annual species like cheatgrass. Negative impacts of grazing to sagebrush-dependent wildlife include physical destruction of dense, structurally diverse patches of sagebrush and the corridors that connect them, resulting in simplified and fragmented sagebrush habitats. Fragmentation of habitats can influence size, stability and success of wildlife populations. Even a small number of cattle, which gravitate toward deeper soil sites or shade provided by shrubs, can strongly impact shrub structure. This is an impact that is never measured, quantified or controlled by land management agencies. This adverse modification of habitat can significantly alter or impair normal behavior patterns, as any agent that lessens shrub cover and structure harms the habitat components required by many native wildlife species. Livestock Fences Degrade and Fragment Upland Habitats and Aid Predators Between 1962 and 1997, more than 51,000 km of fence were constructed on land administered by BLM in states supporting sage grouse populations (T. Rich pers. comm. cited in Connelly et al. 2000). The pace of new fence construction shows no sign of letting up, and in fact appears to be increasing as land managers seek to perpetuate high stocking rates on degraded lands. Construction of fences often involves cutting or clearing sagebrush along new fence lines, thus reducing areas of big sagebrush cover. Fence lines are often routinely driven, including during construction, with new roading the end result. Roads spring up along fencelines, as the land is driven during the process of fence construction as well as for future maintenance, and visible scars attract continued motorized use by the public. Livestock trailing back and forth along fences commonly occurs, further crushing and battering sagebrush, as well as compacting and trampling soils and degrading understories. Fences with maintained trails adjacent to them provide travel corridors for predators of sage grouse (Braun 1998. Many BLM 1:100,000 land status maps show this effect – most of the spider-webbing of roads and roading are associated with livestock fences, pipelines and other facilities. While fences are frequently described as being constructed to “improve livestock distribution”, the end result, is more intensive livestock utilization and degradation of previously less used areas. Fences provide perch sites for raptors, ravens and brown-headed cowbirds. (Call and Maser 1986, cited in Connelly et al. 2000). Raptor predation has been the cause of known or suspected pygmy rabbit mortality in many pygmy rabbit field studies, and of sage grouse mortality. Vast lower elevation wild lands (sage brush and salt desert shrub) are a landscape that is devoid of many natural elevated perch sites that can be used by raptors to scan for prey, so fences introduce an unnatural and harmful vertical structure that provides an advantage to predators. Fences distribute livestock over areas that were sporadically or lightly used in the past (Nevada BLM Sage Grouse/Sagebrush Ecosystem Plan 2000), to the detriment of native species. Range “improvement” risks to all known sage grouse habitats identified by Nevada BLM that and that are directly relevant to pygmy rabbits include: Construction of water developments that result in increased livestock utilization in known sage grouse habitats; construction of fences that provide perch sites for avian predators, construction of livestock facilities (livestock troughs, fences, corrals, handling facilities) that result in livestock concentrations in sagebrush habitats. Nevada BLM livestock grazing decisions continue to blithely ignore the agency’s own guidelines for sage grouse. This is another example of a plan, that looked great on paper, but land management agencies ignore it, and recommendations are seldom, if ever, implemented. BLM must act to implement actions necessary to protect native species from the harmful effects of livestock facilities. Control of livestock under this planning effort must be focused on measurable standards of use, and active herding, and not structural facilities that fragment habitats and degrade wild land settings. Livestock Water Developments Degrade and Destroy Habitats Water developments typically dig into the heart of springs, and water is removed from the spring to a pipeline system that then supplies a series of troughs in upland sites. These developments extend use into less used areas, and have serious harmful impacts to soils, vegetation and wildlife. This de-watering of springs can also reduce the zones of soil moisture surrounding springs that often are capable of supporting the tallest Basin big sagebrush. Once a spring is dug into (or a well drilled), and water put into a pipe, the pipeline provides new water sources, and resultant intensive concentration of livestock use in lands surrounding each trough site. The impacts of this extreme use extend outwards in a bulls eye pattern. The immediate area around the trough becomes a dead zone – dirt, manure, stubs of sagebrush, heavily compacted soils - and an ideal site for weed infestation and spread. The area becomes a sacrifice zone to livestock. Locations chosen for troughs and pipelines are often remnant patches of better condition native vegetation, which may be essential refugia for native species. Livestock utilization levels are averaged over large areas, and impacts of new developments are largely unaddressed and unmitigated. There is a lag time between when pipeline and trough installation occurs, and the full extent of resulting damage to more distant native vegetation communities occur. Rapid habitat loss occurs in zones close to the trough. Vegetation depletion spreads outward each year, and is followed by continued and cumulative degradation and loss of native understory vegetation and altered shrub structure for 1 to 2 miles surrounding upland water sources. Plus, spring projects de-water wetted areas of deeper soils surrounding springs, and the size of the area capable of supporting tall sagebrush and other vegetation may shrink over time. Pipeline construction also causes large bare areas of disturbed soils, and pipeline routes often are driven, and end up becoming new roads. Roads serve as travel corridors for predators in sagebrush habitats (Braun 1998, Connelly et al. 2004) and hunters, as well as conduits for OHV users to access new terrain. This plague of pipelines and other livestock developments has been accelerating in recent years, driven by failure of livestock permittees to meet grazing objectives and agency unwillingness to cut overall livestock use and numbers. Stock ponds typically are dug in to springs or ephemerally moist areas, and alter flows and watershed processes in drainage networks. Plus, they are typically hideously degraded and polluted, and serve as attractants for nest predators by extending water into otherwise arid areas. They also serve as source of mosquitoes that carry West Nile virus that may impact sage grouse, migratory birds and other native species. Thorough mapping and analysis of facility impacts must be a primary emphasis of this assessment. Water Hauling for Livestock Demolishes Habitats BLM frequently allows water hauling as a way to provide livestock access to water in lands with some forage remaining. Water hauling is a method to extend livestock use in allotments where forage near traditional water has been severely depleted, and has the same effect as pipeline trough placement. Water hauling is typically little controlled, and one-time livestock watering events can cause long-term and/or irreversible harm to native vegetation sites. Nevada BLM offices in the range of pygmy rabbit routinely allow and extol the benefits of unsupervised water hauling in new sites to extend livestock use from severely depleted sites into less used areas. In addition, water hauling activities associated with sheep and cattle grazing can obliterate habitats in a couple of hours or less. Many sheep operators in arid lands have water trucks that haul water to troughs that are regularly moved over the course of a day along with the sheep. Soils and sagebrush surrounding temporary water trough locations can be irreversibly damaged by large concentrations of sheep. BLM must fully assess all impacts of any water hauling here, including providing maps of any water haul sites. BLM must stop this use of water-hauling, as it leads to destroying, rather than restoring native plant communities. One-time water hauling events can cause permanent harm to sites where tanks are located and large areas of surrounding lands, as they result in intense concentrations of livestock. The surrounding area essentially becomes ”cow-bombed”, with native vegetation and microbiotic crusts destroyed, and primed for weed invasion. Lands that are too arid to have available surface water should not be grazed. The more arid the lands, the greater the difficulties - or impossibility – of site restoration following disturbance events. We have been shocked by BLM grazing decisions we have received in the past that actually promote/require the use of new water haul sites for livestock, with minimal or no discussion of the serious harmful impacts that result. If BLM plans to continue water hauling, it will not be fulfilling its goal of restoration. Any sites must identified and catalogued. Livestock Wells and Pipelines Destroy Habitats To sustain high numbers of livestock, BLM typically relies on a plethora of new water developments that extend livestock use into remnant less grazed lands. The current BLM strategy West-wide is to shift livestock impacts from beleaguered riparian areas, and extend livestock use into previously less-used native shrub-steppe habitat. New intrusions in remnant less grazed uplands will have especially harmful impacts to populations of sage-steppe and pinyon-juniper species, as these may be the habitats where reproductive success is greatest, predation is less, etc. Such agency actions are rapidly destroying remnant less grazed big sagebrush habitats in the Owyhee region. This effort must focus on removing wells and pipelines, and restoring disturbed lands. Fencing Shifts Intensive Livestock Use in Unresilient Uplands Typical fencing projects slice across sagebrush uplands, with livestock use shifted and concentrated into new areas, causing significant new “dead zones” - where livestock strip understories and batter and often kill shrubs - and large bare soil areas vulnerable to weed infestation, result. Water gaps, sometimes several hundreds of yards or more, may be constructed to allow livestock access to water sources, and floodplain, banks and sidehills become a barren wasteland. Livestock use here is often so intense that agencies dump rocks on banks and sidehills to “harden” the water gap. Zones of impact of shrub structural damage, soil compaction, etc. of water gaps extend for large areas, as livestock converge on single point water access. Fences concentrate use into new areas. In the course of 2 or 3 years alone, we have observed big sagebrush habitats that has been essentially stripped of understory, the sagebrush battered, bashed, and weakened, and canopy cover reduced – due to construction of fencing projects designed to continued high levels of livestock grazing. Placement of Livestock Salt and Mineral Supplements in Upland Sites Destroys Habitats Due to current agency focus on shifting livestock use away from riparian areas, many agency grazing permits require the placement of salt and mineral supplements ¼ mile or more distant from water – which means in anywhere a rancher wants in sagebrush uplands. Agencies exercise no oversight over where these livestock lures are placed, as management paradigms view sagebrush as “disposable”. A one-time placement of salt or minerals can cause long-term alteration of dense patches of big sagebrush, severe soil compaction, lead to irreversible weed invasions, etc. Nevada BLM (2000) Sage grouse/sagebrush plan recognizes this as a threat. Holistic Grazing and Typical Herding Destroy Big Sagebrush Habitats Holistic grazing is often invoked by agencies and livestock interests to resist or delay making reductions in livestock numbers in degraded lands. The practices of holistic grazing are particularly harmful to wildlife habitats. Large herds of livestock uniformly inundate sites, uniform and heavy utilization occurs, and soils are uniformly trampled and disturbed. Plus, a basic “tool” of holistic grazing is placement of salt or supplements in patches of thick shrubs to lure livestock to break down and alter the shrub structure – practices that are anathema to the pygmy rabbit. Austin (2002) documented destruction and abandonment of occupied pygmy rabbit burrows and sagebrush by a livestock herding event in Shoshone Field Office lands. All impacts of concentrated herding here must be assessed. Rest Rotation Grazing Schemes Flood Wildlife Habitats with Cattle Without significant cuts in livestock numbers, a rest rotation grazing system typically means livestock numbers are increased in lands in “rotation” years when they are grazed and not being rested. This means additional livestock use on depleted lands. Effects of increased livestock numbers during spring periods or drought years increases competition for grasses, and may place even more stress on pygmy rabbit populations, and lead to declines or extirpation. Drought Exacerbates Livestock Grazing Impacts and Competition Agencies allow heavy levels of livestock use even in drought years. For example, despite 2002 being the third or fourth consecutive drought year throughout the pygmy rabbit’s range, status quo livestock grazing continued on BLM and Forest lands in nearly all areas. In 2002, all of Nevada and many big sagebrush counties in Idaho were declared drought disaster areas. The consequence of unrelenting livestock grazing is vividly shown in the drought and livestock destroyed lands. Weakened, stressed plants, depleted understories, pulverized soils with damaged microbiotic crusts with increased vulnerability to exotic species invasion, etc. all result. BLM Nevada Sage Grouse/Sagebrush Guidelines (2000) conservatively states the need to reduce stocking rates or change management practices with two years of drought, and identifies the failure to adjust grazing during drought periods as a when competition for scarce resources intensifies as a risk factor for sage grouse and sagebrush ecosystems. This should be part of the management that BLM develops here. Don’t base stocking rates on “average” use. Mechanisms for immediate removal of livestock during drought should also be part of the grazing plan. Protection of Native Vegetation BLM must use current ecological science to develop a range of alternatives that act to protect remaining native vegetation communities from activities that result in disturbance that could lead to weed invasion/proliferation of exotic species that threaten sagebrush, salt desert shrub, and other vulnerable vegetation communities, and cause their ultimate further fragmentation. Protection of these communities is the first step to ensuring that their ultimate restoration may be possible. BLM must conduct a current inventory of native plant community condition and restoration needs. BLM must include a description and analysis of all the significant sagebrush, sagebrush- bitterbrush, low sagebrush, and other vegetation community special status species habitat values. This includes a discussion of the regional and national significance of less-fragmented sagebrush landscapes, wild raptor habitats, sage grouse habitats, etc. For example, BLM should describe the setting, and discuss in detail the unique and significant biological features of the lands, as its first and foremost consideration. This process should be seen as an opportunity to evaluate the ecological and conservation significance of these lands from the standpoint of special status species and scarce desert waters. BLM must consider livestock grazing as one of many uses of these public lands, and analyze it accordingly. This analysis must encompass native vegetation, soils, microbiotic crusts, native wildlife specie occurrence and habitats, special status species occurrence and habitats, roadless lands, livestock facilities, fragmentation, weeds, desertification, etc. We believe it is necessary for BLM to consider new ACECs to protect the significant special status species, conservation, watershed and wild land values - of a size that will protect landscapes or ecosystem level processes. In addition, BLM should designate RNAs, embedded within a larger matrix of an ACEC of sufficient size to protect important ecological values. Large ACECs and seasonal avoidance criteria should be part of this process - for example, all identified sage grouse habitat should be withdrawn from ALL new development of livestock water, due to the extensive habitat fragmentation that could occur if new pipelines are built, and subsequent increased chronic depletion were to occur. Seasonal avoidance habitats by livestock grazing and other activities should occur during periods when sage grouse and migratory birds are nesting, when pygmy rabbit young are in shallow natal burrows, etc. All WSAs, recommended Wild and Scenic Rivers, significant unroaded lands suitable for wilderness, all ACECs, etc. should be protected from new or increased livestock intrusion in all parts. Roadless Lands BLM must use this planning process to expand its understanding of unroaded lands beyond that of the out-dated, deeply flawed and politically biased wilderness inventory process of over 20 years ago. The importance of large parcels of interconnected unroaded wild lands in these allotments becomes greater with each passing day – as more information about roads causing disturbance to species during sensitive times of the year, roads serving as conduits for weed invasion (Gelbard and Belnap 2003), with weeds then being spread into wild lands by livestock, and road impacts to watersheds, is gathered. FLPMA requires BLM to undertake a continuing inventory of the public lands and to use this inventory to develop land or resource management plans. Review of BLM’s own records on the 1979-1980's wilderness inventory process show that BLM engaged in flawed, biased and irrational analysis. It focused primarily on canyons