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Map 2.

National Greater Sage-Grouse Planning Strategy: Identifying Winter Habitat

Where the Rubber Meets the Road

The National Greater Sage-Grouse Planning Strategy is a commendable effort to improve management of more than 60 million acres of the Sagebrush Sea, a little known, but vitally important landscape to fish and wildlife, recreation, western communities and sustainable economic development. In September 2015, the federal government released Records of Decision for 14 of 15 final sage-grouse plans prepared under the Planning Strategy. While no conservation strategy is perfect, given the level of management discretion and deference in the final plans, interpretation and implementation of the plans will be particularly important to their success or failure to conserve and recover sage-grouse and their habitat.

Defenders of Wildlife closely monitored development of key sage-grouse conservation measures throughout the four-year planning process. A number of issues remain unresolved in the Records of Decision (ROD) and approved resource management plan amendments (ARMPA). In this series of blog posts, Defenders will respectfully offer recommendations to address certain deficiencies in the final plans to improve conservation of sage-grouse and hundreds of other species that depend on sagebrush steppe. Although the Bureau of Land Management (BLM) and the U.S. Forest Service were both involved in the Planning Strategy, our analyses and recommendations will focus on the BLM, which manages the majority of sage-grouse habitat on federal lands.

MANAGEMENT ISSUE: most of the BLM’s approved resource management plan amendments failed to identify sage-grouse winter habitat, an essential habitat type for sage-grouse persistence.

RECOMMENDATIONS

     1. Prioritize mapping of sage-grouse winter habitat and immediately incorporate the maps into sage-grouse conservation strategies.

     2. When and where available, use preliminary or draft maps of sage-grouse winter habitat when implementing sage-grouse conservation plans until wintering areas can be more definitively delineated.

 

MANAGEMENT ISSUE: High quality, accessible winter habitat is essential to the sage-grouse’s life cycle.

Sage-grouse winter habitat must provide tall, healthy sagebrush for food and cover to support the birds throughout the season (Braun et al. 2005; Connelly et al. 2011a, citing others). Wintering areas are often on windswept ridges, south-facing slopes or in protected draws where sagebrush is not completely covered in snow (Braun et al. 2005; final Wyoming: 98-99). These landscape features may be geographically limited in some areas (e.g., Beck 1977). Moreover, big sagebrush communities typically used for winter habitat are becoming increasingly rare in the West (Welch 2005).

Sage-grouse typically show high fidelity to winter habitat areas, and a single wintering area may support several different breeding populations (i.e., populations of males and females that use different breeding and nesting habitats in spring) (draft Oregon: 8-39; SGNTT 2011: 51). Moynahan et al. (2007) also observed that the quality of winter habitat appears to influence the abundance and condition of female sage-grouse and their nesting effort and clutch sizes in spring. Healthier females are more likely to have larger clutches and re-nest in case of nest failure (i.e., from predation). Given the importance of winter habitat, the loss or fragmentation of these areas can have a disproportionate impact on sage-grouse population size locally and regionally (Caudill et al. 2013; draft Oregon: 8-39).

MANAGEMENT PRESCRIPTION: The first step to conserving important habitat areas is to identify them. In some cases, land and wildlife managers know where winter habitat exists based on observed use by sage-grouse. Where use is not yet known, surveys of vegetation type, geography and topography can help generally identify winter habitat. BLM’s final plan for Utah noted that such “broad maps are more likely to include all seasonal habitat areas important for each population and can be refined as management agencies gain more information” and that the broadly delineated maps used in that plan may “include known use areas, areas of potential habitat, as well as areas of non-habitat” (final Utah: Append. K, K-3). Notably, a federal court has held that the failure to map sage-grouse winter habitat could be grounds for remanding a land use plan back to the responsible federal agency to address the omission (WWP v. Salazar, 4:08-CV-516BLW, Slip Op. at 3).

PROPOSED FINAL RESOURCE MANAGEMENT PLANS/SUB-REGIONAL ENVIRONMENTAL IMPACT STATEMENTS: Following scoping for the planning process in 2012, the BLM produced 14 draft conservation plans covering sage-grouse range in 2013-2014 (a fifteenth plan for the Lander Field Office in Wyoming was further along in the process and was finalized in 2014). The BLM then released 14 proposed final plans in April 2015, incorporating public comments on the draft plans and recommending management prescriptions to be adopted in the final plans.

Only five proposed final sage-grouse plans identified sage-grouse winter habitat within their planning areas (Map 1). The proposed final plan for Oregon stated that designated priority habitat contains 99 percent of known sage-grouse wintering areas (proposed final Oregon; 3-7; see also 3-6, Oregon core areas contain 99 percent of 1,695 known winter locations), but didn’t include a map of winter habitat (see 2-56, Oregon Department of Fish and Wildlife updating sage-grouse habitat maps). The proposed final plan for the Wind River/Bighorn Basin District in Wyoming identified winter habitat in only one of two resource areas (Worland) in the planning area, though the other resource area (Cody) certainly contains sage-grouse winter habitat. The other seven proposed final plans did not identify sage-grouse winter habitat at all.

Map 1.

Map 1. Five proposed final sage-grouse plans released in April 2015 mapped sage-grouse winter habitat. The Wind River/Bighorn Basin District identified sage-grouse winter habitat for one field office (Worland), but not the other (Cody).

RECORDS OF DECISION/APPROVED RESOURCE MANAGEMENT PLAN AMENDMENTS: The BLM released final versions of 14 sage-grouse plans in September 2015. Only two final plans included maps of sage-grouse winter habitat (Map 2). In some cases, BLM sage-grouse plans mapped and prescribed greater protection for winter range for species other than sage-grouse. For example, the final plan for the Lander Field Office included maps of winter and “crucial” winter range for bighorn sheep, elk, moose, mule deer and pronghorn, but not sage-grouse.

Map 2.

Map 2. Only two of fifteen plans (including the Lander Field Office) incorporated maps of sage-grouse winter habitat in the final stage of the planning process.

Five final plans apparently rejected maps of sage-grouse winter habitat included in previous draft and proposed final versions:

  • Three final plans—HiLine, Northwest Colorado and South Dakota—dropped winter habitat maps included in proposed final versions (proposed final HiLine: 439, Map 3.22; proposed final South Dakota: Map 2-9). In fact, the map in the proposed final plan for Northwest Colorado depicted both sage-grouse winter range and “severe winter range,” which might have been important for current and future decision-making concerning the species (proposed final NW Colorado: Append. A, A-32, Fig. 3-4).
  • The final Wyoming plan, while describing both the characteristics and importance of conserving winter habitat (final Wyoming: 107) .
  • Both the proposed final and final plans for Idaho/Southwest Montana failed to incorporate a map of sage-grouse winter range included in the draft plan (draft Idaho/SW Montana: Append. I, vol 3, I-32) nor did they include a map of winter habitat prepared by the Idaho Department of Fish and Game.

Both BLM RODs for the sage-grouse planning process promised to incorporate new maps of sage-grouse winter habitat in individual plansthrough subsequent plan maintenance, revision, or amendment, as appropriate” and that “[p]riority should be given to ensuring that wintering habitat is identified and captured in all changes in habitat maps subsequent to [the Records of Decision]” (RM ROD: 1-40; GB ROD 1-42). This is helpful direction for long-term conservation of sage-grouse. However, in the interim, the BLM should consider adopting existing maps (even draft maps that broadly identify winter habitat) and take a precautionary approach to managing all potential wintering areas until they are more definitively delineated in planning documents.

Mark Salvo is Senior Director for Landscape Conservation at Defenders of Wildlife.

Lauren McCain is a Federal Lands Policy Analyst for the organization.

Posted in Imperiled Wildlife, Public Lands0 Comments

Section 7 Consultation Locations

New Endangered Species Study and Database

New study on section 7 consultations

We are pleased to announce the release of two products this Monday that will improve the public’s understanding of how federal agencies implement section 7 consultations under the Endangered Species Act.  First is the publication of our article in the Proceedings of the National Academy of Sciences on the results of all 88,290 consultations the U.S. Fish and Wildlife Service recorded from 2008 through April 2015.1  This is the most comprehensive study on FWS consultations, with many interesting findings:

  • Only 7.7% of the 88,290 consultations were formal.  The percentage was highest in 2008 (9.5%) and steadily declined to 6.3% in 2014.  The total number of consultations has also declined since 2008.

