August 5, 2019 Jan Cutts District Ranger

California Program Office 980 Ninth Street, Suite 1730 | Sacramento, California 95814 | tel 916.313.5800 www.defenders.org

August 5, 2019

Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport, CA, 93517 Via email to: [email protected]; comments-intermtn-humboldt-toiyabe- [email protected]

Re: Scoping comments on Bridgeport Southwest Rangeland Project

Dear Ms. Cutts;

Thank you for the opportunity to submit scoping comments on the Bridgeport Southwest Rangeland Project. Scoping comments included in this letter are submitted by Defenders of Wildlife (Defenders) on behalf of its 1.8 million members and supporters in the U.S., including 279,000 in California.

Defenders is a national non-profit environmental dedicated to protecting all wild animals and plants in their natural communities. To this end, Defenders uses science, public education and participation, media, legislative advocacy, litigation, and proactive on-the-ground solutions in order to impede the accelerating rate of extinction of species, associated loss of biological diversity, and habitat alteration and destruction.

Project background

The Humboldt-Toiyabe National Forest, Bridgeport Ranger District is preparing an environmental assessment (EA) for proposed cattle grazing on the existing Cameron Canyon, Dunderberg, Summers Meadow, and Tamarack grazing allotments in Mono County, California, which comprise 19,360 acres of federal land. The allotments include a portion of the Hoover Wilderness where livestock grazing is allowed since it was an existing use prior to enactment of the Wilderness Act and its designation in 1964.

The project area includes designated critical habitat for the Sierra Nevada Bighorn Sheep (SNBS), which was listed as endangered under the Endangered Species Act (ESA) in 1999. At that time, the Forest Service began consultation with the U.S. Fish and Wildlife Service (FWS) on domestic sheep grazing authorizations on these allotments due to the risk of disease transmission from domestic sheep to SNBS. As a result of the consultation, the grazing permits were allowed to expire and were cancelled in 2014 due to the high risk of disease transmission and its impact on survival of SNBS.

The grazing permitees appealed the decision to cancel the grazing permits in 2014 and entered into a settlement agreement with the U.S. Forest Service in 2015. The settlement agreement stipulated that the U.S. Forest Service would conduct an environmental analysis of the effects of converting the allotments for use by domestic cattle and issuing permits to the affected grazing permittees which have filed applications for permits to graze domestic cattle. However, the settlement agreement does not commit the U.S. Forest Service to issue grazing permits, and it retains its authority to not issue permits based on the outcome of the environmental analysis.

Scoping comments

Scoping comments from Defenders on the proposed Bridgeport Southwest Rangeland Project are as follows:

1. National Environmental Policy Act (NEPA) – Range of Alternatives: NEPA requires federal agencies, including the U.S. Forest Service to “rigorously explore and objectively evaluate” a range of reasonable alternatives to proposed federal actions.” See 40 C.F.R. §§ 1502.14(a) and 1508.25(c), including the mandatory alternative of no action.

Reasonable alternatives analyzed should be those based on resource occurrence and sensitivity, with a goal of avoiding or minimizing impacts by modifying the extent and location of a proposed project size and location accordingly.

2. Toiyabe National Forest Land and Resource Management Plan (LRMP), as amended: The Toiyabe LRMP includes amendments stemming from the 2004 Sierra Nevada Forest Plan Amendment (SNFPA) and the 2016 Greater Sage-grouse Bi-State Distinct Population Segment Forest Plan Amendment (Bi-State Amendment). The amended LRMP provides management direction, goals, objectives and desired future conditions for all lands and resources within the Toiyabe National Forest, including sensitive species and their habitats, and water quality.

The environmental analysis for the proposed project should clearly state the management direction, goals, objectives and desired future conditions for all lands within the grazing allotments, their listed and sensitive species and habitats, their current condition and trend, as

National Headquarters | 1130 17th Street, N.W. | Washington, D.C. 20036-4604 | tel 202.682.9400 | fax 202.682.1331 | www.defenders.org well as water quality and water quality objectives from the Lahontan Basin Plan of the State Water Quality Control Board. Of note, critical habitat for three federal listed species is found in the analysis area, and habitat for the bi-state DPS of greater sage grouse is also found in the analysis area. As the agency is aware, the U.S. Fish & Wildlife Service was ordered by a federal court to re-consider its decision not to list the bi-state sage grouse and will do so by October 1, 2019.

3. Impact Analysis: Although the U.S. Forest Service concluded that all LRMP goals, objectives and desired conditions had been met when the domestic sheep permits were cancelled in 2014, the effects of cattle grazing are well documented to be different than those of domestic sheep on meadows, wetlands, riparian areas and near water sources, and thus the analysis must be specific to cattle-grazing. Unless excluded from or actively herded, cattle typically occupy meadows, wetlands and riparian areas where they obtain forage, water and shelter; and their much larger size and weight compared to domestic sheep results in greater hoof pressure on soils. This increased hoof pressure has the potential to cause higher soil compaction, higher precipitation runoff and soil erosion. These potential impacts should be thoroughly analyzed in the environmental analysis. Cattle grazing could also directly damage Threatened Yosemite toads, poses risks to the Endangered Sierra Nevada bighorn sheep and may adversely impact sage grouse habitat, including lekking areas.

The environmental analysis should include an analysis of the proposed project on surface waters and their quality both within and downstream of the subject grazing allotments. The analysis should be based on the water quality objectives and beneficial uses as stated in the Lahontan Basin Plan.

The Notice of Proposed Action for the project identifies issues that have been raised by the public during previous scoping opportunities. We note that for nearly all those issues, including those involving potential for adverse impacts to sensitive species and their habitats, and water quality, the U.S. Forest Service responded that, “Grazing management under the proposed action, reflecting Forest Plan and other management direction, would preclude notable adverse impacts…” By assuming such adverse impacts would not occur or be negligible simply because the Toiyabe LRMP would prevent them from occurring is inappropriate and inconsistent with the abundance of documented adverse impacts from cattle grazing to subalpine meadow, stream and spring habitats. That is akin to assuming that motor vehicle speeds would not exceed the legal limit simply because speed limit signs are in place on streets and highways.

The impact analysis must also consider the capability of the U.S. Forest Service to monitor and enforce mitigation measures designed to prevent and minimize adverse impacts to listed and other sensitive species and their habitats, as well as meadows, wetlands and riparian habitat favored by cattle. Furthermore, relying on range-riders to herd cattle away from these areas National Headquarters | 1130 17th Street, N.W. | Washington, D.C. 20036-4604 | tel 202.682.9400 | fax 202.682.1331 | www.defenders.org would likely require their services on a full-time basis throughout the proposed grazing season and in sufficient numbers to be effective. Based on Defenders’ experience in the field in cattle grazing allotments, we doubt the U.S. Forest Service has the capability and the livestock operators have the means to deploy range-riders sufficient to ensure that goals and objectives for all biological resources would be met.

The impact analysis should be based on impacts observed on similar active grazing allotments in the Eastern Sierra Nevada having Endangered, Threatened and sensitive species, especially those with meadows, wetlands, streams and riparian habitats.

Lastly, the purpose of analyzing the impacts of a proposed federal action through an environmental assessment is to determine if the adverse impacts remaining after applying mitigation measures would be significant. If so, then an Environmental Impact Statement would be required. Given the abundant evidence of significant impacts resulting from cattle grazing in the higher elevation habitats of the eastern Sierra Nevada, including meadows, wetlands, water quality, as well as habitats for species listed under the Endangered Species Act, Defenders recommends that the U.S. Forest Service prepare an Environmental Impact Statement for the proposed grazing project.

4. Mitigation Measures: If the Forest Service decides to proceed with authorizing cattle grazing in these allotments, an extensive array of mitigation measures designed to avoid and minimize impacts will be required. Such measures should not simply include adaptive management based on monitoring and subsequent corrective actions. Mitigation measures must be developed and implemented in order to avoid and minimize adverse impacts on a proactive basis. Further, for significant impacts that can’t be avoided, compensatory mitigation must be required.

Mitigation measures should be developed in consultation with scientific experts on the listed species and also should be based on literature reviews and from measures implemented on other active cattle grazing allotments in similar environments in the Eastern Sierra Nevada.

These mitigation measures need to be included in the environmental analysis so that the public can review and comment on them, and not left to some speculative future after a decision has been made to authorize grazing on the allotments.

5. Diseases of domestic cattle: The Environmental Assessment for the proposed Bridgeport Southwest Rangeland Project should identify and analyze the potential for transmission of diseases harbored by domestic cattle to SNBS.

Field research and associated reports on the potential for transmission of diseases from domestic cattle to desert bighorn sheep in various mountain ranges in the Mojave Desert of California have identified two gnat-borne viruses causing hemorrhagic diseases (bluetongue

National Headquarters | 1130 17th Street, N.W. | Washington, D.C. 20036-4604 | tel 202.682.9400 | fax 202.682.1331 | www.defenders.org and epizootic hemorrhagic disease), one influenza virus (parainfluenza-3), a pox virus (contagious ecthyma), and Mycoplasma spp. of the Pasteurellaceae bacterial family, particularly M. ovipneumoniae. M. ovipneumoniae has been implicated in causing high mortality in bighorn sheep populations due to pneumonia, and has the potential of being transmitted from domestic cattle to bighorn sheep. Bighorn become susceptible to pneumonia, which is usually a secondary infection in a virus-initiated disease process.

Refer to the following for details regarding potential for disease transmission from domestic cattle to bighorn sheep: Wehausen, J. and M. Hansen. 1986a; Wehausen, J. and M. Hansen. 1986b; Wehausen, J. 1990; Wolf et al. 2010; Wehausen, J.D., V.C. Bleich, B. Blong, and T.L. Russi. 1987; DeForge, J.R., and J.E. Scott. 1982; Drew, M.L., K.M. Rudolph, A.C.S. Ward, and G.C. Weiser. 2014.

6. Endangered Species/Endangered Species Act: The Notice of Proposed Action for the project identifies several species listed under the Endangered Species Act (ESA) that occur within and adjacent to the allotments and may be impacted by cattle grazing. These species are 1) Sierra Nevada bighorn sheep (Endangered) and its designated Critical Habitat, 2) Sierra Nevada yellow-legged frog (Endangered) and its designated Critical Habitat, and 3) Yosemite toad (Threatened).

The ESA includes two mandates for federal agencies:

1. Section 7(a)(1) states that “…Federal agencies shall, in consultation with and with the assistance of the Secretary, utilize their authorities in furtherance of the purposes of this Act by carrying out programs for the conservation of endangered species and threatened species listed pursuant to section 4 of this Act.”

2. Section 7(a)(2) states that “Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency (hereinafter in this section referred to as an “agency action”) is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species which is determined by the Secretary, after consultation as appropriate with affected States, to be critical, unless such agency has been granted an exemption for such action by the Committee pursuant to subsection (h) of this section.”

The goal of the ESA is to recover listed species, not manage them to simply avoid jeopardizing their continued existence or to avoid destroying or adversely modifying their critical habitats. Legally, Section 7(a)(1) is independent of the Section 7(a)(2) responsibility. However, long-term practices of federal agencies to simply focus on and comply with Section 7(a)(2) responsibilities has resulted in hundreds of species remaining in long-term decline despite having been listed National Headquarters | 1130 17th Street, N.W. | Washington, D.C. 20036-4604 | tel 202.682.9400 | fax 202.682.1331 | www.defenders.org for many years.

We recommend that the range of alternatives for the proposed project include one that is based on actions deemed necessary to recover the listed species within the grazing allotments and to prevent destruction or adverse modification of their critical habitat. Such an alternative would align with the Section 7(a)(1) mandate of the ESA. The recovery plans for the listed species within the grazing allotments should be used in developing a listed species recovery alternative to the proposed project, as well as coordination with the U.S. Fish and Wildlife Service and California Department of Fish and Wildlife. Furthermore, the conservation actions included in such an alternative would enable the U.S. Forest Service to include them in its ESA Section 7 consultation with the U.S. Fish and Wildlife Service under Section 7(a)(2), ensuring compliance with the mandates of the ESA, including actions that contribute to the conservation and recovery of the listed species.

7. Grazing in Wilderness Areas: Section 1133(d)(4)(2) of the Wilderness Act provides in relevant part that “the grazing of livestock, where established prior to September 3, 1964, shall be permitted to continue subject to such reasonable regulations as are deemed necessary by the Secretary of Agriculture.

Livestock grazing occurring within the Hoover Wilderness at the time the Wilderness Act became law was by domestic sheep. No Term Grazing Permits for cattle have been issued in the affected allotments after the establishment of the Forest, which preceded the Wilderness Act and establishment of the Hoover Wilderness. Since the allotments were grazed by domestic sheep, the environmental analysis should address the issue of changing the classification of the allotments as available for cattle grazing and if this proposed change is allowed under provisions of the Wilderness Act.

8. Literature Cited:

DeForge, J.R., and J.E. Scott. 1982. Ecological investigations into high lamb mortality. Desert Bighorn Council Transactions. 26:65-76.

Drew, M.L., K.M. Rudolph, A.C.S. Ward, and G.C. Weiser. 2014. Health status and Microbial (Pasteurellaceae) Flora of Free-ranging Bighorn Sheep Following Contact with Domestic Ruminants. Wildlife Society Bulletin 9999. http://www.idahowildsheep.org/2015/Drew_et_al_2014_Health_status_bighorn_sheep_follow ing_contact_with_domestic_sheep.pdf.

Wehausen, J. and M. Hansen. 1986a. Impacts of cattle grazing on bighorn sheep. White Mountain Research Station, University of California. Final report completed under Interagency Agreement No. C-913 with the California Department of Fish and Game. Bishop, CA. 29 pp. +

Wehausen, J. and M. Hansen. 1986b. Impacts of cattle grazing on bighorn sheep. White Mountain Research Station, University of California. Final report completed under Interagency Agreement No. C-913 with the California Department of Fish and Game. Bishop, CA. 29 pp. + attachments.

Wehausen, J.D., V.C. Bleich, B. Blong, and T.L. Russi. 1987. Recruitment dynamics in a southern California mountain sheep population. J. Wildl. Manage. 51:86-98.

Wehausen, J. 1990. Cattle impacts on mountain sheep in the Mojave Desert: Report III. White Mountain Research Station, University of California. Final report completed under Interagency Agreement No. FC-7468-A1 with the California Department of Fish and Game. Bishop, CA. 61pp.

Wolf et al. 2010. A bighorn sheep die-off in southern Colorado involving a Pasteurellaceae strain that may have originated from syntopic cattle. Journal of Wildlife Diseases, 46(4), 2010, pp. 1262–1268.

9. Conclusion: Defenders understands the settlement agreement specifies that the U.S. Forest Service will prepare an environmental analysis of effects of the proposal to authorize cattle grazing on currently vacant allotments (i.e., Dunderberg, Cameron Canyon, and Tamarack); and that it will make a decision to authorize or deny cattle grazing permits based on the findings in the environmental analysis.

These allotments support several listed and sensitive species on diverse habitats ranging from meadows, wetlands, riparian areas, and uplands comprised of sagebrush, aspen and bitterbrush. Our experience in the field indicates federal agencies, including the U.S. Forest Service, lack sufficient staff to effectively monitor and enforce all the required terms and conditions in grazing permits, especially in highly sensitive environments such as higher elevations of the eastern Sierra Nevada. This limitation typically results in substantial and widespread degradation of lands and resources within allotments, including sensitive biological resources.

Given the above as well as other comments in this letter, we believe an Environmental Impact Statement should be prepared for the proposed grazing project and that the U.S. Forest Service should identify No Action as its preferred alternative.

Sincerely,

Jeff Aardahl California Representative Defenders of Wildlife 46600 Old State Highway, Unit 13 Gualala, CA 95445 [email protected]

Really? Once again the USFS plans to defer to wealthy cattle ranchers and allow them to raise their stock on the land owned by ALL American citizens?

I often wonder, when I can't filter clean water from a lake or stream because it's been defiled by feces from cows that are supposed to be kept away from our waterways by their owners, how those ranchers rate so highly with our government. The cost of many of our backpacking permits are now higher than the annual fees some of these ranchers pay for grazing rights. Rangers have explained, "It's a culture for these wealthy families, that goes back many years." Really? Our climbing club, which is a 'culture' for us, tried to get permission to climb some rocks in Tahoe NF and we were told public lands cannot be used for 'clubs' without special permission, and the stack of applications from citizens for special use permits was backed up about 4 years.

OK. But cattle ranchers have more rights than me? I've paid hundreds of thousands of dollars in taxes over the years, and that money is used to pay USFS salaries and to maintain public lands. Each citizen is an equal owner of the lands the government has been charged to protect for us. We have a right to expect that we can visit our lakes and streams without the risk of trampled vegetation and massive cow pies along the shores.

Last October, while camped in a designated public lands camping area in Point Reyes NP, I awoke at 2am to the sounds of snuffling, snorting and stamping of hooves, while the sides of my tent were fluttering and being pushed this way and that. I poked my head out and saw that I was surrounded by about 100 head of cattle, one with his huge head about a foot and a half from my face.

I got out and sent them running down the beach by waving my arms and shouting, only to have them all return an hour later. The beach was covered with cow dung and the pit toilet had a loose, 2 foot diameter pile right in front of the door. My permits were not free, even though the land is mine. The ranchers who did not maintain their herd did not have to reimburse me. You think this is fair and equitable?

Private enterprises, like ranching, mining and logging, that destroy the environment, endanger native species, and detract from the experiences that American citizens seek, have NO PLACE on our public lands. Ranchers do not have more rights than any other public lands owner.

Keep this in mind when considering the Bridgeport Southwest Rangeland Project proposed for this slice of our American heritage.

Thank you,

Arnold

Do NOT reopen eastern Sierra grazing allotments to the destruction caused by non-native species. The Bridgeport Southwest Rangeland Project will undo all the recovery that has taken place since the closing of this beautiful and fragile area. Dry areas like this do not recover easily. We have enough grazing land for sheep and cattle. Both of these corporate products are devastating our public lands. This has to stop to protect our upland water sources. We do not need more acreage ground up by these ravenous gigantic beasts. I love the variety of subtle colors from sage habitat. I love the fragile little wildflowers. Allowing cattle and sheep into these areas ruins them for decades. Stop doing this to out publicly owned lands.

Bibb

My native state of California contains more endemic species of plants than any other state. It ALSO seems to be fortunate enough to have some people who actually CARE about all living organisms and wish to retain as much of this biodiversity as possible given all the damage humans tend to cause unless they take the time to inform themselves about the bigger picture rather than follow a narrow spectrum of “life.”

Despite the fact that our current “leader” is trying to exploit EVERY LAST RESOURCE FOR MONEY FOR HIMSELF AND OTHERS LIKE HIM – full speed ahead and dam the consequences! – my expectation is that the staff of our California Forest Service respects and values our unique and endangered areas. Not to mention that there is an enormous volume of information about plant-sourced diets being FAR MORE HEALTHY AND LIFE-SUSTAINING than flesh and blood creatures the mass production of which is wasteful and often inhumane to a point of disbelief that “intelligent” beings could engage in such atrocities!

Please say a strong “no” to those who would continue to trample the earth, subsidized by we who pay the taxes and some who TRY to have as light a footprint on the planet as we can!

Thank you.

Bodiford

I am opposed to the renewal of grazing on National Forest lands. In the past it has proven to be detrimental to the land, especially in riparian areas and servers but to help a few at the at the expense of many concerned citizens.

Bridgeport allotment

End all plans for future livestock grazing on the Bridgeport allotment. It's current status has proven to be a huge success as a conservation and public recreation resource.

August 5, 2019

Ms. Jan Cutts District Ranger Bridgeport Ranger District Humboldt-Toiyabe National Forest HC 62 Box 1000 Bridgeport, CA 93517

Submitted via email: [email protected]

RE: Notice of Proposed Action Bridgeport Southwest Rangeland Project

Dear Ms. Cutts:

Thank you for the opportunity to comment on the Humboldt-Toiyabe National Forest’s Proposed Action (PA) for the Bridgeport Southwest Rangeland Project (Project). The Project proposes to reopen old sheep grazing allotments that have not been utilized since 2009 for cattle grazing. It is important to note that cattle have never grazed on these allotments. I have been recreating in the Twin Lakes and Mono Basin areas for over 50 years. I have been a Mono County resident for over 20 years and own a home in Mono City and a cabin at Twin Lakes. I am very familiar with this area. I do not support cattle grazing on any of these allotments. My specific comments are as follows:

• The current PA does not adequately evaluate the impacts of cattle on these areas. Specifically, mitigations do not go far enough to address impacts to fragile high elevation meadow vegetation, seeps, springs and ephemeral creeks that will be significantly impacted by cattle grazing.

• The PA proposes that cattle will be controlled and trailed by “range riders” instead of fences. I find it hard to believe that cattle can be herded and moved in this way. The possibility of individual cattle straying from the rest of the herd seems high which will then result in damage to sensitive areas and recreational user conflicts.

• The allotments span a geographic area from south of the Virginia Lakes Road to southeast of the Twin Lakes basin. The Virginia Lakes and Twin Lakes areas are very popular with a variety of recreationists. Camping, fishing, backpacking, hiking, photography, hunting, approved off highway vehicle use routes, bird watching, wildflower viewing and more are popular in this area. In the past 50 years I have witnessed a sharp increase in the number of people that frequent the area. Cattle grazing would definitely impact all of these recreational activities.

• Endangered and sensitive species depend on these areas as noted in the PA but I do not think the PA has sufficiently evaluated the impacts to these species. I am especially concerned for Sierra Nevada bighorn sheep and impacts from cattle on the availability of sufficient winter forage for them.

• I am concerned that the monitoring described in the PA will not be sufficient to ensure that all of Bridgeport Ranger District’s (BRD) management strategies and requirements of the lessee will be achieved. I have witnessed first-hand destructive ATV use in the Kavanaugh Ridge area every spring with vehicles driving off-road and around snow berms (on fragile, newly emerging spring vegetation) and no apparent enforcement from the BRD.

• I do not believe that cattle grazing and recreational uses are compatible, at least not for the people recreating. In the past, I would frequently go to Buckeye Canyon to hike, fish, and camp. I haven’t been to that area for some time because of the grazing impacts. Most people I know are not interested in recreating in those areas now. This area of the Humboldt-Toiyabe National Forest is a gem and the increase in visitation over the years and diverse activities enjoyed there prove it. Approving these areas for cattle grazing leases will forever change that and our recreating public, which is so important to Mono County’s economic health, will suffer. If the BRD continues to proceed with this proposal to authorize cattle grazing on these allotments, I strongly request that a full Environmental Impact Statement (EIS) be prepared. The fact that cattle have never grazed on these lands and the significant impacts touched on in the PA justify further, in-depth review. Thank you for the opportunity to comment. Sincerely, Cutting

Bridgeport Southeast Rangeland Project

Thank you for accepting comments on this project.

I've been a resident of Mono County since 1971, and the proposed project that that will open pristine meadows to cattle grazing is cause for great concern. These beautiful high country meadows have recovered so well after years of sheep grazing, it would be a tragedy to see them trampled by cows. I know these areas to provide critical habitat for Sage Grouse, Yellow-legged frogs, and numerous species of native wildflowers. With increased recreational visitation in the area, these peaceful places of exceptional beauty are critical to all who venture along these corridors.

The impact to animals and plants will be great, and the thought of domestic livestock introducing invasive species makes me cringe- many of us work diligently to uproot the plants that threaten native plant habitats, and to bring them in is inexcusable.

With the above concerns in mind, I therefore I ask that you complete a full and thorough Environmental Impact Statement.

Thank you again, for considering the negative impact of this project on these beautiful places.

Sincerely,

DesBaillets

The land on which the Bridgeport Southwest Rangeland Project is planned is some of the most beautiful land along the entire length of Highway 395, the main thoroughfare between the Tahoe- Reno area and Yosemite, Mammoth and Mount Whitney. Just east of Yosemite, one of the most visited national parks in the world, the lands between Virginia Canyon and Bridgeport are a major attraction for both professional and amateur photographers.

Ungrazed for the last decade, the natural vegetation is rebounding and it’s becoming ever more beautiful and healthy. Please consider both the importance of allowing natural areas to thrive and the commercial tourist value of these beautiful lands to local communities like Mono Lake and Bridgeport. Please close the Bridgeport Southwest Rangeland Project grazing allotments and mange the land for recreation and wildlife.

Dusheck

Dear Project Directors,

Please complete an EIS with a full analysis of a range of alternatives for this project. Also, has a survey and complete report been completed for:

Rare and endangered plants, insects and mammals?

A breeding bird survey in the spring and summer?

An archaeological survey?

Thank you for this opportunity to comment.

Duvall

August 5, 2019

Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport CA 93517

Letter sent via email: [email protected]

RE. Bridgeport Southwest Rangeland Project: Notice of Proposed Action

Dear Jan Cutts,

As a Mono Basin resident with a lifelong connection to the High Sierra, I submit the following concerns about the 2019 Notice of Proposed Action (NOPA) regarding potential conversion of the Dunderberg, Cameron Canyon, Summers Meadows, and Tamarack allotments to cattle grazing.

First, thank you very much for removing Cattle Creek from the allotments considered for cattle grazing.

Second, I still stand by my comments sent June 7, 2018. I remain strongly opposed to permitting cattle grazing on these fragile high elevation allotments.

Some of the many reasons:

1. In the NOPA, Identification of Issues, within every listed statement, a positive and a negative are given. The positives, like, “Under properly managed grazing, hoof action could roughen soil surfaces and increase infiltration, a positive effect on soil quality,” or “On the other hand, properly managed grazing could increase plant vigor and cover and maintain plant composition, and redistribution of livestock waste across the landscape could increase nutrient cycling, fertility, and plant production,” or “Properly managed grazing could maintain soil and streambank stability while increasing the vigor and diversity of aquatic and riparian plant and wildlife communities,” are long reaches—seemingly far-fetched attempts to balance the negatives with a positive spin. We all know cattle are not native to these ecosystems. They do not belong in these places. Their very presence can’t help but be detrimental and have long-lasting effects on everything in these high elevations.

2. With warming temperatures, these allotments cannot afford to deal with additional stressors, like cattle grazing. USFS must keep the quickly changing climate in mind in every decision made, including this one. Climate cannot be disregarded or not addressed, as suggested in the NOPA.

3. The proposal that “range riders” will successfully manage the cattle in mountainous terrain and keep them in check sounds impossible, time consuming, and expensive. And what about the impacts of the range riders, the horses galloping around on fragile grounds? Where are they going to camp? The horses will graze as well. None of this is accounted for in the NOPA.

4. I worry about the “flexible season of use”—how the “permittee would be able to graze more cattle for a shorter season or fewer for a longer season.” The season would be shorter because of a heavier winter which means the meadows would be wetter and at their most vulnerable. It doesn’t make sense that more cattle would be allowed in these times.

5. I worry, too, that “Monitoring would initially be completed yearly, though it may be less frequent once the BRD was satisfied that permit terms and conditions were being implemented, …” Having witnessed the USFS struggle with maintaining a strong management presence in the field, I’m sure not keeping an eagle eye on the management of the cattle grazing is a recipe for disaster. Even monitoring once a year seems inadequate.

6. Cattle will not only degrade these allotments—fragile subalpine and alpine landscapes with magnificent views, vibrant displays of wildflowers, wildlife, clear springs and streams—but also impact recreational use through this degradation and by their very presence. Recreationalists and cattle are not compatible.

Again, these allotments are very special places in the Sierra Nevada. All four deserve to be well taken care of, not trampled for profit by one at the expense of many.

I urge the Humboldt-Toiyabe National Forest not to proceed with the Bridgeport Southwest Grazing Project. If the Humboldt-Toiyabe decides to proceed, then completing an EIS with a full analysis of a range of alternatives should be required.

Thank you very much for the opportunity to comment.

Sincerely,

Eissler

Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport CA 93517

August 5, 2019

Re: Bridgeport Southwest Rangeland Project Proposed Action

Submitted via email to: [email protected]

Thank you for the opportunity to submit comments on the Notice of Proposed Action (NOPA) for the Bridgeport Southwest Rangeland Project. We previously submitted comments in June of 2018 highlighting the various significant and cumulative impacts of this project and the necessity for an Environmental Impact Statement (EIS). The Forest Service appears to have decided to continue with an environmental assessment (EA) addressing livestock grazing on the Cameron Canyon, Dunderberg, Summers Meadow, and Tamarack grazing allotments, with only modest boundary adjustments and little to no response to our scoping comments.

Necessity to prepare an EIS The considerable and cumulative impacts of the new proposal to issue cattle grazing permits on these allotments warrant the preparation of an EIS (See 40 C.F.R. § 1508.27). Specifically, there is proximity to unique historic and cultural resources (3) and the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973 (9). Furthermore, an EIS would also be consistent with the previous NEPA for grazing in this location. We understand the agency is attempting to streamline their NEPA processes and therefore relying more and more on EAs instead of EISs. We would like to remind the USFS of its obligation under current NEPA regulation and the degree to which this grazing proposal will impact certain resources outlined in section 1508.27 of the NEPA regulations.

There is a legal obligation to respond to an application to graze cattle on these allotments but it is well within the agency’s authority to continue to rest these allotments for an indeterminate amount of time and to possibly deny grazing permits at this time under provisions of the Endangered Species Act. The EIS must consider a range of alternatives that should include, but are not limited to: a no action alternative of no cattle grazing, not authorizing cattle grazing on some of the allotments or portions of the allotments; resting the allotments for at least a ten year period before any new livestock grazing is considered in order to update baseline surveys for rare, sensitive, and listed species; greater protective measures for water resources and species habitat on these allotments; and further limiting the season of use and animals per unit. Furthermore, the

1 environmental analysis must addresses the impacts of new proposed fencing to protected species (bi-state sage grouse, bighorn sheep); the reduction of native forage available for bighorn sheep, mule deer and other species; impacts to water resources, water quality and riparian areas; the spread of invasive weed species; and impacts to recreational resources. These topics are addressed in more detail below.

There have been significant changes to the landscape since sheep grazing ceased over a decade ago. Based on our site visit in the spring of 2018 allotments are moving toward desired conditions as outlined in the Forest Plan and subsequent amendments (Toiyabe National Forest 1986 Land and Resource Management Plan p., IV-4); 2004 Sierra Nevada Forest Plan Amendment, p. 42). There has been a slow recovery of meadow and subalpine systems from previous sheep grazing and it is because this area has been rested that it is moving toward or in some cases, meeting desired conditions.

Allotment boundaries and adjacent lands Boundary adjustments to limit impacts and reduction of allotment sizes should be analyzed in one or more alternatives. We appreciate the exclusion of Cow Creek from the Tamarak allotment. Further boundary modifications to eliminate and adequately buffer critical habitat for Sierra Nevada Bighorn Sheep, Yosemite Toad and Sierra Nevada Yellow Legged Frog are necessary to analyze in an alternative as well. Further, given the USFWSs pending review of listing the Bi-state Sage Grouse as threatened under the ESA it would be prudent to also include an alternative eliminating proposed critical habitat for the grouse. Although we were provided maps for critical habitat and wilderness boundaries well before this comment deadline upon request, we kindly request the Forest post maps available for download to the project website.

Fencing There is no precedent or science to support the assertion in the NOPA that cattle will stay within allotment boundaries with herding as a substitute for fencing. Cattle could easily disperse over ridgelines and access lands managed by Bureau of Land Management and the State of California. Protecting wilderness values is of particular concern for allotments with no fencing in and adjacent to the Hoover Wilderness. In addition, no fence-lines are proposed to separate the Jordan Basin Unit from Lundy Canyon to the south, resulting in cattle traveling into a core area occupied by Sierra Nevada Bighorn Sheep.

There is an inherent conflict with fencing the entire allotments especially because of the core management strategy to reduce or eliminate existing fencing in Bi-State sage grouse habitat, but also because of other impacts to wildlife. The fencing dilemma is another indication of the complexity that warrant an EIS level analysis. Some of the issues with existing and future fencing are further described in our previous scoping comments (June 2018).

Waterways and Monitoring The NOPA acknowledges the potential impact to steams and wetlands but fails to offer an analysis of impacts or offer alternatives via an EIS to exclude cattle from all springs,

2 seeps, wet meadows and other wetlands and buffers in all these allotments. The creeks found within the proposed allotments offer a variety of resources for fish, wildlife and people. These streams are not functioning at risk primarily because they have not been grazed for an extended period of time. Many currently occupied grazing allotments on the HTNF are functioning at risk. Best Available Science on cattle impacts to water quality and their associated bed and banks should be documented in the EIS. Cattle preferentially graze meadows, springs and waterways due to high forage quantity and access to drinking water. In order to ensure proper monitoring in compliance with plan amendments the USFS must provide baseline data on water quality and, if cattle grazing is permitted, require frequent monitoring to measure water quality in these areas, protect water quality, and prevent eutrophication of streams. E. coli are indicators of fecal contamination and therefore can provide accurate assessment of water quality conditions and human health risks. The proposed monitoring of once a year and perhaps even less in the future (NOPA pg 12) is inadequate to ensure standards and guidelines of the 2004 Sierra Nevada Forest Plan Amendment are met.

Season of use A reasonable range of alternatives should include different and shorter seasons of use for these allotments to protect the resources on these allotments. For example, the Jordan Basin Unit, being higher elevation than many of the other allotments will likely have snowmelt and mud conditions during most years well into the summer. The EIS should consider not allowing grazing to commence on this allotment until July at the earliest, in order to reduce impacts on native vegetation, soils and water resources. Reducing the season of use would help to mitigate the significant and unavoidable impacts of cattle grazing.

Recreation The Bridgeport Ranger District is increasingly becoming a recreational district with high use concentrated in the Virginia Lakes and Green Creek areas. Recreational conditions have changed dramatically since the last environmental analysis for grazing over a decade ago. The Recreation Opportunity Spectrum within the existing Forest Plan does not adequately capture the use and resource within the project area. Therefore, please reference 40 C.F.R. § 1508.27 regarding significant impact on the human environment, when deciding whether NEPA warrants an EIS vs. an EA.

In a district that was once primarily focused on extractive use such as mining and grazing, the district must now consider new information on other uses to be compliant with multiple use mandates. The area is popular for camping, fishing, hiking and hunting the fall, as it presents several trail access points to the Hoover Wilderness and Yosemite National Park beyond. There are numerous dispersed primitive campsites within the proposed allotments. The absence of fences in a majority of the allotments adjacent or within recreation sites is an issue that must be addressed, further adding to the degree and complexity to which the human environment of recreation could be in conflict with cattle. The issue of recreation deserves further analysis within the alternatives of an EIS.

The Virginia Creek Fishing Unit is a popular recreational fishing area for non-native

3 game trout and without fences cattle will be allowed to enter waterways. The NOPA does not indicate there will be an analysis of these impacts of cattle grazing in this area on these trailhead access points and recreational activities. It is necessary to discuss the status of visitor use, visitor satisfaction, and progress toward meeting recreation objectives in this part of the Forest. Multiple use opportunities may be better met in this popular area for hiking, camping, fishing, and wildlife viewing, without the addition of cattle grazing. The Forest has worked to increase the quality and quantity of developed and dispersed recreation opportunities and grazing and increased fencing could conflict with recreational values and these efforts.

Also related to recreation, there are a number of homeowners in the Virginia Lake cabins tract that are concerned that free roaming cattle will come close to cabins and damage property. Without fences there is no way to ensure cattle will not be conflicting with cabin owners who pay taxes to use Forest Service land. It has been suggested homeowners will be responsible for fencing cattle out themselves, a burden that should not be placed on homeowners. The issue with cabins and cattle makes this project highly controversial, another consideration in deciding between an EA and EIS.

Public Safety Related to the high recreational use that overlaps with the proposed allotments, public safety is an issue to be analyzed and considered as an unavoidable impact. The lack of fencing within allotments adjacent to roads that are travelled by recreation users pose a risk to public safety, especially for vehicles travelling too fast, or driving at night when cattle are on the road way.

Sierra Nevada Bighorn Sheep Friends of the Inyo supports the actions taken by the Forest Service to protect Sierra Nevada Bighorn Sheep from disease transmission by permanently canceling the domestic sheep permits on these allotments. Proposed grazing allotments are within the Northern Recovery Unit for the Sierra Nevada Bighorn Sheep, a federally protected species. The Green Creek and Twin Lakes units contain suitable habitat where CDFW have observed animals in the past, and could be important areas for population expansion to reach recovery levels. The Mount Warren Unit overlaps the Jordan Basin and Dunderberg Allotments. This bighorn herd unit is considered essential for survival and recovery of the Sierra Nevada bighorn sheep as a whole. Between 2003-2016 there have been multiple sightings of sheep within the Jordan Basin Unit, the western edge of the Dunderberg Allotment, and the high crest of Monument Ridge inside the Cameron Canyon Allotment, towards Summers Meadow. Lundy Canyon just to the south of Jordan Basin is heavily used by Sierra Bighorn sheep. The Recovery Plan states that: “…data on known bighorn sheep locations and predicted spring-summer and rut utilization areas indicate that bighorn sheep are likely to enter the Dunderberg, Tamarack, Cameron Canyon, Rickey (south), Green Creek (BLM), Dog Creek (BLM), Jordan Basin, Summer’s Meadow…allotments at any time of the year, which greatly increases the risk of contact.”

Cattle grazing has the potential, although remote, to negatively impact bighorn populations: cattle are known to carry pathogens that can be transmitted to bighorn sheep,

4 bighorn sheep are known to avoid areas where cattle are present eliminating optimal habitats, reducing foraging efficiency, and cattle contribute to the spread of noxious weeds which outcompete native vegetation, degrade bighorn sheep habitat, and increase fire risk. Bighorn sheep remain at risk of disease from livestock pathogens throughout the West, with authorized grazing on public lands a limiting factor for many populations.

Cattle have been implicated in pneumonia-related die-offs of bighorn sheep, as well as in outbreaks of Bovine Viral Diarrhea and other diseases impacting wild sheep. Bovine respiratory syncytial virus (BRSV) and bovine parainfluenza virus 3 have been identified as co-agents in pneumonia outbreaks in bighorn sheep populations, affecting bighorn herds exposed to primary agents Mycoplasma ovipneumoniae and Mannheimia haemolytica. Mannheimia haemolytica originating in cattle is believed to have been a primary respiratory disease agent in at least one bighorn sheep pneumonia outbreak.1

It is important the environmental team working of this project carefully review the literature on Bighorn sheep and vectors of disease introduction. Wehausen et al. (2011)2 offer a review of the experimental evidence implicating livestock in bighorn respiratory disease. Besser et al. (2012) included a similar literature review, which included those same experiments with cattle.3

We also recommend consultation with CDFW so this project can fully align with future management of SNBS. Sierra Nevada bighorn sheep are subject to management direction contained in FSM 2670. Therefore, the Forest Service must complete a Biological Evaluation to determine the likelihood of harm to bighorn sheep viability (FSM 2672.41). The Forest Service must “ensure that actions authorized, funded, or carried out by them are not likely to jeopardize the continued existence of any threatened or endangered species or result in the destruction or adverse modification of their critical habitats” (FSM 2670.11). It will be critical for USFS to engage with CDFW and USFWS on the preparation of their Biological Evaluation.

Given this data and the provisions of the NEPA and ESA regulations, the district ranger has the authority to decline grazing permits in order to protect this endangered species without a plan amendment, and this should be analyzed in one or more alternatives.

Yosemite Toad Critical habitat designated in 2016 lies just outside the Dunderberg allotment (https://ecos.fws.gov/ecp0/profile/speciesProfile?sId=7255#crithab). While we appreciate the design features (NOPA pg 6), unfortunately the NOPA fails to describe how monitoring will ensure these design features are met, and the proposal to allow cattle to roam free with occasional range rider management and once a year visits from USFS

1 Wolfe, L. Diamond, B., Spraker, T., Sirochman, M., Walsh, D., Machin, C., Bade, D., Miller, M. (2010). A bighorn sheep die-off in southern Colorado involving a Pasteurellaceae strain that may have originated from syntopic cattle. Journal of Wildlife Diseases, 46(4), 1262-8 2 Wehausen, J,D, Kelley T.S., Ramey II, Rob R. (2011). Domestic Sheep, bighorn sheep and respiratory disease: A review of the experimental evidence. California Fish and Game 97(1), 7:24 3Besser, T.E., E. Frances Cassirer F.E., Yamada C., Potter K.A., Herndon, C.,1 William J. Foreyt, W.J., Donald P. Knowles D.P., and Srikumaran S. (2012). Survivial of Bighorn Sheep commingled with domestic sheep in the absence of Mycoplasma ovipneumoniae. Journal of Wildlife Diseases, 48 (1), 168-172. 5 staff, will likely mean these design features are not met in reality. The NOPA asserts that “cattle grazing could potentially have a number of positive and negative effects on these species that this analysis addresses. Properly managed grazing could help maintain the native communities that include and support these species” (NOPA pg 15), but these statements are not backed by any science and there is little to support this assertion in the literature. Furthermore the level of monitoring currently proposed would not allow the agency to effectively assess if the allotments are being properly managed. Given staffing and other constraints, the condition of other allotments on the district do not give us confidence these new allotments will be managed to maintain native communities, let alone support them.

Bi-state Sage Grouse Bi-state Sage-Grouse in this area are managed in the Bodie Population Management Unit (PMU). Jordan Basin, Dunderberg, Cameron Canyon, and parts of the Summers Meadow Allotments contain excellent habitat for sage-grouse and are used by birds year round. Brood-rearing habitat on shrub-meadow edges appeared to be of high quality and recovering from past sheep grazing. We found native grasses and forbs growing well in this ungrazed condition. The Forest lists a few standards and guidelines in the NOPA that reduce impacts of livestock water facilities, yet the Forest does not address the impacts to sage-grouse habitat of grazing meadows and riparian to early seral stages. This contradicts the Bi-State Sage-grouse plan amendment, which states desired conditions for nesting habitat should allow for “[p]erennial grass height provides overhead and lateral concealment from predators,” and “[g]rass forb heights provide lateral and overhead concealment.” (pg. 38). The EIS should reference and adhere to the Bi-state action plan and management plans of the HTNF.

Mule Deer and hunting Proposed allotments contain high quality, heavily used deer habitat. Cattle grazing can deplete mule deer browse and during our field visit we noted mule deer calving sites in Jordan Basin. The NOPA proposes grazing through October 31, nearly a month of overlap with mule deer season which generally runs late September through October (see CDFW hunting regulations). The allotments are within a prized mule deer hunting location and the potential for cattle to disrupt the hunting season and conflict with hunting use in the fall should be analyzed.

Cultural Resources The NOPA acknowledges the presence of prehistoric and historic human use such as stone mortars, lithic scatters, and remains of past ranching activity including aspen carvings and the adverse impact cattle cause to these resources. Aspen carvings, known as Basque arborglyphs are a particular risk because of cattle preference to graze in aspen groves. The documentation and analysis of unavoidable impacts to these sites may warrant an EIS under NEPA regulation (see first paragraph).

Conclusion Because of the great number of valuable resources found within the proposed allotments and the high risk of unavoidable and cumulative impacts to them, we believe that an EIS

6 is needed before issuing any decision on cattle grazing permits for these allotments. Through an EIS process there is an opportunity to present and analyze a variety of alternatives that may give the Forest the flexibility to achieve a resolution to the settlement agreement that causes the least harm to the ecological integrity of the area and balances mixed uses such as grazing and recreation. We also feel this area is worthy of a administratively designated special management area that would allow this area to continue to recover from grazing, provide exceptional recreational opportunities, and move the Forest towards desired conditions. Thank you for considering these comments. Please reach out to us with any questions or concerns as this project moves through NEPA.

Sincerely,

Jora Fogg

Policy Director

I am writing to oppose the re-opening of the Bridgeport allotment to livestock grazing. The area provides habitat for multiple sensitive wildlife species, and a haven for primitive outdoor recreation in a natural and wild setting.

gonzales

Dear USFS,

Concerning the Notice of Proposed Action: Bridgeport Southwest Rangeland Project I think that monitoring should be done annually. I think that aspen groves should be included in the monitoring. Would there be an annual accounting to be sure that the number of head-months was not exceeded? I think that an environmental impact study should be considered. My wife and I, and visiting friends, have traveled many of the roads in the Dunderberg and Jordan Basin areas, we have hiked there and picnic there often.

Thank you, Hawkins

that grazing suitability was not adequately addressed in any of the plans reviewed. AFSEEE's investigation reveals a consistent pattern of problems in the forest plans: (1) failure to document standards or criteria used for determining grazing suitability; (2) failure to make suitability determinations based on "an analysis of the economic and environmental consequences and the alternative uses forgone;" and (3) failure to identify particular land areas suitable for livestock grazing.

Instead of analyzing the "economic and environmental consequences of grazing and alternative uses forgone" as required by the regulations, the typical forest plan, if it addresses grazing suitability at all, narrows its suitability analysis to questions of forage production and steepness of slope. Instead of publishing a map that identifies lands suitable for grazing on a site specific basis, the typical forest plan describes suitability in generic terms such as absolute numbers of suitable acres or the proportion of the total area that is allotted for grazing. ... In the past, the Forest Service has emphasized suitability standards which reflected primarily the physical limitations of livestock rather than the inherent suitability of the land for grazing. For instance, the definitions of "Suitable Range - Livestock" and "Unsuitable Range - Livestock" in the Forest Service Manual refer to steepness of slope and "land that is accessible or can become accessible to livestock."25 In order to comply with the NFMA planning regulations, such criteria must be updated to focus on ecosystem considerations such as presence of sensitive species and habitats, sensitive soils, presence of cultural resources, conflicts with recreation, length of growing season, water quality effects, forest health, cumulative watershed effects, and consistency with natural patterns of disturbance. Heiken D., 1995. RIGHT PLACE -- WRONG ANIMAL: Determining Grazing Suitability Based on Desired Ecosystem Outcomes for the Interior Columbia River Basin. Association of Forest Service Employees for Environmental Ethics. May 1995. https://www.dropbox.com/s/ucw50hhs8xsiz2k/AFSEEE%20Grazing%20Suitability%20Report.d oc?dl=0

Livestock Grazing - Recommendations for Improved Management • The NEPA analysis should provide site-specific analysis of known problem areas in terms of livestock management, and other areas have high ecological value and potential adverse impact from livestock, such as wet meadows, floodplains, and key stream reaches. • Bunch grasses evolved with different kinds of herbivory and are not suitable for livestock grazing. Grazing should be eliminated or grazing seasons should be very short in order to prevent irreversible damage to drought-stressed plants and it will significantly impact the ability of plants to set seeds.

• Please provide for long-term viability of native plants by allowing plants to fulfill their full lifecycle including flowering, seed set, and sexual or asexual reproduction without significant interference by livestock grazing. • "Improving livestock distribution" is not necessarily a good thing because it spreads the effects of livestock to areas that are currently spared the adverse effects of livestock grazing. Improved distribution homogenizes grazing effects and expands the ecological stress caused by livestock grazing. Maybe it would be better to just limit livestock numbers. • Fencing has ecological consequences that should be considered and minimized or avoided when possible. Fences can kill or harm birds and other wildlife. It many cases it may be preferable to just remove livestock from the area. Floyd Reed, retired FS Range staff, says that “fencing is a sign of management failure.” Fencing fragments the forest landscape adversely impacting landscape connectivity and is harmful to wildlife. Fencing is very expensive and difficult to impossible to maintain especially in forested terrain. Fencing is designed to facilitate more intensive commercial livestock management which surveys have shown is not among the values the wider American public holds for public lands. Fencing is for the convenience of a small number of private commercial livestock operators privileged to hold public land grazing privileges at little cost to themselves, but huge costs to other values. Fencing requires gates and cattleguards are often difficult to negotiate by both wildlife and the public. A study released in October 2009 shows that during a seven month period the Wyoming Game and Fish Department documented 146 instances of finding sage-grouse feathers or carcasses on or near a 4.7-mile section of barbed-wire fence. http://world-wire.com/news/0912160001.html. Also, the Colorado Division of Wildlife has prepared a report on the impacts of fences and how to mitigate them. Hanophy, W. 2009. Fencing with Wildlife in Mind. Colorado Division of Wildlife, Denver, CO. 36 pp http://web.archive.org/web/20110101134309/http://wildlife.state.co.us/NR/rdonlyres/20D 5C775-55DD-4C6D-A5CF-C9B83FCEA69E/0/DOWFencingWithWildlifeInMind.pdf. This report asks the important question, “Do you really need a fence?” because “… the best fence for wildlife is no fence at all.” Remember the option of removing livestock instead of building fences. See also, Bryan S. Stevens 2011. IMPACTS OF FENCES ON GREATER SAGE- GROUSE IN IDAHO: COLLISION, MITIGATION, AND SPATIAL ECOLOGY. University of Idaho Masters Thesis. May 2011. (“Increasing terrain ruggedness reduced probability of collision presence, whereas increasing fence length per km2 increased probability of collision. Broad-scale modeling also suggested collision counts per km2 were influenced by distance to nearest active sage-grouse lek, where increasing distance reduced expected collision counts. These data suggest 2 km mitigation buffers around leks in high risk areas may be necessary… ”) • Consider and avoid impacts to wildlife, including big game, ground nesting birds, uncommon plants, pollinators, and aquatic species. Ensure that livestock grazing is not impairing the maintenance of viable populations including well-distributed plant and animal communities with healthy age-class distributions. Focus on species that are

sensitive to livestock grazing such as aspen and other highly palatable plants, and animals that live near the ground such as ground-nesting birds, amphibians, mollusks, etc... Grazing is known to have significant adverse impacts on ground nesting birds. Glenn E. Walsberg 2005. Cattle Grazing in a National Forest Greatly Reduces Nesting Success in a Ground-nesting Sparrow. The Condor Volume 107, No. 3. August, 2005. See also, Sara Jane Wagoner 2011. The Effects Of Spring Cattle Grazing On The Nutritional Ecology Of Mule Deer (Odocoileus Hemionus) In Eastern Washington. Masters Thesis. Washington State University. May 2011. (“Our results suggest that moderate spring cattle grazing in dry-stony ecological sites reduced the amount of digestible nutrients available to mule deer during the year of grazing.”) • Consider and minimize adverse impacts of livestock grazing on pollinators. On June 20, 2014, the White House released a “Presidential Memorandum—Creating a Federal Strategy To Promote the Health of Honey Bees and Other Pollinators.” https://www.fs.fed.us/wildflowers/pollinators/documents/PresMemoJune2014/Presidentia lMemo-PromoteHealthPollinators.pdf, which states “Over the past few decades, there has been a significant loss of pollinators, including honey bees, native bees, birds, bats, and butterflies, from the environment. The problem is serious and requires immediate attention to ensure the sustainability of our food production systems, avoid additional economic impact on the agricultural sector, and protect the health of the environment. … Given the breadth, severity, and persistence of pollinator losses, it is critical to expand Federal efforts and take new steps to reverse pollinator losses and help restore populations to healthy levels.” Further, Section 3 calls for “Increasing and Improving Pollinator Habitat … (e) The Departments of Agriculture and the Interior shall… develop best management practices for executive departments and agencies to enhance pollinator habitat on Federal lands.” A statement released by Bob Periciasepe, Deputy Administrator, Environmental Protection Agency, and Krysta Harden, Deputy Secretary, U.S. Department of Agriculture (USDA), emphasized: “The memorandum also requires federal agencies to lead by example, taking specific measures to substantially expand pollinator habitat on federal lands and to build on federal efforts with public-private partnerships.” https://www.fs.fed.us/wildflowers/pollinators/BMPs/. With this direction, U.S. Department of Agriculture and U.S. Department of Interior, issue this timely and critically needed document, Pollinator-Friendly Best Management Practices for Federal Lands, May 11, 2015. https://www.fs.fed.us/wildflowers/pollinators/BMPs/documents/PollinatorFriendlyBMPs FederalLands05152015.pdf. (“Objective: To reduce the impact to pollinators from livestock grazing. Explanation: Livestock grazing alters the structure, diversity, and growth pattern of vegetation, which affects the associated insect community. Grazing during a time when flowers are already scarce may result in insufficient forage for pollinators. Grazing when butterfly larvae are active on host plants can result in larval mortality and high intensity grazing can cause local loss of forb abundance and diversity. Implementation: The following actions should be considered in rangelands when livestock grazing is present: • Determine which types of pollinators and which pollinator habitat elements are affected by grazing livestock. • Assess if grazing is compatible with the specific needs of target pollinator species on site, including targeted butterfly species. • Prevent trampling ground-nesting sites by implementing practices to minimize hoof action of grazing animals, which causes soil compaction or erosion in pollinator nesting

and shelter patches. • Minimize livestock concentrations in one area by rotating livestock grazing timing and location to help maintain open, herbaceous plant communities that are capable of supporting a wide diversity of butterflies and other pollinators. • Protect the current season’s growth in grazed areas by striving to retain at least 50% of the annual vegetative growth on all plants. • Enhance the growth of forbs to ensure their ability to reproduce and to provide nectar and pollen throughout the growing season by setting grazing levels to allow forbs to flower and set seed. • Leave nearby ungrazed areas to provide reserves for pollinator populations. • Prevent grazing during periods when flowers are already scarce (e.g., midsummer) to maintain forage for pollinators, especially for bumble bee species. • In important butterfly areas, avoid grazing when butterfly eggs, larvae, and in some cases pupae are on host plants. • Consider the needs of pollinators when placing range improvements and structures on the landscape. • Ensure that fencing is adequate and well maintained. • Include protection of pollinator species in grazing management plans.”) • Manage livestock to avoid conflicts with predators. Special attention should be given to facilitate recovery of ecologically functional populations of threatened gray wolves. Some allotments may need to be closed to give predator populations an opportunity to expand thrive while minimizing risks of human conflicts. Where grazing will continue in areas frequented by predators, permitees should be required to take all necessary steps to avoid conflicts and use non-lethal methods to prevent and limit depredation of livestock. See ODFW Non-Lethal Measures to Minimize Wolf-Livestock Conflict, http://dfw.state.or.us/Wolves/docs/ODFW Non-lethal Measures 130719.pdf, http://dfw.state.or.us/Wolves/non-lethal methods.asp • Livestock are naturally prone to cause adverse impacts because they spend a disproportionate amount of time in sensitive areas such as meadows, wetlands, and riparian areas. Livestock don’t move when we want them to. It takes significant resources to ensure that range conditions are monitored and livestock are moved. If the agency and the permittee fail to commit necessary resources for range monitoring and moving animals, livestock grazing should be terminated. UNAUTHORIZED GRAZING: Actions Needed to Improve Tracking and Deterrence Efforts. GAO-16-559: Published: Jul 7, 2016. http://www.gao.gov/assets/680/678292.pdf • Protect springs, streams, and wetlands from the impacts of livestock (and restoration of areas already degraded) are of utmost important because they represent a small subset of the landscape, they provide disproportionately important ecosystem services, and they suffer disproportionate adverse impact from livestock grazing. The adverse effects of livestock on water quality are well documented. Lindsey Myers, Brenda Whited. 2012. The Impact of Cattle Grazing in High Elevation Sierra Nevada Mountain Meadows over Widely Variable Annual Climatic Conditions. Journal of Environmental Protection, 2012, 3, 823-837. doi:10.4236/jep.2012.328097. http://www.scirp.org/journal/PaperInformation.aspx?paperID=21784. • Take to heart current policy requiring agencies to avoid actions that would slow attainment of aquatic objectives (e.g. “do not retard” language in PACIFISH/INFISH and NWFP). Continued livestock grazing with only minor modifications is unlikely to avoid retarding recovery. Riparian vegetation that is ungrazed will provide better shade, better

bank stability, better nutrient cycling. Riparian areas that are grazed will have more erosion, less bank stability, less shade, less tightly coupled nutrient cycles, lower water quality, more soil compaction and faster run-off. “[N]atural restorative processes should be used wherever possible; in fact, natural processes may be sufficient once the degrading influences have been removed. Because the process of restoration is progressive, the criteria of success are not easy to define. The most important point is that ecosystem development should be on an unrestricted upward path.” A.D. Bradshaw 1996. Underlying principles of restoration.. Can. J. Fish. Aquat. Sci. 53(Suppl. 1): 3–9 (1996). http://www.globalrestorationnetwork.org/uploads/files/LiteratureAttachments/353 underl ying-principles-of-restoration.pdf. Other important public policy objectives near streams include protection of beneficial uses of water, conserving ESA listed fish & wildlife, avoiding future listings by maintaining viable populations of native species, and meeting treaty obligations related to fish & wildlife. In most cases this will require excluding livestock from sensitive meadows and streamside areas. Livestock conflicts with water quality goals are highlighted by recent research showing that E. coli bacteria from livestock can survive in stream sediments for months. Anne Perry 2011. E. coli: Alive and Well, Probably in a Streambed Near You. Agricultural Research l July 2011. http://www.ars.usda.gov/is/AR/archive/jul11/Ecoli0711.pdf. • The agency has not prepared a legally adequate grazing suitability analysis based on economic and environmental considerations as required by NFMA. Heiken D., 1995. RIGHT PLACE -- WRONG ANIMAL: Determining Grazing Suitability Based on Desired Ecosystem Outcomes for the Interior Columbia River Basin. Association of Forest Service Employees for Environmental Ethics. May 1995. https://www.dropbox.com/s/ucw50hhs8xsiz2k/AFSEEE%20Grazing%20Suitability%20 Report.doc?dl=0 • The ecosystem will store more carbon and help mitigate climate change if they remain ungrazed. The agency needs to help mitigate climate change by managing all living systems to capture and storage optimal levels of carbon. Livestock grazing reduces carbon storage in vegetation and soil at an ecosystem scale and grazing must be reduced to help mitigate climate change. • Climate change is a new and added stress on native ecosystems. Climate change is expected to increase winter storms, summer droughts, reduce snowpack and summer streamflows, and cause earlier spring snowmelt and run-off. This adds stress to plants, animals, and streams that are also stressed by grazing. To avoid cumulative impacts from the combination of climate stress and anthropogenic stresses such as grazing, the agency needs to reduce anthropogenic stress from livestock grazing. Here are a few concrete examples. First, livestock trample and destabilize streambanks and expose streambanks to erosion. Such streambanks are vulnerable to erosion during peak flows. Climate change is expected to bring bigger precipitation events which will increase the erosive power of peak flows resulting in adverse cumulative interactions between climate change and grazing. Second, plants are stressed by summer dry periods which limits their ability to set seed, set buds, and store nutrients in woody parts and roots. These life functions are directly related to their survival. Climate change is expected increase the intensity and duration of summer droughts resulting in another adverse cumulative interaction between grazing and climate change. In order to help ecosystems cope with climate stress, the

agency should reduce or eliminate anthropogenic stresses such as livestock grazing. In the absence of livestock grazing streambanks will be better protected by plant roots and plants will be able to store more energy reserves which will help them be more resistant and resilient in the face of climate change. • We strongly encourage the agency to make contingency plans that require the removal of livestock during droughts, and after droughts the agency should provide for long periods of rest and recovery before livestock are allowed to return so that plants can rebuild soil cover, biomass, and energy stores both above and below ground. • Consider and avoid the effects of livestock grazing on the fire regime. Livestock grazing shifts the plant community composition from palatable grasses and forbs toward unpalatable conifers. This is contrary to current policy goals related to forest which urge us to avoid creating more ladder fuels. Livestock decrease the abundance of fine fuels which are necessary to carry periodic, low intensity surface fires. This reduces the frequency of fires, but increases their severity. See Kirsten Stade, MS, and Mark Salvo, JD. 2009. Ponderosa Pine in Peril: Assessing Public Lands Livestock Grazing in Ponderosa Pine Forests. Wild Earth Guardians. http://www.wildearthguardians.org/Portals/0/support docs/report-ponderosa-pine-08- 09.pdf; Belsky, A.J., Blumenthal, D.M., “Effects of Livestock Grazing on Stand Dynamics and Soils in Upland Forest of the Interior West,” Conservation Biology, 11(2), April 1997. http://web.archive.org/web/20030409094020/http://www.onda.org/library/papers/standdy namics.pdf. See also Wuerthner, George. Livestock Grazing and Fire. January, 2003. http://web.archive.org/web/20040107135236/http://www.onda.org/library/papers/Livesto ck_Grazing_and_Fire.pdf; and Michael H. Madany, and Niel E. West. Livestock Grazing-Fire Regime Interactions within Montane Forests of Zion National Park, Utah. Ecology: Vol. 64, No. 4, pp. 661-667. Comparing grazed and ungrazed areas of Zion National Park this study found “… the increased understory density of plateau stands should not be attributed primarily to cessation of fires. Instead, heavy grazing by livestock and associated reduction of the herbaceous groundlayer promoted the establishment of less palatable tree and shrub seedlings…” • The agency should protect and restore biotic soil crusts that help prevent erosion, fix nitrogen, cycle nutrients, and increase site productivity. Livestock grazing conflicts with the maintenance and recovery of biotic soil crusts. “Comparison of grazed and long- ungrazed sites revealed lower cover of biotic crusts, nitrogen-fixing lichens, crust- dominated soil surface roughness, and lower species richness in the grazed transects. There was more bare ground in the grazed transects…” Jeanne M. Ponzetti and Bruce P. McCune. 2001. Biotic Soil Crusts of Oregon's Shrub Steppe: Community Composition in Relation to Soil Chemistry, Climate, and Livestock Activity. The Bryologist 104(2):212- 225. 2001. • Grazing spreads weeds that alter vegetation structure, habitat, hydrology, and fire regimes. Weeds are a slow motion explosion that are adversely affecting native plant communities and entire ecosystems. By reducing the vigor of native plants, reducing soil cover, and exposing mineral soil, livestock grazing has a strong tendency to spread invasive weeds and exacerbate this problem. The agency should limit or exclude

livestock in order to help prevent the spread of weeds. Michael D. Reisner, James B. Grace, David A. Pyke and Paul S. Doesche 2013. Conditions favouring Bromus tectorum dominance of endangered sagebrush steppe ecosystems. Journal of Applied Ecology 2013 doi: 10.1111/1365-2664.12097. http://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/38539/jpe_12097_Rev_EV. pdf (“Evidence suggests abundant bunchgrasses limit invasions by limiting the size and connectivity of gaps between vegetation, and [biological soil crusts] appear to limit invasions within gaps. Results also suggest that cattle grazing reduces invasion resistance by decreasing bunchgrass abundance, shifting bunchgrass composition, and thereby increasing connectivity of gaps between perennial plants while trampling further reduces resistance by reducing [biological soil crusts]. … Grazing exacerbates Bromus tectorum dominance in one of North America’s most endangered ecosystems by adversely impacting key mechanisms mediating resistance to invasion. If the goal is to conserve and restore resistance of these 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.”) • Do not allow livestock grazing in existing ecosystems that are healthy and largely ungrazed. Let’s not extend the harm to grazing to ecosystems that have been spared up to now. Similarly, please take steps to permanently terminate grazing authorizations in existing vacant or inactive allotments. • The NEPA analysis for the applicable RMP is no longer current and adequate to support this proposed grazing decision. The agency cannot tier to that document because things have changed significantly, such as climate change and forest health concerns which are now paramount and were not addressed in that plan. • Please mitigate all the significant ecological impacts of livestock grazing described in Fleischner, T.L. 2010. Livestock grazing and wildlife conservation in the American West: historical, policy, and conservation biology perspectives. Pages 235-265 in J. DuToit, R. Kock, and J. Deutsch, eds. Wild Rangelands: Conserving Wildlife While Maintaining Livestock in Semi-Arid Ecosystems. Zoological Society of London/ Blackwell Publishing Ltd., Oxford, UK. and Fleischner, T. 1994. Ecological Costs of Livestock Grazing in Western North America. Conservation Biology. Volume 8 Issue 3, Pages 629 – 644. http://www.rmrs.nau.edu/awa/ripthreatbib/fleishner ecocosts.pdf.

• The agency should not misunderstand their responsibilities under the multiple-use laws. The agency is not required to allow livestock grazing everywhere, nor everywhere they have historically or currently allowed grazing. The agency’s highest priority is to meet the requirements of substantive requirements of the Clean Water Act and Endangered Species Act even if it means curtailing grazing. The agency should strongly weigh the moral imperative of mitigating climate change by storing more carbon in ungrazed ecosystems. People who choose to raise cattle should bear the full costs of their business operation. Grazing should occur primarily on private lands where the costs are

internalized, rather than on public lands where the public is forced to bear the ecological costs and someone else gets to pocket the profits. • Portions of these grazing allotments may occur in inventoried roadless area or unroaded areas larger than 1000 acres. Such areas are rare on the landscape and contribute disproportionately to ecological values and ecosystem services. Enhanced efforts toward conservation of ecological values are appropriate in such areas. • Questions for the NEPA analysis: (i) How much has the agency spent in this permit area in the last ten years? Specifically, how much on fencing? How much of that expenditure was on materials and how much was on labor? What contributions were made by the permittees? (ii) How many of the boundaries are soft versus fenced? (iii) As Oregon struggles with water quality, quantity, and broken systems, what has the agency done and what will they do to protect seeps, springs, water retention, and maintaining and restoring the water table in this permit area? • George Wuerthner describes a variety of adverse effects from livestock grazing on public lands. The NEPA analysis should address each of these and propose alternative ways to avoid, minimize, and mitigate adverse effects. 1. Dewatering of streams to the detriment of aquatic ecosystems. 2. Conversion of native riparian habitat and sage brush steppe to hay pastures of exotic grasses. 3. Trampling of biological crusts and contribution to soil erosion. 4. Trampling of biocrusts which facilitate cheatgrass invasion. 5. Soil compaction which decreases water infiltration. 6. The trampling of riparian areas and springs reduces it’s ability to soak up water and store for late season flows. It also destroys habitat for native mollucks. 7. Water troughs are breeding grounds for mosquitoes that carry west nile virus (and harm sage grouse). 8. Fences block migration and are a major source of mortality for sage grouse. 9. We kill all kill all kinds of predators and other wildlife (like prairie dogs) as pests and “varmints”. 10. The eating of riparian vegetation eliminates hiding cover and habitat for many species from songbirds to sage grouse chicks. 11. Forage competition. On many public lands, the vast majority of forage is allotted to domestic livestock. Many wet meadows, etc. are grazed to golf course height to the detriment of native wildlife. 12. Disease transfer such as occurs with domestic sheep and wild bighorns.

13. Weed invasion–grazing of native perennials and trampling and disturbance of soils favors weedy invasions. 14. Even where grasses are meeting “objectives” like 4 inch stubble height that is not enough to hide ground nesting birds. For instance, grouse require at least 10 inches of stubble height which you seldom see where there is significant grazing. 15. Effects on fire regimes. The invasion of cheatgrass, created by livestock disturbance, is a major factor in the burnout of sage brush habitat. Similarly, grazing can enhance conifer establishment in the ponderosa zone, including stand densities, again affecting fire regimes. 16, Cows are a major source of methane and thus GHG emissions contributing to global warming. Worse than all the transportation put together. 17. Most of the dams built-in the West are for water storage to provide for irrigation. These dams change the water characteristics of rivers and block migration (think of salmon). While you might say a few situations where dams have created trout habitat below them as “good”, this doesn’t account for the numerous losses imposed by dams. 18. Grazing favors invasives and exotics over native plants. Grazing has dramatically altered many native plant communities. GEORGE WUERTHNER, Critique of Montana Outdoors proposed “Green” Grazing article. The Wildlife News. AUGUST 14, 2017 http://www.thewildlifenews.com/2017/08/14/critique-of-montana-outdoors-proposed- green-grazing-article/ • Consider the grazing standards in Appendix 2 of AFSEEE’s 1995 Grazing Suitability Report. We consider these to be minimum standards to meet the agency’s legal requirements under NFMA, ESA, MBTA, NEPA, etc.

APPENDIX TWO

DETERMINING GRAZING SUITABILITY BASED ON DESIRED ECOSYSTEM OUTCOMES

AFSEEE proposes that the Interior Columbia Basin planning team fulfill the grazing suitability requirement as follows:

(1) Define "Desired Ecosystem Outcomes" and "Ecosystem Management Standards" for Columbia Basin ecosystems affected by livestock grazing;

(2) Determine grazing suitability for particular land areas based on whether livestock grazing would prevent or retard the attainment desired ecosystem outcomes or violate ecosystem management standards;

(3) Manage livestock grazing on suitable lands consistent with management standards to rapidly attain desired outcomes for Columbia Basin ecosystems; and

(4) Monitor to assure compliance with Ecosystem Management Standards and achievement of Desired Ecosystem Outcomes.

In an effort to stimulate open dialogue about appropriate definitions of Desired Ecosystem Outcomes, Ecosystem Management Standards, and standards for determining grazing suitability, AFSEEE proposes the following language be included in the Interior Columbia River Basin Record(s) of Decision:56

1. Desired Ecosystem Outcomes.

Upland, riparian, and aquatic ecosystems on National Forest System lands in the Interior Columbia Basin shall be managed to achieve ecosystem health and integrity. Ecosystem health and integrity will be indicated by the presence of ecosystem components, structures, processes, and functions described below. Ecosystem health and integrity will be indicated when the described characteristics attain wide distribution and site-potential.57 These ecosystem characteristics will be heterogenous, dynamic, and resilient. A healthy and integral ecosystem will not deviate greatly, over long periods of time or over large spatial areas, from the mean of the long-term range of natural variability.

Achievement of this desired outcome will include rapid attainment, and ongoing maintenance of at least the following indicators of ecosystem health and integrity:58

Soil a. Fully functioning soil, including intact O-horizons and A-horizons, well-developed microbiotic components, and high capacity for water infiltration and water retention; b. Nutrient cycling leading to stored supplies of carbon, nitrogen and other nutrients adequate for productive, fertile soils; c. Plant litter accumulation adequate to help protect soil, retain moisture, provide habitat complexity, provide safe sites for germination of indigenous plants, and help carry low-intensity ground fire;

Vegetation d. Plant distribution, age-class diversity, and species diversity are adequate for perpetuating healthy and diverse indigenous plant communities; e. Complete vegetative and reproductive life cycles for indigenous plant species, including viable rooting throughout the available soil profile, normal vegetative growth forms, and maximum seed production; f. Adequate germination micro-sites (safe sites) available for regeneration of indigenous plant species; g. Photosynthetic activity occurs throughout the period suitable for growth of indigenous plants; h. Undesirable influences from non-indigenous plants are prevented and eliminated; i. "Park-like" forest stands that are resilient to disturbances such as fire, drought, insects, and disease are maintained where appropriate via maintenance of herbaceous plants and litter adequate to carry low- intensity fire along the ground and compete with and prevent excessive establishment of woody species.

