February 28, 2015


Sally Jewell, Secretary of Interior

Michael Bean, Principal Deputy, Fish, Wildlife and Parks

Neil Kornze, Director Bureau of Land Management

James Lyons, Deputy Assistant Secretary for Lands and Minerals Management

Sarah Greenberger, Senior Advisor to the Secretary

Department of Interior

1849 C Street Northwest

Washington, DC 20240


Dear Interior Secretary Jewell, BLM Director Kornze and Interior Department Officials,

WildLands Defense is alarmed at the proposal laid out in an October 27, 2014 USFWS memorandum and map, developed in conjunction with BLM. The Memo is entitled: Greater Sage-Grouse: Additional Recommendations to Refine Land Use Allocations in Highly Important Landscapes. This shows a very diminished land area as “Super-PACs”.

We do not support the SuperPACs habitat segregation. The land area in the earlier PACs was also already much too small for effective conservation of sustainable and viable populations of greater sage-grouse across the species range.

The SuperPAC scheme is the latest in a series of USFWS and BLM actions aimed at reducing habitat considered of importance to greater sage-grouse to a very small land area that will never be sufficient to preserve the species.

First and foremost, all agencies in Interior must commit to protection of all remaining extant populations of greater sage-grouse within all habitats that are occupied by sage-grouse, and lands that are identified for restoration. The Super-PAC concept, to be of value to conservation, must be applied to all remaining occupied sage-grouse habitat and identified restoration habitat for this landscape species.

Regrettably, with each new habitat segregation scheme, Interior agencies are dramatically shrinking and whittling away at habitats of high concern.

This is the latest in a long series of efforts to cut back on habitat protections to benefit industry. The series includes:

***Doherty et al. 2010 “Core” mapping under Interior secretary Ken Salazar.

***BLM PPH/PGH that segregated occupied habitat including diminishing Key habitat, and down-graded the importance and management protections for vast areas of Occupied habitat.

*** The severely flawed COT PAC cuts of 2012-2013 that very significantly cut habitats across southeastern Idaho, portions of Utah, Oregon and other areas.

*** The series of BLM Draft Greater Sage-grouse EIS’s with habitat mapping showing the areas of highest priority for sage-grouse conservation shrinking – often dramatically. This was done by: Federal agencies capitulating to weak and greatly inadequate state plans (such as Idaho’s) that segregated habitat into three categories, immediately cutting Priority habitat. This three category segregation pervades the EIS’s across the species range.

Now, environmentalists are confronted with the egregious 2014-2015 Super PAC effort at broad-scale slashing of habitats to a mere 16 million acres.

At this rate, FWS will be recommending zero acres for conservation by the end of 2015!

With the Super-PACs, the habitat segregation cuts have gotten to an absurd point. FWS’s habitat segregating schemes superlatively illustrate the failure of existing regulatory mechanisms, and demonstrate the need for expeditious Listing of sage-grouse under the ESA.

 SuperPACs carve up the landscape with a management scheme that enables the species’ incremental extinction.

An E& E article describes how Interior formed a Dream Team of agency people to “save” sage-grouse. http://www.eenews.net/stories/1060009471/print

Only one of the people chosen for the Team had ever seen a sage-grouse. We fear such lack of experience with sage-grouse and the sagebrush biome is why they were chosen, since no credible sagebrush biologist would countenance such a drastic shrinking of important habitat as takes place with the SuperPAC scheme.

Sage-grouse are a landscape species. There has been significant conservation concern about reliance on a lek-based “core” approach for habitat range-wide (see Doherty et al. 2010). The Core approach was developed in the relatively continuous and more uniform landscape of Wyoming. It immediately segregated occupied habitat into areas of lesser importance (including sometimes to please energy interests, powerful ranchers, etc.). The Core habitat segregation scheme made it easier for agencies to begin the process of sacrificing habitats to industry in areas where sage-grouse were less numerous.

This lek-based approach especially handicaps conservation of sage-grouse populations in Basin and Range and other naturally fragmented and heterogeneous topographical settings, as well as the populations that now exist in shrinking and ever-more isolated pockets due to human development and habitat degradation and disturbance.

By focusing on only the areas where sage-grouse are (or were) most numerous (based on what in reality are very old lek count data used to determine abundance), FWS gives tacit approval for smaller populations to continue to decline and blink out. FWS and the Dream Team appear to be abandoning the agency’s mission, and instead are behaving more like pawns of industry, ever-willing to lessen habitat acres with each passing year.

