BARK
503-331-0374
www.
December 10, 2003
BARK
503-331-0374
www.
December 10, 2003
6780 Highway 35
Mt. Hood/Parkdale, OR 97041
Emailed to: [email protected]
Dear Ms. Black:
Re: Long Prairie Grazing Allotment Reauthorization
These scoping comments pertain to the proposed
reauthorization of livestock grazing within the Long Prairie Allotment, which
spans
The scoping letter of
The Analysis team must
adequately determine suitability of Long Prairie Area for grazing
Comparison to Historical
Conditions
Management must ensure ample water availability for wildlife and vegetative needs as a priority above all other uses, including commercial livestock grazing. Current conditions of area watersheds, including riparian areas, soil resiliency and moisture retention, peak flows and runoff rates, seasonal ranges of water table levels, function of riparian areas for wildlife dispersal, etc., must be compared to historical ecological conditions prior to livestock grazing in the area. Some of this long-term data is likely not available for Long Prairie, but areas with similar aspect, soils, and fire regimes can be studied and compared to this site. It is critical that the Forest Service demonstrate what impact grazing has had historically in order to determine what the future impacts will be and to determine what the opportunity costs are for the ecosystem if grazing continues instead of allowing natural processes to shape vegetative communities and aquatic environments. Conditions and trends concerning water availability, wildlife populations and native vegetation abundance and distribution must also be compared to historical pre-livestock conditions in this area. The NEPA document must disclose the differences between historical ecological conditions and current conditions, and address necessary restoration throughout this allotment.
The Analysis team must
adequately analyze impacts to water quality
Lack of Information Available
One of our primary concerns for this project is water quality. We ask that in depth study and documentation of water quality within the planning area be completed as a part of the NEPA analysis. The NEPA analysis for this proposal must disclose if there are any water diversions, as well as the current livestock consumption of water, water tanks and/or wells, pumping facilities, where cattle have access to streams, and any other impacts to water quality and/or quantity. Included in this analysis must be the cumulative impacts of these uses to water availability, ecological integrity, and wildlife and botanical species. Impacts to area springs that have made natural water sources non-potable for human use must also be addressed. Included in this assessment must be plans to restore water quality at all area springs.
The little data provided from the Mill Creek Watershed
Analysis (MCWA) is outdated and inadequate. The MCWA admits that little information
was available even at the time of the documents’ publication in 2000. “Compared
with other watersheds within the eastern portion of the
Protect Riparian Areas
The
Livestock impact the landscape by three mechanisms:
consumption of forage, trampling, and deposition of excreta (Smeins 1975). The
terrain and diet that cattle prefer influence the magnitude of their impacts on
water quality. Cattle prefer flat or
gently sloping terrain (Mueggler 1965,
The affinity of cattle for flat or gently sloping terrain
corresponds to their disproportional occupation of riparian zones (Severson and
Boldt 1978, Platts and
Nelson 1985).
“Livestock grazing has damaged approximately 80% of stream
and riparian ecosystems in the western
The ecological value of riparian areas is high because of
the great biodiversity which is characteristic of riparian areas. This rich biodiversity is due in part to
their high soil moisture and fertility levels.
(Hubbard 1977, Meehan et al. 1977, Thomas et al. 1979,
Knight and Bottorff 1984, Fleischner
1994, Ohmart 1996). An estimated 60-70% of western bird species (Ohmart 1996) and as many as 80% of wildlife species in
Arizona and New Mexico (Chaney et al. 1990) and in southeastern Oregon (Thomas
et al. 1979) are dependent on riparian habitats. Because of this, riparian ecosystems are
considered to be important repositories for biodiversity throughout the
west. A.J. Belsky, A. Matzke,
Impacts from Sediment
Sediment affects stream organisms while it is in the water column as suspended solids (turbidity), and after it has settled to the bottom (Lynch et al. 1977). Excessive levels of sediment can change species densities, species diversity, and community structure of a stream. (Hubert et al. 1992). Suspended solids also influence the thermocycles of the water column (Hubert et al. 1992). Ellis (1936) found that as suspended sediments settle they interfere with the heat transmission of the water. The metabolic rates of aquatic organisms may be affected by change in these cycles. Suspended solids have direct and indirect impacts on fish (Hubert et al. 1992). Physiologically, the function of the gills is inhibited by the amounts of suspended solids in the water column. Vision is impaired by turbidity, thus affecting a fish’s ability to capture prey items. Suspended solids also affect the drift behavior of macroinvertebrates (Gammon 1970), which are prey for fish.