Wildlife j. Terrestrial and aquatic micro- and macro-invertebrates are present in adequate numbers and diversity to break down detritus and provide food for viable populations of indigenous fish, birds, reptiles, amphibians, mammals, and other wildlife; k. Fully functioning upland, riparian, and aquatic habitats in the proper ratio and configuration to maintain viable populations of all indigenous species; l. Minimum human intervention in the dynamic relationship between populations of predators and prey;

Water/Hydrology m. Indigenous riparian vegetation, both woody and herbaceous, that contributes to bank stability, sediment trapping, shade, and habitat for diverse and well-distributed populations of riparian-associated indigenous species, including invertebrates and viable populations of vertebrates; n. Optimum water quality for all beneficial uses, including domestic and municipal water supply, recreation, and the maintenance of well-distributed, viable populations of indigenous aquatic and other species. This subsumes water quality that is legally compliant as to temperature, sediment/turbidity, coliform bacteria, pH, dissolved oxygen, phosphates, nitrates, sulfates, and specific conductance; o. Beneficial conditions of water flow, including moderated peak flows and extended late season flows; p. Cumulative impacts from livestock and existing populations (or planned reintroductions) of beaver will not adversely affect woody riparian vegetation and normal fluvial processes. q. Stream habitat features indicating fully-functioning fluvial systems, including: stable undercut banks, pool frequency, channel type, width-to-depth ratio, substrate particle size and distribution, bed load transport, migrating stream channels, and energy dissipation characteristics; r. Restored riparian/wetland functions, including timing and variability of water table elevation, groundwater recharge, and the ability to route flood waters;

2. Determining Grazing Suitability. a. National Forest System lands may be designated suitable for livestock grazing only where the applicable forest plan makes a documented affirmative finding that maintenance of livestock numbers necessary to support a viable livestock operation59 will not prevent or retard attainment60 of all Desired Ecosystem Outcomes, listed under 1 above, nor lead to any violation of Ecosystem Management Standards, listed under 3 below. b. In each area considered for possible livestock grazing, the resources most sensitive to degradation by livestock must be given special consideration in the suitability determination. c. To support a grazing suitability determination the deciding officer must make a finding that livestock grazing in areas to be designated as suitable for grazing is consistent with the principle of multiple-use. To wit--

12 i. Management of all the various renewable resources of the national forest, including but not limited to livestock grazing, recreation, fish & wildlife habitat, water resources, and timber, are utilized in the combination that best meet the needs of the American people; and ii. Upon consideration of all the various resources, and not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output, livestock grazing is harmonious with other uses, and will not impair the productivity of the land for other uses. d. The standards of this part apply equally to areas where grazing occurred in the past, areas where grazing is currently being permitted, and areas where grazing is being newly proposed. e. Before the deciding officer may rely upon the effectiveness of existing or planned livestock management developments (such as fences and alternative water sources) to support a grazing suitability determination, the deciding officer must first find: i. That the direct, indirect, and cumulative impacts of existing, planned, and necessary additional developments will not violate Ecosystem Management Standards, nor prevent or retard the attainment of Desired Ecosystem Outcomes or the restoration of past resource damage from any cause; ii. That all structural developments and administrative efforts necessary to ensure attainment of Desired Ecosystem Outcomes and prevent violations of Ecosystem Management Standards will be diligently maintained for the duration of the grazing permit, and the risk that the structural developments and administrative efforts will be ineffective is insubstantial. f. Where lands that are otherwise suitable for grazing are mingled with unsuitable lands in such a way that livestock use of the unsuitable lands is reasonably foreseeable, the whole area including the suitable lands shall be designated unsuitable.61 g. Grazing suitability must be considered in light of the capability of land areas to provide habitat for Management Indicator Species,62 the requirement to provide habitat for viable populations of all native and desired non-native vertebrate species,63 and the obligation to provide habitat contributing to the recovery of species listed under the Endangered Species Act.64 i. Indicator species must be selected based on their sensitivity to livestock impacts. ii. In determining grazing suitability, population viability analyses should be conducted on populations of special status species most likely to be adversely affected by livestock grazing. h. Lands harboring significant cultural resources that are likely to be damaged or destroyed by livestock shall be designated unsuitable for livestock grazing.

3. Ecosystem Management Standards

General a. Authorized officers shall authorize grazing only on lands determined suitable for livestock grazing in the applicable forest plan. Livestock shall not be permitted to graze on National Forest System lands unless such lands are specifically designated suitable for livestock grazing in the applicable forest plan. Forest Service personnel shall take immediate and aggressive action to prevent livestock from trespassing on

13 unsuitable lands and shall enforce all applicable rules against unauthorized use of public lands by domestic livestock. b. Adjust grazing to eliminate impacts that retard or prevent the attainment of Desired Ecosystem Outcomes listed under 1 above, or cause a violation of any applicable law, regulation, rule, or management standard. Where adjustments are not effective, eliminate livestock. c. Where monitoring or other evidence shows that lands are not suitable for grazing, livestock shall be prohibited from grazing such lands whether or not such lands are determined in the applicable forest plan to be suitable for grazing.

Soil d. Livestock shall not cause, contribute to, or accelerate noticeable soil movement, such as pedestaling, rills, gullies, scouring, sheet erosion, sedimentation or dunes. e. Livestock shall not increase the existing rate of soil loss or retard the rate of soil recovery that would be expected in the absence of livestock. f. Livestock shall not cause physical displacement of historic artifacts or otherwise cause loss of the information value of such artifacts by, among other things, disturbing the soil in or near historic sites.

Vegetation g. Livestock shall not introduce or spread non-indigenous plants. h. When conducted for the purpose of benefiting livestock, large-scale environmental manipulation, such as chaining of pinon-juniper,65 treatment of brush with herbicides, or conversion of indigenous plant communities shall be prohibited. i. Livestock shall not reduce herbaceous plant cover and litter to such an extent that low-intensity fire is significantly suppressed or to such an extent that understory competition for water and nutrients significantly favors establishment of fire-intolerant woody species.66

Wildlife j. Livestock shall not present a risk of disease transmission to indigenous wildlife (e.g., bighorn sheep); nor render an identified wildlife reintroduction site unsuitable for wildlife reintroduction (e.g., beaver and bighorn sheep). k. Livestock shall not interfere with the maintenance of well-distributed, viable wildlife populations via social displacement, reduction in cover, or competition for food. l. Livestock shall not alter normal relationships between predators and prey (e.g., coyote and waterfowl); parasites and hosts (e.g., cowbirds and neotropical migratory songbirds); specific pollinators and dependent plants; or specific dispersal mechanisms and dependent indigenous organisms. m. Livestock shall not alter habitat to such an extent that the geographic range of wildlife species is altered.

14 n. Lethal control, for the benefit of livestock, of indigenous predators (e.g., coyote and cougar), and competing indigenous herbivores (e.g., rodents and grasshoppers) shall be prohibited. o. Livestock, in combination with existing populations or planned reintroductions of beaver, shall not prevent or retard the attainment of a fully-functioning stream system, including healthy and diverse woody riparian vegetation component.

Economics p. Before livestock grazing is authorized, the deciding officer must prepare a comparative economic analysis which displays the market and non-market costs and benefits to society over time "with" grazing and "without" grazing. q. Consistent with the principle of multiple use, the deciding officer must thoroughly consider market and non-market costs and benefits to determine whether the needs of the American people are best served with grazing or without grazing, based not on the greatest dollar return or the greatest unit output. r. The analysis shall consider and disclose the value of alternative uses forgone when an area is grazed by domestic livestock compared to when an area is not grazed. s. Consider and disclose the economic impact of grazing from several perspectives: federal treasury, permittees, agency budget, county revenues, recreationists. t. The anticipated costs of administering livestock grazing and the costs of livestock-related investments such as fences and water tanks necessary to protect environmental quality shall be disclosed. In consideration of livestock management limitations, the relative risk of environmental harm with and without grazing shall be disclosed.

4. Monitoring a. Ecosystem components, structures, processes, and functions shall be measured on a regular basis to evaluate attainment (or lack of attainment) of Desired Ecosystem Outcomes. b. If monitoring cannot be conducted, for any reason including lack of funding, in sufficient detail and frequency to inform management and the interested public about the potential impacts of grazing, then livestock shall be removed from the area until monitoring shows significant progress toward attainment of Desired Ecosystem Outcomes. c. Utilization standards shall be established in terms of stubble height, percent of leaders browsed, and percent of stream banks disturbed. Livestock utilization on suitable lands shall be monitored and necessary adjustments made to maintain suitability by promptly removing livestock when utilization limits are reached.

/footnotes/ 56 Keep in mind that the desired ecosystem outcomes described in this appendix are not inclusive of all ecosystem values. They have been developed with livestock grazing in mind. For instance, although old- growth habitat values will be an important issue in the overall regional plan, they may not be fully represented in this paper because there is only limited association between livestock grazing and old-growth habitat characteristics.

57 The qualifiers "wide distribution" and "site potential" apply to all the of the attainment goals listed. "Wide distribution" means both spatial (e.g., distribution of plants across a site) and temporal (e.g., photosynthetic activity occurs throughout the period suitable for plant growth). "Site potential" refers to conditions which would be present in the absence of human caused disturbances (e.g., livestock grazing), or human caused suppression of natural disturbances (e.g., fire). Site potential is not "pristine" or steady-state climax, but rather the dynamic mosaic of conditions which would be expected near the mean within the range of natural variability for a given set of climatic and landform conditions.

58 Outcomes a. through g. are indicators of rangeland health adapted from National Research Council, Committee on Rangeland Classification. 1994. Rangeland Health: New Methods to Classify, Inventory, and Monitor Rangelands, National Academy Press. Note: the Committee on Rangeland Classification included Jack Ward Thomas-- then a USDA research scientist, now the Chief of the Forest Service.

59 The regulations require that the Forest Service consider suitability under an "assumed set of management practices and at a given level of management intensity." 36 CFR § 219.3. The inclusion of an assumed "viable livestock operation" is intended to exclude from the suitable land base lands that could only support a small number of livestock. Granting a permit for such small numbers would not make sense administratively for the Forest Service nor economically for the livestock operator. This standard also invokes economic criteria as required by 36 CFR § 219.3. This analysis is much like the validity examinations done on mining claims. The government does not want to support potentially damaging activities on the public lands that do not meet a simple test of profitability. The public interest is not served by a policy that would use the National Forests to support small non-commercial livestock operations, e.g. hobby farms.

60 The clause "prevent or retard attainment of... " is derived from the standards and guidelines for attaining Aquatic Conservation Strategy objectives on federal lands west of the Cascades. See USDA/FS and USDI/BLM, Record of Decision and Standards and Guidelines for Management of Habitat for Late- Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl, April 1994 at pages B-11 and C-33. This approach will also likely be used in the "PACFISH" aquatic conservation strategy. See October 11, 1994 consultation letter from Gray Reynolds (USFS) and Al Wright (BLM) to Rolland Schmitten (NOAA/NMFS) concerning the joint Environmental Assessment for the Implementation of Interim Strategies for Managing Anadromous-Fish Producing Watersheds in Eastern Oregon and Washington, Idaho, and Portions of California, March 1994. This "prevent or retard" standard is becoming a standard approach to achieve ecosystem-based desired future conditions. Where proper ecosystem processes are lacking on public lands, private livestock use must not be permitted to prevent or retard the ability of natural recovery mechanisms to achieve healthy conditions.

61 According to some Forest Service professionals, "no grazing system has been devised for assuring proper use of small riparian meadows with extensive upland range. In addition, the most recent information on grazing uplands suggests that although conventional grazing systems have great intuitive appeal, they are less effective at maintaining ecological quality and livestock production than previously thought." Clary, W.P., and B.F. Webster, Managing Grazing of Riparian Areas in the Intermountain Region, USDA Forest Service, Intermountain Research Station, GTR INT-263, May 1989, page 1. In such cases, effective management of the whole area may be rendered infeasible due to prohibitive administrative costs such as riding, herding, fencing, and monitoring, or due to conflicts with other resources such as recreation, wildlife and fish.

62 36 CFR § 219.20.

63 36 CFR § 219.27(a)(6).

64 16 USC §1536(a).

65 See A.J. Belsky, Viewpoint on Western Juniper Expansion: Is it a Threat to Arid Northwestern Ecosystems?, Journal of Range Management, in press.

66 Belsky, A.J., letter to EEMP Project Leader Jeff Blackwood, September 23, 1994. This letter cites numerous well-respected range scientists whose studies contradict the suggestions of the draft issue paper, "Paleoecological Relationships..." Heiken D., 1995. RIGHT PLACE -- WRONG ANIMAL: Determining Grazing Suitability Based on Desired Ecosystem Outcomes for the Interior Columbia River Basin. Association of Forest Service Employees for Environmental Ethics. May 1995. https://www.dropbox.com/s/ucw50hhs8xsiz2k/AFSEEE%20Grazing%20Suitability%20Report.d oc?dl=0 .

For a critique of arguments often used to promote livestock grazing on public lands see: Hudak & Wuerthner 2013. Public Lands Don’t Need Livestock Grazing! Issued by the Sierra Club Grazing Core Team, Celebrating the Introduction of the Rural Economic Vitalization Act (H.R. 2201, 113th Congress) June 12, 2013. http://www.sierraclub.org/grazing/references-061213.pdf

Grazing and Sage Grouse

There are significant trade-offs between livestock grazing and sage grouse population viability. This is because livestock herbivory has a direct negative effect on the vegetation cover needed by sage grouse to hide from predators. Livestock eat grasses and forbs growing on the ground. Sage grouse rely on vegetation for cover from predators and grass height is a major indicator of sage grouse nest success. Doherty et al (2014) found that nests had only a 47 percent survival rate when grass heights averaged 7 inches. The Montana nests had a 60 percent survival rate at 10.2 inches of grass cover, but didn’t reach the 75 percent survival threshold until grass heights topped 15 inches. Kevin E. Doherty, David E. Naugle, Jason D. Tack, Brett L. Walker, Jon M. Graham and Jeffrey L. Beck 2014. Linking conservation actions to demography: grass height explains variation in greater sage-grouse nest survival. Wildlife Biology, 20(6):320-325. 2014. http://www.uwyo.edu/esm/faculty-and-staff/beck/ files/docs/publications/doherty-et-al-2014- wildlife-biology.pdf (“Nest success is demonstrated to be important to [lambda] in greater sage- grouse, …. Enhancing this vital rate through management represents an opportunity to increase bird numbers inside population strongholds. We identified management for grass height as an action that can improve nest success … The high predictive power of grass height illustrates its utility as a management tool to increase nest success within priority landscapes.”). The agency often uses stubble height as an indicator of livestock utilization, or over-utilization. The agency should amend allotment plans to incorporate low utilization required to maintain residual vegetation that provides high quality cover for sage grouse.

The negative effects of grazing on vegetation also negatively affects insects and arthropods that are critical to the nutrition of sage grouse chicks. Research is showing that "rested pastures harbor significantly more food arthropods than grazed pastures, as well as taller vegetation, which shelters and feeds both the birds and their arthropod prey.” Marian Lyman Kirst 2015. Tracking grazing’s impacts on bugs - A Montana biologist studies how livestock influence a 17 favorite sage grouse food source. High Country News. Aug. 17, 2015 http://www.hcn.org/issues/47.14/biggest-experiment-endangered-species-act-sage- grouse/tracking-grazings-impacts-on-bugs

BLM prepared a summary of the science regarding the adverse effects of livestock grazing on sage grouse reporting that … livestock grazing is the most widespread land use across the sagebrush biome … livestock grazing is characterized as a “press” form of disturbance because it exerts repeated pressure across the landscape … [Compared to the pre-settlement period] 3 times the area per AUM is required because current primary production is approximately one-third of what it was during the first interval, … Nesting sage-grouse consistently select areas with more sagebrush canopy cover and taller grasses compared to available habitats … Thermal cover, predator protection, and food availability are important for chick survival during the early brood- rearing period with tall (>30cm) grasses and sagebrush creating this habitat structure. … Heavy fall utilization of sagebrush habitats by livestock has been deemed detrimental to sagebrush overstories and thus may negatively influence sage-grouse habitat suitability (Wright, 1970; Owens and Norton, 1990; Angell, 1997; Beck and Mitchell, 2000). Trampling by livestock under short-duration or season-long grazing may kill sagebrush, particularly seedlings growing in interstitial spaces … [A study] concluded that livestock stocking intensity was more important than grazing system for herbage production (Van Poolen and Lacey, 1979), … In contrast, others found season of use to influence production: grazing heavily during the spring or during spring and fall was detrimental to herbaceous understories (Mueggler, 1950; Laycock, 1978; Owens and Norton, 1990). Insect diversity and density were positively correlated with herbaceous density and diversity (Hull and others, 1996; Jamison and others, 2002); thus, spring or spring-fall grazing could negatively impact nesting sage-grouse and young chick survival during early brood-rearing … [G]razing during the dormant season (late summer through winter) may influence residual-grass- stubble height (Pyke, 2011), which could influence nesting habitat quality for sage-grouse the following spring. A study conducted in central Wyoming compared vegetative conditions in grazed pastures to conditions selected by sage-grouse in the area and found that reduced forage utilization, extended periods of rest, and reduced spring grazing provided conditions most suitable for sage-grouse nesting and early brood-rearing … Long-term removal of livestock generated a steady increase in the richness of shrubs, perennial grasses and forbs, and vegetative heterogeneity through 45-years post-removal of livestock in southwestern Idaho (Anderson and Inouye, 2001). Comparing grazed to un-grazed (not grazed for 25 to 40 years) big sagebrush communities in Utah and Idaho, researchers reported increased sagebrush canopy cover of 13 to 54 percent (Beck and Mitchell, 2000). … Studies tracking changes in vegetation after removal of livestock in sagebrush systems report that initial proportions of the different growth forms were retained, and that a minimum of 10 to 15 years was required for seed production, seedling establishment, and growth to occur

(Connelly and others, 2004; Pyke, 2011). Thus, … extended rest may be required for areas that are currently degraded. … Livestock distribution patterns are directly linked with water availability, and this bias has also had relevant, measureable impacts to riparian habitats, which are of primary importance for sage-grouse as late brood-rearing and summer habitats. The most direct effect of livestock on riparian vegetation is removal of the lower vegetation layers … Sage-grouse generally initiate nesting in April, prior to production of new herbaceous cover; thus, residual grasses left from the previous year represent the initial cover available for nesting sage-grouse … The potential exists to successfully manage for good sagebrush community condition but fail to achieve sage-grouse habitat objectives if annual management for sufficient residual vegetation (standing crop) is not considered. According to research conducted in sagebrush-steppe, adherence to light-utilization standards is the most dependable way to ensure a healthy plant community (Cagney and others, 2010). … Deferring grazing for two growing seasons after disturbance has been recommended because it allows the cool season bunchgrasses—which are especially vulnerable to grazing after treatment—to capitalize on resource availability created by the disturbance (Knick and others, 2011). However, reintroduction of livestock to a disturbed area prior to the native or reseeded plant community becoming established, regardless of the number of years of rest afforded the site, can result in failed rehabilitation efforts … Manier, D.J., Wood, D.J.A., Bowen, Z.H., Donovan, R.M., Holloran, M.J., Juliusson, L.M., Mayne, K.S., Oyler-McCance, S.J., Quamen, F.R., Saher, D.J., and Titolo, A.J., 2013, Summary of science, activities, programs, and policies that influence the rangewide conservation of Greater Sage-Grouse (Centrocercus urophasianus): U.S. Geological Survey Open-File Report 2013–1098, 170 p., http://pubs.usgs.gov/of/2013/1098/

USGS highlights the fact that ravens are attracted livestock and livestock facilities, such as water troughs, which increases the risk that ravens will prey on sage gouse eggs and nestlings. Ravens are almost fifty percent more likely to inhabit areas in sagebrush landscapes if cattle are present, and preferentially select sites near greater sage-grouse breeding grounds.

These findings have implications for greater sage-grouse management practices aimed at reducing raven predation on sage-grouse nests, according to research published in Ecosphere.

Raven abundance in the sagebrush-steppe of the American West has increased three-fold during the last four decades, mostly as a result of unintended food and water subsidies from human land-use practices. Predation is the primary source of sage-grouse nest failure, and reducing ravens access to food and water subsidies could assist with conservation efforts. While removal of ravens may reduce their local abundance in the

short term, removing subsidies that promote ravens will likely be more effective for long- term control of raven predation. USGS 2016. Technical Announcement: Cattle Increase Occurrence of Ravens That Prey on Sage Grouse. Released: 3/2/2016 http://www.usgs.gov/newsroom/article.asp?ID=4463 citing Coates P. S., B. E. Brussee, K. B. Howe, K. B. Gustafson, M. L. Casazza, and D. J. Delehanty. 2016. Landscape characteristics and livestock presence influence common ravens: relevance to greater sage-grouse conservation. Ecosphere 7(2):e01203. 10.1002/ecs2.1203 http://onlinelibrary.wiley.com/doi/10.1002/ecs2.1203/full

Grazing and Climate Change

The agency should do more to incorporate concerns about climate change into all of its management decisions. Ruminant livestock not only cause direct emission of greenhouse gases but livestock grazing also suppresses vegetation growth and prevents the landscape from storing as much carbon as it could. Livestock also make the landscape less resilient to the biophysical changes brought by global climate change. Plants are less healthy, have shallower roots, reduced above-ground and below-ground energy reserves, fewer seeds, and are consequently less resilient to drought stress. Grazed watersheds also have less vegetation cover, more exposed soil, degraded stream conditions, and are less resilient to the amplification of the water cycle and increased storm intensity expected as a result of climate change.

Climate change is an over-arching concern that all agencies must immediately reorient their missions to address. The agency should analyze proposed grazing from at least three perspectives relative to global climate change.

First, NEPA analyses must account for the fact that livestock grazing combined with climate change will result in compound and cumulative adverse effects. See Beschta, R. L., Donahue, D. L., DellaSala, D. A., Rhodes, J. J., Karr, J. R., O'Brien, M. H., Fleischner, T. L., & Deacon- Williams, C. (2012). Adapting to Climate Change on Western Public Lands: Addressing the Ecological Effects of Domestic, Wild, and Feral Ungulates. Environmental Management. DOI 10.1007/s00267-012-9964-9 http://fes.forestry.oregonstate.edu/sites/fes.forestry.oregonstate.edu/files/PDFs/Beschta/Beschta_ 2012EnvMan.pdf Climate change is expected to increase winter storms, summer droughts, reduce snowpack and summer streamflows, cause earlier spring snowmelt and run-off, and may increase the prevalence of herbivorous insects. All these add stress to plants and streams that are also stressed by grazing. To avoid cumulative impacts from the combination of climate stress and anthropogenic stress, we need to reduce anthropogenic stress from livestock grazing. Here are a few concrete examples. First, livestock trample and destabilize streambanks and expose streambanks to erosion. Such streambanks are vulnerable to erosion during peak flows. Climate change is expected to bring bigger precipitation events which will increase the erosive power of streams results in adverse cumulative interactions between climate change and grazing. Second, 20 plants are stressed by summer dry periods which limits their ability to set seed, set buds, and store nutrients in woody parts and roots. These life functions are directly related to their survival. Climate change is expected increase the intensity and duration of summer droughts resulting in another adverse cumulative interaction between grazing and climate change.

“Primary [climate change] adaptation strategies to address changing hydrology in the Blue Mountains include restoring the function of watersheds, connecting floodplains, reducing drainage efficiency, maximizing valley storage, …. Tactics include adding wood to streams, restoring beaver populations, modifying livestock management, …” Halofsky, J.E.; Peterson, D.L., eds. 2016. Climate change vulnerability and adaptation in the Blue Mountains. Gen. Tech. Rep. PNW-GTR-xxx. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. http://adaptationpartners.org/bmap/docs/BMAP_final.pdf

“Moderate and high levels of uncharacteristic grazing effects currently occur on well over half (64 percent) of the FS- and BLM-administered lands in the ICBEMP management region.” Miles A. Hemstrom, Wendel J. Hann, Rebecca A. Gravenmier, Jerome J. Korol. 2000. [SAG] Landscape Effects Analysis of the [ICBEMP] SDEIS Alternatives. USDA/USDI, draft March 2000.

Second, the agency needs to account for the direct emission of potent greenhouse gases from ruminant livestock, such as cattle: Efforts to curb climate change require greater emphasis on livestock 12/20/2013 CORVALLIS, Ore. – While climate change negotiators struggle to agree on ways to reduce carbon dioxide (CO2) emissions, they have paid inadequate attention to other greenhouse gases associated with livestock, according to an analysis by an international research team.

A reduction in non-CO2 greenhouse gases will be required to abate climate change, the researchers said. Cutting releases of methane and nitrous oxide, two gases that pound-for- pound trap more heat than does CO2, should be considered alongside the challenge of reducing fossil fuel use.

The researchers’ analysis, “Ruminants, Climate Change, and Climate Policy,” is being published today as an opinion commentary in Nature Climate Change, a professional journal. [See link below.] … “Because the Earth’s climate may be near a tipping point to major climate change, multiple approaches are needed for mitigation,” said Ripple. “We clearly need to reduce the burning of fossil fuels to cut CO2 emissions. But that addresses only part of the

problem. We also need to reduce non-CO2 greenhouse gases to lessen the likelihood of us crossing this climatic threshold.”

Methane is the second most abundant greenhouse gas, and a recent report estimated that in the United States methane releases from all sources could be much higher than previously thought. Among the largest human-related sources of methane are ruminant animals (cattle, sheep, goats, and buffalo) and fossil fuel extraction and combustion.

One of the most effective ways to cut methane, the researchers wrote, is to reduce global populations of ruminant livestock, especially cattle. Ruminants are estimated to comprise the largest single human-related source of methane. OSU Press Release, Dec. 2013. http://oregonstate.edu/ua/ncs/archives/2013/dec/efforts-curb- climate-change-require-greater-emphasis-livestock. The referenced article is: William J. Ripple, Pete Smith, Helmut Haberl, Stephen A. Montzka, Clive McAlpine and Douglas H. Boucher 2014. COMMENTARY: Ruminants, climate change and climate policy. NATURE CLIMATE CHANGE | VOL 4 | JANUARY 2014. https://newyork2.sierraclub.org/sites/newyork.sierraclub.org/files/documents/2014/01/Ripple%2 0et%20al%202014%20Ruminants%20climate%20change.pdf.

“Greenhouse gas (GHG) emissions associated with [livestock] production are estimated to account for over 14.5 percent of the global total. This is more than the emissions produced from powering all the world’s road vehicles, trains, ships and aeroplanes combined. It is considerably more than the emissions produced by the world’s largest national economy, the United States. … Recent analyses have shown that it is unlikely global temperature rises can be kept below two degrees Celsius without a shift in global meat and dairy consumption. … Intensive rearing of cattle on feedlots is less emissions-intensive than pasture-based grazing systems because grass- fed cows tend to produce more methane and take longer to reach slaughter weight.” Bob Bailey, Antony Froggatt and Laura Wellesley. 2014. Livestock – Climate Change’s Forgotten Sector Global Public Opinion on Meat and Dairy Consumption. Chatham House Research Paper. December 2014. http://www.chathamhouse.org/sites/files/chathamhouse/field/field_document/20141203Livestoc kClimateChangeBaileyFroggattWellesleyUpdate.pdf. See also, Chatham House 3-31-2017 response to some industry critics. https://www.chathamhouse.org/sites/files/chathamhouse/publications/2017-04-05- ResponsetoIEABioenergy.pdf

Large herbivores were once a common sight in all of Earth’s habitable continents. However, hundreds of years of intensive livestock farming has contributed to steep declines in native herbivores and large increases in cattle. Today, there are around 1.5bn cows on Earth.

The replacement of native animals with cattle has caused steep rises in emissions of methane – a greenhouse gas that is 34 times more potent than CO2 over a 100-year period.

This is because cows are “ruminants” – meaning that they have specialised stomachs capable of digesting tough and fibrous material, such as grass through fermentation. The digestive process causes cows to belch out high amounts of methane.

Native herbivores, on the other hand, can have much smaller methane footprints. Dunne, D. 2018. In-depth: Could ‘rewilding’ help to tackle climate change? Carbon Brief. https://www.carbonbrief.org/in-depth-could-rewilding-help-tackle-climate-change citing Phil. Trans. R. Soc. B. Theme issue ‘Trophic rewilding: consequences for ecosystems under global change’ organized and edited by Elisabeth S. Bakker and Jens-Christian Svenning. 05 December 2018; volume 373, issue 1761 http://rstb.royalsocietypublishing.org/content/373/1761

Third, the agency needs to help mitigate climate change by managing all living systems to capture and store as much carbon as possible. Livestock grazing reduces carbon storage in vegetation biomass, microbes, and soil at an ecosystem scale and must be reduced to help mitigate climate change. See: • Dong Wang, Gao-Lin Wu, Yuan-Jun Zhu, Zhi-Hua Shi. 2014. Grazing exclusion effects on above- and below-ground C and N pools of typical grassland on the Loess Plateau (China). Catena 123 (2014) 113–120. http://lab.yangling.cn/UploadFile/ea_201482785433.pdf (“Results showed that soil carbon content in the topsoil, plant biomass and diversity, and grasses increased, while bulk density, pH and forbs decreased after grazing exclusion. The increases in soil carbon content, the cumulative organic carbon pool and the rate of change in the cumulative organic carbon pool mainly occurred in the upper 20 cm soil layer after 8 years of grazing exclusion. Our study suggested that the 8-year grazing exclusion had a great influence on the carbon pools …”) • Lei Deng, Zhinan Zhang, Zhouping Shangguan 2014. Long-term fencing effects on plant diversity and soil properties in China. Soil & Tillage Research 137 (2014) 7–15. http://lab.yangling.cn/UploadFile/ea_2014428151434.pdf (“Long-term fencing also led to marked increases in soil organic carbon (SOC), soil total nitrogen (TN), the carbon: phosphorus (C/P) and nitrogen: phosphorus (N/P) ratios, as well as soil C and N storage within 0–100 cm soil profile.”) • WU Xing, LI Zongshan, FU Bojie, LU Fei , WANG Dongbo, LIU Huifeng, LIU Guohua 2014. Effects of Grazing Exclusion on Soil Carbon and Nitrogen Storage in Semi-arid Grassland in Inner Mongolia, China. Chin. Geogra. Sci. 2014 Vol. 24 No. 4 pp. 479-487. http://egeoscien.neigae.ac.cn/fileup/PDF/20140411.pdf (“The results show that removal of grazing for six years resulted in a significant recovery in vegetation with higher above and below-ground biomass, but a lower soil bulk density and pH value. After six years of grazing exclusion, soil organic C and total N storage increased by 13.9% and 17. 1%, respectively, which could be partly explained by decreased loss and increased input of C and

N to soil. The effects of grazing exclusion on soil C and N concentration and storage primarily occurred in the upper soil depths.”) • Xing Wu, Zongshan Li, Bojie Fu, Wangming Zhou, Huifeng Liu, Guohua Liu. 2014. Restoration of ecosystem carbon and nitrogen storage and microbial biomass after grazing exclusion in semi-arid grasslands of Inner Mongolia. Ecological Engineering, Volume 73, Issue null, Pages 395-403. (“Highlights: * Grazing exclusion resulted in a substantial increase of ecosystem C and N storage. * The restoration of ecosystem C and N were mainly due to the increase of C and N in soil.”) • Dingpeng Xionga, Peili Shi, Xianzhou Zhang, Chris B. Zou. 2016. Effects of grazing exclusion on carbon sequestration and plant diversity in grasslands of China—A meta- analysis. Ecological Engineering 94 (2016) 647–655. (“We conducted a meta-analysis of 447 entries from 78 papers to analyze the spatiotemporal effects of grazing exclusion on plant diversity, productivity and soil carbon sequestration … Our comprehensive meta-analysis demonstrated a consistent positive overall effect of grazing exclusion on grassland biomass and soil carbon stocks. … Our results showed that, compared with the grazed sites, grazing exclusion significantly increased carbon stored in aboveground biomass, litter mass, belowground biomass and soils by 84.7%, 111.6%, 25.5% and 14.4%, respectively.”) • Bruce Myers 2014. Livestock’s Hoof Print. ENVIRONMENTAL LAW INSTITUTE • POLICY BRIEF NO. 8 • FEBRUARY 2014. http://www.eli.org/sites/default/files/docs/policy_brief_8.pdf (“According to the United Nations Food and Agriculture Organization (FAO), 14.5 percent of all heat-trapping GHGs emitted into the atmosphere through human activity is attributable, directly or indirectly, to the livestock sector. By 2050, meat production is projected to double due to increasing population and growing per capita demand … [N]ow is the time to lay the policy groundwork for how best to take on GHG emissions from livestock production.”) • D. G. Milchunas W. K. Lauenroth 1993. Quantitative Effects of Grazing on Vegetation and Soils Over a Global Range of Environments Ecological Archives M063-001; https://doi.org/10.2307/2937150 (“... most effects of grazing on ANPP [above-ground net primary productivity] were negative ... the statistical models predicted increases in ANPP with grazing under conditions of long evolutionary history, low consumption, few years of treatment, and low ANPP” These conditions are highly atypical for public land grazing allotments with a long-history of heavy grazing.)

The agency should consider changes in grazing, such as dramatically reduced utilization, as a mitigation alternative that helps address climate change. We estimate that adjustments in grazing pressure, from current forage offtake rates to rates that maximize forage production, can sequester 148.4 Tg CO2 yr -1 (Tables 2 and 3) in grazing lands worldwide. … [A]rid areas account[] for just over half of the total sequestration potential due to their dominant share of the total amenable rangeland area … Benjamin B. Henderson, Pierre J. Gerber, Tom E. Hilinski, Alessandra Falcucci, Dennis S. Ojima, Mirella Salvatore, Richard T. Conant 2015. Greenhouse gas mitigation potential of the world’s grazing lands: Modeling soil carbon and nitrogen fluxes of mitigation practices. Agriculture, Ecosystems & Environment. Volume 207, 1 September 2015, Pages 91–100. http://authors.elsevier.com/a/1QrWKcA-IJPyp, https://animalscience.psu.edu/fnn/current- 24

research/nature-climate-2925-paper-published-march-16. This study also notes that demand reduction can help. (“Reduced [meat] consumption could have substantial beneficial effects largely through its ability to create ‘spare land’ that can be used for either bioenergy or C sequestration by afforestation.”) Fedeal agencies that manage grazing allotments can help that process along by limiting the supply.

We urge the agency to avoid minimizing the effects of grazing on climate change. To admit that grazing will reduce biogenic carbon storage but then say that the scale is too small to make a difference is an improper way to look at carbon and climate. ALL carbon emissions are minimal if they are looked at individually. The problem is one of cumulative effects, and no emissions should be excluded from that calculus. Global climate change is made better or worse by millions of small decisions about whether or not to cause emissions. Climate change must be addressed by millions of decision-makers around the world, including federal agency line officers making decisions on individual land management actions.

The cause of climate change is from cumulative emmissions from all sources, so there is no silver bullet solution, where one or a few people can decide to take discreet actions to fix the problem. “[T]here is absolutely NO SILVER BULLET to climate change. None. Policy alone won’t do it. Markets alone won’t either. Nor will our actions at home. We need them all. Think SILVER BUCKSHOT, not silver bullet.” https://twitter.com/GlobalEcoGuy/status/1033016301319405570. Nor can we rely on negative emissions technology. “You can rule out a silver bullet,” said Prof John Shepherd, at the University of Southampton, UK, and an author of the report. “Negative emissions technologies are very interesting but they are not an alternative to deep and rapid emissions reductions. These remain the safest and most reliable option that we have.” Damian Carrington 2/1/2018. ‘Silver bullet’ to suck CO2 from air and halt climate change ruled out - Scientists say climate targets cannot be met using the technologies, which either risk huge damage to the environment or are very costly https://www.theguardian.com/environment/2018/feb/01/silver-bullet-to-suck-co2- from-air-and-halt-climate-change-ruled-out?CMP=twt a-environment b-gdneco citing Negative emission technologies: What role in meeting Paris Agreement targets? European Academies' Science Advisory Council. EASAC policy report 35. February 2018. https://easac.eu/fileadmin/PDF_s/reports_statements/Negative_Carbon/EASAC_Report_on_Neg ative_Emission_Technologies.pdf.

The agency cannot argue that grazing this area won’t make a difference in the global scheme of the climate problem, because, as Voltaire said, "No snowflake in an avalanche ever feels responsible.” The NEPA analysis must recognize that global warming will not be solved by one miraculous technological fix or by changing one behavior or one economic activity. The whole global carbon cycle must be managed to reduce carbon emissions and increase carbon uptake. Recent evidence supports the conclusions that all net emissions of greenhouse gases are adverse

to the climate. None can be considered de minimus. “We show first that a single pulse of carbon released into the atmosphere increases globally averaged surface temperature by an amount that remains approximately constant for several centuries, even in the absence of additional emissions. We then show that to hold climate constant at a given global temperature requires near- zero future carbon emissions. Our results suggest that future anthropogenic emissions would need to be eliminated in order to stabilize global-mean temperatures. As a consequence, any future anthropogenic emissions will commit the climate system to warming that is essentially irreversible on centennial timescales.” H. Damon Matthews and Ken Caldeira. 2009. Stabilizing climate requires near-zero emissions. Nature Vol 455 | 18 September 2008 | doi:10.1038/nature07296.

Former D.C. Circuit Judge Wald wrote in a 1990 dissenting opinion, which was recently quoted with unanimous approval by the Ninth Circuit in Center for Biological Diversity v. NHTSA: [W]e cannot afford to ignore even modest contributions to global warming. If global warming is the result of the cumulative contributions of myriad sources, any one modest in itself, is there not a danger of losing the forest by closing our eyes to the felling of the individual trees? 538 F.3d at 1217. Similarly, the US Supreme Court has already rejected the argument that the agency is making. The Supreme Court’s decision in Massachusetts v. EPA noted that one cannot avoid responsibility to reduce and mitigate the climate problem by attempting to minimize the scale of one’s contribution to the problem. ("While it may be true that regulating motor-vehicle emissions will not by itself reverse global warming, it by no means follows that we lack jurisdiction to decide whether EPA has a duty to take steps to slow or reduce it.... In sum, … [t]he risk of catastrophic harm, though remote, is nevertheless real. That risk would be reduced to some extent if petitioners received the relief they seek." 127 S.Ct. 1438, 1455 (2007) http://web.archive.org/web/20080610172128/http://www.supremecourtus.gov/opinions/06pdf/05 -1120.pdf)

Consider the Effects of Livestock Grazing on Forest Health

Livestock grazing has a direct influence on the vegetation structure that this project is designed to address. The agency must analyze the effect of past and future grazing which will tend to reduce palatable fine fuels like grasses and shift the plant community toward less palatable shrubs and trees which are more hazardous as ladder fuels. Livestock grazing probably contributed to the development of plant communities where grass and forbs are underrepresented and small conifers are over-represented. Grazing also likely contributes to the spread of juniper. Future livestock grazing will tend to cause these same trends, so the NEPA analysis must consider the connected and cumulative impacts of livestock grazing.

This project should take steps to address the threat that livestock grazing causes to forest health. There is little point in the agency’s efforts to mechanically reduce tree density unless other 26 underlying causes of overstocking are dealt with, e.g. livestock grazing. The NEPA document describes the effects “on” range resources (e.g., fences and transitory range) but fails to disclose or analyze the effects “of” livestock on forest health and the desired future condition of vegetation composition. The Council on Environmental Quality directs agencies to analyze actions together when the actions are similar in timing or geography, when doing so is the best way to assess the combined impacts of the actions (40 CFR §1508.25). As recognized by BLM, “Evaluating both actions in the same EA allows BLM to better assess the combined effects and to consider complementary design features to reduce potential conflicts among potentially competing uses.” Thurston Hills Trails and Foret Management EA, https://eplanning.blm.gov/epl-front- office/projects/nepa/75350/142227/174633/2018_04_23_THills_EA_Final_Print.pdf

Grazing reduces the density and vigor of grasses which usually outcompete tree seedlings, leading to dense stands of fire-prone small trees. Cows also decrease the abundance of fine fuels which are necessary to carry periodic, low intensity surface fires. This reduces the frequency of fires, but increases their severity. See Belsky, A.J., Blumenthal, D.M., “Effects of Livestock Grazing on Stand Dynamics and Soils in Upland Forest of the Interior West,” Conservation Biology, 11(2), April 1997. http://web.archive.org/web/20030409094020/http://www.onda.org/library/papers/standdynamics. pdf. See also Wuerthner, George. Livestock Grazing and Fire. January, 2003. http://web.archive.org/web/20040107135236/http://www.onda.org/library/papers/Livestock Gra zing and Fire.pdf.

The NEPA document needs to address these issues and consider alternative ways of avoiding these impacts by not grazing. The combination of fire suppression, past high-grading, and livestock grazing together caused the overstocked condition of the stands in the analysis area. Logging and prescribed fire will only partially address the problem. To be effective, livestock grazing must also be eliminated. Grazing and logging cause cumulative effects that must be considered together in one NEPA document.

The court’s decision in League of Wilderness Defenders v. USFS, Civil No. 04--488—HA. 2004 U.S. Dist. LEXIS 24413. November 19, 2004, makes clear that the agency has a duty to take a hard look at the effects of grazing in the context of making timber sale decisions. The agency must disclose cumulative impacts and cannot compartmentalize.

Further evidence of the adverse forest health effects of livestock are presented in Madany et al (1983): Abstract. Major differences were found between the vegetation structure of ponderosa pine-dominated communities on the Horse Pasture Plateau and those on the nearby but isolated Church and Greatheart Mesas in Zion National Park. The Horse Pasture Plateau

was heavily grazed by livestock in the late 19th and early 20th centuries, while the mesas were never grazed. Conditions on the mesas now approximate the pre-European situation of the region as described in the earliest written accounts. Pine, oak, and juniper sapling density and cover were much higher on the formerly grazed plateau than on the relict mesas. Herbaceous species dominated the groundlayer in mesa ponderosa pine savanna stands, while grass and forb cover was low on analogous sites of the plateau. Age-class distributions of major tree species further substantiated that major physiognomic changes have occurred on the plateau since the arrival of European man. Analysis of fire scars showed that prior to 1881, the mean fire-free interval for ponderosa pine stands on the plateau was 4 to 7 yr, while the interval for Church Mesa was 69 yr. Since there were no recorded fires on Church Mesa between 1892 and 1964, and yet no corresponding increase in sapling density, the increased understory density of plateau stands should not be attributed primarily to cessation of fires. Instead, heavy grazing by livestock and associated reduction of the herbaceous groundlayer promoted the establishment of less palatable tree and shrub seedlings, Fire, however, played an important secondary role in maintaining savanna and woodland communities. Michael H. Madany, and Niel E. West. 1983. Livestock Grazing-Fire Regime Interactions within Montane Forests of Zion National Park, Utah. Ecology: Vol. 64, No. 4, pp. 661-667.

Grazing is also known to have significant adverse impacts on ground nesting birds. Cattle Grazing in a National Forest Greatly Reduces Nesting Success in a Ground-nesting Sparrow. Glenn E. Walsberg. The Condor. Volume 107, No. 3. August, 2005.

The agency often erroneously concludes that livestock grazing will not affect upland vegetation of fuel profiles because fire suppressed stands are too dense to allow livestock access, but this is a gross oversimplification. The agency is conducting so-called “restoration” projects to reduce fuels and vegetation density which has and will allow livestock use. The NEPA document must disclose how livestock grazing interacts with the so-called forest restoration projects. The goal of restoration is a more open stand, and the agency wants more grass and forbs and fewer conifers, but grazing in those “restored” stands will cause the opposite effect – more conifers and less grass and forbs – thereby conflicting with the restoration objectives.

Each substantive issue discussed in these comments should be (i) incorporated into the purpose and need for the project, (ii) incorporated into a NEPA alternative, (iii) carefully analyzed as part of the effects analysis, and (iv) considered for mitigation.

Note: If any of these web links in this document are dead, they may be resurrected using the Wayback Machine at Archive.org. http://wayback.archive.org/web/

Sincerely,

Doug Heiken [email protected]

I urge you to not approve the Bridgeport Southwest Rangeland Project. Cattle grazing severely damages the terrain, which includes sensitive riparian and meadow areas and habitat for three federally listed endangered species (Sierra Nevada bighorn sheep, Yosemite toad, and Sierra Nevada yellow-legged frog) as well as habitat for the proposed federally threatened Bi-State greater sage-grouse.

Although there are certain written-in grazing limitations, these type of restrictions frequently do not hold since cattle always seem to find a away to get to water or meadows.

As a Mono County resident, I frequently go hiking, birding, and backpacking in these areas. I enjoy these beautiful places very much. I also have hiked in places with extensive cattle grazing and find the damaged habitat and the presence of cattle while hiking to be very disruptive to my experience and very damaging to the landscape. I urge the Forest Service to not approve of this project and keep these places for their recreational, wildlife and landscape values.

Thank you for this opportunity to comment.

Inouye

I cringed when I read that four closed grazing allotments on the eastern Sierra slope would be reopened under the "Bridgeport Southwest Rangeland Project." Being the author of a book on the effects of livestock grazing, I know that the environmental recovery that's been happening there for decades would be suddenly and dramatically reversed if this plan is adopted. PLEASE don't do it! I've spent a fair amount of time in the eastern Sierras and love the area. Let it keep getting more natural, healthy, and beautiful. Please don't re-trash it for the benefit of a few welfare ranchers. Thank you.

Jacobs

Alcon Reduced grazing aan increases fire. Grazing creates money from nothing. Please balance a fair compromise . Duh

As a former sheep rancher I oppose reopening these four allotments to cattle, or sheep. I've learned and observed the negative impacts livestock grazing has and I only condone it now on private land. Let the livestock producers pay market price to graze private land. If they can't make it using private land, they need to go into a different line of work. Please do not allow these allotments to be grazed by livestock ever again.

Thank you,

Johnson

Sirs,

Consider this an objection to opening up additional cattle grazing south of Bridgeport. How about enhancing the habitat for native wildlife and flora instead of degrading it?

I would be interested in hearing the rational for this proposal.

Kaufmann

You people have a long history of favoring the livestock industry over protecting the habitat for wildlife. I think it is time to do away with the forest service and BLM and start over with some dedicated people who know what they are doing besides writing reports and playing politics. There is way to many employees and vehicles. I have talked to some of your people who made to retirement and got away from the back biting atmosphere, the unhealthy work environment. They had nothing good to say about the forest and BLM.

Kern

Jan Cutts District Ranger Humboldt-Toiyabe National Forest Bridgeport Ranger District

Submitted via email to [email protected].

Dear Ms. Cutts,

The following comments pertain to the Forest Service’s Notice of Proposed Action (NOPA) to open high elevation allotments covering 19,360 acres on the Bridgeport Ranger District to cattle grazing. I am a research scientist with the University of California Sierra Nevada Aquatic Research Laboratory, and have studied aquatic habitats in the Sierra Nevada for more than 25 years, including effects of livestock grazing on California golden trout and water quality, and the status and conservation of sensitive amphibian species, including the endangered Sierra Nevada yellow-legged frog and threatened Yosemite toad. Based on my experience on these issues, I have significant concerns as to whether grazing impacts to threatened or endangered amphibians can be limited or mitigated as the NOPA claims. The comments provided here reflect my personal opinions and not those of the University of California.

The proposed allotments either partially overlap or are adjacent to designated Critical Habitat for both the Sierra Nevada yellow-legged frog and Yosemite toad. The proposed use of range riders to limit straying by cattle seems wholly impractical in the terrain covered by the allotments, and if true, use by cattle of this Critical Habitat could be substantially more extensive than the NOPA discloses. At a minimum, prior to the onset of cattle grazing, aquatic habitats in the allotments and adjacent areas should be thoroughly surveyed to document the current distribution of these and other amphibian species. This information would provide an assessment of baseline conditions and allow a more substantive assessment of potential impacts to Critical Habitat and sensitive amphibian species within the allotments and in adjacent areas (in the event that cattle stray beyond allotment boundaries).

Sincerely,

Knapp, Dear Humboldt-Toyaibe National Forest,

I am writing to express opposition to the proposed action and to urge you to keep the four allotments closed to cattle use.

As a sensitive, semi-arid high altitude area, this land is extremely vulnerable to cattle use, as I have personally witnessed in previous backpacking trips in Humboldt-Toyaibe National Forest. It contains many endangered species and should be managed for values of recreation and wildlife. I am strongly opposed to the proposed action.

Thank you for your consideration of my comments.

Kozarsky

Dear Leeann Murphy,

Dear Forest Service:

I'm writing in opposition to your proposal to re-open parts of the Hoover Wilderness to cattle grazing as part of the "Bridgeport Southwest Rangeland Project."

First established as a Primitive area in 1931, then a Wild area in 1957, the Hoover Wilderness was officially designated in 1964, making it one of the original members of America's National Wilderness Preservation System.

The area in question has not been grazed for years. Previously, the area was grazed by domestic sheep, but that practice was ended to protect the Sierra bighorn sheep, which is listed as both state and federally endangered. In fact, this area is within the Northern Recovery Unit for the Sierra Bighorn sheep.

Allowing cattle grazing in the Hoover Wilderness would create substantial impacts to the Wilderness and its watersheds and native wildlife. Parts of the grazing allotments are well over 10,000 feet in elevation and unsuitable for cattle grazing. Fencing would adversely impact existing habitats and protected species, such as Sierra bighorns. Cattle grazing would directly reduce native forage available for wildlife, damage vegetation and riparian areas, degrade water quality, and spread invasive weeds.

It isn't right to compromise the Hoover Wilderness, which belongs to all Americans, to benefit one or a few ranchers, none of whom have relied on it for their livelihood.

Thank you for your time and consideration.

Sincerely, Mieras

These allocations have been closed to grazing for many years and the natural habitat has recovered. Please do not open these allocations to grazing. Keep them closed to grazing and manage the area for the benefit of wildlife and recreation. There are endangered species in this area such as Sierra Nevada bighorn sheep, Yosemite toad and Sierra Nevada yellow-legged frog. Opening the area to grazing puts these species in more peril, as well as impacts the health of the natural ecosystem. The proposal would allow cattle to graze in Hoover Wilderness Area, where no livestock roam at present.

Thanks,

Miller August 5, 2019

Jan Cutts District Ranger Humboldt-Toiyabe National Forest Bridgeport Ranger District Submitted via email to [email protected].

RE: Notice of Proposed Action, Bridgeport Southwest Rangeland Project

Dear Ms. Cutts,

I am writing regarding the Forest Service’s Notice of Proposed Action (NOPA) to open high elevation allotments covering 19,360 acres on the Bridgeport Ranger District to cattle grazing. I do not support the agency’s proposal for the following reasons:

1. The sprawling region covered by the Dunderberg, Cameron Canyon, Summers Meadow and Tamarack allotments ranges in elevation from 8,000 to 10,000 feet and is home to a diverse mosaic of sub-alpine meadows, stands of mid to high-elevation conifers, extensive aspen groves, alpine fell-fields and extensive stream, wetland and riparian habitats. These areas have been closed to livestock grazing by domestic sheep since 2004-2009 (NOPA, p. 4). During that time vegetation and wetland/riparian systems have been allowed to recover, providing a laboratory of sorts to study mid-to-high elevation mountainous ecosystems that are “recovering” from livestock grazing. This region has great value for scientific study alone and should not be opened to impactful cattle grazing, particularly given the high elevations and sensitive habitats where cattle grazing would be introduced. As we increasingly see the effects of climate change, the generally mesic nature of this high elevation area may make it even more important as a habitat refuge for plant and animal species relative to other nearby areas, especially given its location in the otherwise arid western Great Basin. 2. The area provides habitat or potential habitat for several federal listed species (Sierra Nevada bighorn sheep, Yosemite toad and Sierra yellow-legged frog); the Bi-State population of Greater Sage Grouse, which is being considered for listing by the U.S. Fish & Wildlife Service; and the declining American pika. Other sensitive species may be present. What about rare or endemic plants, butterflies or the recently re-discovered Sierra Nevada red fox? Introducing cattle grazing into this area has the potential to adversely affect many of these species. Before authorizing grazing, surveys should be done to detect the presence of listed and sensitive species, including Sierra Nevada red fox and all other animal and plant species considered sensitive or declining by the Forest Service and/or the State. 3. I do not believe it is feasible for cattle to be herded in an open-range scenario in this location, as is being proposed (NOPA, p. 10). That method might work in an area with a directly adjacent base property, less convoluted topography, and absent the extensive wetlands, aspen groves and other sensitive habitats found here. In this specific location it will be easy for cattle to wander unseen up a drainage or into an aspen grove, to trample wetland and riparian vegetation, and to impact lands outside the authorized allotment areas. In the late 1980s I and others witnessed extensive trespass by open-range cattle in Sequoia Kings Canyon National Parks; cattle wandered from the Golden Trout Wilderness, where they were authorized, into the high elevation meadows of Siberian Outpost (11,000 feet) in Sequoia National Park, causing extensive resource damage that was documented by the Park. Also in the same general area within the Golden Trout Wilderness, cattle wandered from Big Whitney Meadow into Rocky Basin Lakes (elev. 10,784 feet), which was closed to cattle grazing and located approximately three miles from Big Whitney Meadow. Impacts were documented here as well. While the habitat in the Golden Trout Wilderness is different than that in the project area, it is similarly convoluted and indicates that herding by range riders in mountainous terrain can be extremely challenging and incapable of preventing trespass and resource damage in sensitive habitats such as high elevation wet meadows and alpine lakes. Fencing of these allotment parcels does not seem a viable option given the presence of sage grouse, mule deer, black bear and other animal species whose movements could be impeded by extensive fencing. 4. The area is increasingly important for dispersed recreation. There are not many areas in the Mono County where folks can enjoy non-wilderness dependent recreation at high elevations. Summer uses enjoyed by visitors and residents include hiking, hunting & fishing, mountain biking, photography, birding, nature study, car camping and 4WD exploring on legal roads. Introducing cattle into this landscape will very likely cause conflicts with the recreational uses that continue to grow in this region. I personally have enjoyed hiking, mountain biking, 4WD touring, camping and cross-country skiing in this area. 5. With reduced budgets and staffing in the agency, I fail to see how the Forest Service can possibly manage and monitor this project, if approved. Given the plethora of sensitive habitats and species in this region the agency should not authorize grazing here if it is incapable of managing the grazed lands to protect Forest resources over the long-term.

If the Forest Service decides to proceed with its proposal to authorize cattle grazing on these allotments, I request that the agency prepare an Environmental Impact Statement (EIS). I believe potential impacts to this very sensitive landscape will be significant and possibly irreversible in the case of the listed and sensitive species.

Thank you for considering my comments.

Sincerely, Miller

Olsen

District Ranger Bridgeport Ranger District, HC 62 Box 1000 Bridgeport, CA 93517

I would like to register my opposition to the Bridgeport Southwest Rangeland Project proposal to introduce cattle grazing into a number of environmentally vulnerable areas on the Toiyabe National Forest. I have a degree in Environmental Biology, worked 7 seasons for the Forest Service, and my family has owned property in the Virginia Lakes area since 1969.

The areas affected by these proposed grazing permits are precariously balanced ecosystems which, for the most part, are currently stable and a haven for numerous species of birds, wildlife and flora in the Eastern Sierra. Many of these areas, particularly the riparian and meadow areas, will be drastically altered and damaged by the introduction of cattle. It will affect not only the native species, but the recreational value to the taxpaying public.

The proposal suggests that when the tenuous equilibrium in these systems becomes threatened by grazing, adjustments will be made to reverse the damage. I believe this to be a dangerous position. Environmental reclamation is much harder than destruction, and the current budget supporting any environmental protection in the federal government is skeletal, at best. The manpower to assess, leave alone enforce the necessary grazing restrictions simply will not be available and the damage will become yet another permanent ecological loss. That is too high a price to pay just so a few wealthy cattlemen can increase their profits at public expense. Cameron, Dunderberg, Summers and Tamarack all deserve better. Please, please do not instigate this plan. We made steps forward by removing sheep. Let’s not destroy that progress by introducing cattle instead.

Sincerely,

Olsen,

Do not reopen area to cattle or sheep grazing. That former grazing almost destroyed an area full of native plant and animal life that needs to be protected.

Dear Sir/Madame,

I think it is very inappropriate to allow cattle or any grazing on public lands. It destroys the habitat and there is little to no enforcement of regulations when you say there will be. Do not allow any grazing on the Eastern Sierra Nevada lands.

Regards,

Adams D

I agree with Western Watersheds that the plan to reopen the allotments to grazing in the eastern Sierra Nevada is a terrible idea when this land should be set aside for wildlife and for recreation. Cows are very damaging to mountainous terrain and in fact to anywhere in the west. The eastern Sierra Nevada mountains is home to a host of endangered species of wildlife which should be left alone rather than having to deal with cows particularly when we have plenty of areas with cattle already.

Thanks for your attention

Alcock D I ask the Humboldt-Toiyabe National Forest to complete an EIS wxith a full analysis of a range of alternatives for this project. I support the conversion of these historic grazing allotments from sheep grazing to cattle grazing. This land has been used sustainable for decades for grazing, and it's acreage has been removed from our local working landscape under the argument that commercial sheep production could spread disease to Bighorn populations. The proposal to convert to cattle grazing is a win-win, the concern over disease transmission continues to be mitigated while this land can return to a working landscape role, providing our local economy with some much needed input.

No matter what level of environmental review is selected by the USFS for this project, it should also analyze and take into account the positive environmental consequences of allowing grazing to resume on this land. Proper grazing techniques can sequester carbon into the soil. Having active management of this land by ranchers can allow invasive species to be identified and managed quickly. Active irrigation management can provide more productive meadow environments, increasing habitat for native plants and animals. Fuels reduction associated with grazing can help to mitigate the threat of wildfire, also reducing post catastrophic wildfire issues such as watershed degradation through flooding and erosion.

Please no more cattle (nor sheep) grazing, give these allotments the time to restore itself for at least 12 years from the severe grazing damage and infestations, invest in surveys for rare, sensitive, and listed species; take better protective measures for water resources and species habitat on these allotments! Thank you Dear People, I stay in a cabin at Twin Lakes Estates, backpack and hike in the surrounding area, and have enjoyed occasionally seeing big horn sheep in the Sierra backcountry. I oppose sheep grazing in the beautiful meadow above Bridgeport due to the impact it could potentially have on the bighorn and native plants. Please don't allow this desecration of this beautiful area. D

Dear Leeann Murphy,

Dear Forest Service:

I'm writing in opposition to your proposal to re-open parts of the Hoover Wilderness to cattle grazing as part of the "Bridgeport Southwest Rangeland Project."

It isn't right to compromise the Hoover Wilderness, which belongs to all Americans, to benefit one or a few ranchers, none of whom have relied on it for their livelihood.

Thank you for your time and consideration.

Sincerely, Burger No more grazing in the N.National Forest. It injures the native plants; is bad for water queality, is harmful to native species, including big horn sheep. It is an abuse of our public lands. We need to keep these allotments closed and managed for the values of recreation and wildlife. Hiking through cow pies is not fun and we have to do enough of that already. You must protect the Wilderness according to rules concerning these areas. You must protect the Big Horned Sheep, other endangered animals, and plants. This is your job, your mission, and tax payers depend on you to do this.

Sheep do mot belong in any areas near where our heritage sheep live.

Wilderness must be protected so that it thrives for 9 generations. This is your work. Date submitted (UTC-11): 7/28/2019 1:27:14 AM First name: Last name: Dixon Organization: Title: Comments: I wish to voice my opposition to this proposed grazing addition, Project#49993, so close to the Hoover Wilderness. Many areas in the Bridgeport area are already open to grazing, be it sheep or cattle. Some real damage has occurred in the areas of Buckeye Creek, Swauger Creek (Sweetwaters) and along the Bodie Road. The effect on the water quality and wildlife habitat would be great, along with the negative impacts on the outdoor recreation that fuels so much of the Bridgeport economy. Again, I strongly recommend that Project #49993 be rejected and a more suitable site be studied for this use. Thank you for your time and consideration.

Date submitted (UTC-11): 7/26/2019 5:52:08 AM First name: Last name: Dollard Organization: Title: Comments: NO Grazing on Bridgeport Southwest Rangeland

I STRONGLY OBJECT to opening up the Bridgeport Southwest Rangeland Project to grazing. The BSRP will imperil the land's recovery that has been occurring for decades since the allotments were closed to sheep use, and endanger the habitats that have been thriving since the removal of domestic livestock. The area is a biodiversity hotspot, with three federally endangered species present: Sierra Nevada bighorn sheep, Yosemite toad, Sierra Nevada yellow-legged frog, as well as the Bi-State sage-grouse which is proposed for listing as federally threatened. Pacific fishers, rare Sierra Nevada red foxes, pikas, bald eagles, and Lahontan cutthroat trout also inhabit the area. There are wildflower fields, lush green meadows and groves of white bark pine and aspen. We need more places like this, not fewer.

The mountain is also popular for recreation, such as camping, hiking, wildflower-viewing, fishing, and gives access to the Virginia Lakes area and to the high Sierra Crest and Yosemite National Park back-country. The proposal should NOT allow cattle to graze in Hoover Wilderness Area, where CURRENTLY NO livestock roam at present.

Please PROTECT the Bridgeport Southwest Rangeland and do NOT allow ANY grazing to keep the wildlife protected and diverse! Sincerely, y Dollard

Date submitted (UTC-11): 7/26/2019 7:18:24 AM First name: Last name: E Organization: Title: Comments: Keep cattle grazing out of Hoover Wilderness in the Eastern Sierra!

We need to keep these areas carefully managed for the values of wildlife and recreation, and protect rare animals and plant life.

Thank you,

Etienne

Date submitted (UTC-11): 7/5/2019 8:43:54 AM First name: Last name: Farrell Organization: Title: Comments: I am commenting on Bridgeport Southwest Rangeland Project #49993. I am a concerned citizen, and frequent recreational user of the Humboldt-Toiyabe National Forest.

I oppose the proposal to open public land in the Cameron Canyon, Jordon Basin, Dunderburg, and Summer Meadows areas to cattle grazing. Natural vegetation has been making a comeback since these areas were closed to sheep grazing. Please do not create new disturbances with cattle grazing. I am especially opposed to new cattle grazing within the Hoover Wilderness. Livestock grazing is the bane of wilderness. It disturbs native ecosystems, often causes erosion, brings in non-native weedy plants, and creates unsightly and messy muddied areas and cow pies!

Date submitted (UTC-11): 7/26/2019 8:38:14 AM First name: Last name: Flores Organization: Title: Comments: To Whom It May Concern: I have spent many months of my life in the Eastern Sierra, particularly from the Long Valley up through Bridgeport and into the backcountry. I love to fish, hike, and camp in the region. I strenuously object to cattle grazing in this area. Instead it should be left for people to enjoy.

Cattle are water living creatures of habit. They simply do not belong in the arid west. They will befoul the water resources of the area making it unthinkable for hikers to even use water filters to purify the water. The trout will perish. It will go from a place of serenity and joy to an offensive cesspool. I am attaching a photograph of a befouled stream where I volunteered to help repair exclusion fences just last week. I assure you that while standing in that water, everything smelled of a backed up sewer pipe. This fate awaits these allotments.

What is more, the loss of usability of the public lands has only one purpose: to enrichen people with government subsidies. The science is clear that it doesn't prevent fires. Nor is there a justification for the presence of large undulates where none have existed in millenia.

Regretfully, Flores

Date submitted (UTC-11): 7/27/2019 4:23:19 AM First name: Last name: Frazier Organization: Title: Comments: It appears that this agency hasnt examined the problem with grazing sheep anywhere near bighorns! At the present time, mutton & lamb are not exactly the top choice for American's dinner table. Of course considering the cheap rate for grazing on our public & forested lands - how can this industry lose? The idea that because this land has healed - that its ok now to put sheep out to force competition with wild animals - sage grouse? that is already in danger & expected to be put on the threatened list. The grazing allotment program does NOT benefit the American public. In fact, we the public, have to make up the difference between what the industry pays and what this program actually costs. More & more people are choosing NOT to eat meat at this point in time. Do we really want to subsidize an industry that we are already subsidizing far too much?

Date submitted (UTC-11): 7/25/2019 11:35:39 AM First name: Last name: Fretheim Organization: Title: Comments: This is a bad idea.

Date submitted (UTC-11): 7/20/2019 11:15:02 AM First name: Last name: Geiken Westerberg Organization: Title: Comments: I am against allowing cows to graze on this land. I have been on land that the cows have been allowed on and have seen the damage to stream beds, trampling of low wetlands and vegetation. For example, the Clark canyon and Molybdenum creek get destroyed by pulverized soil into dust, trampled vegetation and flies. They ruins it for other users such as fisherman, hikers and campers by early June. These are public lands to be managed for the public.

Date submitted (UTC-11): 7/20/2019 11:15:02 AM First name: Sharon Last name: Geiken Westerberg Organization: Title: Comments: I am against allowing cows to graze on this land. I have been on land that the cows have been allowed on and have seen the damage to stream beds, trampling of low wetlands and vegetation. For example, the Clark canyon and Molybdenum creek get destroyed by pulverized soil into dust, trampled vegetation and flies. They ruins it for other users such as fisherman, hikers and campers by early June. These are public lands to be managed for the public.

Date submitted (UTC-11): 7/28/2019 5:31:37 AM First name: Last name: Glaccum Organization: Title: Comments: Reopening the retired sheep allotment to cattle grazing is NOT compatible with s healthy, diverse ecosystem. The allotment was retired for a reason in this arid high country and should remain retired.

Date submitted (UTC-11): 7/26/2019 5:44:13 AM First name: K. Last name: Gregg Organization: Title: Comments: The "Bridgeport Southwest Rangeland Project" will imperil the land's recovery that has been occurring for decades since the allotments were closed to sheep use, and endanger the habitats that have been thriving since the removal of domestic livestock.

The area is a biodiversity hotspot, with three federally endangered species present: Sierra Nevada bighorn sheep, Yosemite toad, Sierra Nevada yellow-legged frog, as well as the Bi-State sage-grouse which is proposed for listing as federally threatened. Pacific fishers, rare Sierra Nevada red foxes, pikas, bald eagles, and Lahontan cutthroat trout also inhabit the area. There are wildflower fields, lush green meadows and groves of whitebark pine and aspen. We need more places like this, not fewer.

Date submitted (UTC-11): 7/26/2019 6:05:35 AM First name: Last name: Hoover Organization: Title: Comments: Hoover Wilderness Grazing

I grew up as a dependent of an Air Force serviceman. One of the vivid memories I have is going camping in the commons area in England. Frequently we had to set up in areas that had either fresh or dried out cow patties available to us. As kids it was fun as we were told that dried cow patties could be burned as fuel. I never tried it. Later in life we moved to Idaho to a place called Mountain Home. I was excited just by the name. Go look at a map. I joined a troop and camped and hiked my way through high school to a decision to work for the rest of my life in those areas of the state that are iconic beautiful. We were pestered even in these areas by mosquitos that I finally figured out were being fed by livestock that grazed in the areas that were not actual wilderness. My dream came true and I got work as a wildlife agent with the state right out of school. My career other routes and I had to leave that state to help other agencies of the federal government. Our public lands are held in trust and you folks are responsible to keep these areas acceptable for use by all. Cow patties last a long time especially in the arid environment of the eastern Sierra. I have backpacked this area over the last 30 years quite a bit and those turds do not just go away. Nor does the damage done by hooves to the fragile soil of these environments. Worse is the damage to riparian areas that cattle do as they prefer these more moist and cool areas, like we do too.

See what my surname is? I do not give you permission to use my land for grazing cattle. Or sheep either.

Hoover

Date submitted (UTC-11): 7/26/2019 5:48:29 AM First name: Last name: Jacobs Organization: Title: Comments: What a terrible idea... silly, really. Removing livestock has made this area amazing, why would the FS put them back? The greater Mono Lake region and eastern Sierra are special and deserve to thrive in a natural state. Livestock produce little value for anyone, and huge detriment to the public and wildlife. Cow politics are done, get over it, protect the public resource, please.

Date submitted (UTC-11): 7/26/2019 6:14:00 AM First name: Last name: James Organization: Title: Comments: Please stop opening land up for grazing to cattle and sheep. The book I just finished is about Alexander Von Humboldt you would do well to read and take the advice of someone who really knew what he was talking about. Stop opening any land to Rachers. James CT

Date submitted (UTC-11): 7/8/2019 5:57:53 PM First name Last name: Kallio Organization: Title: Comments: The Wilderness Act of 1964 provides for the preservation of certain undeveloped federal land at the most protective level and mandates that wilderness areas shall be "protected and managed so as to preserve their natural conditions." The Act defines wilderness: "Wilderness is land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions." In addition, wilderness should be "affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable."

Incongruously, the Wilderness Act allowed livestock grazing to continue in areas where grazing was established at the time of wilderness designation. This was done to appease Western ranchers and get sufficient Congressional votes to pass the Act. Since grazing is inherently contrary to the concept of wilderness, and since removal of grazing from wilderness lands will present only minor impacts to the livestock industry as a whole, the most logical strategy is that it should be phased out or eliminated rather than encouraged and expanded.

I strongly feel that the allotments located in and adjacent to the Hoover Wilderness be deleted from the Bridgeport Southwest Rangeland Project Proposed Action. The primary supporting reasons are contained in the section entitled Identification of Issues, pp. 13-19, which clearly reports an overwhelming number of negative effects from grazing than positive effects. Furthermore, there appears to be an inherent, erroneous assumption in the proposal that sheep grazing is equivalent to cattle grazing in terms of environmental impact and management. It is indisputable that the heavier cow will do more damage to the environment, especially in wet pastures. While there is a history of sheep grazing in these allotments at the time of the wilderness designation, no evidence of cattle grazing has been documented. So, why allow it now?

Date submitted (UTC-11): 7/26/2019 4:54:37 AM First name: Last name: King Organization: Title: Comments: Please do NOT allow cattle grazing on these areas. Apart from the deleterious effect on the Sage Grouse and the destruction of the viewshed, the roots of the Aspen trees will be thoroughly compromised as demonstrated in a recently published article.

Date submitted (UTC-11): 7/20/2019 2:56:16 PM First name: Christopher Last name: Lish Organization: Title: Comments: Saturday, July 20, 2019

Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport, CA, 93517

Subject: Reject proposal to re-open parts of the Hoover Wilderness to cattle grazing as part of the Bridgeport Southwest Rangeland Project.

To Forest Service Bridgeport Ranger District Project Manager Aaron Coogan and District Ranger Jan Cutts:

I'm writing in strong opposition to the proposal to re-open parts of the Hoover Wilderness to cattle grazing as part of the Bridgeport Southwest Rangeland Project.

