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«BLM Draft EIS Review – State Comments The State of Oregon, through the Governor’s office, has consulted with relevant state agencies and others ...»

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BLM Draft EIS Review – State Comments

The State of Oregon, through the Governor’s office, has consulted with relevant state agencies and

others in compiling the following comments. These comments are intended to ensure consistency

between the BLM’s management direction and that of Oregon’s greater sage-grouse (GRSG)

conservation plan regarding the various threats to the bird and social and economic vitality of human

communities in sagebrush steppe habitats. Desire for ongoing conversations with BLM regarding the State’s comments, BLM’s planning direction, and working to ensure as much consistency as possible between the two.

This GRSG DEIS represents an enormous body of work and analysis, and the State of Oregon deeply appreciates the effort that BLM is devoting to this important subject, and it’s openness to input in achieving the best possible means of conserving GRSG habitat while also integrating that effort into the economic and social fabric of Eastern Oregon. The responsiveness to stakeholder concerns and thoughtful consideration of the alternatives in the DEIS is extremely important because the Record of Decision (ROD) will have significant consequences for many Oregonians and a large part of Oregon for decades to come. The State is confident the BLM through the NEPA process will blend and select an appropriate alternative that balance the use of public lands by all Oregonians and the successful conservation of GRSG.

The State is not as confident that the BLM will have the resources and/or will have the capacity to fully implement the selected alternatives in the ROD. As evidence for this concern, Oregon BLM has not been able to fully implement all “required” policies and Best Management Practices (BMPs) identified in GRSG IMs (e.g. 2011-138, 2012-043, and 2013-128) and BLM has not been able to manage wild horses at Appropriate Management Levels (AML) in all Oregon Herd Management Areas (HMA). As a result, Oregon believes that the BLM should clearly identify necessary resources to implement the conservation measures it recommends.

General Comments on the Alternatives Alternatives A-C Greater sage-grouse are not thriving under current conditions in the Oregon sub-region. Given the longterm downward population trends for GRSG, and given the majority of habitat and about 82% of Oregon’s GRSG population reside on land under the jurisdiction of the BLM, the State does not support the “no action” Alternative A. Alternative B is a range-wide alternative that is not the best way forward for the challenges unique to Oregon. Alternative C recommends measures, such as the elimination of grazing from all occupied GRSG habitat that the State cannot support. There is simply no justification for eliminating grazing from all GRSG habitat. The alternatives that focus on grazing reduction (e.g., Alternatives C and F) reduce emphasis on the primary threats of fire, invasive annual grasses, and habitat fragmentation due to energy development, all of which will still be present whether livestock are present or absent.

Alternative E Alternative E represents a science-based alternative for GRSG conservation. However, Alternative E is based on the ODFW GRSG assessment and conservation strategy, which preceded the current BLM RMP amendment effort, as well as more recent efforts in the SageCon Partnership. Consequently, Alternative E does not specifically address some issues identified during the BLM scoping process and SageCon effort, and it does not recommend conservation measures that fit neatly within the BLM management structure.

Alternative F Alternative F is a range-wide alternative that is not the best fit for Oregon. For example, it calls for an across-the-board 25% reduction in the amount of area open to grazing. Instead of a mandatory across the board reductions in grazing, Oregon favors any adjustments to grazing be based on empirical evidence to maintain sustainable native sagebrush steppe habitat.

Alternative D Generally, alternative D represents a reasonable compromise that balances the need for multiple use of the sagebrush steppe while at the same time emphasizing the conservation of GRSG. Alternative D gives priority to ameliorating threats representing the greatest risk to GRSG habitat such as reduction of wildfire threats, juniper encroachment, and invasive species infestations, which the State agrees represent the most significant threats to GRSG habitat. BLM’s Alternative D incorporates many of the same conservation actions contained in the ODFW GRSG strategy, but in a framework that fits BLM’s management structure and that reflects more recent discussions. The State is pleased to see BLM embrace many of the same conservation actions recommended in the ODFW Conservation Strategy, but believes that certain additions and deletions to the Alternative are warranted in BLM’s final decision, as specified in more detail throughout this document. As written, the State cannot provide unconditional support of Alternative D, but the State believes that with modifications, it could support this Alternative.

Please consider the following comments and suggested edits for improving Alternative D.

Threat Reduction Vegetation Management The State supports strategies and treatments to reduce the probability of adverse wildfire impacts, limit juniper encroachment, and control invasive plant species to benefit GRSG habitat. Our recommendation is to better establish clear strategies, goals, and standards that will allow for prioritization of funding and allocation of additional resources to treat more than the 3% of GRSG habitat proposed for annual vegetation management in the DEIS, as well as to increase Early Detection and Rapid Response (EDRR) efforts, as these actions are the most effective ways known to address the primary threats to GRSG habitat (see pg. 2-44, Table 2-6, Vegetation—D-VG 1).