or very rugged mountainous terrain, and rejected plateau, basin and alluvial fan lands where the livestock industry hoped to increase livestock use through construction of new livestock installations or “treatments”. Besides being fraught with political bias, the lens through which BLM evaluated roadless values in those bygone days is outdated, and unsupported by current scientific knowledge of the accelerating fragmentation of sagebrush habitats, and the sensitivity of sage grouse and many other species to disturbance or habitat degradation resulting from roading, the need for large intact landscapes to protect native species and biodiversity, and the growing ublic appreciation of wide open spaces. BLM must conduct an inventory of all roading in the allotment, and determine its relation to livestock grazing, and evaluate its impacts in fragmenting habitats for special status species, and all threats posed to these species habitats (weed spread – especially when coupled with the added impacts of livestock crisscrossing road conduits and spreading weeds into adjacent wild lands, catalytic converter fires from recreational use on such roads, etc.). On BLM lands, roads are often the result of livestock facility construction or maintenance. BLM must determine all roading that is not essential to livestock management, (ranches have horses!), and development rehab and restoration/road obliteration strategies. In addition, BLM can use this effort to newly evaluate and add to an understanding of: Naturalness, solitude, primitive and unconfined recreation, special features in existing WSAs.. Plus, BLM must update the “Special features” that in 2004 certainly includes presence of sage grouse or pygmy rabbit habitat, presence of native vegetation communities with minimal exotic species infestation, importance of large unfragmented “sagebrush sea” expanses, etc. Impacts of livestock grazing on WSAs or other Roadless land values must be thoroughly evaluated under all alternatives. The Sagebrush Sea Sagebrush plant communities Westwide are besieged by an array of threats. These threats include exotic species, altered fire cycles, continued disdain in the eyes of the livestock industry, continued destruction by livestock grazing: livestock alteration of the native herbaceous understory with resultant cheatgrass invasion; livestock breaking or consuming sagebrush or other shrubs and destroying the physical structure with resultant destruction of the necessary shrub structure for nests of species such as loggerhead shrikes or overhead protection for the pygmy rabbit; plans to hack, beat, thrash, burn and otherwise remove sagebrush to conduct “seedings” or to thin or remove sagebrush in sites susceptible to cheatgrass or weed invasion, especially under harmful grazing practices (stocking levels, levels of use, no real rest) under the Decisions. Note: Many past BLM seedings, green strips, and sagebrush thinning projects have been ecological disasters – leading to loss of topsoil, cheatgrass and other weed invasion, and loss of habitat for native species. Public appreciation of sagebrush country values and the beauty of wide open space and Basin and Range landscapes is growing. Sagebrush dependent wildlife species are known to be rapidly declining or jeopardized (Dobkin and Sauder 2004). The protection, enhancement and restoration of native sagebrush plant communities including: Wyoming big sagebrush, Basin big sagebrush, mountain big sagebrush, big sagebrush-bitterbrush, big sagebrush islands/inclusions in low sage brush, and the various low sagebrush communities - should be the basis driving management decisions in this Planning effort. In addition, the lower elevation salt desert shrub communities interfacing with sagebrush and found in the valleys, provide essential habitat for many special status species or their prey, and must also be considered a high priority. Livestock are causing weed invasion, and shifts in shrub species and loss of shrub structure through consumption and physical damage. Sage Grouse Recent sage grouse research has revealed that vast acreages (across hundreds of square miles) may be used by sage grouse in the course of a year. BLM must fully consider the vast acreages needed by sage grouse for leks, nesting, brood rearing, and winter habitats. Lands must be managed to provide all components of year-round habitats required by sage grouse. We also ask that you work with the appropriate agencies in Nevada to understand the habitat needs of wildlife populations shared between states. This analysis must also transcend allotment boundaries – as wildlife nesting in one allotment may have critical wintering habitats, prey bases, etc. in other allotments, including across state lines.. BLMM must also determine how the degraded condition, recent large-scale habitat loss due to wildfire, and other habitat alteration and fragmentation has affected sage grouse antelope, mule deer and other important and special status species. Restoration BLM must identify lands restored to native vegetation. These include: exotic seedings, annual exotic communities, livestock-damaged native communities, areas highly impacted by livestock facilities or management activities. “Restoration” means returning native vegetation to a site, with ecosystem processes in a natural condition - as near to “pristine” as possible. It does mean achieving some artificially constructed “Desired Future Condition”. Specific areas to be restored to native vegetation composition and structure: Crested wheatgrass seedings, halogeton-infested salt desert shrub communities, cheatgrass communities. In addition: degraded lower elevation salt desert shrub/Wyoming big sagebrush communities with cheatgrass understories, downcutting or shrinking mesic areas o fintermittent drainage networks, “developments” altering watershed processes, white top/hoary cress infested areas, etc. The first step in restoration throughout these lands is reduction or removal of livestock grazing for sufficient periods to enable establishment of fragile native species and/or recovery of native understories. Only native plants should be used in all restoration, and in all post-wildfire seeding. Passive restoration techniques, such as reduced livestock grazing or road closure should be Fire, at present, is not an appropriate restoration technique here due to the risk associated with the threat of exotic species invasion following fire disturbance. The looming threat of exotic species invasions following site disturbance such as fire on livestock-degraded lands makes playing with prescribed fire a dangerous undertaking that may have irreversible consequences. Fire is simply an additional (and often drastic) site disturbance on top of the ongoing chronic disturbance of livestock grazing that has altered species composition, function and structure on these lands (Fleischner 1994). Until BLM sufficiently controls livestock grazing, and sites recover and heal, use of fire further jeopardizes many native plant communities at lower and middle elevations. Livestock Grazing and Alternatives Development There is overwhelming scientific understanding of the harms to arid western lands caused by domestic livestock grazing. We refer BLM to Professor Debra Donahue’s excellent recent book The Western Range Revisited. This book describes and catalogues the loss of biodiversity, exotic species, soil erosion, water pollution, and ask that you incorporate it as part of our comments. Note that during her professional career, Professor Donahue spent time in sagebrush habitats working for BLM on its livestock-degraded lands in Nevada. BLM must prepare the an EIS based on this scientific knowledge about the harms caused by livestock grazing to native species and their habitats. First and foremost, BLM must honestly assess harms being caused by livestock grazing, the importance of this land for other uses, and carefully and honestly evaluate whether continued grazing on damaged lands is in the public interest. If BLM, using current science and following detailed inventory and assessment finds it may be suitable for livestock as a use of public lands to continue in any areas, the EIS must establish specific measurable standards of livestock grazing use as Terms and Conditions of grazing permits. A 6" stubble height must be the trigger to move livestock from intermittent drainages, springs, seeps and meadow or any other riparian area. A trampling standard of 5% or less of accessible bank area with livestock trampling is another trigger/threshold that must be instituted. When the 5% trigger/threshold is crossed, livestock should be removed from the area. Riparian browse use should be 15% or less on new growth. Upland utilization standards must be 20-25% or less of native species, or levels sufficient to allow a minimum seven inch residual herbaceous stubble height, with no grazing allowed during active growing periods or sensitive periods for native species. 10% or less browse and breakage use by livestock should be the maximum allowed on shrubs. Winter grazing desiccates native grasses, strips them of standing material necessary to protect sensitive crowns from winter freezing, eliminates food and cover for native wildlife, and typically occurs during periods when some growth actually is occurring on native plants, and needs to be very carefully controlled and/or eliminated. Microbiotic crust damage from livestock trampling occurs at all times of years - in summer when crusts are powdery dry, and in winter or spring when moist soil conditions results in deep cow hoofprints in soft soil conditions during thaws. BLM must develop a range of alternatives that rely on the implementation of measurable standards of use, coupled with significant reductions in stocking rates and active herding management by permittees, to protect lands from livestock damage. It must not backslide into the construction of even more livestock facilities, or convoluted grazing schemes when the fundamental problem is over-stocking and over-use, and the grazing of lands that under any grazing scheme will be damaged. Again, we refer you to Debra Donahue’s recent book for use in your EIS analysis. We are including relevant scientific references detailing the ecological harms caused by livestock grazing. This should also be used as a basis for BLM’s analyses. Basic references include: Fleischner 1994, Belsky 1996, Belsky et al. 1999, Belsky and Gelbard 2000, Connelly et al. 2004, Freiclich et al. 2003. BLM must develop a range of suitable and clear alternatives that protect special status species, watersheds and ecosystems. Please do not resort to insertion of “poison pills”, in which an alternative contains something blatantly unacceptable to various factions of public lands users who might otherwise support that alternative. BLM must develop a wide range of alternatives aimed at protecting and enhancing these nationally significant lands and affected waters. These alternatives should include establishment of large ungrazed scientific reference areas to serve as a yardstick for measurement of the degree of disturbance and loss caused by livestock in the project area. Alternatives development should also focus on a range of actions to enhancesagebrush- dependent species’ breeding, foraging and cover habitats; decrease animal displacement; increase prey availability; increase native species biodiversity; stave loss of genetic diversity; increase regional carrying capacity; increase populations of important native biota. Alternatives should include a range of facilities removal and science-based restoration actions. Given the outstanding values and significance, and vulnerability to weed invasion and ecosystemic change of many of these lands, BLM must develop several alternatives that focus on ecological protection. All alternatives must have clear, measurable standards of use and objectives for livestock grazing. Minimize Use of Adaptive Management Agencies are increasingly relying on what is termed “adaptive management” as an excuse for not taking decisive action necessary to protect resources of public lands during planning processes. This results in a vacuum of management direction, with resources suffering. Use of adaptive management should be minimized, and a set of clear actions laid out for management situation/challenges: “If X happens, then Y will happen”, not - “we’ll just keep trying something different and never act to really alter situations that are causing harm”. We are alarmed at the “flexibility” in recent Owyhee decisions, and ask that specific use periods and measurable standards be carefully applied, with no exceptions unless new NEPA occurs. Water Quality and Quantity Livestock grazing is the primary (and often the only) cause of water quality degradation in the Owyhee region. Livestock grazing causes watershed destruction ranging from desiccation of headwater springs and seeps to downcutting and gullying of streams resulting in rapid runoff and limited water storage. We have collected water quality samples on springs, seeps and headwater streams on BLM lands in the Idaho. Coliform and fecal coliform bacteria levels of hundreds of thousands are common, and degraded conditions are similar to those found in many parts of the Planning area. It is precisely these polluted waters that are often critical to declining species such as sage grouse, and to pronghorn antelope who are forced to drink what is essentially a brine of liquid livestock feces, urine and mud. BLM must collect baseline water quality data on intermittent drainages, springs, seeps, streams and other riparian areas during periods of the year when livestock are present, and/or runoff is occurring, as part of this process. This is necessary to allow up-to-date and informed decisionmaking on compliance with state water quality standards and the CWA, and much- needed additions to the 303d list. It includes bacterial, temperature, sediment and other data. BLM cannot merely rely on state lists - since in many cases, state agencies regulating water quality have old, or out-dated information that includes only a very limited number of sites. BLM must assess the effects of livestock-caused pollution of springs, seeps and all surface waters on recreational uses, and on aesthetics. BLM must provide for compliance with water quality standards with definite triggers and responses to water quality problems that are clearly spelled out in this process. Application of specific yearly water quality monitoring procedures must be a made a term and condition of livestock grazing permits in the area. BLM must analyze watershed-scale impacts of livestock grazing. FRH Assessments BLM must systematically collect adequate on-the-ground information on the health of the land and waters and prepare valid FRH assessments. Much of BLM’s limited data used here was old, or biased by industry consultants. Updated, systematic, science-based FRH assessments must be conducted, and must be based on adequate monitoring of current conditions. See additional comments in separate area. Large Livestock-Free Reference Sites BLM must designate large (greater than 10,000 acres) sites, and entire watersheds, over several representative portions of the area to act as scientific reference sites to provide refugia for native species whose habitats have been degraded by livestock grazing practices and livestock facilities, and to allow evaluation of livestock grazing impacts to these wild lands. LIVESTOCK RANGE INSTALLATIONS AND VEGETATION TREATMENTS BLM must inventory and identify all livestock facilities, range projects and zones of heavy livestock concentration such as salting or water haul sites, and present this information to the public in the - wells, pipelines, troughs, spring projects, fences, cattleguards, corrals, as well as water haul sites. The location, operating condition and state of repair of all installations must be revealed to the public, as well as their cost at time of construction, and maintenance responsibility. For example, if there is a rusted out cow trough sitting surrounded by a pool of mud that resulted from a spring development, the public needs to know this. How many spring- projects have resulted in drying of the spring water source? How much water is removed from the “developed” springs, and how much remains, for all existing spring projects? Likewise, all vegetation treatments (seedings, chainings/railingsdings prescribed fire, post- wildfire seeding) must be detailed. How many seedings exist on these lands, and what is their current condition and productivity (compared to what the productivity was planned to be)? How are these projects or facilities fragmenting habitats for sagebrush-dependent wildlife? All direct, indirect and cumulative impacts must be identified. How are these installations or treatments impacting soils, vegetation, cultural sites, habitats, etc. on adjacent lands? How are they impacting the broader landscape? BLM must provide an analysis of range installations that may be degrading important wild land sites. For example, if a cow trough is leading to increased disturbance of soils in a WSA or a cultural site or sage grouse nesting habitat, then that cow trough should be removed, and lands rehabilitated. What threats does each of these facilities pose to special status species or their habitats? BLM must examine such impacts across land ownership lines. Livestock permittees routinely clamor for more projects, and BLM - in an attempt to avoid reductions in livestock numbers necessary to protect public lands values - obliges. It is time to reverse this trend. After compiling a comprehensive inventory and analysis of range installations and their impacts to native biota, BLM must identify those which are no longer working/in repair, and also those which are causing harm to special status species, raptor prey, springs, watershed, or other important public lands values, and act to remove them. It does not matter if these facilities were built pre-FLPMA or not. BLM must review all project information in its files, and thoroughly examine the facility network on-the-ground, visit all installations, collect complete and systematic information on their impacts on soils, microbiotic crusts, native vegetation, watersheds, wildlife, and cultural sites, and determine whether it is in the