Spruce Mountain Pinyon Juniper Report – 4/28/24

Included below is an ACEC proposal submitted to Elko BLM in 2006 for the Spruce Valley landscape. 

 

Regrettably, Elko BLM proceeded to ignore every part of the proposal, tear up Pygmy Rabbit habitat, destroy the Ferruginous Hawk habitat, by churning out a series of PJ and sagebrush killing projects.

 

“SPRUCE – VALLEY LANDSCAPE ACEC PROPOSAL AND NOMINATION submitted to Elko BLM, the Nevada State Office BLM, Nevada SHPO’s Office and Nevada Division of Wildlife 

 

October 2006
“Tr

Photos from the site

This used to be sagebrush.

Wyoming big sagebrush obliterated in an Elko Spruce Mountain. The low elevation mature and old growth sagebrush here was prime Sagebrush Sparrow nesting habitat, and had been Pygmy Rabbit habitat. 

 

Elko BLM Chaining Destruction of Old Growth Pinyon-Juniper Forest at Spruce Mountain 

 

Spruce Mountain south of Wells Nevada has long been a target of relentless BLM destruction of both Pinyon-Juniper and sagebrush native vegetation communities. Large areas of mature sagebrush has been railed, mowed and roller-beat. Over 15 years ago, an NDOW non-game biologist got reprimanded for pointing out in an e-mail that an area of proposed sagebrush destruction would destroy the highest density known Pygmy Rabbit habitat in Elko County. BLM – and big game staff in NDOW – relentlessly pushed for major “treatments” – fire, chaining, clear-cutting to attack the beautiful and often tiny ancient trees and replace them with forage grass, and also roller-beating and mowing sagebrush. In the aftermath of the woody plant destruction, the BLM would plant forage grasses that the agencies claimed wintering big game needed. Rather than control cattle and sheep-caused depletion of big game winter range on public lands, the standard agency approach is to attack woody vegetation communities. This only perpetuates the livestock land abuse cycle. 

Elko BLM first did a series of small woody vegetation killing projects, then finalized an EA for laying waste to vast forest areas. BLM was aided by livestock industry friendly range scientists like Robin Tausch (participant in BLM field trips who promoted Elko BLM manipulation designs) who have been seen as forest “experts”.  Range interests have long espoused and promoted ridiculously short fire return and disturbance intervals for PJ forests in the Great Basin to justify leveling the forest. The cadre of range PJ “experts” ignore the historical stability of Nevada pinyon-juniper communities, and also downplay the manor role of white settlement-era deforestation in reducing Great Basin forest cover. They wholeheartedly embrace and promote the PJ encroachment and invasion narrative – even calling trees that have colonized old 1960s PJ chaining areas “invaders”.

     

Tiny ancient trees senselessly destroyed.

This is what land grant college and USDA ag. “range science” promotes on public lands.

A thin “leave-strip” in the background of the soon to be livestock forage seeding.

Trees that escaped the chaining at Spruce show the age and beauty of the forest that was destroyed:

 

Sagebrush Killing at Spruce Mountain

The photos below are from a different area of Spruce Mountain where both trees and sagebrush was destroyed. Note that Sage-grouse use in the Spruce Mountain landscape is minimal, so any claim that this many year assault on native plant communiites is being done for Sage-grouse doesn’t hold water.

Dead tree remains and dead shrubs.

Aftermath of heavy equipment forest destruction.

Tebuthiuron???

Whatever herbicide Elko BLM used, it killed the sagebrush and some rabbitbrush stone cold dead. The question is: Was this intentional? Did they spray the shrubs with Tebuthiuron (a long-lasting persistent killer of woody vegetation for 10 years or more after application), or is this a result of overdosing on “cheatgrass control” toxics? Elsewhere in Nevada, we’ve observed Ely BLM’s purposeful use of Tebuthiuron and its after-effects in the Wilson Creek area. There, under an EA claimed to benefit Sage-grouse in Lincoln County at the very southern extent of their shrinking range, BLM aerial herbicided Tebuthiuron, killing the sagebrush cover all around 3 important Sage-grouse leks. This also spawned dense cheatgrass growth once the site cooling and moisture trapping sagebrush cover was herbicided. There, BLM lied and claimed its herbicide treatments were to help for Sage-grouse because the sage was ‘too dense” – anything other than admitting livestock are a primary driver of all of this manipulation.

BLM herbiciding appears to have killed the lone mountain mahogany left standing.

Cheatgrass invading the deforestation site.

Hard to tell all the types of tree killing here – looks like primarily mastication and some wood-cutting – but one thing is clear – BLM managed to get cheatgrass invading in the “treatment”

Looking West down from Spruce Mountain slopes onto one of many PJ eradication and  forage projects piece-mealed in over the years. Note the highly unnatural appearance of the little islands of trees in a sea of deforestation that BLM left trying to claim they created a “mosaic for wildlife”. 

 

Lethal Livestock Water Developments Continue to Kill Wildlife at Spruce

Birds and bats drowning in livestock water developments in the very arid Spruce region (and many other areas of the Great Basin) has been a known and ongoing problem for decades. Minimal “wildlife escape” ladders do not prevent many drownings in the huge troughs. Or algae chokes the surface of the water so any animal that falls into the water gets tangled in algae mats and can’t escape. The livestock troughs also kill many native insects, an increasing concern as world-wide insect populations plummet in the “insect apocalypse”. Despite the millions of dollars BLM has spent on destroying PJ forest and sagebrush here, BLM has failed to fix the wildlife drowning problem.

A bat rescued from a large cow water trough with a stick warming up. The bat then fell off the stick and got encrusted with bits of soil. The enormous trough had only a single escape ladder.

Remains of a bat drowned in a livestock trough. The trough was rusting and the iron turned the dead bat red. There were many bird remains oin some of the troughs, too.

Insects drowned in a Spruce trough.

 

Included below is an ACEC proposal submitted to Elko BLM in 2006 for the Spruce Valley landscape. 

Regrettably, Elko BLM proceeded to ignore every part of the proposal, tear up Pygmy Rabbit habitat, destroy the Ferruginous Hawk habitat, by churning out a series of PJ and sagebrush killing projects.

“SPRUCE – VALLEY LANDSCAPE ACEC PROPOSAL AND NOMINATION submitted to Elko BLM, the Nevada State Office BLM, Nevada SHPO’s Office and Nevada Division of Wildlife 

October 2006
“Trees that pre-date Euro-American settlement represent woodland structure before the impacts of our land uses, and thus need to be preserved during restoration as is true in other ecosystems.” William L. Baker and Douglas J. Shinneman.

The Spruce-Valley Landscape ACEC Proposal encompasses habitats of conservation importance in the Great Basin, including old growth Wyoming big sagebrush communities with remarkable microbiotic crusts, old growth black sagebrush, some of the highest known density pygmy rabbit and ferruginous hawk habitat, ancient juniper pygmy woodlands on small ridges sweeping out towards valley floors, ancient groves of pinyon and juniper pygmy woodlands on benches, and montane conifer forest that includes bristlecone pine.

Lands in the ACEC (map will be sent separately) include: the rounded to very steep mountainous terrain characteristic of Spruce Mountain, Spruce Mountain Ridge, and the Pequop Mountains – heavily dissected by canyons and washes. Sloping alluvial fans run from the foot of the mountains to the Independence and Clover Valley floors (BLM Spruce Recreation Trails EA 2004 at 14). The ACEC also includes the sloping ridges and alluvial fans of Valley Mountain, and portions of the Goshute and Butte Valleys.   

It includes “some of the highest density ferruginous hawk, pygmy rabbit and burrowing owl nesting/breeding habitat in the state”, where “any increase in the frequency of use [human] during the breeding season (March-August) will likely result in reduced fecundity of several nongame wildlife species” (BLM Spruce Recreation Trails EA 2004 at 68), as well as many other significant adverse impacts. 

Conflicts abound here. Knowing full well the devastating impacts that increased human use would have on native biota here, BLM forged ahead with development of a publicized and promoted OHV trail network cross much of the ACEC area, and acquiesced to large-scale destruction of ferruginous hawk, pygmy rabbit and burrowing owl sagebrush habitat to plant crested wheatgrass — in the 21st century! 

Despite large-scale BLM eradication efforts of trees to promote livestock food at Spruce circa 1962 and even earlier, significant tracts of old growth pinyon and juniper remain in many bench and canyon areas (Fite 1990s, 2005 and 2006 Field observations – substantiated by counting close-spaced growth rings on BLM’s newly cut 2006 trees on Spruce and comparing growth form characteristics of cut trees to standing live trees).

