Andrews Comments
Juniper Group Sierra Club Scoping Comments
Andrews Management Unit/Steens Mountain Cooperative Management and Protection Area Resource Managemant Plan and Environmental Impact Statement
April 14, 2002
Attention: Andrews Resource Management Plan
BLM- Burns District Office
HC 74-12533, Highway 20 West
Hines, OR 97738
Fax: (541) 573-4411
The Juniper Group Sierra Club welcomes this opportunity to offer scoping comments on the preparation of a Resource Management Plan (RMP) and Environmental Impact Statement (EIS) for the Andrews Resource Area (ARA) and Steens Mountain Cooperative Management and Protection Area (CMPA). Please accept these comments and place them in the permanent file for the Andrews RMP/EIS. Our members have long held a personal interest in the health of all the ecosystems on the Burns District, where several of our Executive Committee members have spent years on the ground, exploring, working and recreating. Perhaps the most important goal in the preparation of the draft RMP/EIS is that appropriate management alternatives are presented and up for selection, which will allow for meaningful recovery of all BLM lands within the ARA/CMPA.
We support this open process of comment and review by groups such as the Sierra Club, which represent an interested public willing to participate in the exchange of comment and opinion in the interest of seeing that our concerns regarding the management direction expressed in the range of alternatives and the "Preferred Alternative" are addressed. Several members of our Executive Committee attended the March 6th Public Scoping Meeting at the Riverhouse in Bend.
At the scoping meeting, it was suggested that we orient our comments to fit the steps in the BLM planning process which are designed to fulfill the requirements for a land use plan under the Federal Lands Policy and Management Act (FLPMA), the National Environmental Policy Act (NEPA) and the Steens Mountain Cooperative Management and Protection act of 2000 (Act).
In addition to the consideration of the U.S. Government policy mechanisms above, we will base our comments on policy adopted by the Sierra Club. The following is excerpted from the opening paragraphs of the Sierra Club Conservation Policy on Federal Public Lands Grazing:
"The primary goal of this Sierra Club federal public lands grazing policy is to protect and restore native biodiversity and achieve functional and self-sustaining ecosystems. The Sierra Club recognizes that the preponderance of scientific evidence documents that grazing by non-native species has led to severe and sometimes irreversible degradation of native ecosystems. Federal public lands belong to the American public and must be managed to maintain their long-term ecological integrity. In order to achieve our objectives, the Sierra Club advocates significant changes to current land management practices to correct the problem."
Issues to be addressed
As the BLM formulates the issues to be considered, which in turn orients the planning process to the significant resource management problems and land use conflicts in the area to be covered, it is important to take into account the multiple use and sustained yield mandates of FLPMA. The BLM's historical bias towards extractive and/or consumptive resource uses such as livestock grazing and mineral extraction has persisted in the form of one-sided resource management that favors these uses. This has caused a situation where BLM's management objectives lag behind changing societal values, which increasingly place emphasis on the value of healthy ecosystems, including native habitat for wildlife and the existence value of wilderness as well as non-consumptive recreation opportunities.
Range of Alternatives
The BLM must evaluate a reasonable range of alternatives in the DEIS. In past DEIS documents, BLM often states the purposes of the alternatives so they appear to be different, while the management direction for the various resources in is often quite similar. We suggest the BLM offer a comprehensive and reasonable range of alternatives necessary to meet NEPA requirements to evaluate a reasonable range of alternatives. These alternatives must represent a range of management actions, not the usual "all or nothing" approach seen in other DEIS/Draft RMP documents.