There is a critical need for improved and ongoing EDRR of invasive annual grasses as well as noxious weeds, such as spotted knapweed, yellow star thistle, diffuse knapweed, and white top. These species—if found early in habitat areas critical to GRSG—can be treated before gaining a foothold and creating major impacts to sagebrush steppe habitats. After ground disturbing activities such as juniper removal, management plans need to be implemented to allow for necessary re-seeding of desirable plants, treatment of invasive plants, and ongoing monitoring. The State recommends the BLM consider that more than 3% of the GRSG habitat needs be treated annually in order to make meaningful headway in addressing these major vegetation-based threats to GRSG viability and habitat health. The following page and issue specific comments attempt to indicate how BLM can modify the current DEIS in order to better address these vegetation issues and achieve GRSG conservation outcomes.

Pg. 1-22 - The State supports the BLM’s vegetation management objectives, however, these objectives should more explicitly include collaborating with adjacent landowners, especially private owners, Department of State Lands (DSL), and County Weed Management Areas. Such collaboration would increase the efficiency and effectiveness of vegetation management projects by sharing resources, leveraging additional resources, and promoting habitat improvements "across the fenceline". This concept is also mentioned in Action D-WFM 34 (pg. 2-76). As a neighboring landowner the State recommends an emphasis on communication and coordination regarding weed management.

Section 4.2.

10 - The section indicates that the Oregon BLM Vegetation Management EIS has been completed and effective management of annual invasive grasses is able to occur on all districts. The State does not agree with this characterization. In fact, most districts have not completed their required vegetation management EA’s and any treatment occurring only happens under project-specific EA’s. At this time there is no vehicle to adequately respond to new infestations unless they happen to be found in a previously analyzed project. This issue should be recognized and priority given to get district vegetation management EA’s completed, doing so in a manner consistent with GRSG objectives.

Crested Wheatgrass

Pg. 2-61, Table 2-6, Conservation Action D-VG 12 of the DEIS states as follows: “Priorities for sagebrush

treatment are:

• Large, contiguous areas of Class 5 sagebrush in Cool-Moist Sagebrush or Class 4 sagebrush in WarmDry Sagebrush

• Crested/desert wheatgrass seedings ” It is not entirely clear what is meant by this proposed action, but the State believes sagebrush should not be removed in crested wheatgrass stands or other areas unless emergency conditions make it necessary (i.e., fire suppression). The BLM needs to provide justification for removing sagebrush in areas that contain and/or are returning to native plant composition, especially when sagebrush habitat has already been reduced or compromised and nearly a million acres of sagebrush habitat can be lost in a single year to wildfires. As further discussed below, crested wheatgrass should be considered an interim management option to stabilize soils and reduce risks of non-native annual grasses while aiding in the longer-term restoration of native vegetation and health GRSG habitat conditions. Crested wheatgrass should not be a management objective in and of itself, and sagebrush should not be removed in order to protect or advance crested wheatgrass for forage or other purposes.

Pg. 2-74 - Use of native seed and restoration of native perennial vegetation should be the priority.

However, with the current status and quantity of noxious weeds and invasive annual grasses in the planning area, it may be difficult to ensure native vegetation will successfully out-compete invasive, nonnative competition. Crested wheatgrass is very effective at establishing and out competing weedy species, especially invasive annual grasses. The State recommends BLM allow increased amounts (up to 50%) of non-invasive, non-native bunchgrass and forb species to be used in seed mixtures for restoration and rehabilitation after wildfires in certain circumstances. This would be allowed where predisturbance conditions contained high levels of invasive annual grasses and/or other noxious weeds or other situations where the threat of invasive weed infestations is probable following a disturbance event. NTT guidance on the use of native plan material (as mentioned in Action B-VG 5) should be incorporated into decision-making where use of non-native plant material is being considered.

Action E-WFM 19 should be included in Alternative D in Action D-WFM 19 (pg. 2-74) as an available measure for site-specific situations where the probability of native plant restoration is low and exotic annual grass or noxious weed invasion is high. "If native plant and sagebrush seed is unavailable, crested wheatgrass can be planted in lieu of native species or as a mixture with native species, because it is readily available, can successfully compete with cheatgrass, and establishes itself more readily than natives. If crested wheatgrass is planted initially, specific efforts or plans are needed to interseed native grasses, forbs and shrubs in the rehabilitation area. This might include an initial seed-mix of 1 to 2 pounds per acre of crested wheatgrass mixed with natives. Use of crested wheatgrass is an intermediate step in rehabilitating disturbances to sagebrush habitats."

Invasive Annual Grasses

Invasive annual grasses, such as medusahead rye and cheatgrass, directly displace native vegetation food sources for GRSG (sagebrush, bunchgrass, tall forbs). They are also a primary fuel for wildfires that can devastate large areas of sagebrush and other native plants that take years to re-establish. These invasive annual grasses are a major cause of reductions in GRSG habitat. They alter the frequency and severity of fire cycles, and in turn favor establishment and growth of invasive annual grasses and other invasive noxious weeds over desired native sagebrush and associated native grasses and forbs.

BLM recognizes the extent and severity of the invasive annual grass and weed threat across the public land range of GRSG, noting on pg. 3-30: "Most notable is an annual grass complex made up of the statelisted noxious weed medusa head (Taeniatherum caput-medusae), the invasive species of concern cheatgrass (Bromus tectorum), and North Africa grass (Ventenato dubio), which are estimated to occur on a million acres of BLM-administered lands in eastern Oregon (BLM 2010a)."

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