United States Department of Agriculture

Forest Service

Intermountain Region

June 2014

Response to Public Comments Concerning the

Ely Westside Rangeland Project Draft Supplement to the

Final Environmental Impact Statement

Ely Ranger District Humboldt-Toiyabe National Forest

Lincoln, Nye, and White Pine Counties, Nevada

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual's income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice). USDA is an equal opportunity provider and employer.

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Table of Contents

Table of Contents

Commenters: ................................................................................................................................... 10

Aquatics ........................................................................................................................................... 11

WWP115 .................................................................................................................................. 11

Cultural Resources ............................................................................................................................ 11

WWP144 .................................................................................................................................. 11

WWP145 .................................................................................................................................. 11

Climate Change ................................................................................................................................ 11

WWP15..................................................................................................................................... 11

WWP16..................................................................................................................................... 11

WWP17..................................................................................................................................... 12

WWP68..................................................................................................................................... 12

WWP83..................................................................................................................................... 12

WWP84..................................................................................................................................... 12

WWP85 ..................................................................................................................................... 13

Forest Plan Guidance ........................................................................................................................ 13

WWP32..................................................................................................................................... 13

Monitoring and Supporting Data ...................................................................................................... 13

Sub Topic: Current/Historic Supporting Data .............................................................................. 13

WWP43..................................................................................................................................... 13

WWP49..................................................................................................................................... 14

WWP52..................................................................................................................................... 14

WWP94..................................................................................................................................... 14

WWP125 .................................................................................................................................. 15

WWP140 .................................................................................................................................. 15

Sub Topic: Monitoring Program .................................................................................................. 15

WWP35..................................................................................................................................... 15

WWP134 .................................................................................................................................. 15

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NEPA Process .................................................................................................................................... 16

Sub Topic: Existing Condition and Environmental Effects ............................................................ 16

WWP12..................................................................................................................................... 16

WWP13..................................................................................................................................... 16

WWP14..................................................................................................................................... 16

WWP36..................................................................................................................................... 16

WWP38..................................................................................................................................... 17

WWP39..................................................................................................................................... 17

WWP42..................................................................................................................................... 17

WWP48..................................................................................................................................... 17

WWP53..................................................................................................................................... 17

WWP54..................................................................................................................................... 18

WWP70..................................................................................................................................... 18

WWP73..................................................................................................................................... 18

WWP75..................................................................................................................................... 18

WWP120 .................................................................................................................................. 19

WWP126 .................................................................................................................................. 19

WWP127 .................................................................................................................................. 19

WWP132 .................................................................................................................................. 19

WWP133 .................................................................................................................................. 19

WWP135 .................................................................................................................................. 20

WWP136 .................................................................................................................................. 20

WWP138 .................................................................................................................................. 20

WWP143 .................................................................................................................................. 20

WWP162 .................................................................................................................................. 20

WWP163 .................................................................................................................................. 20

WWP164 .................................................................................................................................. 20

WWP165 .................................................................................................................................. 20

WWP166 .................................................................................................................................. 21

WWP192 .................................................................................................................................. 21

WWP194 .................................................................................................................................. 21

WWP198 .................................................................................................................................. 21

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WWP199 .................................................................................................................................. 21

Sub Topic: General ....................................................................................................................... 22

WWP1....................................................................................................................................... 22

WWP5....................................................................................................................................... 23

WWP9....................................................................................................................................... 23

WWP10..................................................................................................................................... 23

WWP20..................................................................................................................................... 23

WWP22..................................................................................................................................... 24

WWP26..................................................................................................................................... 24

WWP37..................................................................................................................................... 24

WWP45..................................................................................................................................... 24

WWP51..................................................................................................................................... 24

WWP57..................................................................................................................................... 25

WWP64..................................................................................................................................... 25

WWP65..................................................................................................................................... 25

WWP76..................................................................................................................................... 25

WWP79..................................................................................................................................... 26

WWP80..................................................................................................................................... 26

WWP100 .................................................................................................................................. 26

WWP101 .................................................................................................................................. 26

WWP104 .................................................................................................................................. 26

WWP105 .................................................................................................................................. 27

WWP106 .................................................................................................................................. 27

WWP108 .................................................................................................................................. 27

WWP113 .................................................................................................................................. 28

WWP150 .................................................................................................................................. 28

WWP154 .................................................................................................................................. 28

WWP156 .................................................................................................................................. 28

WWP157 .................................................................................................................................. 28

WWP161 .................................................................................................................................. 28

WWP178 .................................................................................................................................. 29

WWP196 .................................................................................................................................. 29

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WWP205 .................................................................................................................................. 29

WWP210 .................................................................................................................................. 29

WWP214 .................................................................................................................................. 30

Sub Topic: Proposed Action and Alternatives .............................................................................. 30

WWP3....................................................................................................................................... 30

WWP30..................................................................................................................................... 30

WWP31..................................................................................................................................... 31

WWP33..................................................................................................................................... 31

WWP34..................................................................................................................................... 31

WWP67..................................................................................................................................... 31

WWP78..................................................................................................................................... 32

WWP82..................................................................................................................................... 32

WWP86..................................................................................................................................... 32

WWP88..................................................................................................................................... 32

WWP89..................................................................................................................................... 33

WWP95..................................................................................................................................... 33

WWP103 .................................................................................................................................. 33

WWP107 .................................................................................................................................. 33

WWP110 .................................................................................................................................. 33

WWP116 .................................................................................................................................. 34

WWP124 .................................................................................................................................. 34

WWP128 .................................................................................................................................. 34

WWP130 .................................................................................................................................. 34

WWP142 .................................................................................................................................. 35

WWP147 .................................................................................................................................. 35

WWP148 .................................................................................................................................. 35

WWP149 .................................................................................................................................. 35

WWP155 .................................................................................................................................. 35

WWP158 .................................................................................................................................. 35

WWP159 .................................................................................................................................. 36

WWP160 .................................................................................................................................. 36

WWP182 .................................................................................................................................. 36

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WWP189 .................................................................................................................................. 36

WWP190 .................................................................................................................................. 37

WWP195 .................................................................................................................................. 37

WWP202 .................................................................................................................................. 37

Sub Topic: Range of Alternatives ................................................................................................. 37

WWP6....................................................................................................................................... 37

WWP62..................................................................................................................................... 38

WWP91..................................................................................................................................... 38

WWP170 .................................................................................................................................. 39

WWP208 .................................................................................................................................. 39

Rangeland Management .................................................................................................................. 46

Sub Topic: Adaptive Management ............................................................................................... 46

WWP7....................................................................................................................................... 46

WWP61..................................................................................................................................... 47

Sub Topic: Capability/Suitability .................................................................................................. 47

WWP8....................................................................................................................................... 47

WWP19..................................................................................................................................... 48

WWP40..................................................................................................................................... 48

WWP47..................................................................................................................................... 48

WWP69..................................................................................................................................... 48

WWP97..................................................................................................................................... 49

WWP98..................................................................................................................................... 49

WWP99..................................................................................................................................... 49

WWP167 .................................................................................................................................. 49

WWP168 .................................................................................................................................. 50

WWP169................................................................................................................................... 50

WWP171 .................................................................................................................................. 50

WWP172 .................................................................................................................................. 50

WWP173 .................................................................................................................................. 50

WWP174 .................................................................................................................................. 51

WWP175 .................................................................................................................................. 51

WWP179 .................................................................................................................................. 51

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Sub Topic: General ....................................................................................................................... 52

WWP2....................................................................................................................................... 52

WWP24..................................................................................................................................... 52

WWP27..................................................................................................................................... 52

WWP41..................................................................................................................................... 52

WWP74..................................................................................................................................... 53

WWP77..................................................................................................................................... 53

WWP90..................................................................................................................................... 53

WWP177 .................................................................................................................................. 54

WWP185 .................................................................................................................................. 54

WWP207 .................................................................................................................................. 54

Sub Topic: Grazing Strategies ....................................................................................................... 54

WWP25..................................................................................................................................... 54

WWP131 .................................................................................................................................. 54

Sub Topic: Livestock Management Activities ............................................................................... 55

WWP23..................................................................................................................................... 55

WWP211 .................................................................................................................................. 55

WWP213 .................................................................................................................................. 55

Sub Topic: Livestock Utilization ................................................................................................... 55

WWP212 .................................................................................................................................. 55

Sub Topic: Rangeland Condition .................................................................................................. 56

WWP63..................................................................................................................................... 56

WWP92..................................................................................................................................... 56

WWP118 .................................................................................................................................. 56

WWP153 .................................................................................................................................. 57

WWP176 .................................................................................................................................. 57

WWP193 .................................................................................................................................. 58

WWP209 .................................................................................................................................. 58

Socioeconomics ............................................................................................................................... 58

WWP66..................................................................................................................................... 58

WWP80..................................................................................................................................... 58

Soils .................................................................................................................................................. 59

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Sub Topic: General ....................................................................................................................... 59

WWP18..................................................................................................................................... 59

WWP 114 .................................................................................................................................. 59

WWP119 .................................................................................................................................. 59

WWP129 .................................................................................................................................. 59

Sub Topic: Microbiotic Crust ........................................................................................................ 59

WWP112 .................................................................................................................................. 59

Vegetation ....................................................................................................................................... 60

Sub Topic: Aspen .......................................................................................................................... 60

WWP50..................................................................................................................................... 60

Sub Topic: General ....................................................................................................................... 60

WWP21..................................................................................................................................... 60

WWP58..................................................................................................................................... 60

WWP60..................................................................................................................................... 61

WWP96..................................................................................................................................... 61

WWP146 .................................................................................................................................. 61

Sub Topic: Noxious/Invasive Species ........................................................................................... 62

WWP11..................................................................................................................................... 62

WWP44..................................................................................................................................... 62

WWP203 .................................................................................................................................. 62

Sub Topic: Riparian ...................................................................................................................... 62

WWP28..................................................................................................................................... 62

WWP29..................................................................................................................................... 63

WWP59..................................................................................................................................... 63

WWP183 .................................................................................................................................. 63

WWP184 .................................................................................................................................. 63

Sub Topic: Sagebrush .................................................................................................................. 64

WWP87..................................................................................................................................... 64

WWP93..................................................................................................................................... 64

Water Quality ................................................................................................................................... 64

WWP55..................................................................................................................................... 64

WWP56..................................................................................................................................... 64

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WWP102 .................................................................................................................................. 64

WWP111 .................................................................................................................................. 65

WWP117 .................................................................................................................................. 65

WWP121 .................................................................................................................................. 65

WWP122 .................................................................................................................................. 65

WWP123 .................................................................................................................................. 66

Wildlife ............................................................................................................................................. 66

Sub Topic: General ........................................................................................................................ 66

WWP72..................................................................................................................................... 66

WWP141 .................................................................................................................................. 66

WWP206 .................................................................................................................................. 67

Sub Topic: Goshawk ...................................................................................................................... 67

WWP181 .................................................................................................................................. 67

Sub Topic: Greater Sage-grouse ................................................................................................... 67

WWP4....................................................................................................................................... 67

WWP71..................................................................................................................................... 67

WWP109 .................................................................................................................................. 67

WWP137 .................................................................................................................................. 68

WWP139 .................................................................................................................................. 68

WWP180 .................................................................................................................................. 68

WWP186 .................................................................................................................................. 68

WWP187 .................................................................................................................................. 68

WWP188 .................................................................................................................................. 68

WWP191 .................................................................................................................................. 69

WWP197 .................................................................................................................................. 69

WWP200 .................................................................................................................................. 69

WWP201 .................................................................................................................................. 70

WWP204 .................................................................................................................................. 70

Sub Topic: Pygmy Rabbit............................................................................................................... 70

WWP46..................................................................................................................................... 70

WWP151 .................................................................................................................................. 70

WWP152 .................................................................................................................................. 71

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References ....................................................................................................................................... 71

Commenters: WWP – Katie Fite, Biodiversity Director, Western Watersheds Project

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Aquatics WWP115 The Forest appears to have avoided collecting critical aquatic habitat sediment, cobble embeddedness, turbidity and other information that would inform understanding of sediment problems in many of the Forest springs and streams in many of the allotments where waters are in poor condition and trampling impacts promote soil erosion and sedimentation.

Forest Response: All available information has been summarized in the 2013 Draft Supplement to the Final Environmental Impact Statement (2013 Draft Supplement). The underlying studies are available in the project record.

Cultural Resources WWP144 We are very concerned that the Forest has not considered much better protections for cultural sites. Many cultural sites are associated with springs and seeps, scenic high ridges, rock alignments, etc. There is no analysis of how livestock are disturbing cultural sites, breaking and displacing artifacts, moving and disturbing rock blinds, promoting erosion that exposes artifacts and sites to looting, or that destroys scientific values.

Forest Response: Alternative 1 contains a design feature relating to cultural resources and the Cultural Resources section in chapter 3 of the 2013 Draft Supplement analyzes the effects of grazing on cultural resources in the project area.

WWP145 What type of surveys have been conducted, and where? What percent of the landscape?

Forest Response: The Cultural Resources section in chapter 3 of the 2013 Draft Supplement provides information on the cultural resource surveys that have been conducted on the Ely Westside Rangeland project area.

Climate Change WWP15 Chronic livestock disturbance here has caused and continues to cause desertification. This represents local climate change and feeds into the global warming cycle

Forest Response: The levels of use and anticipated impacts under the alternatives are discussed in the DEIS. Historic land degradation is also acknowledged as are the improving conditions in the project area since that degradation. The 2013 Draft Supplement discusses climate change on page 23. I nformation from the EPA on the effects of climate change in Nevada is included in that section of the 2013 Draft Supplement.

WWP16 [T]he Forest … ignores…climate change concerns.

Forest Response: The rationale for the level of analysis afforded to “climate change” is provided on page 23 of the 2013 Draft Supplement. Additional information on climate change is included in the document as appropriate. For example, see page 77 (soils) and page 183 (vegetation) in the 2013 Draft Supplement.

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WWP17 Forest lands have great importance in sequestering carbon, and can provide high-quality vegetation and soils, which lead to high rates of carbon sequestration. What is the quality of the vegetation, microbiotic crust and soils? Where are high quality sites present on the Forest? Where are lands degraded, and why? Where is there risk of further losses? What effects will further losses have? What is a high rate of carbon sequestration?

Forest Response: The Forest uses the best available science to analyze resource effects. High quality vegetation and soils are capable of maintaining ecological conditions on a site to meet the needs of a variety of user areas including the storage of carbon. Current conditions are discussed in the 2013 Draft Supplement and detailed analyses are part of the project record. The rate or amount of carbon captured/stored is highly variable depending on local conditions. Sequestered carbons become the basis of plant biomass and will linger in the ecosystem before being recycled back into the atmosphere.

WWP68 What is the global warming “cost” of the ranching activities here, under all alternatives? Please provide detailed analysis of methane and other global warming gases produced, including gases from fossil fuels burned in association with the livestock operation and agency oversight and attempted mitigation of grazing disturbance impacts. Please provide an estimate of the monetary costs/value of the carbon/greenhouse gas and other global warming contributions from these livestock operations – produced or resulting from these operations. To what degree are lands desertified (thus hotter, drier, less productive), and what is the cost of the global warming effects of these depauperate conditions?

Forest Response: While it is possible to estimate the amount of greenhouse gases that would be produced by the proposed activities, at this time it is not possible to meaningfully link individual project actions to quantitative effects on climatic patterns. Although there are no regulatory limits or levels set for methane production or vehicle emissions in the project area at this time, the EPA has established a reporting requirement for facilities that release more than 25,000 metric tons of carbon dioxide. The authorized livestock would produce the equivalent of 671 metric tons of carbon dioxide while in the project area. The rationale for the level of analysis afforded to “climate change” is provided on page 23 of the Draft Supplement. Additional information on climate change is included in the document as appropriate. For example, see page 77 (soils) and page 183 (vegetation) in the 2013 Draft Supplement.

WWP83 The EIS largely ignores any analysis of climate change effects, and how livestock grazing disturbance exacerbates climate change effects, as well as contributes to global warming

Forest Response: Despite the uncertainty associated with any attempt to predict the ecological interactions and trends at a local or site-specific scale, the 2013 Draft Supplement analyzes the effects of climate change in several places. The Soils section in chapter 3 of the 2013 Draft Supplement (page 77) acknowledges that grazing lands are important in sequestering carbon and mitigating the greenhouse effect and other aspects of global climate change. Productive, sustainable grazing lands provide high-quality vegetation and soils, which lead to high rates of carbon sequestration and low levels of carbon dioxide (CO2) emissions. The role that climate change could play in the dynamics of the upland vegetation systems is discussed on page 183.

WWP84 Forest fails to weave any consideration of this into Capability and Suitability analyses.

Forest Response: Capability determinations serve to determine a Forest’s estimated acreage capable of producing forage. Rangeland capability is not a decision to graze. Additional

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information on capability has been provided in response to comment WWP8. A suitability analysis identifies areas in the land base where grazing is appropriate in the context of other land management considerations. Suitability was addressed at the Forest scale during the development of the current Forest Plan. For this project, suitability is further addressed under Alternative 1 (Proposed Action) through the application of a tiered set of proper use criteria (for this project, utilization) based on the area’s ecological condition. Rather than framing the suitability analysis as a decision to graze or not to graze, Alternative 1 (Proposed Action) goes one step further. If the decision is to graze, Alternative 1 (Proposed Action) looks at the appropriate level of utilization based on the degree of suitability. Many factors may make an area that is suitable for grazing more or less suitable. Alternative 1 (Proposed Action) provides for the ongoing assessment of suitability based on desired conditions for other resources, and for additional action to address newly identified suitability issues.

One of the best ways to address global climate change is to maintain the project area in, or to improve it to, functioning ecological condition. Alternative 1 (Proposed Action) bases management decisions on determinations of the ecological conditions in the project area in a way that is designed to achieve functioning ecological conditions across the project area.

WWP85 Project-scale effects will not make individual contributions to greenhouse gas emissions that are significant enough to measure”. But the effects are measurable – it is just that the Forest chooses to ignore use and consideration of science.

Forest Response: The general discussion on climate change in the 2013 Draft Supplement is on page 23. The document does not claim that project-scale greenhouse gas emissions are not measurable. In fact, the 2013 Draft Supplement (on page 23) discloses the projected amount of methane, and its carbon dioxide equivalent, that the livestock would produce while in the project area.

Forest Plan Guidance WWP32 Now in the EIS not only does the Forest try to get rid of Amendment 2 without ever having implemented many of the potential actions the Amendment and the Forest Plan allow, the Forest never even considers critical stream and springbrook bank trampling protections under No Action or the Proposed Action.

Forest Response: Amendment 2 would still apply; utilization in the riparian areas would still be managed consistent with those standards. See response to WWP31 for additional information on within season triggers. Streambank disturbance was identified as proper use criteria for this project. See page 29 of the 2013 Draft Supplement.

Monitoring and Supporting Data

Sub Topic: Current/Historic Supporting Data WWP43 The Forest’s cherry-picked and limited upland data sites, illustrate this. Surveys to date seek out more “pure” or “ideal” communities to assess, and sites chosen are NOT random, and are typically distant from heavily to moderately disturbed areas.

Forest Response: Monitoring is done in more “pure” communities so the data from monitoring

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can be meaningfully compared against what should be in a more “pure” community. Transitional areas between two vegetation communities will have a more random combination of attribute variables than a pure community, making data collected from these areas difficult to interpret.

All available information was used in identifying the current ecological conditions for the uplands and other vegetative communities within the project area. The analysis is summarized in the Vegetation section in chapter 3 of the 2013 Draft Supplement on pages 122 through 146 and additional detail is included in the Vegetation Specialist Report, which is found in the project record. Under Alternative 1 (Proposed Action), utilization limits and within season triggers would be set based on the ecological condition of the various vegetation groups in the allotment.

WWP49 Agencies often purposefully ignore “mixed” communities especially if they are weedy. Agencies seek out the most “pure” better condition community types to monitor. This biases monitoring, and it is not systematic and statistically valid as a representation of the condition of the landscape. “Pure” communities are commonly less impacted by livestock. So focusing monitoring on these areas will not represent the areas often most suffering from livestock disturbance. This also overlooks the fact that communities are dynamic over time, and successional processes may be occurring. It may also overlook the most seriously degraded communities.

Forest Response: Two important factors are involved in choosing a monitoring site for livestock grazing: 1) the site needs to be representative of the grazing use in the area, and 2) the site needs to be able to be meaningfully measured and evaluated. Monitoring sites are chosen by identifying key areas within the allotment. Appendix E in the 2011 Final Environmental Impact Statement (2011 FEIS) includes the process that will be used to select these key areas. It is important to choose sites that are not in transitional areas between one habitat group and another. Choosing a site in a transitional area can invalidate the conclusions that are based on the data collected because the attribute values vary between habitat groups. A transitional area could have attribute values from either of the habitat groups, where a “pure” habitat group can be measured and evaluated solely against its attribute values.

WWP52 From the info that has been collected, it appears that sites in uplands that are distant from water and freer of weeds are the sites that were examined. Please provide detailed information and analysis of how any upland sites were chosen.

Forest Response: Existing data sets were used, including recently collected data. Upland study sites were located in a variety of ways. Mainly, sites were selected based on the ‘key area’ concept described appendix E of the 2011 FEIS. Once an area is selected, transects may be randomly located in the key area by a variety of methods. Distance to water would vary based on the specific site. To determine how many random sites would be necessary to be “statistically valid” would depend on the parameter and population being estimated, level of error, existing variability, and sampling design.

WWP94 Please provide full and detailed data and analysis for the past 20 years of all riparian upland monitoring data, and mapping and other info and analysis of locations where it was collected. What systematic and scientific methodology was used to determine monitoring sites?

Forest Response: The monitoring and mapping data used are analyzed in the Vegetation Specialist Report. The 2013 Draft Supplement offers a summary of this information. A variety of methods was used based on the type of monitoring. The Vegetation Specialist Report includes the list of methods and associated protocols for each type of data set. Data sets are included from the past 20 years. The location of study sites is also included in maps 14 and 15 on pages110-111

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of the 2013 Draft Supplement. Additional maps identifying the location of the study sites have been added to Appendix G of the 2014 Final Supplement. Specific information from the studies is included in the section on Existing Condition By Allotment (pages 122-146).