Types of Consultations Under the ESA Section 7 Process

    • Only two consultations resulted in “jeopardy” findings (0.029% of formal consultations).  One of those consultations also found “destruction or adverse modification” of critical habitat—the only instance of such a finding during our study period.  That consultation was redone in response to a lawsuit, and the revised consultation concluded no jeopardy or destruction/adverse modification.  All jeopardy/destruction/adverse modification findings were accompanied by reasonable and prudent alternatives, so none of the projects was stopped because of section 7.
    • The low percentage of jeopardy findings (0.029%) contrasts with the much higher percentages found in past studies: 8.9% from 1979-1981; 17.5% from 1987-1991; and 7.2% from 2005-2009 for FWS fish-related consultations.  The past studies are cited in our paper.

Jeopardy Findings from Section 7 Consultations

    • Although most consultations occurred in the eastern United States, formal consultations were concentrated in the western states (Florida is an exception).
    • The median duration of consultations was 13 days for informal and 62 days for formal.  Only 1,381 formal consultations exceeded the 135-day limit set in Services regulations, though we suspect many of those consultations were unusually complex and could not have avoided an extension.

map 1

 

    • The most commonly consulted-on species is the Indiana bat (14,979 consultations), but the California red-legged frog is the most common species in formal consultations (722).  The Army Corps of Engineers has the highest number of informal and formal consultations.

Explore the consultation data online

Defenders strongly supports open data and transparency, especially when it comes to the ESA.  That’s why today we’re also releasing a web application for you to explore the FWS consultation data from our study.  The Section 7 Explorer is free to use and requires no registration.

screenshot 1

 

We all know that FWS has only a fraction of the resources it needs to properly implement the ESA.  Open data is one solution to this problem because it allows the public to help analyze how the ESA is implemented and to create tools like the Consultation Explorer.  With the insights that come from open data, the public can identify better ways to implement the ESA.  For example, our study suggests that regulated entities can shorten the duration of many formal consultations by relying more on programmatic consultations when appropriate.  The Services recently finalized their regulation on programmatic consultations.  If implemented properly, the regulation offers an opportunity to streamline consultations without sacrificing conservation outcomes.  Open data can inform this process.

Open data also allows us to rely less on anecdotes, case studies, and unsupported generalizations when forming opinions about the ESA.  It does so by providing the data to analyze how an entire provision of the ESA works, as we’ve done here.  Empowered by this information, we can all guard against the use of unrepresentative, cherry-picked stories about the ESA.

We hope you’ll join us in encouraging federal agencies to prioritize making their ESA data easily accessible to the public, including as part of the Obama Administration’s 2013 Executive Order on Open and Machine Readable Data.  You might also be interested in reading Professor Dave Owen’s insightful blog post on our study and database.

What’s next?

Our study and the Consultation Explorer are just the start of our extended work on using large datasets to improve the effectiveness of the ESA, while minimizing the transaction costs for regulated entities and the public.  We are now evaluating conservation measures in hundreds of formal consultations to determine the impacts of federal projects on species recovery.  The consultation data include latitude-longitude coordinates of over 40,000 consultations (see image below for example), and we are using satellite images to measure the amount of habitat disturbance that has actually occurred.  We will then apply this technique to millions of acres of designated critical habitat to help answer a longstanding question: to what extent has designation helped conserve species?

Section 7 Consultation Locations

Jacob Malcom, Endangered Species Policy and Science Analyst, led the analysis and publication of the section 7 study and created the Consultation Explorer. Ryan Covington, Conservation GIS Analyst, and Jacob created the map of consultation coordinates. Ya-Wei (Jake) Li, Senior Director of Endangered Species Conservation, wrote this update, with help from Jacob and KC Stover, Coordinator for Landscape Conservation and Endangered Species Conservation.

The Endangered Species Conservation Program at Defenders of Wildlife focuses on developing more effective and efficient ways to conserve endangered species, particularly under the U.S. Endangered Species Act. Our approach is innovative, pragmatic, and multidisciplinary, with expertise in wildlife law, policy, science, and on-the-ground implementation.

If you would like to subscribe to periodic email updates like this one from the Endangered Species Program, please sign up at this link.  Updates will not exceed one a month.

If you have questions or comments on any aspects of our work, please email us at esa@defenders.org.

1 The article also appears on the PNAS website: www.pnas.org/cgi/doi/10.1073/pnas.1516938112

Posted in ESA, Federal Policy, Imperiled Wildlife0 Comments

National Greater Sage-Grouse Planning Strategy: Climate Change

National Greater Sage-Grouse Planning Strategy: Climate Change

rubber_meets_road_x

The National Greater Sage-Grouse Planning Strategy is a commendable effort to improve management of more than 60 million acres of the Sagebrush Sea, a little known, but vitally important landscape to fish and wildlife, recreation, western communities and sustainable economic development. In September 2015, the federal government released Records of Decision for 14 of 15 final sage-grouse plans prepared under the Planning Strategy. While no conservation strategy is perfect, given the level of management discretion and deference in the final plans, interpretation and implementation of the plans will be particularly important to their success or failure to conserve and recover sage-grouse and their habitat.

Defenders of Wildlife closely monitored development of key sage-grouse conservation measures throughout the four-year planning process. A number of issues remain unresolved in the Records of Decision (ROD) and approved resource management plan amendments (ARMPA). In this series of blog posts, Defenders will respectfully offer recommendations to address certain deficiencies in the final plans to improve conservation of sage-grouse and hundreds of other species that depend on sagebrush steppe. Although the Bureau of Land Management (BLM) and the U.S. Forest Service were both involved in the Planning Strategy, our analyses and recommendations will focus on the BLM, which manages the majority of sage-grouse habitat on federal lands.

MANAGEMENT ISSUE: the BLM’s Records of Decision and approved resource management plan amendments fail to provide direction for addressing the effects of climate change on sage-grouse and their habitat.

RECOMMENDATIONS

     1. Acknowledge existing authority and direction to address climate change effects in land management planning.

     2. Develop and implement conservation strategies based on the best available science to ameliorate the impacts of climate change on sage-grouse and their habitat at appropriate geographic and temporal scales.

     3. Identify and adaptively manage climate refugia to conserve sage-grouse and other wildlife long-term.

 

THREAT: Climate change is a recognized threat to sage-grouse (Connelly et al. 2011: 556, Table 24.2; Blomberg et al. 2012; van Kooten et al. 2007) that is also predicted to have deleterious impacts on sagebrush steppe (Schlaepfer et al. 2012; Neilson et al. 2005).

EFFECT: Most climate change simulations predict sagebrush steppe will contract as mean temperatures increase and the frost line shifts northward (Blomberg et al. 2012; Neilson et al. 2005). In the worst case scenario, sagebrush species are simulated to contract to just 20 percent of current distribution (Wisdom et al. 2005: 206, citing Neilson et al. 2005). The largest remaining areas will be in southern Wyoming and in the gap between the northern and central Rocky Mountains, followed by areas along the northern edge of the Snake River Plateau and small patches in Washington, Oregon and Nevada (see Miller et al. 2011: 181, Fig. 10.19). Sagebrush steppe may also shift northward in response to increased temperatures (Schlaepfer et al. 2012; Shafer et al. 2001).

New research by the U.S. Geological Survey found that climate change is likely to eliminate over 11 percent of sage-grouse nesting habitat in what is otherwise expected to be a future stronghold for the species in southwestern Wyoming. The authors cautioned “[g]iven declining sage-grouse populations are suffering from other habitat degradation forces, a potential additional 11% loss of future habitat from climate change could be very detrimental to some populations” (Homer et al. 2015: 141).

