The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual's income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.

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Table of Contents

Chapter 1 Purpose of and Need for Action ...... 1

1.1 Background ...... 1

1.2 Description of the Allotments ...... 3 1.2.1 Dexter Creek Allotment ...... 4 1.2.2 June Lake Allotment ...... 5 1.2.3 Mono Mills Allotment ...... 5 1.2.4 Mono Sand Flat Allotment ...... 6

1.3 Purpose and Need ...... 6

1.4 Desired Condition ...... 7 1.4.1 Desired Condition for Range ...... 8 1.4.2 Desired Condition for Water Quality ...... 9 1.4.3 Desired Condition for Hydrologic and Soil Function ...... 9 1.4.4 Desired Condition for Air Quality ...... 10 1.4.5 Desired Conditions for Wildlife ...... 10

1.5 Forest Plan Direction ...... 10 1.5.1 Inyo National Forest Land and Resource Management Plan (1988) ...... 10 1.5.2 LRMP Amendment #6 – Forest-wide Range Utilization Standards (1995) ...... 10 1.5.3 Sierra Nevada Forest Plan Amendment (2004) ...... 11 1.5.4 Mono Basin National Forest Scenic Area Comprehensive Management Plan (Scenic Area Plan) (1989) 11

1.6 Public Involvement ...... 12 1.6.1 Comment and Scoping Period ...... 12 1.6.2 Native American Consultation ...... 12 1.6.3 Issues ...... 13

Chapter 2 Alternatives ...... 14

2.1 Introduction ...... 14

2.2 Alternative Development Process ...... 14

2.3 Alternatives Considered But Eliminated From Detailed Study ...... 14 2.3.1 Sage Grouse Conservation Alternative ...... 14 2.3.2 Resource Conservation Alternative ...... 15 2.3.3 Current Management Alternative ...... 15

2.4 Alternatives Considered in Detail ...... 15 2.4.1 Alternative 1 – No Action (No Grazing) ...... 15 2.4.2 Alternative 2 – Proposed Action ...... 16

2.5 Monitoring ...... 23

Chapter 3 Environmental Consequences ...... 26

3.1 Introduction ...... 26

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3.2 Effects Relative to Range Resources ...... 27 3.2.1 Existing Condition ...... 27 3.2.2 Environmental Consequences ...... 29

3.3 Effects Relevant to Hydrologic Resources, Soil, and Air Quality ...... 38 3.3.1 Existing Condition ...... 38 3.3.2 Environmental Consequences ...... 46

3.4 Effects Relative to Terrestrial Wildlife ...... 52 3.4.1 Existing Condition ...... Error! Bookmark not defined. 3.4.2 Environmental Consequences ...... Error! Bookmark not defined.

3.5 Effects Relative to Aquatic Wildlife ...... 79 3.5.1 Existing Condition ...... 79 3.5.2 Environmental Consequences ...... 84

3.6 Effects Relative to Plants and Noxious Weeds ...... 85 3.6.1 Existing Condition ...... 85 3.6.2 Environmental Consequences ...... 88

3.7 Effects Relative to Cultural Resources ...... 91 3.7.1 Existing Condition ...... 91 3.7.2 Environmental Consequences ...... 95

3.8 Effects Relative to Socio-Economic Factors...... 97 3.8.1 Existing Condition ...... 97 3.8.2 Environmental Consequences ...... 98

3.9 Effects Relative to Finding of No Significance (FONSI) Elements ...... 100

Chapter 4 Lists ...... 105

4.1 Agencies and Persons Consulted...... 105

4.2 References Cited...... 105

APPENDIX A: Allotment Maps ...... 115

APPENDIX B: Amendment #6 Matrices ...... 121

APPENDIX C: Capability and Suitability ...... 123

APPENDIX D: Response to Comments ...... 131

APPENDIX E: Comparison of Alternatives ...... 148

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List of Tables

Table 1. Current Allotment Management...... 2 Table 2. Desired Conditions for Ecosystem Communities within the Project Area...... 8 Table 3. Design Criteria for Areas Outside of Key Areas by Vegetation Community Type...... 17 Table 4. Other Actions to Reduce Utilization and/or Improve Livestock Distribution. ... 19 Table 5. Amendment #6 Standards for Utilization for the Dexter Creek Allotment...... 20 Table 6. Amendment #6 Standards for Utilization for the June Lake Allotment...... 21 Table 7. Amendment #6 Standards for Utilization for the Mono Mills Allotment...... 22 Table 8. Amendment #6 Standards for Utilization for the Mono Sand Flat Allotment.... 23 Table 9. Monitoring Plan...... 24 Table 10. Cultural Resources Recommended for Monitoring and SRPMs ...... 25 Table 11. Summary of Existing Conditions...... 28 Table 12. Stream Proper Functioning Condition and Key Area Amendment #6 Watershed Condition Rating Results for all Allotments...... 44 Table 13. Cumulative Watershed Effects Calculations for Watersheds in the Mono Basin Allotments...... 48 Table 14. Potential Sage-grouse Habitat within the Mono Basin Allotment Group...... 56 Table 15. Comparison of Sage-grouse Habitat Utilization Within and Outside Four Grazing Allotments ...... 57 Table 16. Acres of Potentially Suitable Northern Goshawk Habitat by Allotment...... 58 Table 17. Northern Goshawk Protected Activity Centers in the Mono Basin Allotment Group...... 59 Table 18. Miles of Perennial Stream...... 81 Table 20. Sensitive Species Found or With Potential Habitat in Analysis Area...... 86 Table 21. Watch List Plants and Other Rare Species Known from Analysis Area ...... 87 Table 22. Known Weed Species, with Ratings and Inyo NF Proposed Treatment (USDA FS, 2007)...... 88 Table 23. Survey Matrix ...... 93 Table 24. Project Acres-- Survey and Cultural Site Summary...... 94 Table 25. AUMs, Head Months, and Fees...... 99

Chapter 1 Purpose of and Need for Action

1.1 Background

There are five grazing allotments in the Mono Basin that vary in size from 8,696 acres to 29,263 acres (Table 1). Of those, four are currently under analysis for this environmental assessment: Dexter Creek, June Lake, Mono Mills and Mono Sand Flat. The fifth allotment, Black Canyon, will be analyzed at a later date.

Grazing by sheep and cattle has occurred in the area for over 150 years. According to Menke et al, grazing in the Eastern Sierra first took on significant proportions after 1870 at the height of the mining boom. Livestock during this period numbered in the hundreds of thousands. After the creation of the Forest Service in 1905, use became more regulated and livestock numbers decreased. However, the area was grazed beyond its capacity until relatively recent times (Menke et al, 1996).

Traditionally, sheep are grazed in the Mono Basin during the summer months and spend the rest of the year at lower elevations in other parts of California. This practice carries on today in the ranching families that have long settled here. Cattle may be moved to lower elevations, but also may spend the winter in the Eastern Sierra, as has been the case on the Mono Sand Flat Allotment.

Currently, grazing on the allotments is authorized by Term Grazing Permits that specify the terms and conditions for grazing, including the type and timing of livestock as well as any management actions necessary to meet desired rangeland conditions. The Dexter Creek and June Lake Allotments are permitted to the I&M Sheep Company for sheep. Mono Mills is currently vacant, but has previously been permitted for sheep. The Mono Sand Flat Allotment is permitted to the Hilton Family Trust for cattle. Table 1 summarizes current management practices for the Mono Basin Allotments.

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Table 1. Current Allotment Management.

Allotment Acres Capable Class of Permitted Last Season of Permitted Grazing Status Last Year Acres Livestock Numbers Use Animal System of Use (Acres On Off Unit capable Date Date Months for grazing) (AUM’s) Dexter Creek 18,781 17,556 Sheep 1,500 Ewes 6/15 9/15 Deferred Active 2010 917 Rotation* June Lake 16,528 12,705 Sheep 1,500 Ewes 7/1 8/31 Deferred Active 2010 S&G Rotation 612

Mono Mills 29,263 28,143 Sheep 4,000 Ewes 7/1 9/15 Deferred Vacant 2005 S&G Rotation 3,038

Mono Sand 8,696 8,570 Cattle 26 Cow/Calf 12/1 5/31 Season- Permittee has 2006 Flat Pairs Long** taken non- use for the 206 past four years for resource protection. *Deferred rotation is defined in Inyo National Forest Land and Resource Management Plan, Amendment #6 as, ―a system in which units are utilized for only a portion of the growing season.‖ **Season-long systems permit continuous grazing throughout the season of use. The season of use in this case is December through May.

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1.2 Description of the Allotments

The Mono Basin Allotments covered in this analysis stretch from the northeastern shore of Mono Lake to the northern slope of the Glass Mountains. They are bounded on the west by U.S. Highway 395 and on the east by Dexter Canyon. Elevations range from approximately 6,400 to 9,317 feet at Crooked Peak. The allotments are relatively flat compared to other portions of the Inyo National Forest, although the allotments other than Mono Sand Flat do have some steep areas. Precipitation ranges from about 12 inches in the Mono Sand Flat Allotment, near 6,500 feet elevation, to about 34 inches in the higher elevations in the southern tip of the Dexter Creek Allotment (30 year average using PRISM data from 1971-2000).

The project area is generally comprised of typical Eastside Sierra sagebrush/bitterbrush type communities, including: Indian ricegrass (Oryzopsis hymenoides), needlegrass (Stipa spp.) basin sagebrush (Artemesia tridentata), rabbitbrush (Chrysothamnus spp.) and bitterbrush (Purshia spp.) as well as several other woody species such Jeffery pine (Pinus jeffreyi), lodgepole pine (Pinus contorta), and single leaf pinyon (Pinus monophylla).

The project area also supports dry meadow type vegetation, which includes saltgrass (Distichlis spp.) and dry land sedges such as Douglas (Carex douglasii) and Ross (Carex rossii). Dry meadow areas are also important to species such as sage grouse.

There is very little riparian vegetation in these allotments, with a few riparian strips along creeks, a few meadows and springs in the Dexter Creek allotment, and one meadow within the Mono Mills Allotment. The spring in the Mono Sand Flat allotment is also surrounded by less than ¼ acre of riparian vegetation.

Desert shrub type communities consist of plants such as Indian ricegrass (Oryzopsis hymenoides), salt grass (Distichlis spicata), greasewood (Sarcobatus vermiculatus), rabbitbrush (Chrysothamnus spp.), and spiny hopsage (Grayia spinosa).

Bedrock consists primarily of volcanic rocks including tuff, basalt, and andesitic and rhyolitic rocks. There is also some granodiorite in the Dexter Creek Allotment. Surficial deposits are also mainly volcanically derived, including ash and pumice deposits. The Mono Sand Flat Allotment has unique surface deposits, as much of the allotment is covered in small, partially vegetated sand dunes.

Most soils are weakly developed and have low productivity, with some areas of moderate productivity and small pockets of high productivity mainly in meadows (USDA Forest Service, 1995). Because most of the area contains sandy and ashy soils with very high permeability, most of the area is often dry and the soils have little potential for compaction. Rill erosion also does not tend to occur in this area due to lack of water concentration. Wind erosion is relatively important in these often unconsolidated soils, and vegetation may return slowly when disturbed.

3 1.2.1 Dexter Creek Allotment Dexter Creek Allotment is located approximately five miles southeast of Mono Lake. Its boundaries are Dry Creek on the west, Dexter Creek on the east, the northern side of the Glass Mountains on the south, and the Forest boundary (mainly running along Highway 120) on the north. The legal description is T1S, R28E, Sections 1, 2, 11- 14, 23-26, 35, 36; T1S, R29E, Sections 1-22, 24- 26, 28- 31; T2S, R28E, Section 1.

The primary forage species are bitterbrush and bunchgrasses such as Indian ricegrass (Oryzopsis hymenoides), needlegrass (Stipa spp.), and bottlebrush squirreltail (Elymus elymoides).

Dexter Creek is used as a sheep allotment by the I&M Sheep Company. Currently, 1,500 sheep are authorized to graze from 6/15 to 9/15. Sheep are herded in bands of approximately 1,500 head. The sheep stay with the band and rarely stray as their movement is directed by a herder who also uses dogs to keep the sheep together. With two exceptions, which are noted below, the I&M Sheep Company has used the same rotation for the past ten years. The pattern is as follows:

1. On approximately July 2, unload sheep at Sagehen Summit – sheep will graze toward the valley between the Summit and Baxter Springs, avoiding pockets of freeze-damaged Bitterbrush.

2. Baxter Corral/Springs – water sheep at road crossing and limit sheep bedding ground to the north side of creek only. Avoid grazing along streambanks and riparian areas.

3. Draft livestock water from Baxter Springs at road crossing.

4. Lower Dexter Bench – water sheep at road crossing in North Canyon, at end of FS Road 1S15A, and at end of unnumbered road in NE 1/4 Sec. 18. After watering, push sheep to higher ground away from creek. All other watering will be done via truck except for one watering site at Dexter Creek.

5. Avoid wet areas and streams on upper Johnny Meadows.

6. Wild Horse Canyon to Crooked Meadows Road – sheep are allowed to water in Dexter Creek at road crossing in SW ¼ Section 30. Wild Horse Meadow – sheep will bed in trees between FS Road 1N02 and meadow. Wild Horse Meadow is closed to grazing for resource protection.

7. Sagehen Peak to Sagehen Meadow – Meadow and downstream riparian/stock pond has water. Bed sheep uphill away from dry meadow/stock pond. Making a once over pass along riparian upstream of pond is approved. Avoid grazing onto private property near edge of meadow and first gabion downstream of meadow ―proper‖.

8. Head towards Gas Pipe Spring and north of Hwy 120 to BLM allotment by September 15.

4 The first exception is that prior to 2004, the sheep started at Baxter Springs (step 2) rather than Sagehen Summit. The second exception is that Johnny Meadow was rested from 2002 to 2008.

1.2.2 June Lake Allotment The June Lake Allotment is located approximately two miles south of Mono Lake. Its boundaries are U.S. Highway 395 on the west, the Forest Boundary on the north, the Mono Craters on the east, and Wilson Butte on the south. Its legal description is: T1N, R27E, Sections 29-33; T1S, R27E, Sections 3-10, 15-22, 28-33, T2S. R27E, Sections 4-9.

The primary forage species are bitterbrush and bunchgrasses such as Indian ricegrass (Oryzopsis hymenoides), needlegrass (Stipa spp.), and bottlebrush squirreltail (Elymus elymoides).

June Lake is run as a sheep allotment by the I&M Sheep Company. Currently, 1,500 sheep are authorized to graze from 7/1 to 8/31. Sheep are herded in bands of approximately 1,500 head. The sheep stay with the band and rarely stray as their movement is directed by a herder who also uses dogs to keep the sheep together. The rotation of sheep through the allotment has been the same since 1994. The rotation is as follows:

1. Enter Allotment on approximately July 1

2. Upper Aqueduct road (1N11) to poleline .

3. Poleline road to 1N11.

4. 1N11 southeast to 1S35.

5. 1S35 South to 1S40.

6. Devil’s Punch Bowl area.

7. North along Mono Craters to Lousy Fire area.

8. Exit allotment on approximately August 31.

1.2.3 Mono Mills Allotment Mono Mills Allotment is located between the June Lake and Dexter Creek Allotment. Its boundaries are the Mono Craters on the west, Highway 120 and the Forest boundary on the north, Dry Creek on the east, and generally the northern side of the Glass Mountains on the south. The legal description is: T1N, R27E, Sections 33, 34, 28; T1S, R27E, Sections 1-3, 10- 15, 22-28, 33-36; T2S, R28E, Sections 1-4, 10, 11; T1S, R28E, Sections 3-10, 14-23, 26-35; T1N, R28E, Sections 3-6, 7.

The Mono Mills Allotment is currently vacant but was used as a sheep allotment prior to 2005. The earliest use in the Forest Service records is 1941, but the allotment has most likely been

5 grazed by sheep since the late nineteenth century. Prior to 2005, 4,000 sheep were authorized to graze from 7/1 to 9/15.

The primary forage species are bitterbrush and bunchgrasses such as Indian ricegrass (Oryzopsis hymenoides), needlegrass (Stipa spp.), and bottlebrush squirreltail (Elymus elymoides).

1.2.4 Mono Sand Flat Allotment The Mono Sand Flat Allotment is located along the northeastern shore of Mono Lake. The northern and eastern boundaries are the Forest boundary and the rest of the boundary is along the shoreline (not including relicted lands). The legal description is T3N, R27E, Sections 22-35; T3N, R28E, Sections 30-32; T2N, R28E, Sections 5-9, 21, 28, 32, 33.

Mono Sand Flat is used as a cattle allotment by the Hilton Family Trust. The Term Grazing Permit allows for 26 cattle to use the allotment between December 1 and May 31. However, the permittee has taken non-use for resource protection since 2006.

The primary forage species are plants such as Indian ricegrass (Oryzopsis hymenoides), salt grass (Distichlis spicata), greasewood (Sarcobatus vermiculatus), rabbitbrush (Chrysothamnus spp.), and spiny hopsage (Grayia spinosa).

1.3 Purpose and Need

The purpose and need for the proposed action is to move from existing to desired future conditions, which are described by certain Inyo National Forest standards and guidelines and management direction while continuing to provide for livestock grazing under updated allotment management plans in the Mono Lake Basin.

1. There is a need for continued livestock grazing under updated allotment management plans for the grazing allotments in the Mono Basin.

Livestock grazing has been identified as an appropriate use of National Forest System lands which have been found to be capable and suitable for grazing. In the Inyo National Forest Land and Resource Management Plan (LRMP), the allotments in the Mono Basin were identified as being capable and suitable for livestock grazing based on an assessment of forage production, accessibility, slope, and other factors (Management Areas 1, 5 [pp. 152]).

Where consistent with other multiple use goals and objectives there is Congressional intent to allow grazing on suitable lands. (Multiple Use Sustained Yield Act of 1960, Wilderness Act of 1964, Forest and Rangeland Renewable Resources Planning Act of 1974, Federal Land Policy and Management Act of 1976, National Forest Management Act of 1976)

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The allotments contain lands identified as suitable for domestic livestock grazing in the LRMP and continued domestic livestock grazing is consistent with the goals, objectives, standards, and guidelines of the Forest Plan (LRMP pages III-45, IV-67, IV-84-86, IV- 134-135, and IV-211).

It is Forest Service policy to make forage available to qualified livestock operators from lands suitable for grazing consistent with land management plans (FSM 2203.1; 36 CFR 222.2 (c)). Current grazing permit holders have expressed interest in continuing use of the Dexter Creek, June Lake, and Mono Sand Flat Allotments, and in resuming use of the currently vacant Mono Mills Allotment.

It is Forest Service policy to continue contributions to the economic and social well being of people by providing opportunities for economic diversity and by promoting stability for communities that depend on range resources for their livelihood (FSM 2202.1).

2. There is a need for improved range vegetation condition and trend where existing conditions are not meeting or moving toward desired vegetation condition. The LRMP, Amendment #6, and the SNFPA provide direction and the desired conditions for range vegetation.

Evaluations in 2008 and 2010 identified portions of allotments in which desired vegetative conditions were not being met. In the Mono Sand Flat Allotment, poor soil quality and dry conditions have resulted in a low density of desirable species (shrubs, bunchgrasses and herbaceous vegetation) that does not meet standards for desired vegetative composition of this community (LRMP, p.76).

In the Dexter Creek, June Lake and Mono Sand Flat Allotments, portions of the desert shrub and bitterbrush communities do not meet standards for desired vegetative condition, being moderately to heavily hedged or browsed without sufficient annual recovery (LRMP, pp.76, 105). There is also a need to ensure sufficient forage for mule deer after livestock grazing season with total annual browse utilization that maintains bitterbrush condition (LRMP, pp.85, 98-99, and 117)

Heavily hedged bitterbrush results from overgrazing due to poor livestock distribution. Distribution can be improved through management direction set forth in annual operating instructions. There is a need to ensure that grazing allotments are managed according to a planned management system. (LRMP, p. 84).

1.4 Desired Condition

Desired conditions are the on-the-ground resource conditions that management is working toward within a defined timeframe. These are the expected results if management goals are fully achieved. They bring broad-scale desired conditions from the Forest Plan down to project level.

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The Inyo National Forest Land and Resource Management Plan (LRMP) directs management of grazing lands and sets standards and guidelines. The LRMP Amendment #6 further defines standards and guidelines and defines desired conditions for range plant communities. The 2004 Sierra Nevada Forest Plan Amendment (SNFPA) also describes desired conditions for range. Parts of the area of interest are also managed under the 1989 Comprehensive Management Plan for the Mono Basin National Forest Scenic Area (Mono Basin Scenic Area Plan).

1.4.1 Desired Condition for Range The LRMP Amendment #6 directs management by prescribing utilization based on plant species composition. Desired conditions for each vegetation community (Table 2) are the conditions identified in the top two tiers or rows of the matrices in Forest Plan Amendment #6, Appendix A (See also section 1.5.2 and Appendix B of this document). Vegetation communities that fall within the third tier or below of the matrix do not meet the desired condition.

Conditions are assessed at key areas on the allotments. Using data from a 100 point transect (toe- point method), the ratio of desired species to the total number of herbaceous hits, in combination with watershed condition determines utilization standards.

Table 2. Desired Conditions for Ecosystem Communities within the Project Area.

Desired conditions for ecosystem communities within the project area from the top two tiers of Amendment #6, Appendix A matrices. Community Type Desired Future Condition At least 51 hits tallied on herbaceous species per 100 point transect with at least 51 of these hits tallied being desirable species including primarily sedges. Properly functioning water, soil and vegetation cycles. Mixed native grass and forb communities provide a mosaic of plants with species Wet Meadow diversity, a variety of vegetative structures and sufficient amounts of litter. Graminoid communities show vigor. Bare ground less than 5%. Achieve or maintain satisfactory range condition on all rangeland in this community type. At least 37 hits tallied on herbaceous species per 100 point transect with at least 37 of these hits tallied being desirable species such as sedges. Properly functioning water, soil and vegetation cycles. Diverse mix of riparian Moist Meadow graminoids and forbs present with significant proportions of riparian species relative to moisture availability. Bare ground less than 5%. Graminoid communities show vigor. Achieve or maintain satisfactory range condition on all rangeland in this community type. Aspen communities with diverse age structure of 2 or more age classes Aspen including seedlings, young plants, mature plants, decadent plants and sprouts or suckers in addition to adequate regeneration. Shrublands: Desert Shrub, At least 30 hits tallied on herbaceous species per 100 point transect with at Sagebrush/Bunchgrass and least 8 of these hits tallied being desirable species including needlegrass, Bitterbrush ricegrass and squirrel tail grass. Vigorous growth and regeneration of mid-

8 Table 2. Desired Conditions for Ecosystem Communities within the Project Area.

Desired conditions for ecosystem communities within the project area from the top two tiers of Amendment #6, Appendix A matrices. Community Type Desired Future Condition late seral shrub species interspersed with a variety of native grasses and forbs. Properly functioning water, soil and vegetation cycles. Achieve or maintain satisfactory range condition on all rangeland in this community type. Properly functioning water, soil and vegetation cycles; reproducing riparian plant communities, at least 80% of the potential vegetative cover along streams; stable, defined channels with appropriate width/depth ratios for stream type; less than 20% of streambank actively eroding, balanced erosion/deposition levels. Maintain at least 80% of potential ground cover within 100’ from the edges of all Streams & Riparian areas perennial streams, or to the outer margin of the riparian ecosystem, where wider than 100 feet. Plant species may include sedges, rushes, tufted hairgrass, willow, birch, aspen and cottonwood of mixed age class. In woody systems, riparian shrubs cover of at least 35% to include a variety of species. Achieve or maintain satisfactory range condition on all rangeland in this community type.

1.4.2 Desired Condition for Water Quality Water quality meets the goals of the Clean Water Act and the Safe Drinking Water Act; it is fishable, swimmable and suitable for drinking after normal treatment. Water quality meets all state and federal standards.

1.4.3 Desired Condition for Hydrologic and Soil Function The Sierra Nevada Forest Plan Amendment (SNFPA 2004) requires that Riparian Conservation Objectives (RCO) are met for all new projects. The RCOs apply to Riparian Conservation Areas (RCAs), which are the areas within 300 feet of perennial streams, springs, and other special aquatic features, or 100 feet of intermittent and ephemeral streams. RCOs focus on water quality, water quantity and aquatic habitat. There is a relatively small area of RCAs within the Mono Basin Allotments, so the RCOs are not applicable to most of the project area. However, they will be discussed where applicable (See Existing Conditions under Hydrologic Resources, section 3.5.2).

Amendment #6 of the LRMP contains desired conditions for soil and hydrologic function. The desired condition is that all areas are fully functional in terms of soil and hydrology.

The desired condition for stream channels is that they are in proper functioning condition (PFC) as defined by the Proper Functioning Condition protocol (USDI 1998).

9 1.4.4 Desired Condition for Air Quality Air quality meets all state and federal standards. The only air quality standard that is relevant to cattle grazing is the PM10 Standard.

1.4.5 Desired Conditions for Wildlife Wildlife habitat is managed to provide species diversity, to ensure that viable populations of existing native vertebrates and invertebrates are maintained, and that the habitats of management emphasis species are maintained or improved.

1.5 Forest Plan Direction

Management direction for the Mono Basin Grazing allotments is described in the Inyo National Forest LRMP (USDA Forest Service, 1988), as amended by LRMP Amendment 6, Forest-wide Range Utilization Standards (USDA Forest Service, 1995) and the SNFPA (USDA Forest Service, 2004).

1.5.1 Inyo National Forest Land and Resource Management Plan (1988) The Inyo National Forest LRMP establishes Forest Management Direction, including Forest goals, forest objectives, standards and guidelines, management prescriptions, and management area direction. The standards and guidelines set the minimal resource conditions for vegetative diversity and range resources.

1.5.2 LRMP Amendment #6 – Forest-wide Range Utilization Standards (1995) This document sets utilization standards for the grazing of domestic livestock that would accelerate the restoration and improvement of degraded range sites, and maintain those sites currently in good condition. A vegetation condition classification determined by toe-point transects compares the total number of desired species within a given area to the total number of herbaceous plants counted. This vegetation composition is applied to the utilization matrices— along with the watershed evaluation criteria—to determine proper use levels for a key area (LRMP Amendment 6, 1995). These utilization levels are set as a percentage of weight of a forage species that is allowed to be utilized by livestock. Standards are determined based on vegetation types within the project area including: Wet Meadow, Moist Meadow, Dry Meadow, Desert Shrub, Sagebrush, and Bitterbrush. These are presented in tables that have a different allowable use standard for early season use (E=pre-boot stage: before seed head is formed) and late season use (L=after seed maturity).

10 1.5.3 Sierra Nevada Forest Plan Amendment (2004) The Sierra Nevada Forest Plan Amendment (2004) amends the Land and Resource Management Plans of the national forests in the Sierra Nevada to address various changed circumstances and information that was not sufficiently addressed in the original plans. One of these circumstances was to establish grazing standards to better reflect the wide array of site-specific conditions and the management opportunities they may provide. Standards include use of noxious weed-free hay, streambank disturbances (specifics for TES and essential habitats), proper functioning condition (PFC) assessments, protection of bogs and fens from livestock trampling, placement of livestock handling facilities, utilization/bare ground, and trend for meadow areas and riparian browse use.

1.5.4 Mono Basin National Forest Scenic Area Comprehensive Management Plan (Scenic Area Plan) (1989) The Mono Basin National Forest Scenic Area (Scenic Area) was established by Section 304 of the California Wilderness Act (PL 98-425) in 1984. The Scenic Area Plan provides management direction, including goals, standards and guidelines, and management prescriptions for range and other resources. Parts of the June Lake, Mono Mills, and Mono Sand Flat Allotments overlap the Scenic Area boundary.

Relevant Management Prescriptions (Each of these zones overlaps parts of the June Lake, Mono Mills, and Mono Sand Flat Allotments.:

General Use Zone – Allow range improvement activities that are compatible with dispersed recreation and wildlife objectives. Permit no grazing in developed recreation sites.

There are no developed recreation sites in the areas overlapping the grazing allotments.

Under the Proposed Action, there are no range improvements planned within the General Use Zone.

Limited Development Zone – Manage grazing use to avoid sensitive areas and emphasized wildlife habitats. Allow range improvements needed to facilitate effective range management when shifting grazing to less sensitive areas.

There are no sensitive areas or emphasized wildlife habitats on the sections of the Limited Development Zone that overlap these allotments.

Under the Proposed Action, there are no range improvements planned within the Limited Development Zone.

No Development Zone – Phase out grazing from National Forest System lands, consistent with ecological, geological, cultural, and visual emphasis of this prescription. Prohibit grazing of domestic livestock on National Forest System relicted lands. Existing range improvements may remain until grazing use is

11 phased out. Improvements used in conjunction with permits to cross National Forest System lands may remain until no longer needed.

The Scenic Area Plan includes direction to close grazing allotments when permits are waived back to the government and when there is no qualified purchaser of permitted livestock and/or base property (p. 34). Consistent with the enabling legislation, ―persons currently holding valid grazing permits will continue to be able to exercise those permits consistent with other applicable law‖ (Public Law 98-425, Title III, Sec. 304(c); Scenic Area Plan, p. 32). This applies to the Mono Sand Flat Allotment.

The section of the Mono Mills Allotment in the No Development Zone is in the Mono Craters and is not grazed.

No grazing currently takes place on relicted lands, nor would this occur under the Proposed Action.

1.6 Public Involvement

1.6.1 Comment and Scoping Period A Proposed Action (October 2010) was mailed to interested parties and a legal notice requesting comments on the Proposed Action was published in the Inyo Register October 23, 2010. The scoping period ran concurrently with the comment period. Comments were received from seven organizations/agencies, including Western Watersheds Projects, Lahontan Regional Water Quality Control Board, Center for Biological Diversity, California Department of Transportation (CalTrans), City of Los Angeles Department of Water and Power (LADWP), the Mono Lake Committee (MLC), and the Utu Utu Gwaitu Paiute Tribe. Each of these comments was received prior to the end of the 30-day comment period. The comments from CalTrans, LADWP, and the Utu Utu Gwaitu Paiute Tribe did not require a response. Responses to the other comments can be found in Appendix D.

1.6.2 Native American Consultation

Native American Tribes that claim ancestral home lands within the project area were consulted pursuant to the American Indian Religious Freedom Act of 1978, Executive Order 13007 (1996), and under Section 101(d)(6)(B) of the National Historic Preservation Act of 1966 (as amended). No issues or concerns have been brought forward. This project has been discussed with the following Tribes via formal letters, phone calls and meetings. Formal consultation for this project began in April 2010.

Federally Recognized Tribes: Bridgeport Paiute Indian Colony Benton Paiute Reservation, Utu Utu Gwaitu Paiute Tribe

12 Bishop Paiute Indian Tribal Council Big Pine Paiute Tribe of Owens Valley

Not Federally Recognized Tribes or other interested groups: Mono Lake Kutzadikaa Tribe California Indian Basketweavers Association

1.6.3 Issues An issue is a point of debate, dispute, or disagreement regarding anticipated effects of the proposed action. To develop issues for the proposed project, the ID Team analyzed comments from the public and separated the issues into two groups: key issues and non-key issues. After analysis of the comments, it was determined that there were no key issues that resulted in the development of additional alternatives. The Western Watersheds Project recommended four additional alternatives, including the No Grazing Alternative, Sage Grouse Conservation Alternative, Resource Conservation Alternative, and Current Management Alternative. The No Grazing Alternative is included in the EA as an alternative considered in detail, however there were no specific actions identified for the Sage Grouse Conservation Alternative and Resource Conservation Alternative, as described under ―Alternatives Considered, But Eliminated from Detailed Study‖ (section 2.3). The Current Management Alternative is also discussed under ―Alternatives Considered, But Eliminated from Detailed Study‖(section 2.3).

13 Chapter 2 Alternatives

2.1 Introduction

This section describes the Proposed Action and alternatives to the Proposed Action considered in this Environmental Assessment. Two alternatives were analyzed in detail: Alternative 1 (no grazing) and Alternative 2 (Proposed Action). Three alternatives were considered based on comments received during public scoping, but were eliminated from detailed study, and they include: Sage Grouse Conservation Alternative, Resource Conservation Alternative, and Current Management Alternative.

2.2 Alternative Development Process

This chapter describes in detail two alternatives for managing livestock grazing practices: Alternative 1 (No Grazing) and Alternative 2 (Proposed Action). The Proposed Action was developed following direction from the District Ranger in consultation with the Forest range and resource staff.

The Inyo National Forest Land and Resource Management Plan (USDA Forest Service, 1988), Forest Plan Amendment #6: Forest-wide Range Utilization Standards (USDA Forest Service, 1995), and the Sierra Nevada Forest Plan Amendment (SNFPA) (USDA Forest Service, 2004) provide direction and the desired conditions for vegetation, riparian, aquatic, hydrology, water quality, soil, plant, wildlife, and heritage resources. Resource condition assessments in 2008 and 2010, along with grazing history and monitoring data, provided the means to assess the difference between existing conditions and desired conditions. With this comparison, management actions were identified and a proposed action was developed. The implementation of LRMP Amendment 6 for each allotment formed the basis of the proposed action.

2.3 Alternatives Considered But Eliminated From Detailed Study

2.3.1 Sage Grouse Conservation Alternative This alternative was not analyzed in detail because the proposed action alternative incorporates measures that conserve sage grouse and their habitat. In addition, no specific actions were provided in the comments received during public scoping that made this alternative different than the proposed action alternative. The proposed action alternative includes measures to reduce potential disturbance to sage grouse during the breeding season and measures to maintain suitable habitat. For example, the proposed action delays the start of grazing within suitable sage

14 grouse nesting habitat until after July 1 to reduce disturbance during the breeding season and does not allow livestock use in areas within two miles of active sage-grouse leks. The proposed action also includes allowable use standards within key areas based on existing vegetation conditions and by vegetation community type (i.e. wet meadows, upland, and riparian), and applies grazing management techniques (i.e. rotating use) to keep livestock distributed as evenly as possible throughout suitable rangelands within pasture or herd areas, as part of maintaining suitable sage grouse habitat.

2.3.2 Resource Conservation Alternative This alternative was not analyzed in detail because the proposed action alternative incorporates measures that conserve sensitive resources. In addition, no specific actions were provided in the comments received during public scoping that made this alternative different than the proposed action alternative. The proposed action alternative incorporates specific actions designed to meet or move toward desired conditions based on watershed and vegetation conditions, following direction outlined in the LRMP Amendment 6: Forest-wide Range Utilization Standards (USDA Forest Service 1995). Resource condition assessments in 2008 and 2010, along with grazing history and monitoring data, provided the means to assess the difference between existing and desired conditions. The proposed action was developed based on the comparison between existing condition and desired conditions for watershed, vegetation, aquatic and terrestrial wildlife, and cultural resources.