WWP125 ALL of these factors must be carefully assessed in a revised EIS, and they have not been. Also these elements (below) must be examined in the Range using the best available science and current inventories.

Forest Response: While some of the information included in this list would be desirable for the analysis of the Ely Westside Rangeland Project, it is not required to complete the analysis and make a decision on this project. There is always more information that could be collected and there are always more studies that could be done. This project uses the best available information and current science to describe the existing conditions in the project area and to predict how the project area will respond to the grazing activities under the two action alternatives.

WWP140 It appears that much of the basis of the Forest’s very limited soils analysis is the same old extremely limited plots. The Forest ignores nearly all springs and seeps, intermittent and ephemeral drainages, and systematic study of the vast upland areas across the allotment.

Forest Response: The best available information and scientific literature were used in the preparation of the Soils section in chapter 3 of the 2013 Draft Supplement. While additional data and especially more recent data are always desirable, the available information and scientific literature provide a sufficient basis to analyze the effects of livestock grazing in the project area.

Sub Topic: Monitoring Program WWP35 If the Forest is going to adopt such a risky scheme, then the EIS that does so must provide a current systematic baseline ecological survey across all uplands and watersheds, and the Forest must include an Assessments of the risks of continued cheatgrass and other weed invasions and losses of sage-grouse and other sensitive species habitat based on comprehensive ecological data to serve as a baseline.

Forest Response: The best available information on the project area was used in the preparation of this analysis. The quality and quantity of this information is sufficient to support the analysis of this project. Conclusions that can be drawn from this information are included in the 2013 Draft Supplement. This information and the specialist reports that analyzed it are included in the project record.

The risk of continued cheatgrass and other weed invasions is assessed in the Vegetation section in chapter 3 of the 2013 Draft Supplement. The risk of loss of sage-grouse and other sensitive species habitat is assessed in the Wildlife section in chapter 3 of the 2013 Draft Supplement.

WWP134 The EIS must provide adequate current data from 2011 or at least a recent time period – to understand the baseline and then provide a reasoned analysis of the degree of change that would occur. This is also necessary to conduct an informed analysis of the No Grazing or any of an expanded range of Grazing alternatives.

Forest Response: The best available information on the project area was used in the preparation of this analysis. The quality and quantity of this information is sufficient to support the analysis of this project. Conclusions that can be drawn from this information are included in the 2013

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Draft Supplement. This information and the specialist reports that analyzed it are included in the project record.

NEPA Process

Sub Topic: Existing Condition and Environmental Effects WWP12 There is no integration of grazing info such as the current scientific literature on trampling associated with the overstocking of the permitted AUMs fostering exotic species through damage to microbiotic crusts; causing shifts in species composition over time; disrupting watershed processes or many other factors.

Forest Response: The 2013 Draft Supplement (page 73) contains information on microbiotic crusts and their value in controlling annual weeds. Page 112 of the 2013 Draft Supplement discusses how historic heavy grazing has converted many meadows to other species, such as shallow-rooted annual and perennial grasses, tap-rooted forbs, and shrubs. The Water Quality section of the 2013 Draft Supplement (pages 96-102) discloses the potential effects of livestock grazing on water quality and quantity.

WWP13 EIS is based on a simplistic fairy tale world view of grazing effects --- i.e. that 40% use, close to the old “Take half, leave half”, has been shown to be a resounding failure as weed invasion sweeps the sagebrush biome and portions of the pinyon-juniper and mountain mahogany communities. Native species habitats are further altered and destroyed, ecosystems unravel, and sensitive species face reduced viability and imperilment.

Forest Response: There is a significant body of scientific literature that supports the contention that if a habitat group is in functioning condition it can tolerate up to 50 percent utilization and still maintain its vigor, habitat values, and resiliency to invasion from weeds. These works are cited in the 2013 Draft Supplement, as appropriate, and are addressed in additional detail in an annotated bibliography in the project record.

WWP14 The Forest must start this process over (see discussion of Purpose and Need), and base any analysis here on a broad scientific integration and honest analysis of the effects of grazing and trampling on shrubsteppe and other native ecosystems in the arid West

Forest Response: Alternative 1 (Proposed Action) proposes to manage the lands in the project area based on their ecological condition. The ecological condition depends on more than just the area’s ability to produce forage every year. Many other factors were considered when the ecological conditions described in the 2013 Draft Supplement were determined. The current ecological conditions identified in the 2013 Draft Supplement are the product of a broad scientific integration of the various resources in the project area. The effects of grazing and trampling are disclosed, supported by numerous citations to scientific literature, and discussed throughout the 2013 Draft Supplement. For examples, see pages 76-78 (regarding soils), pages 95 (regarding water quality and streambanks), and page 149-151 (vegetation in meadow and stream groups).

WWP36 The Forest (in its greatly inadequate economics analysis and throughout the EIS), bases it no action alternative, “baseline” condition understanding and analyses on the bloated “permitted” stocking rates. These include a large number (never revealed) of AUMs that are not used on a regular basis.

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Forest Response: Permitted numbers were used because these are the numbers used in calculating a permittees fees for use of the allotment, and these numbers are more accurately tracked. Permitted numbers represent the best available information on this matter.

WWP38 This can only be viewed as an effort to artificially prop up the re-sale value of a grazing permit by through continuing to ignore that violation of standards, depletion, desertification, drought, non- compliance and other actions all have resulted in far fewer livestock being grazed than shown on paper under “permitted” AUMs.

Forest Response: As noted above in response to WWP36, the use of permitted numbers could also be viewed as an effort to use the best available information in the preparation of the 2013 Draft Supplement.

WWP39 This and other “nuts and bolts” information on annual monitoring results and how grazing has actually been carried out in the District in recent decades up to the present is essential to understand the number of AUMs grazed/stocking rate, how long cattle are present and where, etc - and other cow basics that have caused the levels of degradation - and few areas of lead to the areas of claimed improvement on the Forest must be provided and analyzed.

Forest Response: Information on current grazing management is found on pages 47 through 52 of the 2013 Draft Supplement, including the permitted number of livestock by allotment, current season of use, and current management system. Table 12 of the 2013 Draft Supplement does not list information on the temporary grazing permit on the Troy Mountain Allotment because under Alternative 2 (Current Management) the Troy Mountain Allotment would remain closed and no temporary permit would be authorized on it. However, a summary of the annual operating instructions for 2008, 2009, and 2010 for all of the allotments in the project area, including the Troy Mountain Allotment, were included as appendix C to the 2011 FEIS. These summaries provide information on livestock numbers, head months, season of use, grazing systems, etc.

WWP42 Another part of the grazing mechanics that is overlooked is the effects of seasons of use, turnout times, etc. on important environmental values and MIS, sensitive species, Wilderness recreation with hot season use conflicting with visitor use and enjoyment, etc. Effects range from disturbing nesting birds in late spring/early summer to concentrating use on a handful of perennial stream segments in late summer. How do AOIs over the past 20 years inform understanding of adverse effects on/conflicts with - sensitive species, ecological conditions, population losses or viability?

Forest Response: The effects of livestock grazing on MIS, sensitive species, and wilderness recreation are discussed in the Wildlife and Fish (pages 189 through 288) and Wilderness (pages 305 through 326) sections in chapter 3 of the 2013 Draft Supplement.

WWP48 Vegetation treatments also represent habitat degradation, alteration ad loss. You have failed to assess this across the Project Area.

Forest Response: Vegetation treatments were analyzed as discussed in appendix H, page D-16 to H-17 of the 2013 Draft Supplement. The cumulative effect of these treatments is considered by resource, as appropriate, in chapter 3 of the 2013 Draft Supplement.

WWP53 There is no analysis of the profligate burning, disking, railing, herbiciding, etc. and other disturbances that may have caused conditions–despite an abundance of info even in the range literature on the scale of past grazing and other activities including burning of native vegetation to

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promote forage and in association with settlement activities.

Forest Response: This is information is located throughout the cumulative effects for this document. Vegetation treatments, such as prescribed fire, mechanical treatments (mastication, mowing, chipping, whole tree removal, cut/leave and fire wood removal), would continue to occur in the project area and on adjoining BLM. These projects may have short-term adverse effects on the quality of habitat, composition of vegetative communities, and a short-term increase to bare ground. These adverse impacts generally only last for 2-3 years or less. Over the long term, these projects should result in an improvement to the quality of habitat, by maintaining vegetation communities, which in turn would increase the quality of the habitat. Also the reduced fuel loading would help prevent a wildfire from removing larger acres of habitat, and the sagebrush habitat would be maintained by the reduction in the expanding pinyon and junipers.

WWP54 Info is not provided on the time of year and timing of grazing in association with comparative info in the EIS.

Forest Response: The season of grazing for the allotments for 2008, 2009, and 2010 are included in appendix C of the 2011 FEIS.

WWP70 We ask that you carefully review (and include in all analyses of indirect, synergistic and cumulative effects of grazing here), and to understand cumulative effects of these operations and degraded conditions across the landscape, the Forest must the full range of information on how BLM is managing public lands, waters and habitats for native biota.

Forest Response: How BLM chooses to manage its grazing allotments is outside the scope of this project. The environmental effects of livestock grazing on the watersheds and habitats in the project area are discussed in chapter 3 of the 2013 DEIS. A cumulative effects analysis is required by NEPA and is a part of this EIS.

WWP73 We also stress that spring developments, leaking pipelines, stock ponds and other livestock water developments in the landscape (BLM, Forest, private) significantly increase the chances of West Nile virus.

Forest Response: Data indicates that troughs do provide incubation habitat when water is stagnate. According to the CDC website (http://www.cdc.gov/westnile/index.html), they pose no more risk than any of the other water capturing devices they list such as buckets, wheel barrows, gutters on a house, used tires, and other items capable of holding water. There have been 268 cases of West Nile in Nevada since 1999, 6 of which were fatal. Of those cases, most were documented in Clark or Churchill County; other affected counties included Washoe, Humboldt, Douglas, Nye, and Elko. There has been a significant decline in the documented cases since 2006, with 2 - 16 occurring annually from 2007 to 2013.

WWP75 Please see CEQ Sheridan (1981), Dregne 1986, Steinfeld et al. 2006, and fully integrate this information into any economic claims you make and into all analyses. Please also consider all ecological effects – including no important and sensitive species – of desertification and global warming/climate change processes on the landscape.

Forest Response: The Forest is not claiming that it is examining economic factors. Rather, the Forest is acknowledging that grazing on National Forest System lands contributes an economic value to the permittees. The ecological effects – including on important and sensitive species – of desertification, as described in response to comment WWP13, and global warming/climate

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change processes are considered throughout chapter 3 of the 2013 Draft Supplement.

WWP120 The Forest analysis is not based on shrubsteppe systems – which are very intolerant of grazing disturbance, and that evolved without large herds of hoofed animals. ALL components – the microbiotic crusts, and the bunchgrasses, are damaged by domestic livestock. Cheatgrass and other flammable weeds thrive in livestock disturbed sites and in association with livestock wastes.

Forest Response: The vegetation analysis of the project area uses the most updated GIS vegetation information available to the Forest. Analysis of soils, vegetation, and other resource areas are included in the document, and “proper use criteria” were developed to maintain or improve them.

WWP126 There is no real analysis of the degree of differences/changes in environmental effects between alternatives.

Forest Response: The effects of the alternatives on the resources in the project area are disclosed in chapter 3 of the 2013 Draft Supplement. Table 14 in the 2013 Draft Supplement summarizes the differences between the alternatives. The description of the effects is not always based on quantifiable data from the project area which demonstrated those effects. In many cases, only qualitative differences can be stated. Many of these statements are based on scientific literature that describes how the various habitat groups will respond to the grazing activities that would be allowed under the alternatives. As noted above, the best available information and current science were used to predict the effects of the alternatives.

WWP127 [T]hat is why the EIS provides no quantitative or firm descriptors for alternatives effects/outcomes on sediment/turbidity, water temperature, dissolved oxygen, nutrients, ground cover, compaction, erosion, bank stability, fisheries populations, sage grouse nesting habitat, sage grouse brood rearing habitat, riparian- percent bare ground, aspen regeneration, upland veg composition, upland forest- bare ground, noxious weeds

Forest Response: In general, the 2013 Draft Supplement provides a qualitative comparison of the effects of the alternatives. A summary of the comparison of effects is included in table 16 of the 2013 Draft Supplement with details provided in Chapter 3.

WWP132 The Forest must carefully identify and specify the degree and magnitude of change that will occur.

Forest Response: The expected outcomes of the alternatives are discussed in detail in chapter 3 of the 2013 Draft Supplement. These outcomes are summarized in chapter 2 in table 16 of the 2013 Draft Supplement.

WWP133 What if an allotment has not been grazed, or is being grazed at a very low level – how will stocking at skyhigh “permitted” levels affect recovery rates under the proposed action?

Forest Response: The analysis in the 2013 Draft Supplement is based on the existing condition and the effects of grazing vegetation in the project area at varying levels of utilization. Even if stocking rates were increased as the comment speculates, the utilization levels identified in both the action alternatives would remain the same. The comment implies that if the stocking rate is increased, higher levels of utilization would be allowed. This is not the case.

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WWP135 It is ridiculous to compare only application of the Standards and then claim under No Grazing “no grazing” would occur. That is not a valid or reasoned analysis of effects.

Forest Response: It is unclear what your comment is that is directed at in the 2013 Draft Supplement. The summary of effects included in the 2013 Draft Supplement in table 16 contains more information than your comments suggest. Additional information is included in the discussions on the No Grazing Alternative in chapter 3 of the 2013 Draft Supplement.

WWP136 The sage grouse info is superficial. Large areas are claimed to be Capable without detailed analysis of all of the site attributes, or consideration of the sagebrush eradication project effects. EIS at 186-187 mentions five leks known in the White Pine Range, but fails to provide crucial data on numbers and trends, and detailed habitat conditions as well as livestock conflicts.

Forest Response: The effects of the alternatives on greater sage grouse are discussed in chapter 3 in the Wildlife section of the 2013 Draft Supplement. Sage grouse population numbers and trend are discussed on page 207 of the 2013 Draft Supplement.

WWP138 Under its Proposed Action the Forest claims habitats would move towards desired conditions. There is no guarantee that necessary habitat conditions would be attained.

Forest Response: These conclusions are based upon a review of the best available science. The 2013 Draft Supplement explains this approach in chapter 2 under the discussion of proper use criteria in the description of Alternative 1 (Proposed Action). An annotated bibliography of scientific literature that was reviewed has been compiled and is available in the project record.

WWP143 Please provide a detailed pasture-by-pasture look at “current ecological conditions”.

Forest Response: Current ecological conditions are summarized allotment-by-allotment in table 7 of the 2013 Draft Supplement. Additional detail on the ecological condition determinations is included in Vegetation section in chapter 3 of the 2013 Draft Supplement.

WWP162 The EIS fails to examine many irreversible commitments.

Forest Response: A section on irreversible commitments is included along with each resource analyzed in chapter 3 of the 2013 Draft Supplement.

WWP163 Please provide detailed discussion and analysis of water rights filings and issues here, and how this might affect local and regional populations of ESA and sensitive species, recreational uses, etc.

Forest Response: On page H-8 of appendix H, the 2013 Draft Supplement notes there are no known plans or proposals for future water diversions in the project area.

WWP164 Please provide a detailed analysis of how RS 2477 filings and claims and actions taken to keep roads open may adversely affect populations of sensitive species, as well as wild lands recreational uses.

Forest Response: The analysis in the 2013 Draft Supplement considers the impacts of existing travel routes regardless of their status.

WWP165

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Please analyze the impacts to sage-grouse populations shared with the Forest of foreseeable large- new powerlines and energy and other developments affect local and regional populations of sage-grouse and other wildlife?

Forest Response: Appendix H, Other Actions Contributing to Cumulative Effects, to the 2013 Draft Supplement includes information on the Southwestern Intertie Project (SWIP), which passes to the east of the White Pine Range on lands managed by BLM. The cumulative effects discussion on sage grouse in chapter 3 of the 2013 Draft Supplement also includes information on SWIP.

WWP166 How does mining, oil and gas, geothermal or other exploration and development impact watersheds and sensitive and rare species?

Forest Response: See pages H-8 and H-9 of appendix H of the 2013 Draft Supplement for a description of past, present, and reasonable foreseeable mineral explorations in or near the project area. Where appropriate, the effects from these mineral projects are considered along with the direct and indirect effects from the alternatives in the cumulative effects analysis that is included with every resource that was analyzed in chapter 3 of the 2013 Draft Supplement.

WWP192 It must discuss the grave risks of continued grazing disturbance…

Forest Response: The environment effects of the two alternatives (Alternatives 1 and 2) that would authorize continued grazing in the Ely Westside Rangeland project area are analyzed in chapter 3 of the 2013 Draft Supplement.

WWP194 [The EIS fails to identify] the degree and severity of degradation already present in uplands …

Forest Response: The current condition of uplands in the project area is generally described pages 115 to 119 in the 2013 Draft Supplement. Allotment-specific information on upland condition are included in pages 123, 125, 127, 129, 131, 133-134, 135-136, 137-138, 139, 141, 143, and 145 of the 2013 Draft Supplement.

WWP198 [w]atershed integrity, sensitive, rare and MIS species habitats, roadless areas and Wilderness lands in the District are facing serious pressures from all directions.

Forest Response: Watershed integrity has been addressed by the response to comment WWP3. The effects of the alternatives on watersheds have been addressed by the responses to comments WWP111 and WWP117. The effects of livestock grazing on MIS, sensitive species, and other wildlife, fish, and plant species are discussed in the Wildlife and Fish (pages 189 through 288), Sensitive Plants (pages 289 through 304), and Wilderness (page 305 through 326) sections in chapter 3 of the 2013 Draft Supplement. Inventoried Roadless Areas are addressed on pages 23-24 of the 2013 Draft Supplement. Additional information on the roadless areas in the project area can be found in the Wilderness and Inventoried Roadless Area Specialist Report in the project record.

WWP199 Recent review papers show range myths about sage and PJ are not correct. Romme et al. 2009. Forester position paper, Baker and Bukowski 2013. Papers show the harmful effects of the treatments – Romme et al. 2009, Hess and Beck 2010, 2012, Jones et al. 2013, other son cd.

Forest Response: From your comment, it is unclear what things you believe are range myths.

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Romme and others (2009) discusses increases in pinyon-juniper density and 3 factors that might be driving the increases. Livestock grazing is one of those factors. Romme and other 2009 noted that heavy grazing on herbaceous vegetation may give tree seedlings a better chance at survival. Alternative 1 (Proposed Action) would set grazing at moderate, not heavy, levels if the vegetation is in desired condition and reduce the use levels if the vegetation is in less than desired condition. These adjustments ensure that herbaceous vegetation is in place in the appropriate amounts. Romme and others (2009) also noted that sustained heavy grazing can reduce herbaceous and other fuels to the degree that low-severity fire is not carried across the landscape and consequently is not reducing tree density. Again, Alternative 1 (Proposed Action) sets moderate grazing levels which ensure vegetation is vegetation remains to serve as forage for other grazers and habitat for other species. The residual vegetation addresses concerns that heavy grazing can limit an area’s ability to carry fire.

Bukowski and Baker (2013) conclude that livestock grazing and fragmentation of patches of sagebrush by roads and developments has likely altered sagebrush fire regimes to lower intensity, patchy fires. This conclusion is based in part on the possibility that overgrazing severely reduced the fine fuels necessary to carry fire across the landscape. As noted above, Alternative 1 (Proposed Action) prescribed moderate to conservative utilization levels which ensure there will be residual vegetation on the allotment.

Hess and Beck (2010) considered sage grouse nesting and brood-rearing habitat response to sagebrush treatments. They concluded that mowing and prescribed burning in Wyoming big sage communities was not recommended. They also suggested adjusting grazing management to improve conditions in Wyoming big sage communities instead of using vegetation treatments. This project includes two alternatives that would change the grazing practices in the project area: Alternative 1 (Proposed Action) and Alternative 2 (No Action/No Grazing). The changes in grazing under Alternative 1 (Proposed Action) are designed to improve the herbaceous component in sagebrush communities without the need for mechanical treatment. This alternative sets utilization levels at sustainable levels based on the area’s ecological condition. Furthermore, there is very little Wyoming big sage in the project area and none of it is being considered for mechanical treatment or prescribed burning. See response to comment WWP203 for more information regarding Wyoming big sage.

Jones and others (2013) suggests that when there are concerns about the lack of herbaceous vegetation or the expansion of pinyon-juniper in a sagebrush community, changes in grazing practices may be a more appropriate response than mechanical treatment. This project includes two alternatives that would change the grazing practices in the project area: Alternative 1 (Proposed Action) and Alternative 2 (No Action/No Grazing). The changes in grazing under Alternative 1 (Proposed Action) are designed to improve the herbaceous component in sagebrush communities without the need for mechanical treatment. This alternative sets utilization levels at sustainable levels based on the area’s ecological condition.

Sub Topic: General WWP1 The Forest provides a largely programmatic document that fails to provide essential site-specific detail on ecological conditions and the current array of wild land values and threats to biotic integrity across the Big Creek, Black Rock, Currant Creek, Ellison Basin, Hooper Canyon, Illipah, Irwin Canyon, Pine Creek/Quinn Canyon, Tom Plain, Treasure Hill and Troy Mountain allotments.

Forest Response: This environmental analysis is a site-specific analysis on a proposal to authorize continued livestock grazing on the allotments within the project

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area. Chapter 3 of 2013 Draft Supplement contains summary of the best available information on the allotments. Most of this information has been displayed by allotment. For example, pages 122 through 146 of the 2013 Draft Supplement contain a description of the existing condition of vegetation in the project area by allotment. Wildlife habitat has been mapped to display the location of that habitat within the allotments. See maps 18 through 34 of the 2013 Draft Supplement. The project record contains the specialist reports, data, and scientific literature that was used to develop these summaries that were included in the 2013 Draft Supplement.

WWP5 We incorporate by reference all of our comments and Alternatives previously submitted on the Humboldt-Toiyabe Jarbidge Rangeland EIS, the parallel Santa Rosa EIS, and the aborted and parallel Mountain City EIS.