"It is horrifying that we have to fight our own government to save the environment." -- Ansel Adams

"Every man who appreciates the majesty and beauty of the wilderness and of wild life, should strike hands with the farsighted men who wish to preserve our material resources, in the effort to keep our forests and our game beasts, game-birds, and game-fish--indeed, all the living creatures of prairie and woodland and seashore--from wanton destruction. Above all, we should realize that the effort toward this end is essentially a democratic movement." -- Theodore Roosevelt

As you are aware, the area in question has not been grazed for years. Previously, the area was grazed by domestic sheep, but that practice was ended to protect the Sierra bighorn sheep, which is listed as both state and federally endangered. This area is within the Northern Recovery Unit for the Sierra Bighorn sheep.

"Our government is like a rich and foolish spendthrift who has inherited a magnificent estate in perfect order, and then has left his fields and meadows, forests and parks to be sold and plundered and wasted." -- John Muir

Allowing cattle grazing in the Hoover Wilderness would create substantial impacts to watersheds, native wildlife, and wilderness. For example: * needed fencing will adversely impact existing habitats and protected species; * cattle grazing will directly reduce native forage available for wildlife and impact habitats; * cattle grazing will adversely impact water resources, water quality and riparian areas; cattle grazing will spread invasive weed species; * cattle grazing will adversely impact recreational users; and * parts of the grazing allotments are well over 10,000 feet in elevation and unsuitable for grazing by cattle.

"Do not suffer your good nature, when application is made, to say 'Yes' when you should say 'No'. Remember, it is a public not a private cause that is to be injured or benefited by your choice." -- George Washington

It isn't right to compromise the Hoover Wilderness--which belongs to all Americans--to benefit one or a few ranchers, none of whom have relied on it for their livelihood.

"A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise." -- Aldo Leopold

Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources.

Sincerely,

Date submitted (UTC-11): 7/3/2019 12:48:11 PM First name: William Last name: Lundeen Organization: Title: Comments: Please do NOT allow cattle to graze in the same area as bighorn sheep! Much has been done to seek the growth and comeback of the Sierra bighorn. Don't hurt that now!

Date submitted (UTC-11): 6/26/2019 9:27:15 AM First name: Anon Last name: Ilene Organization: Title: Comments: Fwd: Bridgeport Southwest Rangeland Project

Sent from my iPad

Begin forwarded message:

From: Date: June 26, 2019 at 1:18:49 PM PDT To: [email protected], [email protected] Subject: Re: Bridgeport Southwest Rangeland Project

To: BridgeportRanger District, Humboldt-Toiyabe National Forest

I am writing because I just learned via other concerned parties about your announcement regarding a Proposed Action concerning the Bridgeport Southwest Rangeland Project. Although I submitted comments during your scoping for this issue more than a year ago, ( please see below), I did not receive via email your recent NOPA letter. I have also learned that several others who sent comments during scoping did not receive this notification.

As we should have received notice and have already lost more than a week of review time for the revised proposed action, I am requesting that you send by email notice to your complete list of commenters who responded during the earlier scoping and that you provide an additional two weeks for submission of comments on the NOPA.

I also request that you provide formal notification of the project and comments deadline in a newspaper local to Mono County, where the project would take place, in addition to the Reno-Gazette, which is a paper not readily available in Mono County.

Thank you very much,

Mandelbaum

To: [email protected] Subject: Fwd: Bridgeport Southwest Rangeland Project

Dear Ms Murphy,

I am resubmitting theses comments as a word document, just in case. Will that work?

Thank you,

Ilene Mandelbaum

-----Original Message----- From: Ilene <[email protected]> To: comments-intermtn-humboldt-toiyabe-bridgeport <comments-intermtn-humboldt-toiyabe- [email protected]> Sent: Thu, Jun 7, 2018 3:28 pm Subject: RE: Bridgeport Southwest Rangeland Project

Leeann Murphy Acting District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport CA 93517

Via email <[email protected]>

June 7, 2018

RE: Bridgeport Southwest Rangeland Project

Dear Ms. Murphy:

Please consider the attached comments that I am submitting in response to the scoping on the above proposed action. I would appreciate an acknowledgment that you have received and can download my comments!

Thank you very much,

Ilene Mandelbaum PO Box 89 Lee Vining, Ca 93541 [email protected]

Date submitted (UTC-11): 7/25/2019 6:45:34 AM First name: Kim Last name: Marcus Organization: Title: Comments: My wife and I are residents of the Twin Lakes subdivision, located southwest of Bridgeport and just north of the proposed grazing alotment. We strongly oppose the opening grazing permit to cattle. We are fearful that our water supply, which comes off Crater Crest, will be contaminated by fecal material from said animals. We also value a cattle free environment in Summers Meadow and environs as a means of preserving its biological diversity. It is a stunningly beautiful and fragile area that is only now recovering from the prior sheep grazing permit. The highest and best use of the land should be for recreational enjoyment and resource recovery and enhancement. There are already way too many cattle in the East Walker River watershed as detailed in the watershed analysis, and the fecal count in Bridgeport Reservoir. This will only make matters worse. Please deny this grazing permit. Sincerely, Kim and Wendy Marcus

Date submitted (UTC-11): 7/25/2019 8:51:17 AM First name: Leslie Last name: McCollum Organization: Title: Comments: I oppose the sheep grazing. No benefit to the few outweighs the damage to the many that would occur.

John Muir said it best: sheep are hooved locusts .

Thank you

Date submitted (UTC-11): 7/4/2019 1:50:31 AM First name: Veronica Last name: Michael Organization: Title: Comments: Please protect our public lands from development.

Date submitted (UTC-11): 7/26/2019 5:45:51 AM First name: Zak Last name: Miller Organization: Title: Comments: Proposed grazing allotments

Please follow your recommendations and move forward on the proposed grazing permits, our bbn public lands belong to all and must be vibrant and healthy. Reasonable and science based grazing on public lands ensures the long term health and viability of the landscape. If we fail to stimulate and manage our public lands, nature will do it for us with much greater and dire consequences.

Please approve the livestock permits

Thankyou

Date submitted (UTC-11): 7/25/2019 11:27:21 AM First name: Last name: Moser Organization: Title: Comments: No domestic sheep in or near wilderness or proposed wilderness!

To whom it may concern,

As a biologist I am aware of the damage that domestic sheep stocks can do to a region's ecosystem-not to mention harming the bighorn populations.

I am very familiar with the Eastern High Sierra as I grew up in Ridgecrest and have vacationed in the Bishop area every year for two decades.

Please do not allow domestic stock (of any species!) to be given access to either proposed or actual wilderness areas, or anywhere they may pose a threat to bighorns.

Thank you,

Date submitted (UTC-11): 7/29/2019 8:35:54 AM First name: Last name: Olson Organization: Title: Comments: Dear USFS:

I am writing to urge you decline the grazing permit for the Cameron Canyon, Jordon Basin, Dunderburg, and Summer Meadows areas, near the community of Bridgeport. This area is used for hiking, hunting, fishing, and other forms of recreation. It also contains cultural resources, and is a critical habitat for Sierra Nevada Bighorn Sheep, Sierra Nevada Yellow-legged Frog, and Bi-state Sage Grouse. To fill this recovering area with cattle-- and all the accompanying infrastructure-- would do great harm to existing activities. Concerns also include impacts to vulnerable animal and plant species, meadows, riparian areas, water quality, cultural resources, and the spread of invasive species An EIS with a full analysis of a range of alternatives for this project must be completed. I strongly recommend the Humboldt-Toiyabe National Forest decline this cattle allotment proposal.

Thank you.

Date submitted (UTC-11): 7/30/2019 5:45:46 AM First name: NANCY Last name: PARSONS Organization: Title: Comments: I would like to see the Bridgeport Southwest Rangeland remain as open space. As stewards of public lands the forest service should complete an EIS with full analysis of a range of alternatives. Since it took roughly ten years for the area to recover from the last grazing period why should it be depleted again? And, after all the hard work of trying to protect and grow the wild sheep population, why risk grazing domestic sheep which can introduce disease to that protected population? Grazing cows would once again deplete the natural grasses and flowers. Please leave this area as open space for the public to enjoy!

Date submitted (UTC-11): 7/25/2019 8:53:45 AM First name: Calle Last name: Peek Organization: Title: Comments: I think it would be great to see the area grazed by livestock once again. That area has historically benefited from livestock grazing, and mountain meadow that were created by herders to graze their animals should be maintained in a safe way and conscientious way. Wildlife herds, such as deer, will flourish with increased irrigation and grazing management. Sage grouse populations also do well in combination with cattle herds, as it increases the amount of sage brush to meadow areas. And my final point, grazing is historically the best wildfire prevention. We have lost too many key habitats in the State of California to wildfires and mismanagement of resources, it would be a shame to see it happen again here.

Date submitted (UTC-11): 7/3/2019 6:07:42 PM First name: Last name: Ratcliff Organization: Title: Comments: I hiked in the Sierra Nevada mountains, when I lived in California. I hiked four or five times, to a destination called Scout Carson Lake. About midway through the hike, a ski lift tower's top at the Kirkwood resort, is visible over a high ridge. Cattle herds graze along the hiking trail. The cattle ruin the hiking experience. They trample stream-side vegetation, and muddy the stream waters. They leave manure in large quantities. Once, as I passed a cattle herd, a big bull eyed me from about 15 yards. It was in the open, and there was no cover, if that thing had charged. My negative memories of cattle grazing on public land compel me to urge you to disallow cattle on tracts of land that they would ruin.

Date submitted (UTC-11): 7/29/2019 12:01:25 PM First name: Last name: Rhoades Organization: Title: Comments: Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport CA 93517

August 5, 2019

Re: Bridgeport Southwest Rangeland Project Proposed Action

Submitted via email to: [email protected]

Thank you for the opportunity to submit comments on the Notice of Proposed Action (NOPA) for the Bridgeport Southwest Rangeland Project. I am concerned about the proposal to authorize cattle grazing within SNBS Critical Habitat and within lands that could be locations for reintroduction in the future. The USFS did not analyze the potential for cattle to transmit disease to wild sheep and the behavioral modifications wild sheep undergo when cattle are present. Because SNBS are federally listed as endangered, the Forest must undertake a full Environmental Impact Statement and analyze any and all potential impacts to this species. A lack of adequate governmental regulatory mechanisms relative to domestic sheep grazing was one of two reasons these sheep received federal endangered status in 1999.

Cattle grazing has the potential to negatively impact bighorn populations: cattle are known to carry pathogens that can be transmitted to bighorn sheep, cattle may displace bighorn sheep from optimal habitats, reducing foraging efficiency, and cattle contribute to the spread of noxious weeds which outcompete native vegetation, degrade bighorn sheep habitat, and increase fire risk. Bighorn sheep remain at risk of disease from livestock pathogens throughout the West, with authorized grazing on public lands a limiting factor for many populations. Large areas of historic bighorn sheep habitat are unavailable for recolonization or artificial restocking due to the presence of livestock, including in California.

I appreciate the Forest action to cancel sheep permits and the opportunity for this area to recover ecologically over the last decade but am puzzled by the agency then proposing that cattle graze high elevation areas within critical habitat. However, the Forest Service has the authority to decline grazing permits for cattle as well in order to protect endangered species. This can occur without a plan amendment. I ask that the Forest Service modify the allotment boundaries to exclude bighorn sheep critical habitat.

It is my understanding that the Forest Service must complete a Biological Evaluation to determine the likelihood of harm to bighorn sheep viability. In addition, the Forest Service must make sure that actions authorized, funded, or carried out by them are not likely to jeopardize the continued existence of any threatened or endangered species or result in the destruction or adverse modification of their critical habitats and adverse impacts on threatened and endangered species and their habitats, except when it is possible to compensate adverse effects totally. It is critical for USFS to engage with CDFW and USFWS on the preparation of a Biological Evaluation, and should an EIS be prepared, the preparation of a USFWS Biological Opinion.

The effort to recover populations of SNBS has been an effort involving numerous governmental agencies. With this in mind, the Forest Service must analyze and disclose the potential impacts of cattle grazing on Sierra Nevada Bighorn Sheep including those from disease, displacement, forage competition and noxious weeds. The Forest Service must take steps to contribute to the recovery of the species and avoid any adverse impacts to the species or its habitat.

Thank you for this opportunity to comment.

Letter is File 1 Attachment. Thank you.

Date submitted (UTC-11): 6/26/2019 5:02:32 AM First name: Last name: Robinson Organization: Title:

Phone: Comments: I am in favor of responsible grazing because it will provide beneficial fire control, eliminate cheatgrass, and provide agricultural economic support to Mono County.

Date submitted (UTC-11): 7/26/2019 6:28:36 AM First name Last name: Ruprecht Organization: Title: Comments: I strongly oppose the re-opening and authorization of livestock in these allotments. Please do not authorize grazing in these allotments. The lands are far more valuable for recreation, native species habitat, and ecosystem services than they are for the private profit of the livestock industry.

Date submitted (UTC-11): 7/26/2019 7:14:16 AM First name Last name: savelolitap Organization: Title: Comments:

The U.S. Forest Service is proposing to reopen four closed allotments on the wild and scenic Eastern Sierra slope to cattle use. The "Bridgeport Southwest Rangeland Project" will imperil the land's recovery that has been occurring for decades since the allotments were closed to sheep use, and endanger the habitats that have been thriving since the removal of domestic livestock. We want to keep these allotments open for wildlife

Marcus, G.G.

Date submitted (UTC-11): 7/4/2019 1:42:11 AM First name Last name: Seltzer Organization: Title: Comments: Stop destroying our planet.

Date submitted (UTC-11): 7/26/2019 8:21:02 AM First name: Last name: Shepersky Organization: Title: Comments: Hi Forest Service,

We have a lot of livestock grazing on public lands already. Large-scale grazing has negatively impacted our wildlands in so many ways, and now we're proposing to open even more protected land to this use? Can we please leave this particular space to be managed for wildlife? (Leaving it alone and letting the wildlife manage themselves might be worth looking into as well.)

Thanks for your time and the work you do.

Date submitted (UTC-11): 7/25/2019 3:41:43 PM First name: Last name: Short Organization: Title: Comments: I support the opening of this land to cattle grazing. Grazing will help these grasslands and should be opened asap.

Date submitted (UTC-11): 7/28/2019 4:04:16 PM First name: Last name: Smith Organization: Title: Comments: I frequently hike in this area in the late summer and fall. I am a landscape and wildlife photographer. This beautiful area will be ruined by cattle. They will foul the water and tear up meadow areas. Please do not destroy this area with cattle.

Date submitted (UTC-11): 7/5/2019 3:33:55 AM First name: Last name: Smoak Organization: Title: Comments: Dear Ranger,

I would urge you against allowing cattle on any State or Federal Property. They are some of the most eco- destructive creatures in the world. Bison and deer are what should be allowed, not domestic cattle nor sheep.

Smoak,

Date submitted (UTC-11): 7/5/2019 5:03:50 AM First name Last name: Swenson Organization: Title: Comments: Please do not allow cattle to graze on land near Bridgeport, Ca. Not only are cows detrimental to the land itself, but pose a threat to the native species which inhabit the area, such as the Big Horn Sheep.

Date submitted (UTC-11): 7/25/2019 10:01:52 AM First name: Last name: Theotig Organization: Title: Comments: I am writing to submit my comments for the "Bridgeport Southwest Rangeland Project #49993". I strongly support a complete Environmental Statement (EIS) be conducted to adequately identify all significant and cumulative impacts be addressed to assure an objective and complete analysis of the proposed grazing area. Impacts to natural resources include special plant and animal species, invasive weeds, riparian areas, water quality, and meadows. The Forest Service has an option to decline this allotment if the EIS conclusions justify such a decision. This area has been improved from 10 years of restoration and rest from grazing. Why would the Forest Service now decide to degrade an area by reintroducing cattle and/or sheep grazing?

Date submitted (UTC-11): 7/26/2019 7:03:50 AM First name: Last name: Valentine Organization: Title: Comments: Humboldt Bridgeport

To whom it may concern,

I do hope you will reconsider the opening of four closed allotments on the wild and scenic Eastern Sierra slope to cattle use. The Bridgeport Southwest Rangland Project will imperil the land's recovery that has been occurring for decades since the allotments were closed to sheep use, and endanger the habitats that have been thriving since the removal of domestic livestock.

The mountain is also popular for recreation, such as camping, hiking, wildflower-viewing, fishing, and gives access to the Virginia Lakes area and to the high Sierra Crest and Yosemite National Park backcountry. The proposal would allow cattle to graze in Hoover Wilderness Area, where no livestock roam at present. I do not agree with any action that hinders the few remaining wild spaces our great country has!!!

Thank you kindly,

Sarah

Date submitted (UTC-11): 7/28/2019 10:27:57 AM First name: Last name: Walter Organization: Title: Comments: My comment is that a full EIS is required. There has simply been to much recovery to allow questionable practices which could reverse positive gain. I am concerned especially with bighorn sheep, bistate grouse, yellow legged frogs and the quality of the land itself

Date submitted (UTC-11): 7/26/2019 10:00:51 PM First name: Last name: Warner Organization: Title: Comments: The U.S. Forest Service is proposing to reopen four closed allotments on the wild and scenic Eastern Sierra slope to cattle use. The "Bridgeport Southwest Rangeland Project" will imperil the land's recovery that has been occurring for decades since the allotments were closed to sheep use, and endanger the habitats that have been thriving since the removal of domestic livestock.

Therefore, I strongly oppose this plan.

Date submitted (UTC-11): 7/26/2019 7:16:23 AM First name: Last name: Webb Organization: Title: Comments: No good reason for cows to trample needed habitat

Please reconsider allowing livestock on lands needed for critical habitat for endangered species.

Date submitted (UTC-11): 7/12/2019 6:22:57 AM First name: Last name: Willimann Organization: Title: Comments: This proposal will destroy some of the most beautiful and hiking accessible areas in the Eastern Sierra. We live here and have seen how cattle can destroy natural habitat. These areas have just begun to recover from sheep grazing, which are much less destructive than cattle. The water quality going into Mono and Bridgeport valley would be very degraded. Look at the runoff after Robinson Creek or Buckeye run through the cattle grazing in Bridgeport valley and enters the Bridgeport Reservoir. It is dark brown and filled with excrement and waste. There have been studies and mitigation recommendations but the ranchers have just disregarded them. I think that will be the case if cattle are allowed in these even more beautiful places. Hiking up in Buckeye canyon after the cattle are allowed there is a exercise in "cow paddle" avoidance. The native flowers are disappeared, the creeks and small streams are destroyed. There is PLENTY of cattle grazing already here. Give nature some peace and quiet. Enforcement of the conditions of using these areas will be negligible. They are already overworked and underpaid. As a resident I am very much opposed to allowing this Project to be approved.

Date submitted (UTC-11): 7/16/2019 9:27:58 AM First name: Last name: Willimann Organization: Title: Comments: I strongly oppose cattle grazing on these parcels. They just barely recovered from sheep grazing. Cattle are very destructive relative to native plants, water quality, and riparian habitats. These areas are prime tourist attractions and recreational venues for hiking. Our area is already inundated with ranching in the Bridgeport valley and Bodie Hills. Please allow some open and relatively pristine areas for hiking, photography and recreation. Thank you,

Date submitted (UTC-11): 7/25/2019 8:14:21 AM First name: Last name: Willis Organization: Title: Comments: Please conduct a full EIS before allowing cattle into this area.

Date submitted (UTC-11): 7/25/2019 7:54:02 AM First name: Last name: Yoon Organization: Title: Comments: I do not support opening historical allotments that will endanger local wildlife and fauna which includes the Bighorn Sheep. It was due to the transmission of disease from domesticated sheep that nearly wiped out the Bighorn sheep in the sierra. We have invested a significant amount of time and resources to restore the meadows, uplands and riparian systems from grazing, and we are only recently seeing a remarkable recovery that it would be counterproductive to open these lands for grazing, only to be destroyed once more.

Jan Cutts District Ranger Bridgeport Ranger District HC 62, Box 1000 Bridgeport, CA 93517

Dear Jan Cutts,

I would like to thank you for extending the comment period on the proposed cattle grazing permitting on the Bridgeport Southwest Rangeland project.

I have owned a cabin in the Virginia Lakes cabin area for 28 years. I will address my comments to the Dunderburg allotment of this proposal as this is the area I am most familiar with. In the 28 years that I have explored that area I have seen it go from heavily grazed by sheep to the recovered meadows that are the current state.

In exploring the upper meadows of the Dunderburg allotment last week (7/26/2019) I compared the ungrazed meadows that were full of a variety of wildflowers with the meadows down by Sinnamon meadow that are part of the Eastern Sierra Land’s (ESLT) easement. Within the easement cattle are grazed, although they were not there last week. All meadows looked good, they were lush with grass and forbs, but the easement meadow was sorely lacking in a diversity of flowers the other meadows had. If the allotments are grazed in this proposal as planned, the ground cover may be maintained but the diversity of plants will be changed. My other concern regarding the plants is the transportation of invasives. There is minimal cheat grass now in the Dunderburg allotment, just along some of the roadside and the lower watering feature. As cows eat the grass, they will start spreading it farther and the reasonably healthy meadows now could become more cheat grass infested and increase the fire danger.

In the proposal it mentions that the historical sites are mostly mortars, lithic scatters and arborglyphs. However, from what I can tell on the map (Fig.3, pg.9), the upper water feature in the Dunderburg allotment is located in a Forest Service designated historic monument with a stable, cabin and bunk house. Nearby there is a two-stamp mill. This area is a lovely meadow used currently by deer hunters and would be a place the cows would like to hang out as there is Dog creek to drink from, good forage and shade. I am concerned that the cows scratching on the buildings will speed up their decline.

In the 13 years since this area has been grazed the recreational use has changed dramatically. Where in the early 1990 I usually had the area to myself and rarely saw anyone as I rode my mountain bike along the dirt roads; there are now people camping in the deer camps along the Dunderburg Meadow Road all summer long. Since that area has become a designated OHV area the use and misuse of the roads has increased tenfold.

I would like to encourage you to do a full analysis of the impacts to the area, taking into consideration how the meadows have recovered from former grazing; and what the combined use of cattle grazing and the increased motor and non-motorized recreation will have. Please complete an Environmental Impact Statement and do a full analysis of the range of alternatives for the project.

Thank you,

Quinlan

To Whom It May Concern:

I am a retired federal forester with a comprehensive background in managing natural resources on public lands, including National Forests.

I have personally witnessed the negative impacts that the mis management of long term domestic livestock grazing can have on native vegetation, soils, water, wildlife and riparian ecosystems (especially springs and quaking aspen communities).

Therefore, I am strongly opposed to the reopening of these allotments on these public lands.

Sincerely yours,

Ratliff

To the Directors of Humboldt-Toyaibe National Forest, 7/24/19

I live in Menlo Park, CA. I’m a retired Midpeninsula Regional Open Space District ranger, and do most of my hiking and camping in the Bay Area. I’ve been backpacking in the Sierra Nevada and leading Sierra Club National Outings in the Sierra Nevada every summer since I was 22 years old. I’m writing to ask you to keep the cows out of the Sierra Nevada sub-alpine meadows; they do not belong there. My most immediate objection to them is aesthetic. Viewing cow dung and cow tracks and cows really spoils my whole reason for coming to a wilderness area. I avoid visiting areas open to grazing as I object strongly to cow pies, one every couple of yards in any direction, in varying degrees of freshness. Walking through cow pies in the heat of summer is not just ugly but smelly and physically annoying because of all the flies. My aesthetic sensibilities are offended. Could I perhaps also note that that many flies on a public trail could constitute a public health risk? Continuing with the appearances: creeks, wetlands, and ponds are badly degraded by cattle tromping around in them, and presumably relieving themselves as well. Creek banks and meadows, which ought to be alive with lush green ferns and mosses, are reduced to muddy mires. Free-flowing, protected watercourses and wetlands of California are imperiled by cows. These riparian corridors desperately need to be protected! They are, or used to be, the homes of so many rare and endangered species. My secondary objection to the cows is that they do not belong here. They are not wild animals; they are farm animals and this is not a farm. This is, in fact, supposed to be a wilderness; it is labeled as such. The light, air, soil and water in this tiny patch of California is supposed to be devoted to the wild flora and fauna. Even humans don’t “belong” in a wilderness area; we can only visit, and try to be as unobtrusive as possible. The wild plants and animals have nowhere else to go. These last little bits of parkland are all that remain of their home. They can’t go live on a farm. The cows can. Finally, I object to public tax dollars going to subsidize Big Agriculture. Our public lands are being pillaged by these “hoofed locusts,” for a pittance of the true value of the resource they are destroying. I don’t know how much the rancher would be paying you to let his cattle graze on our land, but I’m sure it wouldn’t cover the cost of trying to restore the area the cattle have trashed. Everywhere the cattle go, they terrace the hillsides, they foul the water, they eat the seedlings of native trees and shrubs, they perpetuate weedy non-natives and they occupy the niches that rightfully belong to our native, and endangered wildlife. That’s a lot of restoration. Huge tracts of land, much of it public land, throughout the West is given over to cattle grazing and it makes no sense, even economically, if you factor in the true cost of the environmental damage. Why are we subsidizing the cattle industry? There is the “wildflower” argument: by eating down the thatch of the non-native grasses the cows open up the ground to wildflower seedlings. Sounds good, but I don’t believe it. Go check it out for yourself. Compare the grazed and un-grazed side of a fence, especially one that crosses under a large oak tree where the soil is moist. The ungrazed side has ferns and snowberry and ginger; the grazed side has mud, or bull thistle. By continuing to graze cows on our land, as has been done for the last several hundred years since the time of the Spanish, we don’t, at this point “introduce” weedy species. They are already there. We just let the cows eat them down so the annual weedy cycle can start again. We’ve been doing this for years and the weeds don’t go away. Try something new. Break the cycle. Kick out the cows. Finally, there are the pastoralists, the cowboys and girls, people whose families have made a livelihood ranching, often for many generations. They probably don’t consider themselves and their friends Big Agriculture, but they and their animals have been quietly feeding at the public trough for a long time. Any effort to wean them off our land results in cries of “We were here first.” Excuse me, but the land and all that was endemic to it, was here first. Pastoralists are big subscribers to both the wildflower argument. They consider my concern for aesthetics to be the whining of a pathetic city slicker. They consider my concern for the destruction of native plants and animals and their homes to be completely overblown. Just as other extractive industries such as timber harvesting and mining have been forced by environmental considerations to clean up their act in recent decades, so it is time to take a cold hard look at the arguments of Big Cow. I apologize for running on so long, but, as you can see, I had a lot to say. All efforts toward a cow-free Hoover Wilderness will be appreciated. I would love to hear some good news. Thank you for your thoughtful attention. Reneau

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

August 5, 2019

Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport, CA 93517 [email protected]

RE: Comments on Project: Bridgeport Southwest Rangeland Project

The Range of Light Group is part of the Toiyabe Chapter of the Sierra Club and consists of over 400 Sierra Club members in Inyo and Mono Counties. On behalf of the Sierra Club’s Range of Light Group Executive Committee, I’d like to express our thoughts on the Notice of Proposed Action (NOPA) to open previously closed sheep grazing allotments to cattle in the area west of the Bodie Hills. We believe the NOPA downplays the importance of the biodiversity of this terrain that is critical habitat for endangered species. This terrain could be refuge for many declining species in the face of climate change in the next decade and beyond. We would argue that this terrain is not suitable for grazing on many levels and ask that these grazing allotments remain vacant.

Biodiversity of the terrain/Climate Change Resiliency Public lands are fast becoming the only land where wildlife can live. The Sierra Club believes our public lands should support biodiversity and natural, self-sustaining ecosystems. This is in line with the USFS’ mission statement: “The mission of the USDA Forest Service is to sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and future generations.” The USFS is responsible for keeping the habitat in optimum condition so wildlife can survive. After a decade of rest, the bio-diversity in these six grazing allotments, Green Creek, Virginia Creek, Summers Meadow, Tamarack, Cameron Canyon, and Dunderberg, is significant.1

1 On May 29, 2018 three people went hiking up Summers Meadow Road and observed the following 18 species of birds: Green-tailed Towhee, Violet-Green Swallow, Northern Flicker, Brewer’s Blackbird, White-crowned Sparrow, Yellow Warbler, House wren, Song Sparrow, Mountain Quail, Fox Sparrow, Bullock’s Oriole, Mountain Chickadee, Sooty Grouse, Western Wood Peewee, Stellars Jay, Bewick’s Wren, Western Meadowlark, and Robin. They have all been entered into eBird except one.

They also observed following wildflowers, shrubs, and trees: Mountain Bluebell, Iris, Cinquefoil, Dandelion, Groundsel, wild rose, Corn Lily, Solomon Seal, Wax Current, Strawberry, Horsemint, Pennyroyal, Phlox (different kinds), Indian Paintbrush, Mules Ears, Death Camas, Dwarf Monkeyflower, Larkspur, Lupine, Sierra Stickseed, various lomatium, Wooly-pod Milkvetch, Rockcress, willows, native grasses, sagebrush, bitterbrush, Tobacco Brush, Bitter Cherry, Utah Serviceberry, aspen groves, 1

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

These allotments are on fragile subalpine terrain with a mosaic of tarns, riparian streams, springs, meadows, shrubs, willows, aspen groves, and forest. It is the mixture of habitats that makes this so valuable to wildlife and biological diversity. Together they form a unique block of un-fragmented terrain that provides a migration corridor through the Bodie Hills between the White Mountains and the Sierra Nevada. The north-facing aspect makes it a valuable climate change refugia that will help species survive as our planet continues to heat up. The springs and meadows need to be in optimum condition to hold as much water as possible and to capture rainwater since more precipitation will come as rain instead of snow with climate change. Sedges help retain water in wet meadows and riparian habitats and are present in these allotments. They develop extensive root structures that sequester carbon and will help mitigate climate change. However, sedges are highly palatable and will be eaten by the cows preventing the development of that needed root system. Meadows dry out with decades of livestock compacting the soil. This leads to conifer encroachment. Tuolumne Meadow is a great example of this and is now under restoration by Colorado State University.2 What are they planting? Sedges. (Carex scapulorum)

Mountain Mahogany, Western White Pine, Lodgepole Pine, White Fir and Pinyon Pine. CNPS has also been in the area this spring documenting the plants and would have an even more extensive list.

On July 27 and 31, 2019 the following were observed: 3 different raptors with one being a red-tailed hawk, various lupines, meadow monkey flower, yarrow, mountain aster, slender cinquefoil, pussy toes, mountain chickweed, tall wild buckwheat, penny royal, sulphur buckwheat, another type of buckwheat, dusty maiden, phlox (different kinds), a phacelia, rockcress, indian paintbrush (big patch), sheeps sorrel, death camus, lots of iris, whorl penstemon, fleabane, white stickseed, potentilla, mules ears, alpine willow herb, pink willow herb, dwarf paintbrush (nana), hawksbeard, mariposa lily, maybe a King’s sandwort, dandelion, onion, whitneya, ivesia, yampah, bog mallow, cinquefoil, monkshood, bigleaf avens, elk thistle, penny royal, snowberry, bitterbrush. sagebrush, yellow rabbitbrush, whitebark pine, western white pine, juniper, lodgepole, thread and needle grass, (Stipa comata) great basin wildrye (Leymus cinereus), squirrel tail, (Elymus elymoides) mountain needle grass, prairie junegrass (Koeleria cristata), sedges, rushes, timothy, fescue, bromus, English plantain, fritillaries, Edith’s Copper, Ruddy Copper, Copper Gorgon, Behr’s Hairstreak, and a dark butterfly, various grasshoppers, beetles, and insects. There were a few noxious plant species but in very small amounts: peppergrass, salsify, and wooly mullein. There was cheat grass in patches, but not in among the shrubs and meadows. On August 2, 2019 the following was observed along 32020E: Silene and Ericameria. Photos were taken to back this up.

2 https://www.nps.gov/yose/learn/management/upload/Tuolumne-Meadows-Hydrology-Impacts- Report-FINAL.pdf, https://warnercnr.colostate.edu/wp- content/uploads/sites/2/2017/10/Baldwin_poster.pdf, https://www.engr.wisc.edu/in-yosemite- meadow-study-could-spark-conversation-about-restoration/, 2

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

We question the interpretation of USFS policies that allow grazing at the expense of other appropriate uses that would better serve the public trust, especially in the face of climate change. USFS policies, the 1986 LRMP, the 2004 SNFPA ROD, and the 2011 Climate Change Vulnerability Report, backup a no-grazing option. They are policies based on the science of healthy meadows, climate resiliency, and wildlife habitat. The 1986 Toiyabe LRMP and the ROD for the 2004 SNFPA prioritize the health of riparian, meadow, and aspen ecosystems over grazing. The 1986 LRMP states: “Give preferential consideration to riparian area-dependent resources over other resources in cases of unsolvable conflicts”. One of the “Responsive Actions to Climate Change” in the Humboldt Toiyabe NF Vulnerability Report of 2011 is to reduce stressors such as grazing in critical habitats and to “Maintain or restore riparian, floodplain, and wetland conditions and connections with streams…Minimize hot season livestock grazing” and more. The meadows on the allotments to be reopened to grazing are looking healthy to the untrained eye. There are few bare spots. The flowers and grasses are tall and varied and alive with grasshoppers, bees, and butterflies. (photos attached)

The biodiversity that is there now will die away with decades of cattle grazing. We have only to look at Buckeye, Molybdenite, and Eagle Canyons to see how this area will change. Look at the willows in Clark Canyon in the Bodie Hills where cattle graze. They are old and woody and lack new growth from years of constant trimming of the lower four feet by cows.

Endangered species These allotments are adjacent to critical habitat for the endangered Sierra Nevada Bighorn Sheep (SNBS) and the Yosemite Toad. There is nothing to prevent cattle from wandering into their critical habitat from the Dunderberg allotment despite the best efforts of the lessee. Cattle can traverse the ridges if left to wander. Monitoring of just the allotments would not catch damage done outside of the allotments in these critical habitats. Cattle can transmit diseases to bighorn sheep, although the risk is much lower than it is with domestic sheep.3

The lower part of these allotments is also habitat for the Bi-state Sage Grouse (BSSG), a species that has been considered for listing as a threatened species and is being considered again. A decision on this is expected in October. Until then, no decision should be made. The NOPA includes standards should these species be present, but doesn’t actually state whether or not they are. However, tracking data is available for the BSSG, which should be included. Past VHF data has shown BSSG use this area. 2018 and 2019 data has not been published yet, but should be reviewed before taking this proposed action. The Bi-state Sage Grouse are in decline and they could use the small meadows in these allotments to raise their chicks. USFS grazing guidelines allow meadow grasses to be eaten down to 4-6” depending on the seral status of the meadow.

3 Mycoplasma ovipneumoniae can predispose bighorn sheep to fatal Mannheimia haemolytica pneumonia, Dassanayake et al. 2010 and A Bighorn Sheep Die-off in Southern Colorado Involving a Pasteurellaceae Strain that May Have Originated from Syntopic Cattle, Wolfe et al. 2010. 3

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

However, 7” is the recommended height to provide adequate cover for the sage grouse from predators. So grazing would not fully support their survival.

This terrain is also habitat for the American pika, a near threatened species per the IUCN. Its population is declining. Field surveys by Connie Millar, USFS senior research scientist, show that American pikas are present in the Dunderberg, Jordan sub-unit, and Tamarack allotments. Cattle reduce the food source for pikas around their talus slopes and their supply source for their haystacks.

According to the CNDDB, Sierra Nevada red fox, a state listed, threatened species, has been observed in the proposed Dunderberg allotment near the top of Dunderberg peak. California wolverine, a fully protected species in the state, has been observed west of Dunderberg Peak and Swainson’s hawk, another state listed, threatened species, has been observed within 2 km of the proposed Dunderberg allotment to the east. The following species of special concern have been observed in the area of these allotments based on the CNDDB: western white-tailed jackrabbit, Sierra Nevada mountain beaver (Aplodontia rufa), and Masonic rockcress. A Northern goshawk has been observed in the southern end of Bridgeport Valley. It is another state species of special concern.

There are many more species to consider than just those that are listed as endangered or threatened. With climate change, all species will be stressed and struggling to survive. This region is also home to bears, mountain lions, fox, bobcats, coyote, deer, pronghorn, beavers, mink, badgers, snakes, birds, etc. As temperatures rise and droughts return, animals will be moving around more and seeking higher elevations where it will be cooler and where there will be more water sources. Predictable patterns of the past will not work to predict the future. A red fox showed up unexpectedly in Lee Vining last year. The rich habitat in these allotments will support wildlife better than most areas through climate change. It could also be used to trans-locate species.

Nothing in the NOPA mentions how the lessee or the range riders would address the presence of bears or meso-predators. Will they be sacrificed for the cattle? Coyotes, bobcats, and mountain lions are critical to an ecosystem and should be allowed to pass through or move into this area. This area is a key section of a wildlife corridor between the Sierra Nevada, the Bodie Hills, and the public lands in Nevada. Figure 2.7 of the 2010 California Essential Habitat and Connectivity Project identifies the passage from the Bodie Hills to the Sierra Nevada as essential. Figure 3.11 identifies it as critical and essential habitat. This linkage will be more and more important as the planet heats up. It must remain a safe passage for meso-predators and with access to water.

Impacts of cattle grazing Almost all USFS land has been divided into grazing allotments and most are actively grazed. The same is true of BLM lands. Cattle do degrade our public lands. The standards to be achieved through grazing listed in the NOPA are lower than the quality of the current vegetation on these

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

allotments. That is to say, the land would be significantly degraded by grazing and would continue to be for decades to come as grazing leases are almost always renewed.

The NOPA consistently states “cattle grazing could potentially have a number of negative and positive effects”. However, it does not quantify them. We think the negative effects are significant and far out weigh the positive. To bring in 800+ animals, with a goal of expanding to 1,290+ animals, to a sensitive, subalpine/alpine area is not good for the ecosystem. Cattle do trample vegetation. Cattle do compact soils to the point where the meadows no longer hold water and no longer sequester carbon.4 Cattle do break down stream banks turning streams into channels that no longer keep surrounding meadows wet. Cattle will change the composition of the vegetation by selectively eating some plants (e.g. sedges, timothy, aspen shoots) and not others (e.g. iris). These and other issues were raised in the scoping comments and are not insignificant. Apart from the Upper Summers Meadow and the Dunderberg Creek Meadow, the meadows in these allotments are small; big enough to support wildlife, but would be severely degraded by 800+ cattle. Cattle will congregate in the wet and cooler areas that are the most easily destroyed: the streams, the tarns, the aspen groves, the willows, etc. Reducing AMUs does not change the distribution on the land. The same number of cattle will still congregate in the wet and cooler areas. The NOPA proposes to leave the riparian and aspen groves unfenced.

The NOPA proposal is to repair the existing fencing that basically separates the BLM allotments and Sinnamon and Lower Summers meadows from the USFS allotments. But, there are other inholdings in the proposed Dunderberg allotment. According to the Mono County assessor database, parcels 011-220-002-000, 011-170-017, and 011-170-018-000 are private property, owned by R. Bostrom, the State of California, and Triple D Ranches respectively. Will the cattle be allowed to wander on to the private property and graze? The later two parcel numbers cover the majority of the Dunderberg Creek meadow area. Has CDFW or the state given permission for cattle to graze their land? Would Triple D Ranches want their cattle to mingle with the lessee’s? If the inholdings are fenced off it would leave little of the meadow for the USFS lessee to use. More fencing would create wildlife issues that aren’t addressed in the NOPA

Cattle in the Jordan unit of the Dunderberg allotment could wander down into Mattly Ranch. Is it assumed that the USFS lessee will be the same as the Mono County lessee so no fencing is needed? Mattly Ranch is in critical habitat for the SNBS. It was the reason grazing was closed to domestic sheep. How would the presence of cattle impact the SNBS?

The cattle will need to ford streams when they are moved from one pasture to another, i.e. Virginia Creek, Dog Creek, Green Creek, Summers Creek, Tamarack Creek, streams coming down Cameron, Deep Canyons and Monument Ridge. If the lessee obtains the lease at Mattly Ranch as well, they might be trailed through another sensitive wetland up to the Jordan Basin allotment: along Wilson Creek or up through the draw below the highway. Best management practices

4 See before and after photos of grazed lands: http://www.cof.orst.edu/hart/hartimages.html 5

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

describe specific crossing spots that are reinforced to protect the stream and the banks. Left alone, cattle congregate in streams and pollute them. These streams eventually flow into the Bridgeport Reservoir, which already exceeds Lahontan Regional Water Quality Board standards for bacterial content. Tamarack Creek flows into Twin Lakes where people swim. Also, cattle often follow each other in a line and create trails. Trails then channel rainwater and snowmelt, causing erosion on the hillsides.

This terrain is not typical “rangeland”. It ranges from 7,000’-12,386’. The proposed Dunderberg allotment starts at about 8,600’. The proposed Tamarack allotment starts at about 7,200’. The terrain becomes steep quickly and there are slopes with gradients of 40 degrees or more that are inappropriate for domestic cattle grazing (see page 8, NOPA).5 There are acres within these allotments that are covered in Tobacco Brush and Serviceberry shrubs and impassible. There are dense sections of sagebrush and bitterbrush with little grasses or forbs in between. The vegetation is sparse on the upper parts of the peaks. Realistically, the grazing areas are the flatter meadows and that would be where the streams and seeps are, where the cattle should be excluded. Take that away and there is little left to support cattle grazing. If cattle are not excluded, then we will lose the precious biological and ecological values of the meadows.

The benefits of meadows and riparian areas are more valuable to all of us. Meadows support wildlife, provide ecological services, and are beautiful when not grazed. Meadows that are not grazed have more flowers and grasses and more variety. With that come more insects, pollinators, and more food at the bottom of the food chain. In a recent visit I saw 7 Fritillaries on a cluster of Pennyroyal and five Copper butterflies on a cluster of yarrow. There were grasshoppers jumping all over the place as I walked a little ways into a meadow; green ones, white ones, mottled brown ones. Grazing would eliminate the grasses and forbs that support a lot of life other than cows.

Invasive species Fortunately, invasive species have not gotten a foothold in these allotments. Cheatgrass and other noxious weeds6 are present, but in small areas. There is plenty of cheatgrass nearby, however, in the BLM allotments in old sheep bedding circles and in a recent burn area to provide seed source. Livestock are a vector for spreading cheatgrass, which will only get worse with cattle moving through. Now there are a variety of native grasses. That would change with grazing, trampling of the native vegetation, and soil compaction allowing cheatgrass to move in. Cheatgrass is a huge problem across the west. It has little nutritional value and can only be eaten during the short time it is green. It burns readily and increases the frequency of wildfires. These allotments are adjacent

5https://research.libraries.wsu.edu/xmlui/bitstream/handle/2376/1753/v61%20p74%20Ganskopp %20and%20Vavra.PDF?sequence=1

6 There is an open area in the Tamarack allotment that is covered in cheatgrass, probably a result of past sheep grazing. (Photo attached). Peppergrass, bulbous blue grass, iris, wooly mullein, and salsify, were also observed in the Tamarack allotment. 6

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

to and in wilderness. Cattle could track it into the wilderness since they can wander there. It should be one of the highest priorities to keep cheatgrass out of the wilderness.

Recreational uses Our members as well as visitors from around the world hike and recreate in the Virginia, Green Creek, and Twin Lakes canyons adjacent to the allotments. The public camps out on the roads in these allotments. This 4th of July was packed with campers along County Road 20 and on the USFS road 32020E that follows a ridgeline off of it not far from the Virginia Lakes turnoff. It is wonderful spot to camp or wander with stunning views of the Mono Basin and Bridgeport Valley. People walk their dogs there and ride horses there. It is no longer a well-kept secret. Who wants to camp on or walk through cow pies and among cows?

The NOPA points out that there are no campgrounds in the proposed allotments, but cattle wander. Cattle could easily follow Tamarack Creek down into the campgrounds at Twin Lakes or the County campgrounds along Virginia Creek.

Cattle grazing is a single use of the land that severely limits or precludes all other recreational uses such as hiking, dispersed camping, photography, fall color viewing, birding, botanizing, biking, backpacking, cross-country skiing and hunting. I recently saw three people fishing in Summers Meadow Creek and a dad teaching his young son how to ride a dirt bike on Upper Summers Meadow road. People drive the Dunderberg Meadow road to sightsee. While cows are picturesque, there won’t be the gorgeous wildflower displays and amazing meadows with fascinating butterflies that add to the beauty of the area. The land will look mowed and muddy. On the other hand, the USFS could enhance recreation in the area by adding connecting trails from the Upper Summers Meadow road to the Green Creek trail and to the Cattle Creek trail. Recreation is a growing use of public lands, especially in Mono County. Tourists will appreciate the stunning views of the Bodie Hills, the Mono Basin, and the Bridgeport Valley from the Dunderberg Meadow road as well.

Approximately half of the current Tamarack allotment is in the Hoover Wilderness. Although cattle have been grandfathered in and are allowed in the wilderness (if they were there prior to the 1964 Wilderness Act), it is contrary to the purpose of wilderness. Wilderness is to be an area “untrammelled by man” where the processes of nature play out without interference. It should be managed to preserve the natural conditions. If grazing can be excluded, it should.

Financial factors The NOPA does not address the financial aspects of grazing leases or the terms of the proposed leases. This should be included to show all aspects that would factor into this decision. Grazing leases are a net loss to the USFS although they provide some revenue for our county.7 Grazing

7 The current grazing fee for a cow and a calf is $1.35/month. This is less than the cost of 1 can of dog food. https://www.gao.gov/assets/250/248043.pdf and 7

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

leases are generally ten-year leases that are renewed indefinitely as long as the allotments are used according to the terms. The opening of these allotments will be permanent. It will be a permanent exclusion of other forms of recreation and a permanent reduction in biodiversity. This policy does not reflect modern times, the pressures of increased population, urban sprawl, recreation, shrinkage of wildlife habitat, and the need for special habitats like this terrain for climate change resiliency. The NOPA says the only reason these allotments were closed was to protect the Sierra Nevada Bighorn Sheep. True, but there have been many other ecological and recreational benefits as well. A more accurate statement would be to say the only reason to open these allotments is to support ranchers.

Arguments for an EIS The NOPA documents the policies, guidelines, and criteria for grazing use. It also explains that the USFS will monitor the allotments yearly up to a point. However, the NOPA does not actually have an assessment of the current conditions of the vegetation, a wildlife inventory, nor does it consider alternatives. It just accepts that there will be negative impacts where cattle congregate, e.g. water developments, trailing routes, and along fences. The environmental assessment part of the NOPA comes out in the rebuttal to environmental concerns raised in scoping comments. We request an Environmental Impact Study (EIS) be conducted to fully evaluate the impacts of grazing to this sensitive sub-alpine and alpine environment and the impacts to wildlife.8 Without a baseline, there isn’t a way to tell if the biodiversity is declining.

There should be readable and detailed topographic maps showing the allotments with a vegetation-type overlay and endangered and threatened species overlays. To determine if fences need to be flagged, there needs to be a map of the Bi-state Sage Grouse lekking areas and the tracking data should be included too. How will utilization be measured to ensure it is less than 35% in BSSG habitat or less than 50% outside of BSSG habitat? There should be a map of the springs, seeps, and wetland areas so they can be checked to determine if they are in late seral stage. These are the places that cattle will congregate. How will the Forest Service determine if stream and lake shorelines deteriorate by 20% or more by cattle without a baseline for each stream and tarn? There should be a baseline of the meadows indicating their current stubble height and whether or not sage grouse might use it. If they do, they need 7” grass height for cover. Grazing is to be suspended if meadows are moving in a downward direction. How can they not be moving in a downward direction with a herd of cows walking through it? Are there any meadows in early seral status that need to be rested?

We also ask that the USFS consider turning these allotments into a Botanical Special Management Unit that would allow for dispersed recreation, but not allow grazing. An EIS would provide the https://www.biologicaldiversity.org/programs/public_lands/grazing/pdfs/CostsAndConsequences _01-2015.pdf and https://www.fs.fed.us/news/releases/usda-forest-service-and-blm-announce- 2019-grazing-fees 8 https://www.jstor.org/stable/3809516?seq=1#page_scan_tab_contents 8

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

groundwork for deciding if there is sufficient plant biodiversity that would support animal biodiversity to consider this a more important use of the land than livestock grazing. In 1993 the BLM designated a part of the part of the Dog Creek grazing allotment (CA06058) as an Area of Critical Environmental Concern. It is called the Conway Summit ACEC. It is the stretch of land to the west of Highway 395 from the top of Conway Summit for 2.5 miles heading north. It was designated an ACEC to protect the scenic qualities, especially the fall colors (which means protecting the aspens and the riparian habitat), and to enhance dispersed recreation opportunities. The aspen groves upslope in the proposed Dunderberg and Tamarack allotments also provide spectacular fall color and dispersed recreation opportunities. Aspen habitat across the West has been shrinking.9 For these reasons, these allotments could also be given a protective designation.

Annual monitoring should not stop and should follow a science-based, range assessment protocol, e.g. the Parker C&T transect.10 It has been well documented that the impacts of climate change will vary from year to year, with swings from drought to wet winters and with ever rising temperatures. Cattle in wet years may do more damage than usual and some years may be too dry to allow grazing. We appreciate that the permittee is willing to have range riders and work with the USFS to minimize the negative effects of cattle grazing on these allotments and be part of the monitoring that will be done. However, it isn’t clear in the NOPA just how many and how often range riders would be on the allotments. We assume they would be on horseback and not on ATVs, but the NOPA doesn’t clarify that.

Potential for other alternatives Alternatives were not mentioned, but one alternative could be to evaluate this terrain as an ecological reserve that would provide a migration corridor, climate change refugia, and wetland and meadow water storage. Another alternative that should be considered is to shrink the allotments to just “rangeland”, excluding the riparian areas, small meadows, springs, tarns, shrub lands and critical ESA habitat—the areas that should be protected.

The USFS’ conditions for issuing a grazing permit allow some flexibility for non-standard permits. Section 222.3(c)(1) allows for leases to be shorter than ten years if it is in the best interest of sound management to do so, e.g. climate change. Section 224.4 (a)(1) allows permits to be canceled if the land is to be devoted to another public purpose, e.g. managing for optimal meadow, riparian, and aspen habitat, lowering risks to endangered species, or preventing the decline of native species. Section 224.4 (a)(7) allows for changes in the terms of a grazing permit to conform to other management needs, e.g. much lower AMUs, exclusion areas, smaller allotments,

9 https://www.fs.fed.us/wildflowers/beauty/aspen/decline.shtml and https://www.deseretnews.com/article/705396695/Researchers-find-cause-of-sudden-aspen- decline.html 10 https://pubs.usgs.gov/dds/dds-43/VOL_III/VIII_C22.PDF

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

etc. The USFS also has the option to keep these allotments vacant. The lawsuit settlement does not require the past sheep allotments be reopened. The point of the NEPA process is look at the pros and cons of the project before making a decision. It is not to justify a pre-determined decision. An EIS might show that the ecological benefits outweigh the benefits of leasing. If the grazing leases were opened to cattle, they should be temporary with a clause that clearly states they may be closed to grazing due to other beneficial uses of the land to avoid lawsuits.

Summary As custodians of our precious natural resources, the USFS should not allow activities on the land that will degrade them. The USFS has standards for the health of ecosystems. It is not clear in the NOPA how these standards will be met through grazing. However, these standards can be met if these allotments are left vacant. In line with its mission, the USFS should consider how best to preserve our local biodiversity and mitigate the impacts of climate change for the benefit of all people.

Sincerely,

Lynn Boulton, Chair Range of Light Group Toiyabe Chapter Sierra Club

Range of Light Group Toiyabe Chapter, Sierra Club Counties of Inyo and Mono, California P.O. Box 1973, Mammoth Lakes, CA, 93546 [email protected]

Cheatgrass covers a large open area, a knoll in the Tamarack allotment above the old mine.

Photo Attachments: • Photos of seed heads.pdf • Map of stops.jpeg • Current conditions on the Dunderberg allotment.pdf • Current conditions on the Dunderberg allotment2.pdf • Current Conditions the Tamarack.pdf • Current Conditions on the Tamarack2.pdf • Biodiversity on the Dunderberg allotment.pdf • Diversity of grasses.pdf • Diversity of grasses2.pdf • Diversity of grasses3.pdf • Diversity of grasses4.pdf

11 There are so many species that are just beginning to recover and the area is starting to have it's natural beauty once more. Opening up these cattle allotments once more is only going to lead to the destruction that is delt out to the area at the expense of the wildlife, the habitat and the American tax payer. This has gone on for years with a few wealthy ranchers netting literally free land for grazing at the expense of all of us. When does the Federal Government start to recognize there are more than just a FEW reason why we need to bring the land back to the wildlife and for the enjoyment of the taxpayer.. Greed and money that's the bottomline vs our environment and our wildlife. There has been enough freebee's to the ranchers. Let them purchase their own land and not use mine Please include my comments on the BSWRP.

I used to hunt and fish here. I oppose the re-introducing of private grazing leases on these “allotments”. This public land is much better suited to it’s current use and doesn’t cost us as much as management for livestock. Seeing land recover from historic grazing is rewarding. Reversing this is not in the public’s interest. Maintaining the watershed in robust condition is critical considering the effects of climate change. The negative effects would be to wildlife, watershed, fishing, hunting, backpacking, birding, photography, taxpayers and the regional economy.

Sauber

Jan Cutts, District Ranger Toiyabe National Forest Bridgeport Ranger District HC 62 Box 1000 Bridgeport CA 93517

August 2, 2019

Re: Bridgeport Southwest Rangeland Project Proposed Action

Submitted via email to: [email protected]

Thank you for the opportunity to submit comments on the Notice of Proposed Action for the Bridgeport Southwest Rangeland Project. The Sierra Nevada Bighorn Sheep Foundation was established in 1995 to help coordinate the recovery of Sierra Nevada Bighorn Sheep (SNBS). In 1999, our Foundation successfully petitioned state and federal governments to list this animal as an endangered species. Today our foundation works closely with a variety of state and federal resource management agencies and other organizations as part of the recovery efforts for these sheep. Among our roles is the development and analysis of all genetic data used in managing SNBS to conserve genetic diversity. We also advocate for federal land agency management that contributes to the recovery of SNBS, tracking and commenting on projects that are within critical habitat or overlap with lands covered in the Recovery Plan for Sierra Bighorn.

The purpose of this letter is to raise concerns about the proposal to authorize cattle grazing within SNBS Critical Habitat and within lands that could be locations for reintroduction in the future. The US Forest Service did not analyze the potential for cattle to transmit disease to SNBS and the behavioral modifications these wild sheep may undergo when cattle are present. Because SNBS are federally listed as endangered, the Forest Service must undertake a full Environmental Impact Statement and analyze any and all potential impacts to this species for a project that overlaps its habitat. A lack of adequate governmental regulatory mechanisms relative to domestic sheep grazing was one of two reasons these sheep received federal endangered status in 1999.

Cattle grazing has the potential to negatively impact bighorn populations: cattle are known to carry pathogens that can be transmitted to bighorn sheep, cattle may displace bighorn sheep from potential feeding habitat, cattle can consume forage otherwise available to bighorn sheep, and cattle can contribute to the spread of noxious weeds that degrade native ecosystems. Bighorn sheep remain at risk of disease from livestock pathogens throughout the West, with authorized grazing on public lands a limiting factor for many populations. Large areas of historic bighorn sheep habitat are unavailable for natural re-colonization or artificial restocking due to the presence of livestock, including in California.

Cattle have been implicated in a bacterial pneumonia-related die-off of bighorn sheep1. In addition to a variety of respiratory tract bacteria, cattle can also be carriers of viral pathogens like Bovine Viral Diarrhea and Bovine respiratory syncytial virus2 that can negatively affect bighorn sheep.

We appreciate the previous Forest Service action to cancel domestic sheep permits in this area and the opportunity that provided this area to recover ecologically over the last decade; however, we are puzzled by why this agency would now propose cattle grazing in high elevation areas within SNBS critical habitat. The Forest Service has the authority also to decline grazing permits for cattle to protect endangered species. This can occur without a plan amendment. We ask the Forest Service minimally to modify the allotment boundaries to exclude SNBS critical habitat and to consider a buffer around that bighorn habitat to minimize the potential for stray cattle entering bighorn habitat. Specifically, we recommend the exclusion of the north ridge of Green Creek, Kavanaugh Ridge, and all alpine habitats with the potential for SNBS occupation in the future. These areas all offer limited forage for cattle, and would present a challenge for range riders to manage their livestock.

We also recommend consultation with the California Department of Fish and Wildlife (CDFW) on these boundary modifications to fully align with future management of SNBS. SNBS are subject to management direction contained in FSM 2670. Therefore, the Forest Service must complete a Biological Evaluation to determine the likelihood of harm to SNBS viability (FSM 2672.41). The Forest Service must “ensure that actions authorized, funded, or carried out by them are not likely to jeopardize the continued existence of any threatened or endangered species or result in the destruction or adverse modification of their critical habitats” (FSM 2670.11) and “[a]void all adverse impacts on threatened and endangered species and their habitats, except when it is possible to compensate adverse effects totally…” (FSM 2670.31) (emphasis added). It will be critical for the Forest Service to engage with CDFW and the US Fish and Wildlife Service (USFWS) on the preparation of a Biological Evaluation; and, should an EIS be prepared, also the development of a USFWS Biological Opinion.

The effort to recover populations of SNBS has necessarily been an interagency effort involving numerous governmental agencies. With this in mind, the Forest Service must analyze and disclose the potential impacts of cattle grazing on SNBS, including those from disease, displacement, forage competition and noxious weeds. The Forest Service must take steps to contribute to the recovery of the species and avoid any adverse impacts to the species or its habitat. Unlike most endangered species, SNBS appear able to reach recovery goals and be delisted, and steady progress t owards recovery goals is ongoing. Please do not hesitate to contact us with questions or to discuss this issue

Sincerely,

John D. Wehausen, Board President

Jora Fogg, Board Member

Virginia Chadwick, Board Member

Paula Brown Williams, Board Member

Sierra Nevada Bighorn Sheep Foundation P.O. Box 1183 Bishop, CA 93515 [email protected]

July 26, 2019

Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport, CA, 93517 (Sent via email to: [email protected]. )

RE: My comments on the Brideport Southwest Rangeland Project

Dear District Ranger Cutts:

Please accept, carefully consider, and include my following comments in the project file- administrative record on the above-referenced Brideport Southwest Rangeland Project.

I am a former long-time California resident whose parents once owned a motel in Bishop California. I spent many summers exploring the Owens Valley and other nearby areas of federal lands, including those proximate to this proposed project. I have seen the adverse resource impacts from prolonged livestock grazing on these public lands.

While I believe in appropriate multiple use management, I know the unfortunate reality that livestock grazing is the dominant use on the vast majority of public lands, and that this grazing often diminishes or conflicts with other resource values and public uses. And I've been appalled that too many public lands managers give short shrift to conservation interests while bending over backwards to appease ranching interests. This chronic, profound bias in favor of livestock grazing over other resources and uses is unfair, unscientific, and against the public interest.

With this background in mind, I strongly oppose and urge you to reject this proposed project. This proposal would reopen four closed allotments on the wild and scenic Eastern Sierra slope to cattle use. As such, the proposal would jeopardize and likely reverse the important landscape recovery that has occurred for decades since these allotments were closed to sheep use. Wildlife habitats that have thrived in the absence of livestock grazing would again be threatened by such grazing.

As you know, this project area is a biodiversity hotspot. For example, it has three federally endangered species: Sierra Nevada bighorn sheep, Yosemite toad, and Sierra Nevada yellow- legged frog. In addition, it has the Bi-State sage-grouse which is proposed for listing as federally threatened. Pacific fishers, rare Sierra Nevada red foxes, pikas, bald eagles, and Lahontan cutthroat trout also inhabit the area. There are wildflower fields, lush green meadows and groves of whitebark pine and aspen. This healthy, diverse, and abundant array of native species should be celebrated and allowed to flourish, not threatened by a new round of commercial livestock grazing.

As you also know, this general area is very popular for recreation, including camping, hiking, wildflower-viewing, and fishing. It provides access to the Virginia Lakes area and to the high Sierra Crest and Yosemite National Park backcountry.

Finally, although no livestock are present there now, it would open the Hoover Wilderness Area to livestock grazing. I believe that livestock grazing is inappropriate in wilderness, conflicts with wilderness characteristics, and undermines wilderness protection. Cattle trample soil, erode streambanks, defecate in water sources, denude riparian vegetation, and litter camping areas with cow pies. Bulls may also pose a serious threat to public safety. When enacted wilderness designations provide for potential livestock grazing, they generally do not mandate it, and instead provide land managers with the discretion to limit or prohibit it as needed to protect public resources and other uses.

As a young adult growing up in California, I fell in love with this area's scenic beauty and healthy landscapes. As an American citizen, I am as much of a stakeholder in the proper management of these federal lands as anyone else. I am begging you to not open these allotments up for another round of harmful livestock grazing. Please abandon this regressive proposal and strive to allow this area to continue to recover from past grazing impacts.

Please add me to the notification list for this proposed project and let me know of any other related opportunities for public involvement.

Thank you very much for your consideration.

Sincerely,

Spotts

Jan Cutts District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport CA 93517

Via email

August 2, 2019

RE: Bridgeport Southwest Rangeland Project

Dear District Ranger:

Enclosed are some brief comments regarding the proposed action to authorize cattle grazing within portions of the Dunderberg, Tamarack, Cameron Canyon, and Summers Meadow allotments on the Humboldt-Toiyabe National Forest. Over the last 30 years, I am fortunate to have spent time hiking, birdwatching, and botanizing within the proposed grazing allotments including approximately six visits to enjoy the wildflower displays of Kavanaugh Ridge. On 29 May 2018, I visited the Summers Meadows area for the first time and was delighted by the sweeping vistas, vigorous aspen groves with a lush understory of native species, high diversity of flowering herbaceous species such as Phlox, Astragalus, Senecio, Castilleja, as well as many wax currants (Ribes exigeum) in full bloom. It is a stunning and spectacular area that I hope to visit every year. This is an area of great biological diversity that could be significantly impacted by cattle grazing.

I am requesting that the Forest Service prepare a full EIS to analyze these significant impacts, which are not mitigatable and significant. This document needs to include a full range of alternatives.

1a. Sensitive species. There is potential for many sensitive/threatened/endangered species to be impacted if grazing is allowed to return to the proposed allotments.

Despite hiking Summers Meadow Road during the middle of the day with rain threatening I recorded 49 bird species, including multiple singing Yellow Warblers (Setophaga petechia), California Department of Fish and Wildlife (CDFW) species of special concern when breeding. Please see Attachment A. 1b. Several other special status species that may have been overlooked in other scoping letters is the Sierra Nevada mountain beaver (Aplodontia rufa californica), California Department of 2

Fish and Wildlife (CDFW) species of special concern and yellow rail (Coturnicops noveboracensis), US Forest Service sensitive species as well as CDFW species of special concern. (CDFW Special Animals List dated April 2018). Yellow rail1 has potential to occur in habitats such as the wet meadows of upper Summers Meadow. Also, I highly recommend consultation with Great Basin Bird Observatory (GBBO). During a very quick check of eBird species occurrences, I noted that GBBO submitted a checklist containing the state endangered willow flycatcher for the Little Walker River. Potential habitat for this species (dense willow thickets) is found within the project area. Willow flycatcher has been documented nesting at Dynamo Pond. My apologies, but I did not have time to research the specific date. Please let me know if you do not have access to this record. 2. Grazing impacts. Point Blue Conservation Science states that grazing and over-browsing should be limited. “Grazing and over-browsing can significantly reduce aspen regeneration, understory foliage volume, and the structural diversity important for numerous bird species. Grazing may also increase cowbird abundance which can negatively impact breeding birds.” Health of aspen across the Sierra Nevada has deteriorated. Aspen habitat, especially that associated with riparian vegetation, is the single most species-rich avian habitat in the Sierra Nevada. Aspen restoration should be among the highest priorities of land managers in the Sierra Nevada. See: http://data.prbo.org/apps/snamin/uploads/images/aspen/Managing%20Aspen%20Habitat%20 for%20Birds%20in%20the%20Sierra%20Nevada.pdf 3. Water Quality California Regional Water Quality Control Board (RWQCB) (Lahontan Region) has been concerned about impact of grazing and cow manure on water quality in the East Walker River watershed for many years. I could not find information describing Bridgeport reservoir as an impaired watershed on their website but I did find the following which states that there is a grazing waiver applicable to private landowners on East Walker River above Bridgeport reservoir in the Bridgeport Valley but “grazing activities on federal land are not covered by this waiver” (California RWQCB Renewal of General Conditional Waiver of Waste Discharge Requirements No. R6T-2017-Tentative])

1 Nearby Bridgeport Valley is an Audubon Important Bird Area and is one of only two locales in California known to support breeding yellow rails. See: https://www.audubon.org/important-bird-areas/bridgeport-valley

See: https://www.waterboards.ca.gov/lahontan/water issues/programs/nps/docs/bridgeport tent waiver.pdf

4. Sensitive Habitat. There is potential for many CDFW Sensitive Natural Habitats to occur within the proposed action area. I did a quick search and a few of the many plant alliances listed as sensitive within the state of California could include Mountain Juniper associations (p. 10), single leaf pinyon/aspen groves (p. 20), black cottonwood forest (p. 20). See: https://www.wildlife.ca.gov/Data/VegCAMP/Natural-Communities Please do not allow grazing to return to these spectacular and biodiverse high ridges and wet meadows. 5. Aspens The well-developed aspen woodlands in the proposed grazing area represent both sensitive habitat in and of themselves as well as important avian nesting and foraging habitat. Alas, Eastern Sierra aspens are under seige from the non-native white satin moth (Leucoma salicis). Healthy ungrazed aspens will be more likely to resist Lepidopteran herbivores.

See: Https://www.tahoedailytribune.com/news/satin-moths-eating-carson-range-aspens/

I have attached a few photos from a site visit on 29 May, 2018 with aspens and willows in the background. Many thanks for consideration of my opinion. Strauss Berkeley, California

Dear sirs;

The area is a biodiversity hotspot, with three federally endangered species present: Sierra Nevada bighorn sheep, Yosemite toad, Sierra Nevada yellow-legged frog, as well as the Bi-State sage- grouse which is proposed for listing as federally threatened. Pacific fishers, rare Sierra Nevada red foxes, pikas, bald eagles, and Lahontan cutthroat trout also inhabit the area. There are wildflower fields, lush green meadows and groves of whitebark pine and aspen. We need more places like this, not fewer.

The mountain is also popular for recreation, such as camping, hiking, wildflower-viewing, fishing, and gives access to the Virginia Lakes area and to the high Sierra Crest and Yosemite National Park backcountry. The proposal would allow cattle to graze in Hoover Wilderness Area, where no livestock roam at present.

Please keep these allotments closed and managed for the values of recreation and wildlife.

White

[email protected]

allotments need to be closed, in particular to buffer vital wildlife habitats, riparian and upland vegetation communities and the myriad species that depend on them from climate change stresses and to increase ecological resiliency. See Fleischner 1994, Belsky et al. 1999, Belsky and Gelbard 2000, Steinfeld et al 2006, Catlin et al. 2011, Beschta et al. 2012, Reisner et al. 2013. The FS states:

The project area covers approximately 22,926 acres. It was historically grazed by domestic sheep. The FS proposes imposing BOTH sheep and cattle, which will be highly destructive to riparian areas and watersheds.

Mapping shows there are allotments interspersed between the lands at issue. Full and detailed analysis of the manner and effect of livestock grazing on those lands, and the ecological conditions, land health, monitoring data, compliance, capability/suitability analysis of those areas must also be fully examined – just as this all must be assessed for the subject lands during the period when grazing took place.

Typically, domestic sheep operations roam and spread weeds over vast areas of public lands. This use is often accompanied by scorched earth predator killing. What is the complete public lands grazing footprint of the permittee that the FS cut this settlement deal that this EA is based on with? THIS current NEPA analysis must be fully responsive to public input and concerns – because the pubic was shut out of the settlement deal where the USFS sacrificed the health of the lands and watersheds and sensitive species and bighorn habitats.

The FS states: The project area includes a small amount of designated critical Sierra Nevada Bighorn Sheep (SNBS) habitat, which was listed as endangered under the Endangered Species Act (ESA) in 1999. At that time, the Forest Service began consultation with the U.S. Fish and Wildlife Service (FWS) on domestic sheep grazing authorizations on these allotments to identify management options and operational controls to reduce the risk of contact and subsequent disease transmission between domestic sheep and SNBS.

Full and detailed analysis of the conditions of habitats and populations including population viability for Sierra Nevada bighorn sheep and all other sensitive, important and imperiled species must be undertaken. Please also provide detailed analysis of potential habitat areas for bighorns if domestic sheep grazing was not taking place in this region. Please develop an alternative in this EA that conducts such analysis and focuses on expanding areas that are not grazed. What area of USFS or other lands free of domestic sheep grazing and trailing are needed to enable the bighorn sheep population to expand to the level where they would not require ESA protection? The FS states: “The BRD and permittee engaged in cooperative planning that resulted in grazing authorizations for the allotments that contained multiple control measures to prevent contact between domestic sheep and SNBS. Initially the BRD recognized that owing to the gregarious nature of domestic sheep bands, they could be herded and were unlikely to scatter throughout the allotment, and so they prescribed which areas within the allotments could be grazed and when that grazing could occur. The permittee provided training and instructions to their employees that included detailed steps to be taken if SNBS approached the band of domestic sheep, or if sheep strayed from the band. No contact between SNBS and domestic sheep was recorded.

This is a very poor way to deal with these conflicts – as there is so much chance of lethal disease contact. It demonstrates the political power of the livestock industry - as does the settlement deal the USFS cut -holding public lands wildlife hostage to damaging grazing by sheep and cattle interests.

The FS states: The grazing permits expired and were not reauthorized. This occurred on the Jordan Basin unit of the Dunderberg allotment in 2004 and on the remainder of the Dunderberg allotment in 2006, on the Summers Meadow allotment in 2005, and on the Cameron Canyon and Tamarack allotments in 2009. The sheep grazing permits for these allotments were subsequently cancelled, in 2010 on the Summers Meadow allotment, and in 2014 on the Dunderberg, Cameron Canyon, and Tamarack allotments. The decision to cancel the permits was solely driven by the SNBS issue. Otherwise, desired conditions and objectives were being met, and the impacts of domestic sheep grazing on other resources were at acceptable levels.