Disclosure of current range condition and impact of current management activity
Clear data on range condition should be compiled and listed so that information on the category (I, M or C) is listed along with the dates and results of all allotment inspections. In discussions with Jim Buchanan & Rick Hall at the scoping meeting, they said the range conditions and frequency of allotment evaluations were comparable to what was recently presented in another BLM Draft RMP/EIS document on the Lakeview Resource area on the BLM Lakeview District. When it was pointed out that within the Lakeview Resource Area, the allotments characterized as Category (I) Improve accounted for two-thirds of the total BLM acreage in the Resource Area, they did not seem surprised. We also noted findings based on the information presented in the Lakeview Draft RMP, that on average, each allotment on the Lakeview Resource Area received an evaluation once every 35 years. Unfortunately, this information clearly pointing out the poor overall condition of the scattered tables and charts. This difficulty in deciphering the actual condition of the BLM lands under review seems by design, requiring the reader to bounce from table to table, cross referencing with allotment specific information, just to come up with the total number of acreage that the BLM identifies as being in unsatisfactory condition. The same difficulty is encountered when trying to determine the frequency of allotment evaluations within the past 10 years. We recommend that information and data on range condition and frequency of allotment evaluations be tabulated and displayed for easy review by the public.
It is also important that information relating to the cause of unsatisfactory range condition be identified and presented in planning documents. We often see where the BLM states that problems pertaining to livestock grazing are not related to existing forage allocations. We request the BLM provide whatever evidence and data that pertains to the causes of unsatisfactory range condition. This is an important matter, because the apparent disconnect between unsatisfactory range condition and forage allocation is used to justify continued destructive levels of forage allocation in the face of poor range condition. Many problems from existing over-allocation are well known and well documented. These problems include competition with wildlife, depletion of fire-carrying capacity, soil erosion, noxious weed invasion, and juniper encroachment due to the lack of fire carrying capacity because of overgrazing by livestock.
Need for Objective, numerical standards; Adaptive Management
The draft RMP/EIS must provide meaningful objective, numerical standards for management of rangelands and their associated vegetative and soil resources. NEPA requires that resource management plans inform the public and decision makers how the resources will be managed in the future. Descriptions of these activities are called standards. Standards allow the public to determine whether the proposed management activities are effective, equitable, legal, and non-destructive. FLPMA land use planning also requires defined, actual standards as part of the BLM's program and general management practices.
The concept of adaptive management is usually applied to a majority of acres under recent BLM RMP's within the SEORMP. Although the concept of adaptive management is well accepted among land managers because it provides flexibility and allows management to change as new information is discovered, it should not be substituted for objective descriptions of management activities. The BLM has historically avoided writing true standards by stating that management will be changed if monitoring indicates it necessary.
Adaptive management requires that well developed and statistically valid monitoring programs be in place to identify the positive and negative effects of management. This requires that initial conditions be known and quantified; that a sufficient number of samples be taken to identify significant changes; that the results of different management activities be compared; that a reasonable timeline be established so that management can be changed before the resource degrades; that the data be evaluated in a timely fashion; and that management be changed when indicated. If adaptive management is to be employed as a primary management principal, the draft RMP/EIS must provide for all of these factors. Adaptive management approach only works if evaluation of resource conditions occurs on a nearly continuous basis. We have determined that intervals between allotment evaluations exceeding 20 years routinely occur on a neighboring BLM resource area, and in discussions with Burns District staff, it became clear that similar frequency of allotment evaluations occurs on the ARA. Therefore, it is difficult to have any confidence such a process.
Sage Grouse/special status species
The distribution of western sage grouse in western North America has been significantly reduced since at least 1900 with local extinction of populations having occurred at the periphery of the historic range. Recent (1980 to present) declines are estimated to be in the range of thirty-five to eighty percent. (C. Braun, Colorado Division of Wildlife, Historic and Present Distribution/Status of Sage Grouse in North America, Western Sage Grouse Status Conference, Boise, Idaho, 14 January 1999).
Factors that are important in maintaining viable sage grouse populations include size of area, quality of habitat, potential interchange (corridors), genetic diversity, and number of breeding individuals. (M. Schroeder, Washington Department of Fish and Wildlife, Population Viability and Conservation Planning for Sage Grouse, Western Sage Grouse Status Conference, Boise, Idaho, 14 January 1999).