Another detrimental characteristic of sediment is it acts as a reservoir of bacteria, nutrients, and organic matter (Windell 1983). Sediment is derived from run-off and land erosion. Because of its source, sediment is high in organic material, and in areas that are grazed; bacteria and organic wastes contained in animal feces will enter the stream (Cole et al. 1986). Sediment may act as a sink for organic matter and nutrients (phosphorous and nitrogen). Fredriksen (1972) found that a significant portion of nutrients entering streams are attached to eroded soil particles. Animal wastes are washed into streams as in run-off and may settle out of the water into sediments. Presence of these components accelerates the eutrophication process.
Impacts from Bacteria
Grazing animals increase levels of bacteria in streams from
feces delivery (Tiedemann et al. 1988, Gary et al. 1983, Milne 1976). Bacteria do not impact stream ecology as
broadly as sedimentation does but bacterial increases are still detrimental to
water quality. The major problem with
high levels of bacteria is the dangers posed to human health. The presence of excessive levels of
pathogenic bacteria renders water unsuitable for human consumption or contact
(Hammer and MacKichan 1981). In a study by Saxton et al. (1983), fecal coliform and fecal streptococcal bacteria increased from a
cattle-grazed area with run-off levels in the spring after animals were
removed. In
Nutrients (primarily phosphorous and nitrogen) from animal excreta entering the stream may pass through the stream system with little impact, but provide increased nutrients to downstream bodies of water. Decomposition of increased plant biomass also requires grater amounts of oxygen. Oxygen depletion from eutrophication impacts the ecological balance of the body of water (U.S. Environmental Protection Agency 1979).
Cumulative Effects
Must Be Analyzed
Cumulative effects of grazing combined with other impacts such as logging, roadbuilding, mining, off-highway vehicles, development, noxious weeds, fires, fire suppression, and other anthropogenic factors, have had significant impacts on the Mill Creek Watershed and need to included in the forthcoming NEPA document as continued grazing is considered. The NEPA project team will have to provide detailed reasoning as to how water quality will at least be maintained and be monitored to meet water quality standards if grazing continues in this area.
A thorough examination of cumulative effects will need to occur of all grazing activities in the area both past, present, and future. Examination of baseline water quality data for previous grazing activities should be determined to predict how past and future grazing may impact water quality and fish habitat. Analysis of how riparian areas in general have been impacted as a result of grazing and how they will be impacted in the future must be included. Best Management Practices may not adequately mitigate the damage of grazing, and the practices may need to be further restricted or eliminated from portions of the allotment to comply with state and federal law.
In terms of water quality and wildlife, we are particularly concerned about how this proposal will impact fish species in the planning area. What species are present in the planning area? Which would be affected by continued grazing? Is there a difference in populations of fish species in streams with similar conditions other than some are in watersheds that are grazed and others are not?
The Proposed EA/EIS
Should Address Livestock Capacity and Stocking Rates
How many cattle are being considered for the Long Prairie allotment? Determination of a sensible stocking rate is a scientific question that will vary based on a variety of environmental factors, and the EA/EIS should reveal detailed information about what the proposed rate would be under a proposed action that includes grazing.
The Impact of This
Grazing Proposal on Native Plant & Animal Life Should Be Carefully Analyzed
It is the intent of Congress, and the desire of the American people, that public lands national forests be managed for wildlife viability, natural habitat, and healthy ecosystems (such as healthy streams and riparian areas) as well as recreation. Thus any allotment, or portion of an allotment, deemed suitable for livestock forage must be managed first and foremost for the conservation and protection of natural resource values, including hydrologic function, native botanical species diversity, and native wildlife species viability.
Native Plant Species
There are at least 4 known sensitive species in the Mill Creek Watershed. What sensitive and previously listed C3 species occur in the Long Prairie Area? At the time of the Mill Creek Watershed Analysis, insufficient information was available about the local flora and fungi, lichen and broyophytes; however, it was clear that sensitive plant populations were being harmed by cattle, with evidence of manure concentrations and trampling in sensitive plant habitat along Surveyor’s Ridge. There was also the recommendation that the habitat areas of R6 sensitive plants should be omitted from open range grazing allotments.” (MCWA, 35).