 

Author and naturalist Stephen Trimble described the fine woodlands of the Spruce Mountain area at the southern extent of the Pequop Range, and even the presence of bristlecone pine on limestone-derived soils in the higher elevations.

Here in these mountains and valleys in the rain shadow of the Ruby Mountains, old growth Wyoming big sagebrush and black sagebrush communities interface with ancient pinyon and juniper pygmy woodlands that are greatly threatened by a plethora of ongoing and intensified human activities. In many areas of both Spruce and Valley Mountain, instead of “invading” the pygmy woodlands appear to be retreating – with lower elevation ancient trees dying out – and this appears to be exacerbated by harmful livestock concentration in shaded areas near water or salt placement. 

Protection of ecological systems in the Great Basin is critical, as ecological processes operate at spatial scales above those that support individual plant associations (Nachlinger et al. 2001 at 22). Assemblages of communities that occur together on the landscape are tied together by ecological processes or environmental gradients, and form a cohesive unit. 

The native vegetation communities of the Spruce and Valley Mountain area are being used as a sacrifice area to extend livestock forage and quell complaints from the livestock industry about deer and elk herd numbers.  Agencies aim to kill sagebrush and trees to placate a public lands livestock industry complaining about a burgeoning elk population and other big game. 

BLM continues to countenance all manner of chronic alteration and degradation of native vegetation and harm to native biota (cattle feeding tubs placed amid tall sagebrush, widespread water hauling right next to ancient trees, smashing of sagebrush along road corridors thus creating new swaths of cheatgrass, bats and other small animals constantly drowning in water tanks, and making new management decisions like throwing open sections of the Spruce landscape to crosscountry travel in Oil and Gas exploration) – Fite 2005 and 2006 field and document observations). Much of the vegetation disturbance is conducted to facilitate overstocking of the public lands with large numbers of cattle that are unsupportable with the current native vegetation communities as a forage base. Potential increases in privately owned cattle numbers here are linked to even more projects that eradicate or greatly alter native vegetation and attempt to grow more cattle food, or that extend cattle water. 

A 90-mile cattle water pipeline to extend and intensify cattle use has been planned for several years. New dark green posts on the ground mark the proposed pipeline route and trough locations.  These posts are located amid ancient trees, amid the multi-million dollar proposed vegetation eradication projects including chaining, burning and other manipulation that BLM is on the verge of conducting. Some of these posts are in locations where water hauling has occurred – and many others are present where it has not yet occurred and thus has not yet concentrated livestock use and degraded spectacular microbiotic crusts and native vegetation communities – including ancient juniper, pinyon, mahogany or other trees that livestock concentrate under for shade in the vicinity of water. Introduced weeds, degraded surrounding vegetation, soil compaction, rubbing and breakage of vegetation in intensified zones of livestock concentration may weaken and lead to mortality of the ancient trees and old growth sagebrush – including pulverizing the microbiotic crusts. 

The ACEC includes representative plant communities including: Intact sagebrush semidesert, sagebrush steppe, salt desert scrub, semi-desert shrub-steppe plant, pinyon-juniper and montane forest communities. These plant communities are increasingly threatened by invasive species, livestock grazing practices, fire, proliferating off-road vehicle use and other increasing human uses and activities (TNC 2001, USGS Great Basin-Mojave Desert Region, Nevada Natural Resources Status Report 2002). Harms caused by livestock fire-exacerbated weed invasion and spread, are particularly acute. Weedy exotics are also promoted by intensified livestock grazing and human disturbance such as OHV use or bulldozing.

The ACEC is located in lands greatly threatened by purposefully expanded and much-publicized motorized use – including by OHVs and Hummers. Right now, cheatgrass occurs in the understory of many draw areas where livestock use has been intense, where big sagebrush vegetation has been smashed by primitive “brush-clearing” projects, and other disturbed sites. Placement of feeding tubs with food supplements for livestock amid sagebrush is causing new zones of concentrated cattle trampling disturbance, structural alteration and death of mature sagebrush plants. (Fite 2006 field observations). 

Motorized use off the many existing roads – including those bordering and amid the sprawling project areas – may crush fragile desert soils, disturbing microbiotic crusts and plant habitats. Clearing and eradication of native vegetation under the various highly invasive vegetation manipulation and eradication projects would serve to intensify cattle use on open areas, here would create extensive new areas of soil disturbance. 

Accelerating exotic species invasions follow in the wake of intensification of livestock grazing, livestock water hauling and pipelines, mechanical soil disturbance, OHV use and fire. As recreational uses of disturbed arid lands, especially those that are increasingly invaded by cheatgrass, grow — fire danger from motorized use escalates. 

In the Great Basin, the contraction and fragmentation of sagebrush habitats and increases in nonindigenous plants are aggravated by livestock grazing. More than 99% of the sagebrush-grass zone has been negatively affected by livestock grazing (USGS “Great Basin-Mojave Desert Region”, citing Noss et al. 1995, Nevada Natural Resources Status Report 2002).

Halogeton, mustards and cheatgrass are moving into disturbed big sagebrush and other low elevation shrub sites, and cheatgrass and mustards are proliferating in areas of the bench portions of BLM’s old chainings, fire and other manipulation here. 

Cheatgrass is present in many areas in the understory of the cattle-altered big sagebrush communities in the draws, is present in areas of older treatments, and is no longer confined solely to south-facing slopes – sites typically first invaded at higher elevations. Haloes of cheatgrass ring now-maturing pinyon and juniper in some old BLM “treatments”, and trees where livestock loaf.

Disturbance increases safe site availability for invasive species, and affects community structure and dynamics that promotes invasion by alien plant species. (Masters and Sheley 2001). Invasive species alter the composition, structure and functioning of plant communities. The extensive purposeful disturbance of older and now very new exotic seedings of crested wheatgrass and other species have further altered and fragmented sagebrush habitats here – and areas of older seedings and rehab efforts are clogged with cheatgrass.

Such changes affect habitat for regionally declining small mammals and avian species including migratory birds. See Dobkin and Sauder 2004, describing alarming trends in many Great Basin animal species. 

Montane islands in the Great Basin are important for the potential resilience of the natural communities and species response to climate change (TNC 2001, citing Wharton et al. 1990). Some mammal taxa in the Great Basin are confined to isolated mountain tops, and some may be genetically unique populations of more widespread species (TNC 2001, Dobkin and Sauder 2004). Relict mammal populations on isolated mountains, if lost, may not have chance to recolonize under current climate conditions, and their uniqueness may be lost forever (TNC 001, citing Grayson 1993). Montane meadows, springs and springbrooks are exceedingly rare in the arid Spruce landscape. Lower montane systems consist primarily of: pinyon-juniper woodland, and mountain mahogany woodland with important avifauna.   

Designation of an ACEC here would elevate the importance of the intact and functioning ecosystems, would help protect them from future fragmentation, and would elevate precautionary management for native plant communities and special status species habitats, cultural and other values. 

Rare springs are vital to many species of native wildlife, and provide refueling stops for migrating songbirds. 

Some recent conservation planning assessments (such as TNC’s assessment for Nevada) appears to focus more on plant communities and endemic animals than on many sagebrush, pinyon-juniper and montane species now increasingly recognized as showing broad-scale declines. It was finalized prior to: Recent Partners in Flight planning efforts; the systematic compilation of data on shrub loss and fragmentation in the Sage Grouse Conservation Assessment (Connelly et al. 2004); the Dobkin and Sauder (2004) synthesis of information on problems facing birds and small mammals found in sagebrush and lower elevation shrub communities, the recognition of the large-scale die-offs of pinyon-juniper in the American southwest, and the now undeniable evidence of global warming and climate change and other new information. Important elements from ICBEMP assessments and syntheses – such as Wisdom et al. 2002 are quite relevant to conservation planning efforts for many species across the Great Basin. Thus, up-dated assessment and description of species of animal importance in TNC’s Landscape sites would likely encompass more species, and stress the growing importance of landscapes to maintenance of animal populations. 

The presence of many special status species at Spruce does not show up in databases, simply because there have not been adequate systematic baseline surveys to detect species of concern – so the full range of species and their habitats at stake here has not been studied. The significance of habitat and populations here cannot be understood until this is done. 

The ACEC also contains Scenic and Recreational values, and critical big game ranges and wintering big game populations including mule deer, antelope and a burgeoning year-round elk population.  