The draft plan should clearly state how it will adhere to "Greater Sage-Grouse and Sagebrush-Steppe Ecosystems Management Guidelines" (2000).
The Sage Grouse is a Bureau of Land Management sensitive species, and the SEORMP/EIS acknowledges the BLM's responsibility to manage the grouse accordingly. Anecdotal information presented in the Lakeview Draft RMP/EIS suggests that declines on par with those mentioned above are also occurring in other areas within the SEORMP.
Other special status species known or likely to occur on the ARA should be covered under the RMP so that their priority habitats are clearly identified and management standards and guidelines adopted so that their populations are conserved and recovered. Evaluation of habitat quality and population status for special status species should be performed on a reasonable timeframe so that trends can be established.
Off-Highway Vehicles
Off-Highway Vehicle use in Oregon is on the rise. On p. 327 of the SEORMP's Appendices, the BLM predicts an increase in OHV use of at least 200% over the next 20 years in Oregon. A similar increase on the Andrews Resource Area should be anticipated. The Andrews DRMP/EIS offers a great opportunity to pro-actively address the complex issue of OHV use, especially as motorized backcountry recreation becomes increasingly prevalent and controversial.
Open OHV use is simply incompatible with the BLM's stated objective of properly functioning ecosystems. OHVs are known to: disturb wildlife in all habitat types, including ground-nesting birds, reptiles, young animals, and ungulates such as deer; compact and alter soil structure, sometimes leading to a 90% loss of soil moisture -- a loss arid lands can ill-afford; and compromise the recreational experience of anyone within ear-shot of an OHV.
We urge the BLM to revisit its OHV policy. Specifically, we request that the Draft Andrews RMP/EIS contain the following management guidelines:
- All areas should be closed OHVs, unless posted open. The BLM lacks the resources to patrol and monitor significant portions of the planning area designated as "open" or "limited" OHV usage.
- All vehicle routes should be classified as "designated," rather than "existing." This will hopefully provide the BLM with more control over the use of OHV areas, and allow for better oversight and monitoring.
- Do not cooperate in the organization of OHV events. This is an inappropriate and wasteful use of public funds; the BLM is in no position to spend its very limited resources on planning events that benefit such a small subset of the public -- particularly when this subset is engaged in an activity that gravely threatens a resource belonging equally to 260 million Americans.
- OHVs should be restricted to small areas. No more than 1% of the planning area should be open to OHV use.
Water Quality
There are a number of 303(d) listed impaired waters on the Andrews Resource Area. The draft RMP/EIS must provide for compliance with water quality standards by providing for objective standards with definite triggers and responses to water quality problems. TMDL's should be developed to insure water quality is improved and impaired waters de-listed.
Section 303 of the Clean Water Act addresses water quality via water quality standards, which specify the appropriate uses of water bodies and set standards to protect those uses. Although the BLM appears to understand its place in the TMDL process, it often fails to understand that its adaptive management approach to listed water bodies without approved TMDLs is likely to lead to continuous violations of the CWA.
The draft RMP/EIS should acknowledge that the primary cause of water quality degradation on the public lands is pollution from nonpoint sources. The evidence linking livestock grazing to riparian degradation RMP/EIS should avoid issuance of grazing permits for grazing allotments adjacent to water quality limited streams.
To meet these standards and guidelines as well as to avoid violations of the CWA, the plan should include a specific, immediate promise to satisfy water quality standards and must actually insure that it does not engage in any activity (including issuance of federal grazing permits) that may result in runoff of pollutants into water quality limited streams.
Steens Mountain Cooperative Management and Protection Area
We commend the BLM for its recognition of the Steens Mountain area as a place of significant value to the American public, and we support the agency in its efforts to manage Steens for its wilderness and recreational values.