DRAFT RESOURCE MANAGEMENT PLANS/SUB-REGIONAL ENVIRONMENTAL IMPACT STATEMENTS: All fourteen draft BLM sage-grouse plans released in May 2015 acknowledged that climate change presents challenges to resource management, and many listed climate change as a planning issue to be addressed in management alternatives. Several plans specifically identified sage-grouse as a species that may be harmed by climate change, including the HiLine draft resource management plan amendment. “[S]ensitive species in the planning area, such as greater sage-grouse, which are already stressed by declining habitat, increased development, and other factors, could experience additional pressures due to climate change” (draft HiLine: 260; 434).

MANAGEMENT DIRECTION: The President and the Secretary of the Interior have provided ample direction, and the BLM has developed associated policies, to address climate change effects in resource management planning.

Presidential Direction

  • Executive Order 13653, “Preparing the United States for the Impacts of Climate Change”
  • Council of Environmental Quality (draft) guidance on considering the effects of climate change climate change in planning under the National Environmental Policy Act (CEQ Memo, 12-18-2014)

Department of the Interior

  • Secretarial Order 3289, “Addressing the Impacts of Climate Change on America’s Water, Land, and Other Natural and Cultural Resources” (Sec. Order 3289, Amend. 1)
  • Secretarial Order 3330, “Improving Mitigation Policies and Practices of the Department of the Interior” (Sec. Order 3330)
  • U.S. Department of the Interior manual chapter on climate change (U.S. DOI Manual 523 DM 1)
  • Bureau of Land Management Information Bulletin, “Landscape Approach to Managing Public Lands” (IB 2012-058)
  • Toevs et al. (2011) Bureau of Land Management Assessment, Inventory and Monitoring Strategy for Integrated Renewable Resources Management

MANAGEMENT PRESCRIPTIONS: Science-based measures for ameliorating the effects of climate change on species and landscapes include increasing the size and number of protected areas, maintaining and enhancing connectivity between protected areas, and identifying and protecting areas likely to retain suitable climate/habitat conditions in the future (even if not currently occupied by the species of concern). Management should also prevent the spread of invasive species, sustain ecosystem processes and functions, and restore degraded habitat to enhance ecosystem resilience to climate change (Chester et al. 2012; NFWPCAS 2012). These prescriptions were prepared and recommended by an interagency team of fish and wildlife managers and should be familiar to BLM.

Climate Change Consideration Areas

Conserving wildlife affected by climate change will require management that preserves and restores habitat resiliency and connectivity over the long-term. Recognizing this, BLM’s draft plan in Oregon presented an innovative and promising approach to address climate change effects on sage-grouse and their habitat. The preferred alternative proposed to designate a network of “Climate Change Consideration Areas” totaling 2.2 million acres of occupied and potential sage-grouse habitat in eastern Oregon to serve as climate change refugia for grouse and other wildlife (draft Oregon: 2-19 – 2-20). These areas, which are generally higher elevation with limited surface disturbance, were deemed most likely to provide the best available habitat to sage-grouse over the long-term based on climate change modeling (draft Oregon: 2-21). The draft plan prioritized Climate Change Consideration Areas for habitat restoration, off-site mitigation, conservation partnering, fire suppression, post-fire rehabilitation, and sage-grouse habitat and population monitoring and assessment (draft Oregon: 8-15 – 8-16). The draft even proposed changing the boundaries of Climate Change Consideration Areas over time as habitat shifts and sage-grouse populations move across the landscape (draft Oregon: 2-19).

Unfortunately, the concept of Climate Change Consideration Areas eroded through the planning process. The BLM carried it forward into the proposed final plan for Oregon (proposed final Oregon: 2-47 – 2-48; 2-48, Table 2-7), but with less detail, and the proposed final plan failed to list the conservation measures that may be applied in the areas (proposed final Oregon: 2-48). The designated areas then all but disappeared in the next and final phase of the process—while the umbrella Record of Decision for the Great Basin alluded to the designation of climate conservation areas in the Oregon plan (GB ROD: 1-33), the final plan itself included no mention of the areas.

 

PROPOSED FINAL RESOURCE MANAGEMENT PLANS/SUB-REGIONAL ENVIRONMENTAL IMPACT STATEMENTS: Treatment of climate change in the proposed final plans was inconsistent and generally lacking. Despite the substantial, clear direction to federal agencies to account for the effects of climate change in management planning (see above), every one of the proposed final plans asserted that “[t]here is no BLM … resource program in the proposed plan addressing this threat” (proposed final Utah: 2-10, Table 2.1).

PROTEST RESOLUTION: The BLM issue reports for each responding to administrative protests submitted on the proposed final sage-grouse plans. Some of those reports acknowledged that the plans’ failure to address climate change as a protest-able issue, others did not. Even those reports that did recognize climate change as protest-able issue then summarily dismissed the protesters’ concerns, claiming they were inapplicable, unfounded or otherwise addressed in the final plans and/or Records of Decision.

RECORDS OF DECISION/APPROVED RESOURCE MANAGEMENT PLAN AMENDMENTS: The RODs did not improve on climate change management from the proposed final plans and the underlying ARMPAs scarcely mention climate change as a factor in sage-grouse conservation. In fact, some useful climate resilience provisions that had been proposed in earlier iterations of the plans were not carried through to the final versions (see box). None of the RODs or ARMPAs reference the President’s direction or the Secretary of Interior’s order on climate change, which is remarkable given the unprecedented attention the current administration has given the issue.

The failure of the BLM sage-grouse plans to acknowledge management direction and prescribe measures to address climate change is particularly concerning because the administration believes the agency has done so in partial fulfillment of its “Priority Agenda for Enhancing the Climate Resilience of America’s Natural Resources”  (White House 2015: 28). This makes it especially important for BLM to address climate change impacts (which might even require amending the ARMPAs) during the implementation phase of the planning process.

Mark Salvo is Senior Director for Landscape Conservation at Defenders of Wildlife.

Aimee Delach is Senior Policy Analyst for Climate Adaptation for the organization.

Posted in Imperiled Wildlife, Public LandsComments Off on National Greater Sage-Grouse Planning Strategy: Climate Change

National Greater Sage-Grouse Planning Strategy: Livestock Grazing and Invasive Species

The National Greater Sage-Grouse Planning Strategy is a commendable effort to improve management of more than 60 million acres of the Sagebrush Sea, a little known landscape that is vitally important to fish and wildlife, recreation, western communities and sustainable economic development. The federal government released Records of Decision for 14 of 15 final sage-grouse plans prepared under the Planning Strategy in September 2015. While no conservation strategy is perfect, given the level of management discretion and deference in the final plans, interpretation and implementation of the plans will be particularly important to their success or failure to conserve and recover sage-grouse and their habitat.

Defenders of Wildlife closely monitored development of key sage-grouse conservation measures throughout the planning process. A number of issues remain unresolved in the Records of Decision (ROD) and approved resource management plan amendments (ARMPA). In this series of blog posts, Defenders will respectfully offer recommendations to address certain deficiencies in the final plans to improve conservation of sage-grouse and hundreds of other species that depend on sagebrush steppe. Although the Bureau of Land Management (BLM) and the U.S. Forest Service were both involved in the Planning Strategy, our analyses and recommendations will focus on the BLM, which manages the majority of sage-grouse habitat on federal lands.

MANAGEMENT ISSUE: the BLM’s Records of Decision and approved resource management plan amendments fail to provide direction for managing livestock grazing to avoid contributing to the spread of invasive annual grasses (primarily cheatgrass) in sage-grouse habitat.

RECOMMENDATIONS

   1. Manage livestock grazing to help restore, maintain and improve habitat resiliency against cheatgrass incursion in sage-grouse habitat.

    2. Use livestock to control cheatgrass only in limited circumstances.

   3. Adopt a universal desired habitat condition of less than 5 percent cheatgrass cover within 4 miles of all occupied or pending sage grouse leks.

 

Cheatgrass dominating sagebrush steppe in Idaho.

THREAT: Annual grasses, especially cheatgrass (Bromus tectorum), are a significant threat to sage-grouse and their habitat (US FWS 2010; Miller et al. 2011; Connelly et al. 2011). The BLM has expressed concern about the spread of cheatgrass on sagebrush steppe for nearly two decades (e.g., Pellant 1996). Cheatgrass is now the dominant species on 100 million acres (158,000 square miles) in the Intermountain West (Rosentreter 1994: 170, citing Mack 1981) and is a primary driver of huge, unnatural fires in sagebrush steppe (Miller et al. 2011). The conversion of sagebrush habitat to exotic annual grasslands is by one account “massive” (Allen 2003). Scientists have reported a strong correlation between livestock grazing and cheatgrass incursion (Reisner et al. 2013; Reisner et al. 2015).