In the NEPA process, you must do a full accounting of all Management Indicator, Sensitive, and ESA listed species and describe the likely impacts of continued grazing both on species that currently occupy the area and on species that could occupy the area without grazing. Survey results and methodology must be disclosed and analyzed, so that the agency and the public have the information necessary to develop and evaluate alternatives, and make a reasonable and ecologically sound decision for this proposal. Alternatives must include provisions for restoring damaged natural resources and native species populations throughout the allotment. Specific monitoring and survey protocol must be developed and disclosed as part of the alternatives.
The NEPA document must disclose the current population status and trends of plant species as well as the trends and status of wildlife, including management indicator species and species of concern within the area. The historical and current habitat conditions, and populations must be disclosed, compared and assessed. Cumulative impacts to these and other plant and wildlife species from the past and proposed allotment use, in conjunction with other allotment uses, must also be disclosed and analyzed.
The full results of the past decade of allotment monitoring and wildlife surveys must also be disclosed, including permittee compliance and cooperation with management restrictions and objectives (or lack thereof). The duration of time the allotment permittees have held these allotments, and their past and current track records with regards to grazing practices must also be disclosed.
Provisions for monitoring and restoration must be developed which protect and enhance the viability of native wildlife, as well as native botanical species. Analysis must accurately address if conservation and protection goals for these species can be accomplished under the proposed livestock grazing permits, or if these goals can be better achieved by eliminating grazing in the allotment.
Management Indicator Species
Both deer and Elk are management indicator species (MIS) of high
concern in the
Several studies have found that elk avoid livestock and
human activities. Lyon and Ward (1982)
noted that elk will avoid sheep herds, especially if a herder is present.
There is credible evidence that deer and elk populations could be adversely affected by increased grazing. How will this issue be addressed the EA/EIS? These MIS are also known to be adversely affected by logging, and numerous logging projects are being proposed in the vicinity of the Long Prairie Grazing Allotment. How will cumulative effects of logging projects be analyzed within the context of the proposed grazing? Detailed population trend analysis of these MIS and all other MIS should be conducted pursuant to NFMA. Pursuant to NFMA, “planning alternatives shall be stated and evaluated in terms of both amount and quality of habitat and of animal population trends of the MIS”. 36 C.F.R. §219.19(a)(2). The NEPA team should examine each alternative within the EA/EIS in terms of how each alternative will impact the population trends of Mt. Hood National Forest MIS.
Migratory Bird Population
During the NEPA process, the Forest Service should also fulfill their obligations under the Migratory Bird Act treaty. This proposal will more than likely to negatively impact migratory birds, which depend upon riparian areas that are likely to deteriorate as a result of grazing. Under this act the Forest Service and the U.S. Fish and Wildlife Service should develop and implement a Memorandum of Understanding promoting the conservation of migratory birds impacted by this project. E.O. 13186 §3. Protective measures of migratory birds should be a high priority, particularly in riparian areas where these birds are known to concentrate. The Forest Service should initiate consultation with FWS to fulfill duties pursuant to this Act, and to determine the most effective ways to conserve migratory birds.
Adequacy of Forage Levels
The suitability of grazing areas should include evaluation of the supply of forage for livestock, and the capability of these lands to produce suitable food and cover for selected wildlife species. 36 C.F.R. §219.20(a). This type of analysis should be considered in conjunction with stocking rates. The supply of forage and grazing capacity for livestock and wildlife in the allotment has to be considered. If grazing capacity and the supply of forage are considered separately, then there could be an increased risk of overgrazing and depletion of area resources.
There Must Be Adequate
Monitoring Provisions
The USFS must make provisions in the proposed alternatives for responsibly responding to information from independent monitoring of the allotment by citizens. These provisions must include working cooperatively with conservation organizations to ensure the enforcement of allotment restrictions and protection of conservation goals and values. Whenever the agency is provided with photographic or other evidence of violations of grazing allotment requirements and/or goals from independent monitoring, it must take the necessary steps to immediately prevent further violations from occurring, including the removal of livestock, reduction of livestock numbers, and/or the termination of the allotment.
Included within the NEPA document for this proposal must be a map depicting the locations of all upland, riparian, and pasture/rangeland Designated Monitoring Areas. A description of past and current monitoring methods, along with the monitoring results, must also be included. The analysis document must develop and disclose new monitoring standards and protocols that will prevent or alleviate grazing overuse and adverse impacts which have continued to occur in the recent past.
