BLM LIBRARY
88045747
U.S. DEPARTMENT OF THE INTERIOR
Bureau of Land Management
Burns District Office
HC 74-12533
Highway 20 W.
Hines, Oregon 97738
September 1991
Proposed
Three Rivers
Resource Management Plan
and Final Environmental Impact Statement
Volume II - Appendices
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As the Nation's principal conservation agency, the Department of the Interior has responsibility for most of our nationally owned public lands and
natural resources. This includes fostering the wisest use of our land and water resources, protecting our fish and wildlife, preserving the
environmental and cultural values of our national parks and historical places, and providing for the enjoyment of life through outdoor recreation.
The Department assesses our energy and mineral resources and works to assure that their development is in the best interest of all our people.
The Department also has a major responsibility for American Indian reservation communities and for people who live in Island Territories under
U.S. administration.
BLM-OR-EA-91 -27-1 792
*&&*
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Cover Photo — Federal Land Office - Temporary Headquarters
in the Burns Hotel building from 1889-1891. Predecessor to
the Taylor Grazing Service and Bureau of Land Management.
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rpggo^rt
U.S. Department of the Interior
Bureau of Land Management
Proposed
Three Rivers
Resource Management Plan
Final
Environmental Impact
Statement
Prepared by
Burns District Office
State Director, Oregon/Washington District Manager, Burns
4^
76,5
.on
T573
Table of Contents
Page
Appendix 1
1 General Best Forest Management Practices I-3
2 Summary of Recommended Practices for Stream Protection I-7
3 Stream Segments Proposed for Livestock Removal 1-11
4 Riparian Area Grazing Systems and Inventory 1-13
5 Stream Segments Proposed for Immediate Grazing System Implementation 1-15
6 Stream Segments Proposed for Case-by-Case Grazing System Implementation 1-17
7 Stream Segments Which Lack Sufficient Data for Grazing System
Implementation I_19
8 Actions Proposed in Three Rivers Portion of the Burns District
Wetlands HMP I_2i
9 Allotment Management Summaries - Introduction I-23
10 Allotment Categories I_171
11 Rangeland Monitoring and Evaluation 1-177
12 Standard Procedures and Design Elements for Range Improvements 1-179
13 Range Improvement Costs 1-181
14 Potential Range Improvements by Allotment 1-183
15 Description of Existing and Proposed ACECs 1-187
16 Recommended Management/Use Constraints in ACECs 1-195
17 Off-Road Vehicle Designations - Federal Register Notice 1-197
18 Calculation of Three Rivers Average Annual Recreation Growth 1-199
1 9 Projected Recreation Visits To BLM-Administered Lands in the
Three Rivers Resource Area for the years 2000 and 2010 1-201
20 Gold Development Scenario I-203
Appendix 2
Comment Letters and Responses AIM
(Refer to Appendix II Table of Contents)
IV
Appendix I
nai—fcr^iiti rftitfBiiiSftti ' 'iMiiniiaM
Appendix 1-1
Appendix 1-2
___ — . — __ . , - _ — ___ — _ _ — _ — . . , —
Table 1 . General Best Forest Management Practices
The following Best Forest Management Practices (BFMP) are taken from the Oregon Statewide Planning Manuals, the
Oregon Forest Practice Rules (Oregon Department of Forestry, 1980) and Guidelines for Stream Protection (Oregon
StateGame Commission). Generally, BFMP applications were selected to avoid ratherthan mitigate impacts. In addition,
all road standards and designs will correspond to BLM Manual 91 13.
Road System
Logging road locations, particularly on sensitive areas, should be evaluated by a forester, soil scientist, wildlife biologist,
and other specialists as needed. The location should be fitted to the topography to minimize cut and fill situations. In areas
of important big game habitat, consultation with the wildlife biologist will be necessary to reduce impacts on wildlife,
particularly in areas such as ridgelines, saddles and upper drainage heads. Where alternative locations are not possible,
incorporate mitigating measures into road development plans. Avoid stream crossings, if possible. If not possible,
minimize approach cuts and fills and channel disturbance and maintain stream bank vegetation.
Where possible, locate roads on benches and ridges to minimize erosion; except under special circumstances such as
occurrence of rock bluffs, keep roads out of stream courses. Roads should be high enough to prevent silting to the stream.
Do not locate stream crossings strictly on a grade basis. Choose a stable site and adjust grade to it, when possible.
Keep stream disturbance to an absolute minimum.
If necessary, include short road segments with steeper grades, consistent with traffic needs and safety, to avoid problem
areas or to take advantage of terrain features.
Fortimber harvest spur roads, take advantage of natural landing areas (flatter, better drained, open areas) to reduce soil
disturbance associated with log landings and temporary work roads.
Vary road grades where possible to reduce concentrated flow in road drainage ditches and to reduce erosion on road
surfaces.
Design drainage ditches, waterbars, drain dips, culvert placement, etc., in a mannerthat will disperse runoff and minimize
cut and fill erosion.
Install culverts or drain dips frequently enough to avoid accumulations of water that will cause erosion or road ditches
and the area below the culvert and drain dip outlets.
In bridge location, plan to avoid relocation of the stream channel. Where the stream must be changed, use riprap,
vegetative cover, or other means to reduce soil movement into stream.
Seed (revegetate) cuts and fills the first fall season following disturbance.
Deposit excess material in stable locations well above the high-water level and never into the stream channel. Do not
allow any material, including sidecast soil, stumps, logs or other material to be deposited into a stream.
Hold wet-weather road building to a minimum, particularly on poorly drained, erodible soils which may drain mud directly
to streams.
Build fills in lifts to ensure optimum compaction and minimize slumpage. Avoid the inclusion of slash, logs and other
organic debris in fills.
On primary roads wherever serious erosion is likely, large cut-and-f ill slopes should be stabilized with plant cover as soon
as possible. Local experience will indicate the best practices and species to use.
Appendix I-3
Table 1. General Best Forest Management Practices (continued)
Generally, berms should be removed or at least broken frequently to allow lateral drainage to nonerodible areas. Berms
are desirable on large erodible fills to prevent drainage from the road crown down the center of the fill section.
Plan ditch gradients steep enough (generally greater than 2 percent) to prevent sediment deposition.
When installing culverts and drain dips, avoid changes in channel orientation and place these structures to conform to
the natural channel gradient. Design culverts for maximum stream flow (e.g., 25-year discharge).
Skew culvert approximately 30 degrees toward the inflow to provide better inlet efficiency.
Provide rock or other basins at the outiet of culverts and rock the drain dips if economically feasible.
In building bridge footings and abutments, limit machine work as much as possible to avoid disturbing the stream. This
initial work often greatly increases turbidity and sediment movement. The toes of fills on larger creek crossings should
be protected above the high-water line to prevent soil movement.
Unless no other source is available, gravel should not be taken from streambeds except from dry gravel bars. Washing
of gravel into streams will normally cause sedimentation and should be avoided.
In some areas, alternating inslope and outsiope sections can be built into the road, especially if road grades are rolled
to dispose of road surface flow.
Obtain all necessary permits for stream crossings before beginning activities.
Maintain all roads immediately after logging and the primary roads whenever necessary by cleaning ditch lines, blading
debris from empty landings, trimming damaged culvert ends and cleaning out culvert openings.
Grade the primary road surfaces as often as necessary to retain the original surface drainage (either insloped or
outsloped). Take care to avoid casting graded material over the fill slope. Monitor surface drainage during wet periods
and close the road if necessary to avoid undue damage.
Haul all excess material removed by maintenance operations to safe disposal areas. Apply stabilization measures on
disposal sites if necessary to assure that erosion and sedimentation do not occur.
Vary the steepness of slopes on cut and fill slopes commensurate with the strength of the soil and bedrock material as
established by an engineering geologist or other specialist in soil mechanics.
Control roadside brush only to the extent required for good road maintenance and safety.
Soil Protection and Water Quality
Time logging activities to the season in which soil damage can be kept to acceptable limits.
Design and locate skid trail and skidding operations to avoid across ridge and across drainage operation, and minimize
soil compaction.
Install water bars on skid trails when logging is finished (forester and/or soil scientist will provide assistance as requested
or needed).
Avoid trapping and turning small streams out of their natural beds into tractor trails and landings.
Appendix I-4
Table 1. General Best Forest Management Practices (continued)
Generally, confine tractor skidding operations to slopes of less than 35 percent. Leave appropriate snags and/or large
dead trees for wildlife, as per current BLM Snag Management Policy Guidelines and Agriculture Handbook No 553
(USDA, 1979).
If debris should enter any stream, such debris shall be removed concurrently with the yarding operation and before
removal of equipment from the project site. Removal of debris shall be accomplished in such a manner that natural
streambed conditions and stream bank vegetation are not disturbed.
Provide variable width no-cut/no-skid buffers for all perennial streams, springs and seeps as well as for nonperennial
streams, springs and seeps which significantly impact water quality in perennial waters.
Avoid falling and yarding operations into or across any stream. Use yarding methods that minimize soil disturbance in
the watershed as much as practicable.
Maintain native vegetation on primary disturbed areas (temporary roads, skid trails, landings, etc.) by seeding with
diverse native grass varieties.
Silvicultural
Reforest all cutover lands (either natural regeneration or artificial regeneration) with a commercial species to minimum
stocking levels (100-150 trees/acre within 5-15 years). The differences in stocking level numbers are related to the
differences in site class. For more detail refer to the BLM TPCC Manual 5250.
Slash disposal will be done in a manner conducive to revegetation and advantageous to wildlife. Slash will be burned
when necessary and such burning will be in conformance with State air pollution regulations.
Logging units will be laid out in a manner that would reduce the risk of windthrow. The selection of trees in shelterwoods
will be made in a manner that would improve the genetic composition of the reforested stand. Disturbed areas will be
artificially reforested when natural forest regeneration cannot be reasonably expected in 5-15 years.
Yarding practices to be employed during the planning period consist of tractor systems, ground and partial suspension
cable systems and full suspension systems which include cable and aerial. Each system impacts ground vegetation to
different degrees relative to the soil disturbance resulting from the harvest system used. For example, the tractor system
would cause the greatest impact to existing vegetation and an aerial full suspension system would cause the least
disturbance.
Appendix I-5
Appendix 1-6
Table 2. Summary of Recommended Practices for Stream Protection
Guidelines for protection of fish habitat and water quality in logging operations have been developed as a result of the
Alsea watershed research program and related studies. They include the following:
1 . Extremely small headwater streams can be important spawning and rearing areas for salmon and trout and need
protection. Even streambeds that are dry in the summer can be valuable spawning tributaries at other times of the
year. Also, logging activities in headwaters can affect downstream areas.
2. A formal procedure for reviewing timber harvest operations, in the planning stages as well as during logging,
entered into by participating private, State and Federal groups should be an integral part of any logging program.
3. Stream clearance requirements, and their enforcement, are essential.
(a) Every effort should be made to prevent logging debris from falling into stream channels. If any debris does
get into a channel, the fishery biologist or hydrologist should determine which debris will be removed to
maintain adequate dissolved oxygen levels in surface water and keep migration routes open.
(b) The method of stream clearance and timing of the operation are also important. Heavy equipment should not
normally be used in a stream, and the channel should not be altered. Consultation with the local State fishery
biologist can aid in determining what material should be removed from a stream, and the best time for removal.
4. Streamside vegetation should be protected and remain standing in all logging operations where fish, wildlife and
water quality considerations are involved or can be affected in downstream areas.
(a) Streamside vegetation provides shade to the stream and minimizes water temperature increases.
(b) Commercial conifers do not necessarily have to be left. Shrubs and other less valuable species can, in many
cases, provide adequate shade if the conifers can be removed without destroying such vegetation or
damaging streambanks. In some areas, commercial timber may have to remain to protect other watershed
values or await the technological development of other removal methods.
(c) Areas of vegetation left along a stream do not have to be a certain width. Often a relatively narrow vegetative
unit will provide the necessary fish habitat protection unless other factors such as wildlife habitat enhance-
ment and scenic corridors are involved.
(d) Protecting streamside vegetation serves many purposes. Maintaining a vegetation unit requires care in falling
and yarding timber away from the stream, and will reduce stream clearance needs and dissolved oxygen
problems in surface and subgravel waters.
5. Avoid falling trees into or across streams.
6. Logs should not be yarded through streams.
(a) Yarding logs through streams deposits organic and inorganic debris and sediment in the channel, breaks
down streambanks and streamside vegetation, and contributes to dissolved oxygen and sediment changes
in surface and subgravel environments.
(b) Use yarding methods that minimize soil disturbance in the watershed.
(c) Landings should not be located in the stream channel.
(d) Logs should be yarded uphill and away from the stream.
Appendix I-7
Table 2. Summary of Recommended Practices for Stream Protection (cont
The Society of American Foresters1' Columbia River Section, Water Management Committee2 has developed a list of
recommended logging practices for watershed protection in western Oregon. The recommendations reflect concern for
the impact of roads on stream sediment levels and emphasize proper road location, construction and maintenance.
Although available in the Journal of Forestry for more than 1 0 years, many logging operations have not incorporated the
practices into their programs. Therefore, in an attempt to get wider distribution of the Water Management Committee's
suggested practices, most of its recommendations follow verbatim.
Road Location and Design
1. Where possible, locate roads onbenches and ridgesto minimize erosion; except underspecialcircumstances such
as occurrence of rock bluffs, keep roads out of stream courses. Roads should be high enough to prevent silting
to the stream.
2. Keep road gradients low except where short, steep sections are needed to take advantage of favorable topography
and to avoid excessive cut and fill. Minimize the effect of higher gradients by reducing the distance between culverts
to prevent the accumulation of water in the ditches.
3. Roads leaving landings should have short lengths of slightly adverse grade if possible. They should not have steep
pitches of favorable grade which might drain off mud from the landings into streams.
4. Allowf lexibility in road design so that in construction a minimum of soil is moved. Adjust the radius of curves in critical
areas to achieve this objective.
5. Take advantage of well-drained soils and horizontal rock formations for greater stability, and avoid areas where
seeps, clay beds, concave slopes, alluvial fans and steep dipping rock layers indicate the possibility of slides.
6. Considerthe proper angle of repose forcuts and fills in designing roads on varying types of soils and rock materials.
Consistent with these demands, make road cuts reasonably steep in orderto minimize surface exposed to erosion.
7. In bridge location plan to avoid relocation of the stream channel. Where the stream must be changed3' use riprap,
vegetative cover or other means to reduce soil movement into stream.
8. Install culverts at crossings of all drainage ways except small streams4 and seeps which can be safely diverted to
ditches. Use culverts with sufficient capacity to carry the largest flow expected.
9. Route the road drainage (whether from culverts, cross drainage or ditches) onto the forest floor, preferably on
benches so that sediment can settle out before drainage water reaches stream channels.
1 0. Take drainage water out of ditches at intervals short enough to prevent ditch erosion. Detour it from above unstable
areas to avoid saturation, slumping and erosion.
Road Construction
1 . Plan the pioneering stage of road construction to avoid soil erosion and slumpage. As an example, cull log
crossings5 can be provided where culverts will be placed on the completed road. Avoid pioneering too far ahead
of final construction.
2. Uncompleted road grades which may be subject to considerable washing before final grading should be outsloped
or cross-drained.
3. Hold wet-weather road building to a minimum, particularly on poorly drained, erodible soils which may drain mud
directly to streams.
Appendix I-8
Table 2. Summary of Recommended Practices for Stream Protection (continued)
4. Build fills in lifts to ensure optimum compaction and minimize slumpage. Avoid the inclusion of slash, logs and other
organic debris in fills.
5. Excessfill material should not be dumped within the high-waterzoneof streams where floods can pick it uporwhere
it will flow immediately into the stream; end-haul such material.
6. Where slide areas can be predicted from past experience, their effects should be minimized by such measures as
flatter backslopes and deeper ditches. On slopes gentle enough to hold the fill, avoid disturbance of underground
water courses by building on the fill and providing adequate subdrainage.
7. On primary roads with steep slopes and full benching, consider the use of cribbing to avoid severe disturbance to
unstable slopes.
8. On primary roads wherever serious erosion is likely, large cut-and-fill slopes should be stabilized with plant cover
as soon as possible. Local experience will indicate the best practices and species to use.
9. Avoid channel changes or disturbance of stream channels. Where necessary complete the channel change and
riprap the sides before turning water into the new channel.
1 0. In building bridge footings and abutments, limit machine work as much as possible to avoid disturbing the stream.
This initial work often greatly increases turbidity and sediment movement. The toes of fills on larger creek crossings
should be protected above the high-water line to prevent soil movement.
1 1 . Unless no other source is available, gravel should not be taken from streambeds except from dry gravel bars6
Washing of gravel into streams will normally cause sedimentation and should be avoided.
1 2. Culverts should be properly installed in the stream channel allowing for suitable bed, adequate size, frequency and
grade7. Inlets and outlets should be protected. Aprons should be installed where needed.
13. Where necessary, protect the upper ends of culverts to prevent fill erosion into them. On erodible soil materials,
extend culverts beyond the fills or install permanent aprons below them to disperse flows and prevent gullying.
1 4. Ditches should be of adequate depth and side slope to carry all water and to prevent sloughage.
Road Maintenance
1 . Keep roads well crowned ahead of wet weather so they will drain properly and not become waterways.
2. During current operations, roads should be graded and ditched to avoid interruption to drainage from road centers
to the ditches.
3. After the first rain in the fall, check roads to reduce drainage problems.
4. During periods of heavy rainfall, examine road surfaces to assure that drainage from wheel ruts is properly diverted
to drainage ditches. During such periods it may be worthwhile to provide personnel to patrol the roads and to do
hand drainage work.
5. Provide frequent cross-drains on all temporary roads in the fall to prevent erosion of road and fill.
6. Generally, berms should be removed or at least broken frequently to allow lateral drainage to nonerodible areas.
Berms are desirable on large erodible fillsto prevent drainage from the road crown down the center of thefill sect ion.
Appendix I-9
Table 2. Summary of Recommended Practices for Stream Protection (continued)
7. In using graders to clean out drainage ditches, avoid undercutting the side slopes.
8. Culvert inlets should be inspected and cleaned priorto the rainy season and periodically during that season. For
at least 50 feel above culverts the stream channels should be cleared of wood materials that might clog the culverts.
The outflow should be kept clear also.
9. Install trash racks well above inlets to culverts where experience shows the necessity. Keep the racks cleaned out.
1 Written permission to reprint this material has been granted by the editorial staff of the Journal of Forestry.
'A complete copy of the article and qualifying statements by the Committee Is available in the Journal of Forestry, Vol. 57, No. 6, June 1959. Portions of the article not included In this pamphlet
relate to introductory statements, logging operations and post-operational cleanup and maintenance. The Committee Is currently revising and updating Its recommendations, which will reflect
increased concern about the effects of logging on fish habitat and water quality.
'Timing of bridge construction and culvert installation is important. During the summer, streamflows are low and impacts on fishery resources can be minimal and localized. At that time migration
of juveniles to the ocean and adults returning to spawn would thus not be disrupted. (Author's footnote.)
'Until recently the importance of small streams was not fully documented. Culverts should be installed on all small streams supporting anadromous fish. (Author's footnote.)
5Cull log crossings placed in a stream in the spring can eliminate the downstream migration of fingerlings to the ocean. (Author's footnote.)
"A permit is now required to remove morethan 50 yards of gravel fromthe bed or bank of any water in Oregon (O.R.S. 541 .605 to 541 .660). Permits are issued under the authority of the Director
of the Division of State Lands and coordinated with a number of other State agencies. (Author's footnote.)
'Culvert gradient curves and stream velocity requirements for salmon and trout are available from the Oregon Department of Fish and Wildlife. (Author's footnote.)
Appendix 1-10
HIHM it-.
Table 3. Stream
Segments Proposed for Livestock Removal1
;..■■,
Stream Name
Allot
Miles
Acres
Cond.
Trend
Allot.
No.
Special Status
Species
Claw Creek
Claw Creek
2.30
12.0
Poor
Static
7010
RB/MS2
Skull Creek
Skull Creek
3.50
23.5
Poor
Static
7030
RB
Buzzard Creek
W.Warm Springs
1.50
14.0
Poor
Static
7002
—
Alder Creek
Alder Creek
4.80
15.0
Poor
Static
5536
RB
Bluebucket Cr.
Moffet Table
1.05
3.0
Poor
Static
5511
RB
Coleman Creek
Alder Creek
4.35
24.0
Poor
Static
5536
RB
Stinkingwater
Creek
Dawson Butte
Stinkingwater
Mountain
0.50
1.25
0.50
3.0
5.0
3.0
Poor
Poor
Poor
Static
Static
Static
5524
5531
5532
RB
RB
RB
Smyth Creek
Smyth Creek
2.30
10.0
Poor
Static
5307
RB/MS
Warm Sprgs Cr.
Mountain
Texaco Basin
3.00
1.00
12.0
4.0
Poor
Poor
Downward
Static
5532
5566
RB
RB
This table pertains to Management Actions WL 6.1 ,
2RB indicates Redband Trout, MS incidates Malheur
SSS 2.1 (Table 2.12), WQ 1.4 and AH 1.2.
Mottled Sculpin.
Appendix 1-11
Appendix 1-12
Table 4. Riparian Areas Grazing Systems and Inventory
Several riparian pastures within the planning area have exhibited "speedy" riparian recovery with a short duration (less than 30 days)
early (prior to June 1 ) grazing system (see glossary for definition of "speedy" riparian recovery). However, in some instances an early
turn out riparian pasture or pastures within an allotment is not practical or may be cost prohibitive.
An effort has been made throughout the planning process to develop cost-effective (based on past funding and future projects)
strategies to meet the overall Bureau objective of 75 percent of all riparian areas in good or better condition by 1 997 (Fish and Wildlife
2000, A Plan for the Future, 1 987). With these constraints in mind, a 1 0 percent utilization level for riparian vegetation and a 50 percent
utilization level of herbaceous riparian vegetation were established. These levels were intended for riparian areas which could not
fit into an early grazing system and would be independent of one another (i.e., if either was reached, the livestock would be removed
from the pasture).
The 30 percent herbaceous upland vegetation utilization was arrived at from current utilization levels on upland vegetation within
some of the existing riparian pastures. It wasfelt that 30 percent utilization on upland herbaceous vegetation was the most that would
be reached before one of the other utilization levels as reached in the riparian pasture.'However, some improved riparian conditions
have been achieved with greater than 30 percent upland herbaceous vegetation utilization, therefore, the upland utilization levels
for any particular pasture will be consistent with upland utilization levels prescribed for the particular allotment.
Inventory
During the summers of 1 979 and 1 981 , riparian inventories were conducted on streamside riparian habitat in the Riley and Drewsey
Planning Units, respectively. Two hundred pace toe point transects were run on sites representative of stream segments. Segments
were determined based on changes of overstory and understory dominant plants and, where possible, a change in potential. Data
collected included: vegetative species composition, shrub and tree canopy height and percent cover, slope, wildlife species present,
stream gradient, dominant and codominant overstory and understory species, and canopy distribution and potential. These data were
used as they relate to potential to determine condition. This was not done on a straight percentage of potential basis because the
different components of riparian habitat have different degrees of importance for particular wildlife species. An example of this is the
the South Fork of the Malheur River. The herbaceous riparian vegetation is in good condition but tree and shrub components are
virtually absent. This streamside riparian was rated as fair overall.
Permanent photo trend points were established at each of these segments. These photos have been retaken periodically. The photos
along stream sections where management has changed to favor riparian have been taken more frequently than the photos at points
where conditions are not expected to change. The photos from these points are used to show visible change over time. Trend has
been established by this change over time.
Streams that currently have no condition or trend listed have no data and will be inventoried as funding becomes available. If these
areas do not meet the BLM definition of riparian they will be dropped from consideration.
Appendix 1-13
Appendix 1-14
; ! : : : ,
Table 5. Stream Segments Proposed for Immediate Grazin
g System In
Trend
lplemen
Allot.
No.
tation
Spec
Stream Name
Allot
Miles
Acres
Cond.
rial Status
Species
Devine Creek
Unallotted
3.00
12.0
Good
Static
—
RB/MS
Silvies River
Silvies River
Silvies Meadow
Silvies Canyon
1.50
0.50
2.25
17.4
4.0
26.2
Fair
Fair
Fair
Static
Static
Static
7033
7035
7053
RB
RB
RB
Landing Creek
East Silvies
Landing Creek
0.75
3.00
10.0
24.0
Fair
Fair
Down
Down
7041
7040
RB
RB
Hay Creek
Hay Creek
2.00
35.0
Fair
Up
7031
RB
Silver Creek
Packsaddle
1.10
7.0
Good
Static
7012
RB/MS
Claw Creek
Dry Lake
0.45
2.00
1.50
32.0
15.2
17.5
Poor
Good
Good
Upward
Static
Down
7010
7010
7009
RB/MS
RB/MS
RB/MS
Upper Valley
1.10
7.0
Good
Static
7011
RB/MS
Wickiup Creek
Packsaddle
1.25
18.0
Good
Upward
7012
RB/MS
Mineral Canyon
Packsaddle
0.60
1.0
Poor
Upward
7012
RB/MS
Dairy Creek
Claw Creek
1.20
8.2
Fair
Down
7010
RB/MS
Sawmill Creek
Upper Valley
0.75
3.0
Good
Static
7011
RB/MS
Rough Creek
Claw Creek
0.25
2.0
Good
Static
7010
RB/MS
0.75
15.0
Poor
Upward
7010
RB/MS
Nicoll Creek
Dry Lake
0.75
3.0
Good
Static
7009
RB/MS
Emigrant Creek
Emigrant Creek
0.50
3.0
Good
Static
7027
RB
Varien Creek
Varien Canyon
0.40
1.0
Good
Static
7048
—
Buzzard Creek
W.Warm Springs
0.50
5.0
Poor
Upward
7002
—
Bluebucket Cr.
Moffet Table
1.85
4.0
Fair
Static
5511
RB
Coleman Creek
Alder Creek
1.35
4.0
Fair
Static
5536
RB
Cottonwood Cr.
Cottonwood Creek
0.50
1.35
2.0
6.0
Fair
Fair
Upward
Static
5522
5522
RB
RB
M.F. Malheur
River
Moffet Table
2.30
8.0
Fair
Downward
5511
RB
River
0.80
5.0
Fair
Upward
5530
RB
Paul Creek
Riddle Mountain
0.60
4.0
Fair
Upward
5310
RB/MS
Deep Creek
Deep Creek
1.30
6.0
Good
Static
5330
RB/MS
S.Fk.Malheur
River
Venator
Stockade
1.25
1.35
6.0
4.0
Fair
Fair
Static
Static
5205
5206
RB
RB
Rattlesnake Cr.
Camp Harney
2.70
16.0
Good
Upward
5105
RB
Appendix 1-15
Table 5. Stream Segments Proposed for Immediate Grazing System Implementation (cont.)
Stream Name
Altai
Miles
Acres
Cond.
Trend
Allot.
No.
Special Status
Species
Stinkingwater
Creek
Smyth Creek
Dawson Butte
Mountain
Smyth Creek
Riddle Creek Happy Valley
Riddle Mountain
Riddle Coyote
Hamilton Ind.
Warm Sprgs Cr. Buck Mountain
Coffeepot Creek Camp Harney
Coyote Creek Riddle Mountain
Riddle Coyote
0.75
5.0
Fair
Little Pine Cr.
Pine Creek
2.00
8.0
Fair
Upward
5524
1.00
0.60
5.0
4.0
Fair
Good
Downward
Static
5532
5532
0.40
1.50
2.0
5.0
Good
Fair
Static
Downward
5307
5307
2.00
1.20
8.0
5.0
Fair
Fair
Static
Downward
5309
5310
3.30
2.50
12.0
10.0
Fair
Fair
Downward
Downward
5329
5327
3.00
12.0
Poor
?
5537
0.75
3.0
Fair
Static
5105
2.00
2.20
6.0
7.0
Fair
Fair
Improving
Static
5310
5329
Improving 5503
RB
RB
RB
RB/MS
RB/MS
RB/MS
RB/MS
RB/MS
RB/MS
RB
RB/MS
RB/MS
RB/MS
This table pertains to Management Actions WL 6.2, SS 2.1 (Table 2.12), WQ 1 .5 and AH 1 .3.
Appendix 1-16
Table 6. Stream Segments Proposed for Case-by-Case Grazing Systerr
i Implementation
Stream Name
Allot
Miles
Acres
Cond.
Trend
Allot.
No.
7043
Spec
al Status
Species
Poison Creek
Lone Pine
0.25
1.0
Poor
Static
RB/MS
Landing Creek
Silvies Meadow
0.25
5.0
Poor
Static
7035
RB
Claw Creek
Upper Valley
0.25
4.0
Poor
Down
7011
RB/MS
Beaver Cam Cr.
Sawtooth (MNF)
0.30
1.0
Fair
Static
7051
RB
Coleman Creek
Coleman Creek
0.25
1.0
Poor
Static
5201
RB
Lee Creek
Moff et Table
0.30
1.0
Poor
Static
5511
RB
Paul Creek
0.30
2.0
Poor
Static
5310
RB/MS
Silvies River
Silvies
0.20
1.0
Fair
?
4143
RB
Flat Creek
Silvies
0.40
2.0
Fair
?
4143
RB
Mountain Creek
Silvies
0.50
5.0
Fair
Static
4143
RB
Poison Creek
Silvies
0.25
2.0
Fair
Static
4143
—
Poison Creek
0.25
3.0
Fair
Static
4040
—
*This table pertains to Management Actions WL 6.3,
SS2.1
(Table 2.1
2).
Appendix 1-17
Appendix 1-18
Table 7. Stream Segments Which Lack Sufficient Data for Grazing System Implementation
Allot
Stream Name Allot Miles Acres Cond.* Trend No.
Skull Creek
Hotchkiss
0.5
2.0
?
?
7032
Emigrant Creek
Hay Creek
Sawtooth (MNF)
1.00
0.20
4.0
1.0
?
?
?
?
7031
7051
Yellowjacket
Creek
Hay Creek
0.40
0.5
?
?
7031
Spring Creek
Spring Creek
0.50
3.0
?
?
7029
Ltl Muddy Cr.
Little Muddy Cr.
1.50
6.0
?
?
5505
Mahon Creek
Mahon Creek
1.50
6.0
?
?
5534
Warm Sprgs.Cr.
Mill Gulch
1.25
5.0
?
?
5525
Mule Creek
Mule Creek
1.25
8.0
?
?
5515
Riddle Creek
Unallotted
Dry Lake
0.50
0.75
2.0
2.0
?
?
?
?
5303
Newell Creek
Lamb Ranch FFR
1.25
6.0
?
?
5571
Cow Creek
Cow Creek
0.50
2.0
?
?
5106
Mill Creek
Camp Harney
2.50
10.0
?
?
5105
Crane Creek
Alder Creek
5.00
20.0
?
?
5536
Dog Creek
Silvies
0.75
3.0
?
?
4143
East Creek
East Creek-
Pine Hill
0.75
3.0
?
?
4098
Prather Creek
Prather Creek
Devine
1.50
2.25
5.0
7.0
?
?
?
?
5102
5101
Swamp Creek
Kiger
Smyth Creek
0.5
1.5
2.0
5.0
?
?
?
?
5308
5307
* Riparian condition and trend are unknown for these segments.
Appendix 1-19
Appendix 1-20
Table 8. Actions Proposed in the Three Rivers Portion of the Burns District Wetlands HMP.
- Construct four islands in Dry Lake to improve nesting and loafing areas for waterfowl.
- Build a dam at Ryegrass Spring to create a brood pond.
- Construct five water spreading ditches at Ryegrass Spring to create meadow habitat for nesting and feeding wetland
species.
- Construct one-half mile of dikes with water control structures at Lake-on-the Trail to provide brood water throughout the
summer.
- Construct eight islands on Lake-on-the-Trail to provide increased opportunities for Canada goose nesting.
- Transplant a large variety of emergents around the lakeshore at Lake-on-the-Trail to provide good quality nesting habitat
for ducks.
- Construct a dike at West Chain Lake to provide year long water and 30 acres of nesting cover for wetland species.
Fence this area.
- Build a fence around unnamed Silver Lake Pond in T. 25 S., R. 28 E., Sec. 29 to provide good quality nesting cover.
- Inventory Nordell, Sheep, Dry and Weaver Lakes to determine feasibility of improvements to provide year long water
and nesting cover.
- Implement actions to improve Silvies Valley wetlands for waterfowl as opportunities arise.
Appendix 1-21
Appendix 1-22
Table 9. Allotment Management Summaries - Inl
■■.n
The following collection of summaries provides multiple-use information for each allotment in the Resource Area. Pertinent
information is organized in four general sections 1) Allotment Identification, 2) Grazing Administration, 3) Identified Resource
Conflicts/Concerns and Management Objectives, and 4) Constraints.
Allotment Identification - This section identifies each allotment by name and allotment number. The Selective Management
Category (M, I, C) is identified and acreage within the allotment is provided.
Grazing Administration Information - This section provides basic information on the grazing license and other forage demands
within the allotment including active preference, suspended nonuse, total preference, exchange of use and average actual use (see
Glossary). The reader will also note that Carrying Capacity has been determined on 1 8 allotments through the monitoring and an
allotment evaluation process and uses a minimum of 3 years of monitoring data. Presentation of the evaluation results on these 1 8
allotments was distributed to the public in June of 1 989 in the Riley Rangeland Program Summary Update. Note: Blanks under acres
or AUM's indicate the value of 0.
Identified Resource Conflicts/Concerns and Management Objectives - This section presents the major resource conflicts or
concerns that have been identified in each allotment through public input and interdisciplinary team interactions. For each conflict/
concern identified, management objective for its resolution has been developed. This section forms the basis for establishing or
revising Allotment Management Plans during the implementation of the RMP. This section also forms the basis for the direct
integration of other resource values into the allotment monitoring and evaluation process.
Constraints - This section presents multiple-use constraints that may affect the nature and degree of change that can be imposed
on the allotment through rangeland improvements and other potential surface-disturbing actions.
Allotment Name: Poison Creek
Public Acres:
1,237
Allot. No.: 4040
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 248
Suspended Nonuse: 0
Total Preference: 248
Average Actual Use: 248
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
Riparian or aquatic habitat is in
less than good habitat
condition.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Wetlands habitat in less than
satisfactory condition.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Improve wetlands habitat condition to
satisfactory or better.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
Appendix I-23
'
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Hi Desert
Public Acres:
400
Allot. No.: 4096
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 80
Suspended Nonuse: 0
Total Preference: 80
Average Actual Use: 80
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Trout Creek
Public Acres:
2,839
Allot. No.: 4097
Other Acres:
Mgmt. Category: I
Grazing Administration Info. (AUMs)
Active Preference: 568
Suspended Nonuse: 0
Total Preference: 568
Average Actual Use: 309
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Appendix 1-24
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Management
Objectives
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: East Cr.-Pine Hill
Public Acres: 1,840
Allot. No.: 4098
Other Acres:
Mgmt. Category: M
Grazing Administration Info. (AUMs)
Active Preference: 374
Suspended Nonuse: 0
Total Preference: 374
Average Actual Use: 349
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Riparian or aquatic habitat is in
less than good habitat
condition.
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
CONSTRAINTS
Management
Objectives
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-25
Table 9. Allotment Management Summaries (continued)
Allotment Name: Abraham's Draw
Public Acres:
40
Grazing Administration Info. (AUMs)
Active Preference: 8
Suspended Nonuse: 0
Total Preference: 8
Average Actual Use: 8
Allot. No.: 4126
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: White
Public Acres: 80
Grazing Administration Info. (AUMs)
Active Preference: 10
Suspended Nonuse: 0
Total Preference: 1 0
Average Actual Use: 1 0
Allot. No.: 4138
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-26
Table 9. Allotment Management Summaries (continued)
Allotment Name: Silvies
Public Acres:
11,035
Grazing Administration Info. (AUMs)
Active Preference: 2,500
Suspended Nonuse: 0
Total Preference; 2,500
Average Actual Use: 1 ,642
Allot. No.: 4143
Other Acres:
Mgmt. Category: M
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
75
75
150
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
Wetlands habitat in less than
satisfactory condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout, Allium campanulatum
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Improve wetlands habitat condition to
satisfactory or better.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-27
Table 9. Allotment Management Summaries (continued)
Allotment Name: King Mountain
Allot. No.: 4180 Mgmt. Category: C
Public Acres:
160
Other Acres:
Grazing Administration info.
(AUMs)
Other Forage Demands (AUMs)
Active Preference:
0
Deer:
Suspended Nonuse:
0
Elk:
Total Preference:
0
Antelope:
Average Actual Use:
16
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
Unallotted grazing area.
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Harney-Crane
Public Acres:
480
Grazing Administration Info. (AUMs)
Active Preference: 34
Suspended Nonuse: 0
Total Preference: 34
Average Actual Use: 34
Allot. No.: 5001
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
Rorippa columbiae, long-billed curlew.
CONSTRAINTS
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-28
Table 9. Allotment Management Summaries (continued)
Allotment Name: Catterson Sec. 13
Allot. No.: 5002 Mgmt. Category: C
Public Acres: 160
Other Acres:
Grazing Administration Info. (AUMs)
Other Forage Demands (AUMs)
Active Preference: 9
Deer:
Suspended Nonuse: 0
Elk:
Total Preference: 9
Antelope:
Average Actual Use: 9
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Malheur Slough
Allot. No.: 5003 Mgmt. Category: C
Public Acres: 799
Other Acres:
Grazing Administration Info. (AUMs)
Other Forage Demands (AUMs)
Active Preference: 66
Deer:
Suspended Nonuse: 0
Elk:
Total Preference: 66
Antelope:
Average Actual Use: 66
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-29
Table 9. Allotment Management
aries (continued)
Allotment Name: Withers' FFR
Public Acres:
190
t. No.: 5005
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 22
Suspended Nonuse: 0
Total Preference: 22
Average Actual Use: 22
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Devine Ridge
Public Acres:
8,642
t. No.: 5101
Other Acres:
Mgmt. Category: M
1,914
Grazing Administration Info. (AUMs)
Active Preference: 1 ,307
Suspended Nonuse: 0
Total Preference: 1 ,307
Exchange of Use: 44
Average Actual Use: 993
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
43
16
1
60
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Appendix I-30
Table 9. Allotment Management Summaries (continued)
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Riparian or aquatic habitat is in
less than good habitat condition.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
Conditon objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Prather Creek
Public Acres:
1,025
Allot. No.: 5102
Other Acres:
Mgmt. Category: M
783
Grazing Administration Info. (AUMs)
Active Preference: 41
Suspended Nonuse: 13
Total Preference: 54
Average Actual Use: 76
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Appendix 1-31
Table 9. Allotment Management Summaries (continued)
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Lime Kiln/Sec. 30
Public Acres: 3,314
Allot. No.: 5103
Other Acres:
Mgmt. Category: M
Grazing Administration Info. (AUMs)
Active Preference: 224
Suspended Nonuse: 161
Total Preference: 385
Average Actual Use: 193
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-32
Table 9. Allotment Management Summaries (continued)
Allotment Name: Soldier Creek
Public Acres:
2,673
Grazing Administration Info. (AUMs)
Active Preference: 102
Suspended Nonuse: 98
Total Preference: 200
Exchange of Use: 163
Average Actual Use: 275
Allot. No.: 5104
Other Acres:
Mgmt. Category: M
2,290
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
15
8
1
24
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-33
Table 9. Allotment Management Summaries (continued)
Allotment Name: Camp Harney
Public Acres:
13,423
Grazing Administration Info. (AUMs)
Active Preference: 953
Suspended Nonuse: 639
Total Preference: 1 ,592
Average Actual Use: 973
Allot. No.: 5105
Other Acres:
Mgmt. Category: I
3,342
ther Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
71
52
2
125
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, bald eagle, redband
trout, Malheur mottled sculpin
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Species officially listed as Threatened or Endangered under the Endangered Species Act and/or their critical habitat occur within
the allotment. Consult with USFWS on ail actions which may affect the species and mitigate all management practices to avoid
adversely affecting the species.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-34
Table 9. Allotment Management Summaries (continued)
Allotment Name: Cow Creek
Public Acres:
2,024
Grazing Administration Info. (AUMs)
Active Preference: 230
Suspended Nonuse: 0
Total Preference: 230
Exchange of Use: 240
Average Actual Use: 359
Allot. No.: 5106
Other Acres:
Mgmt. Category: I
2,009
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
8
12
1
21
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-35
Table 9. Allotment Management Summaries (continued)
Allotment Name: Manning Field
Public Acres:
120
Allot. No.: 5107
Other Acres:
Grazing Administration Info. (AUMs)Other Forage Demands (AUMs)
Active Preference: 10
Suspended Nonuse: 0
Total Preference: 1 0
Average Actual Use: 10
Deer:
Elk:
Antelope:
Horses:
Total:
Mgmt. Category: C
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Purdy FFR
Public Acres:
104
No.: 5109
Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 15
Suspended Nonuse: 0
Total Preference: 15
Average Actual Use: 15
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-36
Table 9. Allotment Management Summaries (continued)
Allotment Name: Reed FFR
Public Acres:
255
Allot. No.: 5110
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)Other Forage Demands (AUMs)
Active Preference: 18
Suspended Nonuse: 0
Total Preference: 1 8
Average Actual Use: 18
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Temple FFR
Public Acres:
360
Allot. No.: 5111
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)'
Active Preference: 28
Suspended Nonuse: 0
Total Preference: 28
Average Actual Use: 28
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-37
Table 9. Allotment Management Summaries (continued)
Allotment Name: Smith FFR
Public Acres:
-;2Q
Allot. No.: 5112
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 15
Suspended Nonuse: 0
Total Preference: 1 5
Average Actual Use: 15
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Rattlesnake FFR
Public Acres:
60
Allot. No.: 5113
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 6
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Unallotted grazing area.
Management
Objectives
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-38
Table 9. Allotment Management Summaries (continued)
Allotment Name: Coleman Creek
Public Acres:
2,766
Grazing Administration Info. (AUMs)
Active Preference: 424
Suspended Nonuse: 101
Total Preference: 525
Average Actual Use: 248
Allot. No.: 5201
Other Acres:
Mgmt. Category: M
3,133
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
9
12
1
22
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-39
Table 9. Allotment Management Summaries (continued)
Allotment Name: Hunter
Public Acres:
2,778
Allot. No.: 5202
Other Acres:
Mgmt. Category: M
3,777
Grazing Administration Info. (AUMs)
Active Preference: 453
Suspended Nonuse: 0
Total Preference: 453
Exchange of Use: 56
Average Actual Use: 405
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
12
1
23
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Catterson
Public Acres:
640
Allot. No.: 5203
Other Acres:
Mgmt. Category: C
640
Grazing Administration Info. (AUMs)
Active Preference: 125
Suspended Nonuse: 0
Total Preference: 125
Average Actual Use: 125
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
3
12
1
15
identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
Appendix I-40
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Slocum
Public Acres:
1,912
Allot. No.: 5204
Other Acres:
Mgmt. Category: M
3,593
Grazing Administration Info. (AUMs)
Active Preference: 300
Suspended Nonuse: 0
Total Preference: 300
Exchange of Use: 560
Average Actual Use: 487
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
3
12
1
16
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Venator
Public Acres:
2,589
Grazing Administration Info. (AUMs) O
Active Preference: 320
Suspended Nonuse: 0
Total Preference: 320
Exchange of Use: 480
Average Actual Use: 655
Allot. No.: 5205
Other Acres:
Mgmt. Category: M
4,942
ther Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Appendix 1-41
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Stockade FFR
Public Acres: 1,041
Grazing Administration Info. (AUMs)
Active Preference: 162
Suspended Nonuse: 0
Total Preference: 1 62
Average Actual Use: 162
Allot. No.: 5206
Other Acres:
Mgmt. Category: M
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Appendix I-42
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Allotment Name: Coyote Creek
Public Acres:
1,077
Grazing Administration Info. (AUMs)
Active Preference: 110
Suspended Nonuse: 14
Total Preference: 124
Average Actual Use: 144
Allot. No.: 5207
Other Acres:
Mgmt. Category: M
100
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I -43
Table 9. Allotment Management Summaries (continued)
Allotment Name: Emmerson
Public Acres:
1,850
Grazing Administration Info. (AUMs)
Active Preference: 258
Suspended Nonuse: 0
Total Preference: 258
Exchange of Use: 147
Average Actual Use: 346
Allot. No.: 5208
Other Acres:
Mgmt. Category: M
1,667
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
17
17
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse. ,
Allotment Name: Crane
Public Acres:
1,935
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Exchange of Use:
Average Actual Use:
236
0
236
113
376
Allot. No.: 5209
Mgmt. Category: M
Other Acres:
2,786
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-44
Table 9. Allotment Management Summaries (continued)
Allotment Name: Beckley Home
Public Acres:
1,814
Allot. No.: 5211
Other Acres:
Mgmt. Category: C
1,811
Grazing Administration Info. (AUMs)Other Forage Demands (AUMs)
Active Preference: 113
Suspended Nonuse: 0
Total Preference: 113
Average Actual Use: 1 13
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Mahon Ranch
Public Acres:
4,577
Allot. No.: 5212
Other Acres:
Mgmt. Category: M
5,244
Grazing Administration Info. (AUMs)
Active Preference: 329
Suspended Nonuse: 0
Total Preference: 329
Average Actual Use: 313
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-45
Table 9. Allotment Management Summaries (continued)
Allotment Name: Beaver Creek
Public Acres:
8,812
Allot. No.: 5213
Other Acres:
Mgmt. Category: M
6,789
Grazing Administration Info. (AUMs)
Active Preference: 1,018
Suspended Nonuse: 206
Total Preference: 1 ,224
Exchange of Use: 970
Average Actual Use: 1 ,474
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
12
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Hamilton
Public Acres:
2,437
Allot. No.: 5214
Other Acres:
Mgmt. Category: I
1,320
Grazing Administration Info. (AUMs)
Active Preference: 245
Suspended Nonuse: 0
Total Preference: 245
Exchange of Use: 245
Average Actual Use: 722
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Appendix !-46
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Davies
Public Acres:
3,442
Grazing Administration Info. (AUMs)
Active Preference: 253
Suspended Nonuse: 0
Total Preference: 253
Exchange of Use: 234
Average Actual Use: 451
Allot. No.: 5215
Other Acres:
Mgmt. Category: I
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
3,500
Identified Resource
Conflicts/Concerns
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-47
Table 9. Allotment Management Summaries (continued)
Allotment Name: Quier FFR
Public Acres:
150
Allot. No.: 5216
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 5
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Unallotted grazing area.
Management
Objectives
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Thompson FFR
Public Acres:
471
Allot. No.: 5217
Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 77
Suspended Nonuse: 0
Total Preference: 77
Average Actual Use: 54
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-48
Table 9. Allotment
Management Summaries (continued)
Allotment Name: Bennett FFR
Allot. No.: 5218
Mgmt. Category: C
Public Acres:
320
Other Acres:
Grazing Administration Infc
. (AUMs)
Other Forage Demands (AUMs)
Active Preference:
18
Deer:
Suspended Nonuse:
0
Elk:
Total Preference:
18
Antelope:
Average Actual Use:
18
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Hamilton FFR
Public Acres:
120
Grazing Administration Info. (AUMs)
Active Preference: 19
Suspended Nonuse: 0
Total Preference: 1 9
Average Actual Use: 19
Allot. No.: 5219
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-49
'■ • -
Table 9. Allotment Management Summaries (continued)
Allotment Name: Princeton
Public Acres:
17,528
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Exchange of Use:
Average Actual Use:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew, Rorippa
columbiae
2,532
0
2,532
124
5,515
Allot. No.: 5301
Other Acres:
Mgmt. Category: M
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
4,280
11
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Big Bird
Public Acres:
2,567
Grazing Administration Info. (AUMs)
Active Preference: 418
Suspended Nonuse: 0
Total Preference: 418
Average Actual Use: 947
Allot. No.: 5302
Other Acres:
Mgmt. Category: M
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
418
Appendix I-50
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Management
Objectives
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Dry Lake
Allot. No.: 5303 Mgmt. Category: M
Public Acres: 37,949
Other Acres: 5,848
Grazing Administration Info. (AUMs)
Other Forage Demands (AUMs)
Active Preference: 5,228
Deer: 37
Suspended Nonuse: 0
Elk:
Total Preference: 5,228
Antelope: 5
Average Actual Use: 1 1 ,421
Horses:
Total: 42
Identified Resource
Conflicts/Concerns
Management
Objectives
Wetlands habitat in less than
satisfactory condition.
Improve wetlands habitat condition to
satisfactory or better.
Playa habitat occurs in the
allotment.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew, Ferruginous hawk,
redband trout
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation
at least 85 percent of the winter range currently si
conversions must be limited to less than 400 acres in size. Maintain browse on
pporting browse.
Appendix 1-51
: "■' ■ ■ • "~
Table 9. Allotment Management Summaries (continued)
Allotment Name: Crow's Nest
Public Acres:
2,921
Allot. No.: 5305
Other Acres:
Mgmt. Category: M
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Average Actual Use:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew
0
0
0
1,307
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Rocky Ford
Public Acres:
4,457
Grazing Administration Info. (AUMs)
Active Preference: 900
Suspended Nonuse: 0
Total Preference: 900
Average Actual Use: 1 ,607
Allot. No.: 5306
Other Acres:
Mgmt. Category: M
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew, Ferruginous hawk
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-52
Table 9. Allotment Management Summaries (continued)
Allotment Name: Smyth Creek
Public Acres:
20,417
Allot. No.: 5307
Other Acres:
Mgmt. Category: I
3,622
Grazing Administration Info. (AUMs)
Active Preference: 1,919
Suspended Nonuse: 0
Total Preference: 1,919
Average Actual Use: 1 ,988
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
61
104
5
492
794
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
Playa habitat occurs in the
allotment.
The Kiger Mustang Area of Critical
Environmental concern occurs within
allotment.
The allotment contains all or a
portion of the Kiger Wild
Horse Herd Management Area.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Appendix I-53
Table 9. Allotment Management Summaries (continued)
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensurethatsubstantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit
treatment of this area by mechanical or prescribed fire means to less than
20 percent of area in any one year.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter ra nge currently supporting browse.
Allotment Name: Kiger
Public Acres:
8,720
Allot. No.: 5308
Other Acres:
Mgmt. Category: I
Grazing Administration Info. (AUMs)
Active Preference: 856
Suspended Nonuse: 0
Total Preference: 856
Exchange of Use: 215
Average Actual Use: 1 ,1 00
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
26
35
2
360
424
Identified Resource
Conflicts/Concerns
The allotment contains all or a
portion of the Kiger Wild
Horse Herd Management Area.
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
The Kiger Mustang Area of Critical
Environmental Concern occurs within
allotment.
Management
Objectives
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Appendix I-54
Table 9. Allotment Management Summaries (continued)
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Happy Valley
Public Acres:
17,356
Allot. No.: 5309
Other Acres:
Mgmt. Category: M
560
Grazing Administration Info. (AUMs)
Active Preference: 2,107
Suspended Nonuse: 291
Total Preference: 2,398
Exchange of Use: 52
Average Actual Use: 2,146
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
25
88
4
132
117
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew, Ferruginous
hawk, redband trout, Malheur mottled
sculpin
Riparian or aquatic habitat is in
less than good habitat
condition.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Appendix I-55
Table 9. Allotment Management Summaries (continued)
The Kiger Mustang Area of Critical
Environmental Concern occurs within
allotment.
The allotment contains all or a
portion of the Kiger Wild
Horse Herd Management Area.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Riddle Mountain Allot. No.: 5310
Public Acres: 20,228
Mgmt. Category: I
Other Acres:
4,053
Other Forage Demands (AUMs)
Deer:
177
Elk:
188
Antelope:
3
Horses:
Total:
371
Management
Objectives
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Exchange of Use:
Average Actual Use:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Playa habitat occurs in the
allotment.
3,095
291
3,386
248
3,026
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Appendix I-56
Table 9. Allotment Management Summaries (continued)
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Riparian or aquatic habitat is in
less than good habitat
condition.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Virginia Valley FFRAIIot. No.: 5311
Public Acres: 160
Mgmt. Category: C
Other Acres:
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Unallotted grazing area.
Management
Objectives
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-57
;^^=— rzzzs:
Table 9. Allotment Management Summaries (continued)
Allotment Name: Burnt Flat
Public Acres:
30,388
Allot. No.: 5313
Other Acres:
Mgmt. Category: I
4,590
Grazing Administration Info. (AUMs)
Active Preference: 3,863
Suspended Nonuse: 0
Total Preference: 3,863
Exchange of Use: 571
Average Actual Use: 3,676
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
83
64
15
672
834
Identified Resource
Conflicts/Concerns
The allotment contains all or a
portion of the Riddle Mountain Wild
Horse Herd Management Area.
No forage allocations for elk use
in the allotment have been made.
Playa habitat occurs in the
allotment.
The Kiger Mustang Area of Critical
Environmental Concern occurs within
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Ferruginous hawk
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Allocate forage to meet elk forage
demands.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Wilderness Study Area occurs within allotment. All management activities must conform to Interim Management Protection policy
and be mitigated, as needed, to ensure nonimpairment of wilderness values.
Appendix I-58
Table 9. Allotment Management Summaries (continued)
Allotment Name: Baker FFR
Allot. No.: 5314 Mgmt. Category: C
Public Acres:
360
Other Acres:
Grazing Administration Info. (AUMs)
Other Forage Demands (AUMs)
Active Preference:
0
Deer:
0
Suspended Nonuse:
0
Elk:
0
Total Preference:
0
Antelope:
0
Average Actual Use:
24
Horses:
0
Total:
0
Identified Resource
Conflicts/Concerns
Management
Objectives
Unallotted grazing area.
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Virginia ValleyAllot. No.: 5316
Public Acres: 16,263
Mgmt. Category: M
Other Acres:
1,993
Grazing Administration Info. (AUMs)
Active Preference: 3,640
Suspended Nonuse: 0
Total Preference: 3,640
Exchange of Use: 155
Average Actual Use: 4,747
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
20
28
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-59
" " ~ lTT" ~
=z==
Table 9. Allotment Management Summaries (continued)
Allotment Name: Hatt Butte
Public Acres:
1,560
Allot. No.: 5317
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 103
Suspended Nonuse: 0
Total Preference: 103
Average Actual Use: 103
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Ferruginous hawk
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Black Butte
Public Acres:
760
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Exchange of Use:
Average Actual Use:
Identified Resource
Conflicts/Concerns
95
0
95
10
85
Allot. No.: 5318
Other Acres:
Mgmt. Category: C
120
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-60
:
"■■<■:• ■ ■'-• ■-' ~!
Table 9. Allotment Management Summaries (continued)
Allotment Name: Driveway
Public Acres:
1,680
Allot. No.: 5319
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
Trailing use only.
CONSTRAINTS
Ensurethatsubstantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Kegler FFR
Public Acres:
160
Allot. No.: 5320
Other Acres:
Mgmt. Category: C
600
Grazing Administration Info. (AUMs)
Active Preference: 1 6
Suspended Nonuse: 0
Total Preference: 1 6
Average Actual Use: 1 6
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-61
Table 9. Allotment Management Summaries (continued)
Allotment Name: Hamilton Ind.Allot. No.: 5321
Public Acres: 1,122
Mgmt. Category: I
Other Acres:
Grazing Administration Info. (AUMs)
Active Preference: 150
Suspended Nonuse: 0
Total Preference: 150
Average Actual Use: 150
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Area influencing perennial water occurs within the allotment. Limit
treatment of this area by mechanical or prescribed fire means to less than
20 percent of area in any one year.
Appendix I-62
Table 9. Allotment Management Summaries (continued)
Allotment Name: Briggs FFR
Public Acres:
1,030
Grazing Administration Info. (AUMs)
Active Preference: 230
Suspended Nonuse: 0
Total Preference: 230
Average Actual Use: 230
Allot. No.: 5322
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Clemens' FFR
Public Acres:
730
Allot. No.: 5323
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 78
Suspended Nonuse: 0
Total Preference: 78
Average Actual Use: 78
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-63
Table 9. Allotment Management Summaries (continued)
Allotment Name: Riddle FFR
Public Acres:
160
Allot. No.: 5324
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 5
Suspended Nonuse: 0
Total Preference: 5
Average Actual Use: 5
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Marshall Diamond FFRAMot. No.: 5325
Public Acres: 320
Mgmt. Category: C
Other Acres:
Grazing Administration Info. (AUMs)
Active Preference: 40
Suspended Nonuse: 0
Total Preference: 40
Average Actual Use: 40
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-64
Table 9. Allotment Management Summaries (continued)
Allotment Name: Jenkins N.Lake FFRAIIot. No.: 5326
Public Acres: 80
Mgmt. Category: C
Other Acres:
Grazing Administration Info. (AUMs)
Active Preference: 30
Suspended Nonuse: 0
Total Preference: 30
Average Actual Use: 30
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Jenkins B.FIat FFRAIIot. No.: 5327
Public Acres: 1,480
Mgmt. Category: C
Other Acres:
Grazing Administration Info. (AUMs)
Active Preference: 283
Suspended Nonuse: 0
Total Preference: 283
Average Actual Use: 283
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Wilderness Study Area occurs within allotment. All management activities must conform to Interim Management Protection policy
and be mitigated, as needed, to ensure nonimpairment of wilderness values.
Appendix I-65
Table 9. Allotment Management Summaries (continued)
Allotment Name: Fisher FFR
Public Acres:
320
Allot. No.: 5328
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 46
Suspended Nonuse: 0
Total Preference: 46
Average Actual Use: 46
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Riddle-Coyote
Public Acres:
446
Allot. No.: 5329
Other Acres:
Mgmt. Category: I
1,998
Grazing Administration Info. (AUMs)'
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
'Newly acquired allotment. Insufficient data to determine forage availability
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Appendix I-66
Table 9. Allotment Management Summaries (continued)
Riparian or aquatic habitat is in
less than good habitat
condition.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Deep Creek
Allot. No.: 5330 Mgmt. Category: 1
Public Acres: 640
Other Acres:
Grazing Administration Info. (AUMs)
Other Forage Demands (AUMs)
Active Preference: 128
Deer:
Suspended Nonuse: 0
Elk:
Total Preference: 128
Antelope:
Average Actual Use: 1 28
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM-
authorized actions are having a
negative effect on water quality.
No forage allocations for elk use
in the allotment have been made.
Allocate forage to meet elk forage
demands.
Appendix 1-67
Table 9. Allotment Management Summaries (continued)
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: East Cow CreekAllot. No.: 5501
Public Acres: 5,641
Mgmt. Category: M
Other Acres:
2,603
Grazing Administration Info. (AUMs)
Active Preference: 809
Suspended Nonuse: 32
Total Preference: 841
Exchange of Use: 294
Average Actual Use: 856
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
12
2
24
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Appendix 1-68
Table 9. Allotment Management Summaries (continued)
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Rock Creek
Public Acres:
4,849
Allot. No.: 5502
Other Acres:
Mgmt. Category: M
2,322
Grazing Administration Info. (AUMs)
Active Preference: 568
Suspended Nonuse: 134
Total Preference: 702
Average Actual Use: 501
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-69
H^^HBl^^^Hi
' i^an— — ii^^iii^mi
Table 9. Allotment Management Summaries (continued)
Allotment Name: Pine Creek
Public Acres:
21,930
Allot. No.: 5503
Other Acres:
Mgmt. Category: I
13,406
Grazing Administration Info. (AUMs)
Active Preference: 2,410
Suspended Nonuse: 971
Total Preference: 3,381
Average Actual Use: 1 ,421
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
84
68
7
159
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Lupinus cusickii
The Biscuitroot Cultural Area of
Critical Environmental Concern
occurs within allotment.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-70
Table 9. Allotment Management Summaries (continued)
Allotment Name: State Field
Public Acres:
568
Allot. No.: 5504
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 98
Suspended Nonuse: 0
Total Preference: 98
Average Actual Use: 98
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
The Biscuitroot Cultural Area of
Critical Environmental Concern
occurs within allotment.
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Little Muddy Creek
Public Acres: 7,261
Allot. No.: 5505
Other Acres:
Mgmt. Category: M
4,492
Grazing Administration Info. (AUMs)
Active Preference: 962
Suspended Nonuse: 262
Total Preference: 1 ,224
Exchange of Use: 143
Average Actual Use: 536
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
40
128
Appendix 1-71
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Muddy Creek
Public Acres:
4,298
Allot. No.: 5506
Other Acres:
Mgmt. Category: M
1,121
Grazing Administration Info. (AUMs)
Active Preference: 504
Suspended Nonuse: 0
Total Preference: 504
Exchange of Use: 52
Average Actual Use: 530
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
38
20
53
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Appendix I-72
Table 9. Allotment Management Summaries (continued)
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Wolf Creek
Public Acres:
830
Allot. No.: 5507
Other Acres:
Mgmt. Category: M
600
Grazing Administration Info. (AUMs)
Active Preference: 136
Suspended Nonuse: 0
Total Preference: 136
Average Actual Use: 293
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
20
12
3
35
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-73
Table 9. Allotment Management Summaries (continued)
Allotment Name: Baker-Knowles
Public Acres:
845
Allot. No.: 5508
Other Acres:
Mgmt. Category: M
11
Grazing Administration Info. (AUMs)
Active Preference: 58
Suspended Nonuse: 82
Total Preference: 140
Exchange of Use: 3
Average Actual Use: 53
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
15
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Williams Dripp SpringAllot. No.: 5509
Public Acres: 1,345
Mgmt. Category: M
Other Acres:
Grazing Administration info. (AUMs)
Active Preference: 176
Suspended Nonuse: 67
Total Preference: 243
Exchange of Use: 64
Average Actual Use: 272
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
15
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
Appendix I-74
Table 9. Allotment Management Summaries (continued)
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Jones Dripp Spring
Public Acres: 757
Allot. No.: 5510
Other Acres:
Mgmt. Category: M
245
Grazing Administration Info. (AUMs)
Active Preference: 120
Suspended Nonuse: 0
Total Preference: 120
Exchange of Use: 33
Average Actual Use: 121
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
15
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-75
Table 9. Allotment Management Summaries (continued)
Allotment Name: Moffet Table
Public Acres:
16,412
Allot. No.: 5511
Other Acres:
Mgmt. Category: I
2,817
Grazing Administration Info, (fi
WMs)
Active Preference:
1,885
Suspended Nonuse:
1,273
Total Preference:
3,158
Exchange of Use:
23
Average Actual Use:
1,238
Identified Resource
Conflicts/Concerns
Management
Objectives
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
River segment nominated for
inclusion in the Wild and Scenic
River system.
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
202
172
3
377
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Adjust livestock grazing management
within river corridor to conform with
study report and/or river management
plan upon Congressional approval of
river segment for inclusion in Wild and
Scenic River system.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian oi
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
or
Appendix I-76
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Wilderness Study Area occurs within allotment. All management activities must conform to Interim Management Protection policy
and be mitigated, as needed, to ensure nonimpairment of wilderness values.
Allotment Name: Clark's River
Public Acres:
S'sS
Allot. No.: 5512
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 40
Suspended Nonuse: 0
Total Preference: 40
Exchange of Use: 40
Average Actual Use: 40
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
IS
19
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species or
communities in abundances necessary for their continued existance and normal functioning.
Allotment Name: Shelley
Public Acres:
5,199
Allot. No.: 5513
Other Acres:
Mgmt. Category: M
620
Grazing Administration Info. (AUMs)
Active Preference: 600
Suspended Nonuse: 0
Total Preference: 600
Average Actual Use: 555
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
15
4
1
20
Appendix I-77
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Coal Mine Creek
Public Acres:
5,217
Allot. No.: 5514
Other Acres:
Mgmt. Category: I
54
Grazing Administration Info. (AUMs)
Active Preference: 452
Suspended Nonuse: 54
Total Preference: 506
Average Actual Use: 1 98
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
19
20
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species or
communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-78
Table 9. Allotment Management Summaries (continued)
Allotment Name: Mule Creek
Public Acres:
5,604
Allot. No.: 5515
Other Acres:
Mgmt. Category: I
1,591
Grazing Administration Info. (AUMs)
Active Preference: 41 1
Suspended Nonuse: 527
Total Preference: 938
Average Actual Use: 333
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
42
28
2
72
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Improve surface water quality on public
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensurethat substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-79
Table 9. Allotment Management Summaries (continued)
Allotment Name: Birch Creek
Public Acres:
1,340
Allot. No.: 5516
Other Acres:
Mgmt. Category: M
40
Grazing Administration Info. (AUMs)
Active Preference: 243
Suspended Nonuse: 0
Total Preference: 243
Average Actual Use: 209
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
31
20
51
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species or
communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Otis Mountain
Public Acres:
12,991
Allot. No.: 5517 Mgmt. Category:
Other Acres:
1,166
Other Forage Demands (AUMs)
Deer:
100
Elk:
72
Antelope:
Horses:
Total:
172
Grazing Administration Info. (AUMs)
Active Preference: 1,738
Suspended Nonuse: 776
Total Preference: 2,514
Average Actual Use: 899
Appendix I-80
Table 9. Allotment Management Summaries (continued)
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Newell Field
Public Acres:
990
Allot. No.: 5518
Other Acres:
Mgmt. Category: C
800
Grazing Administration Info. (AUMs)
Active Preference: 155
Suspended Nonuse: 0
Total Preference: 155
Average Actual Use: 155
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-81
Table 9. Allotment Management Summaries (continued)
Allotment Name: Big Upson
Public Acres:
220
Allot. No.: 5519
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 42
Suspended Nonuse: 0
Total Preference: 42
Average Actual Use: 42
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Little Upson
Public Acres:
100
Allot. No.: 5520
Other Acres:
Mgmt. Category: C
520
Grazing Administration Info. (AUMs)
Active Preference: 24
Suspended Nonuse: 0
Total Preference: 24
Average Actual Use: 24
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-82
Table 9. Allotment Management Summaries (continued)
Allotment Name: Rocky Basin
Public Acres:
3,775
Allot. No.: 5521
Other Acres:
Mgmt. Category: M
Grazing Administration Info. (AUMs)
Active Preference: 467
Suspended Nonuse: 0
Total Preference: 467
Average Actual Use: 416
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
12
20
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Cottonwood CreekAllot. No.: 5522
Public Acres: 8,397
Mgmt. Category: M
Other Acres:
1,285
Other Forage Demands (AUMs)
Deer:
42
Elk:
36
Antelope:
Horses:
Total:
78
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Exchange of Use:
Average Actual Use:
186
1,182
143
227
Appendix I-83
r&jiQ 9.
im cs
ummaries (continued)
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limittreatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Tub Spring/Hart
Public Acres:
5,478
Allot. No.: 5523
Other Acres:
Mgmt. Category: M
215
Grazing Administration Info. (AUMs)
Active Preference: 1,002
Suspended Nonuse: 53
Total Preference: 1 ,055
Average Actual Use: 919
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
Substantial surface acreage
within allotment affected by
mineral development activities.
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Adjust allotment capacities and
management system, as needed, to address
minerals development impacts.
Appendix I-84
Table 9. Allotment Managemer
imaries (continued)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Dawson Butte
Public Acres:
3,837
Allot. No.: 5524
Other Acres:
Mgmt. Category: I
Grazing Administration Info. (AUMs)
Active Preference: 614
Suspended Nonuse: 0
Total Preference: 614
Average Actual Use: 555
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-85
Table 9. Allotment Management Summaries (continued)
Allotment Name: Mill Gulch
Public Acres:
2,281
Allot. No.: 5525
Other Acres:
Mgmt. Category: M
640
Grazing Administration Info. (AUMs)
Active Preference: 525
Suspended Nonuse: 0
Total Preference: 525
Exchange of Use: 67
Average Actual Use: 563
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
Substantial surface acreage
within allotment affected by
mineral development activities.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Adjust allotment capacities and
management system, as needed, to address
minerals development impacts.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Chalk Hills
Public Acres:
9,262
Allot. No.: 5526
Other Acres:
Mgmt. Category: M
1,130
Grazing Administration Info. (AUMs)
Active Preference: 936
Suspended Nonuse: 762
Total Preference: 1,698
Exchange of Use: 87
Average Actual Use: 850
Appendix I-86
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
54
54
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
Substantial surface acreage
within allotment affected by
mineral development activities.
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Adjust allotment capacities and
management system, as needed, to address
minerals development impacts.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Riverside FFR
Public Acres:
255
Allot. No.: 5527
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 35
Suspended Nonuse: 0
Total Preference: 35
Average Actual Use: 35
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-87
Table 9. Allotment Management Summaries (continued)
Allotment Name: Cooler
Public Acres:
5,020
Allot. No.: 5528
Other Acres:
Mgmt. Category: M
250
Grazing Administration Info. (AUMs)
Active Preference: 530
Suspended Nonuse: 0
Total Preference: 530
Average Actual Use: 531
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
11
12
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Trifolium leibergii
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: House Butte
Public Acres:
22,857
Allot. No.: 5529
Other Acres:
Mgmt. Category: M
2,645
Grazing Administration Info. (AUMs)
Active Preference: 2,085
Suspended Nonuse: 912
Total Preference: 2,997
Exchange of Use: 93
Average Actual Use: 2,219
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
107
113
Appendix I-88
n- — — —
T&:
Management Summaries (continued)
Identified Resource
Conflicts/Concerns
The Biscuitroot Cultural Area of
Critical Environmental Concern
occurs within allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: River
Public Acres:
24,422
Allot. No.: 5530
Other Acres:
Mgmt. Category: I
2,760
Grazing Administration Info. (AUMs)
Active Preference: 1,649
Suspended Nonuse: 973
Total Preference: 2,622
Exchange of Use: 180
Average Actual Use: 839
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
33
33
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, bighorn sheep, redband
trout, Triflolium leibergii, Lupinus
biddlej
Riparian or aquatic habitat is in
less than good habitat
condition.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Appendix I-89
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Stinkingwater
Public Acres:
23,461
Allot. No.: 5531
Other Acres:
Mgmt. Category: I
1,413
Grazing Administration Info. (AUMs)
Active Preference: 2,857
Suspended Nonuse: 1,659
Total Preference: 4,516
Exchange of Use: 37
Average Actual Use: 3,137
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
23
28
15
240
306
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, bighorn
sheep
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
The Biscuitroot Cultural Area of
Critical Environmental Concern
occurs within allotment.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Appendix I-90
Table 9. Allotment Management Summaries (continued)
The allotment contains all or a
portion of the Stinkingwater Wild
Horse Herd Management Area.
Allotment Name: Stinkingwater (Con't)
Riparian or aquatic habitat is in
less than good habitat
condition.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Mountain
Public Acres:
37,811
Grazing Administration Info. (AUMs)
Active Preference: 3,374
Suspended Nonuse: 1,567
Total Preference: 4,941
Exchange of Use: 298
Average Actual Use: 3,059
Allot. No.: 5532
Other Acres:
Mgmt. Category: I
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
5,585
166
352
10
620
1,148
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Limiting big game habitat in
unsatisfactory habitat condition.
The Biscuitroot Cultural Area of
Critical Environmental Concern
occurs within allotment.
The allotment contains all or a
portion of the Stinkingwater Wild
Horse Herd Management Area.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain big game habitat
in satisfactory habitat condition.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Appendix 1-91
Table 9. Allotment Management Summaries (continued)
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spray ing, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Buchanan
Public Acres:
2,328
Grazing Administration Info. (AUMs)
Active Preference: 152
Suspended Nonuse: 131
Total Preference: 283
Exchange of Use: 160
Average Actual Use: 368
Allot. No.: 5533
Other Acres:
Mgmt. Category: M
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
2,698
Identified Resource
Conflicts/Concerns
The Biscuitroot Cultural Area of
Critical Environmental Concern
occurs within allotment.
Management
Objectives
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Appendix I-92
Table 9. Allotment Management Summaries (continued)
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Mahon Creek
Public Acres:
2,625
Allot. No.: 5534
Other Acres:
Mgmt. Category: M
30
Grazing Administration Info. (AUMs)
Active Preference: 273
Suspended Nonuse: 184
Total Preference: 457
Average Actual Use: 292
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
22
12
34
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-93
Table 9. Allotment Management Summaries (continued)
Allotment Name: Miller Canyon
Public Acres:
6,198
Allot. No.: 5535
Other Acres:
Mgmt. Category: I
850
Grazing Administration Info. (AUMs)
Active Preference: 450
Suspended Nonuse: 153
Total Preference: 603
Average Actual Use: 330
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
51
12
63
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Allotment contains all or a portion of a Wild Horse Herd Management Area. Management actions must be mitigated, as needed, to
ensure free-roaming nature of the herd.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-94
Table 9. Allotment Management Summaries (continued)
Allotment Name: Alder Creek
Public Acres:
29,809
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Exchange of Use:
Average Actual Use:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, bald
eagle
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
2,584
0
2,584
337
3,015
Allot. No.: 5536 Mgmt. Category:
Other Acres:
2,201
Other Forage Demands (AUMs)
Deer:
225
Elk:
196
Antelope:
13
Horses:
Total:
434
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Species officially listed as Threatened or Endangered under the Endangered Species Act and/or their critical habitat occur within
the allotment. Consult with USFWS on all actions which may affect the species and mitigate all management practices to avoid
adversely affecting the species.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-95
Table 9. Allotment Management Summaries (continuec
Allotment Name: Buck Mountain
Public Acres: 14,849
Allot. No.: 5537
Other Acres:
Mgmt. Category: M
1,992
Grazing Administration Info. (AUMs)
Active Preference: 1,515
Suspended Nonuse: 421
Total Preference: 1 ,936
Exchange of Use: 175
Average Actual Use: 1 ,852
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
25
164
20
209
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Lupinus biddlei
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-96
Table 9. Allotment Management Summaries (continued)
Allotment Name: Riverside
Public Acres:
15,588
Allot. No.: 5538
Other Acres:
Mgmt. Category: M
4,884
Grazing Administration Info. (AUMs)
Active Preference: 1,949
Suspended Nonuse: 807
Total Preference: 2,756
Exchange of Use: 728
Average Actual Use: 2,514
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
27
11
38
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
Lupinus biddlei
Intensive recreation use occurs
within the allotment.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Incorporate recreation management
objectives into overall allotment
management system.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix I-97
Table 9. Allotment Management Summaries (continued)
Allotment Name: W&C Blaylock FFR
Public Acres: 410
Allot. No.: 5539
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 30
Suspended Nonuse: 0
Total Preference: 30
Average Actual Use: 30
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
26
26
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Luce Field
Public Acres:
225
Allot. No.: 5540
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 13
Suspended Nonuse: 0
Total Preference: 13
Average Actual Use: 1 3
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-98
Table 9. Allotment Management Summaries (continued)
Allotment Name: Home Ranch ExclosureAllot. No.: 5541
Public Acres: 1,233
Mgmt. Category: C
Other Acres:
Grazing Administration Info. (AUMs)
Active Preference: 100
Suspended Nonuse: 0
Total Preference: 100
Average Actual Use: 100
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Marshall FFR
Public Acres:
302
Allot. No.: 5542
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 13
Suspended Nonuse: 0
Total Preference: 13
Average Actual Use: 13
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix I-99
Table 9. Allotment Management Summaries (continued)
Allotment Name: Devine Flat Field
Public Acres:
78S
t. No.: 5543
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 118
Suspended Nonuse: 0
Total Preference: 118
Average Actual Use: 118
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Brooks Field
Public Acres:
520
Allot. No.: 5544
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 50
Suspended Nonuse: 0
Total Preference: 50
Average Actual Use: 50
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
42
43
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-100
Table 9. Allotment Management Summaries (continued)
Allotment Name: Sunshine Field
Public Acres:
463
Allot. No.: 5545
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 52
Suspended Nonuse: 0
Total Preference: 52
Average Actual Use: 52
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Druitt Field and FFRAIIot. No.: 5546
Public Acres: 746
Mgmt. Category: C
Other Acres:
Grazing Administration Info. (AUMs)
Active Preference: 30
Suspended Nonuse: 0
Total Preference: 30
Average Actual Use: 30
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
15
16
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-101
Table 9. Allotment Management Summaries (continued)
Allotment Name: Lake Field
Public Acres:
30
Allot. No.: 5547
' Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 3
Suspended Nonuse: 0
Total Preference: 3
Average Actual Use: 3
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Substantial surface acreage
within allotment affected by
mineral development activities.
Management
Objectives
Adjust allotment capacities and
management system, as needed, to address
minerals development impacts.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Griffin FFR
Public Acres:
450
Allot. No.: 5548
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 56
Suspended Nonuse: 0
Total Preference: 56
Average Actual Use: 56
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-102
Table 9. Allotment Management Summaries (continued)
Allotment Name: Howards FFR
Public Acres:
392
Allot. No.: 5549
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 30
Suspended Nonuse: 0
Total Preference: 30
Average Actual Use: 30
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Jordan's FFR
Public Acres:
60
Allot. No.: 5550
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 6
Suspended Nonuse: 0
Total Preference: 6
Average Actual Use: 6
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-103
Table 9. Allotment Management Summaries (continued)
Allotment Name: Lillard's FFR
Public Acres:
40
Allot. No.: 5551
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 7
Suspended Nonuse: 0
Total Preference: 7
Average Actual Use: 1 7
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Miller FFR A
Public Acres:
320
Allot. No.: 5552
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 20
Suspended Nonuse: 0
Total Preference: 20
Average Actual Use: 20
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-104
Table 9. Allotment Management Summaries (continued)
Allotment Name: Miller FFR B
Public Acres:
4*4
Allot. No.: 5553
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 5
Suspended Nonuse: 0
Total Preference: 5
Average Actual Use: 5
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: J.Fran Miller FFR
Public Acres:
S49
Allot. No.: 5554
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 25
Suspended Nonuse: 0
Total Preference: 25
Average Actual Use: 25
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-105
Table 9. Allotment Management Summaries (continued)
Allotment Name: Ott FFR
Public Acres:
64
Allot. No.: 5555
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 5
Suspended Nonuse: 0
Total Preference: 5
Average Actual Use: 5
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Pine Creek FFR
Public Acres:
1,298
Allot. No.: 5556
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 1 80
Suspended Nonuse: 0
Total Preference: 1 80
Average Actual Use: 180
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-106
Table 9. Allotment Management Summaries (continued)
Allotment Name: J&G Kane FFR
Public Acres:
110
Allot. No.: 5557
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 5
Suspended Nonuse: 0
Total Preference: 5
Average Actual Use: 5
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: J&G FFR
Public Acres:
130
Allot. No.: 5558
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 33
Suspended Nonuse: 0
Total Preference: 33
Average Actual Use: 33
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-107
Table 9. Allotment Management Summaries (continued)
Allotment Name: Sword's FFR
Public Acres:
172
Grazing Administration Info. (AUMs)
Active Preference: 32
Suspended Nonuse: 0
Total Preference: 32
Average Actual Use: 32
Allot. No.: 5559
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Vicker's FFR
Public Acres:
1,740
Grazing Administration Info. (AUMs)
Active Preference: 1 91
Suspended Nonuse: 0
Total Preference: 191
Average Actual Use: 1 91
Allot. No.: 5560
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-108
Table 9. Allotment Management Summaries (continued)
Allotment Name: Wilber FFR
Public Acres:
1,335
Allot. No.: 5561
Other Acres:
fflgirtt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 125
Suspended Nonuse: 0
Total Preference: 125
Average Actual Use: 125
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Williams' FFR
Public Acres:
Allot. No.: 5562
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 24
Suspended Nonuse: 0
Total Preference: 24
Average Actual Use: 24
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-109
Table 9. Allotm
igement Summaries (continued)
Allotment Name: Arnold's FFR
Public Acres:
230
Allot. No.: 5563
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 23
Suspended Nonuse: 0
Total Preference: 23
Average Actual Use: 23
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Wheeler Basin
Public Acres:
4,981
Allot. No.: 5564
Other Acres:
Mgmt. Category: M
230
Grazing Administration Info. (AUMs)
Active Preference: 618
Suspended Nonuse: 342
Total Preference: 960
Average Actual Use: 737
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
14
14
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-110
Table 9. Allotment Management Summaries (continued)
Allotment Name: Upton Mountain
Public Acres: 13,761
Grazing Administration Info. (AUMs)
Active Preference: 1,615
Suspended Nonuse: 771
Total Preference: 2,386
Average Actual Use: 1 ,404
Allot. No.: 5565
Other Acres:
Mgmt. Category: I
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
354
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, bighorn sheep
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-111
: . . 1
Table 9. Allotment Management Summaries (continued)
Allotment Name: Texaco Basin
Public Acres:
10,714
Allot. No.: 5566
Other Acres:
Mgmt. Category: I
440
Grazing Administration Info. (AUMs)
Active Preference: 1 ,900
Suspended Nonuse: 900
Total Preference: 2,800
Exchange of Use: 22
Average Actual Use: 2,525
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
9
100
109
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Riparian or aquatic habitat is in
less than good habitat
condition.
Wetlands habitat in less than
satisfactory condition.
Intensive recreation use occurs
within the allotment.
The allotment contains all or a
portion of the Stinkingwater Wild
Horse Herd Management Area.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Lupinus
biddei, bighorn sheep
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Improve wetlands habitat condition to
satisfactory or better.
Incorporate recreation management
objectives into overall allotment
management system.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensurethat substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-112
Table 9. Allotment Management Summaries (continued)
Allotment Name: Miler FFR
Public Acres:
160
Allot. No.: 5567
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 1 6
Suspended Nonuse: 0
Total Preference: 1 6
Average Actual Use: 1 6
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensurethatsubstantialvegetationconversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Bryon's FFR
Public Acres:
4«
Allot. No.: 5568
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Average Actual Use:
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-113
Table 9. Allotment Management Summaries (continued)
Allotment Name: Floyd's FFR
Public Acres:
m
Allot. No.: 5569
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 2
Suspended Nonuse: 0
Total Preference: 2
Average Actual Use: 2
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: River FFR
Public Acres:
290
Allot. No.: 5570
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 60
Suspended Nonuse: 0
Total Preference: 60
Average Actual Use: 60
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-114
Table 9. Allotment Management Summaries (continued)
Allotment Name: Lamb Ranch
Public Acres:
2,240
Allot. No.: 5571
Other Acres:
Mgmt. Category: I
Grazing Administration Info. (AUMs)
Active Preference: 246
Suspended Nonuse: 0
Total Preference: 246
Average Actual Use: 246
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-115
Table 9. Allotment Management Summaries (continued)
Allotment Name: Krueger FFR
Public Acres:
30
No.: 5572
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 8
Suspended Nonuse: 0
Total Preference: 8
Exchange of Use: 4
Average Actual Use: 12
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Unallotted grazing area.
Management
Objectives
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: East Warm Springs
Public Acres: 181,390
Allot. No.: 7001
Other Acres:
Mgmt. Category: I
17,547
Grazing Administration Info. (AUMs)
Active Preference: 8,225
Suspended Nonuse: 0
Total Preference: 8,225
Exchange of Use: 40
'Carrying Capacity: 12,292
Average Actual Use: 12,989
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
30
99
1,200
1,379
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
Playa habitat occurs in the
allotment.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Appendix 1-116
Table 9. Allotment Management Summaries (cor
-^m
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew, snowy plover,
Malheur wirelettuce, sage grouse
The South Narrows Area of Critical
Environmental Concern occurs within
allotment.
The allotment contains all or a
portion of the Warm Springs Wild
Horse Herd Management Area.
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
The Foster Flat RNA/ACEC occurs
within the allotment.
Active erosion occurs in the
allotment.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by activity plans associated
with Stephanomeria malheurensis.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system
as required by ACEC Management Plan.
Improve and maintain erosion condition
in moderate or better erosion condition.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Species officially listed as Threatened or Endangered under the Endangered Species Act and/or their critical habitat occur within
the allotment. Consult with USFWS on all actions which may affect the species and mitigate all management practices to avoid
adversely affecting the species.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
"Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-117
Table 9. Allotment Management Summaries (continued)
Allotment Name: West Warm Springs
Public Acres: 295,549
Allot. No.: 7002
Other Acres:
Mgmt. Category: I
11,119
Grazing Administration Info. (AUMs)
Active Preference: 11,167
Suspended Nonuse: 0
Total Preference: 11,167
Exchange of Use: 110
Average Actual Use: 5,1 14
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
116
33
1,224
1,378
Identified Resource
Conflicts/Concerns
Riparian or aquatic habitat is in
less than good habitat
condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, snowy plover
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
The allotment contains all or a
portion of the Warm Springs Wild
Horse Herd Management Area.
Management
Objectives
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-118
Table 9. Allotment Management Summaries (continuec
Allotment Name: East Wagontire
Public Acres: 118,232
Allot. No.: 7003
Other Acres:
Mgmt. Category: I
80,962
Grazing Administration Info. (AUMs)
Active Preference: 8,281
Suspended Nonuse: 0
Total Preference: 8,281
Exchange of Use: 518
Average Actual Use: 6,913
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
86
93
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-119
Table 9. Allotment Management Summaries (continui
Allotment Name: West Wagontire
Public Acres: 66,718
Allot No.: 7004
ier Acres:
Mgmt. Category: !
3,929
Grazing Administration Info. (AUMs)
Active Preference: 7,493
Suspended Nonuse: 0
Total Preference: 7,493
'Carrying Capacity: 4,648
Average Actual Use: 5,682
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
73
82
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
* Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-120
Table 9. Allotment Management Summaries (continued)
Allotment Name: Glass Butte
Public Acres:
7,613
Allot. No.: 7005
Other Acres:
Mgmt. Category: I
953
Grazing Administration Info. (AUMs)
Active Preference: 1,058
Suspended Nonuse: 0
Total Preference: 1 ,058
Exchange of Use: 84
'Carrying Capacity: 518
Average Actual Use: 791
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
12
17
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Substantial surface acreage
within allotment affected by
mineral development activities.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Adjust allotment capacities and
management system, as needed, to address
minerals development impacts.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
* Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-121
Table 9. Allotment Management Summaries (continued)
Allotment Name: Rimrock Lake
Public Acres:
21,815
Allot No.: 7006
Other Acres:
Mgmt. Category: I
619
Grazing Administration Info. (AUMs)
Active Preference: 1,775
Suspended Nonuse: 32
Total Preference: 1 ,807
'Carrying Capacity: 1 ,308
Average Actual Use: 1 ,345
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
25
29
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
"Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-122
Table 9. Allotment Management Summaries (continued)
Allotment Name: Hat Butte
Allot. No.: 7007 Mgmt. Category: I
Public Acres:
18,338
Other Acres: 681
Grazing Administration Info. (AUMs)
Other Forage Demands (AUMs)
Active Preference:
2,209
Deer: 27
Suspended Nonuse:
101
Elk:
Total Preference:
2,310
Antelope: 5
Average Actual Use:
1,586
Horses:
Total: 32
Identified Resource
Conflicts/Concerns
Management
Objectives
Limiting big game habitat in
unsatisfactory habitat condition.
Improve and maintain big game habitat
in satisfactory habitat condition.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices
may be exceeded.
)
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Deer winter range occurs in allotment,
at least 85 percent of the winter range
Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
currently supporting browse.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Sheep Lake-ShieldsAllot. No.
:7008
Mgmt. Category: I
Public Acres:
•
.
13,202
Other Acres: 600
Grazing Administration Info. (AUMs)
Other Forage Demands (AUMs)
Active Preference:
1,685
Deer: 46
Suspended Nonuse:
72
Elk: 21
Total Preference:
1,757
Antelope:
Exchange of Use:
54
Horses:
Average Actual Use:
1,166
Total: 67
Appendix 1-123
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Dry Lake
Public Acres: 20,249
Grazing Administration Info. (AUMs)
Active Preference: 3,099
Suspended Nonuse: 102
Total Preference: 3,201
Exchange of Use: 116
'Carrying Capacity: 2,638
Average Actual Use: 2,158
Allot. No.: 7009
Other Acres:
Mgmt. Category: I
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
6,337
74
25
8
107
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Appendix 1-124
Table 9. Allotment Management Summaries (continued)
Riparian or aquatic habitat is in
less than good habitat
condition.
Wetlands habitat in less than
satisfactory condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, bald eagle, redband
trout, Malheur mottled sculpin
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Improve wetlands habitat condition to
satisfactory or better.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Species officially listed as Threatened or Endangered under the Endangered Species Act and/or their critical habitat occur within
the allotment. Consult with USFWS on all actions which may affect the species and mitigate all management practices to avoid
adversely affecting the species.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-125
Table 9. A!l<
sagement Summaries (contlr
Allotment Name: Claw Creek
Public Acres:
24,244
t. No.: 7010
Other Acres:
Mgmt. Category: I
9,313
Grazing Administration Info. (AUMs)
Active Preference: 2,962
Suspended Nonuse: 141
Total Preference: 3,103
Exchange of Use: 131
'Carrying Capacity: 1 ,241
Average Actual Use: 1 ,1 75
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
160
96
256
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin, bald eagle
Dry Mountain RNA/Area of Critical
Environmental Concern Extension
occurs within allotment.
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Adjust allotment management including
levels and areas of authorized use,
seasons of use and grazing system as
required by ACEC Management Plan.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Species officially listed as Threatened or Endangered under the Endangered Species Act and/or their critical habitat occur within
the allotment. Consult with USFWS on all actions which may affect the species and mitigate all management practices to avoid
adversely affecting the species.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-126
Table 9. Allotment Management Summaries (continued)
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Allotment Name: Upper Valley
Public Acres:
1,745
Allot. No.: 7011
Other Acres:
Mgmt. Category: M
5,155
Grazing Administration Info. (AUMs)
Active Preference: 254
Suspended Nonuse: 11
Total Preference: 265
Average Actual Use: 265
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
3
3
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Management
Objectives
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-127
Table 9. Allotment Management Summaries (continued)
Allotment Name: Packsaddle
Public Acres:
2,368
t. No.: 7012
Other Acres:
Mgmt. Category: I
647
Grazing Administration Info. (AUMs)
Active Preference: 316
Suspended Nonuse: 16
Total Preference: 332
Average Actual Use: 239
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
22
S
40
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
Active erosion occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Improve and maintain erosion condition
in moderate or better erosion condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-128
Table 9. Allotment Management Summaries (continued)
Allotment Name: Zoglmann
Public Acres:
2,240
Allot. No.: 7013
Other Acres:
Mgmt. Category: C
1,600
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Exchange of Use:
Average Actual Use:
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
160
1
161
173
155
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Management
Objectives
Allocate forage to meet elk forage
demands.
10
12
22
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Badger SpringAllot. No.: 7014
Public Acres: 11,043
Mgmt. Category: M
Other Acres:
920
Grazing Administration Info. (AUMs)
Active Preference: 1,048
Suspended Nonuse: 55
Total Preference: 1,103
Exchange of Use: 93
Average Actual Use: 629
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
68
92
160
Appendix 1-129
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Second Flat
Public Acres:
8,921
Allot. No.: 7015
Other Acres:
Mgmt. Category: I
1,281
Grazing Administration Info. (AUMs)
Active Preference: 622
Suspended Nonuse: 32
Total Preference: 725
Exchange of Use: 30
Average Actual Use: 429
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
45
35
11
91
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensurethat substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-130
9. Allotment Management Summaries (continued)
Allotment Name: Juniper Ridge
Public Acres:
26,784
Allot. No.: 7016
Other Acres:
Mgmt. Category: I
2,412
Grazing Administration Info. (AUMs)
Active Preference: 2,041
Suspended Nonuse: 0
Total Preference: 2,076
Exchange of Use: 30
"Carrying Capacity: 1,102
Average Actual Use: 1 ,073
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
34
38
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Allium brandegei
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-131
Table 9. Alio
lanagement Summaries (continued)
Allotment Name: Cluster
Public Acres:
7,843
No.: 7017
Other Acres:
Mgmt. Category: M
13,697
Grazing Administration Info. (AUMs)
Active Preference: 548
Suspended Nonuse: 0
Total Preference: 548
'Carrying Capacity: 317
Average Actual Use: 315
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
* Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Allotment Name: Silver Lake
Public Acres:
16,933
Allot No.: 7018
Other Acres:
Mgmt. Category: I
978
Grazing Administration Info. (AUMs)
Active Preference: 1 ,755
Suspended Nonuse: 0
Total Preference: 1 ,755
Exchange of Use: 36
Average Actual Use: 1 ,406
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Appendix 1-132
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Wetlands habitat in less than
satisfactory condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, snowy plover
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve wetlands habitat condition to
satisfactory or better.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Palomino Buttes
Public Acres: 48,266
Allot. No.: 7019
Other Acres:
Mgmt. Category: I
1,734
Grazing Administration Info. (AUMs)
Active Preference: 2,806
Suspended Nonuse: 89
Total Preference: 2,895
Exchange of Use: 24
'Carrying Capacity: 3,041
Average Actual Use: 3,280
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
264
28
480
772
Identified Resource
Conflicts/Concerns
The allotment contains all or a
portion of the Palomino Buttes Wild
Horse Herd Management Area.
Management
Objectives
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Appendix 1-133
Table 9. Allotment Management Summaries (continued)
Limiting big game habitat in
unsatisfactory habitat condition.
Playa habitat occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Ferruginous hawk,
Eriogonum cusickii
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Improve and maintain big game habitat
in satisfactory habitat condition.
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
"Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Allotment Name: Sand Hollow
Public Acres:
10,240
Allot. No.: 7020
Other Acres:
Mgmt. Category: M
5,650
Grazing Administration Info. (AUMs)
Active Preference: 532
Suspended Nonuse: 0
Total Preference: 532
Average Actual Use: 512
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
33
42
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Appendix 1-134
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Table 9. Allotment Management Summaries (continued)
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Weaver Lake
Public Acres:
23,323
Allot. No.: 7021
Other Acres:
Mgmt. Category: I
880
Grazing Administration Info. (AUMs)
Active Preference: 1,396
Suspended Nonuse: 73
Total Preference: 1 ,469
Average Actual Use: 1 ,595
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
68
17
288
373
Identified Resource
Conflicts/Concerns
Playa habitat occurs in the
allotment.
The allotment contains all or a
portion of the Palomino Buttes Wild
Horse Herd Management Area.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Ferruginous hawk
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Incorporate playa management objectives
into allotment management as such
objectives are developed.
Maintain healthy populations of wild
horses and burros at appropriate
management levels which will achieve
a thriving natural ecological balance.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
Appendix 1-135
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Dog Mountain
Public Acres:
5,120
Allot. No.: 7022
Other Acres:
Mgmt. Category: I
735
Grazing Administration Info. (AUMs)
Active Preference: 176
Suspended Nonuse: 0
Total Preference: 176
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
27
27
Identified Resource
Conflicts/Concerns
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-136
Table 9. Allotment Management Summaries (continued)
Allotment Name: West Sagehen
Public Acres:
13,461
Allot. No.: 7023
Other Acres:
Mgmt. Category: I
495
Grazing Administration Info. (AUMs)
Active Preference: 1,911
Suspended Nonuse: 70
Total Preference: 1,981
Exchange of Use: 77
"Carrying Capacity: 1,010
Average Actual Use: 1,120
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
64
32
7
103
Identified Resource
Conflicts/Concerns
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Eriogonum cusickii
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-137
Table 9. Allotment Manager™
mmaries
Allotment Name: East Sagehen
Public Acres:
23,796
Allot. No.: 7024
Other Acres:
Mgmt. Category: I
5,033
Grazing Administration Info. (AUMs)
Active Preference: 2,510
Suspended Nonuse: 108
Total Preference: 2,618
Exchange of Use: 15
"Carrying Capacity: 1,791
Average Actual Use: 1 ,596
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
105
22
4
131
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
Limiting big game habitat in
unsatisfactory habitat condition.
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, Eriogonum cusickii
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Improve and maintain big game habitat
in satisfactory habitat condition.
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-138
Table 9. Allotment Management Summaries (continued)
Allotment Name: Gouldin
Public Acres:
4,091
Allot. No.: 7025
Other Acres:
Mgmt. Category: I
2,350
Grazing Administration Info. (AUMs)
Active Preference: 567
Suspended Nonuse: 28
Total Preference: 595
Exchange of Use: 189
'Carrying Capacity: 501
Average Actual Use: 432
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
43
43
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
Intensive recreation use occurs
within the allotment.
Limiting big game habitat in
unsatisfactory habitat condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Incorporate recreation management
objectives into overall allotment
management system.
Improve and maintain big game habitat
in satisfactory habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-139
Table 9. Allotment Management Summaries (continued)
Allotment Name: Norton Mill
Public Acres:
3,520
Grazing Administration Info. (AUMs)
Active Preference: 503
Suspended Nonuse: 200
Total Preference: 703
Exchange of Use: 17
Average Actual Use: 305
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Allot. No.: 7026
Other Acres:
Mgmt. Category: I
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
810
15
16
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Emigrant Creek
Public Acres:
225
Allot. No.: 7027
Other Acres:
Mgmt. Category: C
1,360
Grazing Administration Info. (AUMs)
Active Preference: 112
Suspended Nonuse: 0
Total Preference: 112
Average Actual Use: 250
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Appendix 1-140
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Stinger Creek
Public Acres:
50
Allot. No.: 7028
Other Acres:
Mgmt. Category: C
265
Grazing Administration Info. (AUMs)
Active Preference: 3
Suspended Nonuse: 0
Total Preference: 3
Average Actual Use: 3
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-141
Table 9. Allotment Management Summaries (continued)
Allotment Name: Spring Creek
Public Acres:
1,509
Allot. No.: 7029
Other Acres:
Mgmt. Category: C
990
Grazing Administration Info. (AUMs)
Active Preference: 51
Suspended Nonuse: 0
Total Preference: 51
"Carrying Capacity: 1 00
Average Actual Use: 32
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
13
13
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Riparian or aquatic habitat is in
less than good habitat
condition.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Allotment Name: Skull Creek
Public Acres:
27,500
Allot. No.: 7030 Mgmt. Category:
[
Other Acres:
10,414
Other Forage Demands (AUMs)
Deer:
354
Elk:
24
Antelope:
8
Horses:
Total:
386
Grazing Administration Info. (AUMs)
Active Preference: 2,458
Suspended Nonuse: 1,130
Total Preference: 3,588
"Carrying Capacity: 2,871
Average Actual Use: 1 ,823
Appendix 1-142
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout, sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-143
Table 9. Allotment Management Summaries (continu
Allotment Name: Hay Creek
Public Acres:
5,754
Grazing Administration Info. (AUMs)
Active Preference: 585
Suspended Nonuse: 0
Total Preference: 585
Average Actual Use: 540
Allot. No.: 7031
Other Acres:
Mgmt Category: I
5,639
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
29
20
49
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-144
Table 9. Allotment Management Summaries (continued)
Allotment Name: Hotchkiss
Public Acres:
415
Grazing Administration Info. (AUMs)
Active Preference: 26
Suspended Nonuse: 0
Total Preference: 26
Average Actual Use: 22
Allot. No.: 7032
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
335
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for ail beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-145
Table 9. Allotment Management Summaries (continued)
Allotment Name: Silvies River
Public Acres:
1,044
Grazing Administration Info. (AUMs)
Active Preference: 245
Suspended Nonuse: 0
Total Preference: 245
Exchange of Use: 309
"Carrying Capacity: 301
Average Actual Use: 1 89
Allot. No.: 7033
Other Acres:
Mgmt. Category: I
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
699
4
24
28
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
red band trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-146
Table 9. Allotment Management Summaries (continued)
Allotment Name: Scat Field
Public Acres:
837
Grazing Administration Info. (AUMs)
Active Preference: 96
Suspended Nonuse: 0
Total Preference: 96
Average Actual Use: 1 81
Allot. No.: 7034
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
1,826
4
8
5
17
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Silvies Meadows
Public Acres:
1,358
Grazing Administration Info. (AUMs)
Active Preference: 158
Suspended Nonuse: 0
Total Preference: 158
Average Actual Use: 41 1
Allot. No.: 7035
Other Acres:
Mgmt. Category: M
3,150
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
8
IS
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Appendix 1-147
Table 9. Allotment Managemer
immaries (continued)
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Hayes
Public Acres:
5,400
Allot. No.: 7036
Other Acres:
Mgmt. Category: I
560
Grazing Administration Info. (AUMs)
Active Preference: 329
Suspended Nonuse: 761
Total Preference: 1,090
Exchange of Use: 77
Average Actual Use: 262
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
3S
38
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
Appendix 1-148
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Coal Pit Springs
Public Acres: 2,895
Allot. No.: 7037
Other Acres:
Mgmt. Category: C
6,890
Grazing Administration Info. (AUMs)
Active Preference: 370
Suspended Nonuse: 105
Total Preference: 475
Average Actual Use: 265
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
29
29
Identified Resource
Conflicts/Concerns
Active erosion occurs in the
allotment.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Improve and maintain erosion condition
in moderate or better erosion condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-149
Table 9. Allotment Management Summaries (continued)
Allotment Name: Curry Gordon
Public Acres:
729
Allot. No.: 7038
Other Acres:
Mgmt. Category: C
340
Grazing Administration Info. (AUMs)
Active Preference: 72
Suspended Nonuse: 31
Total Preference: 1 03
Exchange of Use: 18
Average Actual Use: 69
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
10
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Cave Gulch
Public Acres:
2,004
Allot. No.: 7039
Other Acres:
Mgmt. Category: M
35
Grazing Administration Info. (AUMs)
Active Preference: 210
Suspended Nonuse: 140
Total Preference: 350
Average Actual Use: 144
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
30
30
Identified Resource
Conflicts/Concerns
Management
Objectives
Appendix 1-150
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Landing Creek
Public Acres:
3,614
Allot. No.: 7040
Other Acres:
Mgmt. Category: I
189
Grazing Administration Info. (AUMs)
Active Preference: 740
Suspended Nonuse: 0
Total Preference: 740
'Carrying Capacity: 310
Average Actual Use: 172
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
43
32
75
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
Appendix 1-151
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
"Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Allotment Name: East Silvies
Public Acres:
4,294
Allot. No.: 7041
Other Acres:
Mgmt. Category: I
965
Grazing Administration Info. (AUMs)
Active Preference: 594
Suspended Nonuse: 0
Total Preference: 594
Average Actual Use: 712
Other Forage Demands (AUMs)
Deer: 50
Elk: 32
Antelope:
Horses:
Total: 82
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Active erosion occurs in the
allotment.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain erosion condition
in moderate or better erosion condition.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Appendix 1-152
Table 9. Allotment Management Summaries (continued)
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continuea existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Dole Smith
Public Acres:
445
Allot. No.: 7042
Other Acres:
Mgmt. Category: C
1,565
Grazing Administration Info. (AUMs)
Active Preference: 25
Suspended Nonuse: 0
Total Preference: 25
Average Actual Use: 53
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for tneir continuea existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-153
Table 9. Allotment Management Summaries (continued)
Allotment Name: Lone Pine
Public Acres:
15,131
Allot. No.: 7043 Mgmt. Category: I
Other Acres:
370
Other Forage Demands (AUMs)
Deer:
135
Elk:
20
Antelope:
6
Horses:
Total:
163
Grazing Administration Info. (AUMs)
Active Preference: 2,137
Suspended Nonuse: 0
Total Preference: 2,137
Exchange of Use: 20
'Carrying Capacity: 1 ,854
Average Actual Use: 1,585
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse, redband trout, Malheur
mottled sculpin
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-154
Table 9. Allotment Management Summaries (continued)
Allotment Name: Cowing
Public Acres:
260
Grazing Administration Info. (AUMs)
Active Preference: 20
Suspended Nonuse: 0
Total Preference: 20
Average Actual Use: 20
Allot. No.: 7044
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
1,490
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Whiting
Public Acres:
399
Allot. No.: 7045
Other Acres:
Mgmt. Category: C
3,403
Grazing Administration Info. (AUMs)
Active Preference: 48
Suspended Nonuse: 0
Total Preference: 48
Average Actual Use: 48
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-155
Table 9. Allotment Manag
fc I Lt^Fj
coniinueuj
Allotment Name: Baker Hill Field
Public Acres:
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Average Actual Use:
188
20
0
20
10
Allot. No.: 7046
Other Acres:
Mgmt. Category: C
522
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Peabody
Public Acres:
26S
Grazing Administration Info. (AUMs)
Active Preference: 60
Suspended Nonuse: 0
Total Preference: 60
Average Actual Use: 67
Allot. No.: 7047
Other Acres:
Mgmt. Category: C
1,514
Other Forage Demands (AUMs)
Deer: 1
Elk: 2
Antelope: 1
Horses:
Total: 4
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Allocate forage to meet elk forage
demands.
Appendix 1-156
Table 9. Allotment Management Summaries (continued)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Varien Canyon
Public Acres:
317
Allot. No.: 7048
Other Acres:
Mgmt. Category: C
2,696
Grazing Administration Info. (AUMs)
Active Preference: 14
Suspended Nonuse: 0
Total Preference: 14
Average Actual Use: 14
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
No forage allocations for elk use
in the allotment have been made.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-157
Table 9. Allotment Management Summaries (continued)
Allotment Name: Forks of Poison CreekAllot. No.: 7049
Public Acres: 3,431
Mgmt. Category: I
Other Acres:
178
Grazing Administration Info. (AUMs)
Active Preference: 648
Suspended Nonuse: 0
Total Preference: 648
Average Actual Use: 340
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
31
13
44
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
sage grouse
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Allocate forage to meet elk forage
demands.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-158
Table 9. Allotment Management Summaries (continued)
Allotment Name: Clemens
Public Acres:
465
Allot. No.: 7050
Other Acres:
Mgmt. Category: C
429
Grazing Administration Info. (AUMs)
Active Preference: 57
Suspended Nonuse: 0
Total Preference: 57
Average Actual Use: 67
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Sawtooth MNF
Public Acres:
535
Allot. No.: 7051
Other Acres:
Mgmt. Category: M
5,170
Grazing Administration Info. (AUMs)
Active Preference: 32
Suspended Nonuse: 0
Total Preference: 32
Average Actual Use: 25
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Appendix 1-159
Table 9. Allotment Management Summaries
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Lone Pine Field
Public Acres:
160
Allot. No.: 7052
Other Acres:
Mgmt. Category: C
320
Grazing Administration Info. (AUMs)
Active Preference: 6
Suspended Nonuse: 0
Total Preference: 6
Average Actual Use: 30
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-160
Table 9. Allotment Management Summaries (continued)
Allotment Name: Silvies Canyon
Public Acres:
925
Allot. No.: 7053
Other Acres:
Mgmt. Category: M
15
Grazing Administration Info. (AUMs)
Active Preference: 1 00
Suspended Nonuse: 0
Total Preference: 100
Average Actual Use: 112
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
10
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
Riparian or aquatic habitat is in
less than good habitat
condition.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Improve and maintain riparian or
aquatic habitat in good or better
habitat condition.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-161
Table 9. Allotment Management Summaries (continued)
Allotment Name: Cricket Creek
Public Acres:
970
Allot. No.: 7054
Other Acres:
Mgmt. Category: C
4:?J
Grazing Administration Info. (AUMs)
Active Preference: 40
Suspended Nonuse: 0
Total Preference: 40
Average Actual Use: 156
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Double "O"
Public Acres:
4,317
Allot. No.: 7056
Other Acres:
Mgmt. Category: M
3,236
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
'Carrying Capacity: 1 ,320
Average Actual Use: 847
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
At this time, the following special
status species or its habitat is
known to exist within the allotment:
long-billed curlew
Management
Objectives
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
'Indicates an allotment where carrying capacity has been determined in a completed allotment evaluation.
Appendix 1-162
— ;_"
Table 9. Allotment Management Summaries (continued)
Allotment Name: Wright's Point
Public Acres:
590
Allot. No.: 7057
Other Acres:
Mgmt. Category: M
&i
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 40
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
No management system established
in the allotment.
Unallotted grazing area.
Management
Objectives
Establish management system.
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Narrows
Public Acres:
1 ,876
Allot. No.: 7058
Other Acres:
Mgmt. Category: I
910
Grazing Administration Info. (AUMs)
Active Preference: 82
Suspended Nonuse: 0
Total Preference: 82
Average Actual Use: 449
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Appendix 1-163
Table 9. Allotment Management Summaries (continued)
Identified Resource
Conflicts/Concerns
Current range condition, level or
pattern of utilization may be
unacceptable, or carrying capacity
(under current management practices)
may be exceeded.
Management
Objectives
Maintain or improve rangeland condition
and productivity through a change in
management practices and/or reduction
in active use. (Note: Upon completion
of the Ecological Site Inventory on the
Three Rivers RA, ecological status
objectives will be developed.)
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Carp
Public Acres:
640
Allot. No.: 7059
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 21
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Unallotted grazing area.
Management
Objectives
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-164
'
■ .
Table 9. Allotment Management Summaries (continued)
Allotment Name: Castle
Public Acres:
751
Allot. No.: 7060
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 7
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Unallotted grazing area.
Management
Objectives
Issue temporary nonrenewable license unless allotted.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Bulger
Public Acres:
320
Allot. No.: 7061
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-165
Table 9. Allotment Management Summaries (continued)
Allotment Name: Devine Canyon
Public Acres:
Allot. No.: 7080
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Water quality does not currently
meet DEQ water quality standards
for beneficial uses.
At this time, the following special
status species or its habitat is
known to exist within the allotment:
redband trout, Malheur mottled
sculpin
No authorized grazing use.
Management
Objectives
Improve surface water quality on
public lands to meet or exceed quality
standards for all beneficial uses as
established by the DEQ, where BLM
authorized actions are having a
negative effect on water quality.
Protect special status species or its
habitat from impact by BLM-authorized
actions.
CONSTRAINTS
Area influencing perennial water occurs within the allotment. Limit treatment of this area by mechanical or prescribed fire means to
less than 20 percent of area in any one year.
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-166
Table 9. Allotment Management Summaries (continued)
Allotment Name: Harney Basin
Public Acres:
640
Allot. No.: 7081
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Allotment Name: Hines Field
Public Acres:
Allot. No.: 7082
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
10
Identified Resource
Conflicts/Concerns
No forage allocations for elk use
in the allotment have been made.
No authorized livestock use.
Management
Objectives
Allocate forage to meet elk forage
demands.
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Appendix 1-167
Table 9. Aliotrrn
Lsmmanes
inued)
Allotment Name: Rainbow Creek
Public Acres:
160
Allot. No.: 7085
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Allotment Name: Silver Creek Valley
Public Acres:
40
Allot. No.: 7087
Other Acres:
Mgmt. Category: C
Grazing Administration Info. (AUMs)
Active Preference: 0
Suspended Nonuse: 0
Total Preference: 0
Average Actual Use: 0
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-168
Table 9. Allotment Management Summaries (continued)
Allotment Name: Sunset Valley
Public Acres:
5360
Grazing Administration Info. (AUMs)
Active Preference:
Suspended Nonuse:
Total Preference:
Average Actual Use:
0
0
0
0
Allot. No.: 7088
Other Acres:
Mgmt. Category: C
Other Forage Demands (AUMs)
Deer:
Elk:
Antelope:
Horses:
Total:
Identified Resource
Conflicts/Concerns
Management
Objectives
CONSTRAINTS
Ensure that substantial vegetation conversions (burning, spraying, chaining, seeding, etc.) do not reduce the variety of plant species
or communities in abundances necessary for their continued existence and normal functioning.
Deer winter range occurs in allotment. Vegetation conversions must be limited to less than 400 acres in size. Maintain browse on
at least 85 percent of the winter range currently supporting browse.
Appendix 1-169
>
Xi
"O
cv
rj
a
x'
Table
10. Allotment Categories
Prudent
Investor's
Selectiv
Range
Allotment
Present
Resource
Present
Willingness
Crit.
Mgmt
Category
Allot.
Allotment
Condition
Potential
Productivity
Conflicts
Controversy
yiqmt
To Invest
Allot.
Number
Name
Sat
Unsat Undef
Hi
Med Low
Hi Med Low
Hi
Med Low
Hi
Med Low
Sat Unsat
Yes
Maybe No
Char.
I, M, or C
4097
Trout Creek
X
X
X
X
X
X
X
5106
Cow Creek
X
X
X
X
X
x
X
5214
Hamilton
X
X
X
X
X
x
5215
Davies
X
X
X
X
X
x
x
5307
Smyth Creek
X
X
X
X
X
X
X
5308
Kiger
X
X
X
X
X
X
X
5310
Riddle Mountain
X
X
X
X
X
X
x
5313
Burnt Flat
X
X
X
X
X
X
x
5321
Hamilton Ind.
X
X
Unknown
X
X
x
x
5329
Riddle/Coyote
X
X
Unknown
X
X
x
X
5330
Deep Creek
X
X
Unknown
X
X
X
X
5503
Pine Creek
X
X
X
X
X
X
X
5511
Moffet Table
X
X
X
X
X
X
X
5514
Coal Mine Creek
X
X
X
X
x
x
5515
Mule Creek
X
X
X
X
X
x
x
5517
Otis Mountain
X
X
X
X
X
x
x
5524
Dawson Butte
X
X
X
X
X
x
x
5530
River
X
X
X
X
X
X
X
5531
Stinkingwater
X
X
X
X
X
X
X
5532
Mountain
X
X
X
X
X
x
X
5535
Miller Canyon
X
X
X
X
X
X
X
5536
Alder Creek
X
X
X
X
X
X
x
5565
Upton Mountain
X
X
X
X
X
X
x
5566
Texaco Basin
X
X
X
X
X
x
x
5571
Lamb Ranch
X
X
X
X
X
X
X
7001
East Warm
Springs
X
X
X
X
X
X
X
7002
West Warm
Springs
X
X
X
X
X
X
X
7003
East Wagontire
X
X
X
X
X
X
X
7004
West Wagontire
X
X
X
X
X
X
>;
7005
Glass Butte
X
X
X
X
X
X
X
7006
Rimrock Lake
X
X
X
X
X
X
>;
7007
Hat Butte
X
X
X
X
X
X
x
7008
Sheep Lake
Shields
X
X
X
X
X
X
X
7009
Dry Lake
X
X
X
X
X
x
7010
Claw Creek
X
X
X
X
X
x
x
7012
Packsaddle
X
X
X
X
X
X
x
7014
Badger Spring
X
X
X
X
X
X
x
7015
Second Flat
X
X
X
X
X
X
X
7016
Juniper Ridge
X
X
X
X
X
X
x
7018
Silver Lake
X
X
X
X
X
X
x
7019
Palomino Butte
X
X
X
X
X
X
X
£
o
CD
Q.
Table 10. Allotment Categories
(continued)
55'
Prudent
-J
Investor's
Selectiv
(NO
Range
Allotment
Present
Resou
ce
Present
Willingness Crit. Mgmt
Allot.
Allotment
Condition
Potential
Productivity
Conflicts
Controversy
Mgmt
To Invest Allot. Category
Number
Name
Sat
Unsat Undet
Hi
Med Low
Hi
Med Low
Hi
Med Low
Hi
Med Low
Sat Unsat
Yes
Maybe No Char. 1, M, or C
7021
Weaver Lake
X
X
Unknown
X
X
X
X
7022
Dog Mountain
X
X
Unknown
X
X
X
X
7023
West Sagehen
X
X
X
X
X
X
X
7024
East Sagehen
X
X
X
X
X
X
X
7025
Gouldin
X
X
X
X
X
X
X
7026
Horton Mill
X
X
X
X
X
X
X
7030
Skull Creek
X
X
X
X
X
X
X
7031
Hay Creek
X
X
X
X
X
X
X
7033
Silvies River
X
X
X
X
X
X
X
7036
Hayes
X
X
X
X
X
X
X
7040
Landing Creek
X
X
X
X
X
X
X
7041
East Silvies
X
X
X
X
X
X
X
7043
Lone Pine
X
X
X
X
X
X
X
7049
Forks of
Poison Creek
X
X
X
X
X
X
X
7058
Narrows
X
X
X
X
X
X
X
1
4098
East Creek-
Pine Hill
X
X
X
X
X
X
X
M
4143
Silvies
X
X
X
X
X
X
X
M
5101
Devine Ridge
X
X
X
X
X
X
)(
M
M
5102
Prather Creek
X
X
X
X
X
X
X
5103
Lime Kiln/
Sec. 30
X
X
X
X
X
X
X
M
5104
Soldier Creek
X
X
X
X
X
X
X
M
M
M
5105
Camp Harney
X
X
X
X
X
X
X
5201
Coleman Creek
X
X
X
X
X
X
X
5202
Hunter
X
X
Unknown
X
X
X
X
M
5204
Slocum
X
X
X
X
X
X
X
M
5205
Venator
X
X
X
X
X
X
X
M
5206
Stockade
X
X
Unknown
X
X
X
X
M
5207
Coyote Creek
X
X
X
X
X
X
X
iv'i
5208
Emmerson
X
X
X
X
X
X
X
M
5209
Crane
X
X
X
X
X
X
X
M
5212
Mahon Ranch
X
X
X
X
X
X
X
M
5213
Beaver Creek
X
X
X
X
X
X
X
M
5301
Princeton
X
X
X
X
X
X
X
M
5302
Big Bird
X
X
X
X
X
X
X
M
5303
Dry Lake
X
X
X
X
X
X
X
Iv'i
M
5305
Crows Nest
X
X
X
X
X
X
X
5306
Rocky Ford
X
X
X
X
X
X
X
M
5309
Happy Valley
X
X
X
X
X
X
X
M
M
M
5316
Virginia Valley
X
X
X
X
X
X
X
5501
East Cow Creek
X
X
X
X
X
X
X
5502
Rock Creek
)(
X
X
X
X
X
X
M
Table 10. Allotment Categories (continued)
Prudent
Investor's
Selectiv
Range
Allotment
Present
Resource
Present
Willingness
Crit.
Mgmt
Allot.
Allotment
Condition
Potential
Productivity
Conflicts
Controversy
Mgmt
To Invest
Allot.
Category
Number
Name
Sat
Unsat
Under
Hi
Med Low
Hi Med Low
Hi
Med Low
Hi
Med Low
Sat Unsat
Yes Maybe
No Char.
1, M, orC
5505
Little Muddy
Creek
X
X
X
X
X
X
X
M
5506
Muddy Creek
X
X
X
X
X
X
X
M
5507
Wolf Creek
X
X
Unknown
X
X
X
X
M
5508
Baker-Knowles
X
X
Unknown
X
X
X
X
M
5509
Williams Dripp
Spring
X
X
X
X
X
X
M
5510
Jones Dripp
Spring
X
X
X
X
X
X
X
M
5513
Shelley
X
X
X
X
X
X
X
M
5516
Birch Creek
X
X
X
X
X
X
X
M
5521
Rocky Basin
X
X
X
X
X
X
X
IVi
5522
Cottonwood
Creek
X
X
X
X
X
X
M
5523
Tub Spring-Hart
X
X
X
X
X
X
X
M
5525
Mill Gulch
X
X
X
X
X
X
X
M
5526
Chalk Hills
X
X
X
X
X
X
X
M
5528
Cooler
X
X
X
X
X
X
X
M
5529
House Butte
X
X
X
X
X
X
X
M
5533
Buchanan
X
X
X
X
X
X
X
M
5534
Mahon Creek
X
X
X
X
X
X
X
M
5537
Buck Mountain
X
X
X
X
X
X
X
M
5538
Riverside
X
X
X
X
X
X
X
M
5564
Wheeler Basin
X
X
X
X
X
X
X
M
7011
Upper Valley
X
X
X
X
X
X
X
M
7017
Cluster
X
X
X
X
X
X
X
M
7020
Sand Hollow
X
X
X
X
X
X
X
M
7035
Silvies Meadows
X
X
X
X
X
X
X
M
7039
Cave Gulch
X
X
Unknown
X
X
X
X
M
7051
Sawtooth-MNF
X
X
X
X
X
X
X
M
7053
Silvies Canyon
X
X
X
X
X
X
X
iVi
7056
Double "O"
X
X
X
X
X
X
X
M
7057
M
Wrights Point
X
X
X
X
X
X
X
4040
Poison Creek
X
X
Unknown
X
X
X
X
C
4096
Hi Desert
X
X
Unknown
X
X
X
X
C
4126
Abrahams Draw
X
X
Unknown
X
X
X
)(
c
>
o
4138
4180
White
King Mountain
X
}(
X
X
Unknown
Unknown
X
X
X
X
X
X
X
X
c
c
CD
5001
Crane FFR
X
X
Unknown
X
X
X
X
c
3
Q.
5002
Catterson
X
X
Unknown
X
X
X
X
c
>"<'
Sec. 13
T
5003
Malheur Slough
X
X
Unknown
X
X
X
X
c
5005
Withers FFR
X
X
Unknown
X
X
X
X
c
>
X3
TJ
CD
3
Li
Table 10. Allotment Categories (continued)
x"
Prudent
"-4
.p-„
Investor's
Selectiv
Range
Allotment
Present
Resource
Present
Willingness
Crit. Mgmt
Allot.
Allotment
Condition
Potential
Productivity
Conflicts
Controversy
Mgmt
To Invest
Allot. Category
Number
Name
Sat
Unsat
Undef
Hi
Med Low
Hi Med Low
Hi Med Low
Hi Med Low
Sat Unsat
Yes Maybe
No Char. 1, M, or C
5107
Manning Field
X
X
Unknown
X
X
X
X
c
5109
Purdy FFR
X
X
Unknown
X
X
X
X c
5110
Reed FFR
X
X
Unknown
X
X
X
X
c
5111
Temple's FFR
X
X
Unknown
X
X
X
X
c
5112
Smith FFR
X
X
Unknown
X
X
X
X
c
5113
Rattlesnake FFR
X
X
Unknown
X
X
X
X
C
5203
Catterson
X
X
Unknown
X
X
X
X
C
5211
Beckley Home
X
X
Unknown
X
X
X
X
C
5216
Quier FFR
X
X
Unknown
X
X
X
c
5217
Thompson FFR
X
X
Unknown
X
X
X
c
5218
Bennett FFR
X
X
Unknown
X
X
X
X
c
5219
Hamilton FFR
X
X
Unknown
X
X
X
X
c
5311
Virginia FFR
X
X
Unknown
X
X
X
X
c
5317
Hatt Butte
X
X
Unknown
X
X
X
X
c
5318
Black Butte
X
X
Unknown
X
X
X
X
c
5322
Briggs FFR
X
X
Unknown
X
X
X
X
c
5323
Clemens FFR
X
X
Unknown
X
X
X
X
c
5324
Riddle FFR
X
X
Unknown
X
X
X
X
c
5325
Marshall
Diamond FFR
X
X
Unknown
X
X
X
X
c
5326
Jenkins N.
Lake FFR
X
X
Unknown
X
X
X
X
c
5327
Jenkins B.
Flat FFR
X
X
Unknown
X
X
X
X
c
5328
Fisher FFR
X
X
Unknown
X
X
X
X
c
5504
State Field
X
X
Unknown
X
X
X
X
c
5512
Clarks River
X
X
Unknown
X
X
X
X
c
5518
Newell Field
X
X
X
X
X
X
X
c
5519
Big Upson
X
X
Unknown
X
X
X
X
c
5520
Little Upson
X
X
Unknown
X
X
X
X
c
5527
Riverside FFR
X
X
Unknown
X
X
X
X
c
5539
W & C Blaylock
FFR
X
X
Unknown
X
X
X
X
c
5540
Luce Field
X
X
Unknown
X
X
X
X
c
5541
Home Ranch
Enclosure
X
X
Unknown
X
X
X
X
c
5542
Marshall FFR
X
X
Unknown
X
X
X
X
c
5543
Divine Flat
Field
X
X
Unknown
X
X
X
X
c
5544
Brooks Field
X
X
Unknown
X
X
X
X
c
5545
Sunshine Field
X
X
Unknown
X
X
X
X
c
5546
Druitt Field
X
X
Unknown
X
X
X
X
c
5547
Lake Field
X
X
Unknown
X
X
X
X
c
5548
Griffin FFR
X
X
Unknown
X
X
X
X
G
>
o
CD
: i
P.
X'
Oi
Table 10. Allotment Categories (continued)
Prudent
Investor's
Selectiv
Range
Allotment
Present
Resou
rce
Present
Willingness
Crit. Mgmt
Allot.
Allotment
Condition
Potential
Productivity
Conflicts
Controversy
Mgmt
To Invest
Allot. Category
Number
Name
Sat
Unsat
Under
Hi Med Low
Hi Med Low
Hi Med Low
Hi Med Low
Sat Unsat
Yes Maybe
No Char. 1, M, or C
5549
Howards FFR
X
X
Unknown
X
X
X
X
c
5550
Jordans FFR
X
X
Unknown
X
X
X
X
0
5551
Lillards FFR
X
X
Unknown
X
X
X
X
c
5552
Miller FFR A
X
X
Unknown
X
X
X
X
c
5553
Miller FFR B
X
X
Unknown
X
X
X
X
c
5554
J. Francis
Miller FFR
X
X
Unknown
X
)(
X
X
c
5555
OttFFR
X
X
Unknown
X
X
X
X
c
5556
Pine Creek FFR
X
X
Unknown
)(
X
X
X,
c
5557
J & G Kane FFR
)(
X
Unknown
X
X
X
X
c
5558
J & G FFR
X
X
Unknown
X
X
X
X
c
5559
Swords FFR
X
X
Unknown
X
X.
X
X
c
5560
Vickers FFR
X
X
Unknown
X
X
X
X
c
5561
Wilber FFR
X
X
Unknown
X
X
X
X
c
5562
Williams FFR
X
X
Unknown
X
X
X
X
c
5563
Arnold FFR
X
X
Unknown
X
X
X
X
c
5567
Miler FFR
X
X
Unknown
X
X
X
X
c
5568
Byrons FFR
X
X
Unknown
X
X
X
X
c
5569
Floyds FFR
X
X
Unknown
X
X
X
X
c
5570
River FFR
X
X
Unknown
X
X
X
X
c
5572
Krueger FFR
X
X
Unknown
X
X
X
X
c
7013
Zoglmann
X
X
Unknown
X
X
X
c
7027
Emigrant Creek
X
X
Unknown
X
X
X
X
c
7028
Stinger Creek
X
X
Unknown
X
X
X
X
c
7029
Spring Creek
X
X
X
X
X
X
X
c
7032
Hotchkiss Ind.
X
X
Unknown
X
X
X
c
7034
Scat Field
X
X
Unknown
X
X
X
X
c
7037
Coal Pit Spring
X
X
X
X
X
X
X
c
7038
Curry Gordon
X
X
Unknown
X
X
X
X
c
7042
Dole Smith
X
X
Unknown
X
X
X
X
c
7044
Cowing
X
X
Unknown
X
X
X
X
c
7045
Whiting
X
X
Unknown
X
X
X
X
c
7046
Baker Hill
Field
X
X
Unknown
X
X
)(
X
0
7047
Peabody
X
X
Unknown
X
X
X
X
c
7048
Varien Canyon
X
X
Unknown
X
X
X
X
c
7050
Clemens
X
X
Unknown
X
X
X
.X
c
7052
Lone Pine Field
X
X
Unknown
X
X
X
X
c
7054
Cricket Creek
X
X
Unknown
X
X
X
X
0
7059
Carp
X
X
Unknown
X
X
.X
X
c
7060
Castle
X
X
Unknown
X
X
X
X
c
7080
Devine Canyon
X
X
Unknown
X
X
X
X
c
7081
Harney Basin
X
X
Unknown
X
X
X
X
c
7082
Hines Field
X
X
Unknown
X
X
X
X
c
7085
Rainbow Creek
X
X
Unknown
X
X
X
X
c
7087
Silver Creek
Valley
X
X
Unknown
X
X
X
X
c
7088
Sunset Valley
X
X
Unknown
X
X
X
X
c
Table 11. Rangeland Monitoring and Evaluation
Purpose of Monitoring
1 ) To determine the effects of management actions on the rangeland resources.
2) To determine the effectiveness of on-the-ground management actions in achieving resource management objectives
within planned timeframes.
3) To provide quantifiable data to identify and support needed management actions.
4) To provide quantifiable data for the periodic review of management objectives.
Monitoring Methods
Monitoring methods must be suitable for the vegetation types and resource conditions that will be encountered. The capability of the
methods to detect subtle changes due to management over short periods of time must be carefully considered.
For monitoring data to be meaningful and useful over time, there must be consistency in the kinds of data that are collected and the
manner in which they are collected. However, the need for changes in sampling may occasionally arise when problems are detected
during a cursory review of the collected data, when analyzing and interpreting the data, or when conducting an evaluation. Serious
consideration must be given to the effect changes will have on the historical value of existing data.
The methods discussed here are the methods currently in use in the Three Rivers RA. These methods are consistent with the District
Monitoring Plan, State Monitoring Guidance and Bureau Policy.
Actual Use
Actual use monitoring provides information concerning the actual amount of grazing use occurring on an area of rangeland during
a specific time period. It is a record of livestock and wild horse use in each pasture of an allotment and represents forage consumed
in terms of AUMs. Livestock actual use is provided by the permittees. Data is verified by field checks and occasional counts. The
report includes livestock numbers, pasture usage and turn out and gathering dates.
Wild horse actual use is determined by multiplying inventoried numbers by the grazing period on their summer and winter range.
This may or may not involve separate pastures.
Actual use is collected in all "M" and "I" category allotments annually.
Utilization
Utilization data are collected to provide information concerning the percentage of forage that has been consumed or destroyed on
an area of rangeland during a specific period of time and the grazing pattern on the allotment. Utilization data are important in
evaluating the effects of grazing use on specific areas of rangeland and identifying areas of concentrated use that may be dispersed
by some form of range improvement.
In the short term, utilization data are considered with actual use and climatic data to determine resource use levels and to identify
the need for range improvement projects, adjustment in management actions, and/or adjustments in grazing use levels. These data
can be used as the basis for implementing adjustments in grazing use through agreement or by decision.
In the long term, utilization data are considered along with actual use, authorized use, estimated use, trend, climate, and any other
data available or necessary for allotment evaluation. Evaluations are conducted to determine if the grazing management actions and/
or practices are achieving the long-term management objectives identified in the land-use and activity plans.
The primary method used in the RA is the Key Forage Plant method. The key forage plant method is an ocular estimate method of
judging utilization within one of six utilization classes on one or more key herbaceous and/or browse species. Utilization is generally
expressed as a percentage of available forage weight or numbers of plants, twigs, etc., that have been consumed or destroyed, and
is expressed in terms of the current year's production removed.
Trend
Trend data are important in determining the effectiveness of on-the-ground management actions and evaluating progress toward
meeting management objectives. They indicate whether the rangeland is moving toward or away from its potential or from achieving
specific management objectives. Trend refers to the direction of change and indicated whether rangeland vegetation is being
maintained or is moving toward or away from the desired plant community or toward or away from other specific vegetation
management objectives. Trends of rangelands may be judged by noting changes in composition, density, cover, production, vigor,
age class, and frequency of the vegetation, and related parameters of other resources.
The trend method used in the RA is the Nearest Plant method, which consists of a minimum of 1 00 observations along a transect
at one pace, or other selected intervals. The observation is the nearest plant within a 1 80 degree arc from the center of the front of
the observer's foot. Close-up and general view photographs are used with this method.
Appendix 1-177
Table 11. Rangeland Monitoring and Evaluation (continued)
This method provides an estimate of relative species dispersion. The indicators of trend monitored with this method are the
percentage of occurrence as nearest plant.
The Photo-plot method is also used to measure trend. This method includes taking a close-up photograph of a 3 x 3 foot plot and
a general view photograph of the study site.
Climate
Climate studies provide a comparison of grazing season climatic conditions with long-term normals. Crop year (September - June)
precipitation accounts for approximately 80 percent of the variation in vegetation production in the Great Basin. The Forage Yield
Index developed at the Squaw Butte Experiment Station is used to adjust forage utilization.
Table 11. (continued)
Evaluation
The analysis and interpretation of inventory and monitoring data are extremely important in the evaluation of management actions
to determine their progress in meeting resource management objectives. This process must be carefully accomplished to determine
if adjustments in grazing use and management actions are needed, and if so, to what extent.
The major steps involved in the evaluation process are as follows:
Assemble and Display Monitoring and Other Data - Review and summarize available data which has been collected from baseline
inventories, monitoring studies, supplemental studies and other sources.
Analyze Data - Perform all necessary calculations of data.
Interpret Data- After the data has been analyzed, it is interpreted to determine whether the results show a trend of have remained
static overtime for each type of study. This includes interpreting individual data sets and examining their interrelationships.
In order to assess proper stocking level or carrying capacity, the following formula may be used.
Potential Stocking Level = Target Util. * Actual Use
(Carrying Capacity) Measured Util. * Yield Index
Evaluate Data-The data is evaluated for consistency, reliability, strong points, weak points, completeness and accuracy. If the results
of the interpretation indicate a trend, the evaluation attempts to determine the causes of the trends and establish a course of action
for future management.
Review Management Objectives - Management objectives must be evaluated as well as the monitoring data in order to make sure
that the objectives are meaningful.
In order for management actions to be monitored and progress to be evaluated, the objectives must be measurable. They must also
be reasonably attainable within a reasonable timeframe. In some cases, detection of a trend toward the desired value may sufficient
to justify continuation of the management practice being evaluated, especially on poor condition ranges where vegetation objectives
will be attainable only in the long-term. In these cases, intermediate objectives may be useful in evaluating the progress.
Evaluate Progress in Meeting Management Objectives - Determine if management objectives have been met or if adequate progress
toward achieving them has occurred or if management objectives or monitoring techniques need redefining.
Summarize Findings and Make Recommendations - The formal evaluation must include concise management recommendations
as well as recommendations on changing monitoring techniques, management objectives, key areas, or key species.
Appendix 1-178
Table 12. Standard Procedures and Design Elements for Range Improvements
Range improvements are proposed for several reasons including, but not limited to: to implement more intensive grazing systems;
to allow deferment of grazing use on native range during the spring; to improve livestock distribution; and to increase forage
production.
The following standard procedures and design elements would be adhered to under the proposed action in constructing range
improvements in the ElSarea. Design elements have been standardized over time to mitigate adverse effects encountered during
range improvement installations.
- Preparation of a site-specific environmental assessment prior to implementation of range improvements is required. Proposed
range improvements may be modified or abandoned if this assessment indicates significant adverse environmental impacts
cannot be mitigated or avoided.
- A wilderness inventory, required by FLPMA, has been completed in the EIS area. All rangeland management activities in
wilderness study areas will be consistent with the IMP and Guidelines for Lands Under Wilderness Review unless and until the
area is removed from this category. Impacts will be assessed before implementing management activities to ensure they meet
guidelines.
- Every effort would be made to avoid adverse impacts to cultural resources. A cultural resources inventory will be completed on
all areas prior to any decision to perform ground-disturbing activities. This would be part of the preplanning stage of a project and
the results would be analyzed in the environmental assessment addressing the action (BLM Manual 8100, Cultural Resources
Management). If significant cultural values are identified, the project could be relocated, redesigned or abandoned. However,
where that is not possible, the BLM would consult with the State Historic Preservation Officer and the Advisory Council on Historic
Preservation in accordance with the Programmatic Memorandum of Agreement (PMOA) by and between the Bureau, the Council
and the National Conference of State Historic Preservation Officers, dated January 14, 1980, which sets forth a procedure for
developing appropriate mitigative measures, in compliance with Section 1 06 of the National Historic Preservation Act (1 966) as
implemented by 36 CFR Part 800. Management adherence to agreed upon mitigative measures will be implemented in
compliance with these regulations.
- If a project might affect any listed threatened or endangered species or its critical habitat, consultation with the USFWS would
be initiated (50 CFR 50 402: Endangered Species Act of 1973, as amended). The project would be modified, relocated or
abandoned in order to obtain a no effect determination. If a project may contribute to the need to list a Federal candidate or Bureau
sensitive species, a technical assistance request would be made to the USFWS.
- Surface disturbance at all project sites would be held to a minimum. Disturbed soil would be rehabilitated to blend into surrounding
soil surface and reseeded as needed with a mixture of grasses, forbs and browse as applicable to replace ground cover and reduce
soil loss from wind and water erosion.
- Seeding would only be done to enhance and sustain multiple-use values. Vegetation manipulation projects would be designed
using irregular patterns, untreated patches, etc., to provide for optimum edge effect for visual quality and wildlife. Layout and
design would be coordinated with local ODFW biologists.
- Seeding would be accomplished by use of the rangeland drill in most cases. Broadcast seeding would occur on small disturbed
areas, rough terrain and rocky areas. Brush would be controlled prior to seeding. Some projects would have brush control only.
Brush control could employ burning, spraying, chaining, etc.; however, the treatment method has not been determined for
individual projects. Generally, areas containing needlegrasses and/or rabbitbrush and areas with sandy soils would not be burned.
BLM would determine seeding mixtures on a site-specific basis, at the EA level in accordance with NEPA, using past experience
and recommendations of the Oregon State University Extension Service and Experiment Stations and/or ODFW. Anticipated
increases in production through vegetation manipulation projects would not be allocated until seedings are established and ready
for use. All seedings would be deferred from grazing for at least two growing seasons to allow seedling establishment. Where
deep furrow drills are used, slopes would be drilled on the contour to prevent water erosion.
- The seeding policy for the BLM in Oregon is as follows: Seedings to change vegetation composition should be used when it is
the most efficient method to accomplish the resource objectives identified through the planning process. The selection of the
seeding area and the species to be used should be based on a site-specific evaluation which considers ecologic potential,
technical and economic feasibility, location of unique resources, plant diversity and cumulative impacts on the ecosystem.