EFFECT:  Reisner et al. (2013) found that, even after controlling for other factors that may contribute to the spread of cheatgrass, there is a strong correlation between grazing effects and cheatgrass incursion. Cattle grazing increases cheatgrass dominance in sagebrush steppe by decreasing bunchgrass abundance, altering and limiting bunchgrass composition, increasing gaps between perennial plants, and trampling biological soil crusts (Reisner et al. 2013; Knick et al. 2003).

A massive burn in Idaho driven by the occurrence cheatgrass in sagebrush steppe.

A massive burn in Idaho driven by the occurrence cheatgrass in sagebrush steppe.

Livestock grazing is also ineffective for controlling cheatgrass, even at the highest grazing intensities (Reisner et al 2013; Hempy-Mayer and Pyke 2008). As the BLM stated in the draft Idaho/southwestern Montana sage-grouse plan (draft Idaho/SW Montana: 3-64 – 3-65), “[i]ntensive livestock grazing is often suggested for controlling cheatgrass competition. Although targeted grazing may have some applications for fuels management, it is not effective in reducing cheatgrass competition…. During the short time when cheatgrass is highly palatable in the spring, a sufficient number of livestock cannot be concentrated on a small enough area to reduce the cheatgrass seed significantly or reduce cheatgrass seed lying on the soil surface. In addition, this type of grazing can be detrimental to remaining perennial grasses, opening the site up for further cheatgrass expansion in the future.”

DRAFT RESOURCE MANAGEMENT PLANS/SUB-REGIONAL ENVIRONMENTAL IMPACT STATEMENTS: All of the draft plans recognized that invasive plants, including cheatgrass, are an important management issue in sagebrush steppe. Most of them specifically identified cheatgrass as a threat to wildlife, including sage-grouse and other sagebrush-dependent species such as pronghorn (draft Bighorn Basin: 3-96) and sage thrasher (draft Bighorn Basin 3-109). Many of the draft plans also acknowledged that livestock grazing and “excessive grazing” can spread invasive plants (e.g., draft Buffalo: 306; draft Bighorn Basin: 4-146; draft Billings-Pompey’s Pillar: 3-88; draft Miles City: 3-77; draft South Dakota: 361; draft Oregon: 4-89). The draft Nevada/northeastern California plan observed that “[l]ivestock grazing is one of the vectors to introduce and or increase the spread of invasive weeds” and that “[m]ultiple factors can influence an area’s susceptibility to cheatgrass invasion, including livestock grazing, perennial grass cover and biological soil crusts”(draft Nevada: ch. 4, 54, citing Reisner et al. 2013).

MANAGEMENT DIRECTION: The Secretary of the Interior issued Order 3336, “Rangeland Fire Prevention, Management and Restoration,” which included direction to “reduce the likelihood, size, and severity of rangeland fires by addressing the spread of cheatgrass and other invasive, non-native species” (SO 3336: 2).

MANAGEMENT PRESCRIPTIONS: Reisner et al (2013), cited in every one of the BLM planning documents, provided clear, science-based prescriptions for managing grazing to avoid contributing the spread of cheatgrass:

“If the goal is to conserve and restore resistance of [big sagebrush] systems, managers should consider maintaining or restoring:

(i) high bunchgrass cover and structure characterized by spatially dispersed bunchgrasses and small gaps between them;
(ii) a diverse assemblage of bunchgrass species to maximize competitive interactions with B. tectorum in time and space; and
(iii) biological soil crusts to limit B. tectorum establishment. Passive restoration by reducing cumulative cattle grazing may be one of the most effective means of achieving these three goals” (Reisner et al. 2013: 1).

Additional research found that cheatgrass and clasping pepperweed (Lepidium perfoliatum, a non-native mustard) out-compete native grasses where vegetative communities are stressed by higher surface temperatures, limited moisture and grazing pressure (i.e., south facing slopes) (Reisner et al. 2015). The U.S. Geological Survey recommends adjusting and even suspending livestock grazing as part of a passive restoration program to maintain and reestablish resilient sagebrush steppe (Pyke et al. 2015).

PROPOSED FINAL RESOURCE MANAGEMENT PLANS/SUB-REGIONAL ENVIRONMENTAL IMPACT STATEMENTS: None of the proposed final sage-grouse plans prescribed grazing management to avoid contributing to cheatgrass invasion, although the Nevada/northeastern California plan included an action to monitor and manage grazing practices to “prevent the establishment of invasive species” (Nevada: 2-30, Action VEG-ISM 1).

While lacking in measures to prevent the spread of cheatgrass, all but two of the proposed plans claim that grazing can reduce fire fuels (i.e., cheatgrass) in sagebrush steppe. Federal land managers could misinterpret such general statements as direction for using livestock as a “tool” for controlling cheatgrass, contrary to evidence. The Humboldt-Toiyabe National Forest is preparing to issue a Record of Decision on the Bi-state Distinct Population Segment Forest Plan Amendment/Final Environmental Impact Statement that includes model language for using livestock as a tool to reduce fire risk from cheatgrass:

Grazing may be used to target removal of cheatgrass or other vegetation hindering [sage-grouse conservation] objectives where monocultures occur to reduce risk of fire and achieve or move toward desired habitat conditions. Sheep, goats, or cattle may be used as long as the animals are intensely managed and removed when incidental utilization of desirable species reaches 25%.

A cattle trail serves as a vector for cheatgrass to invade burned sagebrush habitat in Idaho.

A cattle trail serves as a vector for cheatgrass to invade burned sagebrush habitat in Idaho.

PROTEST RESOLUTION: The BLM issued reports for each responding to administrative protests submitted on the proposed final sage-grouse plans. The agency commonly responded “[t]he BLM has adequately analyzed and disclosed the effects of livestock grazing on native plant communities and invasive species, including cheatgrass” (e.g., Oregon protest resolution: 55; Nevada/NE California protest resolution: 131; Idaho/SW Montana protest resolution: 82). Calls to limit grazing to certain seasons and limit the loss of native perennials were met with promises to perform “site-specific analysis” during implementation (e.g., Northwest Colorado protest resolution: 24-25).

RECORDS OF DECISION: the BLM’s Records of Decision for both the Great Basin and Rocky Mountain regions defer to the underlying approved resource management plan amendments to implement grazing prescriptions in sage-grouse habitat. “Improper livestock grazing” is undefined yet identified as a negative impact on landscape conditions (RM ROD: 1-8; GB ROD: 1-7) and as a hindrance to achieving the habitat objective of maintaining or restoring healthy native perennial grasses (RM ROD: 1-26; GB ROD: 1-24–1-25).

APPROVED RESOURCE MANAGEMENT PLAN AMENDMENTS: While continuing to acknowledge the threat of cheatgrass to sage-grouse, none of the final plans specifically prescribe grazing management to avoid contributing to the spread of cheatgrass in grouse habitat. In fact, the plans defer again to existing rangeland health standards and guidelines for their particular region (e.g., Utah ARMPA: 1-14). These outdated and vague guidelines do not include direction for controlling grazing to avoid the spread of cheatgrass (indeed, if they did, they might have helped to prevent grazing from spreading the invader across sage-grouse range over the last 15 years). All of the final plans would accept a form of “targeted grazing” as a method to contain cheatgrass, a management method that has questionable effects (see above) (some plans do require the BLM to consult with ecologists to strategize use before implementation (e.g., Northwest Colorado ARMPA: 2-9, MD FIRE-12)).

Interestingly, two of the approved management plans adopted a quantitative habitat objective for cheatgrass cover in essential sage-grouse habitat. The Oregon ARMPA includes a habitat objective of less than 5 percent cheatgrass cover within 4 miles of all occupied or pending sage-grouse leks (Oregon ARMPA: 2-10, Obj Veg 3). The Nevada and Northeastern California ARMPA adopted a desired condition of less than 5 percent cheatgrass cover in nesting habitat from April 1 to June 30 (Nevada/NE California ARMPA: 2-4, Table 2-2). None of the other approved plans have a quantitative habitat objective or desired condition for cheatgrass cover.