The NEPA analysis team
should analyze impacts from grazing to soils in the project area
Soil resources should be analyzed based on the impacts caused by prolonged grazing. Sediment flow into project area streams is influenced by sediment movement from area soil. Grazing is known to cause compaction of soil, and reduce the ability of the soil to absorb water and interfere with movement of water through the soil. The cumulative impacts of grazing in this area should be analyzed, and if it’s determined that certain areas are unsuitable for grazing based on existing soil health, then that area should not be grazed.
The primary mechanism by which sediment is delivered to streams is overland flow of precipitation (Foster and Meyer 1977, Meehan et al. 1977). This run-off mobilizes eroded soil particles and carries them into streams. (Statham 1977). Trampling by large grazing ungulates compacts the soil, increasing bulk density of soil. The resulting lowered infiltration rates cause increased run-off and erosion. Consumption and trampling by large ungulates reduces plant vigor and vegetative production. (Winegar 1977). When activities of ungulates make soil available for transport in the riparian zone, the soil particles have a shorter physical distance before they reach the stream, thus they are more likely to enter the stream (Hubert et al. 1992). As in the upland, trampling in the riparian zone compacts soil, reducing infiltration rates. Because riparian soils tend to be moister due to the high water table, flatness of the floodplain, and water received from the upland, they are more prone to compaction (Bohn and Buckhouse 1985).
The data of Kauffman et al. (in process), indicates that grazing has caused the loss of at least about 1.1 million ft3 in soil water storage per square mile of grazed area in wet sites, based solely on the measured loss of soil porosity. It is extremely well documented that grazing significantly elevates soil erosion (Rhodes et al., 1994; Belsky et al.,1999). In many areas in the west, it is highly likely that soil loss caused by grazing exceeds a depth of 1 inch. These impacts are extremely significant due to their persistence. Soil compaction persists for 50-80 years, in the absence of continued impacts. (USFS and USBLM, 1997). Soil properties never recover if subjected to continued impacts, such as roads with on-going grazing. The loss of topsoil is essentially permanent. (Beschta et al., 1995).
The health of soils and water quality should be examined together since soil health can be an indicator of nearby water quality. Soils that have been densely compacted from over grazing should be avoided in the current proposal. A soil science professional should conduct a comprehensive inspection of the site.
The NEPA should
address the impacts of global climate change
The effects of global climate change are becoming clearer
everyday. The latest report on the
The NEPA should
include analysis addressing the impacts of grazing on noxious weeds
The relationship between grazing and introduction of noxious weeds is well understood. As a result of the high level of infestations on Mt. Hood National Forest and nearby forests, a planning process is underway to address the spread of noxious weeds on the landscape and to better understand the cost—both economic and environmental—of their spread. It is premature, therefore, to authorize an activity which could, upon the completion of said analysis, be determined to be detrimental to the landscape. In the meantime, it would be prudent to take preventative measures against further infestations by halting activities that cause the problem in the first place. Currently we do not have a complete understanding of the current level of infestation across the planning area. However, a preliminary map provided by the Site Specific EIS Team on Invasive Plants shows that the Long Prairie area is targeted for treatment due to problematic populations of noxious weeds. Such treatment could involve the application of toxic herbicides, which have their own adverse effects on the landscape, affecting wildlife, drinking water and human health, to state just a few. The Long Prairie NEPA document should analyze and include the effects of pesticide application, which will be likely as a result of grazing. The LRMP requires implementation of control measures in areas affected by grazing, including prevention and early treatment (FW-301).