public interest to remove them and restore damaged lands. We are tired of visiting Owyhee BLM wild lands and encountering seas of livestock feces, bare dirt or weeds surrounding cattle tanks, and on closer examination seeing extensive areas of lithic scatter being newly exposed by erosion from livestock concentration, or expanses of halogeton or white top emanating outward from them. In addition, even modest maintenance and protective measures for native wildlife are often lacking. Floats to promote water flow conservation are lacking, there are no wildlife escape ladders so troughs are deathtraps for migratory birds, etc. BLM must also evaluate the impacts of fences and fence posts on special status species and their habitats. For example, if a fence is located in important sage grouse nesting habitat and it is providing perches for sage grouse nest predators such as ravens, the fence should be removed. See Connelly et al. 2004 for a discussion of harmful impacts of fences. In the past, the construction of these facilities has been the justification for continued excessive stocking rates. A key part of BLM’s analysis must be the suitability/capability studies, and reduction in livestock numbers and changes in livestock management practices that includes facility removal and subsequent site restoration. Removal of Projects In particular, BLM must assess the impacts of all wells, pipelines, water haul sites, stock ponds and other artificial upland water sources on special status species, watersheds, and native vegetation, and analyze the removal of harmful artificial livestock water sources in the alternatives. These artificial water sources are resulting in serious damage to surrounding lands due to concentrated and/or increased livestock use. These facilities and the excessive livestock use associated with them is a serious threat to special status species. It greatly increases site vulnerability to exotic species invasion, creates habitat and behavioral conflicts with wildlife, degrades recreational experiences, etc. These artificial water sources are not compatible with achieving enhancement or restoration of damaged special status species and sagebrush sea habitats. Water Hauling Water hauling is associated with a great risk of weed infestation and spread (regular vehicle trips through weed-infested roads and roadsides, and then deposition of weed seeds in areas of livestock disturbance and ready dispersal). BLM should not continue allowing water hauling. Lands that are too arid to provide surface water to livestock should not be grazed. Water hauling leads to road damage and disturbance of wildlife, as well as ranchers clamoring for road improvement, which may lead to increased human use and disturbance of wildlife. Any sites where water is hauled - even for one grazing season - will suffer permanent harm from trampling - soil compaction, loss of microbiotic crusts, and grazing -weakening or loss of native grasses, structural damage to shrubs, depletion of desirable plants. Thus, allowing water hauling to new areas is particularly detrimental. Plus, water sources for hauling may be on weed-infested private lands (such as white top/hoary-cress infested lands in the South Fork), and water hauling may rapidly spread weeds into wild lands through seeds on vehicle tires, weed infestation and then subsequent cross-country spread by livestock. No TNR BLM should not allow Temporary Non-Renewable Use (TNR) on these lands through this process. TNR use is not compatible with restoration of damaged plant communities, protection of special status species habitats, or maintenance of wildlife populations. TNR has typically occurred in the winter - when there are significant conflicts between wintering wildlife and human intrusion on special status species, raptor, big game and other winter habitats. Plus, in many areas where TNR has been issued, smaller native bunchgrasses may be growing, microbiotic crusts extensively trampled under muddy conditions, and sagebrush consumed as winter browse. Shrub Die-off and Drought Impacts Recent die-off of sagebrush has occurred on many areas of public lands. BLM must inventory and assess areas of plant die-off across these allotments and surrounding lands. How will any die-off affect habitats? What actions can be taken to minimize impacts to native wildlife? Impacts of recent on plant vigor and species composition must be assessed. Post-Burn or Treatment Rest A minimum period of five years rest from livestock grazing following any wild fire must be standard operating procedure on these Owyhee lands. This is necessary to allow recovery and establishment of native species. Grazing should then be allowed only if specific measurable criteria for establishment of native vegetation and microbiotic crusts have been met. Only native species should be used in any post-fire seeding effort - or in any seeding effort (such as road rights-of-way, areas where cow troughs are removed). BLM should not construct new or temporary fences in burned lands. The already existing pasture fences should be used to control livestock. Electric fences very often fail, and burn trespass occurs. Any livestock trespass of burns or areas being rested from grazing must result in permit action against the responsible permittee. The public’s investment in fire rehab is often tens of thousands of dollars, and it can be destroyed through trespass. Road Maintenance Road maintenance must be kept under controls. BLM lands are increasingly characterized by examples of overkill in maintenance that results in blading willows, blading huge bare swaths (as weed corridors) on the roadsides, and unnecessary drainage furrows hundreds of feet long in relatively flat terrain. BLM must try to maintain and promote native vegetation on roadsides and keep them from becoming weed corridors (see Gelbard and Belnap 2003). Predator Killing BLM must assess the impacts of predator control actions across these lands on special status animal species and native plant communities. BLM must outlaw aerial gunning of coyotes - which causes intrusive disturbance in wild land areas and may disturb sensitive wildlife species during critical periods of the year. Activities of Wildlife Services can damage public lands. For example, WS may harm public lands and values by: driving roads when muddy, disturbing wildlife during sensitive times of year; cross-country travel by OHVs spreading weed seeds, crushing vegetation or harming soils; trapping in sensitive species habitats or near popular recreation areas or important wildlife habitats; altering population structure of native predators; removing badgers that are important in providing burrows for burrowing owls; reducing predator kills and thus reducing carrion for bald eagles and some other raptors; accidental mortality of golden eagles or other raptors in traps, etc. Purposeful drastic alteration of predator communities takes place on an annual basis in many wild lands of the West as a result of predator killing activities conducted by APHIS/WS as a subsidy to the western public lands livestock industry. Public lands livestock grazing is often accompanied by aerial gunning, trapping, snaring, den gassing, poisoning and other methods of predator removal, aimed primarily at coyotes. Harmful impacts of removal of resident adult coyotes is discussed below under Predation. Predator removal may also actually increase predation by smaller predators in localized areas. Removal of larger predators like coyotes may result in meso-predator release where smaller predators thrive in absence of larger ones. The placement of artificial water sources (wells, pipelines and water troughs) for livestock may increase predator impacts on sage grouse, pygmy rabbits and other sensitive species, by increasing predator distribution and density. BLM must propose alternatives that constrain or remove WS activities from sensitive species habitats on these lands. Removal of native predators only results in increased predation problems, and upsets the stable social structure of coyotes or other native predators. If a rancher claims a predation problem, then that rancher should be responsible for protecting livestock by increased herding and vigilance. If the rancher is unwilling to do that, the livestock should be removed from the public lands. BLM must present accurate and detailed information on the areas where predator control activities currently occur, and the amount and timing of such activities. Weeds/Exotic Species BLM must address domestic livestock as a primary cause of weed infestation across the project area lands. Livestock: travel cross-country transporting weed seeds in mud on hooves, fur and feces; create zones of intensive disturbance that are ideal sites for infestation by weeds, harm and weaken native vegetation giving aggressive exotic species an advantage. BLM must identify lands that are currently “at risk” for weed invasion, and identify specific preventative measures that will be taken to prevent their spread. BLM has shrugged aside the role of livestock in weed infestation, and thus has been largely ineffective in weed control. BLM continues to graze sites of known weed infestation, thus ensuring that infestations spread – as livestock are tremendous vectors of weed seed spread and create disturbance where weeds thrive. BLM’s approach is obviously not working. BLM must take all possible measures to prevent the spread of weeds into the fairly intact native vegetation communities in the area, including quarantining cattle before turnout on public lands for sufficient periods for weed seeds to pass through their systems. A rapidly expanding threat in the Owyhee lands is white top/hoary cress, which has the potential to become established in disturbed sites - such as livestock-trampled wet meadow and spring margins, and then move out into surrounding native vegetation. BLM’s past failure to act to control livestock grazing practices and reduce stocking rates has resulted in the rapid spread of this uneradicable exotic. BLM must specify actions on permits that will be taken to prevent infestation - such as closing pastures or allotments to all grazing until weed infestations are under control, and conduct an Integrated Management strategy. Vehicles are also a source of weed transport, so banning cross-country travel by permittee ORVs and closing jeep trails or minor roads in lands “at risk” for weed infestation are logical ways to limit vehicle transport of exotic species seeds. Springs, Seeps, Wet Meadows, Springbrooks, Streams BLM mentions two springs, Piute Creek and intermittent drainages – yet NO assessment data is provided. BLM must conduct a full inventory and assessment of the location, condition and characteristics of all spring, seep and wet meadow areas, including historically wetted sites. BLM must study the role of historic and ongoing livestock grazing and trampling activity (and other disturbances such as roads, mining, wild horse use, etc.) in altering, degrading or desiccation of these scarce sites. The inextricable link between the health of springs, seeps and wet meadows and watersheds must be addressed. A full suite of restoration actions for damaged, degraded or diverted riparian areas must be assessed under all alternatives – including an array of passive treatments, such as stubble heights, rest to jump start recovery, or until recovery, then limited, if any grazing. BLM must collect data and photographs provide evidence of the failure of past structural or excavational developments and its failed riparian management actions – especially accompanied by high livestock stocking rates - to protect public land values. Despite the damage it has caused in the past, BLM proposes to develop and irreversibly alter even more fragile springs. Springs are “hot spots of “hot spots” in arid lands. 75 percent of 505 springs surveyed by Sada in northern Nevada were highly or moderately disturbed (Sada and Herbst 2001). Degradation of springs in the Great Basin is widespread. Their isolation and small size render many spring communities particularly vulnerable to disturbance and loss. “The continued development of springs for livestock by ranchers and state and federal agencies also poses a threat to the continued existence of spring biota”. These actions typically involve fencing off an area, immediately adjacent to springs, piping most or all of the water off the site to livestock tanks. Although some riparian vegetation may be retained, “the essential flowing character of the spring is lost, and often no exposed water remains on the surface”. Livestock grazing poses a serious threat to spring communities. Livestock trampling reduces substrates to mud, can completely eliminate vegetation, and alters flow characteristics. The magnitude is likely great because of complete alteration of vegetation and substrate structure. www.biology.usgs/gov/s+t/SNT/noframe/gb150.htm Sada and Pohlman (2003) provide a series of protocols to be followed to assess spring condiitons. Given the scarcity of springs across these allotments, the extreme damage that has been caused by livestock grazing and other disturbance, often coupled the ill-conceived developments that have occurred, often killing all natural water flows at spring sources, BLM must conduct Level I (locate and provide reconnaissance level characterization of springs, delineate important species distribution and salient aspects of habitat, and unique circumstances/challenges) Level II (qualitatively sample riparian and aquatic communities to determine community structure quantitatively sample salient physiochemical elements to identify aquifer affinities), and Level III Surveys (quantitatively sample to determine\aquifer dynamics, sample riparian and aquatic communities and habitats to determine spatial and temporal variation in environmental and biotic characteristics, and to quantitatively determine biotic and abiotic interactions). Identify and characterize all sites. BLM must then follow this with surveys that fully assess the ecological scene, and the effect of management and livestock use and other uses, across a broad area. These Protocols must include collecting information necessary to assess the extreme importance of springs and the continuum of hydric and mesic vegetation communities in their vicinity to sage grouse, especially in providing essential summer brood rearing habitats (green forbs); to migratory birds (deciduous shrubs and trees); and many other important attributes vital to other native animals. Level III surveys can add this element. Thus, in addition to all the important issues raised for consideration, the importance to sage grouse and other wildlife must be fully considered. We believe this elevates ALL spring areas here (especially since so much damage - including harmful development - has been allowed to occur, and the potential at many sites so greatly reduced) that ALL springs, seeps, wet meadows here are worthy of restoration to whatever potential can be achieved. We urge BLM to very carefully examine all intermittent and ephemeral drainages, as well. Often, water not only persists in intermittent and perennial drainages in pockets as a result of runoff, but seep, spring and mesic areas may be present, and interspersed along the length of these drainages. Erosion, downcutting and lowered water tables stemming from livestock grazing is often a primary cause of perennial reaches becoming intermittent. BLM must also determine if stock ponds or other livestock facilities have been built/placed/gouged into or on top of spring, seep or meadow areas. Restoration potential must be assessed, and plans must be developed to restore such sites and incrase perennial flow under all alternatives. BLM must conduct studies of all desiccated, dried up, or otherwise altered springs, and develop plans for restoration of riparian area structure (areal extent of wetted area, native vegetation components), and flows. The benefits of restored or more natural springs to native species must be assessed. For example, what are the characteristics of a riparian community sufficiently restored to support yellow-breasted chats? Aquifer sources: Springs are supported by precipitation that seeps into soil and accumulates in aquifers (through fault zones, rock cracks, or orifices that occur where water creates a passage by dissolving rock) where it is stored. The hydrology of springs is affected by regional and local geology, and how water moves through an aquifer. Perched aquifers often characterize high elevations, where local aquifer springs may be fed by adjacent mountain range precipitation, and may change annually due to recharge from precipitation in mountain range. They typically have cool water, and may dry out during extended droughts. Regional aquifers support warmer springs fed by several recharge sources that may extend over vast areas. Aquifer flow is complex, and may extend beneath several valleys and topographic divides. Seeps are small springs that support vegetation adapted to drier conditions. Springs may be small, but have larger aquatic habitats, and support larger riparian zones with moist-soil affinity species. Springs are characterized by the morphology of their sources. Each spring and seep is a unique combination of physical and chemical conditions (Sada and Herbst 2001, Sada and Pohlman 2003). These, coupled with disturbance factors, are dominant influences on riparian and aquatic plant and animal communities. Highly modified springs have less diverse riparian communities, and may include non-natives, and upland-associated species. Plant and animal communities associated with spring-fed wetlands are a function of physical and chemical characteristics of water and soils, proximity to other aquatic habitats, and prehistorical connections with regional drainage systems (Sada and Herbst 2001, citing Hubbs and Miller 1948, van der Kamp 1995, McCabe 1998). Primary abiotic factors that influence biotic qualities of unmodified springs include habitat persistence, geographical and geological settings, and aquifer dynamics Sada and Herbst 2001 (citing Ferrington 1995, van der Kamp 1995). Springs have a more integral connection with ground water than streams (Sada and Herbst 2001). At Ruby Marsh, Sada et al. 2001 found that substrate composition, water depth, springbrook width, current velocity, conductivity and vegetation were most influential in affecting macroinvertebrate communities. Habitat condition strongly influenced biotic characteristics. Degraded conditions often masked the influences of natural events and chemical characteristics on the macroinvertebrate community structure. 