We request that the BLM develop a detailed plan to manage increasing recreational activity and protect the natural values which make the mountain and its environs an extraordinary place. Specifically, we urge the BLM to:
- Implement a management plan that insures Steens Mountain remains primitive and natural through strong enforcement of the Wilderness Act
- Eliminate snowmobile access on Steens Mountain
- Expand the boundaries of the proposed CMPA to include the Alvord Desert. The Alvord and Steens mountain have been shown to be ecologically connected; together, they represent a rare, intact example of "Basin and Range" ecology and geology.
- Phase out livestock grazing in the entirety of the Steens Mountain CMPA and adjacent wilderness areas.
- The BLM's plan for the Steens SMA should be proactive in addressing development threats on Steens.
Wilderness Study Areas
The Draft RMP/EIS must re-analyze the suitability of non-recommended wilderness study areas (WSAs) for wilderness designation. Lands not designated as Wilderness Study Areas (WSAs) should be inventoried for wilderness suitability. This is in accord with FLPMA's requirement of continuing inventory of the public lands. In addition, the RMP/EIS must adequately protect WSAs from adverse impacts from livestock grazing, off-highway vehicles, and actions on lands adjacent to WSAs.
FLPMA requires the BLM to "prepare and maintain on a continuing basis an inventory of all public lands and their resource and other values (including, but not limited to, outdoor recreation and scenic values)."
WSAs are lands of national significance, not only because of their potential for inclusion in the federal wilderness system, but also because they represent some of the last vestiges of roadless wildlands and intact wildlife habitat left in the United States. These same lands are being compromised by livestock grazing, and the draft RMP must make an attempt to improve this status quo. Thus, we urge the BLM to adopt an alternative in its final RMP that adequately addresses grazing pressures within WSAs; specifically, we request that:
- Livestock grazing be suspended in WSAs where monitoring shows a decline in ecological condition.
- WSAs be managed for wilderness values first and foremost.
- Structures, such as fences and water developments, be prohibited from WSAs; if livestock grazing cannot be conducted in such a way that ecological values are not compromised or degraded in the absence of such structures, then grazing must be discontinued in those WSAs.
- Off-highway vehicles (OHVs) should be prohibited from use within WSAs. Please see our comments specifically regarding OHVs for more details.
Conclusion
The development of a Draft Resource Management Plan / Environmental Impact Statement for the Andrews Resource Area is a challenging task. Care must be taken in selecting the issues to be addressed and identifying appropriate alternatives that offer a meaningful range of options. In order to fulfill NEPA and FLPMA directives, the BLM must consider and give credence to the overall goal of Landscape level health and properly functioning ecosystems. In closing, it would be appropriate to review the following excerpt from Sierra Club's National Conservation Policy on Public Lands Grazing:
"Local Sierra Club entities are urged to advocate whatever incremental improvements seem most appropriate for specific sites within their jurisdiction up to and including an end to commercial grazing.
In addition to local site-specific efforts, the Club may seek federal legislation and regulations to curtail grazing and accomplish the other goals of this policy.
Recognizing that changes to grazing policy will likely take a number of years to accomplish and that some areas of the public lands are more imminently threatened by destructive grazing practices than others, the Sierra Club has prioritized our efforts. As a first priority, the Sierra Club will work toward ending commercial grazing on federal public lands where one or more of the following circumstance exists:
- Lands that receive an average annual precipitation of 12 inches or less or areas with cryic soils.
- Associated activities (e.g., water developments, predator control, vegetation manipulation) are occurring in such a manner that native plant and animal species are significantly impacted.
- Grazing is causing degradation of habitat necessary for threatened, endangered or sensitive native plant and animal species.
- Grazing is causing significant degradation of water quality.
- The public land management agencies have insufficient funding, staff, and determination to create and administer monitoring systems that will provide reasonable assurance that adverse impacts will be minimized and opportunities for restoration taken advantage of.
Adopted by the Sierra Club Board of Directors, September 24, 2000
Yours truly,
Juniper Group Sierra Club
6 N.W. Kansas
Bend, OR 97701-3302
