Great Basin Pinyon & Juniper Forest Destruction Comments
TCF Comments on Bureau of Land Management’s (BLM) Draft Programmatic EIS for Fuels Reduction and Rangeland Restoration in the Great Basin.
June 1, 2020
BLM Idaho State Office
Attn: Fuel Reduction & Rangeland Restoration Draft PEIS
1387 South Vinnell Way
Boise, Idaho 83709
Email: BLM_PEIS_Comments@blm.govLink to doc.: https://go.usa.gov/xdfgV(Comments may be submitted via this link, by email or mail & are due by June 2, 2020.)
Dear BLM Official:
The Cloud Foundation (TCF), is a 501(c)3 nonprofit organization committed to protecting and preserving America’s wild horse and burros – and our public lands - through education and advocacy. On behalf of TCF and our nearly 500,000 supporters, I respectfully submit these comments on the Bureau of Land Management’s (BLM) Draft Programmatic EIS for Fuels Reduction and Rangeland Restoration in the Great Basin.
We appreciate the opportunity to provide comments on this PEIS, which will affect the entire Great Basin ecosystem. The health of this ecosystem is essential to the future survival of many species of plants, animals, insects and microorganisms, which themselves are essential to creating and maintaining a thriving natural ecological balance on our public rangelands.
IMPACT
This proposal will impact 223 million acres of public lands in multiple states: CA, ID, NV, OR, UT & WA. While its stated intent is “to enhance the long-term function, viability, resistance and resilience of sagebrush communities,” we believe an unspoken goal is to enhance these treasured public lands for the benefit of the usual for-profit beneficiaries – extractive industry and private livestock permittees. That this is done under the guise of protecting the sagebrush-steppe ecosystem makes it no less palatable to those who want to see their public lands managed correctly – to nurture and protect native plant species and wildlife, including America’s wild mustangs and burros.
This proposal fails to consider the importance of Great Basin ecosystems such as the Pinyon Pine & Juniper forests. In the course of drafting these comments, TCF has consulted ecologist & resident of the Great Basin, Dr. Craig Downer, who feels the proposal “is much too lopsided & designed to perpetuate traditional uses that are harmful to many special Great Basin species, subspecies & populations & the equally special ecosystem types they inhabit.”
Of urgent concern is the fact that this proposal will eliminate Pinyon Pines & Juniper trees, creating a detrimental chain reaction for the many species that depend upon them and the habitat they create for survival. According to Dr. Downer, “The major reduction of these trees will disrupt critical ecosystem services and will set back crucial natural adaptations that have been ongoing for generations & that are combatting the life-threatening effects of Global Climate Change.”
CLIMATE CHANGE
There is no scientifically valid, plausible denial that our planet and its myriad species are suffering from the effects of climate change. The US government cannot responsibly continue to act as if climate change does not exist and does not threaten the survival of our species and millions of others. We should instead be going to great lengths to ensure that our public lands ecosystems adapt, thrive and continue to provide essential habitat in order to preserve and protect their native inhabitants.
PROPOSED ALTERNATIVES
The Cloud Foundation prefers Alternative A: No Action. The other Alternatives are ill-considered tactics that do not adequately analyze or address the complex challenges facing our public rangelands today. These superficial approaches (Alternatives B, C and D) do not address the issues at the heart of these important decisions and fail to consider the connectedness and interdependence of the species of plant and animal life that make up these ecosystems.
TCF strongly opposes Alternative B, which proposes a variety of treatments - including prescribed fire, seeding with chosen species including non-natives & targeted grazing, we can only assume by privately owned livestock.
Our Great Basin public lands should not be further subjected to overgrazing by nonnative livestock. The rangelands of the West are now suffering the results of a century of overgrazing by imported cattle and sheep. It’s one of the very reasons we are seeing a loss of resilience, drought, and desertification of lands that were formerly havens for countless species of wildlife.
This proposal fails to address potential negative impacts by a variety of factors to Great Basin public land ecosystems, including:
· Off Road Vehicles and the massive damage they do to fragile, recovering ecosystems.
· Disruption from mining & energy development industries.
· Natural imbalances caused by the slaughter of native predators.
· Human by-products such as litter & waste.