2.3.3 Current Management Alternative Under this alternative, livestock management and use would continue as currently being implemented on the four allotments. The current management alternative was not analyzed in detail because it does not fully meet the purpose and need for the project. There is a need for change from current management, as some specific areas on the allotments are not meeting or moving toward desired conditions in an acceptable timeframe (section 1.3 and 1.4). The proposed action alternative incorporates specific actions designed to meet or move toward the desired condition as related to the disparity between the existing condition and the desired condition.

2.4 Alternatives Considered in Detail

2.4.1 Alternative 1 – No Action (No Grazing) Alternative 1 represents the ―No Grazing‖ alternative. Under this alternative, all term grazing permits would be cancelled. No permits would be issued for the four affected allotments until

15 and unless a subsequent NEPA decision to re-authorize grazing on any or all of the allotments is made.

2.4.2 Alternative 2 – Proposed Action The Mono Lake Ranger District of the Inyo National Forest proposes to continue to permit livestock grazing within the Mono Basin Allotment Group. The Proposed Action is designed to maintain trends in vegetation and watershed conditions where current conditions are satisfactory and functioning, or improve trends where conditions are degraded or non-functional relative to livestock grazing. Collectively, these four allotments cover approximately 73,268 acres of National Forest System lands and private lands (management of private lands is not covered by this Proposed Action).

The Proposed Action would:

A. Authorize the continued grazing of livestock on the Mono Basin Allotment Group within the analysis area through issuance of a permit for each allotment. B. Implement an adaptive management system to achieve defined desired conditions through design criteria1, monitoring, and constrained flexibility

2.4.2.1 Design criteria common to all allotments under the Proposed Action

Base on-dates on plant phenology, soil moisture level, annual climate variation, or other site-specific constraints for each key area. Off-date is dependent on level of forage utilization. Distribute livestock as evenly as possible throughout suitable rangelands by managing rotation of livestock through pastures or herd areas during the specified time periods. When rested areas on sheep allotments reach desired condition, reintroduce livestock slowly by rotating the animals through the area quickly (1-2 days) for the first two years and monitor the area as per Table 9 to ensure that the area is maintained at desired condition. Restrict livestock to areas that are, at a minimum, two miles away from any active sage- grouse leks. Follow Amendment #6 protocols in Table 3 to set allowable use levels outside of key areas. Use the Forest Plan Amendment #6 forage utilization matrices to adjust allowable use levels based on vegetation composition as measured through methods such as Toe Point inventories at five-year intervals.

1 Design criteria provide the sideboards to management and define the ―constrained flexibility‖ that adaptive management provides. Design criteria state what constraints will be applied to management.

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When crossing streams or riparian areas, cross streams as perpendicular to flow as possible. Do not herd livestock parallel to the stream for extended distances.

No bedding grounds would be authorized within 500 feet of streams.

Consolidate sheep bedding grounds so that they are no less than ½ mile apart.

Do not repair or replace water tanks on these allotments until evaluated by a heritage specialist.

Sheep would be actively herded by shepherds who would keep them from entering into rested areas.

Equipment (trailers, water drafting equipment) and clothing would be cleaned before arriving on Forest land. Equipment would be considered clean when visual inspection of tires, tracks, and underbody does not reveal soil, seeds, plant material or other such debris. Disassembly of equipment components or specialized inspection equipment is not required.

Table 3. Design Criteria for Areas Outside of Key Areas by Vegetation Community Type.

Vegetation Community Design Criteria Type Grazing management standards prescribed to maintain or move toward desired condition Wet Meadow Allowable utilization level 45% or less and/or Stubble height 4-inches or more Bare ground would not exceed 5% to protect soil Upland and Grazing management standards prescribed to maintain or move toward Shrublands desired condition (including Allowable herbaceous utilization level 50% or less Bitterbrush Allowable browse utilization level 45% or less and/or and Sagebrush Residual dry matter average of 300 pounds per acre or more to protect Communities) soil

17 Table 3. Design Criteria for Areas Outside of Key Areas by Vegetation Community Type.

Vegetation Community Design Criteria Type

Grazing management standards prescribed to maintain or move toward desired condition

Allowable herbaceous utilization level 45% or less

Allowable browse utilization level 20% of annual leader growth of mature riparian shrubs and trees. No more than 20% of seedlings can be browsed. Riparian Remove livestock from any area of the allotment when browsing indicates a change in livestock preference from grazing herbaceous vegetation to browsing woody riparian vegetation.

Streambanks would not exceed 20% disturbance per reach.*

* Earth disturbance is defined as complete removal of vegetation or a percentage of bare ground resulting from the disturbance (USDA, 1995a)

Adaptive grazing management allows land managers to use monitoring as a tool to achieve desired conditions. A course of action is chosen with the goal of reaching and maintaining desired conditions. If monitoring shows that goals continue to go unmet, additional actions may be taken in order to move towards those goals. These additional actions would be aimed at reducing grazing pressure on areas not meeting standards and guidelines if the initial actions prove to be inadequate. Reduction of grazing pressure would be achieved by reducing utilization or improving livestock distribution. By applying principles of adaptive management, land managers would be able to determine the best combination of actions required to ensure that allotments meet desired conditions. These actions would be set forth in each allotment’s Annual Operating Instructions. Table 4 summarizes possible actions that could be used in an adaptive management approach.

18 Table 4. Other Actions to Reduce Utilization and/or Improve Livestock Distribution.

Grazing Management Actions* Use of salt or supplement to draw livestock toward or away from specific areas Requiring herding dogs to control livestock distribution Adjusting the grazing season (livestock turn-on and removal dates) Adjusting the stocking rate (AUMs per acre) Resting areas from livestock grazing for one or more seasons Do not allow livestock grazing Implement rest-rotation grazing system** Implement a once-over grazing system*** * Possible management practices are designed to be used alone or in combinations in order to achieve management objectives. **Rest-rotation includes only the two-pasture rest rotation system in which there would be total rest on one pasture and season- long use on the other. ***Once over grazing refers to a duration of approximately three days for sheep or five days for cattle, within a given management unit.

2.4.2.2 Allotment Specific Actions:

Dexter Creek Allotment

Authorize grazing for sheep.

Permit for 1,500 ewes for a total of 917 Animal Unit Months (AUM)

Delay on date until 6/15 to avoid conflict with sage-grouse breeding season.

Consolidate bedding grounds so that they are no less than one half mile apart from each other.

In order to protect resources at Baxter Springs, construct a drift fence along eastern edge of road 1S15 from the sheep corral to approximately 150 meters south of Baxter Creek.

Reduce utilization in Johnny Meadow to 0%, allowing the meadow to rest until it reaches desired conditions. If desired conditions are met, then allow grazing at allowable use levels specified by Amendment #6 protocols (see Appendix A).

Set utilization level in Key Area 5 to 0%. If desired conditions are met, then allow grazing at allowable use levels specified by Amendment #6 protocols (see Appendix A).

Keep utilization at Wild Horse Meadow at 0% until recovery is documented.

19 Keep utilization at Crooked Meadows at 0% until recovery is documented.

Authorize permittee to use of Roads 01S471 and 01S526, which are closed to the public under the Inyo National Forest Motor Vehicle Use Map (2010).

Assure that the trough at Baxter Springs is thoroughly drained and dry when domestic sheep have vacated this portion of the allotment.

Remove bull thistle and mullein from Baxter Spring area by hand. May use shovels to remove stem base.

Locate all bedding grounds, watering sites and trails outside northern goshawk protected activity centers.

Table 5. Amendment #6 Standards for Utilization for the Dexter Creek Allotment.

Dexter Creek Utilization Key Range Type Amendment #6 Standards** Area Early Late

5* Bitterbrush 40% 30% 6 Bitterbrush 50% 40% 7a Bitterbrush 50% 40% 35% 25% 8* Johnny Meadow (Moist) Exc Bitterbrush 50% 40% *Because this area does not meet desired conditions and recent utilization has been lower than Amendment #6 standards, utilization would be set at 0% until recovery is documented. Recovery is achieved when the area meets desired conditions. **Early = before seed heads are formed on grasses. Late = after seed heads are formed

June Lake Allotment

Authorize grazing for sheep.

Permit for 1,500 ewes for a total of 612 AUM’s.

Delay on date until 7/1 to avoid conflict with sage-grouse breeding season and to avoid the possibility of interaction between domestic sheep and Sierra Nevada big horn sheep.

20 Consolidate bedding grounds so that they are no less than one half mile apart from each other.

Set utilization in Key Area 1 to 0% until recovery is documented. If desired conditions are met, then allow grazing at allowable use levels specified by Amendment #6 protocols (see Appendix A).

Restrict use of the 2010 Mono Fire area until upward trend according to Amendment #6 standards is documented.

Table 6. Amendment #6 Standards for Utilization for the June Lake Allotment.

June Lake Creek Utilization Key Range Type Amendment #6 Standards Area Early Late**

1* Bitterbrush 40% 30%

2 Bitterbrush 50% 40% 3 Bitterbrush 50% 40% *Because this area does not meet desired conditions and recent utilization has been lower than Amendment #6 standards, utilization would be set at 0% until recovery is documented. Recovery is achieved when the area meets desired conditions. **Early = before seed heads are formed on grasses. Late = after seed heads are formed

Mono Mills Allotment

Authorize grazing for sheep.

Permit for 4,000 ewes for a total of 3,038 AUM’s from 7/1 to 9/15.

Consolidate bedding grounds so that they are no less than one half mile apart from each other.

No sheep bedding grounds are authorized in Mono Mills town site.

No sheep bedding grounds are authorized on the pumice sand flats.

Sheep will not be loaded or unloaded at Big Sand Flat.

21 Remove sheep bedding ground/high use area from water pond, water collection site south of Highway 120 in the Big Sand Flat area.

In order to improve livestock distribution, consider installing a centrally located well and water tank to provide approximately 4,000 gallons of water per day. Permittees would use this site to fill water trucks and take the water elsewhere. Livestock would not be watered in the vicinity of the well. Further analysis of this action would take place once the location of the proposed well is established.

If a well is installed in potential sage-grouse habitat within the Mono Mills Allotment, assure that construction does not allow water to pond in the vicinity.

Inspect existing wells on the allotment and repair if possible to help improve livestock distribution.

Permittee is not authorized to take vehicles off road to access water sources.

Locate all bedding grounds, watering sites and trails outside northern goshawk protected activity centers.

Table 7. Amendment #6 Standards for Utilization for the Mono Mills Allotment.

Mono Mills Utilization Key Range Type Amendment #6 Standards** Area Early Late

1 Bitterbrush 50% 40%

2 Bitterbrush 50% 40% 5 Bitterbrush 50% 40%

Mono Sand Flat Allotment

Authorize grazing for cattle.

Permit for 26 cow/calf pairs for a total of 206 AUM’s from 12/1 to 5/30.

Rest allotment until recovery is documented. While being rested, utilization will be set at 5%. Per Amendment #6, ―the 5% allowable use is for incidental use only. The intent is not to have grazing at this level‖ (USDA Forest Service, 1995).

Permittee is not authorized to take vehicles off road to access water sources.

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Table 8. Amendment #6 Standards for Utilization for the Mono Sand Flat Allotment.

Mono Sand Flat Utilization Key Range Type Amendment #6 Standards** Area Early Late

1* Desert Shrub 30% 20%

2* Desert Shrub 30% 20% *Because this area does not meet desired conditions and recent utilization has been lower than Amendment #6 standards, utilization would be set at 5% until recovery is documented. Recovery is achieved when the area meets desired conditions. **Early = before seed heads are formed on grasses. Late = after seed heads are formed

2.5 Monitoring Monitoring that would occur if the Proposed Action was implemented is specified in the Monitoring Plan outlined below. This plan includes both implementation and effectiveness monitoring. Implementation monitoring is used to determine if the grazing activity is implemented as designed. Effectiveness monitoring is conducted to determine if the management practices applied have been effective in moving toward or maintaining desired condition and meeting resource objectives. The monitoring process involves collecting data to determine, what—if any—adjustments are needed to meet the desired conditions and the standard and guidelines outlined in LRMP Amendment #6 and SNFPA. Project-specific monitoring would be conducted at the key areas as described in the Proposed Action. At least 20 percent of the key areas shall be monitored annually.

Key areas on the allotments are chosen because they are representative of the allotment as a whole. Monitoring of key areas allows one to extrapolate the condition of the rest of the allotment and to determine the effects of livestock grazing and its management. By monitoring key areas regularly it is possible to adjust management in order to produce desired conditions.

Weeds

The on-going monitoring of Astragalus monoensis inside and outside the existing exclosure at Big Sand Flat will continue at a minimum of five-year intervals. An initial assessment of the amount of reproductive output removed from Lupinus duranii plants at populations on the allotments will be done and additional monitoring scheduled as needed, depending on the results of the initial study.

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Table 9. Monitoring Plan.

Monitoring Item Method Frequency Variability Indicating Action Implementation Monitoring (Permit Administration) Permit Compliance Allotment and Units Ongoing, annual permittee Non-compliance Inspections actual use reports Annual Operating AOI meetings Annually Non-compliance Instructions (AOI) Fee Payment Bill for Collection Annually Bill not paid by due date Livestock numbers Count livestock Random Numbers outside of AOI authorized for season. Excess use Allotment inspections Ongoing All excess use Improvement maintenance Inspections Ongoing Failure to maintain improvements Salting Allotment inspections Ongoing Failure to follow AOI instructions Range Readiness R5 range readiness Pre-season and ongoing as Range not ready for procedure needed grazing Forage utilization Key Species, Extensive 20% of key areas Annually Utilization standards Browse exceeded Streambank MIM, Alteration by Ongoing Downward trend Stability/Disturbance livestock, Stability and Cover Effectiveness Monitoring Riparian Ecologic Rooted Frequency, 3-5 years Downward trend Condition and Trend Greenline MIM, PFC, Photo Points, BMP Upland Ecological Line Intercept, Toe Point, 3-5 years Downward trend Condition and Trend Shrub age and form Class,

24 Table 10. Cultural Resources Recommended for Monitoring and SRPMs

Allotment Sites Recommended for Annual Monitor Resource Protection RPM Monitoring Count Measures Count Dexter Creek 05-04-51-0001 (CA-MNO-1522) Avoidance of site area 05-04-51-151(CA-MNO-738) 05-04-51-0189 (CA-MNO-822) 05-04-51-1651 (CA-MNO-4744) 5 Drift fence along eastern edge 3 of road 1S15

05-04-51-1657 (CA-MNO-4740) Avoidance of site area June Lake S&G 05-04-51-1649 (26-6152) Repair or replacement of water tanks in this allotment need to 1 be reviewed by a cultural 1 resource specialist prior to approval Mono Mills S&G 05-04-51-0006 (CA-MNO-0116) 05-04-51-0598 (CA-MNO-0534) No off road access to 05-04-51-0419 (CA-MNO-4622) creek/spring

05-04-51-0515 (26-5697) 4 Repair or replacement of metal 2 water tanks in this allotment need to be reviewed by a cultural resource specialist prior to approval Mono Sand Flat 05-04-51-1658 (CA-MNO-4741) No off road access to 05-04-51-1659 (CA-MNO-4742) 2 creek/spring 1 When allotment is used after rest Total Annual Monitoring Resource Protection 12 7 Measures

25 Chapter 3 Environmental Consequences

3.1 Introduction

This section summarizes the physical, biological, social, and economic environments of the affected project area and the potential changes to those environments due to implementation of the alternatives. It describes the environmental impacts of the proposal in relation to whether there may be significant environmental effects as described in 40 CFR 1508.27. Further analysis and conclusions about the potential effects are available in resource specialist reports and other supporting documentation located in the project record. These reports contain more detailed data, methodologies, analyses, conclusions, maps, references, and technical documentation that the resource specialist relied upon to reach the conclusions in this EA. The following documents are incorporated by reference and available upon request:

Biological Assessment for Domestic Sheep Grazing Within the Mono Basin Grazing Allotment Project. Richard Perloff, Wildlife Biologist, Inyo National Forest. January 21, 2011.

Biological Evaluation for Aquatic Species. Lisa Sims, Fish Biologist, Inyo National Forest. January 14, 2011.

Biological Evaluation Sensitive Plant Species. Sue Weis, Assistant Forest Botanist, Inyo National Forest. January 21, 2011.

Biological Evaluation—Terrestrial Animals. Richard Perloff, Wildlife Biologist, Inyo National Forest. January 25, 2011

Cultural Resource Analysis. Crystal West, North Zone Archaeologist, Inyo National Forest. January 13, 2011.

Hydrology and Soils Input for the Mono Basin Grazing Allotments EA. Erin Lutrick, Hydrologist, Inyo National Forest. January 21, 2011.

Inyo National Forest Land and Resource Management Plan. 1988.

Inyo National Forest Land and Resource Management Plan Amendment 6, Forestwide Grazing Utilization Standards. 1995.

Inyo National Forest Land and Resource Management Plan Amendment, Sierra Nevada Forest Plan Amendment. 2004.

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Management Indicator Species Report. Richard Perloff, Wildlife Biologist, Inyo National Forest and Lisa Sims, Fish Biologist, Inyo National Forest. January 25, 2011.

Noxious Weed Assessment. Sue Weis, Assistant Forest Botanist, Inyo National Forest. January 13, 2011.

Rangeland Resources for the Mono Basin Grazing Allotments. April Barron, North Zone Rangeland Management Specialist, Inyo National Forest. January 14, 2011.

3.2 Effects Relative to Range Resources

The discussion below is taken from the Range Report for the Mono Basin Grazing Allotments, which is hereby incorporated by reference (Barron 2011a).

3.2.1 Existing Condition

Sheep and cattle have grazed the entire project area since the late 19th Century. Most of the rangelands in this proposal have been grazed under permit with the Forest Service since the creation of the Inyo National Forest in 1907. Permittees operate on the allotments according to the terms and conditions of their term grazing permits. Specific instructions for management are relayed yearly in each allotment’s Annual Operating Instructions (AOIs). Range personnel make compliance checks throughout the grazing season. Permittees who do not comply with the terms and conditions of their permits may lose their grazing privileges if a pattern of noncompliance emerges.

Table 11 summarizes existing conditions on the allotments.

.

27 Table 11. Summary of Existing Conditions.

Existing Conditions at Mono Basin Grazing Allotment Key Areas Allotment Key Range PFC Desired % in Am. 6 Amendment #6 Area Type Rating Plants/ Form Matrices Watershed Total Classes Top Two Condition Herbaceous 3 or 6* Tiers (y/n)** Dexter 5 Bitterbrush NA 32/53 35% n Fully Functional Creek Dexter 6 Bitterbrush NA 18/50 No Data y Fully Functional Creek Dexter 7a Bitterbrush NA 22/46 7% y Creek Fully Functional Fully Functional Dexter 8 Johnny NA 34/79 NA n Creek Meadow

(Moist) Dexter Exc Bitterbrush NA 20/59 No Data y Fully Functional Creek June 1 Bitterbrush NA 43/62 32% n Fully Functional Lake June 2 Bitterbrush NA 33/44 0% y Fully Functional Lake June 3 Bitterbrush NA 38/51 0% y Fully Functional Lake Mono 1 Bitterbrush NA 31/42 0% y Fully Functional Mills Mono 2 Bitterbrush NA 22/54 0% y Fully Functional Mills Mono 5 Bitterbrush NA 24/51 0% y Fully Functional Mills Mono 1 Desert NA 0/38 NA n Fully Functional Sand Flat Shrub Mono 2 Desert NA 2/21 NA n Not surveyed Sand Flat Shrub

*Form class refers to the degree of hedging of bitterbrush. Classes are described with the bitterbrush matrix in Appendix A. ** One of the factors necessary for an area to be at desired condition is the ratio of desired plants to herbaceous species must lie in one of the top two tiers of the Amendment #6 matrices.

3.2.1.1 Dexter Creek Allotment The Dexter Creek Allotment is characterized by a bitterbrush plant community with some meadows and areas of Jeffrey pine. Three of the five key areas studied were at desired condition. One was not at desired condition due to severe hedging of bitterbrush and another, at Johnny Meadow, was not at desired condition due to a low number of desirable species. However, both

28 of these areas were rated fully functional for Amendment #6 watershed condition. In Key Area 5, species composition also fell into the top two tiers of the Amendment #6 matrices.

3.2.1.2 June Lake Allotment The June Lake Allotment is also dominated by bitterbrush and sagebrush with native perennial bunchgrasses. Data collection showed key areas to be at desired condition with the exception of Key Area 1 which was not at desired condition due to severe hedging of bitterbrush. Species composition met Inyo National Forest standards and guidelines. Key Area 1 is located in the vicinity of a bedding ground. Because of this, it may be grazed more than other areas and is therefore not necessarily representative of the condition of the allotment a whole.

3.2.1.3 Mono Mills Allotment The Mono Mills Allotment has not been grazed for the past four years. The allotment is characterized by stands of Jeffrey pine interspersed with open areas of bitterbrush and sagebrush. The key areas within the allotment are in desired condition.

3.2.1.4 Mono Sand Flat Allotment The Mono Sand Flat Allotment is a desert shrub plant community. Soils are sandy and prone to drifting. Some pedestalling is apparent, but this is a natural occurrence in a sand dune environment (Hydrologist’s note, Amendment #6 Watershed Analysis Field Record 2008). Data collection revealed a low percentage of desired species and both key areas are in unsatisfactory condition. Dry conditions for the past several years have contributed to this decline in condition. Rest and wetter years in the future could bring the allotment back in line with Inyo National Forest standards and guidelines.

The most common species found were greasewood (Sarcobatus vermiculatus), salt grass (Distichlis spicata), and rabbitbrush (Chrysothamnus nauseosus). None of these are desired species under Amendment #6 standards for desert shrub plant communities. Desired species that were found were Indian ricegrass (Oryzopsis hymenoides) (one hit out of 50 points on a transect) and spiny hopsage (Grayia spinosa) (one hit out of 50 points on a transect). There is minimal forage on this allotment and only 26 cow/calf pairs are allowed to graze each season. Cattle graze the Mono Sand Flat Allotment in conjunction with the adjacent BLM lands.

3.2.2 Environmental Consequences

3.2.2.1 Direct, Indirect and Cumulative Effects of No Grazing (Alternative 1) Alternative 1 represents the ―No Grazing‖ alternative. Under this alternative, all term grazing permits would be cancelled. No permits would be issued for the four affected allotments until and unless a subsequent NEPA decision to re-authorize grazing on any or all of the allotments is made.

From an ecological perspective, the No Grazing alternative would allow areas at less than desired conditions to improve at natural rates of recovery. Areas with heavily hedged bitterbrush should recover in two to three years with complete rest. This is because the degree of hedging is

29 based on the condition of two-year-old wood (BLM, 1996). With no grazing, no hedging would be apparent after two years has passed.

Crooked Meadow and Wild Horse Meadow, having already been rested for several years, would take several more years, possibly decades, to return to desired condition (Milchunas, 2006).Without grazing pressure, satisfactory areas would likely be able to maintain desired conditions. Under the No Grazing alternative, those plants favored by livestock would be more likely to consistently maintain high vigor, produce greater amounts of seed, and possibly increase their populations, leading toward maintenance of a more diverse species composition (Dietz, 2006). This is because the possibility of livestock grazing would be eliminated.

Meadows would likely maintain or gain mixed native grass and forb communities that provide a mosaic of plants with species diversity, a variety of vegetative structures, and sufficient amounts of litter. Graminoid communities are expected to show vigor.

Aspen stands would be more likely to have a diverse age structure of two or more age classes, including seedlings, young plants, mature plants, decadent plants, and sprouts or suckers in addition to adequate regeneration. Livestock grazing is not the only factor contributing to aspen decline and cessation of grazing alone would not guarantee recovery.

Shrublands would likely show vigorous growth and regeneration of mid to late seral shrub species interspersed with a variety of native grasses and forbs. Without grazing, overgrazed shrubs should recover in two to three years. Bedding grounds would recover more slowly.

Riparian areas would likely have at least 80% ground cover within 100 feet of the edge of the stream or to the outer margin of the riparian ecosystem where wider than 100 feet. In woody systems, riparian shrub cover would likely be at least 35% and include a variety of species.

But despite the likelihood of improvement, not all unsatisfactory areas would necessarily return to their pre-disturbance state if grazing pressure was removed (Friedel 1991, Laycock 1991). Ending grazing alone should lead to improvement of livestock induced disturbance, but changes in range condition, especially species composition, can depend on many factors. However, it is likely that species composition would trend towards desired condition.

Cumulative Effects

The area affected by grazing lies within the boundaries of the Mono Basin Grazing Allotments. Because the NEPA decision covers ten years, the effects of the No Grazing Alternative would be seen throughout the next decade. However, the effects of previous overgrazing (i.e. grazing that took place before 2011, such as the overgrazing that caused the degraded conditions currently seen at Crooked Meadows) may yet take decades to resolve.

30 Activities other than grazing that affect the condition of the range include recreation, implementation of the 2009 Travel Management EIS Decision, and fuels reduction projects, including prescribed fire. Conditions can also be affected by climate and wildfires.

Recreation has a minimal impact on these four allotments. There are a few primitive camp sites, but these are in areas populated by Jeffrey pines, not in areas where grazing normally occurs. The most common recreation activity on these allotments is off-highway vehicle (OHVs). Implementation of the 2009 Motorized Travel Management Record of Decision may reduce the amount of off highway vehicle use in the allotments as unauthorized routes are closed to public travel. Approximately 67 miles of road will be closed within the Mono Basin Allotments. There are no reasonably foreseeable future proposals to decommission the unauthorized routes or convert them to other uses such as non-motorized trails. However, some revegetation of these routes is expected as motorized use is discontinued, leading to some minor, localized improvement in range condition.

Areas where fuels reduction occurs are not generally primary range, as forage is sparse under tree canopies. Fuels reduction will not negatively impact livestock operations and may improve the availability of forage. Fire suppression has resulted in trees beginning to dominate what were formerly sagebrush and bitterbrush shrublands. Fuels reduction reduces competition, allowing shrubs and bunchgrasses to move back in. This is a positive impact on range conditions.

Prescribed fire will have an effect similar to fuels reduction. In the pre-European era, wildfires reduced the number of trees, allowing for a more open canopy. Fire would periodically sweep through these environments and burn the shrublands, encouraging new growth and regeneration. Prescribed fire can fulfill these functions and help restore the range to a state resembling the pre- European environment. In the long run, prescribed fires would result in higher quality forage. Prescribed fire has been used to treat approximately 9,265 acres within the Mono Basin Allotments.

Climate, along with soils, hydrology, and geography, is one of the factors that ultimately determine the state of vegetation in a region. Climate change may affect range conditions within the project area, although the effects of that climate change are not well known. It is predicted for the region containing the project area that the climate will become warmer, precipitation will remain about the same, but more of that precipitation will occur as rain instead of snow and there will be more extreme weather events such as drought and floods (Furniss et al, 2010). A decrease in the amount of snow would lead to a decrease in snow melt in the spring, leaving less water for plants and riparian areas. However, although climate change will be a factor in range condition in the years to come, it is not possible to predict with any certainty what changes may occur in the next decade or what their significance might be.

Since the year 2000, wildfire has affected 6,350 acres within the Mono Basin Allotments. Wildfire can have a beneficial effect on range conditions, as it removes excess vegetation and allows for regeneration and new growth. However, wildfire can also allow invasive species such as cheat grass (Bromus tectorum) to move in. Wildfires in the project area have not resulted in heavy weed infestation. The 2010 Mono Fire area does not seem to be threatened by weed invasion (Weis, 2011b).

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Determination

There would be no adverse cumulative effects of the No Grazing Alternative when combined with past, present, and reasonably foreseeable future actions within the project area. Under Alternative 1, the purpose and need of improved range vegetation condition and trend would be met, but the purpose and need of continued livestock grazing would not be met.

3.2.2.2 Direct, Indirect, and Cumulative Effects of the Proposed Action (Alternative 2) To avoid repetition, the effects described below pertain to all four allotments. Effects specific to individual allotments are in separate sections below.

The Inyo National Forest Land and Resource Management Plan (LRMP), LRMP Amendment #6, and Sierra Nevada Forest Plan Amendment (SNFPA) standards and guidelines are designed to maintain or move rangeland vegetation to desired conditions. The effects are measured in meadows, shrublands (uplands), aspen stands, and riparian areas. These standards are designed to provide a measurable utilization standard in combination with trend monitoring, in order to provide a more consistent tool for long-term adaptive management in perpetuating healthy and vigorous plant communities throughout the allotments for long term sustainability of the rangeland resources. Because management has met standards and is meeting or moving toward desired conditions in most locations under these standards and guidelines, it is reasonable to assume that this positive trend will continue under similar management including appropriate changes where needed.

Meadows would likely maintain or gain mixed native grass and forb communities that provide a mosaic of plants with species diversity, a variety of vegetative structures, and sufficient amounts of litter. Graminoid communities are expected to show vigor. This would be achieved by keeping allowable utilization levels to 45% or less with stubble height of four inches or more and bare ground not exceeding 5%.

Aspen stands would be more likely have a diverse age structure of two or more age classes, including seedlings, young plants, mature plants, decadent plants, and sprouts or suckers in addition to adequate regeneration. This would be achieved by maintaining allowable browse utilization levels at 20% of annual leader growth for mature trees. No more than 20% of seedlings would be browsed. Livestock would be removed from any area of the allotment when browsing indicates a change in livestock preference from grazing herbaceous vegetation to browsing woody riparian vegetation. Livestock grazing is not the only factor contributing to aspen decline and cessation of grazing alone would not guarantee recovery.

Shrublands would likely show vigorous growth and regeneration of mid to late seral shrub species interspersed with a variety of native grasses and forbs. This would be achieved by keeping allowable herbaceous utilization at 50% or less, allowable browse

32 utilization at 45% or less, and maintaining an average of 300 pounds or more per acre of residual dry matter. Overgrazed shrubs should recover in two to three years. Because bedding grounds would be consolidated, many current bedding grounds would no longer be used and would show a decrease in bare ground and increase in mid to late seral plant species.

Riparian areas would likely have at least 80% ground cover within 100 feet of the edge of the stream or to the outer margin of the riparian ecosystem where wider than 100 feet. In woody systems, riparian shrub cover will be at least 35% and include a variety of species. This would be achieved by keeping allowable herbaceous utilization to 45% or less and browse utilization to 20% of annual leader growth of hardwood seedlings. Stream banks would not exceed 20% disturbance per reach.

Direct effects of grazing can be loss of plant cover and litter, soil disturbance, and streambank alteration. The proposed action is designed to use Amendment #6 standards to lessen these impacts. Areas not at desired condition would be rested and would thus be able to improve, while areas that are at desired condition would be managed to maintain or improve upon their present state. If monitoring shows that the areas are not moving towards or maintaining desired conditions, adaptive management measures would be used to alter use on the allotments (Table 4). For example, if conditions seem to indicate a downward trend, the grazing season could be shortened so that the livestock spend less time grazing in the area.

Continuing to apply Amendment #6 grazing standards would ensure that livestock are distributed more evenly throughout the allotments because they guard against livestock remaining in one area for too long. Once the Amendment #6 level of utilization is reached, livestock would be moved to another location. Pressure would be removed from areas not at desired condition. This would reduce the amount of hedging and trampling in the affected areas and allow for an increase in the number of desirable species.

Applying Amendment #6 standards would require working closely with the permittees and checking utilization regularly during the grazing season, which would allow for annual operating plans that would also result in a more even distribution of livestock and grazing across an allotment. Promoting more even use means that previously ungrazed plants would have more of a chance of being grazed (which would stimulate growth) and that individually, frequently grazed plants would be grazed fewer times. With more even distribution, range condition can improve with little or no reduction in livestock numbers (Anderson, 1967; Holechek et al, 2004).

Because areas not at desired condition would be rested under the Proposed Action, recovery in those areas would proceed in the same manner as under Alternative 1. Overgrazed bitterbrush would probably take two to three years to return to desired condition. Unsatisfactory meadow areas, having already been rested for several years, would take several more years, possibly decades, to return to desired condition (Milchunas, 2006). Satisfactory areas would likely maintain desired conditions because sheep grazing on the allotments will be moderate and will take place in the summer. It has been shown that moderate summer grazing by sheep has little effect on the amount of vegetation or species composition (Harniss and Wright, 1982). If

33 conditions did appear to deteriorate, Amendment #6 allows utilization standards to be reduced progressively if conditions appear to be declining in order to maintain areas at their desired state.

Improved distribution of livestock would also lead to an increase in overall plant vigor because overgrazing would be less likely to occur. Ending over-utilization of forage and browse would allow for the maintenance and/or increase of desirable vegetation (Dietz 2006). Increase in vegetation allows for more ground cover, reduced erosion, retention of soil water, and encourages new growth.

On allotments grazed by sheep, livestock movement would be controlled by herding. The permittees run gregarious breeds of sheep (white-faced and Rambouillet), which rarely stray from the herd. Also, a herder stays with the sheep throughout their time on the allotment. In this way, herders would be able to strictly adhere to the Annual Operating Instructions so that utilization standards would not be exceeded.

Possible Management Actions Employed in Adaptive Grazing Management

Actions described in Table 4 would be taken alone or in combination if the range condition was not on a static or upward trend. These measures are designed to protect resources.

Many of these measures result in more efficient distribution of livestock, which, as stated above, can improve range condition. Use of salt or supplement can draw livestock towards or away from specific areas. Livestock are attracted to salt and supplement blocks. If the blocks are placed some distance from a problem spot such as an overgrazed riparian area, livestock will go to the blocks, leading to less use around the riparian area. Herding dogs can be used to control livestock movement.

Other actions involve resting all or part of an allotment. Resting areas for one or more seasons, not allowing grazing, and implementing a rest-rotation grazing system all fall under this category. Resting areas for one or more seasons would have the same effect as the No Grazing Alternative throughout the period of time the areas are rested. Livestock could then be returned to the area and other management tools under the Proposed Action would be used to ensure that the range continues to trend towards desired condition. Not allowing grazing would have the same effect as the No Grazing Alternative. Under a rest-rotation system, per Amendment #6, the allotment is broken up into two pastures and each year one pasture would be rested while the other would be grazed. This could lead to improved forage conditions. A negative effect of the rest-rotation system is that the pasture being grazed gets increased use. However, the rest- rotation system could be used in conjunction with fewer numbers of livestock so that concentration of use will not increase.