The proposal includes sufficient land to enable meaningful and sound management at the landscape level. Establishment of the ACEC is essential for long-term viability of the ferruginous hawk and other raptor populations and their prey base, refueling stops for migrating birds, important migratory bird nesting habitat, bat roosting and foraging habitat, core pygmy rabbit and sagebrush-dependent migratory bird habitat restoration and protection, intact ancient pygmy woodlands and dependent pinyon jay, juniper titmouse and other declining avian species, and many other outstanding and important values. 

There is a pressing need for protecting critical values here through special management designation of a landscape-level ACEC. This will also enhance opportunities for sound biological research based on a full understanding of site history and ecological attributes. It will aid in proactive, ecosystem-level management of key habitats, and long-term maintenance of viable populations of declining sagebrush, pinyon-juniper, montane forest, and other native biota. It will also conserve large core areas to provide long-term habitat stability: “Identify and conserve remaining core areas of shrub steppe and other source habitats [such as pinyon juniper!] where ecological integrity is still high” (Wisdom et al. 2002). 

Core areas of old growth Wyoming big sagebrush habitats (inhabited by sage sparrow, loggerhead shrike, and Brewer’s sparrow and other declining animals, contain very high densities of pygmy rabbits (BLM Spruce OHV EA 2004, NDOW Memo – describing crested wheatgrass seeding in “Pygmy [Rabbit] Valley”), were greatly fragmented just 3 or so years ago by BLM’s million dollar large-scale sagebrush smashing, harrowing and/or eradication efforts – and planting of alien crested wheatgrass and forage kochia to intensify livestock use in the newly fragmented habitats.  

These large-scale new cattle forage and sagebrush eradication projects not only serve to greatly fragment habitats – the planned intensified cattle use, cattle water pipelines, etc. will lead to a significant alteration and further fragmentation as the composition, function and structure (see Fleischner 1994) of the still-intact old growth non-weedy Wyoming big sagebrush habitats here proceeds under intensified cattle use. 

Further destruction of necessary structural attributes required by the pygmy rabbit (Katzner and Parker 1997, Federal Register March 2003) will quickly ensue. Besides the BLM’s sagebrush eradication disturbance facilitating weed invasions, the resulting intensified cattle use will trample and collapse burrows of pygmy rabbits in adjacent sagebrush stands (see BLM Sage 2004 aerial photos showing the pattern of new disturbance) – creating large new zones of unsuitable habitat for the pygmy rabbit, sage sparrow and other sagebrush-dependent wildlife. 

Extensive structural alteration of the dense sagebrush required by the pygmy rabbit as protection from predators will also occur with increased cattle trampling and rubbing breakage. Vivid evidence of such breakage already exists in the dry draw areas (with cheatgrass understories now present in many sites) where cattle use has been intensified by water development or trough placement. 

The Federal Register Notice for ESA listing of the Columbia Basin DPS of the pygmy rabbit (March 2003) describes the various methods of “take” and habitat alteration associated with intensive livestock grazing of rabbit habitats. 

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FLPMA provides that BLM will designate Areas of Critical Environmental Concern (ACECs): “areas within the public lands where special management attention is required (when such areas are developed or used or where no development is required) to protect and prevent irreparable damage to important historic, cultural, or scenic values, fish and wildlife resources, or other natural systems or processes, or to protect life and safety from natural hazards”.     

Special management attention is greatly needed in the ACEC lands. BLM has just acted to destroy some of the highest density known pygmy rabbit habitat in Nevada, has failed to act to stop exotic species invasions, has facilitated intensified livestock grazing on extremely marginal lands and on unsuitable grazing lands, has facilitated and overseen the promotion of an extensive OHV/Hummer etc. route network in inappropriate areas, and has already used vast sums of taxpayer dollars in recent alteration and destruction of important native species habitats at Spruce. See BLM Sage News 2004 describing sagebrush eradication efforts, see BLM Spruce Recreational Trail EA 2004, and many documents readily available on the Internet discussing or promoting expanded motorized use here.

Plus, BLM, has made no effort to restore (and address the now heightened fire danger) on lands that have already suffered harms – such as the weedlands near the valley floor on the West side of Spruce Mountain – where long-term intensified cattle use facilitated by water development has resulted in expanses of halogeton, mustards and little native vegetation remains; the cheatgrass-infested burns at the mouth of 2 canyons on the West of the Spruce range; or the crested wheatgrass and crested wheatgrass/cheatgrass seeding areas on the northern portion of Spruce —- let alone integrate management actions necessary to protect this greatly important stronghold of Great Basin biota. 

BLM’s management practices (from the massive chaining of old growth pinyon-juniper in 1962 and other native vegetation eradication measures) and recent large-scale efforts have accelerated habitat fragmentation here and increased/will increase as weeds invade disturbed areas) fire risks.  

Ecosystem-level management of the area as a whole landscape is the only logical way to protect and enhance the wide array of nationally significant values in the ACEC ecosystem. Current ecological science and the principles of conservation biology support the view that BLM lands must be managed at a landscape level to preserve the array of regionally and nationally important values at stake and prevent further losses.

Regionally Significant Cultural Locale

“Having been a major hunting corridor utilized by the Western Shoshone hunters in the past, the Spruce Mountain area is the site of multiple antelope traps, [and] hunting/pine nut camps …” (BLM Spruce OHV Trails EA 2004).  

Present too are fragile and irreplaceable cultural sites including antelope traps (BLM Spruce OHV Trails EA 2004, BLM Spruce Restoration EA 2005). See www.wy.blm.gov/cultural/atrisk.htm , www.wy.blm.gov/cultural/events.htm for a better understanding of the nature and significance of such sites and risks that these sites face. 

long “fences” of limbs and wood placed to obstruct antelope movement and funnel them to a kill site). At Spruce, standing live ancient juniper trees still bear evidence of woodcutting for these wood traps and perhaps other purposes. 

These traps and other cultural sites cannot be viewed in isolation. They are not just the exact spots on the earth where old branches remain or limbs have been cut from still-living trees. They must be understood (and protected) in the context of the landscape in which they are found. Antelope behavior in the landscape was understood by the Native Americans building the traps (for example, various ethnographic accounts and also Sarah Winnemucca’s account of antelope hunting). Antelope typically avoid dense forested vegetation and cross fence-like barriers poorly. It is not just the presence of the downed wood, or the standing ancient trees where branches have been removed. The cultural locale must be viewed as the configuration of the dense forested vegetation on the landscape (anathema to antelope) that helped limit and funnel animal movement. The weathered cut branches on the ground, the standing trees, and the pattern of the forested vegetation all provide the environmental context for prehistoric sites of cultural importance.  

As human uses, especially with the much-publicized OHV trail route increases, scavenging for firewood and burning or breakage of centuries old trees can be expected to increase. See www.wy.blm.gov/cultural/atrisk.htm , www.wy.blm.gov/cultural/events.htm , describing detrimental effects of tourism, recreation, collection for firewood, weathering and erosion (exacerbated by livestock or OHV use), vandalism, etc.) on cultural sites including the Wyoming Little Missouri Antelope Trap. As a 90-mile cattle water pipeline or other water provision practices extend and intensify cattle use outward, disturbance of fragile sites will proceed over a distance of approximately two miles from any water sources (two miles is distance cattle are likely to roam from water). BLM has never examined the impacts of ongoing cattle uses and management –let alone expanded use  – on these sites.

Sagebrush Importance

Declining population trends of shrub-steppe birds are tied to losses of shrub habitats both regionally and Westwide. Much of the West’s sagebrush country (and interfacing salt desert communities) have been altered from a natural state (Saab and Groves 1992, Saab and Rich 1997, Knick et al. 2003, Connelly et al. 2004, Rich et al. 2004). Migrants that inhabit shrub habitats have suffered losses through fire, livestock grazing, spraying, plowing, seeding and conversion for agriculture. Massive historical losses occurred. Yet despite these massive historical losses, consistent long-term population declines are noted for several species inhabiting sagebrush and salt desert shrub (Saab and Rich 1997, Rich et al. 2004, Dobkin and Sauder 2004).Proposed treatments such as fire result in long-term loss of big sagebrush cover, and are leikley to result in little if any forage enhancement (see Wamboldt et al 2001).

Critical habitat losses are occurring Westwide for upland sagebrush species (Saab and Rich 1997). Brewer’s sparrow is declining at a highly significant rate (Saab and Rich 1997). Population monitoring of this priority species is important because it is an obligate of sagebrush vegetation, and research is needed to determine causes of their persistent population declines. Other shrub nesting species (gray flycatcher and sage sparrow) have been identified as needing specialized monitoring to adequately trace their populations. (Saab and Rich 1997).

