This was shared w/ me from Lyin'king over on pirate and was the BEST and most well informed comment that I had seen!! Props to him for the work in drafting this.
I submitted my comment TODAY and used ALL of his writhing points in my comment WITH his permission to do so. He said, also, that I could share this with others, so that's what I'm doing.
I did write my own intro and conclusion, but I straight RIPPED his writing points.
Hey Keith!
I finally got to work on the NFS DEIS response and will use it for the BLM and FWS in a modified form too.
As I mentioned my stuff is weak but here it is for what it is . . .
Be well . . . Bob
James Winfrey
Humboldt-Toiyabe National Forest
Bi-State DEIS
1200 Franklin Way
Sparks, Nevada, 89431
jwinfrey@fs.fed.us
To whom it may concern,
Thank you for extending the opportunity to provide comments on the Humboldt-Toiyabe National Forest Service and BLM Carson City District’s Draft Environmental Impact Statement (DEIS) for the Greater Sage-Grouse Bi-State Distinct Population Segment (DPS) forest and resource management plan amendment.
The Humboldt-Toiyabe National Forest has already completed its Travel Management Plan and designated routes where travel is allowed which should be sufficient to protect the Grouse population. The Grouse DEIS now seeks to amend the Land and Resource Management Plan for the Humboldt-Toiyabe National Forest which proposes to add additional burdensome, cost prohibitive and unnecessary regulatory measures.
The U.S. Fish and Wildlife Service proposed to protect the Bi-State Distinct Population Segment (DPS) of greater sage-grouse along the California-Nevada border as a threatened species under the Endangered Species Act (ESA). FWS is also proposing to designate 1.8 million acres as critical habitat to help protect this subgroup of grouse. The proposal includes a special rule that would provide increased flexibility for land management practices that are intended to benefit the sage-grouse. However, the “special rule” is not named or described anywhere.
The original FWS proposals intent was to list the Grouse as threatened. The mitigation measures proposed by the FWS, BLM and FS are disproportionate to that level of designation and represent excessive bureaucratic over reach.
The ESA states that critical habitat designations and revisions are to be made on the basis of the best available scientific data after taking into consideration the economic impact, national security impact, and any other relevant impact of specifying any particular area as critical habitat yet specificity and granularity in this data is conspicuously absent even after over a half century of studying Grouse.
No definitive metrics have been established to evaluate the success or failure of various mitigation efforts proposed in order to determine those which are either effective or have no positive effect. No definitive population thresholds have been set or time lines defined to evaluate efforts which would be used to either begin lifting restrictive mitigation measures or move toward a listing of “endangered”.
Non-native pinyon pine and juniper trees introduced to the habitat and power lines have given low-to-the-ground perches for raptors which eat the grouse, as do ravens, coyotes, badgers and other predators. The preferred course of action and various mitigation proposals do not address the extent of effects predators have on sage grouse populations.
Control of ravens, coyotes, badgers and other predators was once a priority, now they too are protected and in some cases reintroduced. This suggests modern day conservation practices may be as much at fault as any other possible threats identified thus far.
The FWS also found that an invasive grass from Asia that burns easily has helped decimate sagebrush, which is the key element to the grouse's survival.
Invasive grass, predation, fire sterilization, urbanization and solar energy development on ground the Grouse favor are all problems contributing to their declining numbers along with West Nile virus and possibly other threats yet to be identified.
The Grouse is the new Spotted Owl and much like the owl there are many unknowns. In the end we may discover that the Grouse has simply abandoned its historic preferred habitat driven out by another species much like the Spotted Owl was displaced by the Eastern Barred Owl. The Spotted Owl was discovered doing well in new growth forests where they learned to adapt but until recently nobody considered looking for them there until recently. Perhaps the Grouse has moved and adapted too.
Recreational activities including hunting, fishing, camping, bicycle riding, bird watching, photography, hiking and other hobbies or pastimes often require vehicle travel on designated dirt trails, routes, and roads represent no significant impact having existed for centuries in one form or another according to FWS studies. Though the Grouse has been intensively studied for the last 60 years there is scant to little information anywhere related to the effects of motorized recreation on the Grouse and there are no definitive studies that implicate motorized recreation as a contributor to the health and well being of the Grouse cited anywhere in the databases.
Studies conducted where cattle graze in areas Grouse reside have shown the Grouse apparently do better where cattle free range as invasive grasses are kept in check. The impact of wild burros and horses on the Grouse population is a matter the BLM needs to better manage if warranted.
