Comment on FR Doc # 2011-27727

I offer the following comments regarding the draft economic analysis of the critical habitat designation for slickspot peppergrass. Paragraph 91 quotes the F&WS BO language which is quite clear that the BLM can make further changes in “…reducing livestock numbers, varying the timing or season of livestock grazing or trailing,….” In every individual grazing allotment BO that I have seen, including the Mud Springs and the Hot Springs allotments, the F&WS has given clear guidance that the BLM should explore opportunities to decrease spring grazing. From the beginning of the designation of slickspot peppergrass as a sensitive species to the present time, no correlation with populations or habitat has been found with regard to any season or type or intensity of livestock grazing. The service has concluded that livestock grazing is not a significant threat. While their purpose remains questionable, it is clear that the various conservation measures regarding grazing have been adequately implemented. The service has determined that fire and the spread of exotic annual grasses are the main threats. Despite a “host” of fire prevention and control measures implemented by BLM, it is clear that these conservation measures are ineffective and that slickspot habitat is continuing to burn at an unacceptable rate. If the F&WS or BLM cared to examine the fire frequency in slickspot habitat it appears that the frequency is increasing rapidly. As fire is the main force for spreading exotic annual grasses, one can reasonably expect that these plants are also continuing to expand at an unacceptable and likely increasing rate. However no BO discusses the need for new conservation measures to address these main threats as they continue to increase in severity, Decreasing spring grazing flies in the face of the majority of the information available about controlling the spread of exotic grasses and reducing fuel loads to reduce wild fire frequency. The fact that this in