Birds in a Sagebrush Sea (Paige and Ritter 1999) details the plethora of problems facing habitats of sagebrush and lower elevation shrub-dependent birds Westwide. Wisdom et al. (2002) describe habitat problems facing suites of species, including Group 31 (Ferruginous Hawk, Burrowing Owl, Short-eared Owl, Vesper Sparrow, Lark Sparrow, Western Meadowlark, Pronghorn; Group 32 (Preble’s Shrew, Uinta ground squirrel, White-tailed antelope squirrel, Wyoming ground squirrel, Striped whipsnake, Longnose snake, ground snake, Mojave black collard lizard, and longnose leopard lizard), and Group 33: Brewer’s Sparrow, Lark Bunting, Sage Sparrow, Sage Thrasher, Sage Grouse, Pygmy Rabbit and Sagebrush Vole. Many of these species or closely related species occur in the ACEC area.

The importance of the lower elevation sagebrush communities in the ACEC for native animals is indisputable. Wisdom et al. (2002) provide management direction for many of these species — conservation of large core areas to provide long-term habitat suitability. Sagebrush provides critical habitat for burrowing owl, sage sparrow, loggerhead shrike, Brewer’s sparrow, sage thrasher, and small mammals especially the pygmy rabbit whose habitats have very little protection across vast land areas (see discussion of suites of species 30, 31, 32, and 33). 

Small mammal prey in sagebrush communities may be particularly important to migrating, nesting or wintering raptors, such as prairie falcon, golden eagle, ferruginous hawk and others. Thus, integrated management that addresses habitat needs of prey species is essential.

The remaining core areas of old growth Wyoming big sagebrush and black sagebrush with well-developed microbiotic crusts. Native plant communities of the ACEC stand out in sharp contrast to the bleak areas of weedlands, and sterile crested wheatgrass seedings now dominating manipulated sagebrush habitats at Spruce and Valley, and areas in this landscape where concentrated livestock use has converted sagebrush and salt desert communities to weedlands. Plus, some sagebrush die-off has recently occurred in portions of the pygmy habitat.

A significant first step in wild land fire prevention here is to recover the weed lands that already exist here, and undo the ecological mess made by the large-scale new plantings of flammable alien grasses.

This will take concerted and intensive agency action, and is likely to meet fierce resistance from the public lands livestock industry.

However, here the importance of the landscapes and wildlife populations – such as the pygmy rabbit – that are threatened by these alien seedings must be fully weighed and necessary attempts at rehabilitation be made. 

ICBEMP found Ecologically Significant declines in broad-scale cover-type structural stages within the Interior Columbia Basin.  Saab and Rich (1997) recommend habitat or ecosystem-level conservation strategies to maximize effectiveness of conservation efforts. Shrub-steppe habitats have the highest percentage of species vulnerable to management activities under all themes. Even under themes where aggressive restoration activities are planned, it is thought that the deterioration and loss of sagebrush habitat will outpace restoration successes (Saab and Rich 1997). These habitats are identified as restoration priorities (Saab and Rich 1997). 

ICBEMP’s broadscale assessment of the Columbia River Basin identified sagebrush steppe as the highest priority for habitat conservation based on trends in bird populations (Saab and Rich 1997), (Paige and Ritter 1999). The plight of sage grouse across the West and the Great Basin has highlighted the fact that the same processes (degradation, loss, fragmentation of habitats) described for sagebrush and salt desert shrub communities in ICBEMP analyses (Wisdom et al. 2002) are operating across the Great Basin. See also USFWS 2004, Connelly et al. 2004, Rich et al. 2004.

Habitat values of still-intact the sagebrush and salt desert shrub landscapes, which once may have seemed so ordinary in the Intermountain West, are now increasingly significant — in a local, regional and a national context — for conservation of sagebrush and desert shrub birds. The ACEC provides a special opportunity to protect, enhance, restore and study species and populations in a large core area of Wyoming big sagebrush and black sagebrush in the ACEC.

Since the time of those assessments, there has been large-scale die-off not just in sagebrush in areas of the Interior Columbia and Great Basins, but also of pinyon pine in the southwest (New Mexico, Arizona, Colorado) – elevating the conservation importance of both communities.  

The primary sage grouse habitat at Spruce is sage grouse winter habitat. BLM acted to destroy and fragment sagebrush in sage grouse wintering habitat Spruce in its recent million-dollar cattle forage seeding effort in the 21st century. 

The very important old growth sagebrush values at lower elevations at Spruce are its value as nesting habitat for sage sparrow and loggerhead shrike, Brewer’s sparrow, and particularly as critical habitat for the pygmy rabbit.  

Sagebrush and salt desert shrub communities Westwide are in peril due to:

1) Altered fire regimes due to invasion by exotic annual grasses; 2) Continued encroachment by exotics; and 3) Livestock grazing (causes and/or exacerbates) exotic plant invasions. Ecological integrity is threatened by livestock grazing, invasion by exotic plants, and ORV recreation. 

Saab and Rich (1997) describe Shrub-steppe/sagebrush communities as being at High Risk in the Interior Columbia Basin. It has patchy distribution within the assessment area, plus high levels of grazing and fire-associated risks, along with a high risk of invasion or introduction of exotics. 

Successional pathways in shrub-steppe communities are disrupted by exotic annual grasses. Introduced annual grasses invade communities as a result of livestock grazing impacts, fire or other disturbance. Once dominated by annual grasses, the community remains this way because of frequent fire, which prevent shrubs from establishing Whisenant (1991), (Billings 1994), Connelly et al. 2004. Cheatgrass today threatens to dominate 25 million hectares (62 million acres), or more than half of the West’s sagebrush region (Rich 1996, Paige and Ritter 1999).  60% or more of the West’s sagebrush region may now be threatened (Dobkin and Sauder  (2004) citing West (2000). Plus, cheatgrass and other weedy species are evolving to grow at higher and higher elevations, extending well into the pinyon-juniper zone (Monsen 1994)

Habitats for shrub-steppe and salt desert shrub wildlife have been greatly fragmented and ecological integrity has been lost. Increasing fragmentation trends are today found within four terrestrial community groups, including upland herbland, and upland shrubland (Quigley and Arbelbide 1997, p.761). Nevada Natural Resources Status Report 2002, USGS Mojave-Great Basin) describe weed invasion and fragmentation processes mirroring those of ICBEMP-covered lands.

Ecological integrity has been, and continues to be, lost in vegetation communities important to raptors, migratory songbirds, small mammals, reptiles and numerous other special status species found in the ACEC area. Impacts of fragmentation and conversion to cheatgrass of upland shrub-steppe vegetation on sagebrush biota have been elucidated in Knick and Rotenberry (1995), Knick and Rotenberry (1999), Paige and Ritter (1999) and Knick and Rotenberry (2000), Knick et al. 2003, Federal Register 68, 43: 10389-10409, Federal Register 69 (77) 21484-21494, Connelly et al. 2004. 

Assertions have been made of pinyon-juniper invasion at Spruce. However, historical information has not been taken into account in these claims, including widespread deforestation in the vicinity of mining (Lanner 1981, Trimble 1989), as well as for railroads and other purposes (Charlet “Shah-kan-daw” in press).

Additional Biota and Threats

Many native reptiles are increasingly uncommon, especially those associated with lower elevation salt desert or interfacing Wyoming big sagebrush communities (Groves 1994). The loss of shrub habitats portends long-term population declines for reptiles (Groves 1994). A diversity of reptiles is associated with lower elevation sagebrush communities and salt desert shrub habitats.  Species on the edge of their range (in this case  – northern periphery) appear to be especially susceptible to habitat degradation (Collopy and Smith 1995, USDA/USDI 2000).  The loss of habitat is currently affecting several reptile species. Cheatgrass and exotic species invasion in degraded habitats smother the ground surface, and may preclude use by collared lizard and longnose leopard lizard (Wisdom et. al. 2002 citing Whitaker and Maser 1981). 

Changes in composition and structure of vegetation in sagebrush habitats are due to loss of sagebrush and microbiotic crusts, and conversion to exotic forbs and annual grasses (Wisdom et al. 2002). ORVs, pet trade collection, and degradation of habitat were identified as threats. A primary strategy identified to reverse broad-scale declines in habitats for these above species is: “Identify and conserve remaining large areas of shrub-steppe where ecological integrity is still high” — “Large contiguous blocks of land in the northern Great Basin and Owyhee Uplands are the most obvious sites to consider” (Wisdom et al. 2002). 