34 In the once-over grazing system, livestock graze areas with low to moderate intensity for a short period of time. This has the benefit of preventing over-grazing and allowing plants more time to grow without grazing pressure. This could lead to increased plant vigor, less trampling and bare ground, and healthier riparian areas.

Adjusting the grazing season (livestock turn-on and turn-off dates) can be used to decrease the number of grazing days or it can be used to come on or off of the allotment at a time more beneficial to plants and wildlife. For instance, a later turn-on date could allow plants more time to flower and produce seed.

Adjusting the stocking rate can help to improve range condition. Stocking rate can be an important factor that governs ―vegetation, animal, and financial outcomes from rangeland livestock grazing‖ (Holechek et al, 2004).

Dexter Creek

Conditions on the Dexter Creek Allotment meet Inyo National Forest standards and guidelines except for at Key Area 5 where more than 15% of the bitterbrush is heavily hedged and at Johnny Meadow where there is not a high enough ratio of desired plant species to plant species in general. Key Areas 6, 7a, and Exc (this area was formerly an exclosure, but the fencing is no longer extant) meet standards and guidelines, therefore, continuing current management should allow for maintenance of desired conditions in these three areas. Conditions in Johnny Meadow would likely improve relative to current conditions. Conditions in Wild Horse Meadow and Crooked Meadow, which have been rested for the past several years, would likely continue to improve their condition. Key Area 5 would likely recover from overhedging of bitterbrush. Areas with heavily hedged bitterbrush should recover in two to three years with complete rest. This is because the degree of hedging is based on the condition of two-year-old wood (BLM, 1996). With no grazing, no hedging would be apparent after two years have passed.

June Lake

Conditions on the June Lake Allotment are at desired condition except for at Key Area 1 where the bitterbrush is overgrazed. Current management is working in Key Areas 2 and 3; therefore, continuing this management would allow for maintenance of desired conditions in these areas. Key Area 1 is located near a concentrated use area and so is not really representative of the allotment as a whole. However, utilization at Key Area 1 would be set at 0% until recovery is documented (i.e. the area meets desired condition), allowing areas with heavily hedged bitterbrush to recover in two to three years with complete rest. This is because the degree of hedging is based on the condition of two-year-old wood (BLM, 1996). With no grazing, no hedging would be apparent after two years have passed.

35

Mono Mills

Setting utilization at Amendment #6 prescribed levels would allow the allotment to remain at desired condition.

Adding a water source on the Mono Mills Allotment would allow permittees to distribute livestock more widely. The slope of the roads and distance to other water sources currently makes water transport difficult and expensive. This alternative could therefore make ranching operations more economically feasible on the Mono Mills Allotment.

Mono Sand Flat

Mono Sand Flat Allotment would be rested to allow recovery from the effects of previous grazing and dry conditions. Without grazing pressure, desired species may be able to come back into the area. However, if conditions in this desert shrubland system continue to be dry, it may make recovery a slow and difficult process. Resting the allotment instead of closing it would allow the permittee to take advantage of the forage that may rebound when wetter conditions prevail. As only 26 cow/calf pairs are authorized to graze here, only a low amount of grazing pressure would occur on the recovered allotment.

Recovery would be a slow process and may take decades (Milchunas, 2006). If recovery does not take place within the ten year time span this NEPA analysis covers, the Forest may, at that time, decide to continue resting the allotment or take other management actions.

Cumulative Effects The area affected by grazing lies within the boundaries of the Mono Basin Grazing Allotments. Because the permits for these allotments allow for ten years of use, the effects would be seen for 10 to 15 years. Because the Proposed Action calls for utilization which will not exceed the environment’s ability to recover, there should be no damage at the end of the ten year period and appropriately grazed areas should recover within five years. However, the effects of previous overgrazing (i.e. grazing that took place before 2011, such as the overgrazing that caused the degraded conditions currently seen at Crooked Meadows) may yet take decades to resolve.

Activities other than grazing that affect the condition of the range include recreation, implementation of the 2009 Travel Management EIS Decision, and fuels reduction projects, including prescribed fire. Conditions can also be affected by climate and wildfires.

Recreation has a minimal impact on these four allotments. There are a few primitive camp sites, but these are in areas populated by Jeffrey pines, not in areas where grazing normally occurs. The most common recreation activity on these allotments is off-highway vehicle (OHVs). Implementation of the 2009 Motorized Travel Management Record of Decision may reduce the amount of off highway vehicle use in the allotments as unauthorized routes are closed to public travel. Approximately 67 miles of road will be closed within the Mono Basin Allotments. There

36 are no reasonably foreseeable future proposals to decommission the unauthorized routes or convert them to other uses such as non-motorized trails. However, some revegetation of these routes is expected as motorized use is discontinued, leading to some minor, localized improvement in range condition.

Areas where fuels reduction occurs are not generally primary range, as forage is sparse under tree canopies. Fuels reduction will not negatively impact livestock operations and may improve the availability of forage. Fire suppression has resulted in trees beginning to dominate what were formerly sagebrush and bitterbrush shrublands. Fuels reduction reduces competition, allowing shrubs and bunchgrasses to move back in. This is a positive impact on range conditions.

Prescribed fire will have an effect similar to logging. In the pre-European era, wildfires reduced the number of trees, allowing for a more open canopy. Fire would periodically sweep through these environments and burn the shrublands, encouraging new growth and regeneration. Prescribed fire can fulfill these functions and help restore the range to a state resembling the pre- European environment. Prescribed burns maybe cause for temporary cessation of grazing (2-5 years), but in the long run would result in higher quality forage. Prescribed fire has been used to treat approximately 9,265 acres within the Mono Basin Allotments.

Climate, along with soils, hydrology, and geography, is one of the factors that ultimately determine the state of vegetation in a region. Climate change may affect range conditions within the project area, although the effects of that climate change are not well known. It is predicted for the region containing the project area that the climate will become warmer, precipitation will remain about the same, but more of that precipitation will occur as rain instead of snow and there will be more extreme weather events such as drought and floods (Furniss et al, 2010).

A decrease in the amount of snow would lead to a decrease in snow melt in the spring, leaving less water for plants and riparian areas. However, although climate change will be a factor in range condition in the years to come, it is not possible to predict with any certainty what changes may occur in the next decade or what their significance might be. However, the Proposed Action calls for a program of monitoring which would allow range managers to track changes to range conditions so that management could be altered accordingly.

Fire suppression over the past century has allowed distribution of vegetation to become increasingly dense, making the area more susceptible to catastrophic wildfire. Fire can destroy existing vegetation and allow invasive species such as cheat grass (Bromus tectorum) to move in. Wildfire is especially detrimental to bitterbrush and big sagebrush, as they are slow to rebound after catastrophic fires; bitterbrush can take as long as 30 years to fully recover (Nord 1965) and big sagebrush can take as much as 35 to 100 years (Baker 2006). Wildfire could reduce the amount of available forage for many years and necessitate resting the allotments. Since the year 2000, wildfire has affected 6,350 acres within the Mono Basin Allotments.

Determination

37 There would be no adverse cumulative effects of the Proposed Action when combined with past, present, and reasonably foreseeable future actions within the project area. This alternative would meet the standards and guidelines in the Inyo National Forest LRMP (USDA Forest Service, 1988) as revised by LRMP Amendment #6, Forest-wide Grazing Utilization Guidelines (USDA Forest Service, 1995) and the Sierra Nevada Forest Plan Amendment (USDA Forest Service, 2004).

Under Alternative 2, the purpose and need of improved range vegetation condition and trend along with the purpose and need for continued livestock grazing would be met.

3.3 Effects Relevant to Hydrologic Resources, Soil, and Air Quality

The discussion below is summarized from the Hydrology and Soils Input for the Mono Basin Grazing Allotments EA and is hereby incorporated by reference (Lutrick 2011).

3.3.1 Existing Condition

3.3.1.1 Affected Environment

Air Quality Setting

The only substantial air pollution that could be related to livestock grazing is PM10, or particulate matter less than 10 microns in size. This can be created when dust is stirred up through livestock trailing or when livestock are transported to the site in vehicles. Almost the entire analysis area is classified as non-attainment for PM10 due to dust from the dry shorelines around the lowered Mono Lake. As stated in the Mono Basin Planning Area PM10 State Implementation Plan, ―It is clear that the predominant source of PM-10 emissions in the Mono Basin Planning Area is windblown dust…The Control measure to reduce air pollution from PM-10 emissions specifies a gradual increase in the water elevation of Mono Lake…the only feasible method to sufficiently reduce emissions to comply with the federal PM-10 Standard‖. This quote shows livestock grazing it is not an activity of concern for air pollution control agencies, although effects of the alternatives will be discussed briefly below.

Hydrologic Setting

The allotments are within two major drainage basins: Mono Lake, and the Owens River. The allotments are all almost entirely within the Mono Lake Watershed. Only a very small portion (about 3040 acres combined of a total 73,300 acres of allotments) of the June Lake, Mono Mills, and Dexter Creek allotments are within the Owens River Watershed. None of the allotment areas have surface connectivity to the Owens River, or Mono Lake. The few streams infiltrate into alluvial fans on the valley slope.

38 Only the Dexter Creek Allotment and the very northeastern corner of the Mono Mills Allotment have any surface streamflow. There is a total of about 9.5 miles of perennial streams in these two allotments, and none in the others. There is also a spring with standing surface water in the Mono Sand Flat Allotment, which is fenced and therefore inaccessible to livestock. Mono Mills Allotment contains at least four springs. The Dexter Creek Allotment also contains a few intermittent streams and at least 15 springs.

The Forest Service uses watersheds for analysis based on the USGS National Hydrologic Dataset (NHD) layer. Those watersheds are identified by their Hydrologic Unit Code (HUC), which can be seen in the project record. The State of California delineates watersheds using ―Calwater‖ watersheds. The project area lies within 25 Calwater watersheds. For a list of those watersheds, see the project record.

For a description of soils present on the Mono Basin Allotments, see section 1.2.

The Inyo National Forest has established criteria for evaluating soil and watershed condition of rangelands through the LRMP Amendment #6 (Forest-wide Standards and Guidelines). Soil desired conditions and standards for riparian areas and uplands are included in Amendment #6, and are not separated out from hydrologic function. Effects to soil function are components of the Amendment #6 protocol and data collection for this analysis followed this established protocol.

Past and current impacts to soil productivity include grazing by livestock and areas of mining, roads, wildfire, off-road vehicle use, and other recreational uses. Generally, soil is not degraded in these allotments, but in the few meadows where concentrated livestock grazing has occurred in the past, there tends to be loss of soil surface layer, compaction, and increases in bare soil.

Hydrology and Soils Focus and Methods

This analysis focuses on key area hydrologic and soil function, stream functional condition and water quality. These are the three principal water and soil related desired conditions in the Forest Plan Direction (USDA Forest Service 2004).

Key Area Hydrologic and Soil Function Amendment #6 to the Inyo National Forest land and Resource Management Plan (LRMP) establishes a protocol for assessing watershed condition in meadow and upland areas for vegetation and watershed condition. This method is known as key area hydrologic function analysis. Amendment #6 methods are used for an entire key area. Many soil and hydrologic attributes are taken together determine whether an area is hydrologically functional. A hydrologically functional area can withstand high flows or runoff without eroding, has streamcourses that remain connected to their floodplain, and have soil capable of absorbing rainfall or snowmelt. This Amendment #6 protocol was used at 13 key areas along with four

39 other riparian areas in 2008 and 2010. Five of these were in meadow/riparian vegetation types and 12 in upland vegetation types. Results are shown in Table 11 on page 28.

Stream Functional Condition In this analysis, stream functional condition was determined using the Proper Functioning Condition (PFC) protocol (USDI 1998). The PFC protocol was developed by a multi-agency effort, and is a common rapid assessment method for stream condition. If there was a perennial stream at the key area, a PFC analysis was completed. An IDT completed PFC analysis at three sites, although none were key areas. Results are shown in the Existing Condition section in Table 11on page 28.

Water Use Three of the four allotments are proposed for sheep grazing, and sheep are able to graze in areas without surface water. Water is often trucked in from nearby locations. Some water is taken from local springs or streams, while some is taken from nearby municipal water supplies. This document will, where possible, analyze the amount of water taken and any effects to surface or groundwater beneficial uses. It will also analyze the installation of a new well to provide drinking water to sheep on the Mono Mills Allotment.

Water Quality The Forest Plan requires ―Water quality meets the goals of the Clean Water Act and the Safe Drinking Water Act; it is fishable, swimmable and suitable for drinking after normal treatment.‖ Forest Service Region 5 has a management agency agreement with the state Water Quality Control board to apply best management practices to maintain and protect water quality on National Forest lands (USDA Forest Service 2000).

Methods for assessing water quality include; determining beneficial uses of water in the assessment watersheds, assessing the risk and occurrence of potential pollutants, and field assessment of indicators and/or measures of pollutants.

Beneficial Uses and Water Quality Objectives

Beneficial uses are the natural and human uses of surface water and are defined in the State of California Water Quality Control Board Basin Plans. These beneficial uses must be maintained. The designated beneficial uses for the analysis area are in the Lahontan Area Basin Plan (California, LRWQCB, 1995), and are listed and discussed in more detail in the Soil and Hydrology Report for this project.

Region-wide numeric and narrative water quality objectives (WQOs) are established in the Basin Plan (LRWQCB, 1995) and include the nutrient WQO’s that apply to the project area. Relevant WQOs are listed in the Soil and Hydrology Report for this project, as well as in the Basin Plan. Those relevant to grazing can be summarized into sediment, bacteria and other pathogens, and nutrients and are briefly described below.

40 Sediment – Field observations of livestock trampling in springs and stream reaches is a strong indicator that sediment is reaching the stream or spring channel. Cattle and sheep can cause physical impacts to streambanks that can result in stream sedimentation (Marlow 1985, Siekert 1985).

Bacteria and other pathogens – It is well established in the literature that fecal coliform, giardia, and other bacteria or pathogens can be introduced into water by cattle and sheep. For a summary of literature relating to bacterial contamination from grazing in National Forest and similar environments, see Lutrick (2011b). Most existing water quality research related to grazing focuses on cattle, not sheep, so there is little research relevant to this project. Fecal coliform, while not harmful itself, is often used as an indicator of the presence of fecal matter, which can contain harmful pathogens. The Lahontan Basin Plan has a fecal coliform standard of 20 cfu/100 mL. Presence of livestock in wet areas is used here to estimate presence of bacteria and other pathogens. No quantitative water quality measurements are known to have been taken within these allotments.

Field investigation for these biological contaminants includes observing if livestock are present where waste products can enter water directly from defecation or urination, or indirectly from observing livestock trailing along, across or near streams. Presence is an indicator that serves as a surrogate for in-stream bacteria sampling. The threshold for determining if beneficial uses are maintained is whether or not receptors are adversely affected.

Nutrients – Livestock proximity to water can be used to detect the potential for nutrient enrichment. Waste products contain nitrogen, a biostimulatory substance, which may affect the trophic status of waters. Eutrophication can result from nutrient introduction if sufficient quantities are present. A field indicator is condition of aquatic features such as stream channels and springs. A degraded condition from livestock indicates that nutrients may be elevated.

Risk Assessment

Water quality parameters with the most likely potential to be affected by the proposed action are sediment, bacteria and other pathogens and nutrients. Livestock waste products are known to introduce bacteria and other pathogens into water (Suk 1983, 1986), and can cause increased nutrient levels. Livestock can also cause physical impacts to streambanks that can result in stream sedimentation (Marlow 1985, Siekert et al. 1985). Field methods such as observing the ability of livestock to reach surface water or observing where they were actually seen in or adjacent to surface water is used here.

The degree to which, if at all, the above parameters affect beneficial uses of water is key to describing environmental effects of the proposed action. If there is some known or potential introduction of pollutants by livestock, this analysis determines whether the extent adversely affects the beneficial uses of the water.

41 3.3.1.2 Existing Condition

In this section, the existing condition of all allotments will be discussed. Because the Dexter Creek Allotment is the only allotment with surface water or with areas that were not fully functional for hydrologic and soil function (although not in any key areas), it is the only one that will be discussed individually. The others will be discussed site-by-site, but all in the same section.

Air Quality

Almost the entire project area is in non attainment for PM10 due to dust from the dried Mono Lake shoreline. Soil disturbance from the trampling action of the livestock when soil moisture levels are low would result in increased fugitive dust emissions (PM10) in the allotment. In addition, vehicles used in association with livestock operations on the access roads would also generate small additional amounts of PM10 emissions. However, the overall effect on air quality would be slight, local and short-term due to the generally wide distribution of livestock movement patterns in the allotment and the relatively few sheep in the area. Further, the ―State Implementation Plan for the Mono Lake PM10 Non-attainment Area‖ (Patten and Ono, 1995) does not identify grazing or vehicle traffic as a source of concern for PM10, and therefore current grazing is not considered a measurable impact to air quality.

Key Area Hydrologic and Soil Function

While there is some riparian area within the Dexter Creek Allotment, the other four allotments have no surface water that is currently accessed by livestock (in other allotments, springs are fenced off or not in an area that is grazed). Ground cover is naturally sparse in many areas, although pavement and litter act as groundcover over many of these upland areas. In these dry, upland areas, soil has little potential for compaction, and with high infiltration rates, most rainfall and snowmelt infiltrates into the soil with very few incidences of rilling or other overland flow. Disturbance from current sheep grazing tends to be slightly loosened soils, with some reduced groundcover and disturbance of surface litter and/or gravel continuity. This could lead to minor increases in loose soil and ability of any overland flow to move sediment. However, in these allotments, the relatively low use and once-over aspect of sheep grazing has not led to increased erosion at the sites visited. The sheep disturb only the surface layer of soil, and vegetation has a chance to grow back once the sheep have passed over each site. Overall, there is some minor soil loosening and minor reduction in ground cover in high use areas, but the disturbance is well within standards for soil and watershed protection. Exceptions are discussed below.

Bedding grounds have the most severe impacts, However, bedding grounds are small, up to about ½ acre in size. Impacts include highly compacted soil, and alteration of vegetation or removal of vegetative cover. While the effects to bedding grounds are comparable to the effects of a road, there are as few as 20 bedding grounds identified in each allotment, and the total area of disturbed ground is very small compared to the watershed as a whole. None of these bedding

42 grounds are known to be causing erosion or having off-site effects, and therefore are considered a moderate alteration of soil productivity over a very local area.

Of the fourteen sites analyzed for compliance with Amendment #6, twelve were found to be fully functional and two were found to be at-risk. The two at-risk sites were both in meadows within the Dexter Creek Allotment (Crooked Meadow and Wild Horse Meadow) and are not key areas. Crooked Meadow has historical stream incision that has dried out the meadow, and Wild Horse Meadow has some hummocks, rills and gullies. Neither has been grazed in recent years. The specific meadows’ condition will be discussed by allotment below.

As can be seen in Table 11 on page 28, there were few streams analyzed for functional condition rating. That is because only the Dexter Creek Allotment has substantial surface water, and in the other allotments, livestock do not graze at the site of surface water. Of the three streams analyzed in the Dexter Creek Allotment, all were found to be at Proper Functioning Condition (PFC).

Riparian Conservation Objectives (RCOs) are met in most places, deviating only at one known location (unnamed stream about 1.5 miles south of Baxter Spring). Only two known bedding grounds are within Riparian Conservation Areas (RCAs). One, near Johnny Meadow, does not affect any riparian vegetation. The other, south of Baxter Spring, is located within 50 feet of water. RCO Standard #103 requires that less than 20% of each stream reach be disturbed by activities such as grazing. At the site south of Baxter Spring, over a short reach, there is greater than 20% streambank trampling. The proposed action would make changes to bedding ground locations to address this inconsistency with Forest Plan direction.This affects local stream morphology and reduces bank cover, increasing the potential for streambank erosion and instability during high flows. While the banks are currently not eroding excessively, there is potential with a high flow.

In key areas, hydrologic and soil function analysis was completed using the Amendment #6 protocol. Table 12 below shows the results of Amendment #6 and PFC evaluations completed in the field in 2008-2010.

43 Table 12. Stream Proper Functioning Condition and Key Area Amendment #6 Watershed Condition Rating Results for all Allotments. Allotment Key Range Type PFC Rating Amendment 6 Area Watershed Condition

Dexter 5 Bitterbrush NA Fully Functional Creek S&G 6 Bitterbrush NA Fully Functional

7a Bitterbrush NA Fully Functional 8 Johnny Meadow (Moist) NA Fully Functional Exc Bitterbrush NA Fully Functional Wet Meadow (Baxter Spring) PFC ND Unnamed spring north of ND PFC Sagehen Peak Crooked Meadow (Wet) PFC At-risk Wild Horse Meadow (dry/moist) ND At-risk June Lake 1 Bitterbrush NA Fully Functional S&G 2 Bitterbrush NA Fully Functional 3 Bitterbrush NA Fully Functional Mono Mills 1 Bitterbrush NA Fully Functional S&G 2 Bitterbrush NA Fully Functional 5 Bitterbrush NA Fully Functional Mono Sand 1 Desert Shrub NA Fully Functional Flat C&H 2 Desert Shrub NA ND NA = Not applicable (no stream); ND = No Data; PFC = Proper Functioning Condition

Water Quality Water quality has not been measured quantitatively within these allotments. As stated above, only the Dexter Creek Allotment has surface water that is accessed by livestock, and therefore it is the only allotment that will be discussed further in terms of water quality. The other allotments have some springs or surface water. However these features are either fenced off (as in the case of the Mono Sand Flat Allotment), or are in an area where the sheep would not graze (as in the case of the Mono Mills Allotment). Sheep grazing, which occurs on all of the allotments other than Mono Sand Flat, is more contained than cattle grazing, with the sheep driven by a shepherd at all times. Therefore, the areas they graze and over which they travel are controlled. The sheep stay to a known and defined path, and do not access water where they are not led by the shepherd.

Because there is no water accessed by livestock in any of the other allotments, there are currently no potential water quality effects on any allotment other than the Dexter Creek Allotment.

44 Dexter Creek Allotment

Key Area Hydrologic and Soil Function

The Amendment #6 protocol was used to rate seven sites, five of which were found to be fully functional and two at-risk, as shown in Table 12 Three sites were analyzed for stream functional condition (PFC), and of those, all were found to be at desired condition.

The two locations found to be at-risk for watershed condition were Crooked Meadow and Wild Horse Meadow. Both of these meadows have been closed to grazing for resource protection (Crooked Meadow since 1997 and Wild Horse Meadow since 2003), and therefore the current condition is not related to historic grazing. The effects are likely due to past grazing. Crooked Meadow was rated at-risk due to much of the meadow having apparently dried out and converted to sage after stream incision, reducing soil stability and increasing bare ground. The stream in the meadow, however, has adequate vegetation for stable banks and is at desired condition.

Wild Horse Meadow was found to be at risk due to minor hummocking, small area of unstable gullying in the main (dry) stream channel, and minor compaction. The meadow has been closed to grazing for eight years. The meadow is vulnerable when subjected to high levels of grazing due to some bank instability.

Water Quality

There are currently four sites where sheep were reported to cross streams or congregate near surface water (high use sites), all on the Dexter Creek Allotment. These four sites are the sites where sheep manure likely enters surface water. Only three of these sites were observed to have recent high use, at the stream crossing downstream from Baxter Spring, at the bedding ground along the unnamed stream about 1.5 miles south of Baxter Spring, and along Dexter Creek at the southern edge of the Dexter Creek Allotment. At these sites, sheep manure is deposited adjacent to and in surface water. Because sheep are moved by their shepherd every day, each of these sites is only accessed at most a few days a year. While this could cause spikes in nutrients, pathogens, and bacteria on and immediately after those days, and on days when runoff carries remaining manure into the streams, the small amount of manure washed into the streams relative to the streamflow is unlikely to affect beneficial uses. Because manure is only entering the water at four sites, and only over short durations (one to a few days), water quality is not degraded over more than a very local area, over a very short term, and does not pose an overall water quality concern in any watershed. RCO Standard #103 and state water quality standards are therefore met.

45 3.3.2 Environmental Consequences

3.3.2.1 Direct, Indirect, and Cumulative Effects of No Grazing (Alternative 1)

The No Action alternative, which would result in no grazing on the Mono Basin Allotments, would have no measurable effect to air quality, and minor, very local positive effects to water quality, and soil and hydrologic function.

There are no known current air quality effects other than very minor, local increases in dust during and directly after livestock passage. Therefore, it is assumed that removing all livestock from these four allotments would only have very minor, local and very short duration effects of reduced dust input into the air. This would have no effect on the current PM10 violation status of the Mono Basin because the effects would be too small to be measured. Therefore, there would be no measurable positive or negative effect to air quality under the No Action alternative.

Hydrologic and soil function would be slightly improved throughout the allotments over time. Outside of riparian areas, there is currently only minor soil surface disturbance and slightly increased potential for erosion due to loosening of the soil. This is spread out over the allotments, and is within Amendment #6 desired condition at all upland locations. At the sheep bedding grounds, most vegetation is gone and soil is compacted over areas up to ½ acre. Under the No Action alternative, these bedding grounds would slowly decompact, and within a few years, would partially revegetate (with some disturbance-adapted species) to reduce any erosion potential. While the No Action alternative will reduce soil disturbance relative to current condition, the reduction will be minor and desired conditions will still be met.

At two locations, Crooked Meadow and Wild Horse Meadow, soil and hydrologic conditions are currently at-risk, and their condition would likely continue to improve slowly relative to current conditions. Both meadows would be vulnerable were heavy grazing to occur on streambanks, and with no grazing, they would likely continue their slow recovery. Time for recovery to desired condition depends on climate, but would likely take decades. Both meadows have some stream downcutting, and therefore the historic meadow extent may never be reached again. Because these meadow streams are already at PFC, they already meet RCO Standard #117, but removing all potential for grazing would further reduce potential for negative changes in bank stability.

At the one location (watering area 1.5 miles south of Baxter Spring) where it is known that streambank trampling exceeds 20% over a short (roughly 500 feet) distance, the streambanks would gradually become vegetated. This would reduce the potential for bank erosion during high runoff and better meet RCO Standard # 103 and 105.

Under the No Action Alternative there would be no long-term measureable effect to water quantity relative to current condition.

46 Cumulative Effects

This cumulative effects analysis will focus on cumulative watershed effects using the equivalent roaded area (ERA) method. While this method has not been well tested for grazing, it is the standard protocol for determining cumulative watershed effects in Region 5 of the Forest Service. Cumulative effects will also be estimated for air quality.

The No Action alternative will have no cumulative effects for air quality. Because there will be no direct or indirect effects large enough to measure, there will also be no cumulative effects. The Mono Lake Basin will continue to be in non-attainment for PM10 until Mono Lake levels increase, and removing grazing would make no difference in that condition.

Cumulative Watershed Effects (CWE) were calculated using the area of all known past, present, and reasonably foreseeable future actions that are known to cause ground disturbance. For this area, those effects are roads, fuels treatments/timber harvest, urban areas, prescribed and natural fire, and grazing. For all watersheds, a 14-16% Threshold of Concern was used. An ERA coefficient of 0.5 was used for high use grazing areas (here, bedding grounds), 0.05 was used for moderate use areas, and 0.01 was used for low use areas. However, not enough research has been done to quantify the ERA of sheep grazing in uplands, so these coefficients are a best estimate based on local conditions and observed effects of grazing. All allotments were mapped showing high, moderate, low/moderate, and unknown use levels. Further, there is no surface water over most of the grazing area. Therefore, even if there is soil disturbance and some soil compaction (here, found only in bedding grounds), there is no potential for it to be transferred down-gradient in the watershed. For that reason, the ERA method also overestimates cumulative watershed effects from current grazing. However, it was still used here to present an estimate of potential cumulative watershed effects.

Table 13 below shows the results of the ERA analysis for the No Action alternative for each watershed that has at least some portion in the allotments. It shows the results under the current condition, the No Action Alternative, and the Proposed Action Alternative. None of the watersheds were calculated to have an Equivalent Roaded Area at or near their Threshold of Concern under the No Action Alternative. It should be noted that the June Lake and Rush Creek watersheds are fundamentally altered due to diversions and dams that alter water quantities and timing of flows. Because the No Action Alternative will not affect any flows in those watersheds (or any other watershed), there will be no additional cumulative effect from this alternative.

Climate change may affect the hydrologic and soil condition within the project area, although the effects of potential changes are not well known. It is predicted for the region containing the project area that the climate will become warmer, precipitation will remain about the same, but more of that precipitation will occur as rain instead of snow and there will be more extreme weather events such as drought and floods (Furniss et al, 2010).

47 Table 13. Cumulative Watershed Effects Calculations for Watersheds in the Mono Basin Allotments.

Cumulative Watershed Effects calculations for watersheds in the Mono Basin Allotments, using the Equivalent Roaded Area (ERA) method. All watersheds have a threshold of concern of 14-16% Currently and under both alternatives, the watersheds are under the threshold of concern for cumulative watershed effects.

Proposed Action No Action ERA (for year Watershed Name (HUC 6) HUC6 acres Current ERA ERA 2011)

Cowtrack Spring 35,407 0.8% 0.1% 0.8%

Deep Wells 35,129 2.6% 0.1% 2.6%

Dry Creek 22,976 7.2% 3.9% 7.2%

East Craters Sand Flat 29,480 4.7% 1.5% 4.7%

Alameda Well 43,011 3.5% 0.1% 3.5%

Cottonwood Canyon 30,806 1.2% 0.1% 1.2%

Kirkwood Spring 22,113 2.6% 0.1% 2.6%

June Lake* 15,385 1.5% 0.8% 1.5%

Punch Bowl 14,693 5.3% 1.5% 5.3%

Rush Creek* 30,937 5.7% 1.3% 5.7%

Deadman Creek 27,079 6.1% 2.3% 6.1%

Owens River/Dry Creek 25,840 4.0% 0.4% 4.0%

Owens River/Mclaughlin Creek 26,415 4.9% 0.8% 4.9% * These watersheds have major hydrologic alterations due to dams and diversions

Climate change is likely to increase the high flows and decrease the low flows in the few stream within the project area. This could lead to greater erosion potential along the streams due to flashier flows and reduced riparian vegetation due to more dry years. The No Action Alternative would not have an additional cumulative effect, because there would be no grazing on any streambanks.

48 3.3.2.2 Direct, Indirect, and Cumulative Effects of the Proposed Action (Alternative 2)

The Proposed Action would allow for improved meadow, water quality, and streambank condition relative to the current condition, but would have slightly greater minor, local negative impacts than the No Action alternative. These minor impacts would still allow RCOs to be met at all locations, and would protect beneficial uses to meet state and federal water quality standards.

There are no known current air quality effects other than very minor, local increases in dust during and directly after livestock passage. Therefore, continuing with grazing on these allotments would cause existing minor, local dust levels to continue. This would have no effect on the current PM10 violation status of the Mono Basin because the effects would be too small to be measured.

The Proposed Action would result in very local and minor improvements in water quality relative to the current condition. Changes would only occur on the Dexter Creek Allotment. There would be no change relative to the current condition on the Mono Sand Flat, June Lake, or Mono Mills Allotments, because livestock currently do not access any surface water on these allotments. There would still be no access to water in these three allotments under the Proposed Action Alternative.

On the Dexter Creek Allotment, sheep would continue to access surface water at road crossings and watering locations for a period of a few hours to a few days a year. There are currently only four sites that are known to have use near surface water. All bedding grounds would be required to be at least 500 feet away from surface water under the Proposed Action, and therefore the one site that is a watering site/bedding ground that currently has trampled banks, will no longer be accessed by sheep. This would reduce manure and urine input slightly at this location, although watering still may occur. Currently, there are no known or suspected impacts to beneficial uses at the four high use sites, only likely a slight increase in nutrients and bacteria on the few days per year that the sheep are at the water sites, and in the days immediately following that access. This same impact would continue at these four sites. If monitoring shows that there is some possibility that beneficial uses are not met, adaptive management will be used to alter the use to meet beneficial uses. For example, water could be trucked into a location instead of having sheep drink directly out of a stream if the drinking location becomes over trampled or has more than minor inputs of manure or sediment into surface water. Water quality would continue to meet all state and federal standards to meet RCO #1.

Hydrologic and soil function would be slightly improved throughout the allotments over time. At discrete locations, sheep in bedding grounds (except for the Mono Sand Flat Allotment, which is a cattle allotment) remove most vegetation and compact soil over areas up to ½ acre. Under the Proposed Action alternative, some existing bedding grounds would no longer be used, because it will require that bedding grounds are more than ½ mile apart. At the decommissioned bed grounds, soil would slowly decompact, and within a few years, would vegetate to reduce any erosion potential. While the Proposed Action alternative will reduce soil disturbance relative to

49 current condition in upland areas, the change will be very small. Desired conditions for soil and hydrology in these upland locations will still be met.

At two locations, Crooked Meadow and Wild Horse Meadow, soil and hydrologic conditions are currently at-risk. Regardless, their condition would likely continue to improve relative to current conditions because they would not be grazed. Time for recovery to desired condition depends on climate, but would likely take decades. Both meadows have some stream downcutting, and therefore the historic meadow extent may never be reached again. Because these meadows streams are already at PFC, they already meet RCO #117. Removing grazing until vegetation meets desired condition will allow for more stabilization before grazing resumes.

At the one location (watering area 1.5 miles south of Baxter Spring) where it is known that streambank trampling exceeds 20% over a short (roughly 500 feet) distance, the sheep would no longer be allowed to bed down within 500 feet of the stream, and streambanks would gradually vegetate. The site could still be used for watering, but because the sheep would not remain at the site overnight or for days at a time, the banks would receive less trampling. This would reduce the potential for bank erosion during high runoff and better meet RCO Standard # 103.

At Baxter Springs, sheep currently are able to access the North Canyon Creek riparian area. Installation of a fence for resource protection at this site will prevent sheep from entering the North Canyon Creek riparian area. This will reduce potential for streambank trampling and will concentrate use on a road.

The Mono Sand Flat Allotment key areas were found to be in desired condition for soils. Under the Proposed Action, the allotment will continue to be rested until vegetative recovery is documented. Therefore, there will likely be more vegetative cover of types that have roots sufficient to hold some soil in place before it is grazed. Due to this, and to the fact that only 26 cow/calf pairs would be permitted, the Proposed Action will likely not have any detrimental effect to soil condition other than some local, dispersed surface disturbance. During the period of time when the allotment would be rested to achieve vegetative recovery, there would be no detrimental soil or hydrologic effects.

