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Full text of "Proposed Three Rivers resource management plan : final environmental impact statement"

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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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 Foresters 1 ' Columbia River Section, Water Management Committee 2 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 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 changed 3 ' use riprap, 
vegetative cover or other means to reduce soil movement into stream. 

8. Install culverts at crossings of all drainage ways except small streams 4 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 
crossings 5 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 bars 6 
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 
grade 7 . 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.) 

5 Cull 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 Removal 1 




;..■■, 




Stream Name 


Allot 


Miles 


Acres 


Cond. 


Trend 


Allot. 
No. 


Special Status 
Species 


Claw Creek 


Claw Creek 


2.30 


12.0 


Poor 


Static 


7010 


RB/MS 2 


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 , 
2 RB 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 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: 

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: 

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: 

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: 

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: 

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: 

Total Preference: 1 

Average Actual Use: 1 



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: 

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: 







Deer: 


Suspended Nonuse: 







Elk: 


Total Preference: 







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: 

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: 




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: 




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: 

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: 

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: 

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: 

Total Preference: 1 

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: 

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: 

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: 

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: 

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: 

Suspended Nonuse: 

Total Preference: 

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: 

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: 

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: 

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: 

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: 

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: 

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 
a t least 85 per cent 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 

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: 

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: 

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: 

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: 

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: 

Suspended Nonuse: 

Total Preference: 

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: 

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: 







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: 

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 



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: 

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: 


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 









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: 

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: 

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: 

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: 

Suspended Nonuse: 

Total Preference: 

Average Actual Use: 



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: 

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: 





Deer: 





Suspended Nonuse: 





Elk: 





Total Preference: 





Antelope: 





Average Actual Use: 


24 


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. 

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: 

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: 

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 

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: 

Suspended Nonuse: 

Total Preference: 

Average Actual Use: 



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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

Suspended Nonuse: 

Total Preference: 

Average Actual Use: 



'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: 


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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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 



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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

Total Preference: 176 

Average Actual Use: 



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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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 



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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

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: 

Suspended Nonuse: 

Total Preference: 

'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: 

Suspended Nonuse: 

Total Preference: 

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: 

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: 

Suspended Nonuse: 

Total Preference: 

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: 

Suspended Nonuse: 

Total Preference: 

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: 

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. 

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: 

Suspended Nonuse: 

Total Preference: 

Average Actual Use: 



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: 

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. 

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: 

Suspended Nonuse: 

Total Preference: 

Average Actual Use: 



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: 

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. 



Allotment Name: Silver Creek Valley 
Public Acres: 



40 



Allot. No.: 7087 
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. 

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: 










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 





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 





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 





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 Costs 1 



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 


n 9 


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 


n g 


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 
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 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 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 

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 publ ic 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.;- „ -.. j r - 
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 "■ -o|i 
;AJ Closed Designations r~;fi, 

^|beui whicK^ dosed to off-highway ; 
L!mQtoMfinTclejU8Vcomprise;9^30 'ac resrsj 
"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 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 





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 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 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 *" -iimri J 1fffilBiinfBfc 



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 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 



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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 



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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 l tem 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 I 1 

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, pag es 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 Habit at 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 

?nni S (le -' ?T 25% " 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 f hS ri P ari "" 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 1 1 . 

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-1 1 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. pa g es 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 . pag e 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 C hapter 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 f Map 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 2.1-1 2,13)? 

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 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 Chapt er 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, pag es 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 Chapte r 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). 



ACT UAL 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 u ti lig ation 



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 Oreg on Natura l Heri tag e 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 

.umber 

areas 

real 

natural 



3) Biscuitroot Cultura 
carried forward in the 
undisputed cultural va 
val ues as wel 1 . 
of areas in the Stinki 
that quite met RNA cri 
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 

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*rti B s to thin iafors.or.iorv. tagM-M 
=. 1Q a S -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. Ha ll, 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 . Wa ter 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. Qfzf 1 ^- /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 Managemen t 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, wit hi n the buffer zone, 
thnt can be safely ret a ined, 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 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 

Pla nning 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 A l 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--Wate r Qua lity . , 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 A lisma, 
Elodea, Vallisneria, Naiadaceae, and members of the 
Potainogetonaceae, Juncaceae, Typhaceae, and Cyp er aceae 
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 
Oncorhv nchus (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 t at : 
Knhanc ement (ompha;;i.5 o n fish, the! 



Pi-fit. •■:'- <: i 1 :'!! , !■'•-■ u t ■ 't ■:< t. j o/_!_,. 
h a h i l- a t i riclu dinq water 



quali ty) : 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 
o ccidentalis ) 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. 

Vegetatio n Manip ulation/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 ati onal 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.) 

Wil d ,, 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. 

Vi sual 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 R 8 9 1 1 U " 1 2 ~ 4 Return 



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 . paq e-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 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 P referre d Alternativ e . 

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 Q uality... 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.s t-.i-v .in-.] Woodla nds. 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, r ese rvo i r, 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 p l avas — 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 





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. 

Ge o 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 m inimum 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 -^ - ns - 

One comprehensive and detailed map (1/2" scale) should be provided to show all 
the land allocations together for easy comparison 

Conclusio n 

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 production 1 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, 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. 