Please provide full and detailed information on all of the claims made in the above statement. When was an ecological evaluation conducted across the affected lands and watersheds? Was there water quality monitoring in areas suffering sheep grazing? What weeds invaded sheep-disturbed sites? What was the effect of sheep grazing on habitats and populations of sensitive species and their viability? Etc.

The FS states: In 2014, the permittee who had been operating on those allotments filed a suit against the BRD for damages sustained to their livestock production by the cancelling of those grazing permits. A 2015 settlement agreement between permittee and the U.S. Department of Agriculture, Forest Service, gave the permittee preference for cattle grazing permits on the Dunderberg, Cameron Canyon, and Tamarack allotments if an EA completed by the Forest Service supported conversion of the allotments from domestic sheep to cattle. The agreement also included a provision granting the permittee the right to submit a new application for domestic sheep permits for these allotments should such permits become available in the future (paragraph 3). The BRD included the Summers Meadow allotment in the analysis because it is an integral part of the proposed action. The FS states: “National Forest System land is an important source of livestock forage …”. This demonstrates the need for an EIS here to fully detail ALL of adverse socioeconomic impacts of livestock grazing/trailing/facilities/predator killing on public lands – from polluted water, loss of sustainable perennial water flows, soil erosion, weed infestation and spread and subsequent toxic herbicide use, predator killing disrupting ecological processes, wildlife habitat damaged/lost/destroyed, recreational uses and enjoyment lost/harmed, climate costs - including loss of ability of land to buffer climate stress, loss of carbon sequestration, etc.

WLD opposes the proposals to graze cows and/or sheep, the modification of allotment boundaries, the highly uncertain loose and controversial “flexibility” that includes occupancy rates, season of use, and grazing management strategies, grazing during harmful spring and early summer periods when sensitive species are nesting/birthing /caring for young, hot season grazing on riparian areas, etc.. These alone and combined will cause significant adverse direct, indirect and cumulative impacts to the environment. We oppose the livestock water developments, “occupancy rates” and other harmful elements of the proposal. The full adverse ecological impacts of livestock facilities, salting, supplement use, sheep camps etc. must be fully disclosed and limited. This all causes intensive disturbance, irreversible weeds resulting in toxic herbicide use, damaged/destroyed/fragmented sensitive species habitats, dense areas of manure, loss of public recreational opportunities, etc.

The proposed forage appears to be greatly exaggerated. What data and models on production, soils, capability and suitability, and what assumptions and metrics, were applied? What rates of soil erosion? Where are all moderately or highly erodible soils, and how much soil loss is caused by running a herd of a thousand domestic sheep across a 50 degree slope in these soils? What is the soil replacement rate? What magnitude of conflicts with wildlife habitat needs and maintenance of viable populations of sensitive, important and imperiled species? What weight of livbestock was used in any forage calculations?

The proposed expensive fencing will be greatly harmful to many sensitive and important wildlife species. See Fleshcner 1994, Freilich 2003. Birds and bats collide with fences and die. Livestock concentrate and trail near fences, causing significant disturbance. Water developments drone wildlife, gut natural springs and destroy them forever, create sources for mosquitoes that may transmit West Nile virus, etc. Areas where they are placed become seas of stinking manure, weed expanses, etc. and wildlife habitat is fragmented and seriously degraded.

The FS states: “Grazing Management Strategies. The allotments would be grazed under a simple deferred or rest rotation strategy. Adjustments would be made as necessary to the timing, intensity, and duration of grazing use to attain desired conditions. Strategies would be designed to incorporate the following guidelines:

• Do not graze any one pasture twice in the same grazing season. • Vary the time of year livestock are in any one unit over several years. • Provide periodic rest when possible. • Limit the amount of time cattle are in any area so as to minimize impacts of grazing regrowth. • Provide adequate time for growth prior to grazing or for regrowth after livestock have been removed. • Do not allow for multiple entries into a given pasture within a season unless necessary for trailing …

There are so many problems with this scheme --- large-scale “flexibility”/highly uncertain “adaptive” management, incessant trailing and disturbance, stray animals, rugged steep terrain that restricts and constricts movement causing livestock to intensively use and beat out any relatively less steep area or path to move through which causes particular damage to drainage networks, the lack of cutting stocking to accommodate “rest” – and of course the fact that herds of domestic livestock congregating on arid lands are not native and are highly damaging to the Sierra Nevada ecosystem.

The grazing standards and use levels (copied below) are unclear, and are not adequate to protect watersheds, riparian areas, and sensitive species habitats, including potential Bi- state sage-grouse habitat. It is madness to propose impose grazing on BSSG habitat, given the low numbers of the birds, and the great need to expand the population. Under this scheme, thousands of sheep or hundreds of cows could stumble all over BSSG nests, devour the forbs that produce the insects that chicks need to survive and trample and grossly pollute meadows, as well as devour shrubs that provide crucial nesting cover as well as winter habitats.

ANY standards must be triggers for livestock removal, not “end of season” because extreme damage can be done to areas grazed in spring, early summer that may regrow.

We are greatly concerned at the supposed rest and rotation that has bene described, because many areas are steep, rugged and soils/veg are not suitable for earlier season grazing especially on north and east faces. This is a highly complex landscape, and soils/veg/habitat can be rapidly damaged by thousand pound cows or many thousands of sheep hoofs.

Meadow Areas

According to SNFPA, grazing would be managed to leave a 4-inch stubble height in meadows that are in Functioning (late seral) condition or a 6-inch stubble height in meadows that are in Functioning at Risk (early seral) condition. Degraded meadows (Non-Functioning) receive total rest from grazing.

Riparian Areas

The SNFPA limits utilization of woody riparian species to 20 percent. Disturbance to streambanks and natural lake and pond shorelines is limited to 20 percent of the stream reach or natural lake and pond shorelines. The Bi-State Amendment directs that utilization on herbaceous and shrub species be less than 35 percent in riparian and wet meadow habitats.

Upland Areas

The Toiyabe LRMP limits livestock utilization of herbaceous species in Functioning upland sagebrush and mountain brush sites to 45 percent. Utilization is limited to 35 percent on upland sites classified as Functioning at Risk and 10 percent on sites classified as Non-Functioning. Utilization of woody upland species, such as sagebrush, aspen and bitterbrush, is limited to 40 percent in Functioning sites, 30 percent in Functioning at Risk sites, and 20 percent in Non- Functioning sites. The Bi-State Amendment directs that utilization on shrubs be less than 35 percent in upland sagebrush habitats, and that utilization on herbaceous species be less than 45 percent (mountain big sagebrush communities) or 35 percent (black sagebrush, Wyoming and basin big sagebrush communities).

DESIRED CONDITIONS

The desired conditions for the Dunderberg and Cameron Canyon allotments will be:

1. Rangelands will be in satisfactory condition (1986 LRMP p., IV-4). 2. Riparian areas and meadows will be in late seral condition (2004 SNFPA, p. 42).

3. Rangelands in the project area that provide Bi-State greater sage-grouse habitat will meet the desired habitat conditions at the landscape scale (Bi-State Amendment p. 37-38).

The Amendment was greatly inadequate to protect the declining BSSG population. Recent Court ruling found the USFWS acted in illegally in relying on it.

Have there been vegetation treatments in this landscape? If so, what treatments and when, and what have their impacts been?

The NOPA includes the following – and the full direct,indirect and cumulative effects of these actions – plus analysis of more protective actions – must take place in an EIS:

1. Design Features for Yosemite Toad and Sierra Nevada Yellow-legged Frog. The following design features have been adopted from the 2016 Biological Assessment of the effects from continued Rangeland Program Management on the Sierra Nevada Yellow-legged Frog, Yosemite Toad and Their Designated Critical Habitat (Forest Service 2016).

Management of allotments within Yosemite toad habitat:

• Prior to turn out soil conditions will be assessed to determine if they are dry enough livestock use. Within occupied Yosemite toad breeding habitat:

• Riparian areas/Meadows will be grazed to early seral standards until monitoring indicates a different condition (30 percent or minimum six-inch stubble height); • Sage and mountain brush plant communities can be grazed a maximum of 45 percent of the current annual growth of key grasses and 40 percent of the current annual growth of bitterbrush. • Prevent disturbance to streambanks and natural lake and pond shorelines caused by resource activities (for example, livestock, off-highway vehicles, and dispersed recreation) from exceeding 20 percent of stream reach or 20 percent of natural lake and pond shorelines. • In allotments with occupied breeding habitat, the on-date into areas with occupied breeding habitat would be July 31st.Under certain conditions, this date can be modified to accommodate above and below average snowpack years. • Qualified/trained personnel would survey known breeding ponds to determine when metamorphosis occurs.

Within suitable Yosemite toad breeding habitat, (not surveyed, outside critical habitat):

• Riparian areas/Meadows will be grazed to early seral standards until monitoring indicates a different condition (30 percent or minimum six- inch stubble height). • Prevent disturbance to streambanks and natural lake and pond shorelines caused by resource activities (for example, livestock, off-highway vehicles, and dispersed recreation) from exceeding 20 percent of stream reach or 20 percent of natural lake and pond shorelines. • Qualified/trained personnel would survey known potential breeding areas within suitable habitat to determine the presence of breeding toads, tadpoles, or metamorphs. • Suitable habitat (not surveyed breeding habitat, outside critical habitat), areas for YT which overlap with the Bi- State Amendment on the (Bridgeport) Cameron Canyon and Dunderberg.

6 Management of Allotments within Sierra Nevada yellow-legged frog habitat: Within occupied habitat:

Within suitable habitat (not surveyed, outside critical habitat):

Additional Standards and Guidelines from the Greater Sage-grouse Bi-State Distinct Population Segment Forest Plan Amendment

The following standards and guidelines taken from the Bi-State Amendment apply to projects with range improvement components or the potential to be affected by noxious weeds:

• RI-S-02: Salting or supplemental feeding stations shall not be located within 2 miles of an active lek and 0.6 miles from riparian areas. • RI-S-03: Water developments (tanks/troughs) shall be drained when not in use, unless they are needed by other species, so they do not create a breeding habitat for mosquitos that disease such as West Nile Virus. • RI-S-04: Wildlife escape ramps shall be installed and maintained in water troughs or open water facilities with vertical embankments that pose a drowning risk to birds. • RI-S-05: Water developments at springs and seeps shall be maintained to preserve the continuity of predevelopment riparian areas. Modifications to the developments shall be neutral or beneficial to the bi-state sage grouse. • RI-S-06: Livestock watering and handling facilities (corrals, chutes, dipping vats, etc.) or sheep bedding grounds shall not be located within 2 miles of an active lek and 0.6 miles from riparian areas. • Weed-S-03: Agency personnel, contractors, and permit holders working in areas with known weed infestations shall clean vehicles of dirt, mud and visible plant debris before entering a different area, to reduce the spread of noxious weeds. (In AOI, notify of areas of known weed infestations.) We are very concerned that the USFS will essentially have to lie to the public and cover up the magnitude of conflicts to try to shoehorn sheep and cow grazing in to a landscape with so many rare species issues. Serious and significant conflicts will constantly be occurring. Perhaps that is why the FS is proposing such a loose and uncertain schedule – because it is impossible to shoehorn it in and not have conflicts, so the agency is trying to avoid being pinned down and conducting a hard look analysis.

Please provide us with the following information referenced in the NOPA and post it online at the USFS site: “the BRD completed the Domestic Cattle Grazing Capability Assessment: Cameron, Dunderberg, Green Creek, Summers Meadow, Tamarack, Virginia Creek Allotments in 2014 to determine whether the project area could support domestic cattle grazing. In May 2019, the BRD amended the assessment with a letter to the project file that updates the capability assessment to reflect the boundaries as described in the proposed action. The 2014 assessment and 2019 letters are summarized here and available in full in the project record”.

The info in the NOLA shows that there are only 36% Capable acres averaged across the allotments, with less than 40% slopes. Areas with such limited grazable land should not be grazed – as there is no way to keep the cows from seriously damaging non-capable soils, crusts, watersheds and drainage networks, watersheds, native vegetation communities including rare plant habitats, sensitive species habitats, ESA-listed habitats and values of the Hoover wilderness. ALL Of these attributes will be significantly harmed by imposing this use. Plus the grazabiity and degree of harm and impairment also depends on the relative location of capable lands (and how the FS has defined/modeled capability. We are concerned that the USFS may use out-dated information on veg communities and their capability of the land to withstand grazing impacts – especially when climate change and impacts of previous grazing has made the communities less resilient and less able to recover from grazing and other disturbances.

The HT Forest uses a woefully out-dated method of looking at suitability. The FS states:

Suitability is the appropriateness of applying certain resource management practices to a particular area of land, as determined by an analysis of the economic and environmental consequences and the alternative uses foregone (36 CFR 219.3). For the practice of livestock grazing, suitable areas generally include those areas within grazing allotment boundaries that do not conflict with other resources (e.g., designated campgrounds, administrative areas, municipal watersheds). There are no designated campgrounds or administrative areas within the project area. All areas within these allotments are considered suitable for livestock grazing.

This (as does the capability analysis) fails to factor in climate change stress – and factors such as reduced ability of land to sequester carbon, lower site resiliency due to hotter temperatures, more extreme weather, increased weeds that thrive in hotter and drier sites, etc.

NOPA pages 13-17 includes numerous types of ecological damage cattle grazing will cause. Instead of the USFS forthrightly admitting the attributes described here will be damaged, the USFS uses the term “could”.

Why are there no maps and no more complete information n the Hoover Wilderness and the roadless area (s)?

Climate change, soil and watershed resources, plants, terrestrial wildlife, and adjacent property ALL were not considered issues worthy of being carried forward. WHY? The USFS simply can not walk away from in depth analysis of all of these serious issues. Fleischner 1994, Beschta et al, 2012.

The FS describes: TERRESTRIAL WILDLIFE

Livestock grazing may affect terrestrial wildlife populations or their associated habitat. Livestock grazing has the potential to transmit disease from cattle to SNBS, and portions of the Dunderberg allotment are included in designated critical habitat. The project area also provides nesting habitat for bi-state greater sage-grouse and lies within 4-mile lek buffer zones. However, there are no known leks in the project area. The project area also includes potential habitat for flammulated owl, northern goshawk, bald eagle, great gray owl, willow flycatcher, mountain quail, American marten, Townsend’s western big-eared bat, spotted bat.

FISHERIES AND AMPHIBIANS

No special-status fish species occur in the project area, though there are populations of brook, rainbow, and brown trout. There is no occupied Sierra Nevada yellow-legged frog or Yosemite toad habitat in the project area, though potential habitat is present for both species. Livestock grazing may affect fish or amphibian wildlife populations or their associated habitats directly or via water-quality effects.

This and the info in the notice referencing livestock impacts to sols, watersheds, etc. demonstrates why an EIS is essential, and why allowing any grazing here is a an ecologically harmful and destructive action. BSSG, Sierra Nevada Yellow-legged frog, Yosemite toad all have potential habitat here. The lands should remain closed to grazing and habitats here used for species recovery. Full and detailed analysis of habitat conditions in the landscape, populations, trends, etc. for all sensitive species must be fully disclosed. Intensive baseline inventories must be conducted

We hope to submit additional comments.

Sincerely,

Katie Fite Public Lands Director WildLands Defense PO Box 125 Boise, ID 83701 208-871-5738

I am a Bridgeport resident and believe the release of cattle on this part of the eastern front will severely degrade the just recovering vegetation and water quality. I am including a recent study done in Utah on the grazing of cattle on Aspen groves. They not only degrade the grove but actually shrink it by destroying the under support system.

This is the study:

www.sltrib.com/news/environment/2019/07/04/whats-killing-worlds-most/

I sincerely hope that this area will NOT allow cattle. Willimann

Jan Cutts August 5, 2019 District Ranger Bridgeport Ranger District HC 62 Box 1000 Bridgeport CA 93517

Via email [email protected] and Via project website: https://cara.ecosystem-management.org/Public//CommentInput?Project=49993

RE: Bridgeport Southwest Rangeland Project

Dear District Ranger:

These second scoping comments are submitted on the Notice of Proposed Action (NOPA) on the Bridgeport Southwest Rangeland Project by Humboldt-Toiyabe National Forest (Forest) on behalf of Western Watersheds Project, the Center for Biological Diversity, Wilderness Watch, and Conservation Congress (collectively “conservation groups”). The conservation groups submitted extensive comments with attachments and references on June 4, 2018 in response to the initial scoping notice. Those comments, attachments and references are incorporated herein. Western Watersheds Project (WWP) is a non-profit organization with more than 9,000 members and supporters. Our mission is to protect and restore western watersheds and wildlife through education, public policy initiatives and legal advocacy. Western Watersheds Project and its staff and members use and enjoy the public lands and their wildlife, cultural and natural resources for health, recreational, scientific, spiritual, educational, aesthetic, and other purposes. The Center for Biological Diversity is a non-profit environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law. The Center has over 1.6 million members and online activists with over 70,000 members throughout California and the western United States. The Center and its members have worked to ensure the conservation of the Sierra Nevada bighorn including by seeking protections for this endangered species from the risk of disease transmission from domestic sheep grazing in its habitat. The Center and its members have also worked to ensure protection for other listed, rare, and special status species in this area that may be adversely affected by the proposal to allow cattle grazing

on these allotments including Bi-State sage grouse,1 Sierra Nevada red fox, Yosemite toad, gray-headed pika (Ochotona princeps schisticeps), and rare plants. Wilderness Watch is the leading national organization whose sole focus is the preservation and proper stewardship of lands and rivers included in the National Wilderness Preservation System (NWPS). The organization grew out of the concern that while much emphasis is being placed on adding new areas to these systems, the conditions of existing Wilderness and rivers are largely being ignored. We believe that the stewardship of these remarkable wild places must be assured through independent citizen oversight, education, and the continual monitoring of federal management activities. Wilderness Watch is committed to citizen oversight, public education and when necessary, legal and legislative action, to protect America’s finest environmental legacy for present and future generations. The Conservation Congress is a grassroots 501(c)3 nonprofit conservation organization incorporated in the state of California in 2004. We work to protect National Forest lands and native wildlife in northern California. The Conservation Congress is part of Voices for Public Lands (VPL), an informal coalition of public lands conservation groups united by a commitment to the values enumerated in VPL's Declaration of Principles for Public Lands. We believe these public lands that are owned by the American people and paid for with taxpayer dollars should have a strong public voice. Therefore, Conservation Congress especially provides a voice for the voiceless – the wildlife, trees, water and the interconnected ecosystems that cannot speak for themselves.

The conservation groups are concerned that the NOPA appears to show that the Forest Service may have pre-determined the outcome of this process before undertaking needed detailed environmental review regarding the potentially significant impacts of cattle grazing on these allotments. These high-elevation allotments are a hot spot of biodiversity providing habitat for many listed, rare and sensitive species (including, but not limited to, Sierra Nevada bighorn sheep, sage-grouse, Yosemite toad), that would be adversely impacted by cattle grazing on these lands. In addition, other resource conflicts include impacts to water quality, riparian areas, and recreation.

Because this area lies in the heart of the scenic Eastern Sierra region, close to Mono Lake and Yosemite National Park, and in a biodiversity hotspot, a full Environmental Impact Statement (EIS) needs to be prepared, as cattle grazing impacts to other resources would be significant. In addition, whether an EA or EIS is prepared, the Forest Service should consider at least one alternative that would administratively put these allotments in nonuse for the next 10-20 years to promote recovery of environmental resources, and an alternative that would include a plan amendment to close these allotments and not make them available for any livestock grazing to protect environmental resources.

1 The Bi-State sage grouse is currently proposed for listing and along with proposed critical habitat. https://www.federalregister.gov/documents/2019/04/12/2019-07252/endangered-and-threatened-wildlife-and-plants- threatened-status-for-the-bi-state-distinct-population

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 2 August 5, 2019

Desired Conditions Based on forest plans as amended, the allotments in question are beginning to meet desired conditions because they have been rested since 2009, from all livestock grazing. Rangelands will be in satisfactory condition (Toiyabe National Forest 1986 Land and Resource Management Plan p., IV-4); riparian areas and meadows will be in late seral condition (2004 Sierra Nevada Forest Plan Amendment, p. 42); and rangelands in the project area that provide Bi-State greater sage-grouse habitat will meet the desired habitat conditions at the landscape scale (2016 Greater Sage-grouse Bi-State Distinct Population Segment Forest Plan Amendment, p. 37-38). From our 2018 field visits to the allotments, we agree that most of the rangelands are in satisfactory condition, but this is precisely because they have been rested for from 4 to as long as 15 years. Grasses, forbs, meadows, riparian areas, and stream banks are recovering from all impacts of livestock grazing after permits were canceled. Riparian areas and meadows are improving from grazed conditions to late seral conditions. We would like to see these areas continue to improve to climax state or Potential Natural Community free of seral plant species, in order to provide better quality wildlife habitat. Introducing cattle grazing would bring back disturbances which could lower vegetation structure back to early seral stages. Yosemite Toad and Sierra Nevada Yellow-legged Frog As the attached maps show, Yosemite Toad and Sierra Nevada Yellow Legged Frog are present in this area with designated critical habitat adjoining or overlapping the allotments (See Map 1). As such, these species could be present on other portions of the allotment as well and full surveys at appropriate times of year should be conducted for the environmental review. In addition, because full fencing is not required in the proposal and cattle are proposed to be allowed to wander, it is highly unlikely that range riders will be able to contain cattle in these unfenced allotment boundaries completely. Therefore livestock could stray far and wide into critical habitat outside the boundaries, and further into Hoover Wilderness causing additional impacts to these resources. These issues must be fully addressed in the environmental review.

Proposed cattle grazing on the meadows, lake edges, and streams would have negative impacts from erosion of stream banks, trampling, lowering water quality, and removing vegetation that would impact amphibians. There are sensitive meadows along Tamarack Creek in Hoover Wilderness and Tamarack Lake, that would be within the new proposed allotment boundary, and we are concerned about cattle damage occurring there.

The Forest Service must undertake surveys for amphibians in this area, including the allotments and include that baseline data in an EIS.

The NOPA at 6 and 7 states: Riparian areas/Meadows will be grazed to early seral standards until monitoring indicates a different condition (30 percent or minimum six- inch stubble height). The riparian areas and meadows are currently at mid to late seral; stage, so grazing cattle at a rate that would take these habitats back to early seral state is a

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 3 August 5, 2019

significant impact to Yosemite toads and mountain yellow-legged frogs. Early seral states indicate a percentage of bare ground, closely cropped vegetation, disturbance, and potential for erosion and spread of weeds. This is not acceptable.

Bi-State Sage-Grouse

The Forest lists a few standards and guidelines it proposes in the NOPA that reduce impacts of livestock water facilities, yet the Forest does not address the impacts to sage-grouse habitat of grazing meadows and riparian to early seral stages. This contradicts the Bi-State Sage-grouse plan amendment at 38, which states desired conditions for nesting habitat should allow for “[p]erennial grass height provides overhead and lateral concealment from predators,” and “[g]rass forb heights provide lateral and overhead concealment.”

Current sage-grouse habitat is improving and provides better cover of both perennial grasses and sagebrush, than adjacent grazed ranges.

Given the new information of declining populations,2 and new status of the Bi- State Distinct Population Segment of sage-grouse recently coming under formal status review by US Fish and Wildlife Service for listing under the Endangered Species Act,3 an EIS needs to be prepared, not an Environmental Assessment (EA).

Fencing standards and guidelines in sage-grouse habitat need to be better delineated. We found many old and downed barbed wire fences in the allotments, and the proposal to add new fences would add risk of collision mortality to sage-grouse.

Additional fences are proposed if needed (NOPA at 12), which would add impacts to bi-state sage-grouse. Fencing can be protective for some resources and also have significant impacts to wildlife by, for example, fragmenting habitat and by providing perching opportunities for predators. Existing fencing should be reduced or eliminated in Bi-State sage grouse habitat including occupied and recovery habitat and no new fencing should be allowed in these areas. Tagging barbed wire fences does not eliminate sage-grouse mortality—mortality is only reduced. Christiansen (2009) observes a 61% reduction in fence collisions with reflectors on fences, yet this still equates to mortality. Van Lanen et al. (2017) say: "Our results suggest that all three types of fence markers employed in our research were effective at reducing collision probabilities and confirmed our hypothesis, with stretches of marked fence having a 57% (27% - 87%) lower probability of containing ≥1 collision.” But this means, broadly, that fence markers fail to prevent 43% of the collision mortalities from an unmarked fence. The best conservation action would be to remove fences where appropriate.

2 Bi-State Sage-Grouse Local Area Working Group meeting, June 5, 2019, Walker CA. 3 84 FR 14909-14910

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 4 August 5, 2019

The NOPA did not address grass stubble height as it impacts sage-grouse. The height of grass cover in nesting and brood-rearing habitat is a key factor in determining the recruitment success of imperiled greater sage-grouse. Cattle graze down the native vegetation these rare birds use for food and for hiding their nests from predators. Ravens in particular are a problem predator for the Bi-State sage-grouse. In a study conducted in Montana and Wyoming (Doherty et al. 2014), populations showed significantly higher nest survival rates with higher average grass height. When grass heights averaged 7 inches, grouse nests in the Wyoming part of the study had a 75 percent chance of survival, while Montana nests had only a 47 percent survival rate when grass heights averaged 7 inches. The Montana nests had a 60 percent survival rate at 10.2 inches of grass cover, but didn’t reach the 75 percent survival threshold until grass heights topped 15 inches.

This research is consistent with previous science that indicated that land managers should maintain at least 7 inches of grass height in sage grouse nesting and chick-rearing habitats in drier parts of the sage grouse range. California sage-grouse habitats would greatly benefit from similar stubble height standards, especially as ravens are a huge stressor on the Bi-State DPS, from such local factors as the un-covered Mono County trash dump in Long Valley, not far from the project site.

A 7-inch stubble height standard should be applied to both meadows and upland habitat.

Federally Endangered Sierra Nevada Bighorn Sheep Because Critical Habitat overlaps the proposed allotments, and because cattle will effect bighorn by potential disease transfer and behavioral modification, impacts will be significant to this rare species. The NOPA did not acknowledge our concerns discussed in our prior scoping comment letter on this project. Therefore, the Forest must undertake a full Environmental Impact Statement and analyze these potential impacts. Radio-collared bighorn sheep have been observed to wander from Lundy Canyon, and even on occasion into Bridgeport Valley. West-wide, bighorn sheep populations have declined by more than 90% since the mid-nineteenth century, and bighorn sheep overall distribution has been reduced to less than 30% of the species’ historic range.4 The primary causes of historic bighorn sheep declines include livestock diseases, overhunting, and forage competition with livestock.5

Bighorn sheep remain at risk of disease from livestock pathogens throughout the West, with authorized grazing on public lands a limiting factor for many populations. Large areas of historic bighorn sheep habitat are unavailable for recolonization or artificial restocking due to the presence of livestock, including in California.

4 U.S. Forest Service. (2009). Addition of Big Horn Sheep to the Forest Service Intermountain Region Sensitive Species List. 5 Besser, T., Cassirer, F., Highland, M., Wolff, P., Justice-Allen, A., Mansfield, K., Davis, M., Foreyt, W. (2013). Bighorn sheep pneumonia: Sorting out the cause of a polymicrobial disease. Preventive Veterinary Medicine, 108, 85– 93.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 5 August 5, 2019

The Sierra Nevada subspecies of bighorn sheep was reduced to approximately 100 animals by the mid-1970s, and was added to the U.S. Fish and Wildlife Service Endangered Species list through an emergency declaration in 2000. Since this time, the population of Sierra Nevada bighorn sheep has grown to roughly 600 animals.

The allotments being analyzed for this project contain occupied Sierra Nevada bighorn sheep habitat. Cattle grazing has the potential to negatively impact bighorn populations: cattle are known to carry pathogens that can be transmitted to bighorn sheep, cattle may displace bighorn sheep from optimal habitats, reducing foraging efficiency, and cattle contribute to the spread of noxious weeds which outcompete native vegetation, degrade bighorn sheep habitat, and increase fire risk.

Cattle have been implicated in pneumonia-related die-offs of bighorn sheep, as well as in outbreaks of Bovine Viral Diarrhea and other diseases impacting wild sheep. Bovine respiratory syncytial virus (BRSV) and bovine parainfluenza virus 3 have been identified as co-agents in pneumonia outbreaks in bighorn sheep populations, affecting bighorn herds exposed to primary agents Mycoplasma ovipneumoniae and Mannheimia haemolytica.6 7 Mannheimia haemolytica originating in cattle is believed to have been a primary respiratory disease agent in at least one bighorn sheep pneumonia outbreak.8 9

Sierra Nevada bighorn sheep are subject to management direction contained in FSM 2670. Therefore, the Forest Service must complete a Biological Evaluation to determine the likelihood of harm to bighorn sheep viability (FSM 2672.41). The Forest Service must “ensure that actions authorized, funded, or carried out by them are not likely to jeopardize the continued existence of any threatened or endangered species or result in the destruction or adverse modification of their critical habitats” (FSM 2670.11) and “[a]void all adverse impacts on threatened and endangered species and their habitats, except when it is possible to compensate adverse effects totally…” (FSM 2670.31) (Emphasis added).

Will proposed fences be wildlife-friendly to allow safe passage of bighorn sheep. Such fences require smooth-wire bottom strands and 18-inch lower wire height.

6 Dassanayakea, R., Shanthalingam, S., Herndon, C., Subramaniam, R. Paulraj K. Lawrence, Bavananthasivam, J., Cassirer, F., Haldorson, G., Foreyt, W., Rurangirwaa, F., Knowles, D., Besser, T., Srikumaran, S. (2010). Mycoplasma ovipneumoniae can predispose bighorn sheep to fatal Mannheimia haemolytica pneumonia. Veterinary Microbiology, 145, 354–359. 7 Spraker, T., Collins, J., Adrian, W., Otterman, J. (1986). Isolation and serologic evidence of a Respiratory Syncytial Virus in bighorn sheep from Colorado. Journal of Wildlife Diseases, 22(3), 416-418 8 Wolfe, L. Diamond, B., Spraker, T., Sirochman, M., Walsh, D., Machin, C., Bade, D., Miller, M. (2010). A bighorn sheep die-off in southern Colorado involving a Pasteurellaceae strain that may have originated from syntopic cattle. Journal of Wildlife Diseases, 46(4), 1262-8. 9 NDOW. (2001). Bighorn Sheep Management Plan.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 6 August 5, 2019

The Forest Service must analyze and disclose the impacts of cattle grazing on the area’s Sierra Nevada bighorn sheep population, including those from disease, displacement, and noxious weeds, and the Forest Service must take steps to preserve population viability and avoid any adverse impacts to the species or its habitat.

Rare Plants

Surveys for rare and sensitive plants should be undertaken during the appropriate seasons, and results and avoidance measures should be analyzed in an EIS. An EIS should also address best management practices to reduce and eliminate noxious weeds.

Aspen

We observed aspen communities along streambanks, in moist seeps in upland sites, and patches around snowdrifts. All aspen stands appeared to be in functioning condition, with abundant undergrowth. Cattle can heavily impact aspen stands by browsing on saplings, grazing on understory plants, breaking branches, disturbing and trampling the ground. The Forest should propose management guidelines to prevent cattle from impacting these recovering aspen stands, and halt any progression to at-risk status and loss of regeneration and diversity of age classes. Bare ground should not exceed 5%.

Riparian

Some riparian and aspen stands, as along Cameron Creek, may be functioning–at- risk due to indicators such as bare soil and presence of extensive stands of non-native bulbous bluegrass (Poa bulbosa). Most research indicates bulbous bluegrass requires disturbance to increase and can be an indicator of overgrazing by livestock; it is an indicator of deteriorating range conditions.10

Thus we have particular concerns with the Cameron Canyon Allotment. We recommend this allotment have a continued rest, as cattle grazing could push it to a non- functioning state, with a loss of resilience and possible resulting degraded state.

Meadows

The EIS must address how the Forest could prevent cattle from congregating on meadow communities, and cause bare ground, weed invasions, and over-utilization. We observed several meadow types around springs, seeps, and stream banks. Most appeared to be functioning or recovering but still at the threshold of moving back to functioning at risk. Small patches of cheatgrass have the potential to increase with cattle grazing. Undesirable species such as dandelion were abundant in some meadows, and bare ground still in evidence from past sheep grazing.

10 https://www.fs.fed.us/database/feis/plants/graminoid/poabul/all.html

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 7 August 5, 2019

The proposed Dunderberg Mine Allotment, in particular, has signs indicating function-at-risk, such as increased weedy forbs. This should be analyzed in an EIS.

Water Quality

Measures of water quality in all streams should be taken currently, and monitored in the future if cattle are permitted. These measures should include temperature, turbidity, nitrate, dissolved oxygen, and fecal coliform.

Cultural Resources

No mention is made of the high quality arborglyphs in aspen groves within the allotments, which should be protected from livestock. No proposal is given to fence these important areas off, or protect riparian areas and stream banks.

Hoover Wilderness and Inventoried Roadless Areas

Our first comments addressed these topics in some detail. Some of our suggestions dealing with ease of commenting were not incorporated in the NOPA. For example, the Hoover Wilderness boundary is not shown on Figure 3 in the NOPA. In fact, it is not shown on any map in the NOPA. Thus, it is difficult to assess where impacts could occur. The same is true for inventoried roadless areas, including those contiguous with the Hoover Wilderness.

While the NOPA states the EA will be looking at impacts to Wilderness and roadless areas, there is no recognition that grazing in Wilderness is a non-conforming use. In 1964, Congress passed the Wilderness Act “to secure for the American people of present and future generations the benefits of an enduring resource of wilderness.”11 The law provided statutory protections for wilderness areas and established the National Wilderness Preservation System. The Act, among other things, mandated that wilderness areas be administered in a manner that will leave them “unimpaired for future use and enjoyment as wilderness” and provide for “the protection of these areas” and “the preservation of their wilderness character.”12

The Wilderness Act defines wilderness: “A wilderness, in contrast with those areas where man and his works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain.”13 Wilderness is “land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions....”14 In addition, wilderness should be “affected primarily by the forces of nature, with the imprint of man’s work substantially

11 16 U.S.C. § 1131(a). 12 Id. 13 16 U.S.C. § 1131(c) (emphasis added). 14 Id. (emphasis added).

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 8 August 5, 2019

unnoticeable.”15

The provision allowing grazing in the Wilderness Act is an exception to the general premise of the Act, which directs agencies to manage wilderness areas to preserve their wilderness character and natural conditions. The language concerning livestock grazing in wilderness is a mere forty words long: “Within wilderness areas in the national forests designated by this Act...the grazing of livestock, where established prior to September 3, 1964, shall be permitted to continue subject to such reasonable regulations as are deemed necessary by the Secretary of Agriculture.” Thus, grazing which existed in wilderness areas when the Wilderness Act was enacted may continue. However, this proposal is not to continue the same “established” livestock grazing but to introduce a completely new type of livestock grazing by cattle in this high-elevation wilderness area that has only been previously grazed by sheep.

In other words, grazing is an exception to normal wilderness protections. It is a use that, by definition and practice, degrades Wilderness.

Further, the proposal is a grand experiment forced upon Wilderness and roadless areas:

An initial calculation has been made to determine the occupancy rates, but that rate and other aspects of the grazing management strategy may need to be adjusted as both the permittee and BRD learn the most effective and appropriate way to manage cattle grazing in this setting. As a result, the proposed action would authorize flexible occupancy rates, season of use, and grazing management strategies as described below.

NOPA at 10, emphasis added. This is a tacit admission that the EA won’t adequately analyze the impacts to Wilderness and roadless areas because those impacts are not known and, if the NOPA is to be believed, won’t be known until years after the proposal has been approved. However, enough is known about cattle distribution, choice of areas, and utilization the make a much better analysis than the one that is projected.

Similarly, the idea that herding alone can distribute cattle has little basis in research. Few if any public land ranchers have the time or resources to have enough range riders to properly distribute cattle across the landscape to avoid problems. This could have a profound negative impact on Wilderness.

Sensitive meadows along Tamarack Creek would have cattle, as well as Tamarack Lake, would be within the new proposed allotment boundaries. Yet, as stated above, it is clear that the range riders will have a difficult time keeping cattle from wandering including further into the Hoover Wilderness. This should be analyzed in more detail in

15 Id. (emphasis added).

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 9 August 5, 2019

an EIS.

Recreation

The project area is very popular recreationally with visitors to the National Forest. The Virginia Lakes areas are a large draw, and the Trumball Campground is very well used. Dispersed camping along the Virginia Lakes Road is also a popular activity. We are concerned that without fences, and with few range riders, that cattle will wander into both the Trumball Campground and into dispersed campsites along routes in this area, and create negative visitor interactions with livestock.

In addition to the campgrounds, fishing opportunities, dispersed recreation, and wildflower viewing in the Virginia Creek and Dunderberg area, there is a resort near Little Virginia Lake. There are also a number of summer home cabins just below Big Virginia Lake. The cabin owners own their cabin but lease the land from the Forest Service. Leavitt Meadows Pack Station is located in the Virginia Creek drainage, as well as a number of private parcels, some with cabins and homes built on them. Water systems used by the campground, resort, pack station, and private parcels, and summer homes are precarious, and cattle grazing could well compromise water quality.

Robinson Creek area and campground is the most popular and visited recreation site in the entire Humboldt-Toiyabe National Forest. Cattle could impact this campground and the Twin Lakes area.

Robinson Creek and the Twin Lakes part of the district are immediately downhill from the proposed grazing allotment. There are no fences or natural barriers which will prevent cattle from drifting into this important part of the economy for northern Mono County. There are numerous Forest Service campgrounds, which are busy and full for most of the summer. Fishing forms the foundation for recreation activities and all associated activities in this important area. In addition to the campgrounds, there are a number of resorts, restaurants, and boat rentals in the Twin Lakes area. There is a large concentration of summer homes and private cabins in the Twin Lakes area.

Water systems for homes, resorts, and campgrounds are a challenge to maintain. Trampling and cattle waste pose a significant threat to water quality throughout the proposed allotment, and adjacent areas.

None of the facilities scattered throughout the proposed allotment have fences or barriers to prevent cattle from wandering throughout the area. The idea of cattle using this area has never been proposed and they have never grazed this important recreation portion of the Bridgeport Ranger District.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 10 August 5, 2019

In addition to the huge popularity of the Virginia Lakes and Twin Lakes areas, the Upper Summers Meadows Road area, including Cameron Canyon and Upper Summers Meadow, is a very popular recreation area itself. Dispersed camping, RV camping, fishing, arbor art visitations, four-wheel-drive activities on the designated roads, and fishing are all popular seasonal activities. The use is growing with the increasing popularity of Twin Lakes and the Virginia Lakes area. Recreational opportunities should be given high management priority given Californian’s greater demand for front country activities.

The Environmental Impact Statement should analyze an alternative designation recognizing the importance and significance of all of the use, facilities, and the importance of the area to the local economy. A Special Recreation Management Area designation, which manages for no livestock grazing, should be considered administratively. Management prescriptions that allow for primitive and dispersed recreation, with protection of its natural resources, and that keep these allotments closed to sheep and cattle, would have much support from the public. This could help balance multiple uses on this area.

Capability and Suitability Capability indicates acres capable of supporting cattle grazing based on forage production of at least 200 lbs. per acre, slopes less than 40%, and areas within 1 mile of perennial water. The Updated Capability Assessment16 maps only 36% of the total allotment acreages as capable of supporting cattle. We observe that more acres are covered with unpalatable montane shrubland, and this also should be mapped in an EIS and excluded as capable. A reduced-acreage allotment alternative should thus be analyzed in an EIS. It is unclear why the Forest changed this capability assessment from 2014 or what basis was used. An EIS should disclose the methodology and data used to make this change.

An EIS is needed to fully address impacts of the proposed project If a federal action “significantly affect[s] the quality of the human environment” the agency must prepare an EIS. 42 U.S.C. § 4332(c); Anderson v. Evans, 371 F.3d 475, 487 (9th Cir. 2004) (agency prepared an EA, court held an EIS was required). The CEQ regulations, 40 C.F.R. § 1508.27, define the term “significantly” for purposes of NEPA and provides that “significantly” “requires consideration of both context and intensity.” See also, Consol. Salmonid Cases, 688 F. Supp. 2d 1013, 1019 (E.D. Cal. 2010). Many of the “significance” factors set forth in the NEPA Regulations are implicated by adding a new oil and gas well and pipeline in this area. The context of the action includes “society as a whole (human, national), the affected region, the affected interests, and the locality.” Anderson v. Evans, 371 F.3d 475,

16 Updated Capability Assessment for the Bridgeport Southwest Rangeland Project, 5/7/2019, accessed at https://www.fs.usda.gov/project/?project=49993.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 11 August 5, 2019

487 (9th Cir. 2004); 40 C.F.R. § 1508.27(a). The Forest Service must address the context of the proposed action in the environmental review. As explained above, the context shows that the proposed action will have a significant effect as it is could undermine conservation of listed, rare and imperiled species on public lands that provide a rare biodiversity hot spot and could significantly impair world-class recreation opportunities in the high Sierra Nevada. The consideration of “intensity” required by section 1508.27 refers to the severity of impact. 40 C.F.R. § 1508.27(b); Anderson v. Evans, 371 F.3d at 487. In order for an EIS to be required, the public “need not demonstrate that significant effects will occur. A showing that there are ‘substantial questions whether a project may have a significant effect’ on the environment is sufficient.” Anderson v. Evans, 371 F.3d at 488; Consol. Salmonid Cases, 688 F. Supp. 2d at 1033. An EIS is required here under several of the intensity factors because, as detailed above, cattle grazing could have adverse consequences to listed, rare, and special status species, water resources, riparian areas, recreation, and other resources. Each of the following intensity factors may be triggered here. 40 C.F.R. § 1508.27(b)(3) (unique characteristics of the area including proximity to historic or cultural resources or ecologically critical areas); § 1508.27(b)(4) (degree to which effects are likely to be highly controversial); § 1508.27(b)(5) (degree to which effects are highly uncertain or involve unique or unknown risks); § 1508.27(b)(6) (degree to which the action may establish a precedent for future actions with significant effects by allowing a major change in the type of grazing and impacts within wilderness); § 1508.27(b)(7) (whether the action is related to other actions with individually insignificant but cumulatively significant impacts); § 1508.27(b)(8) (may adversely affect significant scientific resources); § 1508.27(b)(9) (adverse effects on endangered species or their critical habitat); § 1508.27(b)(10) (threatens violation of the ESA and the Wilderness Act). These and other impacts must be fully evaluated in an EIS. For example, the potential for disease transmission to bighorn sheep from cattle is known as are the potentially devastating impacts of such disease transmission, this is a unique risk that must be adequately addressed in an EIS before any decision can be made. 40 C.F.R. § 1508.27(b)(5) (degree to which effects are highly uncertain or involve unique or unknown risks). In addition, there is a substantial dispute about the importance and effect of opening these lands to cattle grazing and the proposal is significant under this intensity factor as well. 40 C.F.R. § 1508.27(b)(4) (effects controversy). The cumulative significance factor is also triggered here: “Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts.” 40 C.F.R. § 1508.27(b)(7). The NEPA decision-making process is designed to address significant effects that could otherwise be masked by “the tyranny of small decisions.” See Kern v. Bureau of Land Mgmt, 284 F.3d 1062, 1078 (9th Cir. 2002); Pac. Coast Fed’n of Fishermen’s Ass’ns v. Nat’l Marine Fisheries Serv., 265 F.3d 1028 (9th Cir. 2001).

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 12 August 5, 2019

The information available to date alone shows that the proposed action would impair habitat, water quality, and other values that must be addressed in a through environmental review; therefore, BLM should prepare an EIS. Many of the “significance factors,” both of context and intensity, are triggered by the proposal including the potential effects on listed species and critical habitats, impacts to other species and habitats, impacts to water resources and riparian areas, the controversy regarding cattle grazing in this area, and impacts to recreation and visual resources. Therefore, an EIS is required. Proposed Action Neither Multiple Use Sustained Yield Act (MUSYA) nor the existing Forest Plans require that livestock grazing be the primary use of these lands or be authorized at all where it conflicts with other uses. Given the presence of listed and special status species may be impacted the Forest Service must consider prioritizing those uses over cattle grazing and closing the allotments for 10-20 years to support species and water resource recovery. The NOPA mentions the operative forest plans including the Sierra Nevada Forest Plan Amendment (SNFPA) but appears to only note the sections on livestock grazing. These plans also have other forest wide and resource specific requirements (standards and guidelines) for conserving and protecting water quality, riparian conservation areas, buffer areas, and aquatic/riparian resources including wet meadows that must be considered. In addition, the forest plans provide standards and guidelines for protecting and maintaining special status species habitats as a priority that the HTNF must take into account in the environmental review. Even looking solely at multiple uses under MUSYA, recreation and natural resource protection must be given at least equal weight to livestock grazing and impacts cannot be ignored—decreasing the number of AUMs from the proposed amount and reducing the seasons or years grazed must also be considered. Resting the allotments for an additional 5 years should also be considered along with other alternatives that would keep the allotment closed for 10 or 20 years to protect other resources and allow recovery of native species. Allotments are proposed to be divided up into pastures and grazed in a deferred or rest rotation system. Instead of new fences, range riders would keep cattle in these pastures. An EIS should be prepared since the presence of range riders could have impacts on bighorn sheep use of habitat and water sources, and impacts on sensitive wildlife periods. The Forest proposes flexible occupancy rates, season of use, and grazing management strategies for cattle, after the public review process and Record of Decision. This is an unacceptable as so many sensitive and listed species are present here— adjusting cattle grazing parameters at a later time could greatly impact federally threatened and endangered species, and all flexible management proposals need to be analyzed during an EIS review in front of the public. The Forest should not defer these important management decisions to a later date.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 13 August 5, 2019

Draft versions of any new proposed Allotment Management Plans should be included in the EIS. Proper use criteria should be defined more specifically for vegetation types and habitats. For example, maximum allowable utilization percentages should be defined for aspen stands, wet meadow, dry-to-moist meadow, willow riparian, upland sagebrush- perennial grass communities, and higher-elevation Ceanothus-bitterbrush-sagebrush- conifer communities. Streambank alteration should take into account downstream impacts to Lahontan cutthroat trout populations. Sage-grouse lekking, nesting, and brood-rearing should be a priority that is analyzed for season of use and start dates for grazing on the allotments. Trailing is mentioned in the NOPA at 11. Impacts of trailing cattle through already-grazed pastures should be analyzed on vegetation cover, height, riparian vegetation, stream banks, sage-grouse habitat, bighorn sheep, Yosemite toads, and other species of concern. Soil protection, weed control, and vegetation rehabilitation best management practices (BMPs) should be detailed in an EIS.

Three existing but poorly functioning water developments would be reconstructed to provide reliable stock watering points (NOPA at 12). The Forest should analyze more fully the impacts of new water sources in sage-grouse and Sierra Nevada bighorn sheep habitat in an EIS. Discussions with Forest staff indicate that only one range rider is proposed to keep cattle within unfenced allotment boundaries. This is not adequate to keep cattle from wandering further into designated Wilderness, or into adjacent critical habitat units and those potential impacts must be fully addressed in the environmental review. Property owners in the community of Twin Lakes have made their concerns known about cattle wandering into the community as well. Additional Issues The NOPA at 13 says there is a potential for damage in areas of concentrated livestock use (e.g., around water developments, trailing routes, and along fences). The significant impacts of this issue should be fully analyzed in an EIS. The NOPA at 14 says there is potential for cattle to concentrate around wetlands and in riparian areas despite restrictions on such use, and significantly impact several listed and rare species. The significant impacts of this issue should be fully analyzed in an EIS. The pika should be considered as a species of concern for this project.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 14 August 5, 2019

The NOPA at 16 says there is potential for impacts on wilderness character due to human activity and livestock use. The significant impacts of this issue should be fully analyzed in an EIS. Impacts of new cattle grazing in this scenic region to recreation, wilderness, and Inventoried Roadless Areas should also be analyzed in an EIS. The impacts of cattle grazing to recreation will be significant, with dung, flies, and potential for negative user interface with unfenced cattle. The Virginia lakes area and Twin lakes areas have become increasingly popular with hikers, campers, and other visitors to the National Forest, wilderness, and adjacent parks. An EIS should also analyze a reduced allotment size alternative that completely avoids critical habitat units and provides a buffer to such units. Conclusion

Because of the great number of valuable resources, rare and listed species, potential significant cattle impacts to Sierra Nevada bighorn sheep, sage-grouse, Yosemite toads, and other species, plus the high recreational values of the area, we request that a full Environmental Impact Statement be analyzed for these allotments. . Because of the very high recreational value of the area, and the hot spot of rare and sensitive species, we ask that these allotments be canceled due to significant resource conflicts.

We appreciate the opportunity to assist the Humboldt-Toiyabe National Forest by providing additional scoping comments for the Bridgeport Southwest Rangeland Project environmental review. Please keep each of our groups informed of all further substantive stages in this and related NEPA processes and documents sent to the contacts below. us

Yours sincerely,

Laura Cunningham, California Director Lisa T. Belenky, Senior Attorney Western Watersheds Project Center for Biological Diversity P.O. Box 70 1212 Broadway, Suite 800 Beatty NV 89003 Oakland, CA 94612: phone (510) 844-7107 [email protected] [email protected]

George Nickas, Executive Director Denise Boggs Wilderness Watch Executive Director PO Box 9175 Conservation Congress Missoula MT 59807 [email protected] P: 406-542-2048 E: [email protected]

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 15 August 5, 2019

CC: (via email) Lahontan Regional Water Quality Control Board, Nonpoint Source Program, Senior Water Resources Control Engineer, [email protected]

California Department of Fish and Wildlife, Inland Deserts Region, Senior Environmental Scientist-Specialist, [email protected] and Lacey Greene Environmental Scientist, Sierra Nevada Bighorn Sheep Recovery Program, [email protected]

U.S. Fish and Wildlife Service, Wildlife Biologist, Steve Abele, [email protected]

Attachments: Map 1: Allotment boundaries, proposed boundaries, “capability suitability” areas from NOPA, and designated critical habitats Map 2: Allotment boundaries, proposed boundaries, “capability suitability” areas from NOPA, with threatened species sightings within 2 kim Map 3: Allotment boundaries, proposed boundaries, “capability suitability” areas from NOPA, with CNDDB observations within 2 km References (attached): Besser, T., Cassirer, F., Highland, M., Wolff, P., Justice-Allen, A., Mansfield, K., Davis, M., Foreyt, W. 2013. Bighorn sheep pneumonia: Sorting out the cause of a polymicrobial disease. Preventive Veterinary Medicine, 108, 85–93.

Christiansen, T. 2009. Fence Marking to Reduce Greater Sage-grouse (Centrocercus urophasianus) Collisions and Mortality near Farson, Wyoming – Summary of Interim Results. Wyoming Game & Fish Dept. October 26, 2009.

Dassanayakea, R., Shanthalingam, S., Herndon, C., Subramaniam, R. Paulraj K. Lawrence, Bavananthasivam, J., Cassirer, F., Haldorson, G., Foreyt, W., Rurangirwaa, F., Knowles, D., Besser, T., Srikumaran, S. 2010. Mycoplasma ovipneumoniae can predispose bighorn sheep to fatal Mannheimia haemolytica pneumonia. Veterinary Microbiology, 145, 354–359.

Doherty, K. E., D. E. Naugle, J. D. Tack, B. L. Walker, J. M. G. Beck, and J. L. Beck. 2014. Linking conservation actions to demography: grass height explains variation in greater sage-grouse nest survival. Wildlife Biology, 20(6):320-325.

Nevada Division of Wildlife (NDOW). 2001. Bighorn Sheep Management Plan.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 16 August 5, 2019

Spraker, T., Collins, J., Adrian, W., Otterman, J. 1986. Isolation and serologic evidence of a Respiratory Syncytial Virus in bighorn sheep from Colorado. Journal of Wildlife Diseases, 22(3), 416-418.

Van Lanen, N. J., A. W. Green, T. R. Gorman, L. A. Quattrini, D. C. Pavlacky Jr. 2017. Evaluating efficacy of fence markers in reducing greater sage-grouse collisions with fencing. Biological Conservation 213: 70-83.

Wolfe, L. Diamond, B., Spraker, T., Sirochman, M., Walsh, D., Machin, C., Bade, D., Miller, M. 2010. A bighorn sheep die-off in southern Colorado involving a Pasteurellaceae strain that may have originated from syntopic cattle. Journal of Wildlife Diseases, 46(4), 1262-8.

Comments on NOPA for Bridgeport Southwest Rangeland Project Page 17 August 5, 2019

Attachments

Map 1

Legend

Adjusted Allotment Boundaries Allotments Acres Capable of Supporting Cattle Grazing from Map 2 Bi-state sage grouse proposed critical habitat Sierra Nevada yellow-legged frog critical habitat Sierra Nevada bighorn sheep critical cabitat Yosemite toad critical habitat

SUMMERS MEADOW

CAMERON CANYON TAMARACK

DUNDERBERG

0 0.75 1.5 3 Miles

Map 2

Legend Adjusted Allotment Boundaries Allotments Acres Capable of Supporting Cattle Grazing from Map 2 CNDDB observations of threatened species within 2 km of allotments California wolverine Sierra Nevada red fox Swainson's hawk Yosemite toad Sierra Nevada bighorn sheep critical cabitat

SUMMERS MEADOW

CAMERON CANYON TAMARACK

DUNDERBERG

0 0.75 1.5 3 Miles

Map 3

Legend

Adjusted Allotment Boundaries Allotments Acres Capable of Supporting Cattle Grazing from Map 2 CNDDB observations within 2km yellow warbler western white-tailed jackrabbit upswept moonwort snow willow slender moonwort seep kobresia northern goshawk long seta hump moss gray-headed pika golden violet frog's-bit buttercup fiddleleaf hawksbeard SUMMERS MEADOW common moonwort bog sandwort Yosemite toad Wong's springsnail Tulare rockcress Tioga Pass sedge Tiehm's rockcress Swainson's hawk CAMERON CANYON Sierra Nevada red fox TAMARACK Sierra Nevada mountain beaver North American porcupine Mono Lake lupine Masonic rockcress Masonic Mountain jewelflower Leech's skyline diving beetle California wolverine Bodie Hills rockcress American badger Sierra Nevada bighorn sheep critical cabitat

DUNDERBERG

0 0.75 1.5 3 Miles

References Epizootic Pneumonia of Bighorn Sheep following Experimental Exposure to Mycoplasma ovipneumoniae

Thomas E. Besser1,2*, E. Frances Cassirer3, Kathleen A. Potter1,2, Kevin Lahmers1, J. Lindsay Oaks1,2, Sudarvili Shanthalingam1, Subramaniam Srikumaran1, William J. Foreyt1 1 Department of Veterinary Microbiology and Pathology, Washington State University, Pullman, Washington, United States of America, 2 Washington Animal Disease Diagnostic Laboratory, Washington State University, Pullman Washington, United States of America, 3 Idaho Department of Fish and Game, Lewiston, Idaho, United States of America

Abstract

Background: Bronchopneumonia is a population limiting disease of bighorn sheep (Ovis canadensis). The cause of this disease has been a subject of debate. Leukotoxin expressing Mannheimia haemolytica and Bibersteinia trehalosi produce acute pneumonia after experimental challenge but are infrequently isolated from animals in natural outbreaks. Mycoplasma ovipneumoniae, epidemiologically implicated in naturally occurring outbreaks, has received little experimental evaluation as a primary agent of bighorn sheep pneumonia.

Methodology/Principal Findings: In two experiments, bighorn sheep housed in multiple pens 7.6 to 12 m apart were exposed to M. ovipneumoniae by introduction of a single infected or challenged animal to a single pen. Respiratory disease was monitored by observation of clinical signs and confirmed by necropsy. Bacterial involvement in the pneumonic lungs was evaluated by conventional aerobic bacteriology and by culture-independent methods. In both experiments the challenge strain of M. ovipneumoniae was transmitted to all animals both within and between pens and all infected bighorn sheep developed bronchopneumonia. In six bighorn sheep in which the disease was allowed to run its course, three died with bronchopneumonia 34, 65, and 109 days after M. ovipneumoniae introduction. Diverse bacterial populations, predominantly including multiple obligate anaerobic species, were present in pneumonic lung tissues at necropsy.

Conclusions/Significance: Exposure to a single M. ovipneumoniae infected animal resulted in transmission of infection to all bighorn sheep both within the pen and in adjacent pens, and all infected sheep developed bronchopneumonia. The epidemiologic, pathologic and microbiologic findings in these experimental animals resembled those seen in naturally occurring pneumonia outbreaks in free ranging bighorn sheep.

Citation: Besser TE, Cassirer EF, Potter KA, Lahmers K, Oaks JL, et al. (2014) Epizootic Pneumonia of Bighorn Sheep following Experimental Exposure to Mycoplasma ovipneumoniae. PLoS ONE 9(10): e110039. doi:10.1371/journal.pone.0110039 Editor: Glenn F. Browning, The University of Melbourne, Australia Received June 22, 2014; Accepted September 13, 2014; Published October 10, 2014 Copyright: ß 2014 Besser et al. This is an open-access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited. Data Availability: The authors confirm that all data underlying the findings are fully available without restriction. All relevant data are within the paper. Funding: These studies were funded by grants from the Wyoming Wildlife/Livestock Disease Partnership (T. E. Besser, S. Srikumaran), the Washington Department of Fish and Wildlife (T. E. Besser), the Idaho Domestic Wildlife Research Oversight Committee (E. F. Cassirer), and the Oregon chapter of the Foundation for North American Wild Sheep (T. E. Besser) or the grant support that made these studies possible. The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript. Competing Interests: The authors have declared that no competing interests exist. * Email: [email protected]

Introduction comparative review of the evidence supporting each of these possible etiologies we concluded that M. ovipneumoniae was most Bighorn sheep are a North American species that has failed to strongly supported as the primary epizootic agent of bighorn sheep th recover from steep declines at the turn of the 20 century despite pneumonia [14]. However, the only two previous experimental strict protections and intensive management, and two populations challenge studies with M. ovipneumoniae either did not reproduce (Sierra Nevada and Peninsular) are currently classified as disease [13] or were confounded by challenges with other agents endangered [1]. Epizootic pneumonia is limiting bighorn sheep [16]. The objective of this study was to improve upon previous population restoration and as such, the etiology is of considerable investigations to better assess the outcome of experimental interest. The first appearance of the disease in a population is introduction of M. ovipneumoniae to naı¨ve bighorn sheep. typically in the form of epizootics that affect animals of all ages and is sometimes accompanied by high (.50%) mortality rates. Methods Subsequently, epizootics affecting primarily lambs may occur for decades [2]. Various causes have been proposed for this disease, Ethics statement including lungworms (Protostrongylus sp.) [3–6], Pasteurellaceae, This study was carried out in accordance with the recommen- especially Mannheimia (Pasteurella) haemolytica, [7–12] and more dations in the Guide for the Care and Use of Laboratory Animals recently, Mycoplasma ovipneumoniae [13–16]. In a recent of the National Institutes of Health and in conformance with

PLOS ONE | www.plosone.org 1 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia

United States Department of Agriculture animal research guide- had been successful. On post challenge day 7, DS #00 was lines, under protocols #03854 and #04482 approved by the introduced into pen #1 with BHS #82. Following commingling, Washington State University (WSU) Institutional Animal Care DS #00 and BHS #82 were restrained for collection of nasal and Use Committee. As described in those protocols, euthanasia swab samples on days 1, 2, 4, 7, 14, 21, 28, and subsequently at 30 was performed by intravenous injection of sodium pentobarbital day intervals until the experiment was terminated. Rectal for animals observed to be in severe distress associated with temperatures were recorded from both sheep approximately twice pneumonia during the study and prior to necropsy examination each week. Sheep in pens #2 (BHS #89 and DS #01) and #3 for surviving animals at the end of each experiment. (BHS #07 and DS #LA) were restrained for rectal temperature determination and collection of nasal swabs for microbiology at Experimental aims approximately monthly intervals. All pens were observed daily for Experiment 1 was conducted to investigate the transmission of clinical signs of respiratory disease. The experiment was conducted M. ovipneumoniae to bighorn sheep and their subsequent October 2009–January 2010. development of disease, using an infected domestic sheep source. Experiment 2. BHS #39 was inoculated with M. ovipneu- Experiment 2 was conducted to investigate experimental direct M. moniae just prior to its release into pen #1 with non-inoculated ovipneumoniae infection of a single bighorn sheep and the BHS #38 and #40. Non-inoculated BHS #C, #41, and #42 subsequent transmission of this agent to conspecifics. Both were housed in pen #2 on the same day. The inoculum for BHS experiments were conducted in multiple pens separated by short #39 was prepared as described for that used in experiment 1 but distances, which allowed investigation of transmission to both originated from a different domestic sheep source. In lieu of commingled and non-commingled animals. computation of colony forming units, which is not possible for M. ovipneumoniae due to inconsistent growth on plated media, viable Experimental animals M. ovipneumoniae counts in the inoculum were determined using All experimental animals originated from herds and flocks most probable number (MPN) using a custom 364 format: unexposed to M. ovipneumoniae as determined by repeated testing Triplicate enrichment broth tubes were inoculated at each of four 22 25 with both serology on blood serum and PCR on enriched nasal decimal dilutions (10 –10 ) of the treated nasal wash fluid [17], swab cultures (using the methods described later in the ‘Micro- incubated (72 hrs, 35C) then PCR was used to detect growth of biological testing’ section). In Experiment 1, three hand-reared viable M. ovipneumoniae. The treated fluid was determined to bighorn sheep (yearling rams BHS #82 and #89 and yearling ewe contain 930 MPN/ml (95% confidence interval, 230 to 3800 BHS #07) that originated from a captive flock at WSU and three MPN). Two of the bighorn sheep (BHS #38 and #39) in pen 1 purchased domestic sheep (adult ewes DS #00 and #01 and were recaptured by drive net on day 21 of the experiment for nasal yearling ewe DS #LA) were co-housed in three 46 m2 pens, with swab sampling to detect M. ovipneumoniae infection; otherwise, one domestic and one bighorn sheep per pen. Pens were separated no live animal sampling was conducted in experiment #2to by 7.6–12 m. Experiment 1 animals had all been commingled in a reduce the risk of traumatic injury of the wild bighorn sheep single pen for 104 days immediately prior to the beginning of this involved. The experiment was conducted December 2011–June experiment, as previously described [15]. One of the four bighorn 2012. sheep used in that prior study had died of M. haemolytica Biosecurity. In both experiments, routine biosecurity mea- pneumonia, while the other three, which had demonstrated no sures included: 1) the pens containing the single M. ovipneumo- signs of respiratory disease in that study, were used in experiment niae-challenged animals (exposed pens) were located downwind of 1. In Experiment 2, wild bighorn sheep captured from the Asotin the prevailing wind direction from the pens containing no Creek population in Hells Canyon were housed in two 700 m2 experimentally M. ovipneumoniae exposed animals (clean pens), pens, 7.6 m apart, with three animals per pen (Pen #1: adult ewe 2) order of entry rules were established so that on any single day BHS #40, yearling ewe BHS #38, and yearling ram BHS #39; exposed pens were routinely entered by animal care staff for Pen #2: adult ewes BHS #41 and #42 and adult ram BHS #C). feeding and cleaning only after all work in clean pens had been The study pens had either never previously housed domestic or completed, and 3) personal protective equipment (coveralls and bighorn sheep (pen 1 in experiment 1; both pens in experiment 2) boots) used in exposed pens were either not reused, or were or had been rested for greater than one year since their previous sanitized prior to use in clean pens. occupancy by any M. ovipneumoniae infected sheep (pens 2 and 3 Clinical scores. Clinical score data were determined using in experiment 1) prior to these experiments. the following cumulative point system: observed anorexia (1), nasal discharge (1), cough (2), dyspnea (1), head shaking (1), ear paresis Experimental design (1) and weakness/incoordination (1). Experiment 1. A domestic ewe (DS #00) was placed in Microbiological testing. Routine diagnostic testing per- isolation and experimentally infected with M. ovipneumoniae. The formed by the Washington Animal Diagnostic Laboratory (fully inoculum consisted of ceftiofur-treated (100 ug/ml, 2 hrs, 37uC; accredited by the American Association of Veterinary Laboratory Pfizer, Florham Park, NJ) nasal wash fluids from a domestic sheep Diagnosticians) included detection of M. ovipneumoniae-specific naturally colonized with M. ovipneumoniae [16]. Following and small ruminant lentivirus-specific antibodies in serum samples ceftiofur treatment, no aerobic bacterial growth was observed using competitive enzyme-linked immunosorbent assays (cELISA) from the nasal wash fluids cultured under conditions expected to [14,18,19], detection of M. ovipneumoniae colonization by broth permit growth of M. haemolytica, B. trehalosi, or P. multocida enrichment of nasal swabs followed by M. ovipneumoniae-specific (Columbia blood agar with 5% sheep blood, 35uC, overnight, 5% PCR testing of the broths [20,21], detection of Pasteurellaceae in CO2). DS #00 was then challenged with the treated nasal wash pharyngeal swab samples by aerobic bacteriologic cultures, and fluid by infusion of 15 ml in each nares, 10 ml orally and 5 ml into detection of exposure to parainfluenza-3, border disease, and each conjunctival sac. Subsequent nasal swab samples obtained on respiratory syncytial viruses by virus neutralization antibody assays days 1, 2, 4 and 7 post-challenge were all PCR positive for M. applied to serum samples. ovipneumoniae using the method described later in the ‘Microbi- PCR tests specific for detection of M. haemolytica, B. trehalosi, ological testing’ section confirming that the experimental infection and P. multocida, and lktA (the gene encoding the principal

PLOS ONE | www.plosone.org 2 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia virulence factor of M. haemolytica and B. trehalosi) were applied to detection of specific respiratory pathogens was provided by the DNA extracted from pneumonic lung tissues using previously PCR assays described earlier, whereas these 16S studies were described primers (Table 1) and methods with minor modifica- designed instead to identify the numerically predominant bacteria tions. All reactions were conducted individually in 20 mL volumes in affected lungs. The library size used was based on the binary containing 80–300 ng of template DNA. For M. haemolytica, B. distribution to provide a 95% chance of detection of each taxon trehalosi, lktA and P. multocida, reactions contained 0.5 units of comprising 10% or more of the ribosomal operon frequency in the HotStar Taq DNA polymerase (Qiagen), 2 mL 10x PCR buffer source tissue. Two 1 g samples of pneumonic lung tissues were (Qiagen), 4 mL Q-solution (Qiagen), 40 mM of each dNTP aseptically collected from sites at least 10 cm apart, homogenized (Invitrogen). The M. ovipneumoniae reaction used QIAGEN by stomaching, and DNA was extracted (DNeasy tissue kit; Multiplex PCR mix. Primers were used at final concentrations of Qiagen, Valencia, CA) from 100 uL aliquots of each homogenate. 0.2 mM(M. haemolytica, B. trehalosi, P. multocida, and M. 16S rDNA segments were PCR amplified and cloned as described ovipneumoniae) or 0.5 mM (leukotoxin A). Each reaction included [13]. Insert DNA was sequenced from 16 clones derived from each an initial activation and denaturation step (95uC, 15 min) and a of the two homogenates from each animal, and each sequence was final 72uC extension step (10 min for Mhgcp-2, lktA, lktA set-1, attributed to species ($99% identity) or genus ($97% identity) and LM primers; 9 min for KMT primers; 5 min for Btsod and based on BLAST GenBank similarity [24]. Mhgcp primers). Cycling conditions were as follows: M. ovipneumoniae, 30 cycles of 95uC for 30 s, 58uC for 30 s, 72uC Results for 30 s; B. trehalosi and M. haemolytica (Mhgcp and Btsod primers), 35 cycles of 95uC for 30 s, 55uC for 30 s, 72uC for 40 s; Experiment 1 P. multocida and lktA (lktA primers), 30 cycles of 95uC for 60 s, M. ovipneumoniae infection of DS #00, introduced into pen 1 55uC for 60 s, 72uC for 60 s; M. haemolytica (Mhgcp-2 primers), to start the experiment, was confirmed by positive nasal swab 40 cycles of 95uC for 30 s, 54uC for 30 s, 72uC for 30 s; lktA (lktA samples obtained on days 1, 4, and 7 after inoculation prior to its set-1 primers), 40 cycles of 95uC for 30 s, 52uC for 30 s, 72uC for introduction into pen #1, and on days 1, 2, 4, 7, 14, 21, 28, 60 40 s. Leukotoxin expression was detected in Pasteurellaceae and 90 after its introduction into pen #1, confirming that the isolates by MTT dye reduction cytotoxicity assay as described experimental colonization had been successful and maintained previously [22]. throughout experiment 1. M. ovipneumoniae was first detected in The 16S–23S ribosomal operon intergenic spacer (IGS) regions the bighorn sheep (BHS #82) commingled with DS #00 in pen of M. ovipneumoniae recovered from animals in these studies were #1 on day 28, and subsequent tests on days 60 and 90 were also PCR amplified (Table 1) and sequenced as previously described positive. BHS #82 developed signs of respiratory disease including [23]. nasal discharge (onset day 37); coughing and fever (onset day 42); 16S rDNA analyses to identify the predominant bacterial and lethargy and ear paresis (onset day 61) (Figure 1a). Signs of flora in pneumonic lung tissues. In previous studies, culture- respiratory disease were observed in the bighorn sheep in pens #2 independent evaluation of the microbial flora of lung tissues in (BHS #89) and #3 (BHS #07) beginning on days 62 and 67, naturally occurring bighorn sheep pneumonia revealed a polymi- respectively; these signs also included fever, lethargy, paroxysmal crobial flora late in the disease course [13,23]. For comparison, we coughing, nasal discharge, head shaking, and drooping ears. No applied the same methods to lung tissues of the experimentally signs of respiratory disease were observed in the commingled challenged animals in this study. Note that more sensitive domestic sheep at any time during the experiment. M.

Table 1. Primers and PCR reaction targets used in these experiments.