Water quantity would continue to be slightly affected on a local, short-term scale, with the same effects as the current condition. Sheep currently drink directly out of some streams in the Dexter Creek Allotment. Additionally, water is taken from two springs to be delivered by truck or piped to a trough. This use of water would continue. The diversion of water a few days a year at the Mono Mills spring site, and a small volume of water more continuously in the Dexter Creek Allotment Spring, are not enough to affect beneficial uses.

A well may be installed in the southern portion of the Mono Mills Allotment to provide water to fill trucks for sheep watering. Sheep would not water directly at the well. The well could provide up to 4,000 gallons per day over the grazing season, which is about from July 1 through September 15. If 4,000 gallons is pumped every day for less than 90 days, the total water pumped would be less than or equal to one acre-foot per year. The well would be drilled somewhere adjacent to a road so that the drill rig could access the site. There is no surface water within the Mono Mills Allotment (other than a small stream segment in the north portion of the

50 allotment), and therefore the well would not have the potential to be in the underflow of any stream or spring. Because the well would only pump up to 4,000 gallons per day for less than three months per year, it is very unlikely that it could affect any surface water flow in nearby streams (the nearest stream is about five miles away).

During drilling, Best Management Practices would need to be implemented to prevent soil erosion or contamination. To prevent any erosion from excess water that is found during drilling, the driller must plan for a dispersion system to disperse any of the water, rather than allow it to flow directly onto the landscape where it may cause gully erosion. While an outpouring of water is not certain, the driller should be prepared for that eventuality. Any drilling mud should not be deposited in swales or other areas that might possibly flow during heavy runoff, although there are not likely any such features in the area. With proper implementation of Best Management Practices, there is very little likelihood of any soil erosion.

Cumulative Effects

This cumulative effects analysis will focus on cumulative watershed effects using the equivalent roaded area (ERA) method, as explained under the No Action alternative discussion. Cumulative effects will also be estimated for air quality.

The Proposed Action alternative will have no cumulative effects for air quality. Because there will be no direct or indirect effects large enough to measure, there will also be no cumulative effects. The Mono Lake Basin will continue to be in non-attainment for PM10 until Mono Lake levels increase, and continuing grazing would make no difference in that condition.

Cumulative Watershed Effects (CWE) were calculated using the area of all known past, present, and reasonably foreseeable future actions that are known to cause ground disturbance. A discussion of the methods used is included in the No Action Cumulative Effects discussion.

Table 13 on page 48 shows the results of the ERA analysis for the Proposed Action Alternative for each watershed that has at least some portion in the allotments. None of the watersheds were calculated to have an Equivalent Roaded Area at or near their Threshold of Concern under this alternative. This is not a surprising result, because the current and proposed grazed area would be almost the same. (While slightly less acreage would be open to grazing under the Proposed Action, the difference is too small to create a different ERA result). Currently, none of the watersheds within the project area have any known cumulative watershed effects. Therefore, under the same grazing acreage, there should be no change.

Climate change may affect the hydrologic and soil condition within the project area, although the effects of that climate change are not well known. It is predicted for the region containing the project area that the climate will become warmer, precipitation will remain about the same, but more of that precipitation will occur as rain instead of snow and there will be more extreme weather events such as drought and floods (Furniss et al, 2010).

51 Climate change could reduce the amount of vegetative cover due to decreased snowpack, although this is not known for certain. It is likely to increase the high flows and decrease the low flows in the few stream within the project area. This could lead to greater erosion potential along the streams. The Proposed Action Alternative would allow grazing only at a few locations along streams. These factors could combine to lead to a local cumulative increase in streambank instability. However, due to the very few locations where grazing would occur along streambanks, there would likely be no decrease in stream stability along more than a few hundred feet of stream.

3.4 Effects Relative to Terrestrial Wildlife

This section contains a summary of information presented in the Biological Evaluation, Biological Assessment and Management Indicator Species Report developed for this project (Perloff 2011a, Perloff 2011b, Perloff and Sims 2011) which are hereby incorporated by reference.

3.4.1 Existing Condition

3.4.1.1 Federally Listed Threatened and Endangered Species The Sierra Nevada distinct population segment (DPS) of California bighorn sheep was emergency listed on April 20, 1999. At the time of the emergency listing, the population was thought to total no more than 125 animals. The final rule to list this DPS as endangered was published on January 3, 2000. Notice of Availability of the Final Recovery Plan for SNBS (USDI Fish and Wildlife Service 2007) was published in the Federal Register on February 13, 2008. On August 5, 2008 the U.S. Fish and Wildlife Service published the final rule on critical habitat designation for Sierra Nevada bighorn sheep and a taxonomic name change to Ovis canadensis sierrae (USDI Fish and Wildlife Service 2008a).

Bighorn sheep select open habitats that allow detection of predators at sufficient distances to allow adequate lead-time to reach the safety of precipitous terrain. Optimal bighorn sheep habitat is visually open and contains steep, generally rocky, slopes. Sierra Nevada bighorn sheep avoid forests and thick brush, but will use open woodland habitats on rocky slopes. Bighorn sheep in the Sierra Nevada utilize a wide range of elevations, from alpine peaks in excess of 4,000 meters (13,120 feet) to the base of the eastern escarpment as low as 1,450 meters (4,760 feet) (Wehausen 1980). Within this elevational range, there is a wide variety of vegetation communities, including (from lowest to highest): (1) Great Basin sagebrush-bitterbrush- bunchgrass scrub; (2) pinyon-juniper woodland and mountain mahogany scrub; (3) mid- elevation and subalpine forests, woodlands, and meadows; and (4) alpine meadows and other alpine habitats varying from cliffs to plateaus.

52 On August 5, 2008, the U. S. Fish and Wildlife Service designated approximately 417,577 acres of critical habitat for this species in Tuolumne, Mono, Fresno, Inyo and Tulare Counties. Approximately 272,000 acres of designated critical habitat are within the boundaries of the Inyo National Forest. Critical herd units were also identified, including the Mount Gibbs and Mount Warren units which comprise the Northern Recovery Unit for this species. The Mono Basin grazing allotments are located approximately 3 miles east of the Mount Gibbs herd unit at the closest point (see Figure 1, Biological Assessment). The majority of bighorn sheep use in this herd unit is centralized around the southeast slope of Mount Gibbs in Bloody Canyon, however sheep have been detected as far north as Mount Dana and as far south as Mount Wood. California Department of Fish and Game (CDFG) biologists have fitted a number of sheep in this herd unit with radio-collars and monitor their movements on a regular basis. Their data shows that the closest a collared bighorn sheep has approached the June Lake East Allotment is approximately 5 miles. The Mount Gibbs core use area is located slightly less than 7 miles from the northeast corner of the June Lake East Allotment.

3.5.1.2 Forest Service Sensitive Species and Management Indicator Species The sagebrush-steppe plant community within the analysis area provides habitat for one Pacific Southwest Region sensitive species. That species is the sage-grouse (Centrocercus urophasianus), and several grouse individuals have been detected recently within the June Lake Allotment. The pure and mixed coniferous forest located at higher elevations in the Glass Mountains provides suitable habitat for northern goshawks (Accipiter gentilis) and all or portions of six breeding territories occur within the Mono Mills and Dexter Allotments. No other sensitive species are known to occur within the analysis area, nor is there suitable habitat present for any of these other species. Only the sage-grouse and northern goshawk are discussed further in this document.

Sage Grouse: The greater sage-grouse is a Forest Service sensitive species and a Management Indicator Species representing sagebrush habitats. There are now two distinct species of sage-grouse – the newly recognized Gunnison sage-grouse (Centrocercus minimus) of Colorado and Utah, and the greater sage-grouse (Centrocercus urophasianus) found in parts of eleven western states, including California. The sage-grouse is a permanent resident in northeastern California, ranging from the Oregon border along the east side of the Cascade Range and Sierra Nevada to northern Inyo County. The species was formerly an abundant resident in northeastern California and southeast of the Sierra, as far as Big Pine in the Owens Valley. By the 1940's however, numbers had been greatly reduced and populations fragmented. Because the greater sage-grouse has experienced significant range and population reductions in many areas of the state, it is designated as a (third priority) California Species of Special Concern in its nesting and lek (breeding) grounds.

In January 2002 a petition was filed with FWS requesting that the greater sage- grouse occurring in the Mono Basin area of Mono County, California, and Lyon County, Nevada, be emergency listed as an endangered distinct population segment (DPS) under the Endangered Species Act (Act). There is evidence that this population is genetically distinct from greater sage-grouse

53 elsewhere (Benedict et al. 2003, Oyler-McCance et al. 2005). On December 26, 2002, FWS published a 90-day finding regarding this petition and concluded that listing was not warranted. On April 29, 2008 the FWS published a second 90-day finding on the petition to list the sage- grouse as threatened or endangered (USDI 2008b). It was determined that the petition for listing presented substantial scientific or commercial information indicating that listing may be warranted. On March 23, 2010 the FWS published a notice of 12-month petition findings in the Federal Register. Pertinent finding were that the Bi-State population (previously referred to as the Mono Basin area population) meets the criteria as a distinct population segment (DPS) of the greater sage-grouse and warrants listing under the Endangered Species Act but is precluded by higher priority listing actions.

The Bi-State area population of greater sage-grouse occurs in portions of Carson City, Lyon, Mineral, Esmeralda, and Douglas Counties in Nevada, and of Alpine, Inyo, and Mono Counties in California. The State wildlife agencies in Nevada and California have jointly identified six Bi-State area Population Management Units (PMUs): Pine Nut, Desert Creek-Fales, Mount Grant, Bodie, South Mono and White Mountains. The current analysis of available information suggests only Bodie and South Mono PMUs are likely to persist over the next thirty years, and may also contract in size without increased conservation efforts or implementation of recovery actions.

The Mono Basin grazing allotments are within both the Bodie and South Mono PMUs. The majority of the Mono Sand Flat Allotment lies within the Bodie PMU, however, approximately 420 acres are in the South Mono PMU. Approximately ¾ of the June Lake, a small section of Mono Mills and virtually all of the Dexter Creek allotments are within the South Mono PMU. The remaining portion of the June Lake and Mono Mills allotments are not within a PMU as they support stands of coniferous forest and are not suitable habitat for sage-grouse.

Sage-grouse are generally associated with Great Basin shrub-steppe vegetation. California Wildlife Habitat Relationship (CWHR 2005) habitat types considered to be suitable for sage- grouse include barren (BAR), bitterbrush (BBR), low sage (LSG), sagebrush (SGB) and wet meadow (WTM). Summer habitat consists of sagebrush mixed with areas of wet meadows, riparian or irrigated agricultural fields. As habitat begins to dry up over the summer, grouse broods move to more mesic wet meadows where succulent grasses and insects are still available. Sage-grouse form flocks as brood groups break up in early fall. As fall progresses, grouse move toward their winter ranges. Exact timing of this movement varies depending on the grouse population, geographic area, overall weather conditions and snow depth. Sagebrush is essential for survival during the fall, winter and early spring months.

Open areas within sagebrush communities are needed for courtship displays. Fairly open stands of sagebrush are needed for nesting. The sage-grouse breeds from mid-February to late August, with the peak strutting period in March and April and the nesting and brooding period from May through July. In the Long Valley and Parker areas, juvenile grouse have generally vacated the nest by the beginning of June (personnel communication Overton). Nesting habitat consists of big sagebrush communities that have 15-38% canopy cover and a grass and forb understory. Previous studies of the relation between shrub canopy cover and residual grass cover needed for suitable nesting habitat have determined that nesting sites were selected with a grass-forb

54 understory >18 cm in height and ≥25% shrub cover (mesic areas) and >18cm of height and ≥15% cover in arid sites (Connelly et al. 2000). These studies were conducted in southeastern Idaho and were believed to be similar to sage-grouse nesting needs in the Mono Basin area. However, results from a recent study of sage-grouse nesting success and habitat needs within Mono County, California showed that nest sites were characterized by 42.4% shrub canopy cover, 10.5 cm residual grass height, and 2.7% residual grass cover (Kolada 2007). The nest survival estimate was 43.4%, and the percent cover of shrubs other than sagebrush was the variable most related to nest survival, not residual grass cover or height (Kolada 2007).

Sage-grouse breeding habitats are defined as those where lek attendance, nesting, and early brood-rearing occur (Connelly et al. 2000, Connelly et al. 2004). These habitats are sagebrush- dominated rangelands, typically consisting of large, relatively contiguous sagebrush stands, and are critical for survival of sage-grouse populations (Connelly et al. 2000). Grouse potentially utilizing the project area would be associated with the following three distinct lek complexes.

The Bodie Hills PMU includes one of the largest lek complexes in the Bi-State Planning Area. To date, 29 different leks have been mapped within the boundary of the PMU. The Parker lek complex is located in the extreme northwest portion of the South Mono PMU in the vicinity of the north June Lake Loop, around Grant Lake and Parker Creek and the southern half of the Mono Basin. The Granite Mountain lek complex is located south of Mono Lake along the northern flank of the Glass Mountain range, from Big Sand Flat east to Adobe Valley. To date, two lek sites, Adobe and Gaspipe, have been identified in the Granite Mountain area. Of these two leks, only Adobe is currently active.

Sage-grouse are known to utilize portions of the June Lake Allotment. The United States Geologic Survey (USGS), under contract to the California Department of Fish and Game (CDFG), implemented an intensive radio-telemetry study from 2001 to 2005 to examine seasonal habitat use and home ranges. The study also included nest and random sighting locations and collection of vegetation data. During the period 2003 – 2005 radio-collared grouse associated with the Parker breeding complex flew from the Parker Meadow area to the north-central portion of the June Lake Allotment. The vast majority of grouse use within the allotment occurred within the boundary of the ―Lousy‖ fire; a wildfire which burned in 1985. All detections of radio-collared birds occurred between November and April. No telemetered birds were detected in Mono Sand Flat, Mono Mills or Dexter Creek allotments.

Based on existing vegetation data provided by the Pacific Southwest Region’s Remote Sensing Laboratory, there are approximately 26,722 acres of potential sage-grouse habitat within the four grazing allotments . The Bodie and Mono/Adobe areas as a whole contain approximately 404,162 acres identified as potential sage-grouse habitat. The portion within the four allotments represents slightly less than 7 percent of the total available. Table 14 identifies the amount of potential sage-grouse habitat by allotment within the project area. This includes all polygons typed as CWHR BAR, BBR, LSG, SGB and WTM, with areas containing pinyon pine or other conifers excluded. Suitable sage-grouse nesting habitat was then determined using this vegetation data. All suitable habitat within a two-mile buffer around sage-grouse lek sites was identified as potential nesting habitat. Suitable habitat outside of this two-mile buffer was identified as foraging and roosting habitat. Utilizing a two-mile buffer around currently active

55 leks, the four Mono Basin allotments contain approximately 275 acres of potential nesting habitat.

Table 14. Potential Sage-grouse Habitat within the Mono Basin Allotment Group. Allotment Allotment Size Acres of Sage-Grouse Percent of Allotment Habitat Mono Sand Flat 8,696 3,216 37% June Lake 16,528 8,321 50% Mono Mills 29,263 1,442 5% Dexter Creek 18,781 13,516 72% Totals 73,268 26,495 36%

Habitat quality within the June Lake, Mono Mills and Dexter Creek allotments is in good to very good condition based on the presence of mid- and late-seral shrubs with an understory of grasses and forbs. Some evidence of shrub decadence is found in the June Lake and Dexter Creek allotments, but not at a large enough spatial scale to decrease overall habitat quality. Habitat within the Mono Sand Flat Allotment is considered marginal, due to the presence of scattered junipers, wide spacing between sagebrush plants and lack of herbaceous understory.

Past grazing activities have created small patches of degraded habitat within otherwise suitable sage-grouse habitat. The greatest degree of habitat alteration occurred within areas that received ―high use‖ by livestock. In the June Lake and Dexter Creek allotments these high use areas equate to sheep bedding grounds. Bedding grounds are approximately ½-acre in size and are utilized annually as overnight camps for herders and their sheep. Due to the repeated use, these areas are often devoid of vegetation and do not provide suitable habitat for sage-grouse. There are currently 33 identified bedding grounds in these two allotments so slightly more than 15 acres of potential sage-grouse habitat is presently unsuitable.

Sage-grouse use of habitat within the allotments includes roosting and foraging, primarily during fall, winter, and spring months. Use on adjacent non-Forest Service lands is much higher and includes substantially more use during the summer months. This is likely due to the presence of wet meadow systems on non-Forest Service land near Parker and lower Adobe Creeks which likely provide superior brood rearing habitat.

Relative use of habitat within the allotments was calculated by comparing the number of telemetry locations and nests found within the allotments to the total within the Bodie and Mono/Adobe areas and comparing these figures to overall habitat availability. Table 15 presents a comparison of several metrics related to sage-grouse use inside and outside the project area.

56 Table 15. Comparison of Sage-grouse Habitat Utilization Within and Outside Four Grazing Allotments Sage-Grouse Metric Count Percent of Total Acres of suitable habitat within four grazing allotments1 26,722 7% Acres of suitable habitat outside four grazing allotments 404,162 93% (primarily non-Forest Service land) Total suitable habitat in Bodie and Mono/Adobe areas 430,884 100%

Number of telemetry locations within four grazing 116 4% allotments2 Number of telemetry locations outside four grazing 2,554 96% allotments (primarily non-Forest Service land) Total number of telemetry locations in Bodie and 2,670 100% Mono/Adobe areas

Number of sage-grouse nests found within four grazing 0 0% allotments2 Number of sage-grouse nests found outside four grazing 38 100% allotments (primarily non-Forest Service land) Total number of sage-grouse nests in Bodie and 38 100% Mono/Adobe areas

Acres of suitable nesting habitat within four grazing 275 0.2% allotments3 Acres of suitable nesting habitat outside four grazing 117,513 99.8% allotments (primarily non-Forest Service land) Total suitable nesting habitat in Bodie and 117,788 100% Mono/Adobe area 1. Acres of habitat derrived from Pacific Southwest Region Remote Sensing Laboratory existing vegetation data (USDA Forest Service 2001). 2. Telemetry and nest location data provided by United States Geological Survey (USGS unpublished data). 3. Acres of nesting habitat derrived from existing vegetation data and a two-mile buffer around lek sites (excluding inactive leks).

Northern Goshawk: The northern goshawk is found throughout most of North America, with a few isolated populations in the southeastern and central United States. Within the Sierra Nevada goshawks breed from 2,460 feet in the ponderosa pine/mixed-conifer vegetation types through 10,000 feet in the red fir and lodgepole pine vegetation types. On the eastern slope of the Sierra Nevada goshawks are found in the eastside pine and aspen vegetation types (USDA Forest Service 2001).

Goshawks prey on a variety of species, particularly small mammals and birds in timber areas. Foraging has been documented to occur in heavy canopied forests with open understories. Goshawks generally use perches to identify prey while hunting, so they probably do not forage in expansive treeless areas.

The nesting cycle begins with courtship and nest building during February and March and concludes in late August to early September when fledglings become independent. Stick nests

57 are often built in trees on north or northwest facing slopes of less than 30 percent slope and near water (Reynolds et al 1992).

In the Sierra Nevada goshawks breed from the mixed conifer forests at low elevations up to and including high elevation lodgepole pine forests (Verner and Boss 1982). On the Inyo National Forest this includes primarily Jeffrey/eastside pine, lodgepole pine, mixed conifer and red fir habitats; however territories can occur in riparian-associated quaking aspen stands and cottonwood habitats. The Inyo National Forest contains approximately 426,300 acres of potentially suitable goshawk habitat, primarily in the Sierra Nevada, Glass and White Mountains. Approximately 29,305 acres of potentially suitable habitat occur within the Mono Basin allotment group (Map 3, Biological Evaluation). Table 16 illustrates the distribution of potentially suitable habitat by allotment.

Table 16. Acres of Potentially Suitable Northern Goshawk Habitat by Allotment.

Allotment Acres of Potentially Suitable Northern Goshawk Habitat Mono Sand Flat 0 June Lake 4,286 Mono Mills 21,975 Dexter Creek 3,044 Total 29,305

Northern goshawk protected activity centers (PACs) are delineated surrounding all known and newly discovered breeding territories detected on National Forest System lands. Northern goshawk PACs are designated based upon the latest documented nest site and location(s) of alternate nests. If the actual nest site is not located, the PAC is designated based on the location of territorial adult birds or recently fledged juvenile goshawks during the fledging dependency period. PACs are delineated to: 1) include known and suspected nest stands and 2) encompass the best available 200 acres of forested habitat in the largest contiguous patches possible. The Mono Basin allotment group encompasses all or portions of 6 PACs. Table 17 identifies the PACs and their status.

58 Table 17. Northern Goshawk Protected Activity Centers in the Mono Basin Allotment Group.

PAC Identifier Allotment Acres Within the Last Year With Allotment Confirmed Activity

R05F04D51T10 Mono Mills 58 2006

R05F04D51T04 Mono Mills 201 2004

R05F04D52T06 Mono Mills 156 1998

R05F04D51T11 Mono Mills 200 2009

R05F04D51T06a Dexter Creek 231 1995

R05F04D51T06b Dexter Creek 134 2005

Yellow Warbler:

The yellow warbler (Dendroica petechia) was selected as the MIS for riparian habitat in the Sierra Nevada. This species is usually found in riparian deciduous habitats in summer (cottonwoods, willows, alders, and other small trees and shrubs typical of low, open-canopy riparian woodland) (CDFG 2005). It also breeds in montane shrubbery in open conifer forests. During migration, it visits woodland, forest, and shrub habitats. Yellow warbler is dependent on both meadow and non-meadow riparian habitat in the Sierra Nevada (Siegel and DeSante 1999). Yellow warblers are known to occur in the Mono Basin, but not necessarily in the Mono Basin allotment group. Yellow warblers have been detected along Rush, Lee Vining, Mill and Wilson creeks and was the most frequently captured breeding species at all sites and demonstrated fair to high productivity ratios (Heath et al. 2004).

Riparian habitat was mapped from satellite imagery and subsequently verified through field surveys. The Mono Basin allotments contain approximately 75 acres of yellow warbler habitat (MRI). Five acres occur adjacent to Dry Creek in the extreme northeast corner of Mono Mills allotment. The remainder is adjacent to Dexter Creek and un-named tributaries that feed North Canyon in the Dexter Creek Allotment. The habitat is generally very narrow; rarely extending more than 10-15 feet from the edge of the stream channel. Riparian vegetation consists of an overstory of quaking aspen (Populus tremuloides) with an understory of willow (Salix spp.), wild rose (Rosa woodsii), grasses and forbs. With the exception of two sites, all yellow warbler habitat is outside the area grazed by livestock. Much of the habitat is within deeply entrenched canyons which are inaccessible to livestock. The two sites that overlap with grazed areas include a 0.6 acre bedding ground and watering area in Township 1S, Range 29E, Section 7; and a 1.2 acre watering area in Township 1S, Range 29E, Section 30.

59 The Inyo NF LRMP (as amended by the Sierra Nevada Forests MIS Amendment (USDA Forest Service 2007) requires bioregional-scale habitat and distribution population monitoring for the yellow warbler; hence, the riparian habitat effects analysis for the Mono Basin Grazing Allotment Project must be informed by both habitat and distribution population monitoring data. The sections below summarize the habitat and distribution population status and trend data for the yellow warbler. This information is drawn from the detailed information on habitat and population trends in the 2010 SNF Bioregional MIS Report (USDA Forest Service 2010a), which is hereby incorporated by reference.

Habitat Status and Trend

There are currently 38,140 acres of riparian habitat on National Forest System lands in the Sierra Nevada. Over the last two decades, the trend is stable.

Population Status and Trend

Monitoring of the yellow warbler across the ten National Forests in the Sierra Nevada has been conducted since 2009 in partnership with PRBO Conservation Science, as part of a monitoring effort that also includes mountain quail, hairy woodpecker, and fox sparrow (USDA Forest Service 2010a, http://data.prbo.org/partners/usfs/snmis/). Yellow warblers were detected on 13.7% of 160 riparian point counts in 2009 and 19.4% of 397 riparian point counts in 2010; additional detections were documented on upland point counts. The average abundance (number of individuals recorded on riparian passive point count surveys) was 0.166 in 2009 and 0.309 in 2010. In addition, the yellow warblers continue to be monitored and surveyed in the Sierra Nevada at various sample locations by avian point count, spot mapping, mist-net, and breeding bird survey protocols. The results of these monitoring efforts are summarized in the 2008 Bioregional Monitoring Report (USDA Forest Service 2008). Current data at the rangewide, California, and Sierra Nevada scales indicate that the distribution of yellow warbler populations in the Sierra Nevada is stable.

3.4.1.2 Species of Local Concern

Mule Deer: Mule deer from the Mono Lake and Casa Diablo deer herds pass through the Mono Basin during the spring and fall migrations. All of the perennial streams and Warren Bench receive deer use at these times. Many individuals also stay in the Mono Basin during the summer, primarily along the North Fork of Lee Vining Creek, and on Warren Bench. Deer from these herds generally winter in Huntoon Valley and the Benton area, and summer on both sides of the Sierra Crest. The timing of spring migration is relatively consistent between years.

Suitable mule deer habitat is composed of four distinctly different elements: fawning, foraging, cover, and winter range. Hiding cover is typically close to the ground and thick enough to camouflage the outline of a deer, without being so dense as to obscure the approach of potential predators. Thermal cover is similar and generally thought to be denser, with the additional

60 property of sheltering deer from the elements. Winter range tends to be lower elevation habitats that meet the requirements for forage, hiding, and thermal cover described above. Habitat suitability can be rated by the ratio of cover areas to forage areas and their size and spatial arrangement. Habitat within the June Lake, Mono Mills and Dexter Creek allotments is primarily forage and cover. Some limited fawning habitat may exist along Dexter Creek, but the majority is located west of the allotments closer to summer range on Warren Bench.

Deer leave their winter habitat in April and follow receding snow through transition range, arriving at summer habitat in mid-June to early-July. Fall migrations are less predictable and are generally precipitated by the first major snowfall. The earliest fall migration occurs is in mid- October, though deer more typically begin their migration in mid to late-November.

The quality of forage is most important to deer during the spring migration when does are pregnant and replenishing nutritional stores depleted during the winter. At that time deer seek out nutritious grasses, forbs and new annual leader growth on bitterbrush.

Deer transition range includes portions of June Lake, Mono Mills and Dexter Creek allotments. Portions of the Mono Lake herd travel from winter range, through Adobe Valley and then along the northern escarpment of the Glass Mountains. The remainder of this herd migrates to the north of Mono Lake, primarily in the Bodie Hills. The southern third of June Lake Allotment and the southwest corner of the Mono Mills Allotment are identified as a migration corridor for the Casa Diablo deer herd. Little or no deer use occurs within the Mono Sand Flat Allotment.

Pygmy Rabbit:

The pygmy rabbit (Brachylagus idahoensis) is the smallest North American leporid. Big sagebrush accounts for the majority of their diet and may comprise up to 99 percent of their diet in the winter (Green and Flinders 1980a). Sagebrush canopy also is important as cover for protection from predators (Grinnell et al. 1930). Additionally the pygmy rabbit is 1 of only 2 species of rabbits in North America that digs its own burrows (Orr 1940). Because of the combination of these needs, pygmy rabbits are dependent on dense sagebrush growing on deep, friable soils (Weiss and Verts 1984). The specific habitat requirements mean that even a large, continuous stand of sagebrush may be highly fragmented for pygmy rabbits (Heady 1998). Sagebrush islands are prominent clusters of sagebrush higher than the surrounding sagebrush. Studies have noted that pygmy rabbits were more likely to be found in these clusters (Grinnell et al. 1930, Orr 1940).

The pygmy rabbit was identified as a category 2 candidate for listing under the Endangered Species Act in 1991. Category 2 candidates were species for which there was information indicating that a proposal to list it as threatened or endangered may be appropriate, but for which additional information on biological vulnerability and threat was needed. In April 2003, a petition was submitted to list the species as threatened or endangered in Oregon, Idaho, Montana, Wyoming, California, Nevada and Utah. On September 30, 2010 the Fish and Wildlife Service

61 (Service) published a 12-month finding on the petition to list the species. The Service determined that listing was not warranted at that time.

In California, pygmy rabbits occur in eastern Modoc, Lassen and Mono counties (Orr 1940, Severaid 1950, Jones 1957). The southern limit of their distribution in California is from the vicinity of Lake Crowley in southern Mono County (Jones 1957). Their known elevational range in California extends from approximately 4,800 feet at Goose Lake to 8,373 feet at Bodie. Notable areas of known occupied pygmy rabbit habitat include the Bodie Creek drainage, the historic Bodie Racetrack, Murphy Meadows and the Aurora Creek drainage. Pygmy rabbits have not been detected on the Mono Sand Flat allotment but may be present based on habitat suitability (USDI Bureau of Land Management 2008). It is unknown whether pygmy rabbits occur within June Lake, Mono Mills or Dexter Creek allotments, although some marginally suitable habitat is present.

3.4.2 Environmental Consequences

3.4.2.1 Direct, Indirect and Cumulative Effects of No Grazing (Alternative 1)

Federally Listed Threatened and Endangered Species

Under the No Action Alternative, it was determined that there would be no direct, indirect or cumulative effects to Sierra Nevada bighorn sheep. No livestock grazing would occur within the allotments, negating any possibility of contact between domestic and Sierra Nevada bighorn sheep. No designated critical habitat occurs in the Mono Basin allotments; therefore cessation of domestic grazing would have no impact within bighorn sheep habitat.

Forest Service Sensitive Species and Management Indicator Species

Sage Grouse:

Under the No Action Alternative there would be no direct impact to sage-grouse individuals or their habitat. Cessation of grazing would have the indirect effect of allowing for passive restoration within bedding grounds. Over time, sagebrush plants would become re-established and allowed to grow freely in the absence of livestock trampling. The speed at which recovery occurs would be predicated on the availability of either a suitable seed source or existing seedbed. It is estimated that sagebrush would occupy the sites within 10-15 years. The spatial coverage of sagebrush habitat would increase by slightly more than 15 acres.

Northern Goshawk: Under the no action alternative there would be no direct, indirect or cumulative impacts on northern goshawks or their habitat. Under existing management, no forage competition, direct disturbance, habitat alteration or impedance of movement is occurring within suitable northern goshawk habitat. Cessation of grazing would not alter this condition.

62

Yellow Warbler: Elimination of grazing would have no direct impact on riparian habitat. Under existing management, slightly less than two acres of riparian habitat are within the area grazed by livestock. At these two sites aspen recruitment and understory shrub, grass, and forb cover is reduced relative to un-grazed riparian habitat. Past grazing may have resulted in a reduction of both deciduous and total canopy cover as a result of inadequate aspen recruitment. Under the No Action Alternative, grazing would cease at these two sites and understory vegetation would likely respond rapidly.

Species of Local Concern

Mule Deer: Under the No Action Alternative there would be no direct impacts to mule deer. Under existing management, mule deer and livestock do not overlap temporally on the allotments and disturbance of deer by livestock operations is not occurring. Cessation of grazing would not alter this condition. In the absence of livestock grazing, additional forage may be available to mule deer during fall migration; however forage availability is not a limiting factor for mule deer on the allotments

Pygmy Rabbit: Under the No Action Alternative there would be no direct impact to pygmy rabbit individuals or their habitat. Cessation of grazing would have the indirect effect of allowing for passive restoration within bedding grounds. Over time, sagebrush plants would become re-established and allowed to grow freely in the absence of livestock trampling. The speed at which recovery occurs would be predicated on the availability of either a suitable seed source or existing seedbed. It is estimated that sagebrush would occupy the sites within 10-15 years. The spatial coverage of sagebrush habitat would increase by slightly more than 15 acres.

3.4.2.2 Direct, Indirect and Cumulative Effects of the Proposed Action (Alternative 2)

3.4.2.3 General Potential impacts of grazing on wildlife species include competition for forage, direct disturbance, habitat alteration, and impedance of movement.

Forage competition: Domestic livestock and wildlife species often utilize the same forage species and can compete directly for available forage within a given area.

Direct disturbance: Direct disturbance can take the form of displacement of wildlife species either by the livestock themselves or by other activities associated with grazing management (e.g. presence of humans, operation of equipment, etc.). Another direct impact is the physical trampling or crushing of individual wildlife organisms, nests or burrows.

63 Habitat alteration: Habitat alteration occurs when specific habitat components are trampled (e.g. stream banks, springs, subterranean burrows, vegetation) or modified by consumption (e.g. removal of cover).

Impedance of movement: Structures associated with livestock management (e.g. fences, above- ground pipelines) can hinder wildlife movement and block migration corridors.

Federally Listed Threatened and Endangered Species

Direct and Indirect Effects Implementation of the Mono Basin Grazing Allotment Project would not result in any of the potential impacts listed above as the allotments are all spatially disjunct from occupied Sierra Nevada bighorn sheep habitat. Factors limiting Sierra Nevada bighorn sheep recovery include disease, predation, low population numbers and limited distribution, availability of open habitat, and potential further loss of genetic diversity due to small population sizes and inadequate migration between them. The Recovery Plan identifies disease transmission from domestic to bighorn sheep as a major threat to this species and one of the key factors in listing the species. The greatest risk posed by the proposed action is the potential for direct contact between domestic and wild sheep that could lead to disease transmission. Contact could occur either through straying of domestic sheep or as a result of long-distance movement by bighorn sheep. If contact were to occur and the bighorn subsequently returned to the Mount Gibbs herd unit, there is a high risk of spreading disease and resulting mortality within the Northern Recovery Unit.

The possibility of contact between Sierra Nevada bighorn sheep and domestic sheep can be determined, in part, by quantitatively estimating the relative likelihood of a bighorn sheep moving into a domestic sheep allotment. This analysis was accomplished for all grazing allotments in the Eastern Sierra and is documented in A Process for Identifying and Managing Risk of Contact Between Sierra Nevada Bighorn Sheep and Domestic Sheep (Baumer et al. 2009) (Risk Assessment) and Application of the Document Entitled A Process for Identifying and Managing Risk of Contact Between Sierra Nevada Bighorn Sheep and Domestic Sheep (Croft et al. 2010) (Application Document). Briefly, a geographic information system (GIS) based model was developed that incorporated Sierra Nevada bighorn sheep habitat suitability and proximity to herd use areas to determine the relative likelihood of Sierra Nevada bighorn sheep use of any particular location within the modeled area. The model incorporated habitat suitability, resistance to movement, core bighorn sheep home ranges, and cumulative cost of travel from a core home range location to any point within 60 kilometers (36 miles). The model output is expressed as the Inverse Weighted Distance (IWD). IWD values represent the likelihood of a bighorn sheep using a specific point on the landscape. Values closer to 1 indicate a high likelihood of use by a Sierra Nevada bighorn sheep while values closer to 0 indicate a low likelihood.

