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(IRC) ROBERT (BOB) SCHWEIGERT, INTERMOUNTAIN RANGE CONSULTANTS

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RESPONSE TO COMMENTS FROM IRC Response to IRC1: Each of these sections complements the other. The environmental consequences section describes the effects of livestock grazing on a resource area known to occur from this activity and supported by the best available science. The EIS must disclose all known and likely effects as required by NEPA. Efforts have been made in the FEIS to provide a better contrast between existing condition and the potential effects of the activities being proposed under the alternatives. Response to IRC2: See response to IRC1. Response to IRC3: The DEIS has sufficient detail to allow the reader to put the data displayed in this section into its proper perspective. The DEIS provides a table that individually names approximately 50 major streams in the project area. The DEIS states that 20 water samples were taken and provides a table with the results of those samples and a map indicating the surface water sampling locations. The DEIS also acknowledges there are over 300 seeps and springs in the project area. Response to IRC4: Current condition is one component of the stated purpose and need. There is also the need to update our grazing management to incorporate the best available science. Current management includes only within season triggers. Alternative 2 employs end of season utilization measures to be employed in conjunction with within season triggers designed to ensure that the end of season measures are achieved. Both the end of season and within season utilization levels are consistent with the within season triggers established in Amendment 2 of the Forest Plan. Additional information on the direction provided by Amendment 2 has been included in chapter 1 of the FEIS. These end of season levels were developed from a review of the best available science and should ensure the maintenance of desired conditions and the improvement of less than desired conditions in the project area. Response to IRC5: The Forest has decided to analyze multiple allotments in this decision, but current conditions and specific management are decided at the allotment level. Alternative 4 was analyzed for content and was found in some ways to be similar to Alternative 2. It was not carried forward as the important components of Alternative 4 were represented in Alternative 2. Alternative 4 and Alternative 2 both rely on a set of livestock grazing activities to respond to conditions on the ground. Appendix D of the DEIS lists many of these activities. To that extent, Alternative 4 is a duplication of Alternative 2. The adaptive management process in Alternative 4 is different from Alternative 2. Alternative 2 describes specific adjustments based on specific conditions and describes how those conditions will be determined. This process is consistent with the agency’s regulations found at 36 CFR 220(e)(5). Alternative 2 analyzed the effects of these predetermined adjustments. Alternative 4 does not commit to this level of specificity, which makes it impossible to analyze the effects that may occur. It is not sufficient to say if things are not going the way we want them to, then we will figure out a new course of action that will lead to improvement. Response to IRC6: The purpose and need guided the development of and support Alternative 2 (the Proposed Action Alternative). An EIS is being prepared because domestic livestock grazing has the potential to cause a significant impact to the environmental resources in the project area, not because of the size of the area. None of the measures proposed in the DEIS conflict with the Forest Plan. Response to IRC7: The DEIS proposed changes that are consistent with Forest Plan direction. These changes represent the best available science for managing rangelands in a sustainable ecological condition that will benefit all resources.

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There is no proposal in the DEIS to change the applicability of Amendment 2 of the Forest Plan. The utilization standards set in Amendment 2 are within season measurements that trigger the movement of livestock from the area being grazed. These triggers remain in effect under both action alternatives. Alternative 2 employs end of season utilization levels designed to leave the grazed areas with an appropriate level of residual vegetation at the end of the season. To ensure that the end of season levels are achieved, within season triggers have been identified under Alternative 2. Additional information on the direction provided by Amendment 2 has been included in chapter 1 of the FEIS. Under Alternative 2, maximum end of season utilization levels and within season triggers are set based on the habitat group’s ecological condition. The utilization levels and within season triggers are designed to ensure that the condition of the habitat group is maintained if it is in functioning ecological condition and improved if it is in functioning-at-risk or non-functioning ecological condition. Alternative 2 mandates lower end of season utilization levels and within season triggers if the habitat group is not in functioning ecological condition. These lower levels are the maximum amount of utilization that would be authorized for that ecological condition, but lower levels can be authorized if warranted. Other management actions could also be taken to improve or maintain conditions. Response to IRC8: The Forest recognizes that each allotment and its management concerns are unique. With regard to determining ecological condition, each allotment was analyzed by itself, and its management adjusted to reflect that analysis. Response to IRC9: The Amendment 2 utilization standards represent the maximum utilization allowable before livestock must be moved. Amendment 2 specifically states:

The maximum utilization levels would normally be used only where the plant community is at or near the desired future condition.