Fire fighters have changed their approach in response to loss of Grouse habitat and now attempt to save islands of prime habitat within a wildfire when possible to maintain some ground for the Grouse to survive on and preserve native vegetation that can eventually spread to the surrounding burnt areas.
In an era of National and State economic uncertainty many legislators are concerned the proposed listing and its prescriptive mitigation efforts will have wide-ranging economic impact on State and rural economies in the regions affected as are other state officials. Area ranchers, miners, energy developers and those who depend on tourism will all be impacted, some devastatingly so.
The draconian “objectives” listed such as the goal of “limiting discrete anthropogenic disturbances to no
more than 3% of the total identified Bi-State Sage Grouse habitat regardless of ownership which include
but are not limited to paved highways, graded gravel roads, transmission lines, substations, wind turbines,
oil and gas wells, geothermal wells and associated facilities, pipelines, landfills, homes, and mines” are untenable,
coupled with the two alternatives offered they hint at a predetermined agenda.
To reiterate specific concerns with BLM DEIS conclusions include:
-The DEIS is based primarily on opinion and void of demonstrated scientific results.
-The DEIS authors appear to have extrapolated science from other areas and arbitrarily applied it to
Nevada and California.
-None of the cited studies in the NTT report documented a population decline.
-The BLM has dramatically inflated the actual habitat area causing the new restrictive policies to be
applied in areas not capable of supporting the grouse.
-The BLM already has existing laws and regulations to provide the regulatory assurance necessary to avoid a listing, but failed to discuss and analyze this in the DEIS (No Action Alternative).
-The DEIS fails to resolve inconsistencies with the local plans.
-The proposed action does not meet the BLM's multiple-use mandate, and instead manages the federal lands for a single purpose,
conservation of the Greater Sage-Grouse.
Senate Majority Leader Harry Reid said the decision will have "major ramifications" on the way of life in parts of Nevada and California, yet the proposal ignores the ESA mandate to give these economic matters serious consideration as no data has been provided to quantify impacts of the arbitrary and capricious proposal on human beings and hence does not meet the purposes of NEPA and/or the Section 309review process.
Thank you for your time.
Sincerely,
Bob
I submitted my comment TODAY and used ALL of his writhing points in my comment WITH his permission to do so. He said, also, that I could share this with others, so that's what I'm doing.
I did write my own intro and conclusion, but I straight RIPPED his writing points.
Hey Keith!
I finally got to work on the NFS DEIS response and will use it for the BLM and FWS in a modified form too.
As I mentioned my stuff is weak but here it is for what it is . . .
Be well . . . Bob
James Winfrey
Humboldt-Toiyabe National Forest
Bi-State DEIS
1200 Franklin Way
Sparks, Nevada, 89431
jwinfrey@fs.fed.us
To whom it may concern,
Thank you for extending the opportunity to provide comments on the Humboldt-Toiyabe National Forest Service and BLM Carson City District’s Draft Environmental Impact Statement (DEIS) for the Greater Sage-Grouse Bi-State Distinct Population Segment (DPS) forest and resource management plan amendment.
The Humboldt-Toiyabe National Forest has already completed its Travel Management Plan and designated routes where travel is allowed which should be sufficient to protect the Grouse population. The Grouse DEIS now seeks to amend the Land and Resource Management Plan for the Humboldt-Toiyabe National Forest which proposes to add additional burdensome, cost prohibitive and unnecessary regulatory measures.
The U.S. Fish and Wildlife Service proposed to protect the Bi-State Distinct Population Segment (DPS) of greater sage-grouse along the California-Nevada border as a threatened species under the Endangered Species Act (ESA). FWS is also proposing to designate 1.8 million acres as critical habitat to help protect this subgroup of grouse. The proposal includes a special rule that would provide increased flexibility for land management practices that are intended to benefit the sage-grouse. However, the “special rule” is not named or described anywhere.
The original FWS proposals intent was to list the Grouse as threatened. The mitigation measures proposed by the FWS, BLM and FS are disproportionate to that level of designation and represent excessive bureaucratic over reach.
The ESA states that critical habitat designations and revisions are to be made on the basis of the best available scientific data after taking into consideration the economic impact, national security impact, and any other relevant impact of specifying any particular area as critical habitat yet specificity and granularity in this data is conspicuously absent even after over a half century of studying Grouse.