Adapted native species that can enhance vegetative diversity composition must be given consideration in species selection. To
insure establishment seedings must be protected for two growing seasons or until the vigorous seedlings produce their first seed
crop. Once established, seedings should be properly managed and monitoried to ensure that resource objectives are
accomplished.
- It is anticipated that the existing road and trail system would provide access for range improvements construction. If needed,
unimproved trails and tracks would be created to reach construction sites. These trails would continue to be utilized for
maintenance of the projects.
Appendix 1-179
. '■■:-■ ; - , ' ■'■..■■
Table 12. Standard Procedures and Design Elements for Range Improvements (continued)
- It is assumed that normal maintenance such as replacement of pipeline sections, fence posts and retreatment of vegetation
manipulations would occur.
- VRM procedures would be employed to minimize the adverse visual impacts created by the proposed range improvements.
Additional design features are identified in the following discussion of the individual types of improvements.
Reservoir Construction
Development of reservoirs would involve the construction of pits and dams to impound waterfor livestock and wildlife use. Pits would
be in dry lake beds or other natural depressions. Dams would be constructed in drainages. Water storage capacity would range from
1.0 to 2.0 acre-feet. Fill material, if needed, would come from the impoundment area and/or a borrow area for dams. Excavated
material from pits would be piled adjacent to the pit. Topsoil would be stockpiled and used to rehabilitate the borrow areas.
Wells
Wells would be cased with steel pipe and sealed with concrete to prevent cave-ins and contamination. All State of Oregon water-
well drilling regulations would be adhered to, both in drilling and equipping. A safety device would be installed on new powerline
transformers to prevent electrocution of raptors. Metal storage tanks, painted to blend with the surrounding landscape, would be
placed at each well site. Generally, the tanks would be enclosed and would measure 15 to 30 feet in diameter and 6 to 12 feet high.
Springs
The proposed action includes the development of springs. This would involve digging or drilling to intercept naturally occurring water
flow, installing perforated pipe or concrete boxes to collect water, and installing pipelines and water troughs. The spring source and
trough overflow area would be fenced to prevent livestock grazing and trampling and provide meadow habitat. A small waterhole
would be developed inside the fenced overflow area for wildlife use. Ramps, rocks or float boards would be provided in all water
troughs for birds and mammals to gain access to and/or escape from the water.
Pipelines
Pipelines are proposed to carry water for livestock from wells to areas that lack an adequate water supply. Generally, 1 to 2-inch
diameter plastic pipe would be buried with a pipe-laying device consisting of a modified ripper tooth mounted on a tractor. The pipe
is normally laid as deeply as possible under the ground but no deeper than 30 inches. Where obstructions prohibit burying, the pipe
would be laid on the surface and covered with borrowed soil. Reservoirs would be constructed along the pipeline and fenced to
exclude livestock. This would provide ground level water for wildlife, and serve as an emergency water supply in case of equipment
failure. Watertroughs would be installed approximately every mile along the pipeline. Ramps, rocks orf bat boards would be provided
in all watertroughs for birds and mammals to gain access to and/or escape from the water.
Fences and Cattleguards
Fences would be designed to prevent the passage of livestock without stopping the movement of wildlife. All fences would be
constructed in accordance with Bureau Manual 1741 . The proposed fence lines would not be bladed or scraped. All fences would
comply with VRM procedures.
Where fences cross existing roads either gates or cattleguards would be installed.
Appendix 1-180
Table 13. Range Improvement Costs1
Type of Improvement Unit Cost/Unit
Guzzler
Brush Control
Cattleguard
Fence
Juniper Burning
Pipeline
Prescribed Burn
Reservoir
Road Maintenance
Seeding
Spring
Trough
Well
'Based on recent years' experience, figures in 1991 dollars.
Each
$4,500
Acre
$10
Each
$2,400
Mile
$2,500
Unit
$2,800
Mile
$10,500
Acre
$10
Each
$6,700
Mile
$200
Acre
$25
Each
$3,000
Each
$1,800
Each
$22,500
Appendix 1-181
Appendix 1-182
~~~~~~ — -
Table 14. Potential Range Improvements by Allotment
Allotment
No.
Allotment
Name
Type of
Improvement
Units
Cost/
Unit
No.
Cost
Silver Lake Pond
Fence
Nest Islands
Mile
Each
4098
East Cr.-Pine Hill
Fence
Mile
4143
Silvies
Wetland Improvements
Project
Fence
Mile
5101
Devine Ridge
Reservoir
Each
5102
Prather Creek
Fence
Mile
5105
Camp Harney
Fence
Spring
Mile
Each
Juniper Burning
Units
Cattleguard
Each
5201
Coleman Creek
Fence
Mile
5205
Venator
Spring
Each
5206
Stockade
Fence
Mile
5207
Coyote Creek
Fence
Mile
5218
Bennett FFR
Road Mainte
nance
Mile
5301
Princeton
Trough
Pipeline
Each
Mile
5302
Big Bird
Pipeline
Trough
Mile
Each
5303
Dry Lake
Well
Pipeline
Cattleguard
Trough
Each
Mile
Each
Each
5305
Crow's Nest
Pipeline
Mile
5306
Rocky Ford
Cattleguard
Reservoir
Well
Pipeline
Each
Each
Each
Mile
5307
Smyth Creek
Fence
Mile
Juniper Burn
ng
Units
Cattleguard
Each
Reservoir
Each
5308
Kiger
Cattleguard
Each
Juniper Burn
n9
Units
Reservoir
Each
5309
Happy Valley
Fence
Trough
Mile
Each
Juniper Burn
ng
Units
Pipeline
Mile
5310
Riddle Mountain
Juniper Burn
Spring
Fence
ng
Units
Each
Mile
5315
Virginia Valley
Trough
Pipeline
Cattleguard
Fence
Each
Mile
Each
Mile
5321
Hamilton Ind.
Fence
Mile
5329
Riddle-Coyote
Fence
Mile
5503
Pine Creek
Spring
Fence
Each
Mile
Juniper Burn
ng
Units
5506
Muddy Creek
Reservoir
Each
5510
Jones Dripp
Reservoir
Each
5511
Moffet Table
Prescribed B
Trough
Fence
urn
Acre
Each
Mile
Juniper Burn
ng
Units
5514
Coal Mine Creek
Trough
Each
5515
Mule Creek
Fence
Mile
$3,334
$2,500
$2,500
$21,000
$2,500
$6,700
$2,500
$2,500
$3,000
$2,800
$2,400
$2,500
$3,000
$2,500
$2,500
$200
$1,800
$10,500
$10,500
$1,800
$22,500
$10,500
$2,400
$1,800
$10,500
$2,400
$6,700
$22,500
$10,500
$2,500
$2,800
$2,400
$6,700
$2,400
$2,800
$6,700
$2,500
$1,800
$2,800
$10,500
$2,800
$3,000
$2,500
$1,800
$10,500
$2,400
$2,500
$2,500
$2,500
$3,000
$2,500
$2,800
$6,700
$6,700
$10
$800
$2,500
$2,800
$800
$2,500
1.5
$5,001
2
$5,000
1
$2,500
1
$21,000
0.75
$1,875
1
$6,700
1
$2,500
1
$2,500
1
$3,000
5
$14,000
1
$2,400
2
$5,000
1
$3,000
1
$2,500
0.5
$1,250
1.5
$300
3
$5,400
7
$73,500
2
$21,000
1
$1,800
1
$22,500
12
$126,000
1
$2,400
5
$9,000
2
$21,000
1
$2,400
1
$6,700
1
$22,500
1
$10,500
2.75
$6,875
6
$16,800
1
$2,400
1
$6,700
1
$2,400
2
$5,600
1
$6,700
1
$2,500
1
$1,800
2
$5,600
1
$10,500
8
$22,400
i
$3,000
1
$2,500
5
$9,000
7
$73,500
1
$2,400
3
$7,500
1
$2,500
4
$10,000
3
$9,000
2
$5,000
7
$19,600
1
$6,700
2
$13,400
560
$15,600
4
$3,200
3.5
$8,750
6
$16,800
1
$800
1
$2,500
Appendix 1-183
Table 14. Potential Range Improvements by Allotment (continued)
Allotment
Allotment
Type of
Cost/
No.
Name
Improvement
Units
Unit
No.
Cost
5517
Otis Mountain
Trough
Each
$800
2
$1,600
Juniper Burning
Units
$2,800
4
$11,200
Prescribed Burn
Acre
$10
1,440
$14,400
5522
Cottonwood Creek
Reservoir
Each
$6,700
2
$13,400
Fence
Mile
$2,500
2.5
$6,250
5524
Dawson Butte
Trough
Each
$800
3
$2,400
5526
Chalk Hills
Well
Each
$22,500
1
$22,500
Pipeline
Mile
$10,500
2
$21,000
5528
Cooler
Reservoir
Each
$6,700
1
$6,700
5529
House Butte
Spring
Each
$3,000
2
$6,000
5531
Stinkingwater
Fence
Mile
$2,500
3
$7,500
Road Maintenance
Mile
$200
7
$14,000
Reservoir
Each
$6,700
1
$6,700
5532
Mountain
Fence
Mile
$2,500
8
$20,000
Juniper Burning
Units
$2,800
15
$42,000
Trough
Each
$800
1
$800
Road Maintenance
Mile
$200
12
$2,400
5534
Mahon Creek
Road Maintenance
Mile
$200
2
$400
Fence
Mile
$2,500
1.5
$3,750
5535
Miller Canyon
Reservoir
Each
$6,700
3
$20,100
Juniper Burning
Units
$2,800
6
$16,800
Road Maintenance
Mile
$200
5
$1,000
5536
Alder Creek
Juniper Burning
Units
$2,800
12
$33,600
Road Maintenance
Mile
$200
10
$2,000
Fence
Mile
$2,500
4.5
$11,250
Reservoir
Each
$6,700
4
$26,800
5537
Rock Mountain
Spring
Each
$3,000
1
$3,000
5538
Riverside
Spring
Each
$3,000
1
$3,000
5560
Vickers' FFR
Road Maintenance
Mile
$200
1.5
$300
5564
Wheeler Basin
Trough
Each
$800
1
$800
Reservoir
Each
$6,700
2
$13,400
5565
Upton Mountain
Seeding
Acre
$25
2,000
$50,000
Pipeline
Mile
$200
1
$200
Trough
Each
$800
1
$800
Brush Control
Acre
$10
2,000
$20,000
Reservoir
Each
$6,700
1
$6,700
5566
Texaco Basin
Road Maintenance
Mile
$200
4.5
$900
Fence
Mile
$2,500
2
$5,000
5571
Lamb Ranch
Fence
Mile
$2,500
1.25
$3,125
7001
East Warm Springs
Pipeline
Mile
$10,500
4
$42,000
Fence
Mile
$2,500
17
$42,500
Trough
Each
$1,800
4
$7,200
Reservoir
Each
$6,700
5
$40,200
Well
Each
$22,500
1
$22,500
7002
West Warm Springs
Reservoir
Each
$6,700
12
$80,400
Wetland Improvements
Project
$40,000
1
$40,000
Fence
Mile
$2,500
2
$5,000
7003
East Wagontire
Trough
Each
$800
2
$1,600
Brush Control
Acre
$10
32,665
$326,650
Spring
Each
$3,000
1
$3,000
Seeding
Acre
$25
31,200
$780,000
Fence
Mile
$2,500
42
$105,000
Well
Each
$22,500
2
$45,000
Reservoir
Each
$6,700
8
$53,600
Pipeline
Mile
$10,500
25
$262,500
7004
West Wagontire
Trough
Each
$1,800
7
$12,600
Reservoir
Each
$6,700
2
$13,400
Pipeline
Mile
$10,500
7
$73,500
Well
Each
$22,500
1
$22,500
Fence
Mile
$2,500
20
$50,000
Big Game Guzzler
Each
$4,500
2
$9,000
Appendix 1-184
Table 14. Potential Range Improvements by Allotment (continued)
Allotment Allotment
No. Name
Type of
Improvement
Units
Cost/
Unit
No.
Cost
7006
Rimrock Lake
7007
Hat Butte
7008
Sheep Lake-S
7009
Dry Lake
(Rye Grass)
7010
Claw Creek
7013
7014
Zoglmann
Badger Spring
7015
Second Flat
7016
Juniper Ridge
7017
7018
7019
7031
7033
7036
Cluster
Silver Lake
Palomino Buttes
7020
Sand Hollow
7021
Weaver Lake
7022
Dog Mountain
7024
7025
East Sagehen
Gouldin
7030
Skull Creek
Hay Creek
Silvies River
Hayes
Seeding
Acre
Brush Control
Acre
Spring
Each
Reservoir
Each
Brush Control
Acre
Fence
Mile
Brush Control
Acre
Reservoir
Each
Seeding
Acre
Reservoir
Each
Seeding
Acre
Juniper Burning
Units
Brood Pond
Each
Brush Control
Acre
Reservoir
Each
Fence
Mile
Reservoir
Each
Fence
Mile
Spring
Each
Reservoir
Each
Big Game Guzzler
Each
Big Game Guzzler
Each
Spring
Each
Fence
Mile
Reservoir
Each
Seeding
Acre
Fence
Mile
Pipeline
Mile
Trough
Each
Reservoir
Each
Well
Each
Prescribed Burn
Acre
Brush Control
Acre
Fence
Mile
Brush Control
Acre
Pipeline
Mile
Reservoir
Each
Fence
Mile
Reservoir
Each
Wetland Improvements
Project
Well
Each
Pipeline
Mile
Fence
Mile
Reservoir
Each
Pipeline
Mile
Fence
Mile
Reservoir
Each
Fence
Mile
Reservoir
Each
Spring
Each
Reservoir
Each
Reservoir
Each
Fence
Mile
Brush Control
Acre
Fence
Mile
Juniper Burning
Units
Reservoir
Each
Fence
Mile
Fence
Mile
Fence
Mile
$25
9,000
$225,000
$10
9,000
$90,000
$3,000
2
$6,000
$6,700
12
$80,400
$10
3,000
$30,000
$2,500
4
$10,000
$10
2,500
$25,000
$6,700
1
$6,700
$25
800
$20,000
$6,700
6
$40,200
$25
960
$24,000
$2,800
5
$14,000
$7,500
2
$15,000
$10
1,800
$18,000
$6,700
1
$6,700
$2,500
8
$20,000
$6,700
2
$13,400
$2,500
2.25
$5,625
$3,000
1
$3,000
$6,700
2
$13,400
$4,500
2
$9,000
$4,500
2
$9,000
$3,000
2
$6,000
$2,500
3
$7,500
$6,700
2
$13,400
$25
3,000
$75,000
$2,500
9
$22,500
$10,500
8
$84,000
$1,800
8
$14,400
$6,700
1
$6,700
$22,500
1
$22,500
$10
5,260
$52,600
$10
2,000
$20,000
$2,500
1
$2,500
$10
4,500
$45,000
$10,500
4
$42,000
$6,700
3
$20,100
$2,500
7
$17,500
$6,700
1
$6,700
$50,000
1
$50,000
$22,500
1
$22,500
$10,500
2
$21,000
$2,500
6
$15,000
$6,700
1
$6,700
$10,500
3
$31,500
$2,500
2
$5,000
$6,700
2
$13,400
$2,500
5.5
$13,750
$6,700
1
$6,700
$3,000
1
$3,000
$6,700
2
$13,400
$6,700
i
$6,700
$2,500
4
$10,000
$10
1,600
$16,000
$2,500
2
$5,000
$2,800
10
$28,000
$6,700
2
$13,400
$2,500
4
$10,000
$2,500
4
$10,000
$2,500
1.5
$3,750
Appendix 1-185
Table 14.
Potential Range Improvements by Allotment (continued)
Allotment
Allotment
Type of
Cost/
No.
Name
Improvement
Units
Unit
No.
Cost
7037
Coal Pit Springs
Reservoir
Each
$6,700
1
$6,700
Spring
Each
$3,000
2
$6,000
7040
Landing Creek
Fence
Mile
$2,500
5
$12,500
7041
East Silvies
Spring
Each
$3,000
1
$3,000
Fence
Mile
$2,500
3
$7,500
Reservoir
Each
$6,700
1
$6,700
7043
Lone Pine
Juniper Control
Acre
$80
1,000
$80,000
Reservoir
Each
$6,700
3
$20,100
Juniper Burning
Units
$2,800
5
$14,000
Spring
Each
$3,000
1
$3,000
7048
Varien Canyon
Fence
Mile
$2,500
0.25
$625
7049
Forks of Poison Cr.
Brush Control
Acre
$10
530
$5,300
7058
Narrows
Trough
Each
$1,800
1
$1,800
Reservoir
Each
$6,700
2
$13,400
Well
Each
$22,500
1
$22,500
Appendix 1-186
Table 15. Descriptions of Existing and Proposed ACECs
South Narrows ACEC
South Narrows ACEC is an existing ACEC in the Three Rivers RA. It was established June 30, 1 983. It is located in Harney County
approximately 26 miles south of Burns, Oregon, adjacent to Highway 205. This ACEC is 1 60 acres in size. It is in East Warm Springs
Allotment (No. 7001 ). The elevation of the site is approximately 4,400 feet.
South Narrows ACEC was established to provide special management attention to the designated Critical Habitat of Stephanomeria
malheurensis, Malheur wirelettuce, a plant species listed as endangered under the Endangered Species Act of 1973.
The management goal of the South Narrows ACEC is to provide protection in order to preserve the characteristics of the habitat and
maintain the suitability of the site to support Stephanomeria malheurensis. Actions which have previously been undertaken in support
of this goal include fencing a portion of the ACEC, installing informational signs and undertaking studies to aid in understanding the
interrelationships between Stephanomeria malheurensis and its environment including competition between it and other species.
Management of this area is incorporated into the activity plans associated with Stephanomeria malheurensis.
Legal Description of Site:
South Narrows ACEC:
Willamette Meridian:
T. 27 S., R. 30 E., Sec. 11, SE1/4NE1/4 and NE1/4SE1/4;
Sec. 12, W1/2SW1/4NW1/4, SE1/4SW1/4NW1/4,
SW1/4NE1/4SW1/4 and NW1/4SW1/4.
The area described aggregates 1 60 acres more or less.
Diamond Craters ONA/ACEC
Diamond Craters is an existing ONA/ACEC in the Three Rivers RA. It was established as an ACEC on December 2, 1980, and as
an ONA on April 1 , 1 982. Diamond Craters is located in Harney County, approximately 40 miles southeast of Burns, Oregon, and
4 miles east of Highway 205 adjacent to the eastern boundary of the Malheur National Wildlife Refuge. The existing ONA/ACEC is
1 6,656 acres in size and the proposed addition is 400 acres. The ONA/ACEC will total 1 7,056 acres in size. The elevation of Diamond
Craters ranges from 4,150 to 4,700 feet.
Diamond Craters ONA/ACEC was established to protect the diversity of geologic features and ecosystems. Diamond Craters is
geologically unique because of the great variety of basaltic igneous-volcanic structures representing a complex series of geologic
events which are present within a small geographic area. Preservation of the volcanic features is excellent due to a lack of erosion.
The geologic features include lava flows, vents, craters, domes, a caldera, a maar and a graben. The diversity of vegetation at
Diamond Craters includes both unusual and representative species and communities. The diversity of landforms and vegetation
provides habitat for a large variety of wildlife species.
The management goal of the Diamond Craters ONA/ACEC is to preserve the unique assemblage of geologic features and
ecosystems so that present and future generations may benefit from its exceptional scientific, educational, scenic and recreational
values. Actions which have previously been undertaken in support of this goal include withdrawal of the area from mineral entry,
closure of the area to ORV utilization, removal of livestock and wild horses, development of a self -guided tour, and development of
the Diamond Craters Recreation Area Management Plan which details procedures for managing the recreational uses of the ONA/
ACEC.
Legal Description of Site:
Diamond Craters ONA/ACEC:
Willamette Meridian:
T. 28 S., R. 31 E., Sec. 24, E1/2NE1/4, SW1/4NE1/4,
SE1/4NW1/4, E1/2SW1/2 and SE1/4;
Sec. 25, E1/2NE1/4, NW1/4NE1/4, NE1/4NW1/4
and NE1/4SE1/4.
T.29S, R. 31 E., Sec. 1, E1/2E1/2;
Sec. 12, NE1/4NE1/4.
Appendix 1-187
Table 15. Descriptions of Existing and Proposed ACECs (continued)
T 28 S R 32 E Sec 17 All'
Sec. 8,*Lot4!si/2NE1/4, SE1/4SW1/4, and SE1/4;
Sees. 1 9 through 22, Inclusive;
Sec. 23, SW1/4andS1/2SE1/4;
Sec. 24, SW1/4SW1/4;
Sec. 25, NW1/4NW1/4, S1/2NW1/4, and SW1/4;
Sees. 26 through 35, Inclusive.
T. 29 S., R. 32 E., Sec. 1, W1/2NW1/4 and SW1/4;
Sees. 2 through 6, Inclusive;
Sec. 7, Lot 1, N1/2NE1/4and NE1/4NW1/4;
Sec. 8, N1/2, NE1/4SW1/4, N1/2SE1/4and SE1/4SE1/4;
Sec. 9, All;
Sec. 10, N1/2andSW1/4;
Sec. 11, W1/2NE1/4andNW1/4;
Sec. 5, N1/2NW1/4.
The area described aggregates 16,656 acres more or less.
The addition to Diamond Craters ONA/ACEC:
Willamette Meridian:
T. 28 S., R. 32 E., Sec. 16, W1/2.
T. 28 S„ R. 31 E., Sec. 36, SE1/4NE1/4 and NE1/4SE1/4.
The areas described aggregate 400 acres more or less.
The total area described aggregates 17,056 acres more or less.
Silver Creek RNA/ACEC Addition
Silver Creek RNA/ACEC and the proposed addition are located in Harney County approximately 35 miles west of Burns and 1 5 miles
north of Highway 20 adjacent to the Ochoco National Forest boundary. The existing RNA/ACEC is 640 acres in size and the proposed
addition is 1 ,280 acres including 640 acres of a private inholding, the acquisition of which through exchange is a prerequisite to the
designation of the RNA/ACEC addition. The proposed addition is in the Upper Valley Allotment (No. 701 1 ). The elevation of the site
ranges from approximately 4,520 to 4,800 feet.
Silver Creek RNA/ACEC is an established RNA/ACEC within the Three Rivers RA. It was established to fill the aquatic natural area
cell in the Ochoco, Blue and Wallowa Mountains Province described in the Oregon Natural Heritage Plan (1988) as:
2. First to third order stream system in Blue Mountains originating in ponderosa pine zone, including intermittent streams.
The proposed addition to the Silver Creek RNA/ACEC will provide for a better representation of this cell as it provides a greater
elevational gradient along a single drainage. The proposed addition to the Silver Creek RNA/ACEC will also provide representation
for an unfilled terrestrial natural area cell in the Blue Mountains Province described as:
35. Low sagebrush/bunchgrass community outside the forest zone.
The existing Silver Creek RNA/ACEC in Section 8 consists of ponderosa pine uplands with areas of big sagebrush/bunchgrass as
well as an extensive forested riparian zone. The proposed addition, Sections 1 7 and 20, includes the confluence of Silver Creek and
Sawmill Creek with a combined total of approximately 2.5 miles of high quality riparian area. The riparian zone is dominated by mature
willows and mountain alder with an understory that is mostly Kentucky bluegrass. The uplands are dominated by low sagebrush and
bluebunch wheatgrass. There are also areas of big sagebrush and bluebunch wheatgrass, scattered western juniper and bitterbrush,
Idahofescue and Sandberg's bluegrass. Portions of the existing RNA/ACEC and proposed addition were burned by wildfire in August
1990.
The primary management goal of the Silver Creek RNA/ACEC and proposed addition is to preserve the natural ecosystems and to
provide areas for ecological studies, monitoring, and research, and education. The primary management action which will be
undertaken to aid in the attainment of this goal will be the construction of perimeter boundary fencing. A high standard gravel road
maintained by the county crosses through the southwestern corner RNA/ACEC addition. Coordination with the county will ensure
maintenance does not degrade the RNA/ACEC. Two unimproved dirt roads are also present in the RNA/ACEC addition. These roads
will remain open to public use. Signing of the RNA/ACEC along the county road may be appropriate. A separate management plan
Appendix 1-188
Table 15. Descriptions of Existing and Proposed ACECs (continued)
will be written for this RNA/ACEC subsequent to the acquisition of the private inholding and the ROD. This management plan will
be comprehensive in nature and reflect the allowable uses/use constraints shown in Appendix 1 , Table 1 6 and the procedures and
monitoring discussed in the management decision.
Legal Description of Site:
Silver Creek RNA/ACEC:
Willamette Meridian:
T. 21 S., R. 26 E, Sec. 8, All.
The area described aggregates 640 acres more or less.
Silver Creek RNA/ACEC Addition:
Willamette Meridian:
T. 21 S., R. 26 E., Sec. 17, All;
Sec. 20, All.
The area described aggregates 1 ,280 acres more or less.
Foster Flat RNA/ACEC
The proposed Foster Flat RNA/ACEC is located in Harney County approximately 42 miles south of Burns, Oregon, and 20 miles west
of Highway 205 near the Burns District boundary with Lakeview District. The proposed Foster Flat RNA/ACEC is 2,690 acres in size.
It is in East Warm Springs Allotment (No. 7001 ) and in the Warm Springs HMA. The elevation of the RNA/ACEC is approximately
5,000 feet.
Foster Flat RNA/ACEC will be designated to represent one natural area cell in the Basin and Range Province described in the Oregon
Natural Heritage Plan (1988) as:
1 9. Silver sagebrush/Nevada bluegrass community
This community is found in playas throughout the Great Basin in sites which are flooded for a period of months during the winter and
early spring but which dry up rapidly as the weather warms. Foster Flat covers a large area that is essentially devoid of topographic
relief and is dominated by silver sagebrush. The silver sagebrush/Nevada bluegrass community covers approximately 800 acres
in the central portion of the playa area. At slightly lower elevation on the playa is a silversagebrush/rush community which stays wetter
longer than the Nevada bluegrass association. The slightly higher elevation areas of the playa contain silver sagebrush/green
rabbitbrush. There are also areas of basin wildrye, creeping wildrye or silver sagebrush with no understory. It is ringed by a slightly
raised rim that is dominated by greasewood and big sagebrush.
The primary management goal of the Foster Flat RNA/ACEC is to the manage the area to preserve the characteristics of the
ecosystem and to provide areas for ecological studies, monitoring and research, and education. The primary management action
which will be undertaken to aid in the attainment of this goal will be the construction of perimeter boundary fencing. The perimeter
boundary fence will be constructed to allow livestock and wild horses to access the water source in the northwestern corner of Foster
Flat. Access to the unimproved dirt roads within the RNA/ACEC maybe limited by construction of this fence. Aseparate management
plan will be written for this RNA/ACEC subsequent to the ROD. This management plan will be comprehensive in nature and reflect
the allowable uses/use constraints shown in Appendix 1 , Table 1 6 and the procedures and monitoring discussed in the management
decision.
Legal Description of Site:
Foster Flat RNA/ACEC:
Willamette Meridian:
T. 29 S., R. 29 E„Sec. 34, NE1/4SE1/4 and S1/2SE1/4;
Sec. 35, NW1/4SW1/4 and S1/2SW1/4.
Appendix 1-189
Table 15. Descriptions of Existing and Proposed ACECs (continued)
T. 30 S., R. 29 E.,Sec. 2, Lots 3 and 4, S1/2NW1/4,
SW1/4, NW1/4SE1/4 and S1/2SE1/4;
Sec. 3, Lots 1 and 2, S1/2N1/2 and S1/2;
Sec. 4, SE1/4NE1/4 and NE1/4SE1/4;
Sec. 10, E1/2 and NE1/4NW1/4;
Sec. 11, All;
Sec. 14, N1/2;
Sec. 15, NE1/4NE1/4.
The area described aggregates 2,690 acres more or less.
Dry Mountain RNA/ACEC Addition
The BLM's proposed Dry Mountain RNA/ACEC is located in Harney County approximately 28 miles west of Burns, Oregon, and 1 0
miles north of Highway 20 adjacentto the Ochoco National Forest boundary on Dry Mountain. It is in Claw Creek Allotment (No. 7010).
The proposed RNA/ACEC is 2,084 acres in size. The elevation of the RNA/ACEC is approximately 4,700 to 5,800 feet.
Ochoco National Forest currently has a Dry Mountain RNA proposed in the draft Forest Plan. The USDA-FS proposed Dry Mountain
RNA and the BLM's proposed addition are located in thetransition zone between the Ochoco, Blue and Wallowa Mountains Province
and the Basin and Range Province. The proposed BLM and USDA-FS Dry Mountain RNA/ACEC would fill a number of natural area
cells as described in the Oregon Natural Heritage Plan (1988) for the Ochoco, Blue and Wallowa Province including:
3. Western juniper/big sagebrush community.
7. Ponderosa pine/bitterbrush-mountain mahogany/sedge community.
33. Big sagebrush/bunchgrass community outside forest zone.
41. Mountain mahogany/bunchgrass.
The proposed RNA/ACEC also fills one natural area cell for the Basin and Range Province described as:
1 . Ponderosa pine savanna.
The BLM RNA/ACEC addition contains major portions of the pine-juniper and pine-mahogany types as well as all of the mountain
mahogany community and the complete sagebrush steppetransition zone. The Ochoco National Forest's proposed RNA represents
a ponderosa pine/bunchgrass type with extensions into western juniper and big sagebrush and mountain mahogany types. The
USDA-FS proposed RNA encompasses the higher elevations of the forest-sagebrush transition zone while the BLM proposed RNA/
ACEC provides good representation of the lower elevations of the forest-sagebrush steppe transition which creates a total RNA/
ACEC with more diversity.
BLM's proposed Dry Mountain RNA/ACEC also contains 180 acres which have been removed from the commercial forest timber
base as ponderosa pine old growth management areas. These stands are located in Sections 3 and 1 0 of the proposed RNA/ACEC.
The old growth stands contain an overstory consisting of old and large ponderosa pine trees with a 40-70 percent crown closure.
Theunderstorycontainssmallerponderosapinetrees, many species of shrubs and other herbaceous species. Management of these
areas will be to enhance existing old growth characteristics and to promote continued succession toward old growth. Examples of
management actions which may occurto promote old growth characteristics include stand manipulation forthe maintenance of stand
structure, a desired species composition or a desired snag density. Management of the old growth stands will be in conjunction with
the RNA/ACEC if designated.
The primary management goal of the proposed Dry Mountain RNA/ACEC is to manage the area to preserve all the ecosystems in
a condition where they can provide areas for ecological studies, monitoring, and research, and education. At the current time, it is
felt that perimeter boundary fencing will not be necessary in order to achieve this goal. Utilization of the area by livestock is light due
to steepness of terrain and lack of water sources. Water development or timber harvest in adjoining areas may change livestock
utilization patterns and necessitate the construction of some boundary fences. Low quality unimproved dirt roads exist within the
RNA/ACEC. These will remain open to public use. A separate management plan will be written for this RNA/ACEC subsequent to
the ROD. This management plan will be comprehensive in nature and reflect the allowable uses/use constraints shown in Appendix
1 , Table 1 6 and the procedures and monitoring discussed in the management decision. Additionally, allowable uses/use constraints
and management goals for old growth areas shown in Tables 2.9 and 2.1 0 as they are applicable to the Dry Mountain stands will
also be incorporated into the RNA/ACEC Management Plan.
Legal Description of Site:
Dry Mountain RNA/ACEC:
Appendix 1-190
Table 15. Descriptions of Existing and Proposed ACECs (continued)
Willamette Meridian:
T. 22 S., R. 26 E., Sec. 3, All;
Sec. 4, SE1/4;
Sec. 9, E1/2and E1/2SW1/4;
Sec. 10, N1/2;
Sec. 16, E1/2;
Sec. 22, NE1/4, E1/2NW1/4 and NW1/4NW1/4.
The area described aggregates 2,084 acres more or less.
Biscuitroot Cultural ACEC
The proposed Biscuitroot Cultural ACEC of 6,500 total acres is located approximately 27 miles east of Burns, Oregon, and includes
two associated parcels, both of which are transected by Highway 20. These two parcels, which aggregate approximately 2,1 70 acres
and 4,330 acres, are in the vicinity of Stinkingwater Pass and are primarily oriented north-south, following major ridgeline trends in
the Stinkingwater Mountains. The elevation of the proposed ACEC ranges from 4,280 to 4,995 feet. Access is afforded by high
standard gravel roads and by unimproved dirt roads linked to county and state road systems.
The general location of the Biscuitroot Cultural ACEC is on a plateau northeast of Harney Valley. This locality is afault block mountain
near the juncture of three major physiographic provinces, the Blue Mountains, the Owyhee Uplands, and the Basin and Range. The
plateau is characterized by basalt flows, rimrock, gentle to steeply sloping uplands, and scablands with bare rock or a thin soil mantle.
Soils in the ACEC are generally shallow, well drained, loams and clayey loams that are stony, frigid, and xeric. The Stinkingwater
fault blockformsadivide, with runoff tothe west draining into the Harney Basin and other watersf lowing into the Malheur River system.
Generally, the ACEC has little surface water available other than from a few ephemeral drainages, such as Little Pine Creek,
McMullen Creek, and other unnamed seasonal streams, although springs are found on sloping rocky uplands above Little Pine Creek.
The ACEC features open, stiff sage/bunchgrass vegetation communities, with scattered juniper groves and perennial forbs that
include several edible plants that are culturally valuable to Native American traditionalists.
For generations, Native Americans have used localities in and around the Biscuitroot Cultural ACEC in the Stinkingwater Mountains
for harvesting root crops such as Biscuitroot (Lomatium spp.), bitterroot (Lewisia rediviva), wild onions (Allium spp.), and other
species (e.g. Perideridia bolanderi, Fritillaria pudica) during late spring. Indian people from surrounding regions who came here to
occupy dry camps among the large juniper trees, dig roots, and socialize included the Harney Valley Paiute, Warm Springs Indians,
Bannocks, Shoshones, Umatillas, Yakimas, Suprise Valley Paiutes, and Northern Nevada Paiutes. (Couture, 1978; Couture,
Housley, and Ricks, 1986) Root harvesting was an integral feature of aboriginal culture in the Northern Great Basin and Plateau
regions (Toepel, Willingham, and Minor, 1 979), where roots were intensively exploited during annual root camps of numerous small
family-based groups with attendant social interactions.
These plant resources have great value to contemporary Native Americans as a cultural resource because their continued use is
one of the few traditional activities that is still practiced. The seasonal and social aspects of this activity persist to this day. The
particular localities where the target plant species are harvested provide a significant source of root crops, offering not only nutrition
but also an important cash crop for trade among Indian people Couture, 1978).
Not all "root" fields in the general region are harvested. The high quality and quantity of roots available in these root zones is
noteworthy and could not be replaced by shifting use to other less preferred areas, especially since the preferred fields have, in effect,
been "cultivated" by the long tenure of aboriginal harvest practices. Moreover, particular campsites here are reutilized by families
repeatedly. In recent years, the ACEC area has been utilized by Indian people from Burns, Warm Springs, and Owyhee, Oregon;
Yakima, Washington; Fort Hall, Idaho; Fort Bidwell, California and Fort McDermitt, Nevada.
The primary management goal of the Biscuitroot Cultural ACEC is to ensure the opportunity to continue the traditional practices of
root gathering by contemporary Native Americans in these localities used by generations of Indian people. This will be accomplished
by protecting the habitats of culturally important plants and by minimizing any conflicts posed by competing land uses.
This resource and its cultural use is sensitive to certain other local land uses, primarily gravel pit activities (concurrent use is not
desirable; pit expansion is a threat) and livestock grazing (excessive congregation causes soil compaction; drought year foraging
on cultural plants). Additionally, the potential for increased Native American use pressure in the future could affect the quality and
quantity of the available root crop.
The primary management actions which will be undertaken to attain the management goal will be the cessation of gravel pit activities
upon lease expiration, and restrictions on the use of ORVs. New surface disturbances, plant habitat modifications, and cattle-
congregating practices (e.g., salting, turning out, etc.) will be prohibited within the ACEC. A separate management plan will be
developed for the ACEC subsequent to the ROD. This plan will be comprehensive in nature and reflect the allowable uses and
constraints shown in Appendix 1 , Table 1 6 and the procedures noted in the management decision.
Appendix 1-191
— CTST
Table 15. Descriptions of Existing and Proposed ACECs (continued)
Legal Description of Site:
Biscuitroot Cultural ACEC:
Willamette Meridian:
T. 21 S., R. 34 E., Sec. 27, All;
Sec. 32, That portion east of County Road No. RR1-85;
Sec. 33, All;
Sec. 34, All.
T. 22 S„ R. 33 E., Sec. 12, All.
T. 22 S., R. 34 E., Sec. 4, All;
Sec. 6, All;
Sec. 7, All;
Sec. 9, All;
Sec. 16, All;
Sec. 18, Lot 1, Lot 2, E1/2NW1/4and N1/2NE1/4.
The area described aggregates 6,500 acres more or less.
Kiger Mustang ACEC
The proposed Kiger Mustang ACEC is located approximately 50 miles southeast of Burns, Oregon, on the northern foothills of the
Steens Mountain. It is characterized by open sagebrush hills with juniper-covered ridges and numerous springs and one perennial
stream, Smyth Creek. The proposed Kiger Mustang ACEC is 64,639 acres in size. It is in the Kiger Allotment (No. 5303), Smyth Creek
Allotment (No. 5307), Happy Valley Allotment (No. 5309) and Burnt Flat Allotment (No. 5313). The elevation ranges from
approximately 4,400 to 6,800 feet.
The wild horses that exist in the proposed Kiger Mustang ACEC are an important historic and cultural value, as they represent a
genetic heritage that originated from some of the Spanish Mustangs introduced by European explorers. This area provides a good
location for preserving the primitive markings and features these wild horses exhibit. Adequate water and forage are present to meet
the year-round needs of the wild horses. The two separate portions of the ACEC provide protection for the Kiger Mustang's unique
characteristics, should something happen to one of the herds. The current herd management levels of 84 minimum and 138 maximum
animals gives adequate flexibility for maintaining a large, healthy gene pool of their special characteristics.
The primary management goal of the Kiger Mustang ACEC is to perpetuate and protect the dun factor color and conformation
characteristics of the wild horses present in the Kiger and Riddle Mountain Herd Management Areas. These wild horses also provide
a unique and valuable opportunity for education, research and other public values. A separate management plan will be written for
this ACEC subsequent to the ROD. The management plan will be comprehensive in nature and reflect the allowable uses/use
constraints shown in Appendix 1 , Table 1 6 and the procedures and monitoring discussed in the management decision.
Livestock use by three operators will continue as a viable and compatible activity in the area. The use by both livestockand wild horses
will be adjusted with all resources so to provide for a thriving natural ecological balance in the area as required by the Wild Free-
Roaming Horse and Burro Act of 1 971 . A viewing area and interpretive signs will provide the public an opportunity to see, study and
learn more about these wild horses.
Legal Description of Site:
Kiger Mustang ACEC:
The ACECs western unit is described as follows:
The pasture boundary of the Yank Springs Pasture and the Swamp Creek Pasture in the Kiger Allotment (No. 5308), excluding the
Ham Brown Field (private).
The entire Smyth Creek Allotment (No. 5307) boundary, excluding the Shepard Springs, Duncan and Connelly Fields, which are all
private.
The pasture boundary of the North Big Hill Field and the South Big Hill Field of the Happy Valley Allotment (No. 5309).
Appendix 1-192
; "-
Table 15. Descriptions of Existing and Proposed ACECs (continued)
The ACECs eastern unit is described as follows:
The pasture boundary of the Louie Hughes Pasture and the Oreana Pasture in the Burnt Flat Allotment (No. 5313), excluding the
Cold Springs Field and Tommie's Place Pasture.
Excluding all unfenced private lands within the above described areas.
The areas described aggregate 64,639 acres more or less.
Appendix 1-193
Appendix 1-194
Table 16. Recommended Management/Use Constraints in ACECs
Area Title
Acres
Land
Tenure
Adjustment
Major
Rights
Of Way
Commercial
Timber
Harvest
ORV
Use
Wild
Horses
Fire
Livestock
Grazing
Suppression
Activities
Prescribed
Burning
Vegetation
Treatment
South Narrows AC EC
160
Z1
R
N/A
L
N/A
P
P
R
R
Diamond Craters ONA/ACEC
17,056
Zi
R
N/A
L
N/A
P
P
P
P
Silver Creek RNA/ACEC
640
ZI
R
P
L
N/A
P
R
R
R
Silver Creek RNA/ACEC Add.
1,280
Zi
R
N/A
L
N/A
P
R
R
R
Foster Flat RNA/ACEC
2,690
Z1
R
N/A
L
P
P
P
R
R
Dry Mountain RNA/ACEC Add.
2,084
ZI
R
P
L
N/A
R*
R
R
R
Kiger Mustang ACEC
64,639
ZI
R
N/A
O
R*
R*
O
R
R
Biscuitroot Cultural ACEC
6,500
ZI
R
N/A
L
R*
r-r
P
P
P
Fluid
Energy
Minerals
Solid
Leasable
Minerals
Mineral
Materials
Locatable
Minerals
Camping
Organized
Public
Activities
Wood
Gathering
Plant
Collection
Education
(Repeated
Consumptive)
Rock
Hounding
X)
w
p.
x"
CO
Ol
NSO
NSO
NSO
NSO
NSO
NSO
NSO
NSO
NL
ML
NL
NL
NL
NL
R
NL
P
P
P
P
P
P
R
P
R
W
R
R
R
R
R
R
Z1 = Zone 1, retention and acquisition.
P = Prohibited use or action.
R = Restricted use or action.
R* = Restricted to provisions of AMP or HMAP.
O = Open to use or activity.
N/A = Not applicable.
L = Limited to existing roads and trails,
NSO = No surface occupancy
NL a No leasing.
W - Withdraw from mineral entry.
P
R
P
P
P
P
0
R
P
R
R
R
R
R
R
R
N/A
P
P
P
N/A
P
R
R
R
R
R
P
R
P
R
R
R
R
R
R
R
R
R
R
R
Pi
O
R
O
R
R
R
Appendix 1-196
Table 17. Federal Register Notice
P3&
Federal Register / Vol. 52, No.. 34 /.Friday. February 20, 1987 / Notices
/fon
OH-020-07-4333-10: GP7-123J
Oregon; Off-Highway Vehicle
Designation
agency: Bureau of Land Management,
Interior. •*■ :'~
ACTION: Burns District Office: Notice
given relating to off-highway motorized
vehicle use on public lands.
summary: Notice is hereby given
relating to the use of off-highway
vehicles on public lands in accordance
with the authority and requirements of
Executive Orders 11644 and 11989. and
.". .regulations contained in 43 CFR Part -
i8340vV-;^VJ;:.; "/'..'
'$M The following lands under the
fadmihistration'of the Bureauof Land -•','
■(> Management are designated as closed,. .
fc limited, under Interim Management -'-j ■'-
i|Policy and Guidelines for Lands under -
I Wilderness Review, or open to off- . _ . •;..
:. highway motor vehicle use.
- The area affected by the designations
-isihe Burns District, which includes -. -
3^44,812 acres of public lands in the ., :
Three-Rivers and Andrews Resource " .■'
./Areas located in Grant and Harney . '
Counties; Oregon.;- „ -.. jr-
if^These designations area result of '. -V*/
^resource management decisions made in
^existing Management Framework Plans
•) and analyzed in several grazing . .
f EnvironmentalTmpact Statements.
ifThese designations are published as .-_
^- final until such time that changes in .• . • ..-'
£ riespurce'jinjaMgement^ ..warrant , • . :
? modifications^. " "'* " ■-."..
*- •> **>^-»v^st- A "■ 0-o|i
;AJ Closed Designations r~;fi,
^|beui whicK^ dosed to off-highway ;
L!mQtoMfinTclejU8Vcomprise;9^30 'acresrsj
"C^e area. South Narrows (160 acres), \j
| has been designated dosed'prior to this %
f NbticelThe; following areas are _ .; . h?&
'-: designated dosed to motorized vehide .-
Use to protect resource and scenic ••'•■
values::*; j-.^':.:- ".I*.: — r-Vfis*:'
Malheur Rivet^-Bhie Bucket Creek _ '
Squaw Lake ' ' ■
Hat Butte — ; , — ■— — : —
Windy Point — — -
Devine Canyon — — .-
Acrco
2,080
o„sc:
30
280
1,040
B. Limited Designations
1. Wilderness Study Areas (WSAs)
Wilderness Study Areas, (WSAs)
comprising 829,995 acres will be
managed in accordance with the
nonimpairment criteria of Wilderness
Interim Management Policy which
allows off-highway vehicle use to
Appendix 1-197
Federal Register / VoL 52. No. 34 / Friday, February 20. 1987 / Notices
5349
continue in the manner and degree on
ways and trails where such use was
occurring on October 21. 1376. The only
exception to this would be the
designation of future cross-country
travel m specific sand dune, play^and
snow areas providing that such use does
not impair wilderness character.
The limited vehicle use designation
will remain in effect until Congressional
release of WSAs, or if actual or
unforeseeable use levels cause the
nonimpairment-criteria to be violated, in
which case more restrictive designations
may be made. - :
The following Wilderness Study
Areas are designated as limited to off-
highway motorized vehicle use under
Wilderness Interim Management Policy:
WSA
Unit No.
2-14
2-23L
2-23M
2-72C
2-720
2-72F
2-721
2-72J
2-73A
2-73H
2-74
2-77
2-78
2-81
2-82
2-83
2-84
-2-85E-.
— 2-85G
.2-85H
2-86E
2-86F
2-87
2-98A
2-98C
2-980
2-103
1-146
3-152
3-153
WSA Name
Malheur River/Blue
Bucket Creek.
Stonehouse
Lower Stonehouse .
Sheepshead
Mountains.
Wildcat Canyon
Heath Lake
Table Mountain
West Peak
East Atvord
Winter Range
Alvord Desert
Mahogany Ridge-
Red Mountain
Pueblo Mountains-
Rincon
Alvord Peak
Basque Hills
High Steens..
South Fork Conner
und Blitzed River.
Home Creek __
Blitzen River
Little Blitzen Gorge-
Bridge Creek'.-
Pine Creek (Strawberry
Mtns). ■
Sheep Gulch
(Strawberry Mtns).
Indian Creek (Straw.
Mtns).
Aldrich Mountain
Hawk Mountain
Willow Creek
Disaster Peak
Acres in
Burns
District
2. Lands Other than Wilderness Study
Areas (WSAs)
Lands other than WSAs which have
some type of limited designation
comprise 148.843 acres. These areas axe
limited, in most cases, to use of
motorized vehicles on designated,
existing roads and trails. However,
other limitations may be imposed, such
as use during certain time periods,
certain types of vehicles, or certain off-"
highway vehicle activities.
One area, Steens Mountain
Recreation Lands, including a parcel of
land adjacent to the west boundary for &
total of 164,912 acres, was previously
designated in September. 1980. and
limits use of motorized vehicles to
designated, existing roads and trails.
This area is not included in. this Notice.
The following areas are designated
limited to motorized vehicle use on
designated, existing roads and trails:
These designations "become effective
upon publication in the Federal Register
and wili remain in effect until rescinded
or modified by the Burns District
Manager. Information and maps of areas
with open, closed and limited "
designations are available at the Bureau
of Land Management, Bums District '
Office, 74 South Alvord, Bums, Oregon
97720, Telephone (503) 573-5241.
Dated: February 12. 1987.
Joshua L. Waiburtoc,
District Manager.
[FR Doc 87-3593 Filed 2-9-87; 8:45 am]
RUJNG COM 4310-XJ-M
1 3.480
1 14,825
8.090
23.790
8.730
20.520
"40.592
8,535
22^40
.15,440
97.165
27.940
16.215
.72.090
100.445
16.825
70.600
: '.69,740
•"37;555
' 26.590
'54.280
'9,400
'14,545
200
■ 720
■208
9.395
25,380
2.140
3.740
Steens Mountain Recreation
Lands additional acreage from
land exchanges
Little Blitzen Research Natural
Area (RNA)/Area of Critical
Environmental Concern (ACEC)_
Ltttle Wildhorse RNA/ACEC
South Fork Willow Creek RNA/
ACEC—
Rooster Comb RNA-ACEC
East Kiger Plateau RNA/ACEC-
Silver Creek RNA/ACEC
Pueblo Foothills RNA/ACEC
Turn Turn Lake RNA/ACEC
Long Draw RNA/ACEC-
Mickey Basin RNA/ACEC
Alvord Desert ACEC
Borax Lake ACEC
AlvnirflWr-ArrrV' --
Picket Rim ACEC.
South Steens ACEC
Diamond Craters Outstanding
Natural Area/ACEC_
12.362
-•2^39
: . * 240
'228
•720
•1.240
640
2.520
1^22
440
560
16.700
«_»: 520
-^4;700^
4.000
'50.500
18.658
230511
Warm Springs Reservoir
:f Oregon DepL of Fish & Wildlife
hunting areas , ,
*/«« '••* "MTwii/eTB/vR's. #■'.£.&
■AH acres are within boundaries of Steens Mountain '
Recreation Lands vehicle management designation of Sep-
temper 30. 1360.
*45J40 acres are within ths boundaries of Steens
Mountain Recreation Lands vehicle management designa-
tion of September 3a I960.
49.652
In y
' WSA 2-14: Additional 2,080 acres dosed
by prior management decision.
1 WSA 2-23U Additional 6.500 acres dosed
by prior management decision.
3 The following WSAs have acreages within
the established boundaries of tha Sleens
Mountain vehicle management designation ot
September. 1980. which is consistent with Wil-
derness IMP: 2-85F. 57.650 acres: 2-85 G.
19.005 acres; 2-85H. 22 acres: 2-86E ALL:
2-86F. ALU 2-37. 8.585 acres.
C Open Designations
Areas which are designated open to
-off-highway motor vehicle use comprise
2.390,772 acres. Much of the district's
land topography naturally limits off- •
highway motor vehicle use. Open
designation was determined to be
appropriate as off-highway use of
motorized vehicles is essential to
conduct the management and authorized
utilization of reso'jrcs values.
Appendix 1-198
Table 18. Calculation of Three Rivers Projected Average Annual Recreation Growth.
RMIS Categories (1) NORPS
OR. Project
Activities Reg. 11 (2)
Percent Growth
Low Projection (2)
1987-2000 1987-2010
Percent Grwoth
Mod. Projection (2)
1987-2000 1987-2010
1 986 2000 Low Av. Annual 20 1 0 Low Av. Annual
Base(2) PRrojection Growth Projection Growth
2000 Mod.VAv. Annual 2010 MOodAv. Annnual
Projection Growth Projection Growth
1 ORV Travel
2
Other Motorized
46
3
Nonmotorized
22
24
25
42
43
44
26
4
Camping Visits
27
28
30
31
32
>
\i
CD
3
5 Hunting Visits
6 Other Land-Based
7 Fishing Visits
8 Boating Visits
9 Other Water-Based
10 Winter Sports
11 Snowmobiling Visits
38 Motorcycle Off-Road
39 ATV Driving (3 & 4 Whl)
40 4-WHL Vehicles Off-Road
Sightseeing/Exploring
Day Hiking/Train
O'night Hiking - on trail
O'night Hiking - no trail
Bicybling - on road
Bicycling - off road
Horseback Riding
Climbing/Mountaineering
Rec. Vehic. Camping
Tent Camping/Motor Vehic.
Organ. Group Camping
Horse Camping/Packstock
Horse Camping
48 Hunting Big Game
49 Bow Hunting
50 Hunting/Unland Game
19 Nature Study/Wldlf. Obs..
20 Ooutdoor Photo.
21 Visiting Interp ./Displays
45 Picnicking
1 Fishing from Boat
2 Fishing from Bank/Dock
13 River - nonmotorized
14 Lake - nonmotorized
15 Lake - powerboating
8
14
19
8 Swimming/Wading
9 Waterskiing
36 Cross-Country Skiing
37 Sledding/Snowplaying
33 Snowmobiling
20
31
40
26
9
21
9
21
14
32
33
79
7
15
10
21
8
17
20
44
16
31
1
3
9
22
3
7
5
11
1
2
1
4
21
44
21
51
5
10
0
17
12
23
11
23
2
5
22
50
2
5
2
4
7
16
12
26
14
30
12
25
16
37
21870
23619
26243
25369
29961
25
57
47324
53950
61995
59155
74299
34
84
245307
290983
342224
329790
451292
314501
368552
1 .23%
430462
1 .54%
414314
2.27%
555552
3.19%
25
61
718009
799706
0.81%
903966
1 .08%
896776
1 .78%
1153129
2.53%
21
54
43672
47734
52756
52843
67255
23
58
89509
97453
108403
1 09794
141490
35
96
1 1 6523
133184
153943
157670
228816
86
262
309154
412100
552920
573839
1119108
15
38
57732
61600
66392
66392
79670
23
61
53193
58512
64364
68087
85641
16
37
15728
16923
18323
18244
21547
68551 1
827506
1 .48%
1017101
2.02%
1 046869
3.77%
1743527
6.43%
44
119
457914
550372
660581
661424
1001177
35
77
21 5959
250618
282107
290927
381644
3
6
26410
26779
27202
27123
28047
24
62
19874
21754
24256
24558
32185
8
22
73046
75453
78045
79084
89072
793203
924976
1.19%
1072191
1 .47%
1083116
2.61%
1532125
3.88%
12
25
61759
64847
68257
68874
77332
2
5
14980
15145
15309
15339
15774
5
12
69683
70310
72192
73446
77836
146422
150302
0.19%
1 55758
0.27%
157659
0.55%
170942
0.70%
44
106
188177
227694
270975
270975
387644
45
135
371712
449772
561713
537645
875123
g
24
21473
22482
23684
23491
26562
14
34
80300
86564
93951
91542
107602
661662
786512
1.35%
950323
1 .82%
923653
2.83%
1396931
4.63%
34
74
97375
108838
1 1 9783
130516
169229
32
70
208139
231436
255573
273904
354275
305514
340274
0.81%
375356
0.95%
404420
2.31%
523504
2.97%
8
21
16419
16747
17240
17733
19867
8.--
252
28096
34277
42143
51697
59563
5
11
38321
39087
40123
40237
42690
82836
90111
0.63%
99506
0.84%
1 09667
2.31%
122120
1 .98%
4
9
36231
36956
37753
37716
39637
18
41
46530
49980
53974
54678
65443
82761
86936
0.36%
91727
0.45%
92394
0.83%
105080
1.12%
24
41
14125
15820
17798
17515
19916
30
52
64394
73313
84031
83424
97606
78519
89133
0.97%
101829
1 .24%
100939
2.04%
1 1 7522
2.07%
21
47
45023
50425
0.86%
56278
1 .04%
54477
1 .50%
66183
1 .96%
(1) Source - BLM Recreation Management Information System
(2) Source - Activities by Summary Table Number in the Pacific NW Outdoor Recreation Consumption Projection Study, Oregon State University, January 1989.
to
CO
Appendix 1-200
I— — «h
Table 19. Projected Recreation Visits to BLM Administered Lands in the Three Rivers RA for
the Years 2000 and 2010.
1989
OREGON PROJECT BASE PERIOD
RMIS CATEGORIES NORPS ACTIVITIES, REG. 11 (1) VISITS (2)
PROJECTED REC. VISITS
FOR THE YEAR 2000 (3)
LOW MODERATE
OJECTED REC. VISITS
OR THE YEAR 2010 (3)
LOW MODERATE
1 ORV TRAVEL
38 MOTORCYCLING OFF-ROAD
39 ATV DRIVING (3 & 4 WHL)
40 4-WHL VEHICLES OFF-ROAD
5300
6017
6623
6944
8742
2 OTHER MOTORIZED
3 NONMOTORIZED
4 CAMPING VISITS
46 SIGHTSEEING/EXPLORING 7650
22 DAY HIKING/TRAIL 2120
24 O'NIGHT HIKING - ON TRAIL
25 O'NIGHT HIKING -NO TRAIL
42 BICYCLING - ON ROAD
43 BICYCLING - OFF ROAD
44 HORSEBACK RIDING
26 CLIMBING/MOUNTAINEERING
27 REC. VEHIC. CAMPING 34100
28 TENT CAMPING/MOTOR VEHIC.
30 ORGAN. GROUP CAMPING
31 HORSE CAMPING/PACKSTOCK
32 HORSE CAMPING
8332
2465
9148
2999
38564 43890
9232
2962
11435
4927
44233
61700
5 HUNTING VISITS
48 HUNTING BIG GAME
49 BOW HUNTING
50 HUNTING/ UNLAND GAME
6250
6380
6628
6652
7092
6 OTHER LAND-BASED
19 NATURE STUDY/WLDLF. OBS.
20 OUTDOOR PHOTO.
21 VISITING INTERP./DISPLAYS
45 PICNICKING
18600
21362
24390
25207
35609
7 FISHING VISITS
8 BOATING VISITS (4)
1 FISHING FROM BOAT 16300 17752 20424
2 FISHING FROM BANK/DOCK
13 RIVER - NONMOTORIZED 890 1923 1967
14 LAKE - NONMOTORIZED
15 LAKE - POWERBOATING
19438
1961
26143
2060
9 OTHER WATER-BASED
8 SWIMMING/WADING
9 WATERSKIING
1010
1050
1102
1097
1225
10 WINTER SPORTS
36 CROSS-COUNTRY SKIING
37 SLEDDING/SNOWPLAY
1700
1881
2081
2114
2518
11 SNOWMOBILING VISITS 33 SNOWMOBILING
1300
1423
1515
1571
1812
(1) SOURCE - ACTIVITIES BY SUMMARY TABLE NUMBER IN THE PACIFIC NW OUTDOOR RECREATION CONSUMPTION PROJECTION
STUDY,
OREGON STATE UNIVERSITY, JAN., 1989 FOR SCORP REGION 1 1 (INCLUDING LAKE, HARNEY AND MALHEUR COUNTIES).
(2) SOURCE - BLM RECREATION MANAGEMENT INFORMATION SYSTEM, BURNS DISTRICT.
(3) CALCULATED FROM THE BASE PERIOD FIGURES USING THE AVERAGE ANNUAL GROWTH RATES FOR EACH RMIS CATEGORY AS
SHOWN IN TABLE 18.
PROJECTIONS FOR BOATING VISITS AT CHICKAHOMINY RESERVOIR CALCULATED USING PERCENT CHANGE FOR LAKE, POWER
BOATING ACTIVITY ONLY.
BOATING VISITS FOR WARM SPRINGS RESERVOIR ARE COUNTED BY THE BUREAU OF RECLAMATION, THE MANAGING AGENCY FOR
THAT AREA.
Appendix 1-201
Appendix 1-202
Table 20. Gold Development Scenarios
With the increased activity associated with gold mining in the Vale District (to the east of the planning area) and in northern Nevada
(to the south of the planning area), and with increased claim staking activity in the RA over the past year, it was determined that
generalized gold mining scenarios should be included. One such scenario has been previously developed forthe Proposed National
Historic Oregon Trail Interpretive Center at Flagstaff Hill Decision Record and Environmental Assessment, appendix H (BLM, 1 988).
Another gold mining scenario that should be considered is one similar to the recently proposed Grassy Mountain Mine in northern
Malheur County, Oregon. This scenario would befairly typical of gold mining operations in eastern Oregon that use cyanide, although
it is smaller than most operations in Nevada. While both of these scenarios are based on BLM experience in the field, individual
operations would be expected to vary somewhat. Approval of mine development plans would require sufficient mitigation measures
to address concerns such as reclamation, neutralization, sensitive resource values protection, etc. Both scenarios have been
included for illustrative purposes only.
Mineral Development Scenario for the Flagstaff Hill Mine
The attached scenario is based on the assumption that a potential ore body could be worked by either surface mining and cyanide
heap leaching, or by underground mining associated with agitation cyanide milling. Actual extraction might involve elements of both
or use of a different milling technology. Open pit mining and heap leaching would permit recovery of a larger low grade (about 0.1
oz gold/ton) deposit assumed to be on the order of 6 million tons (100 feet wide x 500 feet deep x 1 ,500 feet long), while higher
extractive costs of underground recovery would limit mining to a smaller amount of higher grade ore (about 0.3 oz gold/ton) on the
order of 400,000 tons (5 feet wide x 1 ,000 feet deep x 1 ,000 feet long). These reserve values were chosen to be generally consistent
with mineral deposit models described in our July 26, 1 988 report on the "Mineral Potential of the Flagstaff Hill Area, Baker County,
Oregon."
Economic projections for open pit development are represented as a range bounded by estimates based on the Bureau of Mines
IC 9070, "Gold Availability", and the Mining Cost Service 1 988 cost model for a 2,000 ton per day m ine with a 4:1 stripping ratio. Back
calculation of direct employment, based on these sources, agrees fairly well with available information reviewed by the staff for other
western U.S. open pit/cyanide leach operations with greater than 5 million tons of reported reserves.
This mineral development scenario was prepared strictly for the benefit of BLM land use planning to assess possible employment
association with operation of a mine at Flagstaff Hill and environmental assessment. This scenario should not be used for any other
purpose. It is based on possible future discoveries and not on the presence of known deposits. The scenario does not include
employment during the development and start up phases of the projected mine(s). It envisions two mine development possibilities
or combinations:
1. Open pit-mineable deposit of about 6,000,000 tons (100 feet x 1 ,500 feet x 500 feet) with a grade of about 0.1 ounce gold per
ton to be recovered by heap leach techniques, and
2. Underground-mineable deposit of about 400,000 tons (5 feet x 1 ,000 feet x 1 ,000 feet) with a grade of about 0.3 ounce gold per
ton to be recovered by agitation cyanide leach milling techniques.
In addition it is important to point out that the chances of any mining operation occurring at the site are in the range of 1 in 5 to 1 in
50, based on our professional judgment and experience in observing the success of similar properties.
Average hourly wage of the labor is taken at $13.89. The cost of labor to the company including fringe benefits is $150/day per
employee-shift. Mine life is assumed to be 1 0 years. The mill is operated 300 days per year and the mine 250 days per year.
1. Open pit and Heap Leach Operations.
Mine production 2,400 tons/day
Mill production 2,000 tons/day
Heap leach recovery 75% of contained gold
Stripping ration (tons of
waste tons of ore 4.0:1.0
Employees Total Other
Yearly Yearly Capital
Payroll Costs Costs
Mine Mill Total (4) ($) ($)
Mine A 133 29 162 5,800,000' 6,600,000 25,000,000
Mine B 64 31 95 3,400,000 - 33,000,000
Mine A from Mining cost Service Cost Model (1988).
Mine B Primarily from data in U.S. Bureau of Mines IC 9070 (1986).
Appendix I-203
Table 20. Gold Development Scenarios (continued)
2. Underground Mine and Agitation Leach
Mine production
(shrinkage stop)
Mill production
Employees
Mine A
Mine
62
Mill
9
Total
71
1 60 tons/day
1 33 tons/day
Total
Yearly
Payroll
($)
2,600,000
Other
Yearly
Capital
Costs
Costs
($)
($)
800,000
12,000,000
Mine A from Mining Cost Service Cost Model (1988)
(projected from 500 m T/D and 1 000 m T/D cost models).
Selected data for Western U.S. open pit and underground mines is given in Table 1 for general comparison with projected mine
development.
The expected economic impacts to the local community include direct and indirect employment, nonwage/salary purchases by the
mine, and increases in the assessed property evaluation. The capital cost of construction can be expected to approximate the
assessed evaluation of the mine and mill for property tax purposes, but does not include a value for inplace ore reserves. Most of
the nonpayroll operating expenses are likely to be spent in the local community. It is assumed that 75 percent of actual nonpayroll
expenses will be spent in the community. The major economic impacts of the mineral development scenario are summarized below:
Open Pit Mine
Employment, direct
Payroll, annual
Purchases in local
community, annual
Mine/Mill Property Value
employment, secondary
Underground Mine
Employment, direct
Payroll, annual
Purchases in local
community, annual
Mine/Mill Property Value
Employment, secondary
95-162 jobs
$3.4-5.8 million
$5.0 million (assumed 75% of total)
$25-33 million (not including ore reserves)
95-234 jobs (assumes factor of 1 .0 to 2.0)
71 jobs
$2.6 million
$0.8 million (assumes 75% of total)
$12 million (not including ore reserves)
71-142 jobs (assumes factor of 1.0 to 2.0)
While the scenario assumes a 10 year-life, it is not an uncommon experience in similar mining districts for additional discoveries to
significantly extend mine life.
Mineral Development Scenario for Northern Malheur County
Location:
Mine Life:
Work Force:
Local Economy:
Reserves:
Overburden:
Heap Leach Ore:
Production:
Disturbance:
Ore Processing:
Mining Method:
Mining Rate:
Operating Hours:
Pit Size:
Heap Pad Size:
Tailings Pond:
Liners:
Neutralization:
Ground Water:
Reclamation:
reshaped and then
25 miles SW of Vale, Oregon.
1 0 years.
150-200 people.
Projected impact is 400 new jobs (economic multiplier of 2).
30-40 million tons.
60-80 million tons.
10-30 million tons.
1 million ounces of gold and silver.
1,100 acres.
Lower grade to be heap leached. Higher grade to be milled (carbon-in-leach).
Open pit (2) and possibly underground.
65,000 tons/day (ore and overburden).
24 hours per day, 7 days per week throughout the year.
Grassy Mountain pit: 2,300' diameter/1 ,000' deep (83 acres).
Crab Grass pit: 3,000' x 2,000' x 100' deep (110 acres).
One heap leach pad covering 160 acres.
One pond covering 124 acres to hold 2 to 5 million tons.
Heap pad, pregnant pond, and tailings pond will be lined with a synthetic liner.
Heap pad will be neutralized after mining.
Water quality monitoring wells will be used to ensure ground water does not become contaminated.
Buildings will be removed. Waste rock piles, heaps, tailing ponds, and other disturbed areas will be
revegetated after topsoil is replaced. Pits will not be backfilled.
Appendix I-204
Appendix II
-■■ ----- ~g*" -iimriJ1fffilBiinfBfc
Appendix 11-1
Index to Comment Letters
LETTER
NUMBER
COMMENTER
1
Oregon Environmental Council/Mary Hanson
Riddle Ranch/Western Range Service, Otleys, Bailey
2
3
Nature Conservancy/VanderSchaff, Dick
4
Harney Co. Stockgrowers Assoc./Mark Doverspike
National Wildlife Federation/Bruce Apple
5
6
Harney Co. Court/White, Wallace, Bentz
7
ODFW/Randy Fisher/Darryl Gowan
3
Otley, Fred
9
Oregon Trout/Kathleen Simpson Myron
10
Exec. Dept./Clearinghouse/Streeter/Park Rec. Dept.
11
Audubon Society of Portland/Linda S. Craig
12
Jensen, Robert & Carol
13
ONRCTTim Lillebo
14
Goirogolzarri, Javier
15
OPLAC/Frank Vaughn
16
Native Plant Society of Oregon/Stuart Garret
17
Shepardson, Stanley
18
Cox, Susan E.
19
Shepherd, James & Elia
20
Bachhuber, Irene
21
Surmann, Paula
22
Burcomber, David
23
Catterson, Ethel
24
Corkran, Charlotte
25
Decker, Van G.
26
Wales, Diana
27
Siegner, Pat and Monte
28
Harris, Melanie
29
3 J Cattle Company/Jerry Temple
30
Oregon Farm Bureau/Breese
31
Mickel, Philip M.
32
Voegtly, Mr. and Mrs.
Stoddart, Lois and John
33
34
Crow Camp Ranch/Stoddart, John
35
Robertson, J.W. and Carol
3S
Same as Letter 35
37
Miller, Don
38
Jenkins Ranches/Jenkins, Richard/Patricia
39
Arntz, T.M.
40
Ott, Perry Harrison
41
Sweeney, Mary Ellen
42
Arnold, Ken and Barbara
43
Rex Clemens Ranch, Inc./Daniel R. Bamhart
44
LaPine High School
45
Can't Read Signature
^:s
Harney Co. Farm Bureau/Herb Davis, Pres.
47
Dunbar, Harvey & Margaret
48
Borelli, Louis John
49
Eastern Oregon Mining Association/Grissom
Culp Cattle Co./Pat Culp
50
51
Cagle, Feme
NW Mining Assoc./E.A. Johnson
Rogue Valley Audubon Society/Frank Hirst
52
53
54
Drewsey Field Ranch/G.W.P. Wright
55
Hotchkiss, Newton
56
Clemens, Del & Theresa
57
Howard RanchTT., E., T, B., Howard
58
Van Grazing Coop/Thomas C. Howard
59
King, Clayton
Taylor, Rex & Elta
60
61
Beckley, Gladys
62
Beckley, Gladys
63
Johns, David M.
64
Morgan, Mike and Betty
65
Morgan, Mike and Betty
55
Jess, Mrs. Marvin (Dorie)
67
Seaman, Vernon L.
68
Seaman, Vernon L.
69
Public Lands Action Network/Jim Fish
70
Jones, Jay Eric
71
Read, Lois
72
Miller, Craig
73
Oregon Trout/Craig Lacy
74
Theodore, Karen
75
Sequeira, Michael
76
Tyler Brothers/Wes Tyler
77
Tyler Brothers/Wes Tyler
78
Harney Co. Sheep & Wool Growers Assoc./Nancy Cray
Appendix II-2
PAGE NUMBER OF
COMMENTS
5
8
18
20
22
25
28
30
32
35
37
41
41
43
44
47
47
48
48
50
50
51
52
52
53
54
55
53
56
57
58
58
59
59
50
31
61
62
52
63
54
58
S3
70
71
72
73
73
74
74
75
75
7S
77
77
78
78
79
79
80
80
81
82
32
83
83
34
84
85
86
86
87
87
83
88
89
90
LETTER PAGE NUMBER OF
NUMBER COMMENTER COMMENTS
79 Arneson, James 91
80 Scollard, Daniel 91
81 Beemer, Ken 92
82 Parrish, Norma 93
83 Cramer, William D. 94
84 Cramer, William D. 94
85 Baldwin, Mari 95
86 Mayo Ranch/ Mark, Kathy, Carl and Jean 95
87 Voile, John 96
88 Oregon Cattlemen's Assoc./Don Gomes, Sr. 96
89 Sterbentz, Cathy M. 97
90 Central Oregon Audubon Chpt./Glen Van Cise 97
91 Miller, Jerry A. 98
92 Purdy, Floyd and Dorothea 98
93 Wilson, Harry E. 99
94 Hammond Ranches, Inc./Dwight and Susan Hammond 100
95 Schillinger, Tom, Walt & Gerry 101
96 Neuschwander, Duane E. 101
97 Cowles, Timothy 102
98 Quigley, Mike 102
99 Gerl, Gary 103
100 NW Fed. of Mineralogical Soc./Jon Spunaugle 104
101 Snyder, Leta Gay 105
102 Gerl, Bob 106
103 Range Ecology/John Barry 107
104 Davies, Emma M. 108
105 Whiting, Hilton/Eva/Ron 109
106 Timms, Eugene HO
107 Joyce, Dan HO
108 Keniston, James 111
109 Evergreen State College/Steven G. Herman 112
1 1 0 Warm Springs Tribe/Marcia Kimball 1 1 3
1 1 1 Oregon Hunter's Assoc/Kelly Smith 1 1 4
112 Peila Ranch, Inc./John M. Peila 115
113 Peila Ranch, Inc./John M. Peila 115
114 Edmunson, Richard 116
115 Bentz, Alician 116
116 Peila, Theresa A. 117
117 UofO/Alvin Urquhart 118
118 Muller, Pat 119
119 W.J. Hoyt Sons Ranches/Claude Mulholland 120
120 USDA, Forest Service/Pacific NW Region/Butruille 121
121 Couture, Marilyn 121
122 Lillebo, Tim 123
123 Otley, Jennie 124
124 Otley, Jennie 124
125 Oregon Trout/Rick Miller 125
126 ODFW/Darryl Gowan 126
127 Davies, Martin M. 127
128 Davies, Andrea 128
129 7 Z Land & Cattle Company, Inc., Zurfluh 129
130 Baker, Alice/Mitch 129
131 Baker, Mitch 130
132 Baker, Mitch and Linda 131
133 Baker, Mitch and Linda 132
134 Sword, John J. 133
135 Ellingson Rocking 3E Ranch/Victor Thurman 134
136 Dunten, Turen and Carol 135
137 Oregon Sheep Growers Assoc/William Rill 136
138 Pine Creek Ranch/Donald A. Dryer 137
139 Davies, Lou W. 138
140 American Mustang & Burro Assoc/Barbara Rehfield 138
141 Wales, Daina 139
142 Drewsey Field Ranch, G.W. Wilber 139
143 Rees, Elaine 140
144 Sierra Club/Mary Garrard 141
145 Meadow Creek Enterprises/Dick Raney 142
146 Keniston, James 149
147 Otley, Allen 150
148 Drinkwater, Jim, Cheryl, Jack, Betty 150
149 Scharff, John 151
150 Lonsdale, Connie 151
151 Grande Ronde Resource Council, Inc./Roberta Bates 152
152 Otley, Harold and Mary 153
153 EPA, Region 10, Ronald Lee 154
154 Christenson, Erleen, Ph.D. 155
155 Smith, Kaye 156
156 Yriarte, Louis 156
157 Peila, William S. 157
158 OSU/William C. Krueger 158
159 Assoc. Of Oregon Archaeologists/Tom Connoly 159
160 Peila, Lori 160
Appendix II-3
LETTER
NUMBER
COMMENTER
PAGE NUMBER OF
COMMENTS
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
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190
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192
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206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
Steward, Janet
Malheur Field Station/Lucile Housley
Clark, N./Sitz, B./Cronin H., Opie, H.
Opie, Helen
Davies, Mary Jo
Johnson, Dora M.
Taylor, W. Reid and Linda
King, Clayton and Mary
Portland Audubon Society/Richard A. Parrish
Otley, Susan
Otley, Susan
V Dash Cattle Co./Ken Bentz
Steens Mountain Ranch/Darrell Otley
Steens Mountain Ranch/Darrell Otley
Elstand, Gregory P.
Otley, Larry
Petition w/45 Signatures
Baker, Alice K.
Baker, Alice K.
Miler, Charles and Norma
French, Rotha
OToole Cattle Co./P. & S. O'Toole/Glenn Harris
Burns Paiute Reservation/Larry Richards
Property Owners/Rails-Trails/1 5 Signatures
Oregon Cattlewomen/Kay Markgraf
Harney Co. Cowbelles/Kathy Dryer
ONRC/Andy Kerr
National Wildlife Fed./Bruce Apple
Carpenter, Bob
The Wilderness Society/Larry Tuttle
Hotchkiss Co., Inc. /Richard A. Hotchkiss
Rex Clemens Ranch, Inc./Don Barnes Rep.
Ostertag, George & Rhonda
Myers, Quintin
Holmes, Mathew J.
Davies, Norma
Davies, Maurice
Ponderosa Ranch/D. Garth Johnson
Drinkwater, Jack, Betty, Jim, Cheryl
Drinkwater, Jack, Betty, Jim, Cheryl
Dunn, Larry
Wharton, Marvin
Ward, James D.
Harney County Chamber of Commerce
Otley, Rod
Oregon Natural Desert Assoc. /Alice Elshoff
Trutwin, Victor
Oregon Forestry Dept./James Brown
Richards, W.A.
Kiger Mustang Assoc./Littleton/Wines
Wines, L. Elwm
Kiger Mestano Assoc./Ann C. Roda
Kiger Mestano Assoc./Frank C. Roda
Roberts, Jon
Roberts, Eve
Vickers, Lyle & Helen
Eagle Cap Wilderness Pack Station/Manford Isley
Isley, Vera
USDI, FWS, Malheur Wildlife Refuge/Cameron
Quarter Moon Cattle Co. /Gary Taylor
American Rivers/Cassidy
Peterson Brothers Upper Valley Ranch/Jon Peterson
Swamp Creek Ranch/Wayne Ousley
TheChuckar Foundation/Edward Robertson
The American Alpine Club
160
161
162
163
163
164
164
164
166
167
167
168
168
169
170
170
171
172
172
173
173
174
175
176
176
177
178
179
179
180
181
103
184
185
185
186
186
187
188
189
189
190
190
191
191
192
193
194
196
196
197
197
198
199
200
200
201
202
203
203
204
206
208
209
210
Appendix II-4
for the
OREGON ENVIRONMENTAL COUNCIL
2637 S.W. Water Avenue • Portland, Oregon 97201 ■ 222-1963
hua L. Warburton February 15,1990
District Manager
U.S. Bureau of Land Management
HC 74-12533 Hwy 20 West
Hines, OR 97738
Re: Three Rivers RMP DEIS
Dear Josh:
I have completed my review of the Three Rivers RMP DEIS
and would like to congratulate you and your staff for
development of a preferred alternative that demonstrates
a commitment to balanced multiple use management. The
shift in management direction toward greater concern for
fish, wildlife, recreation, and cultural resources
presents a major departure, and a welcome one.
Burns District BLM.
I liked the general format of the material, particularly
Table 2.1 which facilitated the comparison of the
management alternatives. The excellent quality maps were
valuable aids. The photographs were a welcome sight.
They should be required in all major BLM documents!
My comments, detailed below by management objective,
address items that need further clarification and
recommendations that would make the preferred alternative
acceptable to OEC. Alternatives C and D are totally
unacceptable. Alternative ft would be acceptable to OEC,
but is unlikely to be adopted in place of the preferred
alternative. Alternatives 3 and C are acceptable with
clarifications and modifications recommended.
Water Quality (Table 2.1-9). The management objective to
-eet or achieve state water quality standards is most
appropriate and long overdue. However, it is not clear
how it could be met under Alternatives C or D.
Item 4, Alternatives B and C: Setting utilization levels
le admirable, however, clarification is needed as to
whether one or all three utilization criteria need to be
met in order to trigger removal of livestock from an
allotment which contains all three components. Also, it
has been my experience that the most rapid riparian
OFFICERS
Allen Johnson
Mary kvIl' Mi-Curdy
BOARD Of DIRtCIORS
Hill Bugbee
Bod Do p pelt
Debbie Gotham
Rod Gutt ridge
Margaret Klfk Patrick
Gloria Mamn
Jo" MHeMU
Nancy Nesewtch
Carol Pedersen Moo '0 neon
Dave Pickering
Warren Roicnfeia
Don Soltiman
Elhun Schist
Gil Sharp
Bob Stocev
arp«r
Paul
EXtCUllVE DIRECTOR
Three Rivers RMP, 2/15/90
greater use of native species in vegetation treatments. OEC
cannot accept either the large acreage destined for conversion or
the continued reliance on crested wheat.
Item 4. We recommend grazing also be excluded from Saddle Butte,
especially since it is not going to be designated an ACEC . all
efforts should be expended to protect native vegetation
communities. We do not feel that native plants should be
jeopardized by grazing. You should at least consider fencing the
adjacent seeding.
1-13 1 Vegetation (Table 2.1-14) Management Objective. OEC recommcr.de
"nclusion of the word "native" before "plant species". We would
ike to sec the restoration of native range based on site
otential as a management objective.
Item 8. Same comments as in Water Quality Item 11 above.
-14 1 Special Status Species (Table 2.1-17) Item 1. This item appears
I to refer only to plant species (Group 1). Docs it also apply to
| animal species listed in Table 3.87
-15 1 ltem 3- Is there research to support the 2 mile standard? Under
I stipulations for fluid energy mineral development (Appendix 9-
I 12), no surface occupancy is allowed within one-half mile of sage
I grouse strutting grounds under Alternative C, 1 mile under
I Alternative B, and 2 miles under Alternative A. These distances
I seem arbitrary. What are they based on?
Actions to restore special st3tus species habitat are excellent.
However Alternative C needs some language to address livestock
grazing where special status plant species occur. If not
exclusion then how about managing grazing so that it does not
hinder recovery or enhancement of special ototuo plant species?
Wildlife Habitat Management (Table 2.1-20) Item 1, The term
"blocks" conjures up visions of a checkerboard. I prefer
"units" . Also, does this action include transportation
corridors, such as "stringers"? I would also like to see
coordination of big game cover with units designated on the
National Forests .
I appreciate the increase in AUM'c allocated to big game.
However, this entire section seems to focus on big game. What
about wildlife habitat management for other species, e.g. cavity
nesters and other birds and mammals that don't have special
species status? Why doesn't the BLM designate indicator species
and develop management objectives for their habitats.
1968 • Tvmty Tsars Protecting Oregon's Future® ■ 1988
Page 2 - Three Rivers RMP, 2/15/90
recovery occurs under exclusion in most cases.
Item 11, Alternatives C: The 20 percent figure could be large or
small depending on the size of the area. Where streams or water
courses are involved it is more appropriate to speak In terms of
subbasins or watersheds. As written, this item does not address
cumulative effects of habitat alteration in adjacent areas, or
the effects of several projects in a given watershed.
1-5 I I* is not clear on Map WQ-1 in Volume 1 what is meant by the
I term "Water Quality Areas". Are they water quality limited,
| areas where water quality is monitored, etc.? Please explain.
In Table 3 in Appendix 1-4 it appears the x's in the three
columns from the right are shifted too far to the left. Enclosed
is a copy of the beneficial use tables from Oregon Administrative
Rules for Malheur River Basin and Malheur Lake Basin. Since most
of the RA is in the Malheur Lake Basin the table should include
beneficial uses for this basin as well.
Soils (Table 2.1-6). According to Map S-2 in Chapter 3, the
majority of soils in the resource area are presently in the
moderate to stable categories. The management objective would
not change things appreciably. A more appropriate objective
would be to achive stable soil conditions. This would
necessitate altering the grazing systems criteria in Item 1
across all alternatives accordingly.
Forestry and Woodlands (Table 2.1-9). Item 6, Alternatives B and
C: This item would be improved by adding a qualifier similar to
that in Alternative A, such as "consistent with other resource
objectives". Also, how did you arrive at the number of average
acres (53) for precommercial thinning? It appears somewhat
arbitrary.
Appendix 2-3. Table 2 does not mention leaving large woody
debris for stream structure or retention of large diameter trees
for recruitment of large woody debris.
Livestock Grazing (Table 2.1-11). Item 3. It is not clear why
the number of acres proposed for seeding in Alternative C is
considerably larger than Alternative D which emphasis commodity
production.
It is discouraging to read in the plan that the Burns B1M
continues to rely on crested wheat to improve forage production.
While the standard procedures for creating optimum edge effect
are commendable, I cannot understand why the BLM doesn't make
Page 4 - Three Rivers RMP, 2/15/90
Wetland, Reservoir and Meadow Habitat (Table 2.1-23) Management
objectives and actions for this category are commendable.
However, I would recommend retaining buffers around plnyar. for
those areas proposed for treatment (Chapter 4-29). It Is not
clear why buffers wouldn't be left, or why you couldn't use a
mosaic pattern around playas as you arc proposing to use in the
guidelines (Appendix 3-177).
Riparian Habitat and Aquatic Habitat (Table 2.1-22-27) Comments
regarding livestock utilization are the same as those given under
Water Quality above.
I'm pleased to cee inclusion of buffer zones for springs, seeps,
and associated meadows in addition to live streams.
1-20 I Item 8 under Aquatic Habitat. I think you should evaluate
1 streambank condition after 3 years, particularly if the grazing
system is changed. You should be able to determine if it is
|_ working within that time . Five years is perhaps too long.
Same as Item 11 under Water
Item 10 under Aquatic Habitat.
Quality discussed above.
Recreation (Table 2.1-31) Item 1, second objective. A brief
description of contents of the Federal Register citation would be
helpful. It could easily be incorporated into an appendix. I
can't imagine where you could have ORV use where vegetation
occurs without sustaining resource damage. The Mohave Desert
springs to mind, and I would not like to see that kind of
degradation occur in Harney County. Any ORV area would have to
be closely monitored and I doubt that the Burns BLM has the kind
of resources available to do that. Please identify areas
proposed for this type of recreation.
Item 2, second alternative. This action is unacceptable for the
same reasons stated for Item 1 above. What evidence do you have
that there is a direct correlation between distance from
population centers and an increase in the number of out-of-county
users as your statement suggests? Alternative B is more
realistic, particularly since there is a sacrifice area already
established for ORV use northwest of Hines.
1-24 I Item
\ map ,
Please identify the Silvics River access trail on the
was unaware of its existence.
[Item 6. Please explain how management of livestock grazing in
riparian areas enhances fishing opportunities. Unmanaged
recreation use can be as damaging to riparian zones as unmanaged
Appendix 11-5
OREGON ADMINISTRATIVE RULES
CHAPTER 340. DIVISION 41 - DEPARTMENT OF ENVIRONMENTAL QUALITY
Three Rivers RMP , 2/15/90
livestock .
Areas of Critical Environmental Concern (Table 2.1-35) I
recommend designation of Hatt Butte and Squaw Lake as ACECs . The
BLM should provide protective designation for ail special and
unique areas until such time as more native communities can be
restored. Since Hatt Butte and Squaw Lake receive little or no
grazing pressure it is difficult to understand why they are not
designated. Designation would provide some prote
surface disturbance from mining. Pleas
Visual Resources This section was rather confusion. Please
explain how the Map VRM-l relates to the VBM classifications
ction from
reconsider .
found in Appendix 8, Tables 1
preferred alternative?
Is it a representation of the
very pleased to see some attention paid
OEC supports Alternatives A, B, and C.
Cultural Resources I1
to cultural resources.
Nice work!
1-281 Energy and Minerals (Table 2.1-38) I object to the language in
I all objectives that intends to maximize energy and mineral
I development in the RA. A more conservative approach would be
I preferable, in spite of current federal mining laws. It would
I help if you deleted the work "maximum" where it occurs in the
_ management objectives .
1-291 Lands and Realty {Table 2.1-42} Item 1 under "Eliminate
I unauthorized use of public lands". How long is long-term, and
| how short is short-term?
Item 3. Good show!
1-30 I Tabic 2.1-44, Item 3 under "Acquire public and administrative
| access...". Add "consistent with other resource values".
On behalf of the Oregon Environmental Council, thank you for the
opportunity to comment.
Sincerely,
Mary Hanson
1B92 W. Pierce
Burns, OR 97720
(September. 1981)
ORECON ADMnnSTRATrVE RULES
CHAPTER 340. DIVISION 41 - DEPARTMENT OF LWIRONMENTAL QUALITY
| | |
| J I J
\ 5 5 ti.
i 1
1-1 The intent is that when any utilization criterion is met, removal of
livestock from the pasture In question would be triggered. See the
Proposed Plan for clarification of riparian utilization criteria.
1-2 It is correct that the most rapid riparian recovery occurs under
exclusion in most cases. The aquatic habitat management actions in
the Proposed Plan are consistent with water quality management
actions and riparian habitat management actions. See WL 6.1, 6.2 and
6.3 of the Proposed Plan.
1-3 Under the Preferred Alternative, Water Quality Management Objective,
item 11, the Intent and purpose was to establish a maximum area that
could be treated if treatments were within 1 mile of a perennial
stream. This would reduce erosion and runoff from treated areas, and
other adverse impacts to aquatic habitats. Due to public concerns
with the proposed wording, this objective will be changed to read ".
. . of any area within 1 mile of perennial water to leas than 20
percent of that subbasin in any one year."
1-4 Though Item 11 does not address cumulative effects of habitat
alteration in adjacent areas; prior to any mechanical or fire
treatment, a prescribed fire plan and an NEPA document would be
developed. The NEPA document would address secondary and cumulative
impacts associated with the prescribed activity.
1-5 The water quality areas identified on Map WQ-1 in Volume 1 of the
text are provided to assist the reader In locating particular streams.
1-6 In Table 3 of Appendix 1, DRMP/DEIS, the x's In the three columns
from the right were shifted too far to the left and have been
corrected In the PRMP/FEIS. Additionally, a table Identifying
beneficial uses of waters in the Malheur Lake Basin was provided In
DRMP/DEIS, Appendix 1, Table 2.
1-7 The management objectives and actions for soils (Table 2.1-6,
DRMP/DEIS) have been rewritten. The management actions target
accelerated erosion (erosion due to human activity). The achievement
of a stable or no erosion equilibrium across the entire planning area
is not an achievable goal, because a certain amount of erosion is
naturally occurring. The rate of geologic erosion depends upon
factors such as slope, soil, climate and cover. With the exception of
cover, these factors cannot be controlled on a large scale. In
addition, geologic erosion is important for the proper functioning of
fluvial systems. Streams can cut laterally or vertically into their
streambanks or beds for several reasons, one of which Is the lack of
sediment during peak flows, when the amount of energy available to
carry sediment Is high (Bull 1979). Accelerated erosion on the other
hand, may cause problems such as slltation and degradation of
fisheries.
(September. 1935)
Appendix 11-6
The statement; "consistent with other resource objectives" will
improve Alternatives B and C statements concerning precommerclal
thinning. The number of acres (53) was derived by correlation.
Approximately 27 percent of the commercial forest land Identified in
the John Day RMP (dated 1985) is included in this RHP; therefore,
approximately 27 percent of the acres identified for precommerclal
thinning In the John Day RMP (200) would be pre commercially thinned
within this planning area.
Alternatives B, C and D (Item 2 of Minor Forest Products) mentions
leaving most dead and down material for enhancement of other resource
values. These values include woody debris within stream areas. Also,
DRMP/DEIS, Appendix 2, Table 2, items 3 and 4 discuss plans for
streamslde vegetation protection and enhancement.
Alternative D ts a continuation of present management. In this
alternative, only the seeding projects proposed in previous land use
plans, specifically the Riley EIS, were brought forward into
Alternative D. Alternative C proposed acreages not addressed in
previous land use plans. Appendix 3, Table 7, DRMP/DEIS, identifies
potential projects by allotment.
Crested wheatgrass has not been chosen as the sole species to seed.
Appendix 3, Table 8, DRMP/DEIS, Standard Procedures and Design
Elements for Range Improvements, states that "BLM would determine
seeding mixtures on a site-specific basis, at the EA level in
accordance with NEPA, using past experience and recommendations of
the Oregon State University Extension Service and Experiment Stations
and/or Oregon Department of Fish and Wildlife." Seedlngs will be
designed "using irregular patterns, untreated patches, etc., to
provide for optimum edge effect for visual quality and wildlife.
Layout and design would be coordinated with local Oregon Department
of Fish and Wildlife biologists." Seed mixes used in the Three Rivers
Resource Area (RA) In the last 5 years have shifted away from
exclusive use of crested wheatgrass to a variety of grass, shrub and
forb species.
The BLM policy on seedlngs for Oregon and Washington says: "Seedlngs
to change vegetation composition should be used when it is the most
efficient method to accomplish the resource objectives identified
through the planning process. The selection of the seeding area and
the species to be used should be based on a site-specific evaluation
which considers ecologlc potential, technical and economic
feasibility, location of unique resources, plant diversity and
cumulative Impacts on the ecosystem. Adapted native species that can
enhance vegetative diversity composition must be given consideration
In species selection. To insure establishment seedlngs must be
protected for two growing seasons or until the vigorous seedlings
produce their firBt seed crop. Once established, seedlngs should be
properly managed and monitored to ensure that resource objectives are
accomplished."
Allotment evaluations are being prepared in the RA to assess the
effects of livestock grazing (both level and timing) on the public
lands. Where it is appropriate, species specific objectives for
special status plant species are being incorporated Into the
allotment evaluation process. Incorporated into these objectives will
be monitoring and inventory.
It does not appear that livestock grazing is adversely impacting
special status plant species; however, through inventory and
monitoring, the status of each special status plant species can be
established and the impacts of livestock grazing on the species can
then be evaluated.
See the Proposed Plan for management
status species.
:tions dealing with special
All timber sale areas will be evaluated on a case-by-case basis to
ensure adequate cover for travel, escape and thermal protection
purposes remains in any particular sale. During the EA process, ODFW
and USDA-FS ranger district personnel are consulted for input into
harvest design. The word blocks has been changed to units, see
Proposed Plan decision WL 2.3.
Habitat for species not specifically mentioned is treated by habitat
types. For instance, good condition riparian areas support a larger
diversity of wildlife species than any other type in the planning
area. The timber harvest, riparian area, wetland, grazing and
vegetation portions of the Proposed Plan are designed to provide
habitat for these animals. Data Is not available, specific to some of
the habitat types in the planning area, to designate indicator
species. Also, baseline data on small mammals and songbirds Is
lacking over most of the planning area. Objective WL 7 shows
management actions which are expected to have the highest degree of
impact on nongame species.
Buffers will be left and mosaic patterns will be created If
treatments are implemented. The guidelines in Appendix 3-177 of the
DRMP/DEIS are standard procedures on all types of improvements. Also,
playa habitat has been shown to be important for some species of
wildlife. Currently, playa conditions and trends are unknown. If
during the life of the plan, conditions are found to be
unsatisfactory, then actions and objectives will be designed during
formulation and evaluation of activity plans.
St re am bank conditions are monitored more frequently than 5-year
intervals on areas with grazing systems designed to improve riparian
and aquatic habitat. The 5-year timeframe refers to stabilization
projects. This period was used because In some cases significant
improvement may take 5 years to become apparent.
The Federal Register Notice of February 20, 1987, is Included in
PRMP/FEIS, Appendix 1, Table 17.
A map locating existing and proposed open, closed and limited areas
for ORV use has been added to the PRMP/FEIS.
Vegetation manipulation through seeding is only one of the tools the
Bureau has at its disposal to resolve resource conflicts and meet
multiple-use objectives. Where possible, management facilities such
as fences and water developments will be considered first In
developing grazing systems and meeting resource objectives, but
seedings will also be considered where they meet management
objectives. Seedlngs will be used under a number of conditions
including, but not limited to erosion control, wildfire
rehabilitation, weed control, increased forage production, and in
cooperation with Individuals and other agencies.
Potential seedlngs will be restricted in deer and elk winter range by
the restriction that prescribed fires be no larger than 400 acres and
no more than 15 percent of browse would be eliminated. There will be
no vegetation treatment within 1 mile of perennial water or aquatic
habitat and no detrimental sagebrush removal within 2 miles oE sage
grouse strutting grounds. See Proposed Plan for water quality and
wildlife habitat restrictions.
The Saddle Butte proposed ACEC does not meet ACEC criteria. Analysis
of current management Indicates that grazing is not causing damage to
the site. If future evaluations Indicate a change In this situation,
management practices can be modified.
The objective and management, actions for vegetation have been
revised, see the Proposed Plan. Upon completion of the Ecological
Site Inventory now underway in the RA, ecological status objectives
will be developed. However, when developed these objectives will not
always have the potential natural community (PNC) as the desired
plant community. Variety and diversity of healthy plant communities
is the Intent of this objective.
Because Congress has repeatedly cited livestock grazing as a valid
use of the public land through FLPMA, the Taylor Grazing Act, the
Public Rangeland Improvement Act, etc., this objective will also meet
the needs of all multiple uses, Including wildlife habitat, livestock
grazing and special status species, among others.
The special status species table has been refined; see Table 2.11 in
the Proposed Plan. The management actions In the Proposed Plan which
are not species specific refer to all special status species, both
plants and animals.
Research does exist to support the 2-mile standard. Wallestad and
Pyrah (1974) and others have found that most nests occur within 2
miles of a lek. As the radius from the lek becomes larger, the total
acreage involved grows at an increasing rate. Surface occupancy
would, therefore, involve less percentage of the total area the
farther away from the lek occupancy takes place. It is felt that with
seasonal stipulations and these distances from leks, sage grouse
nesting and brood rearing habitat will be protected.
Off-road vehicle/of f-highway vehicle use is a valid and accepted use
of BLM lands. This use will not be eliminated from the management
scheme, but as stated in E.O. 11644, policies and procedures will be
established "that will insure the use of off-road vehicles on public
lands will be controlled and directed so as to protect the resources
of these lands." This Includes various measures such as establishing
boundaries, signing, law enforcement and designations to manage ORV
use as stated above.
E.O. 11644 also mandated that all Bureau land be designated as open,
closed or limited. Any open or limited areas where ORV use Is causing
considerable adverse impacts to resources shall be designated closed
until measures are taken to eliminate resource problems and prevent
recurrence.
The only Intensive use area for ORVs has been established on Radar
Hill near Burns and HInes . There are no other requests for such use
nor any other areas planned for designation by the District at this
time. Past requests for cross-country ORV use have come from
out-of-county users. These are considered on a case-by-case basis
with an EA addressing potential Impacts. If Impacts cannot be
eliminated or mitigated to an acceptable level, application is
refused and a permit is not issued. This "cross-country" ORV use Is
relegated to travel on designated roads and trails for point-to-point
racing such as the Burns to Bend Race (the only race allowed; twice:
1978 and 1979). It does not include driving off established routes
and meandering over the terrain. There are no other known, identified
race routes In the RA.
Off-Road Vehicle Management Directives (1) and (2) under Alternative
B, Emphasize Natural Values With Commodity Production, have been
adopted in the Proposed Plan. Management Directive 1 also has
additional wording and reads as follows: "Implement and manage ORV
areas designated in the Federal Register on February 20, 1987, as
well as a prior designation for South Narrows. Exceptions are Warm
Springs Reservoir area (23,811 acres), Squaw Lake area (6,500 acres)
and Malheur River-Blue bucket Creek (2,080 acres). The open areas now
free of ORV use, but susceptible to ORV damage, will be closed or
limited in future designations when a determination Is made that the
use of ORVs will cause, or is causing, significant adverse impacts on
natural, cultural or historical resources of particular areas or
trails on public lands."
The trail is noted
the
atlon map.
Management Directive 6, under the Preferred Alternative to manage
livestock grazing in riparian areas for enhancement of fishing
opportunities, is written to note the relationship between improving
fish habitat and, potentially, fish populations. This is to be
accomplished by managing livestock use to Increase vegetative cover
over streams, stabilize streambanks, reduce water temperature and any
other habitat Improvements to increase fish populations and, in turn,
increase fishing opportunities.
Appendix 11-7
The Interdisciplinary team analysis resulted in the conclusion that
Hatt Butte and Squaw Lake do not meet Bureau AGEC criteria for
relevance or importance. Neither Hatt Butte nor Squaw Lake clearly or
strongly include relevant cell needs that are required by the Oregon
Natural Heritage Plan, rather each falls somewhat short of being
truly representative (relevance) and truly appropriate (importance).
Hatt Butte includes pristine plant communities represented elsewhere
In the system, and is a geological feature that is noteworthy but not
exceptional. Squaw Lake Is not a permanent feature but rather an
intermittent pond, and any associated cell needs for plant
communities have been nominated or designated at better sites
elsewhere. No particular threats are posed to either locality.
Map VRM-1 Is the present classification for managing visual resources
on Bureau-administered lands in the RA. It denotes the acreages
listed in Table 3, Alternative D (Continuation of Present Management)
of Appendix 8, DRMP/DEIS.
Where the expression "maximum opportunity" is used, it is in
reference to opportunity to explore, lease, develop, etc., mineral
resources within constraints imposed by measures to protect sensitive
resource values. Such protective constraints have been designed to be
the least restrictive necessary to protect the sensitive resource
values while avoiding unnecessarily encumbering mineral activity
consistent with BLM's multiple-use mission.
The authority to authorize occupancy or agricultural uses on public
land is contained in Section 302(b) of the FLPMA. The regulations
established under the act limits short-term permits to a maximum
period of 3 years. Long-term leases must be issued for a period that
Is consistent with the time required to amortize the capital
Investment of the use being authorized. In practical terras, depending
on the use, this would range from 3 years to a term of 10, 20 or 50
years or more, as determined by the authorized officer. Perpetual
agricultural or occupancy uses would require disposal of the land by
sale or exchange.
The statement "consistent with other resource values" has been added
to the referenced management objective in the Proposed Plan.
This entire 26 Page Report Entitled:
"Comments and Response to Draft Three Rivers Resource Management Plan and
Environmental Impact Statement" Prepared by Riddle Ranch and Western
Range Service, should be considered as Riddle Ranch stockholders comment
in addition to our individual comment.
RIDDLE RANCH
HC 72, BOX 5 5
PRINCETON, OREGON 97721
January 26, 1990
Joshua L. warburton
District Manager
Burns District
Bureau of Land Management
HC 74 - 12533
W. Highway 20
Hines, Oregon 97738
COMMENTS TO THE
DRAFT THREE RIVERS RESOURCE MANAGEMENT PLAN
AND ENVIRONMENTAL IMPACT STATEMENT
Dear Joshua:
Enclosed is the report entitled "COMMENTS AND RESPONSE TO
Draft Three Rivers Resource Management Plan and Environmental
Impact Statement" dated January 17, 1990 which will serve as our
written comments to the Draft Three Rivers Resource Management
Plan and Environmental Impact Statement dated October 1989. This
report was cooperatively prepared by Riddle Ranch and Western
Range Service, a private range management consulting firm based
in Elko, Nevada. Please carefully review and study this document
(our comments) in its entirety.
We appreciate the opportunity to review the Draft Three
Rivers RMP/EIS. If you have any questions or request any
clarifications, please contact us.
Sincerely, *
Allan Otley y
Enclosure
-2 I
COMMENTS AND RESPONSE
TO
"Draft Three Rivers Resource Management Plan
and Environmental Impact Statement"
Prepared by:
Riddle Ranch
and
Western Range Service
January 17, 1990
SUMMARY
The Draft Three Rivers Resource Management Plan and
Environmental Impact Statement (Draft RMP/EIS) is not needed .
For Three Rivers Resource Area, valid land use plans (Drewsey and
Riley MFP) were developed and implemented within the last ten
years. BLM has reported that there has been considerable
progress in achieving multiple use objectives under current
management. Most of draft's proposed management objectives were
not considered as "planning issues . " Most of the alternatives
are similar. Even the Emphasize Commodity Production Alternative
will have significant adverse impacts upon livestock production.
BLM has not considered a variety of alternatives. Although
Alternative D comes close, a No Action Alternative was not
developed or analyzed. There was no evidence in the Draft
RMP/EIS that the proposed planning criteria was available for
public comment.
The surface water quality and agnatic and riparian habitat
condition ratings appear to be inconsistent and unrealistically
restrictive. If water quality conditions are as poor as BLM
claims (86% of the streams are reported to have poor surface
water quality) , we would expect that there would be no fish left
in the Resource Area, These water quality ratings (surface,
riparian and aquatic) are the basis for the majority of the
adverse impacts to livestock grazing.
All available information indicates that current upland
grazing practices are having no significant adverse impact on
surface water quality. There is no scientific basis for limiting
upland utilization limits to 30%. The 10% utilization limit for
woody riparian shrubs is also unreasonable and without scientific
basis.
The proposal to remove livestock from streams will disrupt
current, successful grazing systems and will have long-lasting
adverse impacts on livestock operations. Only a portion of the
streams are publicly owned. Therefore, BLM's proposed actions
will have very little, if any, effect on overall stream
conditions.
Appendix 11-8
Giving wildlife and wild horses priority over cattle in
forage allocations is unfair and inconsistent with recent Federal
Court decisions. It may well be illegal.
BLM has failed to address many of the adverse impacts of
their preferred alternative on livestock grazing. Funding for
the proposed range improvements will probably not be available.
The upland 3 0% utilization limit is not even considered in BLM's
analysis of impacts associated with the preferred alternative on
livestock grazing. Preliminary analyses indicate that BLM's
preferred alternative will result in 30% to 70% reductions in
livestock grazing in the resource area. BLM was apparently
trying to minimize permittee and community resistance to their
preferred alternative. The failure to disclose such impacts is
misleading and improper.
INTRODUCTION
This document will serve as the Riddle Ranch comments to the
"Draft Three Rivers Resource Management Plan and Environmental
Impact Statement" dated October 19b 9 hereinafter referred to as
Draft RMP/EIS. The organization of this report corresponds to
the organization of the Draft RMP/EIS . The underlined chapter,
page, table or appendix numbers used in this report correspond to
the Draft RMP/EIS.
CHAPTER 1
Ch I, pages 3-4
We strongly disagree that livestock grazing should be
considered an issue and addressed in the current Draft RMP/EIS.
The public participated in the Drewsey Final Grazing Management
Environmental Impact Statement hereinafter referred to as the
Drewsey Grazing EIS. Forage allocations were made for both
livestock, wild horses and wildlife in the Drewsey Grazing EIS.
Since the implementation of the Drewsey Grazing EIS, BLM has
reported that significant progress has been made in obtaining
management objectives.
In the 1981 Rangeland Program Summary update for the Drewsey
Grazing EIS , Burns District Manager stated:
"to date we have made significant progress in improving
the public rangelands through intensive livestock
management and rangeland improvements."
In the 1983 Drewsey Rangeland Program Summary update, BLM
stated:
"The specific objectives are to: improve waterfowl and
fish habitat, increase available forage for wildlife,
wild horses and livestock, maintain water quality and
CHAPTER 2
2-16
2-17
Alternatives A, B and C are very
A and E are similar in many respects.
1610.4 states:
:imilar. Even alternatives
Federal regulations 4 3 CFR
"All reasonable resource management alternatives shall
be considered and several complete alternatives
developed for detailed study. The alternatives
developed shall reflect the variety of issues and
guidance applicable to the resource uses. ..."
Some of the more important
alternatives are listed below:
similarities among the
1) The amount of livestock forage to be converted to wildlife
is identical in Alternatives A, B, C and E [Table 2.1-
22,23) . The "emphasize natural values alternative" (A) and
the "emphasize commodity production" alternatives reduce
currently available livestock forage by the same amount.
2) Alternatives A, B, c and E all remove livestock from
riparian areas for at least five years.
3) Alternatives A, B and C all incorporate the same forage
utilization standards for areas exclusive of Horse
Management Areas.
4) The management objectives and concerns for each allotment
are identical under all alternatives (Table 2.1-8,9,10.11) .
5) There are many other similarities among alternatives in
Table 2.1 which are to numerous to mention.
The Draft RMP/EIS does not provide a variety of alternatives
as required by FLPMA and 43 CFR 1610. For livestock grazing, the
alternatives in this Draft RMP/EIS are either no change or a
reduction in livestock grazing. Alternatives A, B, c and E will
all adversely affect livestock grazing. As we will discuss
below, forage utilization standards proposed in this Draft
RMP/EIS will be the limiting factor for livestock grazing for
Alternatives A, B and C No upland utilization standards are
given for Alternative E 30 the impact of utilization standards
cannot be determined. Currently available and legally
established livestock forage will be reduced and allocated to
wildlife in Alternatives A, B, C and E. cattle will be excluded
from riparian areas in Alternatives A, B, C and E for at least
five years which will reduce the amount of high quality forage
available to livestock, prevent livestock from obtaining water
(especially during droughts) and prevent the enjoyment of private
reduce soil erosion, increase recreational
opportunities and quality, minimize impacts of the
program on visual and wilderness resources, minimize
the impacts of the program on visual and wilderness
resources, minimize the impact of reductions or changes
in use on grazing permittees and protect cultural
resources and threatened and/or endangered plant and
animal species .
There has been considerable progress :
objectives and this progress will
following sections."
chieving these
discussed in
The objectives stated above (in the 198 3 Drewsey Rangeland
Program Summary update) address the Planning Issues related to
livestock grazing and wildlife. If BLM believed the Drewsey
Grazing EIS was successful, there is no reason to change it after
only ten years. To quote a famous saying, "If it a in' t broke
don't fix it."
BLM has not provided any evidence that forage availability
for big game or livestock has changed dramatically since the
implementation of the Drewsey Grazing EIS. The Drewsey Grazing
EIS and Drewsey Rangeland Program Summary addressed the forage
requirements of big game. The reported recent increase in elk
population levels indicates that current forage availability is
adequate. Requiring adequate monitoring and inventory data
before changing management objectives and actions is consistent
with Planning Criteria 4 listed on Chapter 1 page 5.
We request that BLM continue to use the Drewsey Grazing EIS
until appropriate BLM monitoring data indicates that the current
forage allocations are inadequate. Eliminating grazing
management from analysis in this Draft RMP/EIS is consistent with
BLM's elimination of wilderness and weed and grasshopper control
from analysis in the Draft RMP/EIS.
Water quality, riparian condition and aguatic habitat
condition are not listed as planning issues in the Draft RMP/EIS.
Initial public participation apparently did not even address
water quality and aquatic condition. Yet, BLM bases
approximately 1/3 of its management objectives listed in Table
2 . 1 on water quality, riparian condition and aquatic habitat.
Water quality and/or riparian and aquatic condition are addressed
in water quality, soils, forestry and woodlands, livestock
grazing, special status species, wildlife habitat management,
(wetland, reservoir and meadow habitat) , riparian habitat,
aquatic habitat, and recreation management objective categories
in Table 2.1. Since riparian and aquatic condition and water
quality were not considered as planning issues, BLM placed too
much emphasis on these factors during the preparation of the
Draft RMP/EIS.
__D) . Because of
cannot be
stock water rights. Livestock watering is considered a
beneficial use by the state of Oregon (Appendix 1-3) .
2-18 Federal regulations 43 CFR 1610.4-5 (see below) requires
that one of the alternatives considered will be "No Action."
43 CFR 1610.4-5 "One alternative shall be for no
action, which means continuation of present level or
systems of resource use."
Alternative D is considered the "No Action" alternative in
the Draft RMP/EIS. However, there are several changes proposed
in Alternative D. The initial stocking level will be increased
to 161,222 AUM's from current active preference of 150,472 AUM's.
The timber base (acres) was changed. Additional range
improvements are proposed. The allocation of livestock forage to
wildlife was increased from 4,396 AUM's (Appendix l. Table ■', ] to
5,278 AUM's (Chapter 4 , page 2\ . A.U.c-rn
these and other proposed changes, Alternative
considered as the "No Action" Alternative required by law.
Perhaps, Alternative D can be renamed as the "minimal action"
Alternative and used in any future analyses that are necessary.
However, Alternative D cannot be used as the "No Action"
Alternative in the planning process. A "No Action" alternative
must be developed, analyzed and presented to the public for
comment.
Ch. 2. page 3
what is the basis for the "Criteria for the Composition of
the Preferred Alternative"? There is no mention of vegetative
diversity, wetland systems (riparian, aquatic, wetlands and playa
habitats) special species status habitat and Kiger mustang herds
in the Planning Issues and Planning Criteria in Chapter 1 of the
Draft RMP/EIS. Federal regulations 43 CFR 1610.4 state:
". . . Proposed planning criteria, including any
significant changes, shall be made available for public
comment prior to being approved by the District manager
for use in the planning process. ..."
It would have been very helpful to have had the detailed
monitoring and evaluation plan incorporated into the Draft
RMP/EIS. Our comments may have been different if the monitoring
and evaluation plan had been available. We will present our
recommendations for a monitoring and evaluation plan below.
Table 2.1
A discussion of Table 2.1 will be given in our comments
concerning Chapter 4 and throughout this comment report.
Appendix 11-9
Ch. 3. nages 2 and ?7
Why does the number of miles of stream and acres of "flat"
water in the Three Rivers Resource Area vary from 126.55 miles of
stream and 4 ,491 acres of flat water in the Surface Biter section
to 83.65 miles of stream and 4,066 acres of flat water in the
Aquatic Habitat section?
Available references or detailed explanation should be
provided for the methodology used in determining surface water
quality, aquatic habitat condition and riparian condition. Host
of the management objectives are based on the surface water
quality, aquatic habitat and riparian habitat condition and yet
there is no explanation how this information was collected
analyzed and interpreted. what are the differences and
similarities among surface water quality, aquatic habitat and
riparian habitat condition ratings?
Why is temperature used in
Isn't water temperature used
condition rating?
surface water quality condition?
in determining aquatic habitat
In Appcndi :■:
6-3.
.. the aquatic habitat condition ratings and
we assume riparian and surface water quality condition ratinqs
are based on a percentage of optimum or potential. Are the
excellent, good, fair and poor condition ratings based on uniform
?nniS (le-' ?T25% " po0r' 26_6°* " fair' 51-'5t = 9°°=1 =nd 76-
100, = excellent) similar to that used for range condition
ratings r
In Appendices 1, 5 and 6, condition and trend for surface
water quality, aquatic habitat and riparian habitat are presented
for streams m the Resource Area. Are the condition ratings
current? when were the condition ratings last obtained' Were
two or more estimates of condition ratings, obtained at different
points in time, used to determine trend? If trend was based on a
one time reading, the term "apparent trend" rather than "trend"
should be used in Appendices 1, 5 and 6.
There appears to be some inconsistencies among the surface
water quality, aquatic habitat and riparian habitat condition
latii.gs. For example in Deep Creek, aquatic habitat and riparian
habitat condition is good and the trend is static. Apparently
there is little livestock use ["Poor livestock access" (Appendix
£^2)]-. However, the surface water quality is poor "and not
improving. In the Riddle Mountain allotment, the surface water
quality of Riddle Creek is poor and static, aquatic habitat is
not,??? "J" H" 3nd fhS riPari"" habitat is fair and decreasing.
On Rattle Snake creek, riparian condition is good and improving
aquatic habitat is fair and improving and surface water quality
t . 3 , pages 12 and 16
With only 12% of the allotments (24/195) in the Resource
5 1 Area requiring grazing systems, the implementation of grazing
systems should not have been considered as a "Planning Issue"
f Chapter 11 .
Ch. 3. pacres 24-26
Many of the plant and animal species listed in Table 3.8 are
not found in the Three Rivers Resource Area (see Map SS-11 and
should be eliminated from Table 3.8.
ch. 3 , pages 26
The large increase in big game populations indicate that big
game habitat conditions are improving.
Ch. 3. pages 66-67
With the high levels of unemployment and poor economic
conditions in Harney County, BLM should encourage a real increase
in commod ity production and not try to reduce commodity
production. Agriculture contributes significantly to the taxes
collected in Harney County. Any reduction in agriculture
production as a result of this Draft RMP/EIS will adversely
affect the local economy and services provided by Harney County.
Ch. 4 , page 2
The assumption that "funding and personnel would be
sufficient to implement any alternative described" is in error.
Over the last five or more years almost no money has been
available for livestock range improvements throughout most of the
BLM administered public land in the West. What evidence can be
offered to support the contention that adequate funding will be
available?
Ch. 4, pages 2-6
A great potential for adverse impacts to commodity
production and especially livestock production exits with respect
to water quality ratings including the related riparian and
aquatic habitat condition ratings as well as the proposed
management actions and objectives to improve the ratings.
For^ Alternatives A, B and C, a 30% upland herbaceous
utilization limit is supposed to increase vegetative cover which
would in turn lead to decreased sediment loads and water
is poor and static on 371 of the stream. Could these
inconsistencies be a result of differences among observers,
natural variation and/or sampling error? Does BLM have any
estimates of the variation and associated sampling error
associated with these measurements and ratings?
There are no streams in the Resource Area that have good or
better surface water guality. Even areas that have been excluded
from livestock or have limited livestock use do not have good
surface water quality. Does BLM have any evidence to suggest
that good or better BLM surface water quality ratings are
possible in the Three Rivers Resource Area?
Since most of the streams are privately owned or controlled
by other agencies, we find it difficult to believe that any
proposed BLM alternative will have any effect on current stream
conditions, BLM cannot control management practices on privately
owned land. Eliminating grazing on public land for five or more
years will not prevent grazing on privately owned land unless it
is uneconomical to fence it from federal land. (Note: We do not
necessarily agree with BLM's contention that current grazing
practices are damaging surface water quality and aquatic and
riparian habitat condition . ) The proposed management actions
will affect only a portion of the stream and will therefore have
little impact on overall stream condition.
Ch . 3 . page 3
It is very important to note that BLM's best available
information indicates that there is very little if any erosion
(stable or slight erosion condition class) in the Three Rivers
Resource Area (Map S-2) .
If there is so little erosion, why is BLM proposing to
dramatically change utilization standards on uplands on at least
3 of their 5 alternatives?
If there is so little erosio
problem in surface water quality in
why is silt listed
it of the streams (App
If there is so little erosion occurring at this time, will
changing livestock grazing on uplands have any effect on surface
water quality?
BLM data indicates that current
grazing systems have been very successful
[razing practices and
n minimizing erosion.
BLM's surface water quality standards may not accurately
reflect the true potential for streams in the Resource Area.
temperatures. We strongly disagree with this BLM supposition.
Water temperature is dependent primarily upon woody streams ide
cover and to some extent streams ide herbaceous cover (Clary and
Webster 1989). Upland herbaceous cover will have no effect on
water temperature.
Most of the allotments in the Resource Area are using
grazing systems, such as rest rotation, deferred grazing or some
combination. With these types of grazing systems, forage species
can withstand 50% or greater utilization of annual forage
production during the growing season without any significant
changes in basal cover of key forage species. Very little
changes in basal cover of key forage species were noted in
allotments using three pasture rest rotation grazing systems even
with utilization levels of 65% to 80% (Eckert and Spencer 1986,
Eckert and spencer 1987) . Hormay and Talbot (1961) recommended
66% utilization levels for rest rotation grazing systems.
With a grazing system, forage plants can generally withstand
higher utilization levels than season long grazing.
Researchers have given the following recommendations for
proper use factors for intermountain vegetation. Most of the
proper use factors are for season long grazing. Pickford and
Reid (194 8) and Hyder (19 58) recommended that utilization of
biuebunch wheatgrass (an important key forage species in the
Resource Area) should not exceed 55% to 60% during the growing
season in Eastern Oregon. Moderate grazing intensity appears to
the most conducive for maintaining vegetative cover for livestock
grazing in the Northern Great Plains (Olson et al. 1985).
Mccarty and Price (1942) recommended grazing mountain forage
plants at a moderate level.
The proposed 3 0% utilization limit does not consider the
season when grazing takes place. The effect of grazing on the
vigor (cover is often a measure of vigor) of key forage species
depends on the timing of grazing or season of use (Cook 1977 and
Laycock 1967) .
The proposed 30% utilisation limit in Alternatives A, B and
c is especially inappropriate for crested wheatgrass which
comprises approximately 6% of the Resource Area (Table 3.7) .
Crested wheatgrass should provide approximately 23,675 AUM's
(conservatively assuming 4.5 acres/AUM) or 16% of active
preference (21,300/150,472). Cook (1966) recommended a 55% to
60% utilization level for crested wheatgrass on foothill ranges
in Utah. A 65% utilization level was recommended by Frischknecht
et al. (1968). Torell and Godfrey (1983) determined that the
optimal utilization level for crested wheatgrass was over 70%.
BLM's erosion condition classes (Map
o or only slight erosion in almost all
-2) shows that there
>f the Resource Area.
Appendix 11-10
All available informatioi
Summary updates and 1 iterature
grazing practices are having n
surface water quality. There
utilization levels to 30%.
(Hap S-2. Rangeland Program
indicates that current upland
significant adverse impacts on
j no basis for limiting upland
Ch ._
page 7
The 10% utilization standard for woody
(Tabic g.i) is also unreasonable. Light to
generally has little adverse effect and
riparian shrubs
moderate grazing
yem=j.a.j.xj uas J.j.i.i.xt3 auv Bibe t'.L , tsi; i dim ±11 SOlTie Cases Will
stimulate growth of woody riparian species (Clary and Webster
1989) . Hedrick (1958) reported proper use factors of 35% to 70%
for browse species including aspen. There is no scientific basis
for a 10% utilization standard for riparian woody species.
The proposal to remove livestock from riparian areas
(streams) for five or more years will have very adverse effects
on livestock grazing and have little impact on overall stream
conditions . Unless additional fencing is constructed, many
pastures will be unusable for five or more years. This will
require BLM and permittees to modify or eliminate grazing systems
that BLM has reported as being successful (see discussion above
concerning Chapter 1) . Pastures with riparian areas used in rest
rotation and deferred grazing systems will not be available.
Pastures that currently receive periodic rest or deferment will
have to be used continuously or drastic reductions in livestock
and difficult livestock movements will be required.
Most of the allotments contain streams or drain into
streams. Only 14% of the streams listed in Appendix l do not
contain sections with poor surface water quality (BLM estimate) .
Therefore, many permittees will have to remove livestock from
riparian areas for five or more years. Much of the riparian
areas in the Resource Area are privately owned. A large portion
of the streams that BLM has classified as having poor surface
water quality will continue to be grazed on private land. Even
if BLM's allegations concerning the adverse effects of livestock
on surface water quality are correct, livestock removal from
public land will have little effect on overall stream conditions.
The Draft RMP/Eis suggests that temporary additional feed
will be used to mitigate this loss of temporary loss of forage.
However with the upland utilization limit of 30%, all allotments
in the Resource Area will face drastic reductions in livestock
grazing (detailed discussion below). There will be no temporary
additional forage in other allotments.
The Draft RMP/EIS recommends using grazing systems that are
"widely recognized" as promoting the most rapidly riparian
recovery practicable. WHAT GRAZING SYSTEMS DOES BLM BELIEVE ARE
WIDELY RECOGNI2ED AS PROMOTING THE MOST RAPIDLY RIPARIAN RECOVERV
PRACTICABLE? Although BLM found rest rotation and deferred
grazing systems acceptable and successful in the past, apparently
10
BLM data fMap S-2) indicates that almost all of the Resource
Area has little or no erosion. With so little erosion currently
occurring, very little change in erosion is expected with any of
the alternatives.
Ch. 4, page 7 and 8
Current Oregon Forest Practices Act provides adequate
protection to other multiple resources in the Resource Area. Due
to the poor economic conditions in Harney County, timber harvest
should be set at a level that allows maximum sustained yield of
timber under current laws.
C-'lT ,
pages 8 to 12
The high populations of big game in the Resource Area
indicate that the restriction in the livestock grazing season
proposed for Alternative A is unnecessary. In fact, reduced
livestock grazing may very well adversly affect big game habitat
and populations.
The impacts to livestock grazing for Alternatives A, B and c
have been grossly underestimated. As discussed above, removing
livestock from areas with streams with poor surface water quality
will disrupt current grazing systems dramatically. BLM estimates
that 28,937 AUM's of livestock forage will be lost for five or
more years. Does this figure take into consideration the impact
on existing (or proposed) grazing systems? Unless temporary feed
is available, the "balance" of livestock operations will be
dramatically and adversely affected. If one pasture within a
three pasture rest rotation grazing system is excluded from
livestock grazing, where will cattle graze while one of the two
remaining pastures is being rested? Unless BLM provides
temporary forage, the only alternative is to graze the cattle on
the permittee's private land base. This will reduce the total
number of livestock (from previous levels) that the operation can
run on a yearlong basis. An adverse alteration in the livestock
balance of a ranch will also reduce the amount of forage
harvested in the rest of the allotment (in addition to the amount
lost in the excluded pasture) .
In Alternatives B and C, the forage loss and the adverse
impacts on livestock balance will have long lasting effects upon
livestock numbers in the Resource Area. After the five year
exclusion of livestock, it will take several years to increase
herd size and increase the amount of forage harvested. The
economic damage resulting from livestock exclusion will last
substantially longer than five years.
during the development of this Draft RMP/EIS BLM has determined
that these systems are not adequate. The only grazing system
that we are aware of that is "widely recognized as promoting the
most rapid riparian recovery practicable" is an early grazing
treatment. This grazing treatment allows riparian vegetation
regrowth after livestock removal (generally it is recommended
that livestock are removed during May or June). However for the
livestock to have forage available during the summer and fall
months, only a portion of the allotment can be grazed early.
Also, the early grazing treatment may not be compatible with
existing grazing systems. Therefore if the Draft RMP/EIS is
implemented, a large percentage (if not all) of every allotment
will be subject to the arbitrary and unacceptable 30% upland
utilization limit.
If BLM's contention that 86% of the streams in the Resource
Area have poor surface water qual ity , one would expect to find
adverse effects on the beneficial uses of the water. Has hay and
crop production in Harney County declined because of poor water
quality? Have wildlife populations declined? Has domestic water
quality declined? Has animal performance and health declined in
the Resource Area? Have recreational activities deel ined
(including fishing, rafting and water fowl hunting) as a result
of poor surface water quality? Is BLM aware of any streams in
Oregon that consistently have good or excellent surface water
quality?
How does BLM propose to continue to provide livestock water
from reservoirs after excluding livestock? Fences for water gaps
are very difficult to maintain in reservoirs. Pumps and piping
are expensive to purchase, install and maintain. If permittees
are required to purchase and maintain these improvements, it will
be a significant additional economic burden.
If Alternative D is "no change from current management," how
can the predicted improvement be based on "the implementation of
grazing systems and/or projects not yet approved and/or funded?"
Currently (no change) only 12% of the allotments in the resource
area require grazing systems (Chapter 3-15,16) . Alternatives A,
B, c and E will require extensive changes in grazing systems
and/or fencing. Because of extensive economic loss that will
result from alternatives A, B and C, there is a good chance of
BLM becoming involved in litigation if any of these alternatives
are implemented. Therefore, Alternatives a, B, C and E will
require more additional funding than Alternative d.
Inconsistently, only Alternative D included the reservation that
predicted surface water quality improvement is based on grazing
systems and projects not yet approved and/or funded. Apparently,
BLM is trying to mislead the public to believe that current
management will not result in continued resource improvement and
to wrongly justify the proposed chanqes in management contained
in preferred Alternative C.
BLM proposes that off site forage would be used to replace
the temporary reductions due to livestock exclusion. Using off
site forage, if available, would increase the operational costs
of livestock operations. Some of the expected extra costs
include trucking, vehicle maintenance and labor. Using off site
forage would disrupt the current (on site) permittees livestock
practices. Some controversy may result from BLM's proposed
disruption of established grazing territories and animal
husbandry practices. With the proposed 30% upland utilization
limit, there will be very little if any "off site" forage
available to be used on a temporary basis (see discussion below) .
Most of the proposed additional forage available from range
improvements will not be available for several years after
funding (if available) and implementation of the projects.
Very little BLM funding has been available for range
improvements in the West during the last five or more years- For
example, many range improvements proposed in the Hi ley EIS have
not been implemented (Chapter 4. page 11) . The proposed
additional forage from range improvements should not be included
in calculating the impacts on livestock grazing unless funding is
guaranteed.
The statement that "(livestock) reductions necessary to
bring utilizations levels to 30 percent cannot be calculated at
this time" is misleading. Apparently, BLM is attempting to
minimize resistance by livestock permittees and the public to
their preferred alternative. BLM estimated the grazing
reductions including utilization restrictions for Alternative B.
Alternative B is similar to Alternative C. However, the
livestock grazing reductions resulting from Alternative B may be
greater than blm's estimate.
If Alternatives A, B or C are implemented the utilization
limits and livestock exclusions will be the limiting factors for
livestock grazing. Grazing systems that are widely recognized as
promoting the most rapid recovery possible will probably only
have a limited effect on most allotments . Unless riparian areas
are fenced separately, the 50% herbaceous riparian and 10% woody
riparian utilization limits will allow only limited use of
pastures with riparian areas. Therefore, almost all of the
usable forage in the resource area will be subject to the 30%
upland utilization limit (only very limited use will be allowed
in pastures with riparian areas) .
Current utilization limits (from the Drewsey Grazing EIS) in
the Drewsey unit are 50% for continuous grazing systems and 7 0%
(80% for crested wheatgrass) for rotation and deferred grazing
systems. The proposed changes in utilization standards will have
a dramatic adverse effect on BLM calculated desired stacking
levels.
11
Appendix 11-11
Currently, BLM's desired stocking levels are based on a
formula described in Exhibit 1 attached herein. The formula uses
observed utilization data, desired proper use factor or
utilization limits and actual livestock use- Although we do not
currently have the information necessary to complete these
calculations on a Resource Area basis, we can use the information
presented in the EIS and make some assumptions.
The first reduction will result from the exclusion of
livestock from streams. BLM estimates that the capacity will be
reduced by 28,937 AUM's (19% cut). Additionally, the remaining
area will be subject to the 30% upland utilization limit. To
achieve this limit, BLM will adjust stocking levels based on
their existing utilization data. If we assume that BLM overall
utilization data is between the 50% and 70% utilization limits we
can estimate the range of impacts of the 30% utilization limit.
Assuming BLM utilization data equals 50%, desired stocking
levels will be reduced to 72,921 AUM's to meet the 30%
utilization limit. Additional allocations to wildlife will
further reduce authorized livestock use to 70,399 AUM's, a 53%
cut from active preference. After 6 or more years and after
livestock grazing is allowed in exclusion areas, livestock
grazing may be increased to 07,761 AUM's, a 42% cut from current
active preference. If all range improvements are implemented
stocking levels could be increased to 9 6, 667 AUM's , a 3 6% cut
from current active preference. If BLM utilization data equals
70%, corresponding cuts initially, after livestock are allowed in
excluded areas and after range improvements are 67%, 59% and 53%.
Refer to Exhibit 1 for formulas, calculations and explanations.
In the Riddle Mountain allotment, Western Range Service
using BLM data methodology (BLM Technical Reference TR 1400-7)
and utilization proper use factors (Drewsey Grazing EIS)
estimated that a 20% to 25% increase in active preference is
indicated. Using the 30% limit in the Draft RMP/EIS, a 50% to
55% decrease in active preference is indicated (Note: this does
not include the proposed allocation to wildlife or water quality
livestock exclusion). If the allocation to wildlife is included,
the decrease in active preference will be 60% to 55%. If
livestock exclusion for water quality is included, the reduction
in livestock grazing will be approximately 70% to 75%.
BI.M must describe and illustrate the calculations and
methodology used to estimate the impacts of the various
alternatives on livestock grazing. There are only minor
differences between Alternatives B and C and yet BLM predictions
on livestock grazing adjustments vary dramatically. Only
Alternative D reflects the problems of limited funding for range
improvements. Our only conclusion is that BLM is trying to be
deceptive and misleading. Why else would BLM ignore the obvious
adverse effects of their proposed actions on livestock grazing?
14
does not plan to control population levels. If BLM does not
__-„ ■ control wild horse population levels, there will be critical
I environmental concerns.
Ch. 4. pages 20
7 2
In Appendix 3. Table 6. BLM has reallocated forage to
wildlife and given priority to wildlife over livestock. For the
Riddle Mountain allotment, the Drewsey Grazing EIS wildlife
allocation is over 32 times larger than the current allocation.
Livestock grazing is facing a 50% to 75% reduction in forage and
wildlife forage is being increase by over 3173%.
We do not believe that one multiple use should have priority
over another multiple use. The recent increases in wildlife have
occurred after the passage of the Taylor Grazing Act. Federal
Judge Roger Foley stated in the recent decision of Fallini et al .
vs. Hodel CV-S-36-645 that:
"... Congress by various enactments has declared
additional purposes for which Taylor Grazing Act land
will be managed by the BLM, there is no indication that
Congress has repealed the Act's primary purpose to
manage grazing lands so as to stabilize and preserve
the livestock industry.
This court has rejected the contention thac cattle
have an status inferior to wild horses in public lands
as a result of congressional enactments after the
Taylor Grazing Act of 1934."
The preferred alternative (and Alternatives B and C) in this
Draft RMP/EIS substantially reduces livestock grazing in favor of
other multiple uses (primarily big game and fisheries) .
The reallocation of 349 AUM's livestock forage to wildlife
in Riddle Mountain allotment will reduce the value of our base
property by approximately $17 , 450 (assume $50 per AUM value) .
Please consider this economic loss in the requested "Takings
Implication Assessment."
Allocations for wildlife should occur after range
improvements have been completed and additional forage is
available. The increase in recent big game populations indicate
that the current allocation to big game is sufficient.
Why didn't BLM consider maintaining or reducing current big
game populations as an alternative during the planning process?
Cattle grazing improves the quality of big game forage on
fall and winter range (Anderson and Scherzinger 1975) . Cattle
grazing also stimulates browse growth by giving a competitive
Utilization standards are not given for Alternatives D and
E. The proposed utilization standards for these alternatives
should be given.
The reductions in livestock grazing resulting from BLM
proposed alternatives will force many livestock operators out of
business. This is contrary to the criteria for the composition
of the preferred alternative (Chapter 2 pace 3) .
BLM's proposed preferred alternative will reduce the value
of the Riddle Ranch base property associated with its BLM grazing
permit for the Riddle Mountain. Assuming a value of $50 per AUM,
a 50% to 75% reduction in active preference will result in a loss
of $77,125 to $115,690. BLM's preferred alternative will cause
unreasonable and unacceptable economic damage to our livestock
operation and livelihood.
Alternatives A, B and C will result in a substantial loss of
our base property value. The proposed BLM actions may result in
reducing the size of our operation so that it is no longer an
economical unit. Therefore, we request that if Alternatives A, B
or C are considered that prior to issuing the Final Three Rivers
Resource Management Plan Environmental Impact Statement, a
"Takings Implication Assessment" be completed as authorized by
Executive Order 12630 (see the November 8, 1988 Memorandum to all
Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel) .
BLM's proposed Alternatives A, B or C will result in
decreases varying from 4 5,14 2 AUM's (3 0% cut) to 105, 330 AUM'S
(70% cut) in active preference for the Resource Area. Assuming a
value $50 per AUM value, the base property associated with
livestock grazing preferences will decrease in value by
$2,257,100 to $5,266,500. This is a substantial loss to the tax
base of Harney County. The tax rates may have to be increased to
continue to provide county services.
Ch. 4. pages 13 - 18
For Alternatives B and C, why should the upland utilization
limits for Horse Management Areas be greater than areas exclusive
of wild horscE [Table 2.1-12,13)?
Wild horses should not have higher priority for forage than
other multiple uses. Livestock grazing preferences were legally
established long before the passage of the Wild Horse and Burro
Act (Table 2.1-12,13) .
Wild horse populations are above appropriate levels
throughout much of West. Wild horse populations are not in any
environmental danger. wild horse management areas should not be
considered as Areas of Critical Environmental Concern unless BLM
15
advantage of browse seedlings over grass. Without grazing,
grasses will out compete browse seedlings and prevent
establishment of shrubs.
Ch. 4, pages 22 and 23
Although the number of raptor prey species may decline after
seedings are established, is there any evidence that the biomass
or density of prey will decline. we hypothesize that the total
amount of available prey and hunting success will improve in the
seedings which are more productive.
Ch, 4. pages 24 to 28
Why are the surface water quality ratings so much lower than
the aquatic habitat condition ratings? In the Glossary, water
quality is defined as the chemical, physical and biological
characteristics of water with respect to its suitability for a
particular use. We assume that the designed use for surface
water quality ratings is for fisheries. Our reasoning is the
references to water temperature and siltation. In Deep Creek,
aquatic habitat is good and surface water quality is poor. We
would expect that if the aquatic habitat (water, stream bed and
banks) is good that the surface water quality for fisheries
should be good.
For additional comments to aquatic and riparian condition
see our comments concerning surface water quality above.
Ch. 4. pages 28 and 29
Playa management objectives referenced in Appendix 3, Table
6 should not be mentioned until they are identified. Since BLM
has not defined their specific concerns, objectives and
management actions and has not allowed the public to comment,
playas should not be addressed in the Draft RMP/EIS.
Ch. 4, pages 3 0 to 3 4
After July 31, most forbs will be dormant, and effects of
grazing on dormant forbs will be minimal . Eliminating grazing
after July 31 should have no effect on the abundance of forbs.
Prohibiting a conversion of cattle to sheep in bighorn sheep
habitat will not benefit sheep habitat because sheep will not bo
allowed to graze near bighorns (We suggest rewording this
particular sentence on Chapter A , page 30. ) Is there any evidence
that providing additional water will be detrimental to bighorn
sheep or their habitat? Bighorn sheep generally do not graze
further than 3 00 yards from escape cover (cliffs) . This means
that most bighorn sheep habitat is in steep, rugged terrain where
cattle generally graze very little.
17
Appendix 11-12
The BLM proposed livestock area exclusions around reservoirs
provide undisturbed nesting areas for the long-billed curlew. Is
there any evidence that nesting success for the long-billed
curlew is lower in a moderately grazed area than a ungrazed area?
If redband trout and Malheur mottled sculpin habitat are
expected to be impacted positively under current management
(Alternative D) , why propose to remove livestock from streams and
reservoirs and dramatically alter utilization limits?
Ch. 4, paces 35 to 41
Closing roads will adversely affect livestock operators
ability to actively improve livestock distribution. Closing
roads will increase the difficulty and cost for placing salt
throughout the allotment to improve distribution. in some cases,
road closures will make
repair
ion.
range improvements
very
difficult and expensive.
Ch. 4, pages 4b and 16
We are not convinced that removing livestock will improve
visual resources unless, of course, BLM considers cattle and
sheep unattractive. Please explain how reducing livestock
grazing will improve visual resources.
Ch. 4 , pages 4 6 and 4 7
Cultural clearance
of range improvements .
on cultural resources.
are required prior to the construction
Range improvements should have no effect
?"U.
pages G8
6 9
As stated above, BLM has failed to account for the impacts
of the proposal utilization standards in their analysis of
Alternative C. These utilization standards will have very
adverse effects on livestock grazing. By ignoring the impacts of
the 30% upland utilization limit and proposing range improvements
which probably will not be funded, BLM has not considered the
adverse impacts of their preferred alternative on livestock
grazing.
Recently, very little money has been available for range
improvements. For Alternative D, BLM estimates proposed range
improvements will cost §2,287,906. However, BLM implies in
Chapter. 4, page 6 that funding is questionable for Alternative D.
