Your Comments Needed Now: WWP Won The Lawsuit in 2004 But The Nevada BLM Fails Miserably In Its Court Ordered DEIS

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Bryan Fuell, Lorrie West
Sensitive Bird Species EIS Project Managers
BLM Elko Field Office
3900 East Idaho Street
Elko, NV 89801-4611

FAX: 775-753-0255

EMAIL: Bryan Fuell: and Lorrie West: (Please send to both Bryan and Lorrie and ask them for a reply acknowledging your e-mail has been received)

Unfortunately, and despite BLM's claims to the contrary, the EIS is not available to the public on-line. The BLM Nevada Website is still shut down, and it is not posted on the national site.

Thank you everybody who submitted scoping comments before! BLM received over 100 scoping comments. Please take the time to comment again! If you want, please e-mail us a copy your comments, too: as Elko BLM has already once before lost/destroyed public records related to these allotments. If you provided scoping comments, but did not receive a copy of this EIS, please let BLM - and us - know.

If you have questions WWP's contact for Nevada public lands is WWP Biodiversity Director, Katie Fite:


1. Prepare a Supplemental EIS.

Cheatgrass, halogeton and invasive species are choking out native plant habitats essential for sage grouse and migratory birds and the small animals that provide a prey base for raptors. BLM's existing livestock facilities and seedings have destroyed important habitats, caused weed invasions and killed spring flows. Stocking lands with numbers of cattle and sheep 28-50% above the numbers that have caused widespread damage to riparian and upland areas is madness. Pursuing more range facilities and sagebrush killing treatments is madness. BLM needs to prepare a Supplemental EIS that conducts valid scientific analysis of habitat conditions and the needs of the sensitive species. Collect and assess new and complete data on special status species habitats and ecological conditions.

2. Accurately determine the current suitability, capability and sustainability of grazing on the allotments.

BLM must be honest with the public about the condition of the plant communities, and the severity of habitat degradation and loss that exists. BLM must develop management to protect and restore damaged special status species habitats, and act to protect remnant better condition lands.

3. Develop a new range of alternatives.

that focus on realistic and much-reduced numbers of cattle and sheep, and reduced livestock "forage" utilization levels based on current scientific data.

4. Consider all Area of Critical Environmental Concern (ACEC) Proposals submitted by the public, and Designate new ACECs.

BLM must act to evaluate and designate large new ACECs to best protect sage grouse, migratory bird and raptor habitats, plus unique natural communities. WWP, along with CHD and ONDA submitted proposals for the Owyhee, Goshute, and other areas, based on TNC Landscape Assessments and other data.

5. Abandon proposals for even more livestock projects, seedings and sagebrush mowing.

Instead, BLM must remove livestock projects that have destroyed spring flows, remove pipeline trough systems that are jeopardizing sage grouse and special status species habitats.

6. Act to restore native Bighorn Sheep to the Goshute and Toano Ranges.

BLM ignored Nevada Department of Wildlife and public comment on developing appropriate management so that bighorn sheep populations can be re-established. BLM must remove domestic sheep that transmit a fatal disease to native Bighorn Sheep from bighorn-suitable habitats.

7. Consider impacts to ALL special status and important species and their habitats,

including rare bats; pygmy rabbit; migratory birds like the loggerhead shrike; mule deer, antelope and sage grouse populations shared between Nevada, Idaho and Oregon in the Owyhee allotment; and wildlife shared between Nevada and Utah in the Sheep Allotment Complex. The mountain ranges contain pinyon-juniper, mountain mahogany, and montane forest habitat for pinyon jay, northern goshawk, pallid bat, and many other species.

8. Remove cattle from the damaged East Squaw Creek Watershed in the Big Springs allotment.

This largely perennial stream and spring complexes provide critical sage grouse brood rearing habitat and a refueling stop for migratory birds in a very arid landscape. BLM proposes excessive grazing and a harmful series of spring developments and band-aid fences. These developments will de-water springs. Plus, they will cause intense cattle grazing and trampling use to be shifted to any unfenced areas and further dry up flowing stream segments.

9. Stop abusive grazing practices that are promoting weed invasion, soil erosion and habitat loss in the Wilderness Study Areas.


In 2004, the Elko Field office of the BLM was ordered by a Federal Court Judge to prepare an Environmental Impact Statement (EIS) to assess livestock grazing impacts to sensitive species including sage grouse, golden eagle, burrowing owl, ferruginous hawk and other raptors across three vast allotments (Sheep Complex, Big Springs and Owyhee) in the Sagebrush Sea of northern Nevada's Elko County. The court order was a result of a lawsuit filed by Western Watersheds Project and the Committee for the High Desert.

These lands include the Owyhee Allotment in the headwaters of the South Fork Owyhee River, the Big Springs Allotment comprised of the forested Pequop and Toano Ranges and surrounding valleys, and the Sheep Allotment Complex including the Goshute and Toano Range near Wendover.

The EIS BLM produced is a travesty. It relies on the same old, limited and deficient data and mindset. It ignores the national importance of these lands and the wildlife that inhabit them. Under ALL new action alternatives in the EIS, BLM proposes to: Increase cattle and sheep AUMs from 28% to as much as 50% above AUM numbers grazed in the past; perpetuate excessive forage use levels; construct new wells, pipelines, spring developments; and eradicate sagebrush with new crested wheatgrass seedings and mowing.

Elko BLM's EIS effort to date serves as a poster child for the increasing imperilment of sage grouse. It demonstrates how agency actions are purposefully imperiling sage grouse, and why sage grouse protection under the Endangered Species Act is necessary.

The Sheep Allotment Complex includes the world famous Hawkwatch Goshute Raptor migration site, and portions of the Bluebell and Goshute Wilderness Study Areas. Nevada Division of Wildlife commented in 2000: "the Allotment Complex is critically important to the long-term health of ferruginous hawk and golden eagle nesting populations in the area".

The Big Springs allotment includes sage grouse lek complexes that are threatened by habitat loss and the high stocking rates of cattle and damaging levels of use. BLM proposes to shift increased livestock numbers into critical sage grouse habitats, and construct new wells, pipelines and seedings. New fences are proposed that will block mule deer migration routes and fragment sage grouse habitats. Despite several existing dilapidated spring "developments" in both this and the Sheep Allotment Complex having killed all surface expression of springs, BLM proposes extensive new spring developments in its EIS.

The Owyhee allotment, whose sole permittee, Doby George, is a mining company, contains still-intact expanses of big sagebrush communities, and 11 known sage grouse leks and year-round habitat. It is part of the interstate Owyhee ecosystem shared between Idaho, Nevada and Oregon. Sage grouse, raptors, migratory birds, antelope and mule deer habitats here are threatened by high numbers of cattle, excessive use levels, new wells, new pipelines, new fences and open-ended sagebrush mowing schemes that would carve up and destroy sagebrush habitats. It includes portions of the Owyhee River Canyon WSA and the South Fork Owyhee WSA.

Wild horse herds are found in all three allotments in several Herd Management Areas. Although blamed by BLM for every problem under the sun, wild horse numbers in these allotments are only a small fraction of the cattle and sheep numbers grazed here.