Mark Salvo is Senior Director for Landscape Conservation at Defenders of Wildlife.

Jamison Shabanowitz is a Renewable Energy and Wildlife Fellow at Defenders of Wildlife.

Posted in Imperiled Wildlife, Public Lands0 Comments

Sage-Grouse Need Sagebrush Reserves

Sage-grouse Need Sagebrush Reserves

The vast Sagebrush Sea in the Intermountain West is one of the least protected ecosystems in the United States. Less than five percent of the landscape receives some level of federal protection as wilderness areas, national parks, national wildlife refuges, national conservation areas, national monuments and similar designations. The lack of protection has contributed to an increasing number of imperiled species in the Sagebrush Sea, most notably the greater sage-grouse. To prevent sage-grouse and other imperiled species from further decline, more sagebrush reserves should be protected from development and other damaging uses.

The federal Bureau of Land Management (BLM) is the caretaker for half of remaining sage-grouse habitat. Public lands managed by BLM are governed by the Federal Land Policy and Management Act (FLPMA) of 1976 (43 U.S.C. § 1701-1787). The law provides few substantive requirements for conservation, though one of them is the identification and designation of “Areas of Critical Environmental Concern” (ACEC) as part of the agency’s resource management planning process. The implementing regulation defines ACECs:

The term “areas of critical environmental concern” means areas within the public lands where special management attention is required (when such areas are developed or used or where no development is required) to protect and prevent irreparable damage to important historic, cultural, or scenic values, fish and wildlife resources or other natural systems or processes, or to protect life and safety from natural hazards. 43 C.F.R. § 1601.0-5(a).

During the resource management planning process, the agency is to “give priority to the designation and protection of areas of critical environmental concern.” 43 C.F.R. § 1601.0-5(a).

The BLM initiated the National Greater Sage-Grouse Planning Strategy in 2011 to update dozens of resource management plans with new measures to conserve sage-grouse on approximately 50 million acres of BLM land. Unfortunately, the draft plans released in 2013-2014 were wholly inadequate to conserve the species  and must be improved to meet the purpose of the planning strategy. However, even if the agency adopts science-based management prescriptions to reduce harm to sage-grouse from development and other effects, we still need strongholds on the landscape that are proactively managed for sage-grouse conservation.

This is why designating ACECs in the sage-grouse planning process is so important. The BLM could create a system of sagebrush reserves with a mission of maintaining and restoring sagebrush habitat and all the species that depend on it, including more than 350 species of conservation concern. ACEC designation can also buy time to adopt and implement other, more durable forms of conservation protections.

A potential ACEC may only be designated if it meets “relevance” and “importance” criteria outlined in BLM regulations. Almost all of the draft plans determined that potential new sage-grouse ACECs met relevance and importance criteria for designation. The draft plan for Oregon, typical of the others, analyzed more than 4 million acres for protection as ACECs, finding that they contained relevant resources, including sage-grouse leks, seasonal habitats, and high quality sagebrush steppe, which are important because sage-grouse are a candidate species for listing and a high priority to the agency. The Northwest Colorado plan analyzed 926,800 acres for potential designation as ACECs and included a series of maps depicting the overlap between the potential ACECs and other important wildlife habitats in the state, including elk and mule deer winter concentration areas, streams with threatened or endangered fish, and suitable habitat for federally protected plants.

Unfortunately, and although the BLM presents a persuasive case for protecting new sagebrush reserves, the draft plans collectively would only designate a few small areas as new ACECs to conserve sage-grouse. The BLM appears to believe that, while new reserves could benefit the species, the proposed management schemes in the selected management alternatives should be sufficient to “protect the relevant and important values… independent of an ACEC designation” (Oregon 4-222).

The process used to analyze ACECs might have prevented planners from recommending additional areas for protection. Most of the draft plans limited their analyses to simply designating all priority habitat within their planning areas as sagebrush reserves (covering more than 44 million acres in the West). The plans did not consider alternative proposals to protect a biologically defined subset of priority habitat as ACECs. The BLM’s all or nothing approach produced a predictable result: planners determined in every case that designating such vast areas of priority habitat as sagebrush reserves was unwarranted and would prevent the BLM from managing for other multiple uses on the affected lands.

This is in stark contrast to other BLM plans that have designated substantial new ACECs for species conservation. The BLM land use plan for the Gunnison Gorge National Conservation determined that ACEC designation was important to conserve Gunnison sage-grouse—even in a national conservation area. In southeastern Oregon, BLM designated the Borax Lake Area of Critical Environmental Concern to help conserve the Borax Lake chub. Increased protections within the ACEC were a contributing factor in the U.S. Fish and Wildlife Service’s recommendation to downlist the species from “endangered” to “threatened” in 2012. And the Las Vegas Field Office in Nevada has designated ten ACECs to protect wildlife habitat, six of which were allocated to safeguard designated critical habitat for federally listed threatened and endangered species, including the desert tortoise; southwestern willow flycatcher; woundfin and Virgin River chub in the Virgin River, and numerous others that occur in Ash Meadows. The desert tortoise ACECs protect 1,097 square miles (702,160 acres) of critical habitat as “desert tortoise ACEC reserves.”

ACEC designation is by no means a conservation panacea. Each ACEC is individually crafted – there are no core substantive requirements for how they are managed. They can also be modified, including de-designated, through future resource management plan amendments and revisions. And sometimes restrictions and management prescriptions that accompany designation are not monitored or enforced, leading to degradation of resources for which the areas were established to protect. Asked during the sage-grouse planning process to designate ACECs for sage-grouse conservation, BLM staff repeatedly claimed that the prescriptions they were developing for managing land use and development in grouse habitat would offer equivalent or even more protection than ACECs would provide.

But we contend ACEC designations do matter. They put a line on a map and a sign in the ground that says “this place is special and needs to be managed for conservation.” ACEC designation helps lay the groundwork for more durable forms of protection in the future. The BLM is authorized under existing law and policy to provide durable protection for lands and resources identified for conservation purposes and compensatory mitigation, including granting rights-of-way (43 U.S.C. §§ 1761(a)(4),(7)), securing easements (43 U.S.C. § 1732(b); 43 C.F.R. § 2920), and executing land withdrawals (43 U.S.C. § 1714(d)(1), § 1702(c)) under FLPMA. These actions, however, would benefit from an ACEC framework that outlines the values targeted for conservation and needed management criteria to preserve them.

The BLM should revisit its ACEC analyses for sage-grouse and consider designating a subset of priority habitat as sagebrush reserves in the records of decision for the final land use plans. A thorough analysis would support designating new ACECs, research natural areas, and similar administrative designations on public lands to conserve sage-grouse and other sagebrush-dependent species.

Posted in Federal Policy, Imperiled Wildlife, Public Lands0 Comments

Threat Multiplier: Climate Change Exacerbates Risks to Sage-grouse

A new study by the U.S. Geological Survey states that “climate change may pose substantial future risk to sagebrush habitat in southwestern Wyoming.”

Climate change is a recognized threat to sage-grouse1 that is also predicted to have deleterious impacts on sagebrush steppe.2  Most climate change simulations predict sagebrush steppe will contract as mean temperatures increase and the frost line shifts northward.3 In the worst case scenario, sagebrush species are simulated to contract to just 20 percent of current distribution.4 Previous studies project that the largest remaining areas will be in southern Wyoming and in the gap between the northern and central Rocky Mountains, followed by areas along the northern edge of the Snake River Plateau and small patches in Washington, Oregon and Nevada.5 Sagebrush steppe may also shift northward in response to increased temperatures.6

The new research by the U.S. Geological Survey is notable because the scientists conducted their study in southwestern Wyoming, finding that climate change is likely to eliminate over 11 percent of sage-grouse nesting habitat in what is otherwise expected to be a stronghold for the species. The authors caution, “[g]iven declining sage-grouse populations are suffering from other habitat degradation forces, a potential additional 11% loss of future habitat from climate change could be very detrimental to some populations.”