Forest Response: This is a separate environmental analysis on a different project area. As such, it stands on its own merits and warrants comments based on its analysis.

WWP9 This Forest-wide Rangeland EIS effort was begun years ago under livestock industry-driven Bush administration policies and pseudo-science (see Dietz: The Stockmen’s Pamphlet). Its purpose then was to gut the requirements of Amendment 2 that serve to prevent damage, and that require accountability by the public lands livestock industry on the National Forest lands of the Humboldt-Toiyabe Ranger Districts, as well as Open up lands to grazing while continuing to graze vast areas of non-capable and/or unsuitable wild lands and critical habitats.

Forest Response: The purpose and need for this project is identified on page 7 of the 2013 Draft Supplement. This project does not propose to change the applicability of Amendment 2 in any manner.

WWP10 It also fails to take into account the severe impacts of desertification caused by livestock grazing and overstocking, as well as greatly flawed crested wheatgrass seedings and sage and juniper eradication measures conducted here.

Forest Response: Dregne (1986) offers the following definition of desertification: Desertification is the impoverishment of terrestrial ecosystems under the impact of man. It is the process of deterioration in these ecosystems that can be measured by reduced productivity of desirable plants, undesirable alterations in the biomass and the diversity of the micro and macro fauna and flora, accelerated soil deterioration, and increased hazards for human occupancy.

The 2013 Draft Supplement takes these factors into account when analyzing the effects of the alternatives on the resources in the project area. The levels of use and anticipated impacts under the alternatives are discussed in the 2013 Draft Supplement. Historic land degradation is also acknowledged as are the improving conditions in the project area since that degradation. Past, present, and reasonable foreseeable range developments and vegetation treatments are analyzed in the cumulative effects section for each issue and resource. Additional information on range developments and vegetation treatments is included in appendix H of the 2013 Draft Supplement, pages H-4 through H-8 and H-16 through H-17.

WWP20 The full degree and severity of desertification on BLM and private lands in these watersheds must also be examined. BLM lands in particular are undergoing all manner of new intrusive development – for Oil and Gas, as well as the greatly harmful new SWIP/ON-Line transmission

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line and its roading, veg removal, weed spread, and habitat intrusion into sensitive sagegrouse and other rare species habitats with an immense Footprint across this landscape.

Forest Response: A discussion of the relevant projects taking place on neighboring BLM land in included in appendix H, pages H-21 through H-22, of the 2013 Draft Supplement. Where appropriate, these projects are discussed and analyzed in the cumulative effects sections for the issues and resources analyzed in the 2013 Draft Supplement.

WWP22 The Forest omits consideration of important direct, indirect and cumulative effects and issues related to the deleterious effects of livestock grazing disturbance. The Westside EIS at 18-21 contains a long list of critical issues and concerns the Forest has ignored.

Forest Response: These issues have not been ignored, but they were not analyzed in detail in the 2013 Draft Supplement. The rationale for excluding these issues from detailed analysis is also provided in table 5 on pages 21 through 24 of the 2013 Draft Supplement.

WWP26 The Forest cannot produce an EIS that addresses livestock grazing on “rangelands” and not lay out present stocking rates and actual use, and the changes that will actually be necessary under a range of alternatives.

Forest Response: The present stocking rates are disclosed in table 6 of the 2013 Draft Supplement. A summary of recent years’ annual operating instructions was included as appendix C to the 2011 FEIS to provide additional information on current allotment management and authorized use. Appendix I in the Final Supplement provides additional information on how current stocking levels were developed.

WWP37 Without providing a year-by-year accounting of actual use (number of cattle grazed and how long AUMs) pasture-by pasture and allotment-by-allotment, it is impossible to understand the environmental baseline, develop and adequate range of alternatives, analyze environmental effects,

Forest Response: Appendix I was included in the 2013 Draft Supplement to provide greater detail on the history of grazing on the allotments. The environmental baseline in this document was developed using the best information available for each resource. The range of alternatives was developed by reviewing the issues identified in the review of the proposed action and comments received during the comment period on the 2013 Draft Supplement. The full range of alternatives is discussed in chapter 2 of the 2013 Draft Supplement. The environmental effects of the alternatives that were analyzed in detail are discussed in chapter 3 of the 2013 Draft Supplement.

WWP45 [I]n understanding how much and what type of herbicide use is occurring or foreseeable, and the suitability of continuing grazing in watersheds inhabited by trout (native salmonids are highly sensitive to herbicides, as new research is showing), rare mussels springsnails [are nay present?], White River dace, or other aquatic species …

Forest Response: Use of herbicides is outside of the scope of this project and would be considered under a separate environmental analysis. By maintaining rangelands in, or improving rangelands to, functioning ecological condition, Alternative 1 (Proposed Action) is designed to make the project area more resilient and less susceptible to noxious and invasive plant species.

WWP51 The Forest has provided in sufficient analysis on how it has determined what community exists

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where, the criteria for community discreteness, whether the Forest will monitor and base decisions on ALL community types in any pasture or area, where a vegetation type chosen for monitoring will be located in relation to water, and other info essential to understand current ecological conditions and watershed integrity.

Forest Response: The vegetation communities were modeled using appropriate protocols and the best available information. Table 25 on page 105 and maps 12 and 13 on pages 106 and 107 of the 2013 Draft Supplement display the acres of the dominant vegetation types by allotment. Additional maps identifying dominant vegetation types in each allotment have been included in Appendix G to the 2014 Final Supplement. Additional information is available in the Vegetation Specialist Report located in the project record. For the purposes of this project, monitoring would be conducted and decisions would be based on the vegetative groups identified through application of the dichotomous key included in the Matrices (see appendix A of the 2011 FEIS). Alternative 1 (Proposed Action) uses two types of monitoring, short- and long-term. Short-term monitoring involves observing proper use criteria (for this project, utilization and stream bank disturbance) as needed on riparian and upland habitats identified as key areas in the allotment management plans. Selection of key areas has been addressed in response WWP52.

WWP57 Timing of grazing use seriously overlaps important wildlife use periods degrades essential habitat components.

Forest Response: Alternative 1 (Proposed Action) contains design features that specifically address and minimize impacts from grazing to a variety of wildlife species (see page30 in 2013 Draft Supplement). These design features address to the location and timing of grazing in areas important to wildlife in the project area.

WWP64 The Forest ignored analysis of the important and unique ecological values of these lands, and protections for unique or important biological values that are jeopardized by continued livestock or other disturbance. It did not examine “reserve” and other ecological concepts, and protection and enhancement of remaining native sagebrush and other communities as critical habitats for shrubsteppe species, and as buffers against climate change effects.

Forest Response: The level of analysis, alternative development, and proper use criteria for this project meets the requirements in NEPA and Regional guidelines. Grass reserves were considered but did not fit into this project area. However, under all alternatives we have kept three allotments open, but vacant. Active restoration projects identified through this analysis are outside the scope of this project and require additional NEPA.

WWP65 The EIS Goals shows bias to the livestock industry. It places overwhelming emphasis on livestock permittees and “economics”.

Forest Response: Technically, the “goal” of the EIS is to provide information on a potential federal action and to disclose the effects of the various alternatives. From the context of your comment, it appears you are addressing the purpose and need. The purpose and need is discussed on page 7 of the 2013 Draft Supplement. Rather than providing overwhelming emphasis to livestock permittees, the purpose and need tempers the permissible multiple use of domestic livestock grazing against sustaining the health of the project area.

WWP76 Please also provide a breakdown, by permittee and/or permit, of all of the above information.

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This is also important to understand what we believe is a flawed statement and discussion of Purpose and Need.

Forest Response: This information would not be useful in the decision-making process for this project. Grazing is an appropriate multiple use of National Forest System lands. The economic commitments that have previously been made by permittees are acknowledged in the 2013 Draft Supplement, but it does not drive any of the analysis in the document. Likewise, previous commitments of resources by the Forest Service in management of these rangelands are not a determinative factor.

WWP79 The Forest refuses to examine the relationship between many of the minor and other roads here and livestock grazing activities in Travel Planning processes. So this EIS is where such analysis should be conducted, and roads identified for closing and rehab in areas where they are redundant, where ranching activities could be conducted on foot or horseback, where facilities are causing damage.

Forest Response: The travel management environmental analysis for the Ely Ranger District has been completed. This project will not duplicate that effort.

WWP80 A Rangeland EIS must be driven by a Purpose and Need that aims at protecting the public interest, retaining and restoring habitats, sustaining and recovering viable populations of native biota, and providing for intact and healthy lands. THEN decide where (if anywhere) grazing disturbance may be the least damaging.

Forest Response: The purpose and need for this project can be found on page 7 of the 2013 Draft Supplement. It contemplates authorizing grazing under terms and conditions that allow the health of the land to be sustained.

WWP100 The EIS ignores the major issues of INVASIVE SPECIES, WATER QUANTITY, microbiotic crusts and their critical role in ecosystems from fixing nitrogen to stabilizing soil surfaces and preventing erosion to serving as first-line defense against cheatgrass and other invasive species.

Forest Response: Invasive species are identified and discussed, by allotment, in the Noxious and/or Invasive Weeds section of the 2013 Draft Supplement on pages 119-122 and pages 181-187. Water quantity was not addressed as an issue for detailed analysis. Information on the effects of livestock grazing on water quantity is included in the Water Quality section on page 96 of the 2013 Draft Supplement. Microbiotic soils are discussed in the Soils section, pages 73-83, of the 2013 Draft Supplement.

WWP101 The Forest has ignored the importance of these lands for many other important and sensitive species and also ignores the need to protect and restore habitats for populations adversely affected by grazing disturbances and other adverse effects. These species include bighorn sheep that may be displaced by cattle, pygmy rabbit, Brewer’s sparrow, loggerhead shrike, mule deer, antelope, bighorn sheep and other aquatic species, as well.

Forest Response: Chapter 3 of the 2013 Draft Supplement analyzes the effects on many important and sensitive species, including sage-grouse. Other analyses are included in the Vegetation, Botany, MIS, and Wildlife specialist reports included in the project record.

WWP104 Frequent reductions (drought, Forest actions related to trespass or resource degradation, etc.), and

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other closures or alterations in grazing use and stocking rates, are not provided or examined in detail so that the public can understand that both the No Action and the Proposed Action/Preferred Alternative are based on a fantasyland illusion of what the “baseline” of actual stocking and livestock use (including upland utilization) has been here.

Forest Response: This comment suggests that the 2013 Draft Supplement predicts improvement under the Alternative 1 (Proposed Action), in large part, because it falsely relies on inflated stocking rates under the Current Management Alternative (Alternative 2). In essence, it claims there is an assumption that there are more cattle under current management (many of which are not actually turned out) and fewer cattle under Alternative 1 (Proposed Action) (but in actuality the numbers are very similar to what are actually turned out under current management), so conditions will improve under Alternative 1 (Proposed Action). This misses one of the most important features of Alternative 1 (Proposed Action) – management of the allotments based on their current ecological condition and not on an estimate of how many head of livestock can be fed over a prescribed period of time. Under Alternative 1 (Proposed Action), the number of livestock could actually increase, although such an adjustment would likely lead to a shorter season. If other grazing management activities, such as herding to improve distribution, are employed, then the season of use may remain the same or be even longer despite the increase in numbers. The determining factor is the ecological condition of the pasture, not the number of livestock, and proper use criteria (for this project, utilization) are to limit annual use to be consistent with the ecological condition of the allotment.

WWP105 All of this information, and the severity of impacts examined area-by-area caused by cattle use at a particular stocking level must be analyzed.

Forest Response: The impacts of grazing at the levels contemplated under the two action alternatives are analyzed in chapter 3 of the 2013 Draft Supplement.

WWP106 This must be overlaid with a reality-based analysis of the degree of existing desertification/reduced production due to shifts in plant community composition/losses of surface and ground waters due to livestock-caused and other erosion, climate change effects, weed expansion risks under continued cattle disturbance, etc.

Forest Response: The 2013 Draft Supplement identifies the existing conditions of vegetation (including weed expansion), water, soils, and other resources using the best available information. The 2013 Draft Supplement also discusses how the disturbance associated with livestock grazing under the two action alternatives would affect those resources.

WWP108 Is the Forest admitting here that to undertake restoration in a true sense, lands will need to have no grazing disturbance? Perhaps the Forest is well aware of all the science it fails to provide in support of No Grazing. We are also very concerned that the Forest fails to adequately weigh and explain all the ecological, recreational, cultural site and other protections and full benefits of No Grazing.

Forest Response: No. Through the descriptions and analysis of Alternative 1 (Proposed Action), the Forest is demonstrating that the rangelands in the project area can be maintained in or moved toward desired condition without the removal of all grazing disturbance. The anticipated effects under the No Grazing Alternative (Alternative 3) are disclosed in chapter 3 of the 2013 Draft Supplement. Recreation was not identified as resource concern that necessitated individual analysis in the 2013 Draft Supplement. No grazing is authorized in campgrounds in the project area. Grazing can affect a variety of the resources (wildlife, aquatic species,

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vegetation, water quality) that recreationists rely on as part of their recreational experience (hunting, fishing, photography, wildlife viewing, hiking, and camping). The effects on the resources are disclosed in chapter 3 of the 2013 Draft Supplement.

WWP113 The Forest may use building more facilities or dumping more rocks in headcuts as part of its “adaptive management” and BMP scheme. But it fails to analyze and detailed info on such facilities/actions like rock dumping and effects on values of the public land.

Forest Response: None of the alternatives proposes to build new facilities. Before any new facilities could be constructed, an appropriate environmental analysis would have to be conducted.

WWP150 While the Forest may make drought adjustments, this is all nebulous, and may be what is occurring already.

Forest Response: Drought is addressed in table 5, in chapter 1, of the 2013 Draft Supplement. See also response to comment WWP78.

WWP154 The cumulative effects area and analysis must include other allotments and BLM and other lands in these watersheds, as well as across the relevant sage-grouse PMUs, and full analysis of the capability for populations –like sage-grouse and pygmy rabbit.

Forest Response: We interpret this term to mean the entire area being considered for use, not just one good or bad spot within the area. The cumulative effects area for this project was described, by resource, chapter 3 of the 2013 Draft Supplement.

WWP156 Closure of significant areas currently grazed to all continued livestock grazing must be examined as a viable mitigation.

Forest Response: Alternative 3 (No Grazing/No Action) would end grazing in all of these areas, addresses all of these concerns, and analyzes the effects of removing livestock grazing from these areas.

WWP157 Other mitigation includes removal of facilities in each allotment that may be negatively impacting sage-grouse, rare plant, or other habitats.

Forest Response: Alternative 3 (No Livestock Grazing/No Action) would remove existing improvements over time that are no longer functional or needed including interior fences, cattleguards, and water developments as allowed by funding and management priorities.

WWP161 The Forest can not assure that it is complying with NFMA and MUSYA until it provides an adequate baseline, addresses microbiotic crusts, spring and seep and water quantity issues, conducts watershed integrated analysis, addresses desertification, climate change/global warming, important, conducts valid sensitive species viability and habitat analyses including consideration of connectivity/fragmentation analyses and identifies and assesses population viability here.

Forest Response: The National Forest Management Act requires projects to be consistent with the applicable Forest Plan. Both action alternatives are consistent with the Humboldt National Forest. The MUSYA mandates national forests to develop and administer their renewable surface resources “for multiple use and sustained yield of the several products and services obtained there

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from” while giving due consideration “to the relative values of the various resources in particular areas.” This project relies on the best available science cited in the 2013 Draft Supplement, the specialist reports, and other documents in the project record.

WWP178 The Forest has not provided detailed info and analysis on how its new contrived definitions of Functioning at risk, and its Matrices correspond to Condition and other information in the Forest Plan and past analyses.

Forest Response: In chapter 1 (pages 10-11), the 2013 Draft Supplement acknowledged that there were several different but similar terms that have been historically used to describe rangeland condition and how those terms relate to one another.

WWP196 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.

Forest Response: Threatened, endangered, candidate, and sensitive species were analyzed in the Wildlife and Fish section of the 2013 Draft Supplement on pages 189 through 287. As noted on page 190 of the 2013 Draft Supplement, there are no federally-listed threatened or endangered wildlife or fish in the project area.

WWP205 WWP requests that the Forest provide much more informative maps showing pastures, and underlying vegetation, cheatgrass and other information for the EIS area allotments. The mapping is at a scale so as to be often uninformative.

Forest Response: The 2013 Draft Supplement contains maps that display the location of many resources along with the allotment boundaries: Stream, Springs and Watershed Boundaries (maps 10 and 11), Vegetation Types (maps 12 and 13), Categorized Springs, Seeps, and Streams (maps 16 and 17), Wildlife habitat (maps 18 through 34), Wilderness areas (map 35), and Range Developments (maps 36 and 37). In addition to these maps, the 2014 Final Supplement includes maps for each draft Allotment Management Plan that identifies the vegetation types and range developments in the allotments.

WWP210 Please fully and fairly examine ecological conditions related to livestock and other disturbances to soils, microbiotic crusts, watersheds, water quality, water quantity, native vegetation communities, risk of invasive species including annual or other exotic grasses, altered fire cycles due to exotic grasses and grazing impacts, native sensitive species habitats and populations, native aquatic species habitats and populations, all rare, sensitive, imperiled, and declining species and their populations, cultural values of the public lands, recreational uses including Wilderness, roadless areas, adjacent BLM Lands with Wilderness Characteristics, aesthetic uses and enjoyment, and scientific and other pursuits on the public lands.

Forest Response: The 2013 Draft Supplement examines the existing conditions and the effects of the alternatives on soils and microbiotic crusts on pages 74 through 83. The 2013 Draft Supplement examines the existing conditions and the effects of the alternatives on watersheds, water quality, and water quantity on pages 90 through 102. The 2013 Draft Supplement examines the existing conditions and the effects of the alternatives on native vegetation communities and invasive species (including annual and exotic grasses) on pages 108 through 188. The 2013 Draft Supplement examines the existing conditions and the effects of the alternatives on native sensitive species habitat on pages 193 through 218, 231 through 267, and 290 through 303. The 2013 Draft

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Supplement examines the existing conditions and the effects of the alternatives on native aquatic species on pages 95 through 102, 226 through 228, and 273 through 277. The 2013 Draft Supplement examines the existing conditions and the effects of the alternatives on a wide array of rare, sensitive, and other plant and animal species of interest on pages 108 through 188, 189 through 286, and 290 through 303. The 2013 Draft Supplement examines the existing conditions and the effects of the alternatives on cultural resources on pages 328 through 333. The 2013 Draft Supplement addresses recreation uses in general on page 24. The 2013 Draft Supplement examines the existing conditions and the effects of the alternatives on wilderness on pages 309 through 326. The 2013 Draft Supplement addresses inventoried roadless areas on pages 23 through 24. BLM does have some lands with wilderness character adjacent to the project area. These lands are located on the north end of the Grant-Quinn Range, adjacent to the Irwin Canyon and Troy Mountain allotments. The selected action will not have any impact on these lands because livestock grazing will not be authorized in the Irwin Canyon Allotment or the portion of the Troy Mountain Allotment that is in the Grant Range Wilderness. This means livestock grazing will not be authorized in the portion of the project area that is adjacent to the BLM lands with wilderness character. Furthermore, even if livestock grazing was authorized in this area, it is very rugged and difficult for livestock to access making it very unlikely that livestock grazing or grazing impacts would occur in the area. The 2013 Draft Supplement addresses aesthetic uses and enjoyment in general on page 24. The 2013 Draft Supplement considers scientific pursuits as related to Research Natural Areas and other special features on pages 311, 318, 321, 324, and 325.

WWP214 2011 COMMENTS – ALL CONCERNS TO BE CARRIED FORWARD IN 2014 IN ADDITION TO THOSE SUBMITTED Forest Response: The Forest responded to your 2011 comments in 2011. Those responses are being included and incorporated by reference. As appropriate, some of those responses have been updated. Because many of the comments in your 2014 comment letter are similar to those offered in 2011, the Forest has retained the numbering sequence from the 2011 comments. If a response to a 2014 comment was addressed in the Forest’s 2011 Response to Comments, the 2014 comment has been given the 2011 comment number and the associated response.

Sub Topic: Proposed Action and Alternatives WWP3 The EIS takes the stats [sic] quo, and worsens and complicates management by imposing a ridiculously complicated grazing system based on vegetation conditions while failing to protect the scarce waters and already greatly compromised watersheds from livestock trampling disturbance.

Forest Response: Proper use criteria developed in the proposed action reduces utilization of herbaceous and woody vegetation at a level that promotes healthy vegetation; these use levels also provide a reduction in soil disturbance by permitted livestock. Transitory use of non-capable lands by permitted livestock is acceptable and expected. The proposed proper use criteria also include standards for riparian vegetation as well as monitoring and reporting requirements.

WWP30 The Forest actually gets rid of the best adaptive management action it has: That is the existing Adaptive actions possible under the No Action Alternative and Amendment 2.

Forest Response: There is no proposal in the 2013 Draft Supplement to change the applicability of Amendment 2 of the Forest Plan. The utilization standards set in Amendment 2 are within

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season measurements that trigger the movement of livestock from the area being grazed. These triggers remain in effect under both action alternatives. Alternative 1 (Proposed Action) employs end of season utilization levels designed to leave the grazed areas with an appropriate level of residual vegetation at the end of the season. To ensure that the end of season levels are achieved, within season triggers have been identified under Alternative 1 (Proposed Action).

WWP31 Under the new scheme with much less accountability and thus much greater uncertainty, new livestock damage can happen each and every year as nothing exists that prevents it. Livestock can remain out year after year as end of grazing period use is what will be measured. Plus, ranchers won’t even be required to meet the end of season use standards each year. This also allows greater use to occur in lands grazed in late spring and early summer during the active growing period or with exceptional rains, as plants may be grazed to very low levels including during sensitive nesting and birthing periods for native species, and some “regrowth” occur but the levels of use are not measured until the fall.

Forest Response: Under Alternative 1 (Proposed Action), maximum end of season utilization levels and within season triggers are set based upon the habitat group’s ecological condition. The utilization levels and within season triggers are designed to ensure that the condition of the habitat group is maintained if it is in functioning ecological condition and improved if it is in functioning-at-risk or non-functioning ecological condition. Alternative 1 (Proposed Action) mandates lower end of season utilization levels and within season triggers if the habitat group is not in functioning ecological condition. These lower levels are the maximum amount of utilization that would be authorized for that ecological condition, but lower levels can be authorized if warranted. Other management actions could also be taken to improve or maintain conditions.