Pathogen/Virulence gene Target Primer Name Sequence (59 R 39) Size (bp) Reference

M. haemolytica gcp MhgcpF AGA GGC CAA TCT GCA AAC CTC G 267 [33] MhgcpR GTT CGT ATT GCC CAA CGC CG M. haemolytica gcp MhgcpF2 TGG GCA ATA CGA ACT ACT CGG G 227 [34] MhgcpR2 CTT TAA TCG TAT TCG CAG B. trehalosi sodA BtsodAF GCC TGC GGA CAA ACG TGT TG 144 [33] BtsodAR TTT CAA CAG AAC CAA AAT CAC GAA TG P. multocida kmt1 KMT1T7 ATC CGC TAT TTA CCC AGT GG 460 [35] KMT1SP6 GCT GTA AAC GAA CTC GCC AC Pasteurellaceae leukotoxin lktA lktAF TGT GGA TGC GTT TGA AGA AGG 1,145 [36] lktAR ACT TGC TTT GAG GTG ATC CG M. haemolytica leukotoxin lktA lktAF set-1 CTT ACA TTT TAG CCC AAC GTG 497 [34] lktAR set-1 TAA ATT CGC AAG ATA ACG GG Mycoplasma ovipneumoniae 16s rDNA LMF TGA ACG GAA TAT GTT AGC TT 361 [20,21] LMR GAC TTC ATC CTG CAC TCT GT Mycoplasma ovipneumoniae 16S–23S IGS MoIGSF GGA ACA CCT CCT TTC TAC GG Variable,490 [23] MoIGSR CCA AGG CAT CCA CCA AAT AC

doi:10.1371/journal.pone.0110039.t001

PLOS ONE | www.plosone.org 3 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia ovipneumoniae was detected in nasal swab samples from all #1. On day 49, signs of respiratory disease were first observed in bighorn and domestic sheep in pens #2 and #3 when sampled on the bighorn sheep in pen #2 (Figure 2b). On days 65 and 109, day 70. The bighorn sheep were euthanized for necropsy on days #41, and #42 in pen #2 died or were euthanized in extremis. The 93 (BHS #89) and 99 (BHS #82 and #07). At necropsy, surviving three bighorn sheep exhibited varying degrees of significant abnormal findings were limited to the respiratory tract. respiratory disease: BHS #38 showed persistent respiratory Bronchopneumonia affecting 25–50% of the lung volume was disease, while BHS #40 and #C showed decreasing respiratory observed in all three bighorn sheep (Figure 2). Histopathological disease over time, which became minimal after days 161 and 154, examination revealed peribronchiolitis with large lymphoid cuffs, respectively. On day 204, the three surviving bighorn sheep were bronchiectasis with purulent exudates, pulmonary atelectasis, and euthanized for necropsy. At necropsy, significant abnormal hyperplastic bronchial epithelia lacking visible cilia (Figure 2). findings were limited to the respiratory tract. All six bighorn sheep had bronchopneumonia, with consolidation of lung tissue Experiment 2 volumes ranging from an estimated 5% (BHS #40) to 80–100% On day 21 following release of the inoculated bighorn into pen (BHS #41) (Figure 2). Histopathological examination revealed #1, M. ovipneumoniae was detected in the inoculated animal and severe peribronchiolitis with large lymphoid cuffs as seen in one pen mate (BHS #38 and #39); the third animal (BHS #40) experiment 1. Animals that died or were euthanized in extremis evaded capture and sampling on that day. The first signs of had an overlying necrotizing bronchiolitis (#39) or abscessing respiratory disease were observed in pen #1 animals on day 21 bronchiolitis with bronchiectasis (BHS #41, #42) (Figure 2). during drive net capture for sampling, apparently triggered by exertion (Figure 2a). On day 34, inoculated BHS #39 died in pen

Figure 1. Clinical signs exhibited by M. ovipneumoniae infected bighorn sheep. Clinical scores (3-day moving averages) of bighorn sheep following introduction of M. ovipneumoniae: A) Experiment 1, 3 separate pens; solid line, Pen 1, BHS #82; dashed line, Pen 2, BHS #89; dotted line, Pen 3, BHS #07; B) Experiment 2, Pen 1: solid line, BHS #39 (died day 34); dashed line, BHS #40; dotted line; BHS #38.; C) Experiment 2, Pen 2: solid line, BHS #42 (euthanized day 109); dotted line, BHS #41 (died day 65); dashed line, BHS #C. doi:10.1371/journal.pone.0110039.g001

PLOS ONE | www.plosone.org 4 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia

Figure 2. Gross and histologic lesions in lungs of bighorn sheep experimentally infected with M. ovipneumoniae. Images of BHS #82 (A, B), BHS #39 (C, D), BHS #C (E, F) and BHS #42 (G, H). Original magnification of histologic images was 200X (B, D, H) or 100X (F). doi:10.1371/journal.pone.0110039.g002

Microbiology respiratory samples were PCR indeterminate (Table 3). Aerobic All bighorn sheep in both experiments seroconverted to M. cultures and/or PCR tests identified B. trehalosi from pneumonic ovipneumoniae (Table 2). Most experimental animals had neu- lung tissues from all bighorn sheep in both experiments (Table 3). tralizing antibody to parainfluenza-3 virus, but no significant B. trehalosi isolates from BHS #82 and #07 carried lktA and changes in antibody titers were observed during the experimental expressed leukotoxin activity (Table 3). P. multocida and M. period. Detectable antibody to other ovine respiratory viruses, haemolytica were not detected in these animals by either aerobic including border disease virus, ovine progressive pneumonia virus, culture or PCR. and respiratory syncytial virus was occasionally observed in single samples. Culture independent survey of bacteria in pneumonic M. ovipneumoniae was detected at necropsy in both upper and bighorn sheep lung tissues lower respiratory tracts of all bighorn sheep except BHS #40 DNA sequences of cloned 16S rDNA revealed that the whose lung tissues were PCR negative and whose upper predominant bacterial species in pneumonic sections of lung were

PLOS ONE | www.plosone.org 5 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia

Table 2. Antibody responses to M. ovipneumoniae and parainfluenza-3 (PI-3) virus.

M. ovipneumoniae1 PI-3 virus2

Experiment ID Pen Pre3 Post3 Pre3 Post3

1 82 1 –8% 93% 512 512 1 89 2 –7% 88% 128 128 1 07 3 –1% 92% 256 512 2 38 1 –6% 74% Neg 64 2 39 1 –13% 67% Neg ,32 2 40 1 –23% 75% 64 512 2 41 2 –19% 82% 512 NT 2 42 2 –11% 82% 256 NT 2 C 2 –4% 66% 256 512

1M. ovipneumoniae antibody detected by cELISA, expressed as percentage inhibition of the binding of an agent-specific monoclonal antibody [14,18]. 2PI-3 virus neutralizing antibody detected by virus neutralization [37]. 3Pre samples in experiment 1 were obtained on the day that the M. ovipneumoniae colonized domestic sheep was introduced to pen 1 and in experiment 2 were obtained on the day that BHS #39 was inoculated with M. ovipneumoniae. ‘Post’ samples in both experiments were obtained at necropsy. Neg = No titer detected. NT = Not tested, due to inadequate specimen volume. doi:10.1371/journal.pone.0110039.t002 diverse (Table 4). In experiment 1, M. ovipneumoniae was Discussion detected in the lung tissues of all animals. B. trehalosi also comprised substantial proportions of the pneumonic lung flora in The most striking finding of these experiments was the high two animals (BHS #82 and #07), while obligate anaerobic transmissibility of M. ovipneumoniae and the consistent develop- species, primarily Fusobacterium spp., predominated in the third ment of pneumonia that followed infection of bighorn sheep. The animal (BHS #89). The flora identified in the pneumonic lungs of bacterium was naturally transmitted from single experimentally the animals in experiment 2 was also substantially comprised of inoculated animals (a domestic sheep in experiment 1 and a mixed obligate anaerobes especially Fusobacterium spp. (Table 4). bighorn sheep in experiment 2) to all animals within and between Molecular epidemiology of respiratory pens up to 12 m distant. Eight of nine bighorn sheep exposed to pathogens. Consistent with epidemic transmission, M. ovip- M. ovipneumoniae developed severe bronchopneumonia and neumoniae strains recovered from all experimental sheep within three died, while all the domestic sheep remained healthy. each experiment shared identical IGS DNA sequences with the Previous experimental challenge studies conducted with M. respective challenge inoculum (GenBank HQ615162 in experi- haemolytica or B. trehalosi in the absence of M. ovipneumoniae ment 1; KJ551511 in experiment 2). have not documented transmission. For example, Foreyt et al. [8]

Table 3. Microbiologic findings from pneumonic lung tissues, based on aerobic culture and species specific PCR.

Expt. ID Bacterial pathogens identified in pneumonic lung tissues B. trehalosi M. haemolytica lktA M. ovipneumoniae Other5

1 82 Cult, sodA1 Neg2 Pos3 16S4 None 1 89 Cult, sodA Neg Neg3 16S Pasteurella sp.5 1 07 Cult, sodA Neg Pos 16S Pasteurella sp. 2 38 Cult, sodA Neg Neg 16S Pasteurella sp. 239NT,sodA NT, Neg2 Neg 16S NT5 2 40 Cult Neg Neg Neg4 Trueperella pyogenes5 2 41 Cult, sodA Neg Neg 16S None 2 42 Cult Neg Neg 16S None 2 C Cult Neg Neg 16S Pasteurella sp.

1Cult = B. trehalosi detected by bacterial culture; sodA = B. trehalosi detected by sodA species-specific PCR (Table 1); NT = Unable to test by bacterial culture (overgrowth by Proteus sp.). 2Neg = M. haemolytica not detected by either bacterial culture or by PCR with either gcp primer set (Table 1); NT = Unable to test by bacterial culture (overgrowth by Proteus sp.). 3Neg = Pasteurellaceae lktA not detected in DNA extracts from pneumonic lung tissues by two different lktA PCRs (Table 1) [34,36]. Pos = lktA detected in B. trehalosi isolates obtained from BHS #82 and #07 [36]. 416S = M. ovipneumoniae detected by PCR (Table 1) [20]; Neg = M. ovipneumoniae not detected by PCR. 5Pasteurella sp., Trueperella pyogenes = Bacteria isolated and identified by aerobic culture; Pasteurella sp. were determined not to be B. trehalosi, M. haemolytica, or P. multocida; NT = Unable to test by bacterial culture due to overgrowth by Proteus sp. doi:10.1371/journal.pone.0110039.t003

PLOS ONE | www.plosone.org 6 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia

reported a series of three experiments in which commingled bighorn sheep were either challenged with intra-tracheal M. haemolytica or given sterile BHI as controls. Four of the five control bighorn sheep survived without evidence of disease while commingled with eight M. haemolytica-challenged bighorn sheep, of which seven died of pneumonia [8]. Commingled bighorn

1 sheep also remained healthy in several other studies where

(100.0) individual bighorn sheep died with apparent M. haemolytica 6 Other 1 (3.1) 2 (6.3) 4 (12.5) 13 (23.2) 15 (26.8) 6 (18.8) 5 (15.6) 1 (3.1) bronchopneumonia (confirmed by isolation of this bacterium from

5% of sequenced clones. lung tissues) [15,25,26]. , In addition to high transmissibility, the time course of disease development and the predominant microbiology of the pneumonic lung tissues following experimental introduction of M. ovipneumoniae differed from that seen in previous bighorn sheep challenge experiments with other respiratory pathogens. Bighorn sheep directly challenged with leukotoxin positive M. haemolytica or B. 1 trehalosi develop peracute bronchopneumonia and .90% die within a week of challenges with 105 cfu or more [16,27–30]. In contrast, disease following experimental M. ovipneumoniae Porphyro 0 0 0 9 (16.1) 19 (33.9) 0 0 0 exposures was considerably slower in onset (14–21 days post infection) and development (deaths occurring 34 to 109 days post infection; respiratory disease persisted up to 6 months post- infection); this slow time course closely resembles that documented previously in bighorn lamb pneumonia outbreaks [13]. After lethal M. haemolytica challenge, the agent is typically isolated from lung

1 tissues in high numbers and pure cultures [15,25]; in contrast in naturally occurring pneumonia outbreaks M. ovipneumoniae may Prev 3 (9.4) 1 (3.1) 0 20 (35.7) 5 (8.9) 0 5 (15.6) 0 be predominant early in the disease course but 16S library analyses have been used to document its overgrowth by diverse

sp.; Other = taxa other than those previously listed, each comprising other bacteria later in the disease course [14,23]. Although the numbers of animals in the experimental M. ovipneumoniae infection studies reported here are small, the results are consistent with the trend for early predominance of M. ovipneumoniae 1 followed by overgrowth by diverse other bacterial later in the Porphyromonas Fuso 0 21 (65.6) 0 8 (14.3) 17 (30.4) 24 (75.0) 21 (65.6) 31 (96.9) disease course (Tables 3 and 4) [13,14,23]. Our results also differ from our previous attempt to experimentally reproduce respiratory disease by challenge inoculation of 1-week-old bighorn lambs with M. ovipneumoniae, which sp.; Porphyro = produced minor lesions and seroconversion but no clinically significant respiratory disease [13]. However, laboratory passage

1 of M. ovipneumoniae (as was performed in that experiment) has Prevotella been reported to attenuate virulence in M. ovipneumoniae [31]. Movi 8 (25) 7 (21.9) 12 (37.5) 2 (3.6) 0 0 0 0 Challenge of bighorn sheep with un-passaged M. ovipneumoniae produced different results, as observed here in experiment #2. In sp.; Prev = another study [16], nasal washings from domestic sheep naturally colonized with M. ovipneumoniae or lung homogenates from a M. ovipneumoniae-infected bighorn sheep were used for challenge of bighorn sheep after ceftiofur treatment to eliminate detectable

Fusobacterium Pasteurellaceae. Consistent with increased virulence of un- passaged M. ovipneumoniae, infection and respiratory disease Fuso = 2 signs were observed in all four bighorn sheep, one of which died 19

1 days following challenge. The three surviving animals continued to exhibit respiratory disease signs for 42 days, at which time the Bacterial species identified in pneumonic lung tissues Btre 20 (62.5) 1 (3.1) 16 (50.0) 4 (7.1) 0 2 (6.3) 0 0000 5 1 (3.1) 0 experiment was terminated by challenge with M. haemolytica (using a dose documented to be rapidly fatal to bighorn sheep even

M. ovipneumoniae; in the absence of M. ovipneumoniae) [16]. As a result, the longer term effects of the mycoplasma infection were not determined in 0 ID 82 89 07 38 C 39 41 42

Movi = that study. Therefore, the experiments reported here are the first in which naı¨ve bighorn sheep were exposed to un-passaged M.

Microbiologic findings by 16S clone library (culture independent) method. ovipneumoniae and then followed over a time period comparable with the naturally occurring disease course. B. trehalosi; The possibility of viral agents contributing to the disease

Btre = N (%) of the sequenced 16S clones from each animal whose DNA sequences were identical to those of the tabulated bacterial species in each column. observed in this study cannot be completely ruled out, since the doi:10.1371/journal.pone.0110039.t004 Table 4. Expt. 1 1 2 1 1 2 2 2 24 2 2 inoculum was derived from nasal washings from domestic sheep

PLOS ONE | www.plosone.org 7 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia and no virucidal treatments were applied. However, a previous with the nearly 100% mortality that follows experimental study using ultrafiltrates of bighorn sheep pneumonic lung tissues commingling of bighorn sheep with presumptively or documented or nasal washings from domestic sheep failed to reproduce any M. ovipneumoniae-positive domestic sheep and suggests an respiratory disease in inoculated susceptible bighorn sheep [16]. In important role for polymicrobial secondary infections in deter- addition, serologic monitoring for the predominant domestic sheep mining mortality rates, which could be investigated in future respiratory viruses did not demonstrate seroconversion of the studies. Finally, M. ovipneumoniae was still detected in nasal swab experimental animals in this study, as described in the Results and samples of several surviving bighorn sheep that were euthanized at in Table 2. Therefore, the most parsimonious interpretation of the the completion of these studies, suggesting that survivors of data presented here is that the disease observed resulted from M. naturally occurring pneumonia outbreaks may continue to carry ovipneumoniae infection and the sequelae of that infection. and shed this agent in nasal secretions. Such carriage may provide The transmission of M. ovipneumoniae from pen-to-pen in these a mechanism for the post-invasion disease epizootics in lambs experiments strongly suggests that direct contact is not necessary described in free-ranging populations. If so, this presumptive for epizootic spread of pneumonia in bighorn sheep. Feeding, carrier state requires further study to characterize the factors that watering and other procedures involving animal care or research determine its occurrence and persistence, as these may be critical staff were designed to minimize the risk of human or fomite- for the development of effective management control measures for mediated transmission of the pathogen from pen to pen, although this devastating disease. we recognize it is impossible to completely rule out this possibility. On the other hand, since aerosolized droplet transmission is Acknowledgments recognized as a transmission route for the closely related bacterium, Mycoplasma hyopneumoniae (the cause of atypical We thank Donald P. Knowles for his contribution to the design of pneumonia of swine) [32], it is plausible that a similar transmission experiment 1 and manuscript editing, Margaret Highland for skillful mode occurs with M. ovipneumoniae. Infectious aerosols gener- technical assistance and for manuscript editing, Glen Weiser for providing ated by coughing animals would likely contribute to the explosive custom selective media for Pasteurellaceae, Duane Chandler and Amy nature of the pneumonia outbreaks observed following initial Hetrick for assistance with animal care, handling and restraint and sample collection, George Barrington for providing access to M. ovipneumoniae introduction of M. ovipneumoniae into naı¨ve bighorn sheep free domestic sheep, the Washington Department of Fish and Wildlife for populations. wild bighorn sheep, Katie Baker for skillful technical assistance, and In conclusion, we demonstrated that experimental M. ovipneu- Shannon Lee Swist for serving as Principal Investigator of the Wyoming moniae infection of naı¨ve bighorn sheep induces chronic, severe Wildlife/Livestock Disease Partnership grant. bronchopneumonia associated with multiple secondary bacterial infections and that this infection spread rapidly to animals both Author Contributions within the same pen and to animals in nearby pens. The significance of these findings would be clarified by parallel Conceived and designed the experiments: TEB EFC JLO S. Srikumaran WJF. Performed the experiments: TEB EFC JLO KAP KL S. experiments specifically designed to determine transmissibility Shanthalingam. Analyzed the data: TEB EFC KAP KL. Contributed and associated disease outcomes in other agents associated with reagents/materials/analysis tools: TEB EFC KAP KL S. Shanthalingam S. bighorn sheep pneumonia, particularly M. haemolytica, in the Srikumaran. Contributed to the writing of the manuscript: TEB EFC KAP absence of M. ovipneumoniae. Furthermore, the case-fatality rates S. Shanthalingam S. Srikumaran WJF. of M. ovipneumoniae infected animals described here contrasts

References 1. Festa-Bianchet M (2008) Ovis canadensis. The IUCN Red List of Threatened 13. Besser TE, Cassirer EF, Potter KA, VanderSchalie J, Fischer A, et al. (2008) Species. Available: http://www.iucnredlist.org/details/summary/15735/0. Ac- Association of Mycoplasma ovipneumoniae infection with population-limiting cessed 2014 Jul 24. respiratory disease in free-ranging rocky mountain bighorn sheep (Ovis 2. Cassirer EF, Plowright RK, Manlove KR, Cross PC, Dobson AP, et al. (2012) canadensis canadensis). J Clin Microbiol 46: 423–430. Spatio-temporal dynamics of pneumonia in bighorn sheep (Ovis canadensis). 14. Besser TE, EF Cassirer, MA Highland, P Wolff, A Justice-Allen, et.al. (2012) J Animal Ecol 82: 518–528. Bighorn sheep pneumonia: Sorting out the cause of a polymicrobial disease. Prev 3. Marsh H (1938) Pneumonia in Rocky Mountain bighorn sheep. J Mammal 19: Vet Med 108: 85–93. 214–219. 15. Besser TE, Cassirer EF, Yamada C, Potter KA, Herndon C, et al. (2012) 4. Buechner HK (1960) The bighorn sheep in the United States, its past, present, Survival of Bighorn Sheep (Ovis canadensis) Commingled with Domestic Sheep and future. Wildl Monog 4: 3–174. (Ovis aries) in the Absence of Mycoplasma ovipneumoniae. J Wildl Dis 48: 168– 5. Forrester DJ (1971) Bighorn sheep lungworm-pneumonia complex. In: Davis 172. JW, Anderson RC, editors. Parasitic Diseases of Wild Mammals. Ames, IA: Iowa 16. Dassanayake RP, Shanthalingam S, Herndon CN, Subramaniam R, Lawrence State University Press. 158–173. PK, et al. (2010) Mycoplasma ovipneumoniae can predispose bighorn sheep to 6. Demartini JC, Davies RB (1977) An epizootic of pneumonia in captive bighorn fatal Mannheimia haemolytica pneumonia. Vet Microbiol 145: 354–359. sheep infected with Muellerius sp. J Wildl Dis 13: 117–124. 17. Blodgett R (2010) Bacteriologic Analytical Manual Appendix 2: Most Probable 7. Miller MW (2001) Pasteurellosis. In: Williams ES, Barker, I K., editor. Infectious Number from Serial Dilutions. Washington DC. Available: http://www.fda. diseases of wild mammals. Ames IA USA: Iowa State University Press. 558. gov/Food/FoodScience Research/LaboratoryMethods/ucm109656.htm. Ac- 8. Foreyt WJ, Snipes KP, Kasten RW (1994) Fatal pneumonia following cessed 2014 Jul 24. inoculation of healthy bighorn sheep with Pasteurella haemolytica from healthy 18. Ziegler JC, Lahmers KK, Barrington GM, Parish SM, Kilzer K, et al. (2014) domestic sheep. J Wildl Dis 30: 137–145. Safety and Immunogenicity of a Mycoplasma ovipneumoniae Bacterin for 9. Kraabel BJ, Miller MW, Conlon JA, McNeil HJ (1998) Evaluation of a Domestic Sheep (Ovis aries). PLoS One 9(4): e95698. multivalent Pasteurella haemolytica vaccine in bighorn sheep: Protection from 19. Herrmann LM, Cheevers WP, Marshall KL, McGuire TC, Hutton MM, et al. experimental challenge. J Wildl Dis 34: 325–333. (2003) Detection of serum antibodies to ovine progressive pneumonia virus in 10. Rudolph KM, Hunter DL, Foreyt WJ, Cassirer EF, Rimler RB, et al. (2003) sheep by using a caprine arthritis-encephalitis virus competitive-inhibition Sharing of Pasteurella spp. between free-ranging bighorn sheep and feral goats. enzyme-linked immunosorbent assay. Clin Diag Lab Immunol 10: 862–865. J Wildl Dis 39: 897–903. 20. Lawrence PK, Shanthalingam S, Dassanayake RP, Subramaniam R, Herndon 11. Rudolph KM, Hunter DL, Rimler RB, Cassirer EF, Foreyt WJ, et al. (2007) CN, et al. (2010) Transmission of Mannheimia haemolytica from domestic sheep Microorganisms associated with a pneumonic epizootic in Rocky Mountain (Ovis aries) to bighorn sheep (Ovis canadensis): unequivocal demonstration with bighorn sheep ( ). J Zoo Wildl Med 38: 548–558. Ovis canadensis canadensis green fluorescent protein-tagged organisms. J Wildl Dis 46: 706–717; erra- 12. Weiser GC, DeLong WJ, Paz JL, Shafii B, Price WJ, et al. (2003) tum, J Wildl Dis 46: 1346. Characterization of Pasteurella multocida associated with pneumonia in bighorn sheep. J Wildl Dis 39: 536–544.

PLOS ONE | www.plosone.org 8 October 2014 | Volume 9 | Issue 10 | e110039 M. ovipneumoniae-Induced Bighorn Sheep Pneumonia

21. McAuliffe L, Hatchell FM, Ayling RD, King AI, Nicholas RA (2003) Detection sheep against Mannheimia haemolytica challenge. Clin Vaccine Immunol 18: of Mycoplasma ovipneumoniae in Pasteurella-vaccinated sheep flocks with 1689–1694. respiratory disease in England. Vet Rec 153: 687–688. 30. Foreyt WJ, Snipes KP, Kasten RW (1994) Fatal pneumonia following 22. Gentry MJ, Srikumaran S. (1991) Neutralizing monoclonal antibodies to inoculation of healthy bighorn sheep with Pasteurella haemolytica from healthy Pasteurella haemolytica leukotoxin affinity purify the toxin from crude culture domestic sheep. J Wildl Dis 30: 137–145. supernatants. Microb Pathog 10: 411–417. 31. Alley MR, Ionas G, Clarke JK (1999) Chronic non-progressive pneumonia of 23. Besser TE, Highland M, Baker K, Anderson NJ, Ramsey JM (2012) Causes of sheep in New Zealand - a review of the role of Mycoplasma ovipneumoniae. pneumonia epizootics among bighorn sheep, western United States, 2008–2010. N Z Vet J 47: 155–160. Emerg Infect Dis 18: 406–414. 32. Desrosiers R (2011) Transmission of swine pathogens: different means, different 24. Petti CA (2007) Detection and identification of microorganisms by gene needs. Anim Health Res Rev 12: 1–13. amplification and sequencing. Clin Infect Dis 44: 1108–1114. 33. Dassanayake RP, Call DR, Sawant AA, Casavant NC, Weiser GC, et al. (2010) 25. Foreyt WJ, Jenkins EJ, Appleyard GD (2009) Transmission of lungworms Bibersteinia trehalosi inhibits the growth of Mannheimia haemolytica by a (Muellerius capillaris) from domestic goats to bighorn sheep on common proximity-dependent mechanism. Appl Environ Microbiol 76: 1008–1013. pasture. J Wildl Dis 45: 272–278. 34. Shanthalingam S, Goldy A, Bavananthasivam J, Subramaniam R, Batra SA, et 26. Foreyt WJ, Lagerquist JE (1996) Experimental contact of bighorn sheep (Ovis al. (2014) PCR assay detects Mannheimia haemolytica in culture-negative canadensis) with horses and cattle, and comparison of neutrophil sensitivity to pneumonic lung tissues of bighorn sheep (Ovis canadensis) from outbreaks in the Pasteurella haemolytica cytotoxins. J Wildl Dis 32: 594–602. Western USA, 2009–2010. J Wildl Dis 50: 1–10. 27. Onderka DK, Rawluk SA, Wishart WD (1988) Susceptibility of Rocky 35. Townsend KM, Frost AJ, Lee CW, Papadimitriou JM, Dawkins HJ (1998) Mountain bighorn sheep and domestic sheep to pneumonia induced by bighorn Development of PCR assays for species- and type-specific identification of and domestic livestock strains of Pasteurella haemolytica. Can J Vet Res 52: Pasteurella multocida isolates. J Clin Microbiol 36: 1096–1100. 439–444. 36. Fisher MA, Weiser GC, Hunter DL, Ward ACS (1999) Use of a polymerase 28. Dassanayake RP, Shanthalingam S, Herndon CN, Lawrence PK, Cassirer EF, chain reaction method to detect the leukotoxin gene IktA in biogroup and et al. (2009) Mannheimia haemolytica serotype A1 exhibits differential biovariant isolates of Pasteurella haemolytica and P. trehalosi. Am J Vet Res 60: pathogenicity in two related species, Ovis canadensis and Ovis aries.Vet 1402–1406. Microbiol 133: 366–371. 37. Rossi CR, Kiesel GK (1971) Microtiter tests for detecting antibody in bovine 29. Subramaniam R, Shanthalingam S, Bavananthasivam J, Kugadas A, Potter KA, serum to parainfluenza 3 virus, infectious bovine rhinotracheitis virus, and et al. (2011) A multivalent Mannheimia-Bibersteinia vaccine protects bighorn bovine virus diarrhea virus. Appl Microbiol 22: 32–36.

PLOS ONE | www.plosone.org 9 October 2014 | Volume 9 | Issue 10 | e110039 Fence Marking to Reduce Greater Sage-grouse (Centrocercus urophasianus) Collisions and Mortality near Farson, Wyoming – Summary of Interim Results

Tom Christiansen Sage-Grouse Program Coordinator Wyoming Game & Fish Dept. [email protected]

October 26, 2009

Background: Fence collisions have been anecdotally reported to cause sage-grouse injury and mortality but few efforts have been made to quantify this concern and publish results. Our study was initiated after two falconers independently reported numerous sage-grouse mortalities on range fences in Sublette and Sweetwater Counties in Wyoming. One of these falconers subsequently began marking such fences with aluminum beverage cans in a volunteer effort to reduce these mortalities. Our study seeks to quantify the level of sage-grouse fence strikes and mortalities and test whether marking devices can effectively reduce collisions in a cost effective manner that is not visually intrusive. Our interim results are summarized below.

Study Area: Approximately 12 miles northeast of Farson, WY adjacent to Little Sandy Creek on the Sweetwater-Sublette County Line. Greater sage-grouse use the area in large numbers year-round. Two large leks (100+ males) are located within 2 miles of the fence. The creek and associated riparian area serve as late brood-rearing habitat and the fence bisects winter habitat for, at least, several hundred grouse.

Study Dates: These results are for the April 15, 2005 – May 14, 2009 period. The study is ongoing.

Study Fence: 3-wire BLM range fence that is approximately 7.6 km (4.7 mi) long. The fence generally runs from southwest to northeast but does so in a zigzag manner.

Pretreatment data: From April 15, 2005 through Nov. 16, 2007 pretreatment data were collected during 9 surveys where 1-3 observers documented evidence of wildlife fence strikes and mortality while driving 2-3 mph immediately adjacent to the fence. These surveys resulted in evidence of 170 bird strikes/mortalities and 2 pronghorn mortalities. Confirmed greater sage- grouse accounted for 146 (86%) of the 170 strikes/mortalities documented. The other 22 observations were of waterfowl (n=4; 2%), raptors (n=5; 3%), passerines (n=2; 1%), shorebirds (n=1; <1%), and unknown birds (n=12; 7%).

Treatment/Control data: From Nov. 16, 2007 through May 14, 2009 approximately 1.54 miles (2.5 km) of the fence was marked in approximately .26 mi (416 m) sections with either FireFly™ bird diverters (donated by FireFly Diverters LLC for this study) or homemade markers patterned after those developed and used by the University of Oklahoma’s Sutton Avian Research Center http://www.suttoncenter.org/fence_marking.html to reduce lesser prairie-chicken fence mortality. The later were modified with reflective tape to increase visibility in snow cover conditions. The fence was unmarked (control) for 3.2 miles (5 km). Marked sections were bounded on either side by unmarked sections. Only the top wire was marked since very few collisions were documented on the lower two wires during pretreatment monitoring.

During the Nov. 16, 2007 through May 14, 2009 period, 6 surveys were conducted in the same manner as those conducted in the pretreatment phase of the study. Results suggest markers (all types combined) reduced bird fence collisions by 70% over unmarked sections. Seven (7) bird strikes, all sage-grouse, were documented in marked sections (4.55 strikes/mile) while 47 bird strikes (15.31 strikes/mile) were recorded in the unmarked sections. Thirty-six (36) of these were confirmed sage-grouse (11.73 strikes/mile). If only confirmed sage-grouse data are compared, the markers appear to have reduced grouse mortality by 61%.

On-going/Future Efforts: On May 14, 2009 the treatment sections were changed to control sections, the types of markers were changed, and more treatment sections were added. Half of the fence is now marked, alternating between sections of treatment and control. All of the markers are now based on the Sutton design. The FireFly I design has been eliminated from the study. Although it was highly effective (0 strikes), the price, maintenance and visibility of the device was not appropriate for wide scale use. With this information, the company, FireFly Diverters LLC, has applied their unique system of reflective/glow in the dark tape to the Sutton model and now markets a FireFly III Grouse Diverter (see attached) which we are currently testing along with other versions of the Sutton device to which different reflective tapes have been applied. Early indications suggest all of these markers will succeed and likely further decrease avian fence collisions beyond the 70% level suggested by our initial efforts reported above. We intend to attempt to publish our results after the next phase of the study is complete.

Interim Management Recommendations: Not every fence is a problem; those that tend to cause problems typically include one or more of the following characteristics: 1) constructed with steel t-posts, 2) are constructed near leks, 3) bisect winter concentration areas, and/or 4) border riparian areas. Areas of greater topographic relief (roughness) appear to have lower incidence of collisions apparently because the birds have to fly higher to avoid the ground. Avoid building fences within at least ¼ mile (preferably 0.6 mile) of leks. New and existing fences in these areas should be surveyed for evidence of grouse fence strikes before installing permanent fence markers. In brief, surveys can be conducted by walking, driving or riding slowly (2-3 mph) along the fence looking for carcasses or concentrations of feathers on the ground and individual feathers caught on top wire barbs. Evidence of fence strikes does not last long due to weather and scavengers. The discovery of fence strikes is therefore cause for mitigation. Where the decision has been made to mark a fence we currently recommend the top wire be marked with at least 2 markers of the Sutton design modified with high quality reflective tape. While we have yet to substantiate the need for reflective tape, untaped markers become essentially invisible with snow cover. Arrangements are being made to make markers available to ranchers at no cost. Contact the author for further information.

Acknowledgements: We thank the following groups and individuals for their contributions to this effort: Steve Chindgren, Utah Zoological Society, FireFly Diverters LLC, Little Sandy Grazing Association, BLM Rock Springs Field Office, and the Wyoming Game and Fish Dept.

Veterinary Microbiology 145 (2010) 354–359

Contents lists available at ScienceDirect

Veterinary Microbiology

journal homepage: www.elsevier.com/locate/vetmic

Short communication Mycoplasma ovipneumoniae can predispose bighorn sheep to fatal Mannheimia haemolytica pneumonia

Rohana P. Dassanayake a, Sudarvili Shanthalingam a, Caroline N. Herndon a, Renuka Subramaniam a, Paulraj K. Lawrence a, Jegarubee Bavananthasivam a, E. Frances Cassirer a,d, Gary J. Haldorson a,b, William J. Foreyt a, Fred R. Rurangirwa a,b, Donald P. Knowles a,c, Thomas E. Besser a,b, Subramaniam Srikumaran a,* a Department of Veterinary Microbiology and Pathology, Washington State University, Pullman, WA 99164-6610, USA b Washington Animal Disease Diagnostic Laboratory, Washington State University, Pullman, WA 99164-6610, USA c Animal Disease Research Unit, USDA Agricultural Research Service, Washington State University, Pullman, WA 99164-6630, USA d Idaho Department of Fish and Game, 3316 16th St., Lewiston, ID 83501, USA

ARTICLE INFO ABSTRACT

Article history: Mycoplasma ovipneumoniae has been isolated from the lungs of pneumonic bighorn sheep Received 25 November 2009 (BHS). However experimental reproduction of fatal pneumonia in BHS with M. Received in revised form 9 April 2010 ovipneumoniae was not successful. Therefore the speciﬁc role, if any, of M. ovipneumoniae Accepted 13 April 2010 in BHS pneumonia is unclear. The objective of this study was to determine whether M. ovipneumoniae alone causes fatal pneumonia in BHS, or predisposes them to infection by Keywords: Mannheimia haemolytica. We chose M. haemolytica for this study because of its isolation Mannheimia haemolytica from pneumonic BHS, and its consistent ability to cause fatal pneumonia under Mycoplasma ovipneumoniae experimental conditions. Since in vitro culture could attenuate virulence of M. Bighorn sheep ovipneumoniae, we used ceftiofur-treated lung homogenates from pneumonic BHS lambs Pneumonia or nasopharyngeal washings from M. ovipneumoniae-positive domestic sheep (DS) as the source of M. ovipneumoniae. Two adult BHS were inoculated intranasally with lung homogenates while two others received nasopharyngeal washings from DS. All BHS developed clinical signs of respiratory infection, but only one BHS died. The dead BHS had carried leukotoxin-positive M. haemolytica in the nasopharynx before the onset of this study. It is likely that M. ovipneumoniae colonization predisposed this BHS to fatal infection with the M. haemolytica already present in this animal. The remaining three BHS developed pneumonia and died 1–5 days following intranasal inoculation with M. haemolytica.On necropsy, lungs of all four BHS showed lesions characteristic of bronchopneumonia. M. haemolytica and M. ovipneumoniae were isolated from the lungs. These results suggest that M. ovipneumoniae alone may not cause fatal pneumonia in BHS, but can predispose them to fatal pneumonia due to M. haemolytica infection. ß 2010 Elsevier B.V. All rights reserved.

1. Introduction died of pneumonia (Miller, 2001). Experimental infection with this organism has confirmed its ability to cause fatal Mannheimia (Pasteurella) haemolytica has been isolated bronchopneumonia in BHS (Foreyt et al., 1994; Dassanayake from the lungs of bighorn sheep (BHS, Ovis canadensis)that et al., 2009). M. haemolytica has long been identified as a commensal bacterium of the upper respiratory tract of ruminants (Dunbar et al., 1990; Weiser et al., 2009). Active * Corresponding author at: Department of Microbiology and Pathology, viral infection and stress factors have been identified as Washington State University, 402 Bustad Hall, PO Box 647040, Pullman, WA 99164-7040, USA. Tel.: +1 509 335 4572; fax: +1 509 335 8529. predisposing factors for pneumonia caused by M. haemo- E-mail address: [email protected] (S. Srikumaran). lytica in cattle (Rehmtulla and Thompson, 1981). However,

0378-1135/$ – see front matter ß 2010 Elsevier B.V. All rights reserved. doi:10.1016/j.vetmic.2010.04.011 R.P. Dassanayake et al. / Veterinary Microbiology 145 (2010) 354–359 355 the role of predisposing factors in M. haemolytica-caused The animals were inoculated as detailed in Table 1. The pneumonia in BHS has not been investigated. inoculum was administered intranasally using an atomi- Mycoplasma ovipneumoniae and Mycoplasma arginini zer. M. ovipneumoniae inoculum for Groups I and II were have been isolated from the upper respiratory tract of obtained from two sources: (1) lung homogenates from young and adult domestic sheep (DS, Ovis aries; Brogden pneumonic BHS (three lambs and one adult; Besser et al., et al., 1988). M. ovipneumoniae (but not M. arginini) causes 2008); (2) nasopharyngeal washings from DS (four ewes) atypical pneumonia especially in DS lambs; however, that were M. ovipneumoniae-positive by culture and PCR experimental reproduction of pneumonia with M. ovip- assay. These preparations were filtered using a 0.22 mm neumoniae in DS lambs has been inconsistent (Buddle et al., filter (to remove any bacteria), and the filtrates were 1984; Ruffin, 2001). Unlike in DS, only non-pathogenic M. submitted to WADDL to detect respiratory viruses. The arginini has been isolated from healthy BHS (Woolf et al., unfiltered nasopharyngeal washings and lung homoge- 1970). In our recent study (Besser et al., 2008), M. nates were treated with the antibiotic ceftiofur (64 mg/ml, ovipneumoniae was detected in the bronchoalveolar lavage 37 8C for 1 h), expected to reduce or eliminate M. fluid from pneumonic BHS lambs by culture and 16S rRNA haemolytica and other ceftiofur-susceptible bacteria, but species-specific PCR. M. ovipneumoniae-specific 16S not M. ovipneumoniae. BHS were inoculated either with the sequences and antibodies were detected in lung tissues filtrate, ceftiofur-treated M. ovipneumoniae-positive lung and serum respectively, of bronchopneumonic BHS, but homogenates, nasopharyngeal washings or M. haemolytica not from BHS dying of other causes. However, experi- as detailed in Table 1. mental inoculation of M. ovipneumoniae failed to cause The animals in each group were observed daily and fatal pneumonia in BHS lambs (Besser et al., 2008). scored for the signs of pneumonia including anorexia, Therefore, the objective of this study was to elucidate lethargy, cough, dyspnoea and nasal discharge. The animals the role of M. ovipneumoniae in BHS pneumonia. that died before the end of the observation period were necropsied immediately, and appropriate tissues were 2. Materials and methods collected for bacteriological, viral and histopathological examinations. The animals in the control Group (III) were 2.1. Bacterial strains and growth conditions euthanized 3 weeks post-challenge, necropsied and tissue samples collected. The lungs were carefully examined for M. haemolytica serotype A1 strain 89010807N (Murphy pneumonic lesions. The degree of involvement of right and et al., 1995) and serotype A2 strain WSU-1 (Foreyt et al., left lungs was noted as percent pneumonic scores. Pleuritis 1994) were grown in BHI agar supplemented with 5% was noted as present or absent. Bacterial and viral isolations sheep blood and BHI broth as previously described were attempted using routine methods at WADDL. M. (Dassanayake et al., 2009). haemolytica isolates were serotyped by agglutination test 2.2. Bighorn sheep challenge studies using anti-serotype A1 and A2 specific sera.

Nasal and pharyngeal swabs and blood samples were 2.3. PCR detection of M. ovipneumoniae and M. haemolytica collected from all the animals before bacterial inoculation, leukotoxin and were submitted to Washington Animal Disease Diagnostic Laboratory (WADDL) at Washington State M. ovipneumoniae-specific 16S rRNA PCR was per- University for detection of M. ovipneumoniae, M. haemo- formed as previously described (McAuliffe et al., 2003; lytica or other Pasteurella sp, and any known respiratory Besser et al., 2008). Leukotoxin A gene (lktA)ofM. viruses. Serology was performed to detect antibodies haemolytica and Bibersteinia trehalosi was amplified by 0 0 against respiratory viruses, M. ovipneumoniae and M. PCR using lktAF(5-TCAAGAAGAGCTGGCAAC-3 ) and lktAR 0 0 haemolytica leukotoxin (LktA). (5 -AGTGAGGGCAACTAAACC-3 ) primers in a final volume

Table 1 Inoculation timeline of M. ovipneumoniae and M. haemolytica to BHS.

Group BHS Day Inoculuma

I OR26 0 Filtrate (0.22 mm) from M. ovipneumoniae-positive pneumonic BHS (three lambs and one adult) lung homogenates in PBS (10 ml) R124 28 M. ovipneumoniae-positive, pneumonic BHS (three lambs and one adult) lung homogenates in PBS, unﬁltered but treated with ceftiofur (10 ml) 42 Same treatment as on day 28 70 M. haemolytica serotype A1 (1 106 CFU in 5 ml RPMI)

II Y45 0 Filtrate (0.22 mm) from nasal washings (PBS) from four M. ovipneumoniae-positive DS (10 ml) R123 28 Nasal washings (PBS) from four M. ovipneumoniae-positive DS, unﬁltered, but treated with ceftiofur (10 ml) 42 Same treatment as on day 28 70 M. haemolytica serotype A2 (1 106 CFU in 5 ml RPMI)

III Y30 0 RPMI (5 ml) Y39 a Administered intranasally using an atomizer. 356 R.P. Dassanayake et al. / Veterinary Microbiology 145 (2010) 354–359 of 50 ml with GoTaq1 PCR SuperMix (Promega Inc., pathogenic M. arginini (Table 2). As expected, none of the Madison, WI) under standard conditions. animals had demonstrable M. ovipneumoniae antibody titers (Table 3). All the animals were culture-positive for B. 2.4. Serology trehalosi but were negative for lktA by PCR (Table 2). Several animals had antibody titers to RSV (R123, R124, Anti-LktA-neutralizing antibodies from BHS serum Y45) and PI-3 (OR26, Y45, R123, R124) (Table 3). However, samples were detected by MTT dye reduction cytotoxicity all were culture-negative for respiratory viruses (Table 2). assay as previously described (Gentry and Srikumaran, All the animals except two (R123, R124) were negative for 1991). Indirect hemagglutination assay for M. ovipneumo- M. haemolytica (Table 2). Of the two that were positive, one niae was performed by WADDL using M. ovipneumoniae had lktA-positive M. haemolytica (R124) while the other antigen-sensitized and non-sensitized erythrocytes with one had lktA-negative M. haemolytica (R123; Table 2). All serially diluted serum samples as described previously the animals had insigniﬁcant levels of anti-LktA anti- (Besser et al., 2008). Serum neutralization assays were bodies (Table 3). We could not perform serological assays performed by WADDL to determine antibody titers for for the control animals’ sera due to the poor quality of the respiratory viruses including BRSV, BVDV, BHV-1, and PI-3. sera.

2.5. Histopathology 3.2. M. ovipneumoniae fails to induce fatal pneumonia in BHS

Histopathology was performed by WADDL. Lung Lung homogenates from pneumonic BHS lambs and lesions were described by noting the character of the nasopharyngeal washings from M. ovipneumoniae-posi- inflammatory infiltrate, degree of necrosis, presence or tive DS ewes were used as the source of M. ovipneumo- absence of abscessation and bacterial colonies (Besser niae for inoculation of four BHS (Table 1). When animals et al., 2008; Dassanayake et al., 2009). were inoculated with the filtrates, none of the BHS developed any signs of respiratory viral infection, during 3. Results the 4-week observation period, demonstrating the 3.1. The microbial profile of the nasopharynx of the BHS absence of any BHS respiratory viral pathogens in the inoculum. These preparations were negative for any All the animals were culture- and PCR-negative for M. viruses by culture as well. None of the animals ovipneumoniae, although all BHS were positive for non- developed any signs of pneumonia following intranasal

Table 2 Bacterial and viral pathogens isolated from or detected in nasopharynx and lungs of bighorn sheep before and after M. ovipneumoniae and M. haemolytica challenges.

Groups animal M.h M.ovi M.arg B.t BRSV PI-3 BVDV BHV-1

Pre Post Pre Post Pre Post Pre Post Pre Post Pre Post Pre Post Pre Post

I OR26 +a,c ++++b +b +e R124 +a +a ++++b +b

II R123 +b +a,d ++++b +b +e Y45 +a,d ++++b +b

III Y30 ++ +b +b Y39 ++ +b +b

M.h – M. haemolytica; M.ovi – M. ovipneumoniae; M.arg – M. arginini; B.t – B. trehalosi; BRSV – bovine respiratory syncytial virus; BVDV – bovine viral diarrhea virus; BHV-1 – bovine herpes virus-1; PI-3 – parainﬂuenza-3; Pre – before the challenge; Post – at necropsy. a lktA-positive. b lktA-negative. c M. haemolytica serotype A1. d M. haemolytica serotype A2. e Detected by ELISA.

Table 3 Serum antibody titers for Pasteurellaceae leukotoxin A, M. ovipneumoniae and respiratory viruses before and after M. ovipneumoniae exposures and M. haemolytica challenges.

Groups Animal LktA M.ovi BRSV PI-3

Pre Post Pre Post Pre Post Pre Post

I OR26 10 10 0 >2560 0 0 128 128 R124 80 500 0 1280 32 128 32 64

II R123 160 10 0 >2560 4 0 128 128 Y45 40 100 0 >2560 0 8 64 32

LktA – Pasteurellaceae leukotoxin A (M. haemolytica and B. trehalosi). M.ovi – M. ovipneumoniae. BRSV – bovine respiratory syncytial virus. PI-3 – parainfluenza-3. Pre – before the challenge. Post – at necropsy. R.P. Dassanayake et al. / Veterinary Microbiology 145 (2010) 354–359 357 challenge with ceftiofur-treated BHS pneumonic lung 3.3. Inoculation of M. haemolytica causes pneumonia and homogenates or DS nasopharyngeal washings although death of M. ovipneumoniae-inoculated BHS all four BHS became culture- and PCR-positive for M. ovipneumoniae 2 weeks post-challenge. Therefore, the M. haemolytica serotype A1 and A2 were intranasally animals were re-challenged with the same inoculum inoculated into the remaining BHS in Group I and two BHS in (Table 1). During the next few days, all the BHS Group II, respectively, on day 70 as shown in Table 1.Both developed signs of M. ovipneumoniae infection including R123 and Y45 died 1 day post-inoculation with M. lethargy, reduced appetite, intermittent cough, nasal haemolytica. The gross- and histopathology of the lungs of discharge, and head shaking. One animal from Group I both these animals were similar. The right and left lungs (R124) died of pneumonia on day 47. However, it should showed 30–50% consolidation (Fig. 1A). There was some be noted that this animal had been consistently positive fibrin deposition on the pleural surface of the left cranial for lktA-positive M. haemolytica since day 1 of the lobe, bronchi and pericardium suggesting that the death of experiment. Anti-LktA, anti-M. ovipneumoniae and BRSV the animals was due to acute broncho/pleuropneumonia titers gradually increased (Table 3). However, BRSV was characteristic of M. haemolytica infection. The lungs had not isolated by culture, from any of the samples regional filling of alveoli with neutrophils, fibrin, and collected. Post-mortem examination of R124 revealed erythrocytes (Fig. 1C). All the samples collected from the acute bronchopneumonia in the right lung with animals, including the middle ears, were positive for M. severe consolidation over 50% of the ventral portion of haemolytica serotype A2, B. trehalosi, Pasteurella multocida all lobes. Histologically, the lungs had severe filling of (toxA-negative) and M. ovipneumoniae. All the isolates of M. alveoli and many bronchioles with neutrophils and haemolytica, but not B. trehalosi, were positive for lktA by PCR variable amounts of fibrin and edema residue. All the (Table 2). LktA-neutralizing titers of R123 changed only samples taken from the lesional tissue were heavily slightly over time except at the time of death when the titers positive for M. haemolytica, B. trehalosi and M. ovipneu- became low (Table 3). Lkt neutralization titers of Y45 moniae. All the isolates of M. haemolytica but not B. remained unchanged. M. ovipneumoniae titers of both R123 trehalosi were PCR-positive for lktA. R124 also showed and Y45 increased from undetectable titers prior to neutralizing titers for BRSV and PI-3, but not for any experimental challenge to high titers (>1:2560) after the other viruses (Table 3). second M. ovipneumoniae challenge until the time of death.

Fig. 1. Lung lesions of BHS inoculated with M. ovipneumoniae followed by M. haemolytica. BHS were inoculated with two doses of M. ovipneumoniae (2 weeks apart) followed by one dose of M. haemolytica 4 weeks after the second M. ovipneumoniae inoculation. (A) Gross pathology of the lungs of BHS (R123) inoculated with M. ovipneumoniae followed by M. haemolytica A2. (B) Gross pathology of the lungs of a control BHS (Y39) administered sterile RPMI. (C) Histopathology of lungs of R123. (D) Histopathology of lungs of Y39. (C, D: hematoxylin and eosin staining, original magniﬁcation = 100). 358 R.P. Dassanayake et al. / Veterinary Microbiology 145 (2010) 354–359

Except for low neutralizing titers (1:4) for BRSV on two the serotype A2 is more virulent than serotype A1 occasions and stable PI-3 titers (1:128), R123 did not show (unpublished observation). The death of one BHS in Group neutralization titers against other respiratory viruses tested I after inoculation with M. ovipneumoniae, but before (Table 3). Y45 had a BRSV positive titer of 1:8 at the time of inoculation with M. haemolytica, was very likely due to the death and fairly consistent PI-3 positive titers (1:32–64) presence of lktA-positive M. haemolytica in the nasophar- during the study period. Although nasal swabs and lung ynx of this BHS right from the onset of this study. The tissues were positive for BRSV antigen in R123 by ELISA, we pneumonic lesions of the lungs were indicative of M. could not isolate any viruses in cell cultures (Table 2). haemolytica-caused pneumonia. The death of all three BHS The animal OR26 died 5 days following M. haemolytica following intranasal inoculation with M. haemolytica serotype A1 inoculation. The gross- and histopathologic suggests that M. ovipneumoniae acted as a primary lesions in this animal were similar to those of R123 and pathogen, reducing the resistance of BHS to the M. Y45. As expected, M. haemolytica A1, M. ovipneumoniae, B. haemolytica challenges predisposing these animals to trehalosi (lktA-negative), and P. multocida (toxA-negative) relatively rapid development of fatal pneumonia due to were isolated from numerous samples. This animal M. haemolytica infection. It is likely that M. ovipneumoniae- showed very low LktA-neutralizing antibody titer during induced loss of mucociliary defense of the respiratory tract the course of the study. M. ovipneumoniae titers increased (Niang et al., 1998) facilitated rapid proliferation and from undetectable titers prior to challenge, to high titers descent of M. haemolytica into the lower respiratory tract (>1:2560) following second M. ovipneumoniae inoculation. and induction of fatal bronchopneumonia. However, in a Anti-PI-3 titer remained unchanged at 1:128, but no previous study by us intra-tracheal inoculation of M. antibodies against other respiratory viruses were detected haemolytica (1 109 CFU of a serotype A1 strain) resulted throughout the study period. OR26 also showed positive in the death of all four BHS within 48 h (Dassanayake et al., BRSV results by ELISA on lung tissues. No viruses were 2009). Furthermore, in a recent experimental challenge isolated in cell cultures. As expected, the lungs of the two study by us, intranasal inoculation of a strain of M. BHS in the control group (Y30 and Y39) showed no haemolytica (1 106 CFU of serotype A2) caused the death evidence of pneumonia (Fig. 1B and D). of three out of four BHS within 48 h (unpublished observation), which questions the necessity for a predis- 4. Discussion posing agent such as M. ovipneumoniae to render the mucociliary apparatus dysfunctional in order for M. M. ovipneumoniae has been isolated from wild BHS haemolytica to cause fatal bronchopneumonia, at least in lambs and adults in naturally occurring pneumonia in that experimental challenge model. previous studies (Besser et al., 2008). However, M. Antibodies specific for RSV and PI-3 have been detected ovipneumoniae isolated from these animals failed to induce in several BHS herds (Elliott et al., 1994; Spraker et al., sustained clinical illness in two BHS lambs given multiple 1986). Although RSV was not isolated by culture from any intranasal inoculations despite successful oropharyngeal of the BHS in this study, lung tissue from two of them colonization. Virulence attenuation of M. ovipneumoniae (R123 and OR26) were positive for RSV by ELISA. The RSV occurs during laboratory culture (Gilmour et al., 1979; titers of two animals (R124 and Y45) increased (from 1:32 Jones et al., 1982) which could be responsible for the to 1:128, and from undetectable to 1:8, respectively) failure to reproduce clinical disease. Therefore we rea- during the experiment. Therefore, we cannot rule out the soned that the use of lung homogenates from pneumonic possibility that RSV also was involved in the induction of BHS or nasopharyngeal washings from M. ovipneumoniae- pneumonia in these animals. Studies are currently under- positive DS should avoid this possibility of attenuation and way to elucidate the role of RSV and PI-3 in the etiology of better assess the etiologic role of this agent. pneumonia in BHS. Although all BHS inoculated with unfiltered, but In summary, our findings indicate that M. ovipneumoniae ceftiofur-treated, lung homogenates and nasopharyngeal by itself did not cause fatal pneumonia in BHS used in this washings developed clinical signs of M. ovipneumoniae study. However, it did predispose them to fatal pneumonia infection, only one died prior to the time of intranasal M. caused by M. haemolytica. We propose that low virulent haemolytica challenge. Therefore, based on this study, we strains, but not high virulent strains, of M. haemolytica may propose that M. ovipneumoniae alone is not adequate for require a predisposing agent such as M. ovipneumoniae for the induction of fatal bronchopneumonia in BHS, which is the induction of fatal bronchopneumonia in BHS. in agreement with the findings of our previous M. ovipneumoniae challenge studies with BHS lambs (Besser Acknowledgments et al., 2008). Our finding that three out of three BHS developed bronchopneumonia and died 1–5 days post- This research was supported by funds from the Wild inoculation with M. haemolytica clearly indicates that M. Sheep Foundation, and its Eastern, Idaho, Oregon, and haemolytica is the pathogen that causes fatal pneumonia in Washington Chapters. BHS challenged under our experimental protocol. The difference in the interval between the inoculation and References death of the BHS in Group II (1 day) and Group I (5 days) is very likely due to the difference in virulence between M. Besser, T.E., Cassirer, E.F., Potter, K.A., VanderSchalie, J., Fischer, A., Knowles, D.P., Herndon, D.R., Rurangirwa, F.R., Weiser, G.C., Sriku- haemolytica serotype A2 and serotype A1 that was used to maran, S., 2008. Association of Mycoplasma ovipneumoniae infection inoculate the BHS. Our earlier studies have indicated that with population-limiting respiratory disease in free-ranging Rocky R.P. Dassanayake et al. / Veterinary Microbiology 145 (2010) 354–359 359

Mountain bighorn sheep (Ovis canadensis canadensis). J. Clin. Micro- McAuliffe, L., Hatchell, F.M., Ayling, R.D., King, A.I., Nicholas, R.A., 2003. biol. 46, 423–430. Detection of Mycoplasma ovipneumoniae in Pasteurella-vaccinated Brogden, K.A., Rose, D., Cutlip, R.C., Lehmkuhl, H.D., Tully, J.G., 1988. sheep flocks with respiratory disease in England. Vet. Rec. 153, Isolation and identification of Mycoplasmas from the nasal cavity 687–688. of sheep. Am. J. Vet. Res. 49, 1669–1672. Miller, M.W., 2001. Pasteurellosis. In: Williams, E.S., Barker, I.K. (Eds.), Buddle, B.M., Herceg, M., Davies, D.H., 1984. Experimental infection of Infectious Diseases of Wild Mammals. Iowa State University Press, sheep with Mycoplasma ovipneumoniae and Pasteurella haemolytica. Ames, IA, pp. 330–339. Vet. Microbiol. 9, 543–548. Murphy, G.L., Whitworth, L.C., Clinkenbeard, K.D., Clinkenbeard, P.A., Dassanayake, R.P., Shanthalingam, S., Herndon, C.N., Lawrence, P.K., 1995. Haemolytic activity of the Pasteurella haemolytica leukotoxin. Frances Cassirer, E., Potter, K.A., Foreyt, W.J., Clinkenbeard, K.D., Infect. Immun. 63, 3209–3212. Srikumaran, S., 2009. Mannheimia haemolytica serotype A1 exhibits Niang,M.,Rosenbusch,R.F.,Andrews,J.J.,Lopez-Virella,J.,Kaeberle, differential pathogenicity in two related species, Ovis canadensis and M.L., 1998. Occurrence of autoantibodies to cilia in lambs with a Ovis aries. Vet. Microbiol. 133, 366–371. ‘coughing syndrome’. Vet. Immunol. Immunopathol. 64, 191– Dunbar, M.R., Ward, A.C.S., Power, G., 1990. Isolation of Pasteurella 205. haemolytica from tonsilar biopsies of rocky mountain bighorn sheep. Rehmtulla, A.J., Thompson, R.G., 1981. A review of the lesions in shipping J. Wildl. Dis. 26, 210–213. fever of cattle. Can. Vet. J. 22, 1–8. Elliott, L.F., Boyce, W.M., Clark, R.K., Jessup, D.A., 1994. Geographic ana- Ruffin, D.C., 2001. Mycoplasma infections in small ruminants. Update lysis of pathogen exposure in bighorn sheep (Ovis canadensis). J. Wildl. Small Rumin. Med. 17, 315–332. Dis. 30, 315–318. Spraker, T.R., Collins, J.K., Adrian, W.J., Olterman, J.H., 1986. Isolation and Foreyt, W.J., Snipes, K.P., Kasten, R.W., 1994. Fatal pneumonia following serologic evidence of a respiratory syncytial virus in bighorn sheep inoculation of healthy bighorn sheep with Pasteurella haemolytica from Colorado. J. Wildl. Dis. 22, 416–418. from healthy domestic sheep. J. Wildl. Dis. 30, 137–145. Weiser, G.C., Miller, D.S., Drew, M.L., Rhyan, J.C., Ward, A.C., 2009. Varia- Gilmour, J.S., Jones, G.E., Rae, A.G., 1979. Experimental studies of chronic tion in Pasteurella (Bibersteinia) and Mannheimia spp. following trans- pneumonia of sheep. Comp. Immunol. Microbiol. Infect. Dis. 1, 285–293. port and antibiotic treatment in free-ranging and captive Rocky Gentry, M.J., Srikumaran, S., 1991. Neutralizing monoclonal antibodies to Mountain bighorn sheep (Ovis canadensis canadensis). J. Zoo Wildl. Pasteurella haemolytica leukotoxin affinity-purify the toxin from Med. 40, 117–125. crude culture supernatants. Microb. Pathog. 10, 411–417. Woolf, A., Kradel, D.C., Bubash, G.R., 1970. Mycoplasma isolates from Jones, G.E., Gilmour, J.S., Rae, A.G., 1982. The effects of different strains of pneumonia in captive Rocky Mountain bighorn sheep. J. Wildl. Dis. Mycoplasma ovipneumoniae on specific pathogen-free and conven- 6, 169–170. tionally-reared lambs. J. Comp. Pathol. 92, 267–272. Linking conservation actions to demography: grass height explains variation in greater sage-grouse nest survival Author(s): Kevin E. Doherty, David E. Naugle, Jason D. Tack, Brett L. Walker, Jon M. Graham and Jeffrey L. Beck Source: Wildlife Biology, 20(6):320-325. 2014. Published By: Nordic Board for Wildlife Research DOI: http://dx.doi.org/10.2981/wlb.00004 URL: http://www.bioone.org/doi/full/10.2981/wlb.00004

BioOne (www.bioone.org) is a nonprofit, online aggregation of core research in the biological, ecological, and environmental sciences. BioOne provides a sustainable online platform for over 170 journals and books published by nonprofit societies, associations, museums, institutions, and presses. Your use of this PDF, the BioOne Web site, and all posted and associated content indicates your acceptance of BioOne’s Terms of Use, available at www.bioone.org/page/terms_of_use. Usage of BioOne content is strictly limited to personal, educational, and non-commercial use. Commercial inquiries or rights and permissions requests should be directed to the individual publisher as copyright holder.

BioOne sees sustainable scholarly publishing as an inherently collaborative enterprise connecting authors, nonprofit publishers, academic institutions, research libraries, and research funders in the common goal of maximizing access to critical research. Wildlife Biology 20: 320–325, 2014 doi: 10.2981/wlb.00004 © 2014 Th e Authors. Th is is an Open Access article Subject Editor: Hans Pedersen. Accepted 15 July 2014

Linking conservation actions to demography: grass height explains variation in greater sage-grouse nest survival

Kevin E. Doherty , David E. Naugle , Jason D. Tack , Brett L. Walker , Jon M. Graham and Jeffrey L. Beck

K. E. Doherty ([email protected]), US Fish and Wildlife Service, Lakewood, CO 80228, USA. – D. E. Naugle and B. L. Walker, Wildlife Biology Program, Univ. of Montana, Missoula, MT 59812, USA. DEN also at: USDA Sage Grouse Initiative, Missoula, MT 59812, USA. – J. D. Tack, Fish, Wildlife and Conservation Biology, Colorado State Univ., Fort Collins, CO 80523, USA. – J. M. Graham, Mathematical Sciences, Univ. of Montana, Missoula, MT 59812, USA. – J. L. Beck, Dept of Ecosystem Science and Management, Univ. of Wyoming, Laramie, WY 82071, USA

Conservation success often hinges on our ability to link demography with implementable management actions to infl uence population growth ( l). Nest success is demonstrated to be important to l in greater sage-grouse Centrocercus urophasianus , an imperiled species in the North American sagebrush-steppe. Enhancing this vital rate through management represents an opportunity to increase bird numbers inside population strongholds. We identifi ed management for grass height as an action that can improve nest success in an analysis of sage-grouse nests (n ϭ 529) from a long-term study (2003 – 2007) in the Powder River Basin, southeast Montana and northeast Wyoming, USA. Average grass height by study area and year varied (11.4 – 29.2 cm) but its positive eff ects on nest survival were consistent among study years and study areas that diff ered in absolute rates of nest success. We tested the predictive ability of models by grouping output from log-link analyses (2004– 2006) into two bins with nest success probabilities Ͻ 0.45 and Ͼ 0.55, and validated the relationship with additional data from 2003 and 2007. Nests with probabilities Ͼ 0.55 were 1.64 (2004– 2006) to 3.11 (2007) times more likely to hatch than those Ͻ 0.45, except in 2003 when an early wet spring resulted in universally high grass height at nest sites (29.2 cm) and high predicted nest success (64%). Th e high predictive power of grass height illustrates its utility as a management tool to increase nest success within priority landscapes. Relationships suggest that managing grass height during drought may benefi t sage-grouse populations.

Achieving desired conservation outcomes requires planning 2013), cultivation for row crop production (Foley et al. at scales that match the biological needs of wide-ranging 2011) and others (Knick et al. 2013). Th e current sage- focal species (Nicholson et al. 2013). Inherent in conserva- grouse distribution encompasses 76 million hectares, yet tion success is our ability to link demography to implement- population densities are highly clumped across their range able management actions that infl uence population growth (Doherty et al. 2010a). In eff orts to focus conservation ( l; Mills 2012). Implementing locally benefi cial conserva- actions, the US Fish and Wildlife Service identifi ed “ Prior- tion practices inside intact ecosystems maximally benefi ts ity Areas for Conservation” (PACs; US Fish and Wildlife species for which landscape context matters (Wilson et al. Service 2013) by consulting US states to incorporate the 2007, Schultz 2010). Advances in spatial ecology make best available population and habitat data into site delinea- landscape prioritization more feasible (Millspaugh and tion. Research has focused on reducing threats to popula- Th ompson 2009), but identifying intact targets is only a tions within PACs (Baruch-Mordo et al. 2013, Copeland fi rst step (Knight et al. 2008). Still missing in most plans is et al. 2013), yet management actions that aim to bolster a demographic link between a conservation action and its populations within priority areas will be critical for a species ability to infl uence demographic traits infl uencing l with declining distribution. (Wisdom et al. 2000, Caswell 2001). Th e purpose of our paper is to increase conservation Greater sage-grouse Centrocercus urophasianus (hereafter eff ectiveness by exploring linkages between demography and sage-grouse) are native only to western arid and semiarid implementable actions to benefi t populations. Nest success sagebrush Artemisia spp. landscapes (Schroeder et al. 1999), is demonstrably important to λ, and enhancing this vital rate and extirpated from half their range (Schroeder et al. 2004), through management may benefi t populations (Taylor et al. the species is a candidate for listing under the federal Endan- 2012). Variation in nest survival may in part be explained gered Species Act (US Fish and Wildlife Service 2010). Major by grass height (DeLong et al. 1995), a feature infl uenced fragmenting threats include energy development (Naugle by grazing (Rickard et al. 1975), and a preeminent landuse 2012), wildfi re (Bukowski and Baker 2013, Murphy et al. in sagebrush systems. We used generalized linear models to

320 estimate the infl uence of vegetation and nest characteristics Table 1. List of variables used in model selection explaining sage- on sage-grouse nest survival within a landscape context grouse nest survival, Powder River Basin, Montana and Wyoming, USA, 2004 – 2006. (Dinsmore et al. 2002, Rotella et al. 2004). Findings will help guide the US Dept of Agriculture ’ s Sage Grouse Candidate variables Description Initiative (SGI) in implementing rotational grazing sys- Local scale habitat tems designed to increase hiding cover for nesting grouse variables inside PACs on 847 000 ha of privately-owned rangelands Shrub canopy cover using the line-intercept method along ( Ͻ www.sagegrouseinitiative.com/our-work/proactive- two 30 m perpendicular transects Ͼ centered at nest or random conservation/ under Grazing Systems). locations (Canfi eld 1941) Shrub density all shrubs Ͼ 15 cm within 1 m of transect line were counted, total Material and methods /120 m2 Quadratic shrub canopy shrub canopy cover ϩ (shrub canopy cover cover ϫ shrub canopy cover) Study area Nearest shrub height height of nearest shrub to Daubenmire quadrant location. We sampled sage-grouse in two distinct study areas in There were 10 Daubenmire quads Johnson and Sheridan Counties in northeast Wyoming on each of the two 30 m transects (southern region), and Bighorn, Rosebud, and Powder for a total of 20 Daubenmire quads. They were spaced 3 m apart and River Counties in southeast Montana (northern region), started at 0 m USA. Northern study areas were dominated by sagebrush, Visual obstruction height density readings at 0, 1, 3 and with conifer encroachment in more rugged landscapes and at nest 5 m from nest or available shrub in overall larger grassland areas. Southern study areas were also each cardinal direction (Robel et al. dominated by sagebrush, but had no conifers and exhibited 1970) Nearest grass height average of the vegetative droop smaller grassland areas. Shrub – steppe habitats were domi- height for the nearest grass from the nated by Wyoming big sagebrush A . tridentata wyomingensis 20 Daubenmire quadrants with an understory of native and non-native grasses. Land Tallest grass height average of the vegetative droop height use in both study areas was dominated by cattle ranching and for the tallest grass from the 20 land tenure was a mix of federal, state and private. Doherty Daubenmire quadrants Average grass height (nearest grass height ϩ tallest grass et al. (2008) provides detailed descriptions of study areas. height)/2 Because of the diff erences in landscape context, study area Nest characteristic variables was included as a categorical blocking variable. Hen age yearling or adult (Walker 2008) Nest age (nest age in days ϩ nest age in days2 ) Capture, radio-tracking and predictor variables (Walker 2008) Snowstormmarker grouped 7 nests that were abandoned following major snow event in May We captured sage-grouse in rocket-nets and walk-in traps 2005 (Giesen et al. 1982) and by spotlighting (Wakkinen et al. Abiotic site variables 1992) March – April and July – October in 2003 – 2007. Study area north or south Powder River Basin We aged females, fi tted them with necklace style VHF radio Year year of observation collars, and relocated sage-grouse to monitor nests by ground based radio-tracking throughout the breeding season. We We assigned predictor variables into 1 of 3 model categories: used established protocols (Connelly et al. 2003) to quantify 1) habitat, 2) nest characteristic, and 3) site variables local vegetative features known to infl uence habitat selec- Յ (Table 1). We fi rst examined univariate selection for study tion within 15 m of nests (Connelly et al. 2000, Hagen area and the 8 habitat variables, and removed variables if et al. 2007; Table 1). Doherty et al. (2010b) provides a full 95% confi dence intervals overlapped zero. If predictor description of nest monitoring. variables were highly correlated (r Ն |0.7|), only the variable with the greatest biological merit was included in the Statistical analyses and model selection model (Chatfi eld 1995). When variables were moderately correlated (i.e. |0.3| Յ r Ͻ |0.7|), we checked for stability We used generalized linear models with a binomial likeli- and consistency of parameter estimates as predictor variables hood and a log-link to estimate the infl uence nest age, study were added. area and grass height on the daily survival rates (DSR) of We allowed each variable that made it past variable screen- nests (Dinsmore et al. 2002, Rotella et al. 2004). We derived ing to compete with all other combinations of variables to nest survival rates by multiplying DSR together over the 28 identify the most parsimonious model for habitat and study day predicted incubation time for sage-grouse. We divided area. If variables made it past screening we determined if samples into nests used to build the model (n ϭ 383 nests their addition improved model fi t via Akaike’ s information in 2004 – 2006) and those used to test model stability and criterion with a small sample size correction factor (AICc ; predictive capability (n ϭ 146 in 2003 and 2007). Burnham and Anderson 2002). After obtaining the best We followed an iterative system for model selection. habitat model using AICc values, we then tested if inclusion We fi rst included a variable that controlled for the known of nest characteristic variables (Table 1) and an additional eff ect of a spring snow storm in 2005 on DSR in all abiotic site variable (year eff ect) documented in Walker (2008) variable screenings and fi nal model selection (Walker 2008). were still important predictor variables when included with

321 habitat covariates. We followed the exact variable screening Table 2. Comparisons of grass height, study area and nest age and AIC methods described above to test if these variables variables to identify the AICc best model explaining sage- grouse nest survival, Powder River Basin, Montana and Wyoming, improved model fi t. 2004 – 2006 a . We tested the predictive strength of the fi nal habitat w model by grouping predicted nest survival probability from Model K AIC c Δ AICc i log-link analyses (2004– 2006) into two bins with probabili- Average grass height ϩ 6 834.418 0.000 0.974 ties of nest survival, Ͻ 0.45 and Ͼ 0.55, generically repre- study area ϩ nest age ϩ senting low and high nest survival probabilities, respectively. Average grass height 4 841.634 7.216 0.026 study area We then compared observed nest success from independent Average grass height 3 866.099 31.681 0.000 data sets (2003 and 2007) between low and high valida- Study area 3 927.881 93.463 0.000 tion bins, and calculated the ratio of observed nest success between the high and low bins. We reasoned that observed a all models included a categorical blocking variable which controlled for nests abandoned in a heavy spring storm in 2005 nest success should be higher in the top validation bin if the (Walker 2008). fi nal model predicted nest success well across years, demonstrated by a ratio of observed nest success Ͼ 1 between bins. We further evaluated the predictive model by comparing Estimates of average grass height tracked annual trends predicted nest success from our top model to observed nest in nest success (Fig. 1; northern region 2003 – 2007, beta success by year. Average grass height around nesting sage- estimate ϭ 0.036, p ϭ 0.023; southern region 2004 – 2007, grouse in a given year (Table 1) was the only continuous pre- beta estimate ϭ 0.079, p ϭ 0.001). Bootstrap analyses dictor variable included in our top model, thus we evaluated showed the positive relationship between average grass how well one variable served as an indicator of nest success. height and nest success (Fig. 2). Our fi nal model including Statistical analyses were performed in program SAS ver. 8.0 grass height and study area demonstrated large eff ect sizes Ͻ Ͼ (SAS Inst. http://v8doc.sascom/sashtml/ ). (Fig. 2). Nests with probabilities Ͼ 0.55 were 1.64 (2004 – We performed a bootstrap analysis to quantify precision 2006) to 3.11 (2007) times more likely to hatch than and the eff ect size of grass height on nest survival, using beta those Ͻ 0.45 (Table 3), except in 2003 when average grass coeffi cients from the best approximating model (Burnham height (29.2 cm) and apparent nest success reached their and Anderson 2002). We used the logistic exposure highest recorded levels (68%, Fig. 1). equation (Rotella et al. 2004) to generate the predicted probability of successfully hatching a nest for each bootstrap dataset (n ϭ 5000) by systematically varying grass height Discussion within the observed range of variation. We computed at each percentage the probability of successfully hatching a nest for High predictive power of grass height illustrates its utility each of 5000 simulations. We ordered these probabilities and as a management tool to benefi t sage-grouse populations. used a rankit adjustment (Chambers et al. 1983) to estimate Findings show grass height is a strong predictor of nest sur- upper and lower 95% confi dence intervals. vival inside intact landscapes, and increasing hiding cover can increase nest success, a demographic rate that explains a Results

Nearest, tallest and average grass height were the only variables with signifi cant coeffi cients when tested univari- ately. Nearest, tallest and average grass height were all positively associated with nest success, but were highly correlated and could not be included in the same model. Average and nearest grass height had virtually identical univariate coeffi cient estimates, however average grass height showed less variation around the estimate (average grass height β ϭ 0.034, SE ϭ 0.013, 95% CI ϭ 0.008 – 0.060 vs nearest grass height β ϭ 0.039, SE ϭ 0.019, 95% CI ϭ 0.001 – 0.076). Further, average grass height outcompeted nearest and tallest grass measures based on AICc values, thus it was retained for additional modeling. Th e addition of study area increased model fi t, while hen age and year eff ects were removed from the model because they explained no additional variation in nest survival when included with habitat variables and confi dence intervals around eff ect estimates overlapped zero. Th e inclusion of Figure 1. Apparent and predicted annual nest survival by year for ϭ sage-grouse in the Powder River Basin, Montana and Wyoming, nest age increased model fi t ( wi 0.974; Table 2). Our fi nal US, 2003 – 2007. Th e fi nal model included the eff ects of grass model included average grass height, nest age, study area and height, nest age, study area, and 2005 spring snow storm. Grass the variable that controlled for the known eff ect of a spring height measurements were averaged across nests within years to snow storm in 2005 on DSR. make annual predictions.