64 To determine a threshold of acceptable risk, the final GIS product (described above) was overlain with locations where Sierra Nevada bighorn sheep are known to have occurred. The IWD value at each known sheep location was calculated. Through this analysis, it was determined that the values for all the known locations of collared rams ranged from 0.833 to 1.0. The lowest value (0.833) for a known bighorn sheep location was, therefore, identified as a threshold value, above which bighorn sheep use is highly likely. If domestic sheep are grazed in locations that have a high likelihood of Sierra Nevada bighorn sheep use, the potential for contact between domestic and wild sheep exists and is predicted. Because the goal of the Risk Assessment is to prevent contact between the two species, values between 0.833 and 1.0 fall into a category of unacceptable risk. The locations of those areas that have a value between 0.833 and 1.0 and their relationship to the Mono Basin allotments are displayed in Figure 2, Biological Assessment. Approximately 1,670 acres (10%) of the June Lake Allotment fall within the area with IWD values between 0.833 and 1.0. Of this, 265 acres are in the central median between the divided lanes of Highway 395 and are not used by domestic sheep. Similarly, another 134 acres within the zone of overlap are located north of State Route 120 East in an unused portion of the allotment. The total area of overlap is therefore approximately 1,271 acres or <8% of the allotment. This area has experienced historic livestock grazing as evidenced by the presence of 3 sheep bedding grounds; however no grazing has occurred since the mid-1990s and none would occur through implementation of the proposed action. None of the other Mono Basin allotments are within the range of IWD values that suggest a high risk of contact between domestic and bighorn sheep. In summary, no domestic sheep grazing is expected to occur in the area with IWD values between 0.833 and 1.0 under the proposed action.

The Application Document (Croft et al. 2010) identifies several criteria land managers should consider when evaluating whether an allotment or portion of an allotment identified as having a high/unacceptable risk of contact may remain open and still ensure the prevention of contact between domestic and Sierra Nevada bighorn sheep (i.e. allotment specific criteria).

Criteria 1) Allotments or portions of allotments within the predicted area of potential contact (i.e., mapped areas of inverse weighted distance values between 0.833 and 1.00) that are separated from occupied Sierra Nevada bighorn sheep habitat by towns, highly developed recreation areas, or other human developments that inhibit bighorn sheep movement.

2) Allotments or portions of allotments within the predicted area of potential contact that are separated from occupied Sierra Nevada bighorn sheep habitat by large contiguous forested areas that inhibit bighorn sheep movement.

3) Allotments or portions of allotments within the predicted area of potential contact that are east of the U.S. Highway 395 management boundary recommended in Section II-E of the final Recovery Plan for Sierra Nevada Bighorn Sheep (USDI Fish and Wildlife Service 2007).

4) Allotments or portions of allotments within the predicted area of potential contact that are separated from occupied Sierra Nevada bighorn sheep habitat by major bodies of water (e.g., Mono Lake, Crowley Lake) that inhibit bighorn sheep movement.

65 The portion of the June Lake Allotment with mapped IWD values between 0.833 and 1.0 is entirely east of Highway 395 and therefore meets criteria 3. In this area, Highway 395 is a four lane divided roadway with moderate traffic volume. This stretch of highway is sufficiently wide and busy to serve as a barrier to eastward movement by a Sierra Nevada bighorn sheep. Similarly, the highway would also deter westward movement by domestic sheep if they were separated from the band. There are several other natural and man-made features between the Mount Gibbs herd unit and the June Lake Allotment that help to minimize the potential for contact between the two species. The direct line of travel between occupied bighorn habitat and the allotment is bisected by pure and mixed stands of coniferous forest. Grant Lake extends for 3 miles from north to south and also bisects the most direct line of travel. State Route 158, a two lane paved road passes along the western boundary of Grant Lake and creates an additional impediment to potential eastward travel by bighorn sheep.

The analysis in Clifford et al. (2007, 2009) showed a significant reduction in the probability of Sierra Nevada respiratory disease transmission by not grazing domestic sheep during the rut, limiting grazing days by domestic sheep, and vigilant domestic sheep grazing management. Clifford (2009) considered the rut to extend from October through November.

The proposed action for the June Lake East Allotment includes several best management grazing practices to further minimize contact between domestic and wild sheep. The permitted season of use would be July 1 to August 31 each year which is a month before the onset of rutting season for bighorn sheep in the area. The grazing period would be limited to 60 days a year and the total number of domestic sheep would not exceed 1,500. Each of these are verifiable grazing practices to reduce the probability of contact between bighorn and domestic sheep (Clifford 2007, Baumer et al 2009). Additional allotment-specific grazing practices are included to prevent and detect straying of domestic sheep outside the allotment boundary. These include:

1. The permittee shall count all individual sheep upon entering and exiting the allotment. One hundred percent counts will also be conducted following any type of ―scatter‖ event;

2. The permittee shall use marker sheep at a ratio of at least 1 to 35;

3. The permittee is responsible for assuring all permitted sheep are accounted for at all times. A daily log of sheep numbers and counts will be maintained by the permittee. The permittee will conduct daily counts of marker sheep following any significant change in sheep distribution (e.g. after leaving bed grounds, trailing, or movement to a new feeding area); and

4. If at any time during the grazing season a domestic sheep is unaccounted for, the permittee will notify the Forest Service immediately and the Escape Management Plan (USDA Forest Service 2010b) will be implemented.

Cumulative Effects The cumulative effects analysis area is defined as the following HUC-5 watersheds which encompass the Mono Basin allotments: Mono Lake North, East Mono Basin, Mono Lake West, Adobe Valley, and Rush Creek. These five watersheds total approximately 691,300 acres. Within the cumulative effects boundary, cumulative effects are analyzed on the accumulation of

66 all past, present and reasonably foreseeable future actions or disturbances that would occur within the next 20 years. The species was emergency listed in 1999 as endangered by the U. S. Fish and Wildlife Service because of the dramatic population decline in the late 1990s attributable to predation by mountain lions, failure of sheep to utilize favorable low elevation winter range habitat because of the presence of mountain lions, and the threat of large-scale mortality that could occur if domestic sheep transmitted disease to a bighorn population. The inability of existing regulatory mechanisms to deal with the issues of lion predation and disease transmission was also noted as a major reason for the listing of the species.

Domestic sheep grazing has already been eliminated on all or portions of 6 of the 7 Inyo National Forest allotments located west of Highway 395. The 7th allotment (Sherwin/Deadman) is partially within the area with IWD values between 0.833 and 1.0; however the areas of overlap are either not grazed by domestic sheep, or are separated from occupied Sierra Nevada bighorn sheep habitat by a highly developed area (Town of Mammoth Lakes) and large contiguous forested areas. Domestic grazing by cattle is expected to have negligible impacts on Sierra Nevada bighorn sheep or designated critical habitat as wild sheep tend to inhabit areas unsuitable for cattle use.

The Humboldt-Toiyabe National Forest has temporarily suspended domestic sheep grazing on all or portions of those allotments within the area with IWD values between 0.833 and 1.0. They are currently analyzing these allotments under the National Environmental Policy Act (NEPA) and may permanently vacate the allotments or switch the class of livestock to cattle. A Proposed Action is expected in 2012 once an analysis of whether the allotments are suitable for cattle grazing is completed. Similarly, the Bureau of Land Management’s NEPA analysis of Dog Creek and Green Creek allotments is ―in progress‖.

Mountain lion predation continues to be a risk factor for Sierra Nevada bighorn sheep; however recent efforts by CDFG to monitor lion movements and remove lions known to prey on bighorn are helping to mitigate this risk.

There are no other projects or activities identified in occupied bighorn sheep habitat that, in conjunction with the Proposed Action, are likely to have cumulative negative impacts on Sierra Nevada bighorn sheep populations.

Determination The Biological Assessment determined that the implementation of the Mono Basin Grazing Allotment Project WILL NOT AFFECT Sierra Nevada bighorn sheep or adversely modify designated critical habitat for this species. This determination was based on the following factors:

1. No domestic sheep grazing would occur in areas with inverse weighted distance values mapped between 0.833 to 1.0 which are considered to be areas of unacceptable risk of contact between domestic and bighorn sheep;

67 2. The grazed portion of the June Lake Allotment is entirely east of Highway 395 which is a four lane divided highway and serves as a barrier to eastward movement by bighorn sheep and westward movement by domestic sheep (Step 3, Criteria 3 Application Document);

3. Other natural and man-made barriers exist within the most direct line of travel between the June Lake Allotment and occupied Sierra Nevada bighorn sheep habitat; and

4. A variety of best management grazing practices are identified in the proposed action, including removing domestic sheep by the end of August (one month before the rut), limiting grazing duration to 60 days, and implementing a number of measures to insure vigilant domestic sheep grazing management.

Forest Service Sensitive Species and Management Indicator Species

Sage-Grouse:

Direct and Indirect Effects Livestock grazing can have negative or positive impacts on sage-grouse habitat depending on the timing and intensity of grazing (Crawford et al. 2004). For example, early season light to moderate grazing can promote forb abundance/availability in both upland and riparian habitats (Crawford et al. 2004). Heavier levels of utilization decrease herbaceous cover, and may promote invasion by undesirable species (Crawford et al. 2004). Direct impacts from livestock grazing can include disturbance during the breeding, nesting, early- and late-brood rearing seasons. Disturbances may lead to dispersal from the area or abandoning nest sites. Direct impacts also include inadvertent trampling of sage-grouse and sage-grouse nest sites by livestock. Although nest destruction by livestock trampling is rare, the presence of livestock can cause sage-grouse to abandon their nests (Crawford et al. 2004; Call and Maser 1985). Direct impacts also include those related to vegetation structure. Grazing can remove grass or forb cover that helps conceal sage-grouse nests from predators (Hockett 2002; Beck and Mitchell 2000).

Indirect impacts to sage-grouse habitat can include changes in composition, density, and structure of vegetation and removal of brood forage and cover in meadows (Call and Maser 1985; Crawford et al. 2004). Trampling of vegetation by livestock can kill sagebrush, particularly the smaller plants (Beck and Mitchell 2000). Grazing can also move sagebrush-grass communities into lower successional stable states dominated by sagebrush with little herbaceous understory (Beck and Mitchell 2000). The reduction in herbaceous understory can reduce the understory cover and decrease the suitability of these areas for nesting. The reduction in forbs during the spring and summer may also limit their availability for sage-grouse broods (Hockett 2002). Localized and concentrated use by livestock can reduce understory grass cover, which may impact the quality of nesting habitat the following year and may affect nesting if grazed during the late spring (Beck and Mitchell 2002).

68 Competition for forage is not expected to occur within the allotments. Grouse appear to be using the allotments primarily during non-summer months when livestock are absent. Greater sage- grouse are sagebrush obligates and the importance of sagebrush as a source of food and cover has been well established (Patterson 1952, Braun et al. 1977, Connelly et al. 2000). During winter, sage-grouse feed almost exclusively on leaves of sagebrush. Livestock grazing does not substantially alter the density or productivity of sagebrush. Sagebrush is not a preferred browse species, likely due to the concentrations of monoterpenoids in the foliage. Trampling and destruction of sagebrush plants can occur in areas of concentrated cattle/sheep occupancy (e.g. bedding grounds). It is estimated that less than 20 acres of vegetation are currently being trampled and are unavailable to foraging grouse.

Insects and forbs composed the bulk of the diet of juvenile sage-grouse in Idaho, Montana and Oregon (Klebenow and Gray 1968, Peterson 1970, Drut et al. 1994). Insects were the greatest component of the diet for chicks until the second week post-hatch when forbs were consumed in greater quantities (Klebenow and Gray 1968, Peterson 1970). The majority of suitable forb and insect foraging areas are found within the meadow systems present in the vicinity of the project area. The majority of these meadow systems are located on lands not managed by the Forest Service and are not located within an allotment boundary. A single wet meadow system (Crooked Meadows) occurs within the Dexter Creek Allotment. Under the proposed action, no livestock grazing would occur in Crooked Meadows.

Direct disturbance of sage-grouse as a result of the proposed livestock operations is expected to be minimal and would not occur during the time of year when disturbance would constitute a negative impact. There are no strutting grounds within the allotments; therefore there would be no potential for livestock/grouse interactions during the breeding season. The proposed grazing season in Dexter Creek and June Lake would be delayed until after June 15 and July 1 respectively. By June 1 grouse in Long Valley and Parker Meadows have finished courtship and nesting and broods are capable of limited flight (Overton, personal communication). There would be no temporal overlap between grouse nesting and livestock grazing. This would eliminate the potential for livestock to cause nest abandonment or inadvertent trampling of sage- grouse nests.

Some disturbance may occur if grouse are using the upland portions of June Lake, Mono Mills and Dexter Creek allotments during the summer months. Grouse may be flushed during foraging or loafing and displaced short distances away from the source of disturbance. This disturbance would be of relatively low intensity and short duration and grouse would be able to re-occupy the site shortly after the passage of livestock.

The potential exists that grouse and cattle will overlap spatially and temporally in the Mono Sand Flat Allotment. At present grouse are not known to occupy this allotment; however telemetered birds were found approximately 1.5 miles north of the allotment during winter months. It is possible that when grouse numbers increase, the population’s range may expand to include the Mono Sand Flat area. Under the proposed action, no livestock grazing will occur within this allotment until desired vegetation and watershed conditions are attained. It is unknown how long it will take for recovery to occur, but it could be during the 10 year permit period. At some point both grouse and cattle may be present and some level of disturbance of grouse could occur. The

69 degree of disturbance would likely be minimal due to the low number of cattle (26 cow/calf pairs) permitted.

Some level of habitat alteration is occurring under current grazing systems and is expected to continue, to a lesser degree, through implementation of the proposed action. Overall, livestock grazing appears to mostly affect productivity of sage-grouse populations (Beck and Mitchell 2000). Productivity is decreased when nests are unsuccessful (e.g. predated, abandoned, trampled) or habitat quality is too poor to provide insects and forbs during the brood rearing period.

The greatest degree of habitat alteration occurs within areas that receive ―high use‖ by livestock. In the June Lake and Dexter Creek allotments these high use areas generally equate to sheep bedding grounds. Bedding grounds are approximately ½-acre in size and are utilized annually as overnight camps for herders and their sheep. Due to the repeated use, these areas are often devoid of vegetation and do not provide suitable habitat for sage-grouse. There are currently 33 identified bedding grounds in these two allotments so slightly more than 15 acres of potential sage-grouse habitat is presently unsuitable. Under the proposed action all or most of these same bed grounds would continue to experience annual use. There are 3 historic bed grounds in the Mono Mills Allotment within suitable sage-grouse habitat which would likely be re-opened under the proposed action. Therefore, under the proposed action a total of approximately 18 acres of potential sage-grouse habitat would be unsuitable for the 10 year life of the grazing permits.

Braun et al. (1977) indicated that most hens nest within 3.2 km of a lek although other researchers have described distances ranging from 2.7 to 7.8 kilometers. In this analysis, important breeding habitat is identified as all suitable habitat within 3.2 kilometers (2 miles) of an active lek. The Dexter Creek Allotment contains 50 acres of suitable habitat within 3.2 kilometers of the Adobe lek. The June Lake Allotment contains 225 acres of suitable habitat within 3.2 kilometers of the Parker lek complex. Under the proposed action, no livestock grazing would occur within this important breeding habitat.

Some nesting may occur at distances greater than 3.2 kilometers from an active lek. If this is occurring, it is possible that some sage-grouse nest in areas of the June Lake and Dexter Creek allotments that would be grazed by livestock. Herbaceous cover associated with nest sites may provide scent, visual and physical barriers to potential predators. Habitat alteration would have the greatest impact within the allotments if residual grass height was insufficient to protect and screen nests. Kolada (2007) found that the residual grass height found at sage-grouse nesting sites within Mono County, California averaged 10.5 cm and residual grass cover averaged 2.7%. Within the Dexter Creek Allotment, surveys conducted after the 2003 and 2006 grazing seasons noted residual grass heights averaged 23.6 cm and 17.8 cm, respectively. Therefore the residual grass height within the project area exceeds that identified by Kolada and is likely providing suitable cover for nesting habitat.

Sage-grouse movements are not currently being impeded by structures associated with livestock use of the four allotments. No fences or other potential obstructions are present within June Lake, Mono Mills or Dexter Creek allotments. Fencing is generally not required for sheep

70 grazing operations as herders in combination with dogs are able to maintain herd cohesiveness and direct sheep to appropriate locations. Mono Sand Flat contains several boundary fences as well as an exclosure fence around the primary spring source. These fences are low and generally do not extend above the adjacent brush canopy. Sage-grouse flight tends to be above canopy level except during take-off and landing, and the existing fences should not constitute a barrier to movement or possible source of collision. A short section (0.1 miles) of new fence is proposed near Baxter Springs. The fence will be fitted with mylar streamers which is a technique known to make fences more visible to sage-grouse and reduce the potential for collisions.

Cumulative Effects

The Bi-State Conservation Plan identifies a variety of factors other than livestock grazing that pose potential risks to sage-grouse within the Bodie and South Mono PMUs. These include pinyon-juniper encroachment, urbanization/changing land use, fences/transmission lines, recreational activities, predation, sport hunting, poaching, sagebrush habitat condition, and mining/geothermal/energy development.

Pinyon-juniper encroachment is limited within the project area. Approximately 406 acres of CWHR type PJN occur within the 4 allotments, primarily along the eastern edge of Dexter Creek Allotment. It is unknown how rapidly the range of pinyon-juniper is expanding into the sagebrush community.

Urbanization and changing land use is largely absent within the four allotments. Approximately 430 acres of private land are within the allotments. A 40 acre parcel is present near Sagehen Meadow. A single family residence was constructed at this site in 2008 which encumbers less than 1/2-acre. No other subdivision of this property is reasonably foreseeable. The remaining private land is a single parcel within the Mono Sand Flat Allotment. There is no indication that this parcel will be developed.

As discussed previously there is a limited amount of fencing present within the Mono Sand Flat Allotment. Several additional miles of fence are present immediately east of the Dexter Creek Allotment associated with the Adobe Ranch complex. Direct mortality of sage-grouse due to fence strikes is a potentially significant population risk. This risk is most often associated with the low-level flight of birds into leks under poor light conditions. Similar impacts are expected as sage-grouse access other small habitats of concentrated use, for example night roosts, springs and meadows. Fences are a yearlong risk, with seasonal peaks occurring in the spring and summer, as birds concentrate near strutting grounds and late brood habitats. Sage-grouse mortality resulting from fence strikes has been documented in Long Valley, but not in the Mono Basin. The fences in Long Valley where collisions occurred have been re-constructed to easily drop down during the breeding season and documented mortality has decreased substantially.

No transmission or distribution lines are situated within the four allotments. An overhead transmission line runs roughly parallel to Highway 395 west of the June Lake Allotment. The distance from the line to sage-grouse habitat in the allotment ranges from 400 feet to over ½- mile. Poles for above ground utility lines provide perches for avian predators (Ellis 1984, 1987)

71 and may cause sage-grouse to avoid the immediate area where they are placed. Utility lines may also cause direct mortality if flying sage-grouse strike the wires (Call and Maser 1985). To date, no utility wire strikes have been documented in the South Mono or Bodie PMUs. Recreational activities within the allotments are dispersed in nature and consist of fuelwood gathering, vehicle use of existing dirt roads and isolated un-improved campsites.

Lands within the Mono Basin allotments are mostly un-developed and do not provide areas that would attract predators or provide a source population of feral cats and dogs. A 40 acre landfill that services the communities of June Lake and Lee Vining is located less than 1 mile west of sage-grouse habitat in the June Lake Allotment. The landfill likely attracts ravens and coyotes, both of which are known to prey on grouse and decrease nesting productivity (Coates and Delehanty 2010).

Sport hunting is the physical act of removing individual birds from the population during a regulated season and by regulated methods of take (shotgun, archery, falconry). However, hunting seasons are only scheduled when specific population criteria are met. Sport hunting of sage-grouse occurs within the South Mono PMU within a designated hunting zone called the South Mono/Inyo Hunt Zone. In the Bodie PMU hunting is allowed in the North Mono Hunt Zone. Quota numbers for the two zones are relatively conservative, with 25 permits issued for the north zone and 35 for the south zone during the 2010-2011 season (CDFG 2010). The Mono Basin allotment group lies between the two hunt zones. Any harvest within the allotments would be illegal. There are no recent accounts of sage-grouse poaching within the South Mono PMU. Mineral extraction and geothermal development are essentially absent from the Mono Basin allotments. Several old prospect sites are present in the vicinity of Sagehen Peak, but no current extraction is on-going. The Forest Service is currently analyzing a proposal to install an anemometer in the vicinity of Sagehen Peak. The project proponents are attempting to determine whether the site is properly situated to develop a wind energy facility. The anemometer itself is not likely to represent a negative impact to sage-grouse as the guy wires would be constructed with anti-collision devices and all horizontal parts of the tower would contain structures to deter raptor perching. Although not reasonably foreseeable at this time, construction of a new wind energy facility could present substantial risk to local sage-grouse populations due to mortality associated with wind turbines as well as habitat disruption from ancillary facilities such as roads and transmission lines. Any proposal for construction of a wind energy facility would entail additional analysis under NEPA, including an analysis of the potential effects on sage-grouse.

West Nile Virus (WNv) has emerged as a potential threat to greater sage-grouse since 2002 (Naugle et al. 2004, USDI Fish and Wildlife Service 2008c, Walker and Naugle 2009). West Nile virus has been identified as a cause of sage-grouse mortality in the Bodie PMU (Casazza et al 2005). Greater sage-grouse are considered to have a high susceptibility to WNv, with resultant high levels of mortality (McLean 2006). In sagebrush habitats, WNv is primarily regulated by environmental factors, including temperature, precipitation and distribution of anthropogenic water sources that support the mosquito vectors (Reisen et al. 2006). Livestock watering facilities have the potential to support the mosquito vector, especially if the water is allowed to stagnate. Most livestock watering within the June Lake, Mono Mills and Dexter Creek allotments is not likely to contribute to potential spread of WNv. Water for sheep is generally transported by truck throughout the

72 allotments and provided to livestock in portable troughs. The troughs are drained after 1-2 days and moved to a new location in the allotment. This short duration precludes stagnation of water and does not create suitable mosquito breeding habitat. At Baxter Springs, water is piped to a permanent trough. The trough location is within potential sage-grouse habitat and could be a mosquito breeding ground if water is allowed to remain for extended periods of time. The proposed action includes installation of a centrally located well and water tank in the Mono Mills Allotment. Water may escape from this facility and pond nearby, creating additional mosquito breeding habitat. To alleviate the potential spread of WNv from these water sources, the following measure is incorporated in the Proposed Action: WLF-1. Assure that the trough at Baxter Springs is thoroughly drained and dry when domestic sheep vacated this portion of the allotment. If a well is installed in potential sage-grouse habitat within the Mono Mills Allotment, assure that construction does not allow water to pond in the vicinity. The Mono Sand Flat Allotment contains a spring fed pond with relatively slow moving and ponded water. The pond is a potential location for mosquito breeding; however, surveys conducted during July and August 2010 failed to detect mosquito larva.

Although not identified in the Bi-State Plan, wildfire may pose the greatest long-term risk to maintenance of sage-grouse populations. Fire tends to kill mature sagebrush plants. Re- establishment of sagebrush stands may take up to 15 years or more post-fire. In some portions of burned areas such as south facing slopes, cheat grass may rapidly expand and dominate such sites after wildfire. The resulting mono-culture of annual brome is substantially less suitable for sage-grouse. The presence of cheat grass may lead to an altered fire regime and exacerbate the occurrence of landscape fires. Contemporary fires (since 2000) have generally been relatively small or have only consumed small amounts of sagebrush vegetation in the vicinity of the Mono Basin allotments. During this period, approximately 6,350 acres of shrub-steppe vegetation has burned. Type conversion or rapid spread of weeds in burned areas is not currently occurring in the vicinity of the Mono Basin allotments (see Botany section of this document) These burns have had the beneficial effect of creating a mosaic of patches of early-seral sagebrush-steppe vegetation which more closely resembles historic levels of seral diversity. The cumulative impact of wildfire on sage-grouse habitat in the Mono Basin is not a limiting factor for population viability. The potential for a large, landscape scale wildfire exists, however these events are stochastic and it is not possible to predict when such an incident may occur.

Determination Considering the above discussion of effects, it is my determination that implementation of the Mono Basin Grazing Allotment project may impact individual sage-grouse, but would not result in a trend towards federal listing or loss of viability within the project area. This determination is based on the following factors:

1. Livestock will not be authorized to graze until after June 15th, when sage-grouse have completed the breeding and nesting season in this area;

2. All meadow systems that provide potential brood rearing habitat have a 0% allowable utilization standard;

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3. Utilization standards will continue to allow for suitable cover needed during the nesting season;

4. Reducing allowable utilization to 0% in the Mono Sand Flat Allotment will allow for gradual restoration of potential sage-grouse habitat; and

5. The impacts of the proposed action were on-going when the sage-grouse was identified as a priority 3 candidate for listing under the Endangered Species Act and are not likely to elevate the species to a higher priority.

Northern Goshawk: Direct and Indirect Effects Livestock grazing identified in the proposed action may be a source of disturbance during goshawk breeding and nesting activities. It is unlikely that other impacts associated with livestock grazing (i.e. forage competition, habitat alteration, impedance of movement and non- native species) are affecting northern goshawk population or habitat within the Mono Basin allotment group.

Human disturbance has the potential to cause goshawk to abandon nesting during the nesting and post fledging period (February 15 through September 15). Goshawks initiate breeding when the ground is still covered in snow and sometimes nests are located along roads when they are not yet in use. Additionally, roads and trails provide flight access for goshawk. When the snow melts, these sites can potentially be areas of conflict as sheep bedding grounds are often located along roads.

Goshawks display a variety of responses to humans and vehicles. During the nest establishment period (March – April), repeated perturbations may cause individuals to abandon nest building. Once the female has begun incubating eggs, she is less likely to display any overt response when people or vehicles approach the nest. Observations of nests on the Inyo National Forest suggest that both the male and female adults become more aggressive shortly after juveniles hatch and will actively defend the nest by ―dive bombing‖ approaching humans. This behavior results in an energetic cost to the adults and may also detract from their ability to tend to young or forage. This aggressive behavior declines significantly once juveniles are capable of independent flight (mid-August) and by the end of August human disturbance in the vicinity of nests does not appear to negatively affect juvenile survival.

The use of sheep bedding grounds or the trailing or watering of sheep in close proximity to an active goshawk nest presents a risk to goshawk individuals and productivity. The presence of humans, sheep and vehicles may elicit territorial or defensive behavior by goshawks and lead to nest abandonment or reduced ability to protect the nest. These impacts would most likely to occur if the source of disturbance was very close to an active nest. The protected activity center is a viable proxy for the area where disturbance would likely be detrimental to goshawks. Disturbance outside of PACs is unlikely to negatively affect northern goshawks. Under existing management, there are no sheep bedding grounds or watering sites within PACs. New bedding

74 grounds may be required to adequately distribute sheep throughout the Mono Mills Allotment. To assure that disturbance of northern goshawks during the breeding season is minimized or eliminated, the following measure is incorporated in the Proposed Action:

WLF-2. Locate all bedding grounds, watering sites and trails outside northern goshawk protected activity centers.

Cumulative Effects The major threats to northern goshawks at the present time involve the effects of vegetation management (e.g., timber harvest, fuels treatments, etc.) and wildfire on the amount, distribution and quality of habitat (DeStefano 1998).

The 1988 Inyo National Forest LRMP designated 29,697 acres within the Mono Basin allotment group as prescription #10 (high-level timber management). Upon publication of the Record of Decision for the Sierra Nevada Forest Plan Amendment Project (USDA Forest Service 2004) the area was reclassified as ―general forest‖. Some level of timber harvest has historically occurred throughout this area. Prior to the early 1990s harvest methods included overstory removal, small clearcuts, pre-commercial and commercial thins. Beginning in the early 1990s, the Forest discontinued the cutting of large old trees and began a program of ―old-growth‖ restoration. Since that time timber harvest has consisted of thinning from below or removing the smallest diameter trees sequentially until a desired basal area and spacing was reached. Cut trees were sold as firewood or left on site for the public to collect. Most areas were subsequently treated with prescribed fire.

Since 1994 approximately 9,265 acres have been treated in this manner. The units were likely goshawk foraging habitat prior to treatment and continue to provide foraging opportunities as the dominant overstory trees were retained. Potential goshawk nesting habitat was identified by the early 1990s and no timber harvest has occurred in those stands since that time.

Wildfire has not played a significant role in modifying northern goshawk habitat in recent history. Since 2001 four wildfires have affected approximately 525 acres of suitable goshawk foraging habitat. Fire intensity within these habitat areas was generally low to moderate and they continue to provide foraging opportunities.

Determination

Considering the above discussion of effects, the Biological Evaluation determined that implementation of the Mono Basin Grazing Allotment project may impact individual northern goshawks, but would not result in a trend towards federal listing or loss of viability within the project area. This determination is based on the following factor:

1. Bedding grounds, watering sites and trailing routes will not be allowed within northern goshawk Protected Activity Centers (Mitigation WLF-2).

Yellow Warbler: Direct and Indirect Effects

75 Under this alternative livestock use would continue within approximately 1.2 acres of riparian habitat. The Proposed Action eliminates sheep bedding grounds within 500 feet of streams. This would eliminate livestock use of the 0.6 acre bedding ground located in Township 1S, Range 29E, Section 7. In the absence of grazing, understory vegetation would likely respond rapidly at this site. The remaining 1.2 acres of riparian habitat would be managed with the following use standards (USDA Forest Service 1995):

• Allowable herbaceous utilization level 45% or less;

• Allowable browse utilization level 20% of annual leader growth of hardwood seedlings and advanced regeneration; and

• Streambanks would not exceed 20% disturbance per reach.

These use standards are compatible with maintaining adequate aspen recruitment and there should be no change in total acres of riparian habitat, deciduous canopy cover, total canopy cover or CWHR size class.

Cumulative Effects

Livestock grazing and water diversions are the primary historic and on-going activities that affect yellow warbler habitat across the Sierra Nevada. As described above, grazing is currently occurring within slightly less than 2 acres of riparian habitat within the Mono Basin allotments. This represents approximately 2 percent of the total available habitat within the allotments. There are no water diversions or other perturbations cumulatively impacting riparian habitat in the analysis area. Sport fishing has been known to affect riparian habitat in some areas of the Sierra Nevada. Anglers may trample or remove vegetation while attempting to access waterways. The northern Glass Mountains is a relatively remote area without an established sport fishery. As such, angling pressure is light to non-existent and not a source of disturbance within yellow warbler habitat.

Aspen stands are often utilized by dispersed campers. This use may reduce the suitability of yellow warbler habitat due to trampling of young aspen suckers which may lead to a reduction of aspen regeneration. Dispersed camping does occur in the Glass Mountains; however no dispersed campsites were identified in riparian habitat within the Mono Basin allotments.

Determination

Livestock grazing has been occurring since the 1860s within the project area (Fletcher 1982) and, in conjunction with wildfire and climate, has created the vegetative mosaic present on the landscape. Under the proposed action, allowable use standards are modified based on the condition of key areas within the allotments and are designed to provide accelerated restoration and improvement of degraded range sites to a functional condition and to maintain those sites currently in a fully functional condition. Under the proposed action livestock use would be discontinued within 0.6 acres of riparian habitat in Township 1S, Range 29E, Section 7. The proposed action would allow some level of impact to continue on approximately 1.2 acres out of

76 38,140 acres (0.003%) of riparian habitat on National Forest System lands in the Sierra Nevada. The degree of impact is anticipated to be minimal, and would not alter the existing trend in the habitat, nor lead to a change in the distribution of yellow warblers across the Sierra Nevada bioregion.

Species of Local Concern

Mule Deer:

Direct and Indirect Effects Implementation of the proposed action would have minimal or no impact on mule deer. Livestock and mule deer would not overlap temporally as the on dates for livestock are delayed until after June 15 or later at which time deer have already accessed summer range west of Highway 395. Similarly, livestock would be removed from the allotments no later than September 15 each year which is at least one month prior to the earliest onset of fall deer migration. This would negate the potential for livestock disturbance of deer or disruption of fawning.

Similarly, competition for forage would be minimized by delaying livestock use until after spring migration. Deer would have access to all new growth of grasses, forbs and shrubs as well as the residual from the previous year. Forage availability would not be a limiting factor for deer during fall migration. The use standards prescribed in Forest Plan Amendment #6 are maximum limits of use by all species (both domestic livestock and wildlife). Adaptive management would entail monitoring utilization after fall deer migration. If deer use in the fall results in exceeding utilization limits, livestock use would be reduced the following year to correct the imbalance. Cover habitat would not be affected by livestock grazing. Cover habitat on the allotments is provided by dense stands of conifers which are not impacted by sheep grazing. Implementation of the proposed action would have no effect on the ability of mule deer to pass through the allotments. There are currently no fences or other potential barriers in June Lake, Mono Mills or Dexter Creek allotments A short (0.1 mile) section of fence would be constructed near Baxter Springs which may cause deer to detour a small distance. Generally, however, deer are able to jump over or crawl under standard height fences. 2. Cumulative Effects

Past and present effects to deer include historic grazing within deer habitat; loss or creation of habitat by wildfire; loss of hiding and thermal cover from timber and fuels projects, along with an increase in forage; urban expansion; and a general increase in noise and sight disturbance from recreational activities such as hunting, camping and pleasure driving, including all forms of motor vehicle use. Deer mortality from collisions with vehicles is expected to continue on high- speed paved routes such as US395. Between 1965 and 2001, deer mortality on a 40 mile stretch of US395 ranged from 5 – 56 deaths per year (EMA 2003). Bleich et al. (2006) reported that road-kills accounted for 27 percent of deer mortality investigated during their study.

Wildfire can remove both cover and forage for mule deer. Contemporary fires (since 2000) have generally been relatively small or have only consumed small amounts of shrub-steppe vegetation in the vicinity of the Mono Basin allotments. During this period, approximately 6,350 acres of

77 shrub-steppe vegetation has burned. The potential for a large, landscape scale wildfire exists, however these events are stochastic and it is not possible to predict when such an incident may occur.

Habitat burned by wildfire does not necessarily become unsuitable for mule deer, but may change from hiding or thermal cover to foraging habitat. In other cases, when invasive plant species colonize the site post-fire, habitat quality is reduced. Only when a complete type conversion (e.g., sagebrush/bitterbrush to cheat grass) occurs would the habitat become unsuitable. Type conversion or rapid spread of weeds in burned areas is not currently occurring in the vicinity of the Mono Basin allotments (see Botany section of this document) and burned areas continue to provide foraging opportunities for mule deer.