Defenders of Wildlife evaluated (see pages 28-29 in linked report) if and how draft federal conservation plans developed under the National Greater Sage-Grouse Planning Strategy addressed climate change impacts on sage-grouse. All of the draft plans acknowledged that climate change presents challenges to resource management, and many listed climate change as a planning issue to be addressed in management alternatives. Several plans specifically identified sage-grouse as a species that may be harmed by climate change, including the HiLine Draft Resource Management Plan and Environmental Impact Statement. “[S]ensitive species in the planning area, such as greater sage-grouse, which are already stressed by declining habitat, increased development, and other factors, could experience additional pressures due to climate change” (HiLine 260; 434).

Yet, only two of fifteen draft plans proposed more than marginal conservation measures to preserve or restore habitat resiliency in areas where scientists predict sagebrush steppe will still persist in 50-100 years. In fact, in four plans (including the plan covering southwestern Wyoming), the Bureau of Land Management claimed it had “no…resource planning program for addressing [climate change] effects to [sage-grouse] and its habitat.” This is untrue. The agency is required under existing law and policy to consider the best available science in management planning (which would include analysis of climate change effects), and is specifically required to address climate change in planning under Secretarial Order 3289, Department of the Interior Manual chapter 523, and Executive Order 13653, among other guidance.

Measures for ameliorating the effects of climate change on species and landscapes include increasing the size and number of protected areas, maintaining and enhancing connectivity between areas, and identifying and protecting climate refugia likely to retain suitable climate/habitat conditions in the future (even if not currently occupied by the species of concern). Management should also seek to control invasive species, sustain ecosystem processes and functions, and restore degraded habitat to enhance ecosystem resilience to climate change.7

Properly addressing climate change through the Planning Strategy would require federal agencies to analyze the effectiveness of their proposed conservation actions in light of climate change impacts and make appropriate modifications to ensure they are effective over the long-term. Proper analysis of climate change would also require agencies to examine the cumulative environmental consequences of their proposed actions in a changed climate as their baseline for analysis. For example, the impacts of habitat disturbance may be more pronounced when combined with the effects of climate change (as the draft HiLine plan indicated), which could lead agencies to different management decisions about whether, where, how much, and in what manner development activities should occur.

This is in fact the take away from the new USGS study: if we can expect upwards of an 11 percent loss of important sage-grouse habitat due to climate change, agencies should increase protections from other disturbances we can control now to give sage-grouse a fighting chance in the future.

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1 Connelly et al. 2011b: 556, Table 24.2; Blomberg et al. 2012; van Kooten et al. 2007.
2 Schlaepfer et al. 2012; Neilson et al. 2005.
3 Blomberg et al. 2012; Neilson et al. 2005.
4 Wisdom et al. 2005b: 206, citing Neilson et al. 2005.
5 See Miller et al. 2011: 181, Fig. 10.19.
6 Schlaepfer et al. 2012; Shafer et al. 2001.
7 Chester et al. 2012; NFWPCAS 2012.

Posted in Climate Change, Imperiled Wildlife, Public Lands0 Comments

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Sage-grouse, Grazing Management, and Voluntary Permit Retirement

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Livestock grazing can negatively affect riparian areas that are important to sage-grouse and other wildlife in the West. Oregon Natural Desert Association

At least 26 land uses and related effects threaten sage-grouse, none more pervasive than domestic livestock grazing. The Bureau of Land Management (BLM), the largest landowner in the American West, administers approximately 18,000 grazing permits and leases to graze almost 13 million animal unit months on 160 million acres of public lands, including large swaths of sage-grouse habitat. The U.S. Forest Service also permits grazing on millions of acres of sage-grouse range. More than 99 percent of remaining sagebrush steppe has been affected by livestock and approximately 30 percent has been heavily grazed.

Grazing can negatively affect sage-grouse in a variety of ways1 and livestock management was an identified planning issue in each of the fifteen draft plan amendments and sub-regional environmental impact statements (plans) developed under the federal National Greater Sage-Grouse Planning Strategy.

In March, conservation organizations sent a letter to the Departments of the Interior and Agriculture urging the BLM and the Forest Service to adopt adequate regulatory mechanisms in the final plans to manage grazing to avoid harming sage-grouse—and to immediately incorporate them into grazing permits as terms and conditions for grazing use on associated grazing allotments. Current law allows both agencies to update grazing permits in the land use planning process, rather than wait to implement the new measures over many years as each 10-year permit comes up for renewal.

The organizations also recommended that federal agencies adopt measures to facilitate voluntary grazing permit retirement on allotments in sage-grouse habitat. While every one of the draft plans developed under the planning strategy would continue livestock grazing in sage-grouse range, most of them also recognized the benefits of eliminating grazing to conserve the species.2

In fact, all fifteen draft plans analyzed voluntary grazing permit retirement as a mechanism for conserving the species in at least one management alternative. Nine of them included some form of voluntary grazing permit retirement in their preferred alternatives (typically limited to priority habitat areas),3 including the now final Resource Management Plan for the Lander Field Office.4

Federal agencies are increasingly using voluntary grazing permit retirement to resolve grazing conflicts on public lands. Willing permittees are usually compensated by a third party to relinquish their grazing permits for retirement, typically by a conservation or sporting organization or other public lands user group.

Voluntary grazing permit retirement may be a particularly useful tool in sagebrush habitat mitigation programs, which could also provide the funds needed to facilitate retirement. Permit retirement offers measureable, and durable conservation benefits that comport with the U.S. Fish and Wildlife Service’s Greater Sage-Grouse Range-Wide Mitigation Framework (2014) and the Department of the Interior’s A Strategy for Improving the Mitigation Policies and Practices of The Department of the Interior (2014).

The BLM and Forest Service can improve voluntary grazing permit retirement provisions in the final sage-grouse plans. Many of the preferred alternatives in draft plans that would allow for grazing permit retirement also imposed extra conditions that could hinder retiring permits in practice. For example, some plans would require land managers to prepare additional (and unnecessary) analysis before determining whether to retire permits voluntarily relinquished by grazing permittees. Others would allow managers to accept permits for retirement, but then convert the associated grazing allotments into reserve allotments or grass banks for future grazing use, potentially diminishing their conservation value.

The BLM and Forest Service should adopt a simple, straight-forward provision in the Records of Decision for sage-grouse plans that would immediately retire grazing permits in priority habitat for sage-grouse wherever and whenever ranchers might decide to relinquish them. Doing so would be a win-win for wildlife and willing grazing permittees alike.

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1 Livestock grazing is considered the single most important influence on sagebrush habitats and fire regimes throughout the Intermountain West in the past 140 years (Knick et al. 2005: 68). Grazing remains the most widespread use of sagebrush steppe and almost all sagebrush habitat is managed for grazing (Connelly et al. 2004; Knick et al. 2003; Knick et al. 2011). Livestock grazing disturbs the soil, removes native vegetation, spreads invasive species and limits productivity in sagebrush steppe (Knick et al. 2005; Knick et al. 2003; Reisner et al. 2013; West 1983). Cattle or sheep grazing in sage-grouse nesting and brood-rearing habitat can negatively affect habitat quality; nutrition for gravid hens; clutch size; nesting success; and/or chick survival (Connelly and Braun 1997; Beck and Mitchell 2000; Barnett and Crawford 1994; Coggins 1998; Aldridge and Brigham 2003). Livestock may directly compete with sage-grouse for grasses, forbs and shrub species; trample vegetation and sage-grouse nests; disturb individual birds and cause nest abandonment (Vallentine 1990; Pederson et al. 2003; Call and Maser 1985; Holloran and Anderson 2005; Coates 2007).