322 and subspecies (Attwater ’ s prairie-chickens Tympanuchus cupido attwateri, Lehmann 1941; plains sharp-tailed grouse T . phasianellus jamesi , Hillman and Jackson 1973; greater prairie-chicken T. cupido pinnatus , McKee et al. 1998). Findings suggest that maintaining grass height during drought may provide the greatest benefi ts to populations. Average grass height and predicted nest success in this study is within the range of published literature (Schroeder et al. 1999, Connelly et al. 2000). Benefi ts may be negligible in years resembling 2003 when spring rains provided abundant grass and the correspondingly highest predicted nest success for the northern study area. High variation in pooled grass height by study area and years (11.4 – 29.2 cm) also suggested that modifying grazing practices to maintain nesting cover could improve a habitat feature that otherwise limits l . We have identifi ed a strong corollary of nest success in the Powder River Basin (PRB). If this relationship is validated in new study areas across diff erent parts of the sage-grouse Figure 2. Relationship between average grass height and sage-grouse range, and if the relationship between grass height and nest nest survival, Powder River Basin, Montana and Wyoming, USA, success can be calibrated within these new areas, grass height 2004– 2006. Estimates of nest survival (95% confi dence intervals may be useful as a surrogate to monitor nest success. [CIs]) in both study areas are based on 5000 bootstrap samples. Findings emphasize the importance of an indirect eff ect of grazing on sage-grouse nest success. Results have third of variation in l (Taylor et al. 2012). Moreover, grass broad implications because livestock grazing is the most height is a reliable management tool because it explained widespread land use in the world (Holechek et al. 2003), variation (Fig. 2) despite variability in absolute rates of nest aff ecting 70% of land area in the western US (Fleischner success between study areas. Positive eff ects of grass height 1994). Eff ects of grazing on sage-grouse habitat may be should be evaluated on other important demographic rates wide-ranging depending upon current and historic timing including adult female and chick survival (Taylor et al. 2012) and intensity of grazing, soil conditions, precipitation, plant to see if benefi ts extend beyond what is now known. communities and habitat features under consideration (Beck Managing grass height in large and intact landscapes with and Mitchell 2000, Connelly et al. 2000, 2004, Crawford grazing is a tool that may benefi t populations in eastern Mon- et al. 2004). However, adjustments to duration and timing tana and northeast Wyoming. Positive eff ects of grass height of grazing also may increase residual cover with the added in our study areas explained variation in nest success between benefi t of increasing long-term rangeland health on which years with large and precise eff ect sizes. Diff ering intercepts birds depend. For example, reducing the short-term stock- prohibit extrapolating of results to novel sagebrush systems ing rate of sheep increased black grouse Tetrao tetrix num- because absolute eff ects likely depend upon regional condi- bers by 6% annually in Europe by increasing residual cover tions that infl uence grass and shrub composition. South and (Calladine et al. 2002). Replicated experiments to document west of our study areas where sagebrush rather than grass sage-grouse response to diff erent grazing systems are needed provides most hiding cover, grass height had only a weak to help guide land managers to practices that are benefi cial eff ect on nest success, and nest fates were dominated by year to sage-grouse and economically viable to producers and site eff ects (Holloran et al. 2005). Grass height is posi- (Krausman et al. 2011). tively related to nest success for other prairie grouse species Habitat management within a PAC-based conservation strategy may benefi t populations, but sage-grouse are a wildland species, and grass height is of little consequence Table 3. Validation of grass height as a predictor for sage-grouse nest if sagebrush systems continue to be replaced by anthropo- success, Powder River Basin, Montana and Wyoming, 2003– 2007. genic land uses (Knick et al. 2013). Viability of ranching as We tested the AICc best model (Table 2) by calculating the predicted a predominant land use may in part determine the future of probability of hatching for each nest by applying grass height and region coeffi cients from log-link analysis (2004– 2006) to observed sage-grouse conservation in the West. Th e SGI has increased grass heights at nests. We used the predicted probability (n is by four-fold their implementation of rotational grazing number of nests in each category) of hatching to group nests with systems by resting for up to 17 months the pastures used Ͻ Ͼ probabilities of 0.45 and 0.55 and then compared apparent by nesting sage-grouse grouse within 488 000 ha inside nest success ratios. We also validated the relationship with independent data sets (2003 and 2007). Nest age was excluded because Montana’ s PACs (J. Siddoway pers. comm.). Our fi ndings we exponentiated daily survival rate for nests across the 28-day suggest that these types of grazing systems that promote nest incubation period. success may provide one mechanism to off set population Observed nest success losses by increasing bird numbers. Predicted probability 2003 2004 – 2006 2007 p Ͻ 0.45 (low) 0.714 (n ϭ 7) 0.486 (n ϭ 70) 0.200 (n ϭ 5) Ͼ ϭ ϭ ϭ Acknowledgements – We thank landowners in the PRB that granted p 0.55 (high) 0.667 (n 30) 0.796 (n 184) 0.623 (n 52) access to private lands. J. Hess, K. Keith, D. Nonne and F. Sutti Ratio (high/low) 0.93 1.64 3.11 provided outstanding leadership and assistance in the fi eld. Major

323 funding for this work came from Bureau of Land Management Doherty, K. E. et al. 2010b. Greater sage-grouse nesting habitat: (BLM) offi ces in Montana and Wyoming. Additional support came the importance of managing at multiple scales. – J. Wildl. from the BLM (Washington DC), US Dept of Energy, Montana Manage. 74: 1544 – 1553. Dept of Fish, Wildlife and Parks, Wyoming Game and Fish Dept, Fleischner, T. L. 1994. Ecological costs of livestock grazing in National Fish and Wildlife Foundation, National Science Founda- western North America. – Conserv. Biol. 8: 629 – 644. tion (EPS– CORE program), Montana Cooperative Wildlife Foley, J. A. N. et al. 2011. Solutions for a cultivated planet. Research Unit, Petroleum Association of Wyoming, Western Gas – Nature 478: 337 – 342. Resources Inc., Wolf Creek Charitable Foundation, Bighorn Giesen, K. M. et al. 1982. Methods for trapping sage-grouse in Environmental Consulting, Anheuser-Busch Companies, Inc. and Colorado. – Wildl. Soc. Bull. 10: 224 – 231. the Univ. of Montana. Th e views of the lead author are his own and Hagen, C. A. et al. 2007. A meta-analysis of greater sage-grouse do not necessarily represent the USFWS. Centrocercus urophasianus nesting and brood-rearing habitats. – Wildl. Biol. 13: 42 – 50. Hillman, C. N. and Jackson, W. W. 1973. Th e sharp-tailed grouse in South Dakota. – Pierre, South Dakota, USA, South Dakota References Game, Fish, and Parks Tech. Bull. 3. Holechek, J. et al. 2003. Range management: principles and Baruch-Mordo, S. et al. 2013. Saving sage-grouse from the trees: practices. – Prentice Hall Publishing, Upper Saddle River, NJ, a proactive solution to reducing a key threat to a candidate USA. species. – Biol. Conserv. 167: 233 – 241. Holloran, M. J. et al. 2005. Greater sage-grouse nesting habitat Beck, J. L. and Mitchell, D. L. 2000. Infl uences of livestock selection and success in Wyoming. – J. Wildl. Manage. 69: grazing on sage grouse habitat. – Wildl. Soc. Bull. 28: 638 – 649. 993 – 1002. Knick, S. T. et al. 2013. Modeling ecological minimum require- Bukowski, B. E. and Baker, W. L. 2013. Historical fi re regimes, ments or distribution of greater sage-grouse leks: implications reconstructed from land-survey data, led to complexity for population connectivity across their western range, USA. and fl uctuation in sagebrush landscapes. – Ecol. Appl. 23: – Ecol. Evol. 3: 1539 – 1551. 546 – 564. Knight, A. T. et al. 2008. Knowing but not doing: selecting prior- Burnham, K. P. and Anderson, D. R. 2002. Model selection ity conservation areas and the research-implementation gap. and inference: a practical information-theoretic approach. – Conserv. Biol. 22: 610 – 617. – Springer. Krausman, P. R. et al. 2011. An assessment of rangeland activities Calladine, J. et al. 2002. Eff ects of reduced grazing on population on wildlife populations and habitats. – In: Briske, D. D. (ed.), density and breeding success of black grouse in northern Conservation benefi ts of rangeland practices: assessment, rec- England. – J. Appl. Ecol. 39: 772 – 780. ommendations and knowledge gaps. US Dept of Agriculture, Canfi eld, R. H. 1941. Application of the line interception method Natural Resources Conservation Service, Washington, D.C., in sampling range vegetation. – J. For. 39: 388 – 394. USA, pp. 253 – 290. Caswell, H. 2001. Matrix population models: construction, analy- Lehmann, V. W. 1941. Attwater’s prairie chicken: its life history sis and interpretation. – Sinauer. and management. – US Fish and Wildlife Service, Chambers, J. M. et al. 1983. Graphical methods for data analysis. North American Fauna 57, US Government Printing Offi ce, – Duxbury Press, Boston, MA, USA. Washington D.C., USA. Chatfi eld, C. 1995. Model uncertainty, data mining and statistical McKee, G. et al. 1998. Predicting greater prairie-chicken nest inference. – J. R. Stat. Soc. 158: 419 – 466. success from vegetation and landscape characteristics. – J. Connelly, J. W. et al. 2000. Guidelines to manage sage Wildl. Manage. 62: 314 – 321. grouse populations and their habitats. – Wildl. Soc. Bull. 28: Mills, L. S. 2012. Conservation of wildlife populations. – Wiley. 967 – 985. Millspaugh, J. J. and Th ompson, III, F. R. 2009. Models for plan- Connelly, J. W. et al. 2003. Monitoring of greater sage-grouse ning wildlife conservation in large landscapes. – Academic habitats and populations. – College of Nat. Resour. Exp. Stn Press. Bull. 80, Univ. of Idaho, Moscow, ID, USA. Murphy, T. et al. 2013. Trial by fi re: improving our ability to reduce Connelly, J. W. et al. 2004. Conservation assessment of greater wildfi re impacts to sage-grouse and sagebrush ecosystems sage-grouse and sagebrush habitats. – W. Ass. of Fish and through accelerated partner collaboration. – Rangelands 35: Wildlife Agencies. Cheyenne, WY, USA. 2 – 10. Copeland, H. E. et al. 2013. Measuring the eff ectiveness of Naugle, D. E. 2012. Energy development and wildlife conservation conservation: a novel framework to quantify the benefi ts of in western North America. – Island Press. sage-grouse conservation policy and easements in Wyoming. Nicholson, E. et al. 2013. Testing focal species approach to making – PLoS ONE 8:e67261. conservation decisions for species persistence. – Divers. Crawford, J. A. et al. 2004. Ecology and management of Distrib. 19: 530 – 540. sage-grouse and sage-grouse habitat. – J. Range Manage. 57: Rickard, W. H. et al. 1975. Impact of cattle grazing on three 2 – 19. perennial grasses in south– central Washington. – Soc. Range DeLong, A. K. et al. 1995. Relationships between vegetational Manage. 28: 108 – 112. structure and predation of artifi cial sage grouse nests. – J. Robel, R. J. et al. 1970. Relationships between visual obstruction Wildl. Manage. 59: 88 – 92. measurements and weight of grassland vegetation. – J. Range Dinsmore, S. J. et al. 2002. Advanced techniques for modeling Manage. 23: 295 – 297. avian nest survival. – Ecology 83: 3476 – 3488. Rotella, J. J. et al. 2004. Extending methods for modeling hetero- Doherty, K. E. et al. 2008. Greater sage-grouse winter habitat geneity in nest-survival data using generalized mixed models. selection and energy development. – J. Wildl. Manage. 72: – Stud. Avian Biol. 34: 34 – 44. 187 – 195. Schroeder, M. A. et al. 1999. Sage grouse Centrocercus urophasianus . Doherty, K. E. et al. 2010a. Mapping breeding densities of greater – In: Poole, A. and Gill, F. (eds), Th e birds of North America. sage-grouse: a tool for range-wide conservation planning. BLM 610. Acad. Nat. Sci., Philadelphia, PA, USA. Completion Report Interior Agency Agreement #L10PG00911. Schroeder, M. A. et al. 2004. Distribution of sage-grouse in North – US Bureau of Land Management. America. – Condor 106: 363 – 376.

324 Schultz, C. 2010. Challenges in connecting cumulative eff ects Walker, B. L. 2008. Greater sage-grouse response to coal-bed analysis to eff ective wildlife conservation planning. – Bio- natural gas development and West Nile virus in the Powder science 60: 545 – 551. River Basin, Montana and Wyoming, USA. – PhD thesis, Taylor, R. L. et al. 2012. Managing multiple vital rates to maximize Univ. of Montana, Missoula, MT, USA. greater sage-grouse population growth. – J. Wildl. Manage. 76: Wakkinen, W. L. et al. 1992. An improved spotlighting technique 336 – 347. for capturing sage grouse. – Wildl. Soc. Bull. 20: US Fish and Wildlife Service 2010. Endangered and threatened 425 – 426. wildlife and plants; 12-month fi ndings for petitions to list the Wilson, K. A. et al. 2007. Conserving biodiversity effi ciently: what greater sage-grouse ( Centrocercus urophasianus) as threatened or to do, where and when. – PLoS Biol. 5:e223. endangered. – Federal Register 75: 13909 – 14014. Wisdom, M. J. et al. 2000. Life stage simulations analysis: estimat- US Fish and Wildlife Service 2013. Sage-grouse Conservation ing vital- rate eff ects on population growth for conservation. Objectives Team completion report. – US Dept of the Interior, – Ecology 81: 628 – 641. Washington, D.C., USA.

325 NEVADA DIVISION OF WILDLIFE’S

BIGHORN SHEEP MANAGEMENT PLAN

OCTOBER 2001

STATE OF NEVADA Kenny C. Guinn, Governor

NEVADA DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES R. Michael Turnipseed, P.E., Director

DIVISION OF WILDLIFE Terry R. Crawforth, Administrator

GAME BUREAU Gregg Tanner, Chief

BOARD OF WILDLIFE COMMISSIONERS

Bill Bradley ...... Reno Tommy A. Ford ...... Las Vegas Chris MacKenzie ...... Carson City David McNinch ...... Reno John T. Moran Jr...... Las Vegas Eric J. Olsen ...... Fallon Bradley D. Quilici ...... Lovelock Mike Riordan ...... Jiggs Jelindo A. Tiberti II ...... Las Vegas

The Nevada Division of Wildlife receives funds from Federal Aid in Fish and Wildlife Restoration Acts. Federal and State law state that there shall be no difference in the treatment of individuals because of race, color, creed, religion, national origin, sex or disability. Anyone receiving alleged discriminatory treatment in any Division program, activity or facility should report it to either:

Administrator U.S. Fish & Wildlife Service Nevada Division of Wildlife Department of the Interior 1100 Valley Road 18th & C Streets Reno, Nevada 89512 Washington, D.C. 20240

THE VALUE OF BIGHORN SHEEP

The sight of bighorn sheep leaping nimbly across rugged slopes elicits emotions that impress and inspire viewers. From primitive inhabitants to civilized peoples, a recurring theme in records kept on bighorn sheep is the strong sentiment elicited by this animal.

One of the most difficult tasks in wildlife management is to place value on wildlife. Economics alone do not even come close to describing the values of wildlife to the people of the State of Nevada. Other values, which are nearly impossible to quantify, must be considered when evaluating what an animal is worth. Activities such as wildlife viewing and photography are examples of the use of the bighorn sheep resource that are not well documented but no doubt account for thousands of recreational days annually. Even people that have no expectations of seeing bighorn sheep in the wild want to know they are present and will be into the future.

The interest and enthusiasm expressed in bighorn sheep through conservation organizations such as Nevada Bighorns Unlimited, the Fraternity of the Desert Bighorn and the Foundation for North American Wild Sheep attests to the tremendous respect and admiration that sportsmen and the general public have for the State’s bighorn sheep. Through political and financial support, construction of water developments, and other habitat improvement projects, these bighorn-support groups have benefited many wildlife species. The Nevada Division of Wildlife recognizes these immeasurable values of bighorn sheep and has the responsibility to ensure that they are managed for the enjoyment and use by both present and future generations.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan

TABLE OF CONTENTS

ACKNOWLEDGEMENTS ...... 1

EXECUTIVE SUMMARY ...... 2

WILDLIFE COMMISSION POLICIES ...... 3

HISTORY ...... 4

HABITAT MANAGEMENT ...... 6 POLICY STATEMENTS ...... 6 Habitat Delineation ...... 6 Habitat Acquisition ...... 8 Special Habitat Designation ...... 9 Movement Corridor Protection ...... 9 Water Development ...... 10 Grazing Input ...... 11 Fire ...... 12 Roads, Off Road Vehicle Use ...... 13 Mining ...... 14

POPULATION MANAGEMENT...... 14 POLICY STATEMENT ...... 15 Bighorn Sheep Capture and Transplanting ...... 15 Reintroductions ...... 15 Augmentations ...... 16 Capture ...... 17 Population Monitoring ...... 17 Subspecies Delineation ...... 18 Disease ...... 21 Predator Management ...... 22

HARVEST MANAGEMENT ...... 23 POLICY STATEMENT ...... 23 Quota Criteria and Tag Requirements ...... 23 Season Structure ...... 24

LAW ENFORCEMENT ...... 25

ECONOMICS ...... 26 Hunter Expenditures ...... 26 Division Revenue ...... 26 Division Expenditures ...... 27 Trapping and Transplanting Costs ...... 28

CONSERVATION EDUCATION ...... 28

Nevada Division of Wildlife’s Bighorn Sheep Management Plan i

POLICY STATEMENT ...... 28 Educating Nevada’s Youth ...... 29 Educating the General Public ...... 29 Educating Hunters ...... 30

PLAN EVALUATION ...... 30

LITERATURE CITED ...... 31

APPENDIX A - LAWS AND REGULATIONS PERTINENT TO BIGHORN SHEEP MANAGEMENT ...... A-1 Appropriate Federal Laws, Policies and Agreements Pertinent to Bighorn Sheep Management in Nevada ...... A-1 Nevada Revised Statutes Pertinent to Bighorn Sheep Management ...... A-3 Nevada Administrative Code Pertinent To Bighorn Sheep Management ...... A-4 Commission Policies Pertinent To Bighorn Sheep Management ...... A-4 Department of Agriculture Regulations on Lost Or Trespass Domestic Sheep And Goats ...... A-5 43 CFR (BLM) ...... A-5

LIST OF FIGURES AND TABLES

Figure 1. Bighorn Sheep Distribution In Nevada In 1860, 1960, And 2001...... 5

Figure 2. Occupied And Unoccupied Potential Bighorn Sheep Habitat In Nevada As Of 2001...... 7

Figure 3. Bighorn Sheep Subspecies Delineation Boundaries For Future Transplants Of Desert, California, And Rocky Mountain Bighorn Sheep...... 20

Figure 4. Average Age Of Harvested Desert And California Bighorn Sheep Rams In Nevada From 1990 – 2000...... 23

Figure 5. Nevada Bighorn Sheep Tag Sales Revenue And Its Potential Federal Aid Match From 1981 – 2000...... 27

Table 1. Annual Division Bighorn Sheep Management Expenditures For FY2000...... 28

Nevada Division of Wildlife’s Bighorn Sheep Management Plan ii

ACKNOWLEDGEMENTS

This plan was developed in a collaborative process by the bighorn sheep management team. The team was formed from sportsmen and bighorn sheep enthusiasts selected by the Nevada Board of Wildlife Commissioners and Nevada Division of Wildlife (NDOW) biologists selected by the agency. Team members included:

• Tommy Ford, Wildlife Commissioner • Clint Bentley, representing the Fraternity of the Desert Bighorn • Ed Pribyl, representing the Fraternity of the Desert Bighorn • Jack Robb representing the Nevada Bighorns Unlimited – Reno • Michael Hornbarger, sportsman and hunting guide • Mike Cox, NDOW big game staff biologist • Pat Cummings, NDOW, southern Nevada bighorn sheep biologist • Mike Dobel, NDOW, western Nevada bighorn sheep biologist • Ken Gray, NDOW eastern Nevada bighorn sheep biologist • Chris Hampson, NDOW, western Nevada bighorn sheep biologist • Craig Stevenson, NDOW southern Nevada water development/habitat biologist • Tony Wasley, NDOW eastern Nevada bighorn sheep biologist

The photographs on the plan’s cover were taken by Craig Stevenson. Tony Wasley developed the maps within the plan. Special thanks go to the many NDOW biologists and staff involved in the review of the initial draft plan who provided valuable comments to improve the plan and manuscript. Appreciation is also extended to other agencies and organizations and to the general public who took the time to review the document and provide valuable comments. Funding for this project was from tag and license revenues and financial assistance provided by the Federal Aid in Wildlife Restoration program.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 1

EXECUTIVE SUMMARY

The bighorn sheep management plan is a guiding document for the Nevada Board of Wildlife Commissioners (Commission) and the Nevada Division of Wildlife (Division) efforts in the conservation and management of bighorn sheep populations and their habitat. The plan includes Commission policies that are overall goals that guide the Division. The majority of the plan is a framework that outlines the actions and strategies that Division employees will follow in planning and conducting bighorn sheep management and conservation.

Bighorn sheep have been shown to be one of the more numerous and most widely distributed large ungulates throughout historic Nevada. But by the late 19th century, several factors caused the decline of Nevada’s bighorn populations.

The quality and quantity of suitable habitat will ultimately determine the number of bighorn sheep that the State of Nevada will support. Continued collaboration with land management agencies, government entities, private landowners, and sportsmen is imperative when protecting and enhancing bighorn sheep habitat. All occupied and potential bighorn sheep habitat will be delineated and limiting factors will be identified for each. Information gathered through this activity will be the basis for protection and enhancement activities. The purchase of conservation easements, property and associated grazing privileges, conversions of Animal Unit Months (AUM’s) from domestic sheep to cattle or water rights, will be done to protect or enhance important bighorn sheep habitat. The Division will actively pursue a program to provide water for bighorn sheep as a means to increase population levels and distribution in water deficient habitats.

From a population management perspective, the underlying goal of this plan is to restore and maintain bighorn herds at optimal population levels based on a multitude of demographic and ecological parameters. Bighorn sheep will be reintroduced into suitable but unoccupied habitats. Bighorn herds below optimal levels will be augmented to bolster populations. Comprehensive planning, coordination, and follow up will be conducted in the capture and release of bighorn sheep. All future releases of bighorn subspecies will be within their identified delineation area, with the largest portion of Nevada being delineated for desert bighorn sheep. Bighorn populations will be adequately monitored to assess trends and detect significant demographic changes and/or home range/movement changes. The Division will investigate and address all disease related problems in a timely fashion.

Bighorn sheep hunting is a legitimate and desirable use of the bighorn resource. The Division will develop quota recommendations with the expectation of obtaining a statewide average age of 6 years for harvested rams. Since bighorn sheep are a highly regarded and sought after big-game species, the Division will continue to protect bighorn sheep populations through education and appropriate enforcement of pertinent wildlife laws and regulations

The desert bighorn sheep is Nevada’s state animal; yet, the general public has very little knowledge about bighorn sheep. Therefore, the Division is challenged to increase public awareness and appreciation for bighorn sheep and their habitats in order to facilitate decisions favorable to their long-term well being.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 2

BIGHORN SHEEP MANAGEMENT PLAN’S WILDLIFE COMMISSION POLICIES

• The Division will work to protect all bighorn sheep habitat that is currently in good condition.

• In order to expand numbers and distribution of bighorn sheep, limiting factors, such as lack of water and poor forage conditions, need to be addressed. Management actions to enhance these deficiencies will be aggressively pursued.

• The Division will increase bighorn populations of all subspecies statewide to a level where all habitats are occupied and each herd is self-sustaining.

• Bighorn sheep hunting is a legitimate and desirable use of the bighorn resource.

• The Division will increase public awareness and appreciation for bighorn sheep and their habitats in order to facilitate decisions favorable to their long-term well being.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 3

HISTORY

The earliest archaeological record of bighorns in Nevada are remains from Pintwater Cave, northwest of Las Vegas, dated at 28,000 years before the present (Buck et al. 1997). Archeological investigations based on bones and petroglyphs have shown bighorns to be one of the more numerous and most widely distributed large ungulates throughout historic Nevada (Harrington 1933; Jennings 1957; Gruhn 1976). John C. Fremont wrote on January 11, 1834 during his travels through Nevada’s Lake Range, “On our road down, the next day, we saw herds of mountain sheep.....” (Smith 1909). But by the beginning of the late 19th century, commercial and illegal hunting, competition with livestock, and the effects of livestock diseases all appear to have caused the decline of Nevada’s bighorn populations.

The earliest effort at bighorn management in Nevada appeared as an 1861 law closing sheep harvest between January 1st and July 1st. Other laws were enacted, varying the hunting season dates, but in 1901, the legislature closed bighorn hunting and it continued to be closed until 1952. As more laws and attention were brought on bighorn sheep management, indications were that illegal, subsistence-based hunting in the state began to decline during the 1940's (Jonez 1957).

The Nevada Division of Wildlife (Division), formerly known as the Department of Fish and Game, began bighorn sheep management in the late 1940’s. In 1936, the U.S. Fish and Wildlife Service created the Desert National Wildlife Range for the protection of several desert bighorn sheep herds in southern Nevada. However, despite conservation efforts, Nevada’s bighorn numbers continued to decline until the middle part of the century.

Figure 1 depicts the estimated bighorn sheep distribution in 1860, 1960, and 2001. The 1860 distribution is based on historic accounts and archeological evidence of bighorn sheep and biological judgment of areas that had adequate bighorn habitat. Using this distribution and a conservative density value for bighorn sheep, it was calculated by the bighorn sheep management team that Nevada’s bighorn population in 1860 exceeded 30,000. But by 1960, it was estimated to have declined to a level between 2,000 and 3,000 bighorn. By the 1980’s, bighorn sheep management intensified and restored animals to many of their historic ranges through habitat improvement and transplant programs. The 2001 statewide estimate was 6,500 bighorn sheep in 74 mountain ranges.

The continued existence of bighorn sheep in Nevada will rely on a mixture of science, sentiment and proper management decisions. This plan is a part of an effort to continue a course of action to ensure that this species will endure.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 4

Figure 1. Bighorn Sheep Distribution in Nevada in 1860, 1960, and 2001.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 5

HABITAT MANAGEMENT

The quality and quantity of suitable habitat will ultimately determine the number of bighorn sheep that the State of Nevada will support. Since most of the bighorn sheep habitat is managed by the Bureau of Land Management, the U.S. Forest Service, the U.S. Fish and Wildlife Service, the National Park Service, military installations, Indian Tribes, and private landowners, it is imperative that the Division always strive for cooperation and collaboration with these entities. State, County, and Local Governments also make decisions that have the potential to impact bighorn habitat. It is important that the Division provides input for all decisions affecting bighorn sheep habitat since the loss of habitat, or reduction in the habitat quality, will reduce the number of sheep that an area can support. The Division supports land use and habitat designations (i.e., wilderness, ACEC’s, etc) as long as wildlife management activities that are used to manage bighorn populations and their habitat are allowed to continue.

Conservation organizations, such as Nevada Bighorns Unlimited (NBU), the Fraternity of the Desert Bighorn Sheep (Fraternity), The Foundation for North America Wild Sheep (FNAWS) and others, play an extremely important role in habitat protection and enhancement. The Division will continue to foster excellent working relationships with these groups in order to maximize habitat protection and habitat enhancement efforts.

POLICY STATEMENTS

• The Division will work to protect all bighorn sheep habitat that is currently in good condition.

Habitat Delineation

Management Action: All occupied and potential bighorn sheep habitat will be delineated and limiting factors will be identified for each. Information gathered through this activity will then be used as a major tool to identify protection and enhancement activities.

Strategy: Biologists will identify all occupied and potential bighorn habitat within their area of responsibility (Figure 2). Factors that limit an area’s ability to provide optimal habitat for bighorn sheep will be identified.

Strategy: The habitat information that depicts current distribution at optimal and less than optimal levels, potential habitat, and limiting factors will be incorporated into the Geographic Information System (GIS) database. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 6

Figure 2. Occupied and unoccupied potential bighorn sheep habitat in Nevada as of 2001. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 7

Strategy: The maps and information will be provided to the land management agencies for incorporation into land use planning documents, and will be used to help facilitate habitat protection and enhancement activities.

Habitat Acquisition

Thousands of acres of bighorn sheep habitat have been lost in recent years to urbanization in southern Nevada. Thousands of acres of bighorn sheep habitat have been traded from public ownership through land exchanges. None of these land exchanges have acquired additional bighorn habitat to compensate for this loss. In addition, human activity such as highways and reservoirs has fragmented huge expanses of historic bighorn sheep habitat.

Domestic sheep operations pose the largest obstacle to the further expansion of bighorn sheep populations in the State of Nevada due to continued concerns over disease transmission. For example, out of 12 mountain ranges identified in southern Nevada that contain suitable bighorn sheep habitat, but are currently unoccupied, 8 have domestic sheep associated with them. In the past, willing sellers have approached both the Division and conservation organizations with a desire to sell their domestic sheep grazing operations. However, no process has been established to evaluate these offers and therefore, opportunities to secure wildlife habitat for the long-term have been lost.

As directed by Commission Policy (P-62), it is imperative that the Division does everything possible to prevent the loss of habitat. In situations when the loss of habitat is inevitable, replacement or compensatory mitigation is a viable option. Habitat acquisition is one avenue that the Division will pursue to compensate for the loss of habitat. Habitat acquisition, through willing sellers, is also consistent with the Division’s strategic plan

Management Action: The purchase of conservation easements, property and associated grazing privileges, conversions of Animal Unit Months (AUM’s) from domestic sheep to cattle, or acquisition of water rights, will be pursued in order to protect or enhance important sheep habitat.

Strategy: Any AUM conversion, acquisition of private land, grazing privileges or easements will only be accomplished through a willing seller. The purchase of conservation easements and AUM conversions would be preferred over the purchase of property.

Strategy: The Division will develop guidelines and criteria in order to evaluate potential habitat acquisitions in a timely fashion.

Strategy: Potential funding sources and partners will be identified so that when opportunities do arise, they can be acted on in a timely fashion. Funding sources could include mitigation from urban sprawl (such as Southern Nevada Public Lands Management Act), conservation organization partnerships, heritage account, bond revenues and federal aid. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 8

Strategy: The Commission’s mitigation policy (P-62), will be used to direct Division activities associated with the potential loss of habitat and the associated mitigation alternatives including habitat acquisition.

Special Habitat Designation

The objective of special habitat designations would be to ensure that large blocks of existing high quality public habitat would be managed and protected, with an emphasis on bighorn sheep for the long-term. An example of an area that could be designated a special bighorn habitat area is the Arrow Canyon, Meadow Valley, Delamar, South Hiko and S. Pahroc Ranges. This is a large, continuous block of sheep habitat that is threatened by development. Maintaining not only the bighorn habitat, but also the migration corridors between these ranges, is essential to the long-term future of bighorn sheep in these areas.

Management Action: The Division will work with land management agencies and conservation organizations to designate critical bighorn sheep habitats with the goal of providing long-term protection to these areas.

Strategy: Through the use of GIS, evaluate potential threats to bighorn sheep habitat, and other biological and political/social issues to determine and prioritize areas suited for designation.

Strategy: Coordinate with land management agencies to determine what designation options would be best suited to protect large, continuous blocks of sheep habitat.

Strategy: Form partnerships with conservation organizations and land management agencies and actively pursue designations in top priority areas.

Movement Corridor Protection

Bighorn sheep movement can be categorized into two general types. The first is daily movement where bighorns move between watering areas, foraging areas and resting areas. These movements normally do not exceed more than a few miles in a day. The second is seasonal movements where bighorn move to other parts of a range or to other mountain ranges in response to changes in vegetation quality, water availability or weather. These movements can include several thousand feet in elevation and a 20- or 30-mile movement to another range. The impediment of either of these movements can be devastating to a bighorn sheep population.

Management Action: The Division will work to maintain bighorn sheep movement corridors.

Strategy: The GIS will be used to delineate important movement corridors. This information will be provided to land management agencies and the Department of Transportation.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 9

Strategy: The Division will follow Commission Policy 62 (mitigation policy) when reviewing and commenting on movement impediments.

Strategy: The Division’s first priority will be to minimize fences, roads, ditches and other movement impediments in bighorn sheep habitat. The Division will work with land management agencies and private landowners to consider alternatives to impediments, or to relocate the activity to an area with less impact to bighorn sheep.

Strategy: The Division realizes that some fences will be constructed within bighorn habitat. In these instances, the following fence specification should be used: A 39-inch high, three-strand fence with a smooth bottom wire. The wire spacing from ground up would be 20", 15" and 4" (BLM Handbook).

Strategy: Any roads built in bighorn sheep habitat or movement corridors must be constructed in such a way as to allow continued bighorn movement. Some strategies could include under or over passes, ramps cut into steep side slopes, alternatives to continuous guard rails and/or fence specifications along roads that allow sheep movement.

Water Development

Nevada is the driest state in the nation. The southern half of the state is extremely dry, especially in habitats capable of supporting bighorn sheep. To compound this problem, many of the natural water sources have been degraded or eliminated from a wildlife standpoint by human development, livestock use or have been eliminated by the pumping of the ground water for either agriculture or urban development.

The Division has evaluated dozens of Nevada’s mountain ranges as to their suitability to support bighorn sheep. Many ranges have the topography and the vegetative resources to support bighorn sheep but lack adequate, available water. The protection and development of water is one of the management activities that can be used to expand both bighorn sheep distribution and population size.

Through December 2000, approximately 240 water developments had been constructed within bighorn sheep habitat. Not only are bighorn sheep dependent on these units, but a whole host of other wildlife species regularly use these waters. It is imperative that these existing developments be regularly maintained and kept in working order. In some years these developments do go dry.

Management Action: The Division will actively pursue a program to provide water for bighorn sheep as a means to increase population levels and distribution in water deficient habitats.

Strategy: The protection and development of natural water sources will be a high priority. The Division will work with other agencies to protect riparian areas. Conservation Nevada Division of Wildlife’s Bighorn Sheep Management Plan 10

easements will be pursued in order to protect important water sources for wildlife. The acquisition of water rights will be pursued as identified in Commission Policy 61 (Water Rights) including the development of guidelines and procedures for water right filings.

Strategy: The Division will aggressively pursue protection of existing water developments against actions or activities that intend to remove or eliminate any water development that is used by bighorn sheep.

Strategy: The Division will pursue water developments in water deficient habitats to mitigate for habitat losses in other areas. Consideration must be given for multiple water sources in summer range to moderate impacts from failed water developments and focused predation. When determining water development sites, consideration should be given to provide for winter range or dry areas.

Strategy: The maintenance of existing water developments will be a high priority. A combination of approaches may need to be employed to ensure that all waters are maintained. Strategies could include the establishment of a permanent fund whereby the interest from the account would be used to fund a long-term annual maintenance program. Other approaches could include the use of conservation groups, volunteer labor, area biologists and agency fire crews.

Strategy: The Division will, where feasible, augment water in those water developments that are deficient in available water. Conservation groups, volunteer labor, area biologists and agency fire crews may be utilized.

Strategy: The Division will work cooperatively with federal land management agencies, conservation organizations and private landowners to develop adequate water distribution for bighorn sheep throughout the state.

Strategy: The Division will use the best development design for a given site in order to provide adequate water in the most cost efficient and maintenance-free manner. Other factors will be considered when designing developments such as the merits of using one large development in an area verses several smaller units.

Strategy: The Division in cooperation with land management agencies will use employees, private contractors, conservation organizations and volunteers for the installation of water developments in order to achieve water development objectives.

Grazing Input

Livestock, feral horses and feral burros are associated with most of the bighorn sheep habitat within the State. In many instances, livestock, horses, and burros compete directly with bighorns for forage, water, and space. It is important that bighorn sheep habitats are managed to ensure land use objectives are achieved and that habitats are maintained in good to excellent ecological condition. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 11

Management Action: The Division will encourage and support land management decisions and resource management techniques that result in the attainment of good to excellent ecological condition on public and private rangelands.

Strategy: The Division will encourage and support the management of livestock when such management results in the attainment of land use goals and objectives consistent with wildlife needs. The Division should take appropriate action, including litigation, when these goals and objectives are not obtained.

Strategy: The Division will encourage and support the management of feral horses and burros when such management results in the attainment of land use goals and objectives consistent with wildlife needs. The Division should take appropriate action, including litigation, when these goals and objectives are not obtained.

Strategy: The Division will encourage and support sound monitoring procedures as the basis to determine the condition of ranges and to assess the amount of use by class of animal. The Division should take appropriate action, including litigation, when these goals and objectives are not obtained.

Strategy: The Division will provide comments or take other appropriate action through the land use planning process when poor range conditions exist and are in need of improvement for the benefit of wildlife including bighorns. The Division should take appropriate action, including litigation, when these goals and objectives are not obtained.

Fire

The effects of fire on bighorn sheep habitat vary depending on the vegetative community impacted. In some of the lower elevation sagebrush habitats, cheatgrass readily establishes after a fire and prohibits the reestablishment of native vegetation. In other areas, primarily dominated by pinyon and juniper trees, fires can be a major benefit to sheep habitat by increasing the productivity of the site through reduction in tree cover and increasing grasses and forbs.

Management Action: The Division will evaluate the effects of fire on bighorn sheep habitat on a case-by-case basis. In areas where fire is determined to be detrimental, the Division will work with land management agencies to reduce fire intensity and frequency. In areas where fire may benefit bighorn habitat, the Division will support the burning of some habitats when tiered to a plan which has definable objectives established through a collaborative process.

Strategy: The biologist will determine the effects of fire on the bighorn sheep resources and habitats within their areas of responsibility, and the information will be incorporated into GIS.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 12

Strategy: The information will be provided to land management agencies to be used in fire suppression decisions. Areas of critical concern will be emphasized.

Strategy: In areas where fire will benefit bighorn habitat, the Division may support prescribed fire tiered to a burn plan.

Strategy: The Division will maintain a high level of interaction with land management agencies following wildfire in order to develop seed mixes to enhance bighorn forage and cover values. The Division will also encourage and support good grazing management practices following fire.

Strategy: The Division will work with the land management agencies to develop green- stripping in strategic locations in order to reduce the frequency and intensity of fires in crucial bighorn sheep habitat.

Roads, Off Road Vehicle Use

Off-road races will continue to increase throughout Nevada. Land management agencies field numerous requests for new races and route locations each year. Bighorn sheep habitat will be impacted both by the race participants and by the spectators to the event.

The development of new roads, improvement of existing roads, and use of all terrain vehicles (ATVs) will bring more people into bighorn sheep habitat. Often, bighorn sheep will move away from otherwise suitable habitat due to increased human activity.

Management Action: The Division will support the development and maintenance of reasonable access to all public lands. In areas where roads and off-road use pose serious impacts to the well being of bighorn sheep, the Division will work with land management agencies and private landowners to reduce these conflicts.

Strategy: The Division will monitor the proposed racecourses and will actively work with land management agencies and private landowners to locate races away from bighorn habitat. Bighorn habitat GIS maps will be distributed to various land management agencies in order to assist them in their decision making process. The Division should seek cooperator status with the BLM through a statewide MOU on review of applications for off-road races. Land management agencies should be encouraged to map existing roads designated for off-road races.

Strategy: The Division will maintain a high level of interaction with land management agencies regarding the building or maintenance of roads within bighorn sheep habitat. In areas where potential conflict exists, the Division may recommend alternative locations or recommend downgrading the quality of the road. The rehabilitation of roads used for fire suppression, off-road races or mining should be considered. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 13

Strategy: The Division will continue to monitor impacts of ATV use on bighorn sheep habitat and bighorn behavior and ATV-related hunter complaints. If significant conflicts arise, the Division will work with appropriate land management agencies to address these conflicts.

Mining

Mining occurs in several mountain ranges occupied by bighorn sheep. Issues associated with mining include direct habitat loss, indirect habitat loss such as habitat fragmentation from roads, increased disturbances, potential contact with lethal chemicals such as cyanide, and animal entrapment.

The mining industry, for the most part, has demonstrated successful reclamation practices on dumps and roads. In some instances, opportunities may exist to rehabilitate a mine area in order to enhance the area for bighorn sheep. (In Alberta, Canada for example, bighorn sheep inhabit the high walls and the dumps of a coalmine where grass was used to rehabilitate the disturbances).

Management Action: The Division will continue working closely with the mining industry and land management agencies in regards to wildlife and wildlife habitat issues associated with mining activity.

Strategy: The Division will follow Commission Policy 62 (mitigation policy) when reviewing and commenting on mining activities within bighorn sheep habitat.

Strategy: The Division will continue to foster a good working relationship with the mining industry to mitigate the affects of mining on bighorn sheep habitat.

Strategy: The Division will, through its mining program, take a pro-active approach to ensure that needs of bighorn sheep are addressed in operation, mitigation and reclamation plans.

POPULATION MANAGEMENT

Population management involves surveying bighorn numbers and distribution, delineating subspecies distribution boundaries, capturing and transplanting bighorns, disease detection and control, and evaluating and controlling predators. The primary factor involved in the management of bighorns is ensuring the proper balance between bighorn numbers and habitat quality and quantity. The underlying goal of this plan is to maintain bighorn herds at optimal population levels. Division biologists will use habitat condition, lamb recruitment, herd health, and past herd history in determining optimal population levels. Though animal density is a common parameter in referencing the proper balance of numbers and habitat, it is highly variable for bighorn sheep throughout Nevada. Because of differences that occur among habitat types, season of use, subspecies, and Nevada Division of Wildlife’s Bighorn Sheep Management Plan 14

water availability for a given amount of surface area, density alone is inadequate as a parameter to determine proper bighorn numbers. Optimal population levels based on a multitude of demographic and ecological parameters allows for bighorn numbers and distribution to be managed at the appropriate level for a given herd and area.

POLICY STATEMENT

The Division will increase bighorn populations of all subspecies statewide to a level where all habitats are occupied and each herd is self-sustaining.

Bighorn Sheep Capture and Transplanting

Reintroductions of bighorn sheep into unoccupied bighorn habitat will largely depend upon the resolution of current limitations and conflicts such as domestic sheep grazing and trailing routes, habitat deficiencies, and the revision of land management agencies’ land use plans. The Division supports the release of bighorns from Nevada to bighorn sheep habitats beyond the boundaries of this state. This supports the overall goal of bighorn sheep restoration throughout North America. Conservation organizations, such as NBU, Fraternity, FNAWS, and others, play an extremely important role in the capture and transplant program. The Division will continue to foster excellent working relationships with these groups to increase bighorn sheep populations.

Reintroductions

Management Action: Establish bighorn sheep populations in suitable but unoccupied habitat.

Strategy: Select reintroduction sites as identified by biologists through the habitat delineation process (see Habitat Delineation section) that have been enhanced through Habitat Management actions and strategies.

Strategy: Evaluate the degree of risk involved with transplanting bighorn sheep adjacent to occupied domestic sheep grazing allotments and trailing routes. Consult with the land management agencies and concerned publics to determine the overall long-term implications of a bighorn release with consideration for other multiple uses and potential recreational and scientific values.

Strategy: Obtain release site clearance in coordination with the appropriate land management agencies. Conservation groups and outside interests may be solicited to help obtain clearance.

Strategy: Incorporate bighorn sheep reintroduction sites into the Big Game Release Plan. The intent of listing sites in the release plan is to provide an adequate Nevada Division of Wildlife’s Bighorn Sheep Management Plan 15

number of optional sites for possible reintroductions at any one time.

Strategy: Coordinate at both the biologist and staff levels to annually prioritize reintroduction sites. In-state reintroductions will take priority over out-of-state releases.

Strategy: Biologists with predator management expertise will evaluate possible predation on bighorn sheep release. If it is determined that predation is a limiting factor, predator management will be instituted until the population shows an increasing annual trend. If predator control does not result in an increasing annual trend, then other limiting factors will be examined. Commission Policy 25, ‘Wildlife Damage Management’ will be followed.

Strategy: Coordination and notification with land management agencies and other interested parties will occur prior to a reintroduction.

Strategy: The preferred number for a release complement will be between 20 and 50 bighorn sheep dependent upon capture stock availability. Some sites may require subsequent reintroduction efforts to attain a viable reintroduction.

Augmentations

Management Action: Augment bighorn sheep populations to bolster populations that are below optimal levels and in some cases increase genetic diversity.

Strategy: Identify augmentations sites through the habitat delineation process (see Habitat Delineation section) where existing populations are below optimal levels or could benefit from increasing genetic diversity or improving herd health. See Reintroduction strategy regarding augmenting bighorn herds adjacent to occupied domestic sheep grazing allotments and trailing routes.

Strategy: Incorporate bighorn sheep augmentation sites into the Big Game Release Plan. The intent of listing sites in the release plan is to provide an adequate number of optional augmentation sites at any one time.

Strategy: Coordinate at both the biologist and staff levels to annually prioritize reintroduction sites. High priority in-state augmentations will take priority over out-of-state releases.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 16

Strategy: Coordination and notification with land management agencies and other interested parties will occur prior to an augmentation.

Capture

Management Action: Capture bighorn to reintroduce into suitable habitat and augment existing populations.

Strategy: Annually determine suitable capture stock from both in-state and out-of-state sources. The big game staff biologist will facilitate and coordinate with regional biologists in securing out-of-state capture sources.

Strategy: The Division will use bighorn sheep from existing populations that are approaching or exceeding optimal levels. Bighorn sheep may be captured from populations that are below optimal levels if the herd has been surveyed within 12 months of the capture operation and the regional staff recommends that the population is capable of supporting the deficit.

Strategy: The Division will consider the potential of disease transmission from a particular capture stock to the release site and adjacent bighorn populations.

Strategy: The Division will consider potential capture problems such as bighorn lambing period and conflicts with ongoing hunting seasons.

Strategy: The Division will finalize a protocol that identifies recommend procedures for capturing, transporting and transplanting bighorns.

Population Monitoring

It is essential to maintain an effective monitoring program for bighorn populations that are relatively low in number and are subject to catastrophic events. Bighorn populations are highly sensitive to changes due to the harsh environments they inhabit. Without knowledge of population status and distribution, the Division is unable to make good sound management decisions regarding harvest, augmentations, habitat conservation and enhancement, and incompatible activities in bighorn habitat.

Management Action: Bighorn populations will be adequately monitored to assess trends and detect significant demographic changes and/or home range/movement changes.

Strategy: Aerially survey bighorn populations a minimum of every two years. Populations that serve as capture stock will be flown on an annual basis. Populations may be flown more often if downward trend exists. Bighorn rams will be classified as follows: yearlings, 2-3 year-old age, 4-5 year-old age, and 6 year-old and older age group.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 17

Strategy: The Division will obtain the necessary Global Positioning System (GPS) and Geographic Information System (GIS) technology and equipment to enable the Division to efficiently collect, display and analyze data.

Strategy: Satellite and radio telemetry and GIS technology will be used when necessary to meet monitoring objectives.

Strategy: Biologist will document bighorn locations on standardized field forms. GPS technology will be the preferred method.

Strategy: The Division will institute hunter logbooks for all tagholders to maintain field observations during scouting and hunting trips. Volunteers may be used to conduct data entry and to plot bighorn sheep observations to assist in determining current bighorn distribution patterns and densities.

Strategy: Division biologists while surveying for a certain species or conducting a specific work assignment should take advantage of opportunities to survey and document bighorn sheep while in the same general area.

Strategy: Bighorn population modeling will be standardized and used to develop annual estimates of population size, structure, and trend.

Subspecies Delineation

Bighorn sheep subspecies boundaries in Nevada were originally based on analysis of skull characteristics by Cowan (1940). Recent genetic and morphometric analysis (Ramey 1993, 2000; Wehausen 2000) suggests that the desert bighorn was distributed throughout Nevada and California bighorns that originated in British Columbia are a branch of the Rocky Mountain subspecies. Based on past management action that released California and Rocky Mountain bighorns and the desires of sportsmen, the Division of Wildlife will continue to manage them, but certainly, a strong emphasis will be placed on expanding desert bighorn sheep distribution into currently unoccupied habitats.

California bighorns, now considered a race of Rocky Mountain bighorns, have adapted well to northern Nevada habitats and climate. California bighorn herds in Nevada from the year they were released to 2001 showed a remarkable 14% average annual rate of increase. This fact reveals that contrary to the historic genetic race of desert bighorns, the management decision to restore northern Nevada with California bighorns was a success, because of similar habitat and climate. Strong consideration was made to continue this management philosophy in north central Nevada to reintroduce bighorn sheep that are best suited for the habitat and climate. Based on the overall goal of desert bighorn sheep conservation throughout North America and recognizing their historic distribution, efforts will be made to expand desert bighorn distribution in Nevada, acknowledging previous subspecies management decisions and development of manmade barriers across once contiguous bighorn habitat. The boundary delineation for future bighorn sheep releases is depicted in Figure 3. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 18

Desert bighorn sheep releases will be restricted to south and west of a line formed by Interstate 80 from the California line to Elko, south along Highway 228/892 to Highway 50, east to Highway 93, south to the Lake Valley Summit and east to the Utah line along the Atlanta Mine/Trough Springs/Big Springs Roads. Rocky Mountain subspecies releases will occur north and east of this line including the line formed by Highway 225/226 north from Elko.

Though the Division acknowledges the scientific determination that California bighorns in Nevada are not a distinct subspecies, for purposes of management, the Division will continue to recognize existing California bighorn herds as a separate subspecies. California bighorns will be released north of the desert bighorn boundary and west of the Rocky Mountain bighorn boundary. The northeastern portion of the state in Elko County excluding Units 101 – 104 and 121 would be where either California or Rocky Mountain bighorns could be released depending on habitat suitability, sheep availability, or the political and social atmosphere at the time (see Figure 3).

It should be noted that this geographic delineation is for the purpose of future releases. Management units will still be used for the purpose of harvest management.

Management Action: The Division will follow the revised bighorn sheep subspecies delineation map as a guide in determining which areas receive which subspecies for future re-introductions and augmentations (Figure 3).

Strategy: The Division will reference the subspecies delineation map in the development of the biennial big game release plan.

Strategy: Desert bighorn herds from mountain ranges with similar topography, habitat, and climate will be the preferred capture stock for releases to mountain ranges in the northern half of the desert bighorn subspecies delineation area.

Strategy: Once an area has been established as a particular subspecies management unit, it will remain an area for that particular subspecies regardless of the amount of mixing that has occurred, unless compelling scientific information exists to the contrary.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 19

Figure 3. Bighorn sheep subspecies delineation boundaries for future transplants of desert, California, and Rocky Mountain bighorn sheep. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 20

Disease

Bighorn sheep have been known to experience periodic epizootics resulting in wide fluctuations in population levels (Buechner 1960). Recently, these epizootics have been diagnosed as pneumonia-related epidemics (Onderka and Wishart 1984; Coggins 1988; Festa_Bianchet 1988; Cassirer et al. 1996; Ward et al. 1997). The Division recognizes the inherent susceptibility of bighorns to certain disease agents such as Pasteurella. Attempts to vaccinate bighorn sheep to combat this disease have been unsuccessful (Cassirer et al. 2001).

Management Action: The Division will investigate and address all disease related problems in a timely fashion.

Strategy: The Division will develop a protocol for disease sampling and testing and adapt it each year to incorporate the most up-to-date methods and information available.

Strategy: The Division will provide each bighorn sheep biologist in addition to each region, a sufficient number of sampling kits and instructional video in preparation of potential disease events.

Strategy: If an unusually high number of mortalities occur during a capture event and the consensus is that it may be disease related, any living bighorn already captured will not be transported to another site. One live sheep should be taken to a wildlife diagnostic laboratory for surveillance.

Strategy: Following the discovery of a disease event, either a ground or aerial survey will be initiated to investigate the potential impact to the rest of the population.

Strategy: The Bighorn Sheep Interaction With Domestic Sheep and Disease and Health Assessment protocols will be followed.

Strategy: The Division may initiate a disease prevention or health enhancement program for a particular population if the costs and benefits are justified.

Strategy: The Division will minimize domestic farm flock sheep/wild sheep interactions through all possible means. This could include entering into cooperative agreements with willing landowners, education, and cooperating with Department of Agriculture.

Strategy: The Division will encourage and support disease research when objectives are clearly outlined and results can be applied directly to management activities.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 21

Predator Management

Management Action: The Division will evaluate and if necessary conduct science- based (treatment-control study design, monitoring and documentation of results) predator management to enhance survival of bighorn sheep.

Strategy: For existing herds, the Division will use criteria to determine if predator management should be initiated. Criteria include but are not limited to the following:

• Continued low recruitment or population trend (stagnant or below maintenance levels) • Predator-caused bighorn sheep mortalities are located. • Evidence suggests that a predator has targeted a certain segment of the bighorn herd. • Hunter/Public observations • Benefits of a predator control program can be measured and successfully implemented. • Environmental conditions (i.e., reduction in alternative prey or water sources) that may cause added vulnerability to predation.

Strategy: The Division will monitor and document the effectiveness of predator management.

Strategy: Biologists will evaluate possible predation on bighorn sheep release. If it is determined that predation is a limiting factor, predator management will be instituted until the population shows an increasing annual trend. Commission Policy 25, ‘Wildlife Damage Management’ will be followed

Strategy: The Division will use the most appropriate and effective agency or individual to conduct predator management. (i.e., designated Division employee, Wildlife Services, private individual, etc.)

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 22

HARVEST MANAGEMENT

POLICY STATEMENT

Bighorn sheep hunting is a legitimate and desirable use of the bighorn resource.

Quota Criteria and Tag Requirements

Hunting bighorn sheep in Nevada is a rare privilege. The average odds of drawing a resident or nonresident tag for the 2001 sheep season were 68 to 1. The first regulated desert bighorn sheep hunting season was held in the spring of 1952. In 1966, a significant change in desert bighorn hunting regulations occurred with the passage of the trophy ram regulation. This regulation replaced the three-quarter-curl law and required hunters to harvest a ram at least 7 years of age or with a Nevada horn score of 144 points. In 1996, the trophy ram regulation was replaced on a statewide basis with the any ram Nevada Bighorn Harvest regulation allowing hunters to harvest 9 any male bighorn. The first California bighorn sheep hunting season was in 7 1984 and has been under the any ram regulation since its inception. 5 Figure 4 shows that the average age of harvested rams has declined only 3 slightly since the implementation of Age of Rams the any ram regulation but has 1 averaged between 5 and 7 years of 90 91 92 93 94 95 96 97 98 99 00 age. Therefore, it would seem a reasonable strategy for the Division Desert California to manage for an average age of harvested rams. With input from the Figure 4. Average age of harvested desert and public, this target age could be California bighorn sheep rams in Nevada from easily measured and met with 1990 – 2000. adjustments in quotas and season structure.

Management Action: Division biologists will develop annual quota recommendations for review by the public. The majority of Nevada’s sheep hunters would like to have an opportunity to harvest a mature bighorn ram. Quota recommendations will reflect this expectation by striving to obtain a statewide average age of harvested rams of 6 years.

Strategy: Quota criteria for tag numbers will be based on 8% of the total rams not to exceed 50% of the estimated number of mature rams 6 years of age or older from each unit group’s population model. Hunter success rates will not be used Nevada Division of Wildlife’s Bighorn Sheep Management Plan 23

to generate quotas.

Strategy: Eligibility restrictions for applying for a bighorn sheep tag (subspecies specific) will be a 5-year wait after receiving a tag and 10-year wait after harvesting a bighorn sheep of that subspecies.

Strategy: Hunters must attend a mandatory indoctrination course provided by the Division as a requirement of receiving their tag. Guides must attend once every 5 years. Guides will be able to attend indoctrination for client.

Strategy: Maintain the any ram regulation.

Strategy: Maintain mandatory checkout of harvested sheep to estimate ram age and horn score.

Strategy: Bighorn sheep populations are susceptible to a large-scale die-off. The Division cannot be accountable to tagholders for this occurrence.

Strategy: Nonresident hunters will be allowed up to 10 percent of annual tag numbers. Distribution of these tags will be based on a fair and equitable cross section of bighorn hunting opportunity within the state.

Season Structure

Nevada is a large state diverse in both topography and weather patterns. Sheep seasons have been conducted during almost every month of the year, with the majority held during the late fall and early winter period. There has been considerable experimentation with season lengths, with the trend in recent years toward longer seasons. Lengths have varied since 1952 from a 4-day to 60-day seasons. With the success of bighorn reestablishment program in northern Nevada, season timing and lengths have become more diverse. A bighorn-hunting season designed for desert bighorn in the southern part of the state may be less desirable for bighorn hunting in the northern portion of the state.

Management Action:. Sheep seasons will remain flexible to take into account the biological needs of the animal and to allow for a quality hunting experience.

Strategy: Split seasons or extended seasons may be used to reduce the number of hunters in the field when hunter congestion becomes an issue.

Strategy: General seasons will not occur during the peak of the rut.

Strategy: Hunting seasons will not be structured to reduce hunter success.

Strategy: Season lengths will not be shorter than 21 days. Season length may be less in units controlled by Department of Defense.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 24

Strategy: Any legal weapon will remain as a means of harvesting bighorn sheep during all seasons.

Strategy: The harvest of ewes may be considered as a population management tool if all other options for population control have been exhausted. Harvest and eligibility regulations for ewe hunts will be developed prior to 2003.

Strategy: The initial hunt on a reintroduced population or rebounding population will be based on survey observations of rams that meet the quota criteria.

LAW ENFORCEMENT

Bighorn sheep are a highly regarded and sought-after big game species. Within the big game hunting community, bighorn sheep have an additional, unique value associated with a hunter’s recognition for harvesting a “grand slam”. A “grand slam” refers to harvesting all races of North American thin-horn and bighorn sheep: Dall, Stone, Rocky Mountain (including California), and Desert. There is a need to protect them from a small segment of society that will go to extremes to harvest a bighorn sheep.

In addition, the desert bighorn holds the distinction of being Nevada’s state animal. Whether for the protection of bighorns for future harvest or simply for their intrinsic values, the Nevada Division of Wildlife has the responsibility to protect bighorn sheep for all to enjoy.

Management Action: The Division will continue to protect and ensure enhancement of bighorn sheep populations by gaining awareness and compliance of the public through education and appropriate enforcement of pertinent wildlife laws and regulations.

Strategy: Game wardens will participate in bighorn sheep indoctrination classes for the purposes of promoting the safe and lawful pursuit of bighorns and enhancing the sportsmen’s knowledge of pertinent hunting laws and regulations.

Strategy: Conduct special investigations whenever sufficient grounds or evidence exists which indicates that a bighorn sheep has been unlawfully taken or possessed.

Strategy: Conduct frequent field patrols during bighorn sheep hunting seasons, thereby increasing contact with bighorn sheep hunters and hunting guides.

Strategy: Conduct frequent field patrols in areas where bighorn are particularly vulnerable to opportunistic poaching.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 25

ECONOMICS

Hunter Expenditures

The Nevada Division published a “Survey of the Economic Value of Trophy Big Game and Deer Harvest” in 1986, which is the only known attempt at assigning dollar values to Nevada’s bighorn sheep resource (Fenton Kay 1988). This study queried sheep hunters about the amount of money they spent on their sheep hunts during 1984 and 1985. Costs included in this survey were guide fees, license and tag fees, fuel, equipment, lodging, food, taxidermy and miscellaneous costs such as phone calls and broken equipment. The current consumer price index was used to convert dollar values from 1986 to 2000. Based on this study and the current average days hunted, it was assumed that a total of 11 days were expended on travel, scouting, and hunting bighorn sheep. Based on these inputs, resident and nonresident hunters expended an average of $2,924 and $10,077 per hunt, respectively in 2000. Expanding these figures to all the 2000 bighorn sheep hunters, 159 resident hunters expended $465,000 and 20 nonresident hunters expended $201,000 for a total of $666,000

A complete evaluation of the economic values of bighorn should also include consideration of nonconsumptive values. Nonconsumptive values would include the value of the resource to the non-hunting public. These values could include just knowing the resource existed even if the person had no expectation of using the resource and knowing the resource will exist into the future. No data exists to estimate these values. The dollar value of bighorn sheep to the nonconsumptive users of the state of Nevada may be higher than that of the hunting public.

Division Revenue

Division revenue to manage bighorn sheep is derived from a number of sources. These sources include tag and license revenue, federal aid derived from the Pittman and Robertson or Wildlife Restoration Act (Congressional mandate that apportions proceeds of an excise tax on firearm and ammunition to each state wildlife agency) and funding from sportsmen and conservation groups.

Figure 5 displays funds generated from resident and nonresident tags, heritage tags, and the potential federal aid match for the last 20 years. Since the first sheep season in 1952, sheep hunters have spent $2,232,332 on tag fees to hunt bighorn in Nevada. Bighorn sheep heritage tag hunters have contributed the lion’s share of this figure spending $1,730,202 for the privilege of pursuing bighorn (Figure 5). A new program named Partnership In Wildlife (PIW) allows hunters to donate part of their tag fee for a second chance at drawing a sheep tag if unsuccessful in the first drawing. Since 1996 this program has generated $108,151 that has been deposited into the Nevada Division of Wildlife’s Bighorn Sheep Management Plan 26

Heritage Account to fund special projects.

Sportsmen and conservation groups have contributed a significant Bighorn Tag Revenues amount of funds to bighorn $900,000 sheep management in $800,000 Nevada. For example, through 2000, FNAWS has $700,000 donated $144,000, and the $600,000 Fraternity of the Desert $500,000 Bighorn has donated $400,000 $1,200,000 since 1984 to the Dollars $300,000 Division and to land management agencies for $200,000 bighorn sheep population $100,000 and habitat management. $0 Other organizations such as 1981 1984 1987 1990 1993 1996 1999 the Nevada Bighorns YEAR Unlimited chapters have also contributed a significant Potential Federal Aid Match amount toward bighorn Heritage Tags sheep management. Resident and Nonresident Tags In addition to the Figure 5. Nevada bighorn sheep tag sales revenue monetary contributions, and its potential federal aid match from 1981 – these organizations have 2000. also donated endless number of volunteer hours during habitat improvement and capture projects. The Fraternity of the Desert Bighorn has estimated their members to work 52,000 hours worth $800,000.

Division Expenditures

The expenditure of money by the Division to manage bighorn sheep includes salaries for personnel, flight charges for aerial composition surveys and telemetry work on newly introduced populations and operating costs including travel and mileage. Table 2 shows these costs by region for fiscal year 2000.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 27

Table 1. Annual Division bighorn sheep management expenditures for FY2000. Operating – Region Salaries Flight Charges Total Cost Travel- Mileage Western $45,931 $1,978 $3,128 $51,037 Eastern $9,097 $1,617 $676 $11,390

Southern $53,616 $23,244 $2,895 $79,755

Capture Costs* $35,797 Total Cost $108,644 $26,839 $6,695 $177,979 *Includes netgun company and veterinarian contract costs only.

Trapping and Transplanting Costs

Since the late 1960’s, a total of 1,293 Desert Bighorn, 587 California Bighorn and 265 Rocky Mountain Bighorn have been released into 58 different mountain ranges within the state. Based on the best available records the Division has expended just over $930,000 dollars on this program. This cost can be broken down by subspecies totaling $520,000 for Desert bighorn, $288,000 for California bighorn and $124,000 for Rocky Mountain bighorn. This program has been a huge success in terms of both public support and the establishment of new and viable sheep populations.

CONSERVATION EDUCATION

The desert bighorn sheep is Nevada’s state animal; yet, the general public has very little knowledge about bighorn sheep. The hunting public has more knowledge about bighorn sheep but lacks an understanding of the threats to bighorn sheep habitat.

Most sportsmen do not know the process for involvement in population and habitat management decisions. Support for bighorn sheep is lacking in significant decisions affecting bighorn sheep habitat. It is believed that an increased awareness and educational program could enhance the support for bighorn sheep in land management, legislative, and local government decisions.

POLICY STATEMENT

The Division will increase public awareness and appreciation for bighorn sheep and their habitats in order to facilitate decisions favorable to their long-term well being.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 28

Educating Nevada’s Youth

Nevada’s youth is the key to the future well being of the State’s wildlife. Extensive efforts are already being implemented in many of Nevada’s schools to educate students in basic ecological principals. The Division, in conjunction with conservation organizations, should provide support materials for this program that will enhance the understanding and appreciation of bighorn sheep and their habitat. An effort should also be made to teach kids the role that sportsmen play in the conservation of Nevada’s wildlife. The conservation of bighorn sheep habitat is the most important element of this public awareness program

Management Action: The Division will continue to support wildlife education in the school system and will provide material that will teach kids about bighorn sheep and their habitat.

Strategy: Develop a compact disc (CD) program about bighorn sheep and their habitat to be used in schools similar to the BLM produced program “The Magnificent Ram”.

Strategy: Build portable boxes or “wildlife trunks” that contain bighorn and other wildlife furs, horns and hoofs to be used in schools and other youth group events for hands-on interactions. Eventually, every community would have one of these boxes.

Strategy: Develop a video/CD that tells the story of bighorn sheep extirpation from Nevada’s mountain ranges and the efforts of sportsmen and Division to bring them back.

Strategy: Encourage sportsmen groups to provide educational materials (books, brochures, posters, etc.) to youth and schools.

Educating the General Public

Nevada’s general public, for the most part, is indifferent towards Nevada’s wildlife. It is believed that a major contributor towards this attitude is the lack of a consistent medium needed to bring wildlife issues to the forefront of the public. A combination of strategies will need to be implemented over a long period of time in order to bring greater awareness to Nevada’s wildlife. The conservation of bighorn sheep habitat is the most important element of this public awareness program.

Management Action: Continue to use all of the means available to educate the general public on issues pertaining to bighorn sheep and other wildlife.

Strategy: Support and participate, where appropriate, with conservation organizations in Nevada Division of Wildlife’s Bighorn Sheep Management Plan 29

habitat improvement projects that are within view of the general public.

Strategy: Construct kiosks with interpretive materials along roadsides adjacent to bighorn sheep habitat and bighorn sheep viewing opportunities.