Some level of timber harvest has occurred throughout the forested portion of the project area. Prior to the early 1990s harvest methods included overstory removal, small clearcuts, pre- commercial and commercial thins. Beginning in the early 1990s, the Forest discontinued the cutting of large old trees and began a program of ―old-growth‖ restoration. Since that time timber harvest has consisted of thinning from below or removing the smallest diameter trees sequentially until a desired basal area and spacing was reached. Cut trees were sold as firewood or left on site for the public to collect. Most areas were subsequently treated with prescribed fire.

Since 1994 approximately 9,265 acres have been treated in this manner. Historic clearcuts effectively converted cover to foraging habitat, until such time as reforestation efforts were successful. Thinning from below reduced the quality of both thermal and hiding cover. Recent thinning operations (since 1996) included design criteria to retain patches of cover throughout areas that received high use by mule deer. No additional timber harvest or fuels reduction projects are reasonably foreseeable within the Mono Basin Allotments.

Pygmy Rabbit:

Direct and Indirect Effects It is unlikely that issuance of term grazing permits would lead to competition for forage between livestock and pygmy rabbits. Sagebrush comprises the majority of pygmy rabbit diets and this plant species is rarely consumed by livestock due to potentially toxic levels of monoterpenoids in the foliage. Some sagebrush can be destroyed by repeated trampling and this is likely to occur to a limited degree within sheep bedding grounds. It is estimated that existing and expected bedding grounds will encumber approximately 18 acres of shrub-steppe vegetation that could provide forage and habitat for pygmy rabbits.

Livestock grazing could be a source of disturbance, especially in the vicinity of rabbit burrows. Burrows usually have a number of entrances, are constructed into a north or east facing slope (Wilde 1978), and are often located at the base of sagebrush patches (Green and Flinders 1980b). In California, their burrows are generally less than 1m long and up to 1.5 m deep (Orr 1940). Burrows are an important element of an individual’s home range because they provide protection from predation and temperature extremes, and are probably used as nesting sites. Disturbance at burrow sites could cause temporary displacement of individuals, but would likely be a short term perturbation, with rabbits able to return to their burrows shortly after livestock vacate the area.

78 The potential for burrow collapse as a result of livestock trampling exists but is expected to be minimal. Of the four allotments, pygmy rabbits are most likely to occur in Mono Sandflat based on habitat suitability, historic range and proximity to known occupied habitat. Under the proposed action, livestock grazing would be deferred on Mono Sandflat Allotment until desired vegetation conditions are attained. During this time there would be no potential for livestock to damage rabbit burrows. If livestock are eventually permitted on the allotment, the numbers would be low (26 cow/calf pairs) and the potential for burrow damage would remain minimal. Livestock grazing on the four allotments is unlikely to have any impact on the ability of pygmy rabbits to move through suitable habitat.

Cumulative Effects The main threat to B. idahoensis in Nevada and California is fragmentation due to large fires. These fires have extirpated populations from entire valleys and without leaving any cover behind may not allow rabbits to repopulate the area. The spread of non-native plant species in recently burned areas can exacerbate this threat. Agricultural fields are also a risk factor. Fields are often placed on the same loamy soils the rabbits prefer, may also create a potentially impassable barrier, and may increase the habitat suitability for cottontails. Road systems represent a potential barrier to dispersal. In nighttime road transect surveys in areas with known ratios of jackrabbits/cottontails/ B. idahoensis, B. idahoensis was consistently significantly underrepresented. This may be due to their reluctance to cross open areas (Sequin 2004). Contemporary fires (since 2000) have generally been relatively small or have only consumed small amounts of shrub-steppe vegetation in the vicinity of the Mono Basin allotments. During this period, approximately 6,350 acres of shrub-steppe vegetation has burned. These burns have had the beneficial effect of creating a mosaic of patches of early-seral sagebrush-steppe vegetation which more closely resembles historic levels of seral diversity. These wildfires have not been large enough to constitute a barrier that would prevent pygmy rabbit dispersal. The potential for a large, landscape scale wildfire exists, however these events are stochastic and it is not possible to predict when such an incident may occur.

Agriculture in the Mono Basin is minimal and restricted to small plots of land on the western side of Mono Lake. Three high-speed paved roads (US395, SR167, and SR120) occur in the vicinity of the Mono Basin allotments. State route 167 forms the northern boundary of the Mono Sandflat Allotment and may act as a barrier for rabbits dispersing from occupied habitat in the Bodie Hills.

3.5 Effects Relative to Aquatic Wildlife

This section contains a summary of information presented in the Biological Evaluation for Aquatic Species (Sims, 2011) which is hereby incorporated by reference.

3.5.1 Existing Condition Aquatic resources within the Mono Allotment group are sparse throughout the area. No running water, or perennial streams, occurs within the Mono Sand Flat or June Lake allotments. Approximately 9.5 miles of perennial streams occur within the Dexter and Mono Mills allotments and are small in size and

79 flow, and typically terminate in the ground. Although these streams provide an important resource for wildlife by creating diverse riparian habitats, they do not provide hydrological connectivity to any major bodies of water, and so are biologically isolated. Desert springs also provide important riparian habitat, not only providing water to the inhabitants of this ecosystem, but also increasing diversity within the landscape. No native fish inhabit these streams and due to the lack of robust, dependable flow, introduced trout have not particularly thrived in these environments. A population of brook trout occurs within Dexter Creek within the allotment, which is a self sustaining population with relatively small individuals.

The condition of the meadows relate to the condition of the streams that flow through them. Meadows that are properly functioning will have minimal soil disturbance along the stream edge, where as meadows not functioning properly or that are in poor condition will have above average sediment input and reduction in surface shade due to the suppression of vegetative growth. Four of the five Key Areas were rated as Proper Functioning Condition, with Johnny Meadow rated at Fair, indicating that meadows within the allotments are in relatively good condition. Streams within these meadows have been rated as Proper Functioning Condition, with vigorous riparian vegetation and shade, stable banks and lack of unstable areas.

80 Above: Location of perennial streams within the Dexter Creek Allotment.

Table 18. Miles of Perennial Stream. Allotment Name Miles of Perennial Streams June Lake Allotment 0 Mono Mills Allotment 0.75 Mono Sand Flat 0 Dexter Creek Allotment 8.75 Total 9 .5 miles

A query of GIS information for springs and streams was conducted for the four allotments. A total of 41 springs were identified throughout the four allotments. The tables below indicate the results of the query.

Table 19. Number of Springs. Allotment Name Number of Springs June Lake Allotment 0 Mono Mills Allotment 3 Mono Sand Flat 1 Dexter Creek Allotment 37 Total Number of Springs 41

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Above: Location of springs on the Mono Sand Flat Allotment. One spring is located on the allotment.

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Map above: Location of springs within the Dexter Creek, Mono Mills and June Lake allotments. Also included are results from springsnail surveys completed by Hershler, 1989, as depicted by the bright green dots. No rare species were identified.

A complete aquatic survey was conducted in 1995 by fisheries technicians to catalog aquatic species throughout Dexter Creek Allotment. Brook trout were identified within Dexter Creek, along with mountain yellow-legged frogs in Crooked Meadows, which have since been extirpated. Springs were also surveyed for springsnails, and an unidentified springsnail was observed in a spring that occurs outside the allotment boundary. No other aquatic species were identified in the surveys. Macroinvertebrates were not included in the surveys.

Prior to 2000, Crooked Meadows within the Dexter Creek watershed was habitat to a robust population of mountain yellow-legged frogs. Since that time, the population was extirpated by the fungal infection, Chytrid. Several surveys have been conducted in the area since that time, with negative results. Personal communication with Roland Knapp, research biologist, in 2009, indicated that he has occasionally observed a single adult frog within the meadow, however, no tadpoles have been observed in the meadow.

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Left: Overview of riparian area within the allotment in the upper watershed of an un-named creek, just northeast of Wild Horse Meadow.

Management Indicator Species (MIS) within the analysis area include the Pacific chorus frog (an indicator of meadow habitat) and the macroinvertebrate populations (an indicator of aquatic habitat). Macroinvertebrates are aquatic–dwelling insects that live either their entire life or part of their life in the water, and for the purpose of using these organisms as an MIS, are good indicators of overall stream health. For the Pacific chorus frog, a total of 91.8 meadow acres are identified as suitable habitat, all which occur within the Crooked Meadows complex along Dexter Creek. For macroinvertebrates, a total of 9.5 miles of stream occur within the allotments that are suitable habitat for these species. The analysis of these MIS is included within the MIS Report for the Mono Basin Group Grazing Allotment Project, and is incorporated by reference.

3.5.2 Environmental Consequences

Direct and Indirect Effects of the No Action and Proposed Action Alternatives:

There are no aquatic species of special concern (Threatened, Endangered, or Sensitive species) within the four allotments that would be affected by a grazing decision (see Aquatic Species Biological Evaluation for the Mono Basin Group Grazing Allotment Project, incorporated by reference). Therefore, neither the No Action nor the Proposed Action would directly, indirectly, or cumulatively affect any aquatic species of special concern.

The implementation of this project will not alter the existing trend in the habitat for aquatic macroinvertebrates across the Sierra Nevada bioregion. The change in flow, sedimentation and

84 shade are too small to be measured in the Mono Basin Group Range Permit Re-issuance analysis area. As a result, both the No Action and the Proposed Action would have no effect on habitat for aquatic macroinvertebrates.

Both alternatives would result in no grazing in the Crooked Meadows area, allowing for a continued upward trend of 91.8 acres in hydrologic function and vegetative cover for this meadow. Therefore, there would be no direct, indirect or cumulative effects on Pacific chorus frog habitat with the implementation of either alternative. The maintenance of 91.8 acres of identified wet meadow in the analysis area will be beneficial to the Pacific chorus frog at the project scale and at the Bioregional scale.

3.6 Effects Relative to Plants and Noxious Weeds This section contains a summary of information presented in the Biological Evaluation for Sensitive Plant Species (Weis 2011a) and the Noxious Weed Risk Assessment (Weis, 2011b).which are hereby incorporated by reference.

3.6.1 Existing Condition The vegetation of the three southern allotments, Dexter Creek, June Lake, and Mono Mills, has been well documented by Michael Honer (2001) and is mostly dominated by sagebrush scrub and Jeffrey pine forests, with other woodlands and forests of pinyon pine, lodgepole pine, and aspen. Riparian vegetation is present along perennial springfed streams and includes willows, wild rose, water birch, sedges, and grasses. There are also several meadow systems adjacent to springs that were used for cattle grazing in the past and show some sign of disturbance (Honer, 2001). Honer identifies the pumice sand flats in these three allotments as a special habitat and they are also described in the California Natural Diversity DataBase (CNDDB) as a rare natural community. They are the principal habitat for the two sensitive species Mono milk-vetch and Mono Lake lupine. Honer describes them as large, nearly shrubless pumice soil ―sand flats‖ surrounded by Jeffrey pine forest and sagebrush.

The Mono Sand Flat Allotment on the northeast shore of Mono Lake consists for the most part of sparsely vegetated sand dunes with some seasonally flooded swales and a few springs with riparian vegetation.

The Inyo National Forest has an aspen enhancement project currently in the planning stage, although surveys of aspen have been ongoing since 2008. There are approximately 60 aspen stands, totaling about 800 acres, in the analysis area, mostly on the Dexter Creek Allotment, with a few on the Mono Mills allotment. Ten of the stands have been visited and evaluated as of 2010. Of these, three were deemed to be at low risk, three at moderate risk, and four at high risk of being lost from above (overtopped by conifers) or not being replaced from below (insufficient aspen regeneration). Sheep browsing was observed at four of the stands, but was an issue at only two of them. The enhancement project proposes to treat aspen stands at moderate, high, and highest levels of risk using a suite of treatments, in order to reduce the risk of loss.

In a Forest-wide search for fens using aerial photos, one meadow, Crooked Meadows, was identified as possibly having a fen. The meadow was visited in 2007 and sampled at three

85 locations, but no areas meeting the Forest Service Region 5 definition of a fen (>40 cm peat, year-round saturated soil, fen plants) were found.

Rare and Sensitive Plants The Biological Evaluation for the Mono Basin Grazing Allotments (Weis 2011a) identified three sensitive plant species known to occur in the project area (Mono milk-vetch, Bodie Hills rock- cress, and Mono Lake lupine) and seven sensitive species for which potential habitat exists within the project area (5 rare moonworts, Williams’ comb-leaf, and Inyo phacelia (Table 20). Known populations in the allotments have been monitored through field visits and mapping within the past ten years as well as through limited sampling of three populations of Mono milk- vetch beginning in 1982. There were inconsistent results among the populations in regard to number of plants present. At Big Sand Flat in the Mono Mills allotment, there are two plots, one inside and one outside of a fenced area, and since 1982, there has been a larger reduction in Mono milk-vetch plants inside the exclosure than outside, although both declined. The effect does not appear to be associated with current grazing since it is more severe inside the fence than outside. In another area, Smokey Bear Flat, which is outside of the Mono Basin, the numbers of plants in two plots have increased over the same period. Information about this species is limited and the factors affecting population levels are not well understood, but monitoring will continue as follows:

The on-going monitoring of Astragalus monoensis inside and outside the existing exclosure at Big Sand Flat would continue at least at five year intervals. An initial assessment of the amount of reproductive output removed from Lupinus duranii plants at populations on the allotments would be done and additional monitoring scheduled as needed, depending on the results of the initial study.

Table 19. Sensitive Species Found or With Potential Habitat in Analysis Area. Species Common # Populations Allotment Habitat Name Astragalus Mono milk- 7 Mono Mills Pumice Sand Flat, adjacent monoensis vetch June Lake Jeffrey pine/lodgepole woodland and sagebrush Boechera Bodie Hills 1 Dexter Creek Rocky volcanic tuff bodiensis rock-cress Lupinus duranii Mono Lake 25 Mono Mills, Pumice Sand Flat, adjacent lupine June Lake, Jeffrey Pine/lodgepole Dexter Creek woodland and sagebrush Phacelia Potential habitat Mono Sand Flat Sagebrush near seasonally inyoensis wet areas Polyctenium Williams’ comb- Potential habitat Mono Sand Flat Edge of seasonally wet areas williamsiae leaf Botrychium spp. Moonworts Potential habitat All Meadows and spring areas (B. crenulatum, B. ascendens, B. lunaria, B. lineare, B. minganense)

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Watch List Plants and Other Rare Species (CNPS, CNDDB) Table 21 lists other rare plants found in the analysis area, but not included on the Forest Service Region 5 Sensitive Species list. These species are on List 2 of the California Native Plant Society (CNPS), which includes plant species that are rare, threatened, or endangered in California, but more common elsewhere. The ranks within List 2 indicate level of threat within California, with 0.2 being a moderate threat and 0.3 being low threat. These species are not disjunct from the larger range of the species and are not considered rare in the rest of their range.

Table 20. Watch List Plants and Other Rare Species Known from Analysis Area Species Common # Allotment List/Status Name populations Camissonia boothii ssp. Booth’s evening- 1 June Lake CNPS 2.3 boothii primrose Camissonia boothii ssp. Booth’s hairy 1 June Lake CNPS 2.3 intermedia evening- primrose Chaetadelpha wheeleri Wheeler’s dune- 1 Mono Sand Flats Inyo NF Watch List, broom CNPS 2.2 Lupinus pusillus var. Intermontane 1 Mono Sand Flats CNPS 2.3 intermontanus lupine Psoralidium lanceolatum Lance-leaved 1 Mono Sand Flats CNPS 2.3 scurf-pea Tetradymia tetrameres Dune horsebrush 2 Mono Sand Flats CNPS 2.2 Thelypodium integrifolium Foxtail 1 Mono Sand Flats CNPS 2.2 ssp. complanatum thelypodium

Weeds The Noxious Weed Risk Assessment (Weis 2011b) identified six invasive weed species known to occur within the project area, including cheatgrass, Russian thistle, mullein, bull thistle, dandelion and tansy mustard (Table 22). The total area mapped within the analysis area is less than 100 acres, or less than 0.1% of the total area.

87 Table 21. Known Weed Species, with Ratings and Inyo NF Proposed Treatment (USDA FS, 2007). Weed Species Proposed INF Priority/ CalIPC rating State Rating Treatment Goal

Bull thistle (Cirsium Manual Moderate/ Moderate C vulgare) Eradicate

Common mullein Manual Moderate/ Limited (Verbascum thapsus) Contain

Cheatgrass (Bromus Manual; seeding Locally high; High tectorum) with native species generally low/

Contain

Russian thistle Manual Low/ Limited C (Salsola spp.) Contain

Dandelion Manual Very low/ Eval – No (Taraxacum Listing officinale) Contain

Mustards Manual Very low Limited/ (Descurainia, (D.sophia)/ Moderate Sisymbrium spp.) Contain

3.6.2 Environmental Consequences

3.6.2.1 Direct, Indirect, and Cumulative Effects of No Grazing (Alternative 1)

No grazing would occur on the allotments, so there would be no trampling or removal of vegetation by domestic animals. The current vegetation condition will be maintained or could improve faster than under the Proposed Action.

The No Action Alternative, when combined with the rehabilitation effects of both the aspen enhancement project and the implementation of Travel Management direction, will most likely be somewhat faster than under the Proposed Action.

Rare and Sensitive Plants Under the No Grazing Alternative, it was determined that there would be no domestic animal trampling, grazing, increased weed introduction, or spreading effects on TESP plant species, so there would be no increase in negative cumulative effects to TESP plant species and vegetation would recover from previous grazing effects, improving habitat conditions for rare plant species.

88 3.6.2.2 Direct, Indirect, and Cumulative Effects of the Proposed Action (Alternative 2) The design criteria for grazing management under Amendment 6 of the Inyo LRMP, including standards for key areas and general vegetation types including aspen, as well as the proposed criterion prohibiting bedding grounds on pumice sand flats, will maintain or improve current habitat conditions for Mono Lake lupine and Mono milk-vetch.

Other actions that will affect vegetation in these allotments are the proposed Aspen Enhancement Project and implementation of the Travel Management decision (2010) which limited OHV use to authorized roads only. The eventual recovery of routes not authorized in the Travel Management decision will improve the condition of the sand flat habitat. The cumulative effects of the Proposed Action and these two other actions will be to enhance the pumice sand flat and aspen communities in particular and vegetation in general.

Under the Proposed Action, a drift fence would be built at Baxter Spring. Because there are no known rare or sensitive species in the area, the fence would have no effect on rare and sensitive plant species.

Rare and Sensitive Plants The effects of the proposed grazing allotment permits were analyzed by habitat type, including pumice sand flats, rocky steep habitat, and riparian habitats. The direct effects of grazing include trampling and grazing of sensitive plants, but the management under Amendment 6, which includes limits on utilization, residual dry matter, and resting several areas until recovery is documented, prescribed watering procedures, and the prohibition of bedding grounds on sand flats will protect sensitive plants and their habitats.

Other uses and factors potentially affecting botanical resources in the area include recreational activities, implementation of the Travel Management decision (2009), previous fuel reduction treatments, fire, management of adjacent BLM allotments, and climate change influence on precipitation and fire intervals. As discussed above, the direct and indirect effects of the proposed action are limited in scope and intensity and they do not contribute to a significant cumulative effect when added to the effects of other past, current, and reasonably foreseeable future activities.

Determination

Based on effectively using Amendment 6 adaptive management of the grazing in the Mono Basin allotments, continuation of monitoring of Mono milk-vetch and Mono Lake lupine populations, the design criterion of no bedding grounds at sand flats, and the decision to close unauthorized routes under the Travel Management project, it was determined that the direct, indirect, and cumulative effects of the proposed activity may impact individuals but will not lead to a trend to federal listing for Mono milk-vetch or Mono Lake lupine.

Based on effectively using Amendment 6 adaptive management of the grazing in the Mono

89 Basin allotments, monitoring of the known Bodie Hills rockcress population, and the likelihood of many undocumented populations, it was determination that the proposed activity may impact individuals but will not lead to a trend to federal listing for Bodie Hills rockcress.

Based on effectively using Amendment 6 adaptive management of the grazing in the four Mono Basin allotments, including resting several meadows, the ability of the moonworts to tolerate some disturbance, and the relatively light use and impact on meadows by sheep it was determined that the proposed action may impact individuals, but is not likely to cause a trend toward federal listing or a loss of viability for slender moonwort, scalloped moonwort, common moonwort, Mingan moonwort, and upswept moonwort.

Based on the fact that the Mono Sand Flat Allotment would be rested until vegetation recovers enough for grazing and on the proposed management using Amendment #6 standards, it was determined that the Proposed Action may impact individuals, but is not likely to cause a trend toward federal listing or a loss of viability for Williams’ combleaf or Inyo phacelia.

Watch List Plants and Other Rare Species (CNPS,CNDDB) The effects on the species in Table 21 are the same as those discussed for the sensitive species above. Based on grazing standards and design criteria, the condition of the habitat will be maintained or improved, and although individual plants may be affected by grazing, no downward population trends are expected.

Weeds Several weed species occur near Baxter Spring, where a change in watering strategy to reduce impacts is proposed. The site will be monitored and bull thistle and mullein removed. The monitoring will also be used to detect any new weed species that may be introduced, since this site appears to be susceptible to weed invasion. Under the Proposed Action, a drift fence would be built at Baxter Spring. Because weeds are present, equipment and clothing should be cleaned before and after work at the site. With this mitigation in place, the construction of the fence should have no effect on weed populations.

Other weeds, particularly cheatgrass are scattered throughout the area, mostly along roads, and are not expected to spread a great deal. The Crater fire in the Mono Mills allotment does not show signs of weed invasion and in a survey of the Mono fire in 2010, no weeds were found adjacent to the burned area, so very little spread is expected. New disturbances such as fires or fuel reduction projects are surveyed for weeds and monitored following the disturbance. Weed populations adjacent to routes considered in the Travel Management assessment (2009) were identified and those posing high risk will be eradicated during implementation of that decision. Other known populations identified for the Weed Treatment EA (2007) will be treated in order of Inyo NF priority (Table 22) as funding allows. Although climate change effects may favor the

90 spread of invasive plant species, the current management for weed treatment and the grazing management under Amendment 6 are expected to reduce the risk.

Many of the areas with weed infestations would have changes in livestock management that reduce the amount of trampling and associated ground disturbance due to resting of the area, a reduction in livestock numbers, or a shortened season. This should contribute to higher levels of vegetation cover and litter, and less bare ground and disturbance in those areas, which should reduce the weed risk. The overall risk of habitat alteration from this project contributing to weed vulnerability is low.

3.7 Effects Relative to Cultural Resources

Summarized from the Cultural Resource Report for the Mono Basin Grazing Allotment Analysis, Report # R2008050401307 (West 2011). The protection of cultural resources has been incorporated into the Proposed Action. The environmental analysis for the NEPA decision and compliance with section 106 of the National Historic Preservation Act (NHPA) were accomplished pursuant to the:

Programmatic Agreement among the USDA, Forest Service, and the Advisory Council on Historic Preservation, Regarding Rangeland Management Activities on National Forest System Lands (USDA FS 1995) (PA) and the

Memorandum of Understanding among the USDA Forest Service, Pacific Southwest Region, California State Historic Preservation Officer, and the Nevada State Historic Preservation Officer regarding Rangeland Management Activities, 1996 (MOU) and the Rangeland Heritage Resources Management Activities, Inyo National Forest, California and Nevada, 1997 (INF Supplemental).

These agreements outline timelines and procedures the Forest will employ to meet their responsibilities under Section 106 of the NHPA and related authorities. The Forest will meet those requirements by implementing a phased identification and evaluation approach pursuant to the MOU. Stipulation XII.D. of the MOU, Amendment No.1 extended the term of the MOU for an additional five years.

3.7.1 Existing Condition Cultural resources found within the four allotments illustrate a long history of human use of the area. Prehistoric Native American sites consist of temporary and seasonal resource procurement camps and sites associated with the collection of piaga, the larvae of the Pandora moth, which was harvested and stored as a valuable food source within the Jeffrey pine forest.

91 Historic sites within the project area are generally associated with logging and grazing that supported the Bodie Gold Mine at the end of the 19th and into the early 20th Century. Basque and Spanish immigrants herded sheep throughout the Dexter Creek, Mono Mills and June Allotments and left their mark and stories of their lives on the bark of aspen trees. The Mono Mills Historic Logging District harvested, milled and transported lumber and firewood to the Mining town of Bodie via the Bodie Railroad. Remnants of this cultural history are found throughout the project area and were analyzed for the direct and indirect effects of the proposed action to continue grazing in the area

3.7.1.1 AREA OF POTENTIAL EFFECT (APE) The area of potential effect for this analysis focused on high use or concentrated grazing areas where impacts to cultural sites are most likely to occur (MOU Table No. 1). These areas were identified from high use and sheep bed GIS data collected by Forest Rangeland Specialists. Other grazing use levels will be analyzed over the next three years and included as addendums to this report. High use areas are defined in the MOU as ―Areas which receive concentrated use from livestock grazing activities, where use is intense enough to cause possible degradation of the environment and or heritage resources through erosion, compaction, or trampling.‖ These areas include but are not limited to seeps, springs, creek banks, meadows, shade areas, watering troughs, stock drives and bedding areas. All high use areas within the four allotments were surveyed for cultural resources.

SURVEY STRATEGY AND FIELD METHODS The inventory strategy for this Environmental Assessment focused on all high use grazing areas. All high use areas plus a 40 meter buffer were intensively surveyed using 20 meter transects.

Current Sheep Allotments (June Lake, Mono Mills, Dexter Creek)

Cultural sites that were identified within 100 meters of a high use grazing area or sheep bedding ground were visited and the effects of grazing analyzed and documented. Sheep bed locations that did not have prior cultural survey were surveyed for cultural resources including a 40 meter buffer surrounding the disturbed area. Areas of high use with low site sensitivity were selectively surveyed.

Current Cattle Allotments with areas of High Use and potential conflicts: (Mono Sand Flat) All identified high use areas where cultural resources were likely were surveyed for cultural resources. Areas that had a low probability of cultural resources such as areas that are inundated with water seasonally were not surveyed.

92 Table 23 provides the archaeological survey levels agreed upon by the California and Nevada State Historic Preservation Officers (Region 5 MOU pp 40).

Table 22. Survey Matrix

Site Sensitivity

High Moderate Low

Coverage to find all sites/intensive Sample based on Spot check based Concentrated survey or professional on professional (High) statistically valid judgment. judgment. predictive model,

Sample based on Sample based on Spot check based

Moderate professional professional on professional judgment. judgment. judgment.

Minimal spot Spot check based Spot check based check based on Grazing Use Low/Moderate on professional on professional professional judgment. judgment. judgment or no survey. Minimal spot Spot check based Spot check based check based on Low on professional on professional professional judgment. judgment. judgment or no survey.

3.7.1.2 CULTURAL RESOURCES

Twenty-eight previously recorded cultural resources are located within 100 meters of high use areas in all four allotments. These sites were visited, analyzed for impacts associated with grazing, resource protection measures recommended if necessary and site records updated if new site features were found. Nine new sites were found and recorded as part of this survey resulting in a total of 37 sites analyzed for this project. Sites located within moderate and moderate-low grazing areas will be spot checked based on the survey matrix (Table 23) over the next three years. All 37 sites have not been evaluated for listing on the National Register of Historic

93 Places. The MOU allows the Forest Service to assume eligibility of unevaluated sites as long as their potential significant historic values can be protected either through avoidance or standard resource protection measures.

Table 23. Project Acres-- Survey and Cultural Site Summary.

Allotment Project APE Acres Previously New Survey Cultural Acres High Use Surveyed Acres High Sites in Acres Use + 40m High Use High Use buffer Area Dexter Creek 18,781 497.6 339.3 350.5 14

June Lake S&G 16,528 69.0 56.3 65.6 5

Mono Mills S&G 29,263 57.4 57.4 0 15

Mono Sand Flat 8,696 51.8 0 139.3 3 Total 73, 268 675.8 453 555.4 37

Evaluation for the National Register of Historic Places:

According to the Range MOU Section IV, D. 2, significance evaluation is not necessary prior to initiating range undertakings if the standard resource treatment measures of Appendix C, clause V can be implemented to ensure that potential values are unaffected in any manner. No cultural resources were evaluated for this undertaking because all potentially significant historic values could be protected using Standard Resource Protection Measures.

3.7.1.3 CULTURAL RESOURCE TREATMENT RECOMMENDATIONS

Standard Resource Protection Measures (SRPMs) may include, but are not limited to maintaining or reconstructing existing range improvements, constructing new range improvements to reduce or eliminate impacts to cultural resources and removing or re-locating the high use area to another location devoid of cultural resources (MOU, Appendix C, V). SRPMs are recommended for seven cultural sites in order to protect their potentially significant historic values from the effects of continued grazing (Table 10). Protection measures will be implemented prior to authorization of grazing.

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3.7.1.4 MONITORING PLAN

Annual site condition monitoring will test effectiveness of protection measures and the assumptions made during the site analysis when grazing effects were ambiguous. Twelve cultural resources are recommended for annual site condition monitoring (Table 10). Monitoring results will be reported to the California State Historic Preservation Office annually in the Inyo National Forest Heritage Program Annual Report under the Range Activities section as well as an addendum to this report. If adverse effects are found as a result of continued grazing use, then standard protection measures will be implemented.

3.7.2 Environmental Consequences

3.7.2.1 Direct, Indirect, and Cumulative Effects of No Grazing (Alternative 1)

If grazing is not permitted in these four allotments, no direct or indirect effects are anticipated. This Alternative would have No Effect 36 CFR §800.5(b) to cultural resources.

Cumulative Effects If there are no direct or indirect effects, there can be no cumulative effects (40 CFR §1508.7).

3.7.2.2 Direct, Indirect, and Cumulative Effects of the Proposed Action (Alternative 2)

The Inyo National Forest proposes to continue to permit livestock grazing by incorporating adaptive management strategies on the four grazing allotments within the Mono Basin Allotment Group while meeting Forest Plan direction. Continued grazing will have little effect to the 37 cultural resources identified within high use grazing areas within the four allotments if standard resource protection measures and monitoring are implemented. The Proposed Action prohibits grazing within the Mono Mills town site, an eligible and contributing element of this Historic District. This restriction will protect this valuable cultural resource. The Proposed Action also prohibits bedding grounds within 500 feet of water which will ultimately protect sensitive heritage resources located in these areas. The Proposed Action calls for construction of a drift fence at Baxter Springs. Consultation with the State Historic Preservation Officer’s office will be needed for concurrence on No Adverse Effect for the construction of the fence. This has not yet been done. Under the proposed action, bull thistle and mullein would be removed at Baxter Springs. This action would have no adverse effect (Sierra PA Attachment 4 Stipulations 11.3). Site condition monitoring will test whether the restrictions in the proposed action are sufficient to protect cultural resource values. A Cultural Resource Specialist shall be contacted if additional

95 range improvements, surface disturbing projects, and changes in grazing practices (that will concentrate grazing and could create impacts) are proposed. These will be cleared on a project by project basis according to Section 106 of the National Historic Preservation Act (36 CFR Part 800). With the above protection measures and monitoring in place, this alternative will have No Adverse Effect 36 CFR §800.5(b) to cultural resources.

Cumulative Effects Cultural resources are non-renewable resources that have continually been impacted by past actions within the four grazing allotments. The majority of cultural sites analyzed for this project have been affected by at least one of the following actions; dispersed camping, looting, livestock grazing, the development of livestock related structures, logging, prescribed fires, construction and maintenance of roads, flooding and fluvial transport of cultural materials and natural weathering. These disturbances have for the most part been documented in the cultural site records, however the effects of these disturbances on the historic integrity of the resource has been largely undocumented and therefore cannot be accurately quantified for analysis. For the purposes of this analysis, it can be assumed that these previous actions have potentially affected cultural sites in similar ways to the direct and indirect effects of the present project, discussed in the Effects Analysis of the Cultural Report (R2008050401307).

Grazing, logging, prescribed fire, and recreation are the primary causes of cultural site disturbance within the project area. Livestock grazing has occurred in the area for nearly 100 years. Damage to the integrity of cultural sites from cattle and sheep grazing has already occurred in a majority of these areas. The current analysis found that continued grazing with specific resource protection measures in place is unlikely to cause more damage to cultural sites.

Road construction, maintenance of roads, and use of roads by the public have also impacted cultural resources by first being constructed through many of them and second by allowing the public to easily access cultural sites and cause damage through camping, collecting and looting. Public recreational use is an ongoing disturbance that is difficult to manage and quantify. Site condition monitoring and site protection is occurring at various cultural sites in the project area with this type of use through the Travel Management Environmental Impact Statement (EIS) Decision (2009).

Logging (historic and more recently) has greatly affected cultural resources within the project area through ground disturbance and road construction, specifically in the Mono Mills Allotment. Again most of the damage has already occurred to cultural sites in these areas. Future logging and thinning projects must comply with historic preservation laws and avoid adverse effects to cultural sites.

Actions in the reasonably foreseeable future with the potential to affect cultural resources include the implementation of the Travel Management EIS Decision (2009) in which certain routes where cultural resources are located are maintained or closed based on this decision. The prescribed fire program in the Mono Mills Allotment has the potential to affect cultural resources. Because both of these are federal undertakings the potential effects from these projects should be avoided through the section 106 process.

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With resource protection measures and monitoring in place, the proposed action should have no cumulative effects on the contributing elements of the cultural resources within the grazing allotments. This alternative would have No Adverse Effect 36 CFR §800.5(b) to the 37 cultural resources analyzed, if monitoring shows that there are no grazing-related changes in site condition. For the remaining cultural resources within the allotments, monitoring, new survey and spot checks based on the survey matrix presented earlier would be used to determine whether additional resource protection measures should be implemented to protect cultural resource values. With resource protections measures and monitoring in place, the proposed action should have no cumulative effects on the contributing elements of the cultural resources within the grazing allotments.

3.8 Effects Relative to Socio-Economic Factors This section contains a summary of information presented in the Social and Economic Effects Analysis for the Mono Basin Grazing Allotments (Barron, 2011b).which is hereby incorporated by reference.

3.8.1 Existing Condition

Demographic Information The communities affected by the EA lie in Mono and Inyo Counties in the state of California. Although California is the most populous state in the nation, these two counties have relatively small populations. Mono County had 13,698 people in 2010 and Inyo County had 18,201 (State of California, 2010). These are rural counties on the eastern side of the Sierra Nevada range, far from California’s population centers on the Pacific Coast. Population density in these counties is low. In comparison to the overall state population density of 239.1 people per square mile (U.S. Census, 2010), Mono County has only 4.4 people per square mile and Inyo County has 1.8 (State of California, 2010).