A recent analysis of birds and small mammals by Dobkin and Sauder (2004) paints a dark picture of habitat conditions and species declines across public lands, and strongly question the long-term viability of 61 species of birds and small mammals. As the processes of habitat fragmentation and weed and cheatgrass invasion and loss of shrubs described by Billings 1994, Knick et al. 2003, Connelly et al. 2004 and many others advances, reptiles face the same threats and habitat losses – and are in many ways are likely comparable to small mammal biota (much less mobile than birds), and may exhibit the same alarming trends as described by Dobkin and Sauder (2004) for small mammals. Plus, local populations are vulnerable to collection and export. 

Instead of protecting the large core areas of old growth sagebrush and other shrub habitats at lower elevations at Spruce, BLM has very recently acted to greatly fragment and alter them for the sole benefit of privately owned cattle (spending nearly a million dollars largely of taxpayer funds). Now, much-intensified disturbance of remaining old growth communities stemming from a 90-mile pipeline and widespread publication of motorized trails is occurring/is imminent. See Nevada Sage BLM 2004 describing million dollar eradication efforts, see Elko BLM 2004 Spruce Trails EA, Elko BLM NEPA Project lists, 2005 and 2006, and miscellaneous BLM documents).

Instead of proposing to selectively remove trees in pockets of sagebrush at Spruce, BLM proposes highly invasive techniques that will kill mature sagebrush, bitterbrush and other shrubs on these sites  – with long-lasting consequences (Wamboldt et al. 2001, Welch and Criddle 2003).  

Raptors: Golden eagles, along with prey species of black-tailed jackrabbits, and ferruginous hawks still exist in the ACEC. Ferruginous hawks nest on junipers interfacing with old growth Wyoming big sagebrush communities.

Prairie falcons may nest and have been observed foraging in the lands of the ACEC (Fite 2005 field observations) and may use both the salt desert shrub and Wyoming big sagebrush habitats of the ACEC. These provide habitat for raptor species and prey. These species (raptors and prey) are in decline in well-studied areas such as the Snake River Birds of Prey Area due to unrelenting habitat loss and especially exotic species invasions fostered by human disturbances. Fite (2005 and 2006) has observed has observed all three species of accipiters hunting at Spruce – but we are aware of no information on potential nesting.  

Flammulated Owl: Recent HawkWatch (2006) studies of migrating flammulated owls in the Goshute Range to the east document migrating flammulated owls and mention likely residents. We are aware of no efforts to collect information on potential flammulated sites at Spruce. NDOW has recognized this area as important burrowing owl habitat. 

 

Bats: The mountains, and many rugged arid small canyons as well as cavities in old growth pinyon and juniper and mine adits provide habitat for rare or declining special status bat species of growing conservation concern. Existing livestock facilities at Spruce are killing bats that are attracted to the water, and drown. See Fite letter of fall 2005 and e-mail of fall 2006 to Elko BLM documenting drowned bats, and 2006 e-mail re: drowned bats and small mammals in Spruce water troughs.

Not only do the existing water developments and troughs at water haul sites drown bats – disregard in water source placement at Spruce for wildlife and vegetation is evident – with water haul troughs placed right next to old growth or mature stringers of juniper trees, old mountain mahogany, or amid pygmy rabbit habitats – fostering weed invasion and spread. 

Magnificent Microbiotic Crusts

In areas of old growth Wyoming big sagebrush and other shrubs in some areas at Spruce that have not been subject to intensive cattle disturbance due to their remoteness from water sources, and especially in areas such as “Pygmy [rabbit] Valley”, remarkable well-developed microbiotic crusts are present –both as cushions of moss around the base of old sagebrush and as lichens and blue-green algae covering the complexly textured soil surfaces in the interspaces between shrubs. Bunchgrass is very limited – with, apparently, crusts instead being the dominant plant life form in the interspaces between shrubs, and not grasses and forbs. Few if any alien species are present – not even bur buttercup – in sites with minimal signs of disturbance. It is precisely these sites – that BLM destroyed with sagebrush smashing and crested wheatgrass seeding – facilitating halogeton, weedy mustards and cheatgrass. 

Weiss and Verts (1984) recognized that pygmy rabbits disappeared from areas infested with cheatgrass in Oregon. Pygmy Valley and several other sites here with pygmy rabbit sign are characterized by these very well-developed crusts and old sagebrush, with few if any alien species.    

These crusts will be readily destroyed by ANY intensified cattle or motorized use. Weeds now infesting areas of the seedings are likely to now gradually infiltrate the sites with well-developed crust, as seeds are transported by wind. Plus, the bare disturbed soils from the seeding will blow onto the surface of the crusted areas. 

Thus, the remaining magnificent microbiotic crusts at Spruce are greatly threatened by alteration and destruction. 

We also hope that BLM will seek knowledgeable botanical expertise in developing protective management for these sites, as right now range extension agents and others characterize these increasingly rare old growth big sagebrush sites as “decadent” and seek to impose all manner of disturbance on them – to promote livestock forage (even if only weeds) at the expense of all other values. 

Arid Wyoming big sagebrush sites, with minimal grass cover and well-developed crusts (and inhabited by pygmy rabbits) are an ecological community on which we have seen no research or ecological papers – yet they are present in areas that have received little cattle use due to distance from water and lack of forage grass – in the West Little Owyhee of Oregon, too – and there are also threatened by intensive development of fences and water for cattle (Fite 2006 field observations). 

Important Pinyon and Juniper Pygmy Conifer and other Forested Communities

The ACEC contains some very important groves and expanses of unfragmented pinyon-juniper communities that provide habitat for pinyon-juniper dependent avifauna, including species of Continental Importance and regional significance such as pinyon jay and juniper titmouse. Very ancient trees are present in many areas, and contain cavities or areas of rot that may be used by cavity nesters. In higher elevations of the benches and mountain slope areas on coarser soil sites, old growth mountain mahogany is found. 

And Spruce and Valley Mountain indeed have some very small statured ancient very much pygmy-sized trees in the pygmy woodlands here. 

Charlet (1998) describes: The Pygmy Conifer Zone in Nevada refers to the formation of woodlands dominated by short conifers (trees usually no more than 20 ft [7 m] tall) that lie between the Montane and Sagebrush Zones …. What I call Pygmy Conifer woodlands are usually called “pinyon-juniper” woodlands, but most often they are not codominant stands of the same, recurring species. Instead, the woodlands are often pure, or nearly pure, stands of either singleleaf pinyon (Pinus monophylla), or any of four species of junipers: Utah (Juniperus osteosperma), western (J. occidentalis), Rocky Mountain (J. scopulorum), or California juniper (J. californica) …”.

This is separation of species in stands is primarily the case in the lower elevation areas of Spruce, where ancient short-statured junipers extend on small ridges towards the valley floor, tolerating drier sites than pinyon pine (Trimble 1989). Also, see Trimble (1989 at 145), Map of “distribution of pinon-juniper woodland in the Great Basin Desert, (Based on Holmgren, 1972; and Barbour and Major, 1977).   

In many areas, these ancient pygmy trees (which may at times bear signs of very old woodcutting with primitive implements) of the pygmy woodland are dying back. The reality is that trees in many areas on Spruce and Valley Mountain are receding, not invading.

Charlet also states: The elevation limits of the Pygmy Conifer Zone are variable throughout Nevada. The factors determining these elevational limits are complex, and include total annual precipitation, the seasonal distribution of this precipitation, and thermal minima and maxima during both the growing season and the winter.

Plus, the montane forested communities at Spruce provide important habitat for additional species of Continental Importance that inhabit these higher elevation lands.  

Partners in Flight identified species of Continental Importance. Each Bird Conservation Region (BCR) also identified species of regional importance based on global factors as well as threats to breeding populations, population trend, area importance, and population numbers were estimated as a starting point (Rosenberg 2004).  The next step is conservation actions aimed at maintaining or restoring habitats. This goal is very similar to management guidance provided in the Wells RMP, and which Elko BLM has long-ignored. The lands of the ACEC contain habitat for Priority Bird Species identified in the Nevada Bird Conservation Plan (see Rosenburg 2004 at 12-27) for: Forest, Riparian, Shrubland, Cliffs habitats.  

Taken as a whole, the lands of the ACEC includes many habitat types identified for bird conservation needs (and to meet population objectives) of Priority Species in Nevada (Rosenburg et al. 2004), and provide valuable Source habitats for long-term conservation of these species. These habitats are also essential in providing prey for avian species – residents, migrants and wintering birds (see Spruce EA describing important and undetermined pinyon-juniper and other forested wintering habitats).