54 percent of aquatic species endemic to the Great Basin springs have suffered population losses and 62 percent have suffered major decreases because of channelization, impoundment, removing water and the introduction of non-natives. Removing water from springs through diversion reduces habitat for vegetation and aquatic biota by decreasing springbrook length, water width, water depth, and quantity of water available for vegetation. Groundwater pumping and surface diversion have decreased and dried up many springs and springbrooks in the Great Basin, causing loss of populations and extinctions. Riparian vegetation at springs may be restricted to area just along immediate boundaries of aquatic habitat, or may extend outward over much larger areas. Wider riparian areas occur where water seeps outward and moistens hydric soils. Species may be restricted to spring sources. Rheocrene-inhabiting species are more similar to stream-inhibiting species, and limnocrene species to lake or pool inhabitants. Springs tend to be more constant environments than other aquatic habitats. Spring size and habitat conditions influence biodiversity of springs (Sada and Pohlman 2003, citing Sada and Nachlinger 1996 and 1998), with different species inhabiting spring sources than downstream reaches/springbrooks. Ephemeral springs and seeps with harsh environments may have fewer species. Possible relict endemic taxa may occur in Great Basin Springs springs, including these allotments. These taxa include springsnails, endemic beetles and bugs (especially if springs have gravel substrates and fast flow). High animal species diversity may exist in springs, due to relative isolation, the presence of water, and their relict nature. Plant diversity and endemism may be high too. Spring-fed riparian habitats are of great importance to wildlife species for roosting, food, and shelter. Higher quality springs have high structural diversity created by a dense undergrowth of tangled vegetation and debris. This vegetation may be reduced by diversion, burning, vegetation control and grazing, so suitable habitat is eliminated or degraded, with the result that the songbird nest parasite brown- headed cowbird can more readily invade and parasitize the nests of migratory birds. Migrating birds may use spring waters to drink, and vegetation and insects associated with springs to refuel. Migration stresses may cause insectivorous and frugivorous bird species to drink. Plus, granivorous species are more dependent on water. Birds are vulnerable to predation, and seek watering sites with greater tree and shrub cover. Areas with larger intact riparian vegetation may attract more migrants, and thus provide more prey for raptors such as Cooper’s hawk or northern goshawk. Small mammals such as voles may be endemic to spring-fed mesic alkali wetlands. Water produces insects whose aerial life forms are eaten by both birds and bats. Insectivorous birds forage on deciduous foliage. A spring creates a continuum of soil conditions from wet to moist to dry, each harboring plant and animal associations adapted to those habitat conditions. BLM must systematically inventory native fauna present in and near springs, seeps and springbrooks, over at least two years. As an example of breeding bird inventories (that should also be performed in the full spectrum of vegetation communities across a range of ecological conditions in these allotments) , see Red Willow 2004, “Pinyon-Juniper and Juniper Birds”. In this two-year study, breeding bird surveys were conducted in and near riparian habitats primarily in pinyon-juniper and interfacing big sagebrush communities, which are typical of much of the vegetation in watersheds supporting springs in the project area. Aquatic biota must also be assessed. Sampling for invertebrates must include collection from all habitat types within a spring (spring, springbrook, degraded reaches, any undegraded reaches). All springs within the project area must be sampled for invertebrates. The link between the condition (health) of the watershed and the functionality springs and springbrooks must also be assessed. Anthropogenic disturbances like livestock grazing and other uses have degraded vegetation, increased water temperature, and increased fine sediments. Aquatic and riparian habitats can be degraded or eliminated through water diversion, intense grazing and trampling, and non-native plants. Springs have often been piped, spring brooks channelized, and excessive ground water withdrawal has occurred. This affects spring biota by decreasing habitat size (drying some habitats) and vegetative cover, and changing species composition. Level I Surveys: Locations, type of spring - rheocrene/limnocrene, volume of spring discharge, springbrook length and depth, wetted perimeter width, DO, temperature, conductivity, pH, percent of emergent cover, percent and type of emergent cover, percent of vegetative bank cover, springbrook bank incision, spring brook bank stability, percent of wetted perimeter covered by watercress, substrate composition, animals present. Estimate site condition and identify influences causing disturbance, i.e. level and cause of disturbance, grazing, horses, diversion. “natural disturbances” – drought, fire, scouring floods, avalanche – however – these can be exacerbated – or caused – by grazing effects. Multiple surveys are needed to measure discharge, which may vary seasonally or otherwise. BLM must research any existing information on spring characteristics – flow rates, aquifer depletion, BLM’s own records and project files regarding any spring or other developments, any water rights filings, any water rights surveys done by BLM, etc. BLM should also research any water rights filings by other parties on spring flows, or any waters where diversion/drilling/depletion may affect flow rates from springs in the project area (which includes other nearby lands important to special status species here, or to which springs may be linked). BLM must provide detailed descriptions of past projects – and promises made during authorizations, funding agreements, etc. and/or NEPA. This is necessary to understand all direct, indirect and cumulative impacts of actions affecting spring flows, health and hydrologic integrity. BLM must describe spring provinces/complexes/clusters, also. What type of spring is it? What functional changes or changes in biodiversity have occurred? How can function and/or biodiversity be restored? What are flow rates throughout the year – under drought or normal conditions? What is the current areal extent of wetted area vs. historical? (Examine soil profiles and characteristics, remnant plant communities, etc.). What vegetation would be present in an undisturbed site? What is the potential of the site (vegetation, flows, habitat) if livestock grazing or other disturbance is removed? Reduced by one half? Reduced by 75%? How are livestock grazing or other disturbances in the watershed affecting aquifer recharge or flow rates? How do runoff rates (and also recharge rates) from a watershed in pristine or good condition compare to the rates from watersheds in poor or fair condition? What is the condition of intermittent or ephemeral drainages in the watersheds? Is gullying, rilling, head-cutting or other erosion occurring, and how is grazing or other disturbance affecting this? What aquifer is each spring part of, and what are past, current or anticipated threats to these aquifers? How long will it take to recover flows to ¼, ½, all historically wetted areas of springs that have been highly degraded or altered through diversion? What are values of each spring as sheltering, rearing, feeding areas for sage grouse chicks, refueling stops for migrants, water for nesting songbirds across a land area, providing essential water to raptor chicks, etc.? BLM must commit to regular scheduled monitoring of many parameters – water quality, flow rates, aerial extent of wetted area, plant species composition trampling, etc. In review of many BLM riparian documents, such as subjective PFC assessments, we have frequently noticed a bias towards rating areas in better condition if livestock grazing has not yet occurred in an area at the time the assessment is conducted. Thus, surveys must be conducted over multiple years, and must also include surveys during periods when livestock have been present for a significant amount of time – for comparison with any studies conducted in livestock-free periods. BLM cannot rely on monitoring only intermittent drainages, springs, meadows in good condition. Given the extreme damage that has occurred (and continues) here – all sites should be monitored. This must be done during the time of year when livestock are actually present in the allotment. It is especially important that BLM track sheep grazing patterns in the Sheep allotment Complex, and fall/winter/spring use areas of the other allotments, and study impacts that are occurring throughout the period when livestock are present, and that these studies be conducted over multiple grazing years. Repeatedly, we have seen Nevada BLM blame wild horses for impacts when in reality livestock, especially trespass cattle, are present during unauthorized seasons of the year and their impacts are being attributed to horses. Under all alternatives, BLM must establish long-term monitoring of effects of levels and types of resource use to riparian and aquatic macroinvertebrates, quantitatively describe biotic communities. Initiate by establishing baseline conditions that identify spatial and temporal; variability in biotic and abiotic features (Sada and Herbst 2001). Quantify baseline conditions by describing changes in vegetation and invertebrate demography and assemblage structure; and the characteristics of riparian and aquatic habitats. Sample for sufficient time to encounter a broad range of environmental conditions and fluctuations in demography and structure. Long- lived species should be sampled for a long time, short-lives species – long enough to encounter environmental variability. Sada and Herbst at 12). Springs and riparian vegetation should be managed as wetlands, and they can generally be protected by guidelines to manage similar wetland systems such as riparian zones. Macroinvertebrate and vegetation surveys should be conducted prior to implementing management actions that may adversely affect spring biota (Sada and Herbst 2001 at 14). These also serve as an environmental baseline to gauge any management changes. In order to be able to understand cumulative, synergistic or indirect impacts of proposed actions (and to adequately understand current conditions). Degradation/loss of springs and other riparian areas may be caused by groundwater pumping, hot spring development, open-pit gold mines. To the south in Nevada, extensive ground water depletion has occurred as a result of cyanide heap leach gold mining. Cumulative or synergistic impacts of such activities, if they affect aquifers or biota on these allotments, must be assessed. As springs associated with aquifer sources affected by gold mining in northern Nevada increasingly dry up, the springs of these lands become of even greater regional significance. BLM must weigh the relative scarcity of undeveloped springs in the landscape, and the increasing loss of springs across the region. Intermittent/Perennial Drainages For all streams and springbrooks in or related to the project area and species of interest, BLM must assess the following: How has vegetation been changed, reduced, eliminated? How have channels been widened or degraded? Have water tables been lowered? Has erosion potential increased? How have these effects impacted habitats for raptors, sage grouse and other special status and important species? How does livestock consumption of overstory vegetation, elimination of shady cover, trampling of banks, etc. affect water quality (temperature, sediment, bacteria, algae) and aquatic species presence and habitats? What are the characteristics of the banks in areas accessible to livestock use? How is livestock grazing affecting recruitment of young willows and other riparian plants, and altering structure of older or mature shrubs and trees? What is was the historical potential of the site? What would the potential of the site be under rest from livestock grazing (coupled with flow restoration if large volumes are diverted or the spring is damaged by diversion) in 5, 10, 15, 20 or more years? How much more quickly would sites heal if livestock were removed to jump start recovery? How is livestock grazing or other current disturbance (of the stream and its watershed) affecting vegetation, banks, water quality, aquatic species, flow, stream morphology? How is livestock grazing or other disturbance contributing to the intermittent or ephemeral conditions of the stream or spring brook? For all riparian areas, BLM must pay particular attention to livestock trampling impacts, as over time, trampling of clay soils near springs may seal the spring, causing it to dry up completely. Plus, BLM must assess the impacts of intense or concentrated livestock use in areas in the vicinity of riparian areas, i.e. troughs or dug out ponds outside small exclosures. BLM must collect detailed water quality measurements throughout the time when livestock are present, as well as during spring runoff to assess livestock impacts to water quality. BLM must fully consider the relative scarcity of these values in the arid landscape when balancing uses. Desertification and Watersheds There is an extensive body of scientific literature on desertification of watersheds, including in the western United States. Desertification is defined as: “a change in the character of the land to a more desertic condition”, involving “The impoverishment of ecosystems as evidenced in reduced biological productivity and accelerated deterioriation of soils and in an associated impoverishment of dependent human livelihood systems”. See Sheridan 1981, CEQ Report 1981 at iii. Major symptoms of desertification in the U. S. include: declining groundwater tables; salinization of topsoil or water; reduction of surface waters; unnaturally high soil erosion; desolation of native vegetation (Sheridan CEQ at 1). The existence of any one can be evidence of desertification. As lands become desertified, they become less productive, and activities such as livestock grazing become less sustainable. Continuing activities like livestock grazing may result in grazing becoming permanently unsustainable across the landscape. In many areas of these allotments, ecological conditions because of desertification and degradation processes that has already occurred and which is still underway, have already crossed the threshold between sustainability and, essentially, “mining” of increasingly non-renewable natural resources. Desertification can be both a patchy destruction, often exacerbated by drought, as well as as the impoverishment of ecosystems within deserts. BLM must assess the levels and degree of desertification that have occurred across these lands. This is necessary to understand the suitability of these lands for livestock grazing, the productivity and carrying capacity of these lands for grazing, the effects of any alternatives developed here, the ability to meet any objectives, and the ability to sustain, enhance or restore habitats and populations of special status and other important species and native plant communities . For example, how has the extensive depletion of understories in many areas of Wyoming big sagebrush and salt desert shrub vegetation affected the degree and rate of desertification processes? How has this affected livestock patterns of use, acres per AUM, etc.? What are the acres per AUM across all vegetation types in all conditions? How many acres per AUM are required to sustain cattle or sheep in the lower salt desert shrub or Wyoming big sagebrush communities? What actions can be undertaken to halt desertification processes and begin recovery? BLM must also assess the combined effects of desertification and exotic species/weed increase and infestation. Even PRIA acknowledged that production on many BLM lands was below potential, and would decline even further. To continue the current level of grazing under BLM’s Decisions will result in even further loss of soil, microbiotic crusts, water, watershed integrity, wildlife habitat, and forage. BLM’s Decisions (and “Proposed Action”) allow livestock numbers greatly in excess of those grazed here in recent decades. The fact that AUMs/stocking rates much below the high permitted levels were actually grazed, demonstrates the continued loss of productivity on these lands. Desertification symptoms in arid lands include: Sparsity of grass; presence of invading plant species - both native and non-native, in grass areas that have survived: plants are of poor vigor; topsoil losses - in many places, topsoil is held only by pedestals of surviving plants. Surface signs of soil erosion include: pedestaling, gullies, rills, absence of plant litter to stabilize soils. Desiccation and erosion caused by livestock can cause water tables to drop, rilling, gullying and arroyo cutting to occur, and result in sediment flow from degraded areas (Sheridan CEQ at 14). Grazing creates extremely dry site conditions for plants due to removal of litter, loss of soil cover, and trampling of the ground that prohibits rainfall from reaching plant roots (CEQ at 15). Livestock grazing exacerbates any climate changes and shifts that may be occurring (CEQ at 16). This is of particular concern in the northern Nevada landscape periodically plagued with severe drought, and which is facing increasing heat and aridity due to global warming. The near-absence of many species of native bunchgrasses, such as larger-sized native grasses from many areas of these lands, such as the diminished state of the once abundant Indian ricegrass (Oryzopsis hymenoides), signals stress of overgrazing (CEQ at 19). Such losses are vividly shown