Geography Mono County encompasses 3,132 square miles between the eastern Sierra Nevada and the Nevada state border. Inyo lies to the south of Mono County and comprises 10,140 square miles. Very little of this land is privately owned. Eighty-five percent of Mono County’s land is owned by the federal government. The State of California and the City of Los Angeles own 3.6% and 3.2% respectively. Only 7.8% is privately held. In Inyo County, 92% of the land is federal, 2.4% belongs to the State, and 3.9% belongs to the City of Los Angeles. Only 1.7% is privately held (Counties of Inyo and Mono Agricultural Commissioner’s Office, 2009). Much of the public land is leased for uses such as ranching, mining, and geothermal development.

Employment and Income The industries that employ the most people in Mono County are retail trade, personal services, and construction. Agriculture, forestry and fisheries fall eighth on the list. In Inyo County, the primary industries are retail trade, health services, and construction, with agriculture, forestry and fisheries falling in seventh place (U.S. Census, 2010).

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Agriculture is a multi-million dollar business in the two counties, with much of that business coming from livestock production. In 2009, livestock production in Inyo County was valued at $9,997,350, or 52% of all agricultural income. In Mono County, the value was $19,596,055, or 60% of the value of all agricultural commodities in the county for that year (Counties of Inyo and Mono Agricultural Commissioner’s Office, 2009).

Social Factors Most of this area remains rural in nature and has a long tradition of agricultural pursuits. Historically, many ranchers have made this area their home. Grazing by cattle and sheep has taken place since the mining boom of the 1870s and ranching has played a significant part in the social fabric of Mono and Inyo Counties. The land is also valued for a myriad of other uses such as recreation, mining, and water development. Balancing all of these uses while enhancing the health and beauty of the landscape can be a challenge.

Grazing in the Mono Basin is well suited to the lifestyle known as transhumance, in which ranchers move their livestock to different areas at different times of year. In this instance, the sheep ranchers keep their livestock in Bakersfield, California in the winter, and bring them to the higher elevations in Mono County in the summer.

The cattle that use the Mono Sand Flat Allotment in the winter remain in the area all year long. The Hilton Family Trust, which is the permittee for this allotment, has its base property in Mono County.

3.8.2 Environmental Consequences

3.8.2.1 Direct, Indirect, and Cumulative Effects of No Grazing (Alternative 1) The cessation of grazing would mean a slight economic loss to the permittees, the local economy, and the U.S. Forest Service. Currently, the allotments provide 1,735 Animal Unit Months2(AUMs) (Table 25). This allows for 7, 645 Head Months3 (HMs) on the Dexter Creek and June Lake Allotments and 206 HMs on the Mono Sand Flat Allotment. Use of these allotments garners the Forest Service $2,270 each grazing season, half of which comes back to the Forest in range betterment funds. Under Alternative 1, the permittees would lose this forage and the Forest Service would not receive grazing fees for range betterment funds.

This alternative would not meet the LRMP Standards and Guidelines in that it would not provide grazing tenure to lend stability to the local livestock-raising community and established ranching operations. The I&M Sheep Company relies on these summer pasture to run their operation. The 3,000 ewes they run on the Dexter Creek and June Lake Allotments constitute over 50% of their business. Under the No Grazing Alternative, they would be forced to seek alternative pastures and if those are not found, their operation may become no longer viable. Along with this would come the loss of seasonal jobs and revenue for the local economy.

2 An Animal Unit Month is the amount of feed or forage required by an animal unit for one month 3 A Head Month is one month’s use and occupancy of range by one weaned or adult animal.

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The Hilton Family Trust runs only 26 cow/calf pairs on the Mono Sand Flat Allotment as part of an on/off allotment in conjunction with BLM lands. This number makes up less than 2% of their total herd and will not have a large impact on their operation.

Table 24. AUMs, Head Months, and Fees.

Alternative AUMs Provided Head Net loss of AUMs Minimal Grazing for Livestock Months Fees Industry

Sheep ($0.27 per head month)

Existing 1,529 (Does not 7,645 NA $2,064 include the proposed 3,038 AUMs for Mono Mills)

1-No 0 0 1,529 0 Grazing

2-Proposed 4,567 22,835 0 $6,165 Action

Cattle ($1.35 per head month)

Existing 206 206 NA $278

1-No 0 0 206 0 Grazing

2-Proposed 206 206 0 $278 Action

3.8.2.2 Direct, Indirect, and Cumulative Effects of the Proposed Action (Alternative 2) Alternative 2 would have a beneficial impact on the permittees, the U.S. Forest Service, and the local economy. Under the Proposed Action, the sheep permittees would be provided with 4,567 AUMs each season The Mono Sand Flat Allotment provides 206 AUMs to the permittee; however, these AUMs would not be available while the allotment is being rested. The permittee has not used the allotment for the past four years, so this would not require any adjustment on his part.

99 With the resumption of grazing on the Mono Mills Allotment in addition to continued grazing on the Dexter Creek and June Lake Allotments, as proposed in Alternative 2, the sheep operations would pay $6,165 in grazing fees yearly. The Forest would receive half of this money back as range betterment funds. The local economy would benefit as seasonal jobs would be created and goods and services would be purchased.

This alternative would meet LRMP Standards and Guidelines because it would provide grazing tenure to lend stability to the local livestock-raising community and established ranching operations. Along with economic stability, this alternative would be beneficial to communities that value traditional uses of the land as part of the rural lifestyle.

Ranching operations may benefit from the new management practices as a result of increased land performance and vegetation health. Enhanced ecosystem conditions may mean increased nutritive value of forage which could result in higher weigh gains on livestock, producing lambs with a higher market value.

3.9 Effects Relative to Finding of No Significance (FONSI) Elements

In 1978, the Council on Environmental Quality published regulations for implementing the National Environmental Policy Act (NEPA). These regulations (40 CFR Parts 1500-1508) include a definition of ―significant‖ as used in NEPA. The ten elements of this definition are critical to reducing paperwork through use of a finding of no significant impact (FONSI) when an action would not have a significant effect on the human environment, and is therefore exempt from requirements to prepare an environmental impact statement (EIS). Significance as used in NEPA requires consideration of the following ten intensity factors in the appropriate context for that factor.

1. Beneficial and adverse impacts. Mitigations and management requirements designed to reduce the potential for adverse impacts were incorporated into the Proposed Action (i.e. standards and guidelines outlined in the Inyo National Forest LRMP (USDA Forest Service 1988), as amended by Forest Plan Amendment #6, Forest-wide Range Utilization Standards (USDA Forest Service 1995), Sierra Nevada Forest Plan Amendment (USDA Forest Service 2004), and the Mono Basin Scenic Area Plan (USDA Forest Service, 1989). These mitigations and management requirements would minimize or eliminate the potential for adverse impacts caused by livestock grazing activities.

100 A discussion of potential effects was summarized above from supporting analysis (Barron 2011, Lutrick 2011, Perloff 2011a, Perloff 2011b, Perloff and Sims 2011, Sims 2011, Weis 2011a, Weis 2011b and West 2011). All analyses prepared in support of this document considered both beneficial and adverse effects of the proposed action; however, beneficial effects were not used to offset or compensate for adverse effects in the analyses. None of the potential effects of the Proposed Action or No Grazing Alternative would be significant, even when considered separately from the beneficial effects that occur in conjunction with those effects.

2. The degree to which the proposed action affects public health or safety. None of the alternatives considered would have an effect upon public health and safety.

3. Unique characteristics of the geographic area such as proximity to historic or cultural resources, parklands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. There are no parklands, prime farmlands, wild and scenic rivers, or ecologically critical areas within the project area.

The allotments contain meadows, springs, and riparian features that would classify as wetlands. Based on the environmental analysis completed for hydrology, range, wildlife, and botany, the Proposed Action would not have a significant adverse effect to riparian values. The resource protection standards applied in the Proposed Action alternative, including restrictions on bedding ground location and livestock movement would ensure a lack of significant effects to wetlands.

The protection of cultural resources has been incorporated into the Proposed Action, and would follow the stipulations in the Programmatic Agreement (PA) among the USDA, Forest Service, and the Advisory Council on Historic Preservation, Regarding Rangeland Management Activities on National Forest System Lands (June 26, 1995) and the Memorandum of Understanding among the USDA Forest Service, Pacific Southwest Region, California State Historic Preservation Officer, and the Nevada State Historic Preservation Officer regarding Rangeland Management Activities, 1996 (MOU) and the Rangeland Heritage Resources Management Activities, Inyo National Forest, California and Nevada, 1997 (INF Supplemental). Details regarding the field surveys and management recommendations for heritage resources sites and features are contained in the Effects Analysis Mono Basin Grazing Allotments NEPA (West 2011) and Heritage Resource Report (#R2008-05-04-01307). By following the recommendations outlined in this report, including the use of the standard procedures outlined in the PA and MOU, it was determined that there would be no adverse effects to cultural resources from implementing this project (Ibid).

101 4. The degree to which the effects on the quality of the human environment are likely to be highly controversial. The proposed project follows the management direction in the Inyo National Forest Land and Resource Management Plan (USDA Forest Service 1988), as amended by Forest Plan Amendment #6, Forestwide Range Utilization Standards (USDA Forest Service 1995), the 2004 Sierra Nevada Forest Plan Amendment (USDA Forest Service 2004), and the 1989 Mono Basin Scenic Area Plan (USDA Forest Service, 1989). The Proposed Action was developed by comparing existing conditions with desired conditions. Potential adverse effects have been minimized or eliminated to the point where there are few effects to draw controversy. Public involvement efforts did not reveal any significant issues or any other significant controversies regarding environmental effects of this proposal. Based on comments from the public and the analysis of effects from the ID Team, there are not significant effects expected to the quality of the human environment from implementing any of the alternatives, including the Proposed Action alternative.

5. Degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. The proposed project follows the management direction in the Inyo National Forest Land and Resource Management Plan (USDA Forest Service 1988), as amended by Forest Plan Amendment 6, Forestwide Range Utilization Standards (USDA Forest Service 1995), the 2004 Sierra Nevada Forest Plan Amendment (USDA Forest Service 2004), and the Mono Basin Scenic Area Plan (USDA Forest Service, 1989). It implements management requirements designed to reduce the potential for adverse effects, and has incorporated utilization standards for the grazing of domestic livestock that would accelerate the restoration and improvement of degraded range sites and maintain those sites currently in good condition.

Local expertise in implementation of grazing activities minimizes the chance of highly uncertain effects or effects which involve unique or unknown risks. Livestock grazing has occurred in the eastern Sierra for more than a century including on the allotments within the Mono Basin Grazing Allotments analysis area. Many of the grazing practices used decades ago are no longer used due to a better understanding of range conditions, the needs of livestock, and effects of grazing on resource values. Rangeland health on the Inyo National Forest has continued to improve over time. Proposed activities are routine in nature, employing standard practices and protection measures, and their effects are generally well known.

6. The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration.

102 The Mono Basin Grazing Allotments Analysis represents a site-specific project that does not set precedence for future decisions with significant effects or present a decision in principle about future considerations. Any future decisions would require a site-specific analysis to consider all relevant scientific and site-specific information available at that time. These activities are in accordance with the best available science to manage grazing activities at this time.

7. Whether this action is related to other actions with individually insignificant but cumulatively significant impacts.

A cumulative effect is the consequence on the environment that results from the incremental effect of the action when added to the effects of other past, present, and reasonably foreseeable future actions, regardless of what agency or person undertakes the other actions and regardless of land ownership on which the actions occur. A cumulative effects analysis was completed separately for each resource area. None of the resource specialists found the potential for significant adverse cumulative effects (Barron 2011, Lutrick 2011, Perloff 2011a, Perloff 2011b, Perloff and Sims 2011, Sims 2011, Weis 2011a, Weis 2011b and West 2011).

8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources.

It was determined that there would be no adverse effect to cultural resources from implementing this project (West 2011; HRR # R2008-05-04-01307), and the Proposed Action does not adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places. Protection of heritage resources in the area was incorporated into the Proposed Action through such measures as restricting livestock movement and bedding ground location. Based on analysis documented in the Heritage Resource Report, the Proposed Action would not cause loss or destruction of significant, scientific, cultural, or historical resources.

9. The degree to which 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.

There is one federally listed threatened or endangered wildlife species known to occur in the vicinity of the project area. This species is the Sierra Nevada bighorn sheep (endangered). There is no critical habitat identified within the analysis area. Based on analysis documented in

103 the Biological Assessments, it was determined that this project would not likely adversely affect individuals or habitat of the Sierra Nevada bighorn sheep (Perloff, 2011b).

No federally listed threatened or endangered plant species have potential habitat (including critical habitat) or occur within or adjacent to the project area (Weis 2011a).

10. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment.

The proposed action would not threaten a violation of Federal, State, or local law, or requirements imposed for the protection of the environment. The proposed action is consistent with the National Environmental Policy Act (NEPA), National Forest Management Act (NFMA), Endangered Species Act (ESA), Clean Water Act, and National Historic Preservation Act (NHPA). The proposed action is fully consistent with the Inyo National Forest Land and Resource Management Plan (USDA Forest Service 1988), as amended by LRMP Amendment #6, Forest-wide Range Utilization Standards (USDA Forest Service 1995), the Sierra Nevada Forest Plan Amendment (USDA Forest Service, 2004), and the Mono Basin Scenic Area Plan (USDA Forest Service, 1989).

104 Chapter 4 Lists

4.1 Agencies and Persons Consulted

Joe Echenique, Echenique Livestock

Miguel Iturriria, I&M Sheep Company

Paco Iturriria, I&M Sheep Company

Kathleen Nelson, Botanist, Inyo National Forest

Cory Overton, Wildlife Biologist, US Geological Survey, Western Ecological Research Center

USDI Bureau of Land Management, Bishop Field Office, Bishop, California

USDI Fish and Wildlife Service, Ventura, California

4.1.1.1 Environmental Assessment Preparers April Barron Rangeland Management Specialist

Erin Lutrick Hydrologist

Richard Perloff Wildlife Biologist

Lisa Sims Fisheries Biologist

Sue Weis Assistant Forest Botanist

Crystal West North Zone Archaeologist

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114 APPENDIX A: Allotment Maps

Map 1: Project Area

Map 2: Dexter Creek Allotment

Map 3: June Lake Allotment

Map 4: Mono Mills Allotment

Map 5: Mono Sand Flat Allotment

BEDDING GROUNDS SHOWN OUTSIDE ALLOTMENT BOUNDARIES ARE IN ADJACENT ALLOTMENTS NOT COVERED BY THIS ANALYSIS.

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120 APPENDIX B: Amendment #6 Matrices

Matrices from Inyo National Forest Land and Resource Management Plan, Amendment #6, Appendix A

CAREX - DOMINATED (WET) MEADOW Allowable Use (% by weight) Key Species: Carex spp. (sedges)

Desired Plants Tallieda/ Total Herbacious Utilization Levels under Deferred Rotation Grazing System Early Late 68/68+ 50% 40% 51-67/51+ 50% 40% 19-50/19+ 40% 30% 7-34/16-85 30% 20% 0-16/0-45 20% 10% a. Number of vegetation hits tallied out of 100 total using the toe-point method (FSH 2209.21 Range Analysis Handbook).

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DESERT SHRUB Allowable Use (%)b Key Species: Stipa spp. (needlegrass), Oryzopsis Hymenoides (Indian ricegrass), Grayia spinosa (spiny hopsage).

Desired Plants Tallied/ Total Herbacious Utilization Levels under Deferred Rotation Grazing System Early Late 29 – 41/ >38 40% 30% 8-40/ >30 40% 30% <32/ >10 30% 20% <14/ >5 20% 10% <8/ <11 10% 5%c b. Percent use on grasses is by weight. % use on brush is the % of the current year’s growth. Whichever is utilized first limits the amount of time grazing is allowed. c. The 5% allowable use is for incidental use only. The intent is not to have grazing at this level. In the proposed action, 0% is used rather than 5% for clarity’s sake.

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BITTERBRUSH Allowable Use (%) Key Species: Purshia spp. (Bitterbrush), Stipa spp. (needlegrass), Oryzopsis hymenoides (Indian ricegrass), Elymus elymoides (squirreltail).

Desired Plants Tallied/ Total Herbacious Utilization Levels under Deferred Rotation Grazing System Early Late 29-41/ >38 50% 40% <15% Purshia in Form Classes 3 and/or 6d 8-40/ >30 50% 40% <15% Purshia in Form Classes 3 and/or 6 <32/ >10 40% 30% >15% Purshia in Form Classes 3 and/or 6 <14/ >5 30% 20% >15% Purshia in Form Classes 3 and/or 6 <8/ <11 20% 5% >15% Purshia in Form Classes 3 and/or 6 d. FSH 2209.21 (Range Handbook) Form Classes for brush. Class 1 = All bitterbrush available, little or no hedging. Class 2 = All bitterbrush available, moderately hedged. Class 3 = All bitterbrush available, heavily hedged. Class 4 = Bitterbrush largely available, little or no hedging. Class 5 = Bitterbrush largely available, moderately hedged. Class 6 = Bitterbrush largely available, heavily hedged.

122 APPENDIX C: Capability and Suitability

Capability and suitability are defined in the Sierra Nevada Forest Plan Amendment (SNFPA) Appendix K. Capability is the potential of an area of land to produce resources, supply goods and services, and allow resource uses under an assumed set of management practices and at a given level of management intensity. Capability depends on current conditions and site conditions such as climate, slope, landform, soils and geology, as well as the application of management practices, such as silviculture or protection from fire, insects, and disease. Capability for each of the allotments was determined primarily through the use of geographic information systems (GIS) and indicates the potential to support domestic grazing by sheep and cattle. 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 alternative uses foregone. A unit of land may be suitable for a variety of individual or combined management practices.

Capability criteria include:

Areas with less than 30% slopes for cattle and less than 45% slope for sheep. Frequently, the degree of slope cannot be used by itself as a clear-cut guide to capability but must be considered as it interacts with other local factors. Among these are location of water, length of slope, and kind of livestock and their familiarity with the range. Exceptions may be made if, through successfully demonstrated historical use, Forest Plan goals and objectives can be met.

Areas producing more than or having the potential to produce an average of 200 lbs. of forage per acre per year on an air dry basis over the planning period.

Areas accessible to livestock (without such factors as rock or physical barriers).

Suitability criteria include:

Areas with potential social conflicts such as developed recreation sites and special use areas.

Administrative sites and research facilities or study sites.

Areas where livestock grazing is impracticable due to economic considerations, either from an agency or permittee perspective.

Key wildlife habitat areas (threatened, endangered, sensitive and management indicator species).

Areas with soil erosion hazard ratings of high or very high.

123 Areas where ground cover (vegetation, litter, rock greater than 1/4 inch) is insufficient to protect soil from erosion. The minimum percentage cover will be 60% unless local data is available for use in setting more specific ground cover requirements.

Weed infestations where livestock use could impede noxious weed control objectives.

Unique habitats such as bogs, fens, jurisdictional wetlands, or rare plant communities.

Areas where the existing condition or rehabilitation needs preclude grazing for the planning period.

The grazing capacity of the range within an allotment is dependent upon the amount and status of capable and suitable acres located within the allotment boundary. The ability of grazing capacity to support a given stocking rate can be inferred from the number of acres meeting specific capability and suitability criteria described above, standards and guidelines governing forage utilization, and overall condition of the range resource within the allotment. When livestock consumption of forage falls within the productive potential of the range and within imposed limits on forage utilization, stocking rates can be considered appropriate. Capable and suitable potential and capacity is discussed below for each allotment.

Capability is as follows for each allotment:

Dexter Creek

Only 446 of Dexter Creek’s 18,781 acres are not capable for grazing. This acreage is located in North Canyon and is not capable due to steep canyon walls. The total capable acreage is 18,335. Most of the capable acreage on the Dexter Creek Allotment is suitable for grazing. Exceptions are known Heritage sites where grazing may cause damage to artifacts. Assuming that minimum site productivity is achieved on all of these acres (this is likely a conservative estimate), permitted use is within the capacity of the range to support grazing at the current stocking rate. Range condition information, described below, appears to corroborate this observation because the majority of key areas4 received satisfactory ratings. Although instances of overgrazing occurred, they were not common nor do they appear related to range capacity (or lack-thereof). Rather, excessive browsing observed on the allotment appeared to be associated with a key area near a sheep bedding ground where concentrated use occurred. Concentrated use at that location does not reflect average use across the allotment as determined through site visits and monitoring information.

June Lake

4,373 acres of the June Lake Allotment are not capable for grazing due to steep slopes and lack of forage production. Most of this acreage (2,949) is in the Mono Craters, an area with steep

4Key areas on the allotments are chosen because they are representative of the allotment as a whole. Monitoring of key areas allows one to extrapolate the condition of the rest of the allotment and to determine the effects of livestock grazing and its management. By monitoring key areas regularly it is possible to adjust management in order to produce desired conditions.

124 slopes and barren sand. The total capable acreage is 12,155. The Mono Fire swept through the northern most portion of the June Lake Allotment in 2010, burning approximately 1,205 acres and making this area unsuitable for grazing for the next three to five years. The rest of the capable acres are suitable for grazing.

Assuming that minimum site productivity is achieved on all of these acres (this is likely a conservative estimate), permitted use is within the capacity of the range to support grazing at the current stocking rate. Range condition information, described below, appears to corroborate this observation because the majority of key areas received satisfactory ratings. Although an instance of overgrazing occurred, it was not common nor did it appear related to range capacity (or lack- thereof). Rather, excessive browsing observed on the allotment appeared to be associated with a key area near a sheep bedding ground where concentrated use occurred. Concentrated use at that location does not reflect average use across the allotment as determined through site visits and monitoring information.

Mono Mills

779 acres of the Mono Mills Allotment are not capable for grazing. This acreage is mostly on the east side of the Mono Craters where there is steep topography and sand flats. The total capable acreage is 28,484. All of the capable acres in the Mono Mills Allotment are also suitable for grazing.

Assuming that minimum site productivity is achieved on all of these acres (this is likely a conservative estimate), permitted use was within the capacity of the range to support grazing at the previous stocking rate. Range condition information, described below, appears to corroborate this observation because key areas received satisfactory ratings. There is no evidence that either short- or long-term damage was inflicted upon the range resource as a result of former stocking rates.

Mono Sand Flat

126 acres of the Mono Sand Flat Allotment are not capable for grazing due to lack of adequate forage production. The total capable acreage is 8,570.

Assuming that minimum site productivity is achieved on all of these acres, permitted use was within the capacity of the range to support grazing at the previous stocking rate. However, range condition information described below appears to suggest that desirable forage species are in relatively low abundance at key areas. The short supply of key species indicates that the productive potential of the site may have declined.

Summary of allotment suitability

Dexter Creek

Most of the capable acreage on the Dexter Creek Allotment is suitable for grazing. Exceptions are known Heritage sites where grazing may cause damage to artifacts.

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June Lake

The Mono Fire swept through the northern most portion of the June Lake Allotment in 2010, making it temporarily unsuitable for grazing. The rest of the capable acres are suitable for grazing.

Mono Mills

The capable acres of the Mono Mills Allotment are suitable for grazing with the exception of the sand flats.

Mono Sand Flat

The capable acres of the Mono Sand Flat Allotment are suitable for grazing.

126 127 128 129

130 APPENDIX D: Response to Comments

131 Commenter 1: Western Watershed Project

Comment 1: The NEPA implementing regulations specify that NEPA documents must analyze a full range of alternatives. Based on the information and analysis presented in the sections on the Affected Environment (40 C.F.R. § 1502.15) and the Environmental Consequences (40 C.F.R. §1502.16), the NEPA document should present the environmental impacts of the proposed action and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public. The regulations specify that agencies shall:

(a) Rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.

(b) Devote substantial treatment to each alternative considered in detail including the proposed action so that reviewers may evaluate their comparative merits.

(c) Include reasonable alternatives not within the jurisdiction of the lead agency.

(d) Include the alternative of no action.

(e) Identify the agency's preferred alternative or alternatives, if one or more exists, in the draft statement and identify such alternative in the final statement unless another law prohibits the expression of such a preference.

(f) Include appropriate mitigation measures not already included in the proposed action or alternatives.

In addition to reviewing any proposed grazing action, other reasonable alternatives that should be reviewed include: (a) Current Management, to establish baseline conditions for comparison of all other alternatives, and to facilitate review of existing management strategies so that the benefits and drawbacks of any proposed management changes and the proposed “adaptive management” can be clearly understood; (b) No Grazing, i.e. amending the LRMP to permanently close one or more allotments to all further use by domestic livestock; (c) a Sage Grouse Conservation alternative. The sage grouse conservation alternative would protect sage grouse breeding, nesting and brood rearing areas by restricting livestock to areas outside of sage grouse use areas and would ensure that residual vegetation heights are maximized to reduce nest predation; and, (d) Resource Conservation alternative. The Resource Conservation alternative would protect all sensitive wildlife and plant habitat on the allotments to conserve the many sensitive species, other wildlife, cultural, and scenic resources found on these allotments.

The IDT considered two alternatives in detail: the No Action (No Grazing) Alternative and the Proposed Action. The two alternatives are discussed in comparative form in Chapter 2 of the EA. The Current Management, Sage-Grouse, and Resource Conservation Alternatives were also considered but were eliminated from detailed study. The reasoning behind this decision are stated in Chapter 2, part 2.3 of the EA. Effects of current management, Alternative 1, and Alternative 2 are presented in the table in Appendix E.

132 Mitigation measures are included in the description of the Proposed Action.

Comment 2: The National Environmental Policy Act (NEPA) document should present the environmental impacts of the proposed action and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public.

According to Forest Service NEPA regulations (36 CFR 220.7(b)(3)(iv)), the EA may discuss the impacts (direct, indirect, and cumulative) of alternatives in a comparative description or describe the impacts of each alternative separately.

Effects of the two alternatives and current management are compared in the table in Appendix E.

Comment 3: The Forest must determine the capability and suitability of each of the four allotments for continued livestock grazing.

The capability and suitability of these allotments to provide livestock grazing is provided in Appendix C of the EA. Capability was mapped based on a GIS analysis. Use areas mapped for past planning purposes were reviewed and updated by the IDT to determine suitability.

Comment 4: The Proposed Action document provides a summary of actual use measured on the allotments over the last 10 years. However, utilization was only provided for a fraction of those years. It is unclear if allotments/key areas were grazed and not monitored or were not grazed in those years where no data is provided. The table should be modified to correct this deficiency and clarify which years the allotments were used.

Data was gathered by monitoring key areas (20% of an allotment’s key areas are monitored each year if staffing is available) and through various studies that have been conducted over the past decade. Allotments that are vacant or are in non-use are not monitored for utilization. Where there is no percentage given, no data exists for that year. Grazing did occur in those years with no data; however, utilization was not monitored in those years.

The IDT used Amendment #6 data from 2008 and 2010 and not utilization data to complete their analyses. Because of this, the utilization table (Table 2 in the Proposed Action) was eliminated from the EA.

Comment 5: The Proposed Action document contains no explanation as to why the number of sheep to be permitted on June Lake Allotment will increase from 1,300 to 1,500.

The number 1,300 in Table 1 of the Proposed Action document is a typographical error. The number of sheep currently permitted for June Lake Allotment is 1,500.

Comment 6: The NEPA documents should clearly document all site-specific problems related to current and prior livestock grazing, what measures the Forest Service has taken

133 to correct these problems, and what measures will be put in place to ensure that similar problems do not arise again.

Site-specific problems related to livestock grazing and measures to correct these problems are discussed in Chapter 2, which contains the Proposed Action, and in Chapter 3, which describes the Proposed Action in relation to each resource area.

Comment 7: The NEPA documents should include estimates of anticipated time to recovery of all areas that are being rested to comply with LRMP Amendment #6.

Anticipated recovery time is addressed in Section 3.3.2.2, Direct, Indirect, and Cumulative Effects of the Proposed Action. This section states that ―Overgrazed bitterbrush would probably take two to three years to return to desired condition. Unsatisfactory meadow areas, having already been rested for several years, would take several more years, possibly decades, to return to desired condition (Milchunas, 2006).‖

Comment 8: The Proposed Action document includes a list of “Design Criteria for Areas outside of Key Areas by Vegetation Community Type.” The only constraints listed in the table are utilization levels. The Forest already sets utilization standards. So what is the difference here?

The differences between current management and the Proposed Action are delineated in the table in Appendix E.

Comment 9: The Proposed Action document provides a list of possible grazing management actions. However, these management actions are all currently available to the Forest. So what is the difference between the current management and the adaptive management that is being proposed?

The differences between current management and the Proposed Action are delineated in the table in Appendix E.

Comment 10: The NEPA documents should consider the impacts of the proposed adaptive management options. Temporary or permanent removal of livestock from allotments or pastures may be essential for resource protection. However, if this does not involve reduction in stocking rates but simply results in the same number of livestock being moved into an adjacent pasture or allotment then a full review of the potential impacts of this redistribution is required.

Effects of the Proposed Action which included these adaptive management options are discussed in the Rangeland Resources Report for the Mono Basin Grazing Allotments (Barron, 2011a) and in Section 3.3 of the Mono Basin Grazing Allotments EA.

Comment 11: The Forest must explain the specific resource monitoring that will be conducted that will allow the Forest “to use monitoring as a tool to achieve desired conditions.”

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Monitoring protocol is discussed in Section 2.5 of the Mono Basin Grazing Allotments EA.

Comment 12: The NEPA documents should include a clear comparison of current and proposed management approaches and monitoring so that the likely effectiveness of the proposed “adaptive management” can be assessed.

Current and proposed management are discussed in Chapters 2 (Alternatives) and 3 (Environmental Consequences) of the EA. Effects of the different management options are presented in the Table in Appendix E

Comment 13: The Forest should evaluate the impacts and risks posed to the endangered Sierra Nevada bighorn sheep population of continuing to authorize domestic sheep grazing on June Lake and Dexter Creek Allotments, and any reopening of Mono Mills Allotment.

Effects of the Proposed Action on the Sierra Nevada bighorn sheep population is discussed in detail in Biological Assessment for the Mono Basin Grazing Allotment Project (Perloff, 2011a) and summarized in Section 3.5 of the Mono Basin Grazing Allotments EA.

Comment 14: The NEPA documents must fully analyze the direct, indirect and cumulative impacts of each alternative on the Bi-State sage-grouse and its habitat.

Effects of the Proposed Action on the Bi-State sage-grouse population are discussed in the Biological Evaluation for the Mono Basin Grazing Allotment Project (Perloff, 2011b) and summarized in Section 3.5 of the Mono Basin Grazing Allotments EA.

Comment 15: The sage-grouse is the Inyo National Forest MIS species for sagebrush. The environmental reviews should include the capability and suitability determinations that are required for MIS species. The Forest must show how allotment conditions correlate with Bi-State sage-grouse population health.

MIS species and their habitat are discussed in detail in Biological Evaluation for the Mono Basin Grazing Allotment Project (Perloff, 2011a) and the Management Indicator Species Report for the Mono Basin Grazing Allotment Project (Perloff and Sims, 2011) and summarized in Section 3.5 of the Mono Basin Grazing Allotments EA.

Comment 16: The NEPA documents should provide a detailed site-specific analysis of the effects of each alternative on the mountain yellow-legged frog (Rana sierra). The Forest should explain the steps that will be taken to protect this candidate species and its habitat if any of its habitat is opened to livestock use.

Effects of the Proposed Action on the mountain yellow-legged frog are discussed in the Biological Evaluation for Aquatic Species (Sims, 2011) and summarized in Section 3.6 of the Mono Basin Grazing Allotments EA.

135 Comment 17: The NEPA documents must outline the results of surveys that have been conducted and review and analyze the individual and the cumulative impacts of livestock grazing in these allotments on pygmy rabbit and the sagebrush habitat they are dependent on.

Effects of the Proposed Action on the pygmy rabbit and its habitat are discussed in Section 3.5 of the Mono Basin Grazing Allotments EA (EA pages 60-62, 77-78).

Comment 18: The NEPA documents should review and analyze potential impacts of each alternative on mule deer, and should review the progress that the Forest Service has made in reaching the goals laid out in the 1988 Inyo National Forest LRMP.

Effects of the Proposed Action on mule deer are discussed in Section 3.5 of the Mono Basin Grazing Allotments EA (EA pages 59-62, 75-76).

Comment 19: The NEPA documents should include results of recent surveys and monitoring of rare and sensitive wildlife and plant species including those species listed in the table below for the project area.

Species Boechera bodiensis Bodie Hills rock-cress RPR 1B.3 Camissonia boothii ssp. boothii Booth's evening-primrose RPR 2.3 Camissonia boothii ssp. intermedia Booth's hairy evening-primrose RPR 2.3 Tetradymia tetrameres dune horsebrush RPR 2.2 Thelypodium integrifolium ssp. complanatum foxtail thelypodium RPR 2.2 Lupinus pusillus var. intermontanus intermontane lupine RPR 2.3 Psoralidium lanceolatum lance-leaved scurf-pea RPR 2.3 Thelypodium milleflorum many-flowered thelypodium RPR 2.2 Lupinus duranii Mono Lake lupine RPR 1B.2 Astragalus monoensis Mono milk-vetch RPR 1B.2 Astragalus kentrophyta var. ungulatus spiny milk-vetch RPR 2.2 Astragalus pseudiodanthus Tonopah milk-vetch RPR 1B.2 Chaetadelpha wheeleri Wheeler's dune-broom RPR 2.2 Artemia monica Mono brine shrimp Sorex lyelli Mount Lyell shrew Accipiter gentilis northern goshawk Falco mexicanus prairie falcon

The status of rare and sensitive wildlife and plant species are described in the Biological Evaluation for the Mono Basin Grazing Allotment Project (Perloff, 2011a), Management Indicator Species Report for the Mono Basin Grazing Allotment Project (Perloff and Sims, 2011), Biological Evaluation for Aquatic Species (Sims, 2011), and the Biological Evaluation for

136 Sensitive Plant Species (Weis, 2011), and summarized in Sections 3.5, 3.6, and 3.7 of the Mono Basin Grazing Allotments EA. Thelypodium milleflorum and Astragalus kentrophyta var. ungulates are not on the FS sensitive species or watch lists and are therefore not included. Astragalus pseudiodanthus is a watch list plant, but is not known to exist in the project area, so it is not included.

