IBLIM ILI BRARY in s 80677 CC OO u.s. Department of the Interior Bureau of Land Management Vale District Office April 2001 Malheur and Jordan Resource Areas Proposed Southeastern Oregon Resource Management Plan and Final Environmental Impact Statement Volume 3 (of 3) - Comment Responses and Reprinted Letters As the Nation’s principal conservation agency, the Department of the Interior has responsibility for most of our nationally owned public lands and natural resources. This includes fostering the wisest use of our land and water resources, protecting our fish and wildlife, preserving the environmental and cultural values of our national parks and historical places, and providing for the enjoyment of life through outdoor recreation. The Department assesses our energy and mineral resources and works to assure that their development is in the best interest of all our people. The Department also has a major responsibility for American Indian reservation communities and for people who live in Island Territories under U.S. administration. BLM Library Denver Federal Center BP.lOd8. uB°ox’ ?255004477 BLM/OR/W A/PL-01/016+1972 Public Disclosure Notice: Comments, including the names and addresses of respondents, will be available for public review at the Bureau of Land Management office address listed on the front cover of this document, during regular business hours, Monday through Friday, except holidays. Individual respondents may request confidentiality. If you wish to withhold your name or street address from public review or from disclosure under the Freedom of Information Act, you must state this prominently at the beginning of your written comment(s). Such requests will be honored to the extent allowed by law and recent court decisions. All submissions from organizations, businesses, or individuals identifying themselves as representatives or officials of organizations or businesses, will be made available for public inspection in their entirety. frS'025%HO HO Comment Responses and Reprinted Letters .07 Volume 3 s“81 _ T-ool Comment Responses v.3 and Reprinted Letters L Proposed Southeastern Oregon Resource Management Plan and Final E1S Abbreviations and Acronyms Reader note: Refer to the list below for GMA ~ geographic management area ORV ~ outstandingly remarkable value abbreviations or acronyms that may have GTR ~ green tree replacement OWFEIS ~ “Oregon Wilderness Final been used in this chapter. HA ~ herd area Environmental Impact Statement” HMA ~ herd management area OWS ~ occupancy with stipulations ACEC ~ area of critical environmental HMP ~ habitat management plan PFC ~ proper functioning condition concern HUC ~ hydrologic unit code PILT ~ payments in lieu of taxes ADC ~ animal damage control ICBEMP ~ Interior Columbia Basin PNC ~ potential natural community AML ~ appropriate management level Ecosystem Management Project PP&L ~ Pacific Power and Light AMP ~ allotment management plan IMP ~ “Interim Management Policy” ' PSEORMP/FEIS ~ “Proposed Southeast¬ AMR ~ appropriate management IMPLWR ~ “Interim Management Policy ern Oregon Resource Management Plan/ response for Land under Wilderness Review” Final Environmental Impact Statement” APHIS ~ Agricultural Plant and Animal INFISH ~ “Inland Native Fish Strategy” PRIA ~ “Public Rangelands Improvement Health Inspection Service JRA ~ Jordan Resource Area Act” ARA ~ Andrews Resource Area KGRA ~ known geothermic resource PUC ~ Public Utilities Commission ATV ~ all-terrain vehicle area RAIDS ~ riparian aquatic information AUM ~ animal unit month LCDC ~ Land Conservation and data system BA ~ biological assessment Development Commission RAWS ~ remote automated weather BIA ~ Bureau of Indian Affairs LGMP ~ "Leslie Gulch ACEC Manage¬ station BLM ~ Bureau of Land Management ment Plan" RCA ~ riparian conservation area BMP ~ best management practice MFP ~ management framework plan RMO ~ riparian management objective BO ~ biological opinion MOU ~ memorandum of understanding RMP ~ resource management plan BOM ~ Bureau of Mines MRA ~ Malheur Resource Area RNA ~ research natural area BOR ~ Bureau of Reclamation NCA ~ national conservation area ROD ~ record of decision BPA ~ Bonneville Power Administration NEPA ~ “National Environmental Policy ROS ~ recreation opportunity spectrum CERCLIS ~ comprehensive environmen¬ Act” RPS ~ rangeland program summary tal response. Compensation and Liability NHOT - National Historic Oregon Trail RS ~ “Revised Statutes” Information System NHPA ~ “National Historic Preservation R&PP ~ recreation and public purpose