Recent Pinyon Die-Off Elevates Importance of Protection of Trees

Widespread concern now exists for the loss of pinyon pine over large areas of the American southwest. Across some of the forested areas on the pinyon-juniper benches big sagebrush occurs as an indication of disturbance of forested habitat. Many of the pockets of sagebrush present on the benches have clear signs of fire disturbance having killed trees – including charred stumps, and standing live very old trees. 

Steep and dry south-facing slopes and portions of the high elevation plateau on the north side of Spruce contain what may be climax mountain big sagebrush sites. But many of the other areas on Spruce, as shown by the presence of existing old growth on similar sites – including the ancient dead trees lying on the ground in the neighboring 1962 chaining on identical sites as BLM’s new project areas, as well as historical documentation, very much appear to be forested sites where sagebrush occurs as a dominant species only as the result of disturbance and deforestation events and where it is not the “climax” species.

Unfortunately, the importance of understanding human disturbance events over the past 150 years on sites where it is claimed that significant invasion of pinyon-juniper has occurred, has been overlooked.

Rare Riparian Oases and Pressures on Them

Declining population trends of riparian-associated bird species are tied to losses and diminishment of riparian vegetation. Riparian communities comprise less than 2% of the arid landscape, yet 60 percent or more of migrant landbirds are associated with them. (Saab and Groves 1992). They are under increased pressure from livestock grazing, logging, and recreation (Saab and Groves 1992). Riparian bird species continue to suffer population declines throughout the Intermountain West (Dobkin and Sauder 2004). 

The very rare springs and springbrooks in the ACEC could provide essential insect-rich foraging areas for migrants. Enhancing riparian flows, shrubs and trees and other vegetation will greatly enhance nesting habitats for riparian species at these oases. Unfortunately, nearly all of these oases have been drastically altered by past water developments for livestock. 

Although areal extent of riparian and wetland communities in the Great Basin desert ecoregion is exceedingly small, they are exceedingly important for many species. (Nachlinger et al. 2001, at 132). 80% of birds and 70% of butterflies in the Great Basin are associated with riparian areas (TNC Nachtlinger et al. 2001, at 132, citing Dobkin 1998, Brussard and Austin 1993).  

Wetted areas may be exceedingly scarce, but the potential to support and restore riparian vegetation and habitats may be enhanced with proper and elevated management actions. Unfortunately, many past BLM spring developments or fencing projects in the arid portions of the Wells RMP area have been resounding failures – such as in the neighboring Big Springs allotment.      

Unfortunately, even the fenced and expensive artificial upland wildlife water sources put in place for wildlife use (mule deer, elk)  – the Elko Bighorn trough guzzler) on Spruce Mountain are grazed/trespassed by cattle (Fite 2006 field observations) – demonstrating the need for extra management attention to be focused on any water sources here.

The exceedingly scarce springs in watersheds of the ACEC are of scientific interest and significance. Habitat protection and enhancement through special management will protect these areas. Protection and enhancement encompasses watershed-level actions including addressing livestock impacts, wild horse impacts, roading and diversion for livestock. Overgrazing has caused downcutting, lowering of the water table, sedimentation and overall desiccation and diminishment and degradation of riparian habitat. Abundant scientific literature supports this. See (Platts 1991, Fleischner 1994, Ohmart, 1996, Belsky et al. 1999). 

Continued, often irreparable damage to watersheds will occur without special management attention to ameliorate de-watering by cattle developments, shrinking of areal extent of riparian areas, loss of surface flows, livestock-caused devegetation, down cutting and lowering of water table, sedimentation from livestock grazing, increased OHV use, roading and other activities in uplands, and exotic species invasions. Very small, isolated riparian areas and populations of biota that inhabit them are vulnerable to environmental disturbances and extinction. Harmful impacts of spring developments include diversion, channelization, impoundment (Sada et al. 2001). 

Alteration of riparian and aquatic habitats is caused by trampling from large ungulates (Sada et al. 2001). Livestock grazing or development (sadly, often the combination of both) reduces biological diversity and causes functional changes in riparian and aquatic systems. Intense livestock trampling may “cap” soils and allow cause springs to dry up (Sada et al. 2001). Trampling and grazing impacts on wetted areas and across watersheds result in topsoil loss during rainfall or snowmelt events. 

Political Pressures to Prevent ESA Listing of Sage Grouse Threatens Ecological Integrity and Native Biota at Spruce 

Much of the suitable sage grouse habitat at middle and lower elevations in the Great Basin has been greatly altered by livestock grazing, livestock/fire/livestock/fire, and has been converted to, or is at serious risk of conversion to, cheatgrass and other weeds. Thus, likelihood of enhancing sage grouse habitat there – especially at the landscape level – is minimal – at least without tremendous effort.

Attempts in Nevada and around the West focus primarily on interjecting new disturbance to plant communities at higher elevations – to try to create more sagebrush habitat. Unfortunately, many of the higher elevation sites are in reality in the moisture and climate regime that characterizes pinyon-juniper communities, which are well recognized to grow over a broad range of soil types (Trimble 1989). In many areas, sagebrush may be slow to recover (as shown at Spruce in the old chainings), or dominates only fleetingly/transitorily  – as a result of recent human disturbance (mining, railroad, promiscuous burning for grazing, etc.) to forested/woodland sites.  

It seems to be somehow politically palatable to kill ancient or mature trees critical to many species dependent on them – to promote patchy successional sagebrush rather than reckon with the ecological problem of the rehabilitation of weed-invaded lower and middle elevation sagebrush sites. Donahue (1999), and Connelly et al. 2004 recognize the unfortunate intrusion of politics into public lands management. Designation of an ACEC will help to better shine the light of ecological science, rather than politics, on this very important area.

The dominant shrub in many of BLM’s old chainings and disturbances from 1962 or earlier is still not sagebrush – but instead is rabbitbrush! Thus, radical disturbance such as BLM seeks to impose on this landscape has been shown to greatly reduce for long periods of time the very shrub that BLM claims to want to perpetuate. Rabbitbrush is present in abundance, too, in areas that are obvious old burns.

Political Pressures to Placate Public lands Livestock Industry Drive Deforestation and Sagebrush Manipulation Including Seeding and Thinning Projects

Elk numbers have greatly increased across much of northern and central Nevada – leading to more controversy with the public lands livestock industry. Killing mature and old growth trees (and the old growth Wyoming big sagebrush in the midst of one of the highest known pygmy rabbit sites in Nevada) to create more livestock forage is a politically expedient way for land management and game agencies to placate powerful public lands ranchers. Federal fire funds have provided a new, abundant and near-bottomless source of tax dollars to funnel into these efforts.

Ignored is the fact that big game, especially mule deer and a host of other wildlife species eat pine nuts, seek shelter and escape cover at all times of the year in forested vegetation, and that forested areas often are the ONLY areas where competition for food, cover and space with domestic livestock is somewhat less. Thus, the lower elevation forested areas of Nevada’s arid ranges may often be havens for big game and other wildlife. Juniper is consumed in harsh winter conditions.

Also much ignored at Spruce is the fact that the pygmy rabbit is very likely much more greatly imperiled than sage grouse, due to its very exacting habitat requirements, limited dispersal ability, intolerance of exotic species, and requirements for deep soils and digging and use of burrows  – including shallow natal burrows that are sites for sequestering young, and that are readily destroyed by trampling by thousand pound (half ton) domestic cattle (see Federal Register March 2003 . All the threats – from Oil and Gas development (including at Spruce! Under BLM’s recent Programmatic Oil and Gas EA) to cheatgrass invasion that face sage grouse are faced by the much less mobile burrow-dependent pygmy rabbit. 

Yet, at Spruce BLM found it politically acceptable to destroy some of the highest density pygmy rabbit habitats in order to plant cow food.

Special management attention at the level of an ACEC is necessary to disentangle the many hidden agendas and political pressures being brought to bear on the landscape here – and prevent undue degradation and loss of native biota, protect important and special status species, and provide for sustained yield of forest products including non-traditional forest products, and provide science-based and well-planned cost-effective fire protection for important areas – and to avoid buckling to such pressures that often subvert science in the name of political expediency.

 

Seedings and BLM Management Elevate Fire Danger

The existing weedlands, crested wheatgrass monocultures and crested wheatgrass/cheatgrass/halogeton seedings both new and old, should be a focus of restoration  – and fire prevention – efforts here – especially since these areas may be located near Highway 93, a source of human-caused ignition. The fine fuels in such areas will result in rapid spread of human-caused fires 

Large percentages of lands in southern Idaho, northern and central Nevada and elsewhere in the arid West have been converted to crested wheatgrass seedings or have become cheatgrass monocultures where plant succession is truncated. Such exotic grasslands (and intermingled halogeton or other weed lands) are biological deserts that support few native species. 

