Casey McQuiston, Resources Staff Officer Shoshone National Forest 808 Meadowland Ave. Cody, Wyoming 82424 August 2, 2017 Purpose: BRG’s Official Comments For the Record to the Supplemental Draft EIS (Use of Domestic Sheep, Goats, and Pack Goats) Dear Mr. McQuiston, The Bighorn Restoration Group’s (BRG) mission is to advance the conservation and restoration of bighorn sheep throughout the southern Wind River Mountains. BRG therefore would like to offer the following official comments for the record to the Supplemental Draft EIS (Use of Domestic Sheep, Goats, and Pack Goats). If, as stated in the July 28th public meeting, the SNF chooses to extend the deadline for comments past the current August 10th deadline to define other possible alternatives to the Supplemental Draft Environmental Impact Statement (SDEIS), BRG may also submit additional comments at that time. July 28th, 2017 Public Meeting Outcomes BRG especially appreciates the Washakie Ranger District (WRD) of the Shoshone National Forest (SNF) hosting the public meeting on July 28th, 2017—complete with hired mediator—to aid the U.S. Forest Service and other interested parties in better understanding the complex concerns involved in this issue from the point of view of all interested parties in attendance. BRG was very pleased with the win/win dynamics and cooperative, collaborative, and accommodating tone of the meeting. We also appreciated and concur with the willingness of all parties involved to pursue and promote a final decision that seeks to formulate an agreeable ruling, which integrates and maximizes all stakeholder concerns and interests. This meeting was very informative, useful, and enlightening with the following notable findings: The disease transfer science between domestic animals and wild bighorn sheep is complicated and imperfect. All diverse interested parties in attendance were able to describe their motivations and needs. The current SDEIS, as is currently written, is constrictive with a win/lose or even a lose/lose dynamic. The interested parties attending the meeting are willing and committed to jointly move forward to create a new alternative, which assimilates the various 1 of 8 central needs of all involved in the spirit of the win/win dynamics promoted in the meeting. BRG’s Current Concerns The SDEIS as now written—especially the preferred alternative (Alternative 2)—is not a win/win for all parties, nor does it meet the goal of the SDEIS of reducing the risk of transfer of disease between domestic livestock and wild bighorn sheep. In fact, the SDEIS’ preferred alternative is a BIG LOSE for the Temple Peak Bighorn Sheep Herd (TPBSH), offering absolutely no concessions or protections for this bighorn sheep herd from the possible transfer of diseases from domestic livestock in direct contradiction to the stated goal of the SDEIS and the win/win dynamics advanced at the July 28th public meeting. BRG has been exceedingly troubled with the SNF’s noticeable callous indifference, apparent neglect of, and conspicuous dismissal of the importance of the TPBSH as presented in the SDEIS. U. S. Forest Service and SNF policy lists bighorn sheep as a “sensitive species” on the Forest. Our organization strongly believes that the more than 120 individuals in the TPBSH herd (not counting lambs born this spring) should be treated as such. BRG desires and expects that the WRD and the SNF will adopt the win/win tone of the July 28th 2017 meeting to correct their inexplicable and perplexing insensitive treatment of the TPBSH in the SNF’s final decision on this issue. The TPBSH herd has in the past, and continues to be, a celebrated and important aesthetic, economic, and recreational resource to the Lander area. BRG admonishes the SNF to discontinue their callas disregard and inattention of this herd and desires that the SNF will resolve to aid this important bighorn sheep herd. The U.S. Forest Service’s sensitive species manual and other U.S. Forest Service policies make no distinction between “native” and “reintroduced” populations of bighorn sheep—all bighorn sheep are required to be aided and protected. Many other National Forests are aiding bighorn sheep herds with reintroductions, habitat enhancements, and other supporting projects on behalf of wild bighorn sheep herds. The WRD and the SNF has a duty to adopt a similar stance. As pointed out in the SDEIS the Temple Peak Bighorn Sheep Herd has, during the past two or three years, shown a striking population growth, thus increasing its aesthetic, economic, and recreational potential and importance. The recent increase in the herd’s numbers has further enhanced and amplified the herd’s value to the Lander and Fremont County area. This trend can and likely will continue, if the WRD and the SNF do their part in aiding this herd to thrive in the spirit of the win/win dynamics promoted at the July 28th meeting. This bighorn sheep herd deserves