February 11, 2002
Montpelier Ranger District
North Fourth Street
Montpelier, ID 83253
Re: North Bear River Range AMP Revision
On behalf of the Greater Yellowstone Coalition (GYC), I appreciate the opportunity to comment on the proposal to re-authorize grazing on the North Bear River Range. GYC would like to submit the following comments:
First of all, the scoping notice states that the project includes 94,262 acres of public land. When was suitability analysis conducted on these lands? While previous AMP dates are included in the scoping document, no mention is made of suitability analysis. The scoping notice states that this project is designed to comply with the Revised Forest Plan (RFP), which is currently in the revision process.
In our comments regarding the revision, we raised serious concerns over the lack of suitability analysis that was conducted on the forest. Until that issue has been resolved, it is premature to state that this proposal will comply with the new forest plan. Therefore, since suitability analysis is only conducted during the revision process, and the Forest Plan may require stricter standards than those being proposed, these AMPs must include language that enforces standards of the new RFP. This may require reducing AUMs or eliminating grazing in some areas beyond what this analysis proposes.
The project area lies within the Bear River Range of the Caribou-Targhee National Forest. The Bear River Range is the only high elevation forested corridor connecting the Greater Yellowstone Ecosystem and the Northern Rockies to the Southern Rockies. For the integrity of wildlife populations, this is the most critical area of the Rocky Mountains between Canada and Mexico, known as the "Utah Gap". This area contains habitat or potential habitat for numerous threatened and sensitive species including Canada lynx, Northern Goshawk, Wolverine, Marten, Fisher, Flammulated Owl, Great Gray Owl, Boreal Owl, Gray Wolf and Bonneville Cutthroat Trout, among others.
Structural range "improvements" in the project area include 22 miles of fence, 96 man-made livestock watering ponds, 26 troughs, 13 cattle guards, and 7 miles of pipeline. What cumulative impacts have these "improvements" had on vegetation, wildlife habitat, water quality, riparian areas, soils, and habitat fragmentation? What changes have occurred to resources as a result of these "improvements?"
The EIS should document how domestic grazing activities on these allotments has affected habitat for threatened, endangered, and sensitive species in the project area. How has livestock grazing affected the ability of the Bear River Range to provide linkage habitat for wildlife species, and how has grazing contributed to habitat fragmentation? How has vegetation changed as a result of a century of livestock grazing?
Additionally, the area contains a number of streams, seeps, ponds, and wet meadows. What is the current condition of these habitats in the project area? The EIS should include detailed site-specific information from the project area. How has domestic livestock grazing affected these areas? How have soils and water quality been affected by grazing in the past, and what affect will this proposal have on those resources in the future? How have aquatic species, including but not limited to cutthroat trout, spotted frogs, and Western toads, been affected? What impacts to these species and their habitat will occur as a result of the proposed action?
Are there any 303(d) listed streams in the project area? How will this proposal affect those streams?
The Forest is proposing to add 2.25 miles of fence, 2 troughs, and 6 water catchment ponds to the area. What impacts to resources can be expected from these developments? What cumulative impacts to resources from these developments combined with other improvements are expected to occur?
Furthermore, the scoping document states that utilization standards for "key species" will be used to limit grazing in the project area. However, this mitigation fails to identify which species are "key" species that will be monitored. Different species have different palatability to livestock, and in some cases "key species" will not be utilized by livestock at all, while other species will be grazed to bare ground. The EIS for this project should state which species will be monitored, at which times of the year monitoring will take place, and should include teeth that require monitoring to take place (especially during the hot season) and standards to be met.
In addition, the EIS for this proposal should include the following:
Moreover, we expect the EIS to discuss a full range of alternatives to the proposed action. GYC requests that the following be incorporated within any proposed alternative that allows permitted livestock use to continue on allotments within the Bear River Range:
Although we know that the Forest has time constraints on this project, there are no legal deadlines for scoping comments. GYC will be sending additional comments regarding this proposal in the near future. We appreciate the opportunity to comment on this proposal, and we look forward to reviewing the EIS when it is completed. Please feel free to contact me with any questions that you may have in regards to these comments.
Greater Yellowstone Coalition