Grazing management was identified as a threat to sage-grouse by three expert panels and in recent reviews (Connelly et al. 2011b: 555-556, Tables 24.1, 24.2). Impacts attributable to historic or heavy grazing in sage-grouse habitat have not been remedied because plant communities are still not given rest from grazing, even under ecologically oriented grazing schemes (Connelly et al. 2004: 7-30 – 7-31, citing others). Furthermore, water developments have increased the area that can be grazed, increasing the distribution and often the intensity of grazing, so that even where livestock numbers have been reduced, they still exert a significant influence on those habitats (Connelly et al. 2004: 7-33). “Even though livestock numbers [are] considerably [reduced from historic use], and management across the West has steadily improved, acres continue to transition away from reference (historic, potential, and [or] desired) conditions” (Manier et al. 2013, citing Cagney et al. 2010). Federal government scientists have suggested that “livestock grazing across the public lands of western landscapes … will continue to impact the quality of those habitats and their ability to support source populations of sagebrush bird species” (Rich et al. 2005: 592).

2 The BLM has identified multiple benefits of eliminating livestock grazing in draft sage-grouse plans, including in the draft Northwest Colorado plan: “[e]limination of livestock grazing…would maintain or improve overall watershed health and water quality…decrease hoof compaction of soil surfaces. When combined with the annual freeze-thaw cycle, this may decrease soil bulk density and improve soil moisture conditions, which facilitates vegetation germination and root development. Removing livestock would also increase plant litter and live vegetative ground cover, which would provide more protection from wind and water erosion. Eliminating livestock grazing…would also eliminate water quality impacts associated with the deposition of manure and urine into surface water (Northwest Colorado: 776). As the agency stated in its draft supplement to the Bighorn Basin plan, “even where sagebrush steppe evolved with some herbivory, removing livestock from the landscape would be a net benefit for sage-grouse” (Bighorn Basin Supplemental ES-9, 4-76, emphasis added).

3 The draft Billings and Pompey’s Pillar National Monument (2-116 – 2-117, Table 2-6.2), HiLine (68), Idaho and Southwestern Montana (alternative D, vol. 2, 2-137, Table 2-18, D-LG/RM-7), Miles City (2-50, Table 2.1, Action 24), Nevada and Northeastern California (ch. 2, 207, Table 2-5, Action D-LG 23), Oregon (2-86, Table 2-6, D-LG/RM 26), South Dakota (37) and Wyoming (2-182, Table 2-5) plans include some form of voluntary grazing permit retirement in their preferred alternatives. Six plans considered voluntary grazing permit retirement in management alternatives other than the preferred alternative, including the Bighorn (Bighorn Basin Supplemental EIS: 2-35, Alternatives E and F); Lewistown (2-35, Table 2-4, Alternatives B and C); North Dakota (2-29, Table 2-3 (Alternatives B and C); Northwest Colorado (159, Table 2-4, Alternatives B and C); and Utah (2-83, Table 2-1, Alternatives B and C2) plans. The draft Buffalo plan proposed designating and managing “resource reserve” allotments in the preferred alternative (169, Table 2.31, Grazing-6020), which the BLM indicated in the draft Northwest Colorado plan could be created through voluntary grazing permit retirement (736).

4 Lander ROD: 98, Record 606. The Record of Decision for the Lander plan also defines grazing permit “retirement” as “[e]nding livestock grazing on a specific area of land” (i.e., the associated grazing allotment) (Lander ROD: 175).

Posted in Federal Policy, Imperiled Wildlife, National Forests, Public Lands0 Comments

Scientists Warn Federal Government of Failed Sage-grouse Conservation Plans

Even as Congress threatens to meddle again in sage-grouse conservation, the Bureau of Land Management and U.S. Forest Service are moving forward on their unprecedented planning process to protect and recover the species on more than 60 million acres of public land. Credit to the agencies—it’s difficult to do one’s job with legislators scrutinizing your every step. But there are also some problems with the planning process that are entirely the agencies’ doing. Last week independent sage-grouse scientists highlighted those problems in a letter to Secretary of the Interior Sally Jewell and Secretary of Agriculture Tom Vilsack that may be pivotal to the future of the species. The scientists’ letter, endorsed by 11 experts on sage-grouse and sagebrush habitats, notes that draft conservation plans produced as part of the National Greater Sage-Grouse Planning Strategy do not correspond with the best available science, and so may fail to conserve the species and its habitat. As the scientists clearly, concisely stated, there are just some basic measures that management plans must adopt if they are to successfully protect and recover sage-grouse:

  • Protect sage-grouse breeding, nesting and brood-rearing habitats from oil and gas drilling and other development. It is well known that oil, gas and grouse don’t mix.
  • Ensure that livestock grazing is managed to allow for tall grasses and other vegetation to provide cover for sage-grouse hens and chicks from predators. Sage-grouse evolved with golden eagles, ravens and coyotes, but they need healthy habitat with lots of places to hide.
  • Do not purposefully burn, plow, spray or otherwise eliminate sagebrush habitat. There’s less and less of the Sagebrush Sea left every year for sage-grouse and hundreds of other wildlife. We’ve got to protect what’s left of the landscape.

The scientists’ letter affirms Defenders of Wildlife’s own assessment of the planning process last spring, finding that key management prescriptions in the draft plans fell short of what science recommends for conserving sage-grouse. The agencies’ failure to adopt these measures is perplexing to say the least, since the BLM itself has identified them as being important for the species’ persistence.

Fortunately, there is still time for federal planners to improve conservation plans for the grouse, and we understand that the agencies are working to strengthen certain measures in the final plans. But the finals can’t merely be better than the drafts—they’ve got to include all of the science-based standards included in the scientists’ letter if they are to achieve their purpose of conserving sage-grouse and their habitat. The Bureau of Land Management and Forest Service are expected to release final plans this spring, when they will be subject to another round of public input. Armed with the scientists’ letter, Defenders of Wildlife and our partners will once again weigh in with recommendations to improve conservation measures for this iconic bird and the quintessential western habitat that it represents.

Posted in Energy, Imperiled Wildlife, Public Lands, Uncategorized0 Comments

sage-grouse_1_Tatiana_Gettleman

BLM Backsliding on Best Available Science

sage-grouse_1_Tatiana_GettlemanGreater sage-grouse are in trouble and may be proposed for listing under the Endangered Species Act by September next year. This pending deadline has prompted the Bureau of Land Management (BLM) to initiate an unprecedented effort to update dozens of resource management plans with new conservation measures for the grouse and potentially preclude the need to list the species. But now this promising planning process could fall short of its goal, simply because the BLM has declined to follow the best available science on sage-grouse and its habitat.

The BLM (with the Forest Service as cooperating agency) initiated the National Greater Sage-Grouse Planning Strategy in 2011. The first step was to convene a National Technical Team (NTT) comprised of 23 federal and state agency biologists and land managers (including 14 BLM officials) to review the extensive scientific record on sage-grouse and develop a report recommending conservation measures for the species. The team issued “A Report on National Greater Sage-Grouse Conservation Measures” six months later. BLM guidance instructed planners to analyze NTT report recommendations in at least one management alternative in draft conservation plans for sage-grouse.

The National Technical Team was unequivocal that the conservation measures in its report were derived from “interpretation of the best available scientific studies” using their “best professional judgment.” Moreover, more than 100 scientists described the NTT report to former Secretary of the Interior Ken Salazar as a “comprehensive compilation of the scientific knowledge needed for conserving Sage-Grouse” that “offers the best scientifically supportable approach to reduce the need to list Sage-Grouse as a Threatened or Endangered species.”

Unfortunately, the BLM has progressively distanced itself from the NTT report since it was published. While BLM planners did as instructed, analyzing NTT report recommendations in each of the 15 draft plans developed under the planning strategy, they declined to adopt the NTT report as the preferred management alternative in any of them. Rather, proposed conservation measures in the draft plans are based on inferior science-—or no science at all—-and many would be inadequate to conserve and restore sage-grouse populations.

The BLM issued additional guidance last April (link) for how planners could resolve inadequate and inconsistent conservation measures related to certain land use in the draft plans. But this time agency leadership scarcely mentioned the NTT report and some of their recommendations were less protective than the National Technical Team advised. The April guidance also allowed exceptions to scientific recommendations for planning areas in Wyoming. Rather than close priority sage-grouse habitat to new oil and gas development (as the NTT report recommends), planners in Wyoming can adopt less protective measures proffered by the state. As Defenders has previously reported, key components of Wyoming’s “core area” conservation strategy lack scientific support and are unlikely to conserve sage-grouse long-term.