Accordingly, the Forest may, at its discretion and as needed for resource protection, enact more restrictive levels of utilization. Additional information on the direction provided by Amendment 2 has been included in chapter 1 of the FEIS. See also response to IRC7. Response to IRC10: See response to IRC4. Response to IRC11: Current management does have the necessary flexibility to address resource problems at the site-specific level; this can be done in the annual operating instructions. However, documentation from the district that this has occurred on a consistent basis is lacking. Alternative 2 provides for some of the adjustments to grazing management to be more predictable and transparent to the permittee and interested members of the public. Response to IRC12: Restoration projects designed to address a site-specific resource need/concern are not covered under either action alternative and would require additional environmental analysis to implement. Response to IRC13: See response to IRC7. The DEIS proposed changes are consistent with Forest Plan direction and represent the best available science for managing rangeland in a sustainable ecological condition that will benefit all resources. A review of the best available science has shown that current management standards for riparian areas are not adequate and that they do not meet the purpose and need outlined in the DEIS. Response to IRC14: See response to IRC3.

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Response to IRC15: The DEIS proposed changes are consistent with Forest Plan direction and represent the best available science for managing rangeland in a sustainable ecological condition that will benefit all resources. The Martin Basin DEIS is one of a number of range management NEPA projects that will consider whether to authorize grazing on the Humboldt-Toiyabe National Forest and, if so, under what conditions. Amendment 2 will continue in effect on the Humboldt portion of the Humboldt-Toiyabe National Forest. Additional information on the direction provided by Amendment 2 has been included in chapter 1 of the FEIS. Proper use criteria (such as utilization, streambank disturbance, soil disturbance, compaction, etc.) for subsequent projects will be tailored to the individual project areas. Similar utilization levels may be proposed in the other projects with the exception of some site-specific standards (e.g., winter grazing). The cumulative effects discussion for the Martin Basin analysis was limited to the Santa Rosa District, which is appropriate under NEPA. Response to IRC16: The NEPA and Forest Service directives require a reasonable range of alternatives, one of which must be the "No Grazing" Alternative. This is true even if the “No Grazing” Alternative would not meet the purpose and need for the project. Response to IRC17: The DEIS includes a reasonable range of alternatives, as discussed in response IRC5. Not all alternatives considered in the range of alternatives must be considered in detail in the environmental impact statement document. Alternative 4 was considered. Alternative 2 covers all of your suggested edits to Alternative 4. Response to IRC18: The DEIS is consistent with the Forest Plan in that it addresses the Forest Plan desired conditions, proposes new management standards that help meet those stated conditions, and uses the best available science to obtain them. See response to IRC7. Response to IRC19: Actual utilization reports are limited for the project area. To provide a better picture of current utilization levels, a 3-year summary of the AOIs for each allotment has been included in appendix C to the FEIS. This appendix displays utilization levels that have been authorized in recent years. Amendment 2 establishes utilization standards that operate as within season triggers for the movement of livestock. Amendment 2 does not contain an end of season indicator with regard to utilization. While the Amendment 2 standards may be appropriate for use as within season triggers, a review of the best available science indicates that allowing these levels of use as end of season indicators would lead to resource problems or inhibit recovery. Response to IRC20: The DEIS is consistent with the Forest Plan in that it addresses the Forest Plan desired conditions, proposes additional management criteria that help meet those stated conditions, and uses the best available science to obtain them. Response to IRC21: The DEIS is consistent with the Forest Plan in that it addresses the Forest Plan desired conditions, proposes additional management criteria that help meet those stated conditions, and uses the best available science to obtain them. The Matrices address the current ecological condition; the information gathered uses standard Forest Service methodologies and is repeatable, so over time will address trend. The Matrices is an assessment tool that considers the data gathered using standard Forest Service methodologies. Those studies can be repeated, providing an opportunity to determine trend. The Matrices only determines ecological condition. This project then associates proper use criteria to those ecological conditions. For this project, utilization measured at the end of the season was chosen as the proper use criteria. Alternative 2 requires proper use criteria adjustments based on ecological condition, but many other livestock management activities remain discretionary based on individual situations.