· Water appropriation by private interests.
The above must be considered and addressed before the selection of an alternative. Interested and affected members of the public must have access to the analysis so that we can understand how decisions are made by our government.
HABITAT FRAGMENTATION
The proposal fails to adequately consider the impacts on hundreds of native species of animal and plant if these invasive “treatments” are allowed to occur. According to Dr. Downer, the proposed actions will “disrupt habitat continuity and isolate populations to numbers below the minimum threshold for genetic viability.” Certain rare native species could potentially be threatened by this genetic isolation, eventually leading to local extirpation of these isolated colonies.
BIASED ACTIONS – ERADICATING PINYON-JUNIPER FORESTS
We must take issue with the USDI’s “Categorical Exclusion” for the removal of “encroaching Pinyon-Juniper trees.” This indicates an unbalanced, biased approach to the management of our public lands - biased in favor of private interests. It also fails to consider that the Pinyon-Juniper forests have extensive positive impacts on - and are an integral part of - the greater ecosystem.
The regrowth of Pinyon and Juniper trees is an example of Nature responding to and healing from years of overuse as well as damage due to climate change. Rather than intervene to thwart this natural healing, we as responsible caretakers of these fragile lands need to take a step back and let the recovery take place.
The Draft PEIS states that Sagebrush communities “will provide multiple use opportunities for all user groups”, but this false and must be corrected. You cannot make this statement if BLM intends to destroy the Pinyon and Juniper forests, and thus the ecosystems and forms of life they support. These forests are sources of nourishment to the aptly named Pinyon Jay and, to a lesser extent, the Clark’s Nutcracker, who in turn help to propagate the forest inadvertently when they cache seeds for later consumption. These species of bird, as well as numerous rodent and insect species will be displaced and possibly die as their habitat is destroyed.
“Both piñon-juniper and western juniper woodlands have high diversities of vertebrate species. Piñon-juniper woodlands provide seasonal to year-long habitat for over 150 vertebrate species (Buckman and Wolters 1987), many of which decline in abundance with reductions in woodlands (Belsky 1996). Both elk and mule deer are year-round residents in piñon-juniper habitat, both of which consume both leaves and fruit of piñons and junipers (Martin et al. 1961) Maser and Gashwiler (1975) attributed the higher diversity of bird species in juniper woodlands to high structural diversity, large numbers of sites for perching, singing, nesting, and drumming, and plentiful berries and high insect diversity for food. They attributed high mammal diversity in the same communities to the presence of hollow trunks, shade, thermal cover, and foliage and berries for food.” (Attachment 1: Mechanical Treatment of Pinyon-Juniper in the Intermountain West: A Review of the Literature)
The BLM’s own proposed actions in undertaking mechanical treatment of sagebrush communities may actually increase the spread of cheatgrass, according to peer-reviewed scientific studies. Additionally, there is no scientific basis for the assumption that clearing Pinyon-Juniper forests will have any beneficial effect on fire reduction.
“…recent studies suggest that climate has a greater influence on fire activity than fine fuels and biomass. Other researchers found that the surface disturbances associated with mechanical treatments may facilitate cheatgrass (Bromus tectorum) expansion and lead to increased fires. At present, there is little research supporting the contention that removing pinyon and juniper reduces incidence of fire.” (Attachment 2: Do Mechanical Vegetation Treatments of Pinyon-Juniper and Sagebrush Communities Work?)
The proposed actions are also based on erroneous assumptions. BLM is relying on the old, unsupported idea that sagebrush communities burned every few decades. This is a myth.
“Although some studies suggest that fire return interval in sagebrush communities is 10 to 40 years, there are no data to support that. In fact, other researchers indicate it may be between 50 to 150 years or more. Since half of the studies in our review showed that treatments increase flammable non-natives, they may actually shorten the fire cycle rather than restore the natural fire regime.”(Attachment 2)
The final PEIS must include cumulative analysis of Pinyon and Juniper removal. Before sanctioning the further removal of Pinyon or Juniper the PEIS must list all specific areas, dates and methodology utilized for Juniper and Pinyon removal since 1970. Such cumulative analysis must also include any fires (prescribed or otherwise) in or near areas where removals have taken place. Deforestation projects such as the proposed actions often have great cumulative impacts which must be disclosed and analyzed. BLM must undertake a thorough analysis (and disclosure) of all fires in areas where Pinyon and Juniper removals have happened within the past 50 years.