Strategy: Develop additional bighorn sheep dioramas and interpretive displays in public facilities such as airports.

Strategy: Encourage sportsmen groups to advertise in newspapers and other media to portray bighorn sheep conservation efforts and solicit involvement in such efforts.

Strategy: Conduct “ride alongs” with influential individuals during aerial surveys to gain support of the bighorn sheep conservation efforts.

Strategy: Pursue Department of Tourism for sponsoring advertisements and stories about bighorn sheep viewing and conservation.

Educating Hunters

Educating hunters on issues relating to wildlife is probably the easiest because we have mediums that consistently reach them. These sources include the Sportsmen Almanac, the Division’s web page and hunter indoctrinations. Unfortunately, very few hunters realize the importance of habitat and even fewer get directly involved in the decision-making processes that impact wildlife and habitat.

Management Action: Continue to use all available sources to educate hunters on issues relating to bighorn sheep. Emphasis should be placed on the importance of habitat and the decision-making processes that affect bighorn sheep and their habitat.

Strategy: Develop a video of bighorn sheep (ecology and conservation) to be used in the hunter indoctrination classes. This video could be produced in such a way as to be used in schools and civic presentations.

Strategy: Update and improve the “Hunting the Desert Bighorn Sheep” pamphlet. Funding for this could include conservation organization partnerships or advertisements.

Strategy: Have the bighorn sheep conservation groups sponsor articles in the Almanac and other Division publications dedicated to bighorn sheep and their habitat.

PLAN EVALUATION

Original team members will meet August 2004 to evaluate the plan’s implementation. A Nevada Division of Wildlife’s Bighorn Sheep Management Plan 30

written report will be developed and presented to the Commission.

LITERATURE CITED

Buechner, H. K., 1960. The bighorn sheep in the United States, its past, present, and future. Wildlife Monographs No. 4: 174 pp.

Buck, P. E., B. Hockett, F. Nials, and P. Wigand. 1997. Prehistory and Paleoenvironment at Pintwater Cave, Nevada: Results of Field Work During the 1996 Season. Prepared by DRI for Nellis Air Force Base, Nevada.

Cassirer, E. F., L. E. Oldenburg, V. L. Coggins, P. Fowler, K. M. Rudolph, D. L. Hunter, and W. J. Foreyt. 1996. Overview and preliminary analysis of Hells Canyon bighorn sheep die-off 1995-1996. Biennial Symposium of the Northern Wild Sheep and Goat Council 10: 78-86.

Cassirer, E. F., K. M. Rudolph, P. Fowler, V. L. Coggins, D. L. Hunter, and M. W. Miller. 2001. Evaluation of ewe vaccination as a tool for increasing bighorn lamb survival following Pastuerellosis epizootics. Journal of Wildlife Diseases. 37: 49-56.

Coggins, V. L. 1988. The Lostine Rocky Mountain bighorn sheep die-off and domestic sheep. Biennial Symposium of the Northern Wild Sheep and Goat Council. 6:75- 64.

Gruhn, R. 1976. Excavation in Amy’s Shelter, Eastern Nevada. Nevada State Museum Anthropological Papers, No. 17, Carson City.

Kay, F. R. 1988. Nevada survey of the economic value of trophy big game and deer harvest. Biological Bulletin No. 9. Nevada Department of Wildlife. 60 pp.

Festa-Bianchet, M. 1988. A pneumonia epizootic in bighorn sheep, with comments on preventive management. Biennial Symposium of the Northern Wild Sheep and Goat Council. 6: 66-76.

Harrington, M. R. 1933. Gypsum Cave, Nevada. Southwest Museum Papers, No. 8. Los Angeles, CA.

Jennings, J. D. 1957. Danger Cave. University of Utah Anthropological Papers No. 27:XIV +328 pp.

Jonez, A. 1957. Status of Bighorn Sheep in Nevada. Trans. Desert Bighorn Council 1:12- 15.

McQuivey, R. P. 1978. The Bighorn Sheep of Nevada. Biological Bulletin No. 6. Nevada Department of Wildlife. Reno, NV. 81 pp. Nevada Division of Wildlife’s Bighorn Sheep Management Plan 31

Onderka, D. K., and W. D. Wishart. 1984. A major bighorn sheep dieoff from pneumonia in southern Alberta. Biennial Symposium of the Northern Wild Sheep and Goat Council. 4: 356-363.

Ramey, R. R. II. 1993. Evolutionary Genetics and Systematics of American Mountain Sheep: Implications for Conservation. PhD dissertation. Cornell University. Ithaca, NY. 212 pp.

Ramey, R. R. II. 2000. New Perspectives on the Evolutionary Origins, Historic Phylogeography, and Population Structure of North American Mountain Sheep. In Thomas, A.E. and H.L. Thomas (eds.). 2000. Transactions of the 2nd Northern Wild Sheep Conference. 9-16.

Smith, J. U. 1910. John C. Fremont’s Expedition in Nevada, 1843-1844. Nevada Historical Society Papers. pp 106-152.

Ward, A. C. S., D. L. Hunter, M. D. Jaworski, P. J. Benolkin, M. P. Dobel, J. B. Jeffries, and G. A. Tanner. 1997. Pasteurella spp. In sympatric bighorn and domestic sheep. Journal of Wildlife Diseases. 33:544-557.

Wehausen, J. D. and R. R. Ramey II. 2000. Cranial morphometric and evoluationary relationships in the northern range of Ovis Canadensis. Journal of Mammalogy. 81:145-161.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan 32

Appendix A Laws and Regulations pertinent to Bighorn Sheep Management

Appropriate Federal Laws, Policies and Agreements Pertinent to Bighorn Sheep Management in Nevada

Taylor Grazing Act, 1934. As amended, provides for wildlife management on public lands.

Executive Order 7373. 1936. Created the Desert National Wildlife Range for the protection of resident desert bighorn sheep.

50 CFR . Code of Federal Regulations pertaining to wildlife

Fish and Wildlife Coordination Act of 1956. Encourages the development of cooperative agreements for a variety of fish and wildlife programs on Federal lands.

National Wildlife Refuge System Administration Act. 1966.

National Environmental Policy Act, 1968 (1981). - 42 U.S.C. 4321-4347. Requires that actions taken or permitted by Federal agencies be analyzed to determine their effects on the environment.

Master Memorandum of Understanding Between the Nevada Department of Fish and Game and the Bureau of Sport Fisheries and Wildlife, Department of the Interior, 1970.

Master Memorandum of Understanding Between the Nevada Department of Fish and Game and the Bureau of Land Management, Department of the Interior, 1970.

Master Memorandum of Understanding Between the Nevada Department of Fish and Game and the National Park Service, Department of the Interior, 1971.

Wild Free-Roaming Horse and Burro Act, 1971. Sec.3.(a) “... All management activities shall be at the minimal feasible level and shall be carried out in consultation with the wildlife agency of the State wherein such lands are located to protect the natural ecological balance of all wildlife species which inhabit such lands, particularly endangered wildlife species. Any adjustments in forage allocations on any such lands shall take into consideration the needs of other wildlife species which inhabit such lands. ....” and (b) in determining the number of horses and burros on the public lands and

Nevada Division of Wildlife’s Bighorn Sheep Management Plan A‐1

appropriate management levels ...”the Secretary shall consult with the United States Fish and Wildlife Service, wildlife agencies of the State or States wherein wild free-roaming horses and burros are located ....”

Endangered Species Act, 1973.

Sikes Act, 1974. “Section 201. (a) The Secretary of the Interior and the Secretary of Agriculture shall each, in cooperation with the State agencies and in accordance with comprehensive plans developed pursuant to section 202 of this title, plan, develop, maintain, and coordinate programs for the conservation and rehabilitation of wildlife, fish, and game. ...”

Master Memorandum of Understanding Between the Nevada Department of Fish and Game and the U.S. Department of the Agriculture, Forest Service, Region 4, 1971.

Federal Land Policy and Management Act, 1976 - Sec.102. (a) “The Congress declares that it is the policy of the United States that .... (8) the public lands be managed in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archeological values; that, where appropriate, will preserve and protect certain lands in their natural condition; that will provide food and habitat for fish and wildlife and domestic animals;.... “, “(11) regulations and plans for the protection of public land areas of critical environmental concern be promptly developed; . . . .”,

Sec. 103. (j) “The term “withdrawal” means withholding an area of Federal land from settlement, sale, location, or entry, under some or all of the general land laws, for the purpose of limiting activities under those laws in order to maintain other public values in the area or reserving the area for a particular public purpose or program;

Five Party Cooperative Agreement. 1977. U.S. Department of Defense (Air Force), U.S. Department of Energy (Nevada Test Site), U.S. Department of the Interior (Fish and Wildlife Service and Bureau of Land Management) and Nevada Department of Fish and Game. Provides for cooperative management of the Nellis Air Force Range and the Nevada Test Site.

Public Rangelands Improvement Act, 1978. Directs that the condition of the public rangelands be improved so that they become as productive as feasible for wildlife habitat and other rangeland values. The Act provides for on-the-ground funding of wildlife habitat protection, improvement and maintenance projects.

The Fish and Wildlife Conservation Act of 1980.

43 CFR 24.3. General jurisdictional principles. “(a) In general the States possess broad trustee and police powers over fish and wildlife within their borders.....” (b) “.... Congress has, in fact, reaffirmed the basic responsibility and authority of the States to

Nevada Division of Wildlife’s Bighorn Sheep Management Plan A‐2

manage fish and resident wildlife on Federal lands.”

43 CFR 1610.3-1 Coordination of planning efforts. “(b) State Directors and District Managers shall provide other Federal agencies, State and local governments, and Indian tribes opportunity for review, advise and suggestion on issues and topics which may affect or influence other agency or other government programs.”

Rangewide Plan for Managing Habitat of Desert Bighorn Sheep on Public Lands. 1988. BLM plan.

Grazing Guidelines for Management of Domestic Sheep in Bighorn Sheep Habitats. 1992. Revised 1998. Recognizes the need for spatial separation of domestic sheep and bighorns, and continued cooperation between all affected interests and agencies.

Mountain Sheep Ecosystem Management Strategy in the 11 Western States and Alaska. 1995. BLM Plan.

Nevada Revised Statutes Pertinent to Bighorn Sheep Management ` 1952. Commission authorizes first hunt.

Nevada Legislature designates desert bighorn sheep as official state animal. 1973.

NRS 501.182. The Commission may enter into cooperative agreements with adjacent states for the management of interstate wildlife populations......

NRS 503.584. “1. The legislature finds that: (a) The economic growth of the State of Nevada has been attended with some serious and unfortunate consequences. Nevada has experienced the extermination or extirpation of some of her native species . . . . . 2. The purpose of NRS 503.584 to 503.589, inclusive, is to provide a program for the: (a) Conservation, protection, restoration and propagation of selected species of native fish and other vertebrate wildlife, including migratory birds; and (b) Perpetuation of the populations and habitats of such species.”

NRS 503.587. “The commission shall use its authority to manage land to carry out a program for conserving, protecting, restoring and propagating selected species of native fish, wildlife and other vertebrates and their habitats which are threatened with extinction and destruction.”

NRS 533.023. As used in this chapter, “wildlife purposes” includes the watering of wildlife and the establishment and maintenance of wetlands, fisheries and other wildlife habitats.

NRS 533.367. Before a person may obtain a right to the use of water from a spring or

Nevada Division of Wildlife’s Bighorn Sheep Management Plan A‐3

water that has seeped to the surface of the ground, he must ensure that wildlife which customarily uses the water will have access to it. The state engineer may waive this requirement for a domestic use of water.

Nevada Administrative Code Pertinent To Bighorn Sheep Management

Season dates set under the authority of sections 501.181, 502.140, 502.250, 503.120 and 503.140 of NRS. Includes indoctrination requirements, Wildlife Heritage tags and Partners in Wildlife tags.

NAC 502.403.

NAC 503.020. Game mammals. 9. Sheep Bighorn...... Ovis canadensis canadensis Ovis canadensis nelsoni Ovis canadensis californiana

NAC 503.094. Scientific permit for collection or shipping of wildlife: Application; contents; term or permit; reporting requirement; conditions and restrictions. NAC 503.101. Factors for classification of wildlife as game.

NAC 503.110. Restrictions on importation, transportation and possession of certain species. 1. Except as otherwise provided in this section and NAC 504.486, the importation, transportation or possession of the following species of live wildlife or hybrids thereof, including viable embryos or gametes, is prohibited: (d) Mammals (30) Barbary (Aoudad) Sheep...... Ammotragus lervia (31) Mouflon sheep, Urial, Bighorn and Argali……..All species of the genus Ovis, except domestic sheep, Ovis aries.

NAC 503.173. Cape and horns or antlers or wildlife must be maintained with carcass.

Commission Policies Pertinent To Bighorn Sheep Management

Commission Policy Number 22. Establishes direction for the introduction, transplant, release and re-establishment of fish and wildlife into the State and exportation of the same out of the State as guided by NRS 501.181.

Commission Policy Number 25. To inform the public and guide the Division in actions relating to mammalian predator management.

Commission Policy Number 60. Water application guidelines.

Nevada Division of Wildlife’s Bighorn Sheep Management Plan A‐4

Commission Policy Number 61. Guides the Division in securing water for the preservation, maintenance and enhancement of wildlife and their habitats.

Commission Policy Number 62. Guides the Division in mitigation activities which have the potential to adversely impact fish and wildlife resources in Nevada.

Department of Agriculture Regulations on Lost Or Trespass Domestic Sheep And Goats

Definitions: “Estray” means any livestock running at large upon public or private lands in the State of Nevada, whose owner is unknown in the section where the animal is found. (NRS 569.005) “Livestock” means: (d) All goats or animals of the caprine species; (e) All sheep or animals of the ovine species;... (NRS 569.005)

All estrays are the property of the Department of Agriculture (NRS 569.010). NDA is not responsible for any trespass or damage caused by those estrays.

A written notice must immediately be sent to NDA by . . . any individual who impounds any livestock (NRS 569.020).

NDA or its authorized agent (usually the brand inspector) will attempt to determine ownership by following NRS 569.060-.070.

. . . NDA may dispose of the estray (usually through sale to defer expenses incurred (NRS 569.080).

NDA may destroy livestock infected with or exposed to disease: Procedure; owner's compensation (NRS 571.190)

43 CFR (BLM)

SUBCHAPTER B - LAND RESOURCE MANAGEMENT (2000)

Group 2000–Land Resource Management; General

PART 2070–DESIGNATION OF AREAS AND SITES

Subpart 2070–Designation of Areas and Sites

S 2070.0-1 Purpose. This subpart defines the circumstances and procedures under which specific areas of public and other Federal lands exclusively administered by the Secretary of the

Nevada Division of Wildlife’s Bighorn Sheep Management Plan A‐5

Interior through the Bureau of Land Management may be designated and identified.

S 2070.0-3 Authority. (a) Section 1 (b) (1) of the Classification and Multiple Use Act of September 19, 1964 (78 Stat. 986, 43 U.S.C. 1411) (b) Section 2478 of the Revised Statute (43 U.S.C. 1201)

Subpart 2071–Type and Effect of Designations

S 2071.1 Areas or sites that may be designated. (a) No lands may be designated under the regulations in this subpart unless they are either (1) classified for retention for multiple uses management under the regulations and criteria in Group 2400 of this chapter, or (2) withdrawn or reserved under the regulations in Group 2300 of this chapter o r other appropriate authority, or (3) given special status by act of Congress ......

(b) The following types of areas and sites may be designated under the regulations in this subpart: (1) Recreation lands. . . . .Scenic areas of natural beauty . . .

Recreation lands will contain one or more of the six classes adopted by the Bureau of Outdoor Recreation. . . . (i) Class I - High density recreation areas: ...... (ii) Class II - General outdoor recreation areas: ...... (iii) Class III - Natural environment areas: . . . . (iv) Class IV - Outstanding natural areas: . . . . (v) Class V - Primitive areas: . . . . . (vi) Class VI - Historic and cultural sites: ......

(2) Recreation sites. Small tracts, intensive recreation, facilities. (3) Resource conservation areas. These are relatively small areas of land which include a variety of resource management activities demonstrating multiple use and sustained yield conservation action. (4) Natural resources experiment and research areas. These are relatively small areas of land which are used for research and experimental purposes. (5) National resource lands. Large areas, multiple use management, emphasis on products (minerals, timber, etc.)

Nevada Division of Wildlife’s Bighorn Sheep Management Plan A‐6 Isolation and Serologic Evidence of a Respiratory Syncytial Virus in Bighorn Sheep from Colorado Author(s): Terry R. Spraker and James K. CollinsWilliam J. Adrian and James H. Otterman Source: Journal of Wildlife Diseases, 22(3):416-418. Published By: Wildlife Disease Association https://doi.org/10.7589/0090-3558-22.3.416 URL: http://www.bioone.org/doi/full/10.7589/0090-3558-22.3.416

BioOne sees sustainable scholarly publishing as an inherently collaborative enterprise connecting authors, nonprofit publishers, academic institutions, research libraries, and research funders in the common goal of maximizing access to critical research. 416 JOURNAL OF WILDLIFE DISEASES, VOL. 22, NO 3, JULY 1986

Earle’s salt base supplemented with 10% (75%), and 8-10-yr-olds (25%). Fifty-six heat-inactivated FBS. Gentamicin was percent of the males and 35% of the fe- added to the medium at a final concen- males were seropositive for RSV. Anti- tration at 50 pglml. The microtiter plates body titers ranged from 1:5 to 1:20 (me- were incubated at 37 C for 5 days. Anti- dian = 1:5).This is the first report on the body titers were expressed as the highest Occurrence of RSV antibodies in mountain dilution of serum that prevented 50% RSV goats and indicates enzootic transmission cytopathogenic effect. in the population. The importance of RSV Neutralizing antibodies to RSV were infection in the epizootiology of respira- detected in 29 (42%)of the 69 mountain tory disease in mountain goats is un- goats, including kids (25%), yearlings known. (28%),2-4-yr-olds (43%), 5-7-yr-olds

journal of Wildlife Dfaeases. 22(3). 1986. pp 416-418 0 Wildlife Disease Arsocintion 1986

Isolation and Serologic Evidence of a Respiratory Syncytial Virus in Bighorn Sheep from Colorado

terry R. Spraker and James K. Collins, Diagnostic Laboratory, College of Veterinary Medicine, Colorado State University, Fort Collins, Colorado 80523, USA; and William J. Adrian and James H. Ottoman, 317 W. Prospect, Colorado Division of Wildlife, Fort Collins, Colorado 80526, USA

In December 1984, personnel of the animals and included a moderate suppur- Colorado Division of Wildlife began bait- ative rhinitis/tracheitis and subacute sup- ing Rocky Mountain bighorn sheep (Ouis purative bronchopneumonia. Approxi- c. canudensis Shaw) near Ouray, Colo- mately 5% of lung parenchyma was rado in order to treat them for Proto- consolidated in both animals. The thymus strongylus stilesi Dikmans. When the was totally atrophied in the lamb. Gross sheep began to visit the bait station, it was lesions of the respiratory system were sim- observed that approximately 50% of the ilar to those in bighorn sheep with early herd were coughing and about 20% had a cases of bronchopneumonia observed dur- nasal discharge. Since a bighorn lamb had ing previous die-offs in Colorado (Spraker been found dead on the bait station the et al., 1984, J. Wildl. Dis. 20: 319-327). previous week, it was decided to collect Tissue samples from posterior nasal sep- and necropsy sick animals from this herd tum lymphoid tissue, trachea, consolidat- in order to investigate this possible respi- ed and normal lung parenchyma, and ratory problem. lungworm nodules were placed in viral On 4 January 1985, two clinically ill transport media and transported on ice to sheep exhibiting signs of coughing, slight- the Diagnostic Laboratory, Colorado State ly dull rough hair coat, and nasal dis- University, Fort Collins, Colorado. These charge were collected and necropsied. One tissues were also cultured for bacteria. animal was an adult ewe and the other A respiratory syncytial virus (RSV)was animal was an 8-mo-old ewe lamb. Gross isolated from posterior nasal septum necropsy findings were similar in both lymphoid tissue, trachea, and a lungworm nodule from the 8-mo-old lamb. The virus was identified by induction of character- Received for publication 13 August 1985. istic syncytial cytopathic effect in fetal RESEARCH NOTESCASE REPORTS 417

TABLE1. Results of serological testing for bovine respiratory syncytial virus and parainfluenza type-3 virus in bighorn sheep from Ouray, Colorado during the winters of 1983 and 1985.

1983 1985 No. sheep Antibody No. sheep Antibody Virus tested titer No. wsitive tested titer No. wsitive

BRSW 16 1:W 4 (25%) 40 1:W 1(2%) PI-3b 16 l:Eid 7 (44%) 40 1:W 9 (23%) 1:16 7 (44%) 1:16 10 (25%) 1:32 2 (12%)

Bovine respiratory syncytial virus. Parainfluenza type-3 virus. Neutralizing antibody titer against BRSV. Hemagglutination-inhibition antibody against PI-3 lamb lung cell cultures and by fluorescent 6: 159-163) and blood samples were col- antibody (FA) testing on infected cells lected from the sheep for serology and na- with a FA reagent specific for bovine re- sal swabs were taken for bacterial culture. spiratory syncytial virus (BRSV) (supplied Sera had been collected previously from by Dr. Merwin Frey, Virus Research Lab- this herd in February 1983, and at that oratories, University of Nebraska, Lin- time the herd appeared to be healthy. Sera coln, Nebraska 68583, USA). Cytopathic collected during the winters of 1983 and effect developed within 3-5 days after in- 1985 were tested for antibody to BRSV oculation of the specimens. No virus was using the serum neutralization (SN) test isolated from the adult ewe. Routine FA (reagents obtained from Dr. Merwin Frey) tests were negative for both BRSV and and PI-3 virus using the HI test. Results parainfluenza type-3 (PI-3) virus on lung of the serological survey for these two vi- tissues from both animals. Sera from these ruses demonstrated higher prevalences of two sheep were checked for antibody ti- antibodies to both BRSV and PI-3 virus in ters to PI-3 virus using a hemagglutination 1983 when compared to 1985 (Table 1). inhibition (HI) test, to infectious rhino- Pasteurella huemolytica biotype T was tracheitis virus (IBRV) using the serum isolated from nasal swabs from 17 of 40 neutralization test, and to bluetongue vi- animals during the trapping of January rus (BTV) and ovine progressive pneu- 1985. monia virus (OPPV) using the agar Results of this investigation document immunodiffusion test. Reagents were ob- the presence of a bighorn sheep respira- tained from the National Veterinary Ser- tory syncytial virus within the Ouray herd. vices Laboratories, Ames, Iowa 50010, The serological results can be interpreted USA. The adult ewe had a titer of 1:8 to in at least two ways. First, it is evident BRSV and 1:32 to PI-3 virus. Antibody from the prevalences that viral activity was titers of <1:8 for BRSV and 1:16 for PI-3 higher for BRSV and PI-3 virus in the virus were found in the lamb. All other winter of 1983 than during the winter of serological tests were negative. Pasteurel- 1985. Since more of the observed animals la hemolytica biotype T was isolated were sick during the winter of 1985 than from nasal cavities, tonsils, and lungs of in 1983, the seropositives could suggest both sheep. that these viruses did not play a role in During the last week of January 1985, the pathogenesis of the respiratory prob- the Ouray herd was trapped with a drop lem in 1985. Alternatively, the antibody net (Schmidt et al., 1978, Wild]. SOC.Bull. titers may have decreased and animals 418 JOURNAL OF WILDLIFE DISEASES, VOL. 22 NO. 3, JULY 19% may have lost detectable antibody due to rado (Spraker, 1979, Ph.D. Thesis, Colo- natural decline or to chronic stress occur- rado State University, Fort Collins, Colo- ring during the last several years. The rado, 232 pp.). Respiratory syncytial virus sheep could have then become susceptible has been isolated from domestic sheep to infections with these agents, predispos- (Evermann et al., 1985, Am. J. Vet. Res. ing them to bacterial (Pasteurella) pneu- 46: 947-952) and pneumonic lesions have monia. The exact role of this respiratory been induced experimentally in sheep us- syncytial virus or of PI-3 virus in the ing challenges of both respiratory syncy- pathogenesis of illness of sheep of the tial virus and Pasteurella huemolytica (Al- Ouray herd could not be elucidated, but Barraji et al., 1982, Am. J. Vet. Res. 43: further serologic testing should help to 236-240). Isolation of a respiratory syn- clarify their roles. cytial virus from this 8-mo-old bighorn Viruses were first implicated as being a lamb and serological evidence of this virus possible predisposing factor to bacterial within the herd documents the presence pneumonia in bighorn sheep in the mid of another respiratory virus of bighorn 1960’s (Howe et al., 1966, Bull. Wildl. Dis. sheep. The primary role of this bighorn Assoc. 2: 34-37). The first respiratory vi- sheep respiratory syncytial virus in the rus isolated from bighorn sheep was PI-3 pathogenesis of bacterial bronchopneu- virus from a captive herd in Wyoming monia observed in these two sheep and in (Parks et al., 1972, J, Wildl. Dis. 6: 669- producing the rhinitis and coughing in the 672). Later PI-3 virus was isolated from herd was undetermined. free-ranging bighorn lambs from Colo-

Journal of Wildlife messes, 22(3). 1986. pp. 418-420 Q Wildlife Disease Arsociation 1986

Serologic Studies of Select Infectious Diseases of Moose (Alces alces L.) from Alaska

A. Alan Kocan,’ Albert W. Franzmann,* Kenneth A. Waldrup,’ and Gary J. Kubat,‘ ‘Department of Veterinary Parasitology, Microbiology, and Public Health, College of Veterinary Medicine, Oklahoma State University, Stillwater, Oklahoma 74078, USA; and 2Alaska DeDartment of Fish and Game, Moose Research Center, Soldotna, Alaska 98669, USA

Few serologic studies have been con- antibodies to bovine viral diarrhea virus ducted on moose from Alaska. Serologic and infectious bovine rhinotracheitis virus reactivity has, however, been demonstrat- (Dieterich, 1981, In Alaskan Wildlife Dis- ed in moose from Alaska to select arbo- eases, Dieterich (ed.), Univ. of Alaska viruses (Zarnke et al., 1983, J. Wildl. Dis. Press, Fairbanks, pp. 28-29). The present 19: 175-179) and antibody to contagious serologic survey was designed to deter- ecthyma was detected in an experimen- mine the prevalence of certain infectious tally exposed moose calf (Zarnke et al., agents of free-ranging moose from Alaska. 1983, J. Wildl. Dis. 19: 170-174). Sera of Serum samples were obtained between moose from Alaska were also positive for 1974 and 1982 from 110 free-ranging moose from Alaska. Samples were obtained from one location on the Alaska Received for publication 15 July 1985 Peninsula (12 samples), three locations See discussions, stats, and author proﬁles for this publication at: https://www.researchgate.net/publication/318303872

Evaluating eﬃcacy of fence markers in reducing greater sage-grouse collisions with fencing

Article in Biological Conservation · September 2017 DOI: 10.1016/j.biocon.2017.06.030

CITATIONS READS 2 105

5 authors, including:

Adam Green David C. Pavlacky Jr. Bird Conservancy of the Rockies Bird Conservancy of the Rockies 12 PUBLICATIONS 85 CITATIONS 19 PUBLICATIONS 234 CITATIONS

SEE PROFILE SEE PROFILE

Some of the authors of this publication are also working on these related projects:

Dynamic multiscale occupancy model to account for variation in site selection View project

Avian community ecology in juniper woodlands of southwestern Wyoming: patterns of landscape and habitat utilization View project

All content following this page was uploaded by Adam Green on 09 October 2017.

The user has requested enhancement of the downloaded ﬁle. Biological Conservation 213 (2017) 70–83

Contents lists available at ScienceDirect

Biological Conservation

journal homepage: www.elsevier.com/locate/biocon

Evaluating eﬃcacy of fence markers in reducing greater sage-grouse MARK collisions with fencing

⁎ Nicholas J. Van Lanen , Adam W. Green, Taylor R. Gorman, Laura A. Quattrini, David C. Pavlacky Jr

Bird Conservancy of the Rockies, 14500 Lark Bunting Lane, Brighton CO 80603, USA

ARTICLE INFO ABSTRACT

Keywords: Anthropogenic infrastructure routinely interferes with wildlife movement, habitat use, and survival. Grouse in Greater sage-grouse the family Phasianidae may be particularly susceptible to collisions with fences due to their morphology and life Collisions history. Because many Phasianid species are of conservation concern, managers often deploy markers on fences Mortality to reduce collision-associated mortality. However, scarce information on the effectiveness of different marker Fence styles or the effects of local and landscape features on collision risk exists. Our objectives were to (1) determine Sagebrush the effectiveness of different marker styles in reducing collisions, (2) estimate the effects of local and landscape Tetraonid features on collision risk, and (3) evaluate an existing greater sage-grouse (Centrocercus urophasianus) collision risk model. We conducted greater sage-grouse collision surveys within Sublette County, Wyoming, USA in March and April of 2014 and 2015. Data were analyzed in a multi-scale occupancy model accounting for incomplete detection of collisions. We found substantial evidence for the ability of all markers to reduce collisions (~57% reduction), with little difference between the tested marker types. We found strong evidence for lower collision probabilities at fences with wood posts and on fences farther from leks. Our results also indicated a negative relationship between collision probabilities and the difference between fence and vegetation heights. We observed little evidence for differences in collision risk between areas defined as “high” or “moderate” risk in a pre- existing collision risk map. We recommend integrating fence marking into conservation practices requiring fencing, and prioritizing fence marking near leks in areas with greater fence exposure.

1. Introduction Phasianids which are thought to be susceptible to collisions with infrastructure due to their high wing loading, lekking behavior, and Anthropogenic infrastructure such as fences routinely interferes in afoveal retina (Bevanger 1994; Lisney et al. 2012; Sillman 1973). In the movements, habitat use, and survival of a wide variety of wildlife North America, Wolfe et al. (2007) found that 39.8% of lesser prairie- species (Bevanger 1994; Drewitt and Langston 2008; Linnell 2016). chicken (Tympanuchus pallidicinctus) mortality was caused by collision Unfortunately, the installation of human infrastructures, including with fences and, based on a subset of the same data set, Patten et al. fences, typically witnessed across landscapes of high-income nations is (2005) observed elevated mortality rates for female lesser prairie- now occurring in low-income countries as well (Bevanger 1994; Drewitt chickens where habitats were more fragmented by fences, power lines, and Langston 2008). The broad-scale erection of fencing has continued and roads. Similarly, greater sage-grouse (Centrocercus urophasianus; due to civil and political unrest throughout the world (Bevanger and hereafter, sage-grouse) collisions with fencing have been observed in Henriksen 1996; Hayward and Kerley 2009; Linnell 2016), the need for two studies in western North America (Christiansen, 2009, Stevens maintaining domesticated livestock within an enclosed area (Hayter et al. 2012a). In Europe, collisions with fences and power lines have 1939), the need to exclude undesired animals from certain parcels been observed for the western capercaillie (Tetrao urogallus), black (Bevanger and Henriksen 1996; Hayter 1939), or to maintain biodi- grouse (Tetrao tetrix), red grouse (Lagopus lagopus scoticus), and ptar- versity (Hayward and Kerley 2009; Linnell et al. 2016). migan (Lagopus spp.) (Baines and Summers 1997; Bevanger 1995; Catt Wildlife collisions with fencing represent a direct impact on the et al. 1994). Although the impact of this collision-associated mortality survival of individuals. Mortality associated with fence collisions has on populations is not particularly well understood, there is some evi- been well documented for numerous avian species, including the dence indicating infrastructure collisions may contribute substantially

⁎ Corresponding author. E-mail address: [email protected] (N.J. Van Lanen). http://dx.doi.org/10.1016/j.biocon.2017.06.030 Received 20 December 2016; Received in revised form 13 June 2017; Accepted 22 June 2017 0006-3207/ © 2017 Elsevier Ltd. All rights reserved. N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Fig. 1. Illustration of four treated segments of fence-line associated with a focal lek. to population declines in some species (Baines and Andrew 2003; organizations to provide significant financial and personnel resources Bevanger 1995; Moss et al. 2000; Smith and Dwyer 2016). to install them at extensive scales (Natural Resources Conservation The risk of wildlife collisions with fencing is likely impacted by a Service, 2015). This effort spurred one peer-reviewed study to evaluate variety of site and landscape-scale factors (Stevens et al. 2012a). Site the effectiveness of this practice. Stevens et al. (2012b) evaluated the factors may include the density and height of local vegetation, fence effectiveness of fence markers in reducing greater sage-grouse collisions height, type of fence, the type of fence posts, the distance between fence and found marked fences reduced collisions by 83%. Similarly, marking posts, the slope or ruggedness of the nearby landscape, and in the case fences reduced black grouse (91%) and capercaillie (64%) collisions of lekking species, the distance to surrounding leks and the number of (Baines and Andrew 2003). Although these studies have shown that individuals attending adjacent leks (Stevens et al. 2012a). Similarly, marking deer and stock fencing can reduce Phasianid collisions with landscape-scale factors may include surrounding landcover types fences, to date, no study has compared the efficacy of multiple marker (Baines and Summers 1997), the density of individuals throughout the types in reducing collisions, while accounting for imperfect detection, landscape (Baines and Andrew 2003), and movement corridors (in- and considering site- and landscape-level factors that may influence cluding prominent ridges or other vegetative or topographic features collision rates. Durability concerns of marker types in Europe under- that funnel animal movement) (Bevanger 1994; von Schweppenburg score the need for evaluating alternative marker styles (Baines and 1929). Andrew 2003). Additionally, few studies have empirically tested site- Marking human infrastructure to increase its visibility is a common and landscape-scale factors that may influence the risk of grouse col- practice for reducing collisions for a variety of avian species (Luzenski lisions with fencing. et al. 2016), including Phasianids due to their predisposition for col- Our research objectives were to 1) determine the effectiveness of liding with fences and the level of conservation concern regarding different fence marker types, 2) estimate the effects of site and land- several species within this subfamily (Baines and Andrew 2003; Stevens scape features on collision risk and 3) evaluate an existing greater sage- et al. 2012b). The growing application of fence markers to reduce grouse collision risk model. We evaluated the effectiveness of bright collisions has prompted government agencies and non-profit yellow FlySafe markers (FlySafe 2016), white markers with reflective

71 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Fig. 2. Photographs of fence marker types deployed in our study. From left to right the above images represent the Flysafe, reﬂective, and white marker treatments.

tape and white markers without reflective tape compared to unmarked (hereafter, we refer to randomly selected leks as “focal leks”) using fence using a dataset collected in western Wyoming where sage-grouse Generalized Random Tessellation Stratification (GRTS; Stevens and densities are high and leks are abundant. Additionally, we investigated Olsen 2004). We determined land ownership from the Sublette County site and landscape features to identify areas with high collision risk and Assessor's Office and requested permission to access the sampling units control for potentially confounding variables related to collision risk at in the rank order of the GRTS sample selection. When landowners de- multiple spatial scales. We evaluated an existing collision risk map nied permission, we selected the next highest rank order of the GRTS (Stevens et al. 2013) to determine if observed sage-grouse collisions sample selection. A useful feature of the GRTS design is the spatially were correlated with areas predicted to have high or moderate collision balanced property of the sample was maintained when private land- risk. owners denied permission to access the sampling units (Stevens and Olsen 2004). 2. Methods 2.3. Treatments 2.1. Study area Each of the four treatments was randomly applied to 500 m stret- Our study occurred on both private and public lands within Sublette ches of fencing within the selected sample units. Treatments were de- County, Wyoming, USA. Sublette County contains some of the highest fined as control (no marker), white (approximately 7.5 × 5 cm piece of sage-grouse population indices within the occupied range (United white undersill vinyl siding), reflective (white markers with a States Fish and Wildlife Service, USFWS 2010). It lies within Manage- 7.5 × 1.8 cm strip of lime-yellow Identi-Tape V97 high intensity re- ment Zone II as identified by Stiver et al. (2006). The county covers flective tape applied to each side), and Fly Safe markers (approximately approximately 3.2 million acres, of which, 80% is publicly owned. 12 × 9 cm yellow plastic markers) (FlySafe 2016)(Fig. 2). We selected Elevations within Sublette County range from 6280 ft to 13,400 ft the marker treatments because they are representative of the gamut of (Wyoming State Historical Society 2016). Lower elevations are largely treatments being implemented within the western U.S. to reduce sage- characterized as sagebrush steppe habitat with riparian corridors along grouse and lesser prairie-chicken collisions with fencing. For the 500 m the Green River and its tributaries. Dominant vegetation within the stretches receiving the white, reflective, or Fly Safe treatments, markers lower elevation sagebrush steppe largely consists of Wyoming big sa- were spaced approximately 1 m from fence-posts and other markers on gebrush (Artemesia tridentata ssp. wyomingensis) and basin big sagebrush the top wire of the fencing to be consistent with fence marking re- (Artemesia tridentate ssp. tridentata). Fencing within our study area commendations (United States Department of Agriculture, USDA 2016). largely consisted of three to four metal strands with barbs on all wires. The design with all three treatments and the control employed at each A small amount of fencing within our study area consisted of metal sampling unit corresponds to a repeated measures design with random woven wire fencing in which the bottom half of the fence consisted of order of the treatments levels (Morrison et al. 2008). both vertical and horizontal metal strands without barbs and forming rectangles 9 cm by 12 cm. Above the woven wires were typically one or 2.4. Sampling methods two single horizontal metal wire strands with barbs. A total of four observers trained in sage-grouse feather identification 2.2. Sampling design and possessing extensive biological survey experience conducted field work throughout the two year study. Observers were intensively trained We developed the sampling frame for Sublette County, Wyoming, to ensure they possessed a complete understanding of field protocols, a using the 3 km-radius collision risk polygons (Stevens et al. 2013) for sufficient ability to identify collision events, and could positively sage-grouse leks represented in the Wyoming Game and Fish Depart- identify sage-grouse remains. ment lek database (Christiansen 2012). We reclassified the high and Surveys were conducted approximately biweekly in March and moderate risk zones into a single collision risk category and omitted the April of 2014 and 2015. A survey of a site entailed either two or four low risk zone for each of the 308 lek polygons in Sublette County visits. The first visit consisted of an observer walking along the site's (Fig. 1) using a Geographic Information System (GIS; ArcGIS Version fence while scanning for evidence of animal collisions. The observer 10.0, ESRI 2011). Next, we intersected the combined high and mod- then crossed the fence and conducted the second visit by doubling back erate risk zones for the lek polygons with the Bureau of Land Man- and walking to the starting point of the first visit (Fig. 1). A survey agement (BLM) fence database (Bureau of Land Management - Pinedale consisted of four visits when a second observer, surveying separately Field Office, GIS Staff 2013). The sampling frame consisted of 77 lek from the first observer, visited the same site on the same day. Observers polygons containing a minimum of 2 km of fence within the combined did not discuss findings during the course of the surveys in order to high and moderate risk zone of the lek polygons. We defined the avoid influencing detection rates. sampling unit as the lek, which was represented by the 3 km-radius Observers maintained a distance of 1-2 m from the fence during collision risk polygon (Stevens et al. 2013). each visit. While surveying, observers primarily searched the wires of We selected a spatially balanced sample of 26 lek polygons the fence for signs of a collision. Additionally, observers scanned the

72 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Table 1 Covariates included in analyses of fence collisions by Greater Sage-Grouse in Wyoming, 2014–2015, and their expected effect on the parameter of interest (positive effect, +; negative effect, −). Parameters include large-scale occupancy (ψ), small-scale occupancy (θ), and detection probability (p). Means and ranges are shown for continuous covariates and levels and frequencies for the categorical covariates.

Covariate Description Parameter Means (ranges) and levels (frequencies) Expected eﬀect

Occ Lek Number of occupied leks within 3 km of the focal lek ψ 1.51 (0–3) + Lek Ct Sum of lek counts for leks within 3 km of focal lek ψ 72.88 (0–265) + Year Year in which survey was conducted ψ,θ 2014 (26), 2015 (25) N/A Trt Fence marker type θ Control (50), FlySafe (51), White (51), Risk of control > white > reflective > FlySafe Reflective (50) Mark Fence marked or not θ Control (50), Marked (152) Lower for marked Angle Angle (°) created by the triangle between the lek and end θ 16.34° (1°–120°) + of fence segment Distance Distance (km) between the midpoint of the fence segment θ 1.85 km (0.15 km–4.60 km) − and the nearest lek Near Ct Mean max male lek count for the nearest lek from 2014 to θ 54.63 (1–265) + 2015 Fence Exp Mean difference (cm) between the top strand of a fence θ 67.69 cm (26.67 cm–96.10 cm) + and the top of the surrounding vegetation Risk Percentage of the fence segment in high risk areas based θ 45.8% (0.0%–100.0%) + on Stevens et al. (2013) Post Type of posts used in a fence segment θ Wood (138), T-post (4), both (62) Risk of t-post > both > wood Surv Biweekly survey (primary) period in which survey was θ, p 1 (200), 2 (202), 3 (189), 4 (189), 5 None conducted (188), 6 (190), 7(186) Visit Visit (secondary period) in which survey took place p 1 (1019), 2 (1014), 3 (114), 4(112) None Obs Observer conducting the survey p A (432), B (226), C (525), D (1076) None Trap “Trap effects” for the 2nd and 4th visits to account for p 1st/3rd (1133), 2nd/4th (1126) Higher for 2nd/4th visits potential lack of independence between visits by the same observer Trap2 “Trap effects” accounting for whether a collision was p Non-detection (1135), detection (1080) Higher if previously detected detected or not on the 1st visit Cloud Cloud cover (%) p 46.1% (0.0%–100.0%) − Snow Snow cover (%) p 33.8% (0.0%–100.0%) + bushes and ground approximately 10 m out from either side of the fence were only included in analyses when species identification was possible for feathers or carcasses. Observers recorded ocular estimates of (i.e., diagnostic feathers found). average snow and cloud cover (0–100%) during the course of each survey. 2.5. Covariate data collection We considered a collision to have occurred when sage-grouse feathers were observed in the wires or barbs of a fence. We believe this We measured fence exposure by estimating the average height of represents a more accurate count of collisions as other experts have woody vegetation and the height of the top strand of fencing in cen- determined carcass recovery can be low due to scavenging (Stevens timeters for each panel. We then subtracted the height of the woody et al. 2011) and we believe wounded grouse may travel significant vegetation from the height of the top wire of fencing to obtain a value of distances after striking fences before they expire. Collisions were re- “fence exposure” in centimeters for the panel. If vegetation was taller corded on each visit during which they were observed. In the event that than the fence, fence exposure had a negative value. We measured these feathers were found on the fence at multiple locations between two values for six panels within each 500 m stretch. Values were calculated fence posts (the fencing between two fence-posts hereafter is referred to at the two panels representing the endpoints and systematically at four as a “panel”), the evidence was considered a single collision unless the additional locations at 100 m intervals along each fence segment. The largest gap between feathers on the wire exceeded the average wing- fence exposure values for each of the six panels per stretch were then span of a sage-grouse (Sibley 2000). Analyses did not include any evi- averaged to derive a single mean fence exposure value for the 500 m dence in a fence that may have resulted from perching, prey plucking, stretch. With assistance from BLM personnel, we also noted whether or preening events, which were generally characterized by a small posts within a fence segment were wood posts, metal t-posts, or a amount of feathers loosely affixed to the barbs of the fence and pri- combination of the two. marily distributed near a wooden post. Using ArcGIS 10.0 (ESRI) we calculated several covariates in- Observers thoroughly documented all collisions found via photo- cluding: 1) the number of occupied sage-grouse leks within 3 km of the graphs and written notes. Observers recorded collision locations with a focal lek, 2) the sum of mean maximum male lek counts in 2014 and hand-held Global Positioning System (GPS) unit. Additionally, ob- 2015 for all leks within 3 km of the fence segment midpoint, 3) the servers recorded the following information pertaining to the collision distance from the midpoint of each fence stretch to the nearest occupied evidence: the distance from the evidence on the fence to the nearest sage-grouse lek and the mean maximum male count for that lek from fence-post, the distance from the evidence on the fence to the nearest 2014 to 2015, 4) the proportion of each fence stretch that fell within the marker, the distance from the ground (or top of the snow layer, when high risk category of the collision risk map (Stevens et al. 2013), and 5) applicable) to the highest evidence on the fence, and the strand of wire the angle of exposure for each stretch of fence (i.e., the angle created by containing the collision evidence. Finally, the observers collected the the triangle between the ends of the fence segment and the associated following data to describe the collision site: the distance between the lek). two fence-posts for the panel containing the evidence, the mean height Lastly, observers estimated cloud cover during each survey and of the vegetation along the fence panel containing the collision evi- percent of the ground covered by snow to the nearest 10%. In 2014 dence, and the number of strands of wire on the panel of fencing con- observers recorded a single value for the average snow cover values taining the evidence. Photographs of feathers were sent to local experts surrounding each of the four fence segments during a survey. In 2015 if the field observers could not be sure of identification. Collision events observers recorded a separate value for average percentage of snow

73 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83 cover along each fence segment. For analyses, we calculated the mean we hypothesized that collision risk would be greater in lek polygons of the 2015 values for each survey to produce a single snow cover value with high numbers of occupied leks (Occ Lek) and with high lek counts consistent with the 2014 data. Table 1 summarizes all covariates in- (Lek Ct, Table 1). Stevens et al. (2012a, 2012b) measured the distance cluded in our models. between fence segments and leks to show that distribution and abundance of leks was related to collision risk at the site-scale. We measured 2.6. Model justification and hypotheses lek density and sage-grouse abundance within the 3-km2 radius lek buffers (28 km2) to evaluate the extent that lek distribution and We used the method of working hypotheses (Chamberlin 1965)to abundance influenced collision risk of lek polygons at the landscape evaluate alternate a priori hypotheses to understand how different scale. Because sage-grouse are known to move between leks on the marker types, site- and landscape-features and mapped collision zones landscape (Emmons and Braun 1984), we predicted that lek polygons affect sage-grouse fence collisions. We used the covariates in Table 1 to containing a greater number of leks and greater numbers of birds would represent hypotheses for the objectives and translated the hypotheses also have greater collision risk. If landscape measures of lek distribution into predictive models. We then used the predictive models to evaluate and abundance prove important, these covariates can be used to ac- relative strength of evidence for the alternate hypotheses in a model count for the dependence of the treatments within 3-km2 radius lek selection framework (Burnham and Anderson 2002). We predicted polygons using the repeated measures design. detection of sage-grouse collisions at the fence segments would be in- To evaluate an existing collision risk map by Stevens et al. (2013) complete, potentially biasing the measurement of effect sizes for the (objective 3), we predicted that collision risk would be greater along fence markers. Therefore, we evaluated several hypotheses for how fence segments in areas characterized by high risk than on fence observers and time occasions may influence the detectability of fence characterized by moderate risk (Risk, Table 1). Because the collision collisions. We predicted the detection of collisions would vary by ob- risk map was based on terrain ruggedness and distance to nearest lek server (Obs), time of the biweekly surveys (Surv), and repeated visits (Stevens et al. 2013), this hypothesis evaluates collision risk in response (Visits, Table 1). We accounted for potential non-independence of de- to moving farther from a lek with increasing topographic relief. tections when observers visited the fence segment twice on the same day using the Trap2 covariate (Table 1). In addition, we hypothesized 2.7. Statistical analyses that snow cover (Snow) and cloud (Cloud) cover may interfere with the ability to detect the signs of collision (Table 1). We developed a multi-scale occupancy model (Nichols et al. 2008) When evaluating the effectiveness of fence markers (objective 1), to estimate occupancy probabilities of collision evidence, and the fac- we predicted that collision risk would be lower on fence segments with tors influencing them at site- and fence-segment levels. The model al- markers than fence segments without markers (Mark, Table 1) since lowed estimation of three parameters that corresponded to each level in fence marking has been shown to reduce collision risk for grouse spe- the nested sampling design. We used repeat visits nested within each cies (Stevens et al. 2013). In addition, we hypothesized that collision survey to estimate detection, repeat surveys of fence segments nested risk would be lowest on fence segments with yellow Fly Safe markers, within a site (i.e., lek) to estimate small-scale occupancy (the prob- intermediate on segments with white markers with reflective tape, and ability of a collision occurring within a 500 m fence segment), and re- greatest on segments with white markers without reflective tape (Trt, plicate leks nested within the study area to estimate large-scale occu- Table 1). Because Phasianid species are known to see carotenoid-based pancy (the probability of a collision occurring within any of the four colors (Mougeot et al. 2007), we predicted the bright yellow Fly Safe fence segments associated with the focal lek). All analyses were con- markers would be more effective than white markers with reflective ducted using Program MARK (version 8.0; White and Burnham 1999) tape. We predicted white markers with reflective tape would be more via RMARK (version 2.1.14; Laake 2013). We defined our three general effective than white markers without reflective tape because reflective parameters as: (1) the probability that evidence of ≥1 new sage-grouse tape is thought to provide greater visibility for low light and snow collision was present on ≥1 fence segment at site i during any of the background conditions (Stevens et al. 2013). In addition, we hypothe- surveys, ψi, (2) the probability that evidence of ≥1 new collision was sized that fence segments with wood posts would be more effective in present at a fence segment during survey j, θij, and (3) the probability reducing collisions than fence segments with iron t-posts and fence that a new collision was detected on visit k, given the fence segment segments with both types (Post, Table 1) because wooden posts may be was occupied during survey j and visit k, pijk. The multi-scale occupancy more conspicuous than iron t-posts (Stevens et al. 2012a) and sage- model is well suited for the repeated measures design by allowing the grouse are known to avoid areas with vertical woody structure (Stiver investigation of covariates influencing occupancy at the large-scale et al. 2006). (i.e., collisions at any fence segment associated with a focal lek) as well We evaluated site- and landscape features to identify areas with as treatments effects on conditional occupancy at the small-scale (i.e., greater collision risk (objective 2) at multiple scales and to control for collisions at individual fence) while accounting for non-independence potentially confounding variables when evaluating the effectiveness of of fence segments within a lek. This is analogous to how variance is different marker types (Morrison et al. 2008). At the local scale, we estimated in a mixed model with a random effect on the focal lek hypothesized that collision risk would be higher on fence segments near (Pavlacky et al. 2012). We assumed fence segments were closed to active leks (Distance) and near leks with greater lek attendance (Near Ct, changes in occupancy within each survey and that new collisions were Table 1) as has been shown in previous research (Stevens et al. 2012b). accurately identified and recorded. The fence segments were allowed to In addition, we predicted that collision risk would be greater on fence be open between surveys. This model also assumes that detections are segments with greater fence exposure above vegetation and on fence independent; however, observers conducted the second visit on the segments (Fence Exp) with a larger “exposure angle” in relation to the opposite side of the fence immediately after the first visit. We attempted focal lek (Angle, Table 1). Stevens et al. (2012a) considered a variable to account for this potential lack of independence by estimating sepa- for the height difference between the fence and the nearest lateral rate detection probabilities for the first and second visits by the same shrub, but did not find strong evidence for this variable. Nevertheless, observer during a survey period along with whether a collision was we felt sage-grouse were more likely to fly above the vegetation than detected during the first visit. between it and greater fence exposure would therefore lead to greater collision risk. Given the positive association of collisions with lek counts 2.8. Model set and small lek distances, we hypothesized that birds needing to cross fencing to attend or leave a lek would have a higher risk of collision and To investigate our hypotheses regarding the factors influencing used the Angle covariate to test this hypothesis. At the landscape scale, large- and small-scale occupancy and detection, the models in our

74 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Table 2 containing the covariate in the model set. Weights ≫ 1 indicate support Model set for models explaining variation in detection probabilities (p) of Greater Sage- for the importance of that variable, weights near 1 are inconclusive, and Grouse fence collisions in Wyoming, 2014–2015. We fit models using the most general ≪ θ ψ weights 1 indicate little support for importance. We used the odds small- ( ) and large-scale ( ) occupancy probability model structures. Because two ff β covariates on each occupancy probability were different measures of similar hypotheses, ratio to express the e ect sizes ( ) in terms of the percentage increase in we included both model structures on each of those parameters. Covariates included to the odds of collision. explain variation in detection probabilities included: fixed visit effects (Visit), fixed ff fi ff “ ff ” survey e ects (Surv), xed observer e ects (Obs), trap e ects for the 2nd and 4th visits 3. Results (Trap), “trap effects” accounting for whether a collision was detected or not on the 1st visit (Trap.2), cloud cover (Cloud), and snow cover (Snow). Model structure on small- scale occupancy included: fence exposure (Fence Exp), proportion of fence segment in We found evidence of 64 confirmed fence collisions by sage-grouse high risk areas (Risk), angle of fence in relation to lek (Angle), Year, biweekly (primary) during the study, with 15 detected in 2014 and 49 detected in 2015. period (Surv), an interaction between post type and marker type (Post × Trt), and an Additionally, we observed 96 instances of possible or likely collisions interaction between distance to nearest lek and the count at that lek (Distance × Near which were not included in analyses. Over 60% of sites (16 of 26) and Ct). Model structures on large-scale occupancy included: Year and either the sum of lek ≥ counts at nearby leks (Lek Ct) or the number of nearby occupied leks (Occ Lek; indicated 26% of fence segments (27 of 104) contained evidence of 1 con- in ψ column). The number of parameters (npar), Akaike's Information Criterion adjusted firmed collision. Only two fence segments were constructed using t- ff for small sample size (AICc), di erence between a model's AICc value and the minimum posts exclusively, and no collisions were detected at those segments; Δ Δ ≤ AICc value ( AICc), and AICc weights are also shown for models with AICc 10. therefore, we fixed small-scale occupancy (θ) of those segments to zero to assist with numerical convergence. ψ p npar AICc ΔAICc Weight Our global models used in the sequential model selection, included Occ Lek Null 25 415.082 0.000 0.582 year and either the number of nearby occupied leks or the sum of the Lek Ct Null 25 416.051 0.969 0.358 lek counts at those leks effects on large-scale occupancy, ψ (Year + Occ Occ Lek Snow 26 423.116 8.034 0.010 ψ Occ Lek Surv 26 423.388 8.306 0.009 Lek) or (Year + Lek Ct); year, survey, treatment × post type, dis- Occ Lek Cloud 26 423.572 8.490 0.008 tance to nearest lek × count for nearest lek, fence angle to lek, pro- Occ Lek Trap.2 26 423.582 8.500 0.008 portion in high risk areas, and fence exposure effects on small-scale Lek Ct snow 26 424.084 9.002 0.006 occupancy, θ (Year + Surv + Distance + Angle + Risk + Fence Exp Lek Ct surv 26 424.358 9.275 0.006 + Post × Trt + Distance × Near Ct); and observer, cloud cover, snow Lek Ct cloud 26 424.541 9.459 0.005 ff Lek Ct trap.2 26 424.551 9.469 0.005 cover, and visit e ects on detection, p (Obs + Cloud + Snow + Visit).

3.1. Detection probabilities model set consisted of various combinations of covariates on each ψ parameter. We included 3 covariates on large-scale occupancy ( ), 10 Using these two global models, we explored 40 other detection θ on small-scale occupancy ( ), and 7 on detection (p; Table 1). We also structures, representing simplifications of our general detection struc- included interactions between post type and marker, as well as ture (Tables 2 and A1). The most parsimonious model included a con- minimum distance to the nearest lek and maximum male count for that stant detection probability (w = 0.59), as did the 2nd best model, cu- θ lek on . Because the model set was very large when considering all mulatively accounting for 95.4% of the weight; thus, we retained this possible combinations of covariates, we used a sequential approach to detection structure, p (.), in our subsequent models. We estimated the fi model selection (Lebreton et al. 1992). We t models that included all probability of detecting ≥1 collision at 0.935 (SE = 0.026). possible additive combinations of covariates on detection, while in- ff ψ cluding additive e ects for all covariates for large- ( ) and small-scale 3.2. Large-scale occupancy (θ) occupancy. There were two covariates on large-scale occupancy that ff were di erent measures of the same hypothesis: (1) the number of Large-scale occupancy of collisions increased as the sum of nearby occupied leks within 3 km of the focal lek (Occ Lek, Table 1) and (2) the lek counts increased and was higher in 2015. However, the 95% con- sum of the lek counts for leks within 3 km of the focal lek (Lek Ct). We fidence intervals for both of these effects included zero. Because of this fi did not include both covariates in the same model. Therefore, we ta uncertainty, the most parsimonious model for ψ was the constant global model containing all other additive combinations of covariates model, which accounted for a majority of the AICc weight (w = 0.85) with Occ Lek and Lek Ct. separately, resulting in two global models. (Table 3). On average, large-scale occupancy was estimated to be 0.717 Then, using the most parsimonious detection structure(s), we evaluated hypotheses related to large-scale occupancy. Retaining the best large- Table 3 scale occupancy model structure(s), we fit models that included all Model set for models explaining variation in large-scale occupancy probabilities (ψ)of possible combinations of covariates thought to influence small-scale Greater Sage-Grouse fence collisions in Wyoming, 2014–2015. We fit models using the occupancy, including the two interaction terms. most parsimonious model on detection probabilities (i.e., null) and the global model θ We used an information-theoretic approach for model selection and structure on small-scale occupancy probabilities ( ). Model structures on large-scale occupancy included: Year and either the sum of counts at leks with 3 km (Lek Ct) or the used Akaike's Information Criterion (AIC) adjusted for sample size number of occupied leks within 3 km (Occ Lek; indicated in ψ column). Model structure (AICc) for model comparison (Burnham and Anderson 2002). We used on small-scale occupancy included: fence exposure (Fence Exp), proportion of fence Akaike weights, wi, as a measure of the relative amount of evidence for segment in high risk areas (Risk), angle of fence in relation to lek (Angle), Year, biweekly each model. Our model set for small-scale occupancy was not balanced (primary) period (Surv), an interaction between post type and marker type (Post × Trt), and an interaction between distance to nearest lek and the count at that lek because of the interaction terms and mutually exclusive covariates (i.e., (Distance × Near Ct). We also include the number of parameters (npar), Akaike's fi Mark and Trt), so we used a modi ed version of cumulative weights Information Criterion adjusted for small sample size (AICc), difference between a model's Δ based on the frequency of the covariate in the model set [w+(j)] AICc value and the minimum AICc value ( AICc), and AICc weights. (Doherty et al. 2012) to determine the relative importance of our ψ Δ covariates, npar AICc AICc Weight Null 23 402.913 0.000 0.852 w f Lek Ct 24 408.447 5.534 0.054 w ()j = ⎡ ⎤ ⎡ ⎤, + Year 24 408.498 5.585 0.052 ⎣11− w ⎦ ⎣⎢ − f ⎦⎥ Occ Lek 24 409.084 6.171 0.039 Year + Occ Lek 25 415.082 12.170 0.002 where w is the cumulative Akaike weight (sum of Akaike weights for Year + Lek Ct 25 416.051 13.139 0.001 models containing the covariate) and f is the frequency of models

75 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Table 4 Table 5

Cumulative AICc model weights for variables thought to inﬂuence small- Model set for models explaining variation in small-scale occupancy probabilities (θ)of scale occupancy (θ) of greater sage-grouse fence collisions in Wyoming, Greater Sage-Grouse fence collisions in Wyoming, 2014–2015. We ﬁt models using the 2014–2015. Cumulative weights were adjusted based on the frequency of most parsimonious model on detection probabilities (i.e., null) and large-scale occupancy the covariate in the model set (Doherty et al. 2012). Variables included in probabilities (i.e., null). Model structures on small-scale occupancy included: distance to the model set are: fence exposure (Fence Exp), proportion of fence seg- nearest lek (Distance), the count at the nearest lek (Near Ct), fence exposure (Fence Exp), ment in high risk areas (Risk), angle of fence in relation to lek (Angle), wood post or t-post (Post), proportion of fence segment in high risk areas (Risk), angle of Year, biweekly (primary) period (Surv), wood post or wood and t-post fence in relation to lek (Angle), marker type (Trt), marked or unmarked fence (regardless (Post), marker type (Trt), whether a fence was marked or unmarked of marker type; Mark), Year, biweekly (primary) period (Surv), an interaction between (regardless of marker type; Mark), the distance to the nearest occupied Distance and Near Ct, and an interaction between Post and Mark or Trt. The number of

lek (Distance), the count at the nearest lek (Near Ct), an interaction parameters (npar), Akaike's Information Criterion adjusted for small sample size (AICc),

between post type and marker type (Post × Trt), an interaction between diﬀerence between a model's AICc value and the minimum AICc value (ΔAICc), and AICc post type and whether a fence was marked (Post × Mark), and an in- weights are also shown for the top 10 models. teraction between distance to nearest lek and the count at that lek

(Distance × Near Ct). Modiﬁed cumulative model weights ≫ 1 suggest θ npar AICc ΔAICc Weight strong support for that variable, weights near 1 are ambiguous, and weights ≪ 1 suggest little support for that variable. Fence Exp + Mark + Distance + Post 9 364.644 0.000 0.030 + Risk + Near Ct Variable Cumulative weight Fence Exp + Mark + Distance + Post 9 364.756 0.111 0.028 + Risk + Year Post 12.797 Fence Exp + Mark + Distance + Post 10 364.903 0.259 0.026 Mark 4.188 + Risk + Year + Near Ct Distance 3.349 Fence Exp + Mark + Post + Risk 10 365.270 0.626 0.022 Fence Exp 1.699 + Distance × Near Ct Year 1.261 Surv + Fence Exp + Mark + Distance 15 365.647 1.003 0.018 Risk 1.246 + Post + Risk + Year Near Ct 1.078 Fence Exp + Mark + Distance + Post 8 365.762 1.118 0.017 Post × Mark 0.908 + Near Ct Surv 0.790 Fence Exp + Mark + Post + Risk + Year 11 365.794 1.150 0.017 Distance × Near Ct 0.658 + Distance × Near Ct Angle 0.476 Surv + Fence Exp + Mark + Distance 14 365.810 1.166 0.017 Trt 0.065 + Post + Year Post × Trt 0.001 Fence Exp + Mark + Distance + Post 9 365.998 1.354 0.015 + Year + Near Ct Fence Exp + Mark + Distance + Post + Risk 8 366.015 1.371 0.015 (SE = 0.127).

3.3. Small-scale occupancy Table 6 Coefficient estimates, standard errors (SE), and 95% confidence intervals (CI) for all variables explaining variation in small-scale occupancy (θ) probabilities of Greater Sage- We found strong evidence for effects of post type [w+(Post) Grouse fence collisioins in Wyoming, 2014–2015. Variables include fence exposure, = 12.80], whether a fence was marked or not [irrespective or marker whether a fence was marked (regardless of marker type; Mark), the distance to nearest lek (Distance), fences with wood and t-posts (wood and t-post), proportion of fence segment type, w+(Mark) = 4.19], and distance to the nearest lek [w+(Distance) in high risk areas (Risk), year (2015), and the count at the nearest lek (Near Ct). The = 3.35] on small-scale occupancy (Tables 4, 5, and A2). There was intercept represents an unmarked fence with wood posts in 2014 with all continuous some support for the effects of fence exposure [w (Fence Exp) = 1.70], + variable values set to 0. Variables included had modified cumulative AICc weights > 1. year [w+(Year) = 1.26], the amount of fence segment within the high Estimates from the third best model are reported because it is the best model including all variables with cumulative weights > 1. All significant coefficients (i.e., 95% CIs do no risk areas based on Stevens et al. (2013) [w+(Risk) = 1.25], and the overlap 0) are indicated by an asterisk. count at the nearest lek [w+(Near Ct) = 1.08; Tables 4 and A2]. Con- sistent with our hypotheses, wood posts, fence marking, and increasing Parameter Mean SE 95% CI distance to nearest lek resulted in lower collision occupancy probabilities (Tables 6, A3, and A4 and Fig. 3). The amount of fence ex- Intercept* −5.544 1.123 (−7.745, −3.342) posure and the proportion of fence in high risk areas increased the Fence Exp* 0.031 0.013 (0.005, 0.058) Mark* −0.843 0.358 (−1.545, −0.141) probability of a collision, as we predicted. Occupancy probabilities Distance* −0.586 0.192 (−0.962, −0.210) were higher in 2015 and as the count at the nearest lek increased, Wood and T-post* 1.774 0.382 (1.025, 2.523) though these coefficients were not significant (Table 6). All marker Risk* 1.150 0.565 (0.042, 2.258) types performed similarly [β= −0.843,(95% CI = −1.545, −0.141); 2015 0.821 0.473 (−0.105, 1.747) − odds ratio: 0.430, (0.128, 0.732)], with reflective [β= −1.018,(95% Near Ct 0.004 0.002 ( 0.001, 0.009) CI = −1.967, −0.068); odds ratio: 0.361, (0.018, 0.705)] and white β − − markers [ = 0.808, ( 1.703, 0.087); odds ratio: 0.446, (0.047, accounting for imperfect detection of collisions, this approach allowed 0.857)] reducing occupancy probabilities slightly more than Fly Safe us to account for the lack of independence between fence segments β − − markers [ = 0.725, ( 1.634, 0.184); odds ratio: 0.484, (0.044, associated with a particular lek (Nichols et al. 2008; Pavlacky et al. 0.924)] based on the model including treatment and all other covariates 2012). with cumulative weights > 1. Studies regarding potential risk of collision with human-associated infrastructure have noted that risks to lekking species may be higher in 4. Discussion close proximity to lek locations (Baines and Summers 1997; Bevanger 1994; Stevens et al. 2012a, 2012b). Therefore, we tested four hy- We adapted the multi-scale occupancy framework to investigate potheses relating to the risk of collision in association to the number of fl landscape- and local-scale features in uencing the probability of fence leks, the number of individuals observed at nearby leks, the position of collision, and our results support the anecdotal and limited empirical fencing (angle) in relation to a nearby lek, and the distance to the evidence for the threat of fences to sage-grouse (Christiansen 2009; nearest lek. Unlike Stevens et al. (2012a), we found little evidence for Flake et al. 2010; Scott 1942; Stevens et al. 2012a, 2012b). Our study an effect of the number of birds using nearby leks on collision prob- fl also provided insight into the factors in uencing fence collisions at two abilities and therefore failed to confirm our hypothesis. Similarly, there spatial scales by using a multi-scale occupancy model. In addition to

76 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Fig. 3. Small-scale occupancy probability (θ, heavy lines) and associated 95% conﬁdence intervals (light lines) as a function of distance to nearest lek for a) unmarked, wood post, b) unmarked, wood and t-post, c) marked, wood post, and d) marked, wood and t-post fence segments.

was no evidence to support an increased risk of collision near fence- This relationship is likely due to increased encounters between birds lines that are near multiple leks. Baines and Andrew (2003) similarly and fences when a fence is closer to an area where birds congregate. We found no effect of lek indices on collision risk indicating that other therefore recommend that marking efforts preferentially mark fence factors may be more predicitive. Our findings may be partially due to close to leks in the future. Additionally, we encourage future studies using presence-absence data to detect differences among leks of various investigating risks of collisions with human-related infrastructure to sizes, such that the probability of ≥1 collision is high for a fence near consider accounting for water and/or food sources, geophagy sites, or even a single smaller lek. Addtionally, lek counts have been criticized other features that may lure large numbers of individuals into a loca- for their inability to accurately reflect abundance of sage-grouse (Beck lized area. and Braun 1980; Johnson and Rowland 2007; Walsh et al. 2004) but As in Stevens et al. (2012a), our results suggest that fence post type have been shown to be a reasonable index of the population of breeding has the largest effect on the occupancy probability of sage-grouse col- males when standard survey protocols are followed (Jenni and Hartzler lisions, with the lowest occupancy probabilities for fence segments with 1978; Emmons and Braun 1984; Walsh et al. 2004; Johnson and wooden posts, which confirmed our hypothesis. Only two fence seg- Rowland 2007). However, lek counts may not accurately represent the ments in our study had t-posts exclusively and neither of those segments number of birds in the area surrounding a lek, and therefore, may be a had evidence of a collision on them; therefore, we were unable to es- poor indicator of the likelihood of a collision. We therefore recommend timate occupancy probabilities for segments with only t-posts. Un- that future efforts to estimate or account for collision risk use estimated marked fence segments with wooden posts had lower occupancy densities when possible. probabilities than segments with both wooden and t-posts and any of Although there is an abundance of peer-reviewed work indicating the fence markers; yet, collision rates for fence segments with wooden that flight paths may greatly increase the risk of bird collisions with posts were reduced further by the use of fence markers. These results human infrastructure (Bevanger 1994; Bevanger 1998; Everaert and are consistent with those found by Summers and Dugan (2001),in Stienen 2007; Henderson et al. 1996; Scott et al. 1972), we found no which, they found full length paling (which resemble wooden posts) to evidence for increased collision risk with an increased angle of fence be the most visible fence marker. As such, we recommend future exposure in relation to the lek which failed to confirm our hypothesis. It marking efforts consider testing the effectiveness of wooden stays is possible this covariate was confounded with the distance to the woven into the fencing. Additionally, preferentially marking fencing nearest lek (closer distances having a larger angle) which we tested and with t-posts or a mixture of wood and t-posts could maximize the re- describe in the following text. Nevertheless, we maintain that flight duction in potential Phasianid collisions with fencing as our results in- paths may be important in determining collision risk for some systems dicated fences without wooden posts may have high rates of collisions. and species and encourage researchers to consider other potential ve- We found a small effect of the amount of exposed fencing on col- getative, topographical, biological, and environmental factors that may lision risk. As vegetation height near a fence decreased, the probability influence or create flight paths in future studies. of a collision increased which supported our hypothesis. Phasianids are We found the proximity of a fence segment to a lek influenced the generally classified as “poor flyers” (Bevanger 1994; Rayner 1988) probability of a collision (Distance); the average occupancy probability which characteristically engage in short flights (Viscor and Fuster decreased by approximately 39% between distances of 153 m (i.e., 1987). These morphological constraints likely result in Phasianids en- smallest distance observed) and 1 km. This is consistent with the find- gaging in proportionately more of their flight at low altitudes, often ings of Stevens et al. (2012a, 2012b) and confirmed our hypothesis. near the top of exposed vegetation, than many birds with lower wing

77 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83 loading. As the top of vegetation approaches or exceeds the top of markers. The smaller effect observed in our study may be due in part to human infrastructure there is thought to be less risk of collisions less resolution to detect covariate effects when using occupancy models (Bevanger 1994). Although we observed a weak relationship between compared to abundance measures because counts are summarized to the amount of exposed fence and collision risk, we maintain areas with presence or absence. In addition, the smaller effect observed in our short vegetation may benefit more from the use of markers by making study may be partially related to accounting for incomplete detection of the fence more visible. Similarly, we suggest that taller “elk fences” in sage-grouse collisions, despite detection being quite high. The collision the western U.S. and “deer fences” in Europe may increase collision risk reduction estimated in our study aligns well with the estimated 64% beyond that of stock fencing due to the potential for additional fence reduction for capercaillie, 91% reduction for black grouse, and 49% projection above the vegetation as well as a general increase in total reduction for red grouse estimated by Baines and Andrew (2003). fence area. This idea was not explicitly tested in our study and re- Overall, we found little difference in the effectiveness of the three presents an area for future research. marker types, as models with a marker effect (for any marker type) had

Our study design was largely based on the collision risk map de- substantially more cumulative AICc weight than models with effects for veloped by Stevens et al. (2013) which predicted high risk of collisions all marker types individually. However, contrary to our hypothesis, Fly in areas close to leks and with little topography. The authors ac- Safe markers were slightly less effective than both white and reflective knowledged their range-wide model was created using data collected markers. We estimated average per marker costs for white markers at within a relatively small geographic area in Idaho. As such, they re- $0.14, reflective markers at $0.71, and Fly Safe markers at $0.40 (USD). commended additional validation efforts be conducted. Our findings Therefore, using the plain white markers without reflective tape, may suggested a slightly increased collision probability in high risk areas, represent the most cost-effective sage-grouse marking strategy of those but this effect was weak. Because we attempted to select fence-line we tested. In Europe, the only study to our knowledge, which in- segments within the high and moderate risk areas of this map, much of vestigated marker utility in preventing Phasianid collisions employed the fence-line included in our study fell within these areas. Therefore, two strips of orange plastic netting on the fence (Baines and Andrew low risk areas were not well represented in our study, precluding an 2003). The authors acknowledged that, although effective in reducing evaluation of the low risk portions of the risk map. We recommend collisions within woodlands, this marker style was not suitable for de- further investigation of the efficacy of the collision risk map in pre- ployment in areas exposed to weather (i.e., open moorland), where red dicting collision risk, particularly to determine if greater slopes asso- grouse densities may be high. We witnessed very little damage to the ciated with topography do impact collision risk range-wide and to de- three types of markers we deployed and therefore recommend trials termine if low risk areas on the collision risk map have a lower number using these marker types in open habitats of Europe. of associated fence collisions. Until the collision risk map can be eval- The effectiveness of the fence markers in reducing Phasianid colli- uated further, we recommend that managers seeking to reduce sage- sions highlights the importance of integrating fence marking into on- grouse collisions focus their fence-marking efforts on fence-lines in both going conservation efforts. Prescribed grazing is often recommended to the high and moderate risk zones which are both close to leks and improve nesting and wintering habitat conditions for lekking-species of possess local site characteristics which have been shown to increase conservation concern such as the greater-sage-grouse (Monroe et al. in collision risk in our study and/or in previous studies. review) and lesser prairie-chicken (Hagen et al. 2016). Because the We estimated a detection rate of 0.94, suggesting a false absence implementation of rotational grazing systems involves additional fen- rate of 6% in the raw collision data. Our detection rate was similar to cing to subdivide an area into several pastures (United States Fish and the collision detection rate calculated by Baines and Andrew (2003) Wildlife Service, USFWS 2010), we recommend marking exposed fence when they simulated collision events with grouse carcasses. This in- near leks even in areas thought to have only moderate collision risk due dicates that detection of collision events is likely quite high when to topography. We suggest fence marking may reduce the potential for conducting walking surveys, provided that evidence of the collision still ecological traps (Battin 2004) associated with conservation practices persists on the landscape. Stevens et al. (2011) calculated much lower that require the creation of additional fencing. detection rates when conducting walking surveys within 15 m of bird carcasses which were placed in the field; however, their estimates ac- Acknowledgments counted for both detectability and scavenging bias. We suspect the scavenging bias was the driving factor in the reduced detection rates; This project was funded entirely through a Conservation Innovation however, they also placed carcasses beyond the search window of both Grant (69-3A75-12-188, 2012) provided through the USDA Natural our study and that of Baines and Andrews (both, of which had an ef- Resources Conservation Service (NRCS). We thank Tom Christiansen of fective search strip width of approximately 5 m). Furthermore, Stevens the Wyoming Game and Fish Department for sharing his expertise on et al. placed piles of feathers and the carcasses within the habitat greater sage-grouse feather identification, identifying evidence of col- whereas in the Baines and Andrews study the carcasses were “vigor- lisions on fencing, and survey methodology. Dale Woolwine of the ously thrown at the fence to simulate flight collisions”. Given that we Wyoming Bureau of Land Management provided the fence layer sha- regularly witnessed feathers widely strewn across areas of 30 m or more pefiles used for sample selection, advice regarding survey methods, in our study, we feel the methods used by Stevens et al. (2011) may not assistance with covariate data collection used in analysis, and was in- have accurately created conditions similar to that of an actual collision strumental in assisting with field logistics and access to survey sites. We event, ultimately underestimating detection probabilities of Phasianid thank Tony Mong of Wyoming Game and Fish Department for pro- collision evidence. viding greater sage-grouse lek data used in analyses. We greatly ap- Our results suggest that all three types of fence markers employed in preciate Bird Conservancy staff, as well as their families and friends, for our research were effective at reducing collision probabilities and helping to add the reflective tape to the vinyl markers. We appreciate confirmed our hypothesis, with stretches of marked fence having a 57% the efforts of David Kramer, Jenny Berven, Eric DeFonso, as well as (27% - 87%) lower probability of containing ≥1 collision. These results Meghann Durbrow and her NRCS staff for their assistance installing align with previous studies by Stevens et al. (2012b) and Baines and fence markers. Additionally, Jenny Berven created maps of the study Andrew (2003) which found marking fences reduced Phasianid colli- sites and Brittany Woiderski provided GIS support to measure spatial sions with fencing. Our results provided weak evidence that reflective covariates. We would like to acknowledge Galen Reid who volunteered markers were the most effective marker type in our study, with a 64% his time to collect data during the 2014 field season. We also thank field (30%–98%) reduction in collision probability. Stevens et al. (2012b) technicians Angela Stemen (2014) and Josh Olsen (2015) for their ef- saw an 83% reduction in sage-grouse collisions using reflective forts collecting data in the field.