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Response to IRC22: Livestock grazing can have impacts on the spread or control of weeds. Additional information has been included in the FEIS to describe the relationship between livestock grazing and weeds. The identification of noxious weeds on a pasture allows the district to plan for treatment and assists in adjusting annual operating instructions to address the problem. Response to IRC23: As disclosed in the DEIS, understory species composition would be the issue with degraded conditions for aspen stands in the project area (page 129, 133-134). When there is a noticeable shift from herbaceous to woody species, livestock need to be moved. The best available science indicates that while some use is to be expected on woody species, prolonged periods of higher utilization does affect the plant. Alternative 2 is then responsive by lowering herbaceous use as condition declines. Ecological condition determinations are made on sites that are representative of the allotment or pasture. The “site-specific fixes” that you have listed remain valid options under both Alternative 1 and 2. Aspen utilization standards have been adjusted in the FEIS to reflect different condition classes. Response to IRC24: See responses to IRC9 and IRC19. Response to IRC25: References cited represent the current best available science, and informational gaps are to be expected. We acknowledge that some of Holechek’s work published in 1998 is based on different ecosystems. However, Holechek and others (2004) is based on studies on a variety of ecosystems including sagebrush. Response to IRC26: Little repeated soil monitoring data exists in the project area. While short-term improvements to soils, usually decreases in the amount of bare ground, are easily detected, long-term effects to soil structure or productivity are likely to take a longer time to see. Response to IRC27: See response to IRC26. Response to IRC28: Without more detail, it is difficult to respond to this comment. Applicable Forest Plan direction was included in chapter 1 of the DEIS. Alternative 2 (Proposed Action) is consistent with the Forest Plan direction and meets the stated purpose and need. Response to IRC29: See responses to IRC9 and IRC19. Response to IRC30: Water quantity is discussed because it is known that livestock grazing can affect water quantity, and this project proposes to authorize livestock grazing in the project area. Belsky and others (1999) is referenced in the FEIS to support this statement. Response to IRC31: The DEIS acknowledges a lack of data yet relies on current best available science to disclose the potential known effects of livestock grazing on water quantity. We do not have any project-specific data on water quantity. The discussion in the DEIS is intended to describe the effects on water quantity that are generally associated with livestock grazing. Response to IRC32: See response to IRC31. Response to IRC33: While the state does set water quality standards, it is the Forest's responsibility, not the state’s, to ensure that activities on the Forest do not create situations where state standards are exceeded. Response to IRC34: Water quality is just one resource area analyzed in determining which alternative best meets the stated purpose and need. Data was collected as time and funding allowed. Any

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shortcoming of data is disclosed in DEIS (page 37). The data is sufficient to reasonably analyze water quality in the project area. Response to IRC35: See response to IRC34. Response to IRC36: See response to IRC34. Response to IRC37: That is correct. Most of the sites sampled were only a point in time. They will only give you an idea of the conditions at that point in time, not which way conditions are trending. Response to IRC38: Climate data included in the DEIS is sufficient for this analysis. Response to IRC39: See response to IRC37. Response to IRC40: Streams were monitored as time and funding allowed. Any shortcomings are noted in the DEIS (page 37). The DEIS acknowledges that the sampling strategy was not designed to be representative. While water quality was a concern at some locations and can be adversely affected by livestock grazing, in general it does not represent a major problem in the project area. Response to IRC41: See response to IRC40. Response to IRC42: See response to IRC40. Response to IRC43: See response to IRC40. Response to IRC44: See responses to IRC34 and IRC40. Response to IRC45: Livestock grazing can affect water quality. As you point out, most of the water quality data in the Forest’s possession indicates there are few problems with water quality in the project area. Alternative 2 considers all available data on the attributes for a habitat group when determining ecological condition. The mere fact that one attribute is in functioning condition does not mean that all of the other data on the other attributes is ignored. We may have data that indicates the pH in a stream is within appropriate levels, but streambank instability, headcuts, or an unacceptable level of noxious weeds may lead to a determination that the stream is not in functioning ecological condition. Response to IRC46: The DEIS and the FEIS recognize that livestock has little influence on pH. See response to IRC45. Response to IRC47: See response to IRC34. Response to IRC48: We have not implied that data was improperly monitored at base flows. There is often a correlation between turbidity and sedimentation, which is why we included the discussion on sedimentation in the FEIS. There is a cause and effect correlation between the two parameters. Response to IRC49: Comment noted. Response to IRC50: See response to IRC34. Response to IRC51: See response to IRC34.