WILD HORSES AND BURROS
One of the stated reasons for the actions proposed in this Draft PEIS is prevention and mitigation of wildfires. The BLM fails to consider, however, the natural preventative benefits that wild horses (a returned native species) and burros offer to sagebrush communities.
These rugged foragers have been forced to survive in some of the harshest environments our western states have to offer. They have become proficient at sourcing nutrients from the very materials that wildfires proliferate on. They consume the raw materials that would become potential tinder, providing a valuable service to the ecosystem.
Protected “where currently found” by the 1971 Wild Free-Roaming Horses and Burros Act (The Act), the rangelands dedicated to these historic animals are to be devoted “principally” for their welfare. The proposed Draft EIS actions could violate this Congressional mandate. The methods proposed by BLM have not been scientifically documented to benefit native ecosystems and will most certainly disrupt the natural landscape and its fragile balance even further. Alternative B is particularly egregious, citing for use chemicals and herbicides which could cause illness or injury to wildlife who inadvertently consume these poisons.
LIVESTOCK
The Draft PEIS somehow evades adequate discussion of perhaps the most important and pervasive impact on our western rangelands – privately owned livestock. But their impacts on public lands cannot be ignored. Cloven-hooved cattle trample fragile soils and plant life. They pollute water sources and damage riparian areas. They compete for forage with native species, including our wild horses. For their sake is the natural biological balance upset through the mass killing of potential predators. It is offensive to the American taxpayers that their hard-won salaries support this money-pit of an industry known as welfare ranching.
Our native ecosystems, including the sagebrush steppe, have suffered from the loss of native grazers and predators caused by the prolific use of these lands by nonnative livestock. Now, the proposed “restoration” of these lands includes actions such as planting nonnative plants like crested wheatgrass; plants which few native species can eat and which therefore serve only one purpose – providing forage for livestock grazing.
Livestock are notorious spreaders of “invasive annual grasses” (Draft PEIS) such as cheatgrass. As Ecologist George Wuerthner, states in his well-researched article on this Draft PEIS, “The way to save the sagebrush steppe is to eliminate all unnatural disturbance. Disturbance enhances the growth of non-native exotic species like cheatgrass, a highly flammable annual.” (Attachment 4: BLM Fuels Reduction and Restoration: License to Destroy Sagebrush Ecosystems) The greatest source of disturbance on these public lands is the millions of head of nonnative cattle, and yet, the Draft PEIS barely gives them a mention.
“Biocrust species richness, which is reduced by livestock grazing, also appears to promote native perennial grasses.” (Attachment 3: Grazing disturbance promotes exotic annual grasses by degrading soil biocrust communities. H.T. Root, J.E. Miller, and R. Rosentreter. Ecological Applications, 0(0), 2019)
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)
“It is a violation of NEPA to allow large-scale surface-disturbance of any kind on BLM lands without site-specific analysis, public accountability, and public input.” (Attachment 4)
This Draft PEIS potentially sets a dangerous standard. It may allow BLM to manipulate vegetation on our Great Basin public lands without seeking public input and without necessary oversight. This is a clear violation of NEPA.
The proposed actions fail to consider any of the prevalent peer-reviewed science that categorically shows mechanical vegetation removal and manipulation causes harm to fragile ecosystems and the many species that depend on them for survival. Site-specific analysis is required by NEPA and anything less is unlawful and an end-run around the rights and interests of the American citizens.
CONCLUSION
This ill-conceived, manipulative plan must not be considered. The only viable option is Alternative A: No Action. It is unacceptable for BLM to ignore the weight of public opinion in order to satisfy the desires of individuals and industries that stand to profit from the exploitation of our nation’s public lands. These lands are held in trust for the American people. Our tax dollars should not be pilfered in order to destroy native ecosystems and wildlife. It is time for government to serve the public again, not the interests of a special few.
Thank you for your consideration.
Ginger Kathrens
Founder and Director
The Cloud Foundation