Environmental organizations have filed an objection to treating up to 76,500 acres of mountain big sagebrush and duncecap larkspur in Wyoming’s Bighorn National Forest (BNF), stating the treatments would harm bird species and other species of wildlife.
The Bighorn Audubon Society (BAS) and Audubon Rockies, along with Forest Service Employees for Environmental Ethics (FSEEE) and Western Watersheds Project (WWP), filed objections to the draft record of decision for the “Invasive and Other Select Plant Management for the Bighorn National Forest” draft environmental impact statement (DEIS).
The project area covers 1.1 million acres of the BNF in north central Wyoming, comprising four Wyoming counties: Big Horn, Johnson, Sheridan and Washakie counties.
The plan calls for the U.S. Forest Service (USFS) to treat approximately 5,310 acres of invasive plant species annually and 5,100 acres of mountain big sagebrush using a combination of prescribed burning, mowing, ground-based application of herbicides and aerial application of herbicides.
According to the draft record of decision, potential treatment areas include big game transition and winter ranges, bird and wild ungulate habitats, fuel reduction projects, burned areas, roads and trails, power lines and rights-of-way.
“Sagebrush habitat is one of the most imperiled ecosystems in North America and has received increasing public attention over the past decade,” BAS wrote.
BAS notes the plan to treat over 76,000 acres of this habitat conflicts with the U.S. Fish and Wildlife Service’s (USFWS) goals. USFWS plans to spend $50 million to conserve the sagebrush ecosystem.
The letter by BAS notes USFS did not take into consideration recommendations by USFWS to consider migrating birds and to abide by the Migratory Bird Treaty Act by limiting activity during sensitive periods to conserve healthy populations of migratory birds.
BAS stressed a need for transparency to disclose sagebrush treatment maps and details regarding the specific areas targeted to have survey teams identify bird species and nesting numbers in sagebrush and larkspur habitats.
BAS cited comments on the DEIS made by the Environmental Protection Agency (EPA), stating USFS did not consider changes to livestock grazing in the forest that could be incorporated to avoid disruption or restoration of the natural vegetation.
EPA recommended USFS “evaluate if there are additional modifications or best practices the BNF can adopt for livestock grazing to lessen the overall need for human interventions in the management of mountain big sagebrush over the next 15 years.”
Jonathan Ratner, WWP director for Wyoming and Utah, wrote the BNF has “extremely high stocking rates with most allotments stocked at below 2 acres per animal unit month, which is far beyond what the ecosystem could support.” Ratner states the rangeland conditions are poor, which is indicative of high stocking rates, and “instead of addressing this foundational issue,
(USFS) simply proposes killing sagebrush to support the unsupportable stocking rate.”
The DEIS calls for 113,800 animal unit months of grazing. The Wyoming Department of Agriculture supported the use of herbicides with livestock grazing. It noted USFS should be allowed to make changes to grazing permits to address specific invasive weed infestations.
Jim Magagna, executive vice president of the Wyoming Stock Growers Association, wrote the management of mountain big sagebrush “is essential in meeting desired resource conditions and maximizing available forage for both livestock and wildlife.”
BAS is asking USFS to minimize the impacts to birds and wildlife by “reducing the acres of sagebrush that will be treated and by requiring baseline monitoring before treatment on species in an area and then implementing adaptive management to specifically address, mitigate and reduce the impacts on birds and other wildlife.”
FSEEE stated the duncecap larkspur should not be considered an invasive species, as it is indigenous to the Bighorn Mountains. FSEEE contends USFS is acting arbitrarily in its decision to kill larkspur based on county “noxious” designations.
“Even if the Forest Service could kill larkspur to make the range safer for cattle, it must first determine that the Bighorn’s larkspur is actually toxic to livestock,” FSEEE Executive Director Andy Stahl wrote.
FSEEE noted that not all larkspur species are toxic to cattle, citing USDA research showing larkspur in Idaho and Montana is not, while larkspur in much of Utah and southern Wyoming is toxic at certain times of the year. The letter continues that USFS did not rely on a good indicator that Bighorn larkspur is toxic by not collecting data to show it is toxic.
The group also objects to aerial spraying of tebuthiuron to kill sagebrush because it can leach into groundwater, and the group said USFS fails to disclose the impacts in violation of the National Environmental Policy Act.
Ratner contends that pesticides are used to eliminate pests, and sagebrush is not a pest. Ratner continues that the DEIS provides no authority for using pesticides to kill sagebrush.
A final environmental impact statement is expected in September, with implementation in October, according to USFS’ schedule of proposed actions. — Charles Wallace, WLJ editor