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Response to IRC52: See response to IRC34. Response to IRC53: See response to IRC34. Response to IRC54: See response to IRC34. Response to IRC55: This response includes all soil related comments found under heading III, Issue 2: Soils (pages 50-60). Soil quality is just one resource area analyzed in determining which alternative best meets the stated purpose and need. Data was collected as time and funding allowed. Any shortcomings of the data are disclosed in the DEIS (page 52-54). The EIS makes no claims to have covered every possible soil type/plant combination but to have a representative sampling of the project area to fairly disclose current conditions and impacts that livestock grazing can have on the soil resources. The Matrices score sheets provide criteria and direction for the evaluation of a site’s current ecological condition. Instructions allow adjustments to be made in ecological condition with additional data or documented site-specific knowledge. The Matrices have measurable parameters to assess site-specific soil conditions that have a localized effect on ecological condition. These assessments may be reasonably correlated to soil conditions throughout the project area. The basis for the development of Alternative 2 is that the best available science indicates that current management is not adequate to protect and maintain ecological conditions in the project area. Current management uses within season triggers established in Amendment 2 of the Forest Plan. See response to IRC4. See response to IRC16 for rationale on the inclusion of Alternative 3 (the “No Grazing” Alternative). Response to IRC56: The Matrices were developed to help determine the current ecological condition for a specified vegetation community type. One of the parameters measured is soils, indications of compaction (structure, rooting depth) as well as bare ground. The Matrices use standard Forest Service methodologies to collect data. The use of the Matrices to determine ecological conditions for this project has been clarified in the FEIS. As stated in the Rangeland (Ecological) Condition section in the description of Alternative 2 in chapter 2 of the FEIS, not all attributes in a particular habitat group are affected equally, or at all, by project level activities. Attributes that are not affected by project level activities would not be used to determine the proper use criteria or make other management adjustments. Response to IRC57: The Matrices were developed incorporating widely accepted Natural Resources Conservation Service (NRCS) ecological site descriptions. The Matrices use standard Forest Service methodologies to collect data and have been peer reviewed. Response to IRC58: The Matrices score sheets provide criteria and direction for the evaluation of a site’s current ecological condition. Instructions allow adjustments to be made in ecological condition with additional data or documented site-specific knowledge. Response to IRC59: See response to IRC58. Response to IRC60: See response to IRC58. Response to IRC61: See response to RC58.

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Response to IRC62: The Vegetation Specialist Report provides detail on the relationship between the mapped vegetation cover types and group types described in the Matrices. In addition, a low sagebrush matrix has been developed and will be included in the FEIS (appendix B). Grassland cover types may be considered as part of other matrices including but limited to Wyoming big sagebrush and mountain big sagebrush. Vegetation mapped as the mixed sage/bitterbrush cover type may be considered under the mountain big sagebrush depending on the amount of bitterbrush cover. Response to IRC63: Intermountain Range Consultants (IRC) uses the Central Nevada Riparian Field Guide and not the Matrices to discuss the soil and vegetation condition in the examples given. However, the Matrices, like the Riparian Field Guide, are based on the measurement of multiple indicators used to determine an overall condition. The following are research papers that propose the use of multiple indicators for monitoring condition and trend to achieve a more balanced view of the ecosystem function. Havstad, K.M. and J.E. Herrick. 2003. Long-term ecological monitoring. Arid Land Research and Monitoring, Vol. 17: 389-400.