CEQ ~ Council on Environmental Act” SCORP ~ Oregon’s “Statewide Compre¬ Quality NL ~ no leasing hensive Outdoor Recreation Plan” CFR ~ “Code of Federal Regulations” NOAA ~ National Oceanographic and SEORAC - Southeastern Oregon CLCAS - “Canada Lynx Conservation Atmospheric Administration Resource Advisory Council Assessment and Strategy” NPS ~ National Park Service SEORMP ~ “Southeastern Oregon CRMP ~ “Cultural Resources Manage¬ NPSP ~ nonpoint source pollution Resource Management Plan” ment Plan” NRCS ~ Natural Resources Conservation SHPO ~ State Historic Preservation CWA - “Clean Water Act” Service Office DLCD ~ Department of Land Conserva¬ NRHP ~ National Register of Historic SMA ~ special management area tion and Development Places SMCMPA ~ Steens Mountain Coopera¬ DOD ~ Department of Defense NSO ~ no surface occupancy tive Management and Protective Area DOE ~ Department of Energy NWSR ~ national wild and scenic river SRMA ~ special recreation management DOGAMI ~ Oregon Department of NWSRA ~ “National Wild and Scenic area Geology and River Act” SRP ~ special recreation permit Mineral Industries NWSRS ~ National Wild and Scenic S&G’s ~ “Standards of Rangeland Health DOI ~ Department of the Interior River System and Guidelines for Livestock Grazing DPC ~ desired plant community OAR ~ “Oregon Administrative Rules” Management” DRFC ~ desired range of future condi¬ OBSMP ~ “Oregon’s Bighorn Sheep TGA ~ “The Taylor Grazing Act” tions Management Plan” TMDL ~ total maximum daily load EA ~ environmental assessment ODA ~ Oregon Department of Agricul¬ TNC ~ The Nature Conservancy EIS ~ environmental impact statement ture TNR ~ temporary nonrenewable grazing EPA ~ Environmental Protection Agency ODEQ ~ Oregon Department of Environ¬ T&E ~ threatened and endangered ER ~ entrenchment ratio mental Quality USDA ~ U.S. Department of Agriculture ERMA ~ extensive recreation manage¬ ODF ~ Oregon Department of Forestry USDI ~ U.S. Department of the Interior ment area ERU ~ ecological reporting ODFW ~ Oregon Department of Fish and USFS ~ U.S. Forest Service unit Wildlife USFWS ~ U.S. Fish and Wildlife Service ESA ~ “Endangered Species Act” ODOT ~ Oregon Department of Trans¬ USGS ~ U.S. Geological Survey ESI ~ ecological site inventory portation VRM ~ visual resource management E/EIS ~ “Eastside Environmental Impact ODPR ~ Oregon Department of Parks WAFWA ~ Western Association of Fish Statement” and Recreation and Wildlife Agencies FAA ~ Federal Aviation Administration ODSL ~ Oregon Division of State Lands WFSA ~ wildland fire situation analysis FERC ~ Federal Energy Regulatory OHV ~ off-highway vehicle WRCS ~ “Western Regional Corridor Commission ONA ~ outstanding natural area Study” FLPMA ~ "Federal Land Policy and ONHP ~ Oregon Natural Heritage WSA ~ wilderness study area Management Act” Program WSRO ~ “Wilderness Study Report, FMP ~ fire management plan ONHTMP ~ “Vale District Oregon Oregon” FWFMP ~ “Federal Wildland Fire National Historic Trail Management WQMP ~ “Water Quality Management Management Policy” Plan” Plan” GIS ~ geographic information system ORS ~ “Oregon Revised Statute” WQRP ~ water quality restoration plan Comment Responses and Reprinted Letters Table of Contents Volume 3 Comment Responses. 1 Introduction . 1 Comments Regarding Andrews Resource Area. 1 Plan Format. Alternatives in General. 2 Miscellaneous Comments. 6 Plan in General. 6 Personal Response. Ecological and Natural Values. .. 12 Military and Non-military Aircraft. .. 13 Other. .. 14 Air Resources. .. 15 Energy and Minerals. .. 15 Fire . .. 17 Forest and Woodlands. .. 20 Rangeland Vegetation. .. 23 Special Status Plants. .. 37 Wildlife . .. 39 Special Status Animals (Terrestrial). .. 48 Special Status Animals (Aquatic). .. 54 Water/Riparian. .. 55 Monitoring and Studies. .. 55 Riparian Management. .. 58 Other Riparian Area Comments. .. 61 Plan-Specific Comments. .. 61 Fish and Aquatic . 66 Wild Horses . . 68 Grazing . . 70 AUM Allocation Comments. . 76 Grazing Standards and Guidelines and Best Management Practices. . 78 Comments Supporting Grazing. . 80 Problems or Deficiencies of Plan Alternatives, Rationale, Objectives, and Others Other Comments. . 81 Recreation . . 92 Winter Use on Steens Mountain. . 92 Promote Naturalness. . 92 Recreation Facilities. . 94 Access/Roads/Transportation. . 94 Miscellaneous. . 95 Off-Highway Vehicles. . 97 Visual Resource Management. 103 Wilderness Study Areas. 104 Wild and Scenic Rivers. 107 General . 107 Donner und Blitzen River. 110 Special Designations. 