in BLM’s Key Area data, as shown in the Assessments. Absence of plant litter makes germination of natives more difficult. Recovery of lower elevation areas will be exceedingly slow, especially considering the aridity of the project area. Arid land recovers very slowly; massive soil erosion has exposed soils that are less able to support plant life because of lower organic content; and invader species have become well established and have the competitive edge (Sheridan CEQ at 21). Even though it is well recognized that “the way to end overgrazing is to reduce the number of livestock in the end” (Sheridan CEQ at 22), political pressures from ranchers results in strong political opposition to reduced grazing. Political pressures have hamstrung implementation of the Taylor grazing Act. This process provides BLM a special opportunity to gain a better understanding of the actual capability and productivity of the vegetation and soils that meets the desires and needs of the public on these lands. Sagebrush, pinyon-juniper and salt desert shrub vegetation communities in Idaho and Nevada are now showing signs of “extensive changes” and significant stresses, with livestock grazing and aggressive non-native weeds recognized as among important causal factors. Nevada Natural Resources Status Report 2002 http://dcnr.nv.gov/nrp01/bio02.htm . Continued grazing disturbance, degradation and weed invasion will cause native plant communities to cross thresholds from which recovery is very difficult, if not impossible. The decline in Nevada’s sage grouse populations and other species dependent on arid land shrub habitats is a landscape-scale biological indicator that the loss of functions and values of sagebrush ecosystems are serious and widespread. These are also signs of desertification processes across the landscape. Imperilment of the Sagebrush Biome A recent analysis, Dobkin and Sauder 2004,“Shrubsteppe Landscapes in Jeopardy: Distribution, abundances, and the uncertain future of birds and small mammals in the Intermountain West”, examined bird and small mammal species in the sagebrush biome. The authors found that “very little of the sagebrush biome remains undisturbed”, the inherent resilience of the ecosystem has been lost and the ability to resist invasion and respond to disturbance has been compromised (Dobkin and Sauder at 5). At least 60% of sagebrush steppe now has exotic annual grasses in the understory or has been converted completely to non-native annual grasslands (citing West 2000). More than 90% of riparian habitats have been compromised by livestock or agriculture. The authors distilled a list of 61 species of birds and small mammals that are completely or extensively dependent on shrubsteppe ecosystems, and conducted an analysis of their distributions, abundances, and sensitivity to habitat disturbance to assess current state of knowledge and conservation needs of these species. Soils, Microbiotic Crusts, Desertification Processes Livestock grazing during all periods of the year damage soils and microbiotic crusts, and increase soil vulnerability to wind and water erosion. Trampling damage to soils effects everything from burrows of native animals, to larvae of native pollinators to roots and mycorrhizae of native tree shrubs and trees. Since harms to soils are hard to quantify and monitor from year-to-year, it is essential that BLM establish upland standards of use that provide maximum protection for soils. In addition, BLM must conduct annual use pattern mapping to identify zones of intense livestock use. Use in no areas of a pasture/allotment should be allowed to exceed upland standards. This means there should be no sacrifice zones to livestock - such as areas close to water sources. If standards of use - upland or riparian - are exceeded anywhere in the pasture/allotment, this should be the trigger to remove livestock. Cultural Values Important cultural sites are often located in association with rare springs, plateau rimrocks, drainages or associated camp or hunting sites. Threats to these sites include increasingly easy road access due roads resulting from livestock facilities and management purposes. Increased or more improved roading leads to vandalism or disturbance of cultural sites. Livestock cause erosion and damage or loss to artifacts and sites - particularly in the vicinity of springs, seeps and other riparian areas. Livestock facility construction causes shifts in livestock use that may lead to new or extended damage to sites – spanning the range from disturbance of rimrock stone blinds, to trampling and breakage of artifacts. Invariably, BLM’s cultural specialists are forced to allow range developments to proceed, despite shifted use to new areas that may also have cultural importance. Comprehensive cultural surveys must be conducted, and the impacts of current livestock grazing and trampling on sites must be studied as part of this process. The best way to protect cultural sites from looting is to limit roading and motorized access to sensitive areas. BLM must analyze significant road closures of salt site roads, or other facility roads (require routine maintenance or salt placement by horseback, limit new livestock developments - that inevitably lead to increased roading), and take other measures to limit ease of access that might damage these sites. Livestock harm and/or destroy cultural sites in many ways, including: trampling and soil compaction breaking artifacts and destroying site stratigraphy; erosion revealing artifacts to surface collection and livestock trampling damage; erosion destroying site stratigraphy; defiling sites with large amounts of feces and urine. BLM must act to stop this damage under all alternatives. Plus, in the Owyhee country, often small subtle rimrock blinds exist – and livestock may push rocks over and destroy blinds, or blinds be disturbed by fencing or other facilities. Paleontological Values The impacts of livestock grazing and facilities under all alternatives on paleontological values of these lands must be thoroughly assessed. Paleontological values are threatened by haphazard collection (exacerbated by networks of livestock facility roads) and livestock grazing and trampling that results in site erosion, exposure of fossils or strata and other impacts. BLM must inventory and assess paleontological sites, evaluate impacts of grazing activities and facilities on these sites, and identify measures to be taken to protect them from damage or loss. Road Rehab/Restoration A large number of the roads in the wild lands of these allotments were pioneered or constructed only because they allowed ranchers to drive salt to the top of hills, or because they access cattle installations, or have just spring up on the path of a pipeline due to construction and subsequent maintenance. Incursions on unroaded lands are routine – such as those undertaken by livestock permittees to develop or maintain water sources, place livestock installations, place salt licks, etc. As part of its analysis, BLM must examine roading in the context of livestock activities. Roads and jeep trails whose primary purpose is placing salt or checking on a water trough should be closed and restored/obliterated. Livestock permittees own horses, and can and should use them in pursuing public lands livestock grazing. BLM must identify methods of road closure and restoration. All direct, indirect and cumulative impacts of mining, wind, geothermal, and other energy development or corridors on populations of special status species or aquifers across the region must be considered. Economic Analyses Any economic analysis involving these lands must clearly identify that changes in livestock numbers in lands here will not be affecting small ranchers. Instead, they involve a very large operator. BLM must detail its annual cost of administration of livestock grazing on affected lands under the current and alternative systems. BLM must provide the percentage of these administrative costs that are covered by BLM’s income from the approx. very meager grazing fee, and present this to the public in its economic analysis. BLM must detail its other costs in administration of these lands (recreational opportunities lost, weeds invading and treatments, increased fire suppression costs with livestock-caused weeds like cheatgrass) and present this to the public in its economic analysis. This is necessary to understand the administration of livestock grazing. Of particular concern is the lesser funding traditionally spent on wild lands restoration, habitat enhancement, collection of baseline biological data. BLM must also examine the total picture of global warming impacts of cattle grazed on public lands – including while the cattle may be on private lands are feedlots. Roads Dissect Habitats and Provide Weed and Predator Corridors Direct effects of roads are destruction of habitat and disruption of dispersal corridors. Indirect effects of roads are cumulative and involve changes in plant and animal community structure and ecological processes. Roads fragment and isolate populations in species that are hesitant to cross them. Direct habitat loss, facilitated invasion of weeds, pests and pathogens, altered predation rates – are all a consequence of roading. Many weedy plants dominate and disperse along road sides. Opportunistic animals benefit from roads. Edge effects are now seen as harmful consequences of habitat fragmentation for many native species. Indirect effects include increased human access, OHV use, hunting, human- caused wildfires, Roads diminish native diversity of ecosystems. Many roads in rugged western terrain follow streamcourses, so are constructed through the middle of big sagebrush sites following drainages and draws that are critical as dispersal corridors for pygmy rabbits. Roads further fragment wildlife habitats and dispersal corridors, and serve to isolate wildlife populations. Energy development and production activities require vast networks of new roads, cutting across sagebrush habitats, as previously described. Mining, oil and gas, geothermal and wind development, cause extensive new roading. Roading associated with exploration and development results. Roading facilitates weed spread. Utilty corridor, Powerlines Dissect Wildlife Habitat, Provide Raptor Perches, Result in Increased Predator Travel Corridors and Weed Spread Although no powerlines exist here now, a gas corridor does. Powerlines are known to isolate and impact sage grouse populations. Sage grouse use of areas near powerlines increases as distance from the powerline increases for up to 600 m., plus powerlines reduce the security of sage grouse populations in linear strips up to greater than 1 km. in width (Braun 1998). Powerlines may follow roads, or cut cross country through otherwise unfragmented sagebrush habitats. Residential development throughout the Intermountain West is accompanied by networks of powerline and utility lines, and a resulting myriad of raptor perches. Powerlines often cut cross country, accompanied by maintenance roads that may serve as travel corridors for predators, weed infestation, hunters, etc. Geothermal and wind development are accompanied by extensive powerline proliferation and agency issuances of rights-of-ways. This planning process must sharply limit new powerlines. Military Training Impacts Must Be Assessed Impacts of military activities or overflights on public lands must be fully assessed in this land use plan process, and the impacts – use of flares causing fires, noise or low level flights interfering with wildlife or recreational uses, etc. must be fully addressed. Currently Mountain Home AFB and the MOA over the allotment is facing increased use by the Singapore military. Weeds/Exotic Species BLM must take all possible steps to prevent the spread of weeds into native vegetation communities. Weeds are spreading at alarming rates on arid western lands. BLM must first recognize that domestic livestock are the primary cause of weed infestation on BLM lands. Livestock: Travel cross-country transporting weed seeds in mud on hooves, in fur, in feces. They create zones of intensive disturbance that are ideal sites for initial infestation by weeds. They prime sites for weed invasion by harming and weakening native plant communities, providing bare soil sites for aggressive exotic species invasion. See Belsky and Gelbard (2000). BLM must inventory all lands and assess their vulnerability to weed infestation. Strong preventative measures necessary to stem and reverse the tide of weed invasions must be identified and put into action. In the past. BLM has shrugged off and ignored the role of livestock in wed infestation. Its only attempt at control was spraying the most obvious weed patches, taking no efforts to revegetate the “nuked” sprayed sites, and continuing to let livestock graze as normal and continue to spread weeds. This head in the sand approach has resulted in the alarming weed problem we now face. White top is rapidly expanding in Planning area lands. These are spread by livestock, and once established in disturbed areas move aggressively into surrounding lands. They are also spread along disturbed road areas, and by vehicles. Livestock should be quarantined for a period of 4 days before entering public lands, and be fed only weed-free hay. Any lands with known weed infestations should not be grazed until the weed problem is addressed, and weeds have been eradicated. Livestock grazing must be sharply restricted or ended on lands at risk to weed invasion. Livestock projects that result in concentrations of animals and epicenters of weed infestation should be removed, and disturbed sites restored. Roads and vehicles are also a major source of weed transport, and soil disturbance that creates ideal sites for weed infestation. Banning cross-country travel by ORVs, closing and restoration of roads and ways in wild lands “at risk” for weed invasions are logical ways to limit spread of weeds. Limiting road maintenance activities is also important, as the blading of ever-widening shoulders on gravel and dirt roads provides an ideal site for weed infestation and then outward spread. Various mineral and energy exploration activities involve significant cross-country travel by heavy equipment that disturbs soils and/or spreads weed seeds. These activities should be prohibited in all lands with known weed infestation, or which are identified as being “at risk” for weed invasion or spread. BLM must make land use allocations that prevent lands from undergoing weed infestation. As you may be aware, WWP, CHD, ALA, NCAP and others have submitted a Citizens Alternative to BLM for its Weed EIS. Our alternative addresses causes of weed infestation, and provides actions to address those causes. These actions include changes/reductions/cessation of livestock grazing, road closure and other actions that are aimed at effectively addressing causes of weed invasion and spread. BLM must also address measures to restore lands where weeds have been treated. Instead of spraying large areas with lingering herbicides that result in large “dead zones” in soils, and then continuing status quo grazing – which typically results in weeds thriving while all native vegetation on the site perishes – you must remove livestock grazing/vehicles – whatever the disturbance factors are to a site – until it is fully restored with native vegetation, healthy microbiotic crusts, etc. Sincerely, Katie Fite Biodiversity Director Kenneth Cole NEPA Coordinator Western Watersheds Project PO Box 2863 Boise, ID 83701 208-429-1679 Relevant Literature Anderson, L. D. 1991. Bluebunch wheatgrass defoliation: effects and recovery. USDI Bureau of Land Management Technical Bulletin 91-2. Salmon, ID. Anderson, D. C., K. T. Harper and R. C. Holmgren. 1982. Factors influencing development of cryptogamic soil crusts in Utah deserts. Journal of Range Management 35(2):180-185. Anderson, J. E. and K. E. Holte. 1981. Vegetation Development over 25 years without grazing on sagebrush-dominated rangeland in southern Idaho. Journal of Range Management 34(1):25- 29. Anderson, Jay E. and Richard S. Inouye. 2001. Landscape-scale changes in plant species abundance and biodiversity of a sagebrush steppe over 45 years. Ecological Monographs 71(4):531-556. Belnap, J. 1995. Surface disturbances: their role in accelerating desertification. Environmental Monitoring and Assessment 37:39-57. Belnap, J. and D. A. Gillette. 1997. Disturbance of biological soil crusts: impacts on potential wind erodibility of sandy desert soils in southeastern Utah. Land Degradation and Development 8:355-362. Belnap, J., R. Rosentreter, S. Leonard, J. H. Kaltenecker, J. Williams and D. Eldridge. 2001. Biological soil crusts: ecology and management. USDI BLM. Technical Reference 1730-12. Belsky, A. J. and J. Gelbard. 2000. Livestock grazing and weed invasions in the arid west. Oregon Natural Desert Association. Bend, OR. 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Proceedings of the symposium on cheatgrass invasion, shrub die-off, and other aspects of shrub biology and management. USDA Forest Service General Technical Report INT-276. Intermountain Research Station, Ogden, UT. Winder, J.A., C.C. Bailey, M.G. Thomas and J. L. Holechek. 2000. Breed and stocking rate effects on Chihuahuan Desert cattle production. Journal of Range Management 53(1):32-38. Wisdom, M. J., R. S. Holthausen, B. C. Wales, M. A. Henstrom, W. J. Hann, M. G. Raphael, R. S. Holthausen, R. A. Gravemeier, and T. D. Rich. 2000. Source habitats for terrestrial vertebrates of focus in the interior Columbia Basin: broad-sale trends and management implications. USDA Forest Service General Technical Report. PNW-GTR-485. Zimmerman, G. T. and L. F. Neuenschwander. 