WWP33 Under the EIS’s flawed AM scheme, band-aid “temporary” fences will be slapped up without adequate NEPA processes.

Forest Response: None of the alternatives in this project are proposing the construction of any fences (temporary or otherwise). If it is subsequently determined that new fences would be beneficial, then the appropriate environmental analysis would be conducted at that time.

WWP34 Then, in the longer term, the Forest’s complex and unrealistic monitoring scheme will stymie real changes on the ground. Cutting cattle numbers/AUMs is based on complex, uncertain and expensive vegetation community monitoring that it is highly unlikely to ever occur.

Forest Response: The monitoring process under Alternative 1 (Proposed Action) is described on pages 42 through 46 of the 2013 Draft Supplement and the management adjustments that would be taken based upon the long-term monitoring results are identified in tables 10 and 11 of the 2013 Draft Supplement. The process uses the Matrices (discussed in WWP7) as a rapid assessment tool to consider quantifiable information on various attributes within a habitat group (gathered using appropriate protocols) and determine the ecological condition of the allotment. These assessments would generally occur on a 5-year cycle. The proper use criteria discussed on pages 31 through 38 of the 2013 Draft Supplement would be adjusted to match the identified ecological condition.

WWP67 It is alarming that the Forest would propose that if conditions improved, AUMs would be increased. This makes no sense, and shows grazing is viewed by the Forest as the single primary use of these lands. Is the Forest proposing increasing AUMs even above the very high numbers

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on the permits at present?

Forest Response: None of the alternatives proposes increasing AUMs above their current levels.

WWP78 Please also describe in detail how the Forest has dealt with determining use levels and stocking rates during drought – and how specifically this will occur under the EIS.

Forest Response: The USDA – Forest Service Guide to Drought Assessment and Mitigation and other direction and resources on the Intermountain Region’s drought monitoring website, guides management activities in relation to drought: http://www.fs.usda.gov/detail/r4/landmanagement/resourcemanagement/?cid=fsbdev3_016096

WWP82 It appears that the Forest may plan to allow permittees that have degraded other lands that higher standards to sprawl grazing use into the Vacant allotments – Is that the case with the Troy Canyon allotment here? This rewards failure, and places primacy on private over public interests.

Forest Response: There are three vacant allotments in the project area: Big Creek, Hooper Canyon, and Irwin Canyon. None of the alternatives propose to authorize grazing on the vacant allotments. The Troy Mountain Allotment is closed, but it was grazed recently under a temporary permit. A temporary permit was first authorized in 2004 and has been re-authorized annually through 2011. The ecological conditions of all pastures in the project area and the utilization levels that would initially be applied are displayed in table 7 on page 29 of the 2013 Draft Supplement. As discussed on pages 31 through 38 of the 2013 Draft Supplement and documented in the annotated bibliography of the research that was reviewed to develop the utilization levels used under the proposed action, Alternative 1 (Proposed Action) should maintain and/or improve the lands and waters in the project area.

WWP86 The Forest must consider much longer periods of rest, or closing lands permanently following fire or its battery of “treatments”, to promote recovery of ecological processes and sustained water, soils, veg and native species.

Forest Response: The Forest Plan requires 2 years of rest from livestock grazing after a fire. All alternatives for this project are consistent with that requirement. Additional rest is considered on a case-by-case basis. Restoration actions following a fire are outside of the scope of this project.

WWP88 As part of this process, we request the Forest examine a range of significant active and passive restoration actions to recover sagebrush communities.

Forest Response: A proposal to authorize livestock grazing is not expected to be an active restoration proposal. Many habitat impacts are the result of historic rather than current livestock grazing practices and may require specific restoration projects, which is generally beyond the scope of a site-specific range allotment analysis.

Alternative 1 (Proposed Action) uses tiered proper use criteria (for this project, utilization) based on the ecological condition of the habitat group in the pasture being considered is a passive strategy. By reducing the impacts on lands that are not in functioning condition, Alternative 1 (Proposed Action) provides these lands with a degree of relief that should allow them to move towards functioning condition. In addition to these required adjustments, range managers and permittees have a variety of other tools that can be used to improve conditions.

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WWP89 The Forest never explains that it is gutting a key protective measure of Amendment 2, i.e. the current triggers that require livestock to be moved from pastures when standards are met.

Forest Response: This project does not propose to change the applicability of the maximum within season triggers established in Amendment 2 of the Humboldt Forest Plan in any manner. Alternative 1 (Proposed Action) applies end of growing season utilization levels identified in the proper use criteria table on page 38 of the 2013 Draft Supplement. The same table (table 9) identifies the within season triggers from Amendment 2. None of the alternatives proposes grazing at levels higher than the standards set in Amendment 2, regardless of whether utilization is measured within or at the end of the growing season.

WWP95 The proposed standards are far too excessive, and use levels in uplands are now in this proposed range anyway. The problem is upland use is not measured in areas frequented by cattle, and even 20% utilization means a large amount of the height (cover) of a grass plant is removed so sage- grouse cannot nest, and forbs and other palatable species get grazed out

Forest Response: The end of season utilization measurements and the within season triggers proposed in Alternative 1 (Proposed Action) are consistent with, and in most cases are more protective than, the standards included in Amendment 2 of the Forest Plan (see table 9 of 2013 Draft Supplement). Authorized and actual use levels in uplands are discussed in the 2013 Draft Supplement on pages 176-177. The 2013 Draft Supplement discusses the literature used to determine the proper use in uplands (starting on page 169). In general, the uplands were determined to be in functioning-at-risk condition. These determinations were reached for a variety of reasons, including pinyon-juniper encroachment, year-long wild horse use, past livestock use and grazing practices, and cheatgrass invasion (pages 122-146).

Utilization is measured in key areas as discussed on page 39 of the 2013 Draft Supplement. These areas should be representative of the grazing use in the pasture, not the most or least impacted areas. See appendix E of the 2011 FEIS for additional information on the selection of key areas. The literature used to determine proper use criteria and the effects of upland vegetation is discussed on pages 32 and 169-170.

WWP103 As part of this EIS please conduct full and detailed analysis of restoration needed for all springs and seeps that have been developed.

Forest Response: Active restoration of seeps and springs in the project area is outside of the scope of this project. As discussed in response WWP79, Alternative 1 (Proposed Action) employs a passive restoration strategy.

WWP107 We never expect the Forest to (yet) get rid of all livestock disturbance, and actually adopt No Grazing. So the Forest must develop a range or combination of actions to remove grazing from critical habitats, restore lands, and minimize damage.

Forest Response: Alternative 1 (Proposed Action) contains design features, pages 30 and 31 of 2013 Draft Supplement, that provide protection for sage-grouse, pygmy rabbit, flammulated owl, bats, wildlife that use aspen and riparian communities, sensitive plants, and cultural resources. The range of alternatives has been addressed in response to comment WWP6.

WWP110 The Forest claims the No Grazing Alternative is analyzed in Full. No – it is not.

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Forest Response: Alternative 3 (No Grazing/No Action) is analyzed under every issue and resource concern addressed in chapter 3 of the 2013 Draft Supplement. Tables 14 and 16, on pages 55 and 57-60 of the 2013 Draft Supplement, summarize that analysis and compare it to the other alternatives. All the scientific literature cited and relied on in the 2013 Draft Supplement are listed in the References section. Additional scientific literature not specifically cited in the 2013 Draft Supplement may be found in the specialist reports prepared for this project.

WWP116 The Forest provides no upland or riparian measures or standards of use to limit or monitor trampling disturbance. This is a serious concern in lands grazed by large herds of livestock, and where large areas of non-capable lands may be traversed by livestock in the course of grazing pockets of “capable” areas.

Forest Response: Upland trampling disturbance was not identified as a proper use criteria. See also responses to comments WWP3 and WWP92. However, several of the attributes in the Matrices (including percent canopy cover, species composition, and bare ground) could be affected by trampling, which could affect the ecological condition determination for that area. Regarding livestock crossing “non-capable” lands, see responses WWP8 and WWP47.

WWP124 How can grazing be managed to minimize further deletion and losses?

Forest Response: The discussion of the alternatives in chapter 3 of the 2013 Draft Supplement describes the anticipated effects of the various alternatives. Alternative 1 (Proposed Action) would allow grazing at sustainable levels based on a habitat group’s current ecological condition. See also response to comment WWP7.

WWP128 The Forest only admits possible loss of AUMs –but never shows where, how many, or when this would occur. The Forest flawed analyses ignore that it plans to Open a Vacant allotment to livestock use – so there will really be an INCREASE in harmful grazing use under the Proposed Action.

Forest Response: A loss of AUMs is possible in the project area but how many or when is unknown at this time; the severity of these possible losses largely depends on the permittees willingness and ability to effectively manage their livestock. There are three vacant allotments in the project area: Big Creek, Hooper Canyon, and Irwin Canyon. No alternative proposes to authorize grazing any the vacant allotments. Vacant allotments have assigned AUMs and are open to grazing but do not have an active grazing permit at this time, so there is not an increase in grazing use as no new allotments or AUMs are proposed in this NEPA analysis. Alternative 1 (Proposed Action) includes a non-significant forest plan amendment to open the Troy Mountain Allotment.

WWP130 The Forest has not adequately defined “rest”, and “hot season” period is much too short. Hot season here, especially in the non-Wilderness lower elevation portions of the Forest is June 1-October 1.

Forest Response: A definition for rest is included on page 361 of the 2013 Draft Supplement in the Glossary. No hot season period is specifically identified in the 2013 Draft Supplement. We view the hot season as the time period when the project area has day time temperatures over 90 degrees Fahrenheit without cooling greatly at night. We also consider the period of time when most plants have flowered (August 15th). Considering these factors, we set the hot season

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between mid to late June through mid August.

WWP142 Alt 2 seems to loosen criteria to limit when turnout could occur.

Forest Response: Alternative 1 (Proposed Action) and Alternative 2 (Current Management) would allow turnout at any time that is consistent with the terms of the grazing permit, the design features included in the alternative, and the ecological condition of the allotment.

WWP147 The Forest keeps promising changes – but never provides the details, mechanics and analysis showing how this will all work. So when cattle are not being grazed – where will they be? Will numbers be increased in other areas, or cut by one third?

Forest Response: This comment implies that any effort to reduce use in one area for resource protection will always have a greater impact on other areas that are being grazed. Both action alternatives have limits on utilization that would prohibit this result. If cows were “doubled” up in another area, then the utilization limits would be reached more quickly and result in a shorter season of use for the permittee.

WWP148 What are the and cumulative effects of implementing the promised changes?

Forest Response: The effects (direct, indirect, and cumulative) of all the alternatives are included in chapter 3 of the 2013 Draft Supplement.

WWP149 The Forest may use earlier turnout/use periods. What range readiness would be applied? What soil moisture levels would damage soils under trampling? If cattle turnout is delayed for 2 weeks, would the forest allow the permittee to stay longer – or graze even larger herds? How will this be handled? Of use is compressed into shorter periods, disturbance will be intensified.

Forest Response: Soil moisture is one of the factors considered when we determine if conditions are appropriate for livestock to be put on the Forest. If turn out is delayed, utilization levels based on the ecological condition of the allotment would still apply as would the general season of use included in the grazing permit. The number of cattle could be increased to correspond with the shorter season, but the utilization levels, not the predicted length of the season, would control the decision to move livestock from the allotment.

WWP155 The EIS is devoid of mitigation for the continued high stocking, harmful and degrading livestock facilities, and the extensive past and ongoing damage caused by the livestock industry on the Forest.

Forest Response: Alternative 1 (Proposed Action) provides several design features in chapter 2 of the 2013 Draft Supplement that address known concerns and negates the necessity for mitigation measures. Furthermore, Alternative 1 (Proposed Action) provides for adjustments to the proper use criteria (for this project, utilization) based on the ecological conditions within an allotment. These adjustments are based on a review of current scientific literature. The ecological response to these predetermined adjustments should also negate the necessity for mitigation measures.

WWP158 The Forest, while imposing this artificial, this scheme, and loose and uncertain Adaptive

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Management is setting up a system that requires a tremendous amount of monitoring.

Forest Response: This comment relates to the discussion of Implementation Monitoring (Short-term) for Alternative 1 (Proposed Action) in chapter 2 of the 2013 Draft Supplement. As described in the 2013 Draft Supplement, this type of monitoring is done to ensure the actions described in the Alternative 1 (Proposed Action) are being implemented as planned. The schedule for this type of monitoring is discussed at length in the 2013 Draft Supplement. The identification of factors that help prioritize monitoring does not mean that only allotments with those factors will be monitored. Those factors would be used to balance where monitoring efforts should be allocated so that the greatest benefit can be derived from those efforts. The timing of the monitoring would depend on the thing being monitored. Utilization measurements have been identified for both within season triggers and end of growing season levels, but implementation monitoring of the design features would vary as appropriate to the design feature. For example, monitoring of the design feature prohibiting grazing in sage-grouse breeding complexes during the reproductive season would need to be done during or immediately following the reproductive season.

WWP159 The Forest provides no comprehensive monitoring to strategy.

Forest Response: Alternative 1 (Proposed Action) contains a detailed discussion on short- and long-term monitoring and the use of key areas on pages 38-46 of the 2013 Draft Supplement. Appendix E to the 2011 FEIS describes the process for selection of key areas.

WWP160 Since the Forest both opens a vacant allotment as well as never reveals actual use, it is very likely that bacterial levels, sediment, turbidity, water temp, DO2, nutrients, bare ground, soil compaction, soil erosion in wind and water (why won’t the Forest recognize the critical role of microbiotic crusts and current science here), and weeds will increase. It is likely that bank stability, water quality and quantity, sage grouse nesting, sage grouse brood rearing, dense big sagebrush pygmy rabbit habitats, riparian health, aspen regeneration, all may decline.

Forest Response: Your observation of the potential for greater levels of grazing disturbance on the Troy Mountain Allotment is noted. However, as the 2013 Draft Supplement acknowledges on pages 13, grazing has been occurring on this allotment since 2004.

WWP182 Please include an Herbicide Risk Analysis the effects of herbicide use and degradates on aquatic biota, as well as burrowing animals like the pygmy rabbit that may be subjected to biocides in soils and in the air in burrows.

Forest Response: The use of herbicides is outside of the scope of this project. See response to comment WWP45.

WWP189 The EIS contains no protective closures for sagebrush communities, and only plans on opening sagebrush allotment area in Troy.

Forest Response: Neither of the action alternatives would fully close areas to livestock grazing. However, Alternative 1 (Proposed Action) does provide general and specific protections for sage-grouse habitat. Generally, Alternative 1 (Proposed Action) would provide for lower utilization levels in areas that were not in desirable condition. These lower levels would reduce the impacts on sage-grouse habitat that may be affected by livestock grazing and provide the areas with an opportunity to recover. Specifically, Alternative 1 (Proposed Action) includes

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design features that provide additional protection to sage- grouse habitat.

WWP190 The Forest does not even propose to avoid grazing disturbances in all nesting habitats during periods when birds are nesting.

Forest Response: You are correct, however in chapter 2 of the 2013 Draft Supplement (page 30), Alternative 1 (Proposed Action) includes the following design features which are intended to minimize impacts to birds in the project area:

Future planned activities that are likely to concentrate livestock use such as salting, placement of watering sources, and placement of temporary handling facilities, would avoid impacting wildlife by being located at least:

• 0.5 miles from a known sage-grouse nest or lek.

• 650 feet from a known active flammulated owl nest until young have fledged.

• 0.25 mile from riparian and aspen vegetation communities.

WWP195 Detailed and time-specific monitoring schedules must be established.

Forest Response: Both action alternatives address monitoring. Under Alternative 1 (Proposed Action), monitoring and monitoring schedules are described on pages 38 through 46 of the 2013 Draft Supplement. Under Alternative 2, monitoring and monitoring schedules are described on pages 51 through 52 of the 2013 Draft Supplement.

WWP202 We strongly oppose the opening of the Troy Mountain allotment, for all the reasons in our former Appeal and comments.

Forest Response: Thank you for your comment. The 2013 Draft Supplement (pages 13 through 16) contains a detailed discussion explaining the recommendation to re-open the Troy Mountain Allotment under Alternative 1 (Proposed Action). The allotment would remain closed under Alternative 2 (Current Management) and Alternative 3 (No Action/No Grazing).

Sub Topic: Range of Alternatives WWP6 [F]ailing to analyze a reasonable range of alternatives under NEPA including alternatives that would significantly reduce stocking and close critical areas to sage-grouse, pygmy rabbit and other wildlife, as well as highly sensitive Wilderness and other watersheds.

Forest Response: The regulations implementing NEPA require the development of a reasonable range of alternatives. This project considers a reasonable range of alternatives that address the stated purpose and need.

• Alternative 1 (Proposed Action) reduces the maximum utilization levels to a moderate level to bring them into line with current scientific literature and makes predictable and predetermined management adjustments based on the ecological condition of the pasture. In many instances, these moderate levels are already being used on allotments in the project area and result in little or no change in utilization, unless the allotment under consideration is not in functioning ecological condition. For allotments that are not in functioning ecological condition, more restrictive utilization levels would be

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imposed to ensure that the area moves toward functioning ecological condition. Alternative 1 (Proposed Action) includes a number of additional design features developed to reduce impacts on wildlife, sensitive plants, cultural resources, and riparian areas. Furthermore, it outlines a comprehensive monitoring plan.

• Alternative 2 (Current Management) represents continuation of the status quo with the potential to set utilization levels up to the standards identified in the Forest Plan.

• Alternative 3 (No Grazing/No Action) proposes to end livestock grazing in the project area.

As discussed on pages 18 through 20 in chapter 2 of the 2013 Draft Supplement, four issues were identified from comments during the scoping period. Those issues were addressed through refinements in Alternative 1 (Proposed Action), which eliminated the need to develop additional alternatives regarding those issues. The refined Alternative 1 (Proposed Action) was included in the DEIS for review and comment.

In addition to the issues identified from scoping, we received requests to develop alternatives that addressed specific concerns. These requests suggested that we develop alternatives that addressed weed infestation, reduce stocking rates, and minimize harm to ground dwelling animals. These alternatives were not considered in detail for several reasons. The suggestion to develop a weed infestation alternative would not meet the purposed and need for this project and weed infestations are being addressed by Alternative 1 (Proposed Action) through a passive restoration process. Rather than actively attacking weed infestations, Alternative 1 (Proposed Action) proposes livestock management under terms and conditions that will reduce selective foraging on native plants, allowing them to compete better with undesired plants. The suggestion to develop an alternative that reduces stocking rates was not considered in detail because it is how livestock are managed, not simply the number of livestock, that controls the effects of livestock grazing. The effects of grazing are controlled through timing, intensity, and duration. Reducing stocking rates without taking these factors into consideration would not result in any predictable outcome. The suggestion to develop an alternative to minimize harm to ground dwelling animals was not considered in detail because it is addressed by Alternative 1 (Proposed Action), which includes a design feature that prohibits concentrated livestock use near important habitat for wildlife, including ground dwelling animals. Sage grouse are protected by a 0.5 mile buffer around nests or leks. Pygmy rabbits are protected by a 100 foot buffer around their burrows. Mammals and birds that use aspen and riparian habitats are protected by 0.25 mile buffers around those habitats.

WWP62 We ask that the Forest make a fresh start, and analyze a broad range of alternatives and abandon the loose, uncertain and behind closed doors adaptive management, and the desired conditions. Specific sideboards should be placed on any Adaptive actions, and specific responses must be triggered by specific violations should be considered under a range of alternatives examined here.

Forest Response: Alternative 1 (Proposed Action) provides a very structured and predictable approach to livestock management in the project area. This alternative includes triggers designed to maintain and improve the rangelands and prescribes predetermined adjustments to respond to changes in condition. Violations of the terms or conditions in the term grazing permits, allotment management plan, or annual operating instructions are handled administratively under the Forest Service Handbook 2209.13, 19 – General Administration of Grazing Permits.

WWP91 If the Forest indeed is going to be basing any grazing decisions on current science, then both the upland and riparian standards it proposes are very excessive and a greatly revised DEIS with new more conservative standards must be prepared.

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Forest Response: The utilization levels were developed based on an exhaustive review of available scientific literature. An annotated bibliography of this review is included in the project record.

WWP170 We propose large areas of significant habitats (sage-grouse and pygmy rabbit habitats, bighorn sheep, pinyon jay), must be evaluated for conflcits and closure in a greatly revised EIS.

Forest Response: Alternative 3 (No Action/No Grazing) would end grazing in all of these areas, addresses all of these concerns, and analyzes the effects of removing livestock grazing from these areas.

WWP208 Please apply these principles to development of a wide range of suitable alternatives in an EIS that examines all direct, indirect and cumulative adverse impacts of livestock grazing in the EIS area. …

This new process must fully evaluate a reasonable range of alternatives that will conserve, enhance and restore habitats and populations. This process must recognize the importance of conservation of native vegetation communities as habitat for declining, rare and imperiled species and many kinds of migratory birds. …

Forest Response: As part of their comments on the Draft Supplement to the FEIS for the Ely Westside Rangeland Project, WWP included an appendix entitled “Appendix B - Alternative to Protect Forest Resources from Cattle (and Potential Treatment) Irreversible harms”. Over the next 14 pages of the comment letter, WWP offers suggestions for different ways to manage the National Forest System lands in the project area. WWP requests a new alternative be crafted for this project incorporating all of their suggestions.

According to Forest Service regulations, an “alternative should meet the purpose and need and address one or more significant issues related to the proposed action.” 36 CFR 220.5(e).

To facilitate a thorough review of WWP’s suggestions, the alternative was reviewed and the elements of the alternative were identified. The action elements were then considered to determine if they met the purpose and need or raised significant issues related to the proposed action that are not already addressed by another alternative. The purpose and need is addressed on pages S-5 and S-6 of the Draft Supplement as follows:

The purpose of the proposed federal action is to authorize livestock grazing under terms and conditions designed to sustain and improve the health of the land and protect essential ecosystem functions and values. The need for the proposed federal action is to allow these allotments to continue to contribute to the overall desired Animal Use Month (AUM) production for the Humboldt National Forest while improving the gap between existing and desired rangeland conditions.