The Core habitat mapping effort and its derivatives knowingly wrote off an important percentage of the population. This was ecological madness for a species known to be in decline, and facing unprecedented energy development, fire, chronic grazing degradation and other threats – many of which are known to be further amplified by climate change.

Both the COT PAC cuts, and now the SuperPAC habitat slashing omits large areas of the landscape long-identified for sage-grouse conservation.

This includes large areas where extraordinarily expensive so-called “habitat restoration” efforts have taken place, or are planned. In fact, NRCS just published a new report touting how it had spent hundreds of millions of taxpayers dollars and hoped to spend hundreds of millions more – on many of the land areas that the COT PACs and the Super PACs writes off.

We are dismayed that these vast sums are being spent by NRCS and other agencies on projects that closely resemble livestock forage production and infrastructure schemes, and on conservation assessments that fail to rein in abusive grazing practices. Such projects involve even more livestock facility sprawl, and alteration and “eradication” of native vegetation just like was done in the past and which helped to degrade and fragment habitats, and push sage-grouse populations towards their current depressed state. Now, the COT PAC and SuperPAC mapping shows these sums are being wasted on lands the agencies have no intention of managing to prioritize sage-grouse despite spending hundreds of millions of tax dollars in these very areas.

Concern about PEW and other Agendas Driving SuperPACs

We are also concerned that the SuperPACS are in part driven by Interior making some concessions to large Wilderness and other groups, whose land protection agenda is often driven by PEW and others. By narrowing sage-grouse conservation focus to what in reality are postage stamps compared to the former sagebrush ecosystem and historically (and still) occupied habitats, it becomes much easier for some parties to justify looking away from protection and advocacy across Occupied habitat. It is the “Just give us this Special Area and industry can have the rest” mentality that is being legitimized by this SuperPAC habitat slashing.

Basic Agency Culture Means That Identification of SuperPACs Will Diminish Importance of PPH/PGH, PACs, and Designations That Arise from GRSG EIS Process and PACs

The culture of federal land management agencies is to yield when faced with development and pressure from the livestock and other industries. Designating a small land area as PACs and Super PACs will result in widespread harm to the non-Super PAC birds.

Interior officials certainly must know the realities of the “multiple use” management paradigms. Officials certainly must understand the culture of public lands agencies that buffeted are between politically powerful public lands stockmen, energy developers and miners vs. the need of wildlife for food, cover and space. See Professor Debra Donahue’s paper on Capture.

Harmful land uses that threatensage-grouse will be shifted and intensified in the non-“special”/SuperPAC areas, and they will become degraded sacrifice areas. This is precisely what we have observed with the BLM’s PPH and PGH. Since the PPH and PGH habitat segregation took place, BLM has been justifying permitting additional livestock facility sprawl and other harmful activities in PGH – because it is not PPH. BLM even goes to great lengths to segregate habitats within PPH into areas of lesser importance. For example, see Idaho BLM Owyhee 68 allotment livestock grazing EA processes, where harmful livestock seasons of use and stocking levels are justified in occupied habitats with fewer leks (based on artificial barbed wire pasture configurations), despite extensive conflicts with nesting habitat security and ecological conditions.

 All Occupied habitat must be managed as highest Priority habitat. There has already been a dramatic reduction in occupied habitat. Fragmentation of remaining habitats abounds, and is getting worse.

Moreover, beyond intensive development pressures and chronic poorly controlled livestock degradation and habitat conflicts —Events in the natural world are highly unpredictable and can rapidly cause population declines over significant areas. It is hubris to believe that climate-driven wildfires and other annual invasive grass expansion in chronically grazed habitats will not get worse, and continue to eat away at habitat across the species range. No matter if NRCS and other agencies spend billions of dollars.

Enhanced conservation measures must eliminate human disturbances and infrastructure, and restore sage grouse habitats moving forward.

Occupied sage-grouse habitats outside the SuperPACs will serve as the equivalent of “sacrifice areas” where livestock grazing, energy development, mining and other disturbance will be intensified.

Effective protection of federal lands must include all occupied habitats to provide certainty for long-term sage-grouse persistence. This certainty requires meaningful conservation measures across all occupied sage-grouse habitat. Threats must be ameliorated across all greater sage-grouse habitat.