1984. Livestock grazing influences on community structure, fire intensity, and fire frequency within the Douglas fir-ninebark habitat type. Journal of Range Management 37(2):104-110. Zoellich, B.W. 1999. Stream temperatures and elevational distribution of redband trout in southwestern Idaho. Great Basin Naturalist 59(2): 136-143. STATEMENT OF MIKE PELLANT GREAT BASIN RESTORATION INITIATIVE COORDINATOR BUREAU OF LAND MANAGEMENT U.S. DEPARTMENT OF THE INTERIOR BEFORE THE SENATE SUBCOMMITTEE ON PUBLIC LANDS AND FORESTS REGARDING THE GREAT BASIN RESTORATION INITIATIVE October 11, 2007 Mr. Chairman and Members of the Subcommittee, thank you for the opportunity to appear here today to discuss the major threats to ecological and economic stability in the Great Basin and the Bureau of Land Management’s efforts through the Great Basin Restoration Initiative to reduce these threats. My testimony will focus on the key threats of invasive species, especially cheatgrass, and wildfires. Climate change, including extended droughts, is expected to intensify these issues and also negatively affect water management in the Great Basin. I am the Coordinator for the Bureau of Land Management’s Great Basin Restoration Initiative and am responsible for coordinating restoration-related activities across a five-state area for the Bureau of Land Management. Background The Great Basin is North America’s largest desert, encompassing 135 million acres of land between the Rocky and Sierra Nevada Mountains in western North America. The manager of the largest land base in the Great Basin (includes parts of Nevada, Utah, Idaho, Oregon, and California) is the U.S. Department of the Interior’s Bureau of Land Management (BLM) with oversight of 75 million acres of public land. The Great Basin is characterized by aridity (over half the area receives less than 12 inches annual precipitation) and a mix of shrubs [sagebrush (Artemisia tridentata) being the dominant], with an understory of native grasses and forbs. Today, population growth, wildfires, and invasive species are reducing the quality of native rangelands at an accelerating rate (BLM 2000). Based on recent studies by the U.S. Geological Survey and others, climate change could well be expected to accelerate these changes and associated impacts. The Great Basin is a land of wide, historical fluctuations in climate both on a relatively short and long time frame. Extremes in precipitation (wet years followed by multi-year extreme droughts) and temperature challenge the management of livestock, wild horses and burros, and wildlife on public lands. Given this variability in climate, public land managers have flexibility in adjusting time and amount of forage consumption and water use to sustain land health over the long term. BLM managers evaluate these situations on a local basis and have the regulatory authority to remove livestock or wild horses during extended droughts when forage production or water sources are inadequate to sustain native vegetation. The challenge is to separate the natural climatic variation, especially extended droughts that have always existed in the Great Basin, from climate change, in order to modify and adapt management strategies to adjust to the changing environment. Factors Relating to Climate Change, Including Water, Invasive Species, and Wildfires in the Great Basin The impact of climate change on Great Basin ecosystems may be magnified compared to other ecosystems due to the aridity and lower resiliency of these lands. Rangelands in the Great Basin always are “on the edge” given the uncertain timing and quantity of precipitation, invasive species, altered fire regimes and increasing human population pressures. Water Water is the lifeblood of the Great Basin, given the low precipitation and high evapotranspiration (the sum of evaporation and plant transpiration from the earth's land surface to atmosphere) over the majority of the desert. Water is needed to support an increasing population (three of the ten fastest-growing metropolitan areas in the United States - Boise, ID, Reno, NV, and Las Vegas, NV - are in or on the edge of the Great Basin) while still meeting livestock, wildlife and fish needs. The predicted changes of a decline in snowpack, earlier peak spring streamflows, lower summer streamflows, and elevated stream temperatures could have dramatic effects on habitats and resources available to stream fishes (Isaak et al. 2007). Rainbow and brown trout are predicted to be restricted to higher elevations (Jager et al. 1999). The geographic distribution of the Lahontan cutthroat is projected to be reduced (Dunham et al. 1999) while the bull trout, currently listed under the Endangered Species Act as “threatened” with extinction in the northern portion of the Great Basin, could potentially face even greater risks as a result of climate change (Rieman et al. 1997). Change in the timing and amount of streamflows and spring and seep discharges will affect a wide range of wildlife species, livestock, and wild horses and burros. Water availability from these sources could dry up earlier in the summer as a result of the early melt of the snowpack causing increased competition for water and forage across the landscape. Pipelines and troughs installed by BLM and livestock permittees that provide water for livestock, wild horses, and wildlife species over tens of millions of acres may have reduced capacity to meet these needs. Climate change and the associated impacts on the timing and quantity of water available may exacerbate conflicts over water rights between agricultural and urban interests. Proposals to transport water from the Great Basin to Las Vegas are already a contentious issue and could affect important aspects of human occupation and the resource values in the Great Basin. Native Plant Communities and Invasive Species Invasive species are one of the greatest concerns of many managers in the Great Basin. A consortium of organizations led by The Nature Conservancy identified the Great Basin as the third most endangered ecosystem in the United States due in large part to the dominance of exotic species (Stein et al. 2000). Cheatgrass (Bromus tectorum) is an invasive exotic and the most ubiquitous invasive plant in the Great Basin, occupying over 25 million acres of public lands managed by BLM (BLM 2000). Besides being a serious competitor with native plants, cheatgrass is a significant contributor to the increase in frequency and size of wildfires in the Great Basin (Whisenant 1990). Cheatgrass is expected to respond even more favorably than most native plants to conditions with increased atmospheric CO2 (Smith et al. 2000). One recent study hypothesized that the increase in rangeland wildfires is partially due to enhanced cheatgrass production stimulated by increasing CO2 levels (Ziska et al. 2005). This study also found that cheatgrass will become more coarse (e.g., lignin content will increase) in the future which will reduce the time that it is palatable to livestock and wildlife and thereby result in the greater accumulation of fuel loads. Managers are also concerned about the predicted increase in woody vegetation as a result of climate change. An increase in woodland encroachment into shrublands/grasslands, including a significant expansion of juniper into sagebrush steppe, is expected. One model predicts that much of the sagebrush in the southern Great Basin could eventually be replaced by Mojave Desert shrubs to the south due to projected higher temperatures and less frost in this portion of the Great Basin (Neilson et al. 2005). The increase in juniper trees will reduce palatable forage for livestock, habitat for wildlife, and protective understory vegetation resulting in more soil erosion. Loss of sagebrush will have significant impacts on wildlife species, especially sage- grouse and other sagebrush obligate species, which are dependent on this shrub-dominated ecosystem for food and shelter (Knick 1999). Wildfires Wildfires in the Great Basin are a subject of debate again as approximately 2.7 million Federal and non-Federal acres in the Great Basin burned during the 2007 fire season. Over the last 17 years, nearly 16.2 million Federal and non-Federal acres have burned in the Great Basin. Over 1.9 million acres of the total wildfire acres burned two or more times during this same period due, in large part, to increased fuel continuity as a result of the presence of annual grasses, including cheatgrass. (Whisenant 1990) Wildfires spread quickly across such landscapes. (Whisenant 1990) These figures do not include wildfires prior to 1990 so the acreage of reburned areas in the Great Basin is considerably larger. Fire suppression and rehabilitation costs, and private property losses could increase if the plant community changes projected for the Great Basin occur. Besides the increased cost to the American public, wildfire behavior could be more extreme, especially in areas where woody vegetation has increased fuel loads. Risks to fire fighters and the public may continue to rise as well. More severe and frequent wildfires will increase with the invasion of exotic annual plants, such as cheatgrass, and with increased frequency of extreme wet/dry conditions. Wet conditions result in the increased spread of certain exotic annual grasses that then serve as a continuous fuel for wildfires during subsequent dry periods. In turn, these wildfires could further increase weed expansion, soil erosion, and carbon loss. As the exotic annual grasses become more abundant, the potential for fire increases, resulting in a positive feedback loop. Increased wildfires in shrublands in the Great Basin and conversion to cheatgrass dominance has now been documented to cause large scale conversion of rangeland carbon sinks to carbon sources (Bradley et al. 2006). Disruptions to livestock operations on public lands could be more common and habitat important to wildlife and wild horses and burros may continue to decline. It is not known how climate change, more generally, will impact the distribution of state or federal listed noxious weed species that currently cause great ecological and economic harm within the Great Basin. Efforts to Address Environmental Threats and Climate Change in the Great Basin Planning The Great Basin Restoration Initiative (GBRI) has assisted in preparing some draft guidance to address potential effects of climate change in several Great Basin Land Use Plans. The Ely, Nevada, Resource Management Plan currently underway now includes a landscape approach to restoration which is closely tied to GBRI. GBRI promotes a strategy of maintaining intact native plant communities and strategically restoring degraded areas. This strategy is being used in other planning documents outside the Great Basin. Climate change is addressed in the “2006 Conservation Plan for Greater Sage-Grouse in Idaho (http://fishandgame.idaho.gov/cms/hunt/grouse/conserve_plan/)” as it was ranked as the ninth of 19 threats to sage-grouse and sage-grouse habitat in Idaho. Twenty conservation measures (ranging from public education to planning restoration projects) were developed to help local sage-grouse working groups address climate change as they develop conservation strategies and local projects. More emphasis on climate change will be incorporated into land use and sage-grouse plans in the future with additional agency and Departmental guidance and GBRI technical assistance. Science and Monitoring A key component of GBRI is the application of science and monitoring to improve our ability to maintain healthy landscapes and strategically restore degraded areas. Consideration of potential effects of climate change are incorporated into these restoration strategies since treatments applied today will have to be applicable in the future to meet resource and social needs. For example, re-establishment of sagebrush in areas burned by wildfires is a high restoration priority. Sagebrush is very sensitive to the local climatic conditions. Since sagebrush has an expected life span of 50-100 years, it is imperative that appropriate seed sources be selected for current seeding projects to maximize the potential that the sagebrush will adapt to survive in an altered climate in the future. One important strategy to increase the resiliency of Great Basin ecosystems to future disturbances and climate change is to either maintain or restore a diverse native plant community. Native plant diversity acts as an insurance policy against future changes by including a suite of species adapted to different environmental conditions. Loss of a few species, although not desirable, will not cause the system to crash. To improve the BLM’s ability to restore degraded rangelands now and into the future, GBRI has sponsored a regional science and development project to increase the availability of native plants for restoration. This program, “Great Basin Native Plant Selection and Increase Project” was initiated in 1999 as part of the BLM’s Native Plant Materials Development Initiative and has 17 state, federal, academic and seed industry cooperators today (http://www.fs.fed.us/rm/boise/research/shrub/greatbasin.shtml). Native seed have been collected from nearly 1,500 sites in the Great Basin providing the project cooperators with the ability to evaluate, select and augment production of native plant seed. Having such collections available for purchase in the future will provide managers with the needed plant materials to re- establish diverse native plant communities more resilient to the effects of a warmer climate with more erratic precipitation patterns. Reducing the size and extent of wildfires is another component of GBRI’s science program. GBRI is involved in the assessment of livestock grazing effects on fire spread and severity in the Murphy Complex fire. This wildfire burned nearly 650,000 acres in Idaho and Nevada this past summer. A team of fire and resource specialists is addressing this issue with rancher input, remote sensing, monitoring data, and fire models to determine how livestock grazing may be used in the future to reduce catastrophic wildfires. This is one of several projects in the Great Basin addressing livestock, fuels, and wildfires. Monitoring the potential impacts of climate change on the flora and fauna on the 75 million acres of public land in the Great Basin requires a landscape approach. GBRI is participating with the USGS on the development of a “Great Basin Integrated Landscape Monitoring Pilot Project” that will assist managers to predict effects of climate change on stressors such as invasive species and wildfires at a landscape scale (http://fresc.usgs.gov/research/StudyDetail.asp? Study_ID=566). GBRI has also implemented a regional pilot project under the BLM Assessment, Inventory, and Monitoring Initiative project in the heart of the Great Basin in the Owhyee Uplands (http://web.id.blm.gov/owyheeuplands/). This project has been designed in part to provide baseline data at the landscape level to monitor plant community changes over time. This will improve the BLM’s ability to detect plant community changes over time and to better distinguish climate change influences from other forms of disturbance. GBRI has partnered with The Nature Conservancy to co-fund a landscape ecologist to assist in this project. BLM/GBRI is represented on the Executive Committee for the development of the Intermountain Regional Ecological Observatory Network (IRON), the Great Basin regional application to the National Science Foundation's National Ecological Observatory Network (NEON) (http://www.neon-iron.org/). NEON seeks to establish a continent-wide distribution of environmental monitoring infrastructure, including eddy flux towers, sensors for air, soil, and surface water temperatures, windspeed and direction, precipitation, and barometric pressure, photosynthetically active radiation, plant transpiration, and atmospheric composition (CO, CO2, O3, others). Measuring biological response to climate and climatic variation, including the spread of invasive species and infectious diseases, is central to this program. The IRON application seeks to install the monitoring infrastructure on BLM land in the Utah West Desert. IRON asks how ecosystems and their components will respond to changes in natural and human-induced climate across spatial and temporal scales and what system attributes best predict sensitivity to climatic factors. BLM scientists are participating in the design of experiments specific to land management in the Great Basin. GBRI is representing the BLM in the development of the “Great Basin Research and Management Partnership” to improve communication and research to better meet manager needs across the Great Basin. Over 200 managers, scientists, non-government organizations and private citizens met in Reno, Nevada, in the winter of 2006 and identified climate change, invasive species, and wildfires as key challenges in the Great Basin where better linkages between scientists and managers would prove beneficial. GBRI is also an active participant in the development of the Great Basin Environmental Program, sponsored by University of Nevada Reno, The BLM is an active participant in other research that has or is producing data and analysis with application in adaptation to climate change. These efforts include the National Center for Ecological Analysis and Synthesis Nevada Conservation Area Design, the Joint Fire Science- Funded Sagebrush Steppe Treatment Evaluation Project and the USDA-funded Integrating Weed Control and Restoration for Great Basin Rangelands. Restoration Implementation Restoring native vegetation where conversions to exotic annual grasses or noxious weeds have occurred will provide greater plant community stability under an environment influenced by climate change. In addition, carbon sequestration will be enhanced in native communities compared to annual grass communities that reburn at frequent intervals (Bradley et al. 2006). Nearly 25 million acres of public lands in the Great Basin have some cheatgrass as a component of the community (BLM 2000). The Department of the Interior’s Healthy Lands Initiative (http://www.doi.gov/initiatives/healthylands.html) is providing support and funds to implement restoration projects at the landscape level with multiple partners. All of the projects implemented under this Initiative will promote the maintenance or restoration of healthy native plant communities with the increased ability to survive or adapt to anticipated changes in the environment in the future. Three of the six geographic areas receiving Healthy Lands Initiative funding are in the Great Basin which provides multiple opportunities to improve or maintain land health in this important landscape. The increased focus on native seeds and seeding equipment improvement supported by GBRI will improve success and efficiency in the Emergency Stabilization and rehabilitation (ES&R) program. ES&R seeding treatments after wildfires will not result in the restoration of fully functioning native plant communities, however these treatments will start the process toward site stabilization and provide future opportunities for restoration to native or desired plant communities if a restoration funding is available. GBRI will continue to serve as a focal point for the application of science and technology to successfully restore Great Basin rangelands. As the science and predictive ability of climate change models continues to evolve, GBRI will provide a basin-wide perspective on this issue to inform BLM managers of appropriate restoration strategies. Summary Based on studies by the U.S. Geological Survey and others, the Great Basin is experiencing climate change effects that are potentially expected to increase in the future and may increase impacts of invasive species and wildfires. Managers in the Great Basin are cognizant of some of these changes but the magnitude of the changes expected in the future probably exceed the capability of this fragile desert to adapt in full to the changes. However, the BLM has a long history of adapting to environmental variability, so mechanisms are in place to adjust management to accommodate for some of the projected changes. GBRI and the BLM will maintain a close watch on invasive species and climate change in the Great Basin and the science that U.S. Geological Survey and others provide. GBRI will continue to assist managers in the adaptation process by supporting the science and technology required to maintain or restore healthy plant communities. This concludes my testimony. I would be happy to answer any questions you may have. References Bradley, B., R.A. Houghton, J. Mustard, S.P. Hamburg. 