Many of the range improvements in the Riley EIS (Alternative D)
have not been funded. The cost estimate for Alternative C range
improvements is even higher than for Alternative D. BLM should
consider the impacts to livestock grazing with and without range
IS
Playa habitat should not be addressed in this Draft RMP/EIS
until specific management objectives and alternatives are
described and the public is allowed to comment.
From Map RM-l and Map SS-1 there does not appear to be any
Special Status species in the Riddle Mountain allotment.
Many of the publicly owned riparian areas in allotment have
already been fenced and excluded (or will be excluded) from
livestock. Livestock should not be excluded from any pastures in
the Riddle Mountain allotment because of riparian or surface
water quality ratings.
Vegetation conversions will have more positive impacts on
big game than negative effects. Until snow depth becomes
limiting, deer and elk utilize grasses and browse during the fall
and winter. For example, deer utilize crested wheatgrass during
winter months (Austin et al. 1983) . Livestock grazing improves
forage quality for fall and winter range (Anderson and
Scherzinger 1975). The 10% of current browse in deer winter
range limit and 400 acre size limit on vegetation conversions are
too restrictive and may reduce big game productivity.
APPENDIX 12
Append ix \2 . page 2
Alternatives A, B and C will result in a substantial loss of
agriculture productivity in Harney County and other ocunties in
the Three Rivers Resource Area.
RECOMMENDATIONS
For the reasons described above, we believe that
Alternatives A, B and C should not be implemented. Current
utilization standards and grazing systems should be continued
until sufficient and appropriate data is collected and analyzed.
A determination can then be made whether range condition and soil
stability are declining under current management. All BLM data
and analyses in Draft RMP/EIS and Rangeland Program Summary
updates indicate that current management and stocking rates have
been successful and v/ill continue to be successful.
studies to
range
BLM should begin quadrat frequency (trend)
determine the long-term changes in vegetation anc
condition. These studies are recommended and described ir
Technical Reference TR 4400-4 and the Nevada Rangeland Monitoring
Handbook (1984). If frequency studies indicate that the trend in
range condition is declining, current utilization standards,
stocking levels and/or grazing management should be adjusted.
Conversely, if trend improves, utilization standards and stocking
levels should also be adjusted. Until such a monitoring system
20
improvements. If range improvements are not funded, livestock
will be cut drastically in Alternatives A, B and C. No increase
in livestock grazing will be possible i n Alternative E without
range improvements .
BLM expects that some ranchers will expand their operations
and/or base property production after livestock reductions. It
is very unlikely that lenders will approve additional loans when
the value of the base property will be reduced by approximately
S50 for each AUM that is placed in suspension or eliminated from
total preference .
The most likely effect of BLM's proposed alternatives A, B
and C is that many ranchers and long term residents of Harney
County will be forced out of business.
BLM should consider the impacts of livestock reductions on
the tax base of Harney County (see discussion above).
is implemented and data analyzed, current grazing systems,
stocking levels and utilization standards should be continued.
BLM contends in its discussion of surface water quality that
current livestock grazing is lowering vegetative cover and
resulting in soil erosion and subsequent siltation of streams.
If this continues to be a BLM concern, specific studies should be
conducted to monitor vegetative caver and soil erosion. Current
BLM data indicates that soil erosion is minimal (Map S-2) .
These types of monitoring studies were recommended in the
Drewsey Grazing EIS.
Range improvements should be developed as funding becomes
available. Range improvement recommendations proposed in
Alternatives c, D and E will be beneficial to livestock grazing,
wildlife and local economic conditions. Brush control and
prescribed burning will be very cost effective.
Appendix i, pages 52 and 5 i
We will reiterate our
allotment.
KIDI'IJi RANCH
WESTERN RANGE SERVICE
related to Riddle Mountain
The surface water quality ratings appear unreasonably
restrictive. Surface water quality ratings do not appear to
correspond to riparian and aquatic habitat condition ratings. We
would expect that these ratings would be correlated.
The calculated carrying capacity for Riddle Allotment does
not appear to consider BLM's various proper utilization factors,
livestock exclusion or disruption in the grazing systems. Our
calculations indicated a 20% to 25% increase in active preference
under the Drewsey Grazing EIS utilization standards and a 50% to
55% decrease using the Draft RMP/EIS standards, without
considering livestock exclusion or proposed wildlife forage
calculations. Please provide a detailed explanation of the
methodology used for determining estimated capacity and the
methodology that will be used in future allotment evaluations
under each alternative.
With the large increases in big game observed i n the Riddle
Mountain allotment, we must conclude that big game habitat is
currently in very satisfactory condition. BLM's big game habitat
condition ratings do not reflect the obvious health and vigor of
big game animals indicated by their increasing population levels.
We strongly disagree that wildlife should be given priority
over livestock for forage (see discussion above) .
Allan Otley j-4- Al Steninger
J$f^u^i-o^,o vJJ%&<.
Appendix 11-13
LITERATURE CITED
Anderson, E. William and Richard J. Scher2inger. 1975. Improving
quality of winter forage for elk by cattle grazing. Journal
of Range Management 28:120.
Austin, Dennis D. , P.J. Urness and L.C Fierro. 1983. Spring
livestock grazing affects crested wheatgrass regrowth and
winter use by mule deer. Journal of Range Management 36:589.
Clary, Warren P. and Bert F. Webster. 1989. Managing grazing of
riparian areas in the intermountain region. u.s.D.A. General
Tech. Report INT-263.
Cook, C. Wayne. 1965. Development and use of foothill ranges in
Utah. Utah Agricultural Experiment Station, Utah State
University Bulletin 461.
Cook, C. Wayne. 1977. Effects of season and intensity of use and
desert vegetation. Utah Agricultural Experiment Station,
Utah State University Bulletin 483.
Eckert, Richard E. Jr. and John S. Spencer. 1986. Vegetation
response on allotments grazed under rest-rotation
management. Journal of Range Management 39:166.
Eckert, Richard E. Jr. and John S. Spencer. 1987. Growth and
reproduction of grasses heavily grazed under rest-rotation
management. Journal of Range Management 40:156.
Frischkneck, Neil C. and Lorin E. Harris. 1968. Grazing
intensities and systems on crested wheatgrass in Central
Utah: Response of vegetation and cattle. U.S.D.A. Tech.
Bulletin No. 1388.
Heidrick, Donald W. 1958. Proper utilization - A problem in
evaluating the physiological response of plants to grazing
use: A review. Journal of Range Management 11:34.
Hormay, A.L. and M. W. Talbot. 1961. Rest-rotation grazing; A new
management system for perennial bunchgrass ranges. U.S.D.A. ,
Forest Service Production Research Report No. 51.
Laycock, William A. 19S7. How heavy grazing and protection affect
sagebrush-grass ranges. Journal of Range Management 20:206.
McCarty, Edward C. and Raymond Price. 1942. Growth and
carbohydrate content of important mountain forage plants in
Central Utah as affected by clipping and grazing. U.S.D.A.
Tech. Bulletin No. 818.
EXHIBIT 1
The proposed stocking level for Alternative C during the
first five years given in Chapter 4. page 11, Table 4.6 is
133,208 AUM's. In Tabic 2.1-11, initial stocking levels are
proposed to be 139,851 AUM's. However, if the Draft RMP/EIS
(Alternative C) is implemented, livestock stocking levels may be
reduced to 50,000 AUM's or less, a 65% or greater cut. This
reduction will be based on additional allocations to wildlife,
excluding cattle from streams, and the 30% upland utilization
limits. Other restrictions on livestock concerning wild horses,
reservoirs and areas of critical environmental concern may result
in additional cuts.
The first step in the initial reduction will be the
exclusion of livestock from streams. BLM estimates that 28,937
AUM's will be lost by excluding livestock from streams.
Therefore, authorized grazing will be reduced from the current
active preference of 150,472 AUM's by 19% to 121,535 AUM's
(150,472 - 28,937) .
The remaining 121,535 AUM's will then be adjusted based on
the proposed utilization standards. To simplify the calculations
wo will only use the 30% upland utilization limit. Most of the
remaining areas (not excluded) are uplands. Since cattle water
and generally prefer to graze in riparian areas, the 50%
herbaceous and 10% woody riparian utilization limits may result
in even larger cuts than the 30% upland utilization limit.
Livestock use will probably exceed BLM's riparian utilization
limits before the 30% utilization limit is reached. Therefore,
these estimated livestock adjustments are conservative.
To adjust stocking rate based on utilization data, BLM uses
the following formula to adjust stocking rate (BLM Technical
Reference TR 4400-7).
ACTUAL USE
OBSERVED UTILIZATION
DESIRED STOCKING LKVK1,
DESIRED UTILIZATION
This formula can be rearranged to the following form.
ACTUAL USE X (DESIRED UTILIZATION/OBSERVED UTILIZATION) = DESIRED
STOCKING
LEVEL
BLM has collected utilization data and often three or more
years of data for many if not all of the allotments in the Three
Rivers Resource Area. Unfortunately, BLM utilization data for
the entire Resource Area were not available during preparation of
this document. Therefore, the overall average of BIM's
utilization data for the entire Resource Area must be estimated.
24
Nevada Range Studies Task Group. 1984. Nevada Rangeland
Monitoring Handbook. University of Nevada-Reno, Reno,
Nevada .
Pickford, G. D. and Elbert H. Reid. 1948. Forage utilization on
summer cattle ranges in Eastern Oregon. U.S.D.A. Circular
No. 796.
Torell, L. Allen and E. Bruce Godfrey. 1983. The optimum
retreatment schedule for established crested wheatgrass
strands, p. 218-285. In: Johnson, K.L. (ed.). 1986. Crested
wheatgrass: Its values, problems and myths; symposium
proceedings. Utah State Univ., Logan.
Assuming that the overall observed utilization level in the
Resource Area falls between the utilization limits in the Drewsey
Grazing EIS of 50% and 70%, the utilization based adjustments in
stocking levels can be estimated. Using the above formula and
BLM supplied information below, the adjustments in the Resource
Area stocking rate using an assumed overall observed utilization
level of 50% and 70% were calculated.
Current active preference: 150,472 AUM's.
After livestock exclusion {BLM estimate): 121,535 AUM's
Additional allocation of livestock forage to wildlife 2522 AUM's
Overall utilization = 50%
Initially
121,535 X (30%/5O%) = 72,921
72,921 - 2,522 m 70,399
Overall uti ligation
70%
Initially
121,535 X (30%/70%) = 52,086
52,086 - 2,522 = 49,564
70, 399 AUM's (53% cut)
49,564 AUM's (67% cut}
After excluding livestock from streams, 121,535 AUM's will
be adjusted based upon BLM utilization data and the 30%
utilization limit. After excluding livestock from streams, the
actual use value used in the formula will be 121,535 AUM's. If
livestock were not excluded from streams, the active preference
of 150, 472 AUM's or preferably the average licensed use over the
past few years would be used for the actual use value in the
formula. The desired stocking level from the formula is 72,921
AUM's and 52,086 AUM's for the assumed 50% and 70% overall
utilization values, respectively. BLM proposes to reallocate
2,522 AUM's of livestock forage to wildlife. Authorized
livestock grazing will be reduced so that the total of livestock
grazing and wildlife will not exceed the desired stocking level
(from the formula). Therefore, BLM has the potential of
initially reducing livestock stocking levels to 70,399 AUM's (53%
cut) to 49,564 AUM's (67% cut) or perhaps even lower stocking
rates (greater cut) .
After 6 or more years
w ithout range imp rov erne n t s
excluded area
70,399 + [23,937 X (30%/5O%)]
= 87,761 AUM's (42% cut)
After 6 or more years
w i thout range improvements
excluded area
49,564 + [28,937 X (3Q%/70%)]
61,966 AUM's (59% cut)
Appendix 11-14
After five or more years of livestock exclusion from streams
and allowing at least a year for herd size to rebuild and
increase, BLM will allow stocking levels to increase. However,
the 28,937 AUM's from the excluded area will be subject to the
utilization based adjustment. Previous stocking rates in the
excluded area will be reduced. After livestock are returned to
the excluded areas and if proposed range improvements were not
funded, BLM authorized stocking levels would be roughly 87,761
AUM's (42% cut) and 61,966 AUM's (59% cut) assuming the 50% and
7 0% overall utilization values, respectively.
After 6 or more years
with range improvements
87,761 + 8,916 «
96,677 AUM's (36% cut)
After 6 or more years
with range improvements
61,966 + 8,916 =
70882 AUM's (53% cut)
BLM estimates that after range improvements (land
treatments, etc.) proposed in Alternative C are implemented an
additional 8,916 AUM's wil] be available. These improvements
will require several years to plan, fund, implement and
establish. After six or more years, the estimated authorized
livestock stocking level is 99,677 and 70,882 assuming an overall
utilization level of 50% and 70%, respectively, and assuming that
the improvements were funded and successful .
Temperature, sediment and turbidity can be reduced, or at least not
increased, by as little as 0.25-mile of good condition streamside
riparian. Effects of these improvements on the entire stream are
dependent upon many factors including, but not limited to, size and
length of good condition portions, position of the good condition
areas along the entire stream and water quality as it eaters the good
condition areas. Many other Federal, State and private entities are
currently working to restore their riparian habitats to better
conditions. These efforts, in combination, will result in positive
impacts.
Priorities may be set through the land use planning process. Big game
population levels are set by management unit by the Oregon Fish and
Wildlife Commission. These levels are determined through a public
involvement process. Currently, these levels are below the biological
carrying capacity of resource base. Appropriate management levels of
wild horses and burros were set through previous planning processes.
The RMP is not proposing any changes in these herd levels. Section
102(a)? and Section 202(c)! of FLPMA require that management be on
the basis of multiple-use and sustained yield. Wild horse and burro
numbers and livestock numbers will be adjusted in accordance with the
results of monitoring studies and allotment evaluations. Adjustments
in livestock use will be made as provided for in 43 CFR 4110.3 -
4110.3-3. Wild horse and burro levels will not be lower than the
established minimum numbers in order to maintain viability.
The 30 percent utilization level will be eliminated. Upland
utilization targets are being determined through the allotment
evaluation process on an allotment by allotment basis. The general
guidelines for utilization levels arc 50-60 percent on native range
and 60-80 percent on crested wheatgrass. These are guidelines only.
Site-specific utilization targets are based on the objectives,
grazing treatments and season of use of the allotments. After
allotment management is analyzed, target utilization levels can be
modified if management objectives are not being met.
Decause site-specific evaluations of allotments have not been
completed, impacts of these utilization levels cannot be analyzed.
However, regardless of the utilization level, carrying capacity
cannot be exceeded. Any reductions will be based on the results of
the monitoring data and allotment evaluation.
As noted in response 2-1, a planning issue is generally a matter of
controversy or dispute over resource management activities or land
uses. Public response during ongoing scoping and other public
involvement processes have clearly established that substantial
controversy and dispute exists over livestock grazing on public
lands. The purpose and need for the RMP is presented in the
DRMP/DEIS, see p. 1-3.
Planning issues and management objectives are not synonymous.
Planning issues are generally a matter of controversy or dispute over
resource management activities or land uses and are used to focus
inventory, interdisciplinary interaction, analysis and documentation
efforts. Management objectives, however, are required (BLM Manual
1620-1625) on a resource by resource basis regardless of whether the
resource is involved in a planning issue or not. The alternatives
presented in the DRMP/DEIS vary significantly as to which objectives
are stressed and the degree and extent to which individual objectives
would be met.
Alternative D is the "No Action Alternative." In accordance with the
Bureau Manual (H1790-1, Chapter V, Alternatives to be Considered),
the No Action Alternative reflects continuation of current management
practices. This is explained on p. 2-2 of the DRMP/DEIS. A full
description of the planning criteria was distributed to the public In
a flyer dated February 17, 1989. The mailing list indicates that a
flyer was sent to Riddle Ranch.
Water quality and aquatic habitat condition and rating are
intrinsically related to condition of the riparian ecosystem. Water
quality parameters are the physical and chemical constituents of
aquatic systems. Standards for water quality determinations were
developed by Federal action under the Clean Water Act (see 40 CFR
131.10). Surface water quality parameters were measured by
experienced biologists at predetermined monitoring stations on select
streams. If the habitat supported fish fauna, It was evaluated as
aquatic habitat. Criteria used in evaluation of aquatic habitats and
derivation of condition factors were summed in DRMP/DEIS, Volume II -
Appendix 6, Table 2, Criteria for Evaluating Aquatic Habitat.
References pertaining to methods of evaluation of aquatic habitats
were provided with this table (see Bowers, et al.t 1979 and Binns
1982).
Riparian habitats were monitored and evaluated with photo trend
plots, 200 pace toe-point transects, color Infrared photography and
use-utilization studies (see the PRMP/FEIS, Appendix 1, Table 4).
See Proposed Plan management actions WL 6.1, 6.2 and 6.3 for proposed
utilization and grazing systems in riparian areas. Many of the
references used to help formulate the utilization levels are found in
the U.S. Department of the Interior, Bureau of Land Management,
Technical Reference 1737-1 and Technical Reference 1737-4. These
references are named: Riparian Area Management; A Selected, Annotated
Bibliography of Riparian Area Management and Riparian Area
Management; Grazing Management In Riparian Areas. Copies are
available from: Bureau of Laud Management; Service Center; SC-658B;
P.O. Box 25047; Denver, Colorado 80225-0047. Additionally, poor water
quality does not preclude habitation by fish. Streams with poor water
quality experience shifts in species composition, diversity and
abundance to species more tolerant of poor water quality.
The Three Rivers RMP addresses both the old Drewsey planning area and
the old Riley planning area. While significant progress has been made
in some programs through the previous planning (since its approval,
over $1 million have been invested In the Drewsey area - such
Investments have not been made in the Riley area), significant
management problems or concerns remain unresolved. Among these are
forage allocations for elk, special management areas, water quality,
fire management, etc. Where efforts to resolve these concerns would
affect livestock operations, grazing use would be adjusted only on
the basis of approved monitoring and evaluation procedures with the
opportunity for full participation by affected interests.
The Oregon Fish and Wildlife Commission is responsible for setting
big game population levels in Oregon.
These levels, by management unit, were arrived at through a public
involvement process. These numbers were set, in most cases, below the
biological carrying capacity. Some factors used to set these numbers
were private property damage (crops), other economic considerations,
hunter demand and multiple-use concerns.
Big game numbers by allotment were arrived at using these management
levels and current ODFW census results by season of use. The number
was then multiplied by the percent of an allotment administered by
BLM. This adjusted number was then divided by 5.3 for deer, 7 for
antelope and 2.4 for elk. This is the number of each of these animals
(yearlings and adults) that eat 800 pounds of air dry vegetation per
month. This number was then multiplied by the number of months the
animals are present in a particular season. This is the 800 pound AUM
demand for each of these species by allotment. For deer these numbers
were then multiplied by .18 to account for an 18 percent dietary
overlap between deer and cattle. Antelope numbers were multiplied by
.1 for dietary overlap and elk numbers were multiplied by .7 to
account for dietary overlap and differences In use areas.
All use adjustments will be based on allotment-specific evaluations.
Stocking rates and management treatments will be analyzed on the
basis of monitoring done in accordance with Bureau policy and
guidance. The AUM figures cited in the RMP are projections only. The
allotment evaluations include allotment-specific objectives for
resource values such as range condition, riparian and wildlife
habitat and special status species, etc. The Oregon Rangeland
Monitoring Handbook requires allotment management evaluations be done
at Intervals of 5 to 10 years.
The RA is currently conducting an Ecological Site Inventory which is
planned to be completed by 1994.
See Appendix 1, Table 11 Monitoring Methods.
All grazing use adjustments will be made on the basis of approved
monitoring and evaluation procedures with the opportunity for full
participation by affected interests. Future monitoring and evaluation
activities will be adjusted, where appropriate, to conform with
management objectives established through this RMP on an allotment by
allotment basis.
Appendix 11-15
Available soils information was not detailed enough to target
specific erosion problems within the planning area. While an area may
have an overall erosion condition rating of slight or moderate, some
sites within the area may exhibit higher erosion rates, contributing
greater amounts of sediment to the fluvial system. Land management
practices, such as logging or grazing, upstream and outside BLM
jurisdiction, also contribute sediment to these systems.
Upland erosion is not the only source of sediment entering streams.
Unstable strearabanks can be cut laterally or vertically, adding
sediment to the fluvial system. However, proper riparian management
has frequently resulted in positive changes in water quality by
stabilizing streambanks and channels and providing adequate
vegetation for filtering and storing sediment (Elmore and Beschtn
1987, Skovlin 1984).
Changes in current grazing systems should reduce soil erosion and
sediment delivery to streams. The type and quantity of vegetative
cover affects infiltration which in turn influences soil erosion
(Heede 1977). Livestock grazing affects vegetative cover by affecting
vigor, production, composition and litter (Jackson et al., 1985), and
numerous studies indicate that runoff and erosion are related to
grazing intensity (Heede 1977, Gifford and Hawkins 1978, Lusby 1979).
Refer to response 2-25.
The planning issue identified in Chapter 1 was grazing management.
2-34 The special status species table and map have been
2.11 and Map SS-1 of the Proposed Plan.
vised. See Table
Those plants with known populations in Three Rivers RA appear on the
map. The other plant species are those for which habitat exists in
the RA and their presence is suspected within the RA, or
alternatively their presence haB been documented in areas adjacent to
the RA and consequently the plant may also be within the RA.
Wildlife species listed in the special status species table were
provided by the USFWS. The planning area is within previous ranges or
habitat may exist for those species not currently known to exist In
the area. Management actions have been outlined for those species
known to exist or whose recovery is dependant upon reestablishment in
the area.
Many factors determine big game population levels at any given time.
Some of these factors are harvest levels, sex of animals harvested,
climatic conditions and habitat conditions. Rocky Mountain elk and
pronghorn antelope populations have increased in the past 10 years
while mule deer populations have declined.
2-13 Refer to response 2-3.
2-14 It is correct that a reasonable variety of alternatives must be
considered in the DRMP/DEIS and that they must be sufficiently
distinct as to represent a clear choice. Such requirements, however,
do not preclude having management actions which are common to several
or all alternatives (this was noted in the DRMP/DEIS, p. 2-4,
Detailed Description of the Alternatives). This is particularly true,
for example, where legal requirements (as with air quality, see Table
2.1, p.l) do not provide for varying levels of compliance. The
substantial differences between the overall alternatives are
presented in FRMP/FEIS summary.
2-15 For livestock gracing, the alternatives presented are not limited to
either no change or a reduction. Alternative E proposes 14,150 AUMs
over active preference available for livestock grazing.
2-16 It Is correct that no upland utilization standards were identified
for Alternative E.
2-17 The Bureau is required to periodically review grazing preference
under 43 CFR 4110.3, and make changes in grazing preference status
where needed. The Bureau Is also required to reduce active use if the
use exceeds livestock carrying capacity as determined through
monitoring. Increases and decreases In active use will be allocated
in accordance with 43 CFR 4110.3-1 and -2 and Oregon BLM Manual
Supplement 4100. 06G. Refer to Appendix 3, Table 6, DRMP/DEIS.
The Bureau will honor any private water rights; however, no private
water rights are known for riparian areas on public lands. Private
water rights, if any, do not negate BLM's mission to manage the
public lands for multiple-use.
2-18 Refer to response 2-2.
2-19 As noted on p. 2-2, Composition of the Preferred Alternative, the
District Manager and the Area Manager placed special emphasis on an
integrated systems philosophy in composing Alternative C. As they
Interacted with the interdisciplinary planning team and others, these
were the criteria that they employed in making decisions about which
elements to Include in the Preferred Alternative.
2-20 Refer to the Proposed Plan for monitoring actions.
2-21 Not all acres and miles listed in the water quality section currently
support fish and, therefore, were not considered aquatic habitat.
2-22 Refer to response 2-3.
2-23 Refer to response 2-3.
2-24 Water temperature is one of the water quality characteristics which
may affect fish and is listed as such in DEQ's Nanpoint Sources of
Water Pollution Assessments publication. Also, refer to response 2-3.
2-36 The management prescriptions presented in the RMP are objective
oriented rather than rangeland improvement project oriented. As such,
enhanced management can be implemented even where money for livestock
range improvements or other projects is not readily available. This
is clearly noted in Table 2.1 (p. 2.1-12, footnote 1) where it states
that "Implementation of other management actions such as stocking
level adjustments, season of use changes, etc., required under BLM
monitoring and evaluation policy would not be forestalled due to lack
of funding for these rangeland improvements."
Additionally, the portion of the grazing fees collected in the
District that Is returned to the County and the District would be
sufficient funding over the life of the plan to support
implementation of the Preferred Alternative, if invested in the Three
Rivers RA in proportion to the fees collected in the RA. Therefore,
the assumption is considered to be reasonable.
2-37 The 30 percent upland utilization level has been eliminated. See
management actions WL 6.1, 6.2 and 6.3 of the Proposed Plan.
2-38 As shown in Appendix 3, Table 3, DRMP/DEIS many of the grazing
systems which have been set up In the RA are not operational. The
reasons for this Include lack of management facilities, uncooperative
permittees or failure of the system to meet resource objectives.
Refer to response 2-7. Also, see management actions WL 6.1, 6.2 and
6.3 of the Proposed Plan.
2-39 See management actions WL 6.1, 6.2 and 6.3 of the Proposed Plan.
Also, refer to response 2-4.
2^*0 Grazing systems which are currently successful in promoting "speedy"
riparian recovery will not be modified. Where riparian objectives are
not being met, grazing system modification will be accomplished
during allotment evaluation and the activity plan process. Also,
refer to response 2-5.
2-41 Refer to response 2-5.
2-42 Refer to response 2-7.
2-43 Refer to response 1-2 and 2-7.
2-44 In the Three Rivers RA, there were 126.55 miles of perennial streams
of which 82.50 miles, or 65 percent, were in poor condition.
Poor water quality has immediate effects on the beneficial uses of
water resources. Degraded water resources are most often associated
with adverse impacts in related riparian ecosystems. As riparian
cover and associated water quality deteriorate, fish and wildlife
diversity, density, health and performance decline. Degradation of
riparian cover would increase stream bank erosion, instream silt and
sediment loads; and adversely impair fish production, feeding,
respiration and reproduction.
See Appendix 2 and Appendix 6, Table 2, DRMP/DEIS.
Also, the BLM's surface water quality conditions were derived from
field monitoring 103.15 miles of streams, 82 percent of the RA, and
from data published by DEQ in 1988 as a Statewide Assessment of
Nonpoint SourceB of Water Pollution.
For consistency between water quality, aquatic and riparian habitat
condition classes, DEQ classes of severe, moderate and no problem
were converted to BLM classes of poor, fair and good. Streams listed
with DEQ as having no data were assessed with BLM data when
available, or listed in the tables with a question mark (?) if no
data existed.
The excellent, good, fair and poor condition ratings were developed
by Bowers et al., 1979, and Binns 1982 (see Appendix 6, Table 2,
DRMP/DEIS); and have no similarity to range condition ratings.
Condition and trend data for surface water quality and aquatic and
riparian habitat were collected seasonally from select streams and
riparian areas in the RA. Details of riparian inventory methodology
were presented in Appendix 2. Data used to develop tables presented
in the DRMP/DEIS were collected through 1988.
Instream water quality, aquatic and riparian habitat evaluations were
derived differently and would not necessarily coincide (see response
2-3). The BLM does not have any estimates of variance or associated
sampling error.
Though there were no streams with good or better water quality
ratings In the Three Rivers RA, data indicate good conditions in
aquatic habitats with restricted livestock use (see Appendix 6, Table
1, DRMP/DEIS: Aquatic Habitat, i.e., Deep Creek, Stinkingwater Creek
- Upper Mountain Allotment, Smyth Creek). BLM - Best Management
Practices recognize the Importance of protection and restoration of
riparian communities and their direct impact on aquatic habitats and
water quality. With proper livestock/riparian ecosystem management,
surface water quality ratings within the RA are improvable to DEQ
standards.
Refer to response 2-5.
The erosion condition classes depicted in Map S-2 are general in
nature and do not address specific active erosion problems. Paragraph
1 of the Soil Section on p. 3-3 states: "General soils information
has been provided in lieu of specific Information." Furthermore, soil
erosion was not the only criterion used to develop utilization
standards. Refer to the section title Management Conflicts and
Concerns on p. 3-16 for more information.
Appendix 11-16
The Three Rivers interdisciplinary team estimates 70 percent of all
wildlife species in the RA are partially or totally dependent upon
riparian habitats for food, water and cover.
Additionally, recreational uses of water resources decrease as
beneficial uses of water decline. User days decline as waters are
degraded and made unsuitable for human use.
Given the poor condition of surface flowing waters in the RA, the
Preferred Alternative focused on the protection, restoration and
enhancement of aquatic and riparian habitats to the extent possible
under guidelines promulgated by FLPMA. Additionally, one would not
necessarily expect crop production to decline due to poor water
quality. Poor water quality and nutrient enrichment may increase hay
or other crop production.
2-45 Though the Three Rivers RA lacks streams with goo
quality, the Andrews RA has 57 miles of good and
water quality.
or excellent water
miles of excellent
All reservoirs currently fenced have design features or alternate
water sources for livestock watering. This practice will continue in
the future. See page 4-4, DRMP/DE1S.
The reservation cited (p. 4-6, DRMP/DEIS) is incorrect as printed.
This passage should read as follows: "Much of the above improvement
is predicted on the implementation of grazing systems and/or projects
which have been analyzed in previous planning, but have not yet been
funded." The planning team was instructed to analyze Alternative D as
if the previous planning were being fully implemented.
The livestock grazing seasons proposed in Alternative A, DRMP/DEIS,
were recommended to improve browse and forb production and
availability on mule deer and antelope ranges, respectively.
All livestock grazing use adjustments, both upward and downward, will
be made through the monitoring and evaluation process. Such
adjustments shall be made with the opportunity for the full
participation of established affected interests. The object of such
adjustments will be to meet management objectives established for the
allotment(s) In question while being responsive to the needs of
livestock grazing operations as well as other sensitive resource
values ,
Permittees using forage in areas away from their usual allotments
could incur additional costs if the new area was farther away.
Determining what the costs would be is impossible without knowing the
number of livestock and the distance they would have to travels It is
possible that existing systems would be modified which could change a
permittee's usual system. There is controversy surrounding shifting
grazing use between allotments, but the practice is fully supported
by the Oregon Manual Supplement on the Allocation of Additional
Forage Permanently Available for Livestock Grazing Use.
2-64 Refer to response 2-7.
2-65 Utilization levels will not be greater for HMAs. The levels listed in
the alternatives were established to show that use by either
livestock or wild horses would not exceed the sustained yield of any
of the HMAs . The utilization standard for all uplands has been
changed as per response 2-7.
These utilization levels have been removed from the final proposed
action. They were used for analysis purposes only. Actual utilization
standards will not be greater in the HMAs.
2-65 Refer to response 2-6.
2-67 It is correct that wild horse populations are above appropriate
levels throughout much of the West. The Seventh Annual Report to
Congress in 1988 shows the total population of wild horses and burros
to be 43,286 head, while the appropriate management level (AML) is
30,207 head. This report shows horses in Oregon to be 586 head over
the AML. However, inventory numbers of wild horse and burro numbers
In Oregon as of December 8, 1989, are listed at 1,770 head, which is
900 head below the AML. It is also correct to state that wild horses
and burros do not appear to be in any environmental danger. The BLM
has been reasonably successful in Oregon in controlling wild horse
numbers and plans to continue gathering excess numbers as funding
allows .
2-68 The BLM does plan and is mandated by the Wild and Free-Roaming Horse
and Burro Act to control population levels to maintain a thriving,
natural ecological balance with all resources. Wild horse numbers as
well as livestock and wildlife numbers may have to be adjusted in
some cases to maintain this balance. Any area that has been
determined to meet the relevance and importance criteria outlined in
FLPMA and BLM Manual 1613. IB. 3 may be nominated as an ACEC. Based on
staff review, it has been determined the Kiger Mustang ACEC
nomination meets these criteria. These wild horses are unique to this
area and have received national recognition as being historically
significant. It was further determined during review that the entire
area of 66,244 acres originally nominated should be managed as the
Kiger Mustang ACEC.
2-69 Refer to response 2-6.
2-70 Refer to response 2-6.
2-71 Refer to response 2-63.
2-72 Refer to response 2-10.
2-73 Refer to response 2-10.
2-51 Refer to response 2-7.
2-52 The Sums District has no control over future funding levels
appropriated by Congress nor over grazing fee levels.
See Proposed Plan management action GM-1.1 for a listing of allotment
prioritization criteria.
See also response 2-36.
2-53 Refer to response 2-7.
2-54 Refer to response 2-7.
2-55 Refer to response 2-7.
2-56 See Appendix 1, Table 11, PRMP/FEIS for a discussion of the District
monitoring methods and evaluation process.
2-57 Refer to response 2-7.
2-58 Refer to response 2-7.
2-59 Refer to response 2-56.
2-60 Refer to response 2-7.
2-61 The economic analysis presented In the DRMP/DEIS indicates that,
under the Preferred Alternative, potential grazing use adjustments in
the short-term would have a negative impact on some operations.
However, over the long-term, nearly 70 percent of the existing
livestock operations currently in effect would receive less than a 10
percent reduction. This is clearly consistent with Socioeconomic
Systems criterion number 3, "Provide for the continued opportunities
for ranching operations typical of the American western heritage
(emphasis added)."
The economic impacts are overstated. See respon:
2-7.
Takings Implication Assessments are required by E.0. 12630 to assist
Federal agencies in evaluating actions which affect, or may affect,
the use or value of private property. Private property refers to all
property protected by the Just Compensation Clause of the Fifth
Amendment to the Constitution. Grazing licenses and permits do not
create any right, title or Interest in the public lands (43 U.S.C.
315b). The courts have therefore held that grazing licenses and
permits may be revoked without payment of compensation. Osborne v.
United States, 145 F.2d 893 (9th Cir. 1944). In addition, the United
States Is not required to compensate for any element of value based
upon the use of private fee lands in combination with the
Government's permit lands. United States v. Fuller, 409 U.S. 488, 35
L.Ed. 2d 16 (1973). In view of the fact that grazing licenses and
permits as well as associated elements of value in base properties
are not private property protected by the Just Compensation Clause,
it is clear that E.0. 12630 and the requirement for the preparation
of Takings Implication Assessments are inapplicable to planning
activities involving BLM grazing licenses and permits.
2-74 Boula and Sharp (1985) found that the Lone Rabbit crested wheatgrass
seeding near Riley yielded fewer species and lower total biomass than
the two sampled sagebrush types in the same vicinity. Also, as noted
on p. 4-23 of the DRMP/DEIS, hunting may become easier for some
species, due to less small mammal hiding cover. The predicted impact
from the proposed seedings was negligible. Combined with the other
proposed actions of the Preferred Alternative, a low positive impact
to raptors was predicted as shown in Table 4.16, p. 4-23 of the
DRMP/DEIS.
2-75 Refer to response 2-3.
2-76 Refer to response 1-19.
2-77 The word "respectively" should have been added to these sentences.
2-78 The bighorn sheep range outlined on Map SS-1 in both the DRMP/DEIS
and PRMP/FEIS, includes the known travelways used by the sheep. The
tops and steep side slopes of Bartlet and Upton Mountains and the
rough canyons along the Middle Fork of the Malheur River are where
the sheep live except for travel between these areas. Currently, no
known competition for forage, water, cover or space exists on
Bartlett or Upton Mountains or along the Middle Fork. It Is felt that
competition could result from increased livestock water being
developed in these three areas. The Proposed Plan calls for the
long-term enhancement of bighorn sheep habitat in these areas. Future
projects of all types will be evaluated on a case-by-case basis to
ensure the health of the sheep and their habitat are not jeopardized.
Also, competitive forage was not allocated to bighorn sheep because
no competition for forage is suspected or expected.
ent of long-billed
No grazing exclusions arc proposed for in
curlew nesting habitat.
Allen (1981) found that curlews in southeast Washington chose nest
sites which were predominantly cheatgrass/Sandberg's bluegrass fields
which did not present visual barriers.
Most documented long-billed curlew nesting In the planning area takes
place In crested wheatgrass seedings. It is felt that grazing up to
two-thirds of the area in the seedings will provide the vegetative
structure desired by these birds while reducing incidental nest
trampling.
Redband trout and Malheur mottled sculpin habitat would not be
negatively impacted under Alternative D due to habitat improvements
associated with projects already initiated. However, insufficient
progress toward restoration of poor and fair aquatic habitats
Inhabited by these sensitive species would result from selection of
Alternative D.
Appendix 11-17
The road closures in the Proposed Plan would be on a casc-by-case
basis and would be reviewed by an interdisciplinary team and would
have public review through the EA process. No roads needed for
administration or fire protection would be closed.
Reduction of livestock grazing in certain places will improve visual
resources. The amount and degree of grazing is an important
consideration when evaluating the visual impacts incurred as well as
the development necessary to manage livestock grazing.
VRM areas represent the relative value of the visual resources, Class
I and II being the most valued, Class III representing a moderate
value and Class IV being the least value. Often the majority of
Bureau-administered lands are managed as Class IV where the objective
is to provide for management activities which require major
modification of the existing character of the landscape. The level of
change to the characteristic landscape can be high. These management
activities may dominate the view and be the major focus of viewer
attention. However, every attempt should be made to minimize the
impact of these activities through careful location, minimal
disturbance, and repeating the basic elements of form, line, color
and texture which determines how the character of the landscape is
perceived.
Specific places (such as riparian areas, scenic areas, ACECs,
Wilderness Study Areas, Scenic Byways and often-viewed areas along
highways) which may be visually sensitive can have a management
objective to improve or preserve the natural setting. When this is
true, reduced livestock grazing and/or removal of livestock for
periods of time does improve visual resources. Impacts such as
streambank erosion, overgrazed areas, livestock concentration areas
and livestock developments in certain places does impact scenic
quality.
It is true that cultural resource inventories are conducted during
the planning phase prior to the construction of all
surface-disturbing projects, which are commonly redesigned to avoid
Impacts to cultural sites thus found. When projects In the public
Interest cannot be modified to avoid impacts to cultural sites, they
may be impacted upon completion of the comprehensive and, at times,
costly procedures detailed In 36 CFR 800.
Refer to response 2-7.
It is true that full funding has not been available for range
improvements. Without additional range improvements, grazing levels
would be reduced approximately 11 percent. Refer to response 2-52 for
information on funding. Also, refer to response 2-9.
Grazing permits are not the real or personal property of the
permittee, thus are not assessed for tax purposes. Changes In
personal property ownership that would follow Implementation of any
management alternative, Including the No Action Alternative, cannot
be specifically identified. BLM payments in lieu of taxes to Harney
County are not expected to change substantially.
2-87 The RA uses methods approved in Bureau manuals, guidance and policy
for determining condition and carrying capacity. The estimated
capacity listed in DRMP/DEIS, Appendix 3, Table 6, were projections
only. Carrying capacity will be calculated and analyzed in allotment
evaluations.
PRMP/I'EIS, Appendix 1, Table 11, has been included to provide an
explanation of methodology used to determine carrying capacity as
well as an explanation of the allotment evaluation process.
2-88 Fifteen hundred acres of big game range in the Riddle Mountain and
Smyth Creek Allotments were rated as unsatisfactory due to poor
forage conditions related to juniper encroachment and poor
Interspersion of cover and forage areas. The Proposed Plan, when
Implemented, would result in all satisfactory condition in these
allotments.
2-89 Refer to response 2-6.
2-90 Refer to response 1-19.
2-91 The special status species map has been revised. See Map SS-1 of the
Proposed Plan. Also, refer to response 2-34.
2-92 The Proposed Plan calls for maintenance of 85 percent of the current
browse on winter range (see Table 2.1-21). A cursory literature
review did not reveal any evidence that the 400-acre size limit on
vegetative conversions would be detrimental to big game productivity.
2-93 Refer to responses 2-7 and 2-9.
2-94 The Three Rivers RA uses a Nearest Plant trend method as outlined in
the Oregon Rangeland Monitoring Handbook. This method is similar in
concept to the frequency method. Refer to response 2-87.
2-95 Monitoring of sediment, streambank erosion and riparian vegetation
will continue- Also, refer to response 2-30.
2-96 Refer to responses 2-7 and 2-87.
Oregon Field Office
1205 N.W. 25th Avenue
Portland, Oregon 972W
503 228-9561
January 12, 1990
Josh War-burton, District Manager
Bureau of Land Management
HC 74-12533, Highway 20W
Hines, Oregon 57738
Dear Josh,
The Nature Conservancy would like to take this opportunity to
comment on the Three Rivers Resource Management Plan/DEIS. As
you are aware, the Conservancy worked under contract for the BLM
during the inventory phase of the planning process to identify
and evaluate potential Research Natural Areas in the Three Rivers
Resource Area. We were quite pleased with this arrangement and
the results can be seen in the proposed RNAs found in the various
alternatives.
Before we make specific comments about the plan it is important
to note we feel that this is the most comprehensible and
comprehensive RMP that has come out of the BLM in Oregon. The
detailed Table 2.1 incorporates management directives that are
easy to identify, understand and compare between alternatives.
We think this style of RMP will set a precedent for all other
RMPs in this cycle of planning. Congratulations are in order to
Jay Carlson and the staff for a job well done.
RHA./A.CBCS
As noted above we were pleased to see that our RNA/ACEC
recommendations were included in the RMP, however, we have some
particular issues that need to be discussed about several sites.
These sites and related issues are:
1) Foster Flat RNA/ACEC — The original nomination included 1870
acres which encompassed the entire playa called Foster Flat. In
the preferred alternative the recommended RNA was noted at 720
acres. There was no justification provided for such a reduction
in acreage. Furthermore, there is no logical way to design this
RNA other than the original proposal of 1870 acres that includes
I the entire playa. The RNA Committee has worked hard and long
insuring that all RNAs have viable, defensible boundaries that
will both protect the target resource and integrate the
management of the site and the surrounding public lands. Foster
Flat is perhaps the most naturally well-defined RNA imaginable as
it is a distinct desert playa. To include less than the entire
playa is only inviting continued management problems for the RNA
and the surrounding lands. We strongly encourage the District to
establish the RNA along the original 1870 acre boundaries. It
should also be noted that Foster Flat is also a significant sage
grouse site such that protection of the larger site would be very
beneficial to this special status species.
2) Squaw Lake RNA/ACEC--It was indicated in the EIS that Squaw
Lake did not meet the relevance and importance criteria for ACEC
nomination and thus was not included in the range of alternatives
for ACECs. It has been common practice in the BLM to have all
nominated RNA/ACECs that fulfill a natural area cell need, as
defined in the Oregon Natural Heritage Plan, to automatically be
considered as meeting these basic ACEC criteria. The Squaw Lake
site fulfills the Aquatic cell need #12. Mid to high elevation
permanent pond in the Basin & Range Province and also has good
representation of two other natural area cells, #15. Low
sagebrush/Idaho fescue and #17. Low sagebrush/Sandberg' s
bluegrass scabland. Therefore, we feel it is incorrect to say
that Squaw Lake does not meet the ACEC criteria. In addition, in
Table 3.16 {p. 3-48), under Habitat for Species Diversity
category, because there is both aquatic habitat and high quality
uplands that have big game value it seems that the site should
receive at least a Medium ranking. We selected Squaw Lake
after careful consideration of existing RNAs in the steens and
felt it still would be a valuable addition to the RNA system. We
were not ignorant of the fact that current grazing practices
continued to impact the lake or pond but through proper
management we believed that the site could be naturally restored.
We encourage the District to reconsider the site in the final
RMP.
al
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carried forward in the
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val ues as wel 1 .
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need to protect and ma
values present as it
physiographic province
Uplands. The ACEC des
management.
4) Silver Creek RNA Addition— In Table 2.1 (p. 2 . 1-34-35) it is
indicated that designation of the addition will take place after
acquisition of the private lands in section 17. Given the time
it traditionally takes to complete exchanges we would like tc see
the District designate or establish the addition (at least the
public land portion in section 20) in the RMP process and not
wait for the completed transaction. Designation may give needed
1 ACEC — We are happy to see this site
RMP as we feel that the site not only has
lues but also has significant natura.
inventory for RNAs we evaluated a
ngwater Mountains but could not find
teria. However, we felt there was a
nage a portion of this area for the
located at the junction of two
s — the Basin & Range and the Owyhee
ignation should accomplish this with
XJ North Kent Street Arittipan, Vir$mia 22209 703 84 \-5300
Appendix 11-18
3-B
3-9
emphasis to the exchange process as well.
Wild & Scenic Rivers
The analysis of Wild & Scenic Rivers in the RMP seems quite short
sighted with regards to the Middle Fork of the Malheur River,
segment A. This area includes the Malheur-Bluebucket wsa and
private lands upstream from the WSA which has outstanding values
for both scenery, recreation potential, fisheries including
redband trout, and ecological diversity. If one was to include
the downstream river canyon {for approximately 1.5 miles on
private land) as well as Dluebucket Creek and the river segment
noted in the previous sentence, there would be over 7 miles of
river that surely qualifies for Wild and Scenic status. The
adjacent portion of the Middle Fork Malheur River on the Forest
Service lands upstream is designated Wild such that the total
length of designated river would be over 20 miles. This resource
deserves a rating of Eligible when the full extent of the stream
segment is examined. The private lands should be considered as
high priority sites for acquisition at this site as well. The
preferred alternative does correctly propose the Middle Fork of
the Malheur River for designation as a Wild & Scenic river.
Wildlife Habitat
Wildlife habitat is reliant on grazing management on BLM lands.
The preferred alternative's proposal to seed 46,960 acres to
crested wheatgrass will have a negative impact on a wide variety
of wildlife that rely on natural communities. We cannot support
this management action and request that the District utilize
native grasses in all seeding projects.
Grazing management could also be strengthened in the preferred
alternative for special wildlife species needs. Alternative A
and B have more strict requirements for habitat protection for
long-billed curlews nesting habitat and for sage grouse strutting
grounds that should also be implemented for the preferred
alternative. The efforts made to protect and enhance habitat for
redband trout and Malheur sculpin are commendable in the
preferred alternative and will have associated benefits to all
wildlife species that utilize these habitats.
There is also a need to specifically identify snowy plover
habitat, ie playas, for protection of the species. Playas are
highlighted in the Vegetation section of Table 2.1 but snowy
plovers are not mentioned here nor in the Special Status Species
section. Grazing should be restricted from plover habitat during
the nesting season. There are additional threats to playas from
nearby seeding projects. It is detrimental to have seedings near
playas as livestock use will increase in these areas. In no case
should seedings be allowed near playas.
Special status plant species continue to be short changed with
respect to grazing restrictions in the preferred alternative.
3-7
3-8
3-9
The interdisciplinary team determined that the relevant cell needs
for Foster Flat could be met in a geographical area of 720 acres.
However, It is likely that fewer management conflicts will arise with
a larger area designated. It will be necessary to construct the
exclusion fence on the uplands beyond the intermittently flooded
playa area to avoid excessive fence maintenance problems. Therefore,
the interdisciplinary team has subsequently determined that an area
of 2,690 acres will need to be designated. This takes into account
providing for dependable water sources for livestock and wild horses,
reasonable transportation through this locality, allowance for wild
horse movement, and enhancement of important habitat for sage grouse.
Refer to response 3-1.
Refer to response 1-26.
The BIscuitroot Cultural ACEC will be designated to afford protection
to traditional soclocultural values associated with certain natural
floral resources of the area. This will also protect other natural
habitats and plant communities that are present at this juncture of
major physiographic provinces.
The integrity of the proposed Silver Creek RNA/ACEC Addition requires
the designation of the entire area as a unit. Natural resource values
and research designs could be affected by uncontrolled variables
originating from or enhanced by private land activities. Protection
here, as In the existing Silver Creek RNA/ACEC, would probably be
afforded by perimeter boundary fencing. Realistically, excessive
fencing and fence removal projects cannot be considered. In order to
minimize the resource and management difficulties inherent in
designating discontiguous parcels, it Is appropriate to successfully
acquire the private inholding as the key to establishing the new and
larger Silver Creek RNA/ACEC, Including Silver Creek RNA/ACEC
Addition.
The planning team conducted a thorough assessment of the rivers in
the RA for possible inclusion in the Wild and Scenic Rivers System.
Only a portion of this assessment was published In the DRMP/DEIS. To
provide a more In-depth presentation of this analysis, details have
been drawn from the original background documentation of the study
and can be found in the PRMP/FEIS, Tables 2.17 - 2.20 of the
PRMP/FEIS. This detailed presentation provides the basis for the 3LM
recommendation for Segment A, Middle Fork of the Malheur/Bluebucket
Creek.
Refer to response l-ll.
Refer to response 2-79.
Crawford and Lutz (1985) found that sage grouse productivity measures
(chicks/adult, chicks/brood, and percent of adults with broods)
decreased by nearly 80 percent since 1940. Sage grouse chick diets at
Hart Mountain National Antelope Refuge were composed chiefly of
native forb leaves, flowers and Immature fruits (Pyle personal
communications). It Is felt that nest site protection and improved
forb abundance and availability which would result from the Proposed
Plan will enhance sage grouse habitat and production. However,
Some very rare species such as Tri folium leiberqii and Eriogonum
cusickii need immediate inventory and monitoring programs and
their known habitats should be considered for at least temporary
exclusion from grazing.
Riparian Habitat
Riparian habitat is a key component to the health of Three Rivers
Resource Area. The preferred alternative does address the
riparian needs in the RA correctly but falls short in management
actions to improve conditions. Specifically, Table 2.1-22-23
calls for exclosure for 5 years for 81 miles of streams and then
returning the streams to somewhat restricted use. It would be
better to say that grazing would be allowed after 5 years if the
condition of the riparian zone was upgraded from poor to at least
fair if not good. Some poor condition riparian zones may not
rehabilitate themselves in 5 years, especially if active
management funds are not made available. Also in Table 2,1-24-25
there is no mention that roads in riparian zones will be
constructed to BLM standards for the preferred alternative.
Surely this should be corrected in the final RMP.
Lands
There are two issues that arise under the Lands category that we
feel should be included in the preferred alternative. First, we
feel that it is imperative that all ACECs should be formally
withdrawn from mineral entry to protect habitat values. As
mining is incompatible with ACECs and should be prohibited "at
the front end" instead of having to be dealt with after a claim
is filed. The second issue related to lands is that it would be
beneficial to indicate where the emphasis on land exchange or
land consolidation is occurring on the RA. There are several
sites that warrant realty activities, such as Silver Creek RNA,
Diamond Craters ACEC, and the upper Silvies Valley, that
immediately come to mind.
This concludes our comments on the RMP for the Three Rivers RA.
As indicated at the beginning of our comments we feel that the
plan and DEIS is most readable and comprehensive which has
resulted in a much more useful document. Thank you for giving us
the opportunity to review the plan.
JD^J.
Dick Vander Schaaf
Public Lands Coordinator
esearch is currently ongoing In the Jack Creek (East Warm Springs
Allotment No. 7001) area and other management strategies may be
Implemented as research findings become available. Also, refer to
response 1-15.
3-10 Actions for inventory and monitoring of special status species,
including plant species, are In the Proposed Plan. At this time,
these two plant species do not appear to be Impacted by livestock
grazing.
3-11 Known snowy plover nesting habitat is shown on Map SS-1, of the
Proposed Plan. These populations have been discovered and monitored
through coordinated inventory and nesting plover counts.
Snowy plovers prefer sparsely or unvegetated playa margins which
generally receive little cattle use prior to July 1 yearly. Specific
livestock grazing treatments on snowy plover nesting habitat will be
developed during the grazing system formulation proposed for the West
Warm Springs Allotment. Also, refer to response 1-19.
3-12 Refer to response 1-16.
3-13 Experience on streams with poor condition riparian In the planning
area has shown that 5 years of nonuse by livestock results in
improved vigor and condition. Some of these riparian areas are
currently grazed in the spring. This combination has shown that
recovery can continue in a manner that would meet the objective in
most cases. Also, see management actions WL 6.1, 6.2 and 6.3 of the
Proposed Plan.
3-14 Road construction standards have been
Management Action WL 6.6.
3-15 43 CFR 3809. 1-4 (b)(3) provides for submission and approval of a plan
of operations in designated ACECs prior to commencing mining
activity. Plans of operations will be modified in accordance with 43
CFR 3809.1-6 if the proposed activity is inconsistent with the
purposes for which the ACEC was designated. See the Proposed Plan.
3-16 Emphasis on land exchanges and consolidation would generally occur in
areas identified as Zone I on Map LR-1, Implementation priorities
have been included In the Proposed Plan which establishes general
guidelines for land tenure adjustment actions. See Table 2.27. Other
management actions including WL 5.3, WL 6.5 direct that emphasis be
placed on exchanges and acquisitions which Increase the acreage of
wetland, riparian and recreational values in public ownership.
added to the Proposed Plan. See
Appendix 11-19
Harney County Stockgrowers Association
COURTHOUSE
BURNS. 0WKGON- .773 t-ebruary 14,
4
Jay Carlson - HMP/EIS
burns District Office
Bureau ot Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 97 7 38 Snfcff
sanctions tins use tlien it is a v
" . , . Undertundinq may be one reaso
order construction. . .But governme
able use . " It goes on to state
why there has been no government
t cannot force some people alone
;o
bear public bur
by the public a
access to this
conditions are.
en which, in all fairness and justice, should be borne
a whole..." The re tore livestock should have good
ater at all times, no matter what the drought
We are not resticting other uses from the reservoirs.
There is a need to make sure that livestock access to water is
excluded when range improvement money was used to develop the
reservoirs .
REVIEW COMMENTS FOR THE OCTOBER 1989
BLH DRAFT THRSE RIVERS HMP/EIS
year nr. Carlson,
The Harney County Stockgrowers want to go on record that the January
17, 19 90 Kiddle Ranch and Western Range Service comments and response
to the Draft Three Rivers Resource Management Plan and Environmental
Impact Statement are consistent with our views and comments . This
response is our endorsement ot such Riddle Ranch document . Their
response has been submitted to you. We do not include a full copy of
the text only for the reason that it would be an exact duplication of
the Riddle Ranch document. There are several other areas of concern
that this letter will address.
The Harney County Stockgrowers support a no action plan. This plan
would help stabilize a local economy that over the past 10 years has
had many negative impacts. The BLM has reported that significant
progress has been made in obtaining management objectives under the
present plan.
1. 1 Stated by the Burns District Manager in the 1981 Rangeland
Program Summary Update for the Drewsey Grazing BXSi
"To date we have made significant progress in improving the
public rangelands through intensive livestock management and rangeland
improvements . "
2 . ) BLH stated m the 1983 Drewsey Rangeland Program Summary:
"The specific objectives are to t improve waterfowl and fish
habitat, increase available forage ror wildlife, wild horses and
live stock, maintain water quality and reduce soil erosion, increase
recreational opportunities and quality, minimize impacts of the
program on visual and wilderness resources, minimize the impact of
reductions or changes in use on grazing permittees and protect
cultural resources and threatened and/cr endangered plant and animal
species .
There has been considerable progress in achieving these
objectives and this progress will be discussed in toll owing sections."
The objectives stated in the 1983 Drewsey Rangeland Program Summary
Update related to all concerns of multiple use. With the BLH stating
4-6
4-7
There is no scientific data that indicates that livestock use has any
negative effect on the sage grouse population. The restrictions on
livestock in the sageg rouse strutting grounds are unfounded and should
be eliminated. If the sagegrouse population is declining, why did the
Oregon Department of Pish and Wildlife open a season on these birds
tins
air quality restrictions are the sa
eed to be provided. Fire
method ot range improvem
_ /ear is unrealistic. More research is need,-
re a with Fire Hanagement Special ists. Unless there is valid
alternatives
and econo
3000
all alternatives. More
coming a very acceptable
To limit this area to
this
area wi th Fire Hanagement Special ists. Unless there is valid
scientific data to show that limits above this would permenantly
effect air quality these limitations should be eliminated.
ire is nat
ure '
hrubs . Th
e pr
imitations
and
ncrease the tr
ave a negative
ild horses
, an
5 well as
lett
upervision
wil
anqe. [t
will
aior fire
wou I
re better
for
ire .
erore any
aite
o matter v
ti a t
houid be c
ompi
rorage by burning juniper and woody
on prescribed burnings, as well as
of natural fires, will continue to
nd juniper encroachment. This will
etation and grasses used by wildlife,
re open policy on prescribed burns,
burn under fire management
d improve a majority of the existing
loads building to a point that a
ell known that smaller cooler fires
ve vegetation than one najor hot
that causes a reduction ot AUH 's is imposed,
a complete "Takings implications Assessment"
authorized by Executive urder 12ii30.
improving
imitations
ppression
agebrush a
on the veg
ock. A mo
ral fires
aintain an
event fuel
It is w
rn of nati
The designation of the entire Kiger Active
(jo,*5i9 acres] as an Area of Critical Envi]
could have a dramatic economical effect on at lc
AUH' s are reduced. before a reduction of AUM's
Management Area ( KKA )
tal Concern (ACEC)
three ranches if
even considered a
complete "Takings Implication Asses sm
authorized by Executive Order 12630.
run together successfully for years.
District Court for the Southern Distr
Jr., Susan Fallmi and Helen Fallini,
:nt" should be conducted as
Livestock and wild horses have
In a recent decision the U.S.
,ct ot Nevada, Joe B. Fallini
Plaintiffs vs Donald P. Hodel,
Secretary of the Interior; Robert F . Burtord, Director Bureau of Land
that the EIS is succesiul, the Ha
reason to change something that i
multiple- use concerns.
ey County Stockgrowers see
working that address all
Monitor!
Area are
techniques currently in use on the Three Rivers Resource
sufficient, inaccurate , and improperly applied, and then
are extrapolated to indefensible conclusions. Hanagement objectives,
in the absence ot AMP ' s , are documented only in the broadest of terms
making them virtually unmeasurable . No factors, other than short term
wildlife, wild horse, and livestock utilization are indicated as
affecting forage production, ecological status, or potential of the
resource. Therefore, reductions in authorized livestock use is the
primary, if not the only, remedial action recommended. Before a
reduction of AUH's is considered, other management tools such as
changing season or use. length of time, and deferred rotation need to
be considered. Until proper techniques and accurate information is
gathered existing levels of livestock grazing should be maintained.
At such time that reliable information shows trend increase or
decrease, proper adjustments could then be made . The ratings in the
recently published Riley Rangeland Program Summary Update classify
range conditions as poor, fair, good, and excellent. The HMP/EIS
classifies range conditions as satisfactory and unsatisfactory,
consistent use of evaluation ratings is necessary for accurate
evaluation as well as better communication with the permittee.
Enclosed is a copy of the Bureau of Land Management Riparian Area
Hanagement Policy, dated January 22, 1987 signed by BLH Director
Robert J. Burford. This policy has never been rescinded. Please note
that the definition of a riparian area is an area of land "directly
influenced by permanent water, and having visible vegetation or
physical characteristics reflective of permanent water influence."
The definition continues that areas excluded from the definition of a
riparian area include "ephemeral streams or washes that do not exhibit
the presence or vegetation dependent upon free water in the soil."
There are areas classified as riparian that do not meet these
criteria. A thorough review ot all creeks should be made to ensure
they meet the definition of riparian area. Any that do not meet the
requirements should be tan en out ot that classification.
The continual lencntg of reservoirs is in direct conflict with the BLH
objective to disperse livestock away rrom riparian areas and improve
rorage utilization. Tnese reservoirs would not be there today if it
had not been for either the range improvement funds or private funds
that first developed them. The small water gaps that dry up during
the season or don't allow livestock to water durinq low water years
restrict the amount of available forage and can concentrate cattle
more than necessary. Livestock have a biological need for water.
Access can be accomplished by building the water gaps at the deep end
of the reservoir. It the enclosure is more than one-halt mile square,
have more than one access point to allow livestock better access to
all of the forage available around the reservoir. Prom the Fallini
vs. BLH court case "If water is developed for grazing livestock, and
the range improvement permits provides tor and the state permit
Management) Edward F. Spang, Nevada State Director, Bureau ot Land
Management, Defendants ( Fal lini vs BLM), the court rejected a
contention that cattle grazing on federal lands has an inferior statu
to wild horses as a result ot congressional enactments . The
elimination of any livestock grazing is neither justified nor proven
necessary, and appears to be illegal. Wild horse and livestock AUM ' s
have been distributed. Any increase or decrease of AUM's due to a
change in the resource should be done proportionally to all AUH's
involved. The conditions for acquiring the private holds or the
authority to impose this on the private holdings is not fully
addr
sed.
The exclusi
supported .
resource
of cattle on th<
The report states
e to the quality ai
Biscuitroot Cultural ACEC is not
"...these areas to be a high-value
d quantity of roots available."
Appendix 7-12: Vol. 11 Appendicies. Since grazing has been goinq on
in tnis area ror years and the quality and quantity have remained
High, even with root harvesting, there is no justification to change
the practice.
The need for public access along the Silvies River and Poison Creek is
unjustified. The public has access to over 78% or the county already.
These two access routes through private holdings are not needed since
the public has several other routes of entering the federal lands.
Sincerely yours
Oi'LL fi
06,
Mark Dovers^ike, President
Harney County stockgrowers
Star Route 1 Box 134A
Burns, Oregon 97720
Enclosures ( 1 )
Appendix 11-20
Bureau of Land Macijcoeac
Riparian Area KanaReoect poll'
Klparlao areas ace unlqu
, anong the moot productive and Important
.proximately 1 percent of the public lands..
Characteristically, riparian areas display a greater diversity of plant, fUh
wildlife, and other animal apecies and vegetation structure than adjoining
cco3ysteoB. Healthy riparian systems filter aud purify water as it move
through the riparian (QM, reduce sediment loads and_ enhance 3oU_stabll) T*.
provide eicro-cllmate moderation when coot raa ted to extremes in adjacent
areas and contribute to groundwater recharge aud base flow.
^ - an area of land directly influenced by permanent "ate
^e:atlon or physical characteristics reflective of percan
Lake Shores and stream oiiaka arc typical riparian areas-
: vegetation depftQCBD-t upni
Ian Are a-IJcpt;nfleoc Knf.ouiti
o Achlev* riparian area improvement and
^onacement or dieting uses wherever
0 insure that ouw resource nana;
existing plana uhen revised,
and initiate management co oaictam, m
o Prescribe canagcouat for riparian valui
cr-atsctsrlsticn and settings-
lance objective
ilam and activity pi
= ugh the
> the :
riparian values,
based upon site-spec If 1c
G1V« IP.elal attention to monlt^rius aod cvaluatlos o*&agen*ai: activities
in riparian areas and revise oanagemeat practices where site-spec, le
Cooperate with n,d encourage the ttVUHHM Oi interested F <«U»1 . lUlt
and local Eovemmeats and private p*rtiBs to thin iafors.or.iorv. tagM-M
=.1QaS-mcat, coordinate activities, and provide education on the value,
productivity, and Mnagemcut of riparian areas.
Retain rip«rlai
the public int.
public ownership unless disposal uould
leter^ined in the land use planning syst.
O Identify, encourage, and support research a_id studies needrd to e»Eur
cnat riparian area management objectives can be properly defined and
£.
iP
J^' 22 1337
The Bureau has Implemented fire management tactics consistent with
Departmental, Bureau of Land Management policy in accordance with
appropriate State and Federal laws and regulations. Suppression
policies are mandated by the Department of the Interior.
The BLM acknowledges only two fire types, wildfire and prescribed
fire. Any fire that does not have an approved prescribed fire plan
completed prior to Ignition is considered a wildfire. Suppression of
wildfire is a high priority Bureau activity. A wildfire must have
appropriate action taken to suppress it. Appropriate action will he
based upon preplanned analysis consistent with land management
objectives, including the threat to life and property. Fire
suppression actions must be planned and executed to minimize
suppression costs plus resource losses, consistent with management
objectives. An Escaped Fire Analysis will be prepared to govern
suppression actions for all escaped fires (those which exceed initial
attack actions).
When multiple large wildfires are experienced, priority will be given
to suppressing new fires and those large fires where values at risk
are greatest (BLM Manual 9200. 06A Protection Policy).
Resource values at risk (see Map FM-1, page 3-37, DRMP/DEIS) are
established through an interdisciplinary team effort that considers
losses or damage to water resources, soils, wildlife, fisheries,
forage, recreation, cultural, botanical, improvements, intangible
resources, special use areas and landownership. All of these elements
must be considered when developing fire plans.
Prescribed fire under the Preferred Alternative Is allowed on 96
percent (1,180,114 acres) of all public lands within the RA. The two
major restricting factors of the prescribed fire program are smoke
emissions and funding. This alternative also provides for the use of
conditional suppression on 462,080 acres of Land In value classes 1
and 2. These conditional suppression areas will be managed on a least
cost plus resource loss basis. The full spectrum of suppression
intensities will be considered and the determination on which level
of intensity will be initiated based on the conditions at the time of
Ignition.
Refer to response 2-63.
Refer to response 2-68 and 2-63.
Refer to response 2-6. Also, the Falltni case dealt with an issue
Involving the use of water on private land by wild horses. This case
has no relevance on the issue of AUM adjustments. .Also, there are no
proposed reductions in AUMs in the Kiger HMA.
Refer to response 2-6.
Section 205 of the FLPMA provides authority to acquire lands by
purchase, exchange or donation. It limits the use of eminent domain
only to the extent necessary to secure access to public lands.
Refer to response 2-9.
The Bureau does recognize implementing grazing systems as a method to
balance livestock use with forage production. Establishing grazing
management requires a commitment from both the Bureau and the grazing
permittee to, meeting multiple-use objectives. Refer to response 2-87.
The Bureau is required to report range conditions in terms of
good/fair/poor. The Bureau is also required to rate each allotment to
determine "Selective Management Category." The categorization process
looks at range condition In terras of satisfactory and unsatisfactory
In meeting resource objectives. Although this may be confusing, it
aids the Bureau In looking at the rangeland resource in a
multiple-use manner.
The Riley RPS Update and the Three Rivers DRMP/DEIS in Chapters 3 and
4 refer to livestock forage condition which Is based on livestock
forage and soil erosion characteristics. The Bureau is conducting an
ecological site inventory which Is gathering data In terras of serai
stage and range condition as It relates to potential natural
community. For the purposes of identifying resource conflicts and
concerns and determining management objectives, range condition was
considered satisfactory If present conditions were meeting management
objectives and unsatisfactory if they were not. See Chapter 4, pp.
8-12 and Appendix 3, pp. 2-5.
Those streams which do not have a condition listed in Appendix 5,
Table 2, DRMP/DEIS, have not been intensively inventoried for
riparian or aquatic habitat. If these areas do not meet the
definition of riparian when Inventoried, they will be dropped from
the riparian tables and the riparian objectives will not apply. Also,
see PRMP/FEIS, Appendix 1, Table 4.
Refer to response 2-46.
Refer to responses 1-15 and 3-9. Also, no livestock grazing
restrictions are proposed in sage grouse strutting grounds.
Crawford (personal communications) found that there was no
correlation between limited fall hunts and the following spring
breeding population. This suggests that a harvestable surplus of sage
grouse Is available in the fall. To ensure that this surplus was not
exceeded, 0DFW limited the number of hunting permits by management
area. Also, this was one of only four limited seasons held during the
1980's.
Exchanges will be the primary form of land acquisition occurring in
the RA. Purchases normally require a special appropriation and are
limited to specific areas with extremely high resource values. To
date, no funding has been received for purchases in the Three Rivers
RA. If funding becomes available, purchases would be used only If a
land exchange or other alternative Is Infeaslble, in accordance with
Bureau policy contained In Manual 2100.06. All fee purchases and
exchanges would be with willing landowners.
Livestock grazing will not be prohibited within the Biscultroot
Cultural ACEC. Such use will be "restricted" rather than
"prohibited", as was incorrectly shown In the DRMP/DEIS, Appendix 7,
Table 1. See Appendix 1, Table 16 of the Proposed Plan for
recommended management /use constraints in this ACEC. No structures,
salt placement, or livestock loading/unloading will be allowed within
the ACEC area. Adjustments to season of use may be considered In a
management plan specific to this ACEC, and any such decisions are
deferred until the development of that plan.
Access acquisition in the Silvles River Canyon is being carried
forward In the Proposed Plan. The area contains legally inaccessible
public lands Including several miles of the Silvles River. Legal
public access along the river would provide an outstanding
recreational opportunity on these public lands, particularly for
nearby residents of the Bums-Mines area. Public access along other
routes Into the canyon is limited by private lands or difficult
terrain.
The access portrayed In Poison Creek and the Silvles Valley Is along
the Oregon and Northwest Railroad Grade. An effort to acquire the
grade for a recreational trail was dropped from consideration In
April 1989. Since the railroad grade accesses very little adjacent
public land it will not be considered further for access acquisition.
It has been deleted from Map LR-3 in the Proposed Plan.
It is true that air quality restrictions are the same for all
alternatives. The DEQ, in nccordance with the Federal Clean Air Act,
regulates the air quality standards for the state. In the RMP,
particulate emissions are limited to a maximum of 31,000 tons of
burnable fuel. This figure is derived from the District's baseline
data. Plans for using prescribed fire, In the next 10 years, will no
exceed those maximum figures. Conditional suppression of natural
fires on 462,080 acres will be In addition to the prescribed fire
program.
Appendix 11-21
0!fa NATIONAL WILDLIFE FEDERATION 5
February 16, 1990
Jay Carlson, RMP/EIS Team Leader
Bureau of Land Management
Burns District Office
HC 74-12533
Highway 20 W.
Hines, OR 97738
Dear Mr. Carlson:
The National Wildlife Federation (NWF) is the nation's
largest conservation organization, with over 5.8 million members
and supporters. The KWF's commitment to the Pacific Northwest
and to the State of Oregon is evident in the location of its
Pacific Northwest Natural Resources Center in Portland. We are
vitally interested in the restoration, preservation and
protection of Pacific Northwest ecosystems, fish and wildlife
habitats, and the natural resource values of its public lands.
The NWF commends the authors' Three Rivers Draft RMP/EIS for
its comprehensiveness, and high level of detail. It is one of
the best Draft RMPs to come out of the BLM Burns District Office,
and one of the better EIS documents to be reviewed by this
office. The NWF wishes to thank the BLM for extending the
comment period, and the Burns District staff which attended the
clarification meeting at the National Wildlife Federation's
Portland Resources Center. Notwithstanding the BLM's improved
National Environmental Policy Act (NEPA) efforts on this RMP/EIS,
1 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
The protection of sustainable resources is a dominant theme
throughout FLPMA.
In the development and revision of land use plans, the
Secretary shall consider present and potential uses
principles of the public lands, give priority to the
designation and protection of areas of critical
environmental concern, use and observe the principles of
multiple use and sustained yield, and consider the relative
scarcity of the values involved. . . . '
Despite this clear Congressional mandate for protection and
preservation of all resource values, the Three Rivers Draft
RMP/EIS preferred alternative gives unacceptable and overwhelming
preference to livestock grazing. Therefore, the NWF formally
requests modification and/or clarification of the following
management objectives.
A. Vegetation
1. Livestock Grazing Preference
While the Draft RMP/EIS pretends to promote a planning
process which will integrate all natural resources and their
subsequent uses into a balanced approach to multiple use
management of the Three Rivers RA, proposals which clearly favor
livestock grazing, and not multiple use are made throughout the
document. The overall monoculture theme of the RMP/EIS is to
provide adequate livestock forage for the ranching permittees.
The Plan dedicates 139,851 AUMs to livestock grazing, but only
7,800 AUM3 to wildlife needs. Native plant species which provide
food and shelter to wildlife, stabilize soils and promote
4 FLPMA § 1712(c) (1-8)
3 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
however, we have serious reservations about many of the
assumptions and objectives in the plan. While the preferred
alternative is a step in the right direction, significant
modifications must be incorporated into the plan if the BLM is to
meet its Congressionally mandated duty "to provide for
management, protection, development, and enhancement of public
lands." '
The Federal Land Policy and Management Act (FLPMA) is
authorized by public law 94-579 Title I § 102. The legislative
history of this law underscores the Congressional intent to
protect and perpetuate all the natural resource values of the
federal public lands: "[The] underlying mission proposed for
public lands is the multiple use of resources on a susta ined-
yield basis." ' (emphasis added) The drafters of FLPMA expressly
state the management criteria for public lands in the plain
language of the statute.
The congress declares that it is the policy of the
United States that the public lands be managed in a
manner that will protect the quality of scientific,
scenic, historical , ecological , environmental , air and
atmospheric, water resource, and archeological values;
that where appropriate, will preserve and protect
certain public lands in their natural condition; that
will provide food and habitat for fish and wildlife and
domestic animals; and that will provide for outdoor
recreation and human occupancy and use. . - -
1 Legislative history, H.R. 94-1163
2 H.R. 94-1163 Mission
3 FLPMA § 1701(8)
2 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
biodiversity, are at times overlooked in favor of imported
grasses, which primarily provide forage for livestock. The
structural, cover, and biodiversity needs of many non-game
wildlife species are completely ignored,
2. Seeding: The NWF is concerned about the proposed
conversions of vast acres of native rangelands to monocultures of
an introduced grass species. The number of seeded acres under
the preferred alternative (46,960) is greater than the no action
alternative (42,231). Crested wheat grass is a tough, imported
species from the steppes of Russia. While it makes an ideal diet
for livestock, it provides no food or shelter to wildlife. When
non-native species such as crested wheat grass crowd out and
replace the native grasses, mule door, sage grouse and other
wildlife habitat is lost. The conversion of native species of
grass which increase biodiversity, protect the soil and benefit
all users of public lands to a single species of grass designed
only to feed domestic livestock, is inconsistent with the
Congressional goals of protection and multiple use of federal
public lands. Additionally, the plan also fails to list the
prioritization or budget constraints regarding seeding projects,
or to describe in detail how the seeding project monies will be
spent.
The preferred alternative not only proposes to cut native
brush on 15,540 acres of deer winter range, but seed crested
wheat grass on 9,460 of those acres. The NWF is extremely
concerned about the proposed conversion this wildlife winter
4 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
Appendix 11-22
range from shrubs to grasslands, but it cannot adequately respond
without more information and a detailed map of where these
projects would occur.
3. Prescribed burning: The 8,260 acres of prescribed
burning under the preferred alternative is second only to the
proposed 10,000 acres under the emphasized commodity production
alternative. Burning vast acres of range will not promote
multiple use and sustain the resource. The RMP/EIS must fulfill
FLPHA by considering the relative scarcity of resource values
involved, weighing long-term benefits to the public against
short-term benefits, s and giving justification for its preferred
I alternative.
B. ORV Policy
The orv policy stated under the preferred alternative of
Recreation Management Objectives, "Maximize the development of
usable ORV areas and cross-country routes (including snowmobiles
and motorcycles) ... to increase the number of out-of-town
users. . . ." 6 is unacceptable. It is inconsistent with the
Congressionally mandated policy of placing primary concern on
protection of the environment, and fails to adequately discuss
the cumulative impacts of ORV use in conjunction with other
demands upon the natural resources of the Three Rivers RA. A
policy of unrestricted ORV use in open areas fails to insure
Forest and in the BLM's Prineville District- The preferred
alternative plan to "Maximize the development of usable ORV
areas. - . " ' is unacceptable and demonstrates the agency's utter
failure to adequately consider the significant damage to soil
stability, vegetation loss, wildlife habitat destruction,
wildlife harassment, and visual character damage, which is likely
to occur from increased ORV use. The NWF opposes such
irresponsible agency action. While current levels of ORV usage
may be light and not require restrictive actions, increased usage
would almost certainly have a negative effect on indigenous plant
and animal communities. More restrictive rules regarding ORV use
would have to be implemented to avoid these impacts. This would
result in a loss of traditional use and be very difficult to
5-9 E enforce. The NWF therefore urges that the phrase "Maximize ORV
use. . ." be replaced by "Minimize ORV use. . . ," in the
preferred alternative under Recreation Management Objectives.
C. Riparian Habitat
Overgrazing is particularly devastating to the condition and
diversity of riparian areas. It is often directly responsible
for reduced water quality, the loss of year-long water flows,
elimination of streamside shrubs, soil compaction, accelerated
erosion, broken down stream banks, and the loss of critical
fisheries habitat. The preferred alternative recognizes the
serious condition of the riparian areas in the Three Rivers RA,
FLPMA § 1712(C) (607)
6 Three Rivers Draft RMP/EIS Table 2.1, p. 31, item 2
COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
7 Three Rivers Draft RMP/EIS Table 2.1, page 31
COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
adequate protection of public lands.
The NWF incorporates and supports the comments of the Oregon
Department of Fish and Wildlife regarding ORVs in the Three
Rivers Resource Area. The NWF is very concerned about the
possible negative impacts of encouraging increased ORV use from
out-of-county users, and recommends that the BLM take no action
to encourage additional ORV use.
Historically, ORV use in the Burns District has been light
and broadly distributed. Low usage usually causes little in the
way of negative, long term, environmental impacts. However, the
high desert environment is fragile, and the balance between
negligible and significant damage can be precarious. Even a
single incident of intense exposure to ORV use can cause damage
that may take years to heal. Continued intensive exposure can
easily cause significant environmental damage and displacement of
wildlife communities. ORVs are especially destructive to stream
and riparian areas since many operators ride their vehicles
directly up the stream bed and along the banks (as demonstrated
in ORV television commercials) . This destructive practice
increases erosion and turbidity, and destroys aquatic vegetation
as well as polluting the water with oil, gasoline, grease and
carbon monoxide.
The BLM's stated goal of soliciting additional ORV use on
fragile, high desert ecosystems, which are already severely
damaged by overgrazing, is unconscionable. Significant adverse
impacts from ORV use are already occurring on the Ochoco National
6 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
and states that livestock will be removed from 80.9 miles of
stream with "poor" water quality for five years.
The NWF supports a preferred alternative which mandates the
removal of livestock for five years from streams in poor
condition, or in the alternative, until riparian condition
improves to a "good" classification. However, it came to our
attention in a recent meeting with the Three Rivers Draft RMP/EIS
team leader and staff fl, that the proposed preferred alternative
does not guarantee complete rest for damaged riparian areas. The
Draft RMP/EIS actually gives the agency discretion to completely
rest affected riparian areas by removing livestock for five years
or implement "[grazing] systems which are widely recognized as
promoting the most rapid riparian recovery practicable". The NWF
is sorely disappointed by this change of heart. The arbitrary
decision to choose between complete rest of damaged riparian
areas and implementation of an undefined grazing system is simply
unacceptable.
In addition, the agency should be closely monitoring
riparian areas now in fair condition. If a downward trend begins
to develop, immediate corrective action should be taken. In most
cases, the poor riparian habitats and/or poor water quality
streams must receive complete rest for a minimum of five years.
Once full recovery of riparian habitat is achieved, livestock
grazing should never be allowed to reduce riparian habitat and
February 5, 1990 at NWF Pacific Northwest Resource Center
8 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
Appendix 11-23
water quality to less than "good" condition. Under the preferred
alternative for Riparian Habitat Management Objectives, the
RMP/EIS must clarify the phrase "[S]ystems which are widely
recognized as promoting speedy riparian recovery." '' The
reliance on inadequately discussed secondary alternatives, such
as the undefined "grazing systems," to promote riparian
rehabilitation, is a serious breach of NEPA environmental impact
statement guidelines. i0 The reviewer must be provided with a
full and accurate picture of all proposed agency actions to
restore these critical habitat areas. Any livestock grazing
management plan that provides for less than full recovery of
riparian habitat is inconsistent with rehabilitation and
restoration of these critically important habitats. The agency
admits that an estimated 70 percent of all wildlife species in
the Three Rivers RA is partially or totally dependent upon
riparian habitat for food, water and cover. ll Additionally,
with the preferred alternative under Recreation Management
objectives, "Manage livestock grazing in riparian areas to
enhance fishing opportunities." u
Livestock grazing must also be terminated for the season
when any one of the three utilization limits, (woody riparian,
' Three Rivers Draft RMP/EIS Table 2.1, p. 23, item 1
1D Friends of the Earth v. Hall, 693 F. Supp. 904 (WD Wash,
1988)
" TR Draft RMP/EIS Vol. 1 at 3-27
12 Supra , at 33, item 6
9 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
current classification of "poor" stream condition is far too
broad. It currently includes everything from totally denuded
riparian areas to those that are in just slightly less than
"fair" condition. The draft RMP/EIS must therefore include an
additional category, such as "severe [impact] , " to accurately
describe the worst areas of riparian destruction. All users of
public lands must be assured that these definitions and criteria
will be consistent throughout the RA.
D . Water Quality
Current DEQ standards and guidelines state, "In order to
improve controls over nonpoint sources of pollution, federal,
state, local resource management agencies will be encouraged to
regulate and control runoff, erosion, turbidity, stream
temperature, stream flow. . . ." "
The draft RMP/EIS states that "major impacts to water
quality in the planning area are from sedimentation, lack of
shade, and concentrations of fecal coliform bacteria." ^ The
reasons for these impacts are no mystery. As the RMP/EIS points
out, "Major conflicts with water resources are livestock grazing
and timber harvesting." 16 It is both undesirable and
impractical to fence all of the 80.9 miles of stream with poor
{or lower) water quality. The RMP must therefore adopt a
- OAR 340-41-026(9) (19S7)
,J Supra, at 3-2
" Supra , at 3-3
11 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
herbaceous riparian, herbaceous upland utilization) listed under
the preferred alternative of the Water Quality Management
Objectives is reached. "[N]o more than 10 percent livestock
utilization on woody riparian shrubs, 50 percent utilization on
herbaceous riparian vegetation, and 30 percent utilization on
herbaceous upland vegetation. . . . " " This prevents over-
utilization of any one component of the grazing system and
encourages management of livestock to promote a balanced
utilization of the forage available.
Additionally, sensitive aquatic plant species are often the
first vegetation taken out by livestock grazing in riparian
areas. For example, water weeds provide a vital structural
benefit to streams by reducing the formation of anchor ice during
the winter. When livestock grazing removes these plants, the
streams freeze more readily and essential fish habitat is lost.
Since livestock have shown a preference for these and other
beneficial aquatic species, they must be prevented from entering
the affected riparian areas. The NWF endorses and incorporates
the comments of Oregon Trout regarding impacts to aquatic plant
species and riparian areas.
Finally, the Draft. RMP/EIS must adequately define the
threshold criteria for distinguishing "poor, " "fair, " and "good"
water quality and adequately account for ecological values and
functions when describing these stream condition categories. The
Supra, at 3, item 4
10 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
management plan which removes livestock grazing from these
riparian pastures, and keeps them off until the riparian areas
have recovered to a good condition.
E. Prioritization
The BLM must provide an adequate scheduling and
prioritization of Allotment Management Plans on a year by year
basis as part of the Draft RMP/EIS. without this information,
interested parties have no way of knowing how well the proposal
and plans described in the RMP/EIS will be implemented. Changes
at the time of the "Proposed RMP/Final EIS" are always more
difficult to make than for the Draft. In the past large planning
efforts have not been translated into on-the-ground changes.
Without adequately documented implementation plans, utilization
management objectives will become just another "plan on the
shelf."
F. Monitoring
The Draft RMP/EIS does not adequately address monitoring of
the preferred alternative objectives, nor the constraints placed
on monitoring programs by budget limitations. This information
is essential to assess the expectations of interested parties,
and insure enforcement of the preferred alternative objectives.
G. Energy and Minerals
None of the alternatives adequately address mining impacts
on water quality. Even under the "best" environmental
alternative, "Mineral activities have the potential to negatively
12 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
Appendix 11-24
affect riparian habitat." ,7
No recovery or rehabilitation of riparian and water quality
will be achieved if adverse grazing practices are merely replaced
by equally destructive mining practices.
H. Photographs and Maps
The excellent maps included in the Draft RMP/EIS are very
helpful. The level of detail shows that a significant amount of
time and effort were spent on this part of the document.
Unfortunately, the old photographs in the Draft arc of no use to
planning public land management objectives. While some
historical photographs might have been included, the fact that
all of the photographs are 01 the "old West" only reinforces the
perception of many conservation groups that the BLM's
overwhelming commitment is to its western ranching constituency.
Turn of the century photographs fail to document the poor
condition of much of the range and riparian areas in the present
day Three Rivers RA. This omission does a significant disservice
to the concerned reader who wishes to make relevant comments, and
continues to paint the BLH as the government agency essentially
concerned with maximizing livestock grazing opportunities, not
multiple use of natural resources. Some photographic examples of
resource conditions in the present day Three Rivers RA would have
been much more useful to concerned reviewers and interested
parties.
benefits instead of long-term public benefits are inconsistent
with sustaining the natural resources of public lands.
Respectfully submitted,
Ajrz^c^t. Qfzf1^- /Uf
Bruce Apple
Director
/has
[Via FAX to 503-573-7600]
' Three Rivers Draft RMP/EIS Vol.1 at 4-28
13 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
15 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
i . Summary
The NWF supports "management actions which recognize,
promote and enhance the integrity of the ecological and
socioeconomic systems in the Three Rivers RA." 1B We are very
concerned about the deteriorating health and condition of the
range. Deplorable and detrimental grazing practices have been
the rule on public lands for too long. More than fifty years
have passed since the Taylor Grazing Act was passed in the
1930's, but destructive overgrazing continues to be the norm.
A good portion of the natural resource base of Oregon's Great
Basin country has been reduced to barren hills and eroded muck
due to previous BLM mismanagement.
The BLM has a mandated duty to carefully consider the
"relative scarcity of the values involved" " when attempting to
balance the one-dimensional demands of 130 livestock owner
permittees with the multiple use needs of tens of thousands of
hunters, hikers, campers, and other impacted members of the
public. Management decisions which emphasize short-term grazing
18 Three Rivers Draft RMP/EIS vol. I at 2-3
19 FLPMA S 1712(C) (6)
14 COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
5-1 The RMP/EIS is not a document that gives preferential management
consideration to single resource values. Through the Preferred
Alternative, significant Improvements would be realized In water
quality, riparian habitat, aquatic habitat, wetland habitat;
significant additions would be made to the areas protected under
designation as ACECs; explicit management objectives for biodiversity
are established for the first time In any eastern Oregon RMP; and
utility corridor exclusion/avoidance areas are established for nearly
85,000 acres. The total prorated forage demand of nearly 33,200 AUMs
for big game would be provided. Of this amount, 7,800 AUMs are
competitive with livestock and would be allocated directly to big
gome.
Detailed management objectives for a broad spectrum of resources have
been integrated at the ground level on an allotment by allotment
basis, thus ensuring long-term Interdisciplinary management,
monitoring and evaluation.
5-2 Refer to response 1-11.
5-3 Refer to response 1-11.
5-4 Bureau investment policy is clearly established in that I category
allotments have highest priority, M category allotments have the next
highest, and C category allotments have the lowest priority. Refer to
Appendix 3, Table 1, DRMP/DEIS, for allotment categorization In the
Three Rivers RA.
Additionally, Appendix 3, Table 2 of the DRMP/DEIS presents a further
delineation of priorities within the I and M category allotments on
the basis of an Interdisciplinary assessment of resource
concerns/problems. Detailed project descriptions necessary to
describe how seeding project monies would be spent are not conducted
at the RMP level. Such descriptions are made available annually
through the EA register/public notification process.
5-5 The map of potential treatment areas has been added (see Map RM-3).
Refer to response 1-11.
5-6 Prescribed burning is a tool the Bureau will employ to improve range
condition and increase vegetative diversity. DRMP/DEIS, Appendix 3,
Table 8, p. 177, outlines design features for burns. Table 2.1, p.
20-23, discusses actions for wildlife habitat relative to prescribed
burning. Site-specific NEPA analysis Is always done on prescribed
burn projects.
5-7 Refer to response 1-23.
5-8 Refer to response 1-23.
5-9 Refer to response 1-23.
5-10 Some exclosures are proposed where conditions will require complete
rest to regain vigor and riparian plant species composition. Also,
see management actions WX 6.1, 6.2 and 6.3 of the Proposed Plan.
Appendix 11-25
5-11 Riparian habitat monitoring has been ongoing since 1981. See
PRMP/FEIS, Appendix 1, Tabic 4.
5-12 Refer to responses 1-2 and 2-40.
5-13 The utilization levels are independent of one another, if one is
reached livestock, will be moved. Also, refer to response 1-1.
5-14 Refer to responses 2-3 and 2-25.
5-15 Prioritization is a dynamic process which encompasses multiple-use
values, socioeconomic values and the uncertainties of funding support
for implementing actions. The Bureau's funding is through annual
Congressional appropriations, specific priorities are established
annually through budget mechanisms. Since this can be a volatile
process, subject to the shifting of national priorities, funding
levels, politics, etc., the publication in the RMP of an areawide
ranking or scheduling of allotments is not as productive or
informative as it may seem.
BLM is, however, sensitive to the concern that interested parties be
able to keep abreast of priorities and implementing actions over the
life of the plan. To meet this need, the Burns District is
undertaking two specific actions. First, the criteria that will be
utilized for periodic prioritization of allotments are defined under
Procedures to Implement, for proposed decision CM 1.1 in Che Proposed
Plan.
Second, the liurns District has committed to the publication of an
annual "District Update" which will contain several sources of
information pertinent to the concern that you raise:
1. District workload and major priorities for that year will be
presented.
Ian is to be performed at intervals not to exceed 5 years. Reporting
of the results of such monitoring and evaluation efforts is to be
conducted through the public notification document which shall be
distributed annually.
The DRMP/DEIS analyzes the effects of mineral entry on all public
lands within the RA. The DRMP/DEIS prescribes appropriate
restrictions on mineral exploration in areas where they were found to
be necessary to protect other values. Another EIS addressing
comprehensive cumulative impacts of mining Is unnecessary until plans
of operation are filed. (At that time, the appropriate environmental
analysis will be prepared.) In accordance with surface management
regulations at 43 CFR 3809, a plan of operations must be filed with
BLM. The plan must include, among other requirements, measures to be
taken to prevent undue and unnecessary degradation; manner in which
disturbed areas will be reclaimed; and procedures to be taken to
maintain the area In a clean and safe condition including periods of
extended nonoperatlon. Furthermore, it is incumbent on the operator
to assure that all tailings, dumps, deleterious materials or
substances and other wastes are disposed of In a prudent manner
taking Into consideration effects on other resources, and complying
with all applicable Federal and State permitting requirements. Under
the Mining Law of 1872 and regulations in 43 CFR 3809, BLM must act
timely on all plans of operation. However, because of the
nondlscretionary nature of locatable mineral actions, until an actual
notice or plan of operation is filed, discussing the environmental
consequences of the generalized gold raining scenario would be highly
speculative as the impacts would vary significantly depending on the
location of the planned operation. It would be far more relevant to
deal with cumulative Impacts and reasonably foreseeable development
in the NEPA analysis of a proposed operation. To do otherwise would
require BLM to fully inventory all potential resources, planning
areawide, in order to determine whether hypothetical actions would
result in an adverse impact.
2. Planning updates will report on actions undertaken to meet
management objectives established in the District's land use
plans, including the Three Rivers RMP.
3. A register of the EAs of the on-the-ground projects (usually the
implementing actions for the land use plans) that are being
undertaken in the District will be published.
Refer to the Proposed Plan for a detailed description of the
implementing actions and support actions on a program by program,
management directive by management directive basis.
A detailed monitoring and evaluation program has been developed for
the Proposed Plan and is keyed to each management action. It is based
on three levels of monitoring: 1) tracking of the implementation of
the individual management directives; 2) evaluation of the
achievement of objectives; and, 3) evaluation of the effectiveness of
the overall land use plan. Levels one and two, monitoring and
evaluation are to be performed annually. Evaluation of the overall
County Court for Harney County
P.O. BOX 1147
BURNS. OREGON 97720
February 12, 1990
Mr- Joshua L. Warburton
Burns District Manager
Bureau of Land Management
HC74 - 12533 Hwy 20 West
Hines, Oregon 97738
Re: Three Rivers Resource Management Plan
Dear Josh:
Harney County appreciates the opportunity to common c on the
"Draft Three Rivers Resource Management Plan and Environmental
rmpact Statement" which is so important to the livestock industry
in the northern part of Harney County and to the economic
vitality of the County.
The major concern of the Harney County Court as we reviewed this
document was that it pictures the livestock industry in general
and cattle in particular as the cause of all the problems in the
Three Rivers Resource Area. That the only solutions that the BLM
have considered to resolve these problems is to remove livetock
from the range. That there was apparently no effort to consider
mitigating alternatives that could permit the ranchers to
function as economic units while the land management changes
desired by the BLM were implemented.
Harney County would now like to di
particular concern with the Draft Three
ss the folio
vers EIS:
ing items of
1.
In
viewing both Volume I and Volume 11 of the Eis we
f 1 no' nuiuecoua statements as to the condition of Cha range or
Carrying capacity. These appear to be statements of fact but wa
were unable to determine the methodology chat the BLM used in
arriving at their conclusions. Until we know the methodology
used it is impossible for us to verify the accuracy of your
conclusions and to determine whether we concur with your findings
Or not. Please provide documentation of your methodology for us
to validate your conclusions before implementing your Resource
Management Plan .
2. BLM has stated throughout the Draft that the condition
of the range is unsatisfactory or trend is down without any
documentation of proof chat that is true, please provide us wiCh
a copy of how you reached that decision so that we may verify
your findings before you implement the EIS.
February 12, 1990
3. There are statements that water quality does not
currently meet DEO standards on almost every allotment with
water. We understand that DBQ water standards are not always
realistic and in many cases water quality would not meet DEO
standards even if all livestock is removed. If this is true, it
seems unfair to reduce livestock numbers to meet water quality
standards that may never be attainable.
4. Another concern we have with the plan regarding water
quality is that BLM ownership of water is so fragmented that
even if you were able to meet you,: goals on the BLM portion uf
the stream is it going to have any meaningful impact on the
stream as a whole. Have you considered that your actions on the
public lands may require private land owners to use their section
of the stream more intensively and as a result the toCal effect
on the stream will be a negative one.
5. Regardless of water quality cone
livestock watering is a priority beneficial
permitted , and indeed required,
we believe that
dE water that is
er Oregon Water Law.
6. Harney County believes that the poor condition of the
upland range is due more to BLM's fire control policy than it is
to graziny . you arc never going to obtain satisfactory range
forage conditions on ranges thaC have been taken over by big
sagebrush and juniper because of the accive suppression of fire.
We would challenge the BLM to seriously reevaluate youc policy of
initial attack and full suppression of all fires on a majority of
the BLM land. We would also request that you consider
dramatically increasing the acres of land to be controlled burned
each year.
We believe that wildfire cycles of 5 to 25 years was the
normal condition in Harney County until the lasC 80 years or so.
we oeiieve the suppression of fire ana the resulting big
sagebrush and juniper stands have done more to reduce forage
production Chan any other single action.
That removing livestock without removing Che big sagebrush
and juniper is ecologically unsound and will do little to improve
range conditions.
7. We would challenge BLM's plans to fence waterholes that
were developed to disperse cattle. The water was created for
cattle and water quality and small riparian areas that may have
resulted from that creation are secondary to watering livestock
and should continue to be used for that purpose.
8. We are very concerned about statements such as identify
and pursue land purchase and identify and aggressively pursue
Appendix 11-26
February 12, 1990
land purchases. BLM already owns 4,110,077 acres out of Harney
County's total of approximately 6,545,920 acres or 63% of the
total land area and we strongly object to any efforts on the part
lr limited private land base.
Refer to response 2-87.
of BLM
urther erode
9. The reduction of AUM numbers by the implementation o£
Alternative C will have a significant impact on the economy of
Harney County. We respectfully request that a full Economic
Impact Statement be done on the effects of the proposed
reductions on the economy of Harney County.
: ■::■.
AUM '
whether a privilege or a right have an e
value to the ranchers that have them. We have been a;
affected ranchers and do hereby request on their behalf
"Takings Implication Assessment" be completed befot
reductions are made pursuant to the Three Rivers EIS.
ked by
11 .
We
have reviewed the Taylor Grazing Act as Amended and
Supplemented which we understand to still be the law of the land.
The Act's primary purpose is to manage the grazing lands so as to
stabilize and preserve the livestock industry. We find the
statement, "Allocate forage in priority order to satisfy demands
for 1) wild horses, 2) big game, 3} livestock" to be totally
inappropriate and possibly in direct contradiction of the Taylor
Grazing Act .
12. Harney County strongly objects to the proposal to
restrict the season of use for the Pine Creek, material site and
to the plan to close the site in 1992. The conclusion that the
site is a threat to the Indian cultural and root gathering
activities is without foundation. The added cost to County roads
is an economic impact that is not justified and would have a
serious impact on future road building in this area.
In conclusion, Harney County is committed to the long term health
of the environment and of the livestock industry, in our opinion
they are mutually dependent on each other. Our Comments are in
no way intended to reflect anything other than our interest in a
strong and healthy environment.
Our concern is that the Draft Three Rivers BIS has focused only
on the livestock industry and has not adequately addressed the
other activities occurring on public lands that affect its
well-being .
We challenge you to focus more on livestock management
techniques, burning of big sagebrush and juniper and other
mitigating factors that can result in accomplishing the goals
that we are all interested in achieving that can produce the
Refer to
isponse 2-87.
Water quality is in poor condition with static or declining trends on
26.55 miles of streams in the planning area. Many of these waters do
not meet DEQ standards. Under FLPMA, the BLM is required to
coordinate land use planning and management activities with Federal
and State agencies, and comply with all applicable State laws (see
FLPMA Sec. 202(c)(8) and (9)).
Additionally, the BLM feels that DEQ water quality standards are
fully attainable given proper management of riparian and aquatic
ecosystems. Livestock grazing and timber harvest are two major causes
of aquatic and riparian habitat degradation. Reduction In numbers of
livestock and/or changes in the season of use facilitate regeneration
of an area and improve both condition and trend of riparian and
aquatic ecosystems.
Refer to response 2-5.
Though the BLM acknowledges the importance of watering livestock,
FLPMA directs the Bureau to manage public lands and resources under
principles of multiple-use and sustained yield (Sec. 102. (a)(7)).
Additionally, the law states that those lands be managed In a manner
that would protect the quality of ecological, environmental and water
resources (Sec. 102. (a)(8)).
Refer to response 4-8 and 4-9.
Fire management practices, livestock management practices, as well as
climatic conditions are among the factors which have contributed to
the expansion of western juniper. .Juniper control has been proposed
as a method of improving range and wildlife habitat condition as well
as to increase vegetative diversity (removal of juniper reduces
competition and may result in an increase in diversity of other
species, but results in the loss of juniper) as funding and staff are
available. If funding and staff are not available, the Bureau is
still required to balance authorized use with forage production. See
DRMP/DEIS, Table 2.1, pp. 2-5, LI, 20-23 and Appendix 3, Table
172-176 for further information for project proposals and
multiple-use restrictions.
Refer to response 2-46.
The management action referred to In Table 2.1-22 of the DRMP/DEIS
has been modified in the Proposed Plan to read "Place high emphasis
on exchanges and acquisitions . . ."
BLM acquisition efforts should not reduce the Harney County tax base.
Since 1980, the amount of acreage patented Into private ownership in
Harney County through BLM land tenure actions has equaled the acreage
acquired by the BLM. This acreage includes lands purchased by the BLM
in the Steens. It is expected that this balance will continue and
swing in favor of private ownership since most of the exchanges
pp.
February 12,
amenities that we all desire, including livetock production.
Again, thank you for this opportunity to share our concerns with
you and to offer to meet with you at any time to mutually work
towards achieving an environment that is both pleasing as well as
supporting an economy that will permit us to enjoy it.
Sincerely,
HARNEY COUNTY COURT.,
Dale White, County Judge
y/V / ,,
H^ Lee Wallace, County Commissioner
Kenneth J. Ben'tz, Coun W' Commissi
recently completed and those that we expect to pursue, involve
acquisition of lands with high resource values. Generally, in these
types of exchanges, it takes more public land acres than private land
to balance values. Also, refer to response 4-14.
Refer to response 2-63. See discussion of Economic Impacts in Chapter
4, pp. 68-70, DRMP/DEIS.
While one of the purposes of the Taylor Grazing Act is to stabilize
the livestock industry, the primary purpose of the Act is "to stop
injury to the public grazing lands by preventing overgrazing and soil
deterioration." FLPMA directs the Bureau to manage the public lands
on the basis of multiple-use and sustained yield.
Also, refer to response 2-6.
Harney County's permit to use the Pine Creek Material Site expires in
1992. This type of land use consumes landforras and transforms surface
features, effectively destroying natural, habitats and plant
communities.
Plant species with edible roots that are Important to traditional
Native American cultures, such as biscuitroot, bitterroot, and
others, grow on scabland lithosol sites (Helliwell, 1988) including
the subject material site locality. These plants require some topsoil
for essential habitat. At this site, the soil mantle is so thin that
stockpiling topsoil is not feasible. As such, reclamation of the
quarry will leave bare rock where plant regrowth may not occur for
many years. Topsoil from off-site locations is not a viable
substitute as it might introduce exotic plant species that could
compete with the culturally valuable local species.
The subject gravel pit occurs within an area where generations of
Native Americans have traditionally gathered edible roots (Couture,
1978; Couture, Housley, and Ricks, 1986). However, this practice is
undermined by the reduction of plant habitat and the undesirability
of obtaining roots during gravel crushing and loading operations.
Final rehabilitation of the Pine Creek quarry and stockpile sites are
the responsibility of Harney County, in lieu o£ reclamation fees, and
are to be performed at the conclusion of the entry that will occur in
February of 1991. This Is the last planned entry by the county before
their permit expires In 1992. It is likely that county needs for
mineral materials can be found at an alternate site.
Appendix 11-27
Department of Fish and Wildlife
OFFICE OF THE DIRECTOR
506 SW MILL STREET, P.O. SOX 59, PORTLAND, OREGON 97207 PHONG (503) 229-5406
January 19, 1990
Joshua L. Warburton
District Manager
HC 74-12533 HWY 20 West
Hines, OR 97738
Dear Mr. Warburton:
The Oregon Department of Fish and wildlife staff has
reviewed the Draft Three Rivers Resource Management Plan.
The BLM is to be congratulated for the comprehensive manner
in which this plan has been developed. We are pleased to sec
the obvious commitment to improved riparian habitat and
increased forage allocations for big game animals. Though we
have areas of concern with the proposed plan, we found the
descriptions of the affected environment, environmental
consequences, and standards and guidelines to be thorough
and conscientious. We did feel, however, that the sections
on monitoring were somewhat vague and lacked specificity.
The Department is concerned about the proposed conversions
of extensive acreages of native rangeland to monocultures of
an introduced grass species. These conversions, if
initiated, should be carefully weighed and monitored, so
that conflicts with little known wildlife species do not
develop.
Thank you for the opportunity to review and comment on this
proposed Resource Management Plan. Additional comments and
concerns are attached.
4. We have two proposed additions to the BLM priority access
map L-l shown on an enclosed map. Public access is desirable
through both of these pieces of private property to improve the
general public's opportunity to use BLM land. These areas are
popular for deer and elk hunting. Presently, locked gates in
these areas hinder hunter use of large blocks of public land.
5. The preferred Alternative C proposes to control brush on
15,540 acres of deer winter range and seed crested wheatgrass on
9 , 460 acres of deer winter range. We would like to see a map of
where these proposed projects would occur. The conversion of deer
winter range from shrubs to grassland is of concern to us.
However, we cannot adequately respond to the effects of this
proposal on wildlife without more information.
6. Appendix 5, Table 1 lists proposed wildlife range
allocations by allotment. This table shows elk use of forage to
be 10Q£ competitive with livestock. Our experience with elk in
this area shows some spatial differences in the habitat used by
elk and livestock. Elk use is high in areas not favored by
livestock, such as steep slopes, dense Mountain Mahogany/Juniper
thickets, and dry ridge tops. Limited research data is available
to precisely calculate the overlap in forage use between elk and
livestock. However, considering the differences in habitat use,
we do not believe that 100% of the forage elk consume is
competitive with livestock.
7. Map SS-l Special Status Species - chapter 3-28. This map
should show the western snowy plover nesting habitat at Seiloff
Lake. We have enclosed a map with the Seiloff Lake habitat
delineated.
8 1 Chapter 2-3 : Monitoring. The detailed monitoring plan
should have been part of this plan for all to review. We have no
way of knowing how well plans and projects described in the plan
will be monitored. Changes at the time of the "Proposed RMP/Final
EIS" are always more difficult to make than for the Draft. ODFW
will have review comments and specific recommendations when the
Monitoring Plan is available.
enclosure
Department of Fish and Wildlife
506 SW MILL STREET. P.O. BOX 59, PORTLAND. OREGON 97207
January 19, 1989
Following are review and recommendations pertaining to BLM' s
Draft Three Rivers Resource Management Plan by Oregon Department
of Fish and Wildlife.
1. Some California bighorn sheep habitat was omitted on map
SS-l, chapter 3-29. We have enclosed a map with the additional
bighorn habitat in red. This omission was discussed with the
Three Rivers Resource Area wildlife biologist and he corrected
their master map on 12-1-89.
2. We also have an addition to the mule deer winter range
map WL-i, Chapter 3-30. The corrected deer winter range line
comes to the base of Dry Mountain and is shown in red on the
accompanying map. This correction was also added to the BLM
master overlay on 12-8-89 by their wildlife biologist.
3. We recommend three changes on the Lsnd Tenure Zone map L-
5 for preferred Alternative C. These changes are shown on an
enclosed map and are described below. All three of these areas
should be in Zone 1 because they are critical winter range.
A. The Dry Mountain area winters approximately 200 elk
and 500 deer during portions of the winter and also provides good
summer range for these species. The BLM put a guzzler near here
in 1989 in cooperation with the Rocky Mountain Elk Foundation to
provide water for the deer and elk in this area.
B. This area delineated near the Silves River Canyon
has approximately 40 elk at times during the winter.
C. The third area near Coleman Creek had about 200 elk
for two months during the severe winter of 1988-89.
ODFW recommends BLM ownership be retained and private
land be acquired, when available, on these important winter
ranges.
9. Chapter 4-25, Aquatic Habitat: We applaud the Bureau's
decision to remove livestock from streams in poor condition.
However, the decision to replace livestock on those streams once
they have improved to fair condition seems to be perilous. ODFW
recommends that a qualifying statement be attached. It should
stipulate that once livestock are replaced, the stream's
continued progress will be closely monitored. If it is found that
the streams condition does not improve for two consecutive
monitoring periods, livestock will again be removed. In these
instances, livestock should not be replaced until the stream's
condition improves to good, or a completely new grazing strategy
has been developed. Once a stream's condition has been improved
to good, condition and trend should be monitored at least every 3
years. If a downward trend begins to develop, immediate
corrective action should be taken.
10. chapter 4-28, Wetland/Playa/Meadow Habitat: Alternative
C states that the Three Rivers portion of the Burns District
Wetlands Habitat Management Plan would not be implemented until
1997. Why wait 7 years to address critical issues, when a habitat
management plan has already been completed? We recommend that you
give Wetlands HMP plan implementation a higher priority.
11. chapter 4-29: It is stated that an estimated 1500 acres
of playa habitat would be adjacent to crested wheatgrass seedings
in Alternative C It goes on to admit that those acreages of
playa adjacent to the seedings would have a downward trend. It is
important to recognize that it is not only those acreages of
playa that will be impacted. There is an significant habitat
component in the edge effect of those playas that will also be
lost. Is it necessary that those seedings be placed adjacent to
playas? ODFW recommends that a buffer of at least 300m be
maintained between crested wheatgrass seedings and any playa t
wetland, or meadow. This will help maintain the edge component of
those habitats, protect the integrity of fragile environments,
and conserve avenues for wildlife to utilize the playas,
wetlands, and meadows.
12. Appendix 2 - Table 2, Item 4b; ODFW recommends the
insertion of the word ALL before the word commercial. Also, this
section should be more specific in regard to retention criteria.
As written, it leaves one with the impression that there is no
need to retain conifers within the buffer zone. The retention of
conifers is necessary to maintain bank stability, provide
replacement snags and perches for raptors, and to furnish a
continued source of large woody debris. This section should be
re-written to recognize and follow the guidelines provided in the
1979 Interagency Riparian Guide.
A provision should be made in this section that addresses the
retention of snags. All standing snags, within the buffer zone,
thnt can be safely retained, should be. At a minimum, snags
should be maintained at level at least 60 percent of potential
Appendix 11-28
(100% of potential in riparian zones). Additionally, all standing
live trees which grade 60 percent cull or greater should be left
standing to provide replacement snags.
Item 4c: The statement is made " Areas of vegetation left
along a stream do not have to be a certain width". This seems to
be a rather significant digression from statements made within
the body of the document, and in table 2. In both places,
precise descriptions of the width of buffer strips are provided.
The widths of the buffer strips are correlated with the steepness
of the slope (e.g. a 40-50 percent slope would have a buffer
strip of 125 feet, measured horizontally, on each side of the
stream bank. Table 2 . 1-5) . ODFW believes that the establishment
and maintenance of defined, delineated buffer strips is a
necessary prereguisite to the development of a sound stream
protection program, we suggest that you clarify or delete item 4C
from appendix 2-4 . This would serve to reduce confusion with the
document and would provide for a much more sound, comprehensive
riparian management plan.
TABLE 2.1: MANAGEMENT DIRECTIVES BY ALTERNATIVES
2.1-2 water QUALITY: Overall the standards within this
section are excellent. We commend the BLM for the obvious
commitment to rehabilitation and protection of the riparian
resource and water guality. The five year cessation of grazing on
80 miles of stream in poor condition is a particularly
commendable decision. It will provide badly damaged riparian
areas with much needed respite; so they will truly have the
opportunity to begin recovery.
In reference to the statement: "...implement grazing systems
which allow no more than 10 percent livestock utilization on
woody riparian shrubs, no more than 50 percent total utilization
on herbaceous riparian vegetation, and no more than 3 0 percent
utilization on herbaceous upland vegetation...". Is it intended
that each criteria operate as a limiting factor independent of
the others? For example, if 50 percent utilization is attained in
the herbaceous riparian vegetation, but there has only been 10
percent utilization in the upland herbaceous vegetation, will
grazing be terminated for the season because one of the limiting
criteria has been met? Any grazing system that is based on
constituent monitoring criteria should contain such 1 imitations .
A simple qualifying statement should be added which stipulates
that the season's grazing will be terminated when maximum
utilization is reached in any one of the three constituent
monitoring criteria. The benefits of such a stipulation are two
fold. It prevents the over-utilization of any one component of
the grazing system. It also encourages the stockman to manage
livestock in a manner that promotes more even utilization of the
forage available.
2.1-21 ITEM 1: The statement "Maintain 30-60 acre
blocks. . .so that 40 percent of the forest treatment area remains
in suitable big game thermal and hiding cover", should be changed
to read "...so that 40 percent of the RA that is managed for
timber production is retained as suitable big game thermal and
hiding cover. Not less than 15 percent of the area should be in a
thermal cover condition at any one time". ODFW further recommends
that monitoring for the cover retention criteria be tied to sub-
watersheds, and not averaged over the entire RA. This provides
for a much more manageable and comprehend ible land base. Also,
should a problem begin to develop, the management area is small
enough that it will become evident before the condition
deteriorates too far. The buffering effect is simply too great
when monitoring for compliance with retention criteria are
averaged over a large land area (i.e. the entire RA) .
2.1-21 ITEM 5: There should be a time line attached to this
statement. Ten years would be reasonable. Also, verbiage should
be added which stipulates that all residual metal products, that
remain from the old style fences, will be removed.
2.1-29 ITEMS 1-5 DNDER WARM-WATER FISH HABITAT: All of these
action criteria should be tied to a time line.
2.1-43 ITEM i! All applicants for electrical transmission
lines should be required to follow criteria outlined in item 1
under alternative B.
Attachments.
Prepared by:
Darryl M. Gowan
Forest and Rangeland Staff Biologist
Habitat Conservation Division
How will monitoring sites be distributed along the riparian
corridor or pasture management system? A provision should be mode
so that utilization monitoring is not solely based on an average
of that component of the entire pasture management system. That
is, without specific provisions, it would still be possible for
isolated portions of the* management system to be severely
overgrazed while the average utilization for that component still
fell within the described parameters.
2 . 1-5 ; ITEM 11 : The statement is made that vegetative
conversion will be restricted in any area within 1 mile of
perennial water, to less than 20 percent of that area in any one
year. Additional verbiage and clarification is needed here. The
way that this is written it would be possible to completely
convert all lands within 1 mile of perennial water within 5 years
(the reviewer assumes that "vegetative conversion" , in this
instance, refers to conversion of native rangeland to crested
wheatgrass) . An upper limit is needed on total acreage, within l
mile of perennial water, that could be converted. ODFW recommends
that not more than 40 percent of the total acreage, within one
mile of perennial water, be converted.
2.1-9 item 5: The word THERMAL should be inserted after the
words "big game"
item 7: Specific direction for the retention of dead and
down woody material is needed here. Suggest adherence to USDA
Handbook 553.
2. 1-17- Special status Species. No mention is made of the
western snowy plover. This species is listed as Threatened by the
state and is federally listed as a candidate 2 species.
Management practices should be designed to protect snowy plover
nesting habitat.
2.1-19 Item 14 under the preferred alternative is excellent.
ODFW also recommends that domestic sheep be prohibited on all
current or proposed bighorn sheep ranges. Their use is not
compatible with that of bighorn sheep. Such prohibitions are
necessary for the development and maintenance of successful,
productive bighorn sheep populations.
7-1 Refer to response 1-11.
7-2 Tills omission has been corrected (see Map SS-1, PRMP/FEIS).
7-3 This omission has been corrected (see Map WL-1, PRMP/FEIS).
7-4 We are accepting the recommendation to include the referenced lands
in Zone L. Data utilized in the DRMP/DEIS showed these areas
bordering elk winter range. This coupled with the unconsolidated
public land pattern in the areas, was our rationale not to designate
them Zone 1 in the DRMP/DEIS- The new data you have provided has been
Incorporated and the lands changed to Zone 1 In the Proposed Plan.
See Map LR-1.
7-5 All lands included in Zone 1 are considered retention/acquisition
areas. The definition of 7,one 1 lands in Table 2.27, PRMP/FEIS has
been modified to include acquisition.
7-6 The two additions recommended have been included in the Proposed Plan
for priority access. See Map LR-3, PRMP/FEIS.
7-7 Refer to response 5-5.
7-8 The proposed big game allocations table has been revised (see WL
Table 2.13). Also, refer to response 2-10.
7-9 The map has been revised to reflect this habitat. (See Map SS-1).
7-10 Refer to response 5-17.
7-11 Current riparian pastures and enclosures are monitored no Less
frequent than 3-year Intervals, In all but two cases, this monitoring
has been yearly for the first 5 years of exclusion or a change to a
system designed to Improve riparian areas. See the revised management
actions for riparian and Appendix 1, Table 4 In the PRMP/FEIS. Also,
when livestock are again permitted in riparian areas, the use will be
Intensively monitored.
7-12 Full implementation of the Wetlands HMP will be achieved by 1997.
Projects within the plan have been implemented from 1976 to the
present. The 1997 date was determined based on past and projected
funding for wetlands. Nothing in the plan precludes an earlier full
implementation date.
7-13 The standard procedures and design elements have been amended to
reflect the 300 meter playa buffer. The reference to the seedings
being adjacent to playas was not meant to infer that all sagebrush
would be removed up to the playa edge. Also, refer to response 1-19,
7-14 Adding the word "all" would clarify this statement which is intended
to be a minimum requirement statement. In reference to Table 2.1,
statement 4, "all streamside vegetation (including conifers) will be
protected where fish, wildlife and water quality can be affected."
The same applies to the DRMP/DEIS Table 2.1-7, Alternative C, item 4.
Appendix 11-29
7-15 Currently, standing snags are only designated to be felled if they
present a hazard to timber operation crews. The current practice is
to leave commercial sized trees unmarked if they are within a
hazardous distance of a standing snag. Current BLM Wildlife Tree
(snag)/Down Log Policy is to follow the concept developed by Thomas,
et si., in USDA-FS, 1979.
7-16 DRHP/DEIS, Appendix 2, Table 2 (4.c) is changed In the PRMP/FEIS,
Appendix I, Table 2 to read: "Areas of vegetation left along a stream
are correlated with the steepness of the slope."
7-17 No response required.
7-18 Refer to responses 1-1 and 2-7. Also, see PRMP/FEIS, Appendix 1,
Tabic 4.
The Proposed Plan will remain unchanged. Section 503 of FLPHA states
that utilization of rights-of-way in common shall be required to the
extent practical. Bureau policy, as expressed in Bureau Manual
2801. 13B. 1, Is to encourage prospective applicants to locate their
proposals within corridors. The decision to encourage right-of-way
applicants to locate within designated corridors will also provide a
valuable tool for right-of-way project planning while allowing for
flexibility where colocation is not practical due to environmental,
economic, safety, national security or technological reasons. Each
right-of-way application, whether proposed within or outside a
designated corridor, would be subject to NEPA review and mitigation
to reduce or eliminate unacceptable Impacts.
7-21
Detailed utilization monitoring for those systems not employing
early, short-duration grazing will be Implemented on a case-by-casi
basis through the EA, Allotment Evaluation or AMP process. Also, si
PRMP/FEIS, Appendix 1, Table 4.
Upon further review, it has been determined that no vegetative
conversions are proposed within 1 mile of perennial streams or
reservoirs which support fish.
The word "thermal" has been added. See
the Proposed Plan.
nagement action WL 1.1 of
other proposed bighorn sheep
7-22 Refer to response 7-15.
7-23 Refer to response 3-11.
7-24 See Proposed Plan, SSS 2-1. There are
release areas in the planning area.
7-25 The 40 percent hiding and thermal cover by treatment area Is used
because the actual cutting units in a particular treatment area are
in close proximity to one another. This will result In cover areas
being available in each treatment area. It Is correct that no less
than 15 percent should be in thermal cover condition at any one time.
See management action WL 1.1 of the Proposed Plan.
7-26 The statement refers to new fences which shall be built to standards
during the entire life of the plan.
7-27 With reference to warmwater fish habitat management objectives, Table
2.1-29 of the DRMP/DEIS.
Item 1 would be implemented as new reservoir construction
opportunities develop,
Items 2-5
document.
Duld be implemented over the life of the planning
January 30, 199
Bureau of Land Management
Burns District Office
Att. Joshua L. Warburton
HC 74-12533 Kwy 20 West
Hines, Oregon 97738
Mr. Joshua L. Warburton,
. FEB 7 1990
BURNS DISTRICT BLM
Following are my comments concerning "Draft — Three Rivers
Resource Management Plan and Environmental Impact Statement.
The Draft inadequately addressed and evaluated a number of
natural resource problems, resource use allocations and competitive
use determinations. In addition, the analytical -techniques used
to determine resource condition, potental and trend need reviewed
to better reflect field conditions and new research information.
BLM range personel, most knowledgible about biological conditions
in the field, should be giver, the responsibility to develop
progressive AMP ' s and futuristic improvement plans.
The BLM's management directive of "fostering the wisest use of
our land and water resources" and "to effectively manage the basic
resources of the public rangelands to improve and maintain economic
and environmental needs" (FLPHA, PRIA) . emphasizes the need to meet
and manage for the basic soil, water and economic needs of the
RA. Nonuse and restricted management alternatives will not meet
the basic biological and economical needs of the area, therefor
alternatives A — D are illegal and alternative E should be rewritten
to reflect intensive and progressive management of oil of our
resources and uses. The RMP unfairly infers intensive management
has commodity emphasis.
The RHP unfairly blames livestock grazing for poor watershed con-
ditions ignoring the dramatic influence of ecological succession
upon the area due to fire suppression. Recent research by Buckhouse,
Gaither, Eddleman, Miller, Angell , Young and Evans clearly shows
the need to emphasise and manage for serai successional stages to
limit and prevent erosion, manage for water — -elated needs and
provide wildlife needs twenty years and later in the futv.re. A
CRKP group of natural resource educational and research specialists
reviewing research under'.; ay ir. the area felt very strongly juniper
encroachment due to ecological succession was the major watershed
and wildlife concern of the area and that the biological changes
will become critical within the next twenty to forty years wit?
long term and permanent ranif icatiens.
Vegetative manipulation is neccossary to achieve the cptinur. desired
watershed conditions for all resources and uses — progressive
livestock grazing can play a complementary role. Exclusion of
livestock without vegative manipulation will have negligible
.benefits to longterra watershed needs.
;The' described potentials obviously failed to consider intensive
management "and use of available technologies. Resource areas
inadequately considered are watershed improvements, wildlife habitat
enhancement livestock forage improvement , timber management and
recreation development. Prescribed fire, conditional burn desig-
nations and individual tree treatment needs to be emphasized to
a greater degree in the RKF. The archaic cover requirements
listed for big game are rediculous and ignore the biological
realities of the area. In fact, forage quality and predators
are the short term Uniting factors for deer populations while
elk populations are increasing rapidly due to excess forage quantity
in the area. Juniper encroachment has attributed to decreased
bitterbrush and other preferred deer forage areas. Future habitat
requirements need to be readdressed in view of recent research
on juniper encroachment. Junipers are increasing at an exponential
rate with severe negative impacts to all resources.
Existing resource conditions have improved for a number of years
and the RHP ignores this improvement especially in the riparian
and upper watershed areas. This does not mean we can not do even
better and BLM range personel and livestock permittee's are con-
tinually wording together for multiple use and resource improve-
ment inspite of internal BLM nor.iaanagenent interests. Five, ten
and twenty year ecological trend plots would show improved conditio- s
and allow land managers to separate natural ecological changes from
changes caused by resource use.
Proposed livestock grazing reductions are based upon resource data
from two drought years and poor growing conditions. A minimum
of seven years of trend data is needed to properly reflect resource
changes and the causes of chance. The stated utilisation levels have
nothing to do with proper management nor wildlife and watershed
needs. Timing and duration of use need to be emphasised in
establishing AMP changes and permitted livestock use. For instance,
heavy utilisation early ir. the growing season can provide high
quality regrowth to meet critical nutritional needs of deer later
in the year when quality of forage is normally cot available. The
sane early use of riparian areas can accelerate resource improve-
ment in many areas.
The RMP violates or insuf f icently add: Rssed objectives 1, 2, 4,
5 and 7 of FLPMA 202 A. The RIIP fails , to abide by and manage
for sustained use of watershed quantity and quality. Longterm
benefits to wildlife from vegetative manipulation through burning,
shrub planting and grass seeding outweigh short term impacts.
Water development and forage development are also important com-
ponents to sustained yield, long term needs and diversity of wild-
life habitat. The potential benefits to the local economy and the
general public were not fully considered.
parate and allocate levels
emphas
In addition, the RMP attempts to
use to resolve conflicts instead of emphasizing the biolocical
factors causing the problem. Heat uses aro compatible Wits each,
other if properly included in the planning process — the allocatic
of resource uses to different areas or land units is unnecessary.
Management opportunities received inadequate emphasis in the RMP
Appendix 11-30
which also violates Sec. 302 (b) FLPMA requiring the BLM to
prevent' unnecessary or undue degradation of the lands I e.g.
intensive juniper control to meet watershed needs).
Stated management objectives for the various resources . will not be net.
Preferred alternative amplifies problems ana conflicts m the area
bv failing to fully consider benefits of intensive management
alternatives. Apparently, the realities of the field were lost
in the state office. The technically inaccurate methodology to
describe benefits and impacts for each management alternative are
good examples of programed polarization of interests and issues.
Plans to restore suspended nonuse should be included in the final
RMP with no decreases in permitted AUM's in the area. A CRMP
review and a takings implications assessment (TIA) be made of
the reduced permit which is required by Presidential Executive
Order 12630. It has been brought to my attention that a number
of Oregon State grazing leases were voided following the land ex-
change between the BLM and the State of Oregon. These grazing
leases should be reestablished or a TIA be made within six motithc:.
For example, the 43 AUK grazing permit en the former State land
next to the Diamond Craters Natural Area has a very valuable
historic use to the permittee and can not and should not be revoked.
This eighty acre area along with the other proposed addition
should not"1 be added to the Katural Area for biological, economic
■and lack of unaltered character reasons.
Horse wooulations in HMA's should not be allowed to exceed maximum
numbers under any conditions. Vegetative sianipulation and other
management technologies should be fully considered in HlIA's to
optimize watershed management and wildlife objectives. Forage
needs within the area should be met and provided by the HKA —
livestock permits should not be moved to other areas.
The BLM bad no legal authority in moving the Beatty's Butte 'cross-
bred ranch horses (now known as Kiger mustangs) to the Riddle and
Kiger areas. The previous horses in these areas originated from
the Snvth herd and outside horses not indigent to area should not
be in this area. Furthermore, there is no justification for
establishing the Kl-lA's as an ACEC and will face a legal challenge
that could move the horses back to their original area.
The outlined breeding program and bloodlines should be proven
genetically by an unbiased research concern and when proven false,
the program should be dismantled. The program appears
peting with private enterprise in additior
validation. Long term lar.d management objectives should be the
main F.MP consideration. The Deep Creek Allotment (5330} historically
had no horses and should not be included in the Kiger MM& and -the
livestock permittees should be required to put a wire across
ampronriate gates to keep horses inside HK&'s. The Deep Creek
Allotment is a small area having a resricted use and trailing area
With two and three wire boundary fences. Hunters, fishermen or
backpackers are bound to push, these horses through the boundary
fence causing conflict with adjacent property owners and very
expensive horse gathering ccsts paid by the taxpayer.
be con-
aching scientific
The alternatives presented In the DRMP/DEIS meet the legal
requirements specified in FLPMA (1976) as defined in 43 CFR 1610, et
seq. and Bureau Manual 1601-1625.
Refer to response 6-8.
Vegetation manipulation has been considered as one method of
improving forage condition (see DRMP/DEIS Table 2.1-11 and Appendix
3, Table 7).
Use adjustments are based on a minimum of 3 years of actual use,
utilisation and climate data. The estimated capacities listed In the
DRMP/DEIS are projections only. Timing, duration of use and stocking
rate will be established through allotment specific evaluations,
agreements and AMPs.
See PRMP/FEIS, Appendix
response 2-11 .
1, Table 11 on methods. Also, refer to
The entire DRMP/DEIS is based on the principles of multiple-use (see
Table 2.1) and sustained yield. The document was prepared by an
Interdisciplinary staff of 16 different specialists representing over
20 resources (see List of Preparers, p. 6-2, DRMP/DEIS). The
interdisciplinary team has relied upon numerous data sources ranging
from very recent monitoring and evaluation data (see Appendix 3,
Table 6) to historic data dating from the mld-1960's. The
interdisciplinary team has considered both present and potential uses
of the public lands (for example, refer to the Energy and Minerals
sections (pp. 3-49 to 3-56 and 4-48 to 4-54, DRMP/DEIS). Thorough
consideration of the potential rangeland and wildlife habitat
benefits from various vegetation manipulations, prescribed burns,
water developments has been presented in the DRMP/DEIS (see pp. 4-8
to 4-12; Appendix 3, Table 6; and Appendix 3, Table 7).
Sec. 302(b) of FLPMA requires the Bureau to regulate use of the
public land to prevent unnecessary or undue degradation of the lands.
This section does not apply to biological processes such as juniper
encroachment.
The Bureau is required to periodically review grazing preference
under 43 CFR 4110.3 and make changes in grazing preference status
where needed. The Bureau Is also required to reduce active use if the
use exceeds livestock carrying capacity as determined through
monitoring. Increases and decreases in active use will be allocated
in accordance with 43 CFR 4110.3-1, 43 CFR 4110.3-2, and Oregon BLM
Manual Supplement 4100. 06C. Refer to Appendix 1, Tables 9 and 11 ia
the PRMP/FEIS.
Refer to response 2-63 for TIAs.
Disposition of State grazing leases on lands acquired by the BLM
through State exchanges were handled in accordance with Oregon BLM
Manual Supplement 4100.061. In the majority of cases, State leases on
lands acquired by the Bureau were converted to active preference on
the permittees license.
Land tenure adjustments are in the best interest of the public
as long as the adjustment is in the form of a land trade or
exchange and not in the form of the government purchasing private
land. In addition, there must be two willing parties involved
in the exchange with no undue pressure exerted (e.g. exclusion
of grazing in an area unless....).
Wild and Scenic P-iver Designation will have a negative impact
upon future management needs of the area. Watershed needs will
not be met so no new designations should be proposed os supported
by the BLM.
Many times the worst possible way to protect an area of critical
environmental concern is to designate it as such., Some things
we advertise to death instead of protecting through 'management.
ACEC's need to be identified and monitoced without advertisement
and exclusion of use. No new ACEC's should be established under
the present system.
In surma,
not in t'.
nor is i
resource
areas. '
sound no.
for
suppo
the
ti
:."oo?.
ng
gr;
it appea:
technclg;
question
resource;
to be mo:
the svst'
y, exclusion of use particularly livestock gra2ing, is
e best interests of the socioeconomic needs of the area
necessary. Intensive grazing management can accelerate
improvement in plays, wetlands, reservoirs and riparian
he described utilization objectives are not technically
justified — heavy utilization is very beneficial if
right duration and at the right time. The technical data
_ grazing decreases appears to be inadequate and based
lization instead of long term trend data therefor no
reductions should be implemented at this time. In addition
s a full range of progressive management practices and
es were not considered in the planning process. Without
the main problem of the area negatively impacting all
and uses is juniper encroachment. Juniper control needs
e actively persued and fire allowed to become a part of
em in a oreccribed manner.
Thank you for considering the information presented and. my concerns.
If you have any questions please give me a call.
sincerely
Fred I. Otlev
-y
Diamond, Cr D772?
(503) 493-2702 or
(503) 493-24G9
Bob Smith
Secretary of Interior
Oregon State Director
Historical use is not relevant to the disposition of former State
uses. The permittee in this case will not lose these AUMs; however,
final shifts of use cannot be made until the Drewsey reallocation.
The Wild and Free-Roaming iiorse and Burro Act and 43 CFR 4700 group
do not prevent the movement of horses from one HMA to another.
Returning selected horses to HMAs is an accepted practice of
improving the quality of certain herds. Currently, the BLM's main
method of disposing of excess horses is through the adoption program.
Increasing the quality of the wild horses improves their chances for
adoption. The Drewsey, Andrews and Riley Management Framework Plan
amendment for management of seven wild horse HMAs was approved on Hay
29, 1987. This plan amendment addressed this very Issue. The single
protest was considered and rejected by the Director, as he affirmed
the Bureau's legal option to move horses between HMAs.
Refer to response 2-68.
The wild horses in the Kiger and Riddle Mountain are of a distinctive
color and type in that they have the phenotypical appearance of
Spanish Mustangs and by today's standards are a breed of horse. The
dun factor color pattern which they possess Is that of primitive
horses. Blood studies done by equine serology laboratories of the
University of California and the University of Kentucky have shown
that genetically the Kiger Mustangs most closely resemble equine
breeds of Spanish origin. These breeds include the Campolino,
Chlllean Criollo, Argentine Criollo, Peruvian Paso Fino, American
Paso Fino, Puerto Rico Paso Fino, Spanish Mustang Registry, Luistano,
Andulusian and Mangalarga Marchador. It is Important to manage and
preserve this unique kind of horse on the range because they are the
best representation of the Spanish Mustang running wild on public
lands today.
The main goal in managing every herd is to maintain a thriving herd
In balance with other uses In the area. Over time, this results in
healthier animals with Improved conformation.
Kiger Mustangs do not appear to be competing with private enterprise
at this time. Quite the contrary. Members of the public who own
Spanish Mustangs are diligently seeking Kiger Mustangs to improve
their own animals. Also, the small number of Kiger Mustangs entering
the market place, compared to the total market, is negligible.
There was an error on Map WH-1 in the DRMP which has been corrected;
see map of the FEXS/RMP. The suggestion of a horse wire across
boundary gates is a practical and viable option and may be
incorporated into the individual Herd Management Activity Plans.
Refer to responses 4-14 and 6-10. The use of coercive measures In
Federal acquisitions is prohibited by the Uniform Relocation
Assistance Real Property Acquisition Policies Act of 1970.
Appendix 11-31
«2
Oregon Trout 9
Speaking out for Oregon's fish
P.O. Box 19540 • Portland, Oregon • 97219 • (503) 246-7S70
February 12, 1990
Cody M. Hanson, Area Manager
Three Rivers Resource Area
U.S. D.I. , Bureau of Land Management
Burns District Office
HC 74-12533 Hwy 20 West
Hines, OR 97738
Draft Three Rivers Resource Management Plan (RMP) and
Environmental Impact Statement (SIS]
Dear Mr . Hanson:
Oregon Trout thanks you for this opportunity to assist the
Burns District Bureau of Land Management (ELM) in the
planning process.
Our comments will follow this format: organization
description, discussion of areas of main concern including
comments on the planning documents, and summary.
ORGANIZATION DESCRIPTION
Oregon Trout is a state-wide non-profit conservation
organization focused on restoring, protecting, and
maintaining Oregon's wild (native, indigenous) fish and their
habitats. We are primarily a volunteer group, with only
three full time paid staff and approximately 1400 members.
Oregon Trout i-s an advocate for the fish and their habitats;
we are not a fishing club.
DISCUSSION Of. CONCERNS
Planning Documents: Content arid Stvl e: The planning
document!; have noticeably improved in quality, in volume of
detail presented, and in style of presentation. The wealth
of detailed maps togethe
Directives by Al ternatives
th Table 2. 1 ffanaqegi
:nt
rere especially helpful. Oregon
Trout also appreciated the concept behind including the
"Summary" information found on pages iii-vii. Several
elements of that information were confusing rather than
helpful: errors in or absence of totals for streamside
riparian habitat, aquatic habitat condition, wetland habitat,
and pi ay a habi tat trend.
OREGON TROUT COMMENTS Page 3
2/12/90 Draft Three Rivers RMP/EIS
Aquatic vegetation can return to a degraded stream reach with
one year's full rest. Thus one example of a meaningful,
measurable redband trout objective would be, under "Restore
or enhance habitat of special status species:" (Table 2.1-6)
Restore/protect redband trout habitat
beginning with the 1990 dry season such
that native aquatic vegetation is present
in healthy (reproducing) condition by
cold season weather that year.
ft long term objective for that same species then could be:
Protect/maintain redband trout habitat to
maintain year-round healthy populations of
native aquatic plants from 1990 growing season
throughout the life of the management plan
for the health of the resident fish and to
comply with the Clean Water Act of 1987 and
the requirements of the Oregon Department of
Environmental Quality.
Planning Docunn
district
Issues--Water Quality., et al ..:. The
f erred alternative sends a mixed message to
Oregon Trout on water quality, special status species,
wetland/reservoir and meadow habitat, riparian habitat,
aquatic habitat. The stated objective for water quality is
Protect or enhance ground water quality
and improve water quality of streams on
public lands to meet or exceed quality
standards for all beneficial uses as
established (per stream) by Oregon
Department of Environmental Quality (DEQ) -
[Table 2.1-2]
The stated management action is to "Remove livestock for
years from approximately 80.9 miles of stream with poor w
quality." Oregon Trout recognizes that this action will
the greatest probability for "the most rapid riparian
recovery. " Such removal will permit aquatic vegetation t
grow and remain in the streams where such vegetation is
native, thus providing year-round recruitment of fish
"forage" and habitat for aquatic insects and
macroinvertebrates . Native vegetation such as Alisma,
Elodea, Vallisneria, Naiadaceae, and members of the
Potainogetonaceae, Juncaceae, Typhaceae, and Cyperaceae
families may reestablish populations which will moderate
OREGON TROUT COMMENTS Page 2
2/12/90 Draft Three Rivers RMP/EIS
OREGON TROUT COMMENTS Page 4
2/12/90 Draft Three Rivers RMP/EIS
From a fisheries perspective, it woi
totals of stream miles/aquatic habit
condition classes defined in "Table
Evaluating Aquatic Habitat," Appendi
illustrating the total stream miles
unknown condition, as well as bar g
habitat condition and current ripari
trend (acres and stream miles) by al
helpful . Such graphs would show at
public riparian and aquatic zones i
well as those needing to be invento
healthier condition according to the
criteria. The style of presentation
Tables 2-3 of 5, and 1 of 6, require
out, total, and compare this valuabl
the totals and percentages and prese
simple bar graph form would most cle
riparian/aquatic conditions in the r
Id be helpful to include
at meeting the various
2. Criteria for
x 6-3. Bar graphs
in poor, fair, good, and
aphs illustrating wetland
an habitat condition and
lotment would also be
a glance the percent of
need of restoration, as
ied and those in
Bureau's evaluation
used in Appendices 5-6,
s the reviewer to select
e information. Including
nting that information in
arly and usefully state
source area.
In Appendix 6, Table 1. Aquatic Habitat, it would be helpful
to have the streams listed according to watershed, and in
order from headwaters downstream. It is helpful having the
allotment listed in which the stream segment is found , having
the allotment numbers would facilitate use of the detailed
allotment number map. Of the maps provided, the high
contrast F-l is the easiest to read. Having maps with
streams, lakes, and mountains/buttes shown is very helpful.
It would also be helpful to note the habitat locations of
Oncorhvnchus (redband trout) and Cottus bairdi ssp. (Malheur
spotted sculpin) on Map SS-1 , "Special Status Species." The
district might also want to superimpose on Map SS-1, "Special
Status Species , " those areas in the preferred alternative
which the district is considering to convert to crested
wheatgrass cattle forage (46,960 additional acres or an
additional 2.7% of the 1,709,918 acres of public lands in the
resource area, 5% or 85,496 acres of which are already
seedingc for cattle forage). Those acres intended for brush
control (61,275), prescribed burning (8,260), and juniper
burning, control-wood cutting 12,393) also need to be
designated, preferably on Map SS-1.