111 ACEC/RNA’s. 111 National Conservation Area. 120 Human Uses and Values. 121 Cultural Resources. 123 Land and Realty. 125 Specific Sites. 127 Other Comments. 133 Reprinted Letters. 137 Proposed Southeastern Oregon Resource Management Plan and Final EIS Comment Responses and Reprinted Letters Comment Responses Introduction In October 1998, the Bureau of Land Management (BLM) opened a 120-day comment period to allow public evaluation of the Draft Southeastern Oregon Resource Management Plan/Environmental Impact Statement (SEORMP/EIS). At the request of BLM, all public comments were received in writing—266 letters through conventional and electronic mail, 14 of which were received after the deadline, but were included in the content analysis. A team of staff, most of whom were not involved with the Draft SEORMP/EIS, consolidated the comments from the 266 letters received into a “Summary of Public Comments” report. The purpose of this analysis was to objectively identify and display the nature and extent of the public input received on the draft plan. The report summarized opinions and supporting reasons contained in the public input and how they differed according to other variables that may be important, such as respondent’s affiliation, place of residence, or other factors. This report was made available upon request in April, 1999. The SEORMP Interdisciplinary Team used the “Summary of Public Comments” report as a template to respond to substantive comments. Comments on like issues were summarized and paraphrased by the team; however, each specialist also read each letter to better define the context surrounding the comments. All letters received are displayed following the agency’s response to specific comments, and have been assigned an identification number in the upper right hand corner. These identification numbers also appear in each section of the comment analysis to indicate where the comments came from. Each section also identifies opinion or preference comments that are important but that do not lend themselves to a specific response. These opinions were considered, however, while preparing the PSEORMP/FEIS. Numbers of comments are presented in both Inputs (I) and Signatures (S): for example; if three people signed one letter the tally would be 1=1 and S=3. Each comment and response is also numbered for easy reference. Some letters were official positions of governments, groups, companies, or organizations who represented a large constituency. A summary of public comments, as well as changes made to the plan as a result of those comments, is included in the beginning of Chapter 3. Comments Regarding Andrews Resource Area In October 2000, the “Steens Mountain Cooperative Management and Protective Act” (H.R. 4828) was signed by President Clinton. This legislation created far different management for the Andrews Resource Area (ARA) than the Draft SEORMP/EIS had analyzed. Therefore, it was determined that the ARA should be extracted from the PSEORMP/FEIS. All of the letters commenting on the Draft SEORMP/EIS are published; however, since the ARA has been removed from the plan, the comments specific to the ARA do not have a written response. Some comments are inclusive of ARA, or allude to all three resource areas, and have been responded to. All comments regarding ARA will be carried forward to the scoping process for the “Steens Mountains/Andrews Resource Area Resource Man¬ agement Plan. ” Proposed Southeastern Oregon Resource Management Plan and Final EIS Comment Responses Plan Format No. I S 1 1 1 Comment: Table of Contents and body of report are not properly marked with section number. Response: This has been corrected in the final plan. Opinions or Preferences 1 1 Suggest that goals on Page 3-1 be included in Purpose and Need section. 1 1 A chapter for each resource would make the document easier to read. 1 1 Page headings should include the topic discussed on that page. LETTER NUMBER: 004.240,241 Alternatives in General No. I S 2 146 155 Comment: Commentors favor strengthened Alternative D that more greatly restricts or excludes livestock grazing. Reasons: because livestock should be excluded from riparian areas because livestock should be excluded from fish and wildlife habitat; because livestock should be excluded from national wild and scenic rivers(NWSR’s); because livestock should be excluded from grazing allotments in fair and poor condition; because livestock should be excluded from wilderness study areas (WSA’s); and because livestock should be excluded from areas of critical environ¬ mental concern (ACEC's). Response: Alternative D2 was added to the analysis to cover most of the recommended exclusion areas. Alternative D2 does not include livestock exclusion from allotments in fair to poor condition or from WSA’s because we felt this would move Alternative D2 too close Alternative E. When livestock are found to cause degradation of resource conditions in WSA’s, rangelands in poor or fair condition or anywhere else, management is changed to correct and reverse the degradation which could include exclusion. 