The COT report made large cuts to habitats long identified as being of conservation importance. It then went on to claim that PACs represent “the most important areas needed for maintaining sage-grouse representation, redundancy, and resilience across the landscape.” COT Report at 13. Yet the process by which specific areas with concentrations of active leks were omitted from PACs in the COT (like the Big Desert area in Idaho and land areas in southeastern Idaho) appear to have been made for political reasons, bearing no resemblance to the biological needs of the species. The COT PAC land areas selection process arbitrarily varied from state to state. FWS appeared to capitulate to politically tainted state plan cuts in habitat in its delineation of the COT PACs. While Nevada did not suffer immense cuts with the PACs, the SuperPAC cuts are devastating and certain to result in widespread extirpation across much of the Great Basin.

Ameliorating identified threats to greater sage-grouse in all occupied habitat will require application of precautionary management and the best available science.

Very Important Areas Are Missing in Current SuperPACs

Many areas of relatively contiguous federal land with higher sage grouse population densities and remaining habitat have been excluded from the current COT PAC.

This is much worse in the SuperPAC designations. The SuperPAC process appears strongly biased against sage-grouse populations occupying landscapes with Basin and Range topography, for example in the naturally fragmented habitats of central and southern Nevada and Utah in the Southern Great Basin Population. Here, leks are found in valleys and low ridge toe slopes of rugged ranges. They do not occur in steep mountain terrain. Thus the density of leks in any one area is naturally limited by physiographic constraints. Merely drawing a circle with a diameter extending outward from leks with higher numbers of birds will not effectively capture how the landscape is used by sage-grouse in fulfilling their seasonal needs across the landscape.

In contrast, large areas of the landscape occupied by the Northern Great Basin population in northern Nevada are severely degraded by intensive livestock grazing and facilities (fences, water developments), yet this area passed muster as a SuperPAC. SuperPAC lands here contain extensive crested wheatgrass and/or failed fire rehab areas with annual exotic invasive grasses and that lack sagebrush shrub cover at present. Yet these areas are embedded within a large SuperPAC while the more intact Southern Great Basin habitats are cast aside by FWS in this latest scheme.

Nearly all populations within the Southern Great Basin population are omitted from SuperPAC status. This is despite the relatively higher degree of intact sagebrush communities with less wildfire disturbance in many areas. The Southern Great Basin populations, as identified in the COT PACs in Nevada and areas expanded from the COT PACs in UT must all be managed as SuperPACs.

The southern Great Basin population is threatened in Nevada by grazing disturbance promoting invasive species, agency sagebrush reduction treatments such as the Ely BLM Cave Valley and Lake Valley “treatment” project (note that both SNWA and the foreign gold mines are very large grazing permittees in this areas as well), hard rock mining which also causes aquifer drawdown, the Southern Nevada Water Authority aquifer mining and infrastructure and energy development proposal, and other foreseeable developments.

Isolated or nearly isolated population areas at greatest risk of extirpation (e.g., Baker, Oregon southern Utah, Hamlin Valley, Laramie Basin, Jackson Hole, Powder River Basin, Dakotas) and all deserve the highest protection.

All lands where sage-grouse populations threatened by incompatible land uses must be fully protected – the Weiser Idaho population, northwestern Colorado, Utah’s Parker Mountain, the Powder River Basin, Laramie Plains, Jackson Hole in Wyoming, habitats in North and South Dakota. Protecting the most at-risk populations is essential to maintain genetic diversity and population connectivity, and to maximize the potential for the survival of the species.

In this severely flawed process, FWS and BLM have delineated SuperPACs based on sage grouse population densities as mapped in a 2004 study, with a little tweaking. Agencies are living in the past, including in their acknowledgment of how much worse habitat conditions and bird numbers are now – for example, the massive Murphy Complex fire, the 2008 Nevada fires, the Holloway and Long Draw fires in NV and OR in 2012, all have occurred since then.

Plus, we are greatly concerned agencies are still to a large degree relying on the now long-outdated Garton et al analysis in Studies in Avian Biology, which was based on 2007 and prior lek counts.

Current and much more robust population analysis must be applied.

All Nevada populations in the southern Great Basin population, additional Utah populations, the Baker Oregon population and a larger land area for the other Oregon populations, and Idaho populations.

In Idaho, it is difficult to determine from the scale of the mapping of the lands in the southern Big Desert population with numerous occupied leks are included. If not, the area should be expanded to include lands south and east of Craters of the Moon and extending outside the Monument boundary. It must include expanded areas in the northern Jarbidge region and extending east across southern Idaho (in the northern Great Basin population).