the SNF’s and the WRD’s continued proactive involvement, support, and protection. The current blatant indifference and dismissal of the TPBSH as presented in the SDEIS is unacceptable and inconsistent with the goals of the U.S. Forest Service, SNF policy, and even the SDEIS goal of minimizing the disease transfer risk from domestic sheep and goats to bighorn sheep on the SNF. 2 of 8 BRG believes there are several statements made throughout the SDEIS that are likely erroneous and/or in need of being updated or corrected prior to the final EIS being published. They include: 1) On page 8 of the SDEIS is the following statement: “Five of the six core native (bighorn) herds are connected to one another (Whisky Mountain being the exception), and together form the Absaroka metapopulation.” On page 12 the SDEIS also states that: “The Whisky Mountain herd is isolated from the other herds on the Shoshone Nation Forest.” In fact, Whisky Mountain Bighorns regularly cross Highway 287/26 both near Jakey’s Fork, near Red Rocks, and likely at several other locations. Individuals crossing the highway find themselves in the habitat of the so named “Dubois Badlands Bighorn Herd. ” The Dubois Badlands Bighorn Sheep, in turn, have been shown to then interact with both the Younts Peak Herd and Francs Peak Herd to the north. This fact has been well documented as far back as the 1960’s and 1970’s when the Wyoming Game & Fish Department placed collars of various colors on diverse bighorn sheep sub-herds wintering in the Dubois area. Subsequent bighorn movement observations subsequently documented individuals traveling and interacting with individuals from both the Wind River Mountains and the Absaroka Mountains. 2) On page 13 of the SDEIS while discussing the TPBSH there are statements that should be clarified, i.e., “the herd has “never recovered” (from the 1992 all age die off). While this herd’s population numbers have not yet recovered to the totals present prior to the all age die-off in 1992, recent counts, as stated in the SDEIS, show the herd continuing to increase in numbers. As this trend continues, the herd is well on its way to recovering, both in numbers and location of habitats used prior to the die-off. The SNF’s policies support a duty- bound obligation to support the continued increase and habitat use of this recovering bighorn herd. BRG’s contacts with the public overwhelmingly indicate that the public strongly supports the recovery of the TPBSH. 3) A statement on page 13 of the SDEIS reads as follows: “Suitable bighorn sheep habitat within and near the domestic sheep allotments on the SNF is very limited due to its forested nature. In addition, a large portion of the land between the allotments occupied habitat is forested, which essentially precludes bighorn sheep forays to these allotments.” Also see similar language on page 15 of the SDEIS. These statements can easily be refuted by those familiar with bighorn sheep habits on the SNF. The Whisky Mountain bighorn herd for example, as well as bighorn populations residing in the Absaroka Mountains near Cody regularly utilize forested habitat in which to migrate through and as routine habitat. Large numbers of well-utilized bighorn sheep “beds” can be found throughout heavy timber in many locations of the SNF. The TPBSH—prior to the die-off—were also documented as frequently utilizing timbered habitat in the Freak Mountain area and several other areas, as well as utilizing long distance timbered migration routes from winter to summer ranges and back again. Recent GPS 3 of 8 data also clearly shows this herd continues to travel through and utilize timbered areas as important habitat. Additionally, the SNF has several projects in which the NEPA process has been completed and are ready for implementation. These projects would dramatically improve bighorn sheep habitat. 4) Also stated in the SDEIS concerning the TPBSH is: “This herd’s current occupied range is very confined, suggesting that the herd is no longer a migratory herd…” GPS location data collected in 2016 and to date in 2017 from the 21 radio collared individuals from the TPBSH shows that individuals in this herd show extensive annual migrations from low elevation winter ranges to high elevation summer ranges on the SNF, up to and even over the continental divide onto lands administered by the Bridger/Teton National Forest and then back down to low-elevation winter ranges along the eastern front of the southern Wind River Mountains. 5) On page 14 of the SDEIS is the following statement: “The closest domestic sheep grazing on the SNF is about 29 km southeast of the Temple Peak Herd.” NOLS and The Nature Conservancy employees during the past three years have reported sightings of individuals from the TPBHS in the Little Popo Agie Canyon near Wolf Point and on the Red Canyon Ranch in Red Canyon, a very short distance from SNF domestic sheep allotments.