In this article, the authors discuss the need to document changes in important properties of biological communities, for three key attributes: soil and site stability, hydrological function, and biotic integrity. They identify four basic guidelines for developing long-term monitoring, one of which is identifying a suite of indicators which are consistently correlated with the functional status of one or more critical ecosystem processes. Plant cover and composition is one of the indicators used to address all three key attributes.

*Development of the Matrices took this same approach by looking at a suite of possible indicators and determining which indicator measurements would provide the information needed with as much correlation across attributes as possible with limited time and funds to insure an accurate portrayal of condition and trend. Dale, Virginia H. and Suzanne C. Beyler. 2001. Challenges in the development and use of ecological indicators. Ecological Indicators I (2001) 3-10.

The authors discuss the difficulty in selecting appropriate indicators to deal with the complexity of ecological systems, and how it is important to use a suite of indicators representative of the structure, function, and composition of ecological systems.

*The suite of indicators developed for the Matrices are representative of structure, function, and composition by vegetative cover types. By using a suite of indicators, we recognize that not all the indicators will provide the same conclusion as to function, but considered together, these indicator attributes provide a broader view of the condition of the biological community and where we may need to focus attention to improve function. Herrick, Jeffrey E. 2000. Soil quality: an indicator of sustainable land management? Applied Soil Ecology. Vol. 15:75-83.

In this article, Herrick argues that although soil quality is a good measurement of sustainable landscapes, it has not seen widespread adoption due to lack of understanding, difficulty, and expense of monitoring and applicability across different landscapes and landscape uses. He mentions the use of other indicators of soil quality, such as these excerpts listed below: “One of the most straightforward examples is the relationship between soil erodibility, plant canopy cover, and rainfall erosivity. Soils with higher canopy cover are able to resist degradation by more

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erosive storms, even if soil structure is constant. Canopy cover also provides an indication of root and litter inputs of organic matter that contribute to the resilience of soil structure following degradation.” “An example of an indicator of resistance to compaction is soil bulk density, which is related to soil strength which, in turn, is inversely related to susceptibility to compaction.” “Plant functional groups may be defined relative to a number of characteristics, including above- and below-ground morphology, water use efficiency, palatability, and phenology. Furthermore, in both degrading and recovering systems, the soil beneath one or more species of plants may serve as valuable internal references. At one gravelly fan site in south central New Mexico soil stability test values in bare areas were less than 60% of those measured under grass canopies (Table 1).”

Jansen, Amy and Alistar I. Robertson. 2001. Relationships between livestock management and the ecological condition of riparian habitats along an Australian floodplain river. Journal of Applied Ecology. Vol. 38:63-75.

Jansen and Robertson used a multi-indicator monitoring process to assess riparian and stream health in Australia. Some of the indicators they used are canopy cover, understory cover, ground cover, bank stability, and soil structure to arrive at a riparian condition index.

*Many of the same indicator attributes were used in the Matrices. Martin Basin Field Examples Used by IRC: In example 21964, the IRC mentions the note about infiltration abandoned due to rodent holes, but there are other notes, which may have not been in the copy viewed by IRC. These notes state:

“Stream down-cut up to two meters in some spots. Too many undesirable forbs (IRMI, THMO, LILE, TAOF, mustard and Polygonum), too few grasses and sedges. Was once likely a very productive site, but not producing near potential. Too much visible bare soil for a meadow. Stream impacted and has high organic matter deposits and presence of algae and milfoil. Sagebrush encroaching extensively, Ribes (currant) severely hedged and surprisingly the roses are hedged and hiding under willows. Few new willows are getting established. SALU (yellow willow) hedged. Last year’s cow pies evident and in large quantities.”

If the Matrices were utilized the results would be: Rooting depth (average 12 cm) indicates the site is functioning. Species composition (high in low status forbs and low in grasses and sedges) and ground cover (25-26%) indicates the site is not functioning and the presence of blocky soil structure within the upper 30 centimeters of soil indicates the site is functioning at risk. The likely outcome from using the Matrices would be “functioning at risk.” IRC states, “... the “at risk” finding would trip the reduction in authorized livestock utilization levels, while the actual problem is the abundant rodent activity at this site.” The Matrices assess ecosystem condition, they do not determine what has caused that condition. However, the notes indicate that rodents, livestock grazing, and stream down-cutting has impacted the site. In example 95800 and 95802, multiple indicators show a site that has some problem areas and some good areas. The intent of multiple indicators again is to provide a more expansive view of the overall ecological condition, and not base the decision solely on one characteristic that may be at issue. The Riparian Field Guide suggests that where the soil and vegetation data disagree, select the ecological status class where the vegetation data agree with one or more of the soil measures. In the Matrices, key