Reining in Threats to Occupied Habitats

Oil and Gas. Agency mapping must be provided that shows the current area of land leased for OG in all occupied habitats so that the magnitude of buy backs or other conservation efforts including protective terminations can be understood and funded. There is an overwhelming body of literature showing the adverse impacts of energy development on sage-grouse.

Mapping that shows the current area of land with mineral claims and leases in all occupied habitats is also necessary so that the magnitude of the potential mining footprint on habitats and populations can be understood

A moratorium must be imposed on issuance of any new leases.

Mining. Occupied habitats must be closed to future mineral leasing and location, and surface permits on existing mines must not expand. Mining Impacts of mining and any other aquifer drawdown activity (including aquifer mining) on de-watering or loss of mesic brood rearing habitats is a serious concern. Activity and vehicle traffic disturbance of breeding and wintering habitats must not be allowed.

Wind Farms, Geothermal Plants and Wells, Transmission Lines, Gas Pipelines, Aquifer Mining Water Pipelines. Communication Towers and other Infrastructure and Wind Farms.

Occupied habitats must be excluded from the siting of new energy developments, and other ROWs, and transmission and pipelines. As existing Rights-of-way come up for renewal, significant new mitigation must be required. The adverse footprint of existing facilities must be minimized to the maximum extent possible.


Potential geothermal development in areas of the Great Basin and Bi-state sage-grouse habitats would result in transmission lines and industrial development with a significant facility, human disturbance and infrastructure footprint.

Livestock Grazing’s Myriad Habitat Degradation and Disturbance Impacts

Sage-grouse require vital residual grass cover and complex sagebrush structure for concealing nests. Livestock grazing causes cheatgrass and other aggressive annual grass invasion (Belsky and Gelbard Reisner dissertation 2010, Reisner et al. 2013. It seriously degrades meadow, spring, seep and stream brood rearing habitats, and can cause their permanent reduction and loss.

Livestock-trampled springs, seep and spring margins, stock ponds and artificial upland water pipeline and trough systems create conditions favorable for mosquitoes that may transmit rough West Nile Virus.

Upland livestock water sources expand the range of nest and egg predators and mesopredators, and lead to chronic long-lasting degradation of sagebrush uplands over broad areas.

Such water developments, often incrementally expanded across upland habitats, result in significant depletion of understory components of sage-grouse habitats over large areas of their surroundings. Much of the existing network of roading on public lands across occupied habitats stems from this livestock facility and management infrastructure footprint.

Livestock water developments are often dug into natural springs, meadows and drainage courses and diminish and/or destroy the areal extent of wetted areas that can support mesic vegetation. They diminish brood rearing habitat area and vital moist sites.

Livestock trampling is not controlled by BLM across uplands, yet trampling greatly impacts microbiotic crusts, a critical part of the sagebrush ecosystem that serves as a frontline defense against invasive annual grasses. (Belsky and Gelbard 2000, Reisner Dissertation 2010). Trampling of springs, seeps and small streams is also rarely monitored and controlled. Yet trampling promotes desiccating hummocks, headcuts and erosion that permanently and irreversibly shrinks available habitat, and accelerates earlier seasonal drying.

Livestock breakage and browse of sagebrush plants results in the structural alteration and simplification of nesting and hiding cover. Over broad areas of the landscape, grazing results in an unnaturally simplified sagebrush habitat with diminished protective cover, and “see through” sagebrush.

Livestock carrion, waste and disturbance from cattle and sheep, and upland water sources all promote nest and egg predation and mesopredators.

Fences injure and kill sage-grouse. Areas beat out by livestock near fences serve as travel corridors for mesopredators and zones of weed infestation. Fences removal, like large-scale water development removal and restoration, should be high priority across Occupied habitats.

Often, the only monitoring metric tracked by agencies is upland utilization, taken at cherry-picked sites distant from zones of more intensive livestock disturbance. Utilization is often measured on only one or two species, and often these species are larger-sized species that have typically been depleted. Hence utilization as measured by agencies is completely inadequate in tracking the impacts of livestock use, and the amount of essential residual protective cover.

In depleted sagebrush communities, often the primary grass species that are present are small in stature, and can receive 10-15% or even less utilization if they are to provide sufficient residual and screening nesting cover for sage-grouse.

Fire and Vegetation Manipulation Projects

 Fire (both natural and human-caused) along with agency “treatment”/vegetation manipulation projects have a major potential to destroy and/or degrade sage grouse habitats (Beck et al. 2012, Hess and Beck 2012).