2006. Invasive grass reduces aboveground carbon stocks in shrublands of the Western US. Global Change Biology, 12:1815- 1822. Bureau of Land Management: 2000, The Great Basin: healing the land. National Interagency Fire Center, Boise, ID. 36p. Dunham, J.B., M.M. Peacock, B.E. Rieman, R.E. Schroeter, and G.L. Vinyard. 1999. Local and Geographic Variability in the Distribution of Stream-Living Lahontan Cutthroat Trout. Trans. Am. Fish. Society; V 128: 875-889. Isaak, D. J. Buffington, C. Luce, J. McKean, B.E. Rieman, and R.F. Thurow. 2007. Impacts and Uncertainties of Climate Change on Idaho Streams and Fish Communities. Presentation made at the Idaho Chapter, American Fisheries Society annual meeting. February 23, 2007. Boise, ID. Jager, H.I.; W. Van Winkle; and B.D. Holcomb. 1999. Would Hydrologic Climate Changes in Sierra Nevada Streams Influence Trout Persistence? Trans. Am. Fish. Society; V 128: 222-240. Knick, S.T.: 1999, ‘Requiem for a sagebrush ecosystem?’ Northwest Sci. 73:53-57. Nielson, R.P., J.M. Lenihan, D. Bachelet, R.J. Drapek. 2005. Climate Change Implications for Sagebrush Ecosystems. Trans. of the North Am. Wildlife and Nat. Res. Conference. Pp 145- 159. Rieman, B.E. D. C. Lee, and R.F. Thurow. 1997. Distribution, Status, and Likely Future Trends of Bull Trout within the Columbia River and Klamath River Basins. Am. Jour. Fisheries Management; Vol. 17: 1111-1125. Smith, S.D., T.E. Huxman, S.F. Zitzer, T.N. Charlet, D.C. Housman, J.S. Coleman, L.K. Fenstermaker, J.R. Seemann and R.S.Nowak. 2000. Elevated CO2 increases productivity and invasive species success in an arid ecosystem. Nature, 408:79-80. Stein B.A., Kutner L.S. and Adams J.S.: 2000, Precious Heritage: The Status of Biodiversity in the United States. Oxford University Press, New York. 399 p. Whisenant, S. G.: 1990, ‘Changing fire frequencies on Idaho's Snake River Plains: ecological and management implications.’ In: McArthur, E., Durant; R., Evan M. Smith, Stanley D. Tueller, Paul T., (comps.) Proceedings - symposium on cheatgrass invasion, shrub die-off, and other aspects of shrub biology and management; 1989 April 5-7; Las Vegas, NV. Gen. Tech. Rep. INT-276. Ogden, UT: U.S. Department of Agriculture, Forest Service, Intermountain Research Station: 1-7. Ziska, L.H., J.B. Reeves III, B Blank. 2005. The impact of recent increases in atmospheric CO2 on biomass production and vegetative retention of cheatgrass (Bromus tectorum): implications for fire disturbance. Global Change Biology 11, 1325-1332. STUDY: VAST SAGEBRUSH ECOSYSTEMS A VICTIM OF CLIMATE CHANGE? 08-29-05 By David Stauth, 541-737-0787 ?SOURCES: Ronald Neilson, 541-750-7303?Dominique Bachelet, 360-570-2015 http://oregonstate.edu/dept/ncs/newsarch/2005/Aug05/sagebrush.htm CORVALLIS, Ore. - The sagebrush lands of the Great Basin, one of the largest ecosystems in the United States, may be reduced to a fraction of their current area due to ecological changes already under way and climate shifts that will hasten their demise, a new study suggests. This vast, semi-arid region, dominated by frost-tolerant sagebrush and native grasses, is already suffering impacts from invasive species, fire suppression and the encroachment of other woody vegetation. The future will also bring increases in temperature that may allow frost-sensitive species from the Southwest to move hundreds of miles north and further displace the sagebrush, scientists say. These findings were presented recently at a professional meeting and are being published in the Transactions of the North American Wildlife and Natural Resources Conference by researchers from Oregon State University and the U.S.D.A. Forest Service. The hottest climate scenario would reduce sagebrush to about 20 percent of its current area in the Great Basin, a fairly rapid change in hundreds of thousands of square miles of the American West. Increases in woody vegetation and fire are predicted. Only a few small areas of sagebrush in southern Wyoming, the northern edge of the Snake River plateau, and small areas of Washington, Oregon and Nevada are expected to survive and persist under all scenarios, researchers say. "Increases in temperature due to global warming will be the driving force in these changes, along with less-predictable changes in the summer rainfall regime," said Ronald Neilson, a professor of botany at OSU and ecologist with the Forest Service. "A major change will be that as the climate warms, woody vegetation now confined by cold temperatures to the Southwest may move into the higher plateaus of the Great Basin. "Given the flat nature of much of this terrain, once the woody vegetation gets up and over the 2,000-foot elevation, it will be like opening the floodgates," Neilson said. Changes in precipitation are most difficult to predict in future climate scenarios, said Neilson and Dominique Bachelet, an OSU associate professor of bioengineering. Earlier work by these researchers suggested both a decrease in frosts and increases in precipitation over much of the interior West, triggering a dramatic increase in wood expansion at the expense of sagebrush shrub land, and a corresponding increase in fire due to the increased fuel load. More problems with fire in the wild land-urban interface are also probable, the researchers said. The amount of fire suppression conducted by land managers is an unknown variable that will affect total vegetation growth, and could result in a dramatic increase of the overall biomass of these regions in future years, Bachelet said. "What's most certain is the rising temperature, which is going to allow a lot more oak, mesquite and invading grasses into new areas," Neilson said. "Precipitation is harder to predict and may be quite variable, due to inter-decadal climate patterns that appear to be getting even more volatile and intense. We could see some decade-long periods of drought during what should be a period of overall higher precipitation." There may actually be more plant and animal diversity under the new scenario than the sagebrush ecosystems of the past, the study indicated. And the increased amounts of vegetation in the Great Basin, inadvertently, might support a U.S. policy of increased carbon sequestration in ecosystems. But as huge areas of the American West face these changes in their ecology, some existing sagebrush ecosystem species may also go extinct. Seven different climate scenarios were considered in this study, and it's uncertain exactly which one will prevail. As models continue to get more refined they seem to be trending toward the hotter climate scenarios, Neilson said. And the rate of ecological change may be so rapid that the early winners will be invasive weeds that can travel easily and adapt to a wider range of conditions, he said. The existing sagebrush biome of the western U.S. is one of the two or three largest ecosystems in the nation, comparable to the Great Plains and the eastern deciduous forest. The system tends to be very hot in the summer and subject to recurring hard frosts in the winter - a climate to which hardy sagebrush with its deep roots is particularly suited. Sagebrush and the species associated with it - such as sage grouse, sage thrashers and pygmy rabbits - dominate large areas of Nevada, Oregon, Washington, Idaho, Utah, Wyoming, Montana and other western states. These ecosystems have already undergone intense changes since European settlement, with some estimates that intensive agriculture, grazing pressure and other impacts have reduced the sagebrush lands to less than half of their original size. "Aside from the findings of this study in particular, one thing I find most striking is the overarching impact of humans," Bachelet said. "We've brought fire suppression, air and water pollution, we've introduced competitive exotic species, and we are responsible for the incessant expansion of agricultural and urban areas. This has created huge changes for natural systems to adapt to, and may be the ultimate cause of mass extinctions." Public lands as carbon sinks July 29, 2008 — Brian Ertz http://wolves.wordpress.com/2008/07/29/public-land-use-global-warming/ When a lot of folk think about public lands and the value of these places to serve our efforts to curb global climate change they think development. They think of wind farms or solar arrays. If you think about it you can’t really blame them, that’s all they’ve had to think about - with the endless commercials put on by the big “renewable” industry (usually Big Oil patting itself on the back for diversifying), news reports, and politicians making every promise under the sun that the next shiny technology will save the day and let the public keep its wasteful habits. Unfortunately, this thinking doesn’t do a whole lot of good at reducing global warming gases - that’s because renewable energy technologies don’t replace fossil fuel power plants - thus far, they’re doing little more than to serve future increased demand for energy. It’s more cheap energy so people don’t have to think about how they use it. And the planning! Well, these huge developments on public lands aren’t any good for wildlife either - usually they go where not a lot else has, opening that up has meant that some of the last critical habitat for many species is coveted by some of the largest economic powerhouses. When you think about public lands and the value that these places have to serve our efforts to curb global climate change I’d like you to consider a new idea that is as old as dirt ~ passive restoration. Yes, I’m suggesting that part of the answer might be to remove our footprint on those places we can - and in doing so - let the land catch its breath. When everyone else is thinking of the new and shiny technology that promises to make life easy - you know, the direction that got us here in the first place - I’d ask you to consider thinking of healthy soils, vegetation communities, and bountiful wildlife - all the things you love about America’s public land. The cool thing about this is, promoting the things that you love about public lands in the West does reduce global warming gases - a lot. Consider once again ~ the living soil… Dirt: the least charismatic and most under-appreciated of all the diverse members of a healthy ecosystem. Earlier, I described how intact living soil crusts promote the best conditions that prevent weeds - a scourge which is right up there with global warming and livestock grazing as the most pervasive threats to biodiversity. Now I’d like you to think about that same principle - passive restoration - with regard to the soil and our atmosphere. Forests aren’t the only ecosystems that take carbon dioxide out of the air and sink it: Intact desert ecosystems act as carbon sinks - sequestering global warming carbon dioxide. More so than originally thought, desert ecosystems can take carbon dioxide out of the atmosphere and fix it in the vegetation and microbiotic soil crusts (Wohlfahrt 2008). In fact, deserts and semiarid landscapes can absorb more carbon dioxide than forests and grasslands. Wohlfahrt’s recent study suggesting living soil’s healing respiration in the Mojave Desert largely corroborates the carbon sequestration potential demonstrated in other studies completed with desert shrub in Baja California and in a semiarid riparian shrub land in Arizona. The more scientists study these dynamic relationships, the more we find that if we let it, native ecosystems on public lands have much to offer in the way of ecological services that mitigate and sequester carbon emissions that contribute to global climate change. Compaction of soils mitigates global warming gas sequestration potential - can actually spur emission of global warming gas But the ecosystem services that might be used to help mitigate global climate change don’t take well to abuse. A study out of Germany assessing the fluxes of methane (warms the atmosphere at 23 times the rate of CO2) and nitrous oxide (warms at 310 times the rate of CO2!) with forest soils found that compacted soils tend to emit nitrous oxide at up to 40 times the rate of un- compacted soils. Additionally, soils tend to absorb methane out of the atmosphere, but when compacted that same soil absorbs as little as 10% its un-compacted self and in the case of silty clay loam could even go from absorbing methane - to emitting it (Teepe et al. 2004). It seems that when folk talk about the toll of our “ecological” or “carbon” footprint - in both cases they’re being quite literal. These scientific revelations keep nicely in tune with what we’ve already known about the potential for planting trees - but the findings break wide open consideration for a diversity of new ideas about how we approach the “use” of public landscapes and ecosystems, including arid and semi-arid, and they ought be considered when academics, decision-makers, and I hope you, grapple with the difficult question of what to do to mitigate the consequences of climate change: Restore your public land. Land Use and Climate Change Of all the of reasons native ecosystems help to sequester global warming gases, I have yet to come across any indication that extractive industry and disturbing use does anything but negate that potential. And if you think about it, it makes sense. In the Mojave, it’s the smallest, most fragile members of the living community - microbiotic soil crusts - the ones most easily disturbed that draws warming gas into the soil. The vibrancy, health and diversity of ecosystems that give us clean water, clean air, and abundant wildlife are the very conditions that function efficiently and productively toward fixing carbon and other global warming gases. Unfortunately, many of our land use decisions up to this point degrade that vibrancy and simplify those systems - making them less efficient carbon sinks. Take for example a study out of China published in the Journal of Environmental Quality. The study looked at the terrestrial carbon storage of a grassland ecosystem that was grazed versus those excluded from grazing for three years, eight years, 20, 24, and 28 years. The findings were staggering - “The aboveground net primary productivity and soil C [carbon] and N [nitrogen] storage were the highest with 24-yr GE [grazing exclusion] and the lowest with free grazing.” Grazing exclusion for two decades increased the aboveground biomass and soil carbon content by 35.7% and “could facilitate significant C [carbon] and N [nitrogen] storage on decade scales in the context of mitigating global climate change” (Wu et al. 2008). Copyright: Ralph Maughan Grazing boundary. 