In southern Idaho’s Jarbidge Field office, in fact, these exotic seedings – identical to those BLM just undertook at Spruce and the older seedings that are presenting the northern portion of the ACEC, have greatly contributed to large-scale wildfires – as the dry, unpalatable crested wheatgrass – particularly when cheatgrass invades the livestock-disturbed interspaces between grass plants – have fueled huge wildfires – such as the 200,000 acre 2005 Clover wildfire in the Jarbidge that burned primarily crested wheatgrass seedings! Even though these Jarbidge seedings have been subjected to intensive grazing, large fires sweep through them on a regular basis – with another > 50,000 acre blaze in 2006 in a similar setting. The seedings at Spruce pose a special risk, as some are located in close proximity to a major north-south Highway. 

The native Wyoming big sagebrush and black sagebrush at Spruce  – in areas that receive relatively little recent grazing pressure – is characterized by very old shrubs with interspaces and understories largely dominated by microbiotic crust – thus there is little fine fuel to carry fires except in rare circumstances. Unfortunately, the seedings, and concentrations or intensifications of livestock use that results in proliferation of annual alien weeds much elevates fire risk.

In addition, disturbances that open up native shrub and tree communities, and accelerate drying and desiccation of sites, may elevate risks of fire due to increasing site aridity. The role of livestock grazing, woodcutting and other removal of vegetative cover in accelerating drying and desertification processes has been described by Sheridan (1981), Dregne (1986) and others.

Looming Disturbances and Manipulations Pose Serious Risk and Are Fraught with Uncertainty

A broad body of research demonstrates the controversial nature and risks of various disturbances that are to be imposed on Spruce (Lanner 1981, Baker and Shinneman 2003). Several recent articles by Dr. William L. Baker shed new light on the claimed needs on which manipulation proposals are based.

“If restoration of fire … is to be based on sound science, significant methodological hurdles … must first be addressed and resolved … localized site-specific studies are always needed before undertaking restoration … we suggest that before undertaking restoration, managers or scientists date some of the largest trees on a site. If these trees pre-date European settlement, removing or thinning them is inappropriate if restoration is the goal. Trees that pre-date Euro-American settlement represent woodland structure before the impacts of our lands uses, and thus need to be preserved during restoration as is true in other ecosystems (e. g. Friederici 2003)”. BLM’s firebreak and chaining break cutting has already killed trees that pre-date European settlement at Spruce.

We also call BLM’s attention to is own publication: Living with fire: a guide for the homeowner. This publication describes defensible space, limitations of wild land fire control under extreme conditions, and careful and targeted measures to control risk of fire.  

Science-based management based on reasonable, sound and precautionary science that minimizes disturbance, should be the aim of any “treatments” imposed on this fragile landscape. 

Proliferating Motorized Use, Intrusion and Degradation

Values of roadless areas to wildlife and watersheds cannot be overestimated. High road densities are correlated with areas of watershed sensitivity to erosion and sediment transport to streams. Road density is also correlated with the distribution and spread of exotic annual grasses and noxious weeds, and with relatively high risk of human caused fires (USDA/USDI 1996). 

Since World War II, roads have exploded on the American landscape. The scientific literature has overwhelmingly reported serious negative impacts roads have on biodiversity. One consequence of roads and associated human activities is habitat fragmentation, which leads to local extinctions of some species and overall ecosystem degradation. Roads promote the spread of exotic species and are a major source of water pollution causing serious declines in aquatic biodiversity. Roads cause direct mortality of many species and modify animal behavior (Conservation Biology Institute 2000). Wisdom et al. (2002) identified roading as a threat to sage grouse and other species in the Interior Columbia Basin, and recommended implementation of road closures or other management within Source areas. Roads serve as conduits for introduction of exotic weedy species (Gelbard and Belnap 2003). Unfortunately, BLM and others are engaging in promotion of an extensive OHV trail network and greatly expanded motorized use across much of the ACEC landscape. Cattle grazing on roads and trails and in road verges then serve to disperse weeds crosscountry in dung, fur and mud on hooves, plus livestock disturbance of microbiotic crust and vegetation creates ideal sites for infestation and spread of weeds in areas distant from roads (Belsky and Gelbard 2000).   

Incidental creation of new routes and roads that serve as weed corridors through the numerous planned vegetation eradication/treatment projects, OHV use, cattle facility placement and salting practices that destroy woody vegetation and open lands to expanded motorized use.  

Motorized and livestock management activities may conflict with wildlife during sensitive periods of the year (such as raptor nesting), wintering and fawning mule deer, calving of elk, etc – as well as disturb or displace wild horses. Note: While BLM frequently removes horses from eastern Nevada lands, reductions in horse numbers are not paralleled by reductions in cattle numbers or use.

Motorized use is being actively promoted by the ECVA and articles have appeared in OHV magazines. Not only will this activity have a large detrimental impact to native vegetation, prehistoric cultural sites and wildlife, it will also cause new impacts to the historic mining structures and sites in the area.

Increasing populations in Elko, Salt Lake’s Wasatch Front and southern Nevada, as well as the Westwide publicity to lure OHVs and other motorized recreation to Spruce, are resulting in a burgeoning regional recreation boom. Threats to wildlife habitats and scenery/recreation are increasing dramatically. Lands of the ACEC are readily accessible from Interstate 80, elevating threat of expanded motorized use in sensitive areas and wildlife habitats.

Threats to quality of scenic and recreational experiences include: OHV use and increased roading causing disturbance (habitat and behavioral) and population impacts to big game species; Spread of exotic species affecting native species; Livestock disturbance of soils and vegetation. Livestock water hauling and other management activities; BLM water developments that would create new disturbances, de-watering and extending more intense livestock or wild horse use; incidental roading grows up as a result of project construction and maintenance and livestock management activities – such as fencing, pipelines, spring projects, water hauling, or other activities.

Expanded roads and trails are also very likely to develop with Oil and Gas exploration under BLM’s PEA where cross-country exploration activities are authorized on lands at Spruce and surroundings. 

Importance of Pinyon Pine Seeds

Lands of the ACEC are used by both commercial and recreational harvesters of pinyon pine nuts (Fite 2006 field observations). The pinyon pine forests of Nevada are especially important for pine nut production as the trees in the Southwest have suffered large-scale recent die-offs. 

Die-offs of varying extent have also recently occurred in several Nevada ranges (example: ranges in the Battle Mountain BLM District have recently suffered significant pinyon die-off), so the lands of Spruce with a large number of healthy mature pine nut-producing trees for dependent avifauna and other wildlife are regionally significant.

Not only are pinyon pines suffering die-off, but whitebark pine, a staple of the Clark’s nutcracker, are also dead or dying in many areas of the Intermountain West. Thus, the pinyon pines of the Spruce and Valley area and northeastern Nevada as a whole – are of increasing significance to the Clark’s nutcracker, also. 

Global climate change processes are causing mortality of many of the West’s conifers, and the proposed waste and destruction of forested lands at Spruce must be examined in this context, also.   

The old growth and mature pinyon pine at Spruce and Valley Mountain provide a source of pine nuts for human consumption – and the ability of such lands to produce pine nuts may exceed the economic value of the livestock produced on these lands. 

The great majority of the pine nuts consumed in America (80%) are imported, including from China. See www.pinenut.com/noha.htm Sarashkin and Gold, 2004 “American Pinon Pine Nuts: an important Use for Public Lands?”, This import often results in inferior quality, chemically-treated nuts, and adds to the trade imbalance currently facing America. Also, www.pinenut.com/about.htm, including:  “pinyon nuts 28 times more earth efficient in terms of protein produced per acre”; pine nuts at least 148 times more profitable than beef in terms of public lands grazing”. 

In seeking to kill mature and ancient trees in the magnificent forested landscapes of Spruce and Valley Mountain, by highly invasive, destructive and outrageously expensive tree-killing techniques, BLM has ignored the important forest product values of these lands.   

Remaining old growth and mature trees at Spruce and Valley are greatly threatened by multi-million dollar unselective and highly invasive BLM tree eradication efforts (chaining, burning and mastication) that treat the trees as weeds to be destroyed and wasted, rather than as a forest where careful collection and harvest of forest products may occur. 

Careful and sound science-based and precautionary forestry methods to protect the health of trees, as well as in designing any fire-reducing “treatments” is necessary to protect this landscape. 