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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. 



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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 



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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; ide 1 




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 I 1 



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 wi nter 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**, ~tf t /??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 



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«in e the Final Three RlYers Resource 
Management Plan and EnYironmental Impact Statement, a "takincs 
Implication Assessment" be completed as authorized by ExecutiY. 
Order 12 6 3 0(s.e the Member 8, 1988 Memorandum to all AsSst.nt 

SXjJfcSjT" KreCt " S fr °" ^"^^ * **•**£ 

Sri™"^ 3 f "" J t , 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 Ksna E ement 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 O r ALLOCATIONS FOR BIG GAME FORAGE TN 
T ac, SS *J.tOT*TCTI\S, T U E *W?V IS, PHAT F3PS SAW HAV3 ML? R = a"-'i I"' T H ^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). 

T he reallocatio n— 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 



Si y 



/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 

jfeau^ id. 7ti ^? — ... 




'1 



f fl<5 



MM.W &'■ 

i JAN 2 i 19S0 
BURNS DISTRICT BUM 



dot&b'^u-** zWW« uv^v^> /w>-2?wtvc. &**(' s7n*L£-r\r*Ks7<*~v /L&*y££***-*\ 

y&sr. jtsfi-ttlb^ yr^ZtAs-dt cSkM£^ ' o^t^jL^t ^S~ie-^ s&lLnJLJ -^~ 

tt Js*faA-r<J £otJ- /On^yCP^^J erf ju?. u£jLrT qJ^JJ^^ J «4£ <U^^ 



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?3 R 

Dear Mr. Carlson; 

Enclosed are our comments on the draft Three Rivers Resource Management 
Plan dated October l Qfl 9. 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 G a me 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 excell ent, natural condition. 

Also that BIM adopt Alternative "A", which would allow full 

rangeland, raparian and stream recovery. We insist that 

water quality , r iparian and a qn.il.ii.- h abitat 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 wheat prass 

seeding proposals be eliminated. Wc would like to recommend that 

wildlife winter range forage allocations be given priority over livestock 

allocations ;md demand that Bighor n Shggg Hah icat 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.I0 H) 

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,.aiR c 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 nation 1 , 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 You 1 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 »rp rg1i« 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 



79 7 



Allotment will red\ 
property 6y approximately S Z Of.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 ct ed . 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 /tf gpn TL&U Allotment will reduce the value 

property by approximately $ ■3- L r, £ 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 -2 s3 £ 



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 =nimal r 3 "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 

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 "fes cimJ 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- 



t otes' 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^ 
Uh maAca, 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 







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 ly f 



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 AUfl J *~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 


c 77\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 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 fe jfrgi <. 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 
ATtON 11 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 
ownership 1 ' 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^J r 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^/ ^ ^^ /^ ij e /^ (»„„ ^^ 
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 


■$fth£ &LiV\ 


Qisrrz-Ie-T /v\FiOA-&-eFL 


" 



_ £.&£rrta [ d 'SAJ&- TT^e £/2&Fr T}i 72. /f£ - 



&a/4 <fut/ /e-a>K>n^£ /u Tnt- /A? /°/»g.7-" smrETwfruT , 



X uji<,h 70 B xP/ze ss *r ti Of£ E&*L3. - 



7W£ /3c*i -M?^ a oA/£ a- TSTs-Mtaie J~s/a 



" 



t-thu/X . 77-fF /Sc/*i SF>rs~ ao/vF stAJ 









/H/A T/ m/3tA. /ajAujTG./ ££ 



^TQ/tF g y^wafrf OF 7H-/S . 



/. s ovC 





//#'S iOcHsF coF<F&_ _/f S&Z-S6 (J 5 s*t -»*J 




OF Px.c o-*c./ny 5 cot-r/cH- /^fWfsftur 


& TTLUf S7~£ UJ&79. /D £-tftP &F- 5TV2== i-y4-*-/£ / 


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OF ^-L„r<F*c*J Ar/vFS /S /&Ll"4?-/e.4f**~ttS( i A . 


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F^cc-~ ?=r*frz,^( r ^?v 7?-f ^ ^S C ^7 . 






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. 






6-f- aJ i l, -0 <u / FtF- 



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TH& 



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C//jT"IC. 3<J< H 



mmF- cu-Ht?*-/ T7-f& /3c.A\ 



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 Alte rnative 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_ -J LsAA aiP : 



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 



V2-J 






C^iuA-. _.. ; ^. •_. . ■ jj 



-~^- ■s3o_w-*il>J- _bs_ />^3 /xjuO 



A-WTV05 



TCV- too i2jev~-t>, ciaa- <LUW JLi^^-a— 1^-^iL Wiw— <sl)xi^0i£ 
— rr — r- , m ^_ 









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 '" P r °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-U j 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$? !>rr r .' 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. A CT 
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 C ree k 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 8e T C - 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 i ld "it* ' * th " Ir °° "ounc.in burros. 
..tele..,,. , t hi„ 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 o r „„ 

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* ' 

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 =1 o„ 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 R e soyi .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 adverse