24-mile Creek, ID Which side sequesters more carbon? http://www.panoramio.com/photo/12446823 http://www.panoramio.com/photos/original/12446823.jpg [NOTE: PLEASE REVIEW THIS PHOTO IN CONSIDERATION OF GRAZING EFFECTS IN THIS ANALYSIS]. That’s a substantial finding! Especially when you consider that over 300 million acres of Western public lands are leased to graze livestock. Hundreds of millions of acres of public land potentially used to sink carbon - to the benefit of the wildlife that we love. Land use studies like these rekindle many possibilities for decision-makers charged with addressing climate change. Technological innovation is only half of the picture - half of the solution. The very ideas conservationists have been advocating to promote restoration for wildlife species, ecosystems, wild places, clean water and air for decades similarly contributes to America’s potential to combat global climate change. Might land managers recognize the consequences that land uses such as grazing, logging, oil & gas and even centralized “renewable energy” developments inflict onto public lands that would otherwise mitigate climate change by sequestering carbon ? The science says they should. Could public land and wildlife managers begin to recognize carbon sequestration as a legitimate value, a legitimate “land use” to promote on public lands throughout the West ? Common sense suggests it’s the cheapest, least painful and perhaps most effective and efficient course to plot. Yes. Land managers allow ecosystem services to play out on their own with “uses” such as the Wildland Fire Use. We can do it with global warming too. Let’s get started. What do you think ? Posted in Climate change, public lands, public lands management. Tags: Passive Restoration. Hard Choices on Climate Can Wait for Next President, Aides Indicate By Juliet Eilperin?Washington Post Staff Writer?Wednesday, December 12, 2007; A24 http://www.washingtonpost.com/wp-dyn/content/story/2007/12/11/ST2007121102518.html BALI, Indonesia, Dec. 11 -- U.S. officials at U.N. climate negotiations here said Tuesday that they would not embrace any overall binding goals for cutting global greenhouse gas emissions before President Bush leaves office, essentially putting off specific U.S. commitments until a new administration assumes power in 2009, according to several participants. In closed-door meetings, senior U.S. climate negotiator Harlan L. Watson said the administration considers several aspects of a draft resolution circulated by U.N. officials unacceptable, according to an administration official and other negotiators. Watson specifically objected to language calling for a halt in the growth of worldwide emissions within 10 to 15 years, to be followed by measures that by 2050 would drive emissions down to less than half the 2000 levels. The administration also suggested eliminating language in the draft calling for "sufficient, predictable, additional and sustainable financial resources" to help poor nations adapt to climate change, on the grounds that it is vague. "We've been very pro-active, we've been very collaborative, very constructive," said James L. Connaughton, who chairs the White House Council on Environmental Quality and is in Bali this week to participate in the talks. "What we're looking for is a broad negotiating agenda in a road map so we can cover a range of topics the president articulated earlier this year" on climate change. Several environmental activists said that although the administration's position is somewhat more flexible now than it was two years ago -- when it essentially rejected the idea of conducting any formal dialogue on replacing the 1997 Kyoto Protocol on climate with a new binding agreement--its stance leaves all tough decisions on how to address global warming up to the next president. In addition, they warned that the approach U.S. officials are taking could further alienate rapidly industrializing nations such as China, India and Brazil, which are seeking financial incentives to cut their emissions. "The United States once again can't help itself from playing games, and it's a high-stakes game," said Kevin Knobloch, president of the advocacy group Union of Concerned Scientists, who was to meet with Connaughton along with other environmental leaders on Wednesday morning. "They're going to play this game to the bitter end." The U.S. position is expected to hold sway here not only because the United States plays such an important role on the world stage, but because negotiators are fashioning a consensus document that needs to be approved unanimously by the nearly 190 participating countries. Connaughton said the administration's opposition to specific targets, such as the U.N. draft's call for an emissions cut of between 25 and 40 percent by 2020, reflects the concerns of "many countries" that some nations are trying to force a specific outcome for the talks before they actually begin. "It's hard to wrap up a negotiation the day you start it," he said, adding that Bush plans to spend the next year working with leaders of other major economies to determine a long- term goal for cutting emissions worldwide. The United States, along with Russia and Japan, is hoping to substitute less specific language stating that, in light of this year's report by the U.N. Intergovernmental Panel on Climate Change, "an effective response to unequivocal scientific evidence . . . will require enhanced national efforts and joint action by all countries aimed at deeper global reductions of greenhouse gas emissions." Despite that endorsement of the IPCC, which this week received the Nobel Peace Prize along with former vice president Al Gore, administration officials also opposed a proposal to ask the scientists for an updated report before negotiators meet in 2009 to develop a new global climate pact. "That's a huge amount of work for the IPCC to do, and they've already done great work," Connaughton said. "We should declare the IPCC a success and move forward with putting together an aggressive" climate agreement. Hans Joachim Schellnhuber, the top science adviser to German Chancellor Angela Merkel and an IPCC contributor, said in an interview that he did not understand how the United States can praise the IPCC "and when it comes to something like this, block it." Schellnhuber, who is participating in the negotiations, added that if the administration succeeds in taking the specifics out of the Bali text, "it is just ignoring" the scientific evidence. "An agreement on nothing is not a good agreement," he said. While part of the debate here focused on how industrialized nations will address their carbon emissions over the next several years, negotiators were also exploring how to incorporate major emitters from the developing world and the world's most vulnerable nations in the next agreement. China, for instance, is asking industrialized countries to provide more money to ease the transfer of clean energy technology overseas, while poor nations whose deforestation is accelerating global warming are seeking financial compensation for protecting their remaining forests. While the United States endorses both of these goals in principle, it has balked at specifying how much money developed countries should contribute to such efforts. Blairo Borges Maggi, governor of the Brazilian state of Mato Grosso, said regions like his need "an insurance policy" to ensure that the 20 percent of Brazil's forests that are unprotected will remain standing. "It seems like it's a proposal that everyone likes in theory, but in practice, when it's time to put your hand in your pocket, nobody wants to," said Borges Maggi, shoving his hand in his pants pocket as if to pull out money. David Waskow, of the humanitarian group Oxfam America, said U.S. resistance to articulating how much money industrialized nations could provide to help poor nations adapt to a warming world is "in subtle ways, creating trouble for that global deal. . . . If this deal is going to come together, these concerns about equity have to be addressed." David Doniger, climate center policy director at the advocacy group Natural Resources Defense Council, said if the administration succeeds in deferring specifics about curbing emissions until early 2009, negotiators might still be able to forge an agreement that year to follow the Kyoto agreement, which expires in 2012, but it would be hard. "It can be done," he said. "But it's going to be a very busy year." Sen. John F. Kerry (D-Mass.), who came to the Bali talks for a day-and-a-half this week, said he believes that the administration wants "a document that keeps the process moving," but that delegates are looking for more concrete leadership from nations such as the United States and China. "There's a question mark of how long is it going to take the bigfoots to step forward and do what they need to do, or will that happen in 2009 with the right leader?" Kerry said. "You need to believe in this issue. You can't just do it on the side because it's an obligation that somebody throws at you. This has to become a crusade, a passion, a monumental undertaking." June 24-25 Interagency Workshop on Climate Change Impacts on Natural Resource Management in the Columbia Basin Centre on the Grove, Summit Auditorium, Boise, Idaho http://www.fws.gov/pacific/Climatechange/pdf/Boise_Executive_Summary_of_the_Workshop.pdf Overview – Executive Summary Purpose of Workshop: To provide resources and information to natural resource scientists and managers who work to conserve Columbia River Basin ecosystems. To engage scientists and managers in developing conservation strategies that anticipate and respond to a changing climate. Target Audience: Resource managers, planners, program leads, scientists, information & data specialists from Federal, State and Tribal agencies, and conservation groups. Foundational Presentations These presentations provided an overview of observed 20th century global warming, predictions for the 21st century and the associated observed and predicted effects of global warming on natural resources. We started with an overview of the 2007 reports from the Intergovernmental Panel on Climate Change. This was followed by more specific presentations on the Columbia River Basin from the University of Washington’s Climate Impacts Group: What drives the Basin’s climate? What is its normal climate variability? What has been the observed 20th century climate change, and what is the predicted climate change for the 21st century? The IPCC projects an increase in global average annual temperature of 3.2-7.2°F by the end of the 21st century (multiple emissions scenarios are presented and evaluated). This is substantially different than the past 12,000 years. During this period the earth’s average temperature has been relatively stable, ranging approximately +/-0.9°F. In the Pacific Northwest, the El Niño/Southern Oscillation http://cses.washington.edu/cig/pnwc/aboutenso.shtml and Pacific Decadal Oscillation http://cses.washington.edu/cig/pnwc/aboutpdo.shtml are important factors for the region’s climate due to their influence on atmospheric circulation over the North Pacific and North America. The University of Washington’s Climate Impacts Group presented information on observed 20th century changes in the Pacific Northwest including: • Average annual temperature increased 1.5°F between 1920 and 2003; • Decadal variability is the most important feature of precipitation during the 20th century, rather than climate change; • Snowpack declined at nearly all sites in the Pacific Northwest between 1950 and 2000; and • Timing of peak runoff has shifted to as much as 20 days earlier in much of the Pacific Northwest between 1948 and 2002. These findings require us to change our ways of thinking. We have always assumed that the past was a good guide to the future. Management for conservation, subsistence, and resource extraction will need to incorporate change as a fundamental assumption. Presenters provided information on effects to plants and animals, including a synthesis of the scientific literature on how species react to abrupt climate change. Species have different tolerances of rainfall, temperature, storm and drought frequency, and other features of climate that define their distribution. As warming continues and local climates change in complex ways, species historically found together may no longer co-occur and many are forecast by the IPCC to be threatened with extinction. There is evidence that some species’ ranges have already shifted poleward or toward higher elevations as temperatures rose in the 20th century and these trends are continuing. This includes warm-adapted species whose ranges are expanding, and cold-adapted species whose ranges are contracting. Species with narrow ranges of temperature tolerances and less mobile species will likely have greater difficulty adapting to climate change. Potential effects to fish and wildlife include: 1) Impacts on a species’ physiology; 2) Alteration of habitat characteristics; 3) Alteration of a species’ phenology or life cycle; and 4) “De-coupling” of wildlife relationships with key host or food plants, or predator/prey relationships. Species that cannot migrate and/or with slow dispersal rates will suffer the most. For example, plants, amphibians, mollusks, and coral reefs are more vulnerable to changing conditions that may affect their ability to survive, grow and reproduce. We ended this section of the workshop with a proposed project to assess the impact of global warming on species and ecosystems in the West. The species sensitivity analyses are a joint effort by the University of Washington, the U.S. Geologic Survey, and The Nature Conservancy. Module 1: Forestry and Rangeland Presentations These presentations provided an overview of climate change effects to forest and rangeland ecosystems in the Columbia River Basin. US Forest Service presentations emphasized that disturbances cause significant ecosystem changes in western forests and the two most prevalent natural disturbances have been fire and insects. Both of these disturbance factors have been exacerbated by observed 20th century global warming in the Columbia River Basin, and predictions for the 21st century include a trend towards more fire-prone and insect-prone scenarios. For Rangeland ecosystems, the USGS presentation focused on the importance of soil crusts and the overall threats posed by invasive species, changes in water availability, and changes in fire regimes. These threats will continue to be exacerbated by global warming. This section of the workshop also included a pragmatic example of a National Forest using existing climate change information for planning ‘no regrets’ adaptation strategies and activities. Module 2: Aquatic Ecosystems and Hydrology Presentations As emphasized in the foundational presentations, the University of Washington’s Climate Impacts Group finds that the region’s precipitation during the 20th century, and modeled into the future, is more influenced by the El Niño/Southern Oscillation http://cses.washington.edu/cig/pnwc/aboutenso.shtml and the Pacific Decadal Oscillation http://cses.washington.edu/cig/pnwc/aboutpdo.shtml rather than climate change. However, the region’s hydrology is changing significantly due to climate. This includes the decline of snowpack and glaciers, warmer winter temperatures resulting in more rain-on-snow flood or high- flow events, and earlier peak runoff times. These findings are supported by USGS stream gage data in Idaho. It was noted that additional water gauging stations are needed and that these stations do not include water temperature monitoring. Other presentations by USGS focused on the importance of groundwater which provides cool water to streams and other surface waters. The threats to groundwater resources were presented including sensitivity to climate related factors. Snowmelt is a major component of groundwater recharge (30-70% of snowmelt provides cold groundwater for later discharge). The decline of the region’s snowmelt is therefore an important climate-related threat to this resource. USGS also presented the effects of such changes on aquatic systems and organisms. This included a prospective analysis of bull trout, and a retrospective multi-species analysis. Bull trout are associated with cold-water habitat, but also bull trout distributions are tied to elevation and air temperature gradients at broad scales. Since air temperature changes do not affect water temperatures very much compared direct solar radiation on a body of water, the changing nature of the Basin’s hydrology and disturbances to riparian vegetation are likely to cause more effects to bull trout, but additional research is needed. This was followed with examples of species in different ecosystems that respond to climate change and provide records of those effects such as tree rings, mussel rings, clam rings and fish rings. This type of research proposes to use biological chronologies to reconstruct environmental histories of aquatic ecosystems. USGS presented a decision support system that evaluates climate regimes and water temperature changes in the Columbia River through the use of bioenergetic models. The example provided showed that the variation in climate and water temp during the period studied (1933-1996) increased vigor in non-native prey fish. As a result, predation on juvenile salmon has risen sharply and 27.5% of salmonids are found to be consumed due to the increased growth of predators. This is significant for salmonid populations: a 10% reduction in first year mortality is estimated by NOAA to increase population growth rates by 41.5%. The Nature Conservancy concluded this module with a presentation on how to develop adaptation strategies to mitigate climate change impacts to freshwater species and ecosystems. Climate change information should be considered during the four stages of a project: 1) project definition, scope and design; 2) strategy development (with an analysis of the ecosystem’s threats and viabilities) and the development of objectives and actions; 3) work plan development, implementation and monitoring; and 4) the use of results to adapt and improve. Module 3 General Session The Nature Conservancy provided a presentation on State and Federal efforts to reduce and mitigate carbon emissions. The key State effort is the Western Climate Initiative (WCI), a collaboration which was launched in February 2007 by the Governors of Arizona, California, New Mexico, Oregon and Washington to develop regional strategies to address climate change. Utah, British Columbia, Manitoba and Quebec have since joined and other U.S. and Mexican states and Canadian provinces have joined as observers. The WCI is identifying, evaluating and implementing collective and cooperative ways to reduce greenhouse gases in the region. The WCI regional greenhouse gas emission reduction goal is an aggregate reduction of 15% below 2005 levels by 2020. Congress has considered legislation that would reduce total U.S. emissions levels in 2050 to 62 to 66 percent below the 2005 emissions level to reverse the impacts of global climate change while simultaneously preserving robust economic growth. Legislation proposals include funding for natural resources adaptation to States, tribes and Federal agencies. The effort failed this year in the Senate and debate on such measures will likely continue in the next Congress. We concluded the workshop with a manager’s panel. The panel discussed ways to address key challenges such as: developing a natural resources conservation vision and actions for the Columbia Basin with climate change in mind; information gaps; how to keep agencies and decision makers abreast of climate change science; and further information sharing efforts. See: http://www.fws.gov/pacific/Climatechange/boiseworkshop.html this includes copies of presentations from the June 24-25 Interagency Workshop on Climate Change Impacts on Natural Resource Management in the Columbia Basin Centre on the Grove, Summit Auditorium, Boise, Idaho Additional Literature Anderson, D. C., K. T. Harper and R. C. Holmgren. 1982. Factors influencing development of cryptogamic soil crusts in Utah deserts. Journal of Range Management 35(2): 180-185. Baker, W. L. 2003. 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