Statement of objectives in Table 2.1: For these objectives
to be consistently meaningful, achievable, and capable of
being evaluated, the statements need to include an
, implementation (or target) date. Particularly with respect
to water quality and fish habitat objectives, it is desirable
from Oregon Trout's perspective that target dates be set for
varying habitat condition stages rather than setting a single
distant (year 2000, or 2010 for example) target date.
water and soil temperatures while providing habitat for other
species now absent from these miles of "poor water quality"
streams.
These instream plants are an integral element of healthy
stream systems with water quality conditions meeting or
exceeding DEQ standards. They provide essential fish and
fish prey habitat while moderating flood events and stream
temperaturen (maintaining cooler water temperatures with
higher oxygen content in warm weather and warmer water
temperatures preventing "anchor ice" formation in winter).
With streamsi.de vegetation, the aquatic plants filter out
instream debris and sediments, a vital water quality
function.
Even, small numbers of livestock (as few as 2 or 3) grazing
aquatic areas can remove instream vegetation in a matter of
days, setting back stream recovery to mere vegetative
expression. Oregon Trout has observed in the Trout Creek
Mountains, the Crooked River National Grassland, and the
Crooked River basin, to name only three examples, that
grazing cattle in riparian zones leads to the removal of
instream vegetation before or simultaneously with the grazing
down of streamside vegetation (riparian) . This is
particularly true regarding the "water weeds".
Overhanging banks, like instream vegetation, are early
victims of cattle grazing riparian/aquatic zones. Meaningful
riparian recovery is measured not just in the presence of
some vegetation during some months of the year, but in terms
of stream morphology and water quality year-round. Resident
fish require such year-long habitat (which comprises less
than 1% of the public lands east of the Cascades in Oregon) -
Special Status Speci ■.-, and Habi tat :
Knhancement (ompha;;i.5 on fish, the!
Pi-fit. •■:'- <: i1:'!! , !■'•-■ u t ■ 't ■:< t. j o/_!_,.
h a h i l- a t i ricludinq water
quality) : In determining which management actions
implement (including system rest from consumptive use) to
achieve ripari an/ fisheries/aqua tic/ wet land ob jecti ves , it is
important to remember the obvious: fish are limited to
aquatic habitat and are extremely vulnerable to habitat
degradation . Restoring fish habitat to support viable native
populations and protecting and maintaining that restored
system requires regular, intensive monitoring of the effects
of management actions. That restoration, protection, and
maintenance may or may not require human physical
intervention (instream structures, pool construction, etc. ) .
Such labor and funds may be better spent hiring personnel to
Appendix 11-32
OREGON TROUT COMMENTS Page 5
2/12/90 Draft Three Rivers RMP/EIS
OREGON TROUT COMMENTS Page 7
2/12/90 Draft Three Rivers RMP/EIS
serve as fish habitat "watchdogs" (rangers) to guarantee
compliance with management plans focused on fish habitat
recovery and protection, and to ensure adequate monitoring
and data collection.
It is Oregon Trout's understanding that compliance with the
1976 Federal Land Planning and Management Act (FLPMA)
requires the Bureau to elevate to equal management standing
and consideration (with traditional consumptive values such
as grazing) those resource values previously relegated to
secondary consideration or worse. Oregon Trout is aware of
the role of Bureau range conservationists in land management
planning. Since Ron Wiley's departure, how involved have
fisheries biologists with specific expertise in the needs of
the native fishe3 of the resource area been in the process
which produced the draft RMP/EIS?
How involved were native plant botanists and hydrologists
throughout the process? What did they have to say about
giving redband trout/Malheur spotted sculpin habitat a brief
rest from grazing until the habitat reaches "fair" condition,
which is minimal fish habitat condition, then resuming
grazing? Is this the preferred management action for special
status fish species' habitat? How does such action meet the
needs of those species and comply with the Endangered Species
Act of 1973? Such professionals need to be actively
consulted and involved throughout the planning process to
insure that the needs of the area 's native fish and plants ,
songbirds and waterfowl, small mammals and big game species,
aquatic insects and reptiles, etc. , will be met by the
Bureau ' s preferred alternative .
Oregon Trout raises these questions because it is our
understanding, since the February 5, 1990, Portland meeting
with several of the planning team members, that the actual
preferred action is to temporarily remove cattle from an
unspecified number of stream miles OR to employ unspecified
grazing systems "which are widely recognized as promoting the
most rapid riparian recovery practicable..." (Table 2.1-3,
4.) Early spring and/or late winter grazing were mentioned
in this context. This is not what Table 2.1-3, 4. states.
Oregon Trout is not aware of any grazing system which
promotes "the most rapid riparian recovery practicable." In
riparian/aquatic recovery of a degraded, or "poor" condition
stream system, the importance of an initial period (several
to 15 or more years) of complete rest has been recognized by
government resource managers such as Oregon's Wayne Elmore of
Prineville, as well as by conservation groups such as Oregon
Trout. Examples of improved stream conditions, including
What Oregon Trout is hopefully conveying to its public lands
managers in the Three Rivers Resource Area is this :
Management contemplating or planning to
restore aguat ic/riparian acres, to alter
existing native plant communities deemed
to be in "poor" or early serai condition,
or to be in need of "rehabilitation"; need
to consider then manage to provide what
the native fish, mammals, birds, insects ,
and plant species, etc., inhabiting or
migrating through that acreage need to
maintain viable (capable of sustaining
healthy, reproducing) populations. At the
same time, those managers need to manage
to implement management actions which will
result in DEQ- approved water quality and
in heal thy, stabilized soils . These need
to be the driving focus for the Bureau.
Juniper removal, for example, needs to be viewed from this
perspective, where juniper provides the only or major cover
for wildlife, or the major or only remaining stream shading
then cutting or removal needs to be delayed until stream and
riparian vegetation has recovered to provide the cover and
habitat now provided by the juniper. Juniper (Juniperus
occidentalis) is native in the West. The spread of juniper
has been tied to conditions resulting from nearly a century
and a half of overgrazing in Oregon. Caution should be
exercised when considering removing all or the majority of
juniper in any one watershed- -phreatophyte is not a term
automatically designating an undesirable, or "bad" plant
species. Juniper are a native and important element in
■healthy watersheds .
Biodiversity and Interdependency : Speakers at the February,
1990 American Fisheries Society conference (Welches, OR)
included many who spoke in recognition of the values of
biodiversity. The speakers came from a variety of
disciplines including social and biological sciences , but did
not limit their focus to their own disciplines. The
interdependency of all components of any given ecosystem was
emphasized again and again. Oregon Trout has often cautioned
resource managers to consider this interdependency and the
values of biodiversity (genetic and species diversity) .
'Oregon Trout asks now what specific effects are anticipated
from altering vegetation? How are brush control and water
quality linked? What effects on water quality does research
show will result from 61,275 acres (3.6% of the Three Rivers
ORKGON TROUT COMMENTS Page 6
2/12/90 Draft Three Rivers RMP/EJS
water quality, native fish populations, and fish habitat can
be found around the state. Removing livestock is effective
in the rapid recovery of riparian and aquatic zones. Oregon
Trout would like to know (specific and complete references)
what scientific studies identify cattle grazing as "promoting
the most rapid riparian recovery practicable..."
Whether the livestock are effectively removed through fencing
or through intensive herding with daily supervision, the
results can be similar if the livestock operator is dedicated
and committed to complying with livestock exclusion from the
recovery area. It is also important in establishing the
removal of livestock from the miles of poor water quality
stream that the recovery area acreage be removed from
computations determining the number and type of livestock to
be permitted in the affected allotment.
Oregon Trout would like to receive information on the
specific literature and studies which prove and/or support
the utilization percentages (10% on woody riparian, 50% on
herbaceous riparian, and 30 percent on herbaceous upland
vegetation) referred to in the planning documents. We do not
understand how these levels will result in "poor" condition
stream miles achieving the stated Bureau water quality
objective. Also, Oregon Trout does not understand, from the
information provided, how the upland utilization level will
result in desirable soil and water conditions.
Vegetation Manipulation/Alteration other than Grazing:
Regarding any wildfire rehabilitation done, Oregon Trout
would recommend that any species planted be limitod to those
native to the specific affected area. Also, fire
rehabilitation should not become an excuse to seed crested
wheatgrass, which already comprises 5 percent of the public
lands in the Three Rivers Resource Area. Oregon Trout is
concerned with what soil, hydrologic, and native plant and
animal effects result from seeding crested wheatgrass.
Biodiversity and the health of native species is not served
by seeding non-native plant species. The cost in dollars to
seed native species has been argued to be uneconomical by the
Bureau. However, the real cost in ecosystem biodiversity
(number of native plant and animal species present and /or
using the seeded area, number of populations and of diverse
native plant and animal communities present) and in
water/soil system health (quality, quantity, and composition)
is incalculable — and should not be dismissed merely because
no specific dollar amount can be attached to these important
values.
OREGON TROUT COMMENTS
2/12/90 Draft Three Ri
RA public lands) receiving brush control actions? What
effects on groundwater and area surface water will result
from developing 21 springs, 96 reservoirs, and 10 wells?
Will these developments decrease surface flows in already
poor water quality condition streams, aggravating known
annual climatic "stresses" (hot, dry summers; below-freezing
winter temperatures) on these streams? Specifically, how
will these developments result in compliance with Oregon
DEQ's water quality standards? How will they result in
meeting or exceeding these standards? How will altering
.present vegetation achieve these results?
Off-Road Vehicles (ORVs) Management: Oregon Trout is also
concerned with the effects of Off-Road Vehicles on the public
lands, and especially on aquatic/riparian/wetland zones.
Oregon Trout is aware of compliance and enforcement problems
in south central, northeast, southeast, and central Oregon
with ORV operators who refuse to keep their vehicles out of
streams, riparian zones, wet meadows, and other sensitive
areas. Native fish, wildlife, and plant species suffer from
this abuse. Once an area becomes known to some ORV
operators , it is nearly impossible to prevent continued
abuse. One stream area in south central Oregon, the Klamath
Basin, has been repeatedly fenced and posted. Yet ORVs
continue to violate the designated management efforts by
driving through the fencing, after cutting the fencing.
These violators use the riparian zone and stream bed for
their purposes with no regard for the values they are
destroying.
"How will allowing or permitting ORV use to increase comply
with FLPMA's strictures for multiple use? Mow will ORV use
of public lands achieve compliance with Oregon DEQ's water
quality standards, with the Clean Water Act of 1987? How
will ORV use on the public lands of the Three Rivers Resource
Area achieve sustained yield of native fish species, of
riparian plant species? Of native songbirds, small mammals,
big game, reptiles, amphibians, insects (especially aquatic
macroinvertebrates) ? Will such use help maintain visual
resource values? How?
I FLPMA mandates the protection of a variety of land resource
'* values. The Act speaks to the prevention of undue and
unnecessary degradation of those resource values. How will
ORV use accomplish or comply with this stricture?
Appendix 11-33
ORECON TROUT COMMENTS
2/12/90 Draft Three Ri
Page 9
RMP/EIS
for fish populations (see PRMP/FEIS, Table 2.
Table 4).
notes and Appendix 1,
COMMENT SUMMARY
Oregon Trout's concerns in brief are:
1. Riparian and Aquatic Habitat Protection, Restoration, and
Maintenance
2. Fish Species Protection, Restoration, and Maintenance
3. compliance with FLPMA, the Clean water Act, Oregon DEQ's
Water Quality Standards, the Endangered Species Act, the
Bureau of Land Management's Riparian Policy (1987
national and state of Oregon), the Bureau of Land
Management's Fish Habitat Management Pldn (1989), and all
other applicable laws, regulations, policies, and rules
4. Active Consideration of Biodiversity (species,
communities, and individual popul a t. i ons)
5. Active Consideration of Interdependence' (species, et al.,
and actions )
6. Strict Control of Off-Road Vehicles on Public Lands
7. Regular Scientific Monitoring of Results of Management
Actions, Particularly with Regards to Oregon's Native
Fish and Their Habitats
Please contact Oregon Trout if you have any questions
concerning these comments. Thank you aqain for the
opportunity to participate in the planning process. We look
forward to your response.
Sincgrelv.^ , _
Kathrecn Simpson Myron
Associate Director, At-Large
158 SW 11th Avenue
Canby, OR 97013
Ph:
503 2GG-1263
Bill Bakke, Executiv
Mike Crouse/Chad Bac
file
Director
n, Oregon State Office, BLM
Restoration and protection of redband trout and Malheur mottled
sculpin, habitat is implicit In the selection and implementation of
the Preferred Alternative. With the removal of livestock from 38.8
miles of riparian habitat presently in poor condition, and
implementation of grazing systems along 30.4 miles of fish habitat
that restrict utilization of riparian vegetation, short-term
objectives of restoration of fish habitat would be reduced.
With selection and implementation of the Preferred Alternative, the
realization of long-term objectives of protection and maintenance of
restored habitats, and compliance with State and Federal water
quality laws are fully attainable within the life of the management
plan.
Refer to the Proposed Plan for monitoring actions delineating methods
of data collection and evaluation. Funding and workmonths for these
activities will be allocated through the District's Annual Work Plan
submitted to the Washington Office.
Information concerning development and evaluation of a monitoring
plan was included in Volume I, Chapter 2-3 of the DRMP/DEIS.
The BLM does monitor use and utilization on grazing allotments. Range
conservationists evaluate site potential, develop grazing
methodology, evaluate seasons of use and visit sites prior to and
after the period of use to assess utilization. Any unauthorized
activity is noted and duly reported to management, where it becomes a
management decision to act upon those activities.
The production of the RMP has been an interdisciplinary effort
throughout. Individual sections have been prepared by the appropriate
specialists and those specialists Interacted directly with management
in the process of compiling the Preferred Alternative. In addition,
the document was extensively reviewed by District and State Office
program leads and other specialists at several stages of development
prior to final printing. Ron Wiley's departure occurred shortly
before preparations for printing, so he was involved in all
substantive analysis, Interaction and composition. The position has
since teen filled with a professional fisheries biologist.
Refer to response 9-11.
Management actions WL 6.1, 6.2 and 6.3 of the Proposed Plan are the
revised management actions. Also, refer to response 5-10.
The wording in the management actions has been revised; however, the
riparian objectives have not been changed, and riparian habitat in
poor condition with the potential for water quality to reach fair or
better will be excluded for 5 years or until fair Is reached at which
time a grazing system would be Implemented. See management actions WL
6.1, 6.2 and 6.3 of the Proposed Plan.
Information displayed In the DRMP/DEIS summary table was incomplete.
This has been corrected in the summary in the PRMP/FEIS.
Streams and stream miles that met various condition classes were
presented in the DRMP/DEIS, Appendix 6, Table 1, p. 6-2,
Additionally, Volume I, Chapter 3-27, Table 3.10, presented a summary
of streams in each condition class. For additional information on
derivation of condition classes, refer to response 2-25 and Appendix
2, DRMP/DEIS.
It is acknowledged that, for some individuals, a graphical
presentation of data is more effective than a tabular display.
However, the most pertinent information necessary to support factual
analysis and decision-making processes is provided in tabular form.
With limited staff, time, and budget for document preparation, it was
determined by the Planning Team Leader that the staff's efforts would
be better expended on concerns of a more primary nature in the
PRMP/FEIS.
DRMP/DEIS, Appendix 5, Tables 2 and 3 and Appendix 6, Table 1 have
been modified to facilitate interpretation.
The BLM provided Map WQ-1/Water Quality, in Volume I of the
DRMP/DEIS, to facilitate identification and location of important
streams and their tributaries. To facilitate coordination of Map WQ-1
with Appendix 6, Table 1, stream names were reorganized and listed
according to DEQ Nonpoint Source Assessment of drainage basins within
the Three Rivers planning area.
To facilitate comparison of data in DRMP/DEIS, Appendix 6, Table 1,
with allotment management summaries in the text, allotment numbers
were added to allotment names in the PRMP/FEIS.
The redband trout and Malheur mottled sculpin habitat have been added
to the Special Status Species Map (see Map SS-1, PRMP/FEIS). A map of
the potential brush controls and seedlngs has been added (see Map
RM-3, PRMP/FEIS). The prescribed burns, juniper burns and
control-wood cutting areas have only been proposed for general areas
at this time (see Appendix 3, Table 7, DRMP/DEIS). These projects
will be designed on a case-by-case basis through the
interdisciplinary NEPA process.
Based upon public Input and Interaction with the interdisciplinary
team and to the extent practicable, management has established
management priority criteria, and a method of reporting
implementation status regularly. Refer to Appendix 1, Table 10,
PRMP/FEIS.
Aquatic and riparian habitats were evaluated through water quality
monitoring, benthlc macrolnvertebrate analysis, traditional fish
population assessment, photo trend studies, color infrared
photography and vegetative utilization studies. The collection,
analyses and Interpretation of these data provide qualitative and
quantitative Information concerning habitat condition and suitability
9-15 Refer to response 2-4.
9-16 Refer to response 1-11.
9-17
Refer to response 1-11.
9-18 Juniper removal will not be done within riparian areas where the
trees are providing necessary shade or where they are necessary for
soil stability. Each proposed juniper removal or controlled wood
cutting area will be reviewed by an interdisciplinary EA team.
9-19 Refer to response 6-8.
9-20 The potential rangeland improvement projects discussed in the
DRMP/DEIS (see Table 4-9 and Appendix 3, Table 7, DRMP/DEIS) are
considered tentative. The detailed analyses that are requested are
better suited to the project planning level where the actual project
design is developed. Where appropriate, such analyses are performed
In the EA for specific projects. Such projects would be subject to
compliance with DEQ water quality standards.
9-21 Refer to response 1-23.
9-22 Refer to response 1-23.
Appendix 11-34
10
Executive Department
155 COTTAGE STREET NE, SALF.M, OREGON 97310
January 30, 1990
PARKS AND RECREATION DEPARTMENT
525 TRADE STREET SE. SALEM, OREGON 97310 PHONE (503) 378-6305 FAX (503) 378-5447
DATE: January 26, 1990
TO: State Clearinghouse
Joshua L. Warburton
District Manager
Bureau of Land Management
Rums District Office
r£ 74-12533,
Highway 20 W.
Hines, OR 97738
Subject: Draft Three Rivers
Resource Management Plan and EIS
PNRS #ORS9]108-012-4
Thank you for subni tt ing your Draft Resource Management Plan and
Environmental Impact Statement for State of Oregon review and ccmnent.
Your draft was referred to the appropriate state agencies for review.
The Parks Department and the State Historic Preservation Office have
offered the enclosed Garments which should be addressed in preparation
of the Final Envi ronnental Impact Stnlsnent . The Department of Land
Conservation and Development's comments will be forwarded as soon as
they are received.
We will expect to receive copies of the final statement as required by
Council of Environmental Quality Guidelines.
INTHIGOVHN1EOTAL RELATIONS DIVISION
Dolores Strceter
Clearinghouse Coordinator
Attachments
2121T
FROM: Don Eixenberger ^s£.
Research Analyst
SUBJECT: Comments: Draft Three Rivers Resource Management
Plan, Pro-j . No. OR 891108-012-4
Rec re ational Assessment.
The draft Three Rivers Resource Management Plan contains no
analyses of current or projected future recreational use in
the planning area. Lacking such analyses, it is difficult
to see how recreational needs, both current and future, can
be planned for and met. Provision of such data is crucial
in the assessment of management alternatives. The Pacific
Northwest Outdoor Recreation Consumption Projection Study
indicates substantial growth in a variety of activities in
southeastern Oregon. For example, by the year 2000, nature
viewing and study are projected to grow by 41%, RV camping
(42%), tent camping (42%), 4-wheel off-road driving (33%)
backpacking on trails (20%) , and fishing (20%) .
According to the 1988 SCORP, recreationists visiting
southeastern Oregon show diverse preferences in the setting
for their activities. For example, in terms of
Recreational Opportunity Settings , of those engaged in
hunting, 32.6% preferred a Primitive setting, 25.6% a Semi-
Primitive Setting; among campers, 7.7% preferred a
Primitive setting; 42.3% preferred a Semi-Primitive setting
Other than potential wilderness areas the draft management
plan provides no analyses of the recreational opportunities
( in terms pertinent to the ROS) available in the area.
Similarly the plan provides no analyses of other existing
or planned for developed recreational facilities (e.g.
campsites, trails) . Mention is made of Special
Recreational Management areas, but no information is
provided as to their capacities, there use, or how they
might accommodate growth in recreation.
In summary, we suggest the following be included
final RMP.
tha
Project Number
OREGON INTERGOVERNMENTAL PROJECT REVIEW
State Clearinghouse
Intergovernmental Relations Division
155 Cottage Street N. E.
Salem, Oregon 97310
373-7652
STATE AGENCY REVIEW
0R8911O0-012-»_ Date:_
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
I, R, D.
\H 2G 1390
jam 2 a \m
If you cannot respond by the above return date, please call to
arrange -an extension at least one week, prior to the return date.
d I
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
[ ]
[ ]
This project has no significant environmental impact.
The environmental impact is adequately described.
We suggest that the following points be considered in the
preparation of a Final Environmental impact Statement.
No comment.
REMARKS
Ag e ncy \'.\rj<\
IPR #5
By Pcv-- ^J^j^h^u^x^j.
Phone Number_iT8^J*5g,3_
State Clearinghouse
January 26, 1990
Page 2
1. an assessment of current and projected recreational
use by activity type in the Three Rivers Management
Area.
2. an analyses of the diversity of recreational
opportunity offered by the area in terms of the ROS
and formation of alternatives which would _ offer
supplies of these opportunities commensurate with use
levels identified in the 1988 SCORP.
to
10-6 |
a recreational facility development plan
accommodate projected increase in use.
fuller description of existing SRMA's including their
capacity and projected use.
5. identification of existing and potential recreational
conflicts in the area and management options to
resolve them. This should include both those
conflicts with other resource uses and those among
competing recreational uses.
6. rationale and criteria for ORV limitations should also
be presented.
(Note: The state Parks and Recreation Department is
available to provide certain types of data from the SCORP
to assist in developing several of the above items.)
Wild,, and Scenic River Designation
Segments of three rivers were assessed for eligibility and
potential classification. All but one segment were deemed
ineligible. However, no description of the criteria and
processes used to deem these segments ineligible is given.
This should be provided in the Final RMP.
Segment A of the Middle Fork of the Malheur/Blue Bucket
Creek was determined to be eligible. On page 4-41, it is
stated that the recommended classification is "wild" in
preferred Alternative C. Vet in the summary on page vi, no
stream miles are allocated for Wild and Scenic Rivers under
Alternative C. This should be corrected in the final.
In two alternatives, recommendations for designation would
not be in effect or pursued. In other alternatives,
recommended classification are either wild or scenic. No
rationale or criteria are provided for these differences.
Our feeling is that designation and classification
Appendix 11-35
State Clearinghouse
January 26, X990
Page 3
questions should be independently decided^ and not be
contingent on large land management alternatives.
Historically, once a river has been determined to be
eligible, the next step is to conduct a suitability study
to determine the appropriate classification. Before a
decision is made regarding designation, interim management
would entail protecting existing values within the
potential corridor. This interim management should be the
same across all land management alternatives.
Visual Resource Management
Visual management areas are mapped, but again, criteria and
overall management goals are not provided. The plan should
illustrate how visual resource management complements
recreational byways and areas. How would visual management
relate to the issues raised by the section under
recreational assessment?
For example, it appears that an extensive section of the
Desert Trail route is to be managed as Class _ IV,
modification of the landscape character. Is a higher
class, such as Class III, partial retention, possible
through this area? What would be the resource trade offs
of such upgrading?
In closing, the present range and content of management
alternatives provided do not offer a discernable range of
options, especially with regard to recreation. provision
of more data and analyses, as suggested, would allow some
focus on recreational issues and resources in the area .
From these, it would be possible to reshape the scope of
alternatives in ways which would allow the public some
definition of choice with regard to recreational resources.
DE: jn
CLEARING. MMQ
cc: Dave Talbot
Gail Achterman
10-1 Analysis of current and recreation use in the RA has been noted in
the Proposed Plan utilizing both the Statewide Comprehensive Outdoor
Recreation Plan 1988-1993 CSCORP) and the Pacific Northwest Outdoor
Recreation Consumption Projection Study: Oregon Project (NORPS-ORP).
However, the Recreation Opportunity Spectrum (ROS) inventory has not
been completed for the RA and current visitor use data is lacking in
some instances.
10-2 Analysis of Special Recreation Management Areas (SRMAs) and
recreational facilities has been added to the Proposed Plan where
information is available as well as the items noted in your
summarization. Please note that Item No. 3 is an activity planning
action which is more detailed in scope and is scheduled for intensive
use areas after the RMP is finalized. Activity plans will be written
for SRMAs (Chickahominy Reservoir and Diamond Craters) to address
recreation and interpretation. Please refer to response 1-23 which
discusses off-road vehicle management directives.
10-3 Refer to response 10-2.
10-4 Refer to response 10-2.
10-5 Refer to response 10-2.
10-6 Refer to response 10-2.
10-7 Refer to response 10-2.
10-8 Refer to response 10-2.
10-9 Refer to response 3-6, and to PRMP/FEIS, Tables 2.17, 2.18, 2.19,
2.20 and 2.21 which address your comment. The Wild and Scenic Rivers
Inventory for the Three Rivers RA is available for inspection at the
Burns District Office.
10-10 Refer to response 9-1.
10-11 Designation and classification of proposed Wild and Scenic Rivers
will not be independently decided from land management alternatives.
When displaying the range uses of natural and commodity resource
values by alternatives, there are publics who see Wild and Scenic
River designations having a great influence on what is allowed or
restricted on river reaches and are aware that management actions of
rivers designated wild, scenic or recreational can be quite different
from each other. Some publics note the cumulative effects of
management recommendations for Wilderness, Wild and Scenic Rivers,
RNAs, ACECs and SRMAs on large land areas. Therefore, we will
continue to have proposals for the Middle Fork as either Wild, Scenic
or no proposal at all in the way of alternatives.
10-12 Interim management is an integral part of the Wild and Scenic River
designation process and will be the same across all land management
objectives.
OREGON INTERGOVERNMENTAL PROJECT REVIEW
State Clearinghouse
Intergovernmental Relations Division
155 Cottage Street N. E.
Salem, Oregon 97310
373-7652
Rcoewso
novOiM"7'1
TAT
AGENCY
REVIEW
Project Number 0 R 8 9 1 1 0 U " 0 1 2 ~ 4Return
10-16
Date:^
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
If you cannot respond by the above return date, please call to
arrange an extension at least one week priori to the return date.
/!»„,.. JZr^irjU. krJJ M At*.
^7
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
[ ]
[M
[ ]
This project has no significant environmental impact.
The environmental impact is adequately described.
We suggest that the following points be considered in the
preparation of a Final Environmental Impact Statement.
No comment.
REMARKS
pwa
Agency -^ ij fu
Please: coiji/.i,i u
Phone Number fiHSEfl AT 378-5023
Visual Resource Management CVRM) objectives for the four VRM classes
are noted in the PRMP/FEIS glossary of terms (VRM Class 1-IV). The
objectives have been added to the management actions for VRM in the
Proposed Plan. As yet, there are no designated back country byways in
the RA, but other special management areas {Map ACEC-1) such as
Malheur River- Blue bucket WSA, Stonehouse WSA, Diamond Craters
ONA/ACEC, Silver Creek RNA/ACEC and Middle Fork Malheur River and
Bluebucket Creek primitive management area, as well as Appendix 8,
DRMP/DEIS note areas which are also given VRM classifications of I or
II. It can be illustrated how VRM complements these areas by
comparing maps of existing designated areas. The potential areas are
often not In the protective classes, but will be when designated If
the special featureCs) warrants it.
It is possible that the visual foreground of the Desert Trail be
managed as Class III rather than Class IV where the trail traverses
the latter management class. However, portions of the trail route
established in the RA are within livestock seedings which contain
roads, pipelines, troughs wells and tanks. These human developments
were in place before the Desert Trail route was established.
Proponents of the trail consider this visual environment as much a
part of the hiker's experience as the less Impacted high country and
mountainous sections.
There Is a portion of the trail route yet to be established through
the RA and, when It Is completed, a proposal to change VRM can be
made where the trail is on Bureau-administered land and developments
are not In place.
Reshaping the scope of alternatives would not produce a setting other
than that already shown by the document. The majority of recreational
opportunities will not be affected to any degree by any of the
alternatives and a statement is made that the overall changes to the
recreation activity are not considered to be significant (DRMP/DEIS,
Chapter 4-35 through 4-41). Intensive use areas are few in this RA
and the Bureau does not intend on enhancing intensive use by
construction of developments other than Chickahominy, Diamond Craters
and several small proposals such as viewing areas and trails.
Extensive recreation and unstructured uses are the main recreational
pursuits in the RA and will continue without major impacts from any
of the issues brought forth In the RMP process.
Various opportunities to protect particular cultural resource
properties and values are presented in the Proposed Plan. Traditional
Native American sociocultural use areas, certain historic sites and
particular prehistoric sites are proposed for Interpretation or
conservation.
Appendix 11-36
Audubon Society of Portland
515! N.W. Cornell Road
Portland, Oregon 97211)
503-W2-6S5S
February 10, 1990
Mr. Craig M. Hansen
Area Manager, Three Rivers Resource Area
BLM
HC 74-12533 Hwy. 20 West
Hines, Oregon 977 38
Dear Mr. Hansen:
The Audubon Society of Portland (PAS) is an organization of some
6,000 members who are interested in wildlife and protection of
natural ecosystems and wildlife habitat. Many of our members use
the Three Rivers Area for recreation and wildlife viewing. The
Conservation Committee of PAS speaks for the Society on
conservation issues. We have commented on BLM management plans
and recommendations for a number of years, and are pleased to
have an opportunity to make some suggestions for the Throe Rivers
Draft RMP.
We've organized these comments as follows:
I. General comments on organization and adequacy of the draft.
II. Specific page by page comments, suggestions, and corrections.
III. Comments on the Preferred Alternative as described in Table
2.1.
I. General comments
the
aft.
We appreciate the level of detail and specificity you have
written. We are pleased that Burns management is making this
level of commitment to planning, and that you have written an RMP
which you intend to be a meaningful document for its life.
We also want to compliment you on Table 2.1. It is easy to use
and win continue to be useful for following implementation and
tiered planning .
The draft contains a number of management objectives and actions
in the preferred alternative that we support; for example,
positive actions to protect special status species and
designation of some new ACECs/RNAs. We have three major
suggestions for improvement, however.
a. We propose that you strengthen the document as an BIS. The
analysis of potential environmental impacts is, at times,
incomplete and superficial. It won't be adequate for tiering,
and your future EA's will come under more criticism as a result.
Areas that particularly concerned us will be mentioned in the
page-by-page suggestions below.
Page 3
control program, but no one does an analysis of how grazing
programs affect grasshoppers. There is a well-documented
relationship between grasshopper infestations and bare ground.
We believe that this EIS should consider the impact of the
grazing program on the likelihood of grasshopper control
problems.
p. 1-8. Management Objectives. The objectives seem reasonable,
but we guestion whether the natural resource objectives set in
the Plan can be met without a long term reduction in AUMs. We
support the natural resource objectives, and ask that AUMs be
reduced.
p. 2-3. Criteria. We are pleased to see your criteria fur
vegetative diversity and water quality for the preferred
alternative. Although wildlife diversity is closely tied to
vegetative diversity, it is also a useful criterion. Perhaps the
criterion could be more broadly stated as ecosystem diversity.
We are also pleased to see that you want to provide for public
enjoyment of a broad spectrum of recreation opportunities on BLM
land. See the birding/wildlife viewing point above.
p. 2-3. Monitoring. Monitoring is extremely important. We are
sorry that you did not provide a draft monitoring plan in the
Draft so that we could comment. Five years is too long an
interval for monitoring in an RMP with a life of possibly no more
than 10 years. We suggest that budgeting, available funding, and
how money is spent be an important part of monitoring the RMP and
that the Area Manager review progress on management objectives
and spending every two years.
p. 3-2. Ground water quality. Although data are not now
available, the RMP and EIS are not complete without management
objectives and analysis dealing with the issue. We suggest that
the final propose a plan for gathering data in cooperation with
other appropriate agencies. Similarly, data on ground water
quantity should be gathered as well.
You should also start a program to measure and monitor surface
water quantity at all seasons over time. We know that livestock
grazing changes the level of water tables and rate of run off.
An appropriate measure of improved rangeland condition would be
data showing a trend toward year round flows on streams now
intermittent and greater flows in the summer and fall for larger
streams.
I p. 3-3. We'd like to see you quantify the data on Map S-2 and
monitor progress toward reducing soil erosion.
Page 2
b. You have an opportunity, not taken in the Draft, to
strengthen your wildlife and recreation programs in the Burns
District. More and more people use the public lands for values
other than traditional commodities, and your program should grow
and change accordingly. We checked with the Malheur National
Wildlife Refuge and found that they recorded 35,000 visits during
1988. More than 32,000 visits have been recorded each year for
the last 15. with the exception of perturbations from the
flooding, the number of visitors grows each year. The Malheur
Field Station reports that they hosted 8,500 visitor nights
during 1989. These people are coming to see birds and other
wildlife, and they are looking on BLM lands as well as on the
refuge. The RMP doesn't mention birding and wildlife viewing as
a recreation use, or factor in its value to the local economy.
c. The Plan proposes extensive range developments, and says that
the projects are needed in order to meet both your objectives for
natural resource improvement and your proposed number of AUMs.
If the conflict between AUMs and other objectives can only be
resolved by such extensive development, the number of AUMs exceed
the carrying capacity of the land.
Some of the range developments are no longer acceptable to much
of the public (e.g., seedings to nonnative species, pipelines to
ungrazed grasslands), and others won't be funded. If the range
developments don't proceed, what assurance does the Plan offer
that natural resource objectives will be met? We'd like to see a
stronger, more convincing commitment to restoring degraded
riparian systems, wetlands, and grasslands.
We believe that the Plan needs to be more realistic about the
livestock grazing carrying capacity of the land in both the short
and long term. The difference between 50,000 AUMs in
Alternative A and 162,000 AUMs in Alternative C is too large.
II. Specific . paqe-by-paqe comments.
ni. Summary. Some of the data in Alternative D dii
consistent with this being the No Change alternative
Quality {Stream miles) improving, for example, seems
with miles deteriorating on Table 3.1. We couldn't '
initial stocking levels to ot-her numbers provided in
Is the improvement in Livestock forage condition con:
trend? Aquatic habitat condition (stream miles) doe
Table 3.1. etc. In the Alt.c, is Wild and Scenic Ri
Designation to be 0 as in the Summary or 5.4 as in T
We didn't check all of the numbers, but these few er
that there may be others.
p. 1-5. Grasshoppers. APHIS does an EIS for their program,
area-specific EA's are done by the BLM for the grasshopper
siste
n't
seem
tar
nsistent
the
Draft.
nt with
tie to
blc
rors
2. 1?
sugges
Page 4
p. 3-16. Rangeland development projects. Interesting data would
be a five-year report on range projects completed, cost, and
funding source. What percentage of Range Betterment Funds have
been spent for riparian improvement and wildlife habitat
enhancement? What percentage of these funds do you intend to
spend for these uses during the life of the RMP?
Regarding maintenance, from our point of view all exclosures and
riparian zone fences are livestock management fences. Why else
would they be needed? Maintenance has been a serious problem,
and we'd like to see more resources dedicated to maintaining
these kinds of projects once the investment has been made, end
stronger enforcement of maintenance agreements.
A useful table would add the proposed projects in the preferred
alternative to the existing projects in Appendix 3, Table 5. If
the names mean the same thing, you propose to increase seedings
by 37%, miles of pipeline by 56%, and acres of brush control by
400%. Our organization values the public land in a natural
condition; you cause us a lot of grief with this proposal. The
EIS should address cumulative impacts.
p. 3-17. Wild horses. Wild horses and burros are not natural,
and management that increases their numbers does not belong in
Alternative A. Alternative A should settle resource conflicts
between wild horses and burros and native wildlife in favor of
native wildlife and ecosystems. We would prefer that Alternative
C minimize numbers of wild horses and burros where there are
conflicts with native ecosystems.
p. 3-21. We appreciate your support for the Oregon Natural
Heritage Plan.
p. 3-25. Special status species. We are pleased that you have
incorporated concern for these species into management, but we
would like to see more detail on how these species are doing in
the Three Rivers Area. Ferruginous hawk and Western sage grouse
are two species that need more attention in your management
plans. Map SS-1 shows leks and Ferruginous nests. Is your
inventory complete? What data do you need to collect? We'd like
to see protection for these species strengthened in the Preferred
Alternative.
p. 3-26. Raptor habitat. An inventory of raptor nests and
habitat in the Three Rivers Area would be a useful goal in the
RMP. You have proposed certain management actions around raptor
nests. Good data would enhance your management and allow better
monitoring.
Appendix 11-37
p. 3-34. Nongame species. Oregon Department of Fish and
Wildlife has data available on which species would be expected in
the Three Rivers Area (The Nongame Wildlife Plan). The U.S. Fish
and Wildlife Service has been monitoring trends in bird
populations (The Breeding Bird Survey: Its First Fifteen years,
1965-1979, Resource Publication 157). These documents would give
you guidance on likely habitat problems and population trends.
We would urge you to incorporate their data into the final RHP
and to address the needs of nongame species in management.
We believe that you should conduct an inventory of these species
on the Three Rivers Area so that you can monitor the effects of
management on them. Could the Portland Audubon Society be of
help in planning how data might be collected?
p. 3-34. Recreation. The text here and map on p. 3-39 should
include birding and wildlife viewing as the major recreation use
that it is in the Three Rivers. (See I, above.) Please call on
us for further information if you need help with identifying
specific areas.
p. 3-48. The text in the appendix did not support the table data
of "L" for "Vulnerable to Adverse Change" for Squaw Lake and
Saddle Butte. Livestock or wild horse grazing may threaten both-
Since other criteria for designation seem to have been met, we
request that you reconsider recommending these two sites. We
would also support your designating Hatt Butte as an RNA because
ungraded native range is so rare. We do commend you for
including six new areas as RNA's or ACEC ' s and prohibiting
livestock grazing on them. We would like to see the larger area
designated for Foster Flat.
I p. 3-49. We suggest that all RNA's, ACEC's, sage grouse leks, and
WSA's be withdrawn from mineral entry and ORV use.
Because Durns District has not yet experienced the extensive
claim staking for gold happening in Vale, we request that you
withdraw from mineral entry any areas where special cultural or
natural resources would be destroyed by mining. Also, please
refer to Rick Parrish's more specific letter on our behalf
suggesting appropriate analyses for the gold mining potential.
p. 3-59. Map H-2 is hard to use because private land looks like
moderate potential. Can you show it another way?
p. 3-67. Economic conditions. Again, birding is ignored for its
contribution to the economy. The Burns Chamber of Commerce has
found otherwise with its waterfowl festival!
Page 7
Many species of wildlife are dependent on vegetative diversity
and shrub browse or cover. The Portland Audubon Society is
strongly opposed to seeding with nonnative species and to
chemical means of brush control.
Much of the RMP text and our conversations with Three Rivers
employees suggest that this Plan is a balanced approach to
resource management. Table 4-9 documents the lack of balance.
Alternative C is far closer to the alternatives emphasizing
commodity production than it is to those emphasizing natural
values. While the draft may represent an improvement over
historical management practices, in our opinion, it does not yet
approach a balanced multiple use management scheme required in
FLPMA.
C will certa inly
portion of the
p. 4-19. Vegetation. Alternatives A, D, and
not have the same effect, on vegetation. This
environmental analysis is not adequate .
p. 4-21. Big Game Habitat. Arc different areas proposed for
seeding between Alternatives B and C? Why are 12,500 seeded
acres unsatisfactory in Alternative B and 5,500 acres
unsatisfactory in Alternative C.
p. 4-23. Raptors. The document understates the environmental
impact on raptors from seeding crested wheat. ODF £ W's Nongame
Wildlife Plan documents that virtually no native species nest and
feed on crested wheat grass. This comment applies to the nongame
paragraph and table on page 4-30 and 4-31 as well. Table 4.21
suggests a moderately positive effect on bunchgrass dependent
species from seeding crested wheat and a moderately negative
effect on sagebrush dependent species. In extensive literature
searches on this subject, we have found no literature that
supports this conclusion.
p. -1-26. Riparian habitat. Again, the document groups
Alternatives with very different effects on riparian habitat.
Although we have seen evidence that riparian systems can improve
with grazing systems, streams with no grazing improve more.
Grazed streams are never like ungrazed streams for wildlife and
fish habitat or water quality.
p. 4-28. Wotland/Playa/Meadow Habitat. Alternatives A, 13, and C
should not be grouped. You describe differences in the text.
Each alternative should be separately analyzed. Why will playa
habitat be grazed prior to July 31? I recognize that you are
trying to provide forbs for sage grouse, but doesn't grazing then
conflict with nesting birds of other species? Playas should not
be grazed at all.
Page 6
p. 4-2. Assumptions. Assumptions 1, 2, and 4 have not been true
in the past. Because they have not, we would prefer that the RMP
include a buffer for lack of funding, maintenance, and monitoring
by reducing AUM's to a manageable level without the extraordinary
measures proposed in this Plan. How will the Plan be affected if
these assumptions don't hold true? What are your management
alternatives?
I p. 4-7. Soils. Alternatives A, B, and C should not be combined
11-21 I for an EIS_ Alternative C, with 100,000 more AUMs, crested
I wheat, pipelines extending grazing further from water, etc. will
I likely cause significantly more soil erosion than would
I Alternative A.
I p. 4-7. Forestlands. Alternative A, last sentence. "The
significance of this reduction would be very high" ...on what?
I p. 4-8. Livestock grazing. Alternative A language should be
revised to be more scientifically based. The choice of
adjectives suggest that the evaluation of this alternative was
not impartial, changes in condition class are not so slow
compared to the 140+ years it has taken us to get the range into
the poor shape it is in. We disagree that the "only _ objective
that would be met would be to maintain the good condition range."
In other parts of the Plan, you discuss that Alternative A is
beneficial for wildlife, recreation, soils, water quality, water
quantity, special status species, cultural resources, etc.
Whose objective is it to provide approximately 160,000 AUMs for
livestock? If that is an assumed, unstated objective in the RMP,
we protest. This document is supposed to analyze the
environmental impacts and reach an independent conclusion about
how many AOMs the land can support.
Table 4.4 needs a more complete heading
This is Livestock Forage Condition Class,
for condition
p. 4-13. What type of brush control do you propose in
Alternative C? 61,275 acres is a lotl This document does not
adequately assess the environmental impacts of either the brush
control or the seeding. Both kinds of actions influence wildl ife
(including winter browse and cover for all animals, nesting and
feeding habitat for nongame birds, herptiles, small mammals,
etc.), water tables, soil erosion, etc. No analysis is provided
if you are suggesting use of any chemicals.
Are you proposing to alter a total of 61,275 acres or 107,000
acres? (Seeding included in brush control or separately stated?)
Page 8
p. 4-30. Special status species. Management proposed in
Alternative C is not adequate to protect sage grouse. Grazing
should be prohibited in meadows where chicks forage. Brush
control and crested wheat destroy sage grouse habitat.
p. 4-34. We support the occasional use of prescribed fire, and
allowing natural fires to burn where possible, but fires are not
adequate justification for seeding crested wheat. The
Agricultural Research Service in Reno is reporting good success
with getting Indian rice grass to germinate if seeding is
necessary, but seeding should be a last resort. Erosion is a
poor excuse for seeding crested wheat; there is usually more bare
ground between crested wheat plants after a few years grazing
than there is with native, even degraded range.
p. 4-68. Economic Conditions. This analysis is incomplete
because it doesn't consider the steadily increasing visits by
people for wildlife viewing and nonmotorized recreation. If
livestock grazing were decreased, fishing, hunting, wildlife
viewing, and recreation would probably increase. The economy ot
rural counties is changing, and the RMP ignores looking at trends
in the data.
TTI. Comments on tha Preferred Alternative .
In II above, we have made some comments about actions wc would
like to see added to or removed from the preferred alternative,
Alternative C. We've used Table 2.1 to organize the following
suggestions. The Table, a useful addition to the RMP as it is,
would be even more useful if you would add a Table of Contents so
that sections could be easily found.
water Quality... 10. Burned areas within one mile of perennial
water may well successfully rehabilitate themselves, we prefer
that you don't alter native vegetation unless unusual
circumstances warrant action.
rnre.st-.i-v .in-.] Woodlands. 5. Wc are pleased to sat that you wilJ
exclude forest management activities near raptor nests and retain
nest trees and provide perch trees.
Juniper 1. Although we agree that some stands of juniper should
be removed or thinned to increase diversity, more species of
birds use juniper/sage communities for nesting and foraging than
any other eastern Oregon community type. Please assess the value
of stands for wildlife habitat before treatment.
Appendix 11-38
Grazing. 2. We support your reducing grazing in the short terra
to improve riparian, wetland, and range condition. We think the
reduction should be greater and permanent.
3. We do not support range projects which change native
vegetation into nonnative vegetation nor water development
projects which alter natural drainages or allow livestock to move
to new areas.
4. We support your removing livestock from these areas.
Your footnote. We are pleased that you are committed to riparian
and wetland improvement even if funding isn't available for
fences.
Special status species. We are pleased to see that you will
actively work on Recovery Plans and HMPs.
Wetland, reservoir, and meadow habitat. 1. Table 2 . 1 says you
will complete implementation of the Wetlands HMP by 1992. The
text, p. 4-28, says 1997. We hope it is 1992.
I plavas — we arG pleased to see the plan for collecting data on 10
I playa lakebeds. We'd like to see your study and implementation
| schedule move up in time.
I Riparian — We would prefer you follow Alternative A, but if C is
the choice, 50% utilization of herbaceous vegetation in the
riparian area seems high. Can you get adequate recovery in
riparian systems with 50%? We're pleased that your target is no
more than 3 0% in the uplands.
Raptors. 3. Pesticides shouldn't be used for rodent control on
public lands anyway, but many raptors hunt much further than two
miles from nests.
Recreation. 2. Do not maximize the development of orvs . That
is a very harmful use of the public lands. There are more than
35,000 visitors per year, probably mostly from out-of -county , to
see birds and other wildlife. Encouraging them is far less
destructive to other resources.
ACEC 's. We are pleased that you plan to retain existing
designations and name new RNA's and ACSCs. We also support your
designating Hatt Butte and Squaw Lake as RNA's and Saddle Butte
as an ACEC. Increase the size of the Foster Flat RNA/ACEC.
The DRMP/DE1S is designed to give comprehensive management direction
on an areawide basis. Detailed analyses of specific actions are
performed through EAs and are required to be in conformance with the
land use plan. As such, the linkage between future on-the-ground
projects and the RMP will be through the analysis of the conformance
of these projects with the management objectives, directives and
resource or land use allocations made in the RMP.
Your comment on watchable wildlife Is a valid one and a management
directive will be developed to address the opportunities available on
Bureau-administered lands to enhance this use of wildlife resources.
A publication, Oregon Wildlife Viewing Guide Defenders of Wildlife,
1987, shows areas In the RA and a new BLM publication for 1991 will
also highlight areas to view wildlife.
Refer to responses 5-16 and 5-17.
Refer co response 9-1.
As range conditions improve through implementation of grazing
systems, bare ground should decrease through improved plant vigor,
increased ground cover and litter deposition. As these components
improve, the likelihood of grasshopper Infestations is reduced. The
Bureau has no control over the climate which also plays a large part
in grasshopper infestations.
Refer to response 5-17.
The BLM recognizes the importance of collection and Interpretation of
data on ground water; however, under the Clean Water Act and State
Water Law, DEQ has administrative responsibility for development and
implementation of a ground water monitoring plan. Though no plan
presently exists for Harney County, the BLM would cooperate with DEQ
and other appropriate agencies on plan development.
Vegetation composition, distribution and abundance have immediate
effects on rates of runoff, sediment deposition, lnstream Flows and
level of ground water tables. Though the BLM recognizes the
importance of monitoring surface water quantity during all seasons,
our fiscal and manpower limitations prohibit this type of activity.
The soil surface factor method (BLM Form 7310-12), which was used to
determine erosion condition classes, assigns a numerical rating to an
area. Erosion indicators such as soil movement, rills, gullies,
surface litter, pedestalling and surface rock are scored depending on
visual evidence and the scores summed to produce the numerical
rating. These ratings do not quantify the amount of soil loss in
terms of tons/acre, and at the present time there is no Information
on the quantity of soil lost from the planning area. However, the
ratings do provide a general guide as to the severity of erosion. The
numerical breakdown for erosion condition classes are stable (0-20),
slight (21-40), moderate (41-60), critical (61-80) and severe
(81-100). Addition of this numerical breakdown to the RMP would
provide no useful information beyond what is already furnished In the
document.
Please feel free to telephone if you have questions about our
comments. We appreciate the amount of time you have put into
this draft, and hope that our comments help you with your goal of
improving the final RHP.
Sincerely,
P><
.&.
Linda S. Craig ^
for the Conservation Committee
Audubon Society of Portland
The soils management objectives (DRMP/DEIS Table 2.1-6) have been
expanded to provide a basis from which progress can be evaluated. The
objectives target accelerated (human influenced) erosion as opposed
to total (geologic and human) erosion. Refer to the Proposed Plan for
a detailed monitoring program. Also, see "Monitoring The Three Rivers
Resource Management Plan" on page 2-3 of the DRMP/DEIS.
11-10 Bureau directives have required that 30 percent of Range Betterment
Funds (8100) be spent on riparian projects. The Three Rivers RA has
been in compliance with this requirement. This directive has not been
rescinded, therefore, the RMP area will continue to spend at least 30
percent of the Range Betterment Funds allotted to the RA by the
District prioritization process on riparian improvement projects.
Also, see RPS Updates (available
Office).
for inspection at the Burns District
11-11 Section 1 of the Wild and Free-Roaming Morse and Burro Act states ".
. . wild free-roaming horses and burros . . . are to be considered in
the area where presently found, as an integral part of the natural
system of the public lands." Furthermore, there are no proposed
increases under any alternative, in either numbers or size of area in
which horses will be managed. No alternative on DRMP/DEIS Table
2.1-12 and 13 showed or proposed an increase In wild horse numbers.
The numbers shown on Table 3.6 have not been changed from previous
planning documents.
Also, refer to response 2-6.
11-12 Inventory data are incomplete on sage grouse strutting ground
locations, sage grouse brood rearing habitat, sage grouse wintering
area locations, ferruginous hawk nest sites and ferruginous hawk nest
success. Inventory of new areas and monitoring of existing habitat
are ongoing. As sites are discovered, they will be managed under the
management actions described for the particular type of habitat.
Also, refer to response 3-9.
11-13 Ongoing raptor inventory will continue. Also, all types of projects
are subject to the NEPA process. During this process, on-the-ground
site-specific investigations are conducted. In the pant, several nest
sites have been discovered during this process and these
investigations will continue.
11-14 Refer to response 1-18. Also, monitoring of habitats will require an
initial inventory as the monitoring plan is being implemented. Anyone
interested In the wildlife habitat program is encouraged to offer
assistance in the formulation of data collection and monitoring
methods.
11-15 The text will be changed to Include wildlife viewing as a recreation
activity. Bird and other wildlife watching in the Three Rivers RA is
a major recreation use. However, past Inventories of which we are
aware Indicate that the major concentrations of birds and animals
viewed by visitors to the area are In Harney and Blitzen Valleys on
Appendix 11-39
lands administered by the U.S. Fish and Wildlife Service (Malheur
Refuge) and the surrounding private lands.
There is viewing of big game (specifically deer and antelope) and
nongame birds and animals in various widespread areas during certain
seasons of the year, on Bureau-administered lands. Areas of bird and
animal habitats are made known to the public through various means
(such as brochuresj talking with groups interested in certain kinds
of fauna and participating in locally sponsored activities promoting
visitor interest in watchable wildlife). We will continue to promote
wildlife viewing on Bureau lands where it is environmentally and
economically feasible.
11-16 The interdisciplinary team analyzed the text and other information to
conclude that the "L" as shown in Table 3.16, DRMP/DEIS is
appropriate. Saddle Butte did not meet relevance criteria, such that
importance criteria is not an issue. Please note there are only five
new areas being designated as ACECs. See Appendix 1, Table 16 in the
Proposed Plan for use restrictions in these areas. The Foster Flat
RNA/ACEC has been expanded to 2,690 acres. Also, refer to responses
1-26 and 3-1.
11-17 Regulations are in effect which provide greater consideration to
RNAs, ACECs and WSAs when mineral activities are proposed than such
areas would otherwise have as public lands. The cost to automatically
withdraw such areas from mineral entry, when valid existing rights or
claims are present, would be prohibitive. Sage grouse can be afforded
consideration for protection from potentially impactive agents by
means of mitigating measures that minimize any detrimental, effects
upon their habitat requirements.
ORV use has been "limited" to designated roads and trails within
existing RNAs and WSAs already. ACECs and such resources as sage
grouse are considered on a case-by-case basis given the specific
requirements of the resource at a given site.
11-18 It Is not Bureau policy to withdraw areas where special values may be
protected through surface management such as special stipulations or
through mitigation in mining plans of operation.
11-19 Map M-2 has been revised to reflect updated information; however, the
geologic information presented is general in nature and no attempt
has been made to delineate different levels of potential by
landownership. .All lands within a given potential class on the map
are projected to have that potential, regardless of ownership.
11-20 Refer to response 2-36.
11-21 The statement that Alternative C, with a significant Increase in
AUMs, seedings and pipelines will cause more erosion compared with
Alternative A is correct. However, the soil section was set up to
anticipate positive and negative trends when compared with the
current management scenario. The environmental consequences
discussion for Alternatives A, B and C were combined for soils on p.
11-31
11-32
11-33
11-34
11-35
11-36
11-37
11-38
11-39
11-40
11-42
11-43
vegetation have been revised. Sec Vegetation in the Proposed Plan.
The Environmental Consequences section has also been revised, see
Chapter 3, Vegetation. See also response 1-13.
Different areas are proposed for seeding in Alternatives B and C.
The predicted impacts on p. 4-23 of the DRMP/DEIS were not intended
to represent individual actions but implementation of the entire
plan. Littlefield et al. (1984) concluded that while abundance and
blomass may be highest in good condition range, the increased cover
may contribute to lessened availability of small mammals to avian
predators. Also, refer to response 2-74.
Refer to response 3-13.
Refer to response 1-19.
Refer to response 3-9.
Refer to responses 1-11 and 6-8.
A discussion of recreation growth has been added, see Chapter 3,
Recreation, PRHP/FEIS.
Table of Contents for Tabic 2.1
Page Page
Air Quality
Water Quality
Soils
Forestry and Woodlands
Livestock Grazing
Wild Norses and Burros
Vegetation
Special Status Species
Wildlife Habitat Mgt.
Wetland Habitat
Riparian Habitat
Refer to response 9-18.
The basis for this timeframe is the Burns District Wetlands HMP
implementation schedule. Refer to response 7-12.
See management actions WL 6.1, 6.2 and 6.3 of the Proposed Plan.
Also, the utilization levels are independent, meaning if one is
reached the livestock are removed. Also, see response 2-7.
Refer to response 1-23.
Refer to responses 1-26, 3-1 and 11-16.
2
Raptors
24
2
Aquatic Habitat
24
6
Hazardous Materials
28
6
Fire Management
28
8
Recreation
30
12
Areas of Critical
1*
Environmental Concern
34
16
Visual Resources
34
20
Cultural Resources
36
22
Energy and Minerals
38
22
Lands and Realty
40
4-7, because all three should have a positive overall effect compared
with current management on the planning area. It would be impossible
to quantify actual differences in the rates of soil loss between
scenarios using available data for the area.
11-22 The "very high" term refers to the 45 percent reduction in the annual
allowable sale volume (from 621 Hbf/year to 341 Mbf/year). Therefore,
the significance to the existing program is very high, reduced by
almost one-half.
11-23 Refer to p. 4-8 of the DRMP/DEIS for a discussion of the impacts on
livestock grazing. As the life of this plan is 10 years, changes
taking longer than this are termed very slow. In this section, range
condition is the only livestock grazing objective that would be met.
Refer to
ponse 11-23.
The citation of an objective to provide 160,000 AUMs (DRMP/DEIS, p.
4.8) was in error. AUM levels were removed from livestock grazing
objectives to allow the carrying capacity of the land to determine
stocking levels.
This has been corrected in the PRMP/FEIS.
The method of brush control to be used will be determined by the
objective of the project. There are a variety of methods which can be
applied. The acres of potential brush control are approximately 5.6
percent of the big sagebrush type in the RA. A site-specific EA will
be prepared for each brush control project to assess Impacts. At this
time, use of chemicals Is prohibited on public lands except for
noxious weed control. The BLM has prepared an EIS on vegetation
treatment which addresses the herbicide application. Until that EIS
Is finalized and a Record of Decision approved for BLM-admlnistered
lands In Oregon, chemical application is not a viable option as a
method of brush control.
See DRMP/DEIS Table 2.1 pp. 5, 15, 17, 21, 23 and 29; and Appendix 3,
Table 7, p. 3-177, for management directives and standard design
features regarding brush control.
A total of 61,275 acres are listed for potential brush control. This
figure includes seedbed preparation for seeding, as well as areas for
potential brush control only. Seeding acres are Included In brush
control acres. This overlap In acreage will be clarified in the
PRMP/FEIS.
Refer to responses 1-11 and 11-27 ■
Alternatives A, B and C do all have the same overall, long-term
impacts on the vegetation. Specifically, a positive effect on overall
vegetative diversity in the RA. However, the analysis of the impacts
of Alternatives A, B and C on vegetation did not adequately
differentiate among them. The objective and management actions for
Appendix 11-40
I-2Z-90
Robert end Carol Jensen
20180 Brings Road
Be rri, Oregon 97701
12
District Manager
SI M Purrts District Office
HC 74- 1 2533 Hvy. 20 West.
Hinea, Oregon 97738
In accordance with provisions of the Bureau Manual (Section 1622.21),
the Proposed Plan provides for the protection of 482 acres of
selected Ponderosa Pine Old Growth Forests within the RA. Maps F-3,
4, 5 and 6 display the locations of the forest tracts; Tables 2.4,
2,9 and 2.10 address various aspects of Ponderosa Pine Old Growth
Forest management.
12-3
s
12-4
1
12-5
0
12 6
D
12-7
1
12-8
i
12-9
.2-10
i
2-11
i
We vould like to express our concerns vith the Draft Three Rivers Resource Management Plan
8nd Environmental Impact Statement.
Presently, most of the range land is in only fair to poor condition and vill remain so under all
alternatives and your preferred alternative (C.) i3 an ecological disaster. The immediate goal
should be to return all lands to excellent condition. The construction of fences, pipelines,
troughs, veils, reservoirs and the planting of habitat sterile crested vheatgress at taxpayer
expense, vhen gro?i rig fees are droppi ng is unacceptable.
Nearly all reparian end aquatic habitat i3 presently in fair to poor condition. Returning and
maintaining all vater quality to an excellent condition should be Bn i mmediate goal Your
Alternative C provides only token protection or restoration.
I Your draft does not identify the extent of remaining ancient forests and does not explain how
many miles of logging roads it expects to construct.
I Bighorn 3heep habitat protection methods and impacts are not addressed. Deer and elk receive a
token ( Z%) forage allocation virile the balance goes to cattle. This is unacceptable.
Thefollovingareour recommendations:
1) Develop an alternative to restore and maintain range land in excellent, natural condition.
Cattle gracing should be reduced or eliminated where appropriate.
2) At a minimum adopt Alternative A (the Natural Values alternative) until such time as an
alternative is developed which allows for full range land, reparian and stream recwerg. The
Alternative A would at least allow for token recovery of these values.
3) Water Quality, reparian and aquatic habitat must b* improved and maintained in excellent
condition.
4) All ancient forest must he identified end protected.
5) Include all costs of construction of new roads end other range lend projects under the various
alternatives along with their environmental impacts.
6) Eliminate ell crested vheatgrass see-ding project.
7) bighorn sheep habitat protection and impacts must be addressed in tie plan and the forage
allocations within natural bighorn range mu3taota bighorn sheep entirely (no other grazing).
8) Designate the majority of tie South Fork arid Middle Fork Malheur Rivers, all of Bluehucket
Creek, and all of the Silvies River as Wild and Scenic.
9) Wildlife winter range forage allocations should have priority over livestock allocations.
Yours truly *
Robert Jensen
Carol Jensen
The Draft does not address the construction of logging roads in
miles. The forested areas within this RA have all previously been
logged and new road construction would be very minimal. Historically,
only short spur roads or road extensions have been necessary to
accomplish timber management activities. An average of approximately
30 stations C3000 feet) per year has been necessary over the past 8
years and new construction is expected to be the same or less for
future activities. Costs have averaged $76 per station ($2,280 per
year) in the past and this cost is expected to rise in correlation
with future inflation rates. This increased cost will, however, be
offset due to expected reduction in new road construction.
12-2 Refer to responses 2-10 and 2-78.
12-3 Refer to response 1-13.
12-4 The alternatives presented in the Draft were developed with full
public participation and represent a comprehensive and reasonably
achievable range of options for meeting the Bureau's full range of
multiple-use management responsibilities in the Three Rivers RA. It
is not anticipated that additional alternatives will be developed,
however, the concerns expressed were considered by management in the
development of the Proposed RMP.
12-5 Refer to response 2-44.
12-6 Refer to response 12-1.
12-7 See PRMP/FEIS, Appendix 1, Table 13 for project costs.
Site-specific NEPA documentation is prepared for each project to
assess impacts .
See PRMP/FEIS, Appendix 1, Table 12 for Standard Design Features.
12-8 Refer to response 1-11.
12-9 Refer to response 2-78.
12-10 Refer to responses 3-6.
12-11 Refer to responses 2-6 and 2-10.
13
LUT FIELD OL.._.
lObST «U7 /Jturpevf
™" 97T01
Joshua Warburton
District Manager
Burns District BLM
HC 74-12533 Hwy 20West
Hines, OR 97738
tear Mr. Warburton:
1/31/90
The Oregon Natural Resources Council (ONRC) wishes to present comments on the
Three Rivers Resource Management Plan Draft Environmental Impact Statement
(TRDEIS).
ONRC opposes the preferred Alternative C and recommends Alternative A with
modifications.
Special Management Areas
The TRDEIS recommends few areas for special protection status.
ONRC recommends:
Malheur River and Stonehouse WSA's be wilderness.
Diamond Craters inventoried roadless areas he wilderness.
Sage proposal areas: Crow Camp Hills, Behuh, and Stinking Water Country be
backcountry areas (no motorized use, no grazing or restricted grazing, no
domestic seeding development, no water developments for domestics).
Otis Mountain -Birch Creek area be backcountry.
Emmigrant Creek, and Silvia River Canyon be backcountry.
The BLM should consider a backcountry allocation for areas such as trie ones above.
Backcountry would provide protection for specific areas without wilderness
designation.
Mining
The TRDEIS should withdraw ali remaining streamsides, wetlands, springs, aspen
and scenic areas from all forms of mineral entry until a comprehensive
cummulative impacts EIS on mining is done.
Geo thermal
The TRDEIS should withdraw all lands from geothermai entry and issue no leases
until a comprehensive cummulative impacts EIS is done.
'"I
13-8 I
13-9 I
13-13
13-14
ONRC.TRRMP jw 2
Forest
No lands should be allocated to timber management or logged until a
comprehensive old growth and native forest inventory is done and an old growth
forest stystem allocation is designated, for example old growth and native forests
in the Otis Mountain -Birch Creek, Emigrant Creek, and Hay Creek areas. What are
the impacts, extent, and costs of planned logging roads 7
Fisheries, Water Quality and Riparian
Fisheries, concerns including Red Band Trout habitat, are not detailed nor are full
impacts disclosed. Current riparian and water quality conditions are mostly "fair to
poor" and the TRDEIS does not improve these resources enough. After forty years
of "management" with only slight improvements, the management condition goal of
fisheries, water quality and riparian must be "good -excellent" within ten Tears and
then ali "excellent" after ten years. We do not care what methods of riparian,
wetland, and watershed improvements are used, but "excellent" must be the on the
ground result of the TRDEI s, A full inventory of aquatic habitat and a detailed
enhancement and restoration plan of aquatic habitats, including time and costs
schedules should be done in the TREIS.
Crested Wheat Seedings and Range Developments
All crested wheat seedings should be eliminated and native species used for forage
and wildlife projects, except for isolated catastrophic fire cases where severe
erosion will occur and native species will not do the job (as generally recommended
by Oregon BLM State Director on January 23, 1990). Range developments such as
pipelines and fences should be reduced to a minimum so as not to induce cattle into
new areas that were lightly grazed in the past Benefit/cost projections for all
range development proposals should be provided.
Wildlife
The TRDEIS does not adequately address wildlife resources. Bighorn sheep and
antelope should have specific management plans for habitat protection including
full and detailed impact of the proposed action. Bighorn sheep reintroduction
plans il any should be analyzed In bighorn sheep range all forage should be
allocated to wildlife. The forage allocation for big game (deer and elk) appears to
be only 3& of total forage and yet the TRDEIS claims dramatic improvements in big
game habitat condition What defines "satisfactory" and "unsatisfactory" habitat
conditon and what detailed management actions will significantly improve big
game habitat? Winter range forage should be allocated to wildlife first and then
cattle.
*ais omci
lift UNCCILN SHEET
FICFX. OMfflW "mo I
fiORTHWtSf riLLL' .UtlU
FT FIELD OFFICE
BUS6JM
ASRUBfl). (MESON 9TJJ0
Appendix 11-41
**g<- 3
Grazing
The TRDEIS only shows an immediate 10,600 AUM decrease and then projects
increased AUM's in the future. Our experience on the ground, indicates that
overgrazing has occurred in many areas and cattle removal in some areas is the
only way to improve 965,000 acres of "'lair -poor" condition lands. Simple
management method changes will not be enough in some areas and it appears
unrealistic to not significantly decrease cattle AUM's and still show significant
improvements in other resource values such as riparian, wetland, water quality,
watershed and wildlife habitat.
Wild and Scenic Rivers
The TRDEIS is inadequate in analysis for wild and scenic rivers The Wild
recommendation for the middle fork Malheur River is commendable. Than!; you
The following rivers should also be recommended for designation
Middle Fork Malheur River - segment C
Blue Bucket Creek
South Fork Malheur River
Silvies River Segment A
Emigrant and Hay Creeks should be studied
ACEC
We commend the BLM for their ACEC proposals and would like to recommend some
changes.
Foster Flat be increased to 1,870 acres
Biscuitroot be increased to 5,250 acres
Obsidian be included at 16,900 acres
Kiger Mustang area be retained as ACEC, but be designated for protection of natural
values rather than wild horse values
13-18 I M^P5-^5d-AUS-ca-^0-ns-
One comprehensive and detailed map (1/2" scale) should be provided to show all
the land allocations together for easy comparison
Conclusion
Oregon Natural Resources Council (OWRC) looks forward to a revised and complete
TRDEIS with much more detail and disclosure of impact?.
Thanks for the opportunity to comment.
Sincerely,
Tim Lillebo
ONRC Eastern Oregon Field Office
Additionally , Table 2.1, Management Directives by Alternatives,
presented management objectives and discussed Impacts associated with
each alternative for water quality, aquatic habitat, riparian habitat
and special status species, i.e., redband trout and Malheur mottled
sculpln.
13-9 A full restoration and enhancement plan for aquatic habitats,
including costs, workmonths and scheduling was beyond the scope of
management directives for the Three Rivers RMP. However, monitoring
actions are included in the PRMP/FEIS and will be used to assess RMP
plan implementation and attainment of management objectives. A more
specific monitoring plan will be developed which will identify types
of surveys, parameters to be monitored, funding and staffing to be
allocated, and procedures for Implementation of results- These data
would allow the BLM to make site-specific adjustments in the
management plan to attain stated objectives.
13-10 Refer to response 1-11.
13-11 Range developments are used for a variety of reasons including, but
not limited to, improving livestock distribution.
Appendix 1, Table 12, PRMP/FEIS, outlines standard procedures and
design elements that will be incorporated into range improvements.
Range land developments will continue to be utilized to help resolve
resource management problems. Benefit/cost projections are not
provided for the potential projects outlined In the RMP because these
projects are considered to be tentative at this time. Further
refinements in project design at the activity planning level are
anticipated. See page 4-69, DRMP/DEIS, for the rangcland improvement
Investment totals per alternative. See Appendix 1, Table 13,
PRMP/FEIS for a general estimate of the cost per unit of the various
project types.
13-12 There are no proposed bighorn sheep reintroduction sites in the
planning area. Table 2.1-21, Item 2, and Table 2.1-23, item 1, of the
big game section of DRMP/DEIS are proposed, in part, to improve
antelope habitat. See DRMP/DEIS pp. 4-20 through 4-22. Also, see
responses 2-10 and 2-78.
13-13 Refer to responses 2-6, 2-10 and 2-11.
13-14 Satisfactory big game habitat and unsatisfactory big game habitat are
defined in the DRMP/DEIS, pages 6-11 and 6-13, respectively. Also,
see DRMP/DEIS, Table 2.1-20 through 23 and response 2-6,
13-15 Refer to response 2-11.
13-16 Refer to response 3-6.
13-17 Sec ACECs In the Proposed Plan for ACEC designations and their
acreages. Also, refer to responses 2-68 and 3-1.
The Final Oregon Wilderness EIS containing Bureau recommendations for
WSAs has been completed. Therefore, the RMP does not consider
wilderness designations or management of the areas as wilderness,
other than IMP, to protect and preserve their natural condition, as
these considerations arc outside the scope of this plan.
The Bureau has no management category for backcountry or unroaded
areas in its planning system. Backcountry allocations are not
consistent with planning guidance and thus there is no umbrella of
protection under a single backcountry designation or management
direction. Rather, backcountry becomes established and enhanced by
other resource activity recommendations such as off-road vehicle
closures, visual resource management classes, raining withdrawals and
other actions to provide protection of natural values. Also, refer to
response 13—1.
Refer to response 5-18.
Based on the DEIS analysis, there Is no reason to withdraw all lands
from geothermal entry and leasing. Appendix 9 (Tables 4, 6, 8, 10, 11
and 12) addresses geothermal leasing stipulations and development. No
cumulative impacts were forecast for up to 10 scattered temperature
gradient holes with no development projected to occur during the life
of the plan. Before any production can occur, an EIS is required
under NEPA. An EIS would address the cumulative impacts at that time.
Also, refer to response 5-18.
Refer to response 12-1.
Redband trout inventories are scheduled to begin during FY 91/92 and
would delineate age composition and distribution of the population.
These data will contribute to a Redband Trout Habitat Management Plan
scheduled for development in Fiscal Year 93. For additional
information please refer to responses 2-80, 9-6 and 9-8.
Realistic, achievable goals need to be described when identifying
alternatives and selecting a Preferred Alternative. In the Three
Rivers RA, many miles of sensitive aquatic and riparian habitats lie
adjacent to, but outside of, BLM jurisdiction. Management for
restoration to excellent conditions within 10 years was In some cases
not achievable.
Restoration of water quality and aquatic habitats were primary goals
of the Preferred Alternative. Under the Preferred Alternative, 115
miles, or 90 percent of all stream miles, would be either improved to
or maintained at good levels for water quality. Seventy-five percent
of all riparian habitat would be in good or better condition by 1.997.
Details of BLM aquatic habitat Inventories have been discussed in the
DRMP/DEIS in Chapter 3-27 and Chapter 4-3 through 4-6, Summaries of
data were provided in Tables 3.10, 3.11, 3.12, 4.1 and 4.2. Aquatic
habitat summaries were also presented in Volume II - Appendices,
Because of the many overlapping allocations characteristic of
multiple-use management, a visual display of all such allocations on
a map becomes uninterpretable. A 1/2" scale map for the Three Rivers
RA measures approximately 4 feet by 4 feet and is impractical for
this type of document. Refer to the PRMP/FEIS, Table 5.2 for program
by program comparisons.
Appendix 11-42
March 17, 1990
Mr. Joshua L. WarbutLon
District Manager
Burns District Office
HC 74-12533 Hwy 20 Wesc
Mine*, Oregon 97733
Dear Josh:
1 have been reviewing the Draft Three Rivers RMP/EIS for Che past
few weeks. From this review 1 come away with an uneasy feeling and
frankly, a low confidence level in rhe technical analysis of the plan.
Let me begin with the Forest Management, segment of your plan.
Beginning with a baseline of 13.307 acres of forestland, 3,397
acres were withdrawn because they were not commercial forestland. The
definition of commercial forestland is that which will grow 20 cubic
feet of wood per acre per year. (With a board foot to cubic foot
conversion ratio of 5.0, the commercial threshold is 100 board feet per
acre per year.) An additional 619 acres were classified as being "non-
operable" due to constraint.* such us eagle roosts, riparian zones or
wildlife habitat and subsequently withdrawn, resulting in a net
available timber base of 9,291 acres. From this an additional 418
acres is withdrawn as "Not Currently Available" for production in order
to provide cover for big game species, resulting in a total timber base
of 6,873 acres.
This was to have represented the "Preferred" alternative. However
it would appear that this is the commodity emphasis alternative, even
though it is constrained by several factors. These factors are then
Ignored in the literature, indicating that onlv raptor nest trees would
be retained; all other commercial forest land (9.900 acres in total)
would be intensively managed.
The Preferred *1 rArrwir:!"* *>-■>* further ^--rcage and eulyv.1
reductions, although there is no clear indication of need nor of what
these reductions will protect or enhance. Cover and riparian
protection goals are variously mentioned, but in fact, these goals are
already to be met as outlined in your Best Forest Management Practices,
will eh are consistent with Statu of Oregon rules and regulations.
Even more disturbing is the derivation of the annual hnrvoet
•Is,
The.
els
..11
ited
the
thfl'
when
sumpt:
the Allowable Cut was last calculated (about 10 years ago), it turned
our. to be equal to 70 board t**t per acre per year. In effect, the
average commercial forest acre was said to be capable of producing 30%
loss, volume per year: Chan the non-commerc ial threshold of LOO board
Cei
per
■ yea
fL.
od upon the
ring
I have been told that the 70 bd.
actual growth experienced in the eighty inventory plot
nearly 50,000 acres) between 1964 and 1974 in the old Burns District.
The 1984 inventory nor the site potential under intensively managed
stand conditions were taken into consideration in arriving at the 578
MBF harvest level of Che Preferred al ternative . Indeed , no current
allowable cut calculation was run. Using the site class or Fred Hall's
Ecoclasses, the average acre of forestland on che Three Rivers is
probably capable of growing three times your 70 bd. ft. estimate, thus
increasing the allowable cut 300% with no adjustment for inventory or
acreage allocations.
This may appear simplistic However, logic would indicate
tremendous error wich your current methodology.
For years T have been observing the vast tracts of BLM land in
areas like Dry Mountain, Claw Creek, Morton Mill. Emigrant Creek,
Silvias River, Silvies Valley and Drewsey with choir tremendous
ii,m-t«Hry, My oh«p.i-v,iti.n* confirmed. vh.\r 7 hs-J hoard r''i'E chtiUfi
stands were being ignored i or their timber management potential. When
one considers that the trees you are losing are worth S60IJ to $1,000
each in stutnpage, you are indeed squandering a tremendous resource,
At $350 per MBF and 1,000 MBF per year that you understate tha
allowable harvest, the Creasury is losing 5350,000 in payments plus
untold receipts as a result of the jobs created by the preparation,
harvest and processing of this volume.
Let me move now from the timber issue co other resource issues:
1)
Your data indie
feet) of scream
that you lack even 1/100 of a mile (52.8
Excellent" condition. Nor do yon project
improving any streams to excellent condition in che preferred
plan. Having seen some streams that seldom feel the
pressure of one man's boot or one cow's hoof, I must wonder
if your standards of excellence are unobtainable or your
measurement system somehow faulty.
One of the allotments with poor range condition is Kiddle
Mountain. Having pursued birds on that mo unto in, I
particularly noted che varieCy and volume of grosses present
which showed U ttle evidence of grazing, other Than an
occasional deer or elk deposition, Is chat poor range?
Considering the forage you propose to remove from livestock
and "give" to the elk, you should have nearly 600 ilk
residing exqlutlvely on BLH lends year round, When one
considers the area your ownership covers, che mix of land
ownerships and acreage devoid oT elk, you could have no more
than 10% of the elk residing on your lands. That would mean
about 6,000 head within the Three Rivers Boundary. While the
ODFW is the ultimate authority, T would dare say chac 1,500
head In Che area is a more accurate estimate, indicating that
you are only feeding about 150 head.
While Che weight of data involving cattle numbers on the
myriad of allotments and AUM's Is mind boggling t« me. T
cannot discern anywhere how conditions will be improved by
increasing, decreasing or holding constant the cattle numbers
you propose. To ma season of use. duration and intensity nf
14-2
14-3
14-4
14-5
14-6
14-7
14-8
use are far more critical. Utilization of management tools
such as prescribed burning, juniper control and favorable
forage and browse species plantings are equally if noc more
important. The DEQ proscriptions on smoke creation
(burning)are actually minor to non-existent in this area.
contrary to your stated objectives.
1 am certain that more specific comments
plan. That will have to be left for anoCher day
the official comment period has elapsed, the pc
nonetheless critical and must be addressed,
discussion wich some of your staff in which thes
14-9
14-10
tin,
Pie.
feel tx>
ntact me should you
e Issues and concept;
uld be made on your
While I realize that
:s I have raised are
I have had verbal
ssues were discussed
ive any questions or
larsonally.
Total forestland acres equals 13,307. Discussion In the DRMP/DEIS,
Chapter 3-3 indicates only 9,291 acres are commercial forestland by
definition (capable of producing 20 cubic feet per acre per year).
Therefore, 3,397 acres are classified as noncommercial forestland and
619 acres are closed as nonoperable (withdrawn-fragile site). A
further reduction of 418 acres is classified as Not Currently
Available (multiple-use constrained for wildlife cover). The
remaining 5,873 acres (timber base acres) are multiplied by the
factor of 70 which yields the existing 621 Mbf annual allowable
harvest. The factor of 70 was erroneously stated in this document and
to you personally as being a DF growth rate per acre per year. This
number is in fact nothing more than a factor used to determine
allowable cut levels. The old John Day RMP annual harvest of 3,400
Mbf was determined in the BLM's Oregon State Office allowable cut run
in 1974 and was based on an inventory of 48,818 acres. From these two
numbers, the factor of 70 was derived and used in this planning
document to determine harvest levels for all alternatives.
Alternative D, the No Action Alternative with 609 Mbf annual harvest
differs from the existing situation (DRMP/DEIS, Table 3.4, showing
621 Mbf) because the previous John Day RMP did not account for the
buffering of all nonperennial streams, springs and seeps which has
been an accepted practice within BLM resource disciplines for the
past 4 years. Until a current allowable cut Is run, based on our
latest forest inventory (1985), we believe we have used the most
logical process available to determine annual harvest levels, which
should be reasonably accurate.
Also, during the latest forest Inventory, site classes were determine
and all classes within this planning area are Class I or VI.
BLM forest standards are not being ignored for timber management
potential. Current budget constraints dictate forest management
activities which are generally confined to the more concentrated
stands of substantial size (in acres).
Refer to response 14-1.
Refer Co response 14-1.
Refer to response 14-1.
Refer to response 14-1.
Refer to response 14-1.
Refer to responses 2-25, 2-28 and 2-45.
The DRMP/DEIS does not list the Riddle Mountain Allotment as having
poor range condition. On the contrary, Appendix 1, Table 9 shows
Riddle Mountain Allotment as having satisfactory range condition.
However, Appendix 1, Table 7 does identify this allotment as having
unsatisfactory habitat condition for big game.
Refer to response 2-10.
See response 2-11. In the areas where a change in management will
achieve the multiple-use objectives for an alloCment, use reductions
will not be necessary; however, in some areas reductions will be
necessary to achieve the objectives.
Appendix 11-43
15
Bureau of Land Management
HC 74-12553 Hwy 20 West
Hines, Or. 97738
Janurary 51, 1990
151 1
15-2 I
15-3 |
15-6
15-7
Subject; Draft, Three , Rivers , Resource Management Plan.
This appears to be a very good plan especially in the area
of recreation.
The following comments refer to Table 2.1 and the Preferred
Alternative. Page 3, Water Quality, 1., states: "On a case-by-
case basis, close and rehabilitate all roads on public lands not
needed for administration or fire protection." This statement,
as made, applies to all roads in the Resource Area and not just wet
or riparian areas. Most roads in the KA must be left open, whether
maintained or not, to provide access to the handicapped, elderly,
and non-athletic.
Page 19, #11. No land should be acquired accept through the
exchange process, except for public access.
page 21, #16. What system will be used to assure that no
livestock utilization on woddy riparian shrubs occurs?
Page 25, Aquatic Habitat, #1 . Same comment as for page 3,
Water Quality, #1.
Page 29 5t 33, #3. Very pleased to see planned improvements
for Moon reservoir.
Page 31, Cultural Resources, //1. What are the proposed max-
imum 'take limits' for obsidian? Will there be a seperate limit for
each individual site? If not, why not? Will these 'take limits'
be consistant with rules, regulations and policy in other public
land resource areas containing obsidian deposits?
I strongly oppose the establishment of 'take zones'. What
rationale would be used to establish which area would be open or
closed? Would closed areas or open 'take zones' be adequately marked
and posted? What would be the prescribed penalties for taking more
than the maximum amount or from a closed area?
Page 39, Provide for Conservation etc., .?1. Private inholdings
should only be acquired through land exchange. The tax base must
not be reduced.
Page 43, Eliminate Unauthorized Use etc., i?3.a.&b., The option
must remain open for qualified entities to have access to certain
public lands for waste disposal sites. Needs for waste disposal
sites are important to our society and it behoves the public domain
to help meet those needs.
The ELM has grossly under allocated AUMs for big game use. The
planned allocation is 7,800 AUMs (appendix 5, Table 1), while the
need is 15, 685" AUMs.
15-15 I
15-16 |
15-17 |
15-18 |
15-19 |
A 20 percent check of the allotments in Appendix 7, Table S,
asa^nst Appendix 5, Table 1 showed that forage had been allocated
foVantelope in Allotments 70 10 and 7030 in one tabic but no alloc-
ations for forage were made in the other table.
ACECs
HATT BUTTE RNA
There is no information given to support this area as an ACEC.
tfhat is the critical concern? Why were there no management direc-
tions?
I request that this area be dropped for consideration as an
ACSC and that it be retained as an RNA.
SIXVJjfi CR^JJK RNA and Addition
Where is this area? Under Location you show it to be: T21S,
K26K. section 20. Tn the first paragraph under site description it
is stated: "The existing RNA, section 8..." In the second paragraph
it is stated: "The proposed addition, section 20..." 'What would be
the total size of the RNA with an addition, 960 acres or 1,600 acres?
What would be the total size if you acquired section 17?
Ho information is given to support a critical environmental
concern. Under management recommendations you make some condition
statements but your only recommendation is to acquire section 17.
T request that this area be dropped from ACEC consideration
but that it be retained as an RHA.
POSTER PLAT RNA
No information is given to support a critical environmental
concern for this area.
A need and a recommendation are not the same thing. II you
recommend fencing in this area, say-so.
I request that this area be dropped from consideration as an
ACEC and that it be retained as an RNA.
33UAW LAKE SNA
In the last sentence of the first paragraph it is stated: ",.thi
lake remains in an enclosed basin that loses water only through
evaporation." Is it possible that the lake also loses water through
saturation, percolation and/or transpiration?
'Why do BLM employees mix metric measurements into the draft
and plan documents when the metric system is not the American stand-
ard of measurement? I request that use of the metric system be
discontinued until it becomes the American standard, designated by
the United States Congress.
Again under Management Recommendations, conditions are stated
but no recommendations are made. Heeds were also stated.
I request that this area be dropped from ACEC consideration
but that it be retained as an RNA.
It is stated in Volume 1, Chapter 3, page 26: "An estimated
5,000 antelope, 14,000 deer and 1,500 elk winter on public lands in
the planning unit during a normal year. Approximately 4,300 antelope
13,000 deer and 300 elk summer on these lands."
Using the following equivalent ratios: antelope = 7 head/AUM;
deer = 5.6 head/AUM; and elk = 3 head/AUM; season of use would be
summer = 7 months and winter = 5 months. Competitive forage ratio:
antelope = 10.1%; deer = 18.4% and elk 100%.
wint.-;k
:;iiMM[-;K
ANTELOPE Antelope
5,000 * 7 X 5 X .101 = 361 AUM 4,300 * 7 X 7 X .101 = 434 AUM
DUR DEKR
U.000 * 5.6 X 5 K .184 = 2300 A'JM 13,000 + 5.6 X 7 X .184= 2990 AlV
ELK KLK
1,500 X 5 = 7500 AUM 300 X 7 = 2100 AUM
Winter total
Annual total
10,161 AUM
Summer total 5,524 AUM
15,685 AUM
The information concerning estimated capacity and carrying
capacity, as it relates to forage production is misleading and confusing
In a communication, dated November 24, 1989, the BLM states;
"Forage production estimates are computed through rangeland monitoring
and evaluation process. Appendix 3, Table 6, displays these estimates
either as Estimated Capacity (where additional years of data are re-
quired to complete the computation process) or as a Carrying Capacity
(where sufficient data are currently available). BLM has not made a
"total forage production" estimate as this is not required under mon-
itoring abd evaluation procedures." If 'total forage production1 is
not available or known to the BLM then all capacities are estimates
and the carrying capacities are unknown in all allotments. When if
ever does the BLM ascertain total forage production?
There has to be a minimum pound per acre per year of forage prod — '
uced for the range to be classified as suited for grazing. Total'
production must be known to know the true carrying capacity. While
the 3 year monitoring data may be more reliable, capacities are still
estimates. Carrying capacity is also based on the percentage of
total production allocated to forage use.
It is imperative that the BLM ascertain the actual forage pro-
duction rate, on an average, of 20allotments a year for the next 10
years. Then and only then can the range be managed under a truly
prudent plan.
15-26
DRY MOUNTAIN RNA Addition
This area i3 only a proposal to a proposal, it cannot be added
to something that does not exist. Map ACSC-1 does not show the pro-
posed forest service RNA in a cross hatched pattern or any other
pattern. Also the size, in acres, of the forest service proposal
is not given.
There is no indication that this area would not be a continuat-
ion and duplication of the Natural area cells contained in the forest
service proposal.
The narrative mentions heavy impacts by grazing outside of the
area, to the north and west but did not show any impact within the
Dry Mountain unit.
The Management Recommendations section did not contain any rec-
ommendations.
1 request that this area be dropped from both ACEC and RNA con-
ciderations and that it continue to be managed under the multiple
use concept.
Saddle BUTTE ACEC
It seems that current management practices are adequqte for this
area, which does not include either ACEC or RNA recommendations. No
I discussion of critical concern given, nor are recommendations made.
II reouerat that this area continue to be managed under the current
plan.
KIGER MUS2AW0 ACEC
There is no evidence that the progeny of the original Spanish
mustang in Kiger and Riddle Mountain herds are that much different
from herds in other western states. There is no evidence that these
two herds could not exist equqlly as well in Stinkingwater , Warm
Springs or Palomino HMAs. If kept confined inbreeding will decimate
the herd over time .
Contrary to your claim, the Federal Land Policy and Management
Act (PLPMA) of 1976, does not "clearly indicates the need to emphasize
the management of the Kiger and Riddle Mountain HMAs for these desc-
endants of the Spanish mustang." No site specific areas are mentioned
in either :-'LPMA, the Act of December 15, 1971 (05 Stat. 645, 651) or
the Act of September 3, 1959 (73 Stat. 470). The BLM is required to
manage the wild horse herds, but not in any specific area.
No specifics of environmental concern were identified in the
text for this!rior were any Management Recommendations made.
I request that thi3 area be dropped from further ACEC consider-
ation and that continue to be managed as an HMA.
Appendix 11-44
15-32
15-33
BISCUITROOT CULTURAL ACEC
It is quite clear that these root crop production areas are
important to the various Indian and/or other user groups.
It is not shown how much of the 8,480=actes are impacted by-
gravel pit activities, nor were other local land uses identified.
The acres shown in Appendix 7, Table 1 ane not consistant with
the Summary in Volume I.
Do the Indians have a Treaty right to the use of these lands
that could not be usurped by. ACEC designation?
The proposed Biscuitroot Cultural ACKC lies in T.21 & 22S, and
R.35& & 34 i, yet none of the Mineral Materials Sites listed in App-
endix 9, Table 2 are located in these townships and rangeB. What
are the real concerns about gravel developments?
Critical environmental concerns have not been identified nor
have any Management Recommendations been made.
I request that this area be dropped from further AC 3D consider-
ation, and that it continue to be managed under the multiple use
concept .
OBSIDIAN CULTURAL ACEC
The BLM Shows a conflicting number of acres for this proposal.
Appendix ?, Table 2 shows 13,900 acres while Alternative B in the
Summary shows 16,900 acres.
Under description of resources and value, it is stated: "Obsidian
flows are not common in the western United States.11 A Field Guide
to Rocks and Minerals, by Dr. Frederick H. Fough, states: "Obsidian
is locally abundant in the western United States, but does not occur
in the east. The western United States volcanic belt with its
obsidian formations extends down into Mexico (p. 14&1 5 ) • "
These areas have had to much use and disturbance, in recent
times, to be of any archelogical significance. These areas should
be protected from commercial exploitation.
No critical environmental concerns were identified nor were
any Management Recommendations given.
I request that this area be dropped from all consideration as
an A-CJSC.
Bureau of Land Management
HC 74-12533 Hwy 20 West
Hines, Or. 97758
February 1, 19y0
Subject: Draft, Three Rivers, Resource Management Plan.
Reviewing my response, dated Janurary 31, Iy90, at the bottom
of page 1 and top of page 2, I found that I made a gross error in
calculating alloted AUMs for elk; which changes the annual total
for big game. The winter need for elk should have been:
1,500 * 3 X 5 - 2,500 AUM, not 7,500 AUM as shown. The summer need
would be 300 * 5 X 7 = 700 AUM not 2,100 AUM as shown. The total
annual need for big game would be 9,285 AUM and not the 15,685 as
stated. Please make pen and ink corrections.
Also I do recall seeing any AUM allocations for wild horses
and burros, in the draft RMP. If they were not included please
make these allocations .
I appologize for any inconvenience this may have caused.
Sincerely, /" sn
Frank Vaughn
OP lAC- Southeast
936 N 7th
Lakeview, Or, 97630
In Appendix 9, Table 2, Mineral Materials Sites, many of the
legal descriptions are incorrect and confusing. For instance in
Site ;t7, Laton Point is listed in T.23S, R53JS. , sec. 2, j2,SW,v/,3W
Si ofi and SW NW 3E. and contains 400 acres. The E is set off from
the 3W by a comma and the E is an unknown quanity. The M is the
of sec. 2, containing 160 acres; The rf is set off from
a comma and is an unknown quantity. The 3W Si SB is the
_ Of the southeast £ of the southeast j of sec. 2 and
contains 10 acres; and SW NW 5E also contains 10 acres for a total
of 180 acres. Where does the other 220 acres come from?
Site #19, Fort Curry is listed in I. 223., R.26E., sec. 5,
NS N2 NW. This subdivision would only contain 10 acres, not 40
acres as listed.
The subdivision location fo all sites in this table needs
to be reviewed for correctness.
southwest
3W S£ 5S by
southwest -
In numerous places in Volume I of the Draft RMP a plus (+)
sign is included where it is either superflous or inapproprate,
some are listed below by chapter and page: 1-5, Lake (91 , 505+acres ) ;
3-2, less than 10+ inches; 3-12, in 195+ allotments; 3-16, there
are 8,973+ AUMs ~ (1981-1987) is 149,307+ AUMs; 3-21, Juniper
(13+percent); 3-55, (see Map+R-1); 3-44, Table+3; 4-6, 0 to 5.15+
miles;- 4-8, April and July +31: What are the significance of all
these + marks?
Thanks for the opportunity to participate
Resource Management Flan.
in the Three Rivers
Sincerely, / //
Frank Vaughn
OPLAO-Southeast
£&9±Z3? Or. 97630
Refer to response 2-81.
Refer to response 4-14.
Refer to response 3-13.
A management plan will be developed to address the multiple-use
requirements of several Important obsidian source/quarry areas,
especially the consideration for public uses like rockhounding and
education. No specific "take limits" on obsidian will be proposed
until there are rules or regulations In effect to consistently govern
the establishment of reasonable quantity limits for personal
collection, such as those already in effect for petrified wood.
Commercial collecting is regulated under 43 CFR 3600 requiring that
an appropriate permit be Issued prior to such taking. A permit Is
issued to ensure adequate measures are taken to protect the
environment, minimize damage to public health and safety, and to
obtain fair market value for the materials removed.
The concept of a "take zone" was considered as a means to conserve
those portions of obsidian source/quarry areas that exhibit
significant prehistoric archaeological resources and/or lesser
surface disturbance. Accessible areas with existing surface
disturbance are preferable for encouraging public uses, as "take
zones." Such areas with previous disturbance are preferred for
rockhounding and flintknapping uses, in order to minimize the overall
extent of impacts due to extraction of obsidian boulders and the
creation of artificial "Indian" sites by flintknappers.
Public uses in those areas where similar activities are already
focused and roaded access is established will be encouraged by an
on-site signing program. Less utilized areas and specific locations
where significant cultural resources are present will not be
emphasized in informational materials or on-site signing.
Any penalty for exceeding allowable quantities would depend upon the
nature of the activity (e.g., commercial or personal collecting).
Taking material from a closed area would depend upon the methods of
extraction (e.g., mechanical or manual) and access (e.g., motorized
or pedestrian), on a case-by-case basis, In accord with Bureau
regulations.
Refer to response 15-4.
Refer to responses 4-14 and 6-10.
Harney County operates six waste disposal sites on public lands, in
addition to several others on private land throughout the county.
Counting the private landfill which services the Burns-Hines area,
the residents of Harney County have adequate waste disposal
facilities to meet their current needs. Those disposal sites
currently leased to Harney County on public land have adequate
capacity to last well into the foreseeable future. Sale or exchange
of public lands for waste disposal sites to qualified entities would
be considered If a bouaflde public need is exhibited.
Appendix 11-45
15-10
15-12
Refer to responses 2-10 and 2-11.
Total forage production is the sum of competitive and noncompetitive
forage. BLM allocates forage only on the basis of competitive forage;
therefore, total forage production is not necessary to calculate
allotment carrying capacity. To determine total forage production
requires an inventory. A one-polnt-in-tirae inventory has been
determined by the Bureau to be inadequate for determining carrying
capacity. There are no plans to do a production inventory, however,
there is an Ecological Site Inventory in progress in the RA which
should be completed in 1994. We do not use suitability criteria.
Carrying capacity is not based on a percentage of total forage
production.
While actual forage production rate would be valuable information,
funding and staffing levels do not allow gathering such data. The
monitoring and evaluations are an ongoing process. See PRMP/FEIS,
Appendix 1, Table 11, for a description of monitoring and evaluation
methods.
Refe
15-9.
15-11 It is assumed the reader is referring to DRMP/DEIS, Appendix 3, Table
6, and Appendix 5, Table 1. The comment is correct for allotment 7010
and incorrect for 7030. The tables have been examined and corrected.
See Appendix 1, Table 9 and WL Table 1 of the Proposed Plan.
efer to response 1-26.
15-13 Hatt Butte is not recommended as an RNA/ACEC in the Preferred
Alternative. Neither is it recommended by the interdisciplinary team
as an RNA/ACEC {see Table 3.16 of Volume t, DRMP/DEIS).
15-14 The existing RNA/ACEC is in Section 8 (640 acres). The proposed
Silver Creek RNA/ACEC addition includes 640 acres of Section 20,
currently under BLM ownership and 640 acres in Section 17 which is
currently privately owned, but that the BLM is hoping to acquire in a
land exchange. This results in a total of 1,280 acres in the proposed
addition and results in a total RNA/ACEC size of 1,920 acres.
See also response 3-5.
15-15 Silver Creek RNA/ACEC fills the Oregon Natural Heritage Plan (ONHP)
(1988) cell for a first to third order stream. The proposed addition
to the existing RNA/ ACEC will provide a more complete representation
of this cell. As an RNA/ACEC, this area will receive special
management attention to maintain these important natural resources.
Additional management uses/constraints can be found in Appendix 1,
Table 16 of the Proposed Plan.
15-16 Silver Creek was designated in the Federal Register as an RNA/ACEC on
June 20, 1983. The ACEC designation is the principal BLM designation
for public lands "where special management is required to protect
important natural, cultural, and scenic resources and to identify
the Basin and Range Province. The combined areas would provide a
continuous representation of low to high elevation plant communities
in one area and contain five ONHP cells. Therefore, this area (Dry
Mountain RNA/ACEC addition) will not be dropped from RNA/ACEC
consideration until the proposal receives further study by both
agencies, other people and organizations.
15-26 Refer to response 1-12.
15-27 Saddle Butte will not be proposed for RNA/ACEC designation as there
are some conditions that do not make it a good candidate for such
status. It will continue to be managed without designation, but used
as an area for research by the Malheur Field Station and other
Interested researchers.
15-28 Phenotypically the wild horses in Kiger and Riddle herd~ are much
different from animals in other herds. Also, no other herds on public
lands possess the primitive dun factor coloration in total as do the
Kiger Mustangs.
There is no doubt that the wild horses presently on Riddle Mountain
and Kiger HMAs could physically survive on Stinkingwater, Warm
Springs or Palomino Buttes HMAs; however, it is not the objective of
the Herd Management Area Plans for those HMAs to be managed for
Spanish Mustang type horses.
Burns District does not intend to allow close inbreeding of any of
its wild horse herds which would cause physical defects that would
jeopardize the animals in those herds. While the BLM is not dealing
with domestic horses, horse breeders in the domestic horse industry,
in many cases, consider inbreeding and line breeding a very
acceptable management practice with some of their most superior
animals being obtained in this manner. Other wild animals seem to get
along quite well without man's intervention in the mating process
even in somewhat closed systems.
15-29 FLPMA does not indicate the need for special management of wild
horses. The text as shown in DRMP/DEIS Appendix 7, Table 2, page 7-11
is only a reprint of the ACEC nomination as it was received.
The BLM is required to manage wild horses in those areas in which
they were found at the time of the passage of the Wild and
Free-Roaming Horse and Burro Act, as described in Section 1 of the
Act,
15-30 Refer to response 2-
15-31 The Biscuitroot Cultural ACEC
oposcd for the designation of
The Biscuitroot Cultural ACEC is proposed for the designation of
6,500 acres. Discrepancies of acreages as depicted in the Draft RMP
should be corrected to this figure-
natural hazards." The relationship between ACECs and the wide range
of other public land designations is such that a potential ACEC may
be contained within or overlap another designation provided that the
ACEC designation is necessary to protect the resource or value. This
is the case with Silver Creek RNA/ACEC.
15-17 The site will be managed primarily to maintain the natural qualities
of the ecosystem in a state which is suitable for conducting research
or monitoring on this plant community.
See also responses 3-1, 15-16.
15-18 Fencing of the Foster Flat RNA/ACEC is recommended as necessary to
maintain the important natural values of the area.
15-19 Refer to response 15-16. The same conditions apply for this proposed
RNA/ACEC.
15-20 This statement reflects the fact that this basin is not externally
drained; there is no stream flowing from this lake- All water loss is
Internal. This could be by means other than evaporation such as
percolation into the soil. However, the majority of the water loss is
probably through evaporation.
15-21 The metric system is a standard within the scientific community;
however, your concern is noted and the measurements cited have been
converted to American (English) standard units.
15-22 The interdisciplinary team assessed the relative values represented
in the Squaw Lake Proposed RNA/ACEC and determined that it did not
sufficiently meet the importance and relevance criteria. The ID team
recommended, and management concurred that the area not be carried
forward for further consideration. Also, it should be noted that RNA
is not an independent designation. RNAs and Outstanding Natural Areas
(ONAs) are categories within the larger designation of ACECs.
Therefore, an area cannot be dropped as an ACEC, but retained as an
RNA.
15-23 Map ACEC-1 has been changed in the PRMP/FEIS to show the USDA-FS's
proposed Dry Mountain RNA. The USDA-FS proposed Dry Mountain RNA
contains 1,187 acres. Also, see Map ACEC -4 , PRMP/FEIS.
15-24 The proposed Dry Mountain RNA/ACEC addition would be a continuation
of the cells contained within the USDA-FS proposed RNA. Due to the
elevational change between the USDA-FS and BLM areas, the two areas
together provide a more complete representation of these cells.
15-25 The utilization of protecting and managing special uses and resources
through ACECs/purpose-related designations is an integral part of
multiple-use management. Dry Mountain RNA is currently a proposed RNA
on the Ochoco National Forest and is included in the Preferred
Alternative of the Draft Forest Plan. The Dry Mountain RNA/ACEC
addition which is on BLM-administered land also contains the plant
communities necessary to fill the cell for Ponderosa Pine Savanna in
15-32 Treaty rights will be reinforced by an ACEC designation in the
Biscuitroot Cultural ACEC area. Access to "usual and accustomed"
areas for hunting, gathering and fishing are provided for in treaties
with the Confederated Tribes of the Warm Springs and the Confederated
Tribes of the Umatilla Indian Reservation. Studies indicate that the
ACEC was utilized by these and other tribes for root gathering
(Couture, 1978; Couture, Housley, and Ricks, 1986).
15-33 The proposed Biscuitroot Cultural ACEC lies in T. 21 S., R. 34 2.,
and T. 22 S., R. 33 and 34 E. The mineral material sites include the
Pine Creek Material Site which Is In R. 34 E., rather than in R. 35
E. as incorrectly shown In the Draft RMP. This site was established
In a ma.in root camp and has affected the traditional use of the area.
Refer also to response 6-13.
15-34 The Biscuitroot area is important for the protection of cultural
values of Native Americans, especially the Paiute Indians, and will
not be dropped from consideration as an ACEC. In accord with the BLM
1613 Manual, ACECs are a multiple-use designation, to the extent that
all uses allowed are compatible with the ACEC management objectives.
15-35 ACEC acreages listed in the Draft RMP are sometimes inconsistent
which is an error. The Proposed Obsidian Cultural ACEC will not be
designated In the Proposed Plan.
15-36 It is true that obsidian sources are found throughout the western
United States. The narrative description is intended to contrast
those regions which have some surface available ob:; Id inn with Eastern
Oregon's northern Harney County for which obsidian occurrences are
characteristic. Here it is not only "locally abundant" but frequently
occurs as a high quality visually variable mineral, such that prized
obsidian sources are relatively common, as compared to the western
U.S. where "locally abundant" obsidian Is not typically so variable
in color and texture and of such quality. CerLainly Oregon, Nevada
and California do have numerous obsidian occurrences, while In most
other western states obsidian Is not so prevalent.
15-37 Refer to response 15-35.
15-38 The observation that you make is correct. Acreages and legal
descriptions in DRMP/DEIS, Appendix 9, Table 2, were in error. The
corrected table is found In the PRMP/FEIS as Table 2.25.
c conversion of the
t over to a typeset
These anomalies are the result of the electro
draft from its original word processing documi
document for printing. Most of these marks (I.e. "+") were what
referred to as keyboard special characters and did not convert
correctly. More stringent editing of the Final will attempt to
that such problems do not occur again.
Appendix 11-46
Slszrici Manager
3urns district
Hines. :?
16
barcc;
we resp
age:ne;
a??rec:a'
area tha
comments
g for the NPSQ "-3 your Drait Threa Rivers Resource
II Plan. Our statsvlfie group of 85" n",emcer£ In 11 chapters
the opportunity :c provide It.?-: for !fc* nanagefMns of an
s important ;o our isemoera statevioe. I wculo !:*e to offer
several areas.
' SPE!
.his area is of primary concern to us.
ftCEC held populations cf one of only tv
entire state of Oregon. As you also are
.~a.nejrer.sis: cec.ame extinct In the w!
Attempts have oeen maoe since then to recover the plant. This effort Is
not mentioned in your plan. Ve fee; this taxon is of national importance
and deserves specific attention. We vou.d : Ue details of the management
of tne ftCSC s includes.
sa you -.no-.;, the South Narrows
federally 1 istec pi ar.ts in the
■.■■are. that plant :3:epha.nomer ; a
under 31M management In l°8i.
Cther than a listing of species oi inhere
tne ses: t : ve p i ant program for tne area
should oe corrected.
jut 1 : ne of '/ha:
oversight ar.c
Stephanomeria malheurensis (Malheur wirelettuce) has not gone extinct
in the wild. Mo Malheur wirelettuce plants were observed in the wild
in 1995 or 1986; however, one plant survived to maturity in 1987,
seven survived to maturity in 1988 and 11 in 1989. BLM and USFWS are
currently cooperating in an ongoing recovery operation for this
plant, including an intensive study of the effects of biological and
climatologlcal interactions with wirelettuce on its survival. These
cooperative study efforts have been formalized in a Conservation
Agreement between BLM and USFWS. Overall conservation actions and the
management of the 160-acre South Narrows ACEC, which contains all of
the designated Critical Habitat for Malheur wirelettuce-, are
conducted under the Draft Recovery Plan, As such, present management
practices being undertaken through the Recovery Plan are being
carried forward as valid existing management. The Draft Recovery Plan
and associated documents are available for inspection at the Burns
District Office.
See the Proposed Plan for management actions for special status
species, including plant species. These actions will include
inventory, monitoring and the establishment of species specific
objectives within the allotment monitoring and evaluation process
where appropriate. These activities will constitute a major portion
of the special status plant program in the RA.
CONDITION
Management direction shouts oe to get ali ianos in excel lent condition.
Alternative A comes closest to this. Special protection should be
afforded to ripari an areas. We do not support the suds: E tut! an of
crestec wheat plantings for the native range species.
WILD
™;1S
These animals signi i icant !
support their elimination.
ve vsge: a; i on
we strong: y
We would support Alternative A (Emphasise natural Values) as coning
closest to protecting those resscurces most Important to us. Even it is
inadequate in the ways I have oullned asove and we hope that this could
De corrected in the final document.
Sincerely.
4^Aw
Stuart 3 Garrett MD
Pres. NPSO
ISC ; HZ Medical Center Dr
Send, C3 97701
17
Stanley 0. Shepardson
21635 Los Serranos
Bend, Oregon 97701
January 25, 1990
17-1 Refer to response 1-11.
17-2 Refer to responses 2-36 and 12-7.
District Manager
BLM
HC-7412533 Hwy 20 West
Hines, OR 97738
17-2
Dear Sir:
The BLM's EIS
recognize the impo
the highly differe
excessive grazing
aquatic habitat .
Though restor
must be the long t
lands . Fencing off
cattle and in drou
lands should be im
district exist whi
variety of natural
valuable to a crow
lands are able to
It appears cr
other monocultures
I which only exists
cannot resist est
them into smaller
and honestly repor
I the expected reven
grazing allotments
•he Burn's district fails to
rtance of restoring public lands back to
ntiated ecosystem they once were, before
resulted in severe damage to the range and
ation
erm g
ripa
ght y
pi erne
ch co
provi
ested
is o
throu
blish
plots
the
will take decades to accomplish, it
oal in the management of our public
areas, decreasing or dispersing
ears removing livestock from public
nted. Many natural areas in your
uld provide future generations a wide
tation and wildlife that will be more
orld than the few cattle these arid
e .
wheat grass or the establishment of
nly a short term, expensive program
gh heavy federal subsidy. If the BLM
ing such seedings , at least scatter
interrupted with natural vegetation
full expense of such programs and
ceived through the few benefited
Stanley 0- Shepardson
Appendix 11-47
18-1
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18-1 Refer to response 1-13.
18-2 Refer to response 2-44.
18-3 Refer to response 12-1.
18-4 Refer to response 1-11.
18-5 Refer to response 3-6.
To.
aa, iiQo
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Appendix 11-48
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19-1 Refer to response 2-63.
19-2 Average actual use on the Horton Mill Allotment is listed as 424 AUMs
per year In the DRMP/DEIS, Appendix 3-141. However, the past couple
of years actual use on this allotment has been light. A recent
allotment evaluation notes an improvement in soil condition
(reduction in soil erosion), and a need for further improvement. Past
heavy use by livestock has been identified in previous field
documentation as one factor which contributed to the erosion rate on
this allotment. The current allotment evaluation outlines a strategy
for improvement of the soils resource.
19-3 If fences are built in the vicinity of private land, appropriate
measures will be taken to ensure that fences are not built on private
land. The Bureau is generally prohibited from investing public monies
on private land.
19-4 There are a variety of potential projects which may be utilized to
solve the multiple-use conflicts in the Skull Creek Allotment.
Site-specific measures to alleviate these conflicts have been
discussed in the allotment evaluation.
*0ei4-Wer of
u. & C CVw
V>«
tfU ?r
"Si
cA +V\es-e. op^loA/ss . X-V- UJOu-lcA be. o. Se-ue*^. Vs\»t
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Appendix 11-49
20
District Manager
Bureau of Land Management
HC- 7412533 Hwy 20 West
Hines,0R 97738
January 22, 1990
In response to your Draft EI5, 1 find Alternative C to be totally
inappropriate. I would like to see you adopt Alternative A with some
modifications that would allow for the restoration and maintenance of
rangeland in excellent natural condition Cattle grazing should be reduced
or eliminated where appropriate.
20-2 I Riparian and aquatic habitat as well as water quality should be inproved
and maintained in excellent condition. I would like to see Wild and Scenic
2°-3 I River designation for the South Fork and Middle Fork Malheur Rivers, all of
I Bluebucket Creek, and all of the Silvies River
20-4 | The remaining old-growth forests should be identified and protected.
20-1 Refer to response 1-13.
20-2 Refer to response 2-44.
20-3 Refer Co response 3-6.
20-4 Refer to response 12-1.
20-5 Refer to response 2-78.
20-6 Refer to responses 2-6, 2-10 and 2-11.
20-7 Refer to response 1-11.
20-8 Refer to responses 12-1 and 12-7.
The Draft EI5 needs to address big horn sheep habitat protection, with
forage allocations going to bighorns in their home range. In general,
wildlife winter range forage allocations should be given priority over
livestock allocations. The seeding proposals for crested wheatgrass
should be eliminated.
To give an accurate picture, all costs of new road construction and other
rangeland projects (fences, pipeline, troughs, wells, etc.) need to be
included for each alternative. The environmental impacts of each should
also be listed.
This is beautiful and ecologically important land We need it in excellent
condition Please use Alternative A with the above modifications.
\Jk&*u A^CA^A^J
Irene Bachhuber
10561 5E IdlemanRd
Portland, OR 97266
21
815 S.E- 32nd, #3
Portland, OR 97214
January 25, 1990
District Manager
Bureau of Land Management
HC-7412533 Highway 20 west
Hines, OR 97738
Hello:
2 I
21-2 I
21-3 ■
21-4 I
21-5 |
21-6 |
21-7
I am writing to comment on your draft Eis covering the northern
half of the Burns District. As a frequent visitor to eastern
Oregon, I am very unhappy with your choice of Alternative C for
this area. Please reconsider and choose Alternative A.
The following points are very important:
- An alternative to restore and maintain rangeland should be
developed, and cattle-grazing should be reduced or
eliminated in some badly damaged areas.
Water quality, riparian and aquatic habitat should be
improved and maintained in excellent condition.
Ancient forests must be identified and protected.
All costs of construction of new roads and other rangeland
projects should be included under the various alternatives
along with their environmental impacts.
Please eliminate crested wheatgrass seeding proposals.
Bighorn sheep habitat protection and impacts should be
addressed in the plan.
Wild aprt Scenic River designation is needed for all of the
south Fork and Middle Fork Malheur Rivers (except for the
reach through the Drewsey area), all of Bluebucket Creek
and all of the Silvies River-
Wildlife winter range forage allocations should be given
priority over livestock allocations.
Thank you for considering my opinion,
welfare of Eastern Oregon.
I care very deeply for the
Sincerely,
2L-1 Refer to response 1-13.
21-2
21-3
21-4
21.-5
21-6
2 1-7
21-8
Refer to response 2-44.
Refer to response 12-1.
Refer to responses 12-1 and 12-7.
Refer to response 1-11.
Refer to response 2-78.
Refer to response 3-6.
Refer to responses 2-6, 2-10 and 2-11.
Appendix 11-50
^rc 74-/Z5S5 ,2^} Zd^
22
<x
.*£/
^
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-^
s\s^-*~-*~tJA->
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frv-
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/jp~^yu<&i3b~-
22-1 Refer to response 13-11.
Appendix 11-51
13
Buim, OKzqon
3a.wia.ny 25, 1990
Auimu. ol Land Management
HCR 74 12333 Hwy 20
Hlrm, OR 97738
Ge.nt.lejne,n:
PiexiAe. count me a.4 one yo£& ao,aJxat the.
plopot>?.d Thiee. R.ivGi4 Rziouice. Manaqamaivt p£an.
Ai a Zona, time. HaJinty County tia.nche.tL, now tiejtJ.Ke.ri,
T think thii ptiopobtd plan would he. a. dlbcLf.te.ti ioti
the. tia.nche.tii involved and a Knot doimt/A ^on. the
county.
Sincetitly,
Ea.theZ Cattcuon
SK2 1ms Hum ?o
Sham, or 97720
The preferred alternative
enough protection or restoration
be a high priority for BLM eff
and use of prescribed burning in
juniper, should be used along
the
citl
ally
does not provide anyvhere
if riparian areas. This si
orts. Reducing grazing pres;
certain areas of heavy bru:
with fencing to help bring
Alternative A
mpo
■tant
5 preferable
ords in a DEIS
eeds of the la
adically
address the real
show either a radically changed
Alternative A as the preferred altern
changes should reflect a recognit
native grassland, r I par Ian zones,
reducing cattle grazing pressure, e
well as by construction of fencing an
Thank you for the opportunity to
Three Rivers Resource Management Plan
ing back
to Alternative C. , but reads like
rather than like a commitment to
d. I hope that the FEIS will
Iter native C or a changed
tive . In either case, the
on of the need to restore
and wildlife habitat, by
pecially in the spring, as
water troughs, etc.
comment on the DEIS for the
Sine
ely,
Charlotte C. Cork ran
130 N. w. 114th
Portland, OR 97229
No comment; ide1
CHARLOTTE C. CORKRAN
130 N. W. 114th Street Portland, Oregon 97229 (51)3)643-1349
24
V
Joshua L War barton. District Manager
BLM Burns District Office
HC 74-12533 Highway 20 West
Hines, Oregon 97738
Dear Josh,
January 23, 1990
24-1 Refer to response 2-6.
24-2 Management actions for big game habitat are listed in management
objectives WL 1, 2 and 3 in the Proposed Plan.
24-3 Refer to response 2-10 and 2-11.
24-4 Refer to responses 2-78 and 24-2.
24-1 J
24-2 I
It has been
dvisory boards, b
ean 1 ' m not stil
ands, especially
The DEIS for
eal d isappointmen
our through parts
ragile and erod;
n poor condition
ruly protect
nadeguately addre
ack from past
ntensity of graz
ccomplished by
acil i ties for 1
heatgrass seeding
ondition land
lternative relie
rested wheatgras
lternative that
ggressive program
he spring.
I am very co
f the heap rating
here are many In
heep, deer, antel
t from the DEIS
ildlife? Why
llocation? How
mestic sheep t
ldlife to be dea
.ong time sine
ut just because I ha
;ply interested
: Burns Distr ict
the Three Riv
n remember ;
area, look!
was on any of the BLM
t been act ive doesn ' t
the management Of BLM
r ce Management Pla
ble
ils I1
Tvhe
resto
the
razing
e need
the
the de:
ore these
longrange
Ma jo:
ded, and 1
build ing
I agree 1
used to k<
while they recover,
eavily on
ultures.
of these sa
ing grazing
and
sses
over
ng a
jus
vest
t least one
ng at s
n Oregon,
S altern
soils?
need to
changes
ill do m
of
hat
ep c
of red
f enc
some
attle
owever
vert in
techni
ressur
advisory board
e of the most
nd most of them
lve that would
Alternative C
ing these lands
the timing and
e than will be
and watering
reas of crested
f f of desperate
the preferred
ative range to
need for an
s, but also an
especially in
off
ncerned that wildlife is given the usual bottom
the priorities of the management area.
tant winter and breeding areas for bighorn
ope , and other wildli f e , but you 'd never know
How are these areas to be managed to benefit
e game animals given such a small forage
e grazing conflicts, disease transmission from
wild ones, and specific habitat needs of
It with?
CHARLOTTE C. CORKRAN
130 N. W. 114th Street Portland, Oregon 97229 (503)543-1349
Appendix 11-52
25
Van G. Decker
P. 0. Box 106?
Burnt, Oregon 97720
To: Jay Cirlson, RMP/EIS Team Leader
Bureau of Land Management
Burns District Office
HC 74-12533 Highway 20 W.
Hines, Oregon 97738
Dear Mr . Carl son :
The grazing use sold to livestock permittees is the
only user fees of any significance that BLM can collect on a
very large percentage of the RA.
The proposed reductions in grazing recommended in
alternative A and B would have devastating economic effects
on the Harney County community. As stated in the plan, 10.2
percent of total personal i ncome i n Harney County is from
Agricultural income. However, in several of the small
communmi ties within the RA Diamond, Sodhouse, Riley, Crane,
Pr i nee ton , Buchanan , Drewsey , and Pine Creek, agr i cu 1 tural
income is near 100 'A of the income.
Assignment of off-site forage to permittees is an
acceptable method to most permittees particularly those in
the Drewsey Area.
The proposed 30,000 acre seeding In West Warm Springs
Allotment, will likely cost 43,000,000.00. This money
should be spent on more smaller projects in 5 to 10
different allotments. As stated in the study, this
expensive seeding will mainly benefit the wild horses.
The Kiger HMA has not been expanded In this plan. Each wild horse
herd has a designated boundary known as the Herd Area. This is the
area in which they were located at the time the Wild and Free-Roaming
Horse and Burro Act was passed. Within each of these Herd Areas,
there Is a Herd Management Area in which the wild horses are actively
managed. The HKA may include all of the original Herd Area or may be
only a portion of the original Herd Area in which it is feasible to
manage wild horses. Although the Diamond Grade fields are not used by
wild horses every year, they still remain part of the Kiger HMA.
See also response 8-9.
The area mentioned along Yank Creek is, as you said, privately owned.
The BLM was given control of this area for grazing purposes only by
means of an exchange of use agreement. Both livestock and wild horses
have used this area at various times during the past 20 years.
The conditions along Yank Creek do indicate a stream in less than
good condition. It Is recognized that wild horses have caused some of
this condition by their yearlong use of the area. However, since this
area is privately-owned, the BLM is not in a position to prevent wild
horses or livestock from using the stream area. The private landowner
is in a position to fence off this area if he so desires. This may be
one way of correcting the streamoank conditions along Yank Creek.
Also, refer to response 25-2.
KIGER HMA:
Designation of 36,619 acres of Kiger HMA
horse ACEC.
This includes signicantly more area than this herd of
horses has been using in the past years. If I recall
correctly under the original Wild Horse and Burro Act passed
in the late 1960's, Feral horses were not to be moved into
new areas where they had not already been.
Decker Page 2
to this area,
"i this area .
This Kiger herd of horses are not nativ
They were hauled in here by BLM and planted
Mustang horses have been running in common with cattle
in this area for over 30 years and have competed well with
the cattle for feed and shelter.
RIPARIAN AREA USE BY HORSES
I recently made an inspection trip of the Yank Creek
stream bed in the Kiger HMA. This is a parcel of privately
owned land that has been totally used by BLM horses for many
years. The BLM has had complete control and responsibility
for the horse and range management of this area.
The Yank creek stream bed twenty years ago had several
little small stringer meadows along the sides of the creek.
These have been totally tramped out by the horses trampling
in them when wet and pawing and rolling in them when they
are dry. As I lay down beside the creek to get a drink of
water, I noticed the bottom of the stream bed is a series of
little riffles of silt, rather than a layer of small rocks
as is normal in this type of creek. The soil area has been
abused so badly that the soil is all being carried away down
the creek. The horses, by their year round over grazing and
abuse of this riparian area have 90 V. destroyed the riparian
area.
If a livestock permittee running cattle on a BLM
allotment abused a stream bed area to this extent, I beleive
the BLM would likely require removal of his cattle forever.
The Yank Creek stream bed is in the worst condition of any
stream bed I have ever seen anywhere in the Burns BLM
District. I beleive this stream bed riparian habitat would
be rated very. very. poor.
WILD AND SCENIC RISERS:
Segment A and segment B of the Si Jules River do not
meet ihe characteristics to make this river a worthy
addition to the National Wild & Scenic Rivers System
The BLM should actively persue the law suit hy Delmer
and Jo McLean, and not allow them to continue to abbuse the
BLM as they hav* in the past.
Thank you, jff
Van G. Decker
Appendix 11-53
A AKNfSON. I'C
arneson & Wales
AnOHNEVSATLAW
JIBSiJACKSONSTHLH
P.O. BOX 11M
ROSEflURO, OREGON vwt)
26
26-1
District Manager
BLM Burns District Office
HC 74-12533 Hwy 20 West
Hines, Or. 97738
Draft EIS
Dear District Manager:
The proposed alternative. Alternative C, is totally unacceptable
and simple conti nues the management of Lhese publ icl y owned 1 ands
as cheap range for private cattle operations .
Interesti ngl y the cost of construction of new roads and other
range land projects is not included for thi s or the other
al ternati ves , nor are envi ronmental impacts ace u rate 1 y ref lee ted .
The result is a distorted cost/benefit picture.
The SLM must develop a new alternative to restore and maintain
rangeland in excellent, natural condition. Cattle-grazing should
I be reduced, or totally eliminated, to the extent necessary to
■ achieve this goal. Water quality, riparian and aquatic habitat
2°"2 I must be improved and then maintained in excellent condition.
26-3 ' Ancient forests must be identified and protected. All crested
26-4 I wheatgrass seeding proposals should be eliminated.
(Bighorn sheep habitat must be protected and forage allocations go
entirely to bighorns in their home range. In general wildlife
26-6 I winter range forage allocations should be given priority over
I livestock al locations .
Of the alternatives presented, Alternative "A" is the least
objectionable , in that it al lows a token amount of recovery to
occur .
26-1
26-2
26-3
26-4
26-5
26-6
Refer to response 1-13.
Refer to response 2-44.
Refer to response 12-1.
Refer to response 1-11.
Refer to response 2-78.
Refer to response 2-6.
-va-Ay Cdo.
Appendix 11-54
27
4**, ~tft /??o
fee r-
AA,
TV/ /■■£&- y£sif(°<3. A<A«J?-& . -Aor- "A* &^
21-1
27-3
27-4
fJOyP*
A
C (*w si iTh
^C &/-[_ Ah*/-s9?e_o£ ^/f <~'<^^-i*s- •
•=?, 6t/ / dt ,Aa sz^s. e-5~ S~ '. &/i /c/ /?<->r/
Y . /lO //Z<ht5&-' &-/>jA-?iA <£*">£ "Cf '-*lfi--
- t/&- J* a-&~ &A
3
AA^^^t ^E>7 est f**~i»>&Aa^dgA* #?**lj->gi/i<sS <•
/^.^
y% 'e. s^ne>fs**4 "c****4f ^A- /A A
S<->At/A> fydu?*^Aw>(fy*t.cej( ""^"J
0 i*/ 7Ss 7^-fOr o/a^ci
<2A //<£?/ &*\ &K&i
A.
3~ /^?5 <t>r<&t*~7/1~ nHSia-e^ c=^L~74i__
11-1 Economic impacts were analyzed in the DRMP/DEIS, Chapter 4, pages
68-70. This impact analysis has been expanded to include the Proposed
Plan (see PRKP/FEIS, Chapter 3).
27-2 Refer to response 2-44.
27-3 Refer to response 2-6.
27-4 See management actions WL 6.1, 6.2 and 6.3 of the Proposed Plan.
27-5 Refer to response 2-87.
27-6 Refer to DRMP/DEIS, Chapter 5, pp. 5-2 to 5-4, Consultation and
Distribution, where it is noted that all grazing leasees within the
planning area and livestock organizations (such as Oregon Cattlemen's
Association, Oregon Farm Bureau, Oregon Sheep Growers, etc.) were
provided opportunities to participate throughout the planning process.
27-7 Grazing use adjustments would be implemented through monitoriag and
evaluation process (see PRMP/FEIS, Appendix 1, Table 1). If such use
adjustments result in reduced stocking levels and ao off-site forage
is available, reductions would be absorbed by grazing operation.
Also, refer to response 2-49.
27-8 Refer to response 2-6.
27-9 Refer to response 2-52.
27-10 Refer to response 2-11.
f, /?& ^»0-~fi~ z&rTrJ/tiCf, ,
^ / y^^r 0, >"*H.
s>
ft-/& <£-A?&j'~ <s*u£-h,
A
■A*o-L*
/^-na
fi^Mj- ■^fCGfis - ^S>«_ Acz-uJ
'" not M>G*Ac .J^tAiJis £$~ /■.-■
Appendix 11-55
MELANIE S. HARRIS, NP
Harris-Tramol Med. Servieos, lr
229 NORTH EGAIM
BUHNS. OREGON 377ZO
TELEPHONE 573-G12G
Bureau of Land Management
HC 74, 12533 Highway 20
Hines, Oregon 97738
January 19, 1990
□ urgent / □ please reply ev y □ no repiy nsBIO
SUBJECT:...,.. „.,.,
Gentlemen:
I would like to go on record as beinq opposed to the Three Rivers Resource Management .
propos-il . ,'iCCl-i t!i:;«: '.o '.he" ini'-'oinTi'?it.i"(>[i'" that" T"h'sve" 'ofriVan'd";"Tliic""ia""a'"Ib'ss'"i'ri
ex=C9S of S3.000.00C taxable income into this county. This county has had a great
economic loss in the ias^. few" yiaiirs "'with' "the Limber revenues being "down and the
mill not functioning a great portion of the time. The only thing that has kept
""this ' "county afloat is the raricn'Tng "that ""continues yh""fchTs""afea":' Wis",'amSuri'i'"'6T
acreage loss to the cattleman has a devastating impact and therefore will impact
the entire county. I would like to see this proposal denied.
S i r.ce re ly "your s ","
MELANIE S. HARRIS, N.P.
An analysis of community economic impacts has been included in the
PRHP/FEIS. Impacts to cattle and calf sales and personal Income have
been estimated for each alternative. Standard input-output
multipliers for Harney County were used to estimate total community
impacts to personal Income and employment.
m
See responses 2-1 through 2-96, 4-1 through 4-16, 30-1 through 30-4,
and 78-1 through 78-10.
January 29, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12535 Highway 20 Vest
Hines, OR 9773S
Dear Mr. Carlson:
The letters from the Harney County CattleWornen, Stockgrowers,
Farm Bureau, Sheep & Woolgrowers and the January 17, 1990
Riddle Ranch and Western Range Service Comments and Response
to the Draft Three Rivers Resource Management Plan and
Environmental Impact Statement are consistent with our views
and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. Ve do not
include a full copy of the tent for the reason that it would be an
exact duplication of the Riddle Ranch document and organisations
letters.
Sincerely,
5J Cattle Co.
Box 14
Princeton, Oregon 977721
Appendix 11-56
^ farm
bureau
., :;7y:ij .m,-,,j . (y):)) h
f/ie VOtefl of organized agriculture
January 29, 1990
Jay Carlson - RMP/EIS
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 Wes
Hines, OH 97738
30-1 Refer to response 2-3.
30-2 Refer to response 2-6 and 2-49.
30-3 There are no mechanisms in place which would allow the Bureau to
compensate permittees for loss of grazing on public lands. Refer to
response 2-63.
30-4 Refer to response 2-63.
COMMENTS - 1989 BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson:
The Oregon Farm Bureau would like to go on record in general
support of the testimony already received from the Riddle Ranch,
Western Range Service and the Harney County Farm Bureau, in
relation to the Three Rivers Resource Management Plan.
After reviewing the aforementioned comments, we agree that with
the available data, current upland grazing practices are having no
significant adverse impact on surface water quality. The proposal
to remove livestock from streams will disrupt current successful
grazing systems and will have a long-lasting adverse impact on
livestock operations.
Water quality should be determined by standards developed by
federal action under the Clean Water Act and should take into
account the particular and difficult problems caused by the
intrusion of naturally occurring pollutants. The solution to these
difficult problems should not be at the expense of the established
user of water, including agriculture.
Over grazing and damage to range lands by wild horses or game
animals should be managed by control of wildlife populations.
Domestic livestock grazing permits should not be reduced or
eliminated, as a result of misuse of public lands by wild horses
or game animals. It has been recently reported there has been an
increase of elk in the resource area. We strongly feel there should
be no proposal to reduce grazing until a full EIS on the expansion
of wildlife numbers has been done by an independent professional
range manager.
If grazing permits are reduced to permittees, the permittee
should be compensated economically for the amount of time the lands
are used for another public purpose or when the reduction is due
to no mismanagement by the permittee.
We feel that with the designation of the entire Kiger Active
Horse Management Area as an area of critical environmental concern,
it will have an adverse affect on at least one livestock operation.
The takings issue should be addressed under the "Taking Implication
Assessment" authorized by Executive Order 12 63 0. Wild Horses and
livestock have successfully run together in the past and as a
result of the recent BLM sale of Kiger horses, it would tend to
show that the wild horses in that management area are well
established and doing fine.
Given the foreseeable problems associated with this RMP/EIS, it
is our recommendation that a stewardship program and a cooperative
management program be set up in the Three Rivers area.
Doug Breese
President
Appendix 11-57
January 30, 1990
Refer to response 1-13.
District Manager
Bureau of Land Management
HC-7412533 Hwy 20 West
Hinas. Oregon 97736
Dear Sir:
I am extremely disappointed to note that your Resource
Management Plan identifies Alternative C as your
preferred plan for the management of the northern half
of the Burns District .
I have lived in the Central Oregon area for nearly forty
years, and have noted a steady decline in the quality
of the environment in which we live. Our "stewardship"
of this wonderful land seems to have been characterized
primarily by exploitation and overuse . I feel that the
time to change our thinking, and the ways in which we
manage both public and private lands , is long overdue.
I believe that we must begin, now, to pursue policies of
conservation , preservation, and reclamation ,
I would, therefore, request that in the formulation
of management plans for the Burns District, you
emphasize the maintenance and responsible development
of quality natural resources, and that the damaging
effects of our use of natural resources be minimised
( examples: overgrazing of rang el and , overcutting of
timber resources , destruction of riparian zones and
wildlife habitat, etc.).
I support your adoption of A] ternative A, the "Natural
Values Alternative" . I am willing to actively support
you in such a management program
tax dollars, if
even with increased
j&iacar»ly ,
rVv-v . w
IjlJ
Sti*- Ai -ffve
32
&S&U-
AUiw' .'0**—- 97f3$
32-1
(r
^
^Si^
* '7 ^V
32-1 The Three Rivers DRMP/DEIS does not propose to eliminate livestock
grazing. FLPMA identifies livestock grazing as a valid use of the
public lands. There are no proposals to interfere with private land
holdings.
Appendix 11-58
January Zh, J. 990
m
Jay Carlson
Burns District Office
Bureau of Land Management
RC 7*1—12533 Highway 20 West.
Hines, Or. 97738
Refer to response 2-63.
Review Comments for the October 1989
BLtt Draft Three Rivers RMP/EI
Dear Mr. Carlson,
33-1
ting
Ut.rni.tiY., A. B, and C will result in a substantial loss of our
base property Y.lue. Tho proposed BIH actions may result in redo
""''! °f ~* °P»™t"" so that it is no longer an economical
unit. Therefore, we request that if AlternatiYos A, B or C are con
Sld.red, that prior to issu«ine the Final Three RlYers Resource
Management Plan and EnYironmental Impact Statement, a "takincs
Implication Assessment" be completed as authorized by ExecutiY.
Order 12630(s.e the Member 8, 1988 Memorandum to all AsSst.nt
SXjJfcSjT" KreCt"S fr°" ^"^^ * **•**£
Sri™"^3 f""Jt,h,e ""-"W Co""ty Cattlewom.n, Stockgrow.rs, Farm
Buroauu Sheep and Wool^ro.er. and the January 1?, J 990 Riddle Ranch
and Western Kjn*. SerYice Comments and R.spoLe to SL Saft
^hrn, .irers Resource KsnaEement Pland and EnYironmental Impact
Statement are consistent with our Yiews and comments.
dor,™[^ T 00r 8nd0r6™s»t »f such letters and Riddle Ranch
document. Their response has been submitted to you. We do* not
include a full copy of text only for the reason Sat it would bo an
exact duplication of the Riddle Ranch document and conizations betters.
»,™f "^r} °°™""t» »• "W »«Y. are enclosed herein and aro
supplemental to our principal response.
Sincerely,
£JL>-
- John Stoddart
Lois Stoddart
Crow Camp Ranch
HC73-71U Buchanan Rd
Burns, Or. 97720
January 2H, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC ?i*-12533 Highway 20 West
Hines, Or 97738
Refer to response 2-11.
Dear Mr. Carlson
Since ve purchased the Crow Camp Ranch aerf' have the Miller Canyon
range rights we have made a concentrated effort to improve the range
assuming that the suspended I
will be returned to the range right-
By design we reduced numbers. There were so many horses that all
we did was increase the forage for them. Then the horses were re-
moved and the feed did increase. We reduced the length of time
the cattle were on the range in the hope tjf having a lot of old food.
That, too, was euccessful. We feel that, with a normal rainfall
year, and the majority of the wildlife using the forage on our base
property, there is a groat deal more forapo than the grazing ripht
demand of 600 AUHs.
Wo foel that the potential is there and that with an increase of
water holes would further the distribution of the livestock.
r
MsjjeL&£.
John Stoddart
Appendix 11-59
CVWBSITS CO-JCERUNG T-X THREE RIV81S RBSQURSS MANWiBffiHT PLAN AND
RsjVjIVHrtKSTAl. IMPACT STATEMENT:
35
IN REFERENCE TO PARAGRAPH * 5. "COMMENTS 4 RESPONSE'1 , PREPARED BY: RIDDLE
RANCH * WESTERN RANGE SERVICE, WE WHULD ADD THE FOLLOWING- COMMENTS.
ALLOTMENTS 551^ (BIRCH CREEK) * 551? (OTIS MOUNTAIN), THERE HAVE B'SEN
COflCEHHS AND COMPLAINTS OVER LACK Or ALLOCATIONS FOR BIG GAME FORAGE TN
Tac,SS *J.tOT*TCTI\S, TUE *W?V IS, PHAT F3PS SAW HAV3 ML? R = a"-'i I"' TH^92
■■■R-.AS JN -t'-/>Mr ?SAAS 'Mi) MA? KEfi-wrS CO OT^II RAwtfKS 7 j *ttfi| (»;. LI
DOES WOT SEE*i REASONABLE TO ESTABLISH P^R.-iA'iENT FORAGE ALLOCATION ON'
THIS HASIS.
Forage allocations are for the life of the plan. The Drewsey MFP
allocated forage to mule deer In allotments 5516 and 5517, Elk
numbers have Increased planning area wide and were not allocated for
In the Drewsey HFP. Also, refer to response 2-10.
Vegetation conversion is listed as a constraint In the Wheeler Basin
information in the DRKP/DEIS, Appendix 3, Table 6, as a guideline for
future management due to deer winter range.
ALLOTMENT 55^ (WHBBL51 BASIN), THE CONCERN T'lKRS, SSIMG EXCESSIVE
CONVERSION OF PLANT SPECIES IN THE ALLOTMENT AND DOSS NOT ADDRESS THE
FACT THAT IT IS ONLV OWE FOR QW WNTH IM T«E SPRING, T''"S GIVING «MPTE
TIME FO^ RWROWTH. THERE IS NOT A PROBLEM OF WINTER BROWSE FOR DEER, OR
ANY REAL DAMAGE BEING DONE TO PLANTS.
Co ./>#
H*¥
January 17, 19
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 Wemt
Mines, OR 97738
36
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RHP ZEIS
Dear Mr. Carlaont
(If you are facing a reduction in AUM's, please include the next two
paragraphs. If not, cross out second paragraph, )
Alternatives A, B and C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation bo that it is no longer an economical unit. Therefore,
we request that if Alternatives A, B or C are considered, that prior to
Issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a 'Takings Implication Assessment' be completed be
authorized by Executive Order 12630 (see the Hovember 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Model).
The reallocation— andSor-xeduction of
property by approximately s_
AUM's livestock forage
Allotment will reduce the value of our base
(Assume S50 ' per AUM value).
Please consider this economic loss in the requested 'Takings Implication
Assessment. "
The letters from the Harney County CattleWomen, Stockgrowers, Farm Bureau,
Sheep & Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response Is pur endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not Include a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we
supplemental to our principal i
Sincerely,
J. W. & CAROL R03ERT50N
nay have are enclosed herein and are
P.O. BOX 22?