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attributes were chosen to help in the decision process for the condition assessment. The following paragraph describing key attributes is located in Part 1 of the Matrices:

Focusing Ecosystem Attributes in Matrix Assessments In an effort to focus the assessment down to a definable functioning level, the authors have selected certain key attributes Dale and Beyler 2001; Havstad and Herrick 2003; Herrick 2000; Jansen and Robertson 2001). The attributes chosen are measurable, have a known range of values, and a monitoring history. For sites “Not Functioning” those key attributes unlikely to be affected by site capability or recent natural disturbance events were used. Although key attributes were selected to focus the determination of function level, all of the attributes are intended to be used to provide a balanced assessment. In addition, there is a connection between infiltration, root depth, vegetative composition and compaction. The following research projects demonstrate a connection: Kauffman, J. Boone, Andrea S. Thorpe and E. N. Jack Brookshire. 2004. Livestock Exclusion and belowground ecosystem responses in riparian meadows in eastern Oregon. Ecological Applications Vol. 14:6 pp. 1671-1679.

The authors sampled three livestock exclosures that had been closed to grazing for 9 to 18 years and compared them to 3 adjacent grazed sites. They found the total below ground biomass (live and dead roots) in the exclosures to be 50-62 percent greater than the area outside the exclosures. Soil bulk density was significantly lower and soil pore was higher in exclosed sites. The mean infiltration rate in exclosed dry meadows was 13-fold greater than in grazed dry meadows (142 vs. 11cm/h), and in wet meadows, the mean infiltration rate in exclosures was 233 percent greater than in grazed sites (24 vs. 80 cm/h).

*This study demonstrates a correlation between root depth, bulk density, pore space, and infiltration rate. Crider, Franklin J. 1955. Root growth stoppage resulting from defoliation of grass. Technical Bulletin No. 1102, United States Department of Agriculture, Soil Conservation Service, Washington, D.C. 23p.

Crider found that a single clipping that removed most of the foliage stopped root growth from 6 to 18 days in all but one grass species. The greater the percent of forage clipped in a single clipping resulted in a longer period of root-growth stoppage. Effects of frequent clipping were much more severe. Where 70 percent or more of the foliage had been taken repeatedly, no roots were growing at the end of the 33-day test. Stoppage of root growth failed to take place only when 40 percent or less of the foliage was removed.

*This study shows a correlation between high levels of disturbance (in this case livestock grazing in excess of 50%) and root growth. Weixelman, Dave A., Desiderio C. Zamudio, Karen A. Zamudio and Robin Tausch. 1997. Classifying ecological types and evaluating site degradation. Journal of Range Management. Vol. 50:315-321.

This research details how the authors used canonical correspondence analysis ordination to determine relationships between vegetation, landform and soil attributes, and to what extent a gradient of measurable change would occur with site degradation. Plant and soil indicators of degradation for the Central and Sierra Nevada riparian field guides were determined from this analysis.