This Wyoming exception may be a prelude to finalization of the federal plans. This month federal and state officials will hold a series of internal meetings to review and compare proposed conservation measures for 14 draft plans (the BLM finalized the first of 15 plans in June). A memorandum organizing these meetings (link) makes no reference to the NTT report and further elevates the role of western states in the federal planning process. Some states have been pressing federal planners to adopt even less protective measures for sage-grouse than what the BLM had proposed in its draft plans.

The BLM now faces a conundrum. The U.S. Fish and Wildlife Service must consider the best available science when determining whether a species warrants listing under the ESA. Because BLM has declined to adopt conservation measures in its own NTT report, their proposed management alternatives are not based on the best available science for conserving and recovering sage-grouse. If the BLM hopes to obviate the need to list the grouse under the ESA, then it must strengthen conservation measures in its draft plans to protect and restore the species. Yet, their national guidance to planners continues to backslide from the best available science represented in the NTT report.

Federal public lands are key to conserving sage-grouse and hundreds of other species that depend on sagebrush habitats. The National Greater Sage-Grouse Planning Strategy is an extraordinary opportunity to proactively plan for sage-grouse conservation and potentially avoid the need to list the species under the Endangered Species Act. Federal planners can still salvage the federal planning process for sage-grouse. The NTT report recommends science-based prescriptions for managing the grouse and its habitat. The BLM should simply follow its own recommendations for conserving sage-grouse to produce final plans that are sufficient to protect and restore the species.

Posted in ESA, Imperiled Wildlife, Public Lands0 Comments

Sage-Grouse in the Crosshairs

It’s “silly season” in Congress. It’s an election year and the legislative session is winding down, which means that certain legislators and special interests have begun to purposefully introduce nonsensical legislation in the House and Senate this summer as part of an endless game of Congressional politics. These bills are not intended to advance public policy, but to force a response from political opponents in an attempt to gain an advantage in elections back home.

Sage-grouse, the charismatic ambassador of the Sagebrush Sea, have recently become a target in this deceptive practice. More than a decade after being petitioned for listing, the U.S. Fish and Wildlife Service will finally consider the sage-grouse for protection under the Endangered Species Act in 2015. The date certain for a listing decision has also prompted federal agencies and western states to engage in unprecedented planning processes to implement new conservation measures to protect the grouse.

Unfortunately, there are some in Congress who just can’t help but politicize wildlife conservation. This month, legislation was introduced in the House and the Senate, euphemistically named “Sage Grouse Protection and Conservation Act,” that would muck up the listing process for sage-grouse by allowing states to bar the federal government from even considering the species for protection for at least 10 years. This bill is bad for sage-grouse, bad for public lands, bad for stakeholders and bad government. Defenders of Wildlife has identified at least seven reasons why Congress should ignore it.

The legislation is bad for sage-grouse. The grouse is suffering from death by a thousand cuts—at least 26 land uses and related factors affect the species. Any Congressional effort to extend the current timeline would subvert the established science-based administrative process the Fish and Wildlife Service uses for determining whether a species warrants protection under the Endangered Species Act. Recent data indicate that sage-grouse populations continue to decline. Given the conservation challenges facing the sage-grouse, a listing determination is overdue.

The legislation is bad for public lands. If we don’t address sage-grouse conservation needs now, then saving the species from potential extinction – which includes conserving its remaining sagebrush habitat, much of which is on public lands – will be even more difficult, expensive and disruptive in the future.

The legislation is bad for landowners who want to work to improve habitat on private lands for sage-grouse, but need federal assistance to do so. Those funds may dry up if the sage-grouse listing decision is delayed for a decade.

The legislation is bad for stakeholders that would like certainty about sage-grouse conservation and the species’ status. Resource developers and landowners can better plan for their own activities in sage-grouse habitat when they know what will be required to protect and recover the species.

The legislation is unnecessary. Current planning efforts are on schedule to finalize conservation plans in time for the Fish and Wildlife Service to consider them in its listing decision in 2015. Resources, timelines and the incentive for these processes are hinged on the current decision deadline. The challenge facing these planning processes is not the need for more time, but greater resolve among federal agencies and western states to do what is required to conserve sage-grouse. The current decision date ensures continued federal and state commitment to conservation efforts.

The legislation is a beachhead for delaying any sage-grouse listing indefinitely. Will the Fish and Wildlife Service actually be allowed to consider the sage-grouse for listing after 10 years? Or will Congress delay listing again?

The legislation is a bad precedent. The Endangered Species Act has proven to be overwhelmingly successful in preventing the extinction of species since its enactment 40 years ago. Congress should allow the Fish and Wildlife Service to process species listing decisions under the act in accordance with the best available science. Some species have waited for more than 30 years for agency action. Congress should not further delay these scientific decisions by micromanaging the Endangered Species Act on a species-by-species basis, and undermining important administrative decision-making under the law.

Stay tuned, as we expect to see more silliness from this Congress before the session finally ends.

 

Posted in Imperiled Wildlife, Public Lands0 Comments

New Defenders White Paper: “A Guide to the Farm Bill Conservation Programs”

The U.S. has nearly 1.4 billion acres of private land, much of which is used for forestry, agriculture, or pasture and ranch lands. Over half of all the imperiled species in the country have at least one population on private lands, so measures that help landowners conserve the habitats these species depend on are tremendously important. One of our country’s best tools for helping private landowners enact voluntary conservation programs is the Farm Bill. It authorizes a wide array of programs that provide technical and financial assistance to agriculture and forest producers who are interested in improving soil, water, air and habitat quality on their land.

The most recent Farm Bill, signed into law by President Obama on February 7, 2014, makes a number of important changes to these programs. Defenders of Wildlife’s new white paper, “A Guide to the Farm Bill Conservation Programs,” provides an overview of the major programs and how they are changing under the new Farm Bill. We discuss both the “reserve” programs, which offer easements or rental contracts for long-term to permanent land retirements, and the “incentives” programs, which provide cost-share to improve practices on working lands. We also highlight how these can encourage multiple producers in a state or region to work together to accomplish priority conservation goals. Finally, we explore some of the challenges and opportunities that the new changes will likely bring.

Posted in Agriculture, Paying for Conservation, private lands0 Comments

New Defenders White Paper: “Targeting of Farm Bill Program Funding to Advance Conservation Priorities”

“In the past, much of our conservation efforts in the country have been, I would term it, ‘random acts of conservation.’ Instead of focusing on the hot spots — focusing on areas where we can get the greatest ecological benefit — we have instead had a series of disjointed actions.”
— Harris Sherman, Under Secretary for Natural Resources and Environment at USDA

Conservation programs have been an important part of U.S. farm policy since the Dust Bowl prompted the formation of the Soil Conservation Service in 1935. Public investment in natural resource conservation has expanded tremendously in the past three decades, with a proliferation of Farm Bill programs to address a wide range of issues: erosion, water quality, air quality, wildlife habitat, and more. While these programs have had tremendous benefits, enrollment in conservation programs was initially driven by interest on the part of individual producers, rather than being targeted to the places of greatest need or potential benefit. This “random acts of conservation” approach is beginning to change, however, with the advent of a number of new initiatives aimed at matching program funding to state, regional and national priorities. Defenders of Wildlife’s new white paper highlights the good work of a number of these initiatives, with emphasis on:
• Regional and multi-state wildlife and habitat initiatives
• Regional priority programs for water quality
• Targeting and evaluation mechanisms within individual programs

We also provide recommendations to maximize the benefits of program targeting given the major changes and program consolidations in the new Farm Bill, including urging USDA to:
• Reaffirm its commitment the Working Lands for Wildlife initiative
• Ensure that important conservation goals are not lost under the easement program consolidation
• Think strategically and across programs about how targeting can better be used for maximum benefits
• Balance attention to important existing priorities and novel opportunities under the Regional Conservation Partnership Program
• Incorporate climate change resilience into conservation program delivery
• Fully fund all conservation programs

Posted in Agriculture, Paying for Conservation, private lands0 Comments

dotWild is the blog of scientists and policy experts at Defenders of Wildlife, a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities.

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