At least 12 state listed noxious
weeds are present in the vicinity: including Rush Skeleton Weed, Tansy Ragwort,
Yellow start thistle, bull thistle, Canada thistle, diffuse knapweed, Scotch
broom, spotted knapweed,
NEPA Analysis Should Consider Allotment
Retirements & Voluntary and Mandatory Permittee
Conservation Agreements
The NEPA document must disclose and explore the use of methods being developed to accomplish conservation and restoration goals. Among these are:
1. Permanently retiring allotments or portions of allotments when the current permittee transfers or otherwise divests of their contract and interests;
2. Voluntary agreements with permittees to work towards conservation goals by resting allotments for a period of months or years, conducting and/or financially compensating for needed restoration work, terminating grazing allotments in sensitive areas, reducing livestock numbers to levels which do not adversely impact the natural resources of allotments or concentration areas within the allotments, etc;
3. Mandatory measures and contract provisions which work towards conservation goals by:
a. resting allotments for a period of months or years;
b. conducting needed restoration work;
c. requiring financial compensation for natural resource damages incurred from livestock grazing;
d. terminating grazing allotments in sensitive areas;
e. reducing livestock numbers to levels which do not adversely impact the natural resources of allotments--including concentration areas within the allotments,
f. raising the allotment fees to cover the full costs of the now federally subsidized “welfare ranching” programs, and to cover the extensive necessary restoration across the region’s public lands due to past and ongoing livestock grazing practices.
The NEPA document for this proposal must disclose the full economic
costs to the USFS,
1. Managing and monitoring this livestock grazing allotment;
2. Cost share agreements between the USFS and the permittees;
3. Restoration needed due to past livestock grazing on the allotment;
4. Restoration needed or in the likely foreseeable due to livestock grazing on the allotment;
5. All and any other financial or resource subsidies involved in the grazing allotment and its management processes.
It is imperative to making a reasonable decision as required by the NEPA that both the public and the decision-maker have all the pertinent information concerning the consequences and responsibilities inherent in the decision for this grazing allotment proposal. As allotment management and resultant restoration efforts require financial expenditures, these must be disclosed and assessed. The best interests of the public, the wildlife, and natural resource heritage of us all must be weighed against the often considerable financial and ecological costs of what has so aptly been termed “welfare ranching”—which too often benefits a few individual ranchers at the expense of the land, public and government. The analysis must explore alternatives which ensure the costs of managing, maintaining, and restoring this allotment are not borne by the public or federal treasury, but by the individual permittees who run commercial livestock operations. The continued use of public lands by permittees must honor ecological conservation goals. The use of public lands must not become abuse. Livestock grazing is a privilege, not a right. It is the duty of the USFS, entrusted with “caring for the land and serving the people,” to uphold federal conservation goals, the needs of the land, and the best interests of the greater public. Wherever these interests, goals and objectives conflict and cannot be otherwise resolved, it is the responsibility of the agency to revoke or terminate livestock grazing allotment permits. The NEPA document for this process must address this responsibility.
Livestock Conflicts:
Aesthetics, Natural Tranquility, & Recreation
As organizations with members who enjoy the natural environment for recreation, tranquility, wildlife observation, wild native plant identification, ecological research, solitude and beauty, it is imperative that the USFS address the many known adverse impacts of livestock grazing due to all the above. Livestock grazing tramples and devastates what would otherwise be abundantly beautiful wildflower meadows and natural riparian wonderlands. Cattle despoil the landscape with their feces, which assault the olfactory senses, impair respiratory health, support a plague of disease-vector biting insects, and significantly limit the capability or desire of citizens to exercise their Multiple Use Act rights to recreate and enjoy public lands.
Livestock grazing is often in contravention to the Congressional intent, and letter of the law, of federal environmental policy laws. Among these are the National Forest Management Act, mandating the agency maintain and provide for viable populations of all native species; the Clean Water Act, mandating that the agency protect the quality, quantity, and availability of area waters; the Endangered Species Act, mandating the agency protect and restore listed species populations and prevent trends towards federal listing for all other native and desirable species; the federal treaty rights of indigenous nations, mandating the agency ensure access to public lands by native peoples and their continued right to utilize an abundance of botanical and wildlife species; and the Multiple Use Act, mandating that public lands be conserved and managed to provide for a diversity of compatible publicly desired uses, including recreation, wildlife habitat, and natural scenic beauty. In determining the suitability of livestock grazing in this allotment, the agency must disclose and address the significant issues raised herein. Where conflict exists, the agency must abide by the mandates of federal laws, the best interests of the public, and the needs of the lands in its care.
Summary Statement
Bark and ONRC look forward to the USFS providing to the public a comprehensive, scientifically supported, and unbiased analysis that demonstrates that not only is the Long Prairie area suitable for grazing, but that other important resource values are not compromised.
Our organizations look forward to reviewing the NEPA document for this proposal, including a full range of restoration alternatives that address the many needs which are inextricably entwined with, and resultant from, livestock grazing.
Sincerely,
Bark