DREWSEY. OREGON
Siy
/yJ . p"*/?. £Z20t
:p L.oae y*- -\ <_
No comment identified.
Enclosure: Supplemental Comments
Appendix 11-60
^ ^m^^-C- yCa
^^
1
^4 /tit* ^^J^e O
Refer Co response 2-63.
Nonuse is applied for and authorized on a year-co-year basis,
therefore, your use of forage available because of Walter Baker's
noause can only be authorized on a year-to-year basis.
38
JENKINS RANCHES, INC. r\ r\
Barton Lake Ranch Diamond, Oregon 97722 Phone: (503) 493-2420 \J \J
January 22, 1990
Refer to response 2-63.
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hines, Oregon 97738
Dear Mr- Carlson,
I am writing with review comments for the October 1989 BLM Draft
Three Rivers RMP/EIS.
Alternatives A, B and C will result in a substantial loss of our
base property value. The proposed BLM actions may result in reducing
the size of our operation so that it is no longer an economical unit.
Therefore, we request that if Alternatives A, B or C are considered,
that prior to issuing the Final Three Rivers Resource Management
Plan and Environmental Impact Statement, a "Takings Implication
Assessment" be completed as authorized by Executive Order 12630 (see
the November 8, 1988 Memorandum to all Assistant Secretaries and
Bureau Directors from Secretary of Interior, Donald P. Hod el ) .
The letters from the Harney County CattleWomen, Stockgrovers, Farm
Bureau, Sheep & Woolgrowers and the January 17, 1990 Riddle Ranch
and Western Range Service Comments and Response to the Draft Three
Rivers Resource Management Plan and Environmental Impact Statement are
consistent with our views and comments.
This response is our endorsement of such letters and Riddle Ranch
commentary. Their response hns been submitted to you. We do not
include a full copy of text only for the reason that it would be an
exact duplication of the Riddle Ranch document and organizations
letters -
Sincerely,
Richard J . Jenkins , President
Patricia E. (Jenkins, Secretary/
-* Treasurer
>ik
Appendix 11-61
39
' /
- /*■* Sort 4i.rf4<M^ ^S?< <&Aj**?2
39 No comment identified.
isponse 2-63.
Appendix 11-62
if,
Hc it - iz-s'i 3 m™ jo u^v
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41-1 Refer to response 1-13.
41-2 Refer to response 12-1.
41-3 Refer to responses 2-44 and 2-45 and DRMP/DEIS, Appendix 2.
41-4 Refer to response 12-1 and 12-7.
41-5 Refer to response 1-11.
41-6 Refer to responses 2-6, 2-10, 2-11 and 2-78.
41-7 Refer to response 2-6.
41-8 Refer to response 3-6.
Appendix 11-63
42
Ken and R&rbara Arnold
TO Box 237
Drewsey, Or 979^
January 25, 1990
Jay Carlson - HKP/EI^
Burns District Office
Bureau of Land Management
HO 7'J-1.2533 Highway 20 We3t
Nines, Or 97?3R
Dear Mr. Carlson;
Enclosed are our comments on the draft Three Rivers Resource Management
Plan dated October lQfl9. We went through Table 2,1, Management Directives
by Alternatives, and addressed each objective. We felt this method would
be the most comprehensive.
We apologize if some of the comments are repetitive, but the solutions
to several of the objectives are repetitive. In general, we found the
report easy to read and would like to commend the staff for the
excellent job thev did in compiling this information.
We hope the final RKF reflects a broad based multiple use plan that
allows commodity use along with improving natural resources, '■.'e don't
feel reducing livestock numbers is the fix-it-all answer. But we feel
that BLM thinks it is. We hope we are wrong.
ha/ enc. 12
Barbara Arnold
Arnold comments page two
As for road closures, it might help in Some areas, but we fear that people
would drive in there anyway and that could result in more ground damage
and plant damage than maintaining a road with water bars and other erosion
prevention measures.
Currently, BLM has good management practices in effect and we feel they
need to be given time to work.
SOILS: We feel this issue was addressed strictly on a daily basis
rather than a long term one. We would like to know if in fencing and
reducing grazing you are excluding game and wild animal3 also? Elk, deer,
antelope and wild horses cause unmeasured damage with their trails.
Domestic livestock use currently existing trails which the wild animals
US 6 year around and keep defined.
Animals are not the only cause of erosion. Fires destroy plants whose
roots hold the soil together and whose foliage diffuses heavy rains. While
we need plant life to slow erosion, too much foliage is a fire waiting for
the right bolt of lightening. Livestock removal will lead to dry, old growth
foliage. which the wild animals would not utilize.
Also, some erosion is natural. The earth Is not static. The alluvial
fans and rimrocks along canyor.s are results of years of erosion, most before
man ever «aw the United States. The Grand Canyon is another example.
FORESTRY k W0QBLAflD3i We feel the current plan is the best. The main
need is to maintain the current lumber supply and the forests. We are avid
hunters and after years of observing game animal habits we know they prefer
slash cut areas that have nev. seedings. These over old growth stands.
Also, if current logging regulations were enforced, erosion and slash
problems would be drastically reduced. But the areas have buffer tree
hedges planted along the roads and old practices continue away from the
public's eye.
(cont)
Arnold comments page one
Arnold comments page threi
In this response we have directed most of our cedents towards Table 2.1
which is Management Directives By Alternatives. Wb have gone through each
catagorie and analyzed the proposed objectives and actions and commented
accordingly.
AIR QUALITY! the "burn limits might be a solution, but the worst air
we have in the county results from fires outside of the state,
WAEER QUALITY: Your catagotization of water quality as poor on the
majority of the streams we feel is in error. The tributaries and the main
branch of the middle fork of the Malheur River are improving, not declining.
There are no more sewage drain fields emptying into the waters. The last
20 years have seen sharp cut banks slough off and grass and shrub growth
begin on these banks. We have had the riparian areas evaluated on our
private ground and the specialist report was stabilised and improving.
We feel most of the current damage in influents has more to do with
unchecked runoffs than with livestock damage. The severe flooding of the
middle fork rips loose these soft banks and the ice flows gouge out plant
growth, keeping the banks unstable. We feel strearabank stabilization
projects should be implemented and do not feel livestock removal is
necessary .
Cattle make up only a snail percentage of animals using streams, ponds
and reservoirs. De^r. elk and wild horses also use these water sources.
Fencing an area would only make other, open areas congested and cause more
erosion. Another question we have about fencing the proposed exclusion
ponds, lakes, springs and reservoirs is how many of these were developed
and / or constructed primarily as animal watering sources? If this was
their original purpose and they have become a multiple use water source,
we feel they should be retained as animal watering sources primarily with
all other uses secondary.
(cont)
As for junipers, let's see the BLM permit unlimited cutting of them,
except in the restricted area, with cleanup guidelines and hopefully reseeding
with a more beneficial plant.
LIVESTOCK GRAZING: The ranchers in the Drewsey and Riley areas have
absorbed all of the cuts in allotment numbers we can afford to. The
value difference between the no action alternative and the emphasize natural
value alternative is Five and one half MILLION DOLLARS I This amount would
certainly affect the livestock industry dependent on these AUK's! Not to
mention the other businesses dependent on the livestock industry. The cattle
are being blamed for something they have no part in. At the turn of the
century, all this area was severely overgrazed. From local cattle and sheep
owners to the sheep trails that saw animals from the south and north pass
through our county. These times saw a dramatic decline in range conditions.
In the 1890's there was bunchgrass and other native grasses. The early
ranchers and. herders abused this pasture. 'Their descendants have been
trying to rebuild the native ranges with BLM and private work through
soedingr. and. reduced numbers - not just of cattle, but of horses as well.
These plans are succeeding. The range is coming back, everyone is trying
to help. We want to maintain and improve the land for the next generations,
not destroy it. The current System is working and needs to be allowed the
time to continue to do so. Vf« can't fix overnight or even in 2H years
what took 30 years to do. Also, there are some areas that have never
grown anything and never will.
The dramatic increase in big game animal numbers also is detrimental to
the AUM's. But the Fish and Game department want more AUM's all the time.
Mot publicly, but they scatter game during hunting seasons so the kill will
be minimal and numbers will increase.
(cont)
Appendix 11-64
42-5 I
The water developments and vegetation treatment are great ideas, but
the gracing reductions arc not called for. Any grazing reduction would be
subject to a "Takings Implication Assessment" as authorized by Executive
order 12630- We feel horse and game animal numbers should also be reduced
if a reduction can not be avoided. The reductions should be equally
distributed amoung livestock, horses and wild animal AlRI's,
WILD HORSES 4 BURROS: We Here glad to see minimum and maximum
numbers for the horse herds. Please keep these herds within these ranges
by "Utheriir when herd numbers reach the maximum. We don't feel ACEC
status is needed as the horse herds are within their optimum levels
currently, This shows the current RMP is working well. We have mixed
feelings about the plan to acquire private land. Each acquisition should'!--
be carefully considered and should be used only when it is mutually beneficial
to both the land owner and BLM. We know the Keger herd is gaining national
recognition and feel current practices will maintain the herd.
VEGETATION! One area should be enough for the Oregon Natural
Heritage Plan cell needs. Locking up land for the current species is
not logical. Areas are not static but are continually changing. What
was here a thousand years ago is not here today and what is here today
will not necessarily be here in the future. These changes will occur
with or without human interference. Plant communities are constantly
changing, going from the early stages to the climax species. We strongly
feel that reserving areas for a few interested sightseers is unconstitutional.
It restricts the majority of people acess to these public lands, which all
arc entitled to See and use. It also doer. 't follow BLM's multiple use
policy. We do agree with controlling noxious weeds and feel this
problem has been Ignored for too long in Harney County,
(cont)
Arnold comment page six
The fences constructed fan wildlife will not always hold cattle and
that could cause a potential trespass problem. Thlo would not be the
permittee's fault, but would be their problem. Wild animals adapt and
survive. They always make it through existing fences, occasionally
breaking wires and flattening sections of the fence. He don't see new
fences making any major changes. The only ..major change would be to
eliminate fences completely and then we would be back in the 1950s,
loosing what has been gained in the last U0 years!
Me don't see the need to allocate more than the current AUM's of cattle
forage to big game. Please permit current grazing pracitces to continue.
Also, there is a mistake on the number of guzzlers in each of the options.
WETLAND, RESERVOIR MED MEADOW HABIJATl In reference to appendix 5,
table 3. we understand the hardship the wide fluctuation of water causes
at Warm Springs Reservoir. We do not see cattle and blrd3 lnterferring
with each other. The refuge also thought that and have found out the
cattle and other agriculture practices were necessary to maintain the
bird population.
Much work has been done by the government to reclaim wetlands and
return them to production. It is with dismay that we observe the reversal
of this policy arjd feel it is a serious mistake.
RIFARIA" HABITAT: Again, you have singled out livestock as the Sole
problem. Wildlife and unchecked runoffs also add considerably to this
problem. Enclosures should not be used unless they are complete, shutting
out wildlife as well as domestic livestock. Currently, most riparian areas
are stabilized and improving. Time, streambank stabilization projects and
runoff flow checks would dramatically help riparian areas without removing
livestock.
Also, please note the current ULTI riparian area management policy,
signed. 1-22-8?, states that a riparian area is "directly influenced by
(cont)
Arnold comment page five
SPECIAL STATUS SPECIES i Again, plant and animal communities are
constantly changing, some will become extinct and new ones will evolve.
Special management will only delay the inevitable. We disagree grouse
need big sagebrush. There are several flocks of grouse in our area and
they prefer crested wheat seedings and/or meadows to sagebrush areas. That
is sage brush areas on flat, open ground. They do like deep, sage
choked canyons. We think the two mile buffer zone is extreme and would
like to see all areas that are seedable to crested wheat seeded. Leave
the sage brush on the steep hlllr, in the canyons for their private areas.
Besides, these sage brush covered flats at one time were likely a bunch
grass pasture with little sage brush.
Number 1^ oil Table 2.1 - IS under option A and B needs to be clarified.
The area is right on top of Bartlett Mountain and not on the side slopes.
Again, we protest livestock removal as the plant and animal species are
recovering and doing so with livestock present. Also, if livestock are
removed , what about wild horses and game animals? These must also be re-
moved, Then plant "growth will be unchecked by grazing, old growth will
become rampant and eventually fire will destroy the area and there
will be nothing left.
Cattle are not the ones affecting the fish. Too many fishermen s.iy'.
trash fish which eat the trout fingerlings and the trouts food are the
main problems. Poisoning undesireable fish is now forbidden, so that
management tool Is lost. These problems need to h& addressed. Removing
cattle is not the ultimate cure for many of the problems 3LM is facing.
WILDLIFE HABITAT MANAGEMENT: We approve of road closures during
winter months as long as it does not interfer with access to domestic
animals on winter allotments. In this area the cow again becomes the
automatic scapegoat for all the problems,
(cont)
Arnold comment page seven
permanent water". Permanent is underlined as Warm Springs Creek, Little
Pine Creek, Beaver Dam Creek, Blue 'iucket Creek, Little Muddy Creek,
Stinkingwater Creek, Middle Fork Malheur River and the South .Fork Malheur
River go dry during long hot summers. So they can not, under JiLM's own
definition, be called riparian areas as the water is not permanent I
RAPTORS; You have covered this area well. It is sad that people have
to choose. If we keep raptors, we loose game birds such as pheasants,
quail and chuckars as raptors prey on them.
AQUATIC HABITAT; We applaud implementing aquatic habitat enhancement
project work in the Middle Fork Malheur River. That and streambank stabilzation,
where needed, will help the fish population. As will removing the trash
fish from the river and reservoir. We fish the middle fork and for every
bass arid trout we catch, we catch up to four times as many suckers.
Also the number of people fishing the river has dramatically increased ,
resulting in lower fish takes.
Again, you want to pull livestock and again we must remind you of wild
animals, including horses, that also use the river. You can't blame it
all on cattle!
Also, most of the Middle Pork Malheur River passes through private ground
over Which you have no control.
Oregon Pish and Game own several miles of river below Ul highway 20 and
cattle grazing has been severely limited in this allotment for over a decade.
The water, river hanks, etc. have not changed dramatically from the areas
where cattle are still on the river.
Your proposal to enhance warm water fish and their habitat are great!
At the Pish £ Game public meeting in Burns Jan. 17, 1990. this item was
also discussed and many people feel the need to establish more pan fish.
We feel the proposed projects outlined at your question and answer session
(cont)
Appendix 11-65
.ent page eigbt
Arnold comment page 10
will help. The only reservation Is potential interference between recreation
use and the submerged logs during low water years. He feel several
reservoirs, higher in the watersheds, could solve many problems and
keep water flows more consistant year after year.
HAZARDOUS MATERIALS: Please keep hazardous waste off all land. Let's
find a way to neutralize this material before it is disposed of, thus
eliminating this problem. Cities need to learn to recycle and reuse.
We do not need to be Western Oregon, Washington and California's dumpl
FIRE: Keep fire for the valuable management tool it is. Look at each
fire separately and if it will benefit the land by removing unwanted brush,
let it burn.
RECREATION: We disagree with the propossed plan to remove livestock
from riparian areas for reasons already listed in our comments. We also
feel the designation of the 5 A mile section of the Middle Fork Malheur
River as part of the Wild and Scenic River system is unnecessary. This
area is isolated and seldom used. The designation could create more problems
than it would solve. This area has seen many man caused changes over the
last 150 years so technically it does not fit into the wilderness categoric.
He personally feel that wilderness areas arc unconstitutional as they
deprive some people from access to the land which is publicly owned , and
reserve it for only a few.
We have the allotment on the west side of Warm Springs Reservoir. During
the summer months, we spend a lot of time there and visit with the recreationists
using the area.. We have never found anyone who objected to cattle sharing
the area, however, with the current use of four wheelers, we prefer our
cattle to be else where as we have had problems with then being chased!
This problem has no easy solution, except limiting areas of use for the ORV.
(cont)
CULTURAL RPSQURCESi This is an explosive area and again we are
against an earth museum except in some of the areas li3tcd here. We
agree with most of the plan under the preferred categorie. Some
thousand years from now we will be under some microscope as we are
artifact gathered. Yes, we must preserve some of our lands heritage,
but we also must learn that time passes and we have no control of that.
Some areas you wish to withdraw from livestock use, such as the Native
American root gathering areas. The cattle and sheep have ranged on these
areas for about 100 years with no ill effect on the plants in question.
In fact the "natural fertilizer" left behind- has probably helped, not
hurt these crops I
As for acquiring more private land, we have enough land under public
ownership in the state, 'iut it is each individuals right to dispose of
their land as they decide. But if they wish to retain ownership of the
land, that is also their right. Wo would like to 3ee taking by condemnation
prohibited In the final plan in all areas whore private land acquisition
is considered.
ENERGY & MINERALS! We feel that Harney County needs all the commercial
help it 'can get. If this includes BLM leasing mineral, gas and geothermal
rights, please don't hesitate to lease them. Just provide for
protection of the environment . We agree with the management objectives.
LANDS k REALTY: After studying these maps and objectives, we do not
see the nocd of acquiring all the private land designated for Zl and Z2.
There would only be small private communities in an area owned by the
government. This is not the basics of the United States! We do not feel
such wide spread acquisition is necessary. Also, funding for this
project would be astronomical, especially for a federal budget that has
(cont)
Arnold comment page nine
Arnold comment page 11
42-20 ;
A lot of effort and money was put into the crested wheat seedings. Now,
due to recreation use, we can not use the reservoir field except early and
late In the grazing period-. The dry years, low water and dry feed has
prevented use from using it in the fall for several years. As a result,
wolf plants are appearing and both BLM and we agree these are bad. We would
like to see the recreation areas fenced, similar to campground fencing the
forest service uses. Then we could utilize these seodings during the summer
when there were not many users. Also, this would allow more flexibility
to our grazing plan during dry years. This would be beneficial to all.
ACECs We have many mixed reactions to this section, mostly the fact
that our environment is continually changing with or without man's
influence. Trying to make a section of the living earth into a museum
goes against nature. This is what we perceive ACEC are for. It would be
nice to take a certain area and freeze it in time for future observation.
But that is impracticable when you are dealing with a dynamic environment.
Even In the lava beds a tree might take root and severely disrupt part
of the lava flow. We do not feel that additional land needs to be added
to this "earth museum".
VISUAL RESOURCES 1 Wellove the way our county looks and hope it remains
this way forever, however we know that land continually changes so our
hope Is futile. We accept that. Land erodes and deposits elsewhere, streams
aiiri rivers continually change course, carving new ctiannfl.3 in the land. Or.
our land, where once was a deep pool in the river, now is a aanrl bar.
Plants grow, die, are uprooted or eaten. This Is the master plan and has
been for centuries,
You have a preserve class and again we do not feel you can preserve a
dynamic thing without altering it. The best policy is a moderate one.
Man has been hero for centuries and Harney County is not an eye sore!
(cont)
not seen black ink for many years.
This objective, "consolidate public landholdings and acquire lands with
significant resource values values", is not in the public's best
interest. Nor in the interest of the private landholders in the Three
Rivers Area.
We do applaud corridors for utility and transportation needs. Also,
transferring existing dumps to the county sounded like a good idea, until
wo learned that the federal government Is imposing guidelines on dump
construction which could be a financial hardship for Harney County. Again
we ask that acquiring access to land and/or land itself through
condemnation be forbidden in the final plan.
We do not feel that the lands listed in Appendix 10, Table 5 would
best serve public interest if withdrawn from Public Land Laws, We feel
they should be carefully managed in the current practices without drastic
changes. Let's not lock up this county, but keep it as a renewable,
useable resource.
ALLOTMENT 5566: Texaco Basin Is our allotment and we feel the water
quality is excellent In this allotment and would like to see the data
that determiner? poor water quality,
Al3o, here again you discuss riparian habitat and the streams in this
allotment are not year long flowing streams. Jeveral times since we have
been in this allotment Warm Springs Creek has gone dry. The reservoir
has boon a small pool against the dam Several times in the 1980's. The
river has boon a small stream or completely dry. According to BLM's
definition, the only area with live water would be the river. This would
also include Warm Springs Reservoir as the reservoir was established for
(cont)
Appendix 11-66
irrigation purposes, not recreation. The primary objective needs to be
remembered and not replaced by a secondary benefit such as recreation.
It is great that recreation has been a added use, but feel that the
primary use, irrigation water, should not suffer for recreational use.
We: hope that the final plan reflects your current practices with a few
modifications. Please do not look at livestock reduction and removal as
the main answer to the problems.
The Taylor Grazing Act's primary purpose was to control grazing on the
public lands, lixim Blifl has evolved, the purpose-*; have become varied and
many. A;";ain, please dp not forget the primary one, the frrazinc of livestock!
A quick note on mistakes. In the text, the map index is usually two pages
off from where listed. Also in Table 2.1 on page 44 under option A in the
second #1 I think you mean Appendix 10 not 11.
Sincerely,
Ken Arnold
■y
Barbara Arnold
To meet: the objectives of riparian, water quality and aquatic
habitat, wild horses will need to be managed in a manner similar to
livestock. They may be fenced from riparian areas or moved from these
riparian pastures during critical periods in order to achieve a
thriving ecological balance and meet the objectives of multiple-use
and sustained yield as described in Sections 2 and 3 of the Wild and
Free-Roaming Horse and Burro Act of 1971. Also, refer to responses
2-28 and 2-31.
There has been no a
on BLM public land.
ithorization of discharge of ha;
lrdo
materials
Refer to response 4-9.
Segment A, Middle Fork of the Malheur River, does meet the criteria
for a potential Wild River under the provisions of the Wild and
Scenic Rivers Act (Public Law 90-542 as amended). A study process was
completed which considered free-flowing values , outstandingly
remarkable values, classification as wild, scenic and/or recreational
and determination of suitability.
The 5.4 miles of river reach within the 1/2 mile corridor basically
includes the land area between the river rims and very few
human-caused changes are evident. See response 3-6 and Table 2,
Appendix 11 of the DRHP/DEIS In which values for the various river
segments were noted (i.e. primitive trail, primitive road, drift
fences).
There are currently 23,811 acres of BLM-administered land which are
designated as limited to off-road vehicle use around the perimeter of
Warm Springs Reservoir in the Burns District. This designation limits
the use of motorized vehicles to designated, existing roads and
trails. However, the areas near the reservoir where conflicts are
occurring are on lands withdrawn and administered by the Bureau of
Reclamation (BOR) . The BOR has a recreation management plan to manage
recreation use, including regulation of ORV use, but has not made
their presence known by fencing or signing of acres near the
reservoir.
Portions of the seedings on the west side of the reservoir are on BOR
lands, so coordination is necessary before establishing any new fence
locations, implementing signing and enforcing regulations.
An action recommending the acreage designated limited be reduced to
the land area around the reservoir in Reservoir Pasture, No. 5566,
and the remaining acres be returned to management under an open
designation is In the proposed PRMP/FEIS.
42-20 Refer to response 42-19.
42-21 Refer to responses 15-16 and 42-7.
42-22 See response 2-82 which discusses retention or preservation of scenic
values for specific places (Class I and II areas as noted on Map
VRM-1 in Chapter 3, Volume I of the DRMP/DEIS).
42-1
42-2
42-3
42-4
42-5
42-6
42-7
42-8
42-9
42
-11
42
-13
42
-14
Refer to response 2-3 and PRMP/FEIS, Table 2.1.
Juniper cutting is permitted within specific areas. This method has
proven to be more effective at removing enough juniper to release
understory vegetation when compared to indiscriminate cutting
areawide. Also, some juniper stands are providing good cover for big
game and the juniper/sagebrush type provides habitat for many
songbird species. Juniper removal on site-specific areas can enhance
understory species while allowing for continued juniper habitat
availability.
Refer to responses 2-10 and 2-11.
Refer to response 2-63.
Refer to response 2-6.
Refer to response 3-16 and 4-14.
The Oregon Natural Heritage Plan (1988) has many cells for
terrestrial and aquatic ecosystems. Each of the areas being
considered for designation as an RNA/ACEC will fill one or several of
these cells. It is correct that vegetation is not static. However,
areas designated as RNA/AGECs do provide ecosystems where, hopefully,
there is minimal modern human Interference. These areas can be
utilized for ecological studies, monitoring and research, and
education. Information obtained about changes occurring within an
RNA/ACEC will provide a basis to which communities, where a full
range of other multiple-use activities are ongoing, can be compared.
Refer to response 2-78.
There are no road closures that would interfere with access to
livestock on winter allotments. These roads are needed for
administrative purposes and would not be closed.
Fence specifications for fences built in areas of wildlife use are
outlined in BLM Manual Handbook H-1741-1. Fence design will be
determined on a case-by-case basis that will provide for the movement
of wildlife. This has been a standard stipulation in the past MFPs
and Is not proposed for change (see Appendix 1, Table 12, Proposed
Plan).
See management action WL 2.4 of the Proposed Plan.
The riparian management actions have been revised, see management
actions WL 6.1, 6.2 and 6.3 of the Proposed Plan.
Refer to response 2-3, 2-4 and 2-44.
The definition goes on to state "Excluded are such sites as ephemeral
streams or washes that do not exhibit the presence of vegetation
dependent upon free water in the soil." The areas named have
vegetation present that Is dependent upon free water in the soil.
Also, see Appendix 1, Table 4 of the Proposed Plan.
There are 8,560 acres which are under a VRM Class I. These areas are
the two WSAs (Malheur River /Blue bucket Creek and Stonehouse) which
are mandated to be managed as Class X under Wilderness IMP. If these
WSAs are designated wilderness, Class I visual management will
continue. If the WSAs are returned to multiple-use management, the
areas will probably be managed under VRM Class II and 2,040 acres in
Malheur RIver/Bluebucket Creek will remain under VRM Class I as an
administered primitive area. Since scenic resources are high in both
WSAs, this class is still restrictive on what developments will be
allowed.
42-23 Refer to response 4-15.
42-24 Refer to responses 3-16, 4-14 and 6-10.
42-25 The objective of the land tenure zone concept is not to acquire all
lands In Zones 1 and 2. This would be an unrealistic expectation
since most land tenure adjustment would be through exchange. The
concept does provide a means which can help direct land tenure
efforts and funding in specific areas.
A large increase in funding for land tenure adjustment is not
expected. Consequently, changes in the overall landownership pattern
of the RA would be gradual over a long period of time.
Because exchanges will be the primary mode of land transfer, any
increase in public land acreage in Zone 1 would generally have a
corresponding increase of private ownership in Zones 2 and 3.
Also, refer to responses 3-16, 4-14 and 6-10.
42-26 Refer to response 3-16, 4-14, 6-10 and 42-25.
42-27 Section 204 of FLPMA gives the Secretary of the Interior authority to
make, modify, extend or revoke withdrawals.
Diamond Craters ONA/ACEC is already withdrawn from the public land
laws. The 400 acres Identified in Table 2.25 are adjacent to the
existing withdrawal and contain similar outstanding geologic and
natural features as within Diamond Craters. Some of these features
have been damaged from past mining of decorative slab lava. The
additional withdrawal would help protect the features from further
damage as well as provide consistency of management for the entire
Craters complex.
The 640 acres identified for Squaw Butte Experiment Station is
currently under State ownership. The parcel is proposed for exchange
to the United States. If the land is acquired, the withdrawal would
provide two Important purposes. First it would transfer jurisdiction
from the BLM to the Agricultural Research Service, USDA. Second, it
would protect the land from mineral or other activity which might be
incompatible with the ongoing range and agricultural research
occurring at Squaw Butte. As with Diamond Craters, this would be an
addition to an existing withdrawal.
Appendix 11-67
Some of the acreage in Table 2.25 is a proposed withdrawal for the
Blucbucket Creek and Middle Fork of the Malheur River. This would be
an Interim withdrawal to protect the areas pending final action by
Congress on Wild and Scenic Rivers designation. Finally, Chlckahominy
Special Recreation Management Area is being added to the Proposed
Plan for withdrawal to protect campground facilities and adjacent
land from mining and other nondiscretionary activities which are
generally noncompatlble with intensive recreation use.
Refer to response 42-14.
Refer to response 42-14.
Page numbers for maps VRM-1, M-l through M-5, L-l and L-2 are in
error. There were admittedly other page numbering errors in the
draft, and we apologize for this inconvenience in reviewing the
document. Stringent editing has been applied in the PRMP/FEIS to
ensure that such errors are not repeated. The Appendix 11 citation
should read Appendix 10.
m
REX CLEMENS RANCH INC.
thought there was not a problem with the cattle and horses,
shar i ng the range ■ The proposed pi ans in the draft wf 1 1
make the -future of the horses seem better. These pi ans are
very misleading. The horses' future will not actually be
any better; but it will just appear to be that way.
Actually the plan will just suppress the cattle issue with
no actual better changes for the horses in the long run. I
it afn't broke, don't fix it!
Jay Carlson, RMP/EIS Team Leader
Bureau of Land Management
Burns District Office
HC 74-12533 Highway 20 W.
Hines, OR 97738
Dear Mr
Carl son
This letter concerns the aspects of the Three Rivers
Management Draft PI an that immedi ately affect Rex CI emens
Ranch. Our affected allotments are the Kiger,, Smyth Creek,
and Deep Creek a 11 otmen ts .
The en t i re proposed p t an of the Ki ger , Smyth Creek , and
Deep Creek allotments is basically centered on the issue of
the mustangs. The BLM's vision is f urine 1 ed positively
toward wild horses and negatively toward cattle. This
narrowness of mind is shown in all catagories in the draft
varying from riparian zones, forage utilization, to land
Presently the Kiger mustangs are the hot fad of the
Burns BLM. PI ease do not allow this fad to adverse 1 y cl oud
the long term management plan of the area's entire resource
pool. Remember that this isamulti-use area. If this area
is properly managed the range conditions will continue to
improve and it can be shared by wild horses, cattle, deer,
elk, and recreational ists.
Ideally we would not like there to be any wild horses
at all on our range. But due to a great deal of public
Interest for the Kiger mustangs we do recognize a need to
put these horses somewhere . And due to the ci rcumstances of
bad luck our range was chosen for these mustangs. The BLM
has been running the Kiger mustangs along with our cattle
for abou t the last 10 years. This arrangement t has worked
we 11. There has been plenty of forage year round for the
horses as well as plenty of forage for the cattle during the
grazing season. So if things are fine now why change them?
The proposed reduction of cattle grazing on this range is
not necessary. This fact is proven by the evidence Of the
past 10 years of grazing horses and cattle together at the
level of utilization that has been used on this range.
Last year at the Ki ger mustang observat i on site
dedication I heard several of the KMA people say that they
Lie believe the BLM is negligently biased for the Kiger
mustangs and against cattle in this draft.
The BLM has failed to analyze some of the negative
aspects that the wild horses do to the environment. They
have failed to analyze the effect the horses have on the
r i par i an zones. Yank Creek is a pr ime ex amp 1 e of th i s
damage. There have been no cattle in this creek for several
years, just horses .
Horses favor the grass that grows in the creek bank
areas. They graze this grass to the root stub destroying
the crown of the plant with their close-biting nature. In
Yank Creek this has led to several areas that are grazed
bare and are subjec t to severe erosl on . The sof t spr i ngy
areas are trompped to pieces. It is the nature of horses to
graze these f avor i te grasses next to the creek until they
are gone . The stated "f ree-f oami ng" concept of managi ng
horses is not in the best interest of the resource area as a
whol e .
Prioritizing wild horses above big game and then cattle
is wrong (App. 3-50). We believe the Taylor Grazing Act
does not support priority allocations such as this.
On the issue of forage utilization, App. 3-50 has a big
falicy listed in the conflicts column. It is stated that
"cal cu 1 ated capac i ty is 1 ess than 'forage demand . " Th i S is
wrong or your cal cul at i ons are too 1 ow . Th i s all otmen t i s
i n good shape and it presently has a lot of forage left oven
for the horses and wildlife. It is we 1 1 Known that I ow
utilization of forage will cause a downward trend In the
status of the watershed as a whole.
Appendixes 3-49, 3-57, and 3-42 state that "no
management system established in the allotment." Look at
App . 3-6 , 3-9 , and 3-12; they indicate that there is a
management plan. We have been following a management plan
in these allotments for years.
It would be wrong to enlarge the Kiger HMA as proposed.
The East and West Diamond Grade fields of the Smyth Creek
allotment should not be added to the initial HMA. There
have not been horses down this low In the past. The fields
also contain a large portion of Crested Wheatgrass which
Appendix 11-68
does not coinside with the "wild" envi ronment desi red for
the "wild" hors.es. Why h»ue the HMA larger than what the
horses actually use?
There is no need to have the Kiger HliA become an ACEC.
Classification as an ACEC would just bring on more useless
regulations that would block potential future good
multi-use, mul t i -resource management systems. It would be
poor judgement for the BLM to invite this classification
when it is unnecessary.
Ule do not know why the BLM thinks that the parcels of
land that we own on Yank Creek, Poison Creek, and Swamp
Creek are for sale. They are not for sale. Ue also think
that It is greedy for the BLM to want them. The mustangs
water in these creeks just as easily now as if the BLM owned
them.
One has to wonder if the BLM is really just trying to
pressure Mrs. CI emens out of the ranching business so they
can take over the Riddle Ranch on the Little BUtzen River
sooner .
Ue believe that the best action for the BLM to take for
the Three Rivers Resource Area is no action. No action is a
legitimate plan that the BLM did not even consider.
Ue hope that you will seriously consider these comments
on the draft pi an . Thank you for your consideration.
Daniel R. Barnhart,
Represen tat i ve of
Rex Clemens Ranch Inc.
Diamond, Oregon 97722
43-1 There was no analysis of how wild horse movements would be affected
when fencing and grazing systems are implemented on riparian areas
and pastures at this time. Such impacts would be analyzed through the
NEPA process on specific projects and appropriate mitigations would
be applied to minimize detrimental effects on wild horse movement.
Also, refer to responses 25-2 and 25-3.
43-2 Refer to response 42-15.
43-3 Refer to response 2-6.
43-4 The allotment evaluation is not complete for the Kiger Allotment. The
capacity listed in DRMP/DEIS, Appendix 3, Table 6, p. 50, is an
estimate only. Calculated capacity will be determined in accordance
with the methods outlined in Appendix 1, Table 11, PRMP/FEIS.
43-5 The DRMP/DEIS incorrectly listed the Smyth Creek Allotment; there is
an AMP on Smyth Creek Allotment. Although grazing treatments are
outlined for Deep Creek, Hamilton Individual and West Sagehen, they
have never been formally incorporated into an AMP.
43-6 Refer to response 25-1,
43-7 Refer to response 2-68.
43-8 Refer to response 4-14.
43-9 Refer to response 2-2.
44
LaPine High School
P.O. n.ix 306
LaPine, Oregon 9/ 739
(503) 536-1783
District Manager
Bureau of Land Manned
HC-7412533 Hwy 20 Wes
Hines, Oregon 97738
It has come to the attention of the I.aPIne Hich School Advanced
Forestry class that an Environmental Impact Statement has just been
released for public comment. An Immediate operation should be
to return the land to an excellent condition. Presently, the poor
condition of the land disturbs those who enjoy the scenery and
surroundings. The draft basically does not protect the remaining fur
or explain how many miles of road It expects to construct.
One thing evidently not covered was the effect it will cause to the
wildlife. Most forage allocations belongs co cattle, which should no
44-1 Refer to responses 2-10 and 2-11.
44-2 Refer to response 1-13.
44-3 Refer to response 2-44.
44-4 Refer to response 12-1.
44-5 Refer to responses 12-1 and 12-7.
44-6 Refer to response 1-11.
44-7 Refer to response 2-6.
44-8 Refer to response 2-78.
he the is.
44-4 I
44-5 1
44-6 |
44-7 |
44-8 I
We would like to recommend (or demand) that BLM develope art alternative
to restore and maintain ran;;eland in excellent, natural condition.
Also that BIM adopt Alternative "A", which would allow full
rangeland, raparian and stream recovery. We insist that
water quality, riparian and aqn.il.ii.- habitat be improved or maintained
in excel U-:»t condition and ask th.-it all ancient forests be identified
and protected. We also ask that all costs of construction of new
roads and other rangeland projects be included under the various alternatives
along with their environmental impacts and that all crested wheatprass
seeding proposals be eliminated. Wc would like to recommend that
wildlife winter range forage allocations be given priority over livestock
allocations ;md demand that Bighorn Shggg Hahicat protection cad
cts be addressed In plan and further, that forage allocation;]
nllrely to the Bighorns In their home range.
Thank you for your consideration on this
President'
Vice-President
■eere La ry -Treasurer
.T)n,lA>,, S9.I0H)
Raul
Appendix 11-69
45-3
45-4
Zfhs
45
/&*&, *&%***<. <???*&
■rfzad-
Ut ^^-zc^ Agd^fr^ /</ 6t*fy* ■ c-^^^ ',
/*ZB.
fl£^tJZ0 /&&SC&L *Z&L t£,£cfy/*djte£$
-^}-~tf?iz&£/ a^efJ&t&ifteJvid' ;&&?£&—
fate. *?£&*■ jH*U&J /&fsj*0at&K>,<s&£/i/'*
W£%£~ A&efyd A^cZ^a- J^Ct^w^- J^za^tJ^Lj Jk^J^p,
45-1
Refer
to
response 1-13.
45-2
Refer
to
response 2-44.
45-3
Refer
to
response 12-1.
45-4
Refer
to
responses 12-1 and 12-7.
45-5
Refer
to
response 1-11.
45-6
Refer
to
response 2-10.
45-7
Refer
to
response 2-78.
45-8
Refer
to
response 3-6.
45-9
Accor
lln
j to Federal timber expor
timber is exported from the United States. Only private
unmanufactured timber is permitted to be exported. Currently, there
is strong support for legislation allowing individual states to
decide whether to restrict or permit exportation of private timber.
In regard to ancient forests, refer to
;spons
12-1.
Appendix 11-70
Riley, Oregon 97758
Jay Carlson - RMP/EIS
Burns District Office
Bureau of Land Management
HC 74-1.2533 Highway 20 West
Mines, uregon 97738
January 19, 199
REVIEW COMMENTS i'OH THE OCTOBEH 19H9
BLH DRAFT THREE RIVERS RHf/EIS
Dear Hr. Carlson,
The Harney County Farm Bureau want to go on record that the January
17, 1993 Riddle Ranch and Western Range Service comments and response
to the Draft Three Rivers Resource Management Plan and Environmental
impact statement are consistent with our views and comments. This
response is our endorsement of such Riddle Ranch document. Their
response has been submitted to you. We do not include a full copy of
the text only for the reason that it would be an exact duplication of
the Riddle Ranch document. There are several other areas of concern
that this letter will address,
Bure
Enclosed is a copy of tht
Management Policy, dated
Robert J. Burford. This
that the deiinicion
inrluenced by perma
physical characteri
The definition cont
riparian area include "ephemera
the presence or vegetati<
There are areas classirii
criteria . Two creeks brought to
Landing Creek. A thorou
ensure they meet the def
meet the requiremei
Of Land Management Riparian Area
January 22, 1987 signed by BLH Director
policy has never been rescinded. Please note
riparian area is an area ot land "directly
isible vegetation or
anent water influence."
from the definition of a
ashes that do not exhibit
e water in the soil. "
water, and having
reflective of perm
reas excJ
1 Stream:
ndent upc
iparian that do not meet these
gh review of all
lnitlon of ripar
QUI
d be taken
ion are Skull Creek and
eeks should be made to
rian area. Any that do not
ut of that classification.
restrict the amount of available forage and can concentrate cattle
more than necessary. Livestock have a biological need for water.
Access can be accomplished by building the water gaps at the deep end
of the reservoir. It the enclosure is more than one-half mile square,
have more than one access point to allow livestock better access to
all of the forage available around the reservoir.
Before any alternative that causes a reduction of AUH's is imposed,
no matter what reason, a complete "Takings Implications Assessment"
should be completed as authorized by Executive Order 12630.
natur
The
itat
reas
well
will
11 al
tasro
proving torage by burning Juniper and
tations on prescribed burnings, as wel
ions and full suppression of natural tires, will continue
brush and Juniper encroachment. This
ive effect on the vegetation and grasses used by wi
and livestock. A more open policy on prescribed bu
ing natural fires burn under tire management supervi
ntain and improve a maiority of the existing range,
ds building to a point that a major
It. It is well known that smaller c
eturn ot native vegetation, than one
negat
rses
lett
lp ma
so pr
phe £
way of
osed li
fuel
ould r
are better ror the re
ill
dlife,
ns , as
ler
ajor
estrictions are the same for all
to be proposed. Unless there ii
limits above this would permenar
itations should be increased.
alternatives. Mor
valid scientific
tly effect air
hot fire.
The air quality
alternatives nee
data to show tha
quality these li
Harney County recently passed a ballot measure that stated they did
not want any more land acquired by the government. The Land and
Realty Objectives indicate the plan to increase holdings with high
public resourca values through exchanges and acquisition
should listen to the public voice and hono
acquired land should be by exchanges only.
their decision.
BLH
All new
/ &*,
4s
JpU>
Herb Davis, President
Harney County farm Bereau
Box lib
Princeton, Oregon 97721
Monitoring techniques currently in use on the Three Rivers Resource
Area are insufficient, inaccurate, and improperly applied and then are
extrapolated to indefensible conclusions. Management objectives, in
the absence of AMP ' s , are documented only in the broadest of terms
wildlife, wi
affecting fo
resource . T
primary, if
techniques a
livestock gr
information
then be made
satisfactory
virtually unmea
Id horse and li
rage production
heref ore , reduc
not the only, r
nd accurate inf
azing should be
shows trend inc
The ratings
ary Update clas
t. The RMP/EIS
and unsatisfac
for accurate e
surable. No r actors, other than short term
ve stock utilization, are indicated as
, ecological status or potential of the
tions in authorized livestock use is the
erne dial action recommended . Until proper
ormation is gathered existing levels of
maintained. At such time that reliable
rease or decrease, proper adjustments could
in the recently published Riley Range land
sify range conditions as poor, fair, good,
classifies range conditions as
tory. Consistent use of evaluation ratings
valuation as well as better communication
the
There is no scientific data that indicates that livestock use has any
negative effect on the sageg rouse population. The restrictions on
livestock in the sagegrouse strutting grounds are unfounded and should
be eliminated .
The exclusion ot cattle on the Biscuit root Cultural AC EC is not
supported. The report states " . . .these areas to be a high-value
resource due to the quality and quantity ot roots available."
Appendix 7-12; Vol. II Appendicies . Since grazing has been going on
in this area for years and the quality and quantity have remained
high,
the practice
ith
harves
lustifi
cha
The de
{HMA)
( ACEC)
ranchs
Rivers
should
Livest
The co
proven
the author
Addressed.
lignatlon of the entire Kiger active Horse Management Area
36,619 acres) as an Area of Critical Environmental Concern
will have a dramatic economical effect on at least three
Before this change is even considered and the Final Three
HHP/BIS is issued a complete "Takings Implication Assessment-
be conducted as authorized by Executive Order 126 30.
ick and wild horses have run together successfully for years.
iplete elimination of livestock grazing is neither justified nor
necessary. The conditions tor acquiring the private holds or
.hority to Impose this on the private holdings is not fully
46-1 Skull Creek and Landing Creek have vegetation present which is
dependent upon free water in the soil. Also, sec Appendix 1, Table 4
of the Proposed Plan.
46-2 Refer to response 2-87.
46-3 Refer to response 4-6.
46-4 Refer to response 4—15.
46-5 Refer to response 2-68.
46-6 Refer to response 2-63.
46-7 Refer to response 32-1.
46-8 Refer to response 2-46.
46-9 Refer to response 4-9 and 5-6.
46-10 Refer to response 4-8.
46-11 The ballot measure referenced was specific to land acquisitions by
the USFWS.
Since publication of the DRMP/DEIS, the Harney County Court passed a
resolution opposing all Federal land acquisitions without public
hearings and consent of the court. The BLM has, In the past, and will
continue to coordinate and consult with the county on matters
involving land acquisitions.
Also, refer to responses 4-14 and 6-10.
The continual fencing of reservoirs is in direct conflict with the BLM
objective to disperse livestock away trom riparian areas and improve
forage utilization. These reservoirs would not be there today if it
had not been for either the range improvement funds or private funds
. that first developed them. The small water gaps that dry up during
the season or don't allow livestock to water during low water years
Appendix 11-71
4j7
Jan. S.'j.jl.'S"'
Jay Carlson B.L.K
HC. 1L, 133533
nines, Oregon 9773S
Dear lir. QsrlsoB,
As members of nVrney County Stockgrowurs/^arm ^ursau/Catt] evomen and VFW -
our response to the draft - Three Rivars Resource 1 Jttnagement Plan St Environ-
mental Ifflpaet Statement in our opinion effects the whole county in all walks
of life. This fir* ft is HOT IfflD© f.He ^referred s* tar-native in to use al3
this paper work of many hours and dollfrs for firematerirl. Support the manage-
ment on pu:iic Im&a that was intended when the livestock Taylor Ornsing Aot of
1934/36 was put forth, WITHOUT the adverse imprct of this dr-ft K-tP/SIS un-
eexffliBfling the livestock producer and I3L",by special interest grouos of tfiodsy.
The livestock industry across the west are besieged with proposing regula-
tions unnn rorul rtiona sue': ,"e this \'v> f t, end would effect end cost then their
livelihoods - sevsrly wounding the small sparcely populated communities - such
ss Bums/nines end rural Harney County.
Alternatives A, 3 and C will result in substantial LOSS of base private pro-
perty vrlue Ai'JD our educational system for fil] vw Iks of life. Tine 31 K action
could rsauli i.3 r«ducin£ '.'".'" ai«s o* STcrrtiflns in ':!;■■■ "ivostock "',:'n""stry thrt
ere ff'riiily i^tr'ted rn3 be know ] on, ;yjr '.c^-:o:iic^ 1 units.
Idating the uildhorot! priority over the wildii? s/livestock £rf,.aiRc is
ludierouae - the wildhcrss hrs COST the taKppyera - inste-d nf giveing FHvDS.
The livestock puts FEEDS baeta IMTO "^ "laSMt, G0V5KH?3£T, Lister the wild-
horse with - wildlife/livestock B,a directed in this draft - seems a severe
charge AGAT'iST the BIi-1 mission of 'Adopt a Horse Program' which h-s cost the
taxpayers millions of dollars - and the so called count in this draft is false
of the herd number of wildhorsas* Rflneveing livestock from streams, giving
priority to horses end wildlife is - inconsistent with federal Court decisions,
3.
of rights - wan founded with agriculture 'The backbone of the nation1, we era
a vitr.l rmrt in keeping the wheel Mowing for this nation of a grfiftt deficit to
remain a Free Nation Under God:.
We 'Thank You1 for a] lowing us - the livestock grazer producer end protector
of public lands to ba ft part - Of The Public input in this issue. We support the
Riddle Ranch/Western Hange Service/ Farm iiureau/Caitl ewoncn/stockgrowets orgrn-
is'tion letters and endorse there comment/find in rs
Harvey / Margaret Dunbar ■' ' }a*-c£U*
I'renchgl en, Oregon 97736 ;,\
b^C
./*S*-*
and Gtbova ■'
^ible also
face water
spinet Cods plan for b!j creatures - cr-ttle/sheep - are in the
Wej-.thsr conditions in Hrrnay County hpve t greet effect on the sur-
3 rinarian habitat conditions - the basis for the majority of the
adverce imprcts to the livestock grazing is unfounded and unreasonable. Fence-
ing off water reservoirs is a conflict with the BIE objective to disperse live-
stock away from rlpsriefi areas to improve forage utilization. Those waterholes
or reservoirs would not be there - if - it were not for the r.-nge improvement
of privp.ie eusd traprovesnent funds p«lfi 'or b;- ::-.-■ per itte . -:-d 'jrezi':; Zees.
V.ol only for the livestock, hut for the wildlife us well.
Different segments of the livestock industry is funding - r,he cost of public
land Improvements thru the pernits, fees, and w'-dch we til so sh-re in &» federal
tax structure of this nation. Along with the share of stflts %ex structure and the
private property tax. The majority of the 'special interest groups' do not share
in these costs, nor do thay have a (TEK&8 ^S) - yet Utimv usa tno pu.:.ic irJias
and undermine the livestock industry and the government agencies. We in the
livestock industry feel - we are partners in respect of public lands; because we
not only PAY over r_nd over, we work to improve these lands for the livestock and
the wildlife at OUR OWN SXF5NCE.
We know the habits of the wildlife, fowl and wiJ.dhorse - plong with knowledge
of v.he \m&a r;-£ wert:-.;r prttern. We : s iivsstoefc pro'jr.oe-s !I7'." WI..- .": $.,VJ .Z
YSAPi R0U3SB - our e^erience and as a majority - try - to be conpntlK s in nature
with the Si:: nmageir.ent, as compatible manfgers:::i We haV8 the ynofiir genera-
tion of all walks of life to produce food for, and, leave behind e 'Kope' for
the tomorrows of their future.
The Soviet Union economy and government without their people producers of food,
without priv-te urooerty living on the land - effected their whole nation pnd the
world. This SliOUTp tell us something. "Democracy, constitution)-], rights, the Mi;.
Refer to response 2-46.
Appendix 11-72
48
Mr. Jay Carlson - RMP/ET.S
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 97738
ar Mr
Carlson:
In beginning this letter I wish to go on record as supporting the
views and comments contained in the January 19, 1990 letter addressed to you
from the Harney County Stockgrowers Association.
Secondly, T wish to state that It is difficult for me to intelligently
comment further in that 1 found the Draft RHP/EIS documents very difficult
to follow. The presentation, which includes a text separated from the
booklet containing maps and tables is extremely confusing to read compre-
hensively. The continual referral to another source Index seems like some
kind of mind game. This kind of presentation to layman appears as an
attempt to befuddle and confuse. Thus; before any change for any reason is
imposed, a second presentation for comment should be made. This second
presentation should be condensed, logically sequential, and more compre-
hensive. It should be in a single text without cross reference. All
supporting or informative maps or tables should be contiguous with specific
text issues.
The presentation of pertinent information, for a comprehensive land
use plan which addresses over 1.7 million acres is a complex task.
The design of the Three Rivers Draft was to facilitate the reader's
ability to work through a specific section without flipping back and
forth (which has been a common complaint about large-sized single
volume documents). It is unfortunate that this format did not work
well for you. This Is not, however, sufficient reason to republish
the Draft. Should you require assistance In using either the Draft or
the Final, please contact the Burns District 0fflce4
Refer to response 2-63.
.-._-, I Thirdly, before any AUM reduction can he imposed,
| implications assessment" should be completed.
akings
Louis John Borellt
1580 Wooden Valley Road
Napa, CA 94558
mmh
49
Eastern Oregon Mining Ass
[O nonprofit »rp0rg1i«n)
March 3, 1990
P.O. Bo* V37 S03-523-32B5
Three Rivers Resource District
Attn: Craig Hanson, Area Manager
Burns Distric Office
Highway 20 West
Hines, Oregon 97738
No comment Identified.
RE:
rs Resource Management Plan
Dear Craig Hanson,
First I wish to thank you for the kindness of granting
us an additional 30 days for comment. We were still trying
to sort out your management plan when the comment period
ended .
Although I do want to object to you recommending more
river mileage as suitable for wild status and withdrawing
more acres from mineral entry.
I also want to object to your continued restrictive
designations of RNA/ACEC-ONA/ACEC and the rest of the ACEC's
listed under management objectives. Your designating
additional ACEC ■ s including extensions to existing ACEC's.
Way to much latitude given to Wildlife management under
0DFW and USFW department.
Mineral activity and g
indicates a potential for o
Uranium, and locatable or 1
Diatomite, Zeolite, Potassi
Sand and Gravel , Building S
^ logy reports in the area
1 and gas , geo thermal , coal ,
asable minerals as, Cinnabar,
m, Felspar, Obsidian, Cinder,
si minerals ,
including Obsidian, Thunder Eggs, Petrified Wood, and Agate.
No more land withdrawals, No Wild and Scenic, No
ACEC's. We have watched with concern the Forest lock up
public lands for perceived notions of ascetic values. The
Forest Districts are drifting away from Multiple Use,
locking up vast portions for no use by anyone. Congress has
set aside large tracts for such use. we must protest
vigorously the present trend in which the Forest seems to be
locking up public lands under one designation or another.
Sincerely
Roy Grissom
Charles (Chuck) Chase
Appendix 11-73
Jay, Carlson
Burns District Office
Bureau of Lend Managemen
I1C 74 12533 Highway 20
Mines, OR 97736
i©
REVIEW COMMENTS FOR THE AICTOBER 1939
BLM DRAFT THREE RIVEp^ RMP/EIS
Dear Mr. Carls
(If you are facing a reduction in AUM'b, please include the next tr.
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C will result in
property value. The proposed BLM actions
of our operation so that it is no longer a
we request that if Alternatives A, 8 or C
issuing the Final Three Rivers Resource Ma
Impact Statement, a 'Takings Impli
a substantial loss of our base
ay result in reducing the size
economical unit. Therefore,
re considered, that prior to
sgement Plan and Environmental
ompleted ,
uthorized by Executive Order 12G30 (see the November B, 1900 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel).
The reallocation
nd/or reductlo
797
Allotment will red\
property 6y approximately S ZOf.frttL. ■ (Assume S50 per AUM
Please consider this economic loss in the requested "Takings Impli
Assessment. "
AUM's livestock forage
the value of our base
lue).
The letters from the Harney County CottleWomen, Stockgrovers, Farm Bureau
Sheep S. Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with ou
views and comments-
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we may ha
supplemental to our principal respons
nolo
ed he
nd ore
50-1 Refer to response 2-63.
L/C 7 .
T
ja
'Zip Code
Signature
Enclosure: Supplemental Comments
m
H t*U4 , C Mt^^ 9 77i
The DRMP/DEIS Preferred Alternative Identified an Initial livestock
reduction of 11 percent. Reductions would be Implemented only after
the allotment monitoring and evaluation process has been completed.
See PRMP/FEIS, Appendix 1, Table 11 for methodology.
TL(^fj.AAr ~ffUs^-t<£.aAYvJ^ 2>
.V ^yiAjb^UjiJ AJM-OuAjJsA.A-4 ,
£i
Appendix 11-74
as
\ Northwest Mining Association
January 24, 1.990
Mr. Joshua L. Warburton
Burns District Office
HC-74-12533
Highway 20 W.
Hines, Oregon 97738
Dear Sir:
Thank you for sending us a copy of the draft Plan and ETS for
the Three Rivers area. in general , we are concerned that the
approach being taken to future management of this artia is one
that overall is multiple use, hut through special use of each
designated area. We appreciate thf- f»ot that you are trying to
meet a variety (often opposing) of public needs, but with
regards to minerals, the old adage holds true that absence of
evidence is not evidence of absence. We ask that you not place
administrative restrictions on mineral development such as no
surface occupancy, withdraw! , restr i cted . or prohibited
activities . Economic mineral deposits were formed long before
any land use
found. This is esse
from foreign sources
ineral deposi
epts and thus must be produced where they ar>
ssential to rural economies to our independent-
We agree with the adage "absence of evidence Is not evidence of
absence." FLPMA and acts such as the Endangered Species Act of 1973,
as amended, require administrative restrictions on mineral
exploration and development. Under Alternative C, mineral resource
development is administratively restricted or prohibited on less than
4 percent of the lands In the planning area.
The 17,136 acres identified for Diamond Craters ONA/ACEC in the
DRMP/DEIS Appendix 7, Table 1, should be 17,056 acres. This acreage
includes 16,656 acres currently under withdrawal and 400 acres
proposed for a new withdrawal. The 2,750 acres quoted in the
DRMP/DEIS Chapter 4-54 is the total acreage for all new withdrawals.
There was also a minor error in this figure as it should be 2,715
acres. A detailed breakdown of the proposed withdrawals can be found
in Table 2.29, PRMP/FEIS.
Also, there appears to be some confusion as to amount of land
proposed restricted or withdrawn from mineral development in
proposed ACEC areas. In Chapter 4, pg. 54, it is stated that
an additional 2,750 acres would be withdrawn from location under
Alternative C. However, in Appendix 7. Table 1, it appears that
17,136 acres would be withdrawn and 47,339 acres would be
restricted. Although this may be a simple mistake by those
compiling the documents , it is importanr. to the publi c that all
ramifications of the proposed plan be clearly stated.
Thank you for this opportunity to comment and we look forward to
reviewing the final documents.
Sincerely, J /
■■■■; ••- jr^^/Jh^—
LA. (Andy) Jotf
Mgr. Cov. Relat
l. II D1NO-SPOKANE.WA5HINI
s- ROGUE VALLEY %
AUDUBON SOCIETY/,
ortgon chapter tl oincnal auMan societ)
1/29/90
Manager, BIH Burns District Three Rivers Draft BMP 4 EIS
Obviously, much fine effort has been expended in preparing your drafts. However, we of
the Rogue Valley Audubon Chapter feel certain changes should be made in your plan? if our
society is to preserve this land in good condition for future generations*
Restoring and preserving rangeland, water quality, forests, and riparian and aquatic hab-
itats in excellent condition should be our goal in managing the public lands. Th-reforc,
alternative A should be preferred to C so that as much natural recovery to possible can
take place while plans are made for further needed improvements. This may require reduced
cattle numbers in many areas, but that is the price we pay for past negligence.
To protect our native plants and their habitats, introduction of exogenous species such
as crested wheatgrass should not be considered.
The public lands are not important cattle raising areas in the US, but they are important
j for the preservation of our dwindling wildlife. Therefore, top priority should be given
to wildlife in forage allocation, e.g. in bighorn sheep's natural range and in winter
| range for all wildlife.
I We have so little ancient forest left in the Northwest that any existing in your area
should be identified and protected.
I All the costs of new roads and other projects should be included under whatever alterna-
tives they are being considered, and their environmental impacts should be clearly assessed,
I Considering our disappearing supply of natural waterways and their accompanying native
plant and animal species, wo believe the entire length of each of the following should be
recommended for Wild and Scenic status: Bluebucket Creek, Silvies River, South Fork of
the Malheur River, and Middle Fork of the Malheur River except around Drewsey.
Thank you for your ^ood work, and please five more consideration to future generations
and their needs in your planning and management.
53-1 Refer to response 1-11.
53-2 Refer to response 2-6.
53-3 Refer to response 12-1.
53-4 Refer to responses 12-1 and 12-7.
53-5 Refer to response 3-6.
Sincerely,
Frank H. Hirst
Conservation Chair
6^5 Ratten Dr.
Ashland, Or. 97520
Appendix 11-75
^r
54
SW«z<i^ 3<ierfcl ^flamcA
V^
fjttjj) 493-2620
January 28, 1989
In general, the proposals contained in the Three Rivers Resource
Management Plan arc arbitrary, without scientific basis and frought
with the preachings of radical environmental ism and do not represent
! the mai nstream of society. In a recent study conducted by the
Wirthlin Group of "1,000 representative American adults" the
following opinions prevail :
"Seventy percent of consumers believe that cattle ranchers and
farmers take good care of land and water." "...it is in
producer's own interests to take proper care of their
resources . "
Jay Carlson, RMP/EXS
Burns District Office
Bureau of Land Management
HC 7 4-12533 Highway 20 West
Mines, OR 97738
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
"Almost sixty percent say cattle grazing is a good use or" public
rangelnnri." "...consumers believe that, beef production has no
negative impact, nn the environment and that efforts to save the
earth and our natural resources should focus on things that
really matter . "
"Nearly eighty percent say that private ownership ar
are better than government ownership of agricultural land
Lrol
The January 17, 1990 Riddle Ranch and Western Range Service
Comments and Response to the Draft Three Rivers Resource Management
Plan and Environmental Impact Statement are consistent with our views
and comments.
This response is our endorsement of such Riddle Ranch Document.
Their response has been submitted to you. We do not include a full
copy of the text only for the reason that it would be an exact
duplication of the Riddle Ranch document.
The following additional comments are supplemental to our
principal response and address issues of specific concern to us. In
conjunction to Riddle Ranch document, our comments will serve as
Wilber Brothers, Wright Wilber and Patrick Wilber's comments to the
"Draft Three Rivers Resource Management Plan and Environmental Impact
Statement" dated October 1989.
We reject the proposed "Pri vate Water Sources Selected for
Acquisition of Permanent Access (Listed in Priority "'der)"
identified in Appendix 4-2 containing more than 1,600 acres of land
owned by the parties principle to this document . We consider these
lands essential for the protection of our downstream storage and
rightfully adjudicated water rights. Acquisition of this property
through any means contrary to the interests of private ownership
fails the "health, safety and welfare" criteria of public takings and
clearly violates the property rights of the owners.
We reject the allocation of 1,148 Animal Unit Months to wildlife
id wild horses in Allotment 5532 referred to in Appendix 3-87. In
WILBER BROTH KRS
cc: Mark 0. Hatfield
Bob Packwood
Robert F. Smith
$ku @b*4«**~
PATRICK J. WILBER
he past ten years,
se, despite severe
tablized while elk
act, ten years ago ther
oncurrently, 1 ivestock
igher conception rates
razing has had an adver
llotment, it is virtual
ncreased simultaneously
s a fundamental inequjt
he allotment to wildlif
ildlife AUM's provided
djustment is provided,
opulations will increas
rivat.e lands and likely
ontinuous baas s .
r the current management plan
her related stress, deer popu
antelope numbers have actual 1
■ere virtually no elk in th
production has improved with
and calf weaning weights. If
mpact on wildlife populat
ly inexplicable how their pop
with enhanced livestock prod
in increasing the allocatio
given the already substanti
iv private lands for which no
With the proposed allocation
dramatically, further encro
requiring suppl omental feed
of multipl
lations hav
y increased
e al
o tment
sign
f icant
livestock
ions
in the
ulat
ons ha
uction. Th
n of
AUM's
al mi
mber o
AUM
allocs
plan, wild
We reject the allocation of forage in Allotment 55 32 referred to
in Appendix 3-87 giving priority to wild horses, in as much as the
natural characteristics of the allotment are unsatisfactory for the
present allocation of AUM's. Allotment 5532 is a "high mountain"
range subject to heavy winter snow and late forage development in
spring. Consequently, in winter and spring, horses are concentrated
in lower ranges where they severely overgraze the prior years
aftermath and virtually kill off the fragile young grasses of the new
Refer to response 4-14.
Because the elk populations have increased, forage must be allocated
to them to prevent over use of forage. The horse allocation has not
changed. Refer also to response 2-6.
Refer to responses 2-10 and 2-11.
Refer to response 2-6.
The carrying capacity for Allotment No. 5532 was calculated using the
methodology shown in Appendix 1, Table 11. Also, reference response
2-61 relative to the economic Impacts of the proposed action.
The Agricultural Credit Act of 1987 is limited in its intent "to
providing credit assistance to farmers by strengthening the farm
credit supply system and facilitating the establishment of secondary
markets for agricultural loans." The act does not address the
management of public lands. Potential reductions in authorized
livestock grazing levels based on sustained yield capacity or
resource tradeoffs, authorized under the FLPMA, would not contradict
the Agricultural Credit Act. Both public and private suppliers of
farm credit should be aware that Federal livestock grazing permit and
license levels are subject to adjustment and should not be used as a
long-term basis for farm or ranch credit.
We reject the reduction of AUM's allocated to livestock grazing
in Allotment 5532 and assert that the proposal will have a
substantial negative impact on the ability of the principles to this
document to continue operating as a viable economic entity. In
January 1989, Wilber Brothers acquired private ranch property with an
active preference of 1,359 AUM' s (64 3 suspended ) in the allotment.
An additional 2,118 AUM's of active preference (834 suspended) in
Allotment 5 5 32 makeup the economic uni t. Financing for the private
property acquisition was arranged through Farm Credit Services on the
basis of continuing util ization of the existing preference. The
reduction in live stock grazing AUM' s proposed for All o tment 5532 in
the Three Rivers Resource Management. Plan would cause a loss in
revenue from livestock sales of approximately 580,000 per- year. Such
a reduction in the active preference would virtually ensure a
default on Wilber Brothers' loan obligation.
The "Agricultural Credit Act of 1987" had among its principal
purposes the reorganization of the Farm Credit System permitting the
institution to provide credit to farmers, ranchers and cooperatives
at reasonable and competitive rates. Of course, when defaults occur,
the ability of Farm Credit Services to provide credit at reasonable
and competi ti ve rates is essentially eliminated . The proposals
contained in the Three Rivers Resource Management Plan are in direct
conflict with the intent of the "Agricultural Credit Act of 1987" and
put the Department of Interior at odds with the Congress and the
President .
The various alternatives have been developed with full public
participation. Specific sections are documented, where appropriate,
as to the scientific basis for the prescribed actions. The management
prescriptions conform to regulation and policy.
Appendix 11-76
55
Jay Carlson
3urns district Office
Bureau of Land Management
HC 74-12533 Highway 21 tjftSt
Hines Oregon
Review Comments for the October
BLM .-'raft Thre^ Rivers RMP/EIS
Dear Mr. Carlson:
I have carefully read a copy of the letter addressed to you from
Mark S. Doverspike , Frcidcnt of the H. trney bounty Stockgrower "■
Association.
County, and upon retirement from the cattle business , served two
terms as Harney County Judge, I wish to go on record ae fully
agreeing with Mr. Dovers;;ike' s concerns. Any drastic cut in cattle
numbers in Harney County would be real detrimental and far reaching
to the County at large.
■frnwjL
ivt -n Hotehki
)%
55 No comment identified.
C"i
K-ilfre $k\ (Jew ens
ex
"31^:
JLVJt^jrrtvs^
56-1 Refer to response 2-61 and 2-62.
Appendix 11-77
Drewsey, Drego:
January 2A, 1990
§7
Refer to response 2-63.
Jay Carlson
Burns District Office
Bureau of Land Management:
HC 74 12533 Highway 20 West
Hines, OB 97738
Dear Mr. Carlsons
In reference to the October 1989 BLM Draft Three Rivers RMP/E1S, we wish
to voice our objection to alternatives A, B and C which will result in a
substantial loss of base property value to ranches. The nroposed BLM
ftftCtonfl may rpsult in reducing the size of an op°r=tion so that it is no
longer an economical unit. We request that if alternatives A,B andC are
considered, that prior to issuing the Final Three River's Resource Manage-
ment Statement , a 'Taking Implication Assessment * be completed as aut hor-
i?ed bv Executive Order 12630.
It is alarming for us to observe what is happening on our federal lands.
Our ranch has been in operation and in the same family for 100 years.
We care for and about all of our land^private and federal. This land is
as vital to our operation as our deeded land. Surely the federal lands
are more protected today than ever before in the history of our country.
To cut numbers in the rattle run on federal lands is no longer feasible.
The next step is to move the farmer and the rancher off the land and in-
to the city. This has happened in other countries and today their people
are hungry. They no longer have farmers to go back on the land. The
United States is the food basket of the world. We are all aware of the
Starving people around us. We must find a way we can work together
rather than bring on an economic disaster.
The letters from the Harney County CattleWomen, StockgrowerS , Farm Bureau,
Sheep and Woolerowers and the January 17, 1990 Riddle Ranch and Western
Ranee Service Comments and Response to the draft Three River's Resource
Management Plan and Environmental Impact Statement are consistent with
our views and comments.
sponse is our endorsement of such
Their response has been submitted
letters and Riddle Ranch docu-
Si
*iy*.
Howard Ranch
Box 266
Drewsey, OR 97904
.58
January 24 , 1990
Refer to response 2-63.
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hines, OR 97738
Dear Mr. Carlson:
Alternatives A, B and C will result in a substantial loss of our
base property value. The proposed BLM actions may result in a substan-
tial loss of our base property value. The propped BLM actions may result
in reducing the size of our operation so that it is no longer an economic-
al unit. Therefore, we request that if Alternatives A, B or C are con-
sidered, that prior to issuing the Final Three Rivers Resourse Management
Plan and Environmental Impact Statement, a 'Takings Implication Assess-
ment* be completed as authorized by Executive Order 12630.
The letters from the Harney County CattleWomen, StockgrowerS, Farm
Bureau, Sheep and Woolgrovers and the January 17, 1990 Riddle Ranch and
Western Range Service Comments and Response to the Draft Three Rivers Re-
sourse Management Plan and Environmental Impact Statement are consistant
with our views and comments.
This response is our endorsement of such tetters and Riddle Ranch
document. Their response has been Submitted to vou.
Any additional comments we may have are enclosed herein and are sup-
plemental to our princinal response.
The members involved in Va_n Grazing Coop have individually received
substantial cut in cattle numbers on their allotments. Our operation
will not tolerate further cuts.
Sincerely,
Van Grazing Coop
^7-JiriA^U' £ • rh-w-'&JidL^
Appendix 11-78
January 17, 15
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Mines, OR 97738
Refer to response 2-63.
REVIEW COMMENTS FOR THE OCTOBER 1939
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson:
(If you are facing a reduction in AUM's, please include the next tvo
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
we request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a 'Takings Implication Assessment' be completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel ) .
and/or reduction of
M-
The reallocatiqi
in {{U.<^r l/tfgpn TL&U Allotment will reduce the value
property by approximately $ ■3-Lr,£f^)
economic loss in
AUM's livestock forage
ur base
(Assume 050 per AUM value),
the requested "Takings Implication
PI ease consi der thi s
Assessment. *
The letters from the Harney County CattleWomen, Stockgrovers, Farm Bureau,
Sheep & Woolgrawers end the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we may have are
supplemental to our principal response.
closed herein and are
Address
rfffS
Dm
QZ23Z
L
Signature 7
Enclosure: Supplemental Comments
,/i\^^y'
60
Refer to response 13-1, which notes the current status of the
Bureau's recommendations for wilderness. Congress will decide which
areas will be designated wilderness after review of all
recommendations, including those other than the Bureau.
Jay Carlson, RMP-EIS
Burns District Office
Bureau of Land Management
HC 74 - 12533 HWY 20 West:
Hines, Oregon 97738
The letters from the Harney County Cattlewomen, Stcckgrowers , Farm Bureau
Sheep & Hoolgrowers and the January 17, 1990 Riddle Ranch and Western Range
Services comments and response to the Draft Three Rivers Resource Management
plan and environmental impact statement are consistent with our views and
comments .
This response is our endorsement of such letters and Riddle Ranch
document . Their response has been submitted to you. We do not include a full
copy of the text, only for the reason that it would be an exact duplication of
the Riddle Ranch document and organizations letter.
My expression of observation comes as a result of being a permittee of BLM
for 24 years, a member of the Burns District advisory board for over 12 years,
including tours and study trips as a result of being a member of Chat board.
After listening
feel very strongly th.
Wilderness.
and reading comme
ts regarding the
The BLM is on course in its management program. Any area that I
personally saw is in a state of improvement over the past 24 years and with
continued cooperation between the service and permittees I see no reason for
changing from the concept of multiple use.
It has been my experience from immediate obser
the Malheur wildlife Refuge, any field that was put
severe degradation of vegetation cover with loss of
/^cont
Lnued
regula
My f
that
non-use
rfould
ax peri
n, particularil
by wildlife to
the fields immediately adja
Idlife productivity.
whether it be Wildlife Refuge or BLM,
ame degradation. And any Wilderness ,
Sincerely,
Ho -7* ''-"'i^
Appendix 11-79
SI
61-1 Refer to responses 2-1 through 2-96 relative to comments submitted by
Riddle Ranch which you endorse.
<2f #f3-JL£Z3
a^-
473 -2s3 £
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Bines, OR 97738
62
REVIEW COMMENTS FOR TBE OCTOBER 1939
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carleont
No comment Identified.
(If you are facing a reduction In AUM'b, please Include the next two
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C will result in a substantial loss of our base
property valve. The proposed BLM actions may result In reducing the size
of our operation so that it is no longer an economical unit. Therefore,
we request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a 'Takings Implication Assessment' he completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Model).
The reallocation and/or reduction of
Allotment will reouce th:
AUM's livestock forage
property by approximately $_
(Assume §50 per AUM valu
Please consider this economic loss in t,he requested 'Takings Implication
Assessment. "
The letters from the Harney County Catt\LeWomen, Stockgrowers, Farm Bureau,
Sheep £ Wool growers and the January 1 7, 19S0 Riddle Ranch and Western
Range Service Comments and Response to ithe Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response Is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we may have are enclosed herein and are
supplemental to our principal response.
9 ZZA /
Signature
Enclosure: Supplemental Comments
0^-z- £s^4 *S<£i4ti.
Appendix 11-80
63
January 26, 1990
District Manager
Bureau of Land Management
Burns District Office
HC 74-12533 Hiway 20 West
Hines, OR 97738
RE: DRAFT THREE RIVERS EIS/RMP
Dear BLM Manager,
I have reviewed the Draft EIS for the northern portion of the
Burns district and I am very disturbed to see the alternative
written by the ranchers as the recommended alternative. Wel-
fare cattle ranching has caused serious deterioration throughout
the area. So has poor forestry practices such as logging of
ever smaller trees, virtual clear-cutting and the abysmal fail-
ure to protect old-growth.
In the short term BLM, to fulfill its responsibilities under
the Federal Land Policy and Management Act (PL 94-979) , the
Public Rangeland Improvement Act (PL 95-514), should adopt Al-
ternative A. This would prevent further destruction of the
desert and forest by logging and ranching interests while a
plan is developed to restore rangeland to its natural condi-
tion.
It is the responsibility of the BLM to protect natural diversity,
not to pander to local interests. There is a national interest
in the protection of the biosphere, particularly where it is
most fragile. Economic interests should only be allowed to the
extent that they do not degrade the environment. Clearly ranching
has substantially degraded both rangeland and forests in northern
Harney County and to continue with these practices is a violation
of BLM's duties.
As a frequent vistor to the ochoco and Malheur National Forests
and the surrounding desert I am appalled at the way the USFS and
the BLM allow the artifacts of cattle ranching and logging — from
riparian destruction and garbage to generalized degradation of
habitat — to occur. It should not only be stopped but reversed.
At a minimum BLM should:
63-1 I !) Adopt Alternative A as the preferred Alternative in the
interim.
,, , I 2) In conjunction with the USFS identify and protect all old-
I growth forests in the region.
63-1 Refer to response 12-4.
63-2 Refer to response 12-1.
63-3 Refer no response 2-44.
63-4 Refer to responses 1-13, 11-10 and 13-11.
63-5 Refer to response 1-13.
63-6 Refer to response 2-6 and 2-78.
63-7 Refer to response 3-6.
3) Protect water quality by protecting riparian habitat.
4) End subsidies for cattle ranching, including wells, roads
and fencing. These are inappropriate tax-payer supports for
the production of a dubious product with significant health
hazards.
5) Develop a plan for restoring the rangeland to excellect con-
dition.
6) Provide priority for the welfare ofindigenous species over
cattle, meaning adequate lands designated for habitat protec-
tion for big horn sheep and other large mammals, including
priority in winter forage allocations.
7) Designate the following for inclusion as wild and Scenic Rivers:
the Silvies River (entire) , South Fork and Middle Fork of the
of the Malheur River (entire) , and Bluebucket Creek (entire) .
I look forward to seeing a vastly improved Final EIS/RMP that re-
flect BLM's legal mandate to protect natural diversity.
very Truly Y
^'
David M J oh
2747 NE 18th
Portland, OR
Senator Mark Hatfield
Senator Bob Packwood
Representative Ron Wyden
Representative Les AuCoin
Representative Peter DeFazio
Appendix 11-81
Jsy Carlson
Burns District Office
Buroeu of Lend Management
HC 74 - 12533 Bwy 20 West
Hines, Or 97738
Refer to response 2-61, 2-62 (economic impacts) and 2-63 (TIAs).
REVIEW COMMENTS FOR THE OCTOBER 1989
BLH DRAFT THREE RIVERS RMp/SIS
Dei
Mr. Carlson:
Implementation of Alternatives A, B, or C would have a negative affect
on the entire livestock industry in Harney County, drastically reducing
base property values, cutting carrying capacities and creating a ripple
effect that could be fatal to the economy of the entire county. It
oould jeopardise the very survival of Harney County. Before considering
Alternatives A. B, or C we strongly urge that prior to issuing the Final
Three Rivers Resource Management Finn ar,.i £nvi ronmar.tal Impact Statement,
a "Takings Implication Assessment" be complatfid as authorised by Execu-
tive Order 12630 (sec November 8, 1988 Memorandum to all Assistant Secre-
taries and Bureau Directors from Secretary of Interior, Donald P. Hodel.)
We endorse and concur with comments contained in letters to you from the
Harney County Cattlewomen, Stockgrowers , Farm Buroau, Sheep * Woolprowers
and tne January 17, 1990 Riddle Ranch and Western Range Service Comments
and Response to the Draft Three Rivers Resource Management Plan end Environ-
mental Impact Statement. This letter constitutes our endorsement of
th06e letters end documents, which have been submitted to you.
We urge you to seriously consider all correspondence reooived by you from
livestock parmittees and conoerned eitinena regarding elternative resource
management plans. In our opinion. Alternative D is the only plan that
could be successfully implemented to best serve multiple use principles
and not cause severe hardships, particularly on the livestock industry in
Harney County.
Please sec enclosed letter containing our
pur permit on Allotment 7013 (Zoglmann.)
lommants
Thank y
and concerns regarding
Mike and Betty Morgan
Star ffla. 2; 13683 Hwy 20
Burns, Or 97720
65
Jay Carlson - RMP/SIS
Burns District Office
Bureau of Land Management
HC 74 - 12533 Hwy 20 West
Hines, Or 97738
Re: Allotment 7013 (Zoglmann)
REVIEW COMMENTS FOR THE OCTOBER 1989
3LU DRAFT THREE RIVERS RMP/EIS
The area cited has been thinned in the past. In response to this
comment, BLM personnel have conducted a site examination of thr
and have included the timber in the RA sale plan. See PRMP/FF
Table 2.3.
Dec
Mr. Carle.
It states in Volume II-Appendicios that no forage has been allocated for elk
uee end management objective is to allocate forage to meet elk forage demands.
If twelve heed of elk were seen on thie allotment, it had to be an isolated
incident. We have spent countless deys over the years in this eroa, and it
has been our observation that this is primarily a migratory path between Snow
Mountain and Dry Mountain; the elk do not stay there. We have used the allot-
ment since 1963 when we bought property from Gus Zoglmann, including the 1600
deeded {'other*) acres within the allotment. Before that wo assisted Mr.
Zoglmanr. with his cattle, fence maintenance, etc.
In all the years we have had the Zoglmann proDerty we have worked continuous-
ly to improve our own lend with brush fcnd timber thinning, seeding, additional
water development, etc At the same time we have practiced responsible stew-
ardship with the federal property. Forage has been increased significantly.
By contrast, the Bureau of Land Management has done 0KB project . About twenty
years ago they did some tree thinning and it was a sub-standard job'. The
slash wasn't piled but left strewn where it was cut, and the mess is still evi-
dent. The steumos wera muoh higher than the six inches maximum mandated by
forest practice's code, and the thinned areas weren't ro-seeded. In addition,
not nearly as much thinning was done as should havo been.
The timber on the public-owned acres on this allotment is badly in need of
attention, and pine beetles are becoming increasingly evident. Even though
we have thinned and done eomo logging in our timber in efforts to stop the
problem our efforts are being undermined by lack of attention to the BLM
timber adjoining ours. We contacted BLM! forest porsonel in Prineville about
our concerns and were told they would look into it and get back to us, but
we hove hoard nothing from them. All the thinning and logging done by us has
been under direct supervision of the Oregon State Department of Forestry.
Other then thinning, the BLM hes done absolutely nothing to improve this allot-
ment, nor have they shared any of the costs of work that hes been done. A
fencing, water development, seeding,
i done and paid for by i
Mr. So elm
before I
We would seriously oppose cuts in our AUM's to provide forage for oik. There
is always mora than ample forage in excess of what our cattle use to far more
than meet wildlife demands. Good otewardship is responsible for thii.
Yoj
m*5^-
Hike end Batt£ Morgan
Star Rt. 2: 13683 Hicy 20
Burns, Or 97720
Appendix 11-82
/7-U -C GU, C* U-1.0-W.
^. e,/^,,7v-/a i j> //„,. J&
MUl.A.tJL .-■*.<_ <-tf:t/ncy Ce^H^Mjt e-*~jdL
°j /7'Vl"'> <*"**** f'^^ f^fcMtjftiu.^ J2.
-1/lx<^« ^ fitellutJi. ;■■,■> ,,,-c /'fM-^J^,,.
/} -■
.Z^-^- -yt^u^to «<^'i ^/UyeSu. jL^t-KtnvZ^ '
aa^u^xL^ w«a.j«,!( -^-^^v,^
.•{At <!*<-<---* \6'%*j^N*^uL&\sddMell 1-1^- 90,
^IAiA-U^HA. UA*.*. JJ C\* -^4 l^'j •KuJ. _^K&j( e-)3M£\ -
^u5^ j6 -,, >€ -*-^w s^ ^- '
Refer to responses 13-1 and 60-1.
There will be no relocation of existing authorized rights-of-way
under the Proposed Plan. Only occasionally would proposed projects be
relocated or rerouted due to the designation of special management
areas. As stated in Chapter 4-66, DRMP/DEIS, conflicts from the
designation of special management areas on right-of-way development
is expected to be limited for several reasons. First, most of the
areas proposed for special designations are in Isolated areas where
right-of-way demand is low. Second, most of the areas proposed for
special designations would be considered avoidance areas where
necessary right-of-way projects, if compatible with the purposes of
the designation, could proceed with some restrictions but short of
complete relocation. Third, a potential right-of-way applicant would
know early In the project planning process, what areas to avoid so
that the economic impact of an unexpected reroute could be reduced or
eliminated.
January 29, 1990
67
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74- 12553 Highway 20 West
Hines, Oregon 97738
Dear Mr. Carlson:
I do not agree with the Three Rivers Resource Management plan to wit:
Allotment # 7060.
67-1 ^* states their are 751 public acres in this allotment and says nothing
of the approximately 1902 acres of private lands that this 751 seres
are included within the perimeter of these fenced private lands. This
allot if 7050 should be designated FFR due to the fact that public
lands are scattered throughout. Their are Tpproxiicately 3 times the
amount of private lands to the public lands in this allotment tf- 7060.
II request a permanent right to the use of these public lands fenced
67 I within this allotment # 7060. These public lands are accessible
| mostly by crossing private lands or the use of aircraft.
Their is no water for deer only from private sources, I've not observed
any deer in the winter time on these public lands. Only on private
lands at lower elevations.
67-3 1 In table 1 appendix 3-5 its states that investor not willing to invest.
I This is wrong. I would like to purchase part of these public acres or
I work out an agreement that is satisfactory to all.
In the past I have been issued a permit for 6 head of cattle in the
amount of 38 to 4-4- AUM on a Fenced Federal Range basis. I have spent
money and time to be in compliance with this Fencec Federal Range basis.
On January 27, 1990 I received a notice from BLM office intending to
impound livestock if founa on public lands chat are within this stated
allotment £ 7060. In the years past I have not received a certified
letter with a return receiot from BLM office in regards to trespass.
I've not received any warning from BLM office nor to ay knowledge have
I hac =nimalr3 "respass upon public lanus.
A solution needs to be found immeaiatly if not sooner.
There are numerous fences in the vicinity of the public lands
considered Allotment No. 7060. This allotment is considered custodial
due to the large amounts of private land intermingled with scattered
public land. (Custodial means there Is minimal management activity.)
By regulation (43 CFR 4130.2c), the Bureau does not issue permanent
grazing rights to public lands, but rather 10-year permits which must
be renewed. The lands in No. 7060 are leased on an annual, temporary,
nonrenewable basis.
Willingness to invest Is based on a "prudent man" test to Invest in
improvement. Willingness to purchase public lands is not part of the
criteria.
The impound notice you received is a notice sent annually to ail
grazing permittees. Its intent is to notify permittees of the
consequences of unauthorized livestock use and also to define the
impound area.
Respectively
^^
Vernon L. Seaman
1325 Hwy 205 HC 71
Burns, Oregon 97720
c.C. J ".sua L. Warburton
Appendix 11-83
January 17, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Nines, OR 97738
68
ent identified.
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carl
that prior to
issuing the Final Three Rivers Resource Management Plan a'nd Environmental
Impact Statement, a 'Takings Implication Assessment" be completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel ) .
The letters from the Harney County CattleWomen, Stockgrovers, Farm Bureau,
Sheep & Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent trith our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that
duplication of the Riddle Ranch docume.
uld be an exact
nd organizations letters.
Any additional comments we may have are enclosed herein and are
supplemental to our principal response.
Sincerely,
V £& A)n j i L. S' IF A A-l ti a J .
e>^?^- M~„ tfes- ,//c -7/
£
Urj">
Cs're*n „j
/ State
^77^
,:■,■(■
Uz
<f — i -*Y\ ^
Signature
Enclosure: Supplemental Comments
69
P.O, Box 712
Placitas, NM 87043
25 January 1990
69-1 ReEer to response 2-6.
69-2 Refer to response 1-11.
District Manager
Bureau of Land Management
HC-7412533 Hwy 20 West
Hines, OR 97738
Dear District Manager:
I recently received notice of the availability of a draft Environmental Impact
Statement (HIS) on management of the Three Rivers Resource Area. A summary of
the draft was also included. The purpose of this letter is to request 1) a copy of the
full document; and 2) an extension of the public comment period to provide my group
with an opportunity to review the document. Two weeks from date of receipt would
be adequate. If you cannot honor my request, please consider the follow as my
official comments.
The summary indicated that the Bureau is proposing to continue destructive Brazing
practices on range that is mostly in "fair" to "poor" condition. The intent of the
Taylor Grazing Act was to improve range that had been destroyed by a combination
of severe overgrazing and drought. What has been accomplished in the fifty-five (55!)
years since is appalling. When is the BLM going to quit serving as pawns of the
livestock industry and start carrying out its reponsibilities in a professional manner?
According to the information I received, you propose allotting 97% of the forage to
cattle and only 3% to wildlife. What economic justification do you have for this split?
What is the total cost to U.S. taxpayers of your grazing program? What potential
revenues would be available if the land were managed for wildlife? In New Mexico,
we have had a pilot habitat improvement stamp (Sykes Act) for three years. The
program is going statewide in 1991. In the area covered by the pilot program, six
times as much money was collected from hunters as was collected in grazing fees.
Finally, your preferred alternative calls for planting 76,960 acres of crested
wheatgrass. Such destruction of native vegetation and of the biological diversity
represented by native vegetation should be a crime.
Thank you for your consideration, I look forward to seeing the draft ElS. I trust it is
not as bad as represented.
Jim Fish, Founder
Public Lands Action Net\
Appendix 11-84
) Q
Jay Eric Jones
1*310 Maple-ton Drive
West Linn, OR 97065
January 27, 1990
70-1 Refer to response 1-13.
70-2 Refer to responses 1-13, 2-10, 2-11 and 2-49.
70-3 Refer to responses 2-6, 2-12 and 2-78.
70-1 I
70-2 I
70-3 |
70-4 I
District Manager
Bureau of Land Management
HC 7U-12533 Hwy 20 West
Kines, OK 97738
1 am responding to the Threw Kivers RMP & EIS (draft).
As developed, I currently support Alternative a, which
provides the maximum protection of the ecosystem in the
region.
The following are specific comments for your consideration:
— I notice that the Preferred Alternative C (Table h.6) docs
not address rangeland returning to an excellent condition.
It is my contention that an alternative that would return
at least a part of the planning area to"excellent"needs
consideration. Grazing, under law, must be currently
allowed, but a majority of the land need not be grazed.
Also, reduction or elimination of current grazing is
appropriate where conditions are fair or poor.
— Wildlife habitat and allocations must be given priority,
over grazing. An example would be bighorn sheep.
— Uld-growth stands neea identification ana protection from
Refer to response 12-1.
Refer to response 2-44.
See Appendix 1, Table 13. Also, refer to response 12-1.
Refer to response 3-6.
Refer to response 15-16, which notes ACEC designation of public lands
to provide protection of special natural features, as well as Table
3.16 of Volume I and Table 1, Appendix 7 of the DRMP/DEIS. The first
table gives an assessment of the relevance and importance of the
features within potential or existing ACECe and the recommendations
of the interdisciplinary team. Hatt Butte, Squaw Lake and Saddle
Butte do not meet ACEC criteria. Also, refer to responses 1-26 and
15-16 (ACECs), 2-68 (Kiger Mtn.) 15-36 (Obsidian Cultural).
70-5
itiparian and water environments must be improved to the
best possible condition. Grazing should be reaucno. or
eliminated in some areas to achieve this goal.
All of the costs for new roads that benefit primarily
resource users should be incurred in full (or nearly so)
by those users,, The costs of rangeland improvements that
are designed to maintain or increase cattle grazing (thoso
not strictly for environment improvements) should be paid
in full (or nearly so) by those users. Public subsidizing
of private for-profit users must be eventually eliminated.
Reductions, therefore, are appropriate.
I' age 2
Oraft Three Rivers RMP & BIS
Jay Brie Jones comments
— Wild & Scenic '"status for all, appropriate sections of rivers
within trie planning area should be considered/implemented.
— ACECs protection should be continued and, where appropriate,
tightened. Potential ACECs should immediately be made ACECs.
Some examples include Hatt Butte for its ungrazed ponds atop
the butte, Obsidian Cultural for its rare obsidian values,
Saddle Butte for its threatened grasses, Squaw Lake for its
location in the Steens area and use by wild horses, and
Kiger Mustang Wild Morse for these unique herds.
Please let me know of any relevant information concerning the
draft and advise me of your final decision in this matter.
Thank you for your time and consideration.
Cordially,
> a
k, F-vO
Appendix 11-85
71
Refer to responses 12-1 (ancient forests and logging road
construction), and 1-13, 2-6 and 2-10 (forage allocations).
Refer to response 3-6.
January 25, 1990
District Manager
Bureau of Land Management
HC-7412533, Hwy 20 West
Hines, OR 97738
Dear District Manager,
The Resource Management Plan for the northern half of Burns
District of the BLM is pure ecological destruction. Most of
the rangeland , riparian and aquatic habitats are already
in fair to poor condition, but all alternatives (particularly
Alternative C) will further the demise. Alternative C is
also expensive to taxpayers.
The alternatives do not address protection of remaining forest
lands, logging roads expected to construct, and bighorn sheep
habitat protection. Also, there is an imbalance of forage
allocation--only 3% to deer and elk and 97% to cattle.
Returning all lands and water quality to excellent condition
should be the goal. The only alternative that comes close to
this is alternative A, but even this alternative does not al-
low for full land and stream recovery. Wild and Scenic River
designation should be made for the South Pork and Middle Fork
Malheur Rivers, Bluebucket Creek, and Silvies River to ensure
that water quality is maintained.
Sincerely ,
Lois Read
10 Polonius
Lake Oswego, OR 97035
72
District rianaeer 24 January 1990
Bureau of Lena Management
HC-7412533 Mwy 20 Uest
Hines, OR 977J3
re. Draft Three Rivera RMP and EIS
1 have had opportunity to examine the Three Rivers Draft
EIS/RMP recently released. I have several concerns. First,
I propose a new alternative (or significant alteration of
Alternative A) to address, some badly neglected issues.
Secondly, I will register my cnneern with th.- "Preferred"
(Costly row) Alternative C.
I Alternative C or oposes projects including 143 miles of
fence, 86 miles of pipeline, 50 troughs, 91 reservoirs and
76,960 acres of (habitat sterile} crested wheatyrass
seeding. I request that the estimated costs of the**
projects be addr eased in the various alternatives.
■ Seeding of crested wheatgrass causes irreversible
I deterioration of natural habitat, is costly and should be
abandoned on public lands. It is unacceptable for any of
the alternatives.
Thankyou for this opportunity for input regarding the RMP
for the Three Rivers area.
*1 As noted in the document, nearly all rangeland is- in
"fair" or "poor" condition. No alternative presented
addresses optimization of ecological condition. I would
propose a new alternative with specific emphasis on
ecological integrity — lets call it the "Optimized Ecological
Condition" alternative. Under this alternative should be
the long term goal of returning and maintaining most or all
rangeland In good to excellent (late serai to climax)
ecological condition.
tt2 As noted in the document, nearly all uster quality is in
"fair" to "poor" condition. Alt. A addresses the problem
quite well, but the long term goal should be to return and
maintain most water in "excellent" (rather than just "good")
condition. This again may require a new "Optimized
Ecological Condition" alternative. Alternative C takes a
step in the right direction towards improved water quality,
but does not, in my opinion go far enough and may not meet
s for water quality.
DEQ requireme
Hi I can find no mention made in the document regarding
Ancient Forest habitat . I request that all Ancient Forest
stands be identified and an alternative developed to protect
It. Management e>i< *];] other forest lands if\ such m w«>> as
to optimise ecological condition should bs addr#sa*d as
well. I cannot find In the document: how many miles of
logging roads are expected to be built under the various
alternatives, and what Lhe expected costs will be. Please
include this information in the EIS. An "Optimized
Ecological Condition" alternative would discourage the
building of any new logging roads.
tta Optimization of ecological habitat for Bighorn Sheep and
other native wildlife should be addressed under the proposed
n-yw alternative. 1 cannot find a discussion of impacts on
Bighorn sheep in any of the alternatives and I request this
be done.
1
io r/ille
Cra
P.O. Bo
Bend
6376
977D8
72-1 Refer to response 1-13.
72-2 Refer to responses 6-4 and 13-7.
72-3 Refer to response 12-1.
72-4 Refer to response 12-1.
72-5 Refer to response 2-78.
72-6 Refer to response 12-7,
72-7 Refer to response 1-11.
Appendix 11-86
a
73
Oregon Trout
P.O. Box 19540 • Portland, Oregon • 97219 • (503) 246-7870
Oistrict Hanager
Bureau of Land Management
HC-741Z533 Hwy 80 west
Hines, OR 37738
<kuko
73-1 The environmental consequences of the Proposed Plan concludes that
dramatic improvement of riparian will result from implementation of
the Proposed Plan. Also, see response 13-7.
73-2 Refer to response 3-6.
73-3 Refer to response 2-6.
73-4 During the planning process and interagency coordination with ODFW,
no management actions were identified for improvement of chukar
habitat and none of the proposed actions were determined to have a
detrimental effect on chukar.
73-5 Refer to response 2-78.
Dear Distr ict ririnayer ,
These are comment* to the draft EIS and Three Rivers management Plan,
One oF the areas of our concern are your management of the riparian
zones. Currently mast zones are in fair to poor condition. Under your
preferred alternative, it is concluded that there mill be little
change, uie of course Feel that all riparian zones should be managed at
an "excellent" level. The benefits uould be numerous, not the least of
which are better fisheries, more wildlife and improved water quantity
and quality .
We also Feel "Wild and Scenic River" designations are deserving oF the
South and Middle Fork oF the Malheur River and all oF Bluebucket Creek
and Silvies River. IF they do not qualiFy as per your standards, I
should like to know why not.
I also have concerns outside my area of expertise but T will share
them none-the-less .
Winter range is oFten the limiting Factor for big game. It should be
beLter managed. Rangelands jn general are managed in mostly fair tD
poor condition*. This should be unacceptable on public lands "hat are
73-3 1 E~~ ■-ultipiB use. Too high an allocation For cbttle end loo Lttlu for
| wildlife ere apparent.
73-4 | Little mention LS made oF your management; strategies For chucksr .
73-5 I ^ specific plan should accompany the management oF bighorn Sheep.
Craig Li
Central Oregon Director
57 Pinecrest Ct .
Bend, OR 97701
74
25 January, 1990
District Manager
Bureau of Land Management
HC-7412533Hwy 20 West
Hines, OR 97738
Sir:
I have read with interest the draft Environmental Impact Statement for
the northern half of the Burns District. I was concerned to learn that
Alternative C was the Bureau's "preferred" alternative. In my opinion, this
alternative leans much too dramatically in favor of cattle interests at the
expense of all other issues. Deer and elk receive only token forage
allocation with the vast majority being reserved for cattle. Wildlife
winter range forage allocations should take priority over livestock
allocations. In addition, virtually no consideration is given to bighorn
sheep habitat protection.
74-1 Refer to response 2-6.
74-2 Refer to response 1-13.
74-3 Refer to response 1-11 and 1-13.
74-4 Refer to response 3-6 (wild and scenic rivers) and 13-7 (riparian and
aquatic habitat).
74-5 This document is not designed to address the impacts of logging on a
regional nor a site-specific basis. Site-specific environmental
effects are fully evaluated in the environmental analysis process as
required by the NEPA of 1969, Public Law 91-190. Also, refer to
Chapter 3 and Chapter 4 of the PRMP/FEIS for a discussion of economic
impac ts .
Regarding ancient forest, refer to response 12-1.
Because so much of the range is in only "fair" to "poor" condition, I believe
it should be a priority to return the range to "excellent" condition. At the
very least, BLM should adopt Alternative "A", even though this alternative
would allow only a token amount of recovery. This alternative should be
viewed only as a temporary stopgap while BLM develops another
alternative to restore and maintain rangeland to "excellent", natural
; condition.
-3 i To tnat end' cattle-grazing and crested wheatgrass seedings should be
1 eliminated. In addition the plan should commit the Bureau to keep riparian
and aquatic habitat in "excellent" condition. That should include
74-4 I designation of the South and Middle Fork Malheur Rivers, Bluebucket Creek,
| and the Silvies River as "Wild and Scenic" rivers.
Certainly all of this would require careful discussion of restoration
efforts, which none of your current alternatives address. In addition,
nowhere in your proposals do you even attempt to identify remaining
ancient forests nor how logging might impact the region. I believe we
need to reasses priorities for this area. The proposed Alternative C is a
disaster for the land and for the naturally occurring wildlife. I hope my
comments will encourage you to rethink your draft EIS.
Sincerely,
K
Karen L Theodore
2094! Desert Woods Dr.
Send, Oregon 97702
Appendix 11-87
75
District Manager
Bureau of Lend Management
HC-7412533 Hwy 20 West
Hines, OR 97738
Sir:
I have reed with interest the draft Environmental Impact Statement for
the northern half of the Burns District. I was troubled to learn that
Alternative C was the Bureau's "preferred" alternative. In my opinion, this
alternative leans much too dramatically in favor of cattle interests at the
disastrous expense of all other issues. Virtually no consideration is given
to bighorn sheep habitat protection. Deer and elk receive only token
forage allocation with the vast majority being reserved for cattle.
Wildlife winter range forage allocations should take priority over
livestock allocations.
Because so much of the range is in only "fair" to "poor'" condition, it seems
amazing to me that none of the alternatives proposed would come close to
rehabilitating the region to "excellent" condition. It is as if even the
possibility of, for once, making a commitment to redeeming the land is out
of the question. At the very least, BLM should adopt Alternative "A", even
though this alternative would allow only a token amount of recovery. I
believe it is Imperative that BLM develop another alternative to restore
end maintain rangeland in "excellent", natural condition.
To that end, cattle-grazing should be eliminated. Crested wheatgrass
seedings should be eliminated. Along with that commitment to a return to
natural condition should be a plan to keep riparian and aquatic habitat in
I "excellent" condition. That should include wild and scenic designation for
the South and Middle Fork Malheur Rivers, Bluebucket Creek, and the
Silvies River. That would require careful discussion of restoration
efforts, which none of your current alternatives address. In addition,
I nowhere in your proposals do you even attempt to identify any remaining
ancient forests nor how logging might impact the region. I believe we
need to reasses priorities for this area. The proposed Alternative C is a
disaster for the land and for the naturally occurring wildlife.
Sincerely,
ji\-& A*f
Michael A. Sequeira
20941 Desert Woods Dr.
Bend, Oregon 97702
75-1 Refer to response 2-6.
75-2 Refer to response 1-13.
75-3 Refer to responses 1-11 and 1-13.
75-4 Refer to response 3-6.
75-5 Refer to responses 12-1 and 74-5.
76
No comment Identified.
a
■.^LCkiuJ -4kjJ?*v-AJ \&<*> dLsrl£> -fcs~*uJ LtM-fat; i^t> d^J
^JJjL-J (U-UJ *UJ £/U-J C-C^lL Z{us>t£ TZS^ sihldJ
7utjd> _t£ji^ lA^M^U^J jIajlajiJ C-y £fhy -faux) d-e-taJ
sb-KA<!>L/ j&As^^C-J iUjyCs SWuLj a-iS-fitS,
Appendix 11-88
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Nines, OR 97736
77
No comment identified.
REVIEW COMMENTS FOR THE OCTOBER 1939
BLM DRAFT THREE RIVERS RMP/EIS
Deer Mr. Carlson:
(If you
paragraphs-
are facing a reduction in AUM's, please include the next two
If not, cross out second paragraph. )
Alternatives A, B end C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
ve request that if Alternatives A, B cr C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a "Takings Implication Assessment" be completed as
authorized by Executive Order 12630 (see the November 8, 1933 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel),
The letters from the Harney County CattleWomen, Stockgrowers, Farm Bureau,
Sheep & Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we may have are enclosed herein and are
supplemental to our principal response.
/uKC IJ/Zn^/ltf-S
Name J ' '
mil .^//-^
,?«*,»,. 0*
■J*
?77<3Q
Si gnat ure " £? £?
Enclosure: Supplemental Commer,
Appendix 11-89
January 1990
Jay Carlson - RMP/EIS
Burns District Office
Bureau of Land Management
HC 7 4 - 12533 Hwy 20 West
Hines, OR 97736
toot atf
P.O. 00x428
rns. Oregon 97720
78
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
78-1 Refer to response 46-1.
78-2 Refer to response 2-87.
78-3 Refer lo response 2-11.
78-4 Refer to response 4-3 and 4-6.
78-5 Refer to response 4-15.
78-6 Refer to response 2-68.
78-7 Refer to response 2-63.
73-8 Refer to response 32-1.
78-9 Refer to response 2-46 and 5-10.
78-10 Refer to response 2-03.
Dear Mr. Carlson:
The Harney County Sheep & Wool Growers want to go on record that the
January 17, 1990 Riddle Ranch and Western Range Service comments and
response to the Draft Three Rivera Resource Management Plan and
Environmental Impact Statement are consistent with our views and
comments. This response is our endorsement of such Riddle Ranch
document. There are several other areas of concern that this letter will
address .
78-2
78-3
The Bureau of Land
January 22, 1987 si
rescinded. Please
of land "directly i
vegetation or physi
influence". The de
agem
d by
cha
itio
ent R
BLM
at th
ed by
ract
con
st exhibit the pre
wo cree
orough
riparian area
lassif
ught t
the definition
should be taken out of that
lpar
Dire
e de
per
rist
t inu
ncl
etat
led as r
0 our at
1 creeks
a . Any t
assif icat
Ar
ctor
f init
manen
ios r
es th
de "e
ion d
ca Ma
obert
hemer
pende
Ion.
agement Policy, dated
J. Burford has never been
a riparian area is an area
, and having visible
ve of permanent water
s excluded from the
1 streams or washes that do
t upon free water in the
that do not meet these
are 5kull Creek and Landing
be make to ensure they meet
ot meet the requirements
Monitoring techniques currently in use on the Three Rivers Resource Area
are insufficient, inaccurate, and improperly applied and then are
extrapolated to indefensible conclusions. Management objectives, in the
absence of AMP's, are documented only in the broadest of terms making them
virtually immeasurable. Mo factors, other than short term wildlife, wild
horse and lives took utilization, are indicated as affecting forage
production, ecological status or potential of the resource. Therefore,
reductions in authorized livestock use is the primary, if not the only,
inf
maint
or de
recen
condi
range
evali
comm'
Then
negat
lives
tion
n is g
ial
matio
ained
crease, p
tly publi
tions , as
cond
ation
nicat
is
ive e
tock
nated
Ition
rati
ion
sci
ffect
in th
nge
ith
enti
mended .
ed exis"
time tht
d justme:
ley Ran
air, go
atlBfac'
.necessi
e permi'
c data '
e sageg:
grouse :
Until proper teohniques and accurate
ing levelB of livestock grazing should be
t reliable information shows trend increase
ts could then be made . The ratings in the
gel and Program Summary Update classify range
" and excellent. The RMP/EIS classifies
y 'and unsatisfactory. "'■'Consistent 'use of
for aocurate evaluation as well as better
t indicates that livestock use has any
se population. The restrictions on
utting grounds are
nded and should be
78-6
73-7
78-8
The exclusion of cattle on the Biscuitroot Cultural ACEC is not
supported. The report states "...these areas to be a high -value resource
due to the quality and quantity of roots available". Appendix 7-12]
Vol.11 Appendioiea. Since grazing has been going on in this area for
years and the quality and quantity have remained high, even with root
harvesting, there is no justification to change the practice.
The designation of the entire Kiger active Horse Management Area (HMA)
(36,619 acres) as an Area of Critical Environmental Concern (ACEC) will
have a dramatic economical effect on at least one ranch. Before this
change is even oonsidered and the Pinal Three Rivers . RMP/EIS is issued, a
complete "Takings Implication Assessment" should be conducted as
authorized by Executive Order 12630. livestock and wild horses have run
together success* ully/.,f or yearsV'-The complete elimination of livestock
grazing is neither just if led 'nor ''proven necessary.1' The conditions for
acquiring the private holds or ' the authority to impose this on the private
holdings is not full y ad dressed.
The continual fencing of reservoirs is in direct conflict with the BLM
objective to disperse livestock away from riparian areas and improve
forage utilization. These reservoirs would not be there today if it had
not bnen for either the range improvement funds or private funds that
first developed them. The small water gaps that dry up during the season
or don't allow livestock to watHr during low water years restrict the
amount of available forage and can concentrate cattle more than
necessary. Livestock have a bi o logical need for water. Access can be
accomplished by building the water gaps at the deep end of the reservoir.
if the enclosure is more than one-half mile square, have more than or\c.
access point to allow livestock better aocess to all of the forage
available around the reservoir.
Eef ore any alternative that causes a reduction of AUM'g is imposed, no
matter what reason, a complete "Takings Implications Assessment" should be
completsikas authorized by Executive Order 12630.
/S"Ip'cercly , \
Nancy Cray,^resid
Harney County Shee
SR-1 Box 37
Burns, OR 97720
Appendix 11-90
arneson & wales
AnorwEvsATLAw
318S.E.IACKSON STREET
P.O. BOX 2191)
HOblBUKC. OREGON 97470
January 26, 1990
71
Refer to responses 1-13, 13-7, 2-44, 1-11, 12-1 and 2-78.
District Manager
BLM Burns District Office
HC 74 - 12533, Hwy. 20 West
Hines, Oregon 97738
Re:
Draft Three Rivers Resource Management Plan and
Environmental Impact Statement
1 oppose your preferred alternative, Alternative C. I would urge
that you adopt a plan that would restore and maintain rangeland .
riparian and aquatic habitat in excellent, natural conditions. I
would hope that this proposal would eliminate the seeding of
crested wheat grass and that your plan would address and protect
such features as the ancient forests and Big Horn Sheep habitat.
Please adopt the "Natural Values Alternative A".
Sincerely ,
ARNESON & WALES
James A. Arneson
JAA/kkp
)
80
Bid
5fc
&&«nm(\\ , \ja-;\. a-sZx [« Tswa^Oj
uijlgltjft mlMT&g... FJjZm^t TJ+ft-v. .ts>$-8G££i_.
80-3 I- iai-l ^W a "fescimJ cF #l( w*ri<i JwilfT/rO tyi(Mj'*J
fp_ lV3 rt/U-1 feP Jfjw/i, -50 TI&W^ ?/ /eticAliiZ-S
y (^r^ij^l^r^f ~i> e^cM/fcA,?"^ (w*Tvi<?'^- C6KOtr)fK-
totes' r*2. ii&\iism as lb -rift Oh^r'sorti. 6P
/ St
80-1 Refer to response 2-78.
80-2 Refer to responses 2-10 and 2-11.
80-3 Refer to responses 2-44 and 13-7.
80-4 Refer to response 1-13.
Appendix 11-91
J-2**-^0
tJafo-lct /VoM/i^L
8 1
-euLct&-
j£& n^t ~tt!M^ -&bd y-criA ty~z
-blub a-x^p, ■■</> ao-u. -(,
S
(Xthu^dl^ A u^a Mp,. o
\X£ajIgL
0v6tiA4«i^XA^A. aLc^l (AKkh- (?mA Jyvu/t/u-
13 iA/1'UV^ lyhuzJi |bO/lMX<vt yyl^voM
V£>
^y
(u«>>^ ch^ jcWki ovua cUi"vc(. oua^ct
■jii<rv TyU<o(, 1/^^flCtU'^) J y^ ^w^ui Trim SwWbffLL -
O&a-SL OAaof J/A^, iMMl£od- J\)\AJsvJld.
-fclta -sJ(Xt>-c^a RlWa. .
M (Wiser j\£sCAyvJ[*ls<^ ~XMJt. JjMl^aJ-^L^
UhmaAca, yia/ni?K "^ruuciS. oJUft^ttCcrsxj^ U<
® i (yXa- ^Kn- H^ (Vgma^G' > jv^yi Jia,<x>^
{jjs^A \JT*>OsVlAJtot
81-1
Refer
to
response 1-13.
81 -2
Refer
to
responses 2-44 and 13-7,
81-3
Refer
to
response 12-1.
81-4
Refer
to
response 12-1.
81-5
Refer
to
response 1-11.
81-6
Refer
to
response 2—78.
81-7
Refer
to
response 3-6.
81-8
Refer
to
response 2-6.
81-9
Refer
to
response 5-18.
Appendix 11-92
0
82
~7>
M, I ■
(/). -£ &»**
~t^L^h ^i-
f.e, £*y. //J 7
t/U.,
y*0
^d-'H<r>^ -
4)
t>
&Ut
'2dd?*
*yz&>L*
CJ/lOyl^ .A^t^L. /SsZ*-t-<£ ',
*
£
£ZJ* £.
asu- -J-t*-*.^ .("JUL/*'
V
Lt^lJU^-lLJ
3d ■ i
($/■ "m&i*- ~4eJ tkp. . "2H61&/L da.2i5{U- fl-S4»>^.« I*mL«*_
82-1 Refer to responses 2-6, 2-10 and 2-ll.
82-2 Refer to responses 2-3 and 2-5.
82-3 Refer to response 12-1.
82-4 Refer to response 2-78.
82-5 Refer to responses 2-6, 2-10 and 2-ll.
82-6 Refer to response l-ll.
OAJ~ A- ~yvi-£-e-^t_-
U_hL-a lM^^~ r*iM^W^.<j ^CiZj_^^^. Gjt^jb^tJL- (Qsij^O"-: .
(C.) Qua- <hLJL ^tssvuck- 3-oSltU -aMv-M. •£*, -ry>txA-k*.iL a-^-k^
\Sl.{rhj^£t JL ! uIl~ QAXAb-v^j^^^J Lu~lU- "^-t JLl^^j &£$u.1-> 5^iilo
-^f-tf-VL- . - fid 7Hrs*Mt-lJ ' «jlll-<-' Jj~iJL^_ 0- -JiC <[4{S-* s<U*H~C_-lS •=*
U>-il^ ff Mo. tJJL t S* -J) iU^^. ^.a^, ~tXs- 64JL cy,_^j^L.
(J)). ~rL^ J&Ia -}1*4~u3&ua*u -~4wMJ^J-_..^zJio~^£&_ -Z-t. JLM.
(_£) Qma. "uiUnA-fO^ L^-Ucti^ jt-^k3a~ 3^-^j2il ^-(U.. Y^- -
if)
■A* . CahjL- AjJL I
Appendix 11-93
WILLIAM O CRAMER
VILUAM 0. CRAMER. JR
oonooN mai i. UN
CRAMER & MAU.ON
January 25, 1990
83
PHONEI5O3I373506G
Pftl ISO3I5732088
83-1 Refer to responses 2-5, 2-11 and 3-13.
83-2 Refer to response 3-13 and 5-10.
83-3 Refer to response 1-13 and 32-1.
U.S. Dept. of Interior
Bureau of Land Management
District Office
HCR 74, 12533 Hwy. 20 W.
Hincs, OR 97738
RE: Three Rivers Resource Management Plan
Gentlemen:
1 am writing to oppose the preferred alternative grazing policy
submitted in your Three Rivers Resource Management Plan. The
idea that either the streams are as badly degraded as you con-
tend, or that they can be substantially improved by the proposal
to remove livestock from over 80 miles of stream for 5 years is
ridiculous. If you follow your plan, you will not only take the
livestock off their normal watering areas, but also close off
vast areas of hillside grazing which cannot be utilized without
water and without fencing off from the streams.
Your habitat preservation policies are extreme, and should not be
put into effect without substantial additional plot testing.
What I have seen of the relatively few areas you have tested is
that fencing off has not significantly improved the grasses along
the streams. It is true that the animals feed first on the grass
closest to the water. Those plants are used to that kind of
grazing by both domestic and wild life. They come back year
after year after intensive grazing. In the few areas where you
wish to re-establish willows, you can do this by fencing off
those particular areas. You do not need to destroy the whole
grazing system to accomplish this one minor goal.
It seems apparent that your proposals are motivated by an intent
to remove more and more domestic livestock from the BLM areas.
This is absolutely wrong and will not bring any substantial
benefits for anyone .
Please reconsider and come up with a reasonable plan.
Very truly yours ,
WDC:sl
1/75
William D. Cral
CRAMER & MALLON
WILLIAM O CRAMER
WILLIAM 0, CRAMER. JR.
GORDON MALI ON
84
PAX (903IB73-2O68
January 26, 1990
U.S. Dept. of Interior
Bureau of Land Management
District Office
HCR 74, 12533 Hwy. 20 W.
Hines, OR 97738
RE: Three Rivers Resource Management Plan
Gentlemen:
I have written to you about other matters, but I am writing
specifically to object to several other aspects of your plan.
I strongly oppose any attempts to limit upland forage by
30%. There's no scientific basis for this and it is outra-
geous. Particularly after the flowering period, there
should be no limitation at all.
I strongly oppose increase of any wild horse area whatsoever.
This is against the meaning and intent of the Wild Horse Act
and will be a terrible burden on any of the ranchers in
those areas. The fact that the BLM now wants to go into the
wild horse business does not change this.
I request that you emphasize the eradication as much as
possible of juniper trees on the BLM areas. They are
causing far more damage to domestic livestock and wildlife
in the overall range than all other causes put together.
You should plan more substantial burning programs to get ria
of quantities of these trees. They have taken over a huge
amount, of particularly the Steens Mt. area, in the last 50
years.
84-1 Refer to response 2-7.
34-2 Refer to response 11-11 and 25-1.
84-3 Refer to response 6-8.
84-4 Refer to responses 4-14 and 6-10.
1
mining and searching for minerals
I oppose any limitation
in any of the BLM areas.
I strongly oppose the BLM purchasing any additional lands in
this area or facilitating purchase of any lands In this area
by any parties.
Very truly yours,
bLOti
WDC:Sl
2/16
Appendix 11-94
_::,::v::...-::--i-:-: -;v ".:■
FRCirSHRMRDCK PRESS
TO: BLM FM - BURNS '0
JON 31, 1990 3: 15PM P. 01
ei
2-44 and 13-7.
A-s
FiittrJ fl
71
■Since n lyf
MAYO RANCH, INC.
86
January 26, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hines, Oregon 97738
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr- Carlson:
Alternatives A, B and C will result in a substantial
loss of our base property value. The proposed BLM actions
may result in reducing the size of our operation so that it
is no longer an economic unit. Therefore, we request that
if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and
Environmental Impact Statement, a "Takings Implication
Assessment" be completed as authorized by Executive Order
12630 (see the November 8, 1988 Memorandum to all Assistant
Secretaries and Bureau Directors from Secretary of Interior,
Donald p. Hodel) .
The reallocation and/or reduction of 1,859 AUM's
livestock forage in our Rim Lake, Juniper Ridge, Claw Creek
and Dry Lake Allotments will reduce the value of our base
property by approximately $92,950.00- Please consider
this economic loss in the requested "Takings Implication
Assessment . "
The letters from the Harney County Ca ttleWomen,
Stockgrowers , Farm Bureau, sheep 5. Woolgrowers and the
January 17, 1990 Riddle Ranch and Western Range Service
Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are
consistent with our views and comments.
This response is our endorsement of such letters and
Riddle Ranch document. Their response has been submitted to
you. we do not include a full copy of the text only for the
reason that it would be an exact duplication of the Riddle
Ranch document and organizations letters.
71
January 26, 1990
Page Two
We wish to state unequivocally that we believe the
direction the Draft purports to take the Three Rivers area
is detrimental in the extreme to the economic growth and
future welfare of both Harney County and the people living
and working therein- We also wish to state that with the
documented and current cooperation of those same people, we
believe the progress being made at this time in the areas of
concern addressed in the Draft, is in the bests interests of
the environment and the land at issue.
Sincerely,
Mayo Ranch, Inc
Mark R. Mayo
; i'Li^yr
•^v )>iety
Jyan M- Mayo
HC 74, Box 130
Riley, Oregon 97758
Carl L. Mayo
86-1 Refer to response 2-63.
86-2 Refer to response 2-63.
71
HC 74 BOX 130 RILEY, OREGON 97758
71
Appendix II-95
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Bines, OR 97736
&Y
No comment identified.
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson:
(If you are facing a reduction in AUM's, please include
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C will result in .
property value. The proposed BLM actions m.
of our operation so that it is no longer an
we request that if Alternatives A, B or C a:
issuing the Final Three Rivers Resource Man,
Impact Statement, a 'Takings Implication Ast
authorized by Executive Order 12630 (see the November B, 1988 Memorandu.
to all Assistant Secretaries end Bureau Directors from Secretary
Interior, Donald P. Model).
substantial loss of our base
y result in reducing the size
economical unit. Therefore,
e considered, that prior to
gement Plan and Environmental
t" be completed as
The -reallocation and/or reduction of . -AUM"i
Sf " Allotment will reduce the "value o£.
property &y '-approximately S
Please consider this economic
Assessment. r
'livestojik , for a ge
"r ur base
_. (Assume S50 per AUflJ*~v6lue),
the requested 'Takings Implication
The letters from the Harney County CattleWomen, Stockgrovers, Farm Bureau,
Sheep & Woolgrovere and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent vlth our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submi tted to you. We do not incl ude a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments ve may have are enclosed herein
supplemental to our principal response.
Sincerely,
Name
73Tv
Address
C ..ra'":.e.
(JVM On
c77\i -
City
.. .*
■■ Itfa
State
Zip Code
Signature '
/
Enclosure: Supplemental Com
OREGON
CATTLEMEN'S
ASSOCIATION
lOOON.E.Multaamnh Street
Portland, Oregon 97232
(503)281-3811
FAX; (503) 2BO-BB60
Dnr. Cnmrn. Sr
m Bo* 70
Antelnr*. OR 97001
lil Vice Freridnnl
Lynn Lundquisl
Bmifel Bo. 610
Powell Buna, OR 97753
TrMmer
lohn R. Roscbrwk
PO Bu «
Bravo rcrmk, OH 97004
lad Viw Prflrid«n!i
Daniel Bcnl™
RU Bill 103
Bcrmislon. OR 97838
Rich aid BmM
Roulc 2. Bra 525
PruicvJIt. OR 977H
Gordon CdlCO
Rnult 1. Ben 1<10
Beta City, or tilta
Mark BsVHtttkt
SR1.B
134A
Burns, OR 37720
I Dennis Hill
Huule 1. Boi 795
LteeaGvt Vict Prtiidenl
Kick Srrrll
TO N.E MullnomuliSt.
Pnrllirnr!, OH 37Z37.
88
January 30, 1990
Mr. Oay Carlson
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 97738
RE: BLM Draft Three Rivers RMP/EIS
Dear Mr. Carlson:
The Oregon Cattlemen's Association appreciates the
opportunity to respond to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement.
Based on conversations with, and information provided by
livestock producers located in the Three Rivers region,
there is substantial disagreement with the data used to
develop the draft policy for the region. Before the BLM
approves the RMP/EIS, efforts should be undertaken to study
and resolve the issues where parties disagree with
conclusions reached by the BLM. A meaningful dialogue with
affected livestock producers should prove beneficial.
There is no reason for the BLM to move with celerity when
draft policy affects so many with the potential for an
outcome not in the best interest of improving the
environment and economy.
We believe the BLH should thoroughly examine the major
arguments brought forth by livestock producers. The
following are a few issues that should be resolved:
** reviewing all creeks in the region to determine whether
or not they should be included in the riparian area
** developing information to ascertain the impact livestock
has on the sagegrouse population
** allowing cattle on the Biscuitroot Cultural ACEC unless
studies clearly demonstrate damage (we note that
historical grazing practices have not impacted root
structures)
** examining historical data on water quality, since there
is a major disagreement concerning the data provided by
BLM, that does not appear to be substantiated by the
human eye and those living in the area for a number of
years
** determining if preference for wildlife and wild horses is
inconsistent with federal court decisions
** ascertaining how the fencing of reservoirs will enhance
riparian areas
** developing an objective standard to determine the condition
of the range
Undoubtedly, the Draft Three Rivers RMP/EIS will have an adverse
impact on livestock producers raising livestock in the area.
Resolving the issues we have raised, plus the other issues
articulated by producers, will guide the BLH in their quest for
what is best, based on the scientific data.
Sincerely,
Don Gomes Sr
President
Refer to
Refer to
Refer to
spouses 4-4 and 42-14.
spouses 3-9 and 4-6.
sponse 4-15.
88-4 Refer to response 2-3.
88-5 Refer to response 2-6.
88-6 For a discussion of the predicted improvement see the environmental
consequences of the Proposed Plan. Also, refer to response 5-10.
88-7 Refer to response 2-87.
Appendix 11-96
89
89-1 See DRMP/DEIS, p. 3-16, for information on how range improvements are
funded.
-2 Refer to response 3-6.
P 0 Box 96
Entero'iSB, GR 97828
January 30. 1 990
District Manager
Bureau oi Lend Management
HC74-12533 Hwa.20W»t
Hines. OP 977J8
£«rDwtncl Manager
I am writing to comment an your preferred Alternative C for
in ttie BLM'8 Burns District,
As I understand It, you propose to Install mil** Of fence ana sl&slins end njmeroue
troughs, wells end reservoirs, at my expense, fer the benefit of e handful of "welfare"
ranchers
fee former employee end student of Malheur FieM Station. I grew to know and love
that land, and think you're miasing a real opportunity to restart the feng? to Its full
potential iorell living things, not juat Cattle.
I'd prefer my tax doilera to finance native grass Dlentinn. nperien restoration and
preservation oi ancient fpresta -- necessary steps for maintaining a diverse ecosystem.
The Malheur and Silvias Rivers and Blistjucket Creet" are too special U serve as
cattle troughs and urinals. Indeed, the rivers daeerwwild and Kenift statu*.
Touneta and 'heir credit cards will not venture to Harney County to eea cpws and en
gslchM; tfieuwill come for bighorn 9li*eD ancjhealthy trout stream-:-
i oeo at yau no: to cere into pressur-a from me local QCA Thmt :■> in? (•nan
generatlona of Qregantane that will need end benefit more frarri wtlderneea then a few
ounce* of ranae-ted Deaf
J
Cathy SUr6Klt2
CENTRAL OREGON
AUDUBON CHAPTER
P. O. BOX 565
BEND, OREGON 97709
90
90-1 Refer to response 1-13.
90-2 Refer to response 1-11.
90-3 Refer to response 3-13.
90-4 Refer to response 12-7 .
January 31 i
Di str i ct Manager
BLM
HC-74-12533 Hwy 20 West
Hines, Oregon 97738
Dear District Manager:
I am writing as a representative of the 437 members of
Central Oregon Audubon. We were very upset with your
preferred al ternat i vet C) . It maintains the range in
horrible condition and continues to degrade the range even
90-1 I further. All o-f the range should be in restored within the
I next 5-10 years to excellent condition. It is time the BLM
I manage their lands properly instead o-f allowing the ranchers
I to do whatever they want. The BLM lands are owned by all
I 240 million Americans not by a -few local ranchers.
90-2 I tJe -find all crested wheatgrass seedings totally
I unacceptable, Why should the American taxpayers have to
I -foot the bill to provide non-native forage for the local
I ranchers? NATIVE SPECIES OF GRASS are the only species
I acceptable for wildlife.
90-3
pgraded to excellent
e wi Idl ife on BLM lands
an zones to survive.
IA1 1 riparian zones needed to be u
condition immediately. 90Y. of t
eastern Oregon need healthy ripar
I We would like to see the costs of all your new projects
listed alongwith the environmental impacts. The public
needs to know where their taxs are going.
In summary we feel that the only Alternative that is even
close to being acceptable is Alternative A. This
alternative needs to be modified so that the emphasis is on
restoring rangeland to a healthy natural condition. It is
time for the BLM to stand up and manage their lands properly
instead of being waterboys for the local ranchers.
Si ncerel y ,
81 enn Uan Ci se
Conservat i on Chai rman
Appendix 11-97
91
Refer to response 2-63.
PO Box 796
Crane, OR 97732
January 31, 1990
Mr. Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Mines, OR 97738
Dear Mr. Carlson:
Alternatives A, B and C will result in a substantial loss of our
base property value. The proposed BLM actions may result in reducing
the size of our operation so that it is no longer an economical unit.
Therefore, we request that if Alternatives A, B or C are considered,
that prior to issuing the Final Three Rivers Resource Management
Plan the Environmental Impact Statement, a "Takings Implication
Assessment" be completed as authorized by Executive Order 12630
(see November 8, 1988 Memorandum to all Assistant Secretaries and
Bureau Directors from Secretary of Interior, Donald P. Hodel ) .
The letters from the Harney County Cattlemen, Stockgrowers, Farm
Bureau, Sheep and Woolgrowers and the January 17, 1990 Riddle Ranch
and Western Range Service comments and response to the Draft Three
Rivers Resource Management Plan and Environmental Impact Statement
are consistent with our views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not
include a full copy of text only for the reason that it would be
an exact duplication of the Riddle Ranch document and organizations
letters.
Sincerely,
a
^Jerry A. Miller®
January 17, 1WS0
Jay CarlBon
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Mines, OR 97733
92
Refer to response 2-63.
REVIEW COMMENTS FOR THE OCTOBER 1939
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson t
(If you are facing a reduction in AUM's, please include the next ttro
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C will result in a substantial loss of our base
property value. The proposed BLM actions may result In reducing the size
of our operation so that it is no longer an economical unit. Therefore,
tte request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a 'Takings Implication Assessment* be completed as
authorized by Executive Order 12630 (see the November 3, 1983 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel).
AUM's livestock forage
e the value of our base
77j€> reallocation and/or reduction of (r> ^0
In fejfrgi <. i?, ti».fi*i-tft /)>£e.rT. Allotment vlll redui
property by approximately h. 15' 666 — (Assume S50 per AUM value).
Please consider this economic loss in the requested "Takings Implication
Assessment. "
The letters from the Harney County CattleWomen, Stockgrovers, Farm Bureau
Sheep & Woolgrovers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent vlth ou
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it vould be an exact
duplication of the Riddle Ranch document and organizations letters.
Any add! tit
supplemental tt
nal comments ve may have are enclosed herein
our pri nci pal response.
nd are
Sincerely,
/JC./L 75 5~/)t>fi />,,;/_, St-,,0
Address
City
Si gna t ure /
Enclosure: Supplemental Comments
Appendix 11-98
Jay Carlson
RMP/EIS Team Leader
Burns District Office
HC 74-12533
Highway 20 V
Hines, OR 97738
93
Harry E Wilson
2120 N Callow Ave
Bremerton, VA 98312-2908
27 January 1990
93-4
93-5
As stated in the DRMP/DEIS, p. 4-9, Table 4.3, Footnote 7, "the
average annual harvest is an estimate since no systematic inventory
of our woodlands has been conducted. No woodland inventory is planned
for the immediate future."
Thank you for bringing these number omissions to our attention. The
correct numbers are shown in the Proposed Plan. See Table 3.5.
The reallocation of 2,622 AUMs, in addition to the current 5,278
AUMs, would add up to the 7,800 figure. Also, refer to response 2-10.
Refer to response 4-4.
Refer to response 28-1.
Thank you for the opportunity to comment on the Draft
Environmental Impact Statement / Resource Management Plan
for Three Rivers Resource Area.
I believe that Alternative B would be the best
alternative for the resource area as it is almost the same
as Alternative C (the preferred alternative).
On Table 4-3, Impacts to Forestlands and Woodlands, the
Average Sustainable Annual Harvest (cords) is an estimate
Olily. Has any systematic volume and production inventoriee
been conducted in the Resource Area? Or are the figures just
educated gueee?
Table 4.10, what are the figures for Palomino Buttes,
good and fair? Table 4. 11,- what are the figures for Kiger
and Riddle Mountain, poor? Table 4.12, what are the figures
for Warm Springs, Total Change, poor? In most cases it
looks like the figures should be zero, but are they?
Frasi reafling the iMjs*£t* on -'^ &s*K Habitat It »--•«■
that the allocation of 7,800 AUMs of cattle type forage to
would
vis
their
jianit
Table 4, 19, it seems that their is approximately 1/4 ol
the streamside riparian habitat that is in any unknown
rorjcltior. Is their plans to inventory this habitat -co see
what condition it its in?
On page 4-68, Economic Conditions, Livestock Grazi
their should be discussion of the monetary values the
ranchers would face.
Thank you for your time and consideration.
Sincerely ^ <^
Harry E Wilson
:•"■!""■ S Callow Awe
Br#t»*rton, V> WSlS-a^O-a
/WU^7*<**2
Appendix 11-99
94
OWIGHT & SUSAN HAMMOND
Hammond Ranches, Inc.
D I amond , Oregon
Mr. Jay Carlson
Burns D istr ict Off ice
Bureau of Land Management
HC 74 12533 Hwy 20 West
hineb, Oregon 9773S
Dear Mr. Carlson:
NOT BEING DIRECTLY INVOLVED A6 livestock permittees, but being
effected through association and directly neighboring "three
Rivers" boundaries, and being a resident of Harney County which
houses the Three Rivers area, we would like to comment on the
BLM Draft Three Rivers RMP/EIS.
Having read thoroughly the comments submitted to the BLM by the
Harney County Cattlewomen, Stockqrowerb , Farm Bureau, Sheep &
Woolorowerb and the January 17, 1990, Riooli Ranch and Western
Range Service Comments and Response to the Oraft Three Rivers
Resource Management Plan and Environmental Impact Statement; we
would like to ado our complete support for those v i ewb and
comments, and most in particular the fact that this rmp/eis |3
not needed in it's present form.
This RMP seems to us to ge a costly, waste of taxpayers equity
IN THAT IT IS A REPLICA OF A NUMBER OF PROGRAMS THAT ARE ALREADY
IN EFFECT AND FROM FIRST-HAND, ON THE GROUND OBSERVATION, WORKING.
Proposals to remove livestock from streams ano reparian area
in our opinion, not a very progressive responsibleaotion.
our particular area ano areas we have observed personally, t
remove livestock ano game from one natural watering source,
se replaced by a man-made water area, is creati no a problem
other and adoitional areas, which aren't
TO GIVE Wl L
TO US TO BE
OR HONORING
IN PREDICTABLE.
HORSES PRIORITY OVER DOMESTIC GRAZING RIGHTS SEEMS
'CRY BIAS AND POSSIBLY NOT TAKING INTO CONSIDERATION
IISTORIC RIGHTS AND ECONOMIC USES. THIS PLAN SEEMS
to further perpetuate a prohibiti
in the "Wild Horse Program". We
all the time, ano in our opinion,
than there are dinosaurs.
LY COSTLY 8UREAUTIC BOONDOGGLE
VE HERE AND WE SEE THESE HORSES
HERE ARE NO MORE "WILD" HORSES
ALL OF THESE CRITICAL AFFAIRS ARE OF UTMOST CONCERN TO US AS
LIVESTOCK PRODUCERS AND HAVING SEEN THE EFFECTS Of MANY OF THE
PR0P05ED ACTIONS. KNOWING FULL WELL THE ADVERSE IMPACT THEY WILL
HAVE ON THE LIVESTOCK INDUBTRY, WE 00 NOT FEEL THE COMPLETE ECOSYSTEM
IS BEING CONSIDERED.
Refer to response 2-6.
Appendix 1, Table 13, PRMP/FEIS displays specific expenditures for
each type of alternative. Also, refer to response 28-1.
None of the BLM land under agricultural leases is considered "prime
or unique" under Soil Conservation Service definition. Changes in
private land use, including conversion of privately-owned prime or
unique farmland, would be subject to local comprehensive plans. It Is
assumed that no private farmland productive capability could be
adversely affected by BLM land uses or allocations.
The DRMP/DEIS details the availability of public forage under each
alternative. The economic contribution of this single production
input to the ranching industry in Harney County has not been
quantified.
The Landownership percentages for the Three Rivers planning area
found in Table 3.20 of the DRMP/DEIS are in error. They should be:
Public Land - 57.8 percent; Private Land - 34.7 percent; State Land -
4.6 percent; and, USFWS - 2 percent. U.S. Department of Agriculture,
Bureau of Reclamation and the Bureau of Indian Affairs (Bums Paiute
Reservation) make up less than 1 percent each of the land in the
planning area.
Harney County landownership percentages Include 72 percent Federal,
25 percent private and 3 percent State. In contrast, the ratio of
landownership In Oregon is 52 percent Federal and 48 percent State
and private.
Wetlands are one of several public resource values that would be
considered for acquisition. They have international importance as one
of the most productive habitat types. Also, refer to responses 4-14
and 6-10.
d al90 the uni
n , cost of Imp
rce Management
U . 8, | SEEMS T
I N SHORT SuPP
(DERATION IN T
OCE6SES , THIS
WOULD LIKE TO
ATtON11 WOULD B
e adverse effe
no also the e
and Oregon.
ted
LCmENTA
CT ON
CONOMI C
There
The economic impact on Harney County Oregon a
States citizens, in that the care, preservati
TION ANO MAINTENANCE OF THE THREE RlVERS ReSO
would ultimately be that of the people of the
missing. These tax dollars are, at this time,
this has not been addressed or taken into cons
plan. as in a lot of governmental plann i
seems to have been omitted. afi taxpayers
what the cost, or "estimated cost of implement
Also, has an economic study been done as to t
"prime ano unique farmlanos" in harney county
effects on the cattle industry in harney coun t
IS A "human" ELEMENT INVOLVED,
We don't FIND MENTION OF THE percentages of federally owned lands in
comparison to the private ownership in harney county or oregon ;
and we feel that this particular comparison is of utmost importance
to County and State economics and governments when considering
future acquisitions of privately held lands ano al80 land exchanges
where the private sector is loosing acres to federal ownership acres.
Where does the thinking "identify and agressively persue land
exchanges or purchases to increase the acreage of wetlands- |n public
ownership1' have a place in a democratic society? this does not
seem consi6tant with our country's basis.
We feel this Three Rivers RMP would make a wonderful reference
book and that we should use it as such, considering the time and
tax dollars already spent on it; and, that we should utilize the
already in place, working, common-sense management plans and curtail
further needless spending of our very scarce tax $$$ .
Thank nou for allowing us to comment.
Dwight & Susan Hammono
Hammond Ranches, Inc.
Diamond, Oregon 97722
CC: Robert F. Smi th
Harney County Court
Harney County Stockgrowers
Appendix 11-100
95
yj,*f. ?V- /J533 -/iLfiL^^
UjcuT.
No comment identified.
96
3. LA
Tier /v(r. i^/yax.
4k lefkri 4V«* #A Ikrnty C^Jr S4/-
JH^f^ 5?,d3^/e «W «^5 |S»r $4*«>*s fed
UJ^Y A6. fas'/ A/je^ c^l/ohtds art m<n*g«#
ot- <uj i^/ ^ ^^ /^ ije /^ (»„„ ^^
a/m^ u,tlJ- Jul A-nscs a*& -<j4 o<./y <jwer g^^
^«f .*Ka IS iv 4»& Jan/: fyrty IW/cQ cUm.
#*aa. ,vie as ttf^/le, JV >'3 y&iy ezsy A. jee
-/& XifiSe'3 ca-e. U<-&* ^ j^ m'^.'c,
Ze*eS A^Jl -£d ^"ge eSs>ec',c.l'y 3iKOJt. 4>hy
My ag.<^ <^pi e« n ,'jr ^4 £>do a<5>i, jj,
So*^e $u W',H ,/i^-t ^ *?»- >4 i>;/Zr d/^
*5 *
96-1 Refer to responses 25-1, 25-2, 25-3 and 43-2.
Appendix 11-101
January 7.6, 1990
IE JAN 2 9 19S0
BURNS DISTRICT BIM
I
No comment identified.
District Manager
BLM Bums District Office
HC 7^-12533 Hwy 20 West
Hlnes, Oregon 97738
To Whom It May Concern:
At a time when my respect fnr the BLM Is on the rise, I am
disillusioned and shocked to hear that you might reopen
Stiffen! Mtn. to snowmobiles. These energy-consuming, noise
and air polluting machines have no place In sensltive."wllderness
areasl One snowmobile dominates any space; unfortunately, there
is no such thing as one - they travel In packs. Please resist
the pressure from these snowmobllers and recommend Alternative 3.
Additionally, I ask that you adopt Alternative A for the northern
half of the Burns District. 3 am primarily concerned about
bighorn habitat. Certainly you must sense the thrill of seeing
them forage undisturbed In their range, a true wilder-i^ss habitat.
Timot'Ky'H. Cowles
3333^ SE Lusted Road
Gresham. Oregon 97080
98
Refer to response 3-6.