The consideration of these elements is documented below. All elements that are part of the alternative were identified under comment WWP208. Each alternative element is given a unique number so it can be individually addressed and tracked. The discussion on each alternative element considers whether the element meets the purpose and need for this project and identifies the issue raised by the element.

WWP also commented on the range of alternatives during the comment period on the 2011 DEIS. Please refer to comments WWP6, WWP62, WWP91, and WWP170 and the responses from the Forest for more information on the range of alternatives.

WWP208a

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The Forest should consider merging pastures, and removing fencing. What sense do all these tiny little allotments – and tiny little pastures make? They just allow more intensive concentration and disturbance that is harmful to sage-grouse and watersheds.

Forest Response: Pastures and fencing are used to control the movement and distribution of livestock. Pastures are subdivisions of the larger allotment and help ensure that livestock movements and grazing are conducted in an orderly fashion and in a manner that protects the various resources in the allotment. Discontinuation of the use of pastures and fencing coupled with the very low levels of utilization in your suggested alternative would require livestock to be removed from the allotment, not just a particular pasture, almost as quickly as they enter the allotment. Managing the allotments in this manner would substantially limit the ability of the project to contribute to the overall desired animal use month production for the Forest. This is one of the elements of the purpose and need for this project. See section 1.3 Purpose and Need for Action. Because your suggestions would require removal of livestock almost as quickly as they enter the allotment, your suggested alternative is essentially equivalent to Alternative 3 (No Action/No Grazing), which would also remove all range developments.

Properly designed pastures and fences help distribute livestock use over larger areas and reduce impacts from concentrated use. Alternative 1 (Proposed Action) contains numerous design features that protect resources from impacts from concentrated livestock use or the timing of livestock use. Pastures and fencing are two tools that are used to make the design features effective.

WWP208b Please focus on removal of disturbances or livestock developments/facilities promoting degradation; that are sources for weed invasion and spread; are promoting degradation of habitat components of food, covers, space and habitat security; that promote habitat fragmentation; that promote diseases like West Nile viruses, etc.

Forest Response: This suggestion is already being addressed by one of the alternatives that are being considered in detail for this project. Alternative 3 (No Action/No Grazing) would remove existing improvements over time that are no longer functional or needed including interior fences, cattleguards, and water developments as allowed by funding and management priorities.

WWP208c Protect remaining relatively intact sagebrush habitats and arid forest habitats.

Forest Response: This suggestion is already addressed by the alternatives that are being considered in detail for this project. Under Alternative 1 (Proposed Action), grazing would be allowed at sustainable levels based on a habitat group’s current ecological condition. Utilization levels are prescribed under this alternative to ensure that rangeland conditions and the habitats they provide are maintained in desired condition or are moving toward desired condition. Under Alternative 2 (Current Management), the Forest and permittee can always work together to make adjustments to protect rangeland conditions and the habitats they provide. Under Alternative 3 (No Action/No Grazing), livestock grazing would not be authorized and therefore there would be no impacts to sagebrush or arid forest habitats from livestock grazing.

WWP208d Enable passive restoration of lands “at risk” of weed invasion and/or suffering degradation or facing further losses of native species. This will better buffer these lands from adverse impacts of climate change effects. The agency must act to manage lands as an important stronghold for sagebrush species.

Forest Response: This suggestion is already being addressed by two of the alternatives that are being considered in detail for this project. Rather than actively attacking weed infestations,

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Alternative 1 (Proposed Action) proposes livestock management under terms and conditions that will reduce selective foraging on native plants, allowing them to compete better with undesired plants. Alternative 3 (No Action/No Grazing) would not allow livestock grazing in the project area. Livestock would no longer forage in the project area and native plants would be allowed to compete better with undesired plants.

WWP208e Provide for active restoration. Active restoration specifically includes the removal of harmful livestock facilities (and often linked roads) or other developments that may be damaging important, sensitive and imperiled species habitats, species populations, and watershed and other ecological processes. Actions include removal of harmful fences and water developments (wells, pipelines, troughs, water haul sites – no water hauling can be allowed), salt/supplement sites, and associated roading or other disturbance. These sites of more intensive livestock disturbance (and often associated motorized activity) serve as epicenters for initial weed invasion and then subsequent outward spread – including by livestock as weed vectors, and in the trampling and other disturbance livestock cause across arid landscapes. The concentrated disturbance at these sites promotes degradation and weeds. The spread of weeds outward from these sites incrementally eats away at the fabric of the sagebrush and arid ands ecosystem. It degrades crucial habitat components required by sage-grouse, pygmy rabbit and other wildlife. These disturbed sites promote habitat for nest and egg predators that are a particular problem to sage-grouse or migratory birds. Examples of active restoration to address this: Restoration of sage-grouse nesting, brood rearing, winter habitat where habitats are altered and degraded by facilities, developments and linked roading.

Provide for active restoration of crested wheatgrass seedings, past sagebrush destruction projects like mowing/Lawson aerating, etc. and cheatgrass or other exotic species areas. Understories must be protected from undergoing further weed expansion. Under no circumstances should you undertake any mowing, hacking, herbicide thinning (like Tebuthiuron), Lawson aerating, or any other destruction of native sagebrush or other shrub vegetation here. Trees must be handcut, to reduce disturbance and weed spread, and also adverse effects of herbicide use, as well.

Forest Response: The suggestion to provide for active restoration is outside of the scope of the purpose and need for this project. WWP also commented on the range of alternatives during the comment period on the 2011 DEIS. Please refer to comments WWP64, WWP88, and WWP103 and the responses from the Forest for more information regarding active restoration.

WWP208f We request that agencies also consider designation of ZAs, RNAs, ACEC, or series of protected areas here. We have already requested this be considered in comments on the Sage-Grouse EIS process, but urge its site-specific consideration and adoption here, as part of this current process. The sage-grouse population in this area is very small and depressed, and be-set by grazing, OHV and other disturbances during critical periods of the year. Integrated management of irreplaceable and weed-vulnerable irreplaceable natural values is essential.

Forest Response: Creation of a research natural area (RNA) or other special areas is generally considered during the forest planning process and is outside of the scope of this project. See Purpose and Need, section 1.3 in the 2013 Draft Supplement. Furthermore, there are already two RNA’s in the project area (see pages 311-312 in 2013 Draft Supplement).

WWP208g Please then act to remove or greatly reduce livestock conflicts with species needs for food, covers, space, water and habitat security.

Forest Response: This suggestion is already addressed by the alternatives that are being considered in detail for this project. Under Alternative 1 (Proposed Action), grazing would be

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allowed at sustainable levels based on a habitat group’s current ecological condition. Utilization levels are prescribed under this alternative to ensure that rangeland conditions and the habitats they provide (including food, cover, space, water, and habitat security) are maintained in desired condition or are moving toward desired condition. Under Alternative 2 (Current Management), the Forest and permittee can always work together to make adjustments to protect rangeland conditions and the habitats they provide. Under Alternative 3 (No Action/No Grazing), livestock grazing would not be authorized and therefore there would be no grazing impacts to rangeland conditions of the habitats they provide.

WWP208h Please develop alternatives (in any areas where grazing occurs) that significantly reduce livestock grazing to levels below actual use in that land area.

…

Typically, a 10-15% upland utilization must be put in place. It must be measured at sites that are actually used to a significant degree by livestock.

Forest Response: Setting utilization at the suggested levels would be arbitrary. There is no basis for setting utilization at these levels except that they are lower than the utilization levels that would be authorized under Alternative 1 (Proposed Action) or Alternative 2 (Current Management). Measuring utilization at sites that are used “to a significant degree” would create a system that would effective require livestock to leave an area almost as soon as they enter the area. Your suggestion to remove all range developments would allow livestock use to concentrate more quickly than it would under either of the action alternatives, which would create a situation where your proposed utilization levels would be reached very quickly.

Your suggestion to consider lower utilization levels is partially addressed by Alternative 1 (Proposed Action), which sets moderate utilization levels based on end of season measurements. This represents a shift from current management, which often allows for higher utilization. Alternative 1 (Proposed Action) also provides for reduced utilization and streambank disturbance levels when rangelands are not in desired conditions. The moderate utilization levels and reductions based on rangeland conditions are based on a substantial review of scientific literature discussing the effects associated with varying levels of utilization. While lower utilization levels could be applied to grazing in the project area, there is no scientific rationale to significantly reduce utilization levels below the levels proposed in Alternative 1 (Proposed Action). Alternative 3 (No Action/No Grazing) would not authorize grazing in the project area, which would result in no livestock utilization in the project area.

WWP208i This must be coupled with avoidance of any grazing/trailing disturbance during sensitive periods of the year - including during nesting, brooding, birthing and wintering periods.

Forest Response: This suggestion is already being addressed by two of the alternatives that are being considered in detail for this project. Alternative 1 (Proposed Action) contains design features that specifically address and minimize impacts from grazing to a variety of wildlife species (see page30 in 2013 Draft Supplement). These design features address to the location and timing of grazing in areas important to wildlife in the project area. For the most part, livestock would not be present in the project are in the winter. The exception is in the Cherry Creek Allotment, where the permittee is authorized to trail sheep for a two-week period each winter. The utilization standards applied under Alternative 1 (Proposed Action) ensure adequate residual vegetation is preserved for wildlife needs in the winter.

Alternative 3 (No Action/No Grazing) would not allow livestock grazing in the project area and livestock would not be authorized in the project area during nesting, brooding, birthing and

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wintering periods.

WWP208j These conservative levels of use must include both riparian and upland trampling standards. Please include standards that protect microbiotic crusts, understory components and sagebrush/shrub structure. In order to prevent annual exceedances, these standards must serve as triggers for livestock removal from the land area being grazed. The use standards must be mandatory, and be required to be met annually.

…

Please also apply an upland trampling standard to limit disturbance to soils, microbiotic crusts, and native plants including seedlings. This must require less than 5% livestock trampling of the area of a square meter monitored at representative typically grazed sites across the pasture.

…

No areas of the allotment, including those receiving the most intensive use, should be allowed to receive greater than 10% of the surface area being trampled.

Forest Response: WWP has previously suggested and the Forest has already considered trampling standards for this project. See responses to WWP92 and WWP116. Like your suggested utilization levels discussed in response to comment WWP208h, livestock would be required to leave the pasture almost as soon as they enter the pasture. The average size of the hoofprint of a cow is 208 square centimeters. (USDI BLM 2011) This means that your suggested trampling standard could be exceeded if there are more than two hoofprints in a square meter that is representative of a typically grazed site in a pasture.

Alternative 1 (Proposed Action) sets utilization on herbaceous and woody vegetation at moderate levels measured at the end of the grazing season. Alternative 1 (Proposed Action) also provides for reduced utilization levels when rangelands are not in desired conditions. The moderate utilization levels and reductions based on rangeland conditions are based on a substantial review of scientific literature discussing the effects associated with varying levels of utilization. Livestock grazing at these levels is designed to protect soil resources, microbiotic crusts, understory components, and sagebrush/shrub structure. Because these resources are protected by the utilization levels proposed in Alternative 1 (Proposed Action), separate standards for each of these resources is unnecessary. For example, the proposed moderate utilization levels would lead to lower levels of soil compaction and disturbance of soil crusts because livestock would be moved from the area due to the utilization triggers on herbaceous and woody vegetation before soil impacts become excessive. Understory components (herbaceous vegetation) are directly protected because the triggers for livestock movement are measured based on the use of these components. Like soil resources and soil crusts, sagebrush/shrub structure would be protected because livestock would be moved from the area due to the utilization triggers on herbaceous and woody vegetation before structure impacts become excessive. The utilization levels in Alternative 1 (Proposed Action) are mandatory, include within season triggers that prompt the movement of livestock from the area, and must be met every year.

Alternative 3 (No Action/No Grazing) takes a very conservative approach and would not authorize grazing in the project area. This would remove all livestock use and disturbance from microbiotic crusts, understory components, and sagebrush/shrub structure.

WWP208k The agency must commit to annual during and after grazing period timely monitoring, or livestock cannot be grazed. Monitoring sites must be based on use pattern mapping, and must reflect areas that are receiving significant livestock use. It is these areas that are the “weak link” and provide inroads for invasive species and their subsequent inevitable expansion in grazed arid lands.

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Forest Response: This suggestion has already been addressed in Alternative 1 (Proposed Action), which proposes short-term monitoring that requires annual compliance monitoring on every allotment where grazing is authorized that year. Compliance monitoring includes within season trigger observations and end of season observations on proper use criteria (utilization and streambank alteration). See Section 2.2.1.4. Monitoring in the Final Supplement for additional details on the monitoring proposed in Alternative 1 (Proposed Action). Monitoring would be done at key areas, which are selected, in part, but considering use pattern mapping. See Appendix E in the Final Supplement for additional information on the selection of key areas for monitoring.

WWP208l Only one grazing disturbance bout (including trailing) can be allowed annually in a land area. Otherwise, “double dipping” – or repeated use of vegetative resources and multiple disturbances to soils, wildlife, watersheds, etc. occur. Multiple use periods are harmful to sage-grouse, native vegetation, soils, microbiotic crusts, watersheds, etc. Under repeated grazing bouts in the same year, total forage use may significantly exceed the percentage that is allowed. This is due to plants re-growing between grazing bouts. Trailing should not be allowed back through areas that have been grazed.

Forest Response: No action alternative in this project would allow authorized use levels to be exceeded. Forage utilization is examined in two ways: within season and end of season. Within season triggers require livestock to be removed from an area. Regrowth in that area can increase the available forage in a way that can accommodate additional grazing in that area at a later time. However, no action alternative would allow grazing (regardless of the number of entries) to exceed the established end of season levels. Therefore, there is no need to prohibit multiple entries into an area because the within season triggers and end of season utilization levels must always be met.

WWP208m Livestock should be moved into areas all at one, and out of areas all at once. Do not have multiple herds moved into and out of pastures – as this causes even further disturbance to lands the livestock transit through, and it is impossible to tally how many livestock are actually being grazed.

Forest Response: These actions, and the need for these actions, would be considered in the Annual Operating Instructions under any action alternative. They are administrative in nature and generally not included in an alternative. Furthermore, moving all the livestock into an area at one time may actually increase impacts as the herd’s propensity to trail concentrates their impacts into a smaller area. Actual numbers can be confirmed at any time during the grazing season through allotment inspections.

WWP208n All livestock should have agency-issued ear tags or other methods so that BLM can verify stocking.

Forest Response: All animals are branded according to state law, so they are already marked and can be identified for stocking purposes.

WWP208o There must be no grazing disturbance during active or critical growing periods for native grasses and forbs.

Forest Response: The action alternatives in this project already protect native grasses during active and critical growing periods. The action alternatives apply range readiness criteria to determine when grazing can be initiated on the allotment. The range readiness criteria consider

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the key plant phenology of native grasses and other vegetation. See Appendix G of the 2014 Final Supplement for examples of the range readiness indicators that would be included in the new Allotment Management Plans that would be developed if Alternative 1 (Proposed Action) is selected.

WWP208p Stocking levels … must be properly applied so that these standards can be met during every grazing disturbance episode.

Forest Response: If your suggested alternative is carried forward and selected, the need to address stocking levels would be addressed at that time based on the management direction included in the selected alternative.

WWP208q [r]equirements for active herding must be properly applied so that these standards can be met during every grazing disturbance episode.

Forest Response: Herding, and the need for herding, would be considered in the Annual Operating Instructions under any action alternative. The requirement to actively herd is administrative in nature and generally not included in an alternative.

WWP208r Five to 10 years of rest of pastures with damaged riparian resources must be fully considered to jump start recovery, and prevent further degradation.

Forest Response: As the analysis in the Final Supplement indicates, many of the riparian resources in the project area are in less than desired condition. See table 7 and Section 3.4.2.4. Existing Condition By Allotment in the Final Supplement. Your suggestion would mean the closure of every allotment in the project area for 5 to 10 years. Closing the allotments for an extended period of time has been addressed in Alternative 3 (No Action/No Grazing), which would not authorize grazing on any allotment in the project area.

Alternative 1 (Proposed Action) addresses riparian resources that are in less than desired condition by providing for reduced utilization and streambank disturbance levels when riparian resources are not in desired conditions. The moderate utilization levels and reductions based on riparian conditions are based on a substantial review of scientific literature discussing the effects associated with varying levels of utilization.

WWP208s All of these standards must be applied as triggers for immediate removal of livestock from the pasture. If the use level is reached, the livestock must be moved out.

Forest Response: See response to WWP208j.

WWP208t In all instances of avoidance, livestock use must not be shifted and intensified into other fragile sites or vegetation communities, or other rare species impacted. Reductions, not shifted use, must be employed.

Forest Response: This project considers whether to authorize grazing on the 12 allotments in the Ely Westside Project area and, if so, under what terms. The terms of your suggested alternative apply equally across the project area. If those terms required livestock use to be shifted or intensified in other areas, that shift or intensification would have to be to allotments outside of the project area. Because this project is not considering grazing in other areas, it could not authorize grazing in those other areas.

WWP208u

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Do not rely on the complex “State and transition” models, and other deficiencies of the flawed NRCS Ecosites currently in vogue.

Forest Response: See response to WWP209.

WWP208v Do not rely on Ecosites to an extreme - as these are often fraught with range biases. Especially do not rely on them to destroy native plants to meet some kind of ideal site.

Forest Response: See response to WWP209.

WWP208w Dead livestock must be removed from BLM lands.

Forest Response: How BLM chooses to manage its grazing allotments is outside the scope of this project. Forest Service grazing permittees are required to move dead livestock away from particular resources, but they are not required to remove them from the allotment. However, Alternative 1 (Proposed Action) already limits the presence of livestock in areas where sage grouse are actively nesting or brood-rearing, so the potential for dead livestock to attract predators to these areas has been addressed.

WWP208x No calving operations can be allowed on public lands. This will help control mesopredators.

Forest Response: Calving operations occur in the spring, before the grazing seasons for any of the allotments in the project area. Therefore, no calving operations would occur under any of the alternatives for this project.

WWP208y No sheep camps in or near any sensitive habitats Sheep camp sites must be sharply limited, and identified in advance. One-time intensive sheep concentration can destroy native vegetation and promote weed proliferation.

Forest Response: Sheep grazing is authorized on the Cherry Creek Allotment, but only in a limited manner. The permittee is authorized to use the allotment in the winter for no more than 2 consecutive weeks, total. No camp is authorized or associated with this sheep grazing permit.

Rangeland Management

Sub Topic: Adaptive Management WWP7 We are greatly disappointed that the Forest continues to pursue a highly uncertain loose and open-ended adaptive management grazing scheme

Forest Response: Alternative 1(Proposed Action) was designed to provide more predictability with regard to the management actions that would be taken on livestock grazing in the project area. Alternative 1 (Proposed Action) identifies specific proper use criteria (for this project, utilization level and stream bank disturbance) for each of the various habitat groups in the project area based upon their ecological condition. For example, if a wet meadow is determined to be in functioning ecological condition, herbaceous utilization could be allowed up to 45 percent. However, if the ecological condition of a wet meadow is found to be functioning-at-risk, herbaceous utilization could only be allowed up to 35 percent. See table 9 on page 38 of the 2013 Draft Supplement. Ecological condition would be determined using the Humboldt-Toiyabe National Forest’s Ecological Condition Matrices (Matrices), which are included as part of the

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2011 FEIS in appendix A. The Matrices are based on field research, literature reviews, and relevant parts of some of the National Resources Conservation Service (NRCS) ecological site descriptions. The criteria and process included in the Matrices were reviewed by peer scientists.

Other livestock management tools are identified in appendix F of the 2011 FEIS. These management tools would be employed on a case-by-case basis; some would require additional environmental analysis before they could be used.

WWP61 The “adaptive management” envisioned here will allow for political maneuvering by the livestock industry. It shuts the public out from critical parts of this process, as changes can be made hidden from public scrutiny and oversight.

Forest Response: The adaptive management components of Alternative 1 (Proposed Action) are discussed in the response to WWP7. Alternative 1 (Proposed Action) also increases the transparency of livestock management in the project area by requiring the preparation of an annual report summarizing management actions, monitoring, and allotment administration. This report would be completed annually and distributed and/or made available to livestock permittees, state and federal agencies, county and tribal governments, other cooperators, and interested individuals. See page 47 of the 2013 Draft Supplement.

Sub Topic: Capability/Suitability WWP8 [W]hile planning to stock lands across the extremely rugged and arid Westside not capable of withstanding livestock effects even under the agency’s own definitions

Forest Response: The project area has been modeled recently to determine its capability to provide forage for domestic livestock grazing at the Forest level. This modeling effort confirmed the 1986 Forest Plan’s determination that the lands in the project area have this capability. The model used USDA Forest Service Regional protocols. The model identified lands capable of providing forage for domestic livestock grazing in every allotment in the project area. After reviewing the forest level modeling results, the IDT determined that the forest level analysis was sufficient for this project’s capability determination. This modeling effort is discussed on pages 12-13 of the 2013 Draft Supplement and supported by the following documents in the project record: Summary of Capability/Suitability for Livestock Grazing and MIS Analysis Associated with 36 CFR 219.20 during Humboldt Forest Planning Effort (2008), Management Indicator Species (MIS) and Range Suitability/Capability Analysis-Humboldt National Forest Updated MIS Monitoring Report (2008), and Ely Westside Rangeland Project Rangeland Capability and Suitability Report (2011).

Modeling efforts to identify capable grazing lands are not an attempt to define land that is capable of being grazed under all possible management intensities, prescriptions, management scenarios, etc. It does not attempt to define areas that should never be exposed to the presence of livestock. It provides a reasonable, conservative assurance that the areas of land depicted are capable of being grazed. It does not define nor depict decisions that lands not displayed as capable are incapable of being grazed or should not be managed for livestock grazing. The models were used to estimate the amount of national forest rangelands that would provide a forage base for supporting livestock grazing under typical management scenarios and conservative grazing management practices. Not identifying an area as capable does not mean it cannot be crossed by livestock or that some forage cannot be removed by livestock. For example, in areas with enough tree canopy to reduce forage production to less than 200 lbs/acre, it does not mean livestock could not or should not pass by or remove some forage while passing by. It just means the area was not

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deemed to have enough forage production to be used as a base for determining grazing capacity.