Comment 20: Many of these species (see table for comment 18) occur together in rare habitats such as the Big Sand Flat area where the Sierra Nevada Mountain yellow-legged frog, Mount Lyell shrew, and Mono milk-vetch [occur] in association with the Mono pumice flat community. The Forest should redraw allotment boundaries to permanently end grazing in these areas to protect these resources.

These resources are protected under the Proposed Action as no bedding grounds would be allowed on pumice sand flats. Also, ranchers generally do not graze their sheep on pumice sand flats due to lack of forage.

Comment 21: The NEPA documents should include an inventory and maps of habitat types on these allotments including all meadows, springs, stream and riparian areas, soil types, cryptogamic crusts, rare and unique plant assemblages, timber stands, meadows, and juniper, sagebrush and bunchgrass communities. The NEPA documents should review and analyze potential impacts of each alternative on these habitat types including impacts to water quality.

Each of the specialist reports describe the surveys and inventories that were used in the analysis, Maps of habitat types are not included because the small maps presented with the EA could not show the amount of detail required. The Rangeland Management Report (Barron 2011a), Hydrology and Soils Input specialist report (Lutrick 2011), and Biological Evaluations and Assessments (Perloff 2011a, Perloff 2011b, Perloff and Sims 2011, Sims 2011, Weis 2011a, Weis 2011b) each provide information on habitat types and existing condition related to their respective resource. This information is summarized by resource area in the EA in Chapter 3, Environmental Consequences.

Comment 22: The NEPA documents should provide data (with maps) and analyses of changes in vegetation over time including distribution of noxious and invasive species, fire, any vegetation treatments, and range improvements. Vegetation maps should portray rare and unique plant assemblages, timber stands, meadows, and juniper, sagebrush and bunchgrass communities. The vegetation maps should identify areas where sage understories are dominated by cheatgrass, medusahead, and other weeds, and those areas where natural communities persist. The NEPA documents should review and analyze potential impacts of all alternatives on the spread and distribution of these invasive species.

Vegetation communities are described in Chapter 1 (Purpose and Need) and Chapter 3 (Environmental Consequences) of the EA(EA pages 3-6, 28-29, 83-86). Information on vegetation and noxious weeds is presented in the Biological Evaluation for Sensitive Plant Species (Weis, 2011a), the Noxious Weed Risk Assessment for the Mono Basin Grazing Allotments (Weis, 2011b), and the Rangeland Resources Report for the Mono Basin Grazing

137 Allotments (Barron, 2011a), and is summarized in the Mono Basin Grazing Allotments EA(EA pages 3-6, 28-29, 83-86).

Comment 23: The Forest should conduct a cumulative watershed effects analysis for the watersheds in the project area and should present this data in the NEPA documents. The documents should disclose the percent of equivalent roaded acres in the watershed, the threshold of concern, the natural suitability index, and how the allotment (combined with both past and anticipated future projects on both private and public land) will impact these key indices. The documents should also discuss the measures that will be taken to eliminate or reduce these effects. The documents should describe the condition of the watersheds in terms of CWE, ownership patterns, land disturbance history, sensitive habitat, and other issues. In addition, the documents should disclose when, and how many, surveys have been conducted in these watersheds and whether or not these field surveys suggested upgrading the risk of cumulative watershed effects in the affected watersheds. The documents should consider the cumulative impacts of past, present, and future projects (including those on private land) within these watersheds and discuss ways to minimize or eliminate these impacts.

The cumulative watershed effects analysis is discussed in detail in the Hydrology and Soils Input for the Mono Basin Grazing Allotments EA (Lutrick, 2011) and summarized in Chapter 3 of the Mono Basin Grazing Allotments EA (EA pages 46-48, 51).

Comment 24: The Forest must consider the impacts of the proposed action and each alternative on water quality.

Effects pertaining to water quality are presented in detail in the Hydrology and Soils Input for the Mono Basin Grazing Allotments EA (Lutrick, 2011) and summarized in Chapter 3 of the Mono Basin Grazing Allotments EA.

Comment 25: The NEPA documents should inventory all specially designated areas including Wilderness Study Areas, Wilderness, and special management areas that overlap or are adjacent to the allotments. The analysis should explain how each alternative reviewed in the NEPA documents is compatible with maintaining the characteristics and values of those areas.

The Mono Basin Scenic Area overlaps with parts of the Mono Basin Allotments. The Proposed Action is consistent with the legislative direction in the Mono Basin National Forest Scenic Area Comprehensive Management Plan, which states, ―Persons currently holding valid grazing permits will continue to be able to exercise those permits consistent with other applicable law‖ (USDA Forest Service, 1989a).

There are no wilderness areas in or adjacent to the Mono Basin Allotments.

138 Comment 26: The NEPA documents should include an inventory of cultural and historic resources on these allotments. The NEPA documents should review and analyze all potential impacts on these fragile and irrecoverable resources for each alternative.

Information on cultural resources are described in detail in the Cultural Resource Report for the Mono Basin Grazing Analysis (West, 2011, Report R2008050401307) and summarized in Chapter 3 of the EA (EA pages 89-95).

Comment 27: According to the Region 5 website,

The Forest Service strategy for dealing with climate change is based on 20 years of targeted research and a century of science and management experience. The Forest Service strategy includes helping forests adapt to changes in climate by restoring the resilience of forest, range and aquatic ecosystems; managing forests to increase the carbon dioxide they capture and store; using forest products to reduce and replace fossil fuel energy; maintaining a research program, and reducing the agency's environmental footprint.

The NEPA document should explain how each alternative meets this strategy.

In addition, Regulation 36 C.F.R. § 219.20 defines capability as:

The potential of an area of land to produce resources, supply goods and services, and allow resource uses under an assumed set of management practices and at a given level of management intensity. Capability depends upon current conditions and site conditions such as climate, slope, landform, soils, and geology, as well as the application of management practices, such as silviculture or protection from fire, insects, and disease.

Since capability depends upon conditions such as climate, the NEPA documents should consider the impacts of ongoing global climate in making the capability determinations.

Climate change is discussed in the Rangeland Resources Report for the Mono Basin Grazing Allotments (Barron 2011a), Hydrology and Soils Input for the Mono Basin Grazing Allotments EA (Lutrick 2011), and Biological Evaluation: Sensitive Plant Species (Weis, 2011a). These discussions are also in Chapter 3 of the EA (EA pages 30, 36, 46-47, 50, 87).

It is predicted for the region containing the project area that the climate will become warmer, precipitation will remain about the same, but more of that precipitation will occur as rain instead of snow and there will be more extreme weather events such as drought and floods (Furniss et al, 2010). However, it is not possible to depend on the accuracy of predictions about the extent of climactic change over the next ten years, which is the length of the permit.

139 Comment 28: The NEPA documents must fully review the cumulative impacts of livestock, wild horses, mining and mining exploration, global climate change, off road vehicle use, energy developments (including geothermal), transmission projects, and other developments such as the Mammoth Airport on the four allotments’ wildlife, sensitive plant species, habitats for wildlife and sensitive plants, and cultural resources.

Cumulative effects on resources are summarized in Chapter 3 of the Mono Basin Grazing Allotments EA (EA pages 29-31, 35-37, 45-47, 49-50, 60-61, 64-65, 68-71, 72-76, 82, 83-87, 92-94, 95-97)., and discussed in detail in the Rangeland Resources Report for the Mono Basin Grazing Allotments (Barron 2011a), Hydrology and Soils Input for the Mono Basin Grazing Allotments EA (Lutrick 2011), and Biological Evaluations and Assessments (Perloff 2011a, Perloff 2011b, Perloff and Sims 2011, Sims 2011, Weis 2011a, Weis 2011b).

Currently, there are no wild horses, mining and mining exploration, energy developments, transmission projects, or other developments such as the Mammoth Airport on the Mono Basin Allotments.

Comment 29: The NEPA documents should consider the impacts of the proposed adaptive management options. Temporary or permanent removal of livestock from allotments or pastures may be essential for resource protection. However, if this does not involve reduction in stocking rates but simply results in the same number of livestock being moved into an adjacent pasture or allotment then a full review of the potential impacts of this redistribution is required.

The EA (p. 33) states:

Working closely with the permittees and checking utilization regularly during the grazing season would allow for annual operating plans that would result in a more even distribution of livestock and grazing across an allotment. Promoting more even use means that previously ungrazed plants would have more of a chance of being grazed (which would stimulate growth) and that individually, frequently grazed plants would be grazed fewer times. With more even distribution, range condition can improve with little or no reduction in livestock numbers (Anderson, 1967; Holechek et al, 2004).

Improved distribution of livestock would also lead to an increase in overall plant vigor because overgrazing would be less likely to occur. Ending over-utilization of forage and browse would allow for the maintenance and/or increase of desirable vegetation (Dietz 2006). Increase in vegetation allows for more ground cover, reduced erosion, retention of soil water, and encourages new growth.

Comment 30: The Forest must explain the specific resource monitoring that will be conducted that will allow the Forest “to use monitoring as a tool to achieve desired conditions”. The Forest cannot simply describe an ad hoc management system that does not require extensive resource monitoring and call it “Adaptive Management”.

140 The IDT established a monitoring plan (EA pgs. 23-34) to evaluate if the design criteria are being implemented as planned (implementation monitoring) and in the longer term, if management is meeting or moving toward the established desired condition objectives (effectiveness monitoring). The monitoring plan includes measuring vegetation and watershed condition through established protocols. The data collected from these established protocols was used to describe the existing condition, and was the basis for developing the design criteria and adaptive options by comparing the difference between the desired condition and the existing condition. The monitoring plan was reviewed by the IDT, and it was determined that the monitoring prescribed will provide the information needed to determine if adaptive management changes should be made and to guide the direction that those changes take. Implementation will be an interdisciplinary effort, and ongoing evaluations and adaptive changes (if needed) will occur as part of permit administration.

Comment 31: The NEPA documents should include a clear comparison of current and proposed management approaches and monitoring so that the likely effectiveness of the proposed “adaptive management” can be assessed. Adaptive management requires explicit designs that specify problem-framing and problem-solving processes, documentation and monitoring protocols, roles, relationships, and responsibilities, and assessment and evaluation processes (Stankey et al., 2005).

The proposed action outlines an adaptive management strategy that builds in the flexibility to respond to changed conditions or management actions (design criteria) that are not effectively meeting or moving toward the desired objectives. Through an interdisciplinary process, the IDT identified desired conditions, design criteria, and adaptive options that would be available to make adjustments in management if monitoring indicated that adaptive changes are needed. This adaptive management strategy follows direction outlined in FSH 2209.13, 92.23b and A Practical Approach to Adaptive Management, With a Specific Focus on Livestock Management NEPA Based Decisions guidance document (Quimby 2001).

Commenter 2: Mono Lake Committee

Comment 32: The only allotment that is at desired condition is Mono Mills. Dexter Creek and June Lake Allotments have sections that have not met the desired condition. The entire Mono Sand Flat Allotment is not at desired condition. The Proposed Action states that certain areas will be rested until they reach the desired condition, and then grazing will be allowed again. This language suggests a potential pattern of use, degradation, and recovery that may be repeated through time. MLC recommends that the Inyo develop a more sustainable approach to grazing management, one where the desired condition can be achieved and maintained over the long term, and where appropriate levels of grazing can be sustained over time without degradation to watershed resources and habitat.

The Proposed Action calls for more even distribution of livestock with set utilization limits. There are also management options that would be enacted if necessary in order to ensure that areas in desired condition maintain or improve upon that condition. This is intended to ensure long-term stability of range condition. The Proposed Action and its effects are discussed further

141 in Chapter 2 (Alternatives) and Chapter 3 (Environmental Consequences) of the Mono Basin Grazing Allotments EA.

Comment 33: In general, riparian and wet meadow areas should be restricted to grazing use which the proposed action mostly demonstrates. However, within the Dexter Creek Allotment area the Inyo should consider requiring water tanks for all livestock watering as is done within other allotments.

In the Dexter Creek Allotment, areas with surface water accessed by sheep were found to be in desired condition with a stable trend. There is no downward trend related to grazing; therefore, current management is appropriate for these areas. Description of conditions in riparian areas can be found in the Hydrology and Soils Input for the Mono Basin Grazing Allotments EA (Lutrick 2011) and are summarized in the EA, Section 3.4.

Comment 34: Given the current existing condition, the Inyo should be able to demonstrate that the lands within the Mono Sand Flat Allotment are capable of being managed for grazing and achieving desired condition over the long term.

Under the Proposed Action, the Mono Sand Flat Allotment will be rested and will not be grazed until such time that full recovery (return to desired condition) is documented. When and if this allotment returns to desired condition, reintroduction will be a gradual process (using a shortened grazing season) in order to gauge landscape response to grazing.

Comment 35: MLC requests greater detail on how management constraints will be communicated and enforced.

Permittees operate on the allotments according to the terms and conditions of their term grazing permits which will contain the mitigations set in place by the EA. Specific instructions for management are relayed yearly in each allotment’s Annual Operating Instructions (AOIs). Range personnel make compliance checks throughout the grazing season. Permittees who do not comply with the terms and conditions of their permits may lose their grazing privileges if a pattern of noncompliance emerges (FSH 2231.62c).

Commenter 3: Center for Biological Diversity

Comment 36: The Proposed Action employs Chapter 90, a new rule governing livestock grazing that itself has not undergone NEPA review or Endangered Species Act (ESA) consultation with the U.S. Fish and Wildlife Service. The Center has observed that applications of Chapter 90 and its reliance on monitoring and adaptive management evades the Forest Service’s obligation under the NEPA and ESA to take a “hard look” at reasonably foreseeable levels of authorized livestock grazing and ensure that proposed actions will not jeopardize the continued existence of threatened or endangered species.

Reasonably foreseeable levels of authorized livestock grazing and its potential effects on threatened and endangered species is addressed in Chapter 3 of the EA.

142 Rules such as Chapter 90 of the Grazing Permit Administration Handbook (FSH 2209.13 90) are determined at a higher level of decision making and are not subject to analysis in this EA.

Commenter 4: California Regional Water Quality Control Board, Lahontan Region

Comment 37: The PA should be supplemented to acknowledge the water quality standards contained in the Basin Plan, to evaluate the potential for the proposed action to violate those standards, and to specify management measures for controlling nonpoint source pollution that are adequate to ensure protection of waters of the State and compliance with the Basin Plan.

These issues are discussed in Section 3.4 of the EA (EA pages40-41) and in the report Hydrology and Soils Input for the Mono Basin Grazing Allotments EA (Lutrick 2011).

Comment 38: The Existing Conditions section describes the rotation patterns used on the allotments but does not adequately describe the existing soils, hydrology, and vegetation conditions.

The EA has additional information that was not present in the Proposed Action. Soils and hydrology are discussed in Section 3.4 of the EA and in the report Hydrology and Soils Input for the Mono Basin Grazing Allotments EA (Lutrick, 2011). Vegetation conditions are discussed in Sections 3.3 and 3.7 and in the reports Rangeland Resources Report for the Mono Basin Grazing Allotments (Barron 2011a), Biological Evaluation for Sensitive Plant Species (Weis, 2011a), and Noxious Weed Risk Assessment for the Mono Basin Grazing Allotments (Weis, 2011b).

Comment 39: Please clearly differentiate between the current management strategies and conditions and the proposed action.

Current and proposed management are discussed in Chapter 2 Alternatives and Chapter 3 Environmental Consequence. Effects of Alternatives and current management are summarized and compared in the table in Appendix E.

Comment 40: How are sheep prevented from grazing stream banks and riparian areas? How are sheep prevented from grazing Wild Horse Meadow?

On allotments grazed by sheep, livestock movement would be controlled by herding. The permittees run gregarious breeds of sheep (white-faced and Rambouillet), which rarely stray from the herd. Also, a herder would stay with the sheep throughout their time on the allotment. In this way, herders would be able to strictly adhere to the Annual Operating Instructions so that utilization standards would not be exceeded.

Range personnel make compliance checks throughout the grazing season.

143 Comment 41: Table 2 (Table 11 in the EA) key areas do not correspond to key areas shown on figures. The Figures show fewer key areas than Table 2. The key areas should be numbered on figures to correspond to numbering in Table 2.

The table shows both key areas and other locations such as points used in studies which are not key areas. The interdisciplinary team relied on all available data to determine existing conditions.

The IDT used Amendment #6 data from 2008 and 2010 and not utilization data to complete their analyses. Because of this, the utilization table (Table 2 in the Proposed Action) was eliminated from the EA.

Comment 42: Regarding Table 2 (Table 11 in the EA): Please supply annual data or describe why annual monitoring data is not available.

Twenty percent of key areas are monitored annually, and because of that, each allotment does not get checked every year. Twenty percent is an ideal number, and can be met only when there is sufficient staffing to do the monitoring. Where there is no percentage given, no data exists for that year. Allotments that are vacant or are in non-use are not monitored for utilization.

Comment 43: Please describe the terms “PFC” and “good” as they are used in the document (Table 4 in the EA).

The word ―good‖ is equivalent to ―fully functional.‖ To avoid confusion, the word ―good‖ in the EA has been changed to ―fully functional.‖

PFC is defined in: Riparian Area Management: A User Guide to Assessing Proper Functioning Condition and the Supporting Sciences for Lotic Areas, which states: ―Proper functioning condition (PFC) is a qualitative method for assessing the condition of riparian-wetland areas. The term PFC is used to describe both the assessment process, and a defined, on the-ground condition of a riparian-wetland area.

Comment 44: Describe the difference between Desired Condition and PFC.

Desired conditions are the on-the-ground resource conditions that management is working toward within a defined timeframe. These are the expected results if management goals are fully achieved. They bring broad-scale desired conditions from the Forest Plan down to project level.

PFC is defined in: Riparian Area Management: A User Guide to Assessing Proper Functioning Condition and the Supporting Sciences for Lotic Areas, which states: ―Proper functioning condition (PFC) is a qualitative method for assessing the condition of riparian-wetland areas. The term PFC is used to describe both the assessment process, and a defined, on the-ground condition of a riparian-wetland area.

144 Comment 45: Some of the design criteria for wet meadow areas are not set to comply with the Desired Future Condition nor set to achieve a fully functional condition of the watershed. For example, the Wet Meadow Design Criteria states, “bare ground would not exceed 10%.” The Desired Future Condition stated in Table 3 (Table 2 in the EA) is “bare ground less than 5%.” A 10% level of bare ground would indicated a condition between “degraded at 10-15%” and “at-risk at 5-10%” according to Forest Plan Amendment 6. The Design Criteria should be set to achieve fully functional watershed conditions and the Desired Future Conditions in Table 3.

The Wet Meadow Design Criteria statement, ―bare ground would not exceed 10%,‖ in the PA has been changed to ―bare ground would not exceed 5% in the EA.

Comment 46: Please provide a monitoring plan based on scientific principles that details, at a minimum; parameters to be monitored, frequency of monitoring, locations monitored, and methods used.

Monitoring recommendations are discussed in Section 2.5 of the EA.

Comment 47: How will livestock be prevented from grazing the numerous key areas with 0% utilization standards?

The Allotment Management Plan given to the permittee would contain the allowable use standards as set forth by the EA. The Annual Operating Instructions also inform the permittee which parts of the allotment require rest. The permittees would communicate this information to their herders.

On allotments grazed by sheep, livestock movement would be controlled by herding. The permittees run gregarious breeds of sheep (white-faced and Rambouillet), which rarely stray from the herd. Also, a herder would stay with the sheep throughout their time on the allotment. In this way, herders would be able to strictly adhere to the Annual Operating Instructions so that utilization standards would not be exceeded. The cattle allotment, Mono Sand Flat, will be rested.

Range personnel make compliance checks throughout the season.

Comment 48: How long will this management action (reducing utilization) be continued until additional management actions are employed?

Areas with heavily hedged bitterbrush should recover in two to three years with complete rest. This is because the degree of hedging is based on the condition of two-year-old wood (BLM, 1996). With no grazing, no hedging would be apparent after two years have passed.

For the Mono Sand Flat Allotment and unsatisfactory meadows, recovery would be a slow process and may take decades (Milchunas, 2006). If recovery does not take place within the ten- year time span this NEPA analysis covers, the Forest may, at that time, decide to continue resting the allotment or take other management actions.

145

Comment 49: Please describe the column heading “% in Form Classes 3 or 6” used in Table 11.

Form class refers to the degree of hedging of bitterbrush. Classes are described with the bitterbrush matrix in Appendix A.

Comment 50: Who is responsible for the monitoring of sheep that enter the undisturbed portion of Baxter Springs, and how is the monitoring reported?

Range personnel make checks on the allotments throughout the grazing season. During these visits, notes are taken and later placed in the allotment file (2210 file). Range personnel advise the permittees of the results of these checks.

Comment 51: The Mono Mills figure shows multiple bedding areas south of the allotment boundary. This figure should be corrected or an explanation provided as to why livestock are bedding outside the allotment boundary.

The bedding grounds referenced here are in another allotment that is adjacent to the Mono Mills Allotment (the Sherwin/Deadman Allotment).

Comment 52: The PA does not adequately describe the adaptive management approach.

The proposed action outlines an adaptive management strategy that builds in the flexibility to respond to changed conditions or management actions (design criteria) that are not effectively meeting or moving toward the desired objectives. Through an interdisciplinary process, the IDT identified desired conditions, design criteria, and adaptive options that would be available to make adjustments in management if monitoring indicated that adaptive changes are needed. This adaptive management strategy follows direction outlined in FSH 2209.13, 92.23b and A Practical Approach to Adaptive Management, With a Specific Focus on Livestock Management NEPA Based Decisions guidance document (Quimby 2001).

The IDT established a monitoring plan (EA pages 23-25) to evaluate if the design criteria are being implemented as planned (implementation monitoring) and in the longer term, if management is meeting or moving toward the established desired condition objectives (effectiveness monitoring). The monitoring plan includes measuring vegetation and watershed condition through established protocols. The data collected from these established protocols was used to describe the existing condition, and was the basis for developing the design criteria and adaptive options by comparing the difference between the desired condition and the existing condition. The monitoring plan was reviewed by the IDT, and it was determined that the monitoring prescribed will provide the information needed to determine if adaptive management changes should be made and to guide the direction that those changes take. Implementation will be an interdisciplinary effort, and ongoing evaluations and adaptive changes (if needed) will occur as part of permit administration.

146 References

Milchunas, Daniel G. 2006. Responses of plant communities to grazing in the southwestern United States. Gen. Tech. Rep. RMRS-GTR-169. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 126 p.

Quimby, Chuck. 2001. A Practical Approach to Adaptive Management, With a Specific Focus on Livestock Management NEPA Based Decision. USDA Forest Service, Rocky Mountain Region

USDA Forest Service. 1989a. Mono Basin National Forest Scenic Area Comprehensive Management Plan. Inyo National Forest, Bishop, California.

USDA Forest Service. 2005. 2209.13 Grazing Permit Administration Handbook, Chapter 90 Rangeland Management Decision Making.

USDI Bureau of Land Management. 1993. Riparian Area Management: Process for Assessing Proper Functioning Condition. Technical Report. TR 1737-9 1993.

USDI Bureau of Land Management. 1996. Utilization Studies and Residual Measurements, BLM/RS/ST-96/004+1730.

USDI Bureau of Land Management. 1998. A user guide to assessing proper functioning condition and the supporting science for lotic areas. TR 1737-15.

147 APPENDIX E: Comparison of Alternatives

148 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action Effects to Rangeland Improved health and vigor in Possible static or downward Improved health and vigor in Resources vegetation. Upward trend in trend at areas not currently in vegetation. Upward trend in unsatisfactory areas, upward desired condition. unsatisfactory areas, upward or or static trend in areas at static trend in areas at desired desired condition. condition.

Dexter Creek: Upward trend Upward trend at Wild Horse and Dexter Creek: Upward trend at at Key Area 5, Johnny Crooked Meadows. Possible Key Area 5, Johnny Meadow, Meadow, Wild Horse static or downward trend at Wild Horse Meadow, and Meadow, and Crooked Johnny Meadow and Key Area Crooked Meadows. Upward or Meadows. Upward or static 5. static trend in Key Areas 6, 7a, trend in Key Areas 6, 7a, and and Exc. Exc.

June Lake: Upward trend at Possible static or downward June Lake: Key Area 1 would be Key Area 1. Upward or static trend at Key Area 1. rested, resulting in an upward trend at Key Areas 2 and 3. trend. Upward or static trend at Key Areas 2 and 3.

Mono Mills: Upward or static Upward or static trend at all Key Mono Mills: Upward or static trend at all Key Areas. Areas. trend at all Key Areas. New water source would be provided.

Mono Sand Flat: Slow Allotment would not be rested; Mono Sand Flat: Allotment upward trend at both Key the pace of recovery would slow would continue to be rested for Areas. down. resource protection resulting in a slow upward trend.

149 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action Effects to Hydrological No measurable effect to air No measurable effect to air No measurable effect to air Resources quality, and minor, very local quality, and minor, very local quality, and minor, very local positive effects to water negative effects to water quality, positive effects to water quality, quality, and soil and and soil and hydrologic function. and soil and hydrologic function hydrologic function. relative to current condition, but more negative than the NoAction alternative

Very minor, local, and very Very minor, local increases in Very minor, local increases in short duration effects of dust during and directly after dust during and directly after reduced dust input into the air. livestock passage livestock passage No positive or negative effect to air quality

Slight improvement in Minor soil surface disturbance Minor soil surface disturbance hydrologic and soil function and slightly increased potential and slightly increased potential over time. Bedding grounds for erosion due to loosening of for erosion due to loosening of would slowly decompact and the soil. Soil in bedding grounds the soil. Soil in bedding grounds vegetate to reduce any erosion would remain compacted and would remain compacted and potential. sheep would continue to remove sheep would continue to remove vegetation from these areas. vegetation from these areas. However, there will be fewer bedding grounds and soil would decompact and vegetation return to areas where bedding grounds have been eliminated.

150 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action Results of ERA analysis: See Results of ERA analysis: See Results of ERA analysis: See Table 13. Table 13 of EA. Table 13.

No effect to water quantity. No long-term measureable effect No long-term measureable effect to water quality relative to to water quality relative to current current condition, but a condition, but a reduction in flow reduction in flow on the few on the few days at the few sites days at the few sites where water where water is pumped or where is pumped or where sheep drink sheep drink directly from streams directly from streams relative to relative to the No Action the No Action Alternative Alternative

No known or suspected No known or suspected impacts No known or suspected impacts impacts to beneficial uses at to beneficial uses at the four high to beneficial uses on the Dexter the four high use sites, only use sites on the Dexter Creek Creek Allotment, only likely a likely a slight decrease over a Allotment, only likely a slight slight increase in nutrients and few days per year. increase in nutrients and bacteria bacteria on the few days per year on the few days per year that the that the sheep are at the water sheep are at the water sites, and sites, and in the days immediately in the days immediately following that access following that access.

Slightly greater minor, local Improved meadow, water quality, negative impacts than the No and streambank condition relative Action alternative .These minor to the current condition, but impacts would still allow RCOs would have slightly greater to be met at all locations, and minor, local negative impacts

151 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action would protect beneficial uses to than the No Action alternative. meet state and federal water These minor impacts would still quality standards. allow RCOs to be met at all locations, and would protect beneficial uses to meet state and federal water quality standards.

Hydrologic and soil function Hydrologic and soil function Hydrologic and soil function would be slightly improved would be slightly improved would be slightly improved throughout the allotments throughout the allotments over throughout the allotments over over time. time, except at four high use time. areas near water. Very local and minor improvements in water quality relative to the current condition. Changes would only occur on the Dexter Creek Allotment. There would be no change relative to the current condition on the Mono Sand Flat, June Lake, or Mono Mills Allotments, because livestock currently do not access any surface water on these allotments. There would still be no access to water in these three allotments.

152 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action Effects to Terrestrial No direct, indirect or No domestic sheep grazing is No domestic sheep grazing is Wildlife Species cumulative effects to Sierra expected to occur in the area expected to occur in the area with Nevada bighorn sheep. with IWD values between 0.833 IWD values between 0.833 and and 1.0. 1.0.

Will not affect Sierra Nevada Will not affect Sierra Nevada Will not affect Sierra Nevada bighorn sheep or adversely bighorn sheep or adversely bighorn sheep or adversely modify designated critical modify designated critical modify designated critical habitat habitat for this species. habitat for this species. for this species.

There would be no direct May impact individual sage- May impact individual sage- impact to sage-grouse grouse, but would not result in a grouse, but would not result in a individuals or their habitat. trend towards federal listing or trend towards federal listing or Cessation of grazing would loss of viability within the loss of viability within the project have the indirect effect of project area. area. allowing for passive restoration within bedding grounds. Over time, sagebrush plants would become re-established and allowed to grow freely in the absence of livestock trampling. The speed at which recovery occurs would be predicated on the availability of either a suitable seed source or existing seedbed. It is estimated that

153 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action sagebrush would occupy the sites within 10-15 years. The spatial coverage of sagebrush habitat would increase by slightly more than 15 acres.

No direct, indirect or May impact individual northern May impact individual northern cumulative impacts on goshawks, but would not result goshawks, but would not result in northern goshawks or their in a trend towards federal listing a trend towards federal listing or habitat. or loss of viability within the loss of viability within the project project area. area.

All bedding grounds would be Bedding grounds, watering sites, No bedding grounds, watering eliminated. and trails are not restricted from sites, or trails would be located in northern goshawk protected northern goshawk protected activity centers. activity centers.

Elimination of bedding Bedding ground would remain in Elimination of bedding ground in ground in Township 1S, Township 1S, Range 29E, Township 1S, Range 29E, Section Range 29E, Section 7 would Section 7. 7 would lead to rapid response of lead to rapid response of understory vegetation. understory vegetation.

Yellow warbler habitat—no Would not alter the existing Would not alter the existing trend direct impact on riparian trend in the habitat, nor lead to a in the habitat, nor lead to a

154 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action habitat. At two sites aspen change in the distribution of change in the distribution of recruitment and understory yellow warblers across the Sierra yellow warblers across the Sierra shrub, grass, and forb cover is Nevada bioregion. Nevada bioregion. reduced relative to un-grazed riparian habitat. Under the No Action Alternative, grazing would cease at these two sites and understory vegetation would likely respond rapidly.

No effect on the ability of No effect on the ability of mule No effect on the ability of mule mule deer to pass through the deer to pass through the deer to pass through the allotments. allotments. allotments.

No direct, indirect or cumulative impacts on mule deer or their habitat.

No direct impact to pygmy Unlikely to have any impact on Unlikely to have any impact on rabbit individuals or their the ability of pygmy rabbits to the ability of pygmy rabbits to habitat. Cessation of grazing move through suitable habitat. move through suitable habitat. would have the indirect effect of allowing for passive restoration within bedding grounds.

155 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action Effects to Threatened, No TES Aquatic species No TES Aquatic species occur No TES Aquatic species occur on Endangered or Sensitive occur on the four allotments, on the four allotments, except in the four allotments, except in a Aquatic Species except in a non-grazed a non-grazed meadow, therefore non-grazed meadow, therefore meadow, therefore there will there will be no impacts. there will be no impacts. be no impacts. Effects to Aquatic Will not alter the existing Will not alter the existing trend Will not alter the existing trend in Wildlife Species trend in the habitat or aquatic in the habitat or aquatic the habitat or aquatic Management Indicator macroinvertebrates across the macroinvertebrates across the macroinvertebrates across the Species (MIS) Sierra Nevada bioregion. Sierra Nevada bioregion. Sierra Nevada bioregion.

Effects to Management Will result in no change in the Will result in no change in the Will result in no change in the Indicator Species (MIS) amount of available wet amount of available wet meadow amount of available wet meadow meadow habitat for the habitat for the Pacific chorus habitat for the Pacific chorus frog. Pacific chorus frog. frog.

Effects to Plants The rehabilitation effects of Because there is no restriction of Will enhance the pumice sand flat both the aspen enhancement camping on the sand flats, and aspen communities in project and the sensitive plant populations are particular and vegetation in implementation of Travel more at risk of negative impacts general Management direction will than under Proposed Action. most likely be somewhat faster.

There would be no negative May impact individuals but will May impact individuals but will direct, indirect, or cumulative not lead to a trend to federal not lead to a trend to federal effects to TESP plant species. listing for Mono milk-vetch, listing for Mono milk-vetch, Mono Lake lupine, Bodie Hills Mono Lake lupine, Bodie Hills

156 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action rockcress, slender moonwort, rockcress, slender moonwort, scalloped moonwort, common scalloped moonwort, common moonwort, Mingan moonwort, moonwort, Mingan moonwort, upswept moonwort, Williams’ upswept moonwort, Williams’ combleaf or Inyo phacelia. combleaf or Inyo phacelia.

There would be no negative Watch List Plants and Other Watch List Plants and Other Rare direct, indirect, or cumulative Rare Species: Species: effects to watch list plants or Based on grazing standards and Based on grazing standards and other rare species. design criteria, the condition of design criteria, the condition of the habitat will be maintained or the habitat will be maintained or improved, and although improved, and although individual plants may be affected individual plants may be affected by grazing, no downward by grazing, no downward population trends are expected. population trends are expected.

Weeds: Weeds: Weeds: Reduced risk of weed spread The overall risk of habitat The overall risk of habitat and new weed introduction alteration from this management alteration from this project since there will be fewer contributing to weed contributing to weed vulnerability vectors. vulnerability is low. is low.

157 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action Effects to Heritage No direct or indirect effects Current management would have Will have no adverse effects to Resources are anticipated. This a potential to adversely affect cultural resources. Alternative would have no heritage resources because effect. protection measures and site With resource protections condition monitoring would not measures and monitoring in be implemented. place, the proposed action should have no cumulative effects on the contributing elements of the cultural resources within the grazing allotments. Economic Effects Would not provide grazing Would provide grazing tenure to Would provide grazing tenure to tenure to lend stability to the lend stability to the local lend stability to the local local livestock-raising livestock-raising community and livestock-raising community and community and established established ranching operations. established ranching operations. ranching operations.

No AUMs would be The sheep permittees would be The sheep permittees would be authorized. provided with 1,529 AUMs each provided with 4,567 AUMs each season. The Mono Sand Flat season due to the resumption of permittee would have 206 grazing on the Mono Mills AUMs. Allotment. The Mono Sand Flat Allotment provides 206 AUMs to the permittee; however, these AUMs would not be available while the allotment is being rested.

158 Comparison of Alternatives Item to Compare Alternative 1: Current Management Alternative 2: No Action (No Grazing) Proposed Action Enhanced ecosystem conditions may mean increased nutritive value of forage which could result in higher weigh gains on livestock, producing lambs with a higher market value.

159