February 1, 1990
Oislrict Manger
Bums District, BLM
Hines, Oregon 97736
Steen Mm. Loop
As an avid ouldoorsman and conservationist, it has come lo my attention that you want to reopen
the Steens loop during winter/spring to motor vehicle access, principally snowmobiles.
I urge you not to do this. The area Is an Important winter habitat lor deer, elk and other wildlife,
which none of us want disrupted. Your Alternative 3 prohibits vehicular access in winter, and will
guarantee the ecological soundness oi this sensitive ecological area. Snowmobiles can go elsewhere. I
hope that you will adopt Alternative 3,
Three Rivers Management Plan
On a related issue, Alternative C of the Three Rivers Management Plan will be an ecological disaster,
and a giveaway to the already pampered grazing industry at taxpayers expense. I urge you not lo
adopt Alternative C.
Alternative A will help to restore and maintain the natural rangeland. This will ensure protection of
water quality, wildlife habitat, what's left of the old growth forests and other natural resources
which, in the long term, will provide a far greater return on investmeni than continued kowtowing to
the heavily subsidized ranching industry.
I urge you to adopt Alternative A as a minimum.
Wild and Scenic River Designation
I In order lo restore, protect and ensure water quality, soil quality, wildlife habitat, and scenic and
recreational values, I urge you lo designate the Malheur River (South and Middle forks), Bluebucket
Creek and the Silvies River as Wild and Scenic. This will ensure that these waterways will continue lo
provide optimum long-term returns from tourism, hunting, fishing and boating.
Mike Quigley
2009 Red Rock Lane'
Bend, Oregon 97701
cc: Senators Mark Hatfield, Robert Packwood
Appendix 11-102
(D
m
99
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99-1 Refer to response 1-13.
99-2 Refer to responses 1-11, 1-13 and 12-7.
99-3 Refer to responses 2-44 and 13-7.
99-4 Refer to response 2-6 and 2-78.
99-5 Refer to response 12-1.
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Appendix 11-103
Northwest Federation of Mineralogical SWii(it's
Public Land Advisory Comm
2516 - 15th Ave. W. #204
Seattle, WA 98119
Bureau Of Land Management
Burns District Office
IIC 74-12533 Highway 20 West
Hines, Oregon 9773S
Re: Draft Thr
Gentlemen :
Resource Management Plan and EIS
Enclosed is our response to the above draft plan. We do
appreciate the opportunity to comment on ic and wish to commend
thoes responsible for its preparation,
Should the District wish any additional input from the
rockhound community, please feel free to contact this committee,
and/or the Oregon Council of Rock and Mineral Societies In care
of Art Newcombe, Vice President, HC 64, Box 410, Lakeview, OR
97630.
Thank you for this opportunity to comment.
Very truly y.ours ,
Northwest Federation of Mineralogy
Societies
Jon Spunaugle, 2nd Vice President
by the Bureau in 1990, and we would expect to see an increase
in fossil collecting activity as a result. Some reference La
these new rules might want to be included in the Three Rivers
Resource Management Plan final draft.
An area of our concern is the occasional unreasonable and
possibly commercial collecting of large quantities of mineral
materials, especially obsidian, chat has occured from time to time,
in the area by unscrupulous and careless individuals. This has
resulted in some resource depletion and environmental damage.
We do not condone such activity and would suggest that the
District proceed with establishing clear collecting rules and
reasonable quantity limits ("take limits") for personal collection.
We would also suggest that signs be posted in the most widely
used areas to inform visitors of the regulations. At the same
time we are not opposed to commercial collection of these same
resources and materials, but think commercial collection, or
personal collection above the regulation limits should be done
by "permit only" and from only areas the District manager feels
would not be unduely damaged by such activity. The organized
rockhound groups would be interested in assisting the BLM in
accomplishing this and in publicizing any such regulations.
In this regard, we did carefully consider the "Obsidian ACEC"
proposed in some of the Alternatives, Even though we believe
some control is desirable, we do not support the creation of
this Area of Critical Enviornmental Concern. Instead we feel
that the entire Plan area should be regulated as we outlined
in the paragraph above. Perhaps the BLM District would want
to publish a pamphlet on obsidian collecting to point out the
best collecting areas and to remind visitors of the rules and reg-
ulations including thoes on archaeological and cultural
resources .
2. Other ACEC disignations : As long as rockhound access is
not further restricted in these area designations, we support
their continuation. The one possible exception to this is the
Middle fork of the Malheur including Dluebucket Creek designation
as Wild and Scenic. Our concern is not so much with the actual
designation, as it is with the lack of information on the
Response to the
Draft Three Rivers Resource Management Plan and Environmental
Impact. Statement prepared by the Burns District Office,
Bureau of Land Management, Department of the Interior
October 1989
The Northwest Federation of Mineralogical Societies, representing
over 95 organized rockhound clubs with over 5000 members in the
northwestern United States, wishes to respond to the above Manage-
ment flan and EIS. Our response is generally supportive of the
Alternative C. the "Preferred Alternative" or the Alternative D,
the "No Action Alternative". All other Alternatives have many
undesirable aspects and could negatively impact recreational
rockhound activities in the management area.
Our reasons for this opinion and our observations from our
study of the Management Plan Text, the Appendicies, the Table 2.1
and our collective knowledge of the area, are stated below. We
offer them in hopes that they will be helpful to the BLM in its
planning process. We would also commend thoes involved in the
preparation of the Plan documents, especially in recognizing
their thoroughness and the time and effort required to research,
compile, and produce them.
1. Rockhound Recreational Opportunities: We were very pleased
to note that rockhounding is recognized in the Plan as one of the
principal recreational activities. The areas outlined in Chapte
3 in Map R-l, M-5, and M-4 do, in fact, outlin
our members have used for collecting activity.
Of Alternative C and Alternative D, would suggest that
Alternatives do not unreasonabll y changcaccess to thes
collecting reasonable amounts for personal use.
However, we did not find any mention of the area mi
most of the areas
Our understanding
collecting possibilities, also part of our hobby interest. This
Han area docs contain collecting sites for flourescent minerals
and zeolites, as well as others.
We also would suggest, that Strom consideration be given to
misting ■ study of the pa 1 eontologica 1 resources of the Plan
area. New federal land fossil collecting rules should be published
Oreg
on
nted
to
thout
nagem
en
ssibl
y .
stem
mi
ggest
t
parat
el
e eff
ec
this area may contain, and the lack o
ty. In our opinion, the Omnibus Orego
vers Act of 19B8 was passed without gi
reasonable opportunity to consider wh
designate as "Wild and Scenic". To a
much publicity or public input opportu
t Plan, does little to improve our opin
an original well-thought-out designat
ght have contained this four mile sect
hat all Wild and Scenic River designat
y and adopted only after prudent consi
ted area resources.
f pi
b 1 i c in
put
n Wi
Id and
vins
the ci
tiz
ich
rivers
the
dd t
o this
tot
nity
inside
th
ion.
Quite
ion
of this
ri
ion.
llowev
er
ion
be cons
ide
dera
tion of
al
Appendix 11-104
100— 1 All public lands not withdrawn from mineral collection are available
for casual or hobby collection of mineral specimens) provided there
is minimal disturbance, explosive or mechanical means are not used,
and areas of paleontological or scientific interest (e.g.,
prehistoric artifacts) are not disturbed. BLM does not have staffing
or funding necessary to specifically outline potential collecting
areas for casual prospecting; however, District Geologists are often
aware of where such activities commonly are occurring.
100-2 The Three Rivers RA will have an inventory of high potential
paleontological zones, as shown in the PRMP/FEIS.
The Antiquities Act of 1906 prohibits the excavation, taking, or
destruction of any vertebrate or other fossils of recognized
scientific interest. Taking of such Items is strictly limited to
qualified institutions under special permit.
Proposed rules on the management of paleontological resources that
would become 43 CFR 8270 were promulgated in 1990 and reviewed by the
field offices of BLM. These rules will have a bearing upon fossil
collection but are not approved and enforceable at this time.
100-3 Refer to responses 15-4, 15-5 and 100-1.
100-4 Refer to response 15-35.
100-5 Refer to response 3-6.
101
Leta Gay Snyder
351 S. Broad St.
Monmouth, OR 07361
January 31, 1990
101-1 Refer to responses 1-13, 2-6, 2-10 and 2-11.
District Manager
Bureau o£ Land Management
HC-7412533 Hwy 20 West
Hines, OR 9773G
Dear District Manager:
Subject: Three Rivers Resource
Statement
Management Pla
I received a Desert Alert le t
Association who expressed sorn
o£ Alternative C as your mana
BE Eruni ti!.> Gregun Nate
major concerns about }
ement plan .
& Env i connie nt a 1 Impact
r 1 .1 Desert
r ecommendat ion
I've bow hunted a lot of areas in Eastern Oregon and found extreme
overgrazing. Springs de-watered, willows stripped to nothing, and grass
if any so short sheep couldn't eat, let alone deer or elk. The deer
kill last year at Lookout Mnt. in Baker Co. I feel is partly cause hy
overgrazing the year before. I saw the de-watered springs, the grass
eaten down to nothing, and had to watch out for cattle grazing and this
was in September. I'm writing this letter because I'm tired of see poor
range land allocation for the wildlife who needs a good range to
survive. These are our Public Lands not just cheap lease land for
cattle grazi ng.
It is time to take care of what we have. Provide better range land by
reducing grazing, and force improvements around springs and streams. By
fencing areas around streams, springe, etc. the riparian zone will come
back so will the water quality and aquatic habitat.
It is time that you start taking second looks at your management
practices. Our resources are diminishing so stronger management of our
Public Lands must be foil a wed for "
just not a cattlesho
Sjnwr.ly,
Leta Gay Snyder
aker County BLM District Office
Appendix 11-105
rr>,io. 30, mo
"T^isX/uSr (T)cv--o^-^-t
102
Cwa. ^_>-r^J^JUL'vvJN v_
JXx.'^Cb "l^o
^T\>^_
evs
-VtA_ AU«~ m^yOJvjLvv^ W^-V ox _ vi^°—
:| .sU^SL U_ -JLsAAaiP :
Vx^oSi^ cri~tt-«_
. \5a^X_. i^ocXii^^_
n n -4- ' C\ — t —
102-1
Refer
to
response 1-13.
102-2
Refer
to
responses 12-1
and 12-7
102-3
Refer
to
response 1-11.
102-4
Refer
to
response 2-6.
102-5
Refer
to
response 2-78.
102-6
Refer
to
response 3-6.
102-7
Refer
to
response 12-1.
102-8
Refer
to
responses 2-10
and 2-11
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Appendix 11-106
Range
ecology
103
PO Box 566
La Grande, OR 97850
31 January 1990
Di str i ct Manager
Burns District Office
HO 74-12533
Highway 20W
Hines, OR 97738
Dear Manager:
The dra-ft Three Rivers RMP and EIB have been carefully
reviewed. We present the -fallowing comments -for the record:
The two volumes provide much necessary information and some
important considerations are presented. However, the work as a
whole reveals a most unfortunate bias on the part of BLM leaders
who seem intent on discounting the concept of good stewardship
and true multiple use in favor of grazing special interests.
While multiple use is mentioned occasionally throughout the
RMP, actually it is almost totally ignored as a program to be
implemented. Consider that, by using your figures on II and III,
96. BSE of the public land in your area is devoted to grazing.
Simultaneously you point out that only 34.5% of our land is in
"good" condition. Out o-f a total of 126-55 miles of streams, you
find none (zero) mi les in either "good" or "excel lent" condition.
There are no "excellent" quality surface water acres and only 45
of 4491 acres of surface water are in even good condition, ie-»
about 17..
The degradati on of 1 and, water qual i ty and vegetation have
come about largely as a result of grazing cattle. This you well
know. In spite of thi s knowl edge, you ignore positive alterna-
tives and propose to continue and to expand on the same discred-
ited approach of past years of mismanagement.
Your Alternative C preference illustrates how bound you are
to ignoring the national public interest. The plan chosen sug-
gests that taxpayers pay to install fences and pipelines and to
develop springs, convert land to a monoculture of crested wheat,
and further disrupt or eliminate habitat for numerous species of
plants, animal s and insects.
The mandate of the BLM is given on p 1-3 as "to fulfill the
requirement of the FLPMA. " On p 1-5 "Planning Criteria" listed
include (3) "Give priority to the designation of areas of criti-
cal environmental concern. " On p 4-44 you propose under Alterna-
tive C to have slightly less ACEC acreage. This is not a way to
"give priority." FLPMA criteria also include on page 1-5 that
SLM (51 "Consider present and potential uses of the publ ic
lands." Again on p 2—3 under Ecological Systems it states (3)
"Protect, restore and enhance water quality" etc. is a "must
all costs for each al ter native so it is clear what speci fie
expense the publ ic is facing for management and for proposed
projects, as well as income from sale of permits, uses and sales
of resources? Providing clear cost/benefit ratios would enable
both BLM administrators and concerned citizens to make informed
judicious decisions.
We are requesting at least Alternative A, as well a=
elopment of forward-thinking public land stewardship.
the
BLM Reg. Dir.
Gov. Goldschmidt
Rep. DeFazio
Senator Pack wood
ONDA
Sierra Club
Yours very truly.
-^<2
John E. Bar
Conservation Ch.
Range Ecology Group
incorporate" into the Preferred Alternative. The selected alter-
native merely repeats the past and ignores the growing need for
recreation, wildlife habitat, clean water , changing job oppor-
tunities and demographics.
Your proposal to increase cattle grazing would also require
financing and constructing fencing on almost al 1 ripari an zones.
A great public expense for a special interest group is not justi-
fied here. Neither is it in the public interest that you favor a
small segment of the public as proposed under Socioeconomic
Systems (p 2-3). A socialistic paternalistic subsidy to "Provide
for the continued opportunities for ranching operations typical
Df the American western heritage" (!) is outrageous subservience
to a myth. Since when are public lands and resources assigned to
sustain a lifestyle? Perhaps we should bring back the buggy-whip
maker and butter — churn craftsman with public land resources under
BLM guidance.
The table 3.5 (p. 3-12) is difficult to read because the
Estimated Volume (MMBF) apparently are given to three decimal
places. Since these are estimates, why write 2.000 (indicating 2
million BF, I assume)?
On the 1 i mi ted acres of for est 1 and (13,307) there is exces-
sive emphasis on removing trees. On such a small area you could
have perhaps chosen to emphasize multiple use of recreation,
wildlife habitat, water retention, visual amenity, oxygen produc-
tion, shade 'protection and many other multiple uses. It is
unfortunate that again you abandon multiple use for a meager
commodity production. Alarming is the complete lack of protec-
tion for ancient forest and anci ent junipers.
Please note that Volume I -Text and Volume
Esic3 are more than half devoted to cattle, whi
belief that multiple use is a practice consciou
BLM. Less than half of the RMP is concerned wi
values on our public lands — water, air, vegetat
sects, wi Id animal s of many species, recreati on
and campgrounds, oxygen product! on, open space,
beauty, scienti f ic investi gati ons, sol i tude, et
extremely narrow in its focus and does not repr
land stewardship.
II-
App
endici
es
ch
rea
Ffirms dl
alv
avoided
by
the
th
the
numerous
ion
t b
irds.
in-
i h
iki
ng, cs
mpi
nq
wj
Ida
rness.
c .
Th
9 RMP
is
esent
professional
103-4
103-5
103-6
103-7
103-8
Refer to response 1-13.
Writing volumes in this format (3 decimal places) Is the normal
practice in timber management activity. The three decimal places
allow for accounting to the nearest thousand board feet, which is the
rounded amount used in inventories, cruising, contracts and the
recording of data. The three decimal places allow for the elimination
of needing to use three more zeros in our number systems.
Of the total 1,709,918 acres within the planning area only 13,307 Is
classified as forestland (less than 1 percent). Of this, only 8,263
acres are classified as commercial forestland remaining within the
timber base (less than 1/2 percent). While forest management
activities on these 8,263 acres allow for multiple resource
protection and enhancement, there still remains 1,701,655 acres
(greater than 99.5 percent) within the planning area dedicated to
other resource values.
Forest management includes not only the removal of trees but emphasis
on the growth and improvement of the existing forest stands, for the
benefit of all resources including wildlife, recreation, fisheries,
visual, etc.
In regard to the ancient forest concern, please refer to response
12-1.
Refer to response 1-11.
Refer to response 12-1.
Refer to responses 2-44 and 13-7.
Refer to response 1-13.
Refer to response 12-7.
We urge you to implement Alternative A as a minimum to be
supplemented by plans to:
> avoid all crested wheat grass plantations;,
103-51 '" Pr°tect al 1 old growth trees including junipers in sub-
-I stantial stands,
103-6J > bring all water quality to the "excellent" category,
103-71 > apply professional stewardship to rangelands in order to
J bring them to a natural and excellent classification.
J-Uj Imperative is the public's need to know precisely the finan-
I trial aapects of each proposed Alternative. Why do you not list
Appendix 11-107
?8, 1990
Jay Crrl.'-on
Burns District Office
Bureau of t*n<i Y.t>ni>mn
HO 7^ 12533 Hi.-h ■;.- 20 ■
Hiner,, Ox. 977?8
104
3'EVXEW Cr'-'TITTE FCH Tr.Z OCTCBUR I9S9
3LK DRAFT TRP.EE BJV5SS 3l;i'/EIS
Refer to response 2-63.
D«;
■ Mr. CprUon
Alternatives A, ~ and C till result in (l substantial lo#9 of our ttae
property vrlue. The proposed BLH rctions may result ir. reducinp the size
of our operation so tfct-t it is no lcnrer en econon:iccl unit. Therefore
we request th.-.t if Alternatives A, B or C sr* considered, thet prior to
issuinp the Final Three Hirers Kescource MaiiP*ensnt Plen end Snvironrr>ont: 1
Impact Statement, s "Tykinre Implication Ar.pes^mer.t" be completed 00
ruthorized "-.y Executive Crder lPf^O (see the ^nvemtier P, 19$? !>rrr.' rrinr
tn ■ ] l j /r;*tp-t* r.i Sp-cr*t?rf er ■ nr" 'urf u Eii-frfitor* frf- 8i*es"f-V<r;r f'
Interior, Donald F Kodell).
The letters from the Hsrney County CellleVi'oren, Stockf-ro-.;cr3,
Sheer s r.d iveelfrr ewers r«d the January 17, 19?0 Middle Bench >n
S;-rr;e Service Cocr.ents f nd Eeepanae to the Drr f t Three Kivere
Ksnrasent Pier, nd hrvironn pr.ttl Iirp.-et St^terer.t ere consist'
views ."nd eofunaftts.
i»rw Bur
Wptar
This response is cur endorsement of snch
document. Their response has heen submitted to
full copy of text only for the renron that it
of the i.ico'le xi ne* Socun«r.t 1 rz orfsis^tifrpu
nd t'-e Middle Ri-ne
do not include v
p-n exect du^licr-ti
S«7j»n 1 >livf.ry
Dir-rrnr-, (r. 977
Appendix 11-108
1(0)1
Jay Carlson
iuras District Offiee
bureau of Land Manawmnt
H.C. 74 12533 Highway SO wapt
Hines, CH 97736
Dear Mr. Carlson:
As permittees on the Lone Pine Allotment of the B.L.M. and
owners of private land adjacent to &. L.I.I. lands, we would be sig-
nificantly impacted by all of the alternatives submitted in the
3.L.M. Draft Three Rivers HEP/EIS ,
alternatives A, 3, and C would result in a substantial loss
Oi our sase property value. The proposed u.L.]~. action may re-
sult in reducing the size of our operation so that it is' no longer
an economical unit. Therefore, we request that if Alternatives'
ft, B, or C are considered, that prior to issuing the tfloal Iftrse
divers --iosouree Management Plan and Environmental Impact State-
ment, a Takings Implication Assessment" be completed as authorized
by executive Order 12630.
The rsalloc&tiOD and/or reduction of 107 AUM'S livestock for-
age to the Lone Pine Allotment would reduce the value of our base
property by a substantial amount; further, any proposed reduction
on the whiting allotment would increase this reduction of value
Please consider this economic loss in the requested "Takings
Implication Assessment."
Table 1 of Appendix 6 and Table 2 of Appendix 5 of the Draft
i-lan show part of Poison Creek aB being in the Lone Pine Allotment
and the creek to be in poor, declining condition due to heavy live-
stock use. We point out that the rirarock forms a natural barrier
for cattle between Lone Pine Allotment and Poison Creek. ACT
effeots on Poison Creek from livestock use are due to livestock
Other than those ranging on the Lone Pine Allotment.
a© are concerned about the possibility of even further re-
ductions on the Lone Pine Allotment due to the presence of sage-
grouse. ihere is no scientific osta Indicating that livestock
use has a negative effect on the sasesrouee population. Closing
the hunting season on these birds would be far more beneficial
to their population.
V/e also point out that Landing Creek is not a perennial stream
going dry in the summer. It is therefore not affected by permanent'
water and cannot be classified as a rinarian zone.
appendix 3, Table 7 calls for Juniuer control and burning
and the building of additional reservoirs on the Lone Pine Allot-
ment, tie agree with these Improvements, plus the need for sage-
brush control. Juniper invasion Is a serious problem, and its
control should be practiced on all allotments to the'point of
including the issuing of free post and Juniper firewood permits.
-alternatives A, 3, and C have an arrogant disresnrd ^or nri-
vate land ownership in their zoning proposals. There are lar^e
105-1 Refer to response 2-63.
105-2 Refer to responses 2-11 and 2-63.
105-3 Refer to response 2-12.
105-4 Refer to response 4-6.
105-5 Refer to response 42-14.
105-6 The issuance of free use firewood and post permits is permissible
when such disposal will benefit public land management (BLM Manual
5500. 02A). If juniper clearing areas are for the benefit of our land.
management and In the public Interest, free use of these clearing
areas Is permissible. Also, refer to response 6-8.
105-7 Refer to responses 4-14, 6-10 and 94-5.
105-8 Refer to response 4-16.
portions of Silkies Valley and ?oison Creek that are privately
owned, and are proposed by the S.L.M. for iione 1 classification
(acquire or exoanpe for). These lands are vital to the operations
of the private land owners r>.a& should not be zoned for possible
acquisition. The U.S. Government already owns enough of Harney
County's wetlands in the form of Malheur Wildlife Refuge. We would
not want to see Siivies Valley taken over by noxious weeds suah
as is seen at Malheur Refuge.
le do however, support the sale of, or exahange of small, iso-
lated^. L.H. tracts.
we adamantly oppose the acquisition of publio access up Siivies
River, Poison Craek, and the old Oregon northwestern Railroad
right-of-way.
The January 19, 1990, letter from the Karnev County ^toek-
prowers, and the Januarv 17, 1990, Middle Ranch and western Range
-ervice Comments and fleeponse to -;ou are consistent with our views
and eommen ts. iVq endorse these letters and r;ish their content?
to be part of our response.
One of the B.L.I-i. 'a stated objectives for the Preferred Alter-
native, is to "provide for continued opportunities for ranehing
Operations typical of the American Western heritage." We believe
that the Preferred Alternative instead , goes far towards stifling
these opportunities.
Yours truly,
105-9 Refer to response 6—
Hilton Whiting
Eva Whiting
Ronald Whiting
?.S. If juniper Invn^ion is allowed to continue without extensive
control, all the livestock could be removed from the range and its
condition would still decline, simply from the Juniper problem.
This trend would continue to the progressive detriment of wildlife.
Therefore, reducing livestock numbers is not the simple solution
to the range condition problem.
Appendix 11-109
EUGENE (GENE) D. TIMMS
HARNEY. LAKE. MALHEUR. GRANT, BAKER
CROOK. MORHOW COUNTIES
DISTRICT 30
OREGON STATE SENATE
SALEM, OREGON
97310-1347
106
Refer to response 2-11.
January 31, 1990
Mr. Jay Carson
Burns District Office
Bureau of Land Management
HC 74 12433 Highway 20 West
HinaB, OR 97738
Dear Mr. Carson:
I recently attended a field tour at the Starkey Field Station near
La Grande, Oregon. There I saw where government was beginning to collect
factual information in regard to cattle grazing on our public lands.
106-1 | I feel that each cattle operation is unique and areas are different.
1 Therefore, they should be studied before any across the board cuts in
AUM'fi are made.
I have noticed with interest the increase in wildlife on private
lands in my district. It is ironic that ranchers are feeding greater
numbers of wildlife on private lands and having their cattle numbers
lowered on public land.
The letters from the Harney County CattleWomen, 5tockgrouers , Farm Bureau,
Sheep (. Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with my
views and comments.
These arc reasons 1 am opposed to any cuts in AUM's ■
ely yours.
ad ba
Eugene "Gene"
State Senator
District 30
107
I'
a* /??a
107-1 Refer Co respoQBe 2-2 and 2-63.
107-1
^> j^XJtAjJ^t
Appendix 11-110
January S, 1990
P0 Box 873
Nines, OR 97738
; Resource Area Mgr.
Three Ri-
Burns Di-
Bureau of L^nd Management
HC 74-12S33 Highway 20 west
Hines. OR 97738
-ponse to your draft jfe^, Rlvers Reaoucce ManageiDen[:
108-1 The management direction for burros has been reevaluated. It has been
determined that a small number of burros can be effectively managed
In the Warm Springs HMA. The management actions under the Wild Horse
and Burro objectives have been changed to reflect the fact that in
Oregon, burros are unique to the Burns District. Also, refer to
response 2-6.
108-2 Refer to response to 108-1.
D8-1 J J would ask that y.
'«n in Table 2.1
aces that burros
| and that burros not
It would
herd needs
to whether
reader your WM|!ttmc direction for vild burros as
n"rh u 8eTC- iCCCti°n *5 "**•* Wild H««« and Burros
be reinr?", ^TK T ** """^ f°r ">**»» <* ™ £2
be reintroduced should they die out fro, natural cau.es
ippea:
unc:
chii
that the intent is to
I such time as the exis
is in keeping with the
■llmXmca the burros by ignoring burro
:mg population dies out. 1 question a
intent of the Wild Horse Act
prospectors ,„d e.rly settlers ild "it* ' * th" Ir°° "ounc.in burros.
..tele..,,. , thi„t you .„„„ . oh,„„ of ^ g*— .»•._££
BLM i« secivcly luruglng Che horse herds to prevent severe <„hv a-
•U. - -re „ot «, *JZ2i l^Z£jZr£l££">« •*-
The BLM adoption progroi
horses- especially in eh.
people have « history of
higher.
I am concerned that while
•f it. resource. 1„ order
stand to lose one of thosi
rhsc burro, ere .ore e.stly edopted then .re
"her. burros ,„d „ul„ ,« „„« ,.,,_,„„
them, f.rnl.nd i. « , prc-lvani ,„„ tnf
Harney County
to attract tou
unique featur-
crying to
emphasize the uniquen
ersify che economy, w.
The burro herd *c Iron Mountain is the only one in lutoni or„„
as I know, the only herd in che entire .tare Yes toll T ' ""? 1 '
California, New Mexico, Arizona, and Wyo^ng" Sere arew id h '" V*0'
location also. That does not dissua^ BUi^a S^.lr^^/Lt,"
The burro herd can be consiriir^ „ \*A***m
horses. Could It be ch.t there ... be =<»."L,«? .t "„; ,;,"*" t
e=1o„ M to your r.cior.,1. ror „.c eerily ^V«S. bi™."£,.
Thank you for =he
Janes M. Keniston
opportunity to comment
^ ^~ter-
Appendix 11-111
109
109-3
109-4
109-5
109-6
109-7
The Evergreen State College
Olympia, Washington 98505
January 31, 1990
Joshua Warburton, District Manager
Bureau of Land Management
Burns District Office
HC 74-12533
Highway 20 West
Hines, Oregon 97738
Dear Mr. Warburton,
I have reviewed much of the Draft Three Rivers Resoyi.r.c.e
Management Plan & Environmental Impact Statement and offer the
tol lowing comments :
1. In general, I am appalled that you have chosen to continue
your policy of resource destruction. In an era when the BLM is
being lauded for progressive efforts to rectify mistakes that
have been made for decades, the Burns District seems bent on
business as usual. Certainly there are some positive components
included in the preferred alternative, but they are weak overall
and fall far short of the kind of restorative actions that are
mandated by the condition of the resource.
2. You must develop and alternative that will aim at the
restoration of the landscape to excel lent condition. You owe
that to all Americans who own the land you manage.
3. Water Quality, riparian, and aquatic habitat must be improved
to or maintained in excellent condition.
4 . The "Natural Values" alternative is very weak, but certainly
it is the only acceptable one of the several you propose . It is
the only one that would allow any significant recovery to occur.
J 5. You must protect all ancient forest, whether that be
commercial conifers , juniper, or sagebrush .
16. Your cost/benefit analyses must include al 1 costs of range
improvements .
17 . It is impossible to believe that you are still promoting
Crested Wheatgrass ; please eliminate all such proposals .
18. Forage allocations f
Bighorn Sheep) must be g
1 ivestock.
or all kinds of wildlife (and especially
given priority over forage al locations for
9. Please designate all of the South Fork and Middle Fork of the
Malheur River (i.e., those portions over which the BLM has
109-1 Refer to response 1-13.
109-2 Refer Co responses 2-44 and 13-7.
109-3 Refer to response 12-1.
L09-4 Refer to response 12-7.
109-5 Refer to response 1-11-
109-6 Refer to response 2-6.
109-7 Refer to response 3-6.
control, and not the reach through the Drewsey area), all of
Bluebucket Creek , and all of the Silvies River, as Wild and
Scenic Rivers.
As a person who has taught and done research on Burns District
lands for more than two decades, as a neighboring landowner, and
as a member of the Board of Directors of the Great Basin Society
and the Malheur Field Station Consortium, I have a very strong
interest in encouraging the improvement of the condition of the
lands over which you have stewardship. Please keep me fully
informed as your plan progresses and please respond specifically
to my comments.
Thank you very much.
Sincerely,
Steven G. Herman, Ph.D.
Member of the Faculty (Biology)
Appendix 11-112
HI 4 ^\
Wjrm Sp('«js. 0»?5Q/i 97767 503 553 M6>
January 22, 1990
No comment Identified.
Craig M. Hansen, Area Manager
United States Department of the Interior
Burns District Office
HC 14-12533 Hwy 20 West
Hines, Oregon 97738
Dear Mr. Hansen:
This Letter is being written in response to the invitation of the
Bureau of Land Management to participate in evaluating the draft
of the Three Rivers Resource Management Plan. The sections of
the plan concerning the cultural plants and cultural resources
were reviewed in the Cultural Resources office at Warm Springs.
This office, as well as the Culture and Heritage Department, and
the Culture and Heritage Committee, were set up on the Worm
Springs Reservation to preserve the cultural heritage and tra-
ditions, and to manage the cultural plants and cultural sites.
The traditional foods are very important to the people here.
They are a part of their livelihood, and are necessary part of
meals at all of the traditional ceremonies that take place
throughout the year.
The proposal to set aside areas under BLM jurisdiction to be
managed for traditional usage, such as root digging, is one that
we would strongly support. The proposed Biscuitroot ACEC is
primarily used by Burns Pai ute people as part of their customary
gathering areas. It is outside of the Warm Springs ceded area,
but there are enrolled members of Paiute descent at Warm Springs.
The three enrolled tribes are the Wasco, Warm Springs, and Paiute
tribes . There are a number of Paiute tribal members , as well as
people from other tribes, who do come down in the spring to dig
roots in the Burns area on BLM lands- Members from Burns also
come up to Warm Springs to trade their roots with people here.
This exchange is a long established custom. It contributes to
the economic support, as well as continuing traditional practices,
and strenghtening f ami ly ties .
We would encourage the adoption of one of the management alter-
natives that favors the consideration of traditional uses and the
protection of culturally important plants . We would also support
the proposal to retain in federal ownership the root areas that
the BLM currently manages with the maintainance of access to
these lands for traditional usage.
Wwm Sprr'pg;, O'vgan 97761 / 503 553-MfiJ
Mr. Hansen
January 22, 1990
Page 2
The ethnobotanist who worked in the Cultural Resources office
pointed out that increasing reliance on a smaller number of root
digging areas was adversely affecting the root production. His
recommendation' was to alert federal agencies about the root areas
under their jurisdiction and to discourage trading away the re-
maining root areas to private developers.
In 1988 a Cultural Plant Conference was held on the Warm Springs
Reservation to educate personnel working in the federal agencies
in central Oregon about the cultural plants, their uses, and
management. Studies have been done on five of the main roots
used today by people at Warm Springs. A report on these studies
includes management recommendations for these culturally used
plants. We would be glad to share this and any other information
we have that might be helpful.
In the last few years a cooperation has been built up between
the cultural programs at Warm Springs and Cultural Resource
personnel at the Burns District Office. This cooperation has
been very valuable. In closing, please accept out gratitude for
your sensitivity and responsiveness to our Tribe's wishes to
protect and preserve its interests and opportunities in part of
our ancestral lands . We look forward to s trengthening the re-
lationship already established as this plan and its proposals are
being advanced.
Marcia Kimball, Tribal Archaeologist
Cultural Resources
Enclosure:
(2)
Appendix 11-113
111
OREGON HUNTER'S ASSOCIATION
P.O. Box 66I8 • Bend, Oregon 97708 • (503) 382-4058
January 31, 1990
Mr. Joshua L. Warburton
District Manager
Burns Distr Let
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, OR 97738
RE: DRAFT THREE RIVERS RESOURCE MANAGEMENT PLAN
111-1 Refer to response 2-10.
111-2 Refer to response 1-11.
111-3 Seasonal grazing restrictions through various grazing treatments are
a technique the Bureau uses to improve the range and to minimize
conflicts. See Appendix 3, p. 3-8, DRKP/DEIS, for a discussion of
grazing treatments.
111-4 The larger figures of unsatisfactory condition are the current
conditions and the smaller figures are predicted big game habitat
conditions 10 years after full implementation of the plan.
111-5 Refer to response 2-78.
111-6 Refer to response 1-23.
Dear Mr. Warburton:
The Oregon Hunter ' s Association (OHA) would like to
provide comments to the above-referenced draft plan. OHA is
a statewide organization of nearly 3000 members concerned
with management of wildlife habitat. Briefly, our concerns
center on management direction for winter and summer range
for deer, elk, and antelope.
One of our chief conce
placed on livestock grazing
wildlife habitat . The anim
to livestock in the Pref err
nearly the maximum possible
2.1, While this number
it is nearly three times
values alternative, and all
wildlife (7759). Only 10%
antelope, and 18% of the re
allocated AUMs . The balanc
species are assumed to be a
We question this assumption
the allotments allocate not
Table 4). Furthermore, ne
planted with crested wheat
only livestock. Deer winte
the area proposed to be see
believe that any seedings
perennial rye, fescue, or
by wildlife as well as li
rns regards the great empha
the plan, at the expens
al unit months (aums) alloc
ed Alternative (139,851) ar
(164,622), according to Ta
ortedly does not meet the d
level proposed in the nat
ocates only 5% of the aums
of the required AUMs for
quired AUMS for deer are
e of the forage required by
ccomodated by unallocated f
addition, about one-
hing to wildlife (Appendix
rly 50,000 acres are to be
rass, a species that benefi
je occurs on about 20%
ded with crested wheatgrass
hould be native bunchgrasse
ther species that can be ut
stock. We also support se
ble
emand ,
ural
these
orage .
alf of
3,
ts
ilized
asonal
grazing restrictions to hasten range improvement and
minimize conflicts with wildlife usage.
xnese numoers ao not appear to oe cunKisceriE , emu we am
inclined to believe the former . Similar numbers are
presented for elk ranges. We believe a much more aggressive
range-rehabilitation program must be established.
Bighorn sheep habitat is identified on maps in the
pllan, yet there is little if any discussion of management
direction for bighorn sheep habitat. Bighorns are an
important wildlife component of the Three Rivers area, and a
thorough discussion of their management should be included.
There is proposed to be maximum development of off-road
vehicle use in the plan. We are concerned with potential
conflicts with wildlife and habitat degradation caused by
ORV use. A coherent plan for managing and restricting ORV
use is essential for responsible management of the other
values in the rmp area.
Please give our concerns serious consideration. We
w.ould be happy to meet with personnel from your district to
work on these issues .
Sincerely,
Kelly L. Smith
State President
Appendix 11-114
Jay Carlson - PMP/riS
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines. Oregon 977-58
Pcila Ranch, Inc.
Box 806
Bums, Oregon 97720
112
REVIEW COyjJfEKT? FOR THE OCTOBER 1Q3
BLM PRAFT TIT-IE RIVERS RHP/EIS
112-3
-1-
satlsfartory ai*bit»1 for deer and antelope in late spring, Strmwar and fail.
The atlt«Iop« group UF in large herds in the fall and early win-tat to feed on
the meadows and our bunched hay. Even with the increased hunting pressure o
our allotment, the game has increased dramatically. Therefore, we strongly
■agree that wild life should be given priority over livestock forage.
di
As stated, all the alternatives will have adverse impa
production, the economy of Harney County and the conce
which is the BLH's criteria by law. Alternative "D" i
close to having no adverse impact.
up
n livestock
ultiple use
nly one to c
rla
& complete "Taking Implicatio
by Executive Order 12630 befo
AUM's Is implemented.
Ass
;ament" should be completed as authorized
alternative causing reduction in livestoc
i'cila Ranch Inc. wants on record that our response and eomiEJitts to
of the Three Rivers Resource Mamg*m»nt flan and Environmental Imp':
Statement aro consistent and i.ncorporatr with those of F-iddle Ranch
Western Ranee Service and the Harney County Stockgrowers.
:tlv
n: to our .allotment o
r_j£ere«ee of 8231 AUM's
0ta1 of 8759 AUM's but BLM
.ted the average actuil use
We have additional comments and conce'
East Wagontire No. 7003. We have an
plus 515 AUM's, exchange of use with .
estimated capacity is 7730 AUM's and stated the average actuil use of
6 707 AUM's.
We purchifcd the original tfAttfih In 19^9, then U*se«J and purchased the
balance of it in 1976, giving reila Ranch all of East Wagontire allotment.
Each year since 1959 the total active preference in East Wagontire was used
yn/5i£_
.ered 400 wild hoes
off Wagontire (abo
and in 1983
£5 head) , a:
In 1968 we
of wild ho
of horses.
The »lU:numt his
thousands of aerofc of ure»t«<1 wheal J*'*'--
char the cri*ste^ wh«»f graBE seedings, wen
ha *-*•**« ttv 1IM vid ?pil' IMneli, with laho:
'■ wV
he BLM gathered the balance
this allotment was to he fre
nasov* vac
\ ith mope
112-2
Con? s^uently , the condition of the ra
improved, as well as, Ch» riiatrihutio
seedings and r'jmovin.s the hordes off
e over the
Of livesto
the ^llot
This 'all of 1989, thru a cooperative agreement with E!H, Peila Ranch paid
: $7925 to drill a water well in a much needed a^ea for livestock distribution
j and also for wild life, especially antelope. Therefore, it la erroneous and
factually unfounded for the Resource Management Pi in to state that there isn't
| enough feed on East Wagontire for th:- active preference.
Appendix 3-116, the "Identified Resource Conflicts Concerns" states limiting
big game habitat in unsatisfactory habitat condition. Paila Ranch owns 997=
of the live water plus Wagontire and Little Juniper mountains and the wild
irrigate f 1 om tha -ceded springs and tree'-r, ere.:'tlri2 » very
112-1 Refer to response 2-11.
112-2 Refer to response 2-6.
112-3 Refer to response 2-63.
January 17, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hi nee, OR 97738
113
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
113-1 Refer to response 2-63.
Dear Mr. Carlsont
include tbjf next' ivo
(If you are facing a reduction in AUM'g, pleas
paragraphs. If not, cross out second paragraph. )
Alternatives A, B end C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
we request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan end Environmental
Impact Statement, a "Takings Implication Assessment" be completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Model).
The reallocation and/or reduction of / 0 g 9 AUM's livestock forage
in £oaJ- [tJtui^£<*r -,i n .J o q $ Allotment will reduce the value of our base
property by approximately S.£jf £g)g ~ (Assume S50 per AUM value).
Please consider this economic loss in the requested "Takings Implication
Assessment. *
The letters from the Harney County Catx.leWomen, Stockgrowers, Farm Bureau,
Sheep £ Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we may have are enclosed herein and are
supplemental to our principal response.
$£$% ~hi $2Lk&
JVame "
/**■
fiey'^'o^:. V ■ ■ ' .
f'7iO
. State
*&~\ V (Z&J& -
Signature
Enclosure: Supplemental Com
Appendix 11-115
?eh. 6, 1990
114
Jay Carlson
"Burns Dist. Office
Bureau of Land Management
HC 74 Highway 20 West
Hines, Or. 97738
Dear Mr. Carlson,
In reference to Oct. 1989 BLM Draft Three Rivers RMP7EIS:
Alternatives A,D, and G will result in a substantial Iobs of
my base property value. The proposed BLM actions may result
in reducing the BiiBe of my operation so that it is no longer
an economical unit. Therefore I request that if Alternatives
A, B, and C are considered, that prior to issuing the Pinal Three
Rivers Resource Management Plan and Enviromental Impact State-
ment, a "Takings Implication Assessment" be completed as
authorized by "Executive Order 12630 (see Nov. 8, 1988 Memo-
randum to all Assisstant Secretaries and Bureau Directors from
Secretary of Interior, Donald P. Hodel.)
The letters from the Harney County Cattlewomen, Stockgrowers,
Farm Bureau, Sheep and Woolgrowers and the Jan.17f 1990
Riddle Ranch and Western Range Service Comments and Response
to Draft Three Rivers Resource Management Plan and EIS axe
consistant with my views and comments.
furthermore I feel that ~0% reduction of AUMs in my allot-
ment is unfounded and unfair. In 1988and 1989 due to draught
and other conditions T took a voluntary non-use in the Upton
Mt. Allottment. Prior to this time I observed a large number of
tresspass cattle in this allottment. BLM was informed of this,
but there was never any action taken. I feel that because of the
draught conditions and the tresspass cattle, that when the
monitoring was done the allottment was in poor condition, (thus
my reasons for voluntary non-use.).
At this time, in my opinion that allottment is in as good a
condition as it has been in my life time and I have lived on
this family operated ranch for 46 years.
After the draught in 1977 BLM planned to remove the brush
and seed in my allottment. I took my cattle to the Princeton
seeding for two grazing seasons at my expense. The seeding
in my allottment never materalized. My dollar loss over those
two years was approximately $100,000. Another ("there was an
earlier reduction due to BLM EIS) reduction at this time is
totally unwarranted.
Sincerely
Richard Kdrounson
Orewsey, OR.
cc: Congressman R.F. Smith
114-1 Refer to response 2-63.
114-2 Refer to response 2-11.
114-3 Refer to response 8-7.
6\KREfiu of~ Las J YnBrtBQEYnBui:
J/iNEs, OK 177*2
FA
RUHR)
115
tmo
J2T hopE V6U hnvE hkoualnk i/iE Thuet KivERs
flfi/U hhRouah, ;£AoRouoh!y.
4)o you YtJOiu He itnpo&hfilvcz of I AN J owKERs f
X" Joes op/ly aooj ho ENCsuRAQe /fjfj •&££>
I AN A pkivtiE oumnskip. We will less. our.
fkBEdem A/uJ sjzREn/aik within) OUR. NATfoN
if we losz kke pRiv/the /an J owner. ■ Tfis
Jnysh'a of Me tOesi is AN Awful hi a toy
..\)zo piny with, WMEiu it wioKi yy,ean '
faydoRSUUO £hE ttuw-IEK ~vf~ yoUR. C-hi Id KEN.
A~ANd ZESlkss US ho AsVElOB OUR. HrvNdS;
our. HaciAs. Am A our toiwiky anA fs hliE Souse
of p£/)Ji£y , fooJ can onIv wiftfce i£
ihtiouah Ian J ho us.
JZT ftcifiEE hheRE is ft Iou.se £.0 hlxE J/tniJ
buf hkih is wheUE you can Lb rnosh helpful
AiREdiitooy s£it>v.lf>-f-ii»Q anA £meJu'WQ wiik
tommoM sense EXpEfi4'EAice<J wihh hj\£
../an J, with UmAS, &nA ujiik Ho/vEsty 4- i/luihl
TKeRE is Room faR. US A I 1 1 wko Will WE listsM
to ho h>E £&* &-REa£ hEAchER I
No J^A/n Noi tor ike IKree {{{vers P/aai-
' J =5 "
B
fuEEdom An/ J sjzREn/aik wiihin) our. NR~ti
if we Use hhs pRiVAZE /an J owner.. ~7h
Jmysi-ia of hke Aksr is AN fiwfid bia hoy
h-o olny luitl^ wIieiu it mioki r^eAN '
foynoRS&u) ±JiE HunXfEK -'of yoUK <M\dKEN.
..J-AnJ ZEfi&hES US ho oleVElop OUR. WM'Ndaj
CHft. HanJsj UK J OUR (.OMiXRy AN J is hliE Idase
of REfili-ty , foe, J can onIv mfifce ii
■klnn.ou.ah Ian A ho us.
JZT ftqfiEE hkeA.E is Rbu.SE ho h/iE J/Hi)J
louh hk/nb is WHERE y CIA CAN 1>E Tnosi. helpful
JiREchiNO-y siipulAfiNO AJvJ ieAchirua WliU
lOVnmoH SENSE EXOEK-t'ENtEd uihh hhE
Jan J, wiLh iAeas., mnJ wilk Hon/Esij 4- £/ttrfki
~T^ERE is Room feR. us All. Who Will WE lis/rsN
ho/ ho bE hkiE GrKEAi hs-AckiEK. C
Mo Jfnm Noh Tor. fhe IHree {{ivERs PIan.
*■.'■ b£
;:C'",Hua
TlmN-k.'
ou,
No comment identified.
Appendix 11-116
116
February 9, l»9-0
Theresa I'eila
Box 806
Burns, OP. 97720
Jay Carlson - RMP/EIS
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 97738
The grazing fee is published annually in the Federal Register.
Permittees do contribute to a variety of construction projects such
as wells, fences, reservoirs and springs. Permittees are responsible
for paying for electricity on wells. Contributions of money, time or
materials for project construction also come from ODFW, USDA.-FS,
l2aak Walton League, among others.
Refer to response 116-1.
REVIEW COMMENTS F02 THE OCTOBER 1999
3LM DRAFT TT-^E RIVERS RH?/"IS
Hr.
rls.
of
■ BLK
Especially,
Being born and raised as a city person, there is an
Three Rivera Resource Management Plan that concern::, i
when you live in a large metropolitan area, there is only I
frora the concrete, and Cor most people it is recreation and/or hunting.
To rh« average urban resident terms like AUM's, QDEQ water quality,
non-use, permittee and active preference are an enigma. Therefore, to
those persons, tho they may be interested in the public lands, whether
they are used or abused, they can only evaluate a situation by what
printed matter is available.
Nowhere, have I seen any publication from the BLH that discloses not onl
that ranchers pay fees for land usage, but of their contributions to wel
! fences and roads.
This year, for a BLM well, our contribution was S7925. Also,
cost of 15 miles of new BLM fence was split by our ranch and
othe-
rh a 76CQ gal weier tanker trnl CD
i not only our cattle but the entire
artainly felt good « eeuld. Te p»U
ater because the BLM said they were
nt. The Fish & Wildlife coo,
In 1577 we hired h man, equipped him w:
radio to fill water holes. We sustsim
her4 of antelope and wild horses, Vc I
the same fees for usage, evrcn withour \
unable to help with any water improvement
responded they couldn't help in any way.
In 19&3, before Che wild horses were gathered off the Wasontire area by BLM,
we found them to be out of water and reactivitated the water tanker to haul
water to them so the horses could survive.
A serious fire year BLM called and asked if we could let them use our cater-
piller and any manual help we could send to a fire. We took a large truck &
"cat" and pulled U men from our hay crew co help fight fire for several days.
Salt is another forgotten donation from rancher to wild life. No salt is
furnished, at least in our area, to wildlife. All the salt put out by
ranchers goes to antelope and deer, coo. I've never heard a rancher comolaln
about this sharing. Many ranches may he situated like ours. We own 931 of
the live water on our entire allotment. We irrigate wild meadows with deeded
springs and creeks. Deer and antelope have feed late spring, summer and fall.
In fall and early winter , the wild life feeds on the hay we have bunched ,
Therefore, it 19 disproportionate to associate only a paid fee with the
ranchers use of his permit. He contributes much more to both BLM and Fish
& Came agencies than he is ever credited. These expensive and extensive
improvements ranchers make are a constant up-grading for the existing wild
life habitat.
There is a constant accusation by some of the public, that BLM has made ,
"bad deal" on grazing. The best defense is making public all the contributions
derived fron r.uch agreement. The media never presents fhat ;
public ne^er realizes that BLM, Indeed, has eiHeavored he* id-
nd the
land with addi
al ra
ill CO
alp.
perhaps, an impact statement on ranch contribution should be made by the BLM
and available thru their office, so people are aware it is not a one-sided
situation and that BLM - Ranch Permittee is in actuality a supervised and
improvement cooperative involving not only fees, but Cash and labor contributions
from the cattlemen.
Sincerely,
Theresa A. Peila
Appendix 11-117
117-1
117-2
117
January 21, 1930
Disfcr i ct Manaq*r
BLM
HC 74-12533
Hities OR 97738
i JAN Z 3 13S0
BURNS DISTRICT 6LM
117-1 Refer to response 12-1.
117-2 Refer to response 3-6.
Dear District Manager:
I believe that all of the alternatives to the draft EIS and
Plan for the management of the Three Rivers area are
unacceptable because they do not restore the natural
resources of the area. At best, Alternative "A" would not
cause further extensive degradation of an already damaged
natural ecosystem. All of the #1 ft *r native* are simply
excellent examples of the "tragedy Of the commons."
Instead of encouraging activities that are only of local
economic significance, the BLM should be protecting the
national dryland heritage given to its stewardship.
Any resource management plan for the district, should at a
minimum, insist that rangeland, water quality, riparian and
other wetlands be restored to excellent condition — not
simply be maintained at the degraded level that currently
exists throughout most of the region. Virgin forests must
be protected — but first identified clearly in the plan; they
seem not to be. Priority to protection of adequate
rangeland for wildlife must be given. Wild and Scenic River
classification would best fit all of the South and Middle
Forks of the Malheur River with the exception of the Drewsey
area. In a similar manner Sluebucket Creek and Silvies
River should be so designated.
TKle fragile area demands restoration not the continued
harmful uses permitted in all of the alternatives. The area
is well on its w«y to even greater desertification than it
has already experienced. If the BLM won't stand up for tsh*
protection of the nation's land, who will?
QJUIj O^jJi
Alvin W. Urqu .
(Prof«M©r of Geography, University Of Oregon)
1G20 Olive Street
Eugene, OR 97401
Senators Hatfield
nd Pa
..>,< 1
Appendix 11-118
Patricia A. Muller Box 287 Alsea, Oregon 97324
Cu ltura 1 Resource
February 5, 1990
District Manager
Bureau of Land Management
HC-7412533 Hwy 20 West
Hines, OR 97738
Hello:
Please accept my comments on the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement,
I would like the Bureau to change its management direction
to focus on wildlife and recreational needs, rather than acting
merely as a grain supplier for cattle, Charges for grazing
allotments should reflect the true cost of maintaining allotments
in excellent condition.
The DEIS states that the overall trend is downward due
primarily to erosion and vandalism. The BLM management trend
should be towards no further sacrificing of these resources,
protecting all remaining sites.
Water Qual ity
In the preferred alternative, livestock would be temporarily
removed from streams with poor water quality until conditions
have improved to fair. There is no excuse for this! Considering
the high number of areas with poor water quality the BLM should
aggressively pursue returning water quality to good/excellent and
then adopting management procedures to maintain water quality at
that level.
I would be glad to assist you whenever you need public
comment on certain areas or biological plans. I will be lobbying
to see that the Bureau gets the financial allocation it needs to
properly fund these programs. Let me know when times like this
arise on your district. Please send a full copy of the Final
Plan when it arrives.
Thank you.
(JcT
Pat Muller
Kongame Animals and Upland Game Birds
Pg 3-34 states that there has been no comprehensive survey
of non-game or upland species conducted in the RA. It would be
impossible to assertively state that the preferred alternative
would either improve or make worse the wildlife situation. From
my own observations in the area, I have found fields that are
planted in crested wheatgrass to not contain the native species
which used to be even more abundant in the RA . All seeding of
crested wheatgrass should stop unti 1 the effect of replacing
native grasses on bird populations is known.
Wetlands containing vegetation of importance to nesting
birds should not be allowed to be grazed until well after the
nesting season is completed. It is remarkable to assess the
difference in quality of nesting habitat where cows cannot reach,
the vegetation there is of sufficient height to provide cover and
protection for nesting species and their young.
No spraying of herbicides should take place for the sake of
range improvement, since the effects of many of these chemicals
are still unknown.
118-1 Refer to response 1-11.
118-2 Specific wetland proposals are covered In the Burns District Wetlands
Habitat Management Plan. Providing nesting cover and brood water are
two of the major components of this plan. Also, see response 7—12.
118-3 Refer to response 11-27.
118-4 Refer to Response 1-23.
118-5 Refer to response 3-6.
118-6 Refer to response 12-1.
118-7 The BLM management orientation Is toward protection of cultural
resources, as well as utilization of these values for public
purposes. There are numerous known cultural sites and innumerable
unknown properties such that the abatement of erosion and vandalism
will intensify at known significant sites.
118-8 Refer to responses 2-44 and 13-7.
No off ro,
nesting habitat
Off Road Vehicle Use
id vehicle use should continue on snowy plover
Wild and Scenic Rivers
The BLM should more aggressively pursue wild and scenic
designation for more rivers to include all of the South Fork and
Middle Fork Malheur Rivers, Bluebucket Creek, and Silvies River.
Timber Harvest
Given the scarcity of timber areas, the BLM should feel no
obi igation to cut them. The DEIS states that the harvest of
these BLM lands wil 1 have little or no effect on the local
economies. Any ancient forest ecosystems should be identified
and studied to see if species utilizing them have sufficient
habitat.
Appendix 11-119
119
February 5, 1990
Jay Carlson - RMP/EIS
Bureau of Land Management
HC 74 12533 Hwy 20 W.
Hines, Oregon 97738
Dear Mr. Carlson,
On behalf of W.J. Hoyt £ Sons Ranches, I must express our concern of
the BIM Draft Three Rivers RMP/EIS. In accordance with the Federal
Land Use Policy Management Act of 1976, Section 202c, items 1.) and 3.)
of the criteria to be used in planning would be:
1.) Use and observe the principles of multiple use and
sustained yield.
3.) Give priority to the designation of areas of critical
environmental concern.
With respect to these planning and management objectives, we feel that
domestic livestock grazing is not being given proper consideration.
In the Preferred Alternative, "Alternative C, under Criteria for the
Composition of the Preferred Alternative, much special attention is
given to the Waterbased systems; riparian, aquatic, wetlands, and playa
habitats, to Oregon Natural Heritage Plan cell needs, the Special
status species habitat, the Big Game Habitat, and the need to protect
and enhance the unique Kiger mustang herd. Your criteria gives very
little recognition for need to protect the domestic livestock grazing
rights. While we recognise the need to protect the afore mentioned
Natural Resources, We feel' a greater emphasise must be placed on the
domestic livestock grazing rights.
119-1 The planning criteria used in guiding planning efforts are shown on
pp. 1-5 and 1-8 (DRMP/DEIS). These criteria incorporate all nine of
the FLPMA Section 202(c) criteria Cnot just numbers 1 and 3) and were
utilized In the development of all alternatives, including the
Preferred Alternative. Criteria for the Composition of the Preferred
Alternative (p. 2-3, DRMP/DEIS) were utilized by management In
addition to the other planning criteria, as a means of more clearly
defining management: emphasis.
119-2 Refer to response 2-11.
119-3 Refer to response 2-87.
119-4 Refer to response 2-6.
W.J. Hoyt and Sons has experienced a significant "cut" in AUM's in
several of their BLM Allotments, that will greatly effect production.
It is unfair that misleading data was used in arriving at this AUM
reduction.
W.J. HOYT SONS
RANCHES
RQ BOX 647 • BURNS. OREGON • 97720 • {503) 573-4244
'The Nation's Largest Producer of Registered Shorthorn Cattle"
Page 2
This misleading data was obtained via the good management practices
of this ranch, during drought years, while protecting the Public Lands
under our stewardship, we are being penalized for good management
during dry years, the reduction in our grazing capacity represents a
significant economic loss to this ranch.
Over the next three years, we will lose a minimum of approximately 626
AUM's, this represents a $30,000.00 loss to this ranch. Please note,
as yet, less than half of our Allotments have gone thru the evaluation
process.
In summary let it go on record, that we :
1.) Feel the monitoring technique used by the BIM, to gather
data regarding our AUM reduction, was improperly applied
and inaccurate data was used to arrive at their conclusioi
.) Feel that giving wildlife and wildhorses grazing priorities
over domestic livestock is inconsistent and unfair to the
struggling beef producers.
.) Stand firm beside the Harney County Stockgrcwers Assn
and endorse their letter to you concerning the Three
Rivers RMP/EIS.
Sincerely ,
Claude Mulholland
W.J. Hoyt and Sons Ranches
Appendix 11-120
nm
nited states
'* Department of
agriculture
Forest
Service
Pacific
Northwest
Region
319 s.w. Pine Street
P.O. BOX 3623
Portland, OR 97208-3623
Reply to: 1950
Date: February l , 1990
Mr. Dean Bibles, Director
USDI Bureau of Land Management
P.O. Box 2965
Portland, OR 97208
Dear Mr. Bibles:
Hal Beamer and Jim Keniston prepared this joint response to the
Bureau of Land Management (BLM) Draft Resource Management
Plan/Environmental Impact Statement (EI5) to eliminate duplication.
Hal and Jim are District Rangers located at Burns, Oregon for the
Malheur and Ochoco National Forests.
They met with Jay Carlson of BLM on Friday, January 5, to discuss
the BLM Draft Plan. The meeting was extremely productive. They
were able to clarify misunderstood direction, determine management
adjacent to National Forest lands, and identify some potential
conflicts.
It appears that to a large extent the BLM management is consistent
with both the Ochoco National Forest Plan and the proposed Malheur
National Forest Plan. Being a programmatic resource plan rather
than an allocation resource plan like the Forest Service plans,
there are a limited number of specifics. It will be imperative as
you implement your Plan that we coordinate closely on management
around common boundaries to ensure compatible management.
There are few apparent inconsistencies. These were discussed with
Jay and are documented below.
1. The Visual Quality Objective for FR 41 on the Snow Mountain
Ranger District is Retention as per the Ochoco National Forest
Plan. On pages 3-51 of the BLM Plan, the visual management
diraetion For BTM land along a portion of FR 11 in Koction 10,
T21S, R27F, is Level IV. Level IV corresponds to the National
Forest C-prvior. vinu.-il Quality Objective of Modification. Jay did
not indicate that it would be a major problem to have feh« HT.M
direction be consistent with the Forest Service.
2. The BLM proposes a wild and Scenic River classification of
"wild" to a Malheur River segment passing through Section 16, T18S,
R34E (identified as Segment A, Middle Fork Malheur River, pp. 3-42,
43) . The boundaries for this segment would include National Forest
lands in Section 15, T18S, R34E. However, this would not conflict
Director, Bureau of Land Management 3
' addition, the effect of road density in the BLM direction is
unclear.
7. Direction for managing eagle protection differs slightly.
The size of special management areas around nests and roosts agree,
but the Malheur National Forest identifies "potential" roosting
habitat. Similarly, the Snow Mountain Ranger District has two
roost sites and the Ochoco National Forest Plan calls for
protection of potential roost trees within 1/2 mile of existing
sites (Ochoco National Forest Plan, pp. 4-428). The draft Three
Rivers Plan calls for protection of existing sites and any sites
that are subsequently found to be occupied. It does not identify
any potential sites for Bald Eagle roosting. The Malheur and
Ochoco National Forests both contain roost sites but do not have
any active nest sites. Three active roost sites and 15 potential
roost sites have been identified on the Burns Ranger District. The
identification of potential sites is felt to be important to insure
there are options in the future to provide for an expanding
population or provide an alternative should existing active roost
sites become unsuitable for use. This need is identified in the
Bald Eagle Recovery Plan for Oregon and Washington (January 1989) .
Management plans will be completed for the three roost sites within
the Burns Ranger District within the next five years. Due to their
close proximity to BLM land it is important that a high degree of
coordination occur between Agencies to insure protection and
perpetuation of this sensitive habitat. It is recommended that BLM
and Forest Service biologists discuss the bald eagle habitat
management strategy within their respective plans to insure
consistent implementation of the Federal Recovery Plan.
The restricted season for management activities around eagle roosts
varies in the current Cooperative Agreements between the Burns
Ranger District and BLM, and between BLM and the Snow Mountain
Ranger District. We were unable to locate any reference to a
restricted season of use in the BLM Plan. This is of concern as
the Ochoco National Forest Plan has travel restrictions to protect
eagle roosts on adjacent BLM land. See Item 7.
8. The BLM Plan, in Table 2.1-9, calls for a restriction of
management activities within 660 feet of raptor nests from March 1
to August 15. The Ochoco National Forest Plan, on pages 4-423 and
429, states that for eagles the restriction period will be March 1
to August 15, and for other raptors March 1 to August 1.
9. The blm and both Ranger Districts have a number or mutual
livpsfonk grazing permittees. Tt is important that our management
direction be an consistent as possible to reduco the potential for
conflict and confusion.
In reviewing the BLM Plan, we found that allotments on both
National Forest and BLM lands were receiving utilization exceeding
the carrying capacity.
It appears that both Agencies will be faced with significant
challenges in turning the situation around. Since we share
permittees, it will be imperative that we coordinate our management
closely as we implement our respective plans, and we would like to
FEB 0 I 1990
Director, Bureau of Land Management 2
''with the proposed allocation under the proposed Malheur National
Forest Plan should the final designation be "wild." If it is not
designated as "wild," there is potential for conflicting
management.
3. BLM proposes mineral withdrawal for all river segments
designated under the Wild and Scenic Rivers Act. In addition, BLM
direction in riparian and wetland areas is to allow no surface
occupancy within 660 feet of these areas (Appendix, pp. 9-12, 13).
The Forest Service direction in the proposed Malheur National
Forest Plan is that mineral and other uses could exist within river
corridors as long as key river values are protected. The Ochoco
National Forest Plan allows mineral activity to occur outside the
riparian zones (Ochoco National Forest Plan, pp. 4-172, 173).
4. The BLM Plan identifies most of the Silvies Valley as
winter range (pp. 3-30, 31, 32, 33). The winter range is shown
extending to the National Forest boundary on the Burns Ranger
District, but there is no corresponding winter range shown on
Malheur National Forest lands at various locations west of Highway
395 and in the Silvies Valley. East of Highway 395, the identified
winter range is reasonably consistent.
In discussing this with Jay, we found that the Oregon Department of
Fish and wildlife (ODFW) was involved in identifying winter range
on both Agency's area of responsibility, but the data on Elk Winter
Range on the BLM land may be more recent. It is necessary to
understand the explanation for this difference in winter range
lines between the BLM and Forest Service lands. Two possibilities
seem to exist. Either there is a biological explanation for the
difference and the lines are correct or different information was
used to identify winter ranges on BLM land. We are not _ aware of
any recent studies which have updated winter range use in that
area. We believe the ODFW personnel at the Burns Office could
assist in this matter. ODFW input regarding winter range lines on
the Malheur National Forest was provided in 1982. We recommend
that biologists of respective Agencies discuss this matter and
provide an explanation.
5. On the Snow Mountain Ranger District (pp. 3-30, 31, 32,
33) , the winter range shown primarily agrees with that identified
as winter range on National Forest lands. The exception is on the
west side of the Snow Mountain Ranger District, Ochoco National
Forest where winter range identified on the National Forest is not
matched by corresponding winter range on BLM.
6. Both the Ochoco and Malheur National Forest management for
winter range is based on Habitat Effectiveness Indices (HEI) . The
BLM direction is based on providing 30 to 60 acre blocks of
suitable big game cover so that 40 percent of the treatment area
remains in suitable thermal and hiding cover. We believe there is
potential for inconsistency in interpretation of this direction and
recommend that BLM and Forest Service biologists discuss this at
the earliest convenient time, ochoco biologists question the
potential of winter range on BLM to produce thermal cover, based on
traditionally used definitions (percent crown closure, etc) . In
-~^ Director, Bureau of Land Management 4
111
nSsSw1 see some wording to reflect this when our allotments are adjacent
and the same permittee is involved.
There is a difference in utilization standards to resolve riparian
habitat problems. In Table 2.1-23, the BLM calls for removal of
cattle from streams in poor condition for a five year period,
followed by a grazing system that would allow 50 percent use of
riparian herbaceous vegetation and 30 percent use on upland
herbaceous vegetation.
The Ochoco National Forest Plan, on pages 4-141, does not require
the complete removal of livestock, but certainly retains that
option. The Plan also institutes these utilization standards.
Riparian Rrcas
Range Mgmt Levels Max. Use % Grasses Max. Use %
Shrubs
0-30
0-35
0-25
0-30
0-35
Suitable Range Not Riparian
Max. Use % Grasses
Max. Use %
Range Mgmt Levels
Shrubs
Shrublands
Unsat .
a
0-25
c
0-30
0-35
Percent allowable use is driven and prescribed by management
intensities A (not shown in above table; in FSM 2200), B, C, and D.
The use standards are Pacific Northwest Regional direction and are
to be used unless more site-specific objectives are approved in
individual Allotment Management Plans. This applies to all
National Forests with permitted livestock grazing and aids in
consistent dealing with the same permittees on different National
Forests.
□ rest
Grassl
and
Unsat.
Sat.
Unsat
0-30
50
0-30
0-35
55
0-35
0-40
60
0-40
Appendix 11-121
Director, Bureau of Land Management
10. in Table 2.1-3 and 2.1-31, 32, SLM direction calls for
closure of all roads not needed for administration or fire
purposes, allowing all types of Off Road Vehicles (ORV) use in
designated open areas except where unacceptable resource impacts
are occurring or are likely to occur, maximizing development of ORV
areas and cross-country routes (including those for snowmobiles and
motorcycles) to increase the number of out-of-countv users, and
developing trails to accommodate a number of other recreational
activities (paraphrased and emphasis added) .
It would appear that this direction could have the potential for
significant impact to forest resources and to our management.
Since no specific locations are given, it is impossible to assess
exactly what this impact would be. We would like to see some
wording added that would emphasize that any planned recreation
developments or road closures adjacent to or within National Forest
boundaries of either Ranger District be coordinated with the Forest
Service.
120-1 The Bureau-administered lands In Sec. 10, T. 21 S., R. 27 E., along
USDA-FS Road 41 have been changed to a VRM Class II which is similar
to Che LISDA-FS Retention Class in their Visual Management System.
120-2 Refer to
Thank you for the opportunity to comment.
Sincerely,
OHN F. BUTRUILLE
Regional Forester
cc:
Malheur NF
Ochoco NF
PLAN - Nygren
3-6.
120-3 Minerals management in designated Wild and Scenic Rivers will be
established through Federal legislation, if any, which establishes
river classification and the USDA/USDI Socretarys' guidelines for
river management .
120-4 Ihfl differences between BLM and USDA-FS maps were discussed at an
interagency coordination meeting on April 11, 1990, and consequently,
some minor revisions have "been made. See Maps WL-1 and WL-2,
PRMP/FEZS.
120-5 Refer to response 120-4.
120-6 Current timber inventory data show that the thermal and hiding cover
requirement Is being met within the timber treatment areas and the
objective Is to continue to provide for these needs. Coordination
between agencies Is essential and will continue. Also, refer to
response 7-25.
120-7 In a 1982 Inventory, no potential roost sites were discovered. The
characteristics of current roost sites were used to search for
potential sites, but none were found. The subsequent Raid Eagle
Winter RooBt HMP of 1985 outlined specific actions needed to ensure
that tho Burns District's portion of the Pacific Bald Eagln Ronovnry
Plan would be accomplished. Since that time, the HMP has been fully
■Implemented and reviewed on a yearly basis. The Proposed Plan has
been revised to include USDA-FS In the coordination of any new or
ongoing management actions as this coordination Is essential to the
success of the HMP actions. Also, the cooperative agreements arrived
at through the HmP process were not felt to have significant Impacts
to other programs and were not analyzed in the RMP.
120-8 The restrictions are dependent on the specific needs of the species
and the site Involved.
Refer to response 2-7.
Refer to responses 1-22 and 1-23. The action pertaining to
cross-country ORV travel (use of roads and trails) has been reworded
to clarify the management recommendation to the exclusion of
maximizing development and increasing use by out-of-county residents.
Additional management actions have been written in the Proposed Plan
to enhance ORV management in the RA.
February 6, 1990
Joshua Wacburton
BLM Burns District Manager
HC 74-12533 Hwy 20 West
Hines, Oregon 97738
121
Re:
DRMP/EIS
Biscuitroot Cultural ACEC
Dear Mr. Warburton:
I agree with your assessment and description of the resource
and value of the Biscuitroot Cultural ACEC, having studied
these resources and patterns of cultural use by the Burns
Paiute Indians since 1974.
The Biscuitroot Cultural ACEC has been proposed for designation;
however, detailed and specific use protocols will be determined in a
management plan tailored to the requirements of the subject
traditional activities. Native American consultation will be the
basis for any site-specific restrictions, Inasmuch as this ACEC
locality is considered to be a "common area" for Native peoples to
use for root gathering.
Oral history reveals there has been a long term traditional
use of the area by local Native Americans as well as Native
Americans from Warm Springs, Yakima, McDermitt, Fort Hall,
and Fort Bidwell areas with attendant social interactions.
While the crops are nutritious and have a cash value in
trade, the people rely upon the wild root crops in modern
days primarily for their value as an important cultural tool
in educating and creating awareness of young tribal people
as to cultural traditions .
The wi Id plant resource and its use by Indian people is
sensitive to gravel pit activities (concurrent use is not
desirable; pit expansion is a threat) and drought year
livestock grazing (resource is vulnerable to competition).
The livestock compete especially for the yampa (Perlderidia
bolanderi) which tends to grow under moist conditions or
streamside .
I agree with your recommended management and use constraints
for this area, and would further recommend that all Native
peoples be allowed to camp and dig for rooLs in this area
unrestr icted .
Thi
nk you for the opportunity to respond to your DRMP/EIS,
st 5 incerely,
Marilyn 'couture
Cultural Anthropologist
1951 N.W. Walmer Drive
Portland, OR 97229
(503) 297-3449
Appendix 11-122
FZk. Ktfo
122
./4»
122-1 This definition and set of criteria closely resemble those currently
being used by both the Burns Ranger District (Malheur National
Forest) and the Snow Mountain Ranger District COchoco National
Forest). A composite definition and criteria have been formulated for
this plan. See Proposed Plan, Table 2.4.
^AceoS
fr
~T~t*z~
jkUo
jfRQMiNATL. WILDLIFE FED. PDX 70:13894919
FEB 7. 1993
[» roeontmanded by Tim lilllsbo - (ft. Brown 2/6/90)]
3 the size of the area should generally bo no lose than 40
mature, overmature, ana decadent tree components,
3. in addition to the layer provided by 1«9J "J""*"* *™J|' 0t
least one reoognizable layer of .seedlings, saplings, or poles
present;
4. (0) one or more standing 14" dbh or larger snags pa
5 ro) 3-6 (10) large (greater than 12" dbh at largest end) 8
foci long logs' beinl a portion of the overall wooody material
component;
5. native shrub canopy cover of (0) 20-40 (60)% wnUMT with •
variety of native herbaceous plants composed of grasses, sedges,
and forbs.
'adapted with modifications from material prepared by Bill
Hopkins, area Geologist for Fremont, winema, Deschutes and Ochoco
National Forests. Numbers in parentheses indicate low and high
ends of a range.
Appendix 11-123
January 17, 1990
Joshua l. Warburton, District Manager
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, OR 97733
REVIEW COMMENTS FOR THE OCTOBER 19S9
BLM DRAFT THREE EIVEHS RMP/EIS
Dear Mr. warburton:
The January 17, lggo Riddle Ranch and Western Range Service
comments and Response to the Draft Three Rivers Resource
Monagemont Plan and Environmental impact Statement are consistent
with our views and comments.
•This response is our endorsement of such Riddle Ranch
document. Their response has been submitted to you. We Go not
include a full copy of textj only for the reason that it would be
an exact duplication of the Riddle Ranch document.
Any additional comments we may have are enclosed herein and
are supplemental to our principal response.
Refer Co responses 2-1 through 2-96 (r
Western Range Service letter).
isponses to Riddle Ranch and
3 a x £?s j-jr ti
Address ~ -
City State zip Code
Signature
Enclosure: Supplemental comments
January 3] , 1990
124
'iShua L. Warburton
ujrns District Manager
Bureau of Land Management
HC 74-12533 W. Highway 20
Hines, OR 97338
Following is my comment in addition to the comment prepared by Riddle Ranch and Western
Range Service, concerning The Draft Three Rivers Resource Management Plan & EIS.
124-1 I i am opposed to the fencing of 80.9 miles of stream in this RMP, resulting in a loss of
I 28,937 AUM's for 5 years or more. Often the permittee loses much more than the creek
I bottom «ith-:the?fence.''extending beyond the creek bank. The promise of off-site forage
I to replace temporary reductions may not become a reality.
124-2 I BLM lists Riddle Creek and Paul Creek as having poor surface water quality and poor
I aquatic and riparian ratings due to warm water temperature and silt. However during
I normal water-shed years fish are plentiful in these streams. Research has proven that
| livestock grazing is beneficial to riparian areas, with proper management.
124-3 I Since Juniper is the number one erosion problem in this RMP a workable tool of management.
I such as burning, :coulri be implemented into BLM's yearly program. Presently, little is
I being done to rescue the drainage areas from these forests of Juniper. These trees
| intercept much of the moisture, leaving little water for plant life.
Antelope, deer and elk have greatly increased in herd population in the past ten years,
which proves the vegetation is pJentiful,. Ten years ago Riddle Mountain alotment had
few, if any elk.
124-4 I The Kiger and/or Riddle Mountain wild horse Herd Management Area should not be expanded.
I Many of the HMA's in this RMP have herd numbers far beyond the minimum and often more
I than the maximum. Stallions from the wild horse corral in Burns should not be returned
to the range. They ought: to be casterated and placed for adoption or destroyed. Since
124-5 I cattle have priority over wild horses in public land forage, one must question the-
| legality of clasifying wild horse HMA's as Areas of Critical Environmental Concern..
I 124-6 I Mineral exploration and mining should be allowed to continue in this RMP, since Eastern
I Oregon public lands are rich in minerals. Also energy possibilities BUStld receive
I high priority, public lands must remain in multiple-use with recreation allowed.
Maintain timber harvest and livestock grazing in forested areas in the RMP under present
124-7 | management system. There is no scientific proof that livestock grazing is harmful to
I sage grouse strutting areas. Neither is there proof of harm to nesting areas of the
I long bill curlew and raptor, due to livestock grazing. Cattle have grazed for more
I than 100 years on Stinkingwater Mountain with no harm to the harvest of Native
I American roots.
124-8 | No private property should be sold to the federal government, only land exchange when
feasible- Roads should not be closed and re-habilitated without considering ranchers'
124-9 | neeCjS. Under the current management system, Drewsey EIS, the total AUM's issued ought to
L24-10 I remain the same until BLM monitoring data indicates a decline in available forage. BLM
1 area managers i-Tjwyld' identify anything of concern in each allotment and work with
I ranchers to provide a solution before it becomes a problem. Many of the alternative
proposals, if implemented, are in violation of the multiple-use concept of the Taylor
Grazing Act. Any reduction in livestock grazing AUM's will have an adverse effect
on the local economy.
Thank you for the opportunity to make comment.
Sincerely, p ^ _^,/; f
Jennie Qtley Sl^*^^-^ C^^^^
HC 72 Box 55 6 .'J
Princeton, OR 9772]
124-5
124-6
124-7
124-8
124-9
124-10
Refer to response 5-10.
Refer to response 6-4.
The practice of prescribed burning and the felling of juniper stands
has been proposed in the PRMP/FEIS. The implementation of this
process is expected to be ongoing year after year. For information on
prescribed fire constraints and wildfire suppression policy refer to
responses 4-8 and 4-9, respectively. Also, refer to response 6-8.
There is currently a 5-step process for disposing of excess wild
horses gathered from the range. This process as outlined in the 7th
Report to Congress on the Administration of the Wild and Free -Roaming
Horse ami Burro Act, is as follows:
1. Regular adoption program at full fees.
2. Special adoptions at altered fees.
3. Training of wild horses at prisons by inmates, with the trained
animals to be made available for adoption. Animals not adopted
within 30 days after training should be handled through steps 2
and 4, and if not adopted within 30 days, destroyed in
accordance with step 5.
4. Placement of wild horses on private sanctuaries, with the
animals maintained with non-Federal funds.
5. Euthanasia for any animal not disposed of within 90 days
following BLM's certification of its availability for adoption.
Castration or other sterilization measures do remain an option under
the Wild and Free-Roaming Horse and Burro Act; however, these
measures have proven to be unfeasible and are no longer used very
extensively as a method of control.
Also, refer to responses 2-68 and 11-11.
Refer to responses 2—6 and 2-68.
Refer to response 52-1.
Refer to responses 1-15 j 2-79 and 3-9. Also, no livestock grazing
restrictions are proposed for raptor habitat enhancement.
Refer to responses 4-14 and 6-10.
Refer to response 2-81.
Refer to response 2-11.
Appendix 11-124
a
Oregon Trout 125
Speaking out for Oregon's fish
P.O. Box 19540 ■ Portland, Oregon • 97219 • (503) 246-7870
February 6, 1990
Joshua L. Warburcon
District Manager,
Bureau of Land Management
Burns District Office
HC74-12533
dines, Oregon 97738
Dear Mr. Uarburton,
Anyone with some knowledge of our natural resources cannot dispute
the low ecological condition of many of the riparian areas in the Three
Rivers Resource Area. A significant reduction of shrub and tree cover
and loss of many native herbaceous species such as Deschampala
caespltosa to lower producing exotics like Poa pratensis, have greatly
reduced the resource values of our riparian zones"! Many of these zones
are not only producing far below their potential for water quality,
aquatic habitat, wildlife habitat, and recreation values, but also red
meat production. Since European settlement in the sagebrush steppe
region the potential CO produce red meat has been reduced by 60 to 90%.
It is my belief all of these resource needs can be met with Intensive
and creative management. It 1b essential for the long term benefits of
everyone, that management decisions be made from a biological basis.
If management decisions are made from a political basis we will all be
losers.
Grazing by domestic herbivores has been identified as one of the
primary activities causing the decrease in ecological condition in
riparian areas. However, the problem in most cases is not overstocking
but animal distribution. Riparian zones are unlikely to respond to
livestock reductions unless the pastures are truly overstocked.
Riparian areas are frequently overgrazed even In understocked pastures.
Total forage may be adequate in a pasture, but if livestock have access
to riparian zones these areas are frequently the focal point of use,
leading to overgrazing even In an understocked pasture. Fencing these
areas as separate pastures will be one of the most effective tools In
returning these systems back towards maximizing their potential
benefits. Timing, duration and frequency of use by livestock must be
controlled if we are to maintain the integrity of these systems. Hon
traditional seasons of use may also be evaluated, such as early on and
early off, which has worked well in parts of central Oregon.
Brainstorming with leaders In the ranching industry may also develop
creative alternatives to the problem. This will also increase
cooperation which is critical since the majority of the riparian zones
are in private holdings. Proper use of riparian zones will develop
vegetation structure that will increase capture of sediment and better
store water. This means longer growing seasons and higher quality
125-1 Refer to response 3-13.
125-2 The proposed buffers have been effective at decreasing sedimentation
into the small v-shaped canyons characteristic of those found In the
forested areas of the planning area.
forage. It also means more consistent water flows throughout the year.
The ultimate end point Is better aquatic habitat, wildlife habitat,
recreation values, Increased water quality and quantity, and livestock
production.
Concern for fire due to lack of rood access and build up of fuels
In these zones should not be a concern. Fire played an important
historical role in developing plant ecosystems In the Great Basin. Pre
European fire frequencies ranged from 8 to 12 years in the pine forest
to 20 to 30 years In the mountain big sagebrush communities. Riparian
systems were frequently exposed to fire prior to European settlement.
Many of these plant systems would benefit from periodic fire. This
would be particularly true of the uplands where j uulpar Is rapidly
Invading shrub steppe communities. If allowed to continue the Increase
of juniper woodlands will have a negative effect on the watershed with
increased sediment loss, decreased water storage and increased water
loss from the watershed due to evapotransplration.
Reduction of roads In the Three Rivers Area is a positive move
forward. Logging buffers adjacent to riparian areas, however, are not
adequate, particulary in the 0 to 40% slope category. Movement of
streams In areas with 0 to 2% slope can easily move outside of the
buffer. Stream channels are very dynamic.
go wi th the status
zones are unacceptable
I sincerely hope the BLM does not decide
quo. Current conditions of most of our rlparl;
with 82% in fair to poor condition and 44.35% continuing to decline
These zones are producing far below their potential for all resource
values. It Is time to move forward with aggressive management to
benefit everyone. Although Increased inputs, such as fencing, are
expensive many resource benefits will be realized In the long term
outlook. If we do not manage theses ecosystems in an aggressive and
creative manner, from a sound biological basis, we will continue to
exploit our resources.
Sincerely yours
Richard T, Mill.
Southeast Oregon Dt
'M
Appendix 11-125
Department of Fish and Wildlife
506 SW MILL STREET, P.O. BOX 59, PORTLAND, OREGON S7207
February 5, 1990
126
126-1 Refer to response 1-23.
Joshua L. Warburton
District Manager
HC 74-12533
HWY 20 West
Hines, OR 97738
Mr. Warburton
On January 19 the Department provided you with our review
and comments on the Three Rivers Resource Management Plan.
Our district staff has subsequently contacted me to express
apprehension over an item in Table 2.1: Management
Directives by Alternatives. The point of concern is found on
page 31, under the column for the preferred alternative. It
reads: "Maximize the development of usable ORV areas and
cross-country routes (including snowmobiles and
motorcycles) , including areas away from the population
centers in the county, to increase the number of out-of
county users. "
The Department is concerned about the possible negative
impacts of encouraging increased ORV use from out-of -county
users. In most areas of the state we have taken the position
that ORV use should be restricted to designated areas; other
than those areas, ORV's should be required to stay on
developed roads and follow the same rules and regulations as
highway vehicles.
The Burns district, however, is somewhat different. Other
than a few local areas, ORV use is relatively light
throughout SE Oregon- The Department felt that this provided
a unique opportunity for ORV enthusiasts to explore this
vast, sparsely settled, and lightly roaded region with minor
environmental consequences . Therefore, we reasoned that the
potential for negative impacts was slight and did not
recommend designated areas for ORVs..
The key issue here is that ORV use has historically been
light and broadly distributed. Such usage causes little in
the way of negative, long term, environmental impacts and
provides much in the way of unique outdoor opportunity. The
high desert environment, however, is quite fragile and the
balance between negligible and significant damage can be
quite precarious. Even one, relatively intense exposure to
ORV use can cause damage that may take years to heal.
continued intensive exposure can easily cause significant
environmental damage and displacement of wildliCe
communities.
The passage at issue here seems to suggest that the BLM
intends to solicit additional use. The Department would like
to discourage such action by the BLM. Current levels of
usage do not require restrictive actions. However, _ increased
usage would probably have a negative impact on indigenous
plant and animal communities. More restrictive rules
pertaining to ORV use would probably have to be implemented
to circumvent these impacts. Not only would this be an
unfortunate loss of a traditional use, it would be very
difficult to enforce.
The Department recommends that the BLM take no action to
encourage additional ORV use. We suggest that item 2 at the
bottom of page 31 be substituted with item 2 at the bottom
of page 30. It reads: "Develop usable ORV areas and cross-
country routes (including snowmobiles and motorcycles)
around the populated areas of Burns and Hines to accommodate
the needs of the local population and the occasional request
by out-of-county users for cross-country use.
Thank you for your consideration and attention to this
matter.
Darryl M. Gowan
Forest and Rangeland
Staff Biologist
Appendix 11-126
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127-1 Refer to responses 2-11, 2-87 and 8-4.
127-2 Refer Co response 8-4.
127-3 Refer to response 2-63.
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Appendix 11-127
^is
r*bJ,j990
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128-1 Refer to response 8-4.
128-2 Refer to responses 2-11 and 2-87.
128-3 Refer to response 2-63.
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Appendix 11-128
-i tyCCA
January 29, 1*90
Jay Carlson RMP/EIS
Burns District Office' Bu
HC 71 12533 Highway 20 W
Hines, Oregon 97738
Rev
Comments for the? October
Sft Three Rivers RMP/EIS
129-1 The reason that the RHP is being developed and will replace the land
use planning is presented In the DRMP/DIES In Chapter 1, Purpose and
Need.
129-2 Refer to response 2-63.
Dear Mr
rl 5
7Z Land & Cattl e Company, Inc. wish to request the Management Plan
currently in use -for the Three Rivers Resource Area to bo unad « the
"Preferred Alternative". We are aware this alternative was not listed
in the 1939 Draft Three Rivwn RMP/EIS. It shoul rl have been. We
strongly feel if the current management plan were fully implemented in
very~permit and with proper manaqsment af livestock, wild hor=ses, and
ildlife, that with due time we will continue to see an incrrase in
he prn,inr!-inn and condition of the sntf.ro resource area.
We do not believe with the pr&f erred alternative, the 19S9 Draft
Three Ri vers RMP/EIS if implemented, would effect our permit
significantly, if at all. Who can say what might be in the many pages
of the document that we may have overlooked. The draft, if
implemented may not have a negitive e-f-fect on our op&ration, however
it will have a negitive effect an many other ranchers and also the
economy of the county. This county has too few resources as it is. We
should manage those recourses wisely and use them to thery fullist. »
I We request that prior to issuing the final Three River RMP/EIS
using alternitives A, E, or C, that a Takings Implication ftasseMm/fflnt;
be completed as authorised hy executive order 12630 (see the November
S, 1.983 memorandum to all Assistant Secretaries and Bureau Directors
I from Secretary of Interior, Donald P. HDdeV).
The letters from the Harney County Cattlewomen, Stockgrowers , Farm
Bureau, Sheep and Wool growers, and the January 17, 1990 Riddle Ranch
and Western Range Service? comments and response to the Draft Three
Rivera Resource Management Plan and Environmental Impact Statement are
Consistent with our views. This response is our endorsement of such
letters and Riddle Ranch Document. Their response has been submitted
to you. Wjt_4p.<-npt include a full copy of te
that itrf-itiu\^j\lf-'idny&^t duplicat)
Binc»rM- . . . ^ffl
such.
suiflj
Sncl Catt Id Co. , Inc .
Pfi s.
January 17, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hines, OR 97738
130
REVIEW COMMENTS FOR THE OCTOBER 19B9
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson:
(If you are facing b reduction in AUM'b, please include the next tvo
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C trill result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
Of our operation so that it ie no longer an economical unit. Therefore,
ve request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact' Statement, a "Takings Implication Assessment" be completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel>.
The reallocation and/or- reduction of .^35 AUM's livestock forage
vill reduce the value of our base
(Assume $50 per AUM value).
"Takings Implication
The reallocation and/or- reduct
property by approximately S /IP*'
Please consider this economic loss in the requ
The letters from the Harney County CattleWomen, Stockgrovers, Farm Bureau,
Sheep £ Woolgrovers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent vith our
vlevs and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it vould be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments vm may have are
supplemental to our principal response.
and are
130-1 Refer to response 2-63.
Sincerely,
Pl't, *. A a lex:
JMjLA Jukk^A.
Pf>-&c
&tj-r? HJ^,
■)-17,7.
£*M
Signature
Enclosure: Supplemental Cam
Appendix 11-129
!i
COMMENTS AND RESPONSE
Prepared by: Mitch and Linda ttaker
SUMMARY
The Draft Three Rivers Resource Management Plan and Environmental
Impact Statement (Draft RMP/EIS) Is not reeded.
I don't think we need to do a lot of fencing and make this a
riparian corridor. I also don't think we need to change the
'SMC from 'M' to 't' when everything is Improving steadly.
We need to get a good water source in the Plateau pasture to
be able to utilize this field and help 'rotations on Lho other
three pastures. This would Improve wildlife in the plateau
and improve the river riparian at even a faster rate of return.
The removal of livestock from this 1,5 intermittent miles
of river will disrupt current successful grazing. It will also
have long-lasting adverse Impacts on livestock operations. Only
a portion of the streams are publicly owned. Therefore, RLM's
proposed actions will have very little, if any, effect on
overall stream conditions.
The surface water quality and aquatic and riparian habitat
condition ratings appear to be inconsistent and unrealistical ly
restrictive. I f water quality conditions are as poor as BUI
claims, we would expect that there would be no fish left in the
Resource Area. These water quality ratings (surface, riparian
and aquatic) are the basis for the majority of the adverse
impacts to livestock grazing.
All available information indicates that current upland grazing
practices are having no significant adverse impact on surface water
qua 11 ty .
RLM has failed to address many of the adverse impacts of their
preferred alternative on livestock grazing. Funding for the proposed
range improvements will probably not be available.
In the last five years during the BLH's surveys, three of
these years were dry years and ran consecutively with each other.
Two of these years, 1986 and 1987, the river all but went dry
during the summer. In 1988 it did dry up and the only water
going through this property was what was coml ng from Myrtle
Creek. The river was dry from Myrtle Creek up river.
£ -ts -M
J. -*f-
Qjl
V?>o5*X
S1 Ivies River
Allotment # 7033
Background
This allotment contains 1044 acres of BLM land and 699 acres
of private and state land. The allotment is divided into four
pastures. The plateau pasture is non-used every year due to no
water In this allotment. Two of the remaining three pastures
are basically private land. The remaining pasture is a majority
BLM land and accounts for only approximately one third of the
total 1044 BLM acres. This is the onlyrpaSture that the Si 1 vies
River runs completely through BLM property. This pasture does
not include 1.5 miles of continual river side riparian and
fisheries area because the river goes from Forest Service into
private, then to BLM, back to private, to BLM, and back to private
land.
These sections of the river are very heavily fished during
the spring and summer. It is the only access to the river for the
public in any direction for at least 10 miles. The river Is shallow
and has adequate cover, The cover is improving every year.
River side riparian and fisheries habitat had a set back,
in 1982, 1983, and 1984 during the higher than normal and longer
water run-off season. During the run-off season the high water
and Ice jams in the river changed the river channels, taking out
'S' curves and creating sand bars. This destroyed old dense growth
willows and grass. But this caused invigeration of the new growth
of willows and grass along the sand bars and river banks at a much
faster rate.
The cattle have had very little effect on this situation.
Mother Nature caused the damage and she is also repairing the damage
with the new growth. Along with our efforts with lower AUM
numbers and shorter rotation periods, riparian and fish habitat
is improving greatj-y and has been considered and addressed by
the permittee.
131-1 Allotment categorization is based on a variety of criteria. The
process involved is in accordance with Bureau policy and guidance.
See Appendix 1, Tables 10 and 11, PRMP/FEIS.
131-2 Refer Co responses 2-5, 2-11 and 3-13.
131-3 Refer to responses 2-27 and 2-28.
131-4 Refer to response 2-52.
Appendix 11-130
132
February 10, 1990
Jay Carlson - RMP/EIS
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 97738
REVIEW COMMENTS TOR THE OCTOBER 1989
BLM DRAFT THREE RlVERS RHP/ EI5
Dea
Mr
Carlson:
Mi tbh and Linda Baker want to go on record that the January 17, 1990
Riddle Ranch and western Range Service comments and response to the
Draft Three Rivers Resource Management Plan and Environmental Impact
Statement are consistent with our views and comments. This response
is our endorsement of such Riddle Ranch document. There are several
other areas of concern that this letter will address.
A riparian area is defined as an area of land "directly influenced
by permanent water, and having visible Ivegetation or physical vv
characteristics reflective of permanent water influence." The
definition continues that areas excluded from the definition of a
riparian area include1 "ephemeral streams or washes that do not
exhibit the presence or vegetation dependent upon free water in the
soil." A thorough review of all creeks should be made to ensure
they meet the definition of riparian aren. Any that do not meet
the requirements should be tak?n out of that classification.
Monitoring techniques currently in use on the Three Rivers Resource
Area are insufficient, inaccurate, and improperly applied and then
are extarapollated to ^defensible conclusions. Management objectives,
in the absence of AMP's, are documented only in the broadest of terms
making them virtually immeasurable . No factors, other than short term
wildlife, wild horse and livestock utilization, are indicated as
affecting forage production, ecological status or potential of the
resource. Therefore, reductions in authorized livestock use is the
132-1 Refer to response 42-14. Also, those screams with no condition or
trend data have not been inventoried. Streams not meeting the
definition will be dropped from the list.
132-2 Refer to response 2-87.
1.32-3 Refer to response 4-3.
132-4 Refer to response 4-6.
132-5 Refer to response 2-46.
132-6 Refer to response 2-63.
primary, if not the only, remedial action recommended. Until proper
techniques and accurate Information is gathered existing levels of
livestock grazing should be maintained. At such time that reliable
information shows trend increase or decrease, proper adjustments
could then be made. The ratings in the recently published Riley
Rangeland Program Summary Update classify range conditions as poor,
fair, good, and excellent. The RMP/EIS classifies range conditions
as satisfactory and unsatisfactory. Consistent use of evaluation
ratings is necessary for accurate evaluation as well as better comm-
unications with the permittee.
There is no scientific data that indicates that livestock use has
any negative effect on the sagegrouse population. The restrictions
on livestock in the sagegrouse strutting grounds are unfounded and
should be eliminated.
The continual Tencing of reservoirs is in direct conflict with the
BLM objective to disperse livestock away form riparian areas and
Improve forage utilization. These reservoirs would not be there
today If it had not been for either the range improvement funds
or private funds that first developed them. The small water gaps
that dry up during the season or don't allow livestock to water during
low water years restlct the amount of available forage and can concentrate
cattle more than necessary. Livestock have a biological need for
water.
Before any alternative that causes a reduction of AUM's is imposed,
no matter whlaL reason, a complete "Takings Implications Assessment"
should be completed as authorized by Executive Order 12630.
Sincerely yours ,
Mitch and Linda Baker
P. 0. Box 105
Burns, Oregon 97720
p>ww_i
(Or. ":'tn os,o
Appendix 11-131
Landing Creek Allotment #7040
Comments
The reduction of AUM's in this allotment is not necessary 1f
the BLM would stop the unauthorized use of allotment by the
surrounding property owner and leasees. The reduction of our AUMs
Is not going to Improve this allotment If the unauthorized use
1s going to continue year after year through out the summer and
fall even on the allotment's rest years. Also, I don't think
we need to change the 5MC from H to I. The range has been
improving. It is not as bad as the BLM survey says.
Landing Creek is not a free flowing creek year around. It
will have water through out the length of the creek year around
ff ft is a very wet year. Durl ng drier years, this creek will
dry up throughout the length of the creek except for small pools.
This creek Is fed by a small spring at the head of Landing
Creek Canyon and is located outside of this allotment. The spring
would no way ever produce enough water to free flow the length of
the creek. It doesn't even run water to the boundary fence of the
allotment from the spring head year around except on very wet years.
How can riparian and water quality be declining while fish
habitat is improving? This is not consistant, One can't improve
or decline without effecting the other also.
There is in no way by the year 2000 that you will have a 55%
stream shading and water temperature at 77°F. There is not the water
source and flow to support such an assessment.
The reduction of livestock from the stream area will disrupt
the current, successful gracing system. Therefore it will have very
little effect on the overall stream conditions,
133-1 Refer to response 2-11.
133-2 Refer to response 131-1,
133-3 Refer to response 46—1.
133-4 The objectives were formulated partially from Bureauwide objectives
outlined in Fish and Wildlife 2000, A Plan for the Future. Management
actions to meet those objectives were then formulated. Predicted
riparian conditions are listed in the Proposed Plan. Experience has
shown that many riparian areas have the potential to recover quickly
when managed to meet riparian objectives. Particular recovery time
will be dependent in part upon the current condition of the riparian
133-5 Refer to response 133-4.
133-b Refer to response 2-6.
133-7 Monitoring is not done by volunteers.
Comments and Response
Prepared by Mitch and Linda Baker
I don't think the AUM cuts for me in this allotment are
fully justified when the unauthorized use of the allotment
goes on year after year all year long.
The water quality and riparian habitat 1s not going to Improve
very much when you have a creek that goes dry off and on, How
are we to have a good fish population without a good water source
to start with. I don't think fencing cattle out Is our answer.
Our uplands are In \sry good condition. That is where
cattle go to graze and have no significant adverse impact on
surface water quality.
Giving wildlife priority over cattle in forage allocations 1s
unfair and inconsistent.
If we were not improving our range land conditions in these
areas, our wildlife would not be Increasing, However, they are
increasing due to more forage,
There needs to be more money spent on constructive range land
improvements and less spent on survey after survey. The
continued surveys don't produce forage or Water which Is essential
to cattle and all wildlife.
NOTE: It has also been brought to my attention that volunteer
people are being used to assess allotment and plot surveys and
conditions. I question the validity of these assessments when
done by volunteer, possibly unqualified labor.
7rj^cJ- s&i
QU^ JV. ©^O
Appendix 11-132
134
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a,T" 1t>=iT "H^*' o. s 5qo« At« Oote/'C^)
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efer to responses 3-9 and 4-6.
Appendix 11-133
i: -
Drewsey, Oregon
February 10, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Kinea, Oregon 97738
This is an underlying principle of the overall monitoring and
evaluation process. To support such a process, the allotment summary
tables were developed (Appendix 3, Table 6, DRMP/DEI5) to show major
known resource management conflicts or concerns and management
objectives. Such information forms the basis for such interaction
among all interests and is available under all alternatives.
RefR
2-63.
Mr, Carlson:
The so-called study on the Three Rivers Resource Management Flan and
Environmental Impact Statement as it is being proposed could have a
tremendous effect on the livestock operators and the total population of
Eastern Oregon, and all the way through the total livestock industry in
general.
Alternatives A, B and C will result In a loss, not only of how many
cattle we could graze but also in our ability to operate profitably. Either of
these would also reduce our base properly value.
In all of these alternatives and Ideas, I see no mention of the option to
have a plan whereby all parties concerned could work together and eliminate
the problems. In our particular case there Is a great need to control and
remove overpopulation of Juniper trees, sagebrush, and noxious weeds.
Through Joint effort and management with mechanical removal, fire, spring
modifications and seeding as well as voluntary rest in these areas, all of the
problems could be eliminated or controlled to benefit all parties involved.
There Is no need to close down an area to livestock any more than to
close it to wildlife and man. Some of the areas being considered are
practically impossible to have access to if closed to all but the few who could
walk to them.
It's time the powers that be spend some time with the people who will
be the most affected and go over each individual area to get an understanding
of what this plan la all about. When I say "powers that be", I mean Senators,
Representatives, Agriculture Secretary, and even including the Administration
(top close representative of the President of fibe United States).
These type of plans involve not only the eastern portion of Oregon but
all the way across the whole United States where the Government controls or
administration is involved in any type of land use. I know of instances in
other areas where the same type of problems exist, so we the people have to
apeak up to you and your comrades who have so much power over us.
I suggest a Takings Implication Assessment be completed as authorized
by Executive Order 12630 (see the November 8, 1988 Memorandum to all
Assistant Secretaries and Bureau Directors for Secretary of Interior, Donald P.
Hodel).
The letters from the Harney County CattleWomen, Stockgrowers, Farm
Bureau, Sheep and Woolgrowers, the January 17, 1990 Riddle Ranch and
Western Range Service Comments, and Response to the Draft Three Rivers
Resource Management Plan and Environmental Impact Statement are mostly
consistent wi^h my views and comments.
Before any action of this magnitude, which would have such drastic
results on so many, is taken, I suggest a little common sense be put to use and
everything evaluated to the fullest.
Victor H. Thurman, Manager
Ellingson Rocking 3E Ranch
Drewsey, OR 97904
Appendix 11-134
n
Drewsey, Oregon
January 29, 1990
Jay Carlson
Bums District Office
Bureau of Land Management
HC 74 12533 Highway 20 Weat
Hines, Oregon 97738
Dear Mr. Carlson:
136-1 Refer to response 2-63.
136-2 Refer to response 4-15.
136-3 The Stinkingwater Allotment has been a part of the active
Stinkingwater 1TMA since 197.1 when the Wild and Free-Roaming Horse and
Burro Act was passed. The BLM has been directed under Section 1 of
the Act to protect wild horses in the areas in which they were found
at the passage of the Act.
136-4 California bighorn sheep are not an introduced species to the Upton
Mountaiti-Bartlett Mountain area. They have been reestablished in the
area, which was once part of their home range. See also response 2-78.
The letters from the Harney County Cattlewomen, Stockgrowers. Farm
Bureau, Sheep and Woolgrowers and Response to the Draft Three Rivers
Resource Management Plan' and Environmental Impact Statement are
consistent with our views and comments.
This response is our endorsement of such letters and the Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of the texts only for the reason that it would be an exact
duplication of the Riddle Ranch document and organ Izations' letters.
Alternatives A, B and C will result in a substantial loss of base property
values. The proposed BLM actions may result in reducing the size of many
ranching operations so that they will no longer be economical units.
Significant reduction of cattle grazing on public lands would be detrimental to
economic well-being of the families who earn their living from ranches that
have BLM grazing permits, the economy of Harney County, and all people
who provide services and goods to the ranchers affected, Therefore, we
request that if Alternatives A, B or C are considered, that prior to issuing the
Final Three Rivers Resource Management Plan and Environmental Impact
statement, a 'Takings Implication Assessment" be completed as authorized by
Executive Order 12630 (see the November 8, 1988 Memorandum to all
Assistant Secretaries and Bureau Directors for Secretary of Interior, Donald P.
Hodel).
We object to the prohibition of livestock grazing on the 6000 acres of
BlBcuitroot Cultural ACEC area in the Stinkingwater allotments. Restricting
grazing on the Biscuitroot site ia not necessary, as evidenced by the present
quality and quantity of roots after being Included in an active cattle and
sheep grazing area for over 80 years.
136-31 We also object to the designation of Stinkingwater allotment as an
I active wild horse and burro area, and Bartlett Mountain-Upton Mountain area
136-41 &s California bighorn sheep habitat, since these species are introduced species
I to these areas.
We object to the restriction of livestock from artificial ponds and
reservoirs, and the designation of these man-made structures in semi-arid
environments as wetland habitat for waterfowl.
Thank you for your attention to these problems and our comments.
Appendix 11-135
OREGON
SHEEP GROWERS
ASSOCIATION
INC, 1270CHEMEKETAST. N.E.
1
i SALEM, OREGON 97301 ■ 503-370-7019 • FAX 503-585-1921
February 13, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, OR 97738
Re: Three Rivers Resource Management Plan Draft EIS
Dear Mr. Carlson:
On behalf of the Oregon Sheep Growers Association, 1 would like to
express our concerns in regard to the Draft Resource Management plan
(RMP) and Environmental Impact Statement (EIS) for the Three Rivers
First, we are concerned and disagree with the designation of Landing
Creek and Skull Creek as "riparian areas." The designation of these two
areas as riparian seems to be in direct conflict with existing policies of the
Bureau of Land Management which define a riparian area as an area of
land:
"directly influenced by permanent water and
having visible vegetation or physical characteristics
reflective of permanent water influence. "
(emphasis added)
In light of this definition, we would suggest that Skull and Landing
Creeks should not be considered as "riparian" areas. We would also
suggest that following a complete review of all creeks or streams in the
affected area, those not meeting the existing definition be removed from
this classification.
Finally, we have serious concerns with the proposed prohibition
against changes in livestock classes to enhance Bighorn Sheep populations.
At the present time, there seems to be a complete absence of any scientific
evidence indicating that managed grazing of sheep could be detrimental to
Bighorn Sheep populations.
For these reasons, we strongly believe that existing grazing practices
should not be restricted through the draft plan.
Thank you for the opportunity to submit our comments on you-
proposed draft.
Sincerely,
William Rill *
President, OSGA
WR/RK/IIR
Secondly, we are concerned with the potential reduction in the use of
lands for livestock grazing as a result of improper monitoring techniques.
We believe current techniques are too narrow in scope and do not provide
adequate consideration of numerous other factors impacting the resource.
Current techniques seem to maintain a preconceived bias against livestock
grazing, when, in fact, proper and well-managed grazing practices can be
shown to actually "enhance" a land-based resource. In addition, we
disagree with the initial conclusion that existing grazing practices have
negatively impacted populations of sagegrousc. We would suggest the
proposed restrictions on livestock grazing, due to the "potential" impact on
sagegrouse, be eliminated from the draft plan.
We would like to express our concern regarding the Biscuitroot
Cultural Area of Critical Environmental Concern (ACEC) and the Kigcr Horse
Management area. The proposed exclusion of cattle grazing in the
Biscuitroot Cultural ACEC docs not seem justified, since grazing and root
harvesting have continued on these lands for a number of years without
apparent harm.
We would also disagree with the proposal to designate the Kigcr
Horse Management area as an Area of Critical Environmental concern.
Without question, such a designation would result in an extreme economic
hardship for individuals within the area. We believe designating this area
as an ACEC IS premature, at best, and represents an inappropriate "taking"
of private lands. At a minimum, we suggest that if efforts to designate this
area as an ACEC are pursued, the BLM should conduct a complete
assessment to determine if such action would constitute a "taking,"
137-1 Refer to response 46-1 and Appendix lj Table ks Proposed Plan.
137-2 Refer Co response 2-87.
137-3 Refer to responses 3-9 and 4-6.
137—4 Refer to response 4-15.
137-5 Refer to response 2-58.
137-6 Refer to responses 2-63.
137-7 Refer to response 2-46.
137-8 Foreyt (1989) held six bighorn sheep in captivity for over a year,
then introduced six clinically normal domestic sheep into a 5-acre (2
ha) pasture with the bighorn sheep. All bighorn sheep died within 71
days of initial contact with the domestic sheep. He concluded that
domestic sheep and bighorn sheep should not be managed in proximity
to each other because of the potential fatal consequences in bighorn
sheep. The area in question is not currently a domestic sheep
allotment; therefore, potential conflicts can be avoided by
continuing to license this area to cattle use.
Current practices of fencing reservoirs in an effort to control
livestock patterns in riparian areas should also be reviewed. Locations and
numbers of accessible routes around reservoirs should be reviewed to
improve the level of forage utilization, as well as to enhance and maintain
riparian areas to the greatest degree possible.
Finally, wc have serious concerns with the proposed prohibition
against changes in livestock classes to enhance Bighorn Sheep populations.
Appendix 11-136
use
Drewsey, Oregon
January 29, 1990
Jay Carlson
Bums District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hinea, Oregon 97738
Dear Mr. Carlson:
The letters from the Harney County Cattlewomen, Stockgrowers, Farm
Bureau, Sheep and Woolgrowers and Response to the Draft Three Rivers
Resource Management Plan and Environmental Impact Statement are
consistent with our views and comments.
.1.38-1 Refer Co response 2-63.
138-2 Refer Co response 4-15.
138-3 Refer to response 4-6.
138-4 Refer Co response 5-10 and Appendix 1, Table 4, Proposed Plan.
138-5 Refer Co response 2-87.
138-6 Refer to response 6-13.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of the texts only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations' letters.
Alternatives A, B and C will result in a substantial loss of bane property
values. The proposed BLM actions may result in reducing the size of many
ranching operations so that they will no longer be economical units.
Significant reduction of cattle grazing on public lands would be detrimental to
economic well-being of the families who earn their living from ranches that
have BLM grazing permits, the economy of Harney County, and all people
who provide services and goods to the ranchers affected. Therefore, we
request that if Alternatives A, B or C are considered, that prior to issuing the
Final Three Rivers Resource Management Plan and Environmental Impact
statement, a "Takings Implication Assessment" be completed as authorized by
Executive Order 12630 (see the November 8, 1988 Memorandum to all
Assistant Secretaries and Bureau Directors for Secretary of Interior, Donald P.
Hodel).
In regard to our particular Allotment the following issues are of
importance to us; The proposed Biacuitroot gathering area, the Sagegrouoo
Strutting Grounds and the exclusion of Cattle from Riparian areas and
reservoirs.
The proposed Biacuitroot Cultural ACEC has had cattle grazing In this
area for many years and there has been no adverse affect on the quality and
quantity of roots available.
On the subject of the Sagegrouse Strutting Grounds, cattle have no
adverse Impact on the strutting areas and should not be removed.
Removing cattle from the Riparian Areas, Little Pine Creek, is not
warranted because current grazing practices have no significant adverse
Impact on surface water quality.
Monitoring techniques currently in use on Three Rivers Resource Area
are insufficient, Inaccurate and are applied improperly to indefensible
conclusions. The techniques should be consistent throughout the entire study.
Until proper techniques and accurate information are gathered, existing levels
of livestock grazing should be maintained.
As regards the Pine Creek Material Site which is under lease to Harney
County, I believe that the site as now developed has little or no impact on the
Biscuitroot ACEC.
Thank you for your attention to these areas of concern.
Yours truly,
Pine Creek Ranch
Donald A. Dryer, Jr.
Appendix 11-137
February 2, 1990
Jay Carlson- RHF/EIS
Burns District Office
Bure»U of Land Management
1IC 74-12533 Highway 20 Vest
139-3
139-4
139-5
^.m
nin
OH.
RBVIEV COfflCEfflTS POB THE OCTOBEK 1909
BLK DRAFT THREE RIVERS RKTVEIS
Dear Kr. CARLSOH,
1 would at this time like to go on record as 0PPOSIHC the Draft Three
Rivwrs Resource Hana£enent Plan and Evironental Impact Statenent dated
October 19B9, especially the first three alternatives.
The overall Draft Is not based on any sour-: scientific information!
Excluding cows from riparian and aquatic areas will not enhunce the
envfroment, it will DESTROY it!
Leaving grass around riparian and aquatic areas will create a fire
hazard. The first heavy rain after a fire will trash ashes and lye into the
water, tilling all living things in it.
Tour first three alternatives will DESTROY the envlroment «ot save it.
Taking away any livestock AUKs or locking up any forest land in 30 to
60 acre parcels will adversely affect the economic stability of" the local
communities.
Closing and rehabilitating roads will cot only result in the local
residents losing the recreational opportunities, but will also curtail
tourism. Restricting travel only to main roads puts a heavy strain on
already crowded facilities-
Cattle do not conflict with wildlife.
VILD HORSES DO! !
Beef cows keep coyotes away from the vicinity of their calves,
consquent ly, protecting any wildlife in that area as well.
Vildborses are aggressive towards other animals including wildlife.
Please reoave the wild horses from our public land!
Do not take the cattle off of the biscuitroot areas! The grass will
coinpete with the biscuitroot plants and eventuallly crowd them out!
1 object specifically to the classification of unsatisfactory range
conditions, medium allotment potential, medium present productivity, medium
resource conflicts, and unsatisfactory present management on Davids
allotment #5215. These classifications do not coincide with the accurate
estimated capacity of 778 AUXs and average actual use of 451 on page 42 of
Volume II.
I wish to go on record that the views and comments of the Harney
County Stockgrowers dated January 19, 1990 and the January 17, 1990 Riddle
Ranch and Western Range Service comments and resjjonses to the Druft Three
Rivers RKP/EIS are consistent with my veiws and comments. 1 endorse the
Riddle Ranch document.
I ask that you leave all livestock allotments as they are.
LOO V. DAVIES
PO BOX 5
Princeton, OR.
(&W-U/. /Q c
The economic impacts section has been revised, see Chapter 3 of the
PRHP/FEIS.
139-2
139-3
139-4
139-5
Refer to res
onse 2-81.
The Wild and Free-Roaming Horse and Burro Act of 1971 mandates in
Section 1 of the Act that wild free-roaming horses and burros are to
be protected. Section 3 of the Act further provides for their
management on specific ranges. The BLM is not in a position to change
this law.
Refer to response 4-15.
Refer to responses 2-11 and 2-87.
02/14/90
MO
Bureau of Land Management
Attn: Craig M. Hansen and Joshua L Warburton
Bums District Office
HC 74-12533 HWY 20 West
Hines, Oregon 97738
Re: Draft Three River Resource Impact Statement
140-1 The five active HHAs in the RA are being equally protected under all
alternatives in this plan. There has been no proposed reductions or
increases in either the number of wild horses or size of the HMAs.
There are a Local of 19 active HMAa in eastern Oregon. Of these, 13
are managed by BLM and one is jointly managed by BLM and USDA-FS.
After reviewing the draft of the Three Rivers Resource Management
Plan/Environmental Impact Statement, alternative A is our recomendation.
PJr6Tt°~tn§~fa&nh"aT^ lancH
.use planning and environmental~anaiysis, leaving'only five'TH"MA1TTrrOr^on;>
we feel it is necessary to protect these few remaining areas; We' would'''
l.ijte to see the natural values emphasized", as in "alternative A.?
Please keep us updated on the progress of this RMP/EIS.
Sincoroly,
Barbara J. Rehfield
Executive Director
AMERICAN MUSTANG AND BURRO ASSOCIATION
P.O. BOX 7
BENTON CITY, WA 99320
(509) 588-6336
Appendix 11-138
141
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XfUl^cM^ org,!,*, 1«ft.-hf4 ^WZJ*^ . XI
/6' ^? £ qi
"Sft/i- J^d
^7
142
i)leM&&u
&i&ld ' @IcvmcA
v^
No comment identified.
Xhtwttvjf,, @*e&0H .97904
(503) 49X-2620
February 14, 1990
Jay Carlson, RMP/hUS
Burns District Office
Bureau of Land Management
HC 74-12533 Midway 20 West
Hines, OR 97738
Dear Mr. Carlson:
This will 3erve as a follow up to that certain letter of response
to the Draft Three Rivers Resource Management Plan and Environmental
Impact Statement dated January 28, 1989, signed by Patrick J. Wilber,
Wright Wilber and G. W. Wilber for Wilber Brothers.
The letter was incorrectly dated 1989, when, of course, it was
intended to read 1990. Please associate this follow up correspondence,
correcting the date, with the original response in your files.
Sincerely,
G. W. Wilber
For: Wilber Brothers
Patrick J. Wilber
Wright Wilber
Appendix 11-139
143
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f»j«
143-1 Refer Co response 13-7.
143-2 Refer co response 12-7.
143-3 Refer Lo response 13-11.
143-4 Refer to response 12-1.
143-5 Refer to response 2-78.
-2- -
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Appendix 11-140
SIERRA CLUB
Oregon Chapter
144
February 12, 1990
2743 SE 33rd Ave.
Portland, OR 97202
Mr. Joshua L. Warburton
District Manager, Burns District
Bureau of Land Management
HC 74-125 3 3
Highway 20 W.
Hines, Oregon 9773B
Dear Mr. Warburton:
144-1 Refer to responses 1-13 and 3-L3.
144-2 Refer to response 1-11.
144-3 Refer to response 12-7.
This letter is in response to the Draft Three Rivers Resource Manage-
ment Plan and Environmental Impact Statement of October, 1989.
First, we commend the efforts of the Bureau's staff to incorporate the
concepts of multiple use, sustainability, and diversity. Soil condition,
wetland, riparian and aquatic habitat condition, archaelogical sites,
scientific values, wild and scenic rivers, special status species, and
other resources all received attention in the draft Plan. It is encour-
aging to conservationists, whose interests on public lands are affected
by the actions of the managing agency, that the mandates of the Federal
Land Policy and Management Act are being addressed.
An example of this is the 11% reduction in active preference AUMs in the
preferred alternative during the first five years of implementation of
the Plan as shown in Table 4.6. This, plus the exclusion of livestock
from certain reservoirs, would promote improvement of water quality, a
vital concern to environmentalists. Other examples include reductions
in grazing in areas with severe erosion problems, elimination of grazing
in a number of Resource Natural Areas and Areas of Critical Environmental
Concern, and incorporating threatened and endangered species ' habitat
needs into grazing systems.
These and other components of the preferred alternative are to be applauded,
and we strongly support them. Nevertheless, given that 96.8% of the land
covered by this Plan is grazed, it is clear that one resource, one use,
remains overwhelmingly dominant. And a closer examination of the Plan's
preferred alternative is disturbing. For example, a 7.7% increase in
active preference AUMs will occur after the initial five-year 11% reduction
in active preference AUMs. Although the Plan would limit grazing to
certain levels, the document itself states that even under the "most
favorable management," full recovery "may require many years in some cases."
:nJoy and preserve the nation's forests, waters. wUdllfe. and wilderness ,
Mr. Joshua L. warburton
February 12, 1990
page two
Livestock grazing degrades the ecological and esthetic conditions of
water sources, soils, and vegetation. The baseline levels of several
resources addressed by the Plan show clear evidence of the deleterious
effects of grazing. For example, only 1% of surface water is in'good'
condition; none is classed as 'excellent.' Nor are any of the area's
streams considered to be in 'good' or 'excellent' condition. Streamside
riparian, aquatic, and wetland habitat all show similar degraded conditions
So, why allow cows back when the areas grazed will likely never fully re-
cover? Furthermore, the final AUM level projected far 10 years, 162,145
AUMs total, is only 2500 short of the proposed level of Alternative E,
the alternative that emphasizes commodity production. What does this
communicate about the commitment to multiple use and natural values'.1
Also Of concern are projections in the Summary cf Potential Projects in
Table 4.9. In the preferred alternative, a number of projects will be
implemented to support grazing. Among these are 203 miles of fence,
1000 acres of juniper control, 83 miles of pipelines, 96 reservoirs, and
nearly 47,000 acres Of plant aeedings, presumably crested wheatgrass, a
non-native plant. Monoculture plantings do nothing to promote biological
diversity; they merely provide cow habitat and favor single, rather than
multiple, use of public land. We urge the use of seeding, where necessary,
with a variety of native plants instead. Furthermore, there is no indi-
cation o£ how much these projects, which exist only to benefit grazing
interests, could cost the taxpayers.
Clearly, the Bureau can envision a world in which i
emphdisi^ed. Alternative A of the Plan does this mi
Preferred Alternative. The High Desert Wilderness
implementation of Alternative A, in order to promo
of these lands. We urge the Bureau to continue to
beyond the traditional usi
livestock is not all that
of the Ian'
looking towards
the range .
ich better than the
Committee supports the
:e the ecological health
rut'
i which
Thank you for your attention.
Sincerely, ?
Mary L. Garrard, Chair
Grazing committee. High Desert.
cc; Mr. Dean Bibles
Governor Neil Goldschmidt
Congressional Delegation
Environmental Groups
Appendix 11-141
February 12, 1990
145
Jay Carlson. Planning Team Leader
Bureau of Land Management
HC 74-12533 Hwy 20 West
Hines, OR 97738
Dear Mr. Carls
Thank you for the opportunity to review and comment on the
draft Three Rivera Resource Management Plan and
Environmental Impact Statement, We have the following
general and specific comments:
Text page 2.3:
The Plan states that monitoring will be accomplished to
determine the success of the RMP. Yet, no where in the Plan
is there a summary of actions, management, and monitoring
accomplished since the Riley RPS which would establish a
need to change the Implementation of the original Riley RPS.
The Riley RPS decisions were intended to be Implemented over
a ten-year period, followed by a fifteen-year period in
which the benefits of that plan would be realized. Leas
than seven years later , before full impl ementat ion of the
original plan, the BLM is essentially abandoning its
proposal of 19G2 upon which It has presumably Invested
considerable time and monies, and proposing actions which
are drastic deviations from those of the original plan. We
will appreciate a full accounting of the management systems
implemented or improved since 1982, and the range
improvements (spring developments, miles of pipeline, wells,
reservoirs, acres of burns {discounting wildfires], sprays
and seeding) then planned and those actually accomplished.
The BLM now proposes, as a result of actual implementation
of the 1982 proposed actions lagging behind that projected
at the time, to instead make wholesale livestock reductions
and eliminations as a cure-all for perceived, mostly
unverified and undocumented "problems" within the Resource
Area. Such a broad-brush approach is contrary to applicable
laws and regulations governing the BLM in its treatment of
individual permi ttees.
Tattle 1 (appendix page3 1-1
Text page 3-2 and Appendix
and 1-2) I
Tha table doe3 not quantify water quality at all, but glvea
a summary of a subjective evaluation of condition and trend.
can . occur In the resource area or in a part icul ar
allotment, since it includes areas that will forever
"need" forage production improvement and never be able
ace amp 1 ish that objective because of their basic soi 1
nake
jp.
With no ecological site inventory and condiition
classification, It is impossible for the BLM to assert
e i ther an a I lotment potential <even in such amorphous
terms as "High, Medium, Low") and the Present Productivity
as compared to it. Lacking this data for the resource
area, and by specific allotment and areas within each
allotment, the BLM has no rational basis far a value
judgement of present productivity versus potential
productivity, and Table 3-1 is both erroneous and
misleading to the general public who would rely upon it
for their review of the need for management changes.
Specifically, the West Sagehen Allotment contains at least
two (possibl y as many as four) distinct ecological range
sites, with vastly different potential to produce forage
even in climax ecological condition. The Hat Butte
Allotment likewise contains at least two, and possibly
more, distinct ecological range sites, with different
potentials to produce forage.
Resource conflicts In the West Sagehen Allotment are
listed as "medium", and in the Hat Butte Allotment as
"high". As compared to what, and by' what paramenters of
measure? Controversy is listed as "high" In both
allotments. To our knowledge there has been no public
controversy concerning the West Sagehen Allotment or the
Hat Butte Allotment. What is the basis of this statement?
Present management in the West Sagehen Allotment is listed
in Table 3-1 as unsatisfactory. A recent BLM evaluation
11 ota the management system as satisfactory. We believe
management will be Improved in the future by
every-other-year deferment rather than using the some
pasture twice in a row in the growing period, and that
development of waters and fencing of reservoir sites, as
we have proposed to the BLM, are further improvements
which can be accomplished under the continued development
of management called for in the Riley EIS (the No Action
Alternative of the Plan).
Present management in the Hat Butte Allotment Is listed in
Table 3-1 as satisfactory, even though the same table
lists the conflict and controversy as high. While we
agree that present management is for the most part
satisfactory (with further improvements possible), the
table io self-contradictory.
Does specific data exist which lists water temperatures,
turbidity, saltation, etc. for the 1 Isted waters, and which
establishes a trend by repeated observations over several
years? If so, Appendix Table 1-1 should list specific
factors and assess them against state water quality
standards that apply for specific waters <not all standards
apply to all bodies of water), and then include objective,
specific assessment of factors, both natural and man-made,
which prevent the attainment of those standards.
Prudent Investor's Willingness to Invest is listed as
"maybe". We are not sure of how the BLM deflneo a prudent
investor, nor if we are one, but Meadow Creek Enterprises
has requested for several years to invest in water
facilities which would improve livestock distribution and
provide wildlife waters within the West Sagehen Allotment.
These requests have been both for cooperative funding of
the projects with BLM, and more recently under Section -4
authorisation requests.
Text page 3-3:
As stated on this page, the parameters of Soil Surface
Factor do not separate natural levels of soil erosion from
"unnatural" or accelerated levels. The BLM cannot use these
figures as justification for decisions to adjust livestock
stocking level s, or to support the conclusion that adjust ing
utilization percentages, or reducing or eliminating
livestock from given areas, will result in lessened sediment
yields Of erosion. No baseline data exists to even suggest
that any accelerated erosion is occuring in the Resource
Area.
Text page 3-12:
How many grazing systems have been Implemented to date,
compared with those proposed in the Drewsey and Riley EIS
and John Day RMP? The Riley EIS predicted that
implementation of management systems would realize benefits
In the fifteen years fol lowing implementation of management
systems. That time span and the benefits to be derived have
been ignored in the present Plan, and monitoring and
evaluation which would assess those benefits have obviously
not been c omp 1 e t e d ,
Text page 3-16 and Appendix 3:
1. Table 3-1 (appendix page 3-3 and 3-4):
To our knowledge, the BLM has completed no ecological site
Inventory or range condition classification based upon
ecological potential of the range. This Is specifically
true of the West Sagehen Allotment (7023) and Hat Butte
Allotment (7007), and we believe of the entire Resource
Area. Areas of naturally low production because of soil
factors , depth to restrict ive 1 ayers, rocki ness, etc. wl 1 1
forever be "unsatisfactory" from the standpoint of forage
production surveys. We believe Table 3-1 to be a summary
of forage production rather than range condi tlon on the
basis of potential. If so, It is an unreliable measure of
the amount or degree of " Improvement" that ncedo to, or
2. Table 3-2 (appendix page 3-7):
This table lists the grazing treatment in the Hat Butte
Allotment as "Season-long". The treatment in this
allotment is an early grazing treatment and a deferred
grazing treatment. No season-long grazing occurs in
either of the main pastures of the allotment.
This table also lists one type of treatment used in the
West Sagehen Allotment as " Ear I y-bef ore growing season",
which is defined as "use before the growing season".
Table 1-4 of the 1982 EIS lists all major forage
components of West Sagehen Allotment as initiating growth
prior to or by April 1. (The exception is bitterbruoh,
which is a minor vegetation component In a portion of the
allotment.) Authorized use of the West Sagehen Allotment
begins April 1 on only half of the allotment, well after
the majority of forage species have initiated growth. The
other half is deferred until after seedripe of the key
forage species. No "early" use, as defined by this table,
occurs in this allotment.
3. Table 3-6 (Appendix page 3-17);
Wc3t Sagehen Allotment is one of the IS allotments which
has supposedly had Carrying Capacity determined. The BLM
has erred in numerous and significant ways in their
assessment of the West Sagehen Allotment Carrying
Capacity, including the oversampling of areas within close
proximity to waters, inconsistent and erroneous
computation of forage utilization, improper and inaccurate
"adjustment" (i.e. artificial and unwarrented
manipulation) of utilization data, and ascribing all
utilization tc livestock while significant wildlife
numbers have also contributed to that utilization. These
errors have certainly led to erroneous conclusions about
the West Sagehen Allotent, and if they are repeated on the
other 17 allotments where "Carrying Capacity" has been
"determined", the figures for those allotments can be
nothing but suspect.
Appendix 11-142
145-14 8 The "Estimated Capacity" figure used for all the other
allotments of the Resource Area, including Hat Butte
Allotment, no doubt contains the same errors.
Appendix pages 3-120 and 3-137 purport the calculated
grazing capacity of the Hat Butte Allotment and the West
Sagehen Allotment to be lower than the active preference
and less than the forage demand. Range studies conducted
by Meadow Creek Enterprises in 1989, and those of the SLM
prior to and Including 1989 do not support these
statements. The BLM'3 proposed management objectives to
allocate forage in priority to wildlife imply an
understanding of the overlap of diets of each wildlife
species and livestock. This dietary overlap is not a set
figure, as is Implied throughout the Plan, but is highly
dependent on the type and variety of forage species
present, the stage of growth and maturity of the
vegetation species, relative abundance of preferred
species, preference displayed by each of the grazing
species, and season of the year. Dietary agmpetl USD.
depends not only on dietary overlap, but also on the
premise that the components of the diet are lacking or in
"short supply compared to demand, and further on the
spatial and temporal sharing of the habitat by the two
species. Lacking this specific information by allotment
and season, the BLM has no Justification for assuming that
wildlife use in the same vicinity as livestock use
automatically constitutes either a conflict or
competition, or that "livestock forage" should be deducted
from the estimated or calculated capacity o£ the range to
the detriment of livestock grazing.
The BLM has specifically failed to account for wildlife
use (AUM'sJ in its calculation of "carrying capacity" on
the West Sagehen Allotment and the Hat Butte Allotment,
and the wildlife use Is Included in the total utilization
being read on the allotment, the proposed Plan would then
further deduct a predicted wildlife forage demand from the
figure which already includes consumption of forage by the
wildlife on the allotments. This application is erroneous
In the West Sagehen Allotment, In the Hat Butte Allotment,
and in the Resource Area as a whole.
Appendix pages 3-120 and 3-137 list the livestock forage
condition on the Hat Butte Allotment and the West Sagehen
Allotment as unsatisfactory. This statement implies a
comparison of present production of forage to the
potential production under climax ecological conditions.
Lacking an ecological site Inventory and a range condition
classification based upon the ecological potential of the
range, the BLM lacks the information to make such
comparison. The fact that areas of the allotments produce
less forage than other areas within and without the
allotments Is moot as a conflict, since those arcan
prompt the BLM to further reduce livestock grazing, to the
detriment of the livestock permittees of the allotment.
We are opposed to this action and will view such action a3
a taking under Executive Order 12630 and demand
restitution of loss of grazing revenue and value to the
ranch should this proposal be implemented.
Appendix page 3-138 proposes to allocate forage to elk in
the West Sagehen Allotment. If elk have begun using this
area, they have done so under the current grazing
conditions, and despite any "conflicts" which the BLM may
believe exist. Were the forage and habitat not currently
available to support the animals which are purported to be
using the allotment, they would be unable to do so. If
the BLM wishes to allocate forage to elk, it must also
assess the amount of forage which the elk have been
consuming in the time they have been using the allotment.
Since this forage demand has been included or ignored in
the BLM's monitoring (utilization) studies, the future
allocation and present conyumptlon by elk must logically
be oft-setting. No basis exists for a reduction of
livestock use as a result of this "allocation".
Appendix page 3-133 lists as a conflict on the West
Sagehen Allotment the presence of special status species
and their habitats, and proposes to prevent significant
risk to the well-being of special status species. First
of fell * the presence of one or more particular species In
an area which also contains other species, be they
livestock. Other wildlife, or other vegetation, does not
In itself constitute a conflict. To our know! edge, _ no
Information exists which supports the notion that wildlife
grazing, livestock grazing, or the growth of other
vegetation on this allotment constitute risk to the
well-being of cither sagegrouse or Cusick's buckwheat. We
believe that the habitat requirements of neither is
threatened or put to significant risk by continuation of
the present management of the al lament. A recent BLM
evaluation of this allotment contained no data which
supports a supposition opposite to our3.
Table 3-7 (appendix page 3-175):
4.
All alternatives create big game forage demand in the West
Sagehen Allotment by creating water sources accessible
only to big game species in areas which do not presently
support those species in significant numbers. BLM
proposes to decrease livestock use while increasing big
game demand for forage, which we view aa unfair and
Incongrous, and as a taking action under E0 12630. This
table is also In error in that the No Action Alternative
(Alt. D) would, according to text page 2-2, consist of the
present management as proposed in the 1982 Riley EI5.
producing less forage are not capable of producing great
quantities of forage, nor will they ever be capable Of
significant change, due solely to the nature of the soils
which define them.
Appendix pages 3-120 and 3-137 list as a conflict in the
Hat Butte Allotment and the West Sagehen Allotment
"detrimental" use distribution. No data exists to support
the statement that the use patterns encountered In the
allotments have been detrimental to either the range
resource or any other renewable or non-renewable resource.
The BLM's proposed management objective is listed in this
table as Improving livestock distribution, yet no where In
this Plan is there any proposal to install the water
facilities necessary to accomplish the objective
(reference Appendix Table 3-7, pages 3-174 arid 3-175).
The BLM has not matched its stated objective to a
management proposal which will accomplish the objective.
Meadow Creek Enterprises has requested for at least three
years the development of wells on the West Sagehen
Allotment to accomplish this objective, with no response
to date, either in funding or In planning, from the BLM.
Additional water sources would also be beneficial on the
Hat Butte Allotment, other than the sole reservoir
proposed.
Appendix page 3-120 lists as a conflict/concern on the Hat
Butte Allotment "active erosion occurs on the allotment".
Map S-2 (text page 3-9>, however, lists the erosion
classes on this allotment as "Stable" and "Slight". Text
page 3-3 obviates the fact that BLM cannot distinguish
this "active erosion" as being natural or accelerated.
Listing it as a conflict/concern, considering the
contradictions self-contained in this RMP, Is illogical
and unfounded.
Appendix page 3-137 lists as a conflict/concern on the
West Sagehen Al lotment " no management system" . Appendix
page 3-10, however, lists "GS" (Grazing System) as being
Implemented on the allotment since 1978, and appendix page
3-7 lists this grazing system as a "DR" (Deferred
Rotation). Appendix pages 3-7 and 3-10 are correct;
appendix page 3-137 is not.
Appendix pages 3-120 and 3-137 lists big game habitat on
the Hat Butte Allotment and the West Sagehen Allotment in
unsatisfactory condition, implying that a conflict with
livestock grazing Is occurlng on the allotment. No data
exists to support this implication. The BLM proposes on
page 3-175 to install big game guzzlers in the West
Sagehen Allotment, which we assume Is the proposed action
to satisfy this objective. The effect of the proposal to
Install guzzlers Is to create additional big game forage
demand where it does not currently exist, which will
That document did not incl ude provisions for the
development of big game guzzlers in this allotmen
Text page 3-24:
Western sage grouse are currently sport-hunted in the state
of Oregon. It seems incongruous and arbitrary for the
species to be the subject of "special status" designation
and to be a Federal Candidate for listing a3 threatened or
endangered when it is subject to harvest by hunting. The
BLM has also identified 54 specific sagegrouse strutting
grounds covering the length and bredth of the Resource . Area.
Nn doubt many, many more exist which have not been
ident i f ied. The fact that sagegrouse exist in such numbers
within the Resource Area testifies ta their ability to
co-exist with the present management in place In the
Resource Area-
Text page 3-26:
"Future demands" by wildlife implies management for
maximizing wildlife use which does not 'current ly exist, and
the proposed actions include restrictions to livestock use
on the basis of predictions of a future demand which does
not exist and cannot be accurately predicted. If the phrase
"future demands" means those which currently exist and It is
predicted they will continue into the future, then It seems
obvious that the current and future demands are already
being met, since the wildlife already are satisfying their
demand for forage.
Table 1 & 2 (appendix page
Text page 3-27 and Appendix 6,
5-1 ,2,3):
Table 6-2 contains very specific parameters cone
rating of aquatic habitat, but the values of thO:
parameters are not listed In Table 6-1. Have th
parameters been applied to all of the listed aqu
environments listed in Table 6-17 Where they ha
specific values should be listed. Where repeate
measurements have not been taken over time , no t
aquat ic env ironment , or any other environment , c
assessed. If repeated monitoring of the listed
water have taken pi ace , the val ues <rel at ive or
measurements) should be listed to establish the
trend attributed to the waters In Table 6-1,
ernlng the
se
e specific
at ic
ve been , th
d
rend of the
an be
bodies of
absolute
long term
Appendix 11-143
Text page 3-2? and Appendix S, Table 2 (appendix page 5-8) :
We assume the trend reported in Table 3-10 on page 3-27 and
in Appendix Table S-2 are a result of monitoring repeated
over time on the aquatic and riparian areas. Please list
specific data parameters and their respective readings over
time which culminate in the conclusions of trend listed in
these tables. Have these parameters over time undergone^
statistical analysis to avoid conclusions based on sampling
error or sampler bias?
Text page 3-27 and Appendix S, Table 3 (appendix page 5-9) :
Wetlands are defined in the Plan as a combination of the
water-covered acreage and the vegetation surrounding those
waters. No parameters of measurement of condition or trend
are listed in the Plan, and the measurement of condition of
the two components must necessarily be different. Lacking
cl assif icat ion of the range sites surrounding the particular
waters and lacking water quality analysis, there can be no
scientific or management basl3 for the assignment of
condition and trend listed in these pages. Lacking repeated
measurements of measureable parameters, there can be no
basis in assigning a trend of the condition of the
particular parameters. If these parameters exist and have
been measured over time, they should be included in this
document. The presence of livestock and different species
of wildlife obviously does not constitute a conflict by the
mere presence of the different species.
Text page 3-31 (Map WL-1):
This map shows deer winter use in a portion of Vest Sagehen
Allotment dominated by low sagebrush. If deer are dependent
upon big sagebrush for winter thermal and escape cover, this
pairing of low-sagebrush dominated range with wintering deer
la not likely. If deer really are wintering on this area,
the fact serves to prove deer do not require the presence of
big sagebrush to overwinter, and the restrictions placed on
management of big sagebrush in the Plan are overly
restrictive and prohibitive. The Plan also contains no
assessment of potential damage by wildlife species to
special status wildlife species or to special status
vegetation species which occupy the same habitat.
Text page 3-32 <Map WL-2>i
This map shows elk winter range In the same ares of deer
summer range Indicated on Map WL-1 in the West Sagehen
Allotment. The Plan contains no assessment of wildlife
interspecific competition. Other than general areas
proposed to drastically change management direction. This
assumption cannot be considered a valid one in light of the
BLM's change-at-a-whlm proposals contained in this Plan.
Text page 4-3 (WATER QUALITY):
Alternatives A - C:
The 1982 EI5, page 2-5, states that sediment yields are low
in the EIS area and that erosion on upland areas Is
generally law, and that instream water quality is generally
high, except for problems associated with diminishing flows
and unshaded streams. It also states that most of the
streams In the EIS area are Intermittent and flow only as a
result of snowmolt or rainfall in which the intensity
exceeds the capability of the soil to abaorb water. The 1982
EIS also states at page 3-9 that most of the runoff In the
EIS area occurs during snowmelt and that no expectation
existed that any change to the normal runoff would occur as
a result of any of the alternatives.