Right now, BLM has elevated the risk of insect infestations by cutting miles (likely dozens of miles – site observations from walking around 8-10 miles of these strips) of trees around the proposed chaining areas, plus the greater than 3 miles of cut strip cut on the eastern and northern margin of the fire area, and leaving the cut wood on the ground to attract insects that may infest neighboring trees, which include old growth, or mature pines.      

Special management attention is needed just to address the harms that have already occurred here. 

Potential Loss of Bald Eagle Roost Site at Spruce

In response to recent publicity on Spruce, professor Debra Donahue from the University of Wyoming who had worked in the Wells BLM area informed me by e-mail today of the following: “there was a bald eagle roosting area on Spruce Mountain (SW portion, as I recall) that we identified.  Eagles overwintered in the area.  They fed largely on (roadkilled) jackrabbits.  One of their daytime loafing and hunting areas was a gravel pit in Butte Valley.  We also mapped these sites—the gravel pit and the roost sites”. 

BLM has failed to provide an explanation for the management shortcomings that caused the loss of the eagle roost site during its management in recent decades.  If eagles here were subsisting on road-killed jackrabbits, then purposeful destruction of thousands of acres old growth Wyoming big sagebrush inhabited by jackrabbits as well as pygmy rabbits, certainly may have led to the demise of the wintering population here. 

Professor Donahue also communicated that a survey she conducted while working in the Wells area in the 1980s detected an antelope trap at this locale. While Wyoming BLM (see earlier Weblinks) appears to have undertaken special efforts to protect such sites, it appears that there is no management plan or special designation or concerted effort in place to protect the fragile and irreplaceable Spruce and Valley sites.    

ACEC DESIGNATION IS ESSENTIAL TO ADDRESS MULTITUDE OF CHRONIC AND NEW THREATS

Many Threats and Change Agents for the many Relevant and Important Values of the ACEC have been described above. These include livestock grazing depletion and weed spread in over-allocated lands, livestock management activities and practices, new livestock developments and facilities despite many past projects having failed, publicized and expanded motorized use and OHV damage and roading, oil and gas leasing under the Elko PEA, other growing recreational uses and other activities that might disturb wildlife during sensitive periods of the year (such as raptor nesting, pygmy rabbit young n shallow readily collapsible natal burrows, wintering big game, wintering migratory  birds). Degradation of habitats of special status wildlife species and native plant communities may be particularly great.

The ecosystemic threat posed by of invasive species in the wake of new or aggravated disturbance to soils and vegetation here cannot be over-emphasized, with weeds spreading at dramatic rates (Quigley and Cole 1997). Livestock and roading are a key factor in infestation and spread of exotic species. See Belsky and Gelbard (2000), “Livestock Grazing and Weed Invasions in the Arid West”. This report contains an extensive bibliography of sources that document the role of livestock in causing and exacerbating the invasion of nonindigenous plant species in arid lands. 

The overall impact of invasive species, livestock grazing disturbance, altered fire frequencies related to livestock grazing and weeds, livestock facilities and management activities, unregulated OHVs and other motorized activity, and other human disturbances increased habitat fragmentation. 

The impacts of habitat fragmentation have been studied across the world, and the results are predictable (Soule 1999). Area effect, edge effect, isolation and distance effect, rarity effect, disturbance dynamics, scale effects, and the effects of keystone species are all well understood. All argue for the special management and protection of land at the landscape level — and not in tiny fragments or remnants.

Degraded conditions often exist on public lands exist because BLM has been reluctant, and often politically thwarted, in attempts to do necessary and pro-active management on public lands. The designation of the ACEC will enable BLM to direct special management attention to protection and enhancement of regionally and nationally significant values associated with these lands. Responsibility, precautionary management and vision – not politics – must drive this management.

The realization that much of the shrub habitat in the Intermountain West – especially the lower elevation big sagebrush communities – has been altered, converted to agriculture, developed, or impaired with non-native plants is the driving force behind the identification of sagebrush and shrub ecological communities as high priority targets (See TNC Owyhee Canyonlands  – Conservation Focus 1999).  Saab and Rich (1997), as well as Paige and Ritter (1999), Wisdom et al. 2002) stress the high priority need for conservation focus on these habitats. Thus, ecological values of the intact shrub ecosystems that provide core habitat for pygmy rabbit, sage sparrow, and other declining species in the ACEC are of clear regional significance, and may merit national recognition. The old growth Wyoming big sagebrush communities inhabited by high densities of pygmy rabbit (BLM Spruce EA 2005), high densities of sage sparrows (Fite May 2005 Field observations) are in critical need of protection and special management attention. 

Recent extensive die-off of pinyon in the Southwest has elevated the importance of protecting large tracts of pinyon-juniper habitat in Nevada for the pinyon jay and other forest avifauna, and the lands here are significant regionally and globally.

The area provides critical winter range habitat for big game animals – and regionally significant habitat for raptors, and sagebrush-obligate species. The lands are increasingly used for recreational pursuits, and are threatened by livestock grazing practices, levels and facilities, and weed invasions linked to both grazing and roading. Increased human uses in the absence of modern-day land management guidance and planning pose significant threats to wild landscapes and native biota. Significant environmental harm may result from unregulated OHV, expanded roading and other uses. Designation of an ACEC will allow for restoration of damaged or degraded vegetation communities, and re-connected habitats within the landscape.

ICBEMP describes Risks and Opportunities to shrub-steppe habitats (and the same processes apply to these Great Basin Spruce-Valley ACEC lands): 

• Primary risks to ecological integrity are:

1. Continued declines in herbland and shrubland. 

• Dry shrubland highly sensitive to overgrazing and exotic grass and forb invasion. 

 * Primary Opportunities to Address Risks to Integrity include: 

1. a) Containment of exotic weed expansion
2. b) Maintenance restoration of riparian conditions
3. c) Management of grazing intensity, duration, and timing.

The Partners in Flight Landbird Conservation Plan (Rich et al. 2004) provides relevant Recommended Management Actions for the Intermountain region including: 

Retain large tracts of pinyon-juniper; ensure seed supply of seed-producing pinyon pine; Maintain/promote growth of native grasses and forbs in shrub-steppe, prevent large-scale wildfire, restore with native plants following disturbance. Maintain water quality and quantity and vegetation in embedded springs, seeps and riparian areas. Restore degraded habitats and habitats that have been converted to non-native grasslands. 

Designation of the ACEC will:

• Protect food and habitat for wildlife and the quality of scientific, cultural, recreational, scenic, ecological, water, soil, vegetation, and other resources. 
• Conserve and protect important and sensitive animal species, and better enable management to prevent plant and animal populations from becoming threatened or endangered. 
• Protect habitat for avian species of Continental Importance, and of Regional Importance, especially pinyon-juniper dependent species, and lower elevation sagebrush-dependent species.

• Protect and enhance the exceedingly scarce wetlands and riparian habitat. Coordinate management on a watershed or ecosystem basis
• Increase protection for unroaded lands and habitats of wildlife during sensitive periods of the year; limit or reduce impacts of exiting roads.
• Protect sensitive environmental areas from degradation and enhance them. 
• Protect significant examples of amazingly small-statured and very old juniper and pinyon-juniper communities, and groves of very ancient pinyon-juniper on benches, as well as the old growth mountain mahogany and montane forests at higher elevations.

We hope to work with a receptive, rather than an antagonistic, BLM and other agencies to refine ACEC boundaries and develop management criteria and actions to protect the many Relevant and Important/Significant values of the ACEC and further, address the myriad threats/change agents faced by these very significant wild lands, and as described in this Nomination and Evaluation. We also urge BLM to undertake inventories and review records to protect cultural values at the landscape level, and nominate high value Cultural sites and the Spruce locale as a whole as suitable for inclusion in the National Register.

As the information presented above shows, the ACEC meets the Relevance and Importance Criteria for ACEC designation, and has High Old Growth, Scenic, Special Status Animal Species Habitats, Species Diversity, Important Cultural Locales, Regional and National Significance, is very Vulnerable to Adverse Change, and has recently undergone significant adverse change and fragmentation due to livestock forage seeding destruction of big sagebrush communities and their replacement with flammable fine fuels, chaining of ancient very short-statured juniper and pinyon pygmy woodlands, cutting of dozens of miles of chaining boundary without regard for proper forestry practices, and other disturbances.

Relevant Literature 

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Anderson, Jay E. and Richard S. Inouye.  2001.  Landscape-scale changes in plant species abundance and biodiversity of a sagebrush steppe over 45 years.  Ecological Monographs 71(4): 531-556. 

Baker, W. L. 2006. Fire and restoration of sagebrush ecosystems. Wildlife Society Bulletin 34 (1):177-185. 

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