No definitive metrics have been established to evaluate the success or failure of various mitigation efforts proposed in order to determine those which are either effective or have no positive effect. No definitive population thresholds have been set or time lines defined to evaluate efforts which would be used to either begin lifting restrictive mitigation measures or move toward a listing of “endangered”.
Non-native pinyon pine and juniper trees introduced to the habitat and power lines have given low-to-the-ground perches for raptors which eat the grouse, as do ravens, coyotes, badgers and other predators. The preferred course of action and various mitigation proposals do not address the extent of effects predators have on sage grouse populations.
Control of ravens, coyotes, badgers and other predators was once a priority, now they too are protected and in some cases reintroduced. This suggests modern day conservation practices may be as much at fault as any other possible threats identified thus far.
The FWS also found that an invasive grass from Asia that burns easily has helped decimate sagebrush, which is the key element to the grouse's survival.
Invasive grass, predation, fire sterilization, urbanization and solar energy development on ground the Grouse favor are all problems contributing to their declining numbers along with West Nile virus and possibly other threats yet to be identified.
The Grouse is the new Spotted Owl and much like the owl there are many unknowns. In the end we may discover that the Grouse has simply abandoned its historic preferred habitat driven out by another species much like the Spotted Owl was displaced by the Eastern Barred Owl. The Spotted Owl was discovered doing well in new growth forests where they learned to adapt but until recently nobody considered looking for them there until recently. Perhaps the Grouse has moved and adapted too.
Recreational activities including hunting, fishing, camping, bicycle riding, bird watching, photography, hiking and other hobbies or pastimes often require vehicle travel on designated dirt trails, routes, and roads represent no significant impact having existed for centuries in one form or another according to FWS studies. Though the Grouse has been intensively studied for the last 60 years there is scant to little information anywhere related to the effects of motorized recreation on the Grouse and there are no definitive studies that implicate motorized recreation as a contributor to the health and well being of the Grouse cited anywhere in the databases.
Studies conducted where cattle graze in areas Grouse reside have shown the Grouse apparently do better where cattle free range as invasive grasses are kept in check. The impact of wild burros and horses on the Grouse population is a matter the BLM needs to better manage if warranted.
Fire fighters have changed their approach in response to loss of Grouse habitat and now attempt to save islands of prime habitat within a wildfire when possible to maintain some ground for the Grouse to survive on and preserve native vegetation that can eventually spread to the surrounding burnt areas.
In an era of National and State economic uncertainty many legislators are concerned the proposed listing and its prescriptive mitigation efforts will have wide-ranging economic impact on State and rural economies in the regions affected as are other state officials. Area ranchers, miners, energy developers and those who depend on tourism will all be impacted, some devastatingly so.
The draconian “objectives” listed such as the goal of “limiting discrete anthropogenic disturbances to no
more than 3% of the total identified Bi-State Sage Grouse habitat regardless of ownership which include
but are not limited to paved highways, graded gravel roads, transmission lines, substations, wind turbines,
oil and gas wells, geothermal wells and associated facilities, pipelines, landfills, homes, and mines” are untenable,
coupled with the two alternatives offered they hint at a predetermined agenda.
To reiterate specific concerns with BLM DEIS conclusions include:
-The DEIS is based primarily on opinion and void of demonstrated scientific results.
-The DEIS authors appear to have extrapolated science from other areas and arbitrarily applied it to
Nevada and California.
-None of the cited studies in the NTT report documented a population decline.
-The BLM has dramatically inflated the actual habitat area causing the new restrictive policies to be
applied in areas not capable of supporting the grouse.
-The BLM already has existing laws and regulations to provide the regulatory assurance necessary to avoid a listing, but failed to discuss and analyze this in the DEIS (No Action Alternative).
-The DEIS fails to resolve inconsistencies with the local plans.
-The proposed action does not meet the BLM's multiple-use mandate, and instead manages the federal lands for a single purpose,
conservation of the Greater Sage-Grouse.
Senate Majority Leader Harry Reid said the decision will have "major ramifications" on the way of life in parts of Nevada and California, yet the proposal ignores the ESA mandate to give these economic matters serious consideration as no data has been provided to quantify impacts of the arbitrary and capricious proposal on human beings and hence does not meet the purposes of NEPA and/or the Section 309review process.
Thank you for your time.
Sincerely,
Bob