The 2013 Draft Supplement describes the effects of grazing on all grazed lands on the allotments, not just lands identified as “capable” by the modeling efforts cited above or the capability analysis included in the Ely Westside Rangeland Project Rangeland Capability and Suitability Report (2011). Management direction developed to deal with grazing impacts to rangelands, which include Forest Plan standards and guidelines, desired conditions, etc., also apply to all lands within the allotments.

WWP19 It must take a “hard look”, and provide sound analysis that is incorporated into a … suitability analysis.

Forest Response: The Ely Westside Rangeland Project Rangeland Capability and Suitability Report (2011) includes an analysis of the suitability of livestock grazing in the project area. Over 3,400 acres in the project area were identified as unsuitable for livestock grazing. The unsuitable areas include two research natural areas, three Forest Service administrative sites, a reclaimed mine site, and California Springs (on the Treasure Hill Allotment).

WWP40 Actual grazing use and real world stocking also must be factored into understanding of the capability analyses (rangeland, MIS, sensitive and other species) and the suitability analysis.

Forest Response: Actual grazing use and stocking rates are arrived at as a result, in part, of rangeland capability and suitability determinations.

WWP47 ALL of this info must form the basis of modern day capability and suitability analyses, and understanding capable habitats and sustainable levels of grazing use (if any) in arid lands.

Forest Response: The capability and suitability of the rangelands in the project area to provide forage for domestic livestock grazing was evaluated at the time of the development of the 1986 Humboldt Land and Resource Management Plan and again in 2008 using current regional protocols at the Forest and project level. The effects of grazing on the spread of cheatgrass and other invasive plant species have been addressed in response to comment WWP44.

WWP69 How much do mature cows now weigh? 1000 lbs, or more? What was the weight of a cow factored into old forage inventories and old AUM calculations? Or soil damage and loss calculations? When AUM conversions were done? What was the cow and cow:calf pair water consumption factored into previous stocking rate analyses? How has this changed? What flows at springs and seeps are necessary to supply herds? What rate was used in understanding how to apply any capability analysis? How will continued grazing destroy the ability of these lands to serve as habitat for species displaced from lower elevations due to climate change?

Forest Response: For the purpose of analyzing Alternative1 (Proposed Action), these questions are largely irrelevant. Allotments would be managed based on ecological conditions, not the forage requirements based on the size of livestock. If livestock are bigger today and require more forage, then under Alternative 1 (Proposed Action) that would result in fewer numbers or a shorter season, not additional utilization. The relationship between allowable utilization and the length of season desired by the permittee would guide decisions on stocking levels. Range capability does not use water quantity as part of the modeling protocol; it uses distance from water. When capability was modeled for the Analysis of the Management Situation, the value for distance from water was one mile. When range capability was modeled in 2008, the value for distance from water was one mile.

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WWP97 These documents [on range capability/suitability] should have been provided as appendices for full review as part of the DEIS, and their content used and described in EIS discussions of baseline conditions, evaluating alternatives, and alternatives analysis. Failure to do so thwarts knowledgeable commenting.

Forest Response: Commented noted. Rangeland capability is not a decision to graze and is determined at the Forest Plan level. Suitability analysis identifies areas within the capable land base where grazing is appropriate in the context of other land management considerations. These documents are referenced on page 12 of the 2013 Draft Supplement and copies are available on request.

WWP98 The OLD numbers were the basis for the forage allocation and stocking rated/permitted AUMs. Now under the new analysis, at a minimum, livestock numbers should be much reduced, since 200 lbs, per acre, not 50, is now used.

Forest Response: The pounds of forage per acre were not the only difference between the Forest Plan modeling protocols and the current Region 4 capability protocols. Under current modeling protocols, steeper slopes are considered capable. Different data sets and modeling methods (use of GIS software) were also used. Accordingly, looking at the difference between one of the criteria that was considered in the two modeling efforts is not necessarily a good way to predict the outcome of those efforts. The 2008 modeling effort was not used to recalculate capacity and consequently, stocking rates. Alternative 1 (Proposed Action) is designed to make management adjustments based on the ecological conditions in an allotment. See also responses to comment WWP7, 5, 8, 28, 31, 32, 41, and 62.

WWP99 The Forest has largely ignored consideration of current ecological science related to livestock disturbance effects on microbiotic crusts, watershed processes, sage grouse and pygmy rabbit habitat conditions and population needs, aquatic conflicts, the degree and severity of current degradation, decline and losses in water quantity/flows, effects of water developments in disrupting ecological processes, etc. in arriving at any suitability determination here.

Forest Response: The suitability analysis for this project did not result in any changes from the suitability determination made at the Forest level during the forest planning process.

WWP167 This demonstrates that a modern-day suitability analysis that identifies wildlife, fisheries and other concerns must be conducted …

Forest Response: We disagree with your interpretation of the definition of suitability and the process for determining it. The suitability of lands within the Humboldt National Forest for livestock grazing was analyzed when the current Forest Plan was developed. See Summary of Capability/Suitability for Livestock Grazing and MIS Analysis Associated with 36 CFR 219.20 during Humboldt Forest Planning Effort (2008) in the project record for a detailed summary. There is no requirement to conduct an additional analysis at this time. As with capability, suitability is not a decision to authorize grazing in a particular area. Rather, suitability looks at lands and determines if livestock grazing is incompatible with other individual or combined management practices.

The desk guide you are quoting from was designed for forest planning efforts, not project-level analysis such as the 2013 Draft Supplement upon which you are commenting. Typically, suitability decisions are made at the Forest Plan level, but they can be done at the project or

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allotment level. Suitability is established either to provide prescriptive management direction for project-specific analysis and subsequent NEPA decisions, or as a decision not to graze specific designated areas. Suitability issues are typically broad in scope and extend across a larger landscape than a single allotment.

WWP168 Aspen and other vegetation communities are on steep slopes, and so are not readily used, especially in their interior, by livestock. The communities that ARE most accessible are almost all uniformly degraded.

Forest Response: As you point out, cattle cannot access these areas and they will not be grazed. As for the aspen stands that can be grazed, Alternative 1 (Proposed Action) contains utilization levels that are designed to maintain or improve their ecological condition.

WWP169 WWP requests that the Forest undertake analysis to determine unique, special and important values of habitats – similar to RNAs or other natural type areas, and analyze this under the alternatives in a greatly revised EIS. This is critical because Ecoregional analyses of “special” areas have not bothered to take a hard look at much of the Ja area.

Forest Response: The 2013 Draft Supplement and the supporting specialist reports considered the habitat values of many species that use or are thought to use the project area. Creation of a research natural area (RNA) is generally considered during the forest planning process and is outside of the scope of this project. See Purpose and Need, section 1.3 in the 2013 Draft Supplement. Furthermore, there are already two RNA’s in the project area (see pages 311-312 in 2013 Draft Supplement).

WWP171 We stress that a portion of this guidance appears to unlawfully constrain the kind of alternatives developed, and give the impression that only 3 alternatives be analyzed. This part of this Guidance does not comply with NEPA.

Forest Response: This guidance applies to the preparation of forest plans and the environmental analysis conducted for that effort. See response to WWP167. Page G.13 of the desk guide from which you are quoting states:

The Forest must analyze and disclose environmental and economic consequences, and alternative uses foregone. The following is a suggested minimum; analysis and documentation, and should be modified as need to fit each specific situation.

WWP172 How does the Forest deal with woody vegetation here? Is it considered part of “production” in a livestock use-only sense? If so, does this mean livestock are supposed to be consuming a significant amount of sagebrush – or juniper? What did the Ely RD use?

Forest Response: Regional capability/suitability analysis standards for production are 200 lbs/acre and were followed in the Ely Westside analysis. Not all low productivity lands are deemed non-capable, and those that are will still receive some transitory use during the grazing season, which is expected and acceptable. Utilization of woody browse is acceptable and included in the production figures. Livestock will use sagebrush but due to its low palatability will generally not target it. The Ely Westside capability/suitability analysis followed regional standards and guidelines, which determines if there are capable and suitable lands for livestock grazing in the project area and not if livestock will graze said lands.

WWP173

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WHY hasn’t the specific methodology in deriving maps been prominently displayed in detail in association with all parts of the environmental analysis of the EIS and alternatives development?

Forest Response: The EIS endeavors to be a summary of the technical information that was considered during its preparation. As such, many technical descriptions and models have not been included in the EIS. The information you are referring to is in the project record and available upon request.

WWP174 So how has the HT Forest been regulating use of unsuitable and/or uncapable lands in the past? How much of the Monitoring data has been collected on unsuitable lands that the Forest has been allowing grazing on? We are betting almost none. The current EIS is nearly devoid of data or effects of grazing damage to unsuitable lands.

Forest Response: As noted on page 4 of the Summary of Capability/Suitability for Livestock Grazing and MIS Analysis Associated with 36 CFR 219.20 during the Humboldt Forest Planning Effort (2008), the criteria and definition for capability were basically synonymous with suitability. The clearer distinction that is addressed in the 2002 desk guide you referenced earlier in your comments was not being applied to our forest planning effort in the mid-1980s. The relative value of identifying capable acres was addressed in response WWP8. The 33,000 acres that were identified as “unavailable” were the areas that the 2002 desk guide would screen out through a suitability analysis. The Forest has not been authorizing grazing in these “unavailable” or unsuitable areas. The Forest does not conduct grazing monitoring on the steep hillsides, rock outcrops, or other areas where there is no or virtually no utilization.

WWP175 WHERE is detailed mapping showing this info at the time of the plan, and the detailed systematic studies required to show this at present? This all must be presented to the public, including with each alternative so that a “hard look” can be taken at the environmental consequences.

Forest Response: We do not have the original maps from when the Forest Plan was developed in the mid-1980s. In 2007, a modeling effort was conducted using current information. The results were similar to those identified in the forest planning effort. Maps and modeling criteria are included in the Management Indicator Species (MIS) and Range Suitability/Capability Analysis- Humboldt National Forest Updated MIS Monitoring Report (2008), and project-level modeling is available in the Ely Ranger District Rangeland Management Project Capability and Suitability Report (2009). Both of these documents are included in the project record.

WWP179 So what happened in all these years as permitted AUMs (actually fewer if the Forest honestly addresses its actual use levels) were grazed? Across nearly all the landscape, meadows, springs, seeps and many riparian areas did not improve. Trampling promoting bank collapse and erosion, headcutting and other adverse livestock effects progressed, and habitat potential has been lost. Improvement on heavily monitored areas of streams elsewhere in the Forest appears to be due to ESA listing and closer FWS scrutiny and hence more forest monitoring and lower livestock use levels under Amendment 2 requiring triggered moves.

Forest Response: The existing ecological condition of the riparian areas (including meadows, seeps, and springs) is discussed allotment by allotment in the Vegetation section (pages 132 to 146) of the 2013 Draft Supplement. In light of the-site specific information relied upon to determine the existing condition, it would be an overstatement to claim improvement or lack thereof across nearly all the landscape.

There does appear to be an appreciable difference in the improvement visible on areas where Amendment 2 sets lower utilization triggers. As discussed in response to comment WWP31,

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neither action alternative would change the applicability of Amendment 2. The fisheries information on other parts of the Forest that you refer to is one of the most compelling facts that Alternative 1 (Proposed Action) should result in maintaining the project area in or improving it to desired conditions. See response WWP95 for additional information.

Sub Topic: General WWP2 Not a single spring development, fence or any other harmful livestock facility or “treatment” is proposed for removal or restoration.

Forest Response: Active restoration projects identified through this analysis are outside the scope of this project and require additional NEPA.

WWP24 We ask that the forest consider a requited rest period of 10 years following wildfire to allow recovery of microbiotic crusts, shrub structure to some degree to trap and treating moisture on site, and other plant community attributes essential to provide a healthy native vegetation community in a desertified landscape undergoing significant climate change effects.

Forest Response: The Forest Plan requires 2 years of rest from livestock grazing after a fire. All alternatives for this project are consistent with that requirement. Additional rest is considered on a case-by-case basis.

WWP27 The Forest cannot comply with NFMA’s capability and species viability requirements until this is done, either. If 200 cows are placed in Ellison Basin pastures where sage-grouse brood rearing habitat has been much-reduced due to loss of sagebrush next to wet meadows, and continued cattle damage to understories and shrub structure, as well as the Forest’s sagebrush eradication efforts to promote the exotic crested wheatgrass at the expense of sagebrush right by eroding stream and springbrook gullies, we can only foresee further loss and desiccation of wet meadows from grazing effects, and sage-grouse populations becoming nonviable and potential for many native aquatic species being lost. The same applies to nesting habitats.

Forest Response: These concerns are addressed by the sage-grouse design features included in Alternative 1 (Proposed Action) on page 30 of the 2013 Draft Supplement. Concerns for nesting habitat are addressed by the design feature included in Alternative 1 (Proposed Action), which delays grazing until the nesting season is at a close. In regards to brood-rearing habitat, the proposed action would improve habitat quality in wet meadows for sage-grouse due to reduced utilization in those areas.

WWP41 If only half the “permitted” AUMs have been grazed in recent years in a particular pinyon jay, golden eagle habitat or sagegrouse winter or brood rearing area, and now the Forest proposes to continue a status quo allocation that allows potentially double the actual use to occur indefinitely the effects of what would happen if permits were stocked to the maximum level must be woven into all EIS analyses, including allocation of AUMs under the EIS.

Forest Response: We acknowledge that the actual number of livestock can vary from the permitted numbers. However, we have no information to support your supposition that only half of the permitted numbers of livestock are currently grazing the allotments in the project area. Assuming for the sake of this response that only half of the permitted number of livestock is currently grazing the allotments in the project area, there is no reason to believe that number would change if one of the action alternatives is selected. If such a condition actually existed in

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the project area, it would be pure speculation to assume that permittees would suddenly start stocking to the full permitted level.

Under Alternative 1 (Proposed Action), the Forest believes the ecological conditions within the allotments are more important than the number of livestock on the allotment. Whether there are 50 or 100 head of livestock on the allotment, the end of season utilization levels and within season triggers within the various habitat groups would still be based on the ecological condition of those habitat groups. For example, if the uplands (non-riparian) in an allotment have been found to be functioning-at- risk, the herbaceous within season trigger could be 65 percent under Amendment 2 of the Forest Plan, but under Alternative 1 (Proposed Action) the end of season utilization and within season trigger for that habitat group would be set at 40 percent or lower. If there are 100 head of livestock on the allotment, then the utilization limits (both the within season triggers and the end of growing season levels) would be reached more quickly than if there were only 50 head of livestock.

WWP74 The Forest must provide detailed mapping and analysis of all livestock infrastructure, water developments including spring developments and/or diversions, de-watering-gutting projects, stock ponds, troughs, pipelines, water haul sites, etc. on Forest lands as well as adjacent BLM lands.

Forest Response: Maps 36 and 37, on pages 310 and 313 of the 2013 Draft Supplement respectively, identify the type and location of range developments in the project area. These maps are also included in appendix H of the 2013 Draft Supplement. Additional maps have been included in Appendix G of the 2014 Final Supplement that display the range developments by allotment rather than by mountain range.

WWP77 Please provide detailed actual use records (number of AUMs actually grazed vs. “paper cows” on permits) by allotment, pasture, land area and all details for all time periods available. Please also include the AUMs, stocking rates in each land area, (permitted and actual) prior to any AUM conversion. Was there an NEPA analysis, and any capability, suitability, productivity or other forage-water-resource by class of livestock analysis - conducted on the past AUM and livestock class conversion? If so, please provide us with a copy, and a supplement to the DEIS that explains how current stocking rates on paper were arrived at for all affected land areas

Forest Response: The number and head months of livestock are disclosed in the 2013 Draft Supplement (see table 6 in 2013 Draft Supplement) and a summary of annual operating instructions from 2008 through 2014 was included as appendix C to the 2014 Final Supplement. This is the best available information on actual use in the project area. Capability and the calculation of AUMs were addressed in the EIS prepared for the 1986 Forest Plan. This document considers whether to authorize grazing and if so under what terms and conditions.

WWP90 Please provide full and detailed analysis of all the times triggers for livestock movement have been exceeded over the past 20 years, and describe in detail whether livestock were moved, or if they were allowed to remain.

Forest Response: Triggers are used as guidelines to determine when movement or removal of livestock from an allotment may be warranted. Accountability is directly related to the terms and conditions of the grazing permit. A summary of the 2008 through 2014 grazing seasons including authorized use is included in Appendix C of the 2014 Final Supplement. Compliance records, notices of noncompliance, and permit actions are a part of the allotment record and available at the district office.

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WWP177 THIS sure NEVER happened in the past, and the Forest fails to even apply 30% now in 2011 –even for five miles surrounding sage-grouse leks in Core habitats, as described by Doherty et al. (2010). The Forest stocking all along has been based on use in excess of levels its own vegetation data showed were excessive. It appears at some point in this older analysis, the Forest just did not apply methods properly to arrive at stocking rates predicted here. Maybe it assumed cows would eat 3” wood saplings, or something, under “productivity”?

Forest Response: To be completely fair, in some places it has and in others it has not. Adjustments to utilization have been made on a case-by-case basis under current management. Alternative 1 (Proposed Action) provides a framework for predetermined and predictable adjustments that are supported by current scientific literature. The remaining portions of this comment are difficult to understand so no response is offered at this time.

WWP185 How many troughs are present? Are they in nesting or brood rearing/summer habitat? Brood rearing? Wintering? Which could be removed and thus reduce livestock impacts including excessive removal of residual cover required for nesting, and reduce degradation to understories from intensive disturbance associated with proximity water sources?

Forest Response: The number and location of troughs and other range developments are discussed in appendix H of the 2013 Draft Supplement (pages H-6 through H-7). This information was considered when the Wildlife sections of the 2013 Draft Supplement and the Wildlife Specialist Report were prepared for this project. Additional maps have been included in Appendix G of the 2014 Final Supplement that display the range developments by allotment rather than by mountain range.

WWP207 When were all livestock facilities put in place, and under what NEPA? Are livestock facilities? Or is NEPA lacking or very old?

Forest Response: Neither Alternative 1 (Proposed Action) nor Alternative 2 (Current Management) propose to alter existing range developments, so the previous authorizations to construct these range developments are not discussed in the 2013 Draft Supplement. Nonetheless, all available information on the existing range developments was provided to Western Watersheds Project in 2011 in response to a Freedom of Information Act request.

Sub Topic: Grazing Strategies WWP25 Analyzing stocking rate is essential not just in determining effects on soils and vegetation (to understand the potential soil erosion under various alternatives in both capable and the non-capable lands subjected to disturbance. More cows = more trampling across watersheds = more soils displaced= more erosion and sediment).

Forest Response: Analysis of stocking rates is outside the scope of this project. The proper use criteria reduce utilization and so impacts from livestock across the project area. Increasing the numbers of permitted livestock is not part of Alternative 1 (Proposed Action).

WWP131 Forest has also not adequately defined and developed protections/avoidance during the critical and active growing seasons for native herbaceous species (see Anderson 1991, BLM Technical Bulletin).

Forest Response: Alternative 1 (Proposed Action) applies utilization levels and rest or

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deferment of grazing use to address this concern.

Sub Topic: Livestock Management Activities WWP23 We stress here that the Proposed Action claims to include “rest”, and “rest” is otherwise mentioned. It is info crucial to understanding how rest or rehab or other actions be attained without undertaking at least a 50-75% reduction in the actual number of livestock actually grazed is not provided.

Forest Response: Rest as described in Alternative 1 (Proposed Action) means grazing would not be authorized in the same area at the same time for at least 1 out of every 3 years. This could be achieved through a mandated rotational grazing requirement in a deferred rotation or rest rotation system that prevents a pasture from continually being used the same time each grazing season. This system does not require any reduction in numbers of livestock.

WWP211 Please carefully examine the … economic cost-savings and value of waters wildlife and wild lands that do not suffer chronic grazing disturbance.

Forest Response: This project considers whether or not to authorize grazing and, if so, under what conditions. It is not the purpose of this project to determine the economic costs of grazing or lack of grazing within the project area.

WWP213 Please determine what compounds may be in any supplements being fed to livestock, as well as pharmaceuticals being used on livestock that may waters, and adversely impact aquatic biota.

Forest Response: Before any compounds could impact water quality or aquatic biota, it would need to reach the stream through the urine and fecal wastes of the livestock. The information in the 2013 Draft Supplement indicates that livestock urine and fecal waste is generally not reaching streams in levels that affect water quality.

As noted on page 96 of the 2013 Draft Supplement, livestock urine and fecal wastes can affect water quality in increased bacteria levels and nutrients (such as nitrates). In 2006, 38 water samples were taken from representative streams in the project area. Only one of the water samples identified elevated bacteria levels. Accordingly, there is little reason to suspect that compounds from supplements being fed livestock are impacting water quality or aquatic biota because there is virtually no evidence that livestock waste is reaching streams in the project area.

Sub Topic: Livestock Utilization WWP212 when an area “averages”/or “has a median of” 35% utilization, this means that many grass plants are actually being grazed to very harmful levels of 70% or greater. With even one time grazing use this severe, grazing livestock can severely harm or kill native bunchgrass plants by removing growing plant parts and depleting scarce root reserves. This also exposes the grass crown to winter freezing damage or summer heat-desiccation. See USDI Technical Bulletin Anderson 1991, Mack and Thompson 1982.

Forest Response: This comment is raises two points: how utilization is measured and the impact to individual plants that are grazed above the allowable maximum use level. The Forest

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Service uses the annual monitoring methodologies included in the Utilization Studies and Residual Measurements (USDI BLM 1996) and the Nevada Rangeland Monitoring Handbook (University of Nevada Cooperative Extension 2006). These documents provide scientifically defensible monitoring protocols. Your concern regarding the potential for some plants to be grazed above the maximum allowable level is noted. The converse is also true; other plants will be grazed below the maximum allowable levels or not at all. Grazing utilization is measured with this variation in mind. This project relies on a large body of scientific literature to describe the effects of livestock grazing at different utilization levels. For example, see the Overview of Impacts of Livestock Grazing on Vegetation on pages 146 through 149 of the 2013 Draft Supplement. These scientific papers consider the effects of livestock grazing when measured in the same or similar manner as the Forest Service measures and would continue to measure grazing. Accordingly, the effects analysis in the 2013 Draft Supplement regarding the impacts of livestock grazing utilization, even when some individual plants may receive higher levels of use than is indicative of the average use for an area, addresses the situation you have raised in your comment.