3 Comment: 57 62 • Commentors said that BLM should reject Alternative C. Reasons: fails to reduce grazing when damage occurs; Does not protect sensitive fish and wildlife habitat and habitat diversity; fails to designate enough NWSR miles; fails to stop grazing on Donner and Blitzen and Owyhee NWSR's; 2 Comment Responses and Reprinted Letters does not adequately reduce livestock grazing on Steens Mountain; does not protect riparian; allows to much off-highway vehicle (OHV) use; relies on adaptive management; fails to change current conditions and management practices enough even though public lands are not adequately protected/restored; fails to stop livestock grazing when scientists recommend otherwise; fails to describe activities allowed in Steens National Conservation Area (NCA); because it puts livestock industry over public concerns and land health; fails to stop grazing in WSA’s; fails to consider ecosystem-based management principles; fails to discontinue grazing in AC EC’s; needs stronger standards and guidelines and monitoring; high desert lands are too fragile; fails to reduce suppression of wildfire; seriously degrades ecosystem; increases spread of weeds through OHV use; and alternative is too similar to Alternatives A and B; Southeastern Oregon Resource Advisory Council (SEORAC) could not choose; prefers to address individually and failed to reach a consensus. 31 32 • Commentors favor Alternative D. Reasons: allows for livestock grazing reductions; adds NWSR’s; adds ACEC’s and research natural areas (RNA’s); emphasizes low impact recreation; deemphasizes fire suppression; better for stream/riparian which need protection; more closely embraces ecosystem-based management; restores/closes recreation sites; helps land to recover from past degradation; less alteration of vegetation; best compromise between livestock industry and other resources; better for nongame wildlife; better for hunting, fishing, and other publics; better protects scenic values; and reduce grazing on Alvord Desert and Steens Mountain. 3 3* Reject Alternative A. Reasons: does not adequately protect public land resources; is not a realistic alternative; and outside law on the “Endangered Species Act’’ (ESA) and “Wilderness Act. ” 3 Proposed Southeastern Oregon Resource Management Plan and Final EIS 2 2 • Reject Alternative B. Reasons: does not adequately protect public land resources; and allows too much livestock grazing. 1 1 • Support Alternative E. Reasons: opposes abuses of public land resources. % 1 1 • Reject Alternative E. Reasons: Is not a realistic alternative; too little intervention can damage environment; too unresponsive to the need of land; too unresponsive to the needs of public; some livestock grazing is good; and does not allow prescribed burns. 1 1 • Support Alternative A. Reasons: supports liberty and welfare of country. 5 5 • Alternatives are inadequate. Reasons: not enough range of alternatives; will lead to demise of southeastern Oregon desert lands; needs to explore severe cuts in grazing; Alternative A has no counter balance; and need restoration before Alternative D can be implemented. Response: Commentors liked or disliked the specific alternatives for various reasons. Alternative D2 was added and Alternative E was made more realistic to provide greater variety of potential management direction toward limiting commodity uses. The Proposed RMP represents a mix of the alternatives that prescribes public land management in a manner that best meets the needs of the greatest number of public land users. 4 22 23 Comment: Manage the land for everyone, not just ranchers. Response: The Proposed RMP is primarily a mix of Alternatives C and D. Ranchers would have benefitted most from selection of Alternative A. 5 2 2 Comment: Need increased monitoring and enforcement of livestock grazing on Steens Mountain. Response: Refer to Comments Regarding Andrews Resource Area on page 1. 6 3 8 Comment: BLM does not evaluate a reasonable range of alternatives. Response: See comment response 2. 4