This is in direct conflict with the predictions contained in
these sections of the current Draft RMP/EIS. If the BLM has
monitoring data which indicates the former Impact Statement
was in error, those data should be discussed and presented
in this Plan. This Plan itself states that no
differentiation can be made between naturally occuring
erosion and accelerated erosion In the area for which it is
written. Lacking such data, and lacking proper and
site-specific research which supports the notion that
removal of livestock from streams and 30% utilization of
upland forage species will have the predicted effect on
water quality, the BLM has no basis for presenting such a
cone luslon .
The mere presence of livestock, unless shown by adequate
data, cannot in and of itself be construed as ihs, source, or
even a. source of "poor water quality". Where specific
parameters of "poor water quality" are attributable to
livestock through reliable monitoring, the specific problem
can be rectified through specific caae-by-case prescriptions
under provisions of the No Action Alternative (continued
Imp I ementat ion of management systems) .
A large majority of western streams are steep, narrow, and
rocky, and do not have the potential for overhanging banks
and meadows adjacent to the stream; most, as stated in the
1982 EIS, are intermittent. Assessment of the individual
traits of particular streams under the No Action Alternative
(continued implementation of the 1962 RPS) would accomplish
necessary site-specific analysis to analyze and implement
needed actions on a case-by-case basis, and would avoid tho
supplied tha BLM by Oregon Department of Fish and Wildlife,
what is the specific source of data for designating the
areas as they have been designated — pellet group counts?
aerial counts during winter? We believe the BLM is
obligated to verify information supplied by any single-use
group, including ODFS.W, which it uses to formulate proposals
which affect the other multiple uses of the federal lands.
Text page 4-2:
The text defines short-term vs. long-term impacts of the
various alternatives. BLM has not completed the short-term
implementation of the proposed action of 1982, let alone
realized the benefits which were to accrue in the ensuing l*
years following implementation of the proposed action. The
BLM is now proposing changes to systems and management
parameters without benefit of the knowledge of Impacts of
the proposed action and ongoing management implemented Since
1982.
Text page 4-2 (Assumptions);
1. Funding and personnel will be available -- The Plan
contains no analysis of implementation of the 1982 EIS to
enable the reader to know the viability of this assumption.
The "need" for this RMP is stated to be that the last one
was not implemented on schedule, and there is contained in
this RMP no assessment of the annual ability of BLM to
perform range projects it states will be accomplished in the
short term. The 1982 EIS proposed action included many
miles of riparian fence, acres of brush control, seeding,
etO.I how many of each has been accomplished other than in
wildfire situations since 1982?. How many annual dollars
and how many people will be required for each alternative in
the present Plan? The Plan contains no "cash flow"
prediction upon which the reader can depend to assess the
reliability of the assumption, and therefore the reliability
of the predictions of implementation of management and
impacts.
2. Monitoring studies. We have previously mentioned the
lack of proper and thorough monitoring studies, particularly
on the Hat Butte Allotment and the West Sagehen Allotment.
There also exists a lack of appropriate and accurate
monitoring studies, such as determination of accelerated
versus natural erosion, to rely upon the veracity of this
Plan.
3. The RMP is to remain in effect for 10-1S years. The BLM
has not allowed the full implementation, even if delayed, of
lt» 1982 RPS, and the long-term changes predicted in the EIS
have not had sufficient time to occur before the BLM has
broad-stroke generalizations and erroneous conclusions
contained in Alternatives A-C of this Plan.
145-45 I Siltatlon Is a natural process which eventually fills all
lakes and reservoirs. No stated sources of pollution
(siltation) are listed in the RMP, and this proposal Is
based soley on supposition and anti-grazing biases.
145-46 I We know of no research which supports the proposed removals
I or restriction of utilization levels on the basis of
I Improvement of water quality. We request all such slte-
I specific data and research literature which the BLM has
I depended upon for the conclusions contained in this Plan.
The position taken by the BLM in the present Plan is in
direct contrast to that taken in the 1982 EIS. Lacking
information to the contrary, the BLM has no basis upon which
to doubt the validity of its former Impact Statement. The
fact that utilization may be heavy around a water source
does not automatically prove that either accelerated upland
erosion is occuring, nor that lighter or no utilization
around the water source would prevent or reduce siltatlon of
reservoirs, nor that areas of increased vegetative cover
around water sources would be sufficient to prevent erosion,
if occuring, from entering the reservoir. Nothing in the
current EIS analyzes these factors, and they are presented
as foregone conclusions-
Text page 4-7 (SOILS):
Al ternat Ives A~C=
There exists absolutely no scientific or management basis
for the 30% utilization levels proposed under alternatives
A, B, and C. The BLM has stated in this Plan that
separate natural erosion from accelerated erosion wicn lis
current monitoring data concerning soils. It stated in the
1982 EIS that erosion on uplands is generally low, as are
sediment yields (page 2-5 of the Riley EIS). Considering
the lack of monitoring data and research which would support
the need for implementation of the proposed utilization
levels, and considering that the BLM now speculates that
these am£X" decrease sediment yields, reduce headcutting,
and lower the amount of sediment delivered to streams, these
proposals can be considered nothing but arbitrary and
unfounded.
Again, the document contains no supporting information to
lead to the conclusion that accelerated erosion Is occuring
any where in the Resource Area. The Plan explicitly states
that no differentiation can be determined by the BLM between
natural and accelerated erosion with the data now in hand,
annot
Appendix 11-144
and there can be no reasonable prediction that "accelerated
sail erosion would decrease significantly."
the No Action Alternative (1982 preferred alternatives
provides the BLH with the ability to make specific
adjustments to specific caso-by-case problem areas to
correct the specific problems, and the same opportunity
applies to Alternative E, Neither of these alternatives is
a wholesale "rape and ruin" alternative, as ia implied In
the analysis. If the Assumptions contained in this Plan are
to be accepted, then one ha.3 to assume that management
manpower would be committed, and MONITORING would be
conducted, to assess real damage occuring, and correct
specific problems. The statement that these alternatives
have the "potential" to decrease soil stability is an
amorphous Indictment of livestock grazing and commodity
production without specific proofs. The BLM lacks data of
an accuracy to support the cone 1 us ion that under these
alternatives soil conditions you 1 d decrease in many
areas, This generalized statement can be made for each and
every alternative. Provisions of laws governing the
management of BLM-administered J ands under the preferred
alternative of the 1982 EIS (Alternative D in this Plan)
allow the BLM to make corrections of site-specific
management deficiencies where identified by reliable
information .
Text page 4-9 (LIVESTOCK GRAZING):
The Plan contains no economic analysis of the al ternat lves_
and, considering the implications of Alternatives A-C, ia in
violation of the President's Executive Order 12630, which
requires an economic implications assessment of all takings
actions by the federal government. Considering the lack of
data which would support the "need" to impose both livestock
exc lusi on and 1 i mi tat ion of grazing ut i 1 ization to the
stated levels, these alternatives are entirely unacceptable.
Alternative A would decrease the stocking level of BLM
administered lands by 13,654 Animal Units, assuming a
current 7-month authorization. Assuming a $125/Animal Unit
annual opperating cost, this represents an annual revenue
loss of 51,706,750 to the area affected by the Plan. These
operating costs are monies spent by ranchers which go
directly to the communities in the form of taxes, vet fees,
purchase of food and supplies, machinery purchases, and the
like. In the five year timeframe of Table 4.4 <page 4-95,
this represents a loss to the area of at least $8,533,750-
This figure, of course, does not represent the total loss to
the communities because of the symbiotic, or "trickle down"
nature of this monetary f 1 ow. A recent economic cot I mate is
Text page 4-19 (VEGETATION):
The assumption has to be that only low forage-producing
(i.e. "poor condition") ranges with potential to respond
would be treated or seeded under any alternative which
includes brush control and vegetation manipulation
proposals. This would obviously include historically
degraded range sites with poor diversity at present. The
1982 EIS predicted that such projects would be beneficial t
both wildlife and livestock due to both more forage
production and the establishment of perennial forage which
would be available during times of fall and spring green-up
for wildlife needs.
Text page 4-20. (WILDLIFE):
Al 1 Al ternatlveg:
If the proposed livestock reductions are implemented under
Alternatives A-C, the "allocation" of AUM's to wildlife is
both unnecessary and moot- We repeat our earlier
observations concerning the BLM's failure to account for
wildlife use and its effect upon range utilization in their
present monitoring data, and the resultant double-allocation
these proposals represent.
The active and agressive suppression of wildfire in wildlife
habitat leads to a stagnation of sagebrush overstory, with
resultant decline in understory forage species. This will
obviously lead to a decline in vegetation diversity. Fire
is a natural component of the ecology of western ranges, and
such fact needs to be assessed In this Plan. The historic
aggressive suppression of wildfires In Yellowstone Park, the
resultant build-up of fuels, and the ensuing conflagration
in the mid-1980's should serve as notice of this fact.
abaessible only to big
e where It does not now
environment. The BLM's
k, or reduce 1 ivestock
ition for forage places
ng a demand, then taking
that demand. This Is in
ained Yield Act. It Is
dent's Executive Order
will seek to recoup from
losses and the loss in
d this proposal be
The installation of water facilities
game will create a demand by wlldllf
exist due to natural factors of the
stated proposal to exclude, eliminat
grazing in areas of perceived compet
them In the position of first creati
of grazing authorization because of
violation of the Multiple Use / Sust
also a taking action under the Presi
12630, and Meadow Creek Enterprises
the federal government its monetary
value of the ranch properties, shoul
imp! emented.
The installation or development of waters which are
accessible to both livestock and wildlife, however, benefits
both, and is in conformance with the principles of multiple
that each AUM of federal range grazing has a total annual
value of ©484 to the local economy of small communities such
as exist in the area affected by this Plan. Application at
this value would predict a loss to the local area affected
by this Plan of $46,261,204.
Alternative B equates to a loss of 7,286 AU's, with a
5910,750 annual loss to the area of the RMP, at the
simplistic value of *12S per AU. This Is a loss of
34,553,750 over five years. With a value of $484 per AUM to
the local communities'' economies, this represents a
potential loss of $24,664,000.
Alternative C would cost the area 4,134 AU's at a simplistic
value of $516,750 annual loss of revenue, or $2, 583, 750 over
five years. With a value of $484 per AUM to the local
communities' economies, this represents a potential loss of
$14,005,508. This figure further represents only the loss
to the communities as a result of excluding livestock from
areas with streams. A further and significant loss of
revenue would result from the imposition of 30% utilization
levels.
Alternative D would result In an eventual increase of 1536
AU's with an annual (slmpl 1st ioal ly valued) benefit of
S192.000 annual gain in the economies of local areas. With
a value of $484 per AUM to the local communities' economies,
this represents a potential net benefit of $5,203,000.
Furthermore, the BLM's assessment In 1992 and in the present
Plan lo that forage demands for total grazing preference can
be met in the No Action Alternative.
If range improvements would be 1 iml ted" under alternative D
to those listed in Riley EIS, then no guzzlers will be
developed, and no brush control or Juniper control would be
accomplished in the West Sagehen Allotment, since no range
improvements were listed for that allotment in the Riley
EIS. Likewise, no brush control or seeding would be
accomplished In the Hat Butte Allotment. The statement In
this Plan assumes that all possible range improvements were
identified in the Riley EIS; they have not been, and Meadow
Cresk Enterprises has requested the construction of wells to
accompl ish the better distribution of 11 vestock .
Alternative E would result in an eventual increase of 2857
AU's with an annual (simpl ist leal l y valued) benefit of
$357,125 annual gain in the economies of local areas. With
a value of $484 per AUM to the local communities' economies,
this represents a potential net benefit of $9,680,000.
| use
and sustained yield. Where the opportunities exist to
benefit both livestock and wildlife. Meadow Creek
Enterprises supports proposals to Implement such water
devel opment .
This document contains no data or analysis which would
support the BLM's conclusions regarding the benefits of
alternatives to mule deer and elk habitat. Other than
supposition and an apparent and unfounded attitude by the
BLM that removal or reduction of livestock MUST be
beneficial, there exists no basis for these conclusions.
Without a determination of antelope habitat condition, there
can be no basis In fact for the conclusions that any of the
alternatives would result in beneficial impact to antelope
habitat. For all the BLM knows, antelope habitat may be in
the best condition it has ever been and may be the best it
can ever be.
Text page 4-24 (AQUATIC HABITAT):
The BLM has insufficient data to conclude that any of the
proposed alternatives, particularly Alternatives A-C, will
reduce sediment loads and water temperatures in streams as a
resu It of 1 i ve stock removal or reduct ion of ut i 1 i sat ion
levels. No foundation has been laid to believe that
sediment loads are anything but the result of normal
erosion. The BLM's data on erosion cannot separate normal
erosion from accelerated erosion, and the Plan presents no
evidence of monitoring which supports the claim.
No data which the BLM has revealed in this RMP/EIS supports
cither the claim that livestock use ha3 accelerated erosion
losses above the normal levels, nor that that use has
resulted in above-normal ailtation or turbidity of the
specified reservoirs, lakes, springs, and ponds. No data is
presented in this plan which supports the conclusion that
l ivestock use is reaul t i ng in degredat ion of vegetat ion
strips around the specified areas, or that removal of
livestock from around the specified areas would have the
stated effects. Turbidity is the result not only of wave
act ion agai nst shore 1 ines, but al so windbl own dust , common
and normal in the cold desert regime. It is also abundantly
obvious to the most casual of observers that reservoirs,
ponds, lakes, and playas for the most part contain bottoms
which are DIRT. Currents, whether created by wave action,
thermal churning, or stream tributaries, turn this dirt and
stir up the bottom sediments, creating turbidity.
Appendix 11-145
145-1
145-2
145-3
145-5
145-6
145-7
145-8
Refer to response 5-17.
Refer to response 2-17.
Table 3.1, Water Quality, in Volume I of the DRMP/DEIS was derived
from data collected by the BLM and information published by DEQ for
stream condition in the RA (refer to response 2-25). The BLM does
maintain files with water quality, macroinvertebrate, fish population
and aquatic habitat data for streams in the RA. Trend information was
derived from repeated field monitoring of waters in the RA.
The soils information provided in the DRMP/DEIS was not used to
adjust stocking levels. Adjustments are made on an allotment by
allotment basis using information from allotment evaluations. These
evaluations assess whether site objectives are being met, then
stocking levels are adjusted if needed. Vegetative indicators are the
primary parameters used to assess the success of management actions,
unless specific soils problems are identified as a management concern
on an allotment.
There are many scientific studies which indicate that accelerated
runoff and erosion are related to grazing intensity (Heede 1977,
Gifford and Hawkins 1978, Lusby 1979). Increases in runoff and
erosion can also be attributed to other human activities such as
roads, off-road vehicle use, logging and mining activity.
See pp. 3-12-16 and Appendix 3, Table 3, DRMP/DEIS.
Refer to responses 2-6, 2-10, 2-11, 4-3 and 131-1.
Refer to response 131-1.
The management system which Is listed as unsatisfactory is the 2-year
In a row system which is listed as the official system. The area
manager's recommendation Is that an annual graze/defer system will be
more satisfactory. Site-specific information is analyzed In the
allotment evaluation. Refer to response 2-11.
Refer to response 131-1. The present management criteria deals with
grazing management only. It Is entirely possible to have satisfactory
grazing management and still have resource conflicts which are
independent of the livestock or not affected by the grazing system.
The prudent investor test asks if the benefits of a project outweigh
or are of greater value than the cost of an improvement.
See Appendix 1, Table 4
2,25, 2-26 and 4-4.
>f the Proposed Plan and responses 2-3, 2-27,
145-11
145-12
145-13
145-14
According to the information in the Bu
Table 3.2, DRMP/DEIS is correct.
Refer to response 145-11.
Refer to response 2-87.
Refer to response 2-87.
files, the information in
145-33
145-34
145-37
145-38
145-40
145-41
See Appendix 1, Table 4 of the Proposed Plan.
Winter range habitat type selection is dependent upon many factors.
Some Include temperature, proximity of foraging areas to cover, snow
depth and severe weather duration. As the duration of severe
conditions increases, mule deer utilize the best cover available
which in many cases Is big sagebrush and juniper. Also, Vavra and
Sneva (197S) found that sagebrush and juniper combined for 82 and 87
percent of the diets of mule deer on Palomino Buttes during the
winters of 1975-76 and 1976-77, respectively.
No conflicts have been identified; however, monitoring of these
species and their habitat will continue and conflicts which are
identified will be addressed on a case-by-case basis.
Aerial and ground census data were used by ODFW to delineate seasonal
ranges .
Refe
to response 145-36 .
As noted on page 1-4 of the DRMP/DEIS, Planning Issue 1, it does not
appear that the grazing management decisions of the Riley MFP will be
implemented within a reasonable timeframe. This is because the
effectiveness of those decisions depended heavily upon very large
investments in rangeland Improvements. Such investments have not been
funded and there are no Indications that they will be. For this
reason, the current planning process has reoriented the Proposed Plan
toward management prescriptions which are much less investment
intensive.
Refer to response 145-38. Such assumptions are necessary in order to
analyze an adequate range of alternatives In the DRMP/DEIS as
required by NEPA. In contrast with earlier planning efforts, however,
the Proposed Plan has been designed to be fully operational over a.
broad range of funding and staffing levels and is not dependent upon
extensive investment levels to be put into effect. "Cash flow"
predictions are not Included because they are not pertinent. Public
land management is not a "business" in the sense that there Is a
monetary bottom line (income, expense, cash flow). By law, BLM Is
required to manage for a broad spectrum of nonmonetary values as well
as monetary values. Most receipts such as grazing billings do not
return directly to the RA, but contribute to the general treasury. As
such, cash flow predictions are not a valid measure.
Refer to response 2-87.
Refer to responses 145-38 and 145-39.
145-15 Refer to response 2-87.
145-16 Refer to responses 2-6 and 2-10.
145-17 Refer to response 2-87.
145-18 Refer to response 2-87.
145-19 Refer to response 2-87.
145-20 There are plans for additional water sources for West Sagehen
Allotment to Improve livestock distribution. DRMP/DEIS, Appendix 3,
Table 7 has been corrected to Include these projects; see Appendix 1,
Table 14.
145-21 This is correct, Hat Butte (7007) was listed In error as having an
erosion problem. This has been corrected in the PRMP/FEIS.
145-22 Refer to response 43-5.
145-23 The areas proposed for water facilities are currently within big game
ranges. These ranges are In unsatisfactory condition due to distance
from water. The proposed big game forage allocations remain the same
with or without the additional water.
145-24 Refer to response 2-63.
145-25 Refer to responses 2-6 and 2-10.
145-26 Presence of a special status species is not, In and of itself, a
conflict. It is, however, a concern. While there is no Information
which indicates present grazing management is detrimental to
Eriogonum cuslckii, the Bureau is still responsible to prevent
significant risk to special status species.
145-27 Refer to responses 2-6 and 2-63.
145-28 Page 2-2 calls for continuation of present management under
Alternative D. The Riley Grazing EIS only analyzed the impacts
associated with livestock grazing and is only a portion of the
present management direction. The Riley MFP calls for 12 additional
water sources (reservoirs, spring developments, or guzzlers) in the
East and West Sagehen Allotments.
145-29 Refer to responses 4-6 and 4-7.
145-30 Refer to response 2-10. Also, p. 3-26 of the DRMP/DEIS, uses the
phrase "current forage commitments" which are allocations from the
Drewsey and Riley planning processes.
145-31 Specific parameters discussed In Appendix 6, Table 2 (Criteria for
Evaluating Aquatic Habitat), were used to develop condition and trend
data presented in DRMP/DEIS, Appendix 6, Table 1, Aquatic Habitat.
For additional information, refer to response 2-3.
145-46
145-47
145-48
145^.9
145-50
145-51
145-52
145-53
145-54
145-55
In reference to the 1982 EIS, data presented were not inaccurate
given circumstances found in the RA at that time. In 1982, DEQ had
not gathered data nor published statewide basin studies.
Additionally, the State and Federal agencies had not developed best
management practices for nonpoint source (NPS) pollution nor
identified those NPS impacts on the beneficial uses of water. For
details of utilization and grazing systems proposed, please see
PRMP/FEIS, Appendix 1, Table 4. Also, refer to response 2-7 regarding
utilization levels.
Monitoring and evaluation of field data Indicate that livestock were
often directly responsible for poor riparian condition, degraded
aquatic habitats and poor water quality. The No Action Alternative
would not resolve existing multiple-use conflicts within the RA.
Additionally, the BLM is required under FLPMA to prepare
comprehensive land use plans consistent with the principles of
multiple-use and sustained yield (see responses 6-3, 6-4 and 6-6).
The No Action Alternative would leave many waters in the RA in poor
condition and provide unnecessary delays In meeting DEQ water quality
standards. Also, refer to response 2-28.
Streambank dcstabilization and subsequent silt and sediment
deposition are processes often accelerated by poor management of
livestock in riparian zones. Methodology used to identify condition
of aquatic habitats was reviewed in the DRMP/DEIS Volume II, Appendix
6, Table 2, Criteria for Evaluating Aquatic Habitat.
Refer co responses 2-4 and 2-28 and Appendix 1, Table 4, PRMP/FEIS.
Refer Co responses 2-3, 2-4 and 145-42.
See Appendix 1, Table 4, PRMP/FEIS. Also, refer to response 2-7.
Refer to responses 9-10 and 13-9.
Refer to responses 2-63 and 28-1.
Refer to responses 2-49, 2-61 and 28-1.
Refer Co responses 2-49, 2-61 and 28-1.
It is not feasible to list all possible range improvements in a land
use plan. Alternative C Is the Bureau's Preferred Alternative. Refer
to response 145-20 and 145-28.
Refer to responses 2-49, 2-61 and 28-1.
Prescribed fire as well as other public land treatments are proposed
to enhance wildlife habitat.
For Information on prescribed fire and suppression policy, refer to
responses 4-8 and 4-9, respectively.
Appendix 11-146
Text page 4-28 (RIPARIAN HABITAT--A1 ternat 1 vs D) :
We believe the BLM has taken the No Action label of this
alternative literally. The No Action alternative does not
preclude the BLM from continuing to Identify specific
Issues, including riparian habitat, on specific allotments
and implement grazing systems and/or enhancement projects to
rectify identified problems. The No Action alternative does
not imply that the BLM will close its doors — only that It
wl 1 1 cent inue to implement the type of management systems
Identified In 1982, or alter the proposed systems as
appropriate on a case-by-case basis. Ve believe there to be
no credibility to the conclusion that riparian areas with a
current declining trend would continue to deteriorate. If
the BLM has done repeated sampling (no data Is presented In
this Plan to indicate that it has been done), and If
specific areao have been identified by quantifiable data to
have Inadequate management , then the BLM is certainly not
hamstrung to rectify those deficiencies under Alternatives D
or E.
Text page 4-28 <WETLAND/PLAYA/MEADOW HABITAT):
Table 5-3 (appendix page 5-9> verifies that the BLM has
absolutely no. basis for concluding that any alternative
would have any effect on "playa habitat", since It has no
current data on condition or trend of the subject areas. We
repeat our request for the listing in this document of the
specific parameters of condition and trend, and the repeated
readings of those parameters which have resulted in the
conclusions of both condition and trend In this table. It
appears that the only criterion for an area to be listed in
upward trend in this table Is that at some time, whether
recently or In the past, the particular area was excluded
from livestock use.
The BLM also has no basis in fact for cone
or meadows would suffer declining trend as
seeding projects "adjacent" to them. Lack
trend data, no conclusion can be made
data, no conclusion can be made that a see
increase use on those areas. We assume
seedings would be developed Into their own
would enable management of them separate
native vegetation. Even if this is not th
exists no reason to conclude that tht
seedings would lead to the predicted lncre
oi playao, and even if It did, no data ex"
the conclusion that the grazing per se wou
deter lor at ion of the pi ay as.
ludlng that playaa
a result of
lug condition and
eking utilization
ding wou 1 d
at proposed
pastures , which
from surrounding
e case, there
lopment and use of
d utl 1 Izatlon
3ts which supports
Id lead to
area, It certainly is empowered to rectify that situation.
Lacking knowledge of the habitat requirements of the
particular species, and lacking a knowledge of interactions,
and therefore potential conflict, between species, and
finally lacking the specific knowledge that a grazing system
or Intensity is causing harm to a particular population of
"sensitive" species, this conclusion Is completely
unfounded.
Text page 4-43 (WILD AND SCENIC RIVER DESIGNATION —
Al ternatlve D) :
The wilderness IMP does NOT prohibit livestock Improvements
in wilderness gtudy areas. Certain types of facllltes, such
as corrals, may be prohibited, but livestock watering
facilities are certainly allowed, so long as they meet a
single criteria: that the construction does not Impair the
suitablity of the area for consideration as wilderness
(anything which can be constructed and/or removed without
long-term Impairment qualifies). The litmus test Is whether
the area would have been excluded from designation as a W5A
had the project existed at the time of designation and
whether construction would remove the area from
consideration as wilderness. Spring developments, troughs,
and reservoirs have been constructed in BLM WSA areas
througout the west since the IMP guidelines were
establ ished.
Text page 4-46 (CULTURAL RESOURCES):
It Is incredible to us that the BLM seeks to link cultural
resources with Its desire to eliminate or reduce livestock
grazing, and that it would purport Its1 desired outcome ot
ouch elimination or reduction to have a beneficial Impact on
cultural resources. "No specific values are identified as
yet" Is the most telling phrase in this entire section — no
cultural values are identified as being at risk In the
riparian zones or upland areas targeted in the alternatives,
or in any other 1 oca! e , but somehow, in the BLM' s reason i ng,
getting rid of the cows must be a good Idea.
Text page 4-68 (ECONOMIC CONDITIONS):
This section is woefully inadequate in assessing the
economic impacts to the local economy and to Oregon as a
rcsul t of Implement i ng the various a 1 ternat ives. It need3
great expansion so as to clearly, precisely, and accurately
ref lect the potent ial economic damage to the 1 ocal
eommunltites and the economy of the state which Is merely
eluded to elsewhere in this document.
The conclusions of this section are based not on current
data but on biased and unprofessional "doom and gloom"
speculation.
Text page 4-30 (SPECIAL STATUS SPECIES):
We fail to understand the conclusion that grazing playas
only prior to July 31 will provide more forbs for
sagegrouse. Moot forbs in the cold desert regime make their
growth, flower, seed, and disarticulate long before the
f irst of August . Whl le 1 i ve stock certain ly do consume
forbs, their dietary content is generally very low. If the
conclusion is based on the assumption that grazing per se
before July 31 i3 "bad" for grasses, and therefore
competitively "good" for forbs in the long term, the
conclusion is still unfounded, since it is both the degree
of utilization and the overall graz Ing management system
which would ultimately decide whether the particular grazing
la "bad" for grasses. If the BLM is proposing that grasses
be grazed to an abusive level in these areas prior to July
31, and therefore give a competitive advantage to forbs, we
are opposed to the general prescription. Furthermore, no
data has been supplied in this Plan which would lead to the
conclusion that forbs arc- currently a limiting component to
the western sagegrouse in the habitats it occupies, or that
indeed any habitat component is deficient for this species
anywhere in its range. We repeat our position that the mere
presence on a given parcel of land of two species, be they
wild or domestic, does NOT constitute the presence of
conflict between them.
Likewise, no evidence is presented In this Plan that the
Long-Billed Curlew is somehow suffering from the current
management of the range in this resource area, so that a
prescription of no livestock grazing from April l to June 30
is necessary, The livestock have been on the western range
for we 1 1 over 100 years, mostly at greater numbers than
presently exist, and never before with as intensive
management as at present, and the long-billed curlew Is
still around, finding nesting sites and raising its young.
Absolutely no medical proof exists that domestic sheep, by
the mere fact of their species, present a danger to
Cal i £ orni a Bighorn In their present habitat , nor that
construction of livestock watering facilities would in any
way be harmful to the bighorn. No basis therefore exists
for the conclusion that the restriction of those actions
would be beneficial to bighorn.
We take strong exception to the conclusion that "reduced
livestock grazing pressure would benefit some of these
species." If the BLM has evidence that grazing Is harmful
to the multiple uses or renewable resources of a specific
■The size of operation which the BLM believes to be a
self-contained business has little to do with the Importance
of the decisions contemplated in this RMP. A family ranch
with a 100 cow permit is just as important to that family as
a 1000 cow permit is to a corporation, and perhaps more so.
The implication In this RMP Is that any operation of less
than 300 cattle is expendible or not as worthy of
consideration as one of over 300 cattle. We will remind the
BLM that the regulations of 43 CER apply equally to all
permittees who are dependent by use upon the public lands.
Subleasing of BLM forage is a prohibited practice and not
open as an alternative for ranchers affected by the
proposals of this plan.
We take strong exception to the conclusion that "many
ranchers could choose to delay capital replacement, when
possible, and cover only the cash costs of the ranching
operation until forage availability is restored" under
Alternative C. The need to replace equipment, facilities,
and livestock is not a matter of choice; nor is the payment
of ranch debt. This is an extremely poor and simplistic
analysis of the situation facing most ranches in the area of
the RMP, and shows a poor understanding of ranching and
agriculture in general, which have very high capital
investment and relatively low return on capital
expendi tures.
Table 2.1 (MANAGEMENT DIRECTIVES BY ALTERNATIVES):
Our comments on specific sections of this table are
contained In our above comments on the text and appendices
of this draft RMP/EIS.
the opportunity to comment on the subject
Sincerely yours,
Dick Raney
Meadow Creek Enterprises
Appendix 11-147
145-56 Refer to response 145-23.
145-57 Suitable reservoir sices in the areas listed for guzzlers have not
been identified. Many reservoirs have been attempted in some of these
areas and have failed; therefore, the guzzler recommendation. It is
estimated that a 2,500-gallon guzzler would only supply water to 10
cattle for 10 days or about 3 to 4 AUMs.
145-58 See glossary DRMP/DEIS, pp. 6-11 and 6-13, which define satisfactory
and unsatisfactory big game habitat conditions. The management
actions are designed to correct any habitat component deficiencies.
145-59 Yoakum (1974) described one of the preferred characteristics of
antelope habitat in the sagebrush steppe as areas having 10 to 30
percent forb composition. This is true because antelope prefer
succulent forbs throughout the summer. The recommended management
actions to improve forb availability would improve antelope habitat.
145-60 Refer to responses 2-3, 2-26, 2-28, 2-hk , 145-3 and 145-43 and
Appendix 1, Table 4, PRMP/FEIS.
145-61 Refer to responses 2-4, 2-5 and 145-45.
145-62 Refer to response 2-2 and 2-26,
145-63 Refer to response 1-19 and Appendix 3 of the PRMP/FEIS.
145-64 Refer to responses 1-19 and 7-13.
145-65 There is a difference between grazing of upland forbs versus forbs
around playas. Forbs around playas initiate growth as the soil dries.
This can take place throughout the summer dependent upon the size of
the playa and precipitation.
145-66 Refer to response 2-79.
145-67 Refer to responses 2-78 and 137-8.
145-68 Where habitat conflicts have been identified for particular species,
management actions have been formulated to reduce or eliminate these
conflicts. As data and Information become available, management
actions within the scope of this RMP will be initiated on a
case-by-case basis to resolve identified conflicts.
145-69 Wilderness IMP does not prohibit livestock improvements in WSAs. The
portion of the reach of the Middle Fork of the Malheur River and
Bluebucket Creek is within the 2,080-acre administered primitive
management area which was proposed and accepted through a resource
management decision In the previous Drewsey RA MFP.
The 2,080 acres basically includes the area along the river and creek
that is within the steep, canyon walls. There are no range
improvements other than a couple of drift fences. The recommendation
In the Drewsey MFP notes allowance of cattle as a restricted use
pasture which can be made compatible with the use of the area.
However, grazing use does not allow livestock improvements within the
administered primitive area (I.e., the river and creek canyon). If
this reach of river and creek is designated as part of the National
Wild and Scenic Rivers, the management guidelines and standards for
such rivers notes under Management Standards for Wild River Areas,
item f, "Agricultural Practices and Livestock Grazing: Agricultural
use is restricted to a limited amount of domestic livestock grazing
and hay production to the extent currently being practiced. Row crops
are prohibited."
The statement In Alternative D, "Under IMP or primitive recreation
management ..." is changed to read, "under primitive recreation
management. . ."
145-70 Some heavily grazed areas will have important cultural resources
present that have not been documented and where no projects are
planned, including riparian zones. Any management practices that
reduce overall Impacts to these zones may beneficially affect
cultural sites by minimizing soil erosion and trampling of sites
caused by livestock congregation. Livestock grazing may be
detrimental to cultural resources in many situations where hard data
is lacking, since the existing database indicates that highly
sensitive cultural sites frequently occur at or near live water,
including riparian zones.
145-71 The intent of recognizing the numbers of large and small operations
is to better display the impacts to smaller operations. Without this
division, large operations statistically overshadow the smaller
operations. The text has been changed to better express this intent.
145-72 The word "many" should be replaced by the word "some."
Appendix 11-148
January 15, 1990
PO Box 8 73
Mines, OR 97738
14®
other Item that I
Three Rivers Resource A'
Burns District
Bureau of Land Manageme:
HC H -12533 Highway 20 i
Hines, OR 97738
I am writing in response co your draft Three Rivers Resi
Plan/EIS. In further reviewing the documents, I found i
would like to respond to.
I ask that you further define your management direction for ORV areas to show
what uses are actually intended and specifically where these uses would occur,
In Table 2,1-31, you state: "2. Maximize the development of usable ORV areas
and cross-country routes {including snowmobiles and motorcycles), including
areas away for the population centers of the county to increase the number of
out-of-county users." These areas are not identified in the document.
The low rainfall and slow vegetation growth on many of the lands administered
by the ELM doesn't permit very rapid recovery once damage has occurred. In
fact, the tracks made by homesteaders over 100 years ago can still be seen in
some areas, I question as Co whether the results of encouraging ORV cross
country travel is something the BLM would really want to live with in the
future.
I have further concerns regarding the effects of ORV travel on native wildlife
and plants, especially on sensitive and rare species. There is considerable
concern about the fate of Desert tortoise in Nevada due to ORV impacts. I
would hate to see similar situations developing here. Ue also have some
species that are unique ,
Another aspect that I feel needs to be spelled out in the document is how you
will discourage and handle unauthorized entry by ORV users from BLM managed
lands onto other ownerships. There are a number of private and other public
lands intermixed with BLM land with very little boundry designation,
From experience in working on the Mark Twain National Forest in Missouri and on
the Ochoco, I know that letting ORV use develop without control is nor. the way
to go either. Established use is much harder to control than use that is
planned for. It is imperative chat both crails and ORV use be carefully
planned to: first, prevent resource damage and second, to limit damage should
it occur.
I also ask that the types of ORV uses and the scale of those uses that would be
acceptable to your management be considered and spelled out in your final. The
146-1 Refer to response 1-23. The ORV use intended for management within
the RA include cross-country motorcycle, specialized vehicle and 2
and 4-wheel drive vehicles on designated roads and trails as allowed
on a case-by-case basis. Other uses include intensive off-road
vehicle use in specific areas (the only area is Radar Hill) and
snowmobile use in areas north and west of Burns which are adjacent to
the Malheur National Forest. Since the snowmobile use is in areas at
lower elevations than those in the forest, the use is more short-term
(mid-winter), sporadic and in some winter seasons, almost nonexistent.
The known areas of use for the various off-road vehicle uses and
snowmobile use are noted In the Recreation Map R-l. These uses will
not be maximized. The existing off-road vehicle designations in
DRMP/DEIS, Table 3.13 listed as open, closed and limited are now
noted in a new Hap R-2, in the Proposed Plan.
Unacceptable resource impacts should have been more appropriately
stated as "considerable adverse effects." While difficult to define
precisely, this term does not include ephemeral impacts of short
duration and small area which do not affect endangered species,
critical soils, or life cycles of flora and fauna. However,
degradation in any degree of a significant cultural site shall be
considered a "considerable adverse effect." For Bureau purposes,
Section 9(a) of E-0. 11644 is a tool to be used to protect areas when
protection is needed, until the areas can be processed through the
planning system and given a proper designation, and for emergencies
such as fire, flooding, unusually deep snow (for wildlife
protection) , etc.
Section 9(a) requires closure or restriction of an area despite any
current designation made under Section 3 of E.O. 11644 when it is
determined that ORV use will cause or is causing considerable adverse
effects. However, there must be a clear showing, not merely
suspicion, that the use of ORVs will, in fact, have a considerable
adverse impact. When these conditions prevail, immediate closure or
restriction must be made. Restrictions may be made for a specific
type of vehicle causing the adverse effects. Under Section 9(a),
closure or restriction may be made without public participation, and
the closure or restriction may be rescinded without public
participation.
In any case, ample public notice will be given of the action to be
taken or the actual action taken, as is appropriate, and all feasible
action will be taken to mitigate the adverse effects.
146-2 Refer to Response 1-23
146-3 Refer to response 1-23 and 146-1.
146-4 Refer to response 1-23 and 146-1.
terms "maximize ...development" and "increase Lhe number of out-of-county
of activity is compatible with management of BLM lands. Not all ORV users are
families looking for a weekend of recreation.
Once it becomes known that the BLM is encouraging ORV use, it will not be long
before large groups will want to have enduros, meets, and competitions. This
has already been proposed on National Forest lands in the Prineville area.
While this might be beneficial to the local economy, I feel this type of
activity is not suitable on public lands. The impacts are devastating. We do
not need another Barstow run located in Eastern Oregon.
I Table 2.1-31 does mention "unacceptable resource impacts", but exactly what is
unacceptable is not spelled out, This leaves room for considerable amount of
interpretation, with the potential for BLM having to defend its position
against an organized group's interpretation and all the associated political
pressure.
BLM should be trying to promote both an appreciation for the unique ecology of
the Great Basin and an attitude of responsible use to protect that ecology.
Too many people travelling Route 20 think of Eastern Oregon as that
"God- forsaken sagebrush flat east of Bend suitable for all manner of land
abuse". (my quotes)
The open-ended, vague direction of your current plan provides an opportunity
for user groups to propose uses and facilities that could have severe impacts
to the land and resources, while at the same time placing the burden of proof
on the BLM to deny that use. More specific direction in your plan would avoid
this situation.
Thanks again for the oppo:
ity
O
u. k:
M, Keniscon
Appendix 11-149
January 28, 1990
11
Joshua L. Warburton
District Manager
Burns District
Bureau of Land Managent
HC 74-12533
W. Highway 20
Hines, OR 97738
I am not commenting on all the Three Rivers Management Plan and Environmental
Impact Statement, as Western Range Service has commented on most of the issues.
147-1 I * w^sn to comment on a few isues, as follows: I am opposed to fencing any of
I the streams in this RMP. Very little, if any, off-site forage will be available
I to replace the AUM's lost in fencing riparian areas. These off-site fields are
I presently being grazed, annually.
147-2 I lf BLM flrea ^"agers forsee a problem in an allotment they should work with the
I rancher or ranchers to find a solution instead of saying nothing. Then later
| propose a reduction in AUM's, which may not solve the problem in any way.
I see no reason for enlarging the wild horse Herd Management Areas. BLM already
has trouble to maintain the numbers below the maximum in all HMA's. The wild
horse adoption program should not be competing with the commercial horse
business. Declaring a wild horse area an Area of Cri treat Environmental Concern
may not be legal .
The wild horse stallions that are taken from the Burns wild horse corral and
returned to the range, should first be casterated and/or destroyed.
I forsee no reason for changing the present grazing system., Drewsey EIS.
No private property should be sold to the federal government.
147-1 Refer to responses 2-5 and. 3-13.
147-2 Refer to response 2-11 and 2-49.
147-3 Refer to responses 2-68, 11-11 and 124-4.
Thank you for allowing me to make comment.
Sincerely,
Allan Otley
HC 72 Box 55
Princeton, OR 97721
148
eb. cJth, lL.(jO
IT. 'j. Department of tho Interior
Bureau of land Management
Throe Jiivers Management Plan
Hines, Ore.
Dear Sirs;
In regard to your Three Rivers Resource Management Plan
section on access needs, we are extremely dismayed with your
total disregard of the private land owner. After a study of
your map L. I, it is obvious that n^actically all of the nronoaefi
new accesses are routed directly thro -gh private property. In
■■early all cases, access is available t!ir--'.-h alternate routes
that remain 03 public lands. Itseems that yen have declared
"open season, come one, come all" on the rights of the private
land owner. It is hard enough to make ends meet in the ranching
business, with attacks from environmental, special Interest groups ,
"; government a 3 agencies, without being tagged with the job ox baby-
sitting the general public. It seems contradictory to us, that
in one breath, you are trying to limit use and protect those so
called, fragile riparian areas, and in the next breath, you are
trying to increase access and usage of them.
Private property is one of the few remaining places of refuge
for our deer, elk, and ante lone herds for whom you are now
proposing tc allow so many A "J M S to help increase their numbers
and their natural habitat areas. It seems insane to do this and
then try to increase access to them.
As you have surmised by now, we the undersigned, are definitly
against any increases in new access routes, be it public or
private landswithir. the Throe Rivers Management Area.
The hills are already overflowing with roads and trails to
satisfy the needs of the general public.
The routes portrayed on Hap LR-3 in the Proposed Plan are along
existing roads and trails on private lands where no legal access has
been acquired. Bureau policy, as stated In Manual 2100.06, is to
acquire lands and interest in lands, such as easements, which are
needed l:o provide for public use and enjoyment of the public lands.
Access to be acquired would be through negotiated easements or by
other means, such as exchange or donation. Condemnation would only be
considered in rare Instances where critical access Is needed to
public lands with extremely important resource values and only after
every effort to negotiate has failed. By whatever means of
acquisition, all landowners would be fairly compensated and every
effort would be made to limit the Impact of public access through
private property.
The accesses portrayed are generally the best available vehicular
route into an area. If an alternate route does exist, it is often
limited by difficult terrain, long distance or other private lands.
Prior to pursuing an acquisition of any given access, alternative
routes would be considered carefully to determine the feasibility of
the acquisition.
!&'^£)L*<~.JLJ2fr
Appendix 11-150
MI
149-1 Refer to response 1-11.
Jay CaiZion RMP-FIS
Buim Vlitilct Q^lzz
Buizau oh Land Manage.me.nt
IIC 74-12533 Highway ?.0 lfie.it
Hlnzi , Oizgon 91738
Review Commenti |(oi thz Qctobei 198
BLM Dia^t Tkize. Rlvzii RMP/ETS
Vtai UK, Cailion:
A nu.mbe.iL o$ le.tts.ii have. came, to my attzntlon , Zan.ge.ly In oppoii.tJ.on
to the izcommtndtd ie.dacti.om In Zlvtitock numbzii on a numbe.i. of.
langzi. J can appizclatz the conccim o jf the. Ra.ncke.ii.
Hainey County hai thouiandi of acizi v (, non-pioduclng giaii Zandi ,
<$ki.ch aizie. pioduclng good giaa when the ZaiZy day ie.ttZe.ii aiilvzd
In thli cLKta, Long continued ovti-u.it by vait numbzii tr$ Zlvzitock
dznudzd many atzai o& the natlu e giaii zi , but a Zaige, pzictntag z o f
thziz Zand & havz madz Zlttlz oi no ilgm o{, giaii iz-vzge.tati.on din-
ing the, pait fl^ty yzaii, ilncz I have, been In the aiea. It would
appeal to me that moie. of thziz non-giaii pioduclng aizai could bz
KZ-itOitd to good giaii Zand wli h Cititzd Wheat Giaa , to whziz It
wouZdn' t bz nzcziiaiy to make, cuti In numbzii .
Rzductloni In cattZz numbzii would not onZy be, dzvaitatlng to the
Zlvzitock opeiatoii , but to the, county at Zaig z.
l/i'iy Slnczti zly ,
150
65095 Swallcy Koad
Bend, Oregon 97701
February 9, 1990
150-1
Refer to response 12-4. Also, refer to responses 1-11, 1-13, 2-6,
2-10, 2-78 and 3-5.
150-2 Refer to response 12-1.
150-3 Refer to responses 12-1 and 12-7.
District Manager
Bureau of Land Management
Highway 20 West
Hines, Oregon 97738
Dear District Manager,
I am writing to you concerning the Three Rivers Resource
Management Plan and Environmental Impact Statement.
You "must develope alternatives A & C to restore and main-
tain range lands, riparian and stream habitats to their
natural and healthy condition.
Cattlegrazing should be reduced or eliminated where appro-
priate as well as crested wheatgrass seeding. Winter range
forage allocations for wildlife, namely bighorn sheep should
be given priority over livestock allocations. Also with this
management plan it is imperative that Wild & Scenic River
designation be given for all of the South and Middle forks
of the Malheur River {except for the stretch through the
Drewsy area) all of Bluebucket Creek and all of the Silvies
River.
150-2 I Lastly 1 ask that all ancient forest areas that are left be
I identified and protected. Remember the stands of ancient
I trees in the Pacific Northwest are the last remaining in the
150-3 | world. Costs of construction of new roads and other range-
land projects should be included under the various alter-
atives as well as the environmental impact on the areas.
Please review this Resource Plan and Impact Statement and
make the necessary changes to ensure and protect a most
magnificent natural area .
Sincerely,
Connie Lonsdale
Appendix 11-151
GRANDE BONDE RESOURCE COUNCIL, INC.
151
Ma
-BLM.
Our group has a strong interest in public lands and your
wise stewardship o-F public resources. We submit -for your records
the fallowing comments an the Draft Three Rivers Management Plan
and Environmental Impact Statement.
1. There is a measure Of irresponsibility and a lack o-f
professional management in allowing continued heavy grazing on
public lands already degraded by cattle. By your own assessments
the condition of extensive areas of public lands in your district
&re in "poor" and !'f ai r " candi ti an: 1 , 065, 298 acres of a total
of 1,655;, 439 acres.
2. The riparian zones on our public land under BLM-Burns
District management have suffered for years from excessive cattle
populations- f4ot to propose a substantial reduction in fiUMs is a
serious failure in the objectivity of the RMF'-EIS planners. We
propose that considerable reduction in grazing be an essential
component in several of the alternatives.
3. Our emphasis here is a reflection
in 1. and 2. above. The RMP-EIS in it
sd design. The range of alternatives
y alternative emphasizes exploitation
nse of the owners — the American public-
f probl ems pointed
draft farm has a
extremely 1 i mi ted
public land at the
Alternative A i
the
only rational approach,
unacceptable.
merely because the others &re so
4. Altho
is relatively
Lgh we recognise that the designated forest acreage
small [9,291 acres for "intensive management <Table
___;turbing to find no reference to ^preserving old
growth or to eliminating all logging for the'benefit of water
quality, wildlife habitat and recreation. It is alarming to find
that you insist on exploiting even this small acreage.
Your comment under "Forestlands Alternative A" p. 4-7 that
"The significance of this reduction would be very high" is total-
ly unsubstantiated. "Significance" to what? to whom? to eco-
systems? And "very high" is a most unscientific and imprecise
way of measuring anything at all- We urge a reconsideration of
the value of public forests that will lead to a plan mare appro-
priate to the multiple values they represent.
5. Recreation is dealt with in the DRMP-EIS as incidental
to grazing and is another example of multiple use being referred
to but ignored in practice. The two volumes of information and
proposals deals largely with grazing and grazing problems, and
there is no real plan to provide more sites for campgrounds and
for proper control of DRV use.
151-1 Refer tio response 1-13.
151-2 Refer to response 12-4.
151-3 Refer to response 12-1.
151-4 Refer to response 11-22.
151-5 The DRMP/DEIS does consider development of intensive use areas, in
particular Chickahomlny Recreation Site, Diamond Craters ONA/ACEC,
Warm Springs Reservoir and Moon Reservoir. Chickahomlny Reservoir
receives the greatest number of visitors and is the highest priority
in the RA for development, followed by Diamond Craters. Because of
the small local population la the county, plus the current projected
use by out-of-county visitors, development and management of more
campgrounds by the BLM in this RA is not in the best interest of the
public at this time.
In regard to plans for campground development, this document provides
management direction with more comprehensive activity plans to be
written as a next step for addressing specific, on-site needs- Please
refer to responses 1-23 and 145-1 regarding additional explanation of
ORV management which has been incorporated into the PRMP/FEIS-
151-6 Refer to response 3-13.
151-7 Refer to response 12-7.
151-8 Refer to responses 7-12 and 118-2 and Appendix 1, Table 8 of the
Proposed Plan.
151-9 Refer to response 7-12.
151-10 Refer to response 1-11.
Post Office Box 296S, La Grande, Oregon 97850
6. Stating that Riparian Habitat w
var i que grazing treatments" p . 4—26 is a
you intend to put out the fire after you
best and obvious "treatment" is to prohi
juld benefit from
lalagous to statir.
have ignited it.
lit grazing withir
] that
The
attenti on
drainages. The proposed alternatives give little or
to large reduction in the expensive practice of private grazing
on publ i c 1 ands.
7. The DRMP-EIS totally omits an itemized financial
accounting to the taxpayers of the costs of various aspects of
the proposed alternatives. However, the dollar totals presented
on p. 4— 69 reveal that Alternative E would cost the taxpayers
$4,355, 131 to benefit a limited number of grazing permitees —
amounting to a subsidy of nearly $50,000 for each permitee. This
is a flagrant example of special interest welfare.
8. Scrutiny of the very brief references to Wetland
p. 3-27 and Table 3-12 reveals how apparently ineffectual
procedures have been in protecting wetlands. Of the 1351
not classed as "uncontrollable" only 50 sre in "good" con.
for a meagre 3.7 percent. Since these areas have been un
jurisdiction for many years, there is reason to believe tl
management practices and decisions have failed to protect this
resource. Furthermore, it is puzzling to read on p. 4-28 that
the BLM prefers now to wait until 1997 before altering past
destructi ve pract i ces. We fail to understand why i mmedi ate ac-
tion for repairing wetland habitat damage is not underway.
9. We are very much opposed to vegetation manipulations in
particular we reject the notion that monoculture on public lands
benefits our society. Converting the natural variety of vegeta-
tion (and the habitat it provides for numerous insects, plants
and animal s) is a desecrati on of publ ic 1 and for private gai n.
Multiple-use is a charade under this prescription and is a pub-
lically subsidized measure for a very few local individuals.
Hab
itat
BLM
acres
diti
on
der
BLM
hat
BLM
Dur intent in presentir
to reex ami ne BLM approaches
some positive tendencies in
only begin the shift from a
phi 1 asophy,
,g this critique is to encourage you
to managing publ i c 1 ands. There are
the DRMP-EIS but unfortunately they
discredited special -interest manage-
ius reevaluation of BLM procedures
ill be necessary before our public lands
xcel 1 ent conrii t ion.
ill be
in good to
For the GRRC Co
Roberta Bates,
Committee
'■BLM' Director
U.S. Congress
'U.S. Senate.
Sierra Club
Wilderness Society
Gov. Goldschmidt
h Sa
u<z
Appendix 11-152
January 31, 1990
152-3
152-4
^m
Bureau of Land Managem
Burns District Office
Att. Joshua L. Warburton
HC 74-12533 Kwy 20 West
Kines, Oregon 97733
Dear Mr. Warburton,
Following are our comments concerning "Draft — Three Rivers
Resource Management Plan and Environmental Impact Statement:1 We
would like to compliment your staff on language included in the
riparian habitat, aquatic habitat and water quality Management
Directives by Alternative (Table 2.1) "systems which' are widely
recognised as promoting the most rapid riparian recovery practicable
(note that full recovery under even the most favorable management
may require many years in some cases)." This language is vital
to successful management systems in many areas providing CRMP
and &$£? planning processes with the needed flexibility to fully
utilize modern technology and management to enhance and manage for
all resources and uses.
We are concerned about the 30 and 50 percent utilization
levels in the same section. Timing of use and duration of use
are the most important grazing management practices needed to
solve problems and conflicts in wetland type areas in the short
term. ; Utilization levels to meet resource objectives should
vary with different times of use and with the duration of grazing
the described utilisation levels are unrealistic and without
supporting data. The 30 percent utilization levels in the upper
watershed and on uplands is net appropriate with modern progressive
management systems.
Juniper encroachment due to ecological succession and fire
suppression is beginning to negatively impact riparian and upland
wate_shed areas. The RI1P and future RHP ' s need to emphasise" vegetative
manipulation to optimize long term watershed needs. Ground cover
decreases and erosion increases as junipers take over many areas
in the RA. As much as 50 - 75 percent of winter precipitation is
intercepted and lost in the form of evaporation in thick juniper
stands in addition to direct competition for available moisture.
Vegetative manipulation should be done by mechanical means
on low productive sites while fire should be used where adequate
fuels e;tist. A fire management plan needs to be developed where
preestablished fire control lines can be located and built by
mechanically cutting and other means. Potential harm to life
152-1 Prescribed burning and conditional suppression areas are identified
for assisting the RA in meeting management objectives.
The use of pre-established fire control lines has been considered.
Only areas with high resource values at risk and a history of
continued large or multiple fires will justify the costs Involved and
the possible impacts to other resources.
All suppression actions give priority to life, property and
resources, in that order.
152-2
152-3
152-4
152-5
sly
property and livestock should be the primary determinates of '
conditional suppression. Prescribed fire should be more activ.
pursued with all juniper encroachment areas mapoed out and an
ongoing/longterm control program developed.
The Kiger and Riddle EMA ACEC's are not biologically sound
™r,ben^flfial to long term resource management needs. Both
HMA a should not bs -expand^ nor.- should fcor«a numbers be allowed
to increase. The horses should not have been moved to the Kiger
K£iJB fKL!1;-* PlaCe- Livest°ck permittee's inside the EMA's
should either keep boundry fence gates shut or put a wire over
the top of the gate to keep the horses inside the KMAs
Also, refer to responses 4-
suppression policy.
and 4-9 for prescribed fire and
Refer to responses 2-68 and 11-11.
Refer to response 8-9.
This Is a good recommendation and will be Incorporated into the HHAP.
The Diamond Craters were designated as an 0NA/ACEC on April 1, 1982.
All fires will be controlled to prevent loss of human life or
property within the ONA/ACEC or to prevent the spread of fires to
areas outside the ONA/ACEC where life or property may be threatened.
Use of heavy equipment for building fire lines will not be allowed.
Prescribed burning and presuppression measures and techniques may be
allowed when necessary for the protection of public health or safety
(Recreation Management Plan, 1985).
The recreation management plan for Diamond Craters ONA/ACEC which was
written and presented to the public in 1985 notes three parcels for
acquisition through land exchanges or purchase. These are:
(1) El/2, Sec. 16, T. 28 S., R. 32 E. 320 acres
(2) W1/2NE1/4, NW1/4, N1/2SW1/4,
Sec. 36, T. 28 S-, R. 32 E.
(3) SE1/4SE1/2, Sec. 36, T. 28 S., R. 31 E.
Total
320 acres
40 acres
680 acres
The following discussion In the Recreation Management Plan offers an
explanation for proposing the acquisitions.
"If these private lands are offered for sale or exchange the Bureau
should actively seek to acquire them in cooperation with the
landowners . The parcels have large portions of the lava flow within
their boundaries. A trail goes through Section 16 and a main county
road goes through Section 36. Both provide access to fringes of the
lava flow where adverse impacts are possible through removal of
materials, dumping and possible leasing,"
land add to) new ACECs and RK&
biological, sensitive plant or critical habitat c.ite.ia . T. c
K:..r and ^iddie EMA'S €.c not aualify m any s.retc;. oi «« .
imagination nor does the addition to the Diamond Craters ACEC ,a
.d historical use predonmat
wSS man's improvements and historical use preaoniina.e and
* adjacent areas. In fact, existing uses of
the DC1TA.
Butte RtfA, Silver Creak addition
y Hovntain, Saddle Butta, Bisc'
values
pose no risk to
land Drotact ma _
All ether areas tli.
Foster Flat. SCUKW Lak'
Cult v.;
due to pubi
or adjacent
Foster Flat fencing woulc
and horses and change use
152-10
152-11
Butte , BiscuitrocJ
. an Cultural) need to be rejected at this tin'
ic in_,,-t Ear economic ir.oact tc livastocv. J«»W5«a
d'e-.-mor) nr be out ir.to a further stud;; status.
.vse undue congregation of Ii^astOCK
.tterns so other resource management
objectives Will not be met. water development, range °«fiiJS
and otha- improvements away from Foster Flat coulo. protect ti a
inherent" values better because the involved plant communities
developed iiiconjunction with grazing. The South Karrowe *< ■
a good" example where nongrasir.g has been detrim
comr.unitv be inn protected. _ „_„„,,
Oene-allv, the erasing reductions appear to be unneceessa-y
and not "-Justified with trend data or ether biological information ,
S Slanni'Sc aiS CRI1P planning efforts continually evaluate and
nonitcr"ct:er resources and uses. Wildlife £ora*e needs ^vg
already beer, provided in each area so
are double accounting,
forage for all wildlife as compared
big game populations overpepu
Big game cover requirements a
the plant
crtpetitive use AWta s
:ig plans provide higher quality'
unerased areas and unless
forage Quantity is not limiting,
idiculcus and ignore, big game kww**
a-^d use cf the high desert area.
Land fcaonre adjustments ;:ith willing pa
in the form of land exchanges evan if :"ou '
The long terra needs cf the local azcr.
private land. The BLil's r.ain objscti
la-d -,ah£'-2:,-.er.t efforts to improve tls
water aiuf. related resources will :aaat
s should only be
wiilir-r seller,
ai-a inherently tied to
to ccr.tinve.ll" improve
iclorical needs cf scil,
a needs of all uses and
the local area. Single use dasig
be minimised in SZinal plans.
Me trill ■provide additional i
Questions concerning our ccrments
and. allcca
i.ld
152-7 The interdisciplinary team considered the available information and
concluded that the Kiger and Riddle HMAs and the Diamond Craters
ONA/ACEC extension met Bureau criteria for ACEC designation. Please
see Appendix 1, Table 16 of the Proposed Plan for allowable
management use constraints in ACECs.
152-8 The qualities of the proposed ACECs were examined by the District's
ID team in terms of the importance and relevance criteria established
in BLM Manual 1613.1 (see DRMP/DEIS Table 3.16). Those proposed areas
which the ID team felt met the criteria were carried forward in the
planning process (Silver Creek Addition, Foster Flat, Dry Mountain,
Blscuitroot Cultural and Kiger Mustang).
RNA/ACEC designation establishes a management direction In which the
qualities of the site will be managed primarily to maintain the
natural qualities of the ecosystem in a state which Is suitable for
conducting research, monitoring or other studies on the plant
communities. In some areas, this can be done without excluding
livestock or wild horses. At Foster Flat, the presence of a water
source dictates that fencing to exclude livestock and wild horses
will be necessary in order to minimize external influences.
Also, refer to responses 3-1 and 15-17 (Foster Flat); and 15-13 (Hatt
Butte); 15-15 and 15-16 (Silver Creek); 15-22 (Squaw Lake); 15-24 and
15-25 (Dry Mountain); 15-27 (Saddle Butte) and 4-15, 15-32 and 121-1
(Blscuitroot Cultural ACEC).
The Obsidian Cultural ACEC is not proposed for designation at this
time. The management of significant obsidian occurrences which are
included in the nomination will be addressed in a resource-specific
management plan as part of the overall cultural resource program.
Specific and detailed guidelines for use of these areas will be
developed at that time, with consideration given to the stipulations
you have proposed.
152-9 Refer to response 2-10.
152-10 Refer to response 145-34.
152-11 Refer to response 4-14 and 6-10.
Appendix 11-153
153
&EPA
Joshua L Warburton
District Manager
Burns District
Bureau of Land Management
HC 74-12533 Hwy 20 West
Mines, Oregon 97738
Dear Mr. Warburton;
In accordance with our responsibilities under the National Environmental Policy
Act (NEPA) and Section 309 of the Clean Air Act, we have reviewed the Draft Three
Rivers Resource Management Plan and Environmental Impact Statement (draft
RMP and EIS). This planning area includes 1,709,918 acres primarily in Harney
County in southeast Oregon.
Based on our review we have rated the draft EIS EC-2 (Environmental
Concerns - Insufficient Information). This rating reflects our concern that the
declining water quality trends in the Malheur and Malheur Lake Basins be reversed
and that a distinct "no action" alternative be developed. A summary of our comments
will be placed in the Federal Register-
As indicated in Appendix 1 of the draft EIS and the 1988 Oregon Statewide
Assessment of Nonpoint Sources of Water Pollution, water quality in many of the
area's streams are in poor condition or beneficial uses are impaired. The degraded
water quality conditions in the Malheur and Malheur Lake Basins is largely due to
livestock grazing, irrigated agriculture, vegetation management, and recreation.
We would favor Alternative B over preferred Alternative C, as it is more
protective of water quality and would allow a better chance of recovery. Alternative 8
would exclude livestock for 5+ years from streams with poor water quality
(Alternative C would feature only "temporary removal" of livestock). Alternative B
would also discontinue livestock grazing along 16+ reservoirs (four more than
Alternative C). More stream miles would be stopped from declining or improve.
Alternative C allows for a "variable no-cut buffer" along streams, while
Alternative B would have a "no-cut buffer." Even though Alternative B appears more
conservative the buffer issue is still ambiguous. (Appendix 2-2, "General Best Forest
Management Practices," uses the term "variable no-cut buffer.") The differences
between alternatives on no-cut buffers needs to be explained.
coordinate the efforts with agencies, To the extent that methods and parameters can
be agreed upon and sampling stations and timing be coordinated, a district wide
data base can be developed that can be effectively used for decisionmaking.
The monitoring plan should be designed to reduce adverse effects from plan
implementation and demonstrate the effectiveness of mitigation. It should include
types of surveys, location of sampling, parameters to be monitored, indicator
species, budget, procedures for using data or results in plan implementation, and
availability of results to interested and affected groups. Appendices A and O of the
Final Nez Perce National Forest Plan, October 1987, includes the and approach to
water quality and fishery monitoring which we believe will accomplish the stated
objectives.
As an integral part of monitoring a built-in feedback mechanism is needed so
that activities causing a problem will be corrected before they are allowed to continue
and upgrading of best management practices or prescriptions to correct inaccurate
predictions occurs. The feedback mechanism will ensure that mitigation measures,
best management practices, standard operating procedures, intensity of monitoring,
grazing allotment administration, and timber sale administration are adjusted when
monitoring indicates a need. Special grazing allotment administration techniques that
will increase the success and effectiveness of mitigation measures should be
discussed.
The RMP also needs to describe project monitoring. This primarily means
on-site inspection and administration during an activity, verifying that a particular
activity is occurring as prescribed in contracts, leases, or permits. Discussions
should include: frequency of on-site inspections for different activities (before, during
and after); events which trigger when specialists make site visits; and chain of
command for how on-site corrections and decisions are made.
Thank you for the opportunity to review this draft EIS. Because of the critical
need for improving water quality in the Malheur, and Malheur Lake Basins we
recommend close coordination with the Oregon Department of Environmental
Quality. Please contact Wayne Elson at (206) 442-1463 if you have any questions
about our comments.
Sincerely,
Ronald A. Lee, Chief
Environmental Evaluation Branch
Phil Hamilton, BLM Oregon State Office
Roger Wood, Oregon DEO
153-4
153-5
153-6
153-7
The draft EIS lacks a definitive no action alternative (Council on Environmental
Quality Regulations, 5 1502.14(d)). A no action alternative, that is a continuation of
existing management plans, would allow the reader to have a reference point from
which to compare the action alternatives. A new "no action" alternative needs to be
included in Chapter 4 so that the environmental consequences of no action is
understood for each of the resource categories. The draft EIS uses the term
"Baseline Level" in some of the comparison tables. This needs to be explained.
The text states that the environmental consequences of management activities
will have a "positive effect on water quality." The implied reason is that improved
management practices will allow existing degraded conditions to recover, This
assumes guaranteed implementation of mitigation measures. This is a significant
assumption that needs to be explained further. What changes will be needed in the
day-to-day operations of the district to effect these changes? Will increased staffing
or budgets be required? Are there circumstances where this new management
approach would not be achieved?
With regards to state coordination we would suggest that consistency with the
State Water Quality Management program be added (page 1-10).
The inclusion of existing conditions for individual streams is good (Appendix 1 ,
Table 1). The future condition or water quality goals for individual streams should
also be included in the final EIS. Does this table agree with the 1988 Oregon
Statewide Assessment of Nonpoint Sources of Water Pollution? The source for this
data should be cited. Abbreviations for water quality category such as I, M, and C
should be explained with the table.
When the terms poor, fair, good, excellent are used to describe environmental
conditions (such as Tables 3.10, 3.11, and 3.12 which describe aquatic, riparian, and
wetland habitat) they should be defined. In the water quality discussion on page 4-3
for example, is "fair" or "good" water quality consistent with Oregon Water Quality
Standards and are beneficial uses being fully supported?
The text states that for Alternative C, one mile of stream would decline to poor
water quality apparently due to mining activity, This does not appear to be
consistent with Oregon Water Quality Standards and Antidegradation Policy. This
should be corrected.
We are pleased that a detailed monitoring and evaluation plan will be included
with the final EIS. The monitoring plan should respond to the issues and concerns
identified in the scoping process. It will increase the ability of the public to verify that
the environmental effects are within those described in the final EIS.
Good monitoring can be critical to assurance of minimal environmental
consequences. This is why we believe that the RMP should contain as much
detailed as possible on monitoring. We recognize that detailed monitoring may not
be possible in conjunction with each activity. We encourage using opportunities to
153-3
153-4
153-7
153-8
It appears you are referring to Alternative D's no cut buffer since
Alternatives A, B and C refer to the variable no cut buffer.
Alternative D emphasizes the standard 100-foot buffer since that
alternative emphasizes the commodity side of the spectrum. The
variable width buffer is supported by all resources throughout this
document.
Alternative D Is clearly identified as the Continuation of Present
Management or No Action Alternative on page 2-2 of the DFLMP/DEIS
under the Alternatives Considered in Detail section. This Is also the
case in Table 2.1 where all of the alternatives are displayed side by
side. Column 5 clearly identifies the subject alternative as No
Action. Also, refer to response 8-1 and 12-4.
Refer to responses 2-11.
Coordination with interested State agencies was facilitated through
the State Clearinghouse of the Intergovernmental Relations Division
of the Executive Department oE Oregon. Direct communication would be
established with the State Water Quality Management Office for
coordination of the FRMP/FEIS.
Water quality goals were Identified as management objectives In
DRMP/DEIS,, Table 2.1-2 through 6. The 1988 DEQ Statewide Assessment
of Nonpoint Sources of Water Pollution does agree with, and was a
source of Information for data presented in Table 1 of Appendix 1,
DRMP/DEIS.
The I, M and C abbreviations are for selective management categories
for allotments, not water quality designations. These allotment
categorizations are noted in the DRMP/DEIS on p. 3-12, Parameters
used to identify and determine these categories were elaborated on in
the DRMP/DEIS, Appendix 3, Table 1. Allotment Categories.
Refer
response
and Proposed Plan, Table 2.1.
Under 43 CFK 3809 regulations, the operator must comply with all.
applicable State and Federal water quality regulations.
The Proposed Plan has been composed to display general monitoring
requirements for each management action. The detailed parameters to
which you refer are normally addressed at the activity planning level
and are, therefore, not contained in the RMP.
Monitoring procedures and feedback mechanisms have been Incorporated
in the Proposed Plan (see Procedures to Implement/Monitoring Needs)
for each management action.
153-11 Refer
Appendix 11-154
CLARK. COLLEGE
Ml'NITYCOLLhCE
1HD0B Mi-innctiu^mvn
vani:i')!;vi:r s'.a whm.i
T 1 I ITHOMil.'^loO'.^:]
No comment Identified.
Jay Carlson
RMP/ElS Team Leader
Bureau of Land Management
HC 74-12533
Highway 20 W.
Mines. OR 97736
Dear EIS Team:
[ am responding to the Draft, Three Rivers Resource Managemeni Plan and Environmental Impact
Statement. I am a biologist who does research in the Burns area each summer and I am increasingly
concerned about our loss ot land and water that emphasizes natural values,
I suggest that natural values be stressed over commodity production. In my opinion, the purpose of an
environmental impact statement is to project into the luture consequences ol Our actions. Long range,
we must favor natural values.
My suggestions for alternative are;
Water Quality (stream miles)
Water Quality (surface area)
Forest Management (acres)
Fores; Management (annual harvest)
Grazing Managemeni (acres)
Grazing Management (initial stocking levels)
Special Recreation Management Areas
Off-Highway Vehicle Designations (acres)
Wild & Scenic Rivers (stream miles)
Wild & Scenic Rivers (acres)
Areas of Critical Environmental Concern (acres) Alt, E
Visual Resource Managemeni Keep Class
Cultural Resources Alt. A
Art. A
Alt, A
Ait. a - less than
Alt. a - less than sui
Less than 1 million total
50,000
17,176
All, A
Alt, A
AH. A
Energy & Minerals Alt, A
Solid Leasable Minerals (acres) Alt, B
Fluid Energy Minerals (oil & gas lease acres) All. A
Although writing a resource management plan is no easy task, the hardest part is making a commitment to
the future, even though short-term effects are felt I commend you on your efforts so far and hope to see
Harney County enjoying another centennial wi;h clean air, water, and soil wilhin the beautiful landscapes.
Erleen Christenson. Ph.D.
Appendix 11-155
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 Vest
Hines, OR 97738
155
REVIEW COMMENTS FOR THE OCTOBER 1989
8LM DRAFT THREE RIVERS RMP/EIS
No comment identified.
Mr. Carlson :
(If you are facing a reduction in AUM's, please include the next tw
paragraphs. If not, cross out second paragraph. )
substantial loss of our base
y result in reducing the size
1 anger an economical unit. Therefore,
B or C are considered, that prior to
Alternatives A, B and C trill result
property value. The proposed BLM acti
of our operation so that it is i
ire request that if Alternatives
immvittg the Pixel Three Rivers Resource Management Plan and Environmental
Impact Statement, a "Takings Implication Assessment" be completed as
authorized by Executive Order 12630 (see the November 8, 1986 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Model).
The reallocatia
and/or reduction of ,
AUM'i
livestock forage
■alue of our base
_ Allotment will reduce the
property by approximately S . (Assume $50 per AUM value).
Please consider this economic loss in the requested "Takings Implication
Assessment. "
The letters from the Harney County CattleWomen, Stockgrovers, Farm Bureau,
Sheep & Woolgrovers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent vlth our
vlevs and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy Of text only for the reason that it vould be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments ve may have are enclosed herein
supplemental to our principal response.
Sincerely,
Kaye E. Smith
Name
111 Ponderosa Village
Burns, Oregon 97720
nd are
End osure .- Sup pi emcn tml Commen ts
1;
Refer to response 2-63.
<J»y C' rlwn - m-ji/-iiy
uurn,s uiMrict (.flies
cureau or L&ftiS i'iari'<.£ jaunt
nC ?4-12»J3 nl^hway P.Q West
riines, Crayon S'('($o
rvcVlc'.. CCkivKivrS
ueg.r wr. uarlson,
•a. nxvr,na ni'i-f /n, 1 o
<mv' C will result, in ? su
iha proposed nij, r;ct 3 en? t
ion ro uiat it if. nc I'-n^.--.-.
I r«st lr Alternative
una Final rhrea niver
nt ' ai lew 0*' c'Jr
irfuiIi 1 n rsaucirtf
eeoiicniortj. anit.
snfl u are conri^er&a ,
source kana£» men's tflan
Alternatives A , d
D'.ere •?! c^OTty v.ni'j.
Has fi2t; 01 oar Gpsr?ifc
. ihsrei ere , we r<s.:ae_ t
tftat prior to lr--ruin£_
and n-nvlron:neut,ai impact statement, A "T-ikingB implication ftsfseeaaieu
be comply Lea ?.fi authorized uy executive Crcer ico_;C 1 p.ee the jSOVft»,.o*r
a, iQco Memorandum to a±l Arsistant tjeoretaries and uiiraau uirecuors
iron; Docretiry or interior, Uonald 'It. HodelJ.
i'he reallocation and/or reduction of 2i0 A.Uil'a livestock icrage
In Wect Warm spr-ingr. Allotment will reduce trie value or our dace
property Dy approximately ^10,^00. Please consider tnis economic loss
in the requited "Takings impl: cation A-ssessment* tp
Sincerely,
Appendix 11-156
January 26. 1990
157
Jay Carlson - BKP/EE8
Burns District Office
Bureau of Land Management
H.C. 74 - 12533 Highway 20 Wesl:
Hines, OR 97738
Comments And Response to
Draft Three Rivers Resource Management Plan
And Environmental Impact Statement
The Draft Three Rivers RMP/EIS raises many concerns. The full impact
of reduced grazing as proposed in alternatives A, 3, and C were not fully
addressed. Especially , the negative impact upon the community and indi-
vidual rancher.
The BLM monitoring techniques and conclusions on livestock forage
are questionable. Management objectives vague, especially in the area of
surface water quality, aquatic and reparian habitat. The condition ratings
for the surface water and aquatic and riparian habitat are unreasonable a
and seem to be the "heart" of the proposed reductions in livestock grazing.
Yet, if cattle were to be removed from these areas, wouldn't wildlife and
wild horses still use these creeks and areas unless an elaborate and expen-
sive fencing system was implemented?
There is absolutly no basis for giving wildlife and wild horses
priority over cattle in forage allocations. This has already been contested.
In the West Warm Springs allotment, estimated capacity (8259 aum's) is
2908 aum's below active preference (11,167 aum's) and the range is classified
unsatisfactory. Appendix 3-114-115. Yet the average actual use (5952 aum's)
is half of the acitve preference. In the last three years the average actual
use had been only 4255 aum's 6912 aum's below preference. Plus this allot-
ment has had over 50,000 acres of burn due to lightning fires in the last
five years. In essence this range has been rested and allowed to revigorate.
The estimated earring capacity information is grossly inaccurate and reflects
the BLM's attempt to cut livestock grazing "across the board"-
The area shown as mule deer wintering range in the West Warm Springs
allotment is in error- The area mapped as winter range (Ch 3-30) was burned
of fin 1985 by lighting fire. This area doesn't provide any. browse ,, The
area mapped as winter range is also a short distance from- the Malheur National
Wildlife Refuge- The Refuge provides open. water all winter with springs
and a greater variety of feed. Any increase in aum's for deer in the West
Warm Springs allotment would certainly not be realistic.
The wild horse numbers in the Warm Springs allotments are above the
maximum allowed. In order to improve forage the first thing to be done
is bring those numbers back down to the proper level. Apparently forage
must be adaquate as the wild horses are reproducing at a fast pace. Any
reduction of livestock aum's for horses is unfounded-
Alternatives A, B, and C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
we request that if alternatives A, B, or C are considered that prior to :
issuing the Final Three Rivers Resource Management Plan Enviromental Impact
Statement, a "Takings Implication Assessment" be completed as authorized by
157-1 Refer to response 2-6.
157-2 The evaluations are done and figures are in the PRMP/FEIS (see
Appendix 1, Table 9).
157-3 Refer to responses 2-11, 2-17 and 2-87.
157-4 This area is generally used in early winter before snowfall and
temperatures become too severe and In late winter after snow melt.
Also, refer to responses 2-10 and 145-36.
157-5 The wild horses and burros are currently substantially below the
maximum number allowed in Che Warm Springs HMA as listed on an
inventory report dated December 8, 1989. Also, refer to response 2-6.
157-6 Refer to response 2-63.
157-7 Refer to response 2-36.
157-8 See Appendix 3, Table 7, DRHP/DEIS and Appendix 1, Table 14, Proposed
Plan.
157-9 Refer to response 2-87.
157-8
157-9
page 2
RMP/EIS Comment and Response
by Executive Order 12630 (sec the November 8, 1988 Memorandum to all Assistant
Secretaries and Bureau Directors from Secretary of Interior, Donald P. Hodd) .
The reallocation and or reduction of aum's livestock forage in West Warm
Springs allotment will reduce the value of our base property. Please consider
this economic loss in the requested "Takings Implication Assesmcnt. "
Much progress has been realized in striving for multiple use and im-
provement of range condition. Alternatives A,B,and C are not consistent
with those objectives.
In all the Alternatives including the "preferred" a huge anount of
funding would be needed for livestock range improvements. Funding and
personnel has not and probably would not be available. Therefore the only
course of action would be the reduction of livestock grazing to the detriment
of the livestock industry and community.
letters fro-:i the tiamey county Stockgrowers , CattleWomen, Farm Bureau
and the document prepared by Riddle Ranch and Western Range Service have
our whole hearted endorsement. Their responses have been submitted to you.
Rt ■conmenda ti ons
Alternatives A, B, and C should not be inplemented. They would be
devastating to a ocninunity such as Burns, Oregon that depends heavily on the
cattle and timber industry for survival.
The Drewsey and Riley MFP are working and should be continued.
Alternative D comes the closest to that objective-
Range improvement should continue as funds allow.
Long term studies should be conducted to determine vegetation and
range condition. Adjustments could then be made as the trends go up or down.
Grazing should be maintained at present levels until those trends are
definitly defined.
Sincerely,
William S. Peila
Please file a copy of this letter in my permanent file
Appendix 11-157
Depawneni ol
Rangeland RBSOUfCSB
College ol
Agricultural Sciences
University
1158
i. Oregon gn^S/CK
158-1 Refer to response 2-87.
158-2 Refer to response 6-8.
158-3 Refer to responses 2-7 and 4-2.
Mr, Joshua Warburton
District Manager
Bureau of Land Managers
Burns District Office
HC 7^- 12533 Hwy 20 Wes
Hints, Oregon 97 7 38
Dat
■ Mr. Uarbu
The Three Rivers Resource Management Plan and Environmental impact-
Statement reflects a tremendous amount of work on the part of your staff.
However , if. is completely unintcrpre table because no clear description of
the methodology used is given. The reader must accept that each data
point used is collected properly and with no sampling error. Therefore,
it is nearly impossible to evaluate the quality of the data included in
the report. 1 suggest a clear description of methodology for collection
of all data including actual sampling strategies must, be included so the
There is a general succcssional theory implied and sometimes stated in the
document that reduction or elimination of grazing will bring about a
reversal of current trends to domination by sagebrush and juniper, so thai
plant communities with increased herbaceous components will develop.
Unfortunately, current ecological theory and evidence clearly indicates
that succession is much more complex and that range management to create
the kinds of plant communities suggested as desirable will not result
solely from grazing controls. If you want a diverse, healthy rangeland
(.he total system needs management by application of ecological knowledge.
Direct control of woody vegetation in the upland environments is necessary
to achieve the rangeland structure and function as stated and implied
throughout the document.
The, understanding of management of livestock grazing is focused
principally on total numbers of animals placed on the range. Recent
knowledge of the critically important role of timing of grazing and
utilization of livestock grazing to direct succession in positive ways is
not adequately addressed. With current grazing management practices and
theory, as presented in professional journals and other documents, the
critically important environmental concerns in the area may well be
preserved without doing economic damage to the permittees. These options
to reduction in numbers are appropriate when sufficient usable forage
exists in an allotment. And, understandable when it is measured
correctly,
There are many questions this document raises such as the basis for range
condition evaluation or water quality and other items. However, the
process itself is really more troubling than the document. The structure
of the report may be required by law or policy, but the inevitable outcome
will be polarization of interests and no doubt dissatisfaction from all
parties interested in the Three Rivers Area. Within and among those
interested, there is a possibility to focus the energies of the BLM to
manage the rangelands to maximize benefits for everyone rather than
polarize the interests through allocation procedures. I hope BLM can get
this statement behind them and then embark on an aggressive program to
find concensus about land management among the interests and strive to
fully meet all of their needs. The potential and demonstrated successes
throughout eastern Oregon to do this is largely there, and good managers
can put these programs together.
Since
Bly,
William C/Kru.
Department Head
WCK:'bc
Appendix 11-158
^S- /Issocahon of
\^Z/ Oregon
s vlrchotologtste
li
Dedicated to Ihe protection and enhancement of prehistoric and historic archaeological resources.
Sl/A- &um* Oil***
He 74- IA533 Hu)y. io fcT
H***, O^ 1773S
r art* WrHmg you o« b*.hnitf 9+ tk* Aiicc.vi.or, rf OWgoft
ClWI *cEC dsscWWJ m ** TW ft.V«« ««.,« !*£»* _
StaWnT App^i.'x ?-a ^7-«S. *• fs^^br, «**., Actc
ebs^.OT, JWHir<«A HTiclueUd >'h +i.'i /iced. e«r«iLVl»Jr«- 'WW *'^ft«'+i'can1
CulWcJl ar*J 3^d(c.3«'^ V«fu«-& arj ^ long h.^cxy 0$ l""v"1 Ui<i
■ . | Kr-Cc'cuihtJi roeic kouftola arid a OoceJTi'oricJ t-!i<\T-
'« I. • k fcioeciej/y ^or t-xompk <a+ L.'-Hfe 6-lnJ.s6.4fej,
i ,-,i\a. to coft«mt ** geo'og.c rajot«<\.« -Vnr
c
rnaftafl€mi2ft
,-f plon sptt.'f.'c«Jf^ ftJdrtM.'ftg *»K
SkcivU U cUJopeol. -ril'S rrwp«gac™t*T pl°^ 3hcvJd ,i,oW
"3 '
<Lacr<?ni~ collfccinna o-£ ro^o ob-si>J.on mo4e* .'.4 Vfotn tt\e,
/\CEC .skoijd lot by permit Only. TK>1 guofi+.'+y 0+ mats-rvU to
l)/4i
159-1 Refer to response 152-8, last paragraph.
P.O. Box 40327
Portland, Oregon 97340-0327
CWd«»r, CuffawJ ACEC co.U.'d<d£ ' X 2 J
be. remold skoJd be ?."xa.tJ >> "fW p*r».t. TU *„„ ker 0£
perils i^-SUed e^cl yanc .Skotdd b& det<Lrn-> .'n ej fc^i^J 0n
C^i'ec^'Je^ S£r 'Y> +ke. rnahaaa^er^ i pfon wr o^suWno iong-tei
ooc'IclIo, I ,"1/ ©> oloS'' oI.'qd at -rte-se -SoiArce-s,.
2._) FK'n't - knapp.'^o 5
historic £i'+e.£. M«2ar
pre.|v'.stor;<u i.'+e-sl MEar-by o«o^ u.\+K na pre Ki'storit- moiir.ej
sUJd te. des.'gfiaisd fcr rzpl.'o^i.'vie. aod/or 2<f2f ,'nwn+ai wse .
^ne-se, rep'-'ca^'oo areas 5kot*Jol ^£ ^e-coi-JeJ uJ-'tk \be&<L loccCr.'o^s
r-e^orfecl to +ke Oregon StJe M.stor.t Preseru<d-('on off.ct.
Fl.Vt -knapp^o oti.J.tei conduced on -Hv«4Si. «spll'e«i.U« sffe^
tar 5- ^" da-ki'+aqt 5nocJd be reroojej ^ ^e rey^l.'c J ,'on
tv +^'e parion fi) tonJucXi'na "m£ -rliKr-tCiwjpi'n =
Ssd'n^'M, "^e otj'ecJ-.'de 0^ ^>'J ^cord/ng nrj oMs.-foge Pernod
cod to QWMftt rM>i'l*g O-f J't>: + £>3^ °"oi ar-+;$*Js ?rofn
•ff,'.
w(r^-us« s;fe, ^ 'rU- ^^*. prJs.'^nc 1.4...
3) e^p.na ar-d toos+r.ri.'w fi* ^Vs-pi'ts 3n0^ld fee.
prok,b,-4eJ ,'.4e Ok,.d,'»n C^+«r^ McHd .
Tkc^k-yo>A -Por your Co^^o.'na efforls ro moncg/n^
B^rns C^n'cJ r'n ft. S»*.,^« and t-l = nced progrom.
5('^cere-J
/;
Tom Connolly
fWcW , AoA
Appendix 11-159
u@©
February 7, 1990
Jay Carlson -rmp/Eis
Burns District Office
Bureau of land Management
H.C. 74 - 12533 Highway 20 West
Hines, Oregon 97738
Canroents Aici Response to
Draft Three Rivers Resc — i Management Plan
And DivironiTienl'fll Impact Statement
I would like to endorse the letters sent to your office by the Harney
County Stockgrowera , CattleWoman, Farm Bureau and the document prepared by
Riddle Ranch and Western Range Service.
I have a few thoughts of my own to pass along- We have a permit in
the West Warm Springs Allotment and having spent the last few years
tending to our cattle and helping neighbors I am amazed to learn that a
reduction in aum's is even beign considered. The use of aura's is way down
in proportion to the preference and the feed is abundant. There
were miles of range our cattle never even saw let alone grazed, just in
our allocated area-
My recommendation, concerning alternatives A, B, and C should not be
implemented. Our community is unstable at best and the economical impact
would be gigantic.
Sincerely,
161
Refer to response 2-11.
161-1 I
161-2 |
161-3 I
161-4 I
161-5 I
161-6 -
March 16, i990
Janet L, Stewart
P.O. .Box-' g^
Antelope, Oregon 97005
District Manager
Bureau of Land Management
HC-7412533 Hwy. 20 West
Hines, Oregon 97738
Dear Sir:
T maintain that alternative "c" BLM1 s"preferred" (cow)
alternative of the EIS is an ecological didaster .
T demand that the BLM adopt Alternative "A" (the"Naturai values"
alternative) which would at least allow a token amount of
recovery to occur until such time as they complete an
alternative that will allow for full rangeland, raparian and
stream recovery.
Water quality, raparian and aquatic habitat must be improved/maintained
in excellent condition .
161-1 Refer to response 2-44.
161-2 Refer to response 12-1.
161-3 Refer to response 12-7.
161-4 Refer to responses 1-11.
161-5 Refer to response 2-78.
161-6 Refer to response 3-6.
161-7 Refer to responses 2-6, 2-10 and 1-13.
161-8 The manager at the field level who is currently responsible for the
implementation of the RMP is the Area Manager, Craig M. Hansen. The
manager who has the authority to approve the RMP is the State
Director, Dean Bibles.
All ancient forest must be identified and protected .
All costs of construction of new roads and other rangeland
projects be included under the various alternatives along
with their environmental impacts-
See that all crested wheatgrass seeding proposals be
el iminated-
T demand that bighorn habitat protection and impacts be
addressed in the plan and further , that forage allocations
intirely to bighorns in their home range.
I request that wild and Scenic River designation be given
for all of the South Fork and Middle Fork Malheur Rivers
(except for the reach through the Drewsey area}i all of
Bluebucket Creek and all of the Si ivies River .
I recommend that wildlife
be given priority over li
winter range for sage allocations
estock allocations .
I I would like to know the name of the/m/nager to whom I writ-
•J^Cts^A^
Appendix 11-160
Bureau of Land Ma
Burns District Of
HC 74-12533
Highway 20 U
Mines, Oregon 977
W2
Malheux Field Station
HC 72 Box 260
Princeton Oregon 97721
12 February 1990
Refer to response 6-13.
The South Narrows ACEC designation will be retained. The Bureau
expects to continue the activities begun under the Stephanoroeria
malheurensis study plan. The Proposed Plan presents management
actions that the Bureau expects to undertake for RNA/ACECs and otl
special status plant species.
Who
It Hoy Concern.
There ha a been much work and tesBorch put into the preparation of the
Three Rivera Resource Managwent Plan, and many people- have made
contributions . There are two areas about which 1 wi&h to comment .
This is because- J personally have spent a lot of time doing research
on the aroas, the issues involved in land uau management , and the
different peoples who benefit from how the areas ore managed . 1 am
MOT againat grailng, per ae ; however, J em in favor of managing when
areas ere open to grazing.
First, in Vol I Chapter 3 page 48 end vol II Appendix 7-11 the
BISCUITROOT CULTURAL ACEC : I have spent 11 years conducting plant
community research on Stinking Water in the areas where the Burns
Paiute dig there spring "root." crops. Thi s work has been done with
two anthropologists with them studying the social aspects of the.
activities end I studying the plant dynamics and change in relation
to environmental changes, human activities , and animals making an
i ft pact on the plants (antelope, rodents, rabbits, and cattle) . This
is a total systems approach; however , the food plants are only
available and above ground from April into early June.
Elsewhere in the inner mountain West, research has been done
to indicate that cattle prefer not to graze on the alternating spongy
and rocky spring llthosola. This is not the case on Stinkingwater
and during the past, few years, the cattle have caused destruction of
the small stream through one of the main collecting sites, compacting
of soils with trails thruough the area, and actual grazing of the
tops of the "root" food plants . I have photo documentation of all
these influences. This is a resource that is eviaiable during a
Imiied time every year and can not stand the competition of both
cattle and humans . I recommend that if there is grazing in the area
that it be excluded from early Apr il through the middle of June .
The anthropologists working with the Burns Paiute
recommended earl ier that the main Pine Creek camp site not be used
for a gravel pit ; however , this information was not available when
the decision was made or it was ignored. This ia one of many
lithosol areas that ere rich in food planta during the spring, but
are "bare racks" during other parts of the year . This ia not the
first excellent root gathering site I have seen ruined by gravel
pita. Now that thia area has been "claimed" by the Burns Paiute as a
area used for centuries by their ancestors, the gravel pit should be
abandoned and no more pit expansion allowed.
My colleagues and I plan to continue our research if
"outside" influences do not destroy the resource entirely . If the
BLM ia truly going to manage for "multiple use" in this relatively
small area, which ia critically important in the variety of "root
plants" and has thus far demonstrated resi 1 ience in recovery from
outside impacts (cattle and pit barrouing), the area ehould be top on
tPhe list for a CULTURAL ACEC.
page 2
Another concern of mine and one that- I hove etudied, guarded and
worked with the BLM to protect and manage wisely, is the. continuation
of the STEPHANOMERIA MALHEURENSIS ACEC protection. In the case of
the RMAs and other plant areas of concern. The BLH nor the botanical
community have enough information on these plant communities.
Malheur Field Station is helping with research in these areas and
those studies Bhould continue. I concur1' that the ACECa listed in Vol
II Appendix 7-2 should have limited disturbance and "outside" use.
One of the goolB of MFS is to encourage interest and scientific
research in these areas by scientists from all over the USA. The
philosophy in this county appears to be that grazing is a "given" and
that the public must come up with r ea&ona not to graze. That is
backwards. Each area is unique and c»n tolerate different rates of
grazing , grazing times t if any), or in some cases, the si ightest
disturbance is permanent damage: toe natural biosysTL&m snould
determine the use not human assumptions.
Thank you for the time, effort, and thorough discus
ucments for managing the Three Rivers.
of th€
Lucile A.
Botanist/
us ley
log i st/ethnobotan i at
Appendix 11-161
mt
burns District Off
HC 74-12533
Highway 20 W.
Hines, OR 97738
Attn. Jay Carlson,
RMF/EIS Team Leader
Mr
Carls
the Three Riv
■rs Resource Management Plan,
itions concerning permittees on
the effects this plan would
BlI ACEC,
3 of-f«Ct
Concerni
here are some specific obs
the House Butte allotment
have on their permit.
In reference to the Biscuitroot Cultur
reduction in this area could have a negativ
present livestock use on the House Butte allotment #5529.
The present AMP on allotment W5529 has been in place since
1983 and the condition has steadily trended upward with very
little, if any, effect of the availability of the cultural
plants gathered by the local Indian tribes. As near as can
be detected, livestock grazing has a positive impact on the
species of plants that are utilized by the Indians. The
species gathered by the Indians are not palatable (except for
wild onions) , therefore, livestock grazing would help the
species gathered by the Indians by reducing the competition
these plants face.
In the 1950's and 60's, when the House Butte area had
much heavier livestock use, and the Biscuitroot ACEC was
grazed much more severely than it is under the present
system, many more native Americans used the area for root-
gathering. Since there are less livestock in this area since
implementation of the AMP in 1982, a good crop of plants that
the Indians gather has been maintained. We, therefore,
cannot support a reduction in livestock grazing concerning
the Indian root— gathering without mare val id scientific
research then what was used to arrive at the conclusion in
the Three Rivers report. ■
Concern ing range improvemen ts on the House Butte
allotment, the preferred alternative for this allotment
presently has 2 spring developments for improvements. This
falls short of a range management program. There are at
least 4 springs to develop on the allotment. Three (3)
reservoirs could also make for a better distribution of
livestock, as well as a small bit of fencing. we as
permittees would consider the cost of developing the range
for the betterment of our livestock, as well as wildlife use.
These practices should be considered before making a long
range plan since their implementation would improve the
condition of the range even more, which should be the primary
goal of the BLM, anyway. Also, approximately 3,000 acres of
the allotment could be utilized better with brush treatment
and reseeding a more palatable grass such as crested wheat.
Another totally unacceptable idea brought forth is the
idea of limiting upland utilization to 307. and to 10"/. in
163-1 Refer to response 4-15.
163-2 Refer to response 145-53.
163-3 Refer to responses 2-7 and 3-13.
163-4 Refer to response 2-46.
163-5 Refer to response 3-9.
areas with woody riparian shrubs. There is no valid
scientific base behind this decision and is obviously aimed
at reducing cattle numbers ever more since these percentages
are totally unworkable in a good grazing system.
Removing livestock from streams entirely and the mis-
management of their wild horse program are examples of more
poor decisions by the BLM that would adversely effect
everyone who grazes public land.
The continual fencing of reservoirs adversely affects
permitees in the House Butte allotment. These reservoirs,
incidentally, were developed from funds supplied by the
permitees in this allotment. This practice is in direct
conflict with the BLM ' s objective to disperse livestock away
from riparian areas and improve forage utilization.
Another concern for the House Butte permittees is the
unscientific conclusion by the BLM that livestock grazing
adversely affected the population of sagegrouse population.
This statement couldn't be further from the truth. There are
several large bunches of sagegrouse in this al lotmen t as any
researcher who might be doing a study of them would see if
they had taken the time to OArry out anything approaching a
valid, scientific study.
The above issues summarize the concerns of the permitees
on the House Butte allotment. Although some of the decisions
made in the Three Rivers plan do not affect us directly on
our allotment, we sympathize and completely support livestock
owners who have permits in other allotments who are being
affected by the arbitrary and subjective decisions made in
the report - decisions that have no recognized and accepted
scientific research methods to back them up.
The rancher of today recognizes the need for stewardship
of the land and has cooperated with the BLM in all management
decisions made to improve the public land . The current trend
with the BLM - in their zeal to get the "environmentalists
off their back", who want all cattle off of public land - has
changed .their research methods. They seem now., to have the
conclusion - that being to reduce livestock numbers - already
established and then must re— organize all the data to fit
that pre— determined conclusion. This blatant "slap in the
face" of a rancher's intelligence will lead to a more unified
group or ranchers who now know how to pro tec t themselves —
even if legal means must be used.
In conclusion, the rancher has done a good job in
improving the rangelands and any attempt to discredit this by
a report like the Three Rivers Resource Area plan, with its
unscientific, biased opinions, will not be accepted.
Respectfully submitted,
Box 162
Drewsey, OR
Z. Clark
James H. Sitz
Drei.
OR
Harvey Cronin Helen Opie,,
Drewsey, OR Drewsey, OR
Appendix 11-162
164
Jay Carlson- 3JX/SXS
Burns District Office
Bureau of Land Management
HC 7;i-12533 Highway 20 West
Hines, Oregon 97738
!:clen Lpxs
3rswsey, Orsfon
/obruary.j5., 1990
164-1 Refer to response 2—10.
Conttianta Conccrnin,;- rudely Creek Allotemsnt h|'550i
The "n-dy awe.*: allfltaMilt !tac b»« :., a i,i*OAttfof'l AIT eir.Uffl 1:33
anlhaa completed five cycles. This system lias worked well, and nuif-re
conditions have improved:. DU£in£ this time, elk population has increased
in this area. The BLK wanta to take 20 a.'.'.K.'s from livestock and give
to the elk. The elk population would not have increased over the past
seven years if there was not an abundant amount of forage, [■fad this
fora.-e not "been there, the elk would not have moved into thin area.
I cannot support any reduction in livestock grazing for improvement
of water quality, ^he majority of Muddy Creek lies on private land.
I cannot believe that the water quality is poor in this stream. There
is plenty of forage left in this allotment to control any erosion.
I Velieve that livestock grazing at the present rate has a
positive inpact on the ran^e conditions or iluddy Creekl
Respectfully,
Helen Gpie
'Qfju
"I «ST3j6«
nm
P.O.BOX 5
Princeton, OR. 97721
February 12, 1990
Jay Carlson - RHP/EIS
Burns District Office
Bureau of Land Xanagement
HC-74 - 12533 Highway 20 West
Hines, OR 97738
Dear Kr. Carlson,
Let me begin by saying, I am a rancher and proud of It. I was born
and raised on a ranch as was my husband. Ve now are raising our family on
a ranch. Ranching is not only a job but a way of life. Sometimes I think
people who work at a set job havG no concept of just how we live. Ve don't
have any set hours, hourly wages, benefits, etc. The amount of years we
put Into ranching don't entitle us to a raise or promotion. Ve still are
dependent on some very volatile things. Ve are tied to the land-
Therefore I feel most ranchers are good stewards of the land. Ve are
dependent upon it for our existence. If we misuse or abuse it we are only
hurting ourselves. Many ranchers are multi-generation ranchers and hope to
keep the ranch in the family forever. So why would we do anything to harm
the environment?
Ve are not part of the "back to nature " movement because we never
left. Ve've always been in tune with nature. Ve are in a unique position
that we not only observe the wildlife in their natural environment but we
also contribute (quite heavily at times) to their very existence- The deer
and antelope flock to the private hoylands during late summer when the
green is gone from the rangelands. This contributes not only to their
winter survival but puts them in better condition for the breeding season.
In the winter time they also eat right out of our haystacks, ruining as much
or mare than they consume. Ve pay a fair price to graze on the public
lands yet receive no compensation for supporting the wildlife. Hot even
acknowledgement !
As for the wild horses, let me soy many ranchers like horses; yes,
even the wild ones, to a point. There have been wild horses in certain
areas for years. They weren't considered a big problem until the federal
goverment decided to manage them. First the BLH said they owned the
horses. Ho one else could round any of them up for use, resale Dr
whatever. This was the only way the numbers had been kept in check over
the years and it worked. Sow the BLH spends millions of our taxpayers
dollars to run the wild horses, haul them in, feed them top quality hoy,
provide veterinary care, build expensive corrals, and to run the Adopt-a-
I Horse Program. They release quite a few so in a few years this must be
done again and again. But all this isn't enough, they want to make huge
allotments to make HHA areas. Possibly even condemning private land! I
can't believe the BLH would put the horses, who are thriving ahead of
ranchers livelihood. It must be easy to sit in an office and say a 30% cut
here and here is no big deal. But to some people it's an end of their way
of life! PEOPLE, like you and I. not animals! The wildlife and horses will
survive but will the family ranches?
The cattle are supposedly ruining the water quality but yet the horses
and wildlife never seem to be mentioned. Personally I Just don't see the
problem. I'm much more turned off by the campsite litter and other human
abuses. I would really hate to see all the creeks and reservoirs fenced
off. I like to fish along a creek where the cows have grazed as the
mosquitos are not so bou ntiful and I can see a snake In the grass. God
made all the creatures large and small and they can and do live in harmony
if we will just quit meddling.
I want to go on record that I wholeheartedly agree and support the
letters by the Harney County Stockgrowers and the Kiddle/Western Range
Services.
I would like to add another comment and personal concern. In the
Draft Three Rivers Kanagement Plan Vol. 2 Appendix 3-17 Table 6 , Allotment
Management Summaries, the allotment identification categories were
mentioned and Identified as M, I, & C. However, no where did it say what
these stood for! After looking through both volumes several times I did
find it in the glossary of Vol.1 uaderjifilfisiixe. Management Category. At
this point I at least knew what the "I" stood for on our allotment. Yet I
do disagree on the matter, How can it have an estimated capacity of
773aums and an actual use of 451 and need improvement?
It Is mind boggling to think how much time and money went into this
draft of five "different" alternatives when common sense could do it all so
much more just and efficient.
Sincerely,
Vfl
Hary Jh Davie:
165-1 Refer to responses 4-14 and 11-11.
165-2 This will be corrected in the PRMP/FEIS.
165-3 Refer to response 8-4.
Appendix 11-163
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Nines, OR 97738
liS©
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carle
(If you are facing a reduction in AUM's, please Include the next two
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
ve request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a 'Takings Implication Assessment' be completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Model).
AUM's lijyesi.ock-forage
educe the value of our base
property by approximate! vS. — ~- — f Assume~~S50~ per—A-U/l-JdaJjje).
Please consider— ttiilT~economic loss in the requested "Takings ImplTcatfoh
AssessjneJrt. *
The letters from the Harney County CattleWomen, Stockgrowers, Farm Bureau,
Sheep & Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
meat identified.
Any additio
supplemental to
1 comments ve may have are enclosed he
ur principal response.
nd are
Sincerely,
Dora M, ^\e. ni/sqa/
i^jhM n ' M
A d dress
14-
f77S.U
State Z±P Cade
jna t ure ff
Sign a
Enclosure: Supplemental Comments
January 17, 19
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Nines, OR 97738
167
No comment identified.
REVIEW COMMENTS FOR THE OCTOBER 1939
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson:
(If you are facing a reduction in AUM's, please include the next two
paragraphs. If not, cross out second paragraph. )
Alternatives A, B and C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
we request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a "Takings Implication Assessment" be completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Model).
reallocation and/or reductl
Totment
AUM *B livestock forage
11 reduce the value of our base
'50 per AUM value).
in the requested "TaTrtmss — Implication
property by apprjve^itnTPely S_
Please cpju*fB~er this economic
■s~ment. '
The letters from the Harney County CattleWomen, Stockgrowers, Farm Bureau,
Sheep S> Woolgrowers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication Of the Riddle Ranch document and organizations letters.
Appendix 11-164
168
Feb.. 13, 1990
Mr. -Jay Carl'son
Burns District Office, B.L.M.
HC 74, 12533 Hwy. 20 W.
Hine-s, Ore. 97738
Dear Mr. Carlfon:
We just wanted "bo writs a line or two to let you know ion
we feel about the reduction of Aum's on our BLffl permit.
If our permit io cut 30-35$ this naturally reduces our
income and our land value by this same percentage.
The water, situation nends to be improved in our area to
that we could utilize the feed better.
We sincerely hope that some consideration will be given
to the points which we have mentioned above.
Sincerely,
Mary G. King
m^i
168-1 Refer to response 2-7, 2-11, 2-49, and Appendix 3, Table 7, DRMP/DEIS.
Appendix 11-165
Richard A. Parrish
Attorney at Law
215 S.W. Washington St., #200
Portland, Oregon 97204
222-5339
H
February 13, 1990
Craig M. Hansen, Area Manager
Three Rivers Resource Area
Burns District, BLH
HC 74-12533
Hwy. 20 West
Hines, Oregon 9773B
Re:
ants on Draft Three Rivers RMP and EIS
Dear Mr. Hansen:
These comments are submitted on behalf of Portland Audubon
Society (PAS) , and are intended to supplement those submitted on
their behalf by Linda Craig. We appreciate the considerable
effort expended in preparation of the Draft Three Rivers RMP and
EIS, and especially the efforts of you and Jay Carlson to explain
the details of the document to interested members of the public.
My comments will be limited to that portion of the document that
deals with the potential for gold mining on BLM lands in the
Resource Area and the potential environmental impact associated
with that possibility.
Given the significant developments in cyanide heap leach
gold mining activities in the BLM Vale District, and the
recognition that claims staking activity is increasing in the
Three Rivers Resource Area (p. 9-17}, we believe you should
conduct a more thorough and detailed analysis of the likelihood
of such activity and its potential impact on the environment
within .the Three Rivers Resource Area. As it stands now, the
document barely acknowledges the potential for such development
and associated impacts . See p. 3-53 ; App. 9-17 .
The "generalized gold mining scenario" that you included ,
pp. 9-18 to 9-20, deals entirely with the economic impacts of a
hypothetical gold mining and processing operation. It is
interesting and informative . However , a similar analysis of the
environmental impacts of such a hypothetical operation should be
included. You might determine, for example, that there is
insufficient surface water or groundwater available to support
such an operation, which might in turn affect your management of
the resource.
169-1. There presently are no plans of operation for the RA. If and when a
plan of operation is submitted, an EA or EIS would be prepared as
part of the process for analysis and public review prior to issuing a
final decision on the plan.
169-2 Refer to responses 5-18 and 169-1.
169-3 Refer to responses 153-8, 169-1 and 169-2.
169-4 Refer to response 169-1. A plan of operation, as outlined in 43 CFR
3809, makes it incumbent on the operator to commence reclamation at
the earliest feasible time and Include, among other measures, the
prevention or control of on- and off-site damage to Federal lands;
saving topsoil for final reclamation; controlling erosion and runoff;
Isolating, removing, or controlling toxic materials; revegetating of
disturbed areas where reasonably practicable; and rehabilitating of
fisheries and wildlife habitat.
Experience has shown that cyanide heap leach gold mining and
processing operations are likely to contaminate the land, air,
and water and are likely to have at least some impact on
wildlife. The availabil ity of groundwater is a critical issue
Printed on Recycled Pnper
Craig M. Hansen, Area Manager
February 13, 1990
Page 2
for wildlife and range condition in the Three Rivers area. You
stated that an analysis of the impact of the overall RMP on
groundwater will not be attempted because of the lack of data (p.
3-2). With the undeniable potential impact of gold mining on the
groundwater resource, through both contamination and depletion,
we believe you are obligated to develop the data to support a
reasonable discussion of this issue. In the absence of any such
data, but with the knowledge that such developments are
reasonably likely to occur and to threaten the resource, we
believe you are obligated to conduct a worst case analysis of the
potential impact. See 40 C.F.R. Section 1502.22.
Similarly, the potential effects of mineral development on
surface water quality are "impossible to predict." (App. 1, T-4)
Again, if some effect is reasonably anticipated, the data must be
developed or a worst case analysis conducted.
Finally, the degree of reclamation of the land disturbed by
the gold mining operations would have a long-lasting effect on
the wildlife in the area and on the recreational use of the area .
These issues should be thoroughly explored in determining the
management plan for the area for the next 10-15 years.
As you may know, the Vale District of the BLM is preparing
an EIS on a gold mining and milling operation proposed for Grassy
Mountain in Malheur County. Ralph Heft of that office would
certainly have an abundance of information on the potential
environmental impacts of such a scenario.
Again, we appreciate the opportunity to review and comment
on the draft rmp and EIS. We would be happy to work with you to
fill some of the gaps in the analysis, and we look forward to
reviewing a more detailed analysis of gold mining prospects in
the Three Rivers Resource Area in the final RMP and EIS.
Sincerely,
^frj^ /(^IvU
Richard A. Parrish
for
Portland Audubon Society
Jay Carlson, RMP/EIS Team Leader ^
Linda S. Craig , Portland Audubon
Appendix 11-166
170
January 17, 1990
Refer to responses 2-1 through 2-96 which are responses to issues
submitted by Riddle Range and Western Range Services.
Joshua L. Warburton, District Manager-
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, OR 97738
REVIEW COMMENTS FOR THE OCTOBER 198
BLM DRAFT THREE RIVERS RMP/EIS
The January 17, 1990 Riddle Ranch and Western Range Service
Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent
with our views and comments.
This response is our endorsement of such Riddle Ranch
document. Their response has been submitted to you. We do not
include a full copy of text only for the reason that it would be
an exact duplication of the Riddle Ranch document.
Any additional comments we may have are enclosed herein and
are supplemental to our principal response .
Sincerely,
■^sULJd^
Name
City
State zip Code
Signature
Enclosure: Supplemental Comments
171
HC 72 Box
Princeton,
February 8,
]R 97721
1990
Jay Carlson-RHP/EIS
Burns District Office
Bureau of Land Hanagement
HC 74-12533 Highway 20 Vest
Hines, OR 97738
Dear Mr. Carlson:
1 will avoid repetition and state that the 1990 Riddle Ranch and
Vestern Range Service Comments and Response to the Draft Three Rivers
Management Plan and Environmental Impact Statement very adequately
states and stresses my concerns.
1 would lilce to add some other comments:
First, with all these cuts in cattle grazing, the BLH will have
less funds for all of its programs. Is this money going to come from
the already overtaxed federal budget? Currently we have a management
program that includes grazing, with the people and government managing
the public lands with a generation of income. This is beneficial to
both the taxpayers and permittees.
Speaking of economics, I felt the statements Id Vol, I p. 4-68
"sugar-coated" actuality. Hany permittees cannot "absorb income loss. "
They carry large debts and bankruptcy may be the alternative. Due to
the climate of this area"change seasons of use on base property"would
only be a alternative for a very few. They too would have to reduce
herd sizes thus their income. "Capital expenditures on base property to
increase productive capacity", could be impossible with less income and
less borrowing power. Diversifying crops Is limited due to low
precepltation and climatic conditions. Leasing oi private land isn't
even that available at the present. "Seek employment in non-agriculture
sector" - in Harney County?!' Even your Impact Statement elsewhere
mentions the unemployment problems. There will he some indebted
ranchers too young for retirement and too old for another occupation
with a ranch worth less than their debt, if the reductions are too
severe. Also what about the lost revenue to Harmey County for its
schools, hospital, and other vital services?
I see where Riddle/Coyote has an unsatisfactory range condition.
The surrroundlng area has a satisfactory range conditions. This area
would be In the same condition had it been allotted to a permittee. The
owner was in the process of trading the property consequently the fence
was let deteriorate. A permittee with a permanent allotment would have
kept the fence in repair. Riddle/Coyote needs to be allotted and
managed.
Fencing more riparian areas has been proposed even in the preferred
alternative. Vho is to keep this fence in repairtcost and labor)?
If the BLH wants cattle kept off part of the public land they should
provide maintenance. That is how it works In private ownership. Anyone
wanting to be close to nature is sure to find the fenced creeks an
unwelcome sight. If later, these fences are deemed unnecessary or not
in accord with nature and the environment; is the BLH going to clean up
the wire etc. or leave it as an eye-sore and a threat to wildlife?
In Alternate C (the preferred one)- "Acquisition of riparian areas
and wetlands would assure water availability for horses in Klger,
Stinkingwater, and Varm Springs HKAs throughout the Year". I understand
this to mean horses will be grazing riparian areas and wetlands all year
round, not Just a few months as do cattle. They obviously are not going
to be fenced off these riparian areas. Are they less damaging than a
cow? "Aquisitlon" , is private land going to be taken for the horses?
The horse population if left unchecked will expand. Horses (once mature)
have no natural predators or a hunting season as do the big game
animals. The wild horse papulation must be controlled. Private land
should never be condemned for the wild horse!
Our public land has remained in its Dear natural state for many
years under the present multi-use concept. Hany of the range
improvements for cattle have been very beneficial to the wildlife as
well. Some examples include: crested wheatgrass seedings provide more
foroge and water development which provides not only more water but also
less concentration in certain areas. Some other management practices
done soley by the permittee such as salting, haul ing water in a drought,
and cutting ice for water in tie winter is a definite help for the
wildlife.
ely
^c^^^G)
171-1 Refer to responses 2-61 and 28-1.
171-2 This parcel has recently been exchanged to the Bureau. No
site-specific management has been developed. Until a management plan
can be developed, the preferred alternative is to not allocate
Riddle-Coyote Allotment to livestock use.
171-3 See the DRMP/DEIS, p. 3-16, for the Bureau Range Improvement
Maintenance Policy, When the Bureau deems a fence unnecessary, the
unneeded fence materials are removed to prevent a hazard and/or
eyesore.
171-4 Refer to responses 2-6 and 43-2.
171-5 Acquisition of any private land would be to the benefit of all
resources. Also, refer to responses 4-13 and 11-11.
Appendix 11-167
V DASH CATTLE COMPANY
DBEWSEY, OREGON 979EM
Fsbruary 12, 1990
172
Jay Carlson
Bureau of Land Manas em
H C 74 12533 Hwy 20 W
Mines, OR 97738
De
Carlson:
You and your team are to be congratulated on the completion
of the Draft Three Rivers Resource Management Plan and EIS document.
It is readable and fairly understandable, but seems to be lacking
in at least a couple areas, to which I will confine my comments.
One
fundamental — If
augment the e c o 1 o g i
ource.
e to manage and dcrivB benefits
within the bounds, and try
t first made it a desirable
172-1 Lightning-caused fires are a natural process; however, suppression
policy is mandated at the Departmental and Bureau level. Refer to
response 4-9. Since the overall or total suppression policy Is not
changeable at the District level, comments on this concern will be
forwarded to the Oregon State Office.
The prescribed fire program also has established policy that must be
adhered to (refer to responses 4-8 and 4-9). The proposed annual
prescribed fire acres are based on limiting factors with smoke
emissions and funding being two of the major factors. Yearly burning
of 2,000 to 3,000 acres over the next 10 years is a definite step
forward.
172-2 Refer to response 4-3.
The proposed policy of "agressively suppressing" all wildfires
goes outside these bounds. Granted, life and property must be
protected but to thwart the natural process in it's every attempt
to cleanse and rejuvinate itself is not good resource management.
The consequences of the lack of fire this last cenLury are
like an open book if one will but read — the continuing reduction
of the gross cover that holds the soil in place and allows precip-
itation to seep into the ground where it falls; the far Loo numerous
watersheds covered with stagnant stands of brush that is a sorry
substitute for grass in waterholding capability; the encroaching
juniper thickets that are turning thousands of acres into gullied
wastelands; the springs and creeks that go dry in the summertime
because precipitation that should have percolated slowly through
the soil to feed them has rushed off in a silt laden flood.
We can assist the natural process in many ways (this is what
resource management is all'about) but trying Lo totally eliminate
wildfire while replacing it with only a minuscule amount of prescribed
burning is most certainly self-defeati
Thi
al
li L> LI I I-
in the long run.
ion" policy needs to be
Another area that might be misleading to some, is the class-
ification of range conditions as poor, [air, good, and excellent.
It should he explained just what criteria constitutes each of these
ratings. To classify range allottments as poor when they don't have
the potential to ever be much better would seem to be an injustice
Lo Lhe operators involved.
Thank you for the opportunity to comment.
173
January 17, 1990
Refer to responses 2-1 through 2-96 which are responses to Issues
submitted by Riddle Ranch and Western Range Service.
Joshua L< Warburton, District Manager
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, OR 97738
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Warburton:
The January 17, 1990 Riddle Ranch and Western Range Service
comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent
with our views and comments.
This response is our endorsement of such Riddle Ranch
document. Their response has been submitted to you. We do not
include a full copy of text only for the reason that it would be
an exact duplication of the Riddle Ranch document.
Any additional comments we may have are enclosed herein and
are supplemental to our principal response.
Sincerely,
Steens Mountain Ranch, Inc.
Name
Darrell Otley
HC ?2 Ro:c Vj
Address
Princeton. Or. Q77?1
City
Signature
Enclosure: Supplemental Comments
Appendix 11-168
1i 74
February 1J , 1990
Joshua L. Warburton, Dii
Burns District Office
jureau of Land Matlftgasiai
HC 7^-12533 Highway 20 I
Hines, Or 97738
trict I'.anaf^or
Review Comments For The October 1989
BLM Draft Three Rivers HHP/EIS
Dear Mr. Warburton:
Wo wish to go on record that the January 17, 1990 Riddle Ranch and Western Range
Service Comments and Response to the Draft Three Rivere Resource Management Plar.
and Environmental Inpaet JtatemenL are consistent with cur views and comments.
The enclosed response is our endorsement of ouch Riddle Ranch document. There ar
several other areas of concern that this letter will address.
(36,619 acres) as
conomical effect
the Final Three
lent" should be
Order I263O. Livestock and wild horses have
years. The complete elimination of livestock grazing
The designation of the entire Kiger Active Horse Management a
an area of critical environmental concern will have a dramati
on at least one ranch. Before the change is evem considered ,
Rivers RKP/EIS is issued a complete "Takings Implication A
conducted as authorized by
run together successfully f
either Justified or proven necessary. Wild horses should not have higher
priority for forage than other multiple uses. Livestock grazing preferences were
legally established long before the passage of the Wild Korse and Burro Act. In-
volving the permittee in the decision making process would be beneficial to both
the BLM and the permittee*
There is no scientific data that indicates that livestock use has any negative
effect on the sagegrouse population. The restrictions on livestock in the sage-
grouse strutting grounds are unfounded and should be eliminated.
Tbe exclusion of cattle on the Biscuitroot Cultural ACEC is not supported. The
report states "these' areas to be a high-value resource due to the quality and
quantity of roots available." Since grazing has been going on in this area for
years and. the quality and quantity have remained high, even with root harvesting,
there is no justification to change the practice.
The surface water quality and aquatic and riparian habitat condition ratings
appear to be inconsistent and unrealistically restrictive* If water quality
conditions are as poor as 3LK claims (86So of the streaas are reported to have
poor surface water quality) one would expect that there would be no fish left in
the Resource Area0 These water quality ratings (surface, riparian and aquatic)
are the basis for the majority of the adverse impacts to livestock grazing.
All available information indicates that current upland grazing practices are
having no signif icanjt adverse impact on surface water quality 0 There is no
scientific basis for limiting upland utilization limits to J>Q%. The 10> util-
ization limit for woody riparian shrubs is also unreasonable and without scien-
tific basis.
174-1 Refer to responses 2-63 and 2-68.
174-2 Refer to response 2-6.
174-3 Refer to responses 3-9 and 4-6.
174-4
174-5
174-6
174-7
174-8
Refer to response 4-15.
Refer to responses 2-3j 2-25, 2-44, 6-3, 6-4 and Appendix 2 of the
DRMP/DEIS.
Refer to response 2-7.
Refer to responses 2-5, 2-11 and 3-13.
Refer to response 6-8.
The proposal to remove livestock from streams will disrupt current, successful
prazing" systems and will have long-lasting adverse impacts en livestock operations.
Only a Portion of the streams nre publicy owned. Therefore, BLW'S proposed actions
will have very little, if any, effect on overall stream conditions.
e biggest problems
ain the
n times in the last thirty years,
h Of the moisture that could otherwise be used for the production
The juniper infestation in the higher elevation
facing the BLM and Rancher today. On the nothern slopes of Steens
juniper population has increased at least
thus consuming
of forage.
Thank yo
for allowing >
to comment.
Sincerely yours^, A
Steens Mountain Ranch, Inc.
Darrell Ctley
Appendix 11-169
175
Box 53'j-
Hines, Oregon 97738
16 February looo
Refer to response 73-4. Also, the limiting factor to California quail
on lands within the planning area is thought to be riparian
condition. The proposed improvement in riparian condition will
greatly benefit California quail.
U.S. D.I. BUREAU OF LAND MANAGEMENT
Burnsi District office
HC 7^ - 12533 Hwy 20 West
Hines, Oregon 9??38
browsing thru the Draft Three Rivers
Gentlemen:
Last nite 1 spent a few minute
Resource Management Flan.
I would have liked you to pick Alternative B - Emphasize Natural Val-
ues With Commodity Production as your Preferred Alternative. Given
the political situation you folks are in, Lhn, especially .in depen-
dant communities such as Burns, your choice of Alternative C was
probably the wisest pick.
The one thing that really bugged me about this Plan was the lack of
reference in it by name to cither the Chukar Partridge or the Cali-
fornia Quail upland game birds. I think you may not realize what an
important resource these beautiful little birds are to some of us
local folks. . I. spend more.. than a. week every year hunting these won-
derful little birds; I am certainly- not alone out there when I1 am
hunting them: And all of my hunting effort is spent on the lands
that you manage, as I don't care for the hassle of seeking permis-
sion to hunt these birds oh private land. ' . " _' ; ■:
■In ray opinion, then, the Chukar Partridge and the California Quail
deserve more than to be lumped in to the category "Nongame Animals
and Upland Game Birds", a category that itself received very little
analysis effort from you. I am not asking that you. spend big bucks
in managing these little birds'; I' know that that 'would not "be real-
istic. But .1 think you need t.o show in your Plans some awareness
of how important these birds are to some of us, and also some aware-
ness of how important your management actions are to these birds.
For example, I know the locations of coveys of Quail that exist only
because you folks h^ve developed water sources: Quail are a very
water dependent little bird that rarely range more than j- mile frtffl
a year eround source nf running water. Quail arc sn dependent on
water, and so predictable in their dependency, that I find them bv
locating and hunting up the springs that you folks show on your
excellent 1:100,000 scale topographic Ausdrangle maps:
So please, ip^your final draft, don't igno
They are tlft main reason I moved to Mines
/ U^. \ - vvw;
/Cr::gcry^P. Elstad
the.
live
e tw'
176
January 17, 1990
Joshua L. Warburton, District Manager
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines. OR 97738
REVIEW COMMENTS FOR THE OCTOBER 1389
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Warburton:
Refer to responses 2-1 through 2-96 which are responses to issues
submitted by Riddle Ranch and Western Range Service letter.
The January 17, 1990 Riddle Ranch and Western Range Service
Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent
with our views and comments.
This response is our endorsement of such Riddle Ranch
document. Their response has been submitted to you. We do not
include a full copy of text only for the reason that it would be
an exact duplication of the Riddle Ranch document.
Any additional comments we may have are enclosed herein and
are supplemental to our principal response.
Sincerely,
ft/As. elm CM /77J/
s/ate /Zip Code
ML
*AAs,
Signature-y . — -/
Enclosure Supplemental Comments
Appendix 11-170
February 12, 1yyu
rburton
Land Management
177
In reference to the Three Elvers Management Plan we, the undersigned, encourage
you to increase the forage allocated to .,i£— same over what your preferred al-
ternative suggests , thereby decreasing the number of domestic livestock further.
177-1 Refer to response 2-6.
Hams .-.
3 3 tt> iv />,
qi!>
Ait
-4 i. .&w«fe.£f-
February 12, 1°?0
To: Joshua Warburton
Bureau of Land Management
Hines , Oregon
In reference to the Three Rivers Management Plan we, the undersigned, encourage
you to increase the forage allocated to big-game over what your preferred al-
ternative suggests , thereby decreasing the number of domestic livestock further.
Address
■3~/2- fl
j—
jj5Zxi r.hJF
/?J.f~. S/lM*
* v r..sa~!>r
u/e <&<
-A
A~-S.
U?
'It
s*S**^iti*i
g AV* j A fahAMM. OL£
(.zmi-A FruMj, 00 /^£W<-
Tw"
A2U2&&£ii4 <6&&a«Ma^: Q&S.
CffV Q&Uu
&&% I i hi) a I ahe I. a Rr-srrrie QP
ruu
a.°S &»~U~ %t u< ii/i.«y. a<f
1 </s> % gate/, yp/f* £LA£ <2h -
.J file
/fu-1
if.
-^.U(?t,J. gn
fhmW\ 3n,~3U(iyii
izn i tc-iAsK l.«Crnrii*/e Qt
ru -h Hz
i7oY- a p?,<,r,.T&„ t&buJtj&i
2>;,~y v ?/^4~
/J-*.; :^.-
<£~^- /,. ^C— ^ tf,
23.
ail.
25.
28.
29.
30.
Appendix 11-171
February TU, Tyyo
Jay Sarlson RMP- EIS
Sums District Office
Bureau of Land Management
HC 74 T. ? 5 3 3 Hwy. 20, West
Mines, Or. y//J8
178
178-1 Refer to responses for letters numbered 131, 132 and 133.
Dear Mr. Carlson,
I, Alice K. Baker, would like to go on record, as to agreeing
with the statements set forth by Mitch and Linda Baker. Please see
attached copies.... Thank you.
Sincerely, t f~\ r
Alice K. Baker
P.O.Box, 40y
Burns. OR. 97 7 30
January 17, 1990
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hines, OR 97738
179
179-1 Refer to response 2-63.
REVIEW COMHEHTS FOR THE OCTOBER 1989
BLH DRAFT THREE RIVERS RMP ZEIS
Dear ftr. Carlson:
(If you are facing a reduction in AUM's, please include the next tvo
paragraphs. If not, cross out second paragraph. >
Alternatives A, B and C will result in a substantial loss of our base
property value. The proposed BLH actions may result' in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
ve request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a 'Takings Implication Assessment * be completed be
authorized by Executive Order 12630 (see the Hovember ■
to all Assistant Secretaries and Bureau Directors from
Interior, Donald P. Hodel).
8, 1988 Memorandum
Secretary of
115
AUM'
livestock forage
, The reallocation and/or reduction of (
inLnndi^vC Qr.f.k: ^iL-ir-^^ltttment will reduce the
property fry approximately S I 1 1^ (Assume S50 per AUM value).
Please consider this economic loss in the requested "Takings Implication
Assessment. '
The letters from the Harney County CattleWomen, Stockgrovers, Farm Bureau,
Sheep & Woolgrovers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent vith our
vlevs and comments.
This response is our endorsement of such letters end Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication Of the Riddle Ranch document and organizations letters.
Any additional comments ye may have
supplemental to our principal response.
HSi 2 fed "feA^Q
£ 1 osed herei t
and ■
E35^M
a xy-i-^-^h. ,
Q,
g???^
Clky
Qshi,
'o-frJU
Enclosure: Supplemental Comments
Appendix 11-172
Jay Carlson
Burns District Office
Bureau of Land Management
HC 71* 12533 Highway West
Hinee, Oregon 97738
Drewsey, Oregon
February 12, 1990
18©
180-1 Refer to response 11-11.
180-2 Refer to response 4-15.
180-3 California bigho
refer Lo respons
a sheep are native to southeastern Oregon. Also,
2-78.
Dear Nr. Carlson:
We would like to go on record as apsrovins the comments expressed, by the
Harney Coiuity Cattlewcmen, the Stockgrowers, the Farm Bureau, and the Sheep
and Woolgrowers associations , in response to the Three Rivers Resource
Management Plan and Environmental Impact Statement. As their documents
areon record, we will not include copies of their text aa presented in the
Riddle Ranch document.
The proposed E.L.N, actions would lead to a reduction of cattle grazing on
public lands. This would seem to be detrimental, not only to ranch operatic;
but also to the economy of Harney County and to the businesses that are
dependent Upon the stock industry.
We feel that increasing wild horse and burro herds is a big detriment to
the range. These animals destroy more forage than most any type of livestock
as they paw out grass roots. They do this even when there is not a shortage
of food. as they seem to like certain types of roots. If any damage is being
done to the Biscuitroot area, in the Stinkingwater allotment, it would prob-
ably be due to horses. We would therefor object to prohibiting cattle and sheep
from grazing in that area. We object to the designation of the Stinkingwater
Mts., Bartlett Kt. and Upton Mt. areas as Bighorn Sheep habitat. These animals
are not native to the area and we see no reason to introduce them there. It
seems that multiple-use should apply to animals that are native to the area.
Thank you for considering our comments and input, in this matter.
Yours truly,
Chas A. Kiler & Norma L. Miler
181
February 14, 1990
Jay Carlson - RMP/EIS
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 97738
RE:
Dear Mr. Carlson:
Review Comments for the October 1989
BLH Draft Three Rivers RMP/EIS
After reading the comments and response
and Western Range Service to the above,
views are consistent with mine.
made by the Riddle Ranch
wish to state that their
After studying the management proposals I wish to make the following
comments:
I feel that the proposed alternatives A, B and C, if followed, could
greatly affect the economy of the Three Rivers area.
Taylor Grazing'.! was implemented to improve the condition of the Public
Domain by stopping sheep owners who did not own base property from
grazing numerous bands of sheep north in the spring and summer and
south in the winter months plus controlling the numbers of cattle
turned out on the. range. Prior to Taylor Grazing considerable damage
had already been done to the range by over grazing.
With reference to streambank erosion, if it was possible to have
check dams in streams, they should stop some of the erosion especi-
ally during early spring run off. This in turn should help willows
and ground cover to reestablish itself plus improving water quality.
In our area reservoirs in the upper part of the Middle Fork of the
Malheur Hiver would not only control flood waters but would stop
erosion of the river banks which would reduce sediment loads and im-
prove water quality.
I fail to see how removing all livestock for five years from streams
which have poor water quality would greatly help since you cannot
control the wildlife and wild horses that would be using same. Fencing
off streams, reservoirs, springs and leaving only water gaps would only
increase cattle congregating in that area and further depleting forage
and causing more erosion.
It was my understanding that the purpose of Taylor Grazing and BLM
was to assist the stockgrowers in managing the Public Domain better
and not for catering to the whims of the environmentalists who do not
contribute any assistance or monies toward range improvement.
Before any action that causes a reduction of AUM's to the per-
mittees, please reconsider and do a complete Implications Assess-
ment as authorized by Executive Order 12630.
Needless to say a reduction of AUMjs to permittees would cause un-
due hardships and cause some of us to give up ranching.
Sincerely yours,
Rotha French
Drewsey, Or.
oincere±y yours,
PS: Hark Doverspike, President of Harney County Stockgrowers1
comments also coincide with my thoughts.
Refer to response 3-13.
The Taylor Grazing Act of 1934, as amended and supplemented, was
enacted "to stop injury to the public grazing lands by preventing
overgrazing and soil deterioration; to provide for their orderly use,
improvement, and development; to stabilize the livestock industry
dependent upon the public range; and for other purposes."
Refer to response 2-63.
Appendix 11-173
182-1
182
Oju^ju, OR 919*1
£,lM , MO 7ff /2S33 fay Jo (UA<d
fc, Ofl
9773%
tfus ybi£j!2jt>C-
<Ual7Ju Zij^ ~-/tf4/&ute»?4 je***4M*n&J .^w ste^tf**^
I ukAu7a^*if /I, & , aid. (2 j^U/y -A^M.1 W
usu ^zJ=c/a*J^O J^u^^^ 7^^^^^
v /tOauUiD, 4ML/Jjjudi£ -Med. y. gM^Z*1*-*'
sAenfOtd. C^Lmf^L, 'a- " ^JkA**?*, \£vy^>*3^
G^LAjjyu^-u^t " &< '^CJmfiJfikeC ads <zaZA^f^
A (f^cu^i. (Qm&U /#b30t^Jt*s3t» 7%^M^
Sc7>a7 a/jts ad^JZsn&tvZLi ^-ny MAo \_//£j^lJ h&v&iu
_p#ii<>&t teat -&»a£ -.^i^c/ts <$£■ ^^ ^ti^«ia«a4^
s???<s«i£ ^CoaJxlJ a^/cciO uy^ueju u*£s a^u^ 66><>?uAa&j.
(CUuJ fltf&rzl s?y/£ ff^/dM/SMxsi' &#£■ -&U4, _^j.n7y —
J.i/77t> M&U. micjL cyu -/Any TZzty /&/-> -t/ cUl<> -tjL.^
w?2&t<u/: -,0/fi^wlJ ?? \7?/ ' o-TJy Hju J'A^cAdAjU oAs-J
f#tif)ilL. ^jQj Ml jtAts q/&!&>zJ7?J?iZi *&trAj ^mU£ Z5^
ihMyy_ iJ m
-T-CU^c
v.% 300, t si r
^ Qy ^/HCjUzjC jCi'TZcjU-zy jS- (3v%?tH£s (JaZ7&,
lAjzcju ty>v CL&it%jr?sfa£C ^SSJ^. \^z77u^ a™^^ZM&?zJ
Lpl%fi&' cmokZ & oj-stz/^jcj-zjCs oa^ J&? /£&&&?
182-1 Refer to response 2-53.
182-2 This fence is not in the Preferred Alter:
182-3 Refer to response 2-1.1..
182-4
There is no proposal in the RKP to eliminate livestock gra2ing from
public lands. Also, refer to response 1-13.
'JU4/.'
Appendix 11-174
H©3
SPAIIITHESEftVATIOI
HC-71 100PASIGOST- BURNS, OREGON 97720
PHONE{503) 573-2088
February 14, 1990
Josh Warburton
District Manager
Bureau af Land Management
HC 74 Box 12533 - Hwy . 20
Hines, OR 97738
Dear Mr. Warburton:
The Burns Paiute Tribal Council thanks you for this opportunity
to comment on the proposed Three Rivers Management Plan. From
the information provided, it is difficult to fully understand the
proposed management of cu Rural resources and your agencies'
objective to "increasing the opportunity for the public ' s
sociocultural , educational and recreational uses of the area ' s
cultural /paleontological resources . "
The Native American of the Great Basin always has maintained a
strong social tie with the environment. It gives life as well as
death. It provides nutrition through wildlife, vegetation and
the land itself. with the coming of the white man and through
monetary management and fiscal planning, many of the Native
American's inherited aboriginal rights were- lost.
Biscuit Root aCEC
183-1 Refer to response 4-15.
183-2 Refer to response 6'
■13.
The BLM included those areas for which specific input regarding
tribal interests were provided by the tribe during the planning
process. The tribe may be added to the EA mailing list and provide
Input through the site-specific planning and analysis process for
those projects or areas of unique importance to the tribe. At any
time the tribe may provide information that the BLM may use to
protect additional localities and natural resources, while affording
confidentiality to the extent legally possible.
The BLM Burns District has been Involved with the tribe in
negotiations to determine acceptable procedures for consideration of
the reinterment of Native American burials. The BLM intends to renew
efforts to reach an accord on this issue. This and the currently
proposed Biscultroot Cultural ACEC should provide continuing
interactions between the tribe and the BLM Burns District, such that
more progress can be made in such areas.
We are very pleased to see the BLM has made an attempt in the
Three Rivers Plan to address some of the cultural concerns and
aboriginal rights of the Burns Paiute Indians. We agree with the
6000 acre Biscuit Root gathering grounds being designated as an
ACEC, with the exceptions noted in "other concerns". Since the
harvest of the Biscuit Root is usually over by the latter part of
June each year, the Tribe would not be opposed to grazing being
allowed in the area after July 1. However, we would be opposed
to "the placement of salt licks or structures, (corrals, etc.)
bejng' placed in the ACEC.
Pine Creek Materia 1 Site
The Tribe feels the Pine
from usage as soon as po
Creek Material Site should
isible but no later than whe
expires in 1992. This site was a traditional camp site for
Native Americans up until the pit was established. We feel the
sooner the current, use is terminated the sooner the area wil 1
recover and be available for traditional use.
Other Concerns:
In addition to the Biscuit Root ACEC, there are other non-
designated root gathering, ground hog, jackrabbit, religious, and
camping areas which are culturally significant and are included
in the Three Rivers Management Plan. Many of these areas are
"Family" specific. To ensure these areas receive protection to
retain their cul Lura] significance, the Tribe proposes they
pa rticipste in !. he ongoing BLM Planning Process for specific
project s . (i.e. prescri bed burning , herbicide control , fence
building, rodent control, road closure and construction, post and
pole activities , vegetation control , law enforcement , land
transfers, etc.).
Through the participation in the planning process , it is hoped
better lines of communication between the Tribe and BLM will be
established. The Government to Government relations established
through the process will, help develop policies and agreements to
ensure the protection of archeo logical and cultural sensitive
areas .
The Tribe is currently negotiating with the USFWS on a
Reinterment Agreement on the Malheur Refuge and has negotiated a
camas root set aside area with the USFS Snow Mountain District.
Hopefully these agreements can be used to generate like type
proposal s with your agency.
Tn addition , the Tribe is interested in the Castl e Rock and
Beulah Reservoir areas on the Vale BLM District. We appreciate
obtaining a contact person in that District with whoiti »e could
discuss the cultural and religious significance these areas have
in relation to the Burns Paiute Tribe.
Thank you for considering our comments and for the assistance
your personnel have provided on the Three Rivers Project. We
feel the establishment of Government to Government communications
wil 1 be beneficial to both organizations.
Larry B^gai^'rtfSJT*tji,
Chairman
Burns Paiute Tribe
Appendix 11-175
Three Rivers Management Plan
WB4
To: Area Resource Manager
ffe the prooerty owners al-mg the ur-iposed access r-mte fr-im ^rns*
to Seneea( former! y known as Rails to Trails) oppose this route in the
Three Rivers Plan for the following reasons.
1) This recreational oroposal was earlier given to the Deople as an
opportunity to develop , but few offered suuport .
2) The costs for development and upkeep was sited as the major reason
t-9 abandon the plan. These costs would only increase with the deteri-
oration of the trails wioden railroad structures.
7>) The probability of connecting the entire trail with future 1 and
trades or easements would not be f easi>l e and highly unl ikely.
4) Many other trail opportunities exsist on public land without
traveling through 36 miles of adjoining private land.
5) The attempt to bring alive a "dead horse" which was earlier kil 1 ed
from lack of public support would severely influence the credibility
the ELM has with the public.
We ask that you reconsider this proposed access route and remove it
entirely from the Three Rivers Management Plan.
Refer to response 4-16.
Q.u/1^ *> MMc-*
Thank you ^
Jay Carlson- RMP/EIS
Burns District Office
Bureau of Land Management
KC 7^-12533 Highway 20 West
Bines, Oregon 97738
Review Comment Fo
BLM Draft Thre
January 26, 1990
3aker , Oregon
185-2 ■
185-3 |
165-4
185
The October 1989
Rivers RMP/EIS
Dear Mr. Carlson,
The Oregon CattleWoraen, with a membership of over 600 , would
like to go on record in support of the January 17, 1990 Riddle Ranch
and Western Range Service comments and', response.
Until proper techniques and accurate information is gathered and
documented, existing levels of livestock grazing should be maintained.