Construction of large sterile fuelbreaks creates hotter, drier sites for flammable invasive grass infestation, and areas for livestock loafing. Clearing large areas of woody vegetation alongside roads and smaller two tracks increases potential for off-road use and catalytic converter fires, as well as adds substantially to the fragmentation of habitats.

It also causes collateral damage to many other species –like pygmy rabbit, and migratory songbird species that require taller sagebrush for nesting- as roads typically follow draws or areas with near drainage courses, or less rocky areas – and these are deeper soil sites that support larger sub-species of big sagebrush and/or more robust sage growth.

Planting of non-native grasses and other non-natives must be prohibited. Exotic crested wheatgrass and other exotics should be a focus for removal and restoration.

In any restoration and rehab seeding efforts, agencies must use only locally adapted native plant ecotypes.

Vast sums (hundreds of millions of dollars) are being spent destroying native trees, often with much fanfare as a tremendous boons to sage-grouse. Conifer removal projects should be permitted only where there is evidence that conifers are a significant adverse impact to the population. Only selective hand cutting should be used if and when it is shown based on significant evidence that any conifers need removal. Soil disturbance, flammable weed infestation and spread, damage to sage in understory, and collateral damage to non-target species habitats must be minimized.

Sagebrush must not be “treated”, as agencies invariably focus on the denser more structurally intact sagebrush that is at a premium in the landscape, and which is required by pygmy rabit and migratory birds.

Mechanical and chemical treatments must be prohibited. Tebuthiuron, Round Up and other non-selective herbicides must be prohibited.

Continued grazing and trampling impacts to vegetation, soils and microbiotic crusts is highly likely to render germination inhibiting herbicides claimed to temporarily set back cheatgrass invasion ineffective over time. Plus these chemicals may inhibit sagebrush germination and have other unintended ecological consequences.

Increased focus on fungal pathogen control of cheatgrass should be paramount (along with removing livestock trampling and other disturbance that causes cheatgrass).

Predators Are A Natural Component of the Ecosystem

Predation is not identified as a primary threat to sage-grouse. However, we include prudent management actions to preclude claims of a need for predator control. These claims serve to distract from habitat conservation actions, particularly in relation to livestock grazing.

Poisoning of ravens and other corvids should not occur in any habitats. Instead, agencies should provide for large blocks of livestock-free habitat during breeding periods (lek, nesting, early brood rearing) to minimize disturbance and predation.

If in a rare circumstance, control is necessary only non-lethal control should be used. There is growing evidence that taste aversion is effective. See series of marbled murrelet and other corvid studies using carbachol, for example.

Removal of apex or higher level predators like wolves and coyotes also may increase mammalian predation conflicts with sage-grouse by allowing smaller sized mesopredators like skunks and red foxes to thrive. Plus removal of established pairs of coyotes may result in increased predation by younger animals.

Instead of killing predators, agencies must conserve, enhance and restore habitat. They must also require accountability from livestock grazing operations to minimize raven and other nest and egg predation. This management accountability includes removal of dead livestock and carrion; no lambing, calving, afterbirth; no artificial upland water troughs with water throughout this period; no herding dogs and management disturbance, etc. See series of Boarman reports on common sense methods to minimize raven conflicts with desert tortoise, with similar methods applicable to sage-grouse.

ACEC Designation Is Essential Across Occupied Habitats

ACECs are vital as designations to protect Relevant and Important values such as crucial sage-grouse habitats and occupied landscapes, from irreparable harm. BLM is to give priority to such considerations as described in FLPMA. “Transcendental” designations will not necessarily protect sage-grouse from irreparable harm, and are increasingly laced with politically compromised language, plus may take many years to be put into place. In contrast, ACECs can be designated with Land Use Plan Amendments, and the identified Values must be protected.

The bottom line is that sage-grouse habitats and populations are already greatly reduced and habitats highly compromised. All the remaining occupied habitat must be identified as a stronghold if effective conservation of the species is to occur.


cc:        Sally Jewell, Secretary of the Interior

            Janice Schneider, DOI Assistant Secretary for Lands and Minerals Management

            Robert Bonnie, USDA Undersecretary for Natural Resources and Environment

            Dan Ashe, Director U.S. Fish and Wildlife Service

            Neil Kornze, Director, Bureau of Land Management

            Tom Tidwell, Chief, USDA Forest Service

Noreen Walsh, U.S. Fish and Wildlife Service

Bob Dreher, U.S. Fish and Wildlife Service