Sub Topic: Rangeland Condition WWP63 We note that the adverse effects of any treatments, through imposing upper limits on woody vegetation cover that is inherently diverse in the complex natural landscape (see Welch and Criddle 2003), as the Matrices do for sagebrush, is not analyzed or examined in the EIS.

Forest Response: No vegetation treatments are proposed as part of this project. Past, present and reasonably foreseeable vegetation projects are discussed in Appendix H of the 2013 Draft Supplement on pages H-16 to H-17. The cumulative effect of these vegetation treatments with the alternatives analyzed in this project are discussed in Chapter 3 of the 2013 Draft Supplement by resource, as appropriate.

WWP92 The Forest provides no measurable standards of use to limit livestock trampling – known to be a cause of weed expansion the sagebrush biome.

Forest Response: Trampling was not selected as a proper use criterion for this project. However, trampling disturbance should be reflected in the quantitative attributes the Matrices use to assess ecological condition. The stream group (page 3-2 of appendix A of the 2011 FEIS) considers streambank stability, which can be affected by trampling. Other habitat groups in the Matrices look at bare ground and relative cover of various desirable and undesirable species, which can be affected by trampling. Utilization would be reduced if trampling were negatively affecting these attributes.

WWP118 WHY is there no systematic analysis and inventory of headcuts across the Forest watersheds in all pastures in all allotments.

Forest Response: An analysis and inventory of headcuts across Forest watersheds is outside the scope of this project. Active restoration activities/needs identified through this analysis would require additional NEPA. Proper use criteria as well as the required adjustments based on the long-term monitoring for this project are part of a passive restoration strategy that provides for the maintenance or improvement of resource conditions in the project area.

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WWP153 The Forest provides loose, uncertain and ill-defied categories of functioning and other rangeland. The Forest has not shown that there is “capability”/capable acres for many lands shown in sage- grouse, pygmy rabbit and other mapping. How can cheatgrass-invaded areas be renewed? How can areas of sagebrush that have lost large-statured understory bunchgrasses critical for grouse and rabbits be “renewed”? There is no baseline including detailed mapping of these lands. Is the term capability here the same as capability and suitability analysis? How is it defined? There is no restoration plan for nonfunctioning or FAR rangeland. However, even in this non-functioning category, the Forest seems to assume losses may be reversible – despite strong scientific evidence that losses may not be reversible (see Fleischner 1994).

Forest Response: The 2013 Draft Supplement defines rangeland condition using terminology from the Intermountain Region Rangeland Ecosystem Analysis and Monitoring Handbook (page 10). This project uses the Humboldt-Toiyabe National Forest’s Ecological Condition Matrices (Matrices) to determine the condition of various habitat groups in the project area. The Matrices rely on quantifiable measurements of relevant attributes in each habitat group to arrive at the ecological condition determination. Additional information on the Matrices is included in the 2013 Draft Supplement on pages 10 through 12 and the Matrices are included as Appendix A to the 2011 FEIS.

Alternative 1 (Proposed Action) addresses cheatgrass by adjusting the ecological condition determination based on its presence. Using the Matrices to determine ecological condition, an area with more than 5 percent cheatgrass would not be determined to be functioning because cheatgrass at these levels would inhibit the area’s capability for renewal, for recovery from a wide range of disturbances, and for retention of its ecological resilience. The proper use criteria (for this project, utilization and streambank disturbances) would be lowered if the area is found to be in less than functioning condition and other livestock management adjustments could be implemented to reduce the presence of cheatgrass.

Renewal of areas of sagebrush that have lost large-statured understory bunchgrasses would depend on the condition of the stand before the loss of the structure. A functioning (as defined by the quantitative attributes identified in the Matrices) stand of Wyoming big sage that is subjected to a major disturbance (such as a fire) would be expected to return to functioning condition. It could take decades for the area to regain all of the characteristics of a mature stand, but the area could still be considered functioning as it passed through the appropriate successional changes to return to a mature stand. This is an example of recovery from a disturbance and retention of ecological resiliency.

The baseline is the current ecological condition as described in chapter 3 and summarized in table 7 of the 2013 Draft Supplement. While the word “capability” appears in both 36 CFR 219.20 and the definition for functioning rangelands, the context in which the term is used makes its meaning clear. Further clarification is unneeded. Restoration has been addressed in response to comment WWP88. The definition of non-functioning rangelands states this is “a condition where a rangeland has lost the capability across the landscape for ecological resilience.” If a rangeland is in this condition, it is believed that recovery is not possible without active restoration actions. Losses may or may not include any of the examples you have cited.

WWP176 Where is the new info across these acreages? The elaborate Matrices cover up the systemic lack of current and comprehensive info to base any actions that involved continued grazing disturbance here on.

Forest Response: The 2008 Updated MIS Monitoring Report did not attempt to recalculate general range condition, so the report does not contain current information for a comparison to this

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table. The 2008 Updated MIS Monitoring Report did model current condition as it relates to the individual MIS. The results are contained in the report. This modeling was done at the Forest-level and is subject to a reasonable margin of error associated with modeling at that level. The aquatics and wildlife specialist reports prepared for the Ely Westside Rangeland Management Project contain a project-specific analysis of the condition of MIS habitat in the project area. The Vegetation section in the 2013 Draft Supplement and the supporting Vegetation Specialist Report in the project record contain project-specific analysis of the general range conditions in the project area. Table 7 in the 2013 Draft Supplement summarizes those conditions by identifying the ecological conditions of the various habitat groups in each allotment.

WWP193 Instead of designing idealized communities and killing native plants to try to obtain percentages of shrub cover, the forest should manage to retain and enhance native understories and the continuity and integrity of native communities across the forest.

Forest Response: Comment noted. The analysis in the 2013 Draft Supplement reflects that Alternative 1 (Proposed Action) will retain and enhance native understories and protect the native communities in the project area.

WWP209 We are greatly concerned about the federal agency recent blind reliance on flawed and inaccurate NRCS Ecosites that fail to accurately portray the historical and natural vegetation conditions in the region. These ignore the historical vegetation in surveyor records as well as those recognized by plant community ecologists. These appear to be tainted by livestock industry consultant and other livestock industry influence. They often also use long outdated and erroneous fire and disturbance intervals. What disturbance intervals are you using in all parts of this analysis?

Forest Response: NRCS Ecological Site Descriptions have not been completed for National Forest lands the Ely area. Therefore, we are unable respond to your concerns about the accuracy and use of Ecological Site Descriptions. For this project, ecological condition would be determined using the Humboldt-Toiyabe National Forest’s Ecological Condition Matrices (Matrices), which are included as part of the 2011 FEIS in appendix A. The Matrices are based on field research, literature reviews, and relevant parts of some of the NRCS range site descriptions. The criteria and process included in the Matrices were reviewed by peer scientists.

Socioeconomics WWP66 If the Forest is going to claim it is examining economic factors, then much more solid and extensive detailed financial info and disclosure is required.

Forest Response: The Forest is not claiming that it is examining economic factors. Rather, the Forest is acknowledging that grazing on National Forest System lands contributes an economic value to the permittees.

WWP80 What percentage of area economy does grazing in this area represent? A hundred thousandth of the $$$ associated with other activities? County economies are based on gold and other mining by foreign-owned companies - and not ranching.

Forest Response: An analysis of the socio-economic conditions near the project area, including the relative contribution of grazing operations associated with the project area, is included in chapter 3 of the 2013 Draft Supplement.

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Soils

Sub Topic: General WWP18 The EIS fails to provide info and analysis to understand current productivity, current soil condition (including large-scale erosional losses form historical and ongoing grazing and crested wheatgrass seedings and vegetation manipulation “treatments” (mowing, hacking, burning, chopping, masticating, etc.) where there is REDUCED potential of soils due to mis-management.

Forest Response: The condition and potential of soils in the project area are discussed on pages 67-78in chapter 3 of the 2013 Draft Supplement. Additional information is contained in the Soils Specialist Report, which is included in the project record.

WWP 114 There is no analysis of how much topsoil – A horizon – is actually left on-site, or how much excessive gully and other erosion is occurring in association with the livestock-degraded ad or crested wheatgrass seedings in old floodplains or watershed areas near streams an springbrooks. Just how many headcuts are present, and where? What is the risk of further headcutting, and how much more wetted area potential will be lost under the continued extremely high stocking rates without any meadow/bank trampling standards being applied?

Forest Response: This appears to be a request for an action, but does not identify an issue. There is no systematic soil survey available at this time. On selected sites where ecoplots were established, soil data was collected. That information is available in the project record. It was summarized on pages 74-75 of the 2013 Draft Supplement. Soil Erosion hazard was modeled and displayed in the 2013 Draft Supplement on pages 68 through 72.

WWP119 The Forest analysis of ecological processes (such as nutrient cycling) is contradicted by current ecological science for shrub steppe systems.

Forest Response: The discussions on nutrient cycling in the 2013 Draft Supplement were not referring to livestock defecation. The Forest agrees that such a suggestion is not applicable to the project area. The discussion on that type of nutrient cycling relates more appropriately to grazing on plains grasslands, not the Intermountain West. The discussion in this document focuses on the natural nitrogen fixing bacterial (VAM) found in shrub steppe systems. This process is an important part of a healthy rangeland community and the carbon sequestering process.

WWP129 Soils analyses assume that levels of soil erosion under No Action will continue at current rate. There is no scientific basis for understanding if that is correct (it certainly is not for the Vacant or allotments), or if erosion will accelerate.

Forest Response: The Soils section in chapter 3 of the 2013 Draft Supplement discusses the effects of grazing on soil resources and provides the basis for this conclusion. The best available information on the project area was used in the preparation of this analysis. Current scientific literature was also used to determine the effects of the various alternatives on the project area.

Sub Topic: Microbiotic Crust WWP112

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No systematic surveys for microbiotic crusts have been conducted across the Project Area.

Forest Response: The value of known and potential presence of microbiotic crusts in the project area and the impacts of grazing to microbiotic crusts are discussed in the Soils section of chapter 3 of the 2013 Draft Supplement.

Vegetation

Sub Topic: Aspen WWP50 The Forest fails to analyze the effects of livestock browsing in causing disease in aspen. Wounded browsed trees are more susceptible to fungal and other diseases.

Forest Response: Hinds (1985) supports your assertion that wounded aspen are more susceptible to infection. The analysis on aspen in chapter 3 of the 2013 Draft Supplement includes information on the effects of livestock and disease susceptibility.

Sub Topic: General WWP21 The lack of ability of arid lands to recover following grazing and trampling disturbance, or the very slow rate of any progress towards getting better - must all be fully taken into account in analyzing impacts and developing a much-expanded range of alternatives to deal with the severe ecological threat that livestock grazing poses.

Forest Response: The effects of livestock grazing on the various vegetation communities in the project area are described in detail in the Vegetation section in Chapter 3 of the 2013 Draft Supplement.

WWP58 The vegetation mapping of the Matrices (HOW were the matrices used in deriving the “desired conditions” in this Ely effort?) present an ”ideal” vegetation community type – showing discrete communities that would exist at “climax” in specific non-heterogeneous sites, or with some degree of Forest manipulation such as to achieve an unnaturally reduced canopy cover - as for much of the mountain big sagebrush community. They also represent later successional communities, and communities that do not reflect the inherent complexity of soil inclusions, moister to mesic areas, variations between north and south facing aspects, and many other important attributes that are present as part of the natural diversity of the Forest landscape.

Why does the Forest not provide info on all the past treatments, and purposeful removal of sagebrush here, so that recovery times from disturbance could be understood?

Forest Response: The purpose of the maps 12 and 13 (on pages 106-107 of the 2013 Draft Supplement) is to disclose the location of the various vegetation community types in the project area using the best available information. Additional maps have been included in Appendix G of the 2014 Final Supplement that display the vegetation community types by allotment rather than by mountain range. In order to understand the contribution of all the past actions identified in the comment, the analysis in this project relies on current environmental conditions as a proxy for the impacts of those past actions. Existing conditions reflect the aggregate impact of all prior human impact and natural events that affected the environment. By looking at the current conditions, we are sure to capture all the residual effects of past human actions and natural events, regardless of which particular action or event contributed to those effects. Recent wildfires and vegetation

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treatment activities are described in appendix H of the 2013 Draft Supplement and discussed in the cumulative effects analyses in the Vegetation section of the 2013 Draft Supplement.

WWP60 Such effects are not fully shown on mapping. It is uncertain how this disturbance was or was not integrated into capability and suitability analyses as well. How has cheatgrass been dealt with in these analyses, too?

Forest Response: No mapping of cheatgrass in the project area is available at this time. In assessing condition, the pre- and post- fire conditions were considered. Cheatgrass invasion and spread was included if documented in an allotment or based on observation by district staff. Examples of the type of discussions are on pages 121-122, 125 and 181-183 of the 2013 Draft Supplement.

As discussed in the Management Indicator Species and Range Suitability/Capability Analysis- Humboldt National Forest Updated MIS Monitoring Report (2008) and reference documents, we determined vegetation types capable of producing more than 200 pounds of forage per acre within the potential natural community. The vegetation layer that was used to model capability would have included fires up to 2003. As reflected in the discussion on wildfires and prescribed fires on pages H-11 through H-16 in appendix H of the 2013 Draft Supplement, fires since 2003 have been small and isolated.

WWP96 Where is all data, analysis, detailed mapping based on current ecological vegetation condition (including analysis of vulnerability to cheatgrass or other weed expansion with continued grazing disturbance? Why is the Forest obsessing over noxious weeds when cheatgrass and other non- noxious weeds are a much greater threat to biodiversity of the sagebrush biome?

Forest Response: This information can be found in the Vegetation section in chapter 3 of the 2013 Draft Supplement. This section is a summary of the more extensive Vegetation Specialist Report, which is included in the project record. The Vegetation section in the 2013 Draft Supplement initially provides a description of project-wide existing conditions of the various vegetation communities in the project area. Table 25 on page 105 of the 2013 Draft Supplement summarizes one of our modeling efforts and identifies the number of acres of the various cover types that appear in each allotment. The Vegetation section in the 2013 Draft Supplement then steps the analysis down to the allotment level and discusses and discloses the ecological condition of the vegetation communities allotment by allotment. The 2013 Draft Supplement contains analysis on noxious and invasive weeds on pages 181-187.

WWP146 The EIS has not conducted necessary surveys to identify all sensitive and rare plant sites, or to understand the viability of important and sensitive populations.

Forest Response: The best available information was used in the preparation of the sensitive plant species analysis in chapter 3 of the 2013 Draft Supplement. More detailed information is included in the Botany Specialists Report, which is found in the project record. Utilization in the sensitive plant habitats does not appear to negatively impact these plants until it rises to around 65 percent. Concentrating activities such as watering and salting locations can have a negative impact on these species. Alternative 1 (Proposed Action) addresses both of these concerns. Maximum utilization levels would be 50 percent and any area where future planned activities are likely to concentrate livestock use would be surveyed for sensitive and rare plants. A 0.25 mile buffer would be imposed on any concentrated use activity adjacent to known sensitive and rare plant locations.

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Sub Topic: Noxious/Invasive Species WWP11 All of this combined is spawning cheatgrass and other weed invasions in areas that just five years ago had minimal cheatgrass presence. It is also greatly contributing to losses of native biodiversity and habitat for sage-grouse, pygmy rabbit, northern goshawk, pinyon jay, rare plants, and other rare and imperiled species.

Forest Response: The risk of continued cheatgrass and other weed invasions is assessed in the Vegetation section in chapter 3 on pages 181-187 of the 2013 Draft Supplement. The risk of degradation or loss of habitat for animal and plant species is assessed in the Vegetation, Wildlife and Fish, and Sensitive Plants sections in chapter 3 of the 2013 Draft Supplement. The impact of noxious, invasive, and other undesirable plant species on the ecological condition of an area is also reflected in the Matrices scorecard, which includes the percentage of relative cover of these plants as attributes to be considered.

WWP44 We are concerned at how the EIS ignores disturbance-related weed infestation and expansion, or accurate tracking of vegetation and soil and habitat disturbance and degradation from its own treatments over past decades. How did past vegetation treatments affect soil, vegetation and habitat conditions? Where were they conducted? When? What is their current condition? Under an expanded range of alternatives, restoration of the crested wheatgrass seedings and pj burns/treatments must occur. Where is past mining deforestation occur – and where are pinyon- juniper re-occupying sites where they occurred historically – and not “invading” as is often falsely claimed to justify eradication projects.

Forest Response: The 2013 Draft Supplement has a section on noxious and invasive plant species (pages119- 122 and 181-187). The discussions on existing vegetation condition by allotment (pages 122-146) include site-specific information on noxious weeds. Invasive species, such as cheatgrass, are also discussed in the Vegetation and Sensitive Plants sections in chapter 3 of the 2013 Draft Supplement.

WWP203 Michael Reisner Dissertation Excerpts –This Is Provided in Support Of minimizing Disturbance, Passive Restoration, and Protection from Cheatgrass

Forest Response: Thank you providing this information. This dissertation addresses the potential impacts of treatment related disturbances to plant composition in Wyoming big sage brush communities. The Ely Westside Rangeland Management Project does not propose any vegetation treatments. Furthermore, the project area contains a relatively small amount of Wyoming big sage brush. Table 24 in the 2013 Draft Supplement displays the acreages and maps 12 and 13 show the distribution of these vegetative community types in the project area.

Sub Topic: Riparian WWP28 The Forest has stated in the DEIS that it is not planning to analyze weeds, and this means it is not committing to apply as permit Terms the principles of Integrated Weed Management (IWM), which is critical to ensure sustainable native vegetation communities and sage-grouse, pygmy rabbit, migratory bird, and other habitats and populations.

Forest Response: The creation of an Integrated Weed Management strategy is outside of the scope of this project. However, the ecological approach of livestock management put forward by Alternative 1 (Proposed Action) is in many ways a weed, vegetation, wildlife habitat, soil, and

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water management strategy. Alternative 1 (Proposed Action) bases the livestock management adjustment on the ecological condition of the habitat groups in a pasture. Each habitat group has attributes that represent important ecological components from the various resources that make up a habitat group. For example, the Mountain Big Sage group (appendix A, page 3-16 of 2011 FEIS) looks at four categories of attributes: soil, vegetation, hydrology, and disturbance. Each category has two or more individual attributes that can be measured. Attribute 8 identifies the percentages of relative cover of annual grasses in Group D that can be present in the various ecological conditions (functioning, functioning-at-risk, non-functioning). Group D annual grasses for mountain big sage are defined on page 3-17 (appendix A of 2011 FEIS); it includes cheatgrass. So, if the presence of cheatgrass were greater than 5 percent relative cover, but less than 30 percent, Attribute 8 would be viewed as functioning-at-risk. This attribute would be compared with the other 14 attributes to determine the overall ecological condition of the site. If the site is determined to be functioning-at-risk, maximum herbaceous utilization (measured at the end of the season) would set at 40 percent (see table 9 of 2013 Draft Supplement). This lower utilization level should result in less intense use of this area, so soil disturbance and selective utilization of desirable plant species would decline. Lower soil disturbance would reduce the conditions favorable to weeds and lower utilization would give desirable plant species a greater opportunity to achieve their proper role in the ecosystem. As conditions improve, the area will become more resilient and less susceptible to the potential negative effects from disturbances such as grazing and wildfire.

WWP29 The amount of herbicide that is likely to be used will also be increased by the aggressive deforestation and sagebrush mowing-eradication practices of current Ely management. These treated areas then suffer continued abusive grazing and overstocking under the Proposed Action. What chemicals will be used when, where, and how - and what is the potential for drift in this rugged eroding terrain?

Forest Response: Use of herbicides is outside of the scope of this project and would be considered under a separate environmental analysis. By maintaining rangelands in, or improving rangelands to, functioning ecological condition, Alternative 1 is designed to make the project area more resilient and less susceptible to noxious and invasive plant species.

WWP59 The Forest is largely ignoring the harsh reality of the cheatgrass and other Weeds that are spreading under livestock trampling and management activities such as salting/mineral supplement, pipeline fences, and other sites.

Forest Response: Noxious and invasive weeds are analyzed in chapter 3 of the 2013 Draft Supplement, pages 119 to 122 and 181 to 187.

WWP183 Some current weeds were not present on the District during the days of the old REA survey and Forest Plan. Their invasion represents degraded conditions and over-grazed lands. WHEN were all exotic species now found on the Forest and weeds of concern first documented?

Forest Response: The 1986 Forest Plan acknowledges the presence of noxious weeds at the time of its preparation (page II-14) and provided management direction of noxious weeds inventory and control (pages IV-37 and 38). See response to WWP31 and WWP59.

WWP184 The Forest must reconcile its claims of lands being in good or improving conditions with the weed increases: cheatgrass, bulbous bluegrass, new exotic thistle, black henbane and other weed expansions. The Forest has ignored the ongoing adverse effects of trampling disturbance and

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depletion here.

Forest Response: The ecological condition determinations offered in the 2013 Draft Supplement are based on a review of all available data sources, site visits, and professional expertise and knowledge, which was compared against the attributes listed in the Matrices (appendix A of the 2011 FEIS). The amount of cover associated with noxious weeds and other species that are indicative of management problems are attributes that were considered in determining the ecological condition in the project area.

Sub Topic: Sagebrush WWP87 Current science demonstrates very long recovery terms for sagebrush communities – and climate change is likely to exacerbate recovery.

Forest Response: The length of recovery after fire depends of the type of vegetation, capability of the site, and how “recovery” is considered. Recovery potential in sagebrush communities will vary widely even for the most common sagebrush, mountain big sagebrush (Johnson 2000).

WWP93 The Forest provides no measurements or limits on cattle structural alteration, breakage, and consumption of sagebrush.