Your cone
Dr. John Buckh
much research
of riparian areas in also a concern of ours. However,
e of Oregon State University Caciong others) has done
riparian zones that indicates that natural phenomena
such as ice flows can have detrimental effects on riparians. Stream
banks can be damaged by continuous grazing, but 3uckhouse says that
under proper management, grazing cattle has no detrimental effects to
the reparian. Federal agencys and the livestock industry are very
conscious about these fragile areas. We need water and feed for cattle
and wildlife and to abuse it is not to our best interest. I believe
the Harney County Stockbrokers address this issue with comments in
their response.
Your management decision to restrict livestock in the Sagegrouse
strutting grounds is flawed from lack of scientific data and should be
eliminated. The threat to the Biscuitroot Cultural ACEC is not supported
either.
We recognize that horse populations need to be managed in balance
with available forage, water, wildlife, livestock, and other resource
uses. It is our under standing, the BLM can demonstrate resource damage
by Wild Horses and establish that an overpopulation exists and that a
5-step process for disposing of excess animals can occur. Has this
process been done? Is this not a viable action rather than label it
an Area of Critical Environmental Concern?
It has not been established- with fact by the BLM that livestock
in the Three Rivers Resource Management Flan have been detrimental
to the resource. Therefore, it seems to us unwise to do away with a
management tool that is benefitial and pays for the use. Why would
you enlarge 2 areas (Biscuitroot and Wild Horses) who pay no fees to
help administer said lands?
For the above reasons, the Oregon CattleWomen support the comments
and response of Riddle Ranch and Western Hange Service.
Sincerely
f»i r
Kay Markgra^
ocw legislative chairman
185-1 The systems in the Proposed Plan are an attempt to get the riparian
area grazing under proper management in areas where this is not
currently the case. Also, refer to response 3-13.
185-2 Refer to response 4-6.
185-3 Refer to response 4-15 .
185-4 Refer to response 2-68 and 124-4.
185-5 No wild horse herd areas have been enlarged, and adoption fees do pay
for a portion of the wild horse and burro program. There was a
mistake on the ACEC Table 1 in Appendix 7 in the DRKP/DEIS regarding
grazing on the Biscuitroot Cultural ACEC. Livestock grazing is not
being prohibited in the Biscuitroot Cultural ACEC, and the PRMP/FEIS
has been corrected to reflect this change. See Appendix 1, Table 16.
Appendix 11-176
186-3
186-4
ne<s
February 14, 1990
Jay Carlson - hmp/eis
Burns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 97736
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Hr. Carlson,
The Harney County CattleWomen want to go on record that the
January 17, 1990 Riddle Ranch and Western Range Service comments
and response to the Draft Three Rivers Resource Management Plan
and Environmental Impact Statement are consistent with our views
and comments . This response is our endorsement of such Riddle
Ranch document. Their response has been submitted to you. We do
not include a full copy of the text only for the reason that it
would be an exact duplication of the Riddle Ranch document.
There are several other areas of concern that this letter will
address .
The design
(HMA) (36,
(ACEC) cou
ranches if
even consi
should be
Livestock
years. I
Southern !)
and Hel<
the Interi
Management
Land Manag
pro
nee
livestock
of AUM's d
proportion
acquir,
the privat
ation o
619 acr
Id have
AUM's
dered a
conduct
and wil
a rece
istrict
Fall
r; Rob
Edwar
ment
that c
wild ho
ation o
essary
AUM's 1
ue to a
ally to
the pri
e holdi
f the entire
es) as an An
a dramatic i
are reduced.
complete "Ti
as author:
horses havi
nt decision 1
of Nevada, *
, Plaintitfs
ert F. Burfoj
d F. Spang, 1
DefendantsIF;
attle grazint
as a re:
f any livestc
and appears
ave been disi
change in tl
all AUM's ii
ate holds o:
ngs is not fi
Klger Active Horse Managem
a ot Critical Enviror
conoraical effect on at lea
Before a reduction of AUH
kings Implication Assessme
zed by Executive Order 126
run together successfully
he U.S. District court for
oe B. Fallini Jr. , Susan F
vs Donald P. Model, Secret
d. Director Bureau of Land
evada State Director, Bu
llini vs BLM), the court
on federal lands has an
ult of congressional enact
ck grazing is neither just
to be illegal. Wild horse
ributed. Any increase or
e resource should be done
volved. The conditions f
the authority to impose t
lly addressed.
ent Area
1 Concern
st three
llini
ary of
au of
ejected a
nf erior
ments .
and
ecrease
Monitoring techniques currently in use on the Three Rivers
Resource Area are insufficient, inaccurate , and improperly
applied, and then are extrapolated to indefensible conclusions.
BEEF BUILDS STRENGTH BEEF BUILDS STRENGTH
the definition of riparian area. Any that do not meet the
requirements should be taken out of that classification.
The air quality restrictions are the same for all alternatives.
More alternatives need to be provided. Fire is becoming a very
acceptable and economical method ot range improvement. To limit
this area to 3000 acres a year is unrealistic. More research is
needed in this area with Fire Management Specialists. Unless
there is valid scientific data to show that limits above this
would permenantly effect air quality these limitations should be
eliminated.
The continual fencing of reservoirs is in direct conflict with
the BLM objective to disperse livestock away from riparian areas
and improve forage utilization. These reservoirs would not be
there today if it had not been for either the range improvement
funds or private funds that first developed them. The small
water gaps that dry up during the season or don't allow live stock
to water during low water years restrict the amount of available
forage and can concentrate cattle more than necessary. Livestock
have a biological need for water. Access can be accomplished by
building the water gaps at the deep end of the reservoir. If the
enclosure is more than one-half mile square, have more than one
access point to allow livestock better access to all of the
forage available around the reservoir. From the Fallini vs. BLM
court case "If water is developed for grazing livestock, and the
range improvement permits provides for and the state permit
sanctions this use then it is a viable use." It goes on to state
". . ■ Underf unding may be one reason why there has been no
government order construction. . .But government cannot force some
people alone to bear public burden which, in all fairness and
justice, should be borne by the public as a whole..." Therefore
livestock should have good access to this water at all times , no
matter what the drought conditions are. We are not resticting
other uses from the reservoirs. There is a need to make sure
that livestock access to water is not excluded when range
improvement money was used to develop the reservoirs.
ses a reduction of AUM's is
a complete "Takings Implicatio
as authorized by Executive Ord
Before any alternative that c
imposed, no matter what reaso
Assessment" should be complet
12630.
The exclusion of cattle on the Biscuit root Cultural ACEC is not
supported. The report states "...these areas to be a high-value
resource due to the quality and quantity of roots available."
Appendix 7-12; Vol. II Append icies. Since grazing has been going
on in this area tor years and the quality and quantity have
remained high, even with root harvesting, there is no
justification to change the practice.
The need for public access along the Silvies River and Poison
Creek is unjustified. The public has access to over 70% of the
county already. These two access routes through private holdings
Managemen
only in t
No factor
livestock
productio
Therefore
if not th
of AUM's
season of
considere
gathered
maintaine
increase
ratings i
Update cl
excellent
satisf act
ratings
ommunicatio
jecti
ther
lizat
colog
ducti
ly
onsid
, len
Until
ting
At S
ecrea
e recently
ty
he RM
and u
cessa
with
than
ion a
al
ons ;
emedi
ered
gth o
prop
level
ch ti.
ase,
in the absence of AMP 's, are documented
terms making them virtually immeasurable.
short term wildlife, wild horse, and
re indicated as affecting forage
status, or potential of the resource,
n authorized livestock use is the primary,
al action recommended. Before a reduction
other management tools such as changing
f time, and deferred rotation need to be
er techniques and accurate information is
s of livestock grazing should be
ation shows trend
then be made. The
and Program Summary
MP/EIM
unsati
ary to
the
roper
publ
ondit
clas
sf act
X ace
permi
k grazin
that reliable info
ents cou
ley Rang
poor, fa
ange con
nsistent
dltions as
ttee
Fire is
woody sh
as well
will coi
and gras
en pol
valuation
as better
and
burn
nde
improve
fuel loa
Xt is we
return
nature ' s way ot improving forage by burning junipe
rubs . The proposed limitations on prescribed burnings,
as limitations and full suppression ot natural fires,
tinue to increase the trend of sagebrush and juniper
ment. This will have a negative effect on the vegetation
ses used by wildlife, wild horses, and livestock. A more
on prescribed burns, as well as letting natural fires
fire management supervision will help maintain and
ajority of the existing range . It will also prevent
ds building to a point that a major fire would result.
11 known that smaller cooler fires are better for the
f native vegetation than one major hot fire.
livestock
has
There is no scientific data that indica
any negative effect on the sagegrouse population. The
restrictions on livestock in the sagegrouse strutting grounds are
unfounded and should be eliminated. If the sagegrouse population
is declining, why did the Oregon Department of Fish and Wildlife
open a season on these birds this year? If the sagegrouse
population is a problem, why do birdwatchers interfere with their
strutting each spring during the Waterfowl Festival?
Enclosed is a copy of the Bu
Management Policy, dated Jar.
Robert J. Burford. This pol
note that the definition of
"directly influenced by perm
vegetation or physical chara
water influence. " The def in
from the definition of a rip
or washes that do not exhibi
dependent upon free water in
classified as riparian that
thorough review of all creek
reau
of Land Management Riparian Area
uary
22, 19B7 signed by BLM Director
icy h
as never been rescinded. Please
a rip
arian area is an area of land
anent
water
and having visible
cteri
sties reflective of permanent
ition
conti
lues that areas excluded
arian
area include "ephemeral streams
t the
presence or vegetation
the
soil . "
There are areas
do no
t meet
these criteria. A
s should be
made to ensure they meet
are not needed since the public has several other routes of
entering the federal lands.
The Harney County CattleWomen support a no action plan . This
plan would help stabilize a local economy that over the past 10
years has had many negative impacts. The BLM has reported that
significant progress has been made in obtaining management
objectives under the present plan.
1.) Stated by the Burns District Manager in the 1981
Rangeland Program Summary Update for the Drewsey Grazing EISi
"To date we have made significant progress in improving the
public range lands through intensive livestock management and
rangeland improvements. "
impa
prot
and
obj
sec
2. )
ary:
" The s
tat, in
stock,
ease re
he prog
ct of r
ect cul
animal
There
ctives
ons . "
BLM stated in the 1983 Drewsey Rangeland Program
objectives are to: improve waterfowl and fish
available forage for wildlife, wild horses and
.n water quality and reduce soil erosion,
>nal opportunities and quality, minimize impacts
visual and wilderness resources, minimize the
ms or changes in use on grazing permittees and
■esources and threatened and/or endangered plant
ireatic
■am on
iductit
:ural i
;pecie:
has b<
md th:
en considerable progress in achieving these
s progress will be discussed in following
ti
The objectives stated in the 1983 Drewsey Rangeland Program
Summary Update related to all concerns of multiple use. With the
BLM stating that the EIS is succesful, the Harney County
CattleWomen see no reason to change something that is working
that address all multiple-use concerns.
Sincerely yours,
* (i
Kathy Dryer, President
Harney County CattleWomen
Pine Creek Ranch
Drewsey, Oregon 97994
Enclosures { 1 )
Appendix 11-177
Illlli — ^—— — — — — — — — -
Bureau of Land Management
Riparian Area Management. Policy
UflCKGKQUIJD
Riparian areas are unique nod' among the most productive and Important
econystena, comprising approximately 1 percent of the public lands.. m1,
Characteristically, riparian arsaa display a greater diversity of planti fish,
wildlife, and other animal species and vegetation structure than adjoining
ecosystems. Healthy riparian systems filter and purify wat
through the riparian zooe, reduce sediment loads
provide micro-climate moderatlor
[ aun purity water as it movei^— ■
.oads and enhance soil stablllTyV
uted to'estreoes In adjacent! ■ [
and I
DEFI8IH0MS
:ribute
. grou
icharge aud I
flow.
Klparian Area - an area of land directly influenced by permanent I
It has visible vitiation or physical characteristics reflective of pai
■-'fltcr Influence, Lake shores and stream banXa are typical riparian an
txcludad are such sites as epneaeral esreass er waahM EhlX do not eshJ
pttatatV 01 vegetation dependent upon free wnccr in CM soil.
i-Uependet
EUCh I
fish, and certain wildlife i
P2.-L-: it.:-:
The objective of riparian ai
riparlca values to achieve I
carl sea lone-tens benefits.
FOUCTf ST.-'.TZMC.TS
-ea management la to maintain, restore, or luprove
, healthy ami productive ecological condition for
In urdcr to
ct the foregoing objci
Achieve riparian area improvement and m^intcnai
management of existing usee wherever feasible.
Lnsure that new resource oanageoent plane and .
existing pltDJ when revised, recognize the iopi
and Initiate oanageoent to maintain, restore, i
Prescribe management for riparian values that
characteristics and settings.
: objeetiven through the
tance of riparian values
■ lap rove then.
based upon site-spec If li
iltoriug and evaluating manage!
In rlparia
objectives
D are
aot 1
d rev
C pt
actl
via*
net.
0
and local
gover
■ad e
rdina
s and
ge the lnvo
private par
lvltles, an
vim
ptc
vide
edu
productlvl
ey. ■
id canageocut of ripar
an i
""
0
Retain riparian
the public late
««
s in
as d
nubile owner
tc rained Id
hip
the
unle
Land
■a d
"
Identify,
that rip.r
tr.
M»«.
aad
anage
support rese
aent objectl
rch
""bTpr
sposal would be 1
planning systeo.
be properly defined aud r
186-1
Refer
to
responses 2-63 ane
2-68
186-2
Refer
to
responses 2-6 and
4-12.
186-3
Refer
to
response 182-4.
186-4
Refer
CO
responses 2-6 and
2-11.
186-5
Refer
to
response 4-14.
186-6
Refer
to
response 2-87 .
186-7
Refer
to
response 2-87.
186-8
Refer
to
response 2-11.
186-9
Refer
to
response 4-3.
186-10
Refer
L.J
responses 4-9 and
6-8.
186-11
Refer
to
responses 4-6 and
4-7.
186-12
Refer
to
responses 4-4 and
42-14
186-13
Refer
to
response 4-8.
186-14
Refer
to
response 2-46.
186-15
Refer
to
response 2-63.
186-16
Refer
to
response 4-15.
186-17
Refer
to
response 4-16.
186-18
Refer
to
response 2-9.
rector, Bureau of Lind Itaaajemsnt
187
187-1 Refer to responses 5-1 through 5-18.
Jay Carlson
RMP/E1S Team Leader
Bureau of Land Management
Burns District Office
HC 74-12533
Highway 20 West
Hinds, OR 97738
Friday, February 16, 1990
Dear Mr. Carlson,
ONRC concurs with and supports the comments of the National Wildlife
Federation on the Draft Environmental Impact Statement for the Three Rivers
Resource Management Plan.
Thank you for your attention.
Sincerely,
{L*J*\^~
Andy Kerr
Director of Conservation
Appendix 11-178
I'riruettiiii nrvt IftljHipcr
FROM:NnTL. WILDLIFE FED. PDX TO^BLM FM - BURNS
FEB 16. 1990 4:23PM P. 02
M$k NA]^N^WILDUFEiEDERMJON -\QQ
SSlffiiSS Sum- K* Di'kum Mdiflg OT 5 w. l h,rd A*&m# fgni.mrl, OftflWi B*HM
February 16, 1990
Joshus L. Warburton, District Manager
Bureau of Land Management
Burns District office
HC 74-12533
Highway 20 W.
Hines, OR 97738
Re: Three Rivers Resource Area
Your interest status in every Allotment Management Plan and Allotment
Evaluation has been noted, and your agency will be included in the
analysis process for such management activities.
Dear Mr. Warburton:
The National wildlife Federation (HWF) has a vital interest
in the health and rehabilitation of wildlife, waterfowl and
fisheries in the State of Oregon. Due to the documented critical
dependence of wildlife, waterfowl and fish on riparian and
wetland ecosystems, and pursuant to 43 CFR § 4100.0-5, the nwf
formally requests affected interest status on every Allotment
Management Plan and Allotment Evaluation which impacts riparian
and wetland systems in the Three Rivers Resource Area. Please
reference the NWF comments on the Three Rivers Draft RMP/EIS sent
to you today.
Thank you.
/3zc^< %f9f*#t
rf#
Bruce Apple
Director
/bas
cc: Dean Bibles
II
Jay Carl son
BLI1
Highway 20 West
Hines Oregon 97739
RE: Three Rivers Resource Management Plan
fir . Carl son :
I doubt your management plan -for North Harney County will survive
intact . I hope not . I-F it does , it will accompl ish what, decades
of bureaucratic gradualism has religiouslv avoided:
Total mistrust of government programs .
Fencing off o-f mul tip! e use resources -from any practical
uses, such as mining, ranching or timber harvescing.
Severance o-f communications in good -faith between
government and citizen .
Provide abrupt exposure o-f undue in-f 1 uence o-f
environmental zealots on government policy.
Trigger a decl arat ion o-f war between our grass-roots
industry and your organisation.
I cannot stand by in silence while sage hens, burros, horses and
( ish are made custodians and prefered occupants o-f the land that
was made productive and livable -for man and beast alike, through
the hardships and sacrifices o-f the pioneers. The land has been
better managed by those who lived on it than it ever will be by
an empire o-f those who pi ay games with the 1 ives and futures of
our peopl e .
The "Plan" is unnecessary. It is built upon untrue suppositions
of conditions which do not exist. It, if implemented, would be
disasterous to the only long-term industry that can be depended
upon to keep our local economy alive. The other one is already
being managed to death. I see no scientific basis for the
utilization limits proposed for riparian shrubs and upland
grazing. The recent tour taken by ranchers and BLM theorists
failed to demonstrate any effects of undue grazing practices. I
do not believe it provides the spectrum of alternatives, or was
conceived in an open manner as is required by 1 aw .
Refer to responses 1-13 and 12-4.
In short, Mr. Carlson, the "pic
curtain . . .another Berl in wal 1 . G
cprff'ide^ the fate, of the last one.
Lil d buil d an
woul d wel 1
Appendix 11-179
WW 190
THE WILDERNESS SOCIETY
JKECON REGION
APPENDIX 1
Executive Orders
February IS, 1990
Jay Carlson
RMP/EIS Team Leader
Bureau of Land Management
Burns District Office
HC 74-12533
Highway 20 W.
Hines, OR 97738
FAXED February 16, 1990 to 503-573-7600
The Wilderness Society (TWS) is a national conservation
organization that is devoted exclusively to public lands management
issues. Founded in 1935, the Society has more than 350,000 members
and 15 offices nationwide. The Society's staff of more than 100
includes foresters, economists, biologists, lawyers, policy
analysts, legislative specialists, and federal agency land
management special ists .
TWS has three full-time, fully-staffed regional offices in the
Northwest: Portland, OR; Seattle, WA; and Boise, ID. Many of our
members engage in uses on Bureau of Land Management (BLM) lands in
Oregon. Maintaining resource values is of vital interest to TWS,
These values include biological diversity, natural beauty,
recreation, water quality, wildlife habitat, and ecosystem
viability.
We are pleased that you provided the Three Rivers Draft RMP/EIS for
our comment. We support the Pacific Northwest Natural Resource
center. National wildlife Federation detailed comments which have
been submitted to your office. In addition, we are particularly
EXECUTIVE
ORDER 11644
Use of Off-Road Vehicles
on the Public Lands
1 5 million off-road recreational vehicles —
motorcycles, minibikc:;, trail bikes, snowmobiles. dune-bug-
gif.. all-terrain vehicles, and others— are in use in (he United
States today, and their popularity continues to increase
rapidly. Tlic Widespread use of such vehicle-, on the public
lands — often lor Iq'.ium.iu: pm |Kiscs but also in frequent
conflict with wise land and resource management practices,
environmental values, and other types of recreational activ-
ity— hiti demonstrated the need lor a unilicd Federal policy
towaid the UK Of lUCh vehicles on the public lands.
NOW, THEREFORE, by virtue of the authority veiled in
me as President (if the United States by the Constitution of
the United Slates and in furtherance of the purpose and
policy of the National Environmental Policy Act of 1%9 (42
U.S.C. 4311), it is hereby ordered as follow*;
Section I, Purpose. Ii is the purpose of this order to
establish policies and provide for procedures that will ensure
that the use of ofl-road vehicles on public lands win be
controlled and directed so as to protect the resources ol those
land*, to promote the siikly ol all users ol those lands, and to
minimize conflicts among ihe various uses of those lands,
SfcC 2. Definitions. As used in this order, the term:
(1) "public lands" means (A) all lands under the custody
and control of the Secretary of the Interior and the Secretary
of Agriculture, except Indian lands. (B) lands under the
custody and control of the Tennessee Valley Authority that
are situated in western Kentucky and Tennessee and are
designated as "bind Between the Likes." and (C) lands
under the custody and ennrrnl of the Secretary of Defense;
(2) "respective agency head" means the Secretary of the
interior, the Secretary of Defense, the Secretary of Agricul-
ture, and the Board of Directors of the Tennessee Valley
Authority, with respect to public lands under the custody and
control of each;
(3) "off-road vehicle" means tiny motorized vehicle de-
signed for or capable of cross-country travel on or immedi-
ately over land, water, sand, snow, ice. marsh, swampland,
or other natural terrain; except that such term excludes (Al
any registered moinihoai. (B) any military, fire, emergency,
or law enforcement vehicle -!>cr< used lor cnici gency pm
poscS, and (C) any vehicle whose use is expressly authorized
by the respective agency head under 1 permit, lease, license,
(4) "official i
rk-:-i|;iiatcd rcprescniativ
ofil
l the
ns use by an employee, agent. <
of the Federal Government or or
lurse of his employment, agency, i
Sec 3, Zones af Use. (a) Each respective agency head
■.lull ilrvt.-li.ip LiryJ usui; iL'ruLiii.jn-. .m! ailiviinistralivc institu-
tions, within six months of the date of this order, to provide
lor .-uifiimi-.iiaiiv,.- designation ol the specific ureas and trails
on public lands on which the use of off-road vehicles may be
permitted, and areas in which the use of off-road vehicles
may not be permitted, and set a date by which such
designation of all public lands shall be completed, Those
regulations shall direct that the designation ol such areas and
trails will he based upon the protection of the resources of
the public hinds, promotion of the safely of ail users of those
lands, and minimization of conflicts among the various uses
of those lands. The regulations shall further require that the
designation of such areas and trails shall be in accordance
with the following —
soil, watershed, vcc.elation. or other resources of the public
(2) Areas and irails shall be located to minimize harass-
ment of wildlife fii -^ni/kaiii tlist upriiin of *i|fJUI': habir.ii.
(3) Areas and trails shall be located to minimize conflicts
I if tv.c en iili-ru.n.' vchicic o-.c -l::J «i:Jil: l-i^iimc or proposed
tecreiilional uses of the same or neighboring public lands, and
to ensure the compatibility of such uses wiih existing condi-
tions in populated ureas, taking into account noise and other
(J) Areas and trails shall not be located in ollicially
designated Wilderness Areas or Primitive Areas, Areas and
trails shall be located in areas of the National Park system.
Natural Areas, or National Wildlife Refuges and Game
Ranges only if rhc respective agency head determines that
off-road vehicle use in such locmions will not adversely affect
(c) The respective agency nead shj:: ensure aucquate
opportunity for puoln parncipaiinn in the promu.gation o!
suci regulations and in the cesigr.ation of areas and trai.t
, under this section.
primed en 100% rtcycttd papa
concerned with the expansion of off-road vehicle (ORV) use and call
to your attention Executive Orders 11644 and 11989 {Appendix 1).
Your ORV alternative to solicit ORV use is inconsistent with public
policy, and must be replaced with a policy to permit ORV use at a
level at least no greater than current levels.
truly yours,
(c) The
ofl-rc
apply to officii
Laurence TuttleX
Oregon Regional ^Director
raring Conditions. Each respective agency
head shall develop and publish, within one year Of the dale Of
this order, regulations prescribing operating conditions for
off-road vehicles on the public lands. These regulations shall
be directed at protecting resource values, preserving public
health, safety, and welfare, and minimizing use conflicts.
SEC 5. Public Information. The respective agency head
shall ensure that areas and trails whore off-road vehicle use is
permitted are well marked and shall provide for the publica-
tion and distribution of information, including maps, describ-
ing such areas and trails and explaining the conditions on
vehicle use. He shall seek cooperation of relevant Slate
agencies in the dissemination of this information.
Sec, 6. Enforcement- The respective agency bead shall,
wiicic authorized by law. prescribe appropriate penalties lor
violation of regulations adopted pursuant [Q this order, and
shall establish procedures for the enforcement of those
regulations. To the extent permitted by law, he may enter
into agreements with Slate or local governmental agencies for
cooperative enforcement of laws and regulations relating to
off-road vehicle use.
Sec. 7. Consultation, Before issuing the regulations or
iidministrativc instructions required by this order or designat-
ing arens or trails as required by this order and those
regulations and administrative instructions, Ihe Secretary of
the Interior shall, as appropriate, consult with the Atomic
Energy Commission.
SEC. 8. Monitoring of Effects and RtVitW, (a) The respec-
tive agency head shall monitor the elicits Of the use of off-
road vehicles on lands under their jurisdictions. On the basis
Of the information gathered, they shall from lime to time
amend or rescind designations of areas or other actions taken
pursuant to this order U necessary to further the policy of
this order.
(b) The Council on Environmental Quality shall maintain
a continuing review of the implementation ol this order.
RlCHAKOmSON
EXECUTIVE
ORDER 11989
Off-Road Vehicles on Public Lands
By virtue of the authority vested in me by the Constitution
and statutes of the United States of America, and as President
of the United States of America, in order lo clarify agency
authority to define zones of use by off-road vehicles on public
lands, in furtherance of the National Environmental Policy
Act of 1969. as amended (42 U.S.C. 4321 ei seq.), Eiecutive
Order No. 11644 of February B. 1972, is hereby amended as
SLCT10N 1 . Clause (B) of Section 2(3) ol Executive Order
No. 11644. setting forth an exclusion from the definition of
off-rt
u-ry.eiicy ■
law enforcement »
gency purposes, and any combat or combat support vehicle
when used for national defense purposes, and".
5i£C. 2. Add the following new Section lo Eiccutive Order
No. 11644:
"SEC. 9. Special Proreciinrt of the Public Lands, (a)
Notwithstanding the provisions of Section 3 of this Order, the
respective agency head shall, whenever he determines that
the use of off-road vehicles will cause or is causing consi.icr.i-
ble adverse effects on the soil, vegetation, wildlife, wildlife
habitat or cultural or historic resources of particular ateas or
trails of the public lands, immediately close sucn areas or
trails to the type of off-road vehicle causing such effects, until
such time as he determines that such adverse effects have
been eliminated and that measures have been implemented lo
prevent iuture recurrence.
"(b) Each respective agency head is authorized to =dopt
the policy that portions of the public lands within his
jurisdiction shall be closed lo use by off-road vehicles eiccpt
Onfci "
n 3 of tr
1-23 and 5-1 through 5-18.
Appendix 11-180
Hotchkiss Co..
I'hrain 573-222
Inc.
191
Richard A. Hoichklst
Slur Ht. ], Box 132
Jay Carlson - RMP/ElS
Barns District Office
Bureau of Land Management
HC 74-12533 Highway 20 West
Hines, Oregon 9773fi
February 14, 1990
REVIEW COMMENTS FOR THE OCTOBER 19S9
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson,
Hotchkiss Company inc. wants to go on record that the January 17, 19 90
Riddle Ranch and Western Range Service comments and response to the
Draft Three Rivers Resource Management Plan and Environmental Impact
Statement are consistent with our views and comments . This response
is our endorsement of such Riddle Ranch document. Their response has
been submitted to you. We do not include a full copy of the text only
for the reason that it would be an exact duplication of the Riddle
Ranch document. There are several other areas of concern that this
letter will address.
The co
object
forage
had no
sanctio
" . . . Un
bear p
by the
access
condit
that a
tinual fencing of re
ve to disperse lives
utilization. These
been for either the
rst developed them,
son or don't allow 1
t the amount of avai
an necessary. Lives
can be accomplished
reservoir. If the e
re than one access p
the forage available
court case "If wate
ge improvement permi
ns this use then it
erfunding may be one
onstruction. . .But go
blic burden which, i
public as a whole. . .
to this water at all
ons are. On our Ski
e already fenced, Wi
and in poor water y
feels, from the abo
these situation
th good access and w
servoirs is
in dir
tock
away rrom rip
reservoirs
jould n
range improvement
The
small \
/ater g
ivestock to
water
labl
forage and c
tock
have a
biolog
by building
the wa
nclosure is
more t
oint
to allow live
time
11 Cr
How
media
ater
d the reserv
eveloped for
vides for an
iable use . "
n why there
nt cannot fo
fairness and
refore lives
, no matte
ek Allotment
nd State. 1
tate has no
ing that thi
ely. Also,
s insured.
ect confli
arian areas and
ot be there tod
funds or priva
aps that dry up
during low wate
an concentrate
ical need for
ter gaps at the
han one-half mi
stock better ac
oir . From the
grazing livest
the state per:
It goes on to
as been no gov
ce some people
justice, shoul
tock should hav
what the drough
ive two re
oth of these th
access . Hotchk
blm is obligat
if Greenspot is
We are not rest
ith the BLM
improve
ay if it
te funds
r years
cattle
water.
deep end
le square,
cess to
rallied
ock, and
,it
alone to
d be borne
e good
t
servoirs
ccess
iss
d to
fenced
ictlng
Monitoring techniqu
Area are insufticie
are extrapolated to in
in the absence of AMP '
making them virtually
wildlife, wild horse,
affecting forage produ
resource . Therefore ,
primary, if not the on
reduction o£ AUM ' s Is
season of use
Ldered. Until
i existing leve
time that reli
i , proper ad jus
I publ ished Ril
Les range condi
jnt use of eval
jell a
currently in
defensible
the Three Ri
are documented only
No fact
estock utilizat
ical stat
ging
onsid
assif ie
nsisten
aluatio
unmeasur
and live
ction, e
reductio
ly, reme
consider
, length
proper t
Is of li
able int
tments c
ey Range
ers Resource
and improperly applied, and then
nclusions. Management objectives,
in the broadest of terms
than short term
icated as
ntial of the
k use is the
Before a
, other
are in
or pot
thor
dial acti
ed, other manag
of time, and d
echniques and a
vestock grazing
ormation shows
could then be ma
Program Su
ecommended.
agement too
deferred r
curate i
should b
rend inc
e . The
many U p d
J 1 & n t
itation need to
[formation is
: maintained,
'ease or
■atings in the
[te classify
'he RMP/EIS
tions as satisfactory
uation ratings is
better communicati
sfa
essary for ac
with the perm
ry-
There is no scientific data that indicates that livestock use has any
negative effect on the sag eg rouse population. The restrictions on
livestock in the sagegrouse strutting grounds are unfounded and should
be eliminated. If the sagegrouse population is declining, why did the
Oregon Department of Fish and Wildlife open a season on these birds
this year?
The air quality restrictions are the same for all alternatives. More
alternatives need to be provided. Fire is becoming a very acceptable
and economical method of range improvement. To limit this area to
3000 acres a year is unrealistic. More research is needed in this
area with Fire Management Specialists. Unless there is valid
scientific data to show that limits above this would permenantly
effect air quality these limitations should be eliminated.
g to
s on prescr
getation
y burning juniper and woody
ribed burnings, as well as
1 fires, will continue to
r encroachment. This will
nd grasses used by wildlife,
ore open policy on prescribed burns,
burn under fire management
nd improve a majority of the existing
1 loads building to a point that a
well known that smaller cooler fires
ive vegetation than one major hot
Before any alternative that causes a reduction of AUM 's is imposed,
no matter what reason, a complete "Takings Implications Assessment"
should be completed as authorized by Executive Order 126 30.
Fire is nature ' s
way of improvin
shrubs . The
proF
osed limitation
limitations and i
ull suppression
increase the
trend of sagebrush
have a negative e
ffect on the ve
wild horses.
and
livestock. A m
as well as lettin
g natural fires
supervision
Jill
help maintain a
range. It w
Lll a
Iso prevent f ue
major fire w
>uld
result. It is
are better for th
e return of nat
tire.
other uses from the reservoirs . There is a need to make sure that
livestock access to water is not excluded when range improvement money
was used to develop the reservoirs .
A copy ot the Bureau of Land Management Riparian Area Management
Policy, dated January 22, 1987 signed by BLM Director Robert J.
Burtord was submitted by the Harney County Stockgrowers. This policy
has never been rescinded. Please note that the definition of a
riparian area is an area of land "directly influenced by permanent
water, and having visible vegetation or physical characteristics
reflective of permanent water influence. " The definition continues
that areas excluded from the definition of a riparian area include
"ephemeral streams or washes that do not exhibit the presence or
vegetation dependent upon free water in the soil . " There are areas
classified as riparian that do not meet these criteria. One of these
areas is the upper part of Skull Creek, located on the Skull Creek
Allotment. We reel that the area trom the head of the creek until it
turns east, below the private land owned by Towery, Morgan ( Young does
not meet the riparian defination. A thorough review of all creeks
should be made to ensure they meet the definition of riparian area.
Any that do not meet the requirements should be taken out of that
classitication.
Hotchkiss Company Inc. supports a no action plan. This plan would
help stabilize a local economy that over the past 10 years has had
many negative impacts. The BLM has reported that significant progress
has been made in obtaining management objectives under the present
plan.
l. ) Stated by the Burns District Manager in the 1981 Rangeland
Program Summary Update for the Drewsey Grazing EISi
"To date we have made significant progress in improving the
public rangelands through intensive livestock management and rangeland
improvements. "
2.) BLM stated in the 1983 Drewsey Rangeland Program Summary!
"The specific objectives are toi improve waterfowl and fish
habitat, increase available forage for wildlife, wild horses and
livestock, maintain water quality and reduce soil erosion, increase
recreational opportunities and quality, minimize impacts of the
program on visual and wilderness resources, minimize the impact of
reductions or changes in use on grazing permittees and protect
cultural resources and threatened and/or endangered plant and animal
species.
There has been considerable progress in achieving these
objectives and this progress will be discussed in following sections."
The objectives stated in the 1983 Drewsey Rangeland Program Summary
■Update related to all concerns of multiple use. With the BLM stating
that the EIS is succesful, Hotchkiss Company Inc. sees no reason to
change something that is working that address all multiple-use
concerns .
191-10
191-11
191-12
191-13
The d e s i
( 3t , fe.19 ■
could ha1
AUM's ar-
authoriz.
run toge
District
Jr . , Sus;
Secretar-
Managemei
Manageme
contenti
to wild h
eliminati
necessary
qnation of the ent
ores )
Are
i a dra
reduce
"Taking
i by Ex
ter sue
:ourt tor the So
i Fallini and He
of the Interior
Befo
lmplic
cutive
esslul 1
nt. Defendants (
on that ca
irses
m of
and
invol
authorit
addresse
y to impos
ttle g
a resu
lives
ears t
ted.
urce s
nditio
this
K'iger Ac
ritical
al effec
eduction
Assessme
12630.
years .
n Distri
allini,
ert F.
vada St
vs BLM)
on fede
congress
razing
llegai
crease o
be done
acquiri:
the privat
tive Hor
Environm
t on at
of AUM'
should be
tor
ither
en F
Rob
>g, N
.lini
.zing
of
ck g
DUld
5 for
Livesto
In a re
ct of N
Plainti
urf ord,
ate Dir
f the c
ral Ian
ional e
s neith
Wild h
r decre-
proport
ng the ;
holdi:
ecto
ourt
a nag em
1 Cone,
t three
even c
condu
d wild
decisio
, Joe B
s Donal
etor Bu
, Burea
re jecte
ents
stif ied
and liv
I AUM'S
ly to a
te hold
s not t
nt Area (HMA)
rn IACEC)
ranches if
onsidered a
cted as
horses have
n the U.S.
Fallini
d P. Hodel,
reau of Land
u of Land
d a
ferior status
The
11 AUM's
s or the
ully
The exclusion of cattle on the Biscuitroot Cultural ACEC is not
supported. The report states "...these areas to be a high-value
resource due to the quality and quantity of roots available . "
Appendix 7-12 j Vol. II Append icies. Since grazing has been going on
in this area for years and the quality and quantity have remained
high, even with root harvesting, there is no justification to change
the practice .
The need for public access along the Silvies River and Poison Creek is
unjustified. The public has access to over 70* of the county already.
These two access routes through private holdings are not needed since
the public has several other routes of entering the federal lands.
Sincerely your
Richard A. Hotchkiss, Pre si
Hotchkiss Company Inc.
Star Route 1 Box 132
Burns, Oregon 97720
Appendix 11-181
191-1 Refer to response 2-46.
191-2 Refer to response 2-46.
191-3 Refer to responses 42-14 and 46-1.
191-4 Refer to response 2-9.
191-5 Refer to response 2-87.
191-6 Refer to responses 4-6 and 4-7.
191-7 Refer to responses 4-8 and 4-9, respectively.
191-8 Refer to response 2-63.
191-9 Refer to responses 2-63 and 2-68.
191-10 Refer to response 2-6.
191-11 Refer to response 2-49.
191-12 Refer to response 4-14.
191-13 Refer to response 4-15.
191-14 Refer to response 4-16.
Appendix 11-182
192
Don Barnes
Representat i ye of
Rex Clemens Ranch Inc.
Diamond, Oregon 91727.
Jay Carlson, RMP/EIS Team Leader
Bureau of Land Management
Burns Di strict Off ice
HC - 74-12533 Highway 20 W.
Hines, Orego;n 97738
Dear Mr . Carl son !
After studying the CRMP/EIS) texts, it is evident that
the BLM is blaming the cattle -for all o-f the range problems.
Contrary to your beliefs, the so called, Wild Horses, are to
blame for most of the problems. First of all, government
horses are not managed. They are left on the range twelve
months of every year. They compete with big game animals
deer, elk, and antelope. This condition is real critical to
big game animals especially during the winter months.
The BLM Is famous for letting their horses proliferate
to the point that they devistate the landscape. A good
example of that is the Yank Creek Field.
The Rex CI emens Ranch has a grazing right in the Yank
Creek Field, but has not been able to use this field for
several years due to the over population of government
horses. The horses have abused the riparian area in this
field to the point of no return.
The BLM has made no effort to correct this problem.
The only way to correct this problem is to fence the horses
out si nee this is private property.
It is my opinion that the BLM Is I
special interest groups that don't make
County. I believe the BLM should get back to the
1 and management and raise fewer government horses
enced too much by
rney
cs of
Appendi >
2 Table 2
Parcels of private land have been selected for
acquisition. The Yank Springs, Poison Creek, and Swamp
Creek parcels, 1,040 acres, are an important part of our
ranching operation and are not for sale.
Append!
7 -
As stated in the draft RMP/EIS most of the water f
animals of any kind, in this area is on private land,
therefore it is not proper to establish an ACEC here fo
Wl 1 d Horses.
Ulster Qual
Chap. 3, Pages 2 and 27
Available references or detailed explanation should be
prov i ded for the methodol ogy used in de term i n i ng surface
water quality. There are no streams in the R A that have
good or better surface water quality. Does BLM have
evidence to suggest that good or better BLM surface water
quality ratings are possible in the Three Rivers Resource
Area? I beleive the water quality is adequate for the area.
RECOMMENDATIONS
BLM should begin quadrat frequency (trend) studies to
determine the long-term changes in vegetation and range
condition. These studies are recommended and described in
BLM Technical Reference TR 4400-4 and the Nevada Rangeland
Monitoring Handbook (1984). If frequency studies indicate
that the trend in range condition is declining, current
utilization standards, stocking levels and/ or grazing
management should be adjusted. Conversely, if trend
improves, utilization standards and stocking levels should
also be adjusted. Until such a monitoring system is
implemented and data analyzed current grazing systems ,
stocking levels and utilization standards should be
con t i nued. _ s\
o ft
Don Barnes
Rex Clemens RAnch Inc.
Following is a listing of the ranch all otments :
H 5219
ft 5307
tt 5308
tt 5321
ft 5323
tt 5330
Hami 1 ton FFR
Smyth Creek
Kiger
Hami 1 ton Indi
Clemens FFR
Deep Creek
19 AUMS
1,919 AUMS
586 AUMS
150 AUMS
78 AUMS
128 AUMS
3,150 AUMS
On the Clemens Ranch Allotments If a 30 to 50 V.
reduction in allowable AUM's is taken the result will be a
significant reduction in the value of the base property
associated with these BLM permits. At 450.00 per AUM value,
a cut would reduce the base property value by:
3 , 1 50 AUMs
x 30 X
945 AUMs
x 450.00
$47,250 .00
3150 AUMs
x 50 V.
1,575 AUMs
x $50.00
$78,750 .00
192
-3
192-4
192
-5
192
-6
192
-7
The intent of the plan is not to show that livestock are the cause of
all resource problems. Livestock use is a recognized tool for
effecting changes in the range resource. Wild horses have caused
resource damage in some areas just as cattle have in others. The
purpose of this plan is to balance the use by all resources as
outlined under the Purpose and Need section in Chapter 1, DRMP/DEIS.
A recent allotment evaluation of Kiger Allotment shows that resource
conditions in the Yank Springs Pasture have declined when wild horse
numbers exceeded the maximum management levels. Wild horse numbers
have prevented use by cattle in the Yank Spring Pasture during
several of the last 10 years. The riparian areas of Yank Spring Creek
do warrant some attention as do many of the riparian areas of the RA.
Fencing the private land along Yank Springs Creek may be the best
option for improving riparian condition in this area.
The BLM is not in a position of managing the resources on private
lands. Wild horse numbers in the Yank Springs Pasture will be managed
so that livestock grazing remains a valid use for this area.
Refer to response 2-11.
Refer to response 32-1.
Refer to response 4-14.
Refer to response 2-68.
Refer to responses 2-3, 2-25, 2-26, 2-28, 2-44, 6-3 and 6-4. Also,
refer to response 2-87 regarding methodology.
Refer to response 2-94.
The reductions in livestock grazing resulting from BLM
proposed a I ter nat i ves w i 1 l force many livestock operators
out of business. This is contrary to the criteria for the
compos! tion of the preferred alter native (chap ter 2 paqe
3). The most likely effect of BLM's proposed alternatives
A, B, and C is that many ranchers and long term residents of
Harney County will be forced out of business.
BLM's proposed preferred alternative will reduce the
value of the Rex Clemens Ranch Inc. base property associated
with its BLM grazing permit. BLM' preferred alternative
will cause unreasonabl e and unacceptable economi c damage to
our livestock operation and liveli hood. Th is will reduce the
total number of livestock that the ranch operation can run
on a yearlong basis.
Appendix 11-183
"— ™~"«-
193
Bureau of Land Management.
Burns District Office
HC 74-12533
Highway 20 West
HinGS, QR 97738
AS to
then the cut is not reduced to help wildlife because; the cut
would significantly effect timber supplies (page 1-7). Which
is it? Timber production should be done in such ,
Minimise its impact on wildlife.
In short, the perferred plan should revised
significantly. Alternative A is the closest to the plan
We are writing
Resource Management Plan,
ovei — emphasis on grazing an
natural systems and populat
plan (with a few minor cone
ultiple
on the draft Three Rivers
Short , the pi an perpetuates
indei — emphasis or. mai ntai ni ng
is. This is another 8LH graz
.i ons) and does not con form t
i p 1 es .
The forage allocation of 139,851 AUM for livestock
far too high. Statements that it will increase above this
level are even more disturbing. Too much emphasis is placed
on short-term enriching of a small number of ranchers. We
disagree that habitat can be improved to the extent forecast
while keeping livestock grazing at such a high level.' Vou«"
actual analysis is not included in the plan but it must
^contain f aul ty assumpt i ons.
Livestock "improvements," namely planting of crested
wheatgrass should be halted entirely. The planting destroys
the natural ecosystem and creates a cattle monoculture.
Public land use agencies should care about biological
diversity. Crested wheatgrass is also the worst in terms of
multiple use. It's for cattle and cattle alone.
Forage allocations -for big game should increase. A
healthy big game population is worth more than sustaining a
certain level of cattle. Hunting can be big business and be
worth more to the public than a minor number of cows.
Wildlife viewing, similarly has a value ever, though the BLM
docs not collect fees for it. The &LM places too much
emphasis on commodity sales.
The absence of habitat analysis for non-game animals is
a gl ar ing omsfi^sion. Hon— game ani mal s need forage for food ,
shelter, efce. They are an integral part of the ecosystems of
tl'i« area and management of the area should reflect the impact
on them. Most Americans enjoy viewing non-game wildlife and
your lack of information on th«m is indicative of ft
management that is out of step with the public wishes (encept
for c*ttle ranchers). The plan should include specifics to
begin studies of non-game wildlife and the impact of grazing
on them.
ve or a
v»lu
themselves and Are not just a commodity to be sold to feed
cattle. Very little emphasis is placed on repairing damage
to the native ecosystem of the area (with the ewecption of
wetlands and riparian areas). The rangeland ecosytems
themselves have been greatly damaged from past grazing
practices and the preferred plan does nothing to repair that
damage. Additional areas should be given designations which
permanently remove cattle and give the area a change to
recover from a century o-f ovei — grazing damage.
Recreation, like ecosystems, is low on your priority
list. More areas should be given "Special Recreation
Management Area" status. Nothing discussing additional
trails, campgrounds, wildlife viewing areas, recreation maps
and signs, etc. is in the plan. We sre researching a
recreation guidebook and had very little help from your
office in finding recreation opportunities in the district.
It is no wonder that more people don't visit &Ln lands — you
don't publicise them, develop them, or make access easy
though user-f riendly maps and signs. The plan should have
specific plans for signing roads, developing maps (like the
ones put out by the forest service), and constructing
campgrounds and trails.
The rating system for water quality and habitat
conditions (Poor through excellent) is meaningless without
knowing the criteria used to determine the ranking. I aleo
have concerns with the tracking of these rankings. Fundinc
for these ongoing studies often seems to he the first cut. A
statement that funding for livestock grazing projects will be
cut before the funding far monitoring studies to track the
health of habitat and water systems should be added to the
plan. 'Without that assurance, the assumption on page 4-2
<(S2) makes the plan useless.
We support special management of the Kiger horse herd.
It is a special resourso that deserves protection. Another
herd should be started in one of the other HMAs, however, to
further protect the breed from catastrophy. Also
designation of the Malhtier River as Wild snd'Scevn
outlined in your plan.
Protection of wetlands and reoair of riparian systems is
to be applauded. However, removal of cattle from riparian
&r't*a5 shoul d be permanent. Temporary removal on] y sol ves tN-
problem temporarily. Cattle caused the degradation end pr.)v
thej.r long-term removal (or a major reduction in numb era)
with protect riparian arc-as and their associated attributes.
You contadict yourselves with respect- to tirnh'-r. It
States that the timber in the planning «rc„:. ia , nB1 ,uni ;. ,. ..... ,
George Dstertag v
Rhonda Qstertag
4303 25th Ave. NE, #13
Salem, OR 97307
193-1 Refer to response 2-10.
193-2 Refer to response 1-11.
193-3 Refer Co response 2-10.
193-4 Refer to responses 1-18 and 11-14.
193-5 Refer to responses 1-18 and 11-14.
193-6 Refer to response 1-13.
193-7 SRMAs are defined as areas which require greater recreation
Investment, where more Intensive recreation management Is needed and
where recreation is a principle management objective for which the
Bureau plans and manages. The remaining public lands are considered
Extensive Recreation Management Areas (ERMAs) where recreation Is not
a principle management objective and where limited needs or
responsibilities require minimal recreation investment. These areas,
which constitute the bulk of the public lands, give recreation
visitors the freedom of recreational choice with minimal regulatory
constraint.
The Bureau utilizes this categorization of lands in order to set
budget priorities and spend the limited recreation dollars In areas
where they will do the most good and return the most benefit for tile
recreating public. The SRHAs are where funds are spent for
development plans, interpretive plans and construction of facilities
such as campgrounds, picnic areas, trails, interpretive sites, signs,
parking areas, etc. The ERMAs also receive funds to enhance
recreation opportunities but not to the degree as the Intensive used
Special Areas. Funds are often spent for signing, maps, road
improvements, primitive sites, access, boundary marking, etc.
The RMP determines the management direction for each resource and,
for recreation, does not go into details such as signing, map
development or construction of facilities. Specific details to
accomplish management decisions are developed in activity plans which
address much smaller parcels of land or special areas. Please note
that trail development Is addressed (Desert Trail and Silvies River
Access Trail) as is facility development at Chickahomlny, Moon, and
Warm Springs Reservoirs as well as those noted for enhancing
informational and educational opportunities.
193-8 Refer to response 193-7.
193-9 Refer to responses 2-3 &nd 2-25 .
193-10 The type of decisions sought in this comment are outside the scope of
the RMP. The RMP provides comprehensive resource management
prescriptions; funding priorities are not set at the RMP level.
seal
voiu
Year-to-year funding priorities, which are the responsibility of the
District Manager and the Area Managers, are influenced by commitments
made In the land use plan (the RMP). Local funding priorities,
however, must also respond to directives imposed at the state and
national level. Also, refer to response 2-52.
193-11 Refer to responses 2-6, 2-68, 8-11, 11-11 and 13-28.
193-12 Refer to responses 2-11 and 3-13.
Appendix 11-184
H @4
Quintin D Myers
19341 Kiowa~Rd.
Bend, Oregon 97702
503-382-4633
January 19, 1990
District Manager
Bureau of Land Management
HC-74-12533 Hwy 20 West
nines, Oregon 97738
Dear Person;
Regarding the Draft Three Rivers Resource Management Plan and
Environmental Impact Statement.
I am very upset with this plan and I demand that the BLM develop
an alternative to restore and maintain rangeland in excellent,
natural condition. Cattle grazing should be reduced or
eliminated where appropriate. At a minimum the BLM should adopt
ftlter.na.tiv* "a".
I insist that water quality, riparian and aquatic habitat be
improved/maintained in excellent condition, and that all ancient
forest be identified and protected.
I ask that all costs of construction of new roads and other
rangeland projects be included under the various alternatives
along with their environmental impacts.
I ask that all crested wheatgrass seeding proposals be
eliminated.
I demand that bighorn sheep habitat protection and impacts be
addressed in the plan and further, that forage allocations go
entirely to bighorns in their home range.
I request Wild and Scenic River designation for ALL of the South
Pork and Middle Fork Malheur Rivers (except for the reach
through the Drewsey Area), ALL of Eluebucket Creek, and ALL of
the Silvies River.
I also recommend the wildlife winter range forage allocations be
given priority over livestock allocations.
194-1 Refer to response 1-13.
194-2 Refer to responses 2-44 and 6-4.
194-3 Refer to response 12-7.
194-4 Refer to response 1-11.
194-5 Refer to response 2-78.
194-6 Refer to response 3-6.
xyC^-
Quintin Myers
ffl&Hw>H> {fi>l&.**T -- LbMrt'/ffj on 3 /f|V«0 $g&o*f"6JL
!l
Mffrt"/ PJ*A <*AJ £Z$.
ore$re\r> flo ,' ft fa /\A,a n'w J& -z/f t < TXftsJ -/■<■=/ iOi^'t? . &^T you
economic &s\ shell &-f $ke sMrf&uj eififics#« JTvCf * Afo
£>A an af-fcrnafiv-t- U-Krhnur re-tcmv\LJ- -fa Aow) /vil*cA (/ u/i(/
Cos^f ? _T*yi jure ycu LJoulJ o<j/-ec /&;/ -f4u's i'a /*'**■ *o'&i o
i/»Va/ for a weii- t"n&fA\c*{ *n<t*Sm* Ciff*** **rf H*- fl+U*J.
~fk £ da-fa jCfo uAs /vi«/ yo w a. « o l/g/-- <jr^ji^i a*c/
$"h&j TH* m+\°r,4y D-f /i VfMr©r,'<r<s/ -STV-Cei/iij arc in pa
m«r ^C/U me. kou sons, AUflAs Uttt A< ArV^w-"/-
Th-CrA t's /LO-/-A.IS11 fA lL/~t~ &/& c L"V\ e a T -rk<rr Azf/ii WUa. u^mtff*-
ts\m. • CZTCot Car I
Tf X".
si f A/-*- a -f yaur -5 /Wanip^fr
T\Aoue n 'V n**re/ (y /t'^fs ^a A* /7\5 Y\arriC- .
xjC /via Wis -la/Vic a/id fafaoA.
v.
I. tt«J
195-1 When comparing nonmonetary values to values commonly measured in
dollars, the development of proxy monetary values is required to
prepare a benefit cost analysis. Because a single proxy dollar value
cannot adequately represent the breadth of subjective values held by
individuals, benefit-cost analysis are of limited value where choices
about nonmonetary values are being made.
195-2 Refer to response 28-1 and 94-2.
195-3 Refer to response 2-11.
195-4 Refer to response 3-13 and Table 4.19, p. 4-28 DRMP/DEIS-
Appendix 11-185
Princeton, OK. 97721
February 14, 1990
196-1 Refer to response 131-1.
Jay Carlson
Burns District Office
Bureau of Land Management
HC74 12533 Highway 20 Vest
Dear Mr. Carlson;
The letters from toe Harney County Cattlewomen, Stockgrowers, Farm
Bureau, Sheep & Voolgrowers, and the January 17,1990 Riddle Ranch and
Western Range Service Comments and Response to the Draft Three Rivers
Resource Plan and Management and Environmental Impact Statement are
consistent with my views and comments.
I also want to comment on the Davies allotment #5215- Ve as a
family ranch have used this allotment for many years. Ve have never
abused it. I was surprised to find it listed in unsatisfactory
condition in The Draft Three Rivers Statement. I want tD go on record
that I disagree with the "1" Selective Management Category strongly.
Sincerely,
Horma I. Davies
fl/g&zU.
197
Box 10
Princeton, OR. 97721
February 14, 1990
Refer to response 131-1.
Jay Carlson
Burns District Office
Bureau cf Land Management
HC74 12533 Highway 20 Vest
Dear Mr. Carlson:
The letters from the Harney County Cattlewomen, Stockgrowers, Farm
Bureau, Sheep ft Voolgrowers, and the January 17,1990 Riddle Ranch and
Western Range Service Comments and Response to the Draft Three Rivers
Resource Plan and Management and Environmental Impact Statement are
consistent with my views and comments.
Allotment #5215, Davies Allotment has been used by my family for
three generations. 1 Just don't see it in the "needs improving
category". Half of it is used as exchange of use in conjunction with
private land. Ve certainly haven't been misusing either property, The
other part of the allotment is in good range condition also. Your draft
study has the capacity almost double of actual usage so I find it hard
to understand it being in unsatisfactory condition.
Sincerely,
Maurice M, Davies
Appendix 11-186
Ponderosa Ranch
HC 30 Box 3439
Burns, OR 97720
(503) 542-2241
1
Feb. 13, 1990
Jay Carlson - RMP/EI3
Burns District Office
BLM
HC ?k - 12533 Highway 20 West
Hines, OR 97738
Dear Mr. Carlson;
In our review of the Three Rivers Resource Management Plan,
we would like to make a few general comments followed by more
specific comments related to the Silvies allotment (41^3).
First, we believe that the development of a Plan such as this
should involve the ad jacent land owners/permittees in the actu
planning process through one on one or in small group meetings
Not to actively involve people Such as ourselves appears to us
as a real lack of concern for the community. Secondly we wond
if there is really much of a need for such a plan in that it i
so complex, ambiguous, and cumbersome as to render itself usel
Wouldn't it be better to concentrate on the individual allotme
plans making sure they meet the criteria already in force? Al
we see that there seems to be an over emphasis on the wildlifi
relation to the amount of consideration given resolving wildli
livestock/environment conflicts.
Now, more specifically in regards to the Silvies allotment , we
would like to comment on the following items:
1. Appendix 3-21 - BLM figures show that actual use is
2,586 AUM's while the estimated capacity is 2,311 AUM's. You
might be interest to note that in 1979 the BLM range staff and
I established figures on an acre by acre basis what the BLM useage
would be for each pasture since all of the pastures on the allot-
ment have mixed ownership. The preferred useage of 2,500 AIM'S
was based on a total ranch useage of 29,000 AUM ' s , including
the BLM and USFS allotments. Since that time the management on
the ranch has added 3,000+ AUM's on USFS allotments while at the
same time reducing the total AUM's used on the ranch to a maximum
of 2^,000 AUM's. For the past three Seasons our actual total
useage for the ranch has been 18,000 to 22,000 AUM's. Therefore
we would seriously challenge the accuracy of your figures on
actual useage .
2. The BLM also makes note that the wetlands habitat is
fe/
198-1 Refer to response 27-6.
198-2 Refer to p. 1-3, DRMP/DEIS for a description of the Purpose and Need
for the RMP. Appendix 3, Table 6, provides a comprehensive and
detailed treatment of the management needs for individual allotments.
198-3 Refer to response 2-11 and 2-17.
198-4 Refer to response 7-12 and PRMP/FEIS, Appendix 1, Table 4. Also, the
disproportionately high amount of wildlife use In relative scarce
wetlands makes the wetlands high priority.
198-5 Aerial photos and topographic maps Indicate that the dam and a
portion of Charlie Smith Butte Reservoir are on Bureau land. If
surveys show differently the area will of course not be under BLM
jurisdiction. Regardless, this reservoir has and should continue to
provide brood rearing water for waterfowl.
198-6 Refer to response 42-14.
198-7 Site-specific objectives and feasibility of the proposed reservoir on
Poison Creek have not been fully analyzed. Prior to any project work,
a feasibility determination and EA would be accomplished.
less than satisfactory condition. Should that be a priority
on streams that are only seasonal at best, and make up 1 - 2 $ of
the BLM ownership in the Silvies allotment?
3. Charlie Smith Butte Reservoir - although our research
is not quite complete, we believe that the dam is only on the
east edge of the BLM line and that none of the reservoir lies
within BLM ownership. Also the reservoir in not filled by
natural drainage but is filled by ditches coming out Cotton-
wood and Bridge creeks. This water is only available when not
needed on other parts of the ranch.
k. Dog creek, Poison creek, Mountain creek and Flat creek
are short season streams only .
5- A reservoir on Poison creek would be complicated by
the short supply of seasonal water, plus the problem of the
water being needed during the irrigation season.
We believe that the Three Rivers Management Plan needs to have
the above mentioned conflicts' resolved along with the concerns
others are voicing before it is adopted in a final form. Allot-
ment Management Plans and range management philosophies only
work when we're all working together towards the better utilization
and protection of our range resources.
D. Garth J_p«nson, Manager
Ponderosa Ranch
Appendix 11-187
199
<^f;
&*-J( &uJUfr~9A AjZ&'JdaJi fJ^uCkj op Ckffy
199-1 Refer to response 2-11.
199-2
Livestock use Is evident along Poison Creek; however, BLM
administration only covers 0.25 miles of the creek. Refer to response
3-13.
Appendix 11-188
Jay Carlson
Burns District Office
Bureau of Land Management
HC 74 12333 Highway 20 West
nines, OR 97738
2m
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/ElS
200-1 Refer to response 2-63.
Dear Mr. Carlson:
(If you
paragraphs.
If .
reduction in AUM's, please include the next two
out second paragraph. )
Alternatives A, B and C will result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation so that it is no longer an economical unit. Therefore,
we request that if Alternatives A, B or C are considered, that prior to
issuing the Final Three Rivers Resource Management Flan and Environmental
Impact Statement, a "Takings Implication Assessment" be completed as
authorized by Executive Order 12630 (see the November B, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel).
Thevreallocatio
property by approximately S, "7 7t'M
Please consider this econ
Assessment. "
and/or reduction of 7,i AUM'.
Allotment will reduce the
W
livestock forage
'alue of our base
(Assume S50 per AUM value).
9 requested "Takings Implication
The letters from the Harney County CattleWamen, Stockgrowers, Farm Bureau,
Sheep & Woolgrovers and the January 17, 1990 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivera Resource
Management Plan and Environmental Impact Statement are consistent with our
views and comments.
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include a
full copy of text only for the reason that it would be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we may have are enclosed herein and are
supplemental to our principal response.
Sincerely, , K i*C2 /} r-
■J:Jl,i'^.Mcu fet /,jW-j?W
1,\l-
n
Signa~tu
■:Sj^~^Jcu^g I',.,-
Zip Cote \j^\jf^S\i^A.
Enclosure: Supplemental Comments
2®H
&^<V ^JZjJz^ Jil£^/. fffi^y >^£-<4iW
-&•-■**. CP/C. 777.::
,T
201-1 Refer to response 2-11.
201-2 Refer to response 157-5.
'-/ — "<^7
Qi-t-tx-
o-£i~a ,^>£,y ' &£*. c-
2^0 &:-£&*/ „-i'-C —
~t?«-H*s*^y
.-/*~>-^Xf .
^f.A *d&£6( i2-"-^ ^W £*+.<* *6 &L
■~H*-t3fti
'tA
~4
c*-
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J£/«
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Appendix 11-189
202
XJT&L
The Bureau frequently authorizes grazing permittees and other members
of the public to construct developments on public land. Prior to
authorization the Bureau prepares NEPA documentation and analyzes the
proposed project. This is designed to be a 2-year process from
proposal to construction. Refer to response 129-1.
■^gg^X^-^gfcz&ia^^-xa^^^T^":^^ (3 L jv)J
gta Cui ii
1 ^yZ'^f^ ^^^^y (2y^^^^'^f^^dZ^^t^^J^
"I oeef a an M
'Mfdimaia sarnie
James D. Ward
57923 Foothill Rd.
La Grande, Ore. 97850
Joahua War-burton
District Manager
Bureau of Land Management
HC 71+-12533
Hwy. West
Hines, Ore. 97739
January 20, 1990
203
203-1 Refer to response 3-13.
203-2 Refer to response 2-10.
I'm writing in response to you Three Rivers Management Plan. I must say that your
preferred alternative, if instituted, will be a "far cry" better than current
management .
Although it seems you are intending to make significant improvements to your
riparian systems through the reduction of A.U.H.s in these vital areas, I don't
I think you are doing enough, I would like to see complete protection and restora-
tion of all important riparian areas if it means permanent fencing or the restrict
ing of livestock in any allotments that contain the water courses. This would in-
clude ponds, reservoirs and springs as well.
203-2 1 I would also like to see more emphasis on impn
ing forage conditions for elk thai
the preferred alternative suggests. Although I'm aware that many area ranchers
enjoy the relatively inexpensive grazing opportunities on "my" land, considering
the obvious degradation of range lands in your districts, I don't understand why
the public must forsake our priorities for these few.
t ■'
./. u:-,,{
Appendix 11-190
HARNEY
COUNTY
2m
204-1 Refer to response 1-13,
RESOLUTION
WHEREAS over 70% of Che land in Harney County
by Che government;
WHEREAS the wealth of natural
has provided the economic base
public lands con Cain
communities have been
WHEREAS direct paym-
fiscal 1989;
to $4.3 million in
WHEREAS these direct payments comprise a significant share of our
local governmental revenue and reduce the property taxation burden
on property owners;
WHEREAS the majoricy of the Family Wage jobs in our county depend
upon the economic outputs from our Federal lands;
WHEREAS successful implementation of our Regional Strategy for the
diversification of our economy relies upon the maintenance of the
Wood Products Industry;
WHEREAS Federal lands supply over 95% of the raw material which
supplies our local wood products plants;
WHEREAS Federal lands supply 15-20% of the forage consumed by
livestock in Harney County;
BE IT RESOLVED on this 12th day of February, 1990, Chat the Harney
County Chamber of Commerce Board of Directors can and will only
support those Federal Land Management Plans which will ensure the
sustenance of livestock grazing and timber harvesting at or near the
levels of recent history.
Signed,
Harney County Chamber of Commerce
Board of Directors
HARNFYrmiNTVCHAMRFR Of CCMMPTtCF
18 WEST □ STREfcT BUHNS OREGON 97720 ■ 503-573-2535
■mm
January 17, 1990
Joshua L. War/burton, District Manager
Burns District Office
Bureau of Land Management
EC 74-12533 Highway 20 West
Hines, OR 97738
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Warburton:
The January 17, 1990 Riddle Ranch and Western Range Services
Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent
with our views and comments.
This response is our endorsement of such Riddle Ranch
document , Their response has been submitted to you . We do not
include a full copy of text only for the reason that it would be
an exact duplication of the Riddle Ranch document.
Any additional comments we may have are enclosed herein and
are supplemental to our principal response-
Refer to responses 2-1 through 2-96 which are responses to issues
submitted by Riddle Ranch and Western Range Service.
Name
EC 72 a
^
ox ^5
?rincet
on* Or,
97721
Address
City
State
Zip
Code
Signature
E-heleswre-: Suppi-eme-afeal C-osimeff&s
Appendix 11-191
-oeeqoN-
l^faturaf'Deserr
*-«»
Joshua Warburton
District Manager
Burns District BLM
HC 74-12533 Hwy 20West
Hints, OR 97738
•u« ASSOCIATION
Md
2/15/90
RE: Three Rivers Resource Management Plan/EIS
Dear Mr. Warburton:
The Oregon Natural Desert Association appreciates the opportunity to comment on
the Draft Three Rivers Resource Management Plan. We also appreciated the
opportunity to have Jay Carlson and Rob Burns of your office meet with us on
February 2.
Our primary concern deals with the range of alternatives presented. Specifically,
we take issue with the narrow and biased nature of the Alternatives used to
portray the spectrum between the commodity and natural values alternatives.
Fifty-six years after the Taylor Grazing Act mandated conservation and
improvement of our western public lands, and thirteen years after FLPMA, we still
have, of 95 streams identified in this planning area, none in good or excellent
condition and 62 in poor condition. Of 34 wetlands identified, 16 are as yet
unsurveyed and only 4 are in good condition. Of the 1.6 million acres in the
livestock grazing program, 64% are now classified in "fair" to "poor" condition.
This will "improve" to 60% in the preferred alternative, A 4* improvement over
the next 15 years! At that rate, how many years will it take for the entire range
to be in good or better condition? None of the alternatives in this document deal
with the incredible task of restorfngihz land to a healthy, ecological status.
The planning criteria for alternative formation (page 1-81, states that "At least
one alternative among those assessed will provide for emphasizing the protection
and enhancement of natural systems and sensitive resources." The planning
criteria should also include a "restoration" alternative. The term "restoration" far
more accurately describes the course of action you wiil have to follow given the
poor ecological condition of the landscape.
Further, any alternative should be able to answer the following questions: What
has been the consequence on natural systems arid sensitive resources by livestock
and what Specific actions are being proposed to maintain these systems in a
p.o. eox 1005 eeNb, oo.eqoN 97109
. :■: ■:;'
.Ml lands should be
development nnhl a
development*.
awn from mining and geolhermtfl exploration and
idr- £}> is r.-ojnpicir-d on the cumulative n'frrts of these
Range u'hpro^'emejjts
The full costs and adverse impacts of crested wheatgrass and other
"improvements" are hot fully discussed, Crested wheatgrass plantings should be
prohibited unless a full L'lS is conducted.
Implrmrntaiior; costs
The erologic and monetary costs arc- not -vsptayed for the* proposed alternatives,
What wen- the historical conditions, ho^ have the> changed and why. what has
been the- effect on loss of biodiVersil\ mid ecologie integrity, and what will it take
to achieve full ecological recovery? Whai are the required budgets for achieveing
the desired objectives under the proposed alternatives? as a baseline condition
for evaluating the efficacy of the propose-:! alternatives (.i.e. the rate of
improvement), we reeiuesi that yor depict a eosi and 'ime schedule assuming
natural recovery !i.r. if there wrr<- no Ii vested, on the land, estimate how long
would it take for the land It) heal aMf and what BLM's cost would be to effect
this recovery. .Also see wmment below regarding land and water monitoring):,
Native plants
What is the range and health of native, sensitive, threatened and endangered plant
species. To what extent have they been displaced or destroyed by past
management activities and how will they be affected under die proposed
alternatives':1 Whal provision is being inside m the altcmahves for reislablishinent
and recovery'? (?ee cwnmeni referring to the ecologie costs of the propped
alternatives)
rublic input
The plan should define a process :
require individuals fn respond ;.- f
general public can: "<■ : '■" slio-.! ' :! ■■yfa'"' <::<:yf:
mnnag'":'!'iri'-t get iv !!!■'"*•,
Lj^djrrJi.'..\vuier..iui_^iJi,i]'n:J^
A comprehensive network of wutcrshecb* shouli
for long- ttriu uiunitonng of natural recovery.
strategically placed to reflect si! cor: ibintv tioas 1
including soils, rehef, evsfmg eonddfons, zy^rc
Are public involvement that does cai
y\ every fiilGimeni tnanagemen: plan. Tr
■ <:;'.]''■■::■ 'd 'i;> •.:-■* involved in dav'-ta-dtn
be established that would s
"he watersheds should be
1 landscape, characteristics
vegetations, etc, These arr
now
206-9
206-10
:.o.rma! ecological condition? As a specilfc r\;imple. whal are tin- specific (loals
and actions that will maintain bighorn sheep populations. What was their historic
range? How have they been displaced? What is preventing further
rant induction? Where will rein t rod uctiun occur and When?
We there-fore request that the final plan include a restornt/on alternative thai
reflects a plan of action that will maintain natural ecological integrity and
biodiversity.
Additional comments include the following:
Water Quality
We find the condition of water quality, Aquatic habitat arid riparian areas to be
completely unacceptable. We recommend that their be an immediate removal of
al] livestock from all streams in poor or fair condition.
Forage allocations
The tables showing forage allocations only show the competitive amounts. Wha'
are the non-competitive wildlife a Hot -at ions? Arc IVage allocations reserved for
the habitat needs of non-game Midlife'!* If not. why not? How does such inienv
grazing affect the micro-climatic conditions for oilier wildlife species? How can
Q~% of the "competitive" forage be allocated to livestock with only 3* towards
wildlife? What are the consequences on natural wildlife populations (not ODFW
target populations) of this radical proposal?
Implwiimtfltlon sche date
None of the objectives state a time period for achieving the desired condition. If
the range improves by a margin of 1% over the period of the Plan, will the BL.M
report thai as meeting the objective? We fee] it is essentia! to siate the time
frame for implementing the objectives &ncj the level of improvement thai will be
achieved in tire stated time frame, (see comment below regarding implementation)
ecomrn ended, desfgr.
:e )?.V' ^ seres to
sisjiai^ IfcTn acres •
. the Foster Flat Coi
■f-s m 'h" 'y- '■:']■ ■-••o\
AC7.C tihu Vj.UlK) 1
In addition to the areas you hs\
'•<" VACH:. in Diamond Crater*
Obsidian A-CEC.
Wilderness
The Malheur River and Stonehuuse WSAs should be recommended for Wilderness,
Remaining lands' identified in the original Wilderness Inventory should be
reciiinmenfied for primitive, non-roaded status. M^tor vehicles and grazing
eti!'.ancemei".ts wnuid be prohibits!
would provide the public arid aiM to escertr.tn the 1
water management activities relative to a rerovetlnj
:ic\ 0; the sL
1 livestock) wi
ershed.
Wild ft. Scenic Rivers
Bhiebucket Creek, should be designated a "wild" Wild and Scenic River upstream of
the WSA boundary, including the private land, which should be acquired through
purchase or trade along with the private inholding on the Malheur River.
We disagree with your conclusions on aU of the evaluated river reaches with the
exception of section D on the Malheur River. Not only do these river reaches
possess outstandingly remarkable values but also are suitable for management.
We disagree vehemently for using the rationale that because the Silvies and
Malheur Rivers lack "limited rafting in springtime" that they are therefore
ineligible. There is no basis for applying a recreation criteria only to a particular
season of the year much less one that relys on rafting.
We request that a more thorough inventory he made of potential Wild and Scenic
Rivers including aU triutaries (eg Cottonwood Creek. Silver Creek, Ermnigrant
Creek., Pine Creek, Birch Creeketc.) and waterways that have similar flow
characteristics to Bluebucket Creek which you are recommending be designated in
your preferred alternative.
Old Growth
A morotorium on the cutting of all remaining old growth and native forests and
road building should be imposed until a complete inventory and protection program
is established. (Native forests include all forests that are predominantly roadless
and that have not been logged in the past- Old growth forests include all mature
and overmature forest stands and may have been selectively logged and lightly
roaded.)
In conclusion, we compliment the Burns District in putting together a planning
document that exceeds the quality of past BLM plans. Given the number and
complexity of the issues we have raised, we would appreciate the chance to
review a revised draft of the Plan. We look forward to hearing from you.
ional Wildlife Federation
Appendix 11-192
206-1 Refer to response 12-4.
206-2 Refer to response 2-78.
206-3 Refer to response 12-4.
206-4 See Appendix 1, DRMP/DEIS.
206-5 Refer to response 2-10. Also, only competitive forage is allocated,
noncompetitive amounts are available.
206-6 Refer to response 2-10,
206-7 Refer to response 9-7. See also response 5-17.
206-8 The Diamond Craters has been a designated 0NA/ACEC for several years.
An additional 400 acres being proposed for Inclusions would bring the
total acreage to 17 , 056 . The. area is most appropriately managed as an
0NA given the public recreational uses here, while the ACEC
designation affords increased protection. An RNA would be oriented
primarily to research uses, rather than to public recreational
values, as recognized by the ONA/ACEC status at present.
The Biscuitroot Cultural ACEC is proposed for designation, including
6,500 acres. This acreage is incorrectly shown in several places in
the draft plan.
Also, refer to responses 3-1, 15-35 and 159-1.
206-9 Refer to responses 13-1 and 13-2.
206-10 Refer to response 60-1.
206-11 Refer to responses 5-18, 13-4 and 169-2.
206-12 Refer to response 12-7.
206-13 The range and condition of native plant species in the RA is not
fully known because the Ecological Site Inventory (ESI) Is not
complete. The current extent of knowledge concerning special status
plant species is shown on Map SS-1 in the Proposed Plan.
The full extent of the impact of past management activities on plant
species is unknown except In areas where vegetation conversions have
occurred and the native vegetation has been replaced with other
species. Completion of the ESI will provide data on the ecological
status of the upland communities and this may provide an indication
of past management activity impacts.
Direct Impacts to the native vegetation can be found in Chapter 3 of
the PRHP/FEIS. Indirect impacts to the native vegetation will also
result from changes In amount and timing of grazing use as a result
of AMP Implementations and AUM reductions. Protection for and
potential impacts to special status plant species can be found in the
Proposed Plan.
Reestablishment and recovery of native plant species will primarily
be related to improved management of livestock grazing. Upon
completion of the ESI, ecological status objectives will be
established. See the Proposed Plan. Monitoring and recovery programs
for special status plant species are outlined in the Proposed Plan.
Also, refer to response 1-13.
206-14 Refer to response 5-17.
206-15 Refer to response 2-87.
206-16 Dluebucket Creek will not be considered for designation upstream of
the WSA boundary. The same reasons that the private land was not
included in the wilderness alternative for acquisition also apply to
not Including this portion of the creek as "wild."
The old haul roads along the bottom of the creek as well as the
access roads off the main forest road paralleling Bluebucket Creek
may downgrade the potential classification from wild to recreational.
However, the strongest rationale for nonellgibility Is the absence of
outstandingly remarkable values (which may be primarily due to
previous logging, etc.).
206-17 An Inventory of river reaches was conducted and Segment A, Middle
Fork of the Malheur River was found to have outstandingly remarkable
scenic and primitive values. The other segments were either non
free-flowing or did not possess outstandingly remarkable values.
Refer to response 3-6.
206-18 Rafting was only one of several recreational activities that were
evaluated and this was for determination of outstandingly remarkable
recreational values, not wild values.
206-19 The tributaries mentioned may have similar flow characteristics as
Bluebucket Creek but do not possess outstandingly remarkable values
or they are also part of river segments which do not possess
outstandingly remarkable values and are not eligible. The exception
to this may be Silver Creek which is not associated with any river. A
more thorough inventory will be made in coordination with the Ochoco
National Forest. The USDA-FS is tentatively scheduled to complete an
EIS in June 1991, which will analyze this creek for Incorporation
Into the Wild and Scenic River System. A recommendation for
designation of the small portion of the creek under Bureau
administration is contingent upon two factors: (1) that the USDA-FS
finds a contiguous manageable portion of the creek under their
jurisdiction as suitable, and (2) the BLM is successful In acquiring
a private portion of the creek below the section of creek under
Bureau administration through a proposed land transaction, and it,
along with the Bureau lands, Is found to be suitable.
206-20 Refer to response 12-1.
Victor J. Try. twin
1752 135S*. WtV
riioe ,i;n. 56567
207
No comment Identified.
In regard to this Kiger Horseftana^enent Plan and
finvironental Inpact Statement,
I (being a member of the Kl~er Liestano Association, must
Co along with Alternative A would be the most fair to the
horses.
As far as those cattle Ranchers, Well if they did not
raise so maijy . cattle, May they could git a better price for
there prouduot,
f.Hf I, have in the past, adopted a ELM horse and did buy
one iroa another party. And X%% waiting for the day r,-hen 1 can
-It one of these Kiner Horses, I do raise the Spanish SJtiattttig
at the present tine,
So I do hope that this letter will serve cone
purpose ,in aiding these hordes. So 1 do go along with the
Alternative Plan A, It does sound the cost fair.
Thanlc y&i.
Victor J, Trutnin
Appendix 11-193
Forestry Department
OFFICE OF STATE FORESTER
2600 STATE STREET. SALEM, OREGON 97310 PHONE 378-2560
MS
February 16, 1990
and resource planning is a
Department of Forestry
ither interested
Joshua Warburton
District Manager
Burns District
Bureau of Land Management
HC 74-12533 Hwy 20 West
Hines, OR 97733
Dear Mr. Warburton:
Active participation in federal
high priority for all Oregonians . me
appreciates the opportunity to participat .
parties in the review of and comment on the Draft Three Rivers
Resource Management Plan and Draft Environmental Impact Statement
(DEIS) .
While the Three Rivers Resource Area includes predominantly high
desert, sufficient forest resources are found in portions of the
Resource Area to warrant Department of Forestry review and
comment on the Plan and DEIS. As you know, the state depends
heavily upon lands administered by the Bureau of Land Management
(BLM) lands for resources critical to Oregon's economy and
environment. Public Domain lands that BLM manages are important
to both statewide and local economies.
The State of Oregon is committed to both economic development and
environmental quality. Therefore, the Department of Forestry
encourages BLM management plans to balance these objectives by
allowing appropriate economic development, including intensive
timber management, while being sensitive to real or perceived
risks to environmental quality.
The primary objective of this response to the Management Plan and
DEIS is to identify technical concerns and ensure that the Bureau
of Land Management considers the "Forestry Program for Oregon" as
the final Management Plan is prepared-
The Forestry Program for Oregon (FPFO) describes the Board of
Forestry's guidance to the State Forester, Legislature, Governor,
state and federal agencies and to the citizens of Oregon on
matters of forest policy which the Board considers important. The
guidance is provided in terms of a mission statement, objectives,
and an action plan containing policies and programs.
Joshua Warburton
February 16, 1990
areas of unused
b. To enable re-distribution of livestock
or lightly used available forage; and
3. Improvement in the administration of grazing programs and
permits on federal lands.
4. Adoption of programs by federal agencies that increase forage
production for livestock and wildlife, while maintaining or
returning grazeable forest land and riparian areas to excellent
condition.
B. Land Tenure Issue.
The Board and Department encourage exchange and acquisition of
forest lands that consolidate ownerships; in order to place the
management of lands with special needs in the hands of those more
capable of meeting those needs, and protect prime forest lands
that are threatened with conversion to non-forest uses.
C. Wildlife Forage and Habitat Condition Issue.
The Board and Department encourage the adoption of programs by
federal agencies that increase forage production for livestock
and wildlife, while maintaining or returning grazeable forest
land and riparian areas to excellent condition.
D. Fire Management issue.
The Board and Department encourage :
11. Recognition .... that fire plays a natural role in maintaining
the forest environment and wildlife habitat; and
2. cost-effective federal fire management policies that emphasize
planned ignition fires over natural ignition fires and that
consider impacts to the State of Oregon's forest fire protection
program; and
208-3 I 3. That federal plans which develop and implement fire
I suppression policies at both the state and national levels be
| coordinated with the state.
E. Special Management Area Issue
The Board of Forestry recommends that habitat should be managed
based upon sound research data and the recognition that forests
are dynamic and most forest uses are compatible over time and
that forest management standards and regulations should be
established for the protection of necessary habitat based upon
the best knowledge available and that are consistent with
Joshua warburton
February 16, 1990
Page 2
The FPFO encompasses all ownerships of forest land (federal,
state, and private) , and all resources provided by our forests
(fish and wildlife, soil, air, water, recreation, grazing and
timber) .
The objective of the FPFO is to identify opportunities and
describe actions to deal with issues related to the allocation
and management of Oregon's forests.
In the FPFO, the Board of Forestry has directed the Department of
Forestry to:
1. "assist the State of Oregon in the analysis of federal
management plans and help develop land use recommendations
that recognize that forests are dynamic and most forest uses
are compatible"; and
2. "actively and cooperatively review federal management
plans to improve the technical quality of the analysis and
inventory information within each plan"; and
3. "aid federal public land managers in allocating land use
in order to meet the Forestry Program for Oregon objectives,
and will emphasize the integration of forest land uses, in
recognition that most forest uses are compatible over time";
and
4. "encourage federal agencies to maintain as large and as
stable a commercial forest land base as possible and to
minimize future withdrawals from this land base."
Also included in the FPFO, is specific guidance which is related
to the five planning issues identified by the BLM in the Plan and
DEIS as significant and important. This guidance is listed below
with the five identified issues for your consideration.
A. Grazing Management Issue.
The Board and Department encourage:
1. Integration of sound grazing management practices, compatible
with timber management goals and wildlife habitat goals, on
public and private forest lands; and
2. Development of grazing improvements, such as water, fencing,
salt, etc., and utilization of sound grazing practices:
a. To assure additional needed protection of riparian areas
or other sensitive areas: and
Joshua Warburton
February 16, 1990
Page 4
responsible forest management.
Discussion of Alternatives Presented
The Management Plan and DEIS present five alternatives. In The
Forestry Program for Oregon, the Board of Forestry encourages the
integration of forest uses in recognition that forests are
dynamic and most forest uses are compatible. The Board also
encourages the maintenance of as large and as stable a commercial
forest land base as possible. These policies are to be
implemented in a manner that protects soil productivity, and air
and water quality, and enhances forest values where appropriate
to meet the management requirements for these lands.
The Preferred Alternative, of the alternatives considered, is the
most similar in composition to the policies and programs
suggested in the FPFO.
Discussion of Forest Land Management
Information provided in the Manaqement Plan and DEIS about the
current condition (volume, species and stocking information) of
the RA's forest land and analysis of different possible
silvicultural management techniques are not adequate. Discussion
about these factors is insufficient for the Department to
determine if the identified environmental consequences are
correct and the proposed management directives are sufficient to
meet BLM management requirements and policies and programs
recommended in the FPFO.
Though management directives related to Forestry and Woodlands
contained in Table 2.1 and Appendix 2 (General Best Forest
Management Practices) are generally consistent with the
considered alternatives, discussion of silvicultural practices as
included in these two elements of the Plan and DEIS is inadequate
and should be expanded. As you are well aware, the public is
becominq increasingly concerned about the selection of
silvicultural systems, especially as the choice relates to long-
term productivity, residual stocking and the maintenance of other
values. The Department recommends that standards for selection
of silvicultural systems be included in both of these elements.
(This seems especially important because it appears only one
system (overstory removal) is proposed for use in the Plan
without any explanation of why it is the preferred method and
what the consequences of its use are.) Also guidance on
utilization and snag retention should be considered.
Additionally, the "Best Forest Management Practices" are
indicated to be taken in large part from the Oregon Forest
Practices (ODF, 1980). In 1987, the Forest Practices Act was
Appendix 11-194
Joshua Warburton
February 16, 1990
Page 5
amended and significant changes were made to rules related to
forest practices in riparian zones. I have included a copy of
the current eastern Oregon Forest Practices Rules for your use
and suggest that special attention be directed to rule 629-24-
446. With these new riparian rules, it is unlikely that the
procedures suggested to meet the Forest Practices Act under
Alternative E on page 4-8 ("buffers would be maintained with non-
commercial species and brush") would always result in compliance.
In Chapter 3 (Description of the Affected Environment), limited
description of existing silvicultural practices is made. This
description indicates that overstory removal and seed tree are
the usual harvest and reforestation methods. Additionally, tree
planting as a method of reforestation is indicate as a last
resort. The two tree planting areas are described as having
significant animal damage. The description of the affected
environment would be significantly enhanced by including
descriptions of the major forest ecotypes, their extent, current,
inventory, and how past and current management practices have
affected the condition of the forest.
Additionally, discussion in Chapter 4 (Environmental
Consequences) should include consequences to (under either forest
land or vegetation) forest tree species composition and
diversity, and forest insect and disease resistance. The
Department of Forestry's review of overstory removal silviculture
on some federal lands in eastern Oregon has indicated that
residual stocking is not always optimum and adequately protected,
nor is the resultant favored species always the most desireable
in terms of desired product, insect and disease resistance, and
other factors (visual for instance). Therefore, information
provided in the Plan and DEIS should also provide the reviewer at
least some idea about the consequence of existing and proposed
silvicultural practices. Discussion about what combination of
silvicultural practices will optimize timber production should
also be included.
Finally, discussion of silvicultural practices that can be used
to meet timber management objectives while also enhancing other
objectives should be provided. conversely, silvicultural _
practices that can be used to enhance other objectives (riparian
and visual) while also providing some timber should be identified
and discussed for possible use in those forest land areas
currently set aside or proposed to be set aside from timber
production.
Monitoring
The draft Management Plan and DEIS does not include a monitoring
plan, though it is indicated that the final Management Plan and
208-1 It is understood that fire plays a natural role In maintaining the
forest environment and wildlife habitat.
208-2 Consideration of both planned and unplanned ignitions (DRMP/DEIS,
Chapter 1-4) has been addressed. Impacts to the State of Oregon's
forest fire protection program have been and will continue to be a
concern.
208-3 Suppression policies at State and National levels are not a function
of the RMP process. The fire management program has and will continue
to coordinate with the State Fire Protection Program.
208-4 Chapter 3-11, DRMP/DEIS gives a brief description of the major
silvicultural practices and techniques used. This document is not
Intended to describe In detail the silvicultural practices available
in the management of forests. For detailed information about
silvicultural practices, see BLM Manual 5600. Also, for detailed
Information on how silvicultural practices affect wildlife, see
"Wildlife Habitats in Managed Forests", USDA-FS Agricultural Handbook
No. 553, September 1979. Both of these references will be added to
the Forestlands section of Chapter 3-11.
208-5 Refer to response 208-4.
208-6 The wording in the DRMP/DEIS Alternative E, p. 4-8, should read
"would allow harvesting some commercial forest products . . ." The
statement, "Buffers would be maintained with noncommercial timber
species and brush," should be dropped from Alternative E.
208-7 Refer to response 208-4.
208-8 Refer to response 208-4.
208-9 Refer to response 208-4.
Joshua Warburton
February 16, 1990
Page 6
FEIS will include a monitoring and evaluation plan. A
comprehensive system to monitor the full impacts and results of
the program are essential. Failure to include a draft monitoring
plan with the draft Management Plan and DEIS reduces the
opportunity for lreviewers to assist the BLM in developing a
comprehensive monitoring system and hurts the credibility of the
planning process. The Department encourages the BLM to provide
adequate opportunity for interested parties to review and comment
on the proposed monitoring program as it is prepared.
Thank you for the opportunity to review and comment on the Draft
Three Rivers Resource Management Plan and Draft Environmental
Impact Statement (DEIS) . I hope our comments assist you in the
preparation of your final Management Plan and FEIS. For
assistance on the comments in this letter, please contact Ted
Lorensen, Department of Forestry Policy Analyst at 37B-5033.
CTames E. Brown
State Forester
TLL
Enclosure
Appendix 11-195
26°9
rfTt/S). t& ! »-*."j Al. //&nji
J t*t£jk -ho y.&,~ce. /v^y S u pfo*-*' -fc
f-ka.. X'/gft- 6.<u±sJ. .
'^Ti^Y You
1131 Olds fey lb0*
209 No comment identified.
3 ffw-t-j
210
210-1 This hag been done. See the Proposed Plan, Wild Horses and Burros.
"*
■ZZ y^fC/ A^t£~
,#£_- (Zsr-zP^-p*. j*$»*. ¥<r7-vtts&>' &-o^ J2*^l7^
^
££>^&- a/x'/zJ
■Z^ZCv^ - JZJS%L±=L-L^<
Appendix 11-196
xAt/fJ
' P73-Y(o
2 fi»«h 211
211-1 Refer Co response 210-1.
iX*£>f&<£^-r~. jfsicr-r^
Kiger Mestano Association
Post Office Box 452
Bums, Oregon 97720
212
No comment identified.
February 21, 1990
Bureau of Land Management, Burns District Office
Attn: Craig M. Hansen, HC 74-12533
Highway 20 West
Hines, Oregon, 97738
Dear Mr. Hansen,
After careful study of the Three Rivers RMP-EIS I would urge you to adopt
alternative A for various reasons foremost of whjch is the fact that to me
the wild horse has as much right to the open range as any other wild an-
imal without being removed for one special interest group,
I am the owner of two Kiger mustangs for the purpose of breeding these
animals so they will not become extinct should some disaster befall the few
that are left, Thus I fael it is imperitive to do all we can to help pre-
serve these wild mustangs as part of our western heritage and alternative
A would benefit the Kiger herd best.
Sincerely,
Ann C. Roda
623 W. A. Barr Rd.
Rti Shasta, Ca. 96067
Appendix 11-197
Klger Mestano Association A 4 A
Post Office Box 452 Km I O
Bums, Oregon 97720 _ --» 213 No comment identified.
(xL ; IMP Ms
«*- -cL^Z^e/? jb^J jO -sfU. ^^fc^) ^sZZZr*. y^^«4fc.
L/Z>.
3. -BLcJ&SrtL &*sa& sat, Q*~*Mi4zr j'***-*-'"-"'
M^*t- dud. ^4> (ZM^ k^^^^Xf
ime^uJ% .^W^w^ ^^m/d*6- ■^jU^'i :2S^
Appendix 11-198
Post-It "'brand la« iran&milial memo 7671 j * pppagea ► J£
£$&£ M/aJ}i*S
'r°"}rO\l P.(.;h'J h
Cd
Co.
°""'
n—W&t BO/
'"Vov s73?6&0
**'*/*■ tu-tui
214
JON H. ROBERTS
P.O.BOX 254
MT. SHASTA, CA. 96067
2/22/90
ATTN: CRM6 M. HANSEN
BUREAU OF imii MANAGEMENT
BURNS DISTRICT OFFICE
HIGHWAY 20 WEST
HIKES, OREGON 97738
RK: THREE K3VF.RS RESOURCE MANAGEMENT PLAN AND E.I.S.
MR. HANSEN.
1 apprftcittlo this opportunity to express my opinion on an
issue I feci is of importance not only for Americana Now but
most of oil the future generations to come. May I make clear
now Mrong and how important I feel this issue is. We MUST NOT
allow ANYONE to further compromise our Natural Heritage or
Resources. 1 am specifically referring to the management of wild
horses of the Ridri le mountain arid Kiger herds .
It has been the
chisel away at
remains. Oft
be the only remin
have to reconstru
THE POINT BEING t
and ENFORCE PROTE
thip instance a h
to possess qual j t
di scovcry has led
qua! J ties by govo
to protect what i
the gradual erosi
thore elements th
habit and history of this country to chip and
our resources until only a skeletal portion
en a Bronze plaque inscribed with o picture will
del" that our 1 acki ng foresight and i ma gin at ion
ct what was once a GREAT NATIONAL HERITAGE,
hat we must soi2e the opportunity to EXPAND
CTION for the resources that remain. In
erd of wild horses was discovered and documented
ies that few had any notion existed. This
to effort to preserve and perpetuate these
rnmenta] and public concerns. The ONLY way
s there is to develop a pol icy that prevents
on of this resource and instead seeks to provide
at wi 11 i nsure their continued existence .
The Kiger wild horses do not face a reduced grazing area. The Kiger
HMA is the same size now as in 1971 when the Wild and Free -Roaming
Horse and Burro Act was enacted. There is no proposed increase in
grazing use for livestock in this area. Section 102(a)7 of the
Federal Land Policy and Management Act of 1976 states that
"management be on the basis of multiple use and sustained yield . .
." Exclusive use by horses in the Yank Springs Pasture would violate
this mandate of multiple use. Removal of livestock from all riparian
areas would also violate the multiple-use intent of FLPMA. There is
no intent to exclude this land from use by either wild horses or
livestock.
Refer to responses 25-2 and 214-1.
It has also been tho habit and history of Land Management Policie
to favor thope- who claim their economic existence is threatened
unlc-js they are allowed to further exploit public land. The
cattle industry hafi long been the favored recipient of
government assistance and historically has received continued
expansion of puMSc land use. So much so that it has become an
expected ritual, hence "The louder you complain, the more you
get," In light of their "needs" T must comment that I don't know
any business person who isn't having a hard time in today's
economy. Why we must compromise yet another Natural Resource and
Heritage for the benefit of a relative few is beyond reasonable
explanation .
214-1
214-2
afforded a secure and
1 have been to the Burns area, seen the horses, and talked
with several locals and fl.L.M. personnel concerning the Kiger
breed. In this \ have found that the B.L.M. personnel are
making a competent and honest effort to promote and provide the
new found information about the Kiger herds and their special
Qualities. On the other hand, I found the locals locking
knowledge of the herds special traits. 1 was told more than
once that "The Kiger horses where just strays from so and so s
ranch," On the most part the horses were given no value end considered
o waste of hay. I can understand the natural tendencies to
resist information that there has been something important in
your own backyard you had no idea existed. But I can't understand
why once discovered the Kiger herd
well buffered living zone.
The importance of the Kiger 'gene pool' is without a doubt
enough to qualify them as a NATIONAL RESOURCE. The herds have
survived more than a century without management and now face
reduced grazing area and increased competition from commercial
livestock. I find this an unacceptable solution to the
cattleman's woes, I find that I must SUPPORT ALTERNATIVE A,
the removal of livestock from all riparian areas, and exclusive
use of the Yank Springs Pasture (with no forage competition
from livestock). Once taken, the land will be very difficult
(most likely impossible) to retrieve for the Kiger 9 u«.
1 find it hard to believe that with millions of acres of public
land it has become necessary to compromise and threaten a
GREAT NATURAL RESOURCE AND NATIONAL HERITAGE.
I respectively ask everyone to support Alternative A the Kiger
horses"", and a chance to preserve an important and irreplaceable
resource. Once gone, the Kiger hreed cannot return.
Appendix 11-199
215
215-1 Refer to responses 2-19, 2-68, 8-11 and 1-13.
P.O. box 2?j4
fit. Sha&tfl, CA <?&0<W
February 27„ 1990
:-t-'-- tfor»g*ft
{RI-IP/E IP)
nt*l Imp we i
ttn*r Mr. H»r»*wn,
fifUr cftr*-rt»Uy rpviEving t ho £nvlranffl*ntal Insp&ct Stattenitsnt
far t hf.' Thrfrfa Rivotre MariftgwniBM Plan. I choens* to support
Alic-rri/jiivii' A a-, the: Oflly ti£t'Kf?l£bi(E mffnny-me-nt plan.
Thi« .-i]i finM -i vc- it, the- pnly pj*n ittttt SWfVPK to protect ftfid
pp»rpptu#-tf H hf tmiquw br**«d fl-F heime nciw known as. t'hs Kigast"
Heif-U'-fiti. £iy e hot't-int) A)t»t"Mitiv# ft, nut only win the- Kiypr
hnrar-s. bv (jiifi r*rttfc«t1 Ui« op par Urn i ly tti BKittt In their riftt-
nrsO n&tfttiB htt* ferw Amcri(f«fi p*stpl# will J bwtwfit by having o
triUitw lo t(tt»tr national rwritft©*.
ftc ,n riiu-iLry the! it. very pcoud of tt» history, w# often pay
tr-ibn.il.F-,' t r. p].'i:,e-:., building* artel tibjt-Ltc that rspre'swnt our
lwH*§|ii' by way c< p.lattiuMi», bweilt* and ttofcumenta-'Kifeft. Let us
i, oh enjoy a L IVW5 HISTORY rrprncflting who we are and how we<
pi r Wud hut.
Thi-r* t,hi« *)ttfi'n«tiv(e, ALTERNATIVE A, will put public: land to
Its fc.fl*s-t uw i th*i i»i eomcfthinrj which i« gnod for «n the Am--
c-1'lr-.ii puhHr 1 c**tey and in the future.
cy -1-1 - iC-uLt r4- *s
i Eve.- Robwt*
January "l 7, 19
Jey Carlson
Burns District Office
Bureau of Land Management
HC 74 12533 Highway 20 West
Hinee, OR 97738
216
No comment identified.
REVIEW COMMENTS FOR THE OCTOBER 1989
BLM DRAFT THREE RIVERS RMP/EIS
Dear Mr. Carlson:
(If you are facing a reduction in AUM's, please include the next tvo
paragraphs. If not, cross out second paragraph. )
Alternatives A, 3 and C trill result in a substantial loss of our base
property value. The proposed BLM actions may result in reducing the size
of our operation bo that it is no longer an economical unit. Therefore,
we request that if Alternatives A, 3 or C are considered, that prior to
issuing the Final Three Rivers Resource Management Plan and Environmental
Impact Statement, a 'Takings Implication Assessment* be completed as
authorized by Executive Order 12630 (see the November 8, 1988 Memorandum
to all Assistant Secretaries and Bureau Directors from Secretary of
Interior, Donald P. Hodel ) .
The reallocati
and/or reducti
property by approximately S
Please consider this economic loss in
Assessment. "
AUM's livestock forage
Allotment will reduce the value of our base
(Assume B50 per AUM value).
? requested "Takings Implication
The letters from the Harney County CattleWomen, Stockgrowers, Farm Bureau
Sheep A Woolgrowers and the January 17, 1930 Riddle Ranch and Western
Range Service Comments and Response to the Draft Three Rivers Resource
Management Plan and Environmental Impact Statement are consistent with ou
views and i
This response is our endorsement of such letters and Riddle Ranch
document. Their response has been submitted to you. We do not include
full copy of text only for the reason that it vould be an exact
duplication of the Riddle Ranch document and organizations letters.
Any additional comments we may have are enclosed herein and are
supplemental to our principal response.
Name!
i_,,,,-J?-'
'V*. A'A, (U.
MAJ, tf„sJ>s>
UU£.
&*+
sJ^^st^tS
£,0
\. £-.lfccJL-rv~
Enclosure: Supplemental Comments
Appendix 11-200
£JEWU UP WLDHINESJ W£KST«ai4 jf.'
FISHING
AND HUNTING PACK TRIPS
HOURLY
L AND DAILY HORSEBACK RIOE5
«- ' February 22, 1990 **■ —
217-1 Refer to response 210-1.
217-2 Refer to response 124-4.
[soa) 411*4143
Bureau of Land Management
Burns District Dffice
Attn: Crslg M. HBnsen
HC 7<*-12533 Highway 20 WeBt
Mines, Oregon 9773B
uear Sirs,
Alternative A (EMPHASIZE NQTURAL VALUES) is my choice
with some alteration. However, i would like to see the follow-
ing concsrns incorporated in what ever plan you choose as
the Final Plan.
Table 2.1 page 12, WILD HORSES and tiURROS:
Under #U delete one word on line two, word three,
(ADQPTASLE).
There is concern in our Organization that this could' be
lntarpeted to mean take out thE best horses for adaption
and turn all unadoptBble horses back on the range.
The FJ.L.M. has done an excellent job mgnaginp all of
ths Wild Horses on the Burns Oistrict. They have done a
Super job in their selection of horses put back on the
ranae for the Kigar Herd.
After deletinc IROOPTaBlE) in k'k. line two, word 3,
it would read (EACH H.M.A. LULL BE liUENSIUELV MANAGED
FOR QUALITY HORSES).
This assures us that as new Leadership takes over in
the future- in the Burns District Office of the 0.L.M.,
the Manaoino Aqent and other people in charge of the Wild
Horse program, will put Quality horses Pack on the range to
reproduce.
[503) 433- 4145
If Quality horses are put back on tha range, the horses
WILL always bo gdoptable because thg breeding stock will be
top guallty. If peer quality horses are turned out to reproduce,
it will not be a lonp time until most of the horses gathered
will be unadaptable.
Iiie of the K.M.A. would like ta feel assured that plans for
the future will be positive in continuing a quality horse program
and have this in the manaoement plan so that it cannot be changed
without public input.
Once aqain, We are very happy with the job that Josh UJarburton
and Ron Harding have done with their Uild Horse Program on the
Sums District. It could and should serve as a Pilot Procram for
all the Wild Horse Management Programs in the west.
Since Wild Horse Sanctuarys are beinq phased cut, I would like
to see castration on all undesireable male horses turned back on
the rsnae. This would halp to keep the quality in the herds
and assure everyone of the quality of adoptable horses in the
future. This is hy far the cheapest method of control of the
undesireables that I know of.
As a person who Drew i
mast important parte of my
I am very interested in yot
farmed with horses, and wer
waopn to social functions,
about 100 horses snd mules
all of this, I feel that T
horses.
ip with hnrses being one of the
life from childhood to the present
r programs, We rode horses to school,
t on horseback and with team and
My wife and I presently maintain
in our current business. Because of
can speak with some authority on
1 sincerely hope that as people retire and new people take
over the Horse Program that you as a Managing Agency will realize
that 3 Horse nronram is unique. A person managinq a horse program
must have an eye for horses as well as some on hands experience,
people with ths ability to recoqnize qualities in animals are
born with that ability thg same as musicians and artists are bom
with their talent. Formal Education helps but is not the mnin
ability.
Thank you for the chance to share my views and concerns
with ?oency. We look forward to a Great future.
Sincerely,
Manford/ialay .
c
Appendix 11-201
218
rjfL/L'fijIt.
MQ fV- / 3.3 33
<Z
218-1 Refer to responses 2-68 and 8-11.
tJL,'u+> O^u
T"
977-5S-
.May. . /
dLA&^ru^ y-t^J .rStflz^c-- s^*s o-tA-Lj^ J^J^/aL si^Li^i^s
Appendix li-202
United States Department of the Interior 219
FISH AND WILDLIFE SERVICE
Malheur National Wildlife Refuge
Princeton, OR 97721
(503/493-2612)
The recommended changes have been made, see PRMP/FEIS Haps SS-1 and
WL-1.
February 16, 1990
Bureau of Land Managanent
Burns District Office
EC 74 - 12533 Highway 20 West
Hines, Oregon 97738
The refuge staff has reviewed the Draft Three Rivers Resource Management Plan
and Environmental Impact Statement, and we appreciated the briefing provided
at our headquarters by Jay Carlson and his team.
Our specific biological Comments address nesting habitat for snowy plover and
long-billed curlews and winter range for mule deer near Malheur Refuge.
Please refer to the attached maps, SS-1 and WL-1 for our additions to your
identified areas.
Our general comment is that your staff has compiled a tremendous amount of
pertinent information fur use in addressing the irtirifjgerrient objectives in each
of five Alternatives. We especially like your method of portraying and
summarizing this information in Table 2.1. Regardless of the alternative or
combination of alternatives chosnn, a clear management direction is stated.
Our compliments to you on a comprehensive and useful product.
As sister Interior agencies, we share mandates and directives to manage some
resource objectives like air and water quality, vegetation, wetland and
riparian habitat, cultural resources and raptors. We are also mandated to
place a different level of emphasis on uses such as grazing and wild horses.
Regardless of the final path you choose, let us just offer to you that our
staff stands ready to work with yours in facing our common challenges and
opportunities.
Congratulations on a good product;
TuTest W. Cameron
Refuge Manager
QUARTER MOON CATTLE CO.
P.O. BOX 43 • RILEY, OR 97758
220
220-1 Refer to response 2-11.
February 20, 19<?C
Cody Hansen
Burns District 0-F-fice
Bureau of Land Manaqement
HC 74 12533 Hwy 20"west
Hines. OR 97738
Dear hY. Hansen:
In regards to the 1989 BLri draft Three Rivers RMP/EIS and specifically
the Sheep Lake/Shields allotment, I agree that some reduction of AUM's
may be necessary to improve the range condition on the entire allotment.
It is my belief that the Shields and lower Sheep Lake pastures are in
good condition and were only used S0-40X of the full carrying capacity.
Due to the severe drout conditions during the grazing seasons of 1997 &
1988 and lack of stock water on Shields and lower Sheep Lake pastures,
I'm of the opinion that out of necessity, due to the drout, the upper
Sheep Lake pasture was overgrazed. I believe that short term grazing on
Shields and lower Sheep Lake, pastures, removing all cattle from the permit
during the crucial. growing period (June 5th - July 5th) and furnishing a .full
time range rider will afford us the opportunity to more fully utilize
both of these pastures while giving the upper Sheep Lake pasture a rest.
We may or may not have a problem regarding stock water but are prepared
to haul water as needed specifically the Shields pasture.
I feel that with proper management and some water source improvements the
proposed fiUM reduction may not be needed.
In closing. I strongly believe that & 3 year study period is not adequate
to make the assessement and decision necessary to set the AUM's for this
allotment. May I remind you that 2 of the 5 years of this study were
under extreme drout conditions and would probably not reflect the range
conditions of this allotment over a ten year period.
cct Jay Carlson
Teresa F;amasco
Helen Cow«n
William Cramer
Appendix 11-203
American cRjvers
February 1, 1990
Craig M. Hansen, Area Manager
Three Rivers Resource Area
Burns District office
Bureau of Land Management
HC 74-12533 Hwy 20 West
Hines, Oregon 97738
Re: Draft Three Rivers Resource Management Plan
Dear Mr. Hansen:
Introductory Comments
American Rivers is a national, public interest not-for-profit
corporation with more than 12,000 members nationwide. American
Rivers is the only national conservation organization dedicated
exclusively to the preservation of free-flowing rivers. In our
sixteen-year history, American Rivers has worked intensively to
protect rivers under the federal Wild and Scenic Rivers Act and
has actively assisted states and local groups with their river
conservation efforts.
American Rivers has worked extensively with federal agencies in
planning for the river resources on the lands they administer.
We have assisted the planning staff of the Bureau of Land
Management ("BLM") in Washington to clarify administrative
direction for consideration of potential wild and scenic rivers
in BLM's resource management planning, and have reviewed, com-
mented on, and protested numerous BLM plans. We have worked
similarly with the U.S. Forest Service in developing admin-
istrative direction for the evaluation and management of
potential wild and scenic rivers on the National Forests, and
reviewed, commented on, and appealed numerous land and resource
management plans issued by that agency.
Section 5(d) of the Wild and Scenic Rivers Act, 16 U.S.C. section
1271 et seo. , requires all federal agencies to consider potential
national wild, scenic and recreational river areas in all plan-
ning for the use and development of water and related land
resources. 16 U.S.C. section 1276(d). The planning responsi-
bility imposed by section 5(d) plainly requires the BLM to assess
the values of potential wild and Scenic Rivers during the prep-
aration of resource management plans pursuant to the FLPMA.
Recognizing that responsibility, BLM Manual Section 1623.41A2d
801 PENNSYLVANIA AVE.. SE
Mr. Craig Hansen
February 1, 1990
Page 3
In order to protect the resource values and character of its
potential wild and scenic rivers until a decision is reached
regarding their designation, BLM's Guidelines require agency
planners to establish detailed management prescriptions. The
Guidelines state: "[T]he RMP must prescribe the protection
(interim management prescriptions) to be provided for the river
and adjacent public land area pending the suitability and, when
necessary, subsequent action by the Congress." Guidelines,
Section VIII. A. 3. a., at p. ll.
Specific Comments
1. Eligibility
American Rivers commends the Three Rivers planners for evaluating
rivers not listed on the Nationwide Rivers Inventory (NRI) . See
Appendix 11. A failing common to other plans is an examination
of rivers only on the NRI.
Unfortunately, the Draft RMP provides very little information
which supports the planners' conclusions that numerous streams
are not eligible. E.g. . RMP at 3-41, Table 3.15; Appendix 11,
Table 1. For example, is the entire 68 mile length of "segment
B" of the Silvies River so impacted by diversions and channeli-
zation that it is not free-flowing? Similarly, there is no
information within the Draft which enables a reviewer to evaluate
the conclusions that certain segments of the Middle Fork and
South Fork Malheur Rivers do not possess outstandingly remarkable
values. E.g. , RMP at 3-41, Table 3.15. American Rivers believes
the Final RMP should document the facts which led to these
particular conclusions.
Further, there is no indication that other streams which flow
across the Three Rivers Resource Area were evaluated for their
potential inclusion in the national rivers system. Appendix 6
identifies numerous streams within the Resource Area which pos-
sess aquatic habitat. While the presence or absence of aquatic
habitat does not determine the eligibility of a river, it is one
of the only sources of data within the Plan which identifies
free-flowing streams. Further, areas which support aquatic
habitat in the arid lands east of the Cascades provide critical
wildlife habitat and may well serve as an indicator of out-
standing ecological and fish and wildlife values. Additional
candidate rivers may be found among those areas nominated by the
planning team for ACEC consideration, including Silver Creek and
Squaw Creek. See Appendix 7.
Mr. Craig Hansen
February 1, 1990
Page 2
Mr. Craig Hansen
February 1 , 1990
Page 4
identifies wild and scenic river recommendations as a possible
determination to be made in such plans.
To provide further guidance for fulfilling BLM's planning
responsibilities for potential wild and scenic rivers, the
agency's Washington office on July 23, 1987 circulated
Instruction Memorandum No. 87-615, containing draft guidelines
for identifying, evaluating, and protecting potential wild and
scenic rivers on BLM lands. That guidance was promulgated by the
Director in final form in Instruction Memorandum No. 87-670 and
the attached Guidelines for Fulfilling Requirements of the Wild
and Scenic Rivers Act (the "Guidelines") , issued September 8,
1988.
Under the directions established in the Guidelines, planning for
potential wild and scenic rivers on BLM lands follows a rela-
tively straightforward, three-step procedure. Each BLM resource
management plan is to:
(1) evaluate the eligibility of potential wild and scenic
rivers within its planning area for inclusion in the
National wild and Scenic Rivers System in accordance
with the criteria set forth in Section 1(b) of the Wild
and Scenic Rivers Act (i.e., whether the river is free-
flowing and possesses one or more "outstandingly
remarkable" values) ;
(2) determine the appropriate classification ("wild,"
"scenic," or "recreational") for rivers found to be
eligible;
(3) assess the suitability of such rivers for inclusion in
the national rivers system, based upon the public
values and uses that would be enhanced or foreclosed by
such protection, the degree of public, state and local
interest in designation, and practical concerns
regarding costs and feasibility of administration.
Guidelines, Section VIII, at 9-12. Until a final decision is
reached by the agency and, for recommended rivers, by congress,
BLM is to protect river resource values and characteristics
through specific management prescriptions established in more
detailed recreation area management plans or project plans.
Guidelines, Section IV. C. , at p. 7, Section IX, at p. 20. As a
substantive decision regarding the appropriate management of a
sensitive area, the planners' decision regarding suitability must
be accompanied by environmental analysis pursuant to the National
Environmental Policy Act ("NEPA") . Guidelines, Section VIII. B.
at p. 15-16.
. 14 which
ible. See
The planners must undertake a serious evaluation of the free-
flowing streams in the resource area to determine whether they
possess one or more outstandingly remarkable values that might
qualify them for inclusion in the national rivers system. The
failure of the Three Rivers planners to consider all of the
area's streams exposes those with high values that may be eli-
gible for inclusion in the wild and scenic rivers system to
development that can significantly degrade their values and to
damming or diversion that could disqualify them for future
cons ideration .
American Rivers suggests that assessment of other rivers, streams
and creeks, including tributaries and headwaters, within the
Three Rivers Resource Area will result in the identification of
other rivers, streams and creeks eligible for inclusion in the
national wild and scenic rivers system.
The Final RMP should expand Appendix 11 and include a separate
identifiable assessment of the various streams and their values
examined by the planners.
The Final RMP should also correct the error in Table
indicates "segment A" of the Malheur River is not eli
RMP at 3-40.
2. River corridors
The RMP states that the proposed boundaries of the corridor for
the Middle Fork of the Malheur and Bluebucket Creek are "gener-
ally one-quarter of a mile on either side of the mean high water
level of the river and creek ... [and] follow the rim of the
canyon..." RMP at 3-41. However, an examination of the refer-
enced Map WSR-2 indicates that the boundary does not always
follow the rim of the canyon. American Rivers suggests that the
RMP state that the boundary is cne-quarter mile on each side of
the river or the rim of the canyon, whichever is greater.
The RMP fails to identify the particular width of the river
corridors used to study whether particular streams meet the
eligibility standards set forth in the Wild and Scenic Rivers
Act, i.e. , one-quarter mile on each side of the stream or larger
if necessary to protect outstandingly remarkable values.
Failure to identify the width of the study corridor may seriously
prejudice both the initial eligibility determinations for streams
within the Resource Area and BLM's future evaluation of their
suitability for designation. Eligibility determinations are
required to reflect the resource values of the stream itself and
the lands within the study boundary; arbitrarily narrowing, or
Appendix 11-204
Mr. Craig Hansen
February 1, 1990
Page 5
even ignoring, the required corridor of streamside lands may
exclude resource values that should be evaluated together with
the values of the stream itself.
3. Classification
American Rivers agrees that an appropriate classification of the
5.4 segment of the Middle Fork Malheur River and Bluebucket Creek
is wild. See RMP at 4-41.
4. Management standards
American Rivers commends the Three Rivers planners for setting
forth in the Draft RMP detailed management prescriptions for
potential wild and scenic rivers. See Appendix 11. Certain
other RMPs have failed to include such prescriptions. The man-
agement prescriptions set forth in the Three Rivers RMP are
consistent with the BLM Guidelines and will provide appropriate
guidance to BLM and the public of those actions that are
appropriate within the relevant river corridor. E.g. ,
Guidelines, Section VIII. A. 3. a., at p. LI.
Unfortunately, the RMP includes other language which confuses the
relevant prescriptions. For example, the RMP states that there
is a timber harvest prohibition within "perennial streams." RMP
at 4-41. The appropriate standard, as is set forth in Appendix
11, prohibits timber harvest within the relevant stream corridor.
Further, the RMP improperly suggests that such a prohibition
would not apply to an intermittent portion of an eligible stream.
Id.. American Rivers suggests that appropriate changes be made to
the discussion of wild and scenic rivers found at RMP 4-41.
5. Interagency agreements
American Rivers recommends that the Three Rivers planners enter
into an agreement with the ochoco National Forest (or other
relevant federal or state agencies) to study rivers which flow
across lands administered by both agencies, particularly Silver
Creek .
6. Comments concerning Appendix 11
We understand that "Table 2" affirmatively finds "segment A" of
the Middle Fork Malheur River and Bluebucket Creek to be suitable
for designation. See also RMP at 3-41. However, there are
statements within the discussion of suitability that suggest the
BLM has not yet made a suitability determination. For example,
there are contradictory statements that BLM does have the ability
221-1
221-2
221-3
221-4
221-5
221-6
221-7
221-9
221-10
Refer to Tables 2.17, 2.18 and 2.19, PRMP/FEIS.
Refer to responses 206-17 and 206-19.
Refer to responses 3-6 and 206-19.
Refer to responses 3-6 and 206-19.
Refer to response 3-6. Additional Information has been inserted. See
Tables 2.17 through 2.21, PRMP/FEIS.
Table 3.14 has been corrected. Refer to Table 2.18, PRMP/FEIS.
The PRMP/FEIS has been changed to state that the proposed boundaries
will follow the rim of the canyon and may be greater or less than
one-quarter mile from mean high water level of the river and creek.
Refer to footnotes in Table 2.20 and the narrative in the PRMP/FEIS
which describes the proposed river corridor boundaries.
Refer to response 221-8.
The Impact analysis of Wild and Scenic Rivers in the PRMP/FEIS notes
prohibition of timber harvest in the stream corridor.
The Burns District is coordinating with the Ochoco National Forest to
complete a Wild and Scenic Rivers Inventory of Silver Creek. If the
analysis results in suitability of the BLM-administered segment,
cooperation will be continued to ensure the creek Is given
consideration.
Table 2.18, PRMP/FEIS has been changed to indicate that the BLM
considers Segment A of the Middle Fork of the Malheur River and
Bluebucket Creek to be suitable for designation. The information in
Tables 2.17-2.20, PRMP/FEIS substantiates the suitability of this
river segment.
The BLM portion of Segment A of the Middle Fork of the Malheur River
meets the suitability criteria when evaluated along with the entire
USDA-FS segment and the private segment. Bureau guidelines for
fulfilling the requirements of the Wild and Scenic Rivers Act states
"Historical or existing rights which would be adversely affected as
to foreclose, extinguish, curtail, Infringe, or constitute a taking
which would entitle the owner to just compensation If the area were
included in the National Wild and Scenic Rivers System. In the
suitability analysis, adequate consideration will be given to rights
held by owners, applicants, lessees, or claimants."
Mr. Craig Hansen
February 1, 1990
Page 6
to manage the river segment but also that it is not feasible for
BLM to manage its land under wild and scenic designation. See
Appendix 11-6. The planners are flatly wrong to suggest that
acquisition of private lands is necessary for designation: there
are numerous rivers designated by Congress and managed by federal
agencies, including BLM, which include segments of private land.
221-13 I Confusion over whether the RMP finds "segment A" to be suitable
I is fueled also by the statement "[i]n the suitability analysis,
I adequate consideration will be given to rights held by owners
| ..." See Appendix 11-6 — 11-7.
We trust the Final RMP will be clear with respect to this
important issue .
We trust these comments are helpful during the Resource
Management Plan process. We look forward to participating
further in the RMP process. If you have any questions concerning
any of the matters set forth above, please do not hesitate to
communicate with me.
Thomas
Public
cc: Gary Marsh
Appendix 11-205
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222
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Appendix 11-206
5)
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222-1 Refer to responses 2-44, 3-13, 6-3 and 6-4.
222-2 Refer to response 1-23.
222-3 Appendix 5, Table 2, DRMP/DEIS lists riparian conditions while
Appendix 6, Table 1 shows the aquatic habitat conditions. These
conditions, while interrelated, are not always the same. Criteria for
aquatic habitat rating are listed In Appendix 6, Table'2, DRMP/DEIS
and riparian Inventory and condition rating system Is explained in
Appendix 1, Table 4.
222-4 Riparian habitat in upper Silver Creek is listed in DRMP/DEIS
Appendix 5, Table 2 as static trend In good condition. Riparian
values are high in this section of the stream.
222-6 In DRMP/DEIS Appendix 7, Table 2, the referenced site description for
the "Silver Creek RNA/ACEC and Addition" mentions trespass grazing in
a manner that does not clearly and appropriately associate such
livestock trespass with only those public lands in Section 8, T. 21
S., R. 26 E. This Is the existing RNA where no grazing use Is allowed
and an exclusion fence is In place. The public lands In Section 20,
which are licensed for livestock use, are not known to have problems
with trespass grazing, as was implied by the draft narrative. The
privately-owned Section 17 is not subject to Bureau regulations, as
may have been inferred.
222-7 The "prudent investor" test la based on gaining a positive return on
an Investment over the life of a project regardless of the source of
the investment.
222-8 Neither Alternative D or E propose reductions In grazing AUMs from
current active preference. Alternative C proposes short-term
reductions that could be off-set in the long-term with vegetative
treatments. Not all allotments will need reductions to balance
stocking levels with carrying capacity. Please refer to Appendix 3,
Table 6, DRMP/DEIS.
222-9 Refer to response 2-87. The Claw Creek Allotment evaluation was
completed In 1989. As a permittee, you should have received a copy.
If not, please contact our office. This evaluation outlines the
results of monitoring. The Riley RPS Update of December 1986,
classified Upper Valley as a C (custodial) category allotment. As
such, an evaluation has not been completed. The Upper Valley is
categorized as an M (maintain) category allotment in the PRMP/FEIS
and an evaluation, based on utilization and climate, will be
completed when there are at least 3 years of actual use.
Q
^*£*C*oQ-J^^ ULJzjUiajzJl -<cs>i-^-L>lL'±s{- -0/
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Appendix 11-207
January 30 , 197-0
Bureau of Land tlanagement
Burns District Office
Att,. Joshua Ii. '..srbv.rton
HC 74-12533 Hv:y 20 rest
Kines, Oregon f.'773f
223
Mr.
.arburtor.'
I am concErp.ee! about the emphasis given ACEC ' s , HMA'e, VRM's
and other special emphasis areas v;hich apparently ignore proper
resource management in the Draft — Three Rivers Management Plan.
The grazing reductions appear to be unreasonable vithout good
monitoring and without evaluating progressive management alternatives
I feel t":.e P.KP is very damaging to Harney County's economy
which is already depressed. Since 1504 the local economy has been
dependent ujpor. rare) irig and governmental expenditures. Grazing
and timber reductions uill 30verelv impact individual ranches and
the local area.
E;:porie:>cec" EL:: range perscnel are better able to achieve
multiple use objectives than administrative area plans. Range
con's work, with livestock permittees for the betterment of the
range, v.-atershed and wildlife. Good working relationships and
flexibility to adapt to changing conditions are important in
achieving the best possible multiple-use management .and the RHP
does neither.
The RMP discriminates against livestock grazing in almost
every section and this is very damaging to the livestock industry
in terms of our image with the public. The bias is not based
upon biological and scientific principals including the watershed
sections and the description of alternatives A-E. Intensive
management uses available technology to benefi-t and manage all
resources and doos not have a commodity influence or emphasis.
When sagebrush and juniper take over a plant community due
to fire suppression, recent research has shown that a negative
impact tc t) e vatershed occurs. Precipitation interception
evaporation and direct competition with plants beneficial to'
protecting to soil from erosion are negative impacts from juniper.
One large Junipor tree will use 100 gallons of water per day which
1! JJ8 .?,. y lnPa"inu- upland equifers and springs in many parts
of the RMA. If lumpers arc al loved to increase, our watershed
uill get drier and drier. The RH>. should have taken a more in
depth ana realistic, evaluation of the juniper problem especially
when one looks at the number o:T lie. seedlings.
The evaluation of range condition and trend is obviously
biased towrds other uses. The RHP allocation of uses
is ignoring good land management practices and is failing to properlv
evaluate long terr needs of multiple use. f p •
sll^tiL?0531"0' S"»m™I*V »Vlotmanti should be split into separate
allotments and no way should an individual permittee be put in
someone elses allotment. Further, a permit?., should no? have
to alio ; someone to be moved into his allotment. Spread of disease
"rS"S™?rfiJ;'=^1ar °t!;0r e=°n™i!: ^"s «• "• result? '
good vear fa U "'J '11°tnen' !E,'» »«* <K>°d condition and on a
sM'^sfivra^ st *• r,ot jair to ,,ave an°tter
A coc.-.Mnatior of management practices and changes in the timing
223-1 Allotment boundaries may be adjusted after consultation, cooperation
and coordination with permittees or lessees and the authorized
office. Procedures for apportionment of permanently-available forage
are specifically spelled out by regulation and policy. Please refer
to response 2-17.
223-2 Refer to responses 2-63 and 8-8.
223-3 Refer to responses 8-9, 8-11 and 11-11.
flawed ar.d
and duration
than does n::-
other irotXar.cl area
in everyone':? best
conditions and r.\i.
c ta:' better solve problems and conflicts
i: of gra:.ii,g (e.g. streams, reservoirs and
). Developing a RMS with flexibility is
interest so 7-H? ' s can adapt to changing
ate.
The govcrnnct shorld not purchase any private land but land
exchanges ci::o 'sona^icial he lor.g as both parties are satisfied.
My f ct: or zi-iC i.T I trade tl o beet I orse 1 own for a pocket knife
with broker, blado.-; and bot; of us are satisfied then it was a
good. trfltfOi
T',-e Diamond Craters ratur&l Area (DCHA) should not be
expanded. The eig; ty acre niece of land by Oliver Springs is
an. important part of my bv.siness (see my letter dated 1/21/1990)
and the exclusion of use represents a takings of personal property.
The historical use and ir/provenents (water developments, wells,
fences, atSifTzy&V&a , branding corral and roads) prevents it from
nesting nntv.rnl araa criteria. In addition, this piece of ground
d'.:e to location and I'se is iwpoictant in the future for limiting
the size a.-.c". directing a wildfire originating in tbe Refuge
in the DC::."'. Both r-roas : avc a large build up of fine fuel
or
di:e
ecrea^e
tc nonrcr.. Srar.in^ shovld be in13ler.1cr.ted in the DCNA to
fire potcmtiel,
IJWA'O choi Id not be expanded in the RMA and numbers should
be kept below presently established maximum numbers. I feel
select -.-ilt". It-rso brooding ~>-<-r :-ans are illegal and conpetes wit
private enterprise. The Kigo:: r.-stang (so called Spanish barb)
should not . ava beftii coved tc t' e area above Diamond. I do not
believe K ore horsac are genetically spaniel, barbs but escaped
wild crOBS?.vrod sr&nflj. :.<-:rsas. T? oy should not be advertised as
something ;-.:■ cy ■ --.a -r^t until it is nroven aeneticall" by an
independent nzzT.r.r^' enenrn.
In SiLir-E-y, I feel the IttIP does not adequately meet the
biological r.i-d n-mcuical noods of t**a ;.rea and that technical
aOKiri©iw:s.oi; ■■■.::■■: t'-.e long term management potentials of all
resources. If ; 01' ', ave any questions please give me a call. ■
I^ayne Orsley
Swamp Creek Ranch
Diamond, Or G7722
(503) 4C3-24G3
3©b -- :. c
Eacrctr-
Crc-.,-.. ::
dM.
oy*-c aMaaM-
Appendix 11-208
224
CHUICAR
Post Office Box 651 4
Boise, Idaho 83707
(208)345-7511 (208)939-8731
Issue 6
District Manager
1/31/90
Mr. Joshua L. Warburton,
Burns District BLM
HC 74-12533 Hwy 20 West
Hines, OR 97738
Dear Mr. Warburton:
The following comments identify issues and related information needs integral
to the Three Rivers Draft Rmp and EIS.
The current condition and trend of resources within the Three Rivers RA:
Water Quality (Stream Miles)- 81% poor or fair
(Surface Acres)- 99% poor or fair
Livestock Forage (Acres)- 64% poor or fair
Deer Summer & Winter Range (Acres)- 42% unsatisfactory
Elk Summer & Winter Range (Acres)- 16% unsatisfactory
Streamside Riparian Habitat (Acres)- 78% poor or fair
Aquatic Habitat (Stream Miles)- 88% poor or fair
western Sage Grouse- Federal Candidate species threatened or endangered
does not present a balanced picture of past managements efforts. For the
public to fully appreciate the condition of the resource you need to list the
baseline levels when existing plans were implemented; earlier plans; initial
base property adjudication; and more recent adjudications.
Issue 1
Numerous existing planning documents (Drewsey MFP; Riley MFP and the Silvies
portion of the John Day RMP) contain objectives and reconmenda tions for
managentent of resources within the Three Rivers RA. You note in planning
issues, under Grazing Management, that "grazing management practices
prescribed in preceding land use plans have not been fully implemented and it
now appears that they cannot be implemented within a reasonable timeframe."
In order for the public to effectively evaluate proposed alternatives advanced
in the present planning effort, it is necessary to know which past objectives
have been met and which past recommendations have been implemented, which have
not, and why not.
A Cost Benefit analysis needs to be included for all range improvements, by
allotment within the RA for the last 20 years. Benefits to wildlife as well
as livestock need to be broken out. The environmental costs, e.g., soil
erosion, wildlife displacement, loss of vegetation diversity, need to be noted
and factored into the analysis. A Cost Benefit analysis needs to be included
for planned range improvements within the different alternatives. Staff
informs me that economic considerations were not included in the draft plan
text because they were not raised as issues during scoping. This was an
oversight on the Bureau's part. Creative new approaches to how we spend
scarce dollars may be necessary if we are to get the economic asset ( the
land) back into full productivity. The public cannot evaluate the draft
without costs and benefits being analyzed.
Issue 7
Livestock forage produced within the resource area is economically important
to individuals and communities. The social and economic information in
past planning efforts should be updated and expanded to include perspective
on: (1) the extent to which permittees run their own livestock, or run
livestock owned by others, and the amount of subleasing of permits; (2) the
dollar value of the public land forage and its relative importance to each
permittee; (3) the collateral and sale value of each permittee's permit; (4)
the relative economic importance of Three River RA forage/permits to local
communities.
NEPA case law requires an evaluation of social and economic implications for
major federal actions. The Bureau cannot proceed with this draft until this
information is included. See 40 CFR1508.14.
We appreciate the opportunity to comment on this draft. We are willing to
help and are prepared to work with the Bureau to develop creative ways of
preserving and restoring economic viability to the resource area.
Edward I. Robertson Jr.
"Dedicated to improving habitat for chukars and other wildlife on sagebrush grasslands"
Issue 2
There has been a significant investment of public funds in the Three Rivers
RA. The present planning process will guide future investments. In order for
the public to evaluate proposed future investment strategies the following
information needs to be included in the draft: Total investment in the Burns
District and portions of other BLM districts and USFS Ranger Districts that
are contiguous for the past 20 years, broken out by resource area and by major
budget category (e.g., range improvements, fish and wildlife, etc.); total
grazing receipts from grazing fees by resource area. For the Three Rivers RA
this information should be broken down by allotment.
Issue 3
The suitability or nonsuitability of lands for domestic livestock grazing has
an important bearing on the planning process. These areas should be mapped
and accompanied by information explaining the bases for the determination of
suitability or unsuitability. The approximate percentage of each category
within each allotment should be estimated.
Issue 4
while this planning effort focuses on the Three Rivers RA, decisions on
allocation of resources necessarily must be made within the broader context of
the Burns, Vale and Lakeview Districts. In addition, the potential
availability or nonavailability of forage outside the Three Rivers RA might
significantly influence management decisions within the RA. For each RA
within the contiguous districts, you need to have the following information:
(1) The carrying capacity and number of AUMs determined by the initial
adjudication; (2) the carrying capacity and number of AUMs determined by the
readjudication (circa 195Ds-60s); (3) any reductions in licensed AUMs
resultinq from the readjudication; (4) current carrying capacity, licensed
AUMs and actual use; (5) Suspended nonuse, why and how long this status has
been in effect; (6) amount of temporary use, why and how long this status has
been in effect.
Issue 5
The Three Rivers RA generally is in a condition far below its ecological
potential. To effectively evaluate future management and investment
strategies it is essential for the public to have a perspective on: (a) the
opportunity cost of livestock forage forgone (i.e., the difference between
current and potential forage- expressed in AUMs and dollar value; (b) the
generalized effects on fish, wildlife, water quantity and quality, soil
erosion rates, riparian areas, and overall watershed conditions.
224-1 The baseline levels utilized in the DRMP/DEIS are those which were in
effect at the initiation of the RMP process. As such, they represent
the results of the degree to which previous planning has been
implemented. Presentation of baseline data In this manner is standard
procedure for RMPs.
224-2 Past planning efforts, especially the Riley MFP, assumed that there
would be substantial increases in funding of rangeland treatments and
facilities in order to meet management objectives. This was the case
with the Drewsey MFP where approximately $1 million were invested In
a variety of projects over a 5-year period following the completion
of the MFP. However, such expanded funding support for the Riley MFP
and the Silvies portion of the John Day RMP has not been realized.
Because the plans are so heavily dependent on large scale Investment,
other conflict resolution options cannot be pursued without
significant modification of the existing plans.
While an assessment of each objective in each of the three existing
plans has not been performed, the reader can get an idea of which
resource objectives have not been met through an examination of the
Identified Resource Conflicts/Concerns sections in Appendix 1, Table
9 of the Proposed Plan. The ID team has developed this format
specifically to avoid the funding dependency shortcomings of the
previous plans. Within the context of the overall RMP, Appendix 1,
Table 9 provides allotment-specific guidance for the resolution of
resource conflicts or concerns which can utilize Intensive investment
If available, but also provides guidance for management where such
funding is not available.
224-3 Refer to responses 11-10 and 116-1. See also the DRMP/DEIS page 3-16.
Grazing fees are set prior to the grazing year, which begins March 1,
according to a formula established by Congress. Grazing fees have
varied from $0.44 in 1970 to $2.36 in 1980. The grazing fee for 1990
was $1.81. An estimate of grazing fees received in the RA may be
derived by multiplying the grazing fee with the average actual use.
For example:
149,307 AUMs (average actual use) x $1.8l/AUM (1990 grazing fee) -
$270,245.67 in total grazing receipts. These receipts are disbursed
as follows:
$101,342.13 37.52 to U.S. Treasury
$135,122.83 50.0% to Burns District via Range Betterment Fund
$ 33,780.71 12.5% to Harney County via State of Oregon
$270,245.67 Total
The amount of investment made in adjoining BLM and USDA-FS districts
Is available by request from the appropriate agency office.
Appendix 11-209
The information requested is beyond the scope of the RMP. The
planning process is designed to identify existing land use or
management problems/opportunities on Bureau-administered lands within
the planning area and then to consider a range alternative for
resolving the problems and realizing the opportunities. Investment of
public funds is dictated through a vast array of Federal law and
effected through annual Congressional appropriations to BLM and other
Federal agencies. Such Investment is focussed through the
implementation of the RMP on the problems /opportunities identified in
the planning process. While considerable interagency and
lnterdistrlct cooperation is utilized to address management concerns
on a more regional basis, such efforts are usually conducted through
memoranda of understanding, cooperative agreements, interagency
agreements or other similar vehicles. However, the scope of
management prescriptions conveyed through the RMP Is confined to the
planning area.
The wide variation of landforms and vegetation communities found In
the RA makes use of uniform suitability criteria infeasible.
Allotment specific evaluations do address areas which are unusable
for a variety of reasons. At this time, unusable acres have not been
tabulated.
Please refer to DRMP/DEIS page 3-16. The Initial adjudication, circa
1934-5) determined total preference at 169,395 AUMs. Subsequent
read judications, primarily in the 1950's and 1960's, put 18,923 AUMs
Into suspended nonuse and set active preference at 150,472 AUMs.
Additional information on carrying capacity and actual use can be
found in Appendix 1, Table 9 of the Proposed Plan.
Allocations of resources outside the planning area (see Map GEN-1, In
the DRMP/DEIS) are beyond the scope of the RMP and are, therefore,
not addressed in the RMP. Pertinent information on grazing permits is
presented on an allotment by allotment basis in the DRMP/DEIS In
Appendix 3, Table 6 and in the Proposed Plan In Appendix 1, Table 9
for allotments In the planning area.
The discussion on DRMP/DEIS pages 4-10 and 11 evaluates the effects
of range Improvements on forage production. Without range
Improvements, the short-term grazing levels could be expected. An
analysis of the effects of the preferred alternative on all resource
values is discussed in Chapter 4, DRMP/DEIS.
Benefit-cost analyses are performed on a project or system specific
basis at the activity planning level. Overall RMP level benefit-cost
analyses for the various alternatives In the DRMP/DEIS are not
performed due to the lack of project-specific data, mitigations and
interactions necessary for such analyses. Much of this information
becomes available only after consultation, coordination and
cooperation with affected Interests conducted at the activity
planning level.
The extent to which permittees run their own stock or stock owned by
others Is proprietary to the permittees and not available to BLM.
Subleasing of permits is illegal and no cases have been prosecuted in
the Three Rivers RA. As such, no base of information has been
developed. The socioeconomic analysis in the RMP has been revised to
more clearly show the potential community/region socioeconomic
Impacts of the RMP on an economic sector basis. Analysis of Impacts
to Individual permittees Is not performed although Impacts to the
livestock industry are stratified by size of operation (large and
small).
The socioeconomic analysis presented in the Draft has been revised
and Is presented in Chapter 3, Environmental Consequences of the
Proposed Plan and Chapter 4, Revision to the DRMP/DEIS.
225
T! IE AMERICAN ALPINE CLUB
Conservation Comm-lLLm;
11609 S.W. 29th Place
Portland, Oregon 97201
No comment identified.
District Manager, Bureau of Land Management
Mr. Josh Warburton
Burns District Office
Hines, Oregon 97738
Dea
Hr. Uarburti
The American Alpine Club has a deep-seated problem with your proposed
Three Rivers Resource Management Plan. As we interpret the plan, it places
■ coo much emphasis on cows and not enough emphasis on natural resources. When
is BLM going to wake up to the fact that your agency is supposed to husband
public land, and not just to kowtow Co the ranchers?
Nearly all riparian and aquatic habitat is in poi
all of your range Is in the same shape. Your attentioi
animals has been uninspiring.
In managing the Three Rivers area, we belUve that the BLM should:
repair riparian habitats
• eliminate crested wheat grass
get the cows off sensitive lands
• adopt Alternative "A"' which would at least allow some respite fror
overgrazing
The American Alpine Club is committed to following SLM's management
process. We hope our comments will be seriously considered.
Sincerely,
Nicholas A. Dodge
0'
0
o
#
Appendix 11-210
v U.S. GOVERNMENT PRINTING OFFICE: 1991—591-222/41,604 REGION NO. 10
73 1991 v.2
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