78 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Appendix A

Table A1 Model set for models explaining variation in detection probabilities (p) of Greater Sage-Grouse fence collisions in Wyoming, 2014–2015. We fit models using the most general small- (θ) and large-scale (ψ) occupancy probability model structures. Because two covariates on each occupancy probability were different measures of similar hypotheses, we included both model structures on each of those parameters. Covariates included to explain variation in detection probabilities included: fixed visit effects (Visit), fixed survey effects (Surv), fixed observer effects (Obs), “trap effects” for the 2nd and 4th visits (Trap), “trap effects” accounting for whether a collision was detected or not on the 1st visit (Trap.2), cloud cover (Cloud), and snow cover (Snow). Model structure on small-scale occupancy included: fence exposure (Fence Exp), proportion of fence segment in high risk areas (Risk), angle of fence in relation to lek (Angle), Year, biweekly (primary) period (Surv), an interaction between post type and marker type (Post × Trt), and an interaction between distance to nearest lek and the count at that lek (Distance × Near Ct). Model structures on large-scale occupancy included: Year and either the sum of lek counts at nearby leks (Lek Ct) or the number of nearby occupied leks (Occ

Lek; indicated in ψ column). The number of parameters (npar), Akaike's Information Criterion adjusted for small sample size (AICc), diﬀerence between a model's AICc value and the minimum AICc value (ΔAICc), and AICc weights are included.

ψ p npar AICc ΔAICc Weight

Occ Lek Null 25 415.082 0.000 0.582 Lek Ct Null 25 416.051 0.969 0.358 Occ Lek Snow 26 423.116 8.034 0.010 Occ Lek Surv 26 423.388 8.306 0.009 Occ Lek Cloud 26 423.572 8.490 0.008 Occ Lek Trap2 26 423.582 8.500 0.008 Lek Ct Snow 26 424.084 9.002 0.006 Lek Ct Surv 26 424.358 9.275 0.006 Lek Ct Cloud 26 424.541 9.459 0.005 Lek Ct Trap2 26 424.551 9.469 0.005 Occ Lek Surv + Snow 27 432.197 17.115 < 0.001 Occ Lek Cloud + Snow 27 432.347 17.265 < 0.001 Occ Lek Snow + Trap2 27 432.355 17.273 < 0.001 Occ Lek Surv + Cloud 27 432.568 17.486 < 0.001 Occ Lek Surv + Trap2 27 432.627 17.545 < 0.001 Occ Lek Trap 27 432.720 17.637 < 0.001 Occ Lek Cloud + Trap2 27 432.811 17.729 < 0.001 Lek Ct Surv + Snow 27 433.166 18.084 < 0.001 Lek Ct Cloud + Snow 27 433.315 18.233 < 0.001 Lek Ct Snow + Trap2 27 433.323 18.241 < 0.001 Lek Ct Surv + Cloud 27 433.537 18.455 < 0.001 Lek Ct Surv + Trap2 27 433.597 18.514 < 0.001 Lek Ct Trap 27 433.688 18.606 < 0.001 Lek Ct Cloud + Trap2 27 433.780 18.698 < 0.001 Occ Lek Obs 28 439.208 24.126 < 0.001 Lek Ct Obs 28 440.177 25.095 < 0.001 Occ Lek Visit 28 440.748 25.665 < 0.001 Lek Ct Visit 28 441.716 26.633 < 0.001 Occ Lek Surv + Cloud + Snow 28 442.205 27.123 < 0.001 Occ Lek Surv + Snow + Trap2 28 442.276 27.194 < 0.001 Occ Lek Snow + Trap 28 442.373 27.290 < 0.001 Occ Lek Cloud + Snow + Trap2 28 442.426 27.344 < 0.001 Occ Lek Surv + Trap 28 442.621 27.538 < 0.001 Occ Lek Surv + Cloud + Trap2 28 442.647 27.565 < 0.001 Occ Lek Cloud + Trap 28 442.789 27.707 < 0.001 Lek Ct Surv + Cloud + Snow 28 443.173 28.091 < 0.001 Lek Ct Surv + Snow + Trap2 28 443.245 28.163 < 0.001 Lek Ct Snow + Trap 28 443.342 28.260 < 0.001 Lek Ct Cloud + Snow + Trap2 28 443.394 28.312 < 0.001 Lek Ct Surv + Trap 28 443.589 28.507 < 0.001 Lek Ct Surv + Cloud + Trap2 28 443.616 28.534 < 0.001 Lek Ct Cloud + Trap 28 443.758 28.676 < 0.001 Occ Lek Snow + Obs 29 449.910 34.828 < 0.001 Occ Lek Cloud + Obs 29 450.240 35.158 < 0.001 Occ Lek Surv + Obs 29 450.246 35.164 < 0.001 Lek Ct Snow + Obs 29 450.877 35.795 < 0.001 Lek Ct Cloud + Obs 29 451.208 36.126 < 0.001 Lek Ct Surv + Obs 29 451.215 36.133 < 0.001 Occ Lek Visit + Snow 29 451.315 36.233 < 0.001 Occ Lek Visit + Surv 29 451.656 36.573 < 0.001 Occ Lek Visit + Cloud 29 451.786 36.704 < 0.001 Occ Lek Visit + Trap2 29 451.786 36.704 < 0.001 Lek Ct Visit + Snow 29 452.283 37.200 < 0.001

79 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Lek Ct Visit + Surv 29 452.624 37.542 < 0.001 Lek Ct Visit + Cloud 29 452.754 37.672 < 0.001 Lek Ct Visit + Trap2 29 452.755 37.672 < 0.001 Occ Lek Surv + Cloud + Snow + Trap2 29 453.244 38.162 < 0.001 Occ Lek Surv + Snow + Trap 29 453.256 38.173 < 0.001 Occ Lek Cloud + Snow + Trap 29 453.403 38.320 < 0.001 Occ Lek Surv + Cloud + Trap 29 453.607 38.525 < 0.001 Lek Ct Surv + Cloud + Snow + Trap2 29 454.212 39.130 < 0.001 Lek Ct Surv + Snow + Trap 29 454.225 39.143 < 0.001 Lek Ct Cloud + Snow + Trap 29 454.372 39.290 < 0.001 Lek Ct Surv + Cloud + Trap 29 454.576 39.494 < 0.001 Occ Lek Surv + Snow + Obs 30 462.022 46.940 < 0.001 Occ Lek Cloud + Snow + Obs 30 462.034 46.951 < 0.001 Occ Lek Surv + Cloud + Obs 30 462.383 47.300 < 0.001 Lek Ct Surv + Snow + Obs 30 462.989 47.907 < 0.001 Lek Ct Cloud + Snow + Obs 30 463.000 47.917 < 0.001 Lek Ct Surv + Cloud + Obs 30 463.351 48.269 < 0.001 Occ Lek Visit + Surv + Snow 30 463.354 48.271 < 0.001 Occ Lek Visit + Cloud + Snow 30 463.458 48.376 < 0.001 Occ Lek Visit + Snow + Trap2 30 463.458 48.376 < 0.001 Occ Lek Visit + Trap 30 463.600 48.517 < 0.001 Occ Lek Visit + Surv + Cloud 30 463.780 48.698 < 0.001 Occ Lek Visit + Surv + Trap2 30 463.799 48.716 < 0.001 Occ Lek Visit + Cloud + Trap2 30 463.929 48.847 < 0.001 Lek Ct Visit + Surv + Snow 30 464.321 49.239 < 0.001 Lek Ct Visit + Cloud + Snow 30 464.425 49.343 < 0.001 Lek Ct Visit + Snow + Trap2 30 464.425 49.343 < 0.001 Lek Ct Visit + Trap 30 464.567 49.485 < 0.001 Lek Ct Visit + Surv + Cloud 30 464.748 49.666 < 0.001 Lek Ct Visit + Surv + Trap2 30 464.767 49.685 < 0.001 Lek Ct Visit + Cloud + Trap2 30 464.897 49.815 < 0.001 Occ Lek Surv + Cloud + Snow + Trap 30 465.335 50.252 < 0.001 Lek Ct Surv + Cloud + Snow + Trap 30 466.304 51.222 < 0.001 Occ Lek Visit + Obs 31 474.083 59.000 < 0.001 Lek Ct Visit + Obs 31 475.051 59.969 < 0.001 Occ Lek Surv + Cloud + Snow + Obs 31 475.438 60.355 < 0.001 Lek Ct Surv + Cloud + Snow + Obs 31 476.404 61.322 < 0.001 Occ Lek Visit + Snow + Trap 31 476.629 61.547 < 0.001 Occ Lek Visit + Surv + Cloud + Snow 31 476.755 61.673 < 0.001 Occ Lek Visit + Surv + Snow + Trap2 31 476.775 61.692 < 0.001 Occ Lek Visit + Cloud + Snow + Trap2 31 476.879 61.797 < 0.001 Occ Lek Visit + Surv + Trap 31 476.984 61.902 < 0.001 Occ Lek Visit + Cloud + Trap 31 477.020 61.938 < 0.001 Occ Lek Visit + Surv + Cloud + Trap2 31 477.201 62.119 < 0.001 Lek Ct Visit + Snow + Trap 31 477.597 62.515 < 0.001 Lek Ct Visit + Surv + Cloud + Snow 31 477.723 62.641 < 0.001 Lek Ct Visit + Surv + Snow + Trap2 31 477.742 62.660 < 0.001 Lek Ct Visit + Cloud + Snow + Trap2 31 477.846 62.764 < 0.001 Lek Ct Visit + Surv + Trap 31 477.952 62.870 < 0.001 Lek Ct Visit + Cloud + Trap 31 477.988 62.906 < 0.001 Lek Ct Visit + Surv + Cloud + Trap2 31 478.169 63.087 < 0.001 Occ Lek Visit + Snow + Obs 32 488.636 73.554 < 0.001 Occ Lek Visit + Cloud + Obs 32 488.987 73.905 < 0.001 Occ Lek Visit + Surv + Obs 32 488.994 73.912 < 0.001 Lek Ct Visit + Snow + Obs 32 489.603 74.521 < 0.001 Lek Ct Visit + Cloud + Obs 32 489.955 74.873 < 0.001 Lek Ct Visit + Surv + Obs 32 489.962 74.880 < 0.001 Occ Lek Visit + Surv + Snow + Trap 32 491.496 76.413 < 0.001 Occ Lek Visit + Cloud + Snow + Trap 32 491.542 76.459 < 0.001 Occ Lek Visit + Surv + Cloud + Trap 32 491.893 76.811 < 0.001 Lek Ct Visit + Surv + Snow + Trap 32 492.464 77.382 < 0.001 Lek Ct Visit + Cloud + Snow + Trap 32 492.510 77.427 < 0.001 Lek Ct Visit + Surv + Cloud + Trap 32 492.861 77.778 < 0.001 Occ Lek Visit + Surv + Snow + Obs 33 505.266 90.184 < 0.001 Occ Lek Visit + Cloud + Snow + Obs 33 505.279 90.197 < 0.001 Occ Lek Visit + Surv + Cloud + Obs 33 505.653 90.571 < 0.001

80 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Lek Ct Visit + Surv + Snow + Obs 33 506.233 91.150 < 0.001 Lek Ct Visit + Cloud + Snow + Obs 33 506.245 91.163 < 0.001 Lek Ct Visit + Surv + Cloud + Obs 33 506.621 91.539 < 0.001 Table A2 Model set for models explaining variation in small-scale occupancy probabilities (θ) of Greater Sage-Grouse fence collisions in Wyoming, 2014–2015. We ﬁt models using the most parsimonious model on detection probabilities (i.e., null) and large-scale occupancy probabilities (i.e., null). Model structures on small-scale occupancy included: distance to nearest lek (Distance), the count at the nearest lek (Near Ct), fence exposure (Fence Exp), wood post or t-post (Post), proportion of fence segment in high risk areas (Risk), angle of fence in relation to lek (Angle), marker type (Trt), marked or unmarked fence (regardless of marker type; Mark), Year, biweekly (primary) period (Surv), an interaction between Distance and Near Ct, and an interaction between Post and Mark or Trt. The number of parameters (npar), Akaike's Information Criterion adjusted for small sample size (AICc), diﬀerence between a model's AICc value and the minimum AICc value (ΔAICc), and AICc weights are included for models with ΔAICc <4.

θ npar AICc ΔAICc weight

Fence Exp + Mark + Distance + Post + Risk + Near Ct 9 364.644 0.000 0.030 Fence Exp + Mark + Distance + Post + Risk + Year 9 364.756 0.111 0.028 Fence Exp + Mark + Distance + Post + Risk + Year + Near Ct 10 364.903 0.259 0.026 Fence Exp + Mark + Post + Risk + Distance × Near Ct 10 365.270 0.626 0.022 Surv + Fence Exp + Mark + Distance + Post + Risk + Year 15 365.647 1.003 0.018 Fence Exp + Mark + Distance + Post + Near Ct 8 365.762 1.118 0.017 Fence Exp + Mark + Post + Risk + Year + Distance × Near Ct 11 365.794 1.150 0.017 Surv + Fence Exp + Mark + Distance + Post + Year 14 365.810 1.166 0.017 Fence Exp + Mark + Distance + Post + Year + Near Ct 9 365.998 1.354 0.015 Fence Exp + Mark + Distance + Post + Risk 8 366.015 1.371 0.015 Fence Exp + Mark + Distance + Post + Year 8 366.230 1.586 0.014 Surv + Mark + Distance + Post + Year 13 366.584 1.940 0.011 Surv + Fence Exp + Distance + Post + Risk + Year 14 366.689 2.045 0.011 Surv + Fence Exp + Mark + Distance + Post + Risk 14 366.791 2.147 0.010 Surv + Fence Exp + Mark + Distance + Post + Near Ct 14 366.803 2.159 0.010 Surv + Fence Exp + Mark + Distance + Post + Risk + Near Ct 15 366.871 2.227 0.010 Surv + Fence Exp + Distance + Post + Year 13 366.883 2.239 0.010 Surv + Mark + Distance + Post + Risk + Year 14 366.897 2.253 0.010 Fence Exp + Distance + Post + Risk + Year 8 366.926 2.282 0.010 Surv + Distance + Post + Risk + Year 13 366.997 2.353 0.009 Surv + Distance + Post + Year 12 367.005 2.361 0.009 Angle + Surv + Post + Year 12 367.072 2.428 0.009 Surv + Fence Exp + Mark + Distance + Post 13 367.177 2.533 0.008 Fence Exp + Distance + Post + Risk + Year + Near Ct 9 367.183 2.538 0.008 Angle + Surv + Distance + Post + Year 13 367.336 2.692 0.008 Surv + Fence Exp + Mark + Distance + Post + Year + Near Ct 15 367.365 2.721 0.008 Angle + Surv + Mark + Post + Year 13 367.420 2.776 0.007 Fence Exp + Distance + Risk + Near Ct + Post × Mark 10 367.457 2.813 0.007 Mark + Distance + Post + Risk + Year + Near Ct 9 367.459 2.815 0.007 Fence Exp + Distance + Risk + Year + Post × Mark 10 367.587 2.942 0.007 Fence Exp + Mark + Distance + Post 7 367.590 2.946 0.007 Surv + Fence Exp + Mark + Distance + Post + Risk + Year + Near Ct 16 367.591 2.946 0.007 Fence Exp + Distance + Risk + Year + Near Ct + Post × Mark 11 367.717 3.073 0.006 Angle + Fence Exp + Mark + Distance + Post + Risk + Near Ct 10 367.748 3.104 0.006 Angle + Fence Exp + Mark + Distance + Post + Risk + Year 10 367.821 3.177 0.006 Mark + Distance + Post + Risk + Year 8 367.882 3.238 0.006 Angle + Surv + Mark + Post 12 367.902 3.258 0.006 Mark + Distance + Post + Risk + Near Ct 8 367.992 3.348 0.006 Angle + Surv + Mark + Post + Near Ct 13 368.029 3.385 0.006 Fence Exp + Distance + Post + Risk + Near Ct 8 368.075 3.431 0.005 Surv + Mark + Distance + Post + Year + Near Ct 14 368.076 3.432 0.005 Angle + Surv + Post 11 368.076 3.432 0.005 Fence Exp + Distance + Post + Year + Near Ct 8 368.107 3.463 0.005 Angle + Fence Exp + Mark + Distance + Post + Risk + Year + Near Ct 11 368.160 3.516 0.005 Fence Exp + Distance + Post + Year 7 368.210 3.566 0.005 Mark + Distance + Post + Year + Near Ct 8 368.239 3.595 0.005 Angle + Surv + Mark + Distance + Post + Year 14 368.255 3.611 0.005 Surv + Distance + Post + Year + Near Ct 13 368.264 3.620 0.005 Fence Exp + Mark + Post + Distance × Near Ct 9 368.276 3.632 0.005 Fence Exp + Risk + Post × Mark + Distance × Near Ct 11 368.284 3.640 0.005 Surv + Mark + Distance + Post + Near Ct 13 368.308 3.664 0.005 Surv + Distance + Post + Risk + Year + Near Ct 14 368.328 3.684 0.005 Angle + Fence Exp + Mark + Post + Risk + Distance × Near Ct 11 368.379 3.735 0.005 Angle + Surv + Post + Near Ct 12 368.397 3.753 0.005

81 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Surv + Mark + Distance + Post + Risk + Year + Near Ct 15 368.414 3.770 0.005 Surv + Fence Exp + Distance + Post + Year + Near Ct 14 368.431 3.787 0.005 Distance + Post + Risk + Year + Near Ct 8 368.445 3.801 0.004 Angle + Fence Exp + Mark + Distance + Post + Near Ct 9 368.449 3.805 0.004 Angle + Fence Exp + Mark + Distance + Post + Year 9 368.468 3.824 0.004 Fence Exp + Post + Risk + Year + Distance × Near Ct 10 368.499 3.855 0.004 Fence Exp + Distance + Near Ct + Post × Mark 9 368.531 3.886 0.004 Mark + Distance + Post + Year 7 368.550 3.906 0.004 Surv + Fence Exp + Distance + Post + Risk + Year + Near Ct 15 368.591 3.947 0.004 Mark + Distance + Post + Near Ct 7 368.623 3.979 0.004 Table A3 Coefficient estimates, standard errors (SE), and 95% confidence intervals (CI) for all variables from the best model explaining variation in small-scale occupancy (θ) probabilities of Greater Sage-Grouse fence collisions in Wyoming, 2014–2015. Variables include fence exposure (Fence Exp), whether a fence was marked (regardless of marker type; Mark), the distance to nearest lek (Distance), fences with wood and t-posts (wood and t-post), proportion of fence segment in high risk areas (Risk), and the count at the nearest lek (Near Ct). The intercept represents an unmarked fence with wood posts with all continuous variable values set to 0. All significant coefficients (i.e., 95% CIs do no overlap 0) are indicated by an asterisk.

Parameter Mean SE 95% CI

Intercept* −5.104 1.068 (−7.197, −3.012) Fence Exp* 0.033 0.013 (0.007, 0.059) Mark* −0.922 0.359 (−1.623, −0.217) Distance* −0.500 0.197 (−0.886, −0.113) Wood and T-post* 1.783 0.387 (1.025, 2.541) Risk* 1.128 0.565 (0.020, 2.235) Near Ct 0.005 0.002 (0.000, 0.010) Table A4 Coefficient estimates, standard errors (SE), and 95% confidence intervals (CI) for all variables from the second best model explaining variation in small-scale occupancy (θ) probabilities of Greater Sage-Grouse fence collisioins in Wyoming, 2014–2015. Variables include fence exposure (Fence Exp), whether a fence was marked (regardless of marker type; Mark), the distance to nearest lek (Distance), fences with wood and t-posts (wood and t-post), proportion of fence segment in high risk areas (Risk), and the count at the nearest lek (Near Ct). The intercept represents an unmarked fence with wood posts with all continuous variable values set to 0. All significant coefficients (i.e., 95% CIs do no overlap 0) are indicated by an asterisk.

Parameter Mean SE 95% CI

Intercept* −5.181 1.090 (−7.317, −3.046) Fence Exp* 0.032 0.013 (0.006, 0.058) Mark* −0.818 0.356 (−1.515, −0.121) Distance* −0.650 0.186 (−1.015, −0.285) Wood and T-post* 1.685 0.374 (0.952, 2.418) Risk* 1.161 0.557 (0.069, 2.253) 2015* 0.875 0.431 (0.030, 1.720)

References 67, 105–118. Chamberlin, T.C., 1965. The method of multiple working hypotheses. Science 148, 754–759. Baines, D., Andrew, M., 2003. Marking of deer fences to reduce frequency of collisions by Christiansen, T., 2009. Fence marking to reduce greater sage-grouse (Centrocercus ur- woodland grouse. Biol. Conserv. 110 (2), 169–176. ophasianus) collisions and mortality near Farson. In: Wyoming – Summary of Interim Baines, D., Summers, R.W., 1997. Assessment of bird collisions with deer fences in Results. Wyoming Game and Fish Department. Scottish forests. J. Appl. Ecol. 941–948. Christiansen, T., 2012. Chapter 12: sage grouse (Centrocercus urophasianus). In: Tessmann, Battin, J., 2004. When good animals love bad habitats: ecological traps and the con- S.A., Bohne, J.R. (Eds.), Handbook of Biological Techniques, Third edition. Wyoming servation of animal populations. Conserv. Biol. 18, 1482–1491. Game and Fish Department, Cheyenne, Wyoming, USA, pp. 1–55. Beck, T.D.I., Braun, C.E., 1980. The strutting ground count: variation, traditionalism, Doherty, P.F., White, G.C., Burnham, K.P., 2012. Comparison of model building and se- management needs. In: Proceedings of the Western Association of Fish and Wildlife lection strategies. J. Ornithol. 152, 317–323. Agencies. 60. pp. 558–566. Drewitt, A.L., Langston, R.H., 2008. Collision effects of wind-power generators and other Bevanger, K., 1994. Bird interactions with utility structures: collision and electrocution, obstacles on birds. Ann. N. Y. Acad. Sci. 1134 (1), 233–266. causes and mitigating measures. Ibis 136 (4), 412–425. Emmons, S.R., Braun, C.E., 1984. Lek attendance of male sage grouse. J. Wildl. Manag. 48 Bevanger, K., 1995. Estimates and population consequences of tetraonid mortality caused (3), 1023–1028. by collisions with high tension power lines in Norway. J. Appl. Ecol. 32, 745–753. ESRI, 2011. ArcGIS Desktop: Release 10. Environmental Systems Research Institute, Bevanger, K., 1998. Biological and conservation aspects of bird mortality caused by Redlands, CA. electricity power lines: a review. Biol. Conserv. 86, 67–76. Everaert, J., Stienen, E.W.M., 2007. Impact of wind turbines on birds in Zeebrugge Bevanger, K., Henriksen, G., 1996. Faunistiske effekterav gjerder og andre menneskes- (Belgium): significant effect on breeding tern colony due to collisions. Biodivers. kapte barrierer. (In Norwegian with English Summary: Faunistic Consequences of Conserv. 16 (12), 3345–3359. Fences and Other Man-Made Barriers.) Norwegian Institute for Nature Research, Flake, L.D., Connelly, J.W., Kirschenmann, T.R., Lindbloom, A.J., 2010. Grouse of Plains Oppdragsmelding. 393. pp. 1–26. and Mountains: The South Dakota Story. South Dakota Department of Game, Fish, Bureau of Land Management - Pinedale Field Office, GIS Staff. 2013. Unpublished and Parks, Pierre, South Dakota, USA. Material. vector digital data.\\ilmwypd6na1\gis\gisdata\Range\fences.shp. Location FlySafe, 2016. Fly Safe, LLC. http://www.flysafellc.com (accessed 12.16). of Fences within the Bureau of Land Management Pinedale Field Office in Southwest Hagen, C.A., Pavlacky Jr., D.C., Adachi, K., Hornsby, F.E., Rintz, T.J., McDonald, L.L., Wyoming, 1:100,000. University of Wyoming Spatial Data and Visualization Center, 2016. Multiscale occupancy modeling provides insights into range-wide conservation Laramie, Wyoming. needs of lesser prairie-chicken (Tympanuchus pallidicinctus). Condor 118, 597–612. Burnham, K.P., Anderson, D.R., 2002. Model Selection and Multimodel Inference: A Hayter, Earl W., 1939. Barbed wire fencing: a prairie invention: its rise and influence in Practical Information-theoretic Approach. Springer-Verlag, New York, New York, the Western States. Agric. Hist. 13 (4), 189–207. USA. Hayward, M.W., Kerley, I.H., 2009. Fencing for conservation: restriction of evolutionary Catt, D.C., Dugan, D., Green, R.E., Moncrieff, R., Moss, R., Picozzi, N., Summers, R.W., potential or a riposte to threatening processes? Biol. Conserv. 142, 1–13. Tyler, G.A., 1994. Collisions against fences by woodland grouse in Scotland. Forestry Henderson, I.G., Langston, R.H.W., Clark, N.A., 1996. The response of common terns

82 N.J. Van Lanen et al. Biological Conservation 213 (2017) 70–83

Sterna hirundo to power lines: an assessment of risk in relation to breeding commit- Wildl. Manag. 76, 154–162. ment, age and wind speed. Biol. Conserv. 77, 185–192. Rayner, J.M.V., 1988. Form and function in avian flight. In: Johnston, R.F. (Ed.), Current Jenni, D.A., Hartzler, J.E., 1978. Attendance at a sage grouse lek: implications for spring Ornithology. vol. 5. Plenum, New York, pp. 1–66. censuses. J. Wildl. Manag. 46–52. von Schweppenburg, H.F., 1929. “Zugstraßen”–Leitlinien. J. Ornithol. 77 (4), 17–32. Johnson, D.H., Rowland, M.M., 2007. The Utility of Lek Counts for Monitoring Greater Scott, J.W., 1942. Mating behavior of the sage-grouse. Auk 59, 477–498. Sage-grouse. Monitoring Populations of Sage-grouse. 88. College of Natural Scott, R.E., Roberts, L.J., Cadbury, C.J., 1972. Bird deaths from power lines at Dungeness. Resources Experiment Station Bulletinpp. 15–23. British Birds 65, 273–286. Laake, J., 2013. RMark: An R Interface for Analysis of Capture-Recapture Data with Sibley, D.A., 2000. In: Alfred, A. (Ed.), The Sibley Guide to Birds. Knopf, New York, NY. MARK. US Department of Commerce, National Oceanic and Atmospheric Sillman, A.J., 1973. Avian vision. In: Farner, D.S., King, J.R. (Eds.), Avian Biology. vol. Administration, National Marine Fisheries Service, Alaska Fisheries Science Center, III. Academic Press, London, pp. 349–387. Seattle, Washington, USA. Smith, J.A., Dwyer, J.F., 2016. Avian interactions with renewable energy infrastructure: Lebreton, J.D., Burnham, K.P., Clobert, J., Anderson, D.R., 1992. Modeling survival and an update. Condor 118, 411–423. testing biological hypotheses using marked animals: a unified approach with case- Stevens Jr., D.L., Olsen, A.R., 2004. Spatially balanced sampling of natural resources. J. studies. Ecol. Monogr. 62, 67–118. Am. Stat. Assoc. 99, 262–278. Linnell, J.D., 2016. Border controls: refugee fences fragment wildlife. Nature 529 (7585), Stevens, B.S., Reese, K.P., Connelly, J.W., 2011. Survival and detectability bias of avain 156. fence collision surveys in sagebrush steppe. J. Wildl. Manag. 75 (2), 437–449. Linnell, J.D., Trouwborst, A., Boitani, L., Kaczensky, P., Huber, D., Reljic, S., Kusak, J., Stevens, B.S., Connelly, J.W., Reese, K.P., 2012a. Multi-scale assessment of greater sage- Majic, A., Skrbinsek, T., Potocnik, H., Hayward, M.W., Milner-Gulland, E.J., grouse fence collision as a function of site and broad scale factors. J. Wildl. Manag. 76 Buuveibaatar, B., Olson, K.A., Badamjav, L., Bischof, R., Zuther, S., Breitenmoser, U., (7), 1370–1380. 2016. Border security fencing and wildlife: the end of the transboundary paradigm in Stevens, B.S., Reese, K.P., Connelly, J.W., Musil, D.D., 2012b. Greater sage-grouse and Eurasia? Plos Boil 14 (6), e1002483. fences: does marking reduce collisions? Wildl. Soc. Bull. 36 (2), 297–303. Lisney, T.J., Iwaniuk, A.N., Kolominsky, J., Bandet, M.V., Corfield, J., 2012. Interspecific Stevens, B.S., Naugle, D.E., Connelly, J.W., Griffiths, T., Reese, K.P., 2013. Mapping sage- variation in eye shape and retinal topography in seven species of galliform bird (Aves: grouse fence-collision risk: spatially explicit models for targeting conservation im- Galliformes:Phasianidae). J. Comp. Physiol. A. 198, 717–731. plementation. Wildl. Soc. Bull. 37 (2), 409–415. Luzenski, J., Rocca, C.E., Harness, R.E., Cummings, J.L., Austin, D.D., Landon, M.A., Stiver, S.J., Apa, A.D., Bohne, J.R., Bunnell, S.D., Deibert, P.A., Gardner, S.C., Hilliard, Dwyer, J.F., 2016. Collision avoidance by migrating raptors encountering a new M.A., McCarthy, C.W., Schroeder, M.A., 2006. Greater Sage-grouse Comprehensive electric power transmission line. Condor 118, 402–410. Conservation Strategy. Western Association of Fish and Wildlife Agencies. Monroe, A.P., C.L. Aldridge, T.J. Assal, K.E. Veblen, D.A. Pyke, and M.L. Casazza. In (Unpublished Report. Cheyenne, Wyoming). review. Patterns in greater sage-grouse population dynamics correspond with public Summers, R.W., Dugan, D., 2001. An assessment of methods used to mark fences to re- grazing records at broad scales. Ecol. Appl. duce bird collisions in pinewoods. Scott. For. 55 (1), 23–29. Morrison, M.L., Block, W.M., Strickland, M.D., Collier, B.A., Peterson, M.J., 2008. Wildlife United States Department of Agriculture (USDA), 2016. How To Make and Install Fence Study Design. Springer, New York, New York, USA. Markers For Sage-grouse. http://www.sagegrouseinitiative.com/wp-content/ Moss, R., Picozzi, N., Summers, R.W., Baines, D., 2000. Capercaillie Tetrao urogallus in uploads/2013/07/NRCD-SGI_FenceMarker_Instructions.pdf accessed 06.16). Scotland-demography of a declining population. Ibis 142 (2), 259–267. United States Fish and Wildlife Service (USFWS), 2010. Endangered and Threatened Mougeot, F., Martinez-Padilla, J., Perez-Rodriguez, L., Bortolotti, G.R., 2007. Carotenoid- Wildlife and Plants; 12-month Findings for Petitions to List the Greater Sage-grouse based colouration and ultraviolet reflectance of the sexual ornaments of grouse. (Centrocercus urophasianus) as Threatened or Endangered. 50 CFR Part 17. Behav. Ecol. Sociobiol. 61, 741–751. Viscor, G., Fuster, J.F., 1987. Relationships between morphological parameters in birds Natural Resources Conservation Service, 2015. Sage Grouse Initiative 2014 Progress with different flying habits. Comp. Biochem. Physiol. A Physiol. 87 (2), 231–249. Report. http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/programs/ Walsh, D.P., White, G.C., Remington, T.E., Bowden, D.C., 2004. Evaluation of the lek- initiatives/?cid=steldevb1027671 (accessed 02.16). count index for greater sage-grouse. Wildl. Soc. Bull. 32 (1), 56–68. Nichols, J.D., Bailey, L.L., O'Connell Jr., A.F., Talancy, N.W., Grant, E.H.C., Gilbert, A.T., White, G.C., Burnham, K.P., 1999. Program MARK: survival estimation from populations Annand, E.M., Husband, T.P., Hines, J.E., 2008. Multi-scale occupancy estimation of marked animals. Bird Study 46 (Suppl. 1), S120–S139. and modelling using multiple detection methods. J. Appl. Ecol. 45, 1321–1329. Wolfe, D.H., Patten, M.A., Shochat, E., Pruett, C.L., Sherrod, S.K., 2007. Causes and Patten, M.A., Wolfe, D.H., Shochat, E., Sherrod, S.K., 2005. Effects of microhabitat and patterns of mortality in lesser prairie-chickens Tympanuchus pallidicinctus and im- microclimate selection on adult survivorship of the lesser prairie-chicken. J. Wildl. plications for management. Wildl. Biol. 13 (1), 95–104. Manag. 69 (3), 1270–1278. Wyoming State Historical Society 2016. Accessed 3/8/2016. http://www.wyohistory. Pavlacky Jr., D.C., Blakesley, J.A., White, G.C., Hanni, D.J., Lukacs, P.M., 2012. org/encyclopedia/sublette-county-wyoming. Hierarchical multi-scale occupancy estimation for monitoring wildlife populations. J.

View publication stats A Bighorn Sheep Die-off in Southern Colorado Involving a Pasteurellaceae Strain that May Have Originated from Syntopic Cattle Author(s): Lisa L. Wolfe, Brandon Diamond, Terry R. Spraker, Michael A. Sirochman, Daniel P. Walsh, Chandra M. Machin, Donald J. Bade, and Michael W. Miller Source: Journal of Wildlife Diseases, 46(4):1262-1268. Published By: Wildlife Disease Association https://doi.org/10.7589/0090-3558-46.4.1262 URL: http://www.bioone.org/doi/full/10.7589/0090-3558-46.4.1262

BioOne (www.bioone.org) is a nonprofit, online aggregation of core research in the biological, ecological, and environmental sciences. BioOne provides a sustainable online platform for over 170 journals and books published by nonprofit societies, associations, museums, institutions, and presses. Your use of this PDF, the BioOne Web site, and all posted and associated content indicates your acceptance of BioOne’s Terms of Use, available at www.bioone.org/page/ terms_of_use. Usage of BioOne content is strictly limited to personal, educational, and non-commercial use. Commercial inquiries or rights and permissions requests should be directed to the individual publisher as copyright holder.

BioOne sees sustainable scholarly publishing as an inherently collaborative enterprise connecting authors, nonprofit publishers, academic institutions, research libraries, and research funders in the common goal of maximizing access to critical research. Journal of Wildlife Diseases, 46(4), 2010, pp. 1262–1268 # Wildlife Disease Association 2010

A Bighorn Sheep Die-off in Southern Colorado Involving a Pasteurellaceae Strain that May Have Originated from Syntopic Cattle

Lisa L. Wolfe,1,5 Brandon Diamond,2 Terry R. Spraker,3 Michael A. Sirochman,1 Daniel P. Walsh,1 Chandra M. Machin,4 Donald J. Bade,4 and Michael W. Miller11Colorado Division of Wildlife, Wildlife Research Center, 317 West Prospect Road, Fort Collins, Colorado 80526-2097, USA; 2Colorado Division of Wildlife, 300 West New York Avenue, Gunnison, Colorado 81230, USA; 3Colorado State University Diagnostic Laboratory, Department of Microbiology, Immunology, and Pathology, College of Veterinary Medicine, Colorado State University, Fort Collins, Colorado 80523, USA; 4Microbial Research, Incorporated, 2649 East Mulberry Street, Number 15, Fort Collins, Colorado 80524, USA; 5Corresponding author (email: [email protected])

ABSTRACT: We investigated a pasteurellosis utable to historical overharvest, habitat epizootic in free-ranging bighorn sheep (Ovis loss or degradation and, in large part, to canadensis) wherein a Pasteurellaceae strain epizootics caused by introduced patho- carried by syntopic cattle (Bos taurus) under severe winter conditions appeared to contrib- gens, some of which have now become ute to pneumonia in affected bighorns. Twenty- enzootic. The earliest reports of epizootics one moribund or dead bighorn sheep were in bighorn sheep (e.g., accounts in War- found on the ‘‘Fossil Ridge’’ herd’s winter ren, 1910; Grinnell, 1928; Shillinger, 1937; range, Colorado, USA, between 13 December Honess and Frost, 1942) closely followed 2007 and 29 February 2008. Eight carcasses examined showed gross or microscopic evi- the advent of domestic livestock grazing in dence of acute to subacute fibrinous broncho- bighorn habitat, suggesting that bighorn pneumonia. All eight carcasses yielded at least populations in some areas first may have one b-hemolytic Mannheimia haemolytica been exposed to novel pathogens in the (6G) biogroup 1 strain, and seven also yielded a 1800s. More than a century later, recur- b-hemolytic Bibersteinia trehalosi biogroup 4CDS strain; evidence of Pasteurella multocida, ring respiratory disease epizootics remain Mycoplasma ovipneumoniae, and parainfluenza obstacles to recovering bighorn sheep 3 and bovine respiratory syncytial viruses was populations to historic levels (Miller, also detected. Isolates of b-hemolytic Mannei- 2001). Understanding and, where feasible, G mia haemolytica biogroup 1 from a bighorn controlling specific risk factors that may carcass and a syntopic cow showed 99.5% similarity in genetic fingerprints; B. trehalosi cause or precipitate pneumonia epizootics biogroup 4CDS isolates were $94.9% similar to in bighorn sheep has become an impera- an isolate from a nearby bighorn herd. Field tive of this species’ conservation. Unfor- and laboratory observations suggested that tunately, post hoc investigations of epizo- pneumonia in affected bighorns may have been otics under field conditions rarely yield caused by a combination of pathogens including two pathogenic Pasteurellaceae strains— clear answers regarding source(s) of the one likely of cattle origin and one likely of responsible pathogen(s) and the role of bighorn origin—with infections in some cases potential contributing stressors like weath- perhaps exacerbated by other respiratory path- er. Here, we describe a case wherein ogens and severe weather conditions. Our and exposure to a pathogen carried by syntopic others’ findings suggest that intimate interactions between wild sheep and cattle should be cattle (Bos taurus) under severe winter discouraged as part of a comprehensive ap- conditions may have contributed to the proach to health management and conservation onset of epizootic pasteurellosis in a free- of North American wild sheep species. ranging bighorn herd. Our objectives are Key words: Bibersteinia trehalosi, bighorn to report the findings of our field and sheep, cattle, pneumonia, Mannheimia haemolytica, Mycoplasma, Ovis canadensis, Pas- laboratory investigations of this epizootic teurella multocida. and to broaden conventional thinking about risk factors that may affect the The decline of bighorn sheep (Ovis health and perpetuation of North Ameri- canadensis) abundance throughout much can wild sheep species. of western North America appears attrib- The ‘‘Fossil Ridge’’ bighorn herd in

1262 SHORT COMUNICATIONS 1263 southern Colorado, USA (38u30–419N, carcass 10 days earlier. He also noted that 106u34–489W) was started with a translo- this had been a particularly bad year for cation of 20 individuals and had grown to respiratory disease problems in his cattle .60 animals by 2006 (George et al., 2009). herd, perhaps because recently purchased Available range was restricted during most replacement animals had ‘‘brought some- winters and recreation activity may have thing in’’ (e.g., Frank et al., 2003); further reduced the area occupied by however, no previous diagnostic work bighorns. As a likely consequence of had been done on the cattle herd. limited winter range, a local Hereford Twenty-one moribund or dead bighorn breed cattle rancher reported that for sheep were found on the Fossil Ridge about 15 yr some bighorns had come into herd’s winter range between 13 Decem- his cattle feed lines on private land at ber 2007 and 29 February 2008; three times during fall and winter. On the basis additional carcass remains were found in of the belief that such interactions were October 2008. Eight relatively intact not particularly risky to bighorn sheep, carcasses were necropsied; other carcasses this behavior was not discouraged by local were too scavenged, decomposed, or wildlife managers. inaccessible to examine. Lung, tonsil, and The winter of 2007–08 was one of the other select tissues were submitted to the most severe in recorded history for the Caine Veterinary Teaching Center Gunnison Basin (Colorado Division of (CVTC; University of Idaho, Caldwell, Wildlife, 2009), an area that included the Idaho, USA) for bacterial culture with Fossil Ridge herd’s range. On the basis of emphasis on Pasteurellaceae (modified data compiled at the Gunnison County from Jaworski et al., 1998), to Microbial Electric Association weather station for Research, Inc. (MRI; Fort Collins, Colo- the United States National Oceanic and rado, USA) and the Washington Animal Atmospheric Administration, about 51 cm Disease Diagnostic Laboratory (Pullman, of heavy, wet snow fell during 6–7 Washington, USA) for Mycoplasma spp. December 2007, burying mountain shrub culture, and to the CVTC, MRI, and the communities across the basin; below- Colorado State University Veterinary Di- average temperatures ranging from 27C agnostic Laboratory (CSUVDL; Fort Col- to 220 C precluded any appreciable lins, Colorado, USA) for PCR assays to snowmelt thereafter. Apparently healthy detect Mycoplasma spp. DNA (Baird et bighorn sheep were seen on traditional al., 1999; Besser et al., 2008; D. Bade, winter range during the week of 16 unpubl. data; G. Weiser, pers. comm.). December, although no lambs from the Antibody titers to parainfluenza 3 (PI3; previous summer were observed. recent or active infection titer $1:256) The epizootic at Fossil Ridge was first virus and bovine respiratory syncytial virus reported on 23 December 2007 by the (BRSV; recent or active infection titer local rancher, who noticed fewer bighorns $1:64) were measured by virus neutrali- in the area and subsequently found three zation tests at the CSUVDL. Select carcasses and two sick animals nearby. representative Pasteurellaceae isolates Clinical signs included depression, thick from carcasses and live animals (sampling nasal discharge, and dyspnea, but little detailed below) were further compared by coughing. One sick animal was shot; the repetitive DNA sequence genotyping by other was found dead the next day. Newport Laboratories (Worthington, Min- Subsequent field investigation on 23 and nesota, USA) using PCR and boxA1R 24 December revealed additional carcass- primer (Goldberg et al., 2006). Select es and sick animals. In the course of Mycoplasma spp. isolates were identified discussing the situation, the rancher men- by DNA sequencing at the University of tioned finding an adult female bighorn Minnesota Veterinary Diagnostic Labora- 1264 JOURNAL OF WILDLIFE DISEASES, VOL. 46, NO. 4, OCTOBER 2010

TABLE 1. Respiratory disease agents detected from dead and surviving bighorn sheep (Ovis canadensis) and syntopic cattle (Bos taurus) during and after the December 2007 epizootic at ‘‘Fossil Ridge’’ in southwestern Colorado, USA. Evidence of infection or exposure came from culture data for Pasteurellaceae, from culture and PCR data for mycoplasmas, and from serology data for the two respiratory viruses. See text for methods and interpretation.

Bighorn sheep Cattle

Dead (December Alive (February– Alive (February Alive (February Agent 2007), n58 March 2008), n510 2009), n511 2008), n527

Mannheimia haemolytica Biogroup 1 (b)a 5b 000 Biogroup 1G (b)7001 Biogroup 1AG (b)1000 Biogroup 3 (b)0020 Biogroup 3A 0010 Biogroup 16AG(6E) 00020 Bibersteinia trehalosi Biogroup 4CDS (b)7100 Biogroup 4(6various) 0520 Biogroup 2(6various) 0310 Pasteurella multocida 5410 Mycoplasma spp. 8 3 1 15 Mycoplasma ovipneumoniae 8sdc sd 9 Mycoplasma bovirhinis 0sdsd9 Bovine respiratory syncytial virus (titer $1:64) 2 (of 2) 2 nrd 8 Parainfluenza 3 virus (titer $1:256) 2 (of 2) 2 nr 19 a Isolates showed b-hemolysis on blood agar. b Number of individuals positive; total sample size is shown in the column heading except where noted. c Samples discarded by reference laboratory before species-specific PCR being performed. d Not reported because prior vaccination confounded interpretation of titers.

tory (UMVDL; Saint Paul, Minnesota, biogroup 1 isolates (,83% genetic finger- United States). Select liver trace mineral print similarity to the biogroup 1G strain) concentrations were measured at the from five. A Bibersteinia trehalosi CSUVDL using established methods (Ro- biogroup 4CDS strain also was isolated from sen et al., 2009) to rule out feed-associated seven carcasses. In addition, Pasteurella intoxication. multocida (subsp. b or biotype U) was All carcasses examined showed gross isolated from five carcasses. Lung or tonsil and microscopic evidence of acute to tissue samples from all eight bighorn subacute fibrinous bronchopneumonia. carcasses tested PCR positive for Myco- The predominant microscopic lesion was plasma ovipneumoniae (Table 1). Serology severe, subacute bacterial bronchopneu- in two cases where blood was available monia associated with oat-shaped macro- also suggested exposure to PI3 and BRSV. phages, edema, fibrin, and a few neutro- Liver tissue mineral concentrations phils filling and expanding alveolar spaces. (mean695% confidence interval; range) Three dominant b-hemolytic Pasteurella- for copper (146.1678.6 parts per million ceae strains were recovered (Table 1). All [ppm] dry weight; 12.1–316 ppm), man- eight carcasses yielded at least one Man- ganese (6.761.4 ppm; 3.8–9.7 ppm), mo- nheimia haemolytica strain, including lybdenum (3.761.2 ppm; 1.9–5.8 ppm), biogroup 1G isolates from seven and and zinc (122.7637.3 ppm; 60.3–208 ppm) SHORT COMUNICATIONS 1265 were all within acceptable limits (Rosen et from cattle. Three of the surviving big- al., 2009; CSUVDL, unpubl. data; L. L. horns and 15 of the sampled cattle were Wolfe, unpubl. data), but selenium con- PCR positive for Mycoplasma spp. (Ta- centrations (0.760.2 ppm; 0.5–1.5 ppm) ble 1); both Mycoplama ovipneumoniae were lower than reported for healthy and Mycoplasma bovirhinis were detected bighorns (Rosen et al., 2009). in the cattle by PCR or culture. A We captured 10 of the 11 known proportion of both the surviving bighorns surviving bighorns (nine adult females and the sampled cattle had antibody titers and one adult male) via darting about 5 suggesting exposure to PI3 and BRSV or 9 wk after the die-off was first reported. (Table 1). Two adult females were equipped with In February 2009, surviving Fossil very-high-frequency radiocollars and the Ridge bighorn sheep were again baited other eight animals were marked with and recaptured via drop netting. Of 11 unique plastic ear tags. We collected animals captured, three (one lamb, two blood and oropharyngeal swabs and treat- adult females) were unmarked and thus ed each animal with tulathromycin had not been handled in 2008. We (DRAXXINH, Pfizer Animal Health, New sampled and tested bighorns as above York, New York, USA), doramectin and treated each with tulathromycin, (DECTOMAXH, Pfizer Animal Health), doramectin, and two commercial vaccines, and a commercial vaccine containing Triangle 4 and a Mannheimia haemolytica killed PI3, BRSV, infectious bovine rhino- type A1 bacterin-toxoid (One ShotH, tracheitis virus, and bovine viral diarrhea Pfizer Animal Health). Cultures yielded virus (Triangle 4, Fort Dodge; Fort b-hemolytic M. haemolytica biogroup 3 Dodge, Iowa, USA). In addition, we (Table 1), along with nonhemolytic B. collected blood and triplicate nasopharyn- trehalosi, M. haemolytica, and P. multo- geal swabs from a subset of the rancher’s cida isolates. On the basis of numbers of cattle (n527) and treated all of the non-Pasteurellaceae recovered, shipping syntopic cattle with tulathromycin and processing delays likely biased culture (n570). We placed swabs in Port-A-CulTM results. Only the lamb was PCR positive tubes (Becton, Dickinson and Company, for Mycoplasma spp. Cattle were not Sparks, Maryland, USA) and hand-deliv- resampled. ered one set to MRI and shipped the other Laboratory findings linked a combina- overnight to the CVTC for culture and tion of pathogens to this epizootic. Despite Mycoplasma spp. PCR. A third swab in sampling lags and some heterogeneity brain–heart infusion broth was submitted among the Pasteurellaceae isolated from to CSUVDL for Mycoplasma spp. PCR. pneumonic bighorns, a b-hemolytic, M. Serum antibody titers to PI3 and BRSV haemolytica biogroup 1G isolate from a were measured by serum neutralization bighorn carcass showed 99.5% similarity (CSUVDL). in its genetic fingerprint to the M. Nonhemolytic strains of B. trehalosi haemolytica biogroup 1G isolate from one biogroups 2 and 4CDS and P. multocida of the syntopic cattle; moreover, these two were the primary Pasteurellaceae isolated isolates’ fingerprints were $95.5% similar from the surviving bighorns (Table 1); to fingerprints of other M. haemolytica Mannheimia haemolytica was not isolated. biogroup 1G isolates from temporally and Nonhemolytic M. haemolytica biogroup geographically separate cases of domestic 6 16AG( E) were the most abundant Pasteu- sheep (Ovis aires)-associated acute pas- rellaceae isolated from cattle, although a teurellosis in bighorns (Foreyt, 1989; b-hemolytic M. haemolytica biogroup 1G George et al., 2008). These findings also was isolated from one of the cattle support the notion that domestic rumi- (Table 1); B. trehalosi were not isolated nants can harbor Pasteurellaceae strains 1266 JOURNAL OF WILDLIFE DISEASES, VOL. 46, NO. 4, OCTOBER 2010 that are pathogenic in bighorn sheep. The b-hemolytic B. trehalosi biogroup 4CDS also isolated from most pneumonic Fossil Ridge bighorns (but none of the syntopic cattle) has been recovered from several Colorado bighorn herds (Green et al., 1999; L. L. Wolfe and M. W. Miller, unpubl. data); B. trehalosi biogroup 4CDS isolates from both dead and surviving Fossil Ridge bighorns were $94.9% similar by genetic fingerprinting to isolates from the nearby Taylor River bighorn herd where this strain (called ‘‘ribotype FIGURE 1. The intensity and duration of interac- ECO’’ elsewhere; Green et al., 1999) has tions between bighorn sheep and cattle on feed lines been enzootic since at least the early 1990s during December 2007 may have contributed to the (M. W. Miller and L. L. Wolfe, unpubl. apparent exchange of respiratory pathogens associated with a pasteurellosis epizootic in the ‘‘Fossil data). These findings support the notion Ridge’’ bighorn herd that resided in southern that enzootic Pasteurellaceae also can Colorado, USA. contribute to pneumonia during epizootics in bighorn sheep. In addition to Pasteu- rellaceae, both bighorns and syntopic tory methods (Safaee et al., 2006; George cattle showed evidence of exposure to et al., 2008; Dassanayake et al., 2009a; L. Mycoplasma ovipneumoniae (most likely L. Wolfe, unpubl. data) and the potential of bighorn origin), PI3, and BRSV. for pathogenicity to change within strains On the basis of findings from necropsy via horizontal transfer of the gene encod- and live animal sampling, we believe that ing leukotoxin (Kelley et al., 2007). In this pneumonia epizootic was caused by a addition to the pathogens we detected, combination of pathogens including two weather conditions may have contributed or more pathogenic strains of Pasteurella- at Fossil Ridge either as a stressor on ceae—a Mannheimia haemolytica strain bighorns or cattle, or simply by increasing most likely of cattle origin and a B. interactions between bighorns and cattle trehalosi strain most likely of bighorn (Fig. 1). Notably, however, we did not origin—with some cases perhaps exacer- observe epizootic pasteurellosis in a big- bated by exposure to Mycoplasma spp. horn herd wintering in the nearby Taylor and viruses of cattle or bighorn origin. River drainage despite equally severe Despite what we believe to be compelling winter conditions and the presence of support for this explanation, however, we several pathogens also present in the recognize that identifying the true cause(s) Fossil Ridge herd (b-hemolytic B. treha- of this and other pasteurellosis epizootics losi biogroup 4CDS, PI3, BRSV, Mycoplas- in bighorn sheep retrospectively under ma ovipneumoniae; L. L. Wolfe, unpubl. field conditions cannot be done with data), suggesting that the presence of certainty. For example, interpretation of Mannheimia haemolytica or Mycoplasma culture data is complicated by the hetero- bovirhinis in syntopic cattle may have geneity and dynamics of Pasteurellaceae in helped trigger the Fossil Ridge epizootic. bighorns and in domestic sheep and cattle Segregating wild sheep from domestic (Miller et al., 1997; Jaworski et al., 1998; sheep has long been recognized as impor- Miller, 2001; Safaee et al., 2006; Kelley et tant to preventing epizootics in bighorn al., 2007; George et al., 2008; Tomassini et sheep (Warren, 1910; Shillinger, 1937; al., 2009), and is further confounded by Foreyt and Jessup, 1982). Thus far, similar influences of sample handling and labora- emphasis has not been placed on prevent- SHORT COMUNICATIONS 1267 ing interactions between cattle and big- strain characterizations; S. Oliveira and B. horn sheep, most likely because species Schloeder at the UMVDL for Mycoplasma differences and a tendency toward inter- spp. sequencing; and R. Kahn for seeking species avoidance are thought to help and D. Larkin (RMBS) for facilitating minimize opportunities for pathogen ex- emergency funding to support our field change (Foreyt and Lagerquist, 1996). work. G. Weiser, D. Martin, and anony- However, the similarities between Pasteu- mous reviewers provided helpful com- rellaceae and other respiratory pathogens ments on earlier drafts. of cattle and domestic sheep suggest similar adverse consequences to bighorn LITERATURE CITED sheep if pathogen transmission were to BAIRD, S. C., J. CARMAN,R.P.DINSMORE,R.L. occur between cattle and bighorns (On- WALKER, AND J. K. COLLINS. 1999. Detection and derka et al., 1988; Singer et al., 2000). identification of Mycoplasma from bovine mas- titis infections using a nested polymerase chain Such consequences have been demon- reaction. Journal of Veterinary Diagnostic In- strated experimentally: five of eight big- vestigation 11: 432–435. horns died within 4 days of receiving BESSER, T. E., K. A. POTTER,E.F.CASSIRER,J. intradermal injections of a cattle vaccine VANDERSCHALIE,A.FISCHER,D.P.KNOWLES, containing attenuated, live Mannheimia D. R. HERNDON,F.R.RURANGIRWA,G.C. WEISER, AND S. SRIKUMARAN. 2008. Association haemolytica (Onderka et al., 1988), four of Mycoplasma ovipneumoniae infection with bighorns died within 2 days after intratra- population-limiting respiratory disease in free- cheal inoculation with M. haemolytica ranging Rocky Mountain bighorn sheep (Ovis isolated from cattle (Dassanayake et al., canadensis canadensis). Journal of Clinical 2009b), and one of five captive bighorns Microbiology 46: 423–430. COLORADO DIVISION OF WILDLIFE. 2009. Gunnison died 6 days after being copastured with winter feeding operations guide winter 2007– Holstein calves (Foreyt and Lagerquist, 2008. Final February 11, 2009 revised April 24, 1996). We conclude from our findings, 2009. Colorado Division of Wildlife, Denver, combined with other published observa- Colorado, 101 pp. tions, that intimate interactions between DASSANAYAKE, R. P., D. R. CALL,A.A.SAWANT,N.C. CASAVANT,G.C.WEISER,D.P.KNOWLES, AND S. wild sheep and cattle (e.g., shared feed SRIKUMARAN. 2009a. Bibersteinia trehalosi inhib- lines or troughs) also should be discour- its growth of Mannheimia haemolytica by a aged as part of a comprehensive approach proximity-dependent mechanism. Applied Envi- to health management and conservation of ronmental Microbiology, published online ahead North American wild sheep species. of print on 28 December 2009. doi:10.1128/ AEM.02086-09. Our work was funded by the Colorado ———, S. SHANTHALINGAM,C.N.HERNDON,P.K. Division of Wildlife and the Rocky Moun- LAWRENCE,E.F.CASSIRER,K.A.POTTER,W.J. tain Bighorn Society (RMBS). We thank FOREYT,K.D.CLINKENBEARD, AND S. SRIKU- N. and D. Means for property access and MARAN. 2009b. Mannheimia haemolytica serotype A1 exhibits differential pathogenicity in two assistance with field capture and for their related species, Ovis canadensis and Ovis aries. love of wildlife. We also thank M. Thorpe, Veterinary Microbiology 133: 366–371. J. Wenum, and others for field assistance; FOREYT, W. J. 1989. Fatal Pasteurella haemolytica I. LeVan, K. Griffin, K. Fox, L. Baeten, pneumonia in bighorn sheep after direct contact and others for assistance with necropsies with clinically normal domestic sheep. American Journal of Veterinary Research 50: 341–344. and sample handling; G. Weiser and L. ———, AND D. A. JESSUP. 1982. Fatal pneumonia of Lasher at CVTC and A. Hinson, T. bighorn sheep following association with domes- Gillette, A. Richecky, T. Morine, and S. tic sheep. Journal of Wildlife Diseases 18: 163– Stabler at MRI for technical assistance 168. with bacterial culture, PCR, and isolate ———, AND J. E. LAGERQUIST. 1996. Experimental contact of bighorn sheep (Ovis canadensis) with identification; R. Bey, B. Hause, R. horses and cattle, and comparison of neutrophil Shirbroun, and others at Newport Labo- sensitivity to Pasteurella haemolytica cytotoxins. ratories for assistance with Pasteurellaceae Journal of Wildlife Diseases 32: 594–602. 1268 JOURNAL OF WILDLIFE DISEASES, VOL. 46, NO. 4, OCTOBER 2010

FRANK, G. H., R. E. BRIGGS,G.C.DUFF, AND H. S. Williams and I. K. Barker (eds.). Iowa State HURD. 2003. Effect of intranasal exposure to University Press, Ames, Iowa. pp. 330–339. leukotoxin-deficient Mannheimia haemolytica at ———, J. A. CONLON,H.J.MCNEIL,J.M.BULGIN, the time of arrival at the feedyard on subsequent AND A. C. S. WARD. 1997. Evaluation of a isolation of M. haemolytica from nasal secretions multivalent Pasteurella haemolytica vaccine in of calves. American Journal of Veterinary bighorn sheep: Safety and serologic responses. Research 64: 580–585. Journal of Wildlife Diseases 33: 738–748. GEORGE, J. L., D. J. MARTIN,P.M.LUKACS, AND ONDERKA, D. K., S. A. RAWLUK, AND W. D. WISHART. M. W. MILLER. 2008. Epidemic pasteurellosis in 1988. Susceptibility of Rocky Mountain bighorn a bighorn sheep population coinciding with the sheep and domestic sheep to pneumonia in- appearance of a domestic sheep. Journal of duced by bighorn and domestic livestock strains Wildlife Diseases 44: 388–403. of Pasteurella haemolytica. Canadian Journal of ———, R. KAHN,M.W.MILLER, AND B. WATKINS. Veterinary Research 52: 439–444. 2009. Colorado bighorn sheep management plan ROSEN, L. E., D. P. WALSH,L.L.WOLFE,C.L. 2009–2019. Colorado Division of Wildlife Spe- BEDWELL, AND M. W. MILLER. 2009. Effects of cial Report Number 81, Colorado Division of selenium supplementation and sample storage Wildlife, Department of Natural Resources, time on blood indices of selenium status in Denver, Colorado, 88 pp. bighorn sheep. Journal of Wildlife Diseases 45: 795–801. GOLDBERG, T. L., T. R. GILLESPIE, AND R. S. SINGER. 2006. Optimization of analytical parameters for SAFAEE, S., G. C. WEISER,E.F.CASSIRER,R.R. RAMEY, AND S. T. KELLEY. 2006. Microbial inferring relationships among Escherichia coli diversity in bighorn sheep revealed by culture- isolates from repetitive-element PCR by maxi- independent methods. Journal of Wildlife Dis- mizing correspondence with multilocus se- eases 42: 545–555. quence typing data. Applied and Environmental SHILLINGER, J. E. 1937. Disease relationship of Microbiology 72: 6049–6052. domestic stock and wildlife. In Transactions of GREEN, A. L., N. M. DUTEAU,M.W.MILLER,J. the Second North American Wildlife Confer- TRIANTIS, AND M. D. SALMAN. 1999. Polymerase ence. American Wildlife Institute, Washington, chain reaction techniques for differentiating DC, pp. 298–302. cytotoxic and noncytotoxic Pasteurella trehalosi SINGER, F. J., C. M. PAPOUCHIS, AND K. K. SYMONDS. from Rocky Mountain bighorn sheep. American 2000. Translocations as a tool for restoring Journal of Veterinary Research 60: 583–588. populations of bighorn sheep. Restoration Ecol- GRINNELL, G. B. 1928. Mountain sheep. Journal of ogy 8: 6–13. Mammalogy 9: 1–9. TOMASSINI, L., B. GONZALES,G.C.WEISER, AND W. ONESS AND ROST H , R. F., N. M. F . 1942. A Wyoming SISCHO. 2009. An ecologic study comparing bighorn sheep study. Wyoming Game and Fish distribution of Pasteurella trehalosi and Man- Department Cheyenne Bulletin Number 1, nheimia haemolytica between Sierra Nevada Cheyenne, Wyoming, 126 pp. bighorn sheep, White Mountain bighorn sheep, JAWORSKI, M. D., D. L. HUNTER, AND A. C. S. WARD. and domestic sheep. Journal of Wildlife Diseases 1998. Biovariants of isolates of Pasteurella from 45: 930–940. domestic and wild ruminants. Journal of Veter- WARREN, E. R. 1910. The mountain sheep. In The inary Diagnostic Investigation 10: 49–55. mammals of Colorado: An account of the several KELLEY, S. T., E. F. CASSIRER,G.C.WEISER, AND S. species found within the boundaries of the State, SAFAEE. 2007. Phylogenetic diversity of Pasteu- together with a record of their habits and of their rellaceae and horizontal gene transfer of leuko- distribution. G. P. Putnam’s Sons, Knickerbock- toxin in wild and domestic sheep. Infection, er Press, New York, New York, pp. 9–12. Genetics and Evolution 7: 13–23. MILLER, M. W. 2001. Pasteurellosis. In Infectious Submitted for publication 30 November 2009. diseases of wild mammals. 3rd Edition, E. S. Accepted 13 April 2010. Ms. Jan Cutts, District Ranger USDA Forest Service Humboldt-Toiyabe National Forest Bridgeport Ranger District Bridgeport, CA

July 31, 2019

Regarding: Notice of Proposed Action, Bridgeport Southwest Rangeland Project

Dear Ranger Cutts,

Thank you for this opportunity for public comment on the proposed Bridgeport Southwest Rangeland Project.

I am writing in opposition to opening any of the proposed areas to livestock grazing.

I am a homeowner and part-time resident of Mono County, and have been hiking the canyons, steppes, and highlands of the Eastern Sierra in this region extensively for about forty years.

Over this period I have observed many instances of degradation of riparian areas, meadows, and slopes due to livestock grazing. I have written to district rangers, and have, with one exception, never received reply to my concerns.

I am unconvinced that adequate (if any) supervision and enforcement of grazing regulations is occurring in the areas where I have observed livestock, as the destruction of habitat is obvious and common.

The highland areas in the current BSRP are of even greater concern due to their greater fragility, shorter recovery opportunities, and sensitive plant and animal communities. Given what I have witnessed in lower elevation habitats, it is especially urgent that grazing be excluded from these higher areas.

Here are a few examples from lower sites:

Burt Canyon (HTNF): lower canyon, widespread riparian destruction (soil, water, plants) in the lower canyon where cattle were present and observed; similar destruction in the upper canyon due to sheep, which I witnessed. Shepherds and dogs were present, yet the sheep were inflicting widespread damage to the upland meadows and streamside. I haven’t wanted to return to this spectacular and quiet canyon since then.

Buckeye Canyon (HTNF): Dramatic, widespread destruction from cattle, which I witnessed from the trail toward the stream: mud everywhere, plants destroyed, no evidence of any supervision. The upper area, near the Roughs, was a disaster. Again, I haven’t had any desire to visit this area again. It is a loss to all but the cattle.

Parker Canyon (INF): Sheep, apparently unsupervised and seemingly way beyond allowable numbers, were in the process erasing the plant community along Parker Creek. This was a number of years ago, and I believe that problem was addressed by discontinuing the permit.

These are just a few examples from my times in the Mono County area. Further, I have seen innumerable sites of overgrazing in ranges of the HTNF in Nevada.

All of this has left me, over many years of observation, with no confidence in the management of these permits. The current proposal, to allow grazing in ultra- sensitive highland areas should be taken off the table: these lands will not recover; they are too sensitive, even if there were adequate supervision, which there is demonstrably not.

Thanks, again, for the this chance to voice my long-term observations and--based on them and on the sensitive nature of the proposed sites--my concerns about this proposal in particular.

Sincerely,

Wyneken