Forest Response: See response to comment WWP92. Furthermore, cattle generally do not consume appreciable amounts of sagebrush and do so only after grazing on herbaceous plants. By the time cattle switch from herbaceous species to shrubs like sagebrush, they would generally have met the herbaceous utilization levels for that habitat group and movement from the area would be appropriate. The habitat components of pygmy rabbit and the effects of the alternatives to this species are analyzed in the 2013 Draft Supplement on pages 215-217 and 259-262.

Water Quality WWP55 The Forest simply does not provide and analyze adequate data on water, watershed processes and drainage networks. This is especially the case with spring and seeps and small drainages (intermittent, ephemeral and some perennial drainages too), and the upland ecological conditions and vulnerabilities across the landscape with continued grazing disturbance.

Forest Response: Seeps and springs, as well as the possible effects of grazing on seeps and springs, are analyzed in the Soils, Water Quality, and Vegetation sections in the 2013 Draft Supplement.

WWP56 There are no systematic lentic inventories across all springs, seeps, and wet meadows – which are critically important habitat components including for sage-grouse and migratory birds.

Forest Response: This appears to be a request for an action, but does not identify an issue. While surveys of seeps and springs were conducted in coordination with Amendment 2 of the Forest Plan, no further, more systematic surveys have been conducted.

WWP102 Where is all the monitoring data for springs and seeps? Where are all springs and seeps? How many troughs are linked to alteration, destruction or loss of springs and seeps? See Sada et al. 2001, BLM Technical Bulletin.

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Forest Response: Seeps and springs are generally associated with the wet meadow vegetation community type. The Vegetation section in chapter 3 contains a general discussion on seeps and springs (page 112-113 of the 2013 Draft Supplement). Specific discussions on seeps and springs are included in the Riparian vegetation subsection for each allotment-specific discussion (pages 122-146 of the 2013 Draft Supplement). Maps 16 and 17 on pages 159-160 of the 2013 Draft Supplement disclose the location and category of the seeps and springs in the project area. The environmental effects of the alternatives on meadows, seeps, and springs are included in the Riparian section on pages 149-163 of the 2013 Draft Supplement. The range developments, including the water developments, were identified in Table H-1 and maps H-3 and H-4 in Appendix H of the 2013 Draft Supplement. Additional maps have been included in Appendix G of the 2014 Final Supplement that display the range developments by allotment rather than by mountain range. Most of the water developments are troughs fed by springs. Sada (USDI 2001) discusses the need to survey and inventory springs to document their current condition and goes on to suggest that this data should be used to prioritize management programs for the springs. Existing spring data is part of the project record. Generally, troughs are seen as an improvement for water quality and impacts to the soil resource because it moves the watering of cattle off the spring source.

WWP111 The Forest skirts the issue of declines in water quantity and increasing desertification affecting natural water sources across the District. How do the number of livestock grazed affect watershed soils, vegetation and microbiotic crusts – and how do they affect water quantity and quality? How will climate change affect water quality and quantity? How is the condition of the land area linked to watershed function? How will grazing lands that are not capable affect water quality and quantity? How do weed infestations – and degraded watersheds – affect water quality and quantity?

Forest Response: The Water Quality section of the 2013 Draft Supplement (pages 85-102) discloses the potential effects of livestock grazing on water quality and water quantity.

WWP117 We are dismayed that a Forest, where every one of the dozen or so small spring and stream systems is impaired by growing headcuts, almost entirely ignores analysis and discussion of these very serious effects. Yet excessive and expanded (Troy Canyon) overstocking by cattle grazed during the hot season would still be allowed to continue across these degraded watersheds.

Forest Response: The proper use criteria applied in Alternative 1 (Proposed Action) reduce allowable utilization of herbaceous and woody vegetation to a level that promotes healthy vegetation; these use levels also provide a reduction in soil disturbance by permitted livestock. Transitory use of non-capable lands by permitted livestock is acceptable and expected. The proposed proper use criteria also include standards for riparian vegetation as well as monitoring and reporting requirements.

WWP121 Where is an analysis of the amount of waste deposited in surface waters? Washed into surface waters from step slopes of non-capable lands subjected to grazing disturbance here? What disease organisms are hikers or backpackers, including in the wilderness exposed to? What volumes of waste are deposited? Under all alternatives? How many scarce nutrients are exported in livestock “meat”? Why aren’t these questions posed and answered?

Forest Response: The effects of livestock grazing on water quality are analyzed in the Water Quality section in chapter 3 of the 2013 Draft Supplement.

WWP122 Yet the EIS lacks any significant site-specific info on the majority of the springs on the Forest.

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Many are being heavily impacted by livestock trampling – and dried out and desertified. Many are at risk of being lost entirely. Under this EIS, nt adequate baseline analysis is provided, and there is no certainty that the Forest will apply any standards at all to many of these areas.

Forest Response: See responses to comments WWP7 and WWP102.

WWP123 It is essential that the Rangeland EIS prepare a complete spring, seep and wet inventory with current data and information on the degree and severity of alteration and loss of springs and seeps that has already occurred. After systematically identifying all of these areas of concern, it is necessary that the EIS take specific and significant steps to prevent further losses and restore degraded or threatened areas.

Forest Response: This appears to be a request for an action, but does not identify an issue. While surveys of seeps and springs were conducted in coordination with Amendment 2 of the Forest Plan, no further, more systematic survey has been conducted. When fieldwork or monitoring identifies spring restoration needs, these potential projects are prioritized against other potential projects. If determined to be a priority they are assessed and funded as a restoration or improvement project.

Wildlife

Sub Topic: General WWP72 Sage-grouse are landscape species. Pygmy rabbits are highly vulnerable to extirpation if habitats become invaded by cheatgrass in understories, or severed and fragmented – including by unsuitable expanses damaged by livestock. This type of info on the crisis in the landscape must be fully integrated into all Biological Assessments, BAs, BOs, etc. in order for the Forest to have fully considered all direct, indirect and cumulative effects on waters, watersheds, and populations of native plants and animals.

Forest Response: It is correct that sage grouse and pygmy rabbit are negatively impacted by cheatgrass. This information and other threats to the species are analyzed in the biological evaluation and wildlife specialist report. Sage grouse and pygmy rabbit are not federally-listed species. It is inappropriate to analyze effects to sage grouse and pygmy rabbit in a biological assessment (BA) or for the United States Fish and Wildlife Service to complete Endangered Species Act Section 7 consultation on the species as documented in a biological opinion.

WWP141 Livestock use currently begins in May and overlaps with late nesting, any re-nesting, early brood rearing of grouse.

Forest Response: According to table 6 (page 27) in the 2013 Draft Supplement, the earliest date that grazing could occur on the Ely Westside Rangeland project area is May 1 (Pine Creek/Quinn Canyon and Troy Mountain allotments), except for the Cherry Creek Allotment where sheep are trailed for two weeks between December 1 and February 10. Maps 21 and 22 on pages 200 and 201 of the 2013 Draft Supplement reflect that there are no leks or nesting habitat in these allotments. The 2013 Draft Supplement acknowledges that livestock grazing can affect the quality and quantity of nesting and brood rearing habitat and includes several design feature on page 30 to address the potential impacts of livestock grazing. The effects are disclosed in chapter 3 of the 2013 Draft Supplement.

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WWP206 What is the status of local amphibian populations?

Forest Response: Amphibians were not analyzed in the Ely Westside Rangeland Project for several reasons. The Ely Ranger District does not have any amphibians that are listed as threatened or endangered species. Nor does the Ely Ranger District have any amphibians categorized as sensitive or management indicator species. Amphibians were not identified through scoping or other comments on this project.

Sub Topic: Goshawk WWP181 The Plan also identified over large areas of goshawk habitat in the Range – so why are there so very few goshawks found? How does grazing affect their prey base? How does it disturb and conflict with nesting, feeding of young, etc.?

Forest Response: The abundance of northern goshawk in the project area, as well as the effects of livestock grazing on their foraging and nesting habitats, was included in the Wildlife section in chapter 3 of the 2013 Draft Supplement (pages 207-215 and 249-254). This portion of the 2013 Draft Supplement is a summary of more detailed information that is available in the project record.

Sub Topic: Greater Sage-grouse WWP4 [A]lso failing to apply upland use levels that provide for necessary residual cover for sage-grouse nesting and other purposes.

Forest Response: Connelly and others (2000) recommend 18 centimeters of cover, but did not specify at which time of the year that is needed. In many locations in the Great Basin, herbaceous cover does not reach that height until late spring or even late summer, after the nesting period. Holloran and others (2005) found that cover of at least 10 centimeters (4 inches) increased nesting success for sage-grouse. Curtis (2004) documented that in some vegetation types 50 percent utilization will leave at least 4 inches of residual cover.

WWP71 The EIS provides greatly inadequate and minimal analysis of sage-grouse habitats, populations and their viability under different management scenarios.

Forest Response: This appears to be a criticism, but does not identify an issue. The 2013 Draft Supplement identifies the sage grouse habitat in the project area and analyzed sage grouse viability under the three different management scenarios included in the alternatives. The 2013 Draft Supplement also includes population estimates that were provided to the Forest Service biologist directly from NDOW in September 2011.

WWP109 As part of this process, the Forest must consider re-aligning, removing and otherwise altering fenced areas – including both allotment and pasture boundaries to reduce the fence density and impacts. This is needed for both restoration and wildlife population viability. Where does fencing impose on sage-grouse breeding and nesting habitats – making it likely that sagegrouse may collide with fences, or have nests predated by ravens or raptors perched on elevated fence posts? Please identify these areas, and target the fencing for removal.

Forest Response: Fencing removal is outside of the scope of the EIS, and any removal projects

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would be analyzed under a separate NEPA process. There are known active leks on the Tom Plain Allotment, and it is reasonable to assume that nesting occurs on the edges of the Ellison Basin, Illipah, and Treasure Hill allotments. Fencing that does not have smooth wire for the bottom wire and uses wooden fence posts pose a greater hazard to grouse in these areas than other types of fencing.

WWP137 We are greatly concerned that the Forest claims so little of the area is nesting habitat. What are the full parameters of the Model tat [sic] was applied? See EIS at 192.

Forest Response: Please see response to comment NDOW7.

WWP139 The sage-grouse info in the EIS was apparently from 2008 (see DEIS at 194) and updated sage-grouse info is lacking.

Forest Response: Thank you for your comment. We have updated the population estimates included in the 2011 FEIS with information provided from NDOW in 2013.

WWP180 Do how ill the grazing scheme affect [sage grouse] population viability?

Forest Response: The 2013 Draft Supplement states on pages 244, 248, and 249 that implementation of the alternatives is not expected to affect the viability of sage grouse.

WWP186 Where are all leks that are trend leks in these NV PMUs? Please provide detailed lek numbers and any other population info available for all time periods. Where are all active and historic leks? What are the numbers associated with leks within 10 miles of the Forest?

Forest Response: The active leks in the project area have been included on maps 19, 20, 21, and 22 of the 2013 Draft Supplement. No leks appear on maps 21 or 22 because no leks occur on the area displayed; the closest active lek is 26 miles to the east. The 2014 Final Supplement contains the latest population estimates provided by NDOW in 2013 Additional information on sage grouse leks and populations is included in the project record.

WWP187 The Forest has not examined the extent and severity of habitat fragmentation that exists across habitats potentially used by a Sage Grouse population here. Those elements of fragmentation also affect habitats and populations for other sagebrush dependent species. See Knick 2003, Connelly et al. 2004.

Forest Response: Sage grouse habitat was analyzed in the Wildlife Specialist Report at the extent of the western portion of the Ely Ranger District and known causes of fragmentation (e.g. wildfire) were assessed and summarized in the cumulative effects section as appropriate in the 2013 Draft Supplement.

WWP188 The Forest, in understanding the effectiveness of any use standards, stocking levels, uncertain Adaptive Management scheme, in providing habitat and supporting viable populations, must determine what conditions including all seasonal needs is actually required to support Sage Grouse and other sagebrush-dependent wildlife here.

Forest Response: The habitat requirements for greater sage-grouse and other sagebrush dependent species are analyzed pages 202through 207 of the 2013 Draft Supplement. Additional information is available in the Wildlife Specialist Report, which is included in the

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project record.

WWP191 The Forest must examine effects of these grazing operations on a much larger land area – both that includes the Footprint of these grazing operations, as well as in an ecologically meaningful area to meet the year-round habitat needs of a Sage Grouse population, and the needs of other important and sensitive native upland species.

Forest Response: Habitat was assessed across the western portion of the Ely Ranger District for sage-grouse and several other species in the Wildlife Specialist Report. Under Alternative 1 (Proposed Action), we concluded that conditions in sage-grouse habitat would remain stable and habitat in unsatisfactory condition should improve. See pages 244 and 245 of the 2013 Draft Supplement. Under Alternative 2 (Current Management), we concluded that conditions in sage-grouse habitat would remain the stable and habitat in unsatisfactory condition would be unlikely to improve without adjustments to management. See page 248 of the 2013 Draft Supplement. We acknowledge that impacts on sage-grouse habitat outside of the project area can affect the sage- grouse that use the project area for only a portion of their yearly life requirements. However, we only have managerial control over the lands within the project area, and those lands are being managed to achieve or maintain desirable habitat conditions. Our analysis is focused on actions that affect the quality and/or quantity of sage-grouse habitat within the project area.

WWP197 Please see WWP Idaho and Nevada GRSG DEIS comments on Lit cd. These describe the great deficiencies of these documents, and the limited changes that would occur. Forest Response: Thank you for providing us with a copy of your comments. We have reviewed your comments, paying particular attention to your comments on how livestock grazing can potentially impact sage grouse. You have already raised all of these concerns in your comments directed at the Ely Westside Rangeland Project and the Forest has already responded to these comments in this document.

WWP200 A recent USFWS review of various grazing schemes in relation to GRSG (Manier et al. 2013) shows that the claims made in the EIS about the manner in which livestock grazing will occur in the Ely Westside allotments, and their outcome being sustainable, are highly uncertain.

Forest Response: While summarizing much of the same scientific literature cited in the 2013 Draft Supplement, Manier et al. 2013 (page 96) notes that “there are two important influences of detrimental grazing on sage-grouse habitat: the influence on annual conditions in the near-term and the accumulation of selective pressure resulting in altered vegetation dominance over time.” Alternative 1 (Proposed Action) addresses both of these detrimental influences. Alternative 1 (Proposed Action) addresses annual conditions by applying moderate utilization levels for areas that are in functioning condition and more conservative utilization levels in areas that are not in desired conditions. These utilization levels provide protection to native plant communities and ensure that important habitat components for sage grouse and other wildlife species. See pages 243-245 of the 2013 for the anticipated effects to sage grouse associated with Alternative 1 (Proposed Action).

Alternative 1 (Proposed Action) also addresses the potential for grazing to alter vegetation dominance through selective pressure over time. This project uses the Humboldt-Toiyabe National Forest’s Ecological Condition Matrices (Matrices) to determine the condition of various habitat groups in the project area. The Matrices rely on quantifiable measurements of relevant attributes in each habitat group to arrive at the ecological condition determination. Additional

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information on the Matrices is included in the 2013 Draft Supplement on pages 10 through 12 and the Matrices are included as Appendix A to the 2011 FEIS. The Matrices are used to guide determinations on whether an area is in functioning, functioning-at-risk, or non-functioning condition. Some of the attributes in the Matrices scorecards used to guide these rangeland condition determinations include percent canopy cover, species composition, and bare ground. Alternative 1 (Proposed Action) sets utilization rates based on these condition determinations. The lower utilization levels associated with functioning-at-risk and non-functioning condition are designed to allow the area to move back to functioning condition.

WWP201 See Manier et al. excerpts (Attached here as Appendix A) describing how ineffective grazing systems just like what the forest it applying here are likely to be.

Forest Response: See response to WWP200.

WWP204 Thus there are two important influences of detrimental grazing on sage-grouse habitat: the influence on annual conditions in the near-term and the accumulation of selective pressure resulting in altered vegetation dominance over time.

Forest Response: Please see response to WWP200. Alternative 1 (Proposed Action) addresses both of these influences. Annual conditions are protected by end-of-season utilization levels designed to preserve residual vegetation, which preserves elements of food and cover for sage grouse habitat. Alternative 1 (Proposed Action) also requires adjustment to grazing levels if long-term monitoring indicates a change in the ecological condition of the vegetation communities that comprise sage grouse habitat. These adjustments are intended to prevent changes in natural vegetation dominance and restore natural vegetation dominance over time.

Sub Topic: Pygmy Rabbit WWP46 Weiss and Verts (1984) found pygmy rabbits in only 2 of 51 sites occurred were cheatgrass was present. This study re-visited Oregon shrubsteppe historical occurrence, and found rabbits at only 51 of more than 200 formerly occupied sites. Nevada inventories (Larrucea) are aberrant in that they seek to discount the absence of the species at the historic sites. Cheatgrass is now known to be expanding aggressively into mountain big sagebrush sites, particularly with disturbance.

Forest Response: Pygmy rabbits do avoid areas where cheatgrass is present as it is more difficult to burrow through (Larrucea 2007).

WWP151 What are the effects of all the existing facilities, salting sites, facility-related roads, grazing of livestock across large areas of non-capable lands that results in intensified impacts on the few “capable” areas and deeper soils sites required by the pygmy rabbit? Where is a current landscape-wide baseline survey and analysis for pygmy rabbits? What is the population status and its viability here?

Forest Response: There is no population data available at this time and there are no known active sites. No surveys for pygmy rabbits have been conducted for this analysis. However, assessments for habitat that have been performed for other projects on the White Pine and Grant- Quinn ranges have never identified any suitable habitat for pygmy rabbit. Potential habitat is present in the project area, but is very limited. The effects of the activities proposed under the alternatives to pygmy rabbit are discussed in chapter 3 of the 2013 Draft Supplement on pages 259 through 262. Under all alternatives, capable pygmy rabbit habitat in satisfactory condition

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would remain stable; habitat in less than satisfactory condition could improve.

WWP152 Please identify all areas burned, mowed, treated during all periods for which records were kept. Please analyze how all of the sagebrush disturbance and loss has adversely affected dense sagebrush canopy cover and understory characteristics required by the pygmy rabbit.

Forest Response: District records were searched for previous disturbance for the cumulative effects analysis. Sagebrush-disturbing activities (such as wildfire, vegetation treatments) in the project area are discussed in appendix H of the DEIS. These activities are small and would have minimal effect on pygmy rabbit and its habitat. Due to rocky soil conditions, sagebrush in most areas cannot reach height and densities preferred by pygmy rabbit, and soil conditions would make burrowing difficult if not impossible.

References Bukowski, B.E. and W.L. Baker. 2013. Historical Fire Regimes, Reconstructed From Land-

Survey Data, Led to Complexity and Fluctuation in Sagebrush Landscapes. Ecological Society of America. Preprint version.

Hess, J.E. and J.L. Beck. 2010. Greater Sage-Grouse (Centrocercus Urophasianus) Nesting and Early Brood-Rearing Habitat Response to Mowing and Prescribed Burning Wyoming Big Sagebrush and Influence of Disturbance Factors on Lek Persistence in the Bighorn Basin, Wyoming. Final Research Report. December, 29, 2010.

Hinds, T. E. 1985. Diseases. Pages 87-106 in N.V. DeByle and R. P. Winokur, editors. Aspen: ecology and management in the western United States. USDA Forest Service General Technical Report RM-119.

Holechek, J.L., H.S. Gomes, F. Molinar and D. Galt. 1998. Grazing Intensity: Critique and Approach. Rangelands 20(5). October 1998.

Jones, A., J. Catlin, and E. Vasquez. 2013. Mechanical Treatment of Pinyon-Juniper and Sagebrush Systems in the Intermountain West: A Review of the Literature (DRAFT). Wild Utah Project. January 2013.

Lawrence,P.K., S. Shanthalingam, R.P. Dassanayake, R. Subramaniam, C.N. Herndon, D.P. Knowles, F.R. Rurangirwa, W.J. Foreyt, G. Wayman, A.M. Marciel, S.K. Highlander, and S. Srikumaran. 2010. Transmission of Mannhemia Haemolytica from Domestic Sheep (Ovis Aries) to Bighorn Sheep (Ovis Canadensis): Unequivocal Demonstration with Green Flurescent Protein-Tagged Organisms. Journal of Wildlife Diseases. 46(3): 706-717.

Nevada Department of Wildlife. 2011. NEVADA’S GREATER SAGE-GROUSE CONSERVATION PROJECT. Copied from website: http://www.ndow.org/wild/conservation/sg/resources/report/nevadas_sage- grouse_conservation_program_2000-2010.pdf

Romme, W.H., C.D. Allen, J.D. Bailey, W.L. Baker, B.T. Bestelmeyer, P.M. Brown, K.S. Eisenhart, M.L. Floyd, D.W. Huffman, B.F. Jacobs, R.F. Miller, E.H. Muldavin, T.W. Swetnam, R.J. Tausch, and P.J. Weisberg. 2009. Historical and Modern Disturbance Regimes, Stand Structures, and Landscape Dynamics in Pinon-Juniper Vegetation of the Western United States. Rangeland Ecology Management. 62:203-222. May 2009.

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USDI Bureau of Land Management. 1999. Utilization Studies and Residual Measurements. Interagency Technical Reference 1734-3. Cooperative Extension Service, U.S. Department of Agriculture – Forest Service, Natural Resource Conservation Service – Grazing Land Technology, U.S. Department of the Interior – Bureau of Land Management. 1996. Revised in 1997, 1999.

USDI Bureau of Land Management. 2011. Multiple Indicator Monitoring (MIM) of Stream Channels and Streamside Vegetation. Technical Reference 1737-23.Burton, T.A., S.J. Smith, and E.R. Cowley. BLM/OC/ST-10/003=1737=REV. Bureau of Land Management, National Operations Center, Denver, CO. 155 pp.

University of Nevada Cooperative Extension. 2006. Nevada Rangeland Monitoring Handbook. Educational Bulletin 06-03. Sherman Swanson (Editor in Chief), University of Nevada Cooperative Extension. Second Edition

Wehausen, J.D., S.T. Kelley, and R.R. Ramey II. 2011. Domestic sheep, bighorn sheep, and respiratory disease: a review of the experimental evidence. California Fish and Game. 97(1):7-24.