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Response to IRC64: See responses to IRC55 and IRC63. Response to IRC65: See response to IRC45. Response to IRC66: This response includes all fisheries/wildlife related comments found under heading IV, Issue 3: Fisheries and Wildlife (pages 61-106). Fisheries (LCT and other trout) and wildlife are resource areas analyzed in determining which alternative best meets the stated purpose and need. Data was collected as time and funding allowed. Any shortcoming of data is disclosed in the DEIS. The EIS makes no claims to have covered every possible allotment/stream combination but to have sufficient data to fairly disclose current conditions of the project area and impacts that livestock grazing can have on the fisheries and wildlife resources. The Matrices score sheets provide criteria and direction for evaluation of a site’s current ecological condition. Instructions allow adjustments to be made in ecological condition with addition data or documented site-specific knowledge. The Matrices have measurable parameters to assess site-specific soil conditions that have a localized effect on ecological condition. These assessments may be reasonably correlated to habitat conditions throughout the project area and are meant to disclose current conditions, not to reflect trend, good or bad. We agree that general aquatic wildlife survey (GAWs) data appear to show improvement over time on three creeks. Additional information is available in the project record. Response to IRC67: See response to IRC56. Response to IRC68: See response to IRC56. Response to IRC69: This response includes all sensitive species related comments found under heading IVB, Issue 3: Fisheries and Wildlife (pages 61-106). Sensitive species is just one resource area analyzed in determining which alternative best meets the stated purpose and need. Data was collected as time and funding allowed. Any shortcoming of data is disclosed in DEIS. The DEIS makes no claims to have covered every possible modeling option but to have a reasonable amount of data from the project area to fairly disclose current conditions and impacts that livestock grazing can have on the sensitive species resources. The NEPA requires that potential effects to sensitive species be analyzed and disclosed in the NEPA process. Modeling used the best available data to determine current habitat extent and condition. The DEIS acknowledges that livestock grazing is not the only activity that can have an effect on the extent and condition of habitat used by sensitive species. The cumulative effects analysis discloses those additional activities that potentially could affect habitat. The basis for the development of Alternative 2 is that the best available science indicates practices allowable under current management are not adequate to protect and maintain ecological conditions in the project area. Current management uses within season triggers established in Amendment 2 of the Forest Plan. See response to IRC4. See IRC16 for rationale on the inclusion of Alternative 3 (the “No Grazing” Alternative). Response to IRC70: See response to IRC57. Response to IRC71: See response to IRC57. Response to IRC72: See response to IRC57. Response to IRC73: See response to IRC57. Response to IRC74: See response to IRC57.

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Response to IRC75: See response to IRC57. Pygmy do prefer dense stands of taller sagebrush with little herbaceous understory. This is in conflict with most other species’ habitat requirements (Larrucea et al. 2007). Response to IRC76: This response includes all management indicator species related comments found under heading IVC, Issue 3: Fisheries and Wildlife (pages 61-106). Management indicator species are just one resource area analyzed in determining which alternative best meets the stated purpose and need. Data was collected as time and funding allowed. Any shortcoming of data is disclosed in the DEIS. The DEIS makes no claims to have covered every possible modeling option but to have a reasonable amount of data from the project area to reasonably disclose current conditions and impacts that livestock grazing can have on the sensitive species resources. The NEPA requires that potential effects to management indicator species be analyzed and disclosed during the NEPA process. Modeling used the best available data to determine current habitat extent and condition. The DEIS acknowledges that livestock grazing is not the only activity that can have an effect on the extent and condition of habitat used by management indicator species. The cumulative effects analysis discloses those additional activities that could potentially affect habitat. The basis for the development of Alternative 2 is that the best available science indicates practices allowable under current management are not adequate to protect and maintain ecological conditions in the project area. Current management uses within season triggers established in Amendment 2 of the Forest Plan. See response to IRC4. See response to IRC16 for rationale on the inclusion of Alternative 3 (the “No Grazing” Alternative). Response to IRC77: See response to IRC76. Response to IRC78: See response to IRC76. Response to IRC79: See response to IRC76. Response to IRC80: This response includes all other species of interest related comments found under heading IVD, Issue 3: Fisheries and Wildlife (pages 61-106). Other species of interest are just one resource area analyzed in determining which alternative best meets the stated purpose and need. Data was collected as time and funding allowed. Any shortcoming of data is disclosed in the DEIS. The DEIS makes no claims to have covered every possible inventory option but to have sufficient data to reasonably disclose current conditions and impacts that livestock grazing can have on the other species of interest resources. The NEPA requires that potential effects to species be analyzed and disclosed in the NEPA process. Inventories used the best available data to determine current habitat extent and condition. The DEIS acknowledges that livestock grazing is not the only activity that can have an effect on the extent and condition of habitat used by wildlife species. The cumulative effects analysis discloses those additional activities that potentially could affect habitat. The basis for the development of Alternative 2 is that the best available science indicates practices allowable under current management are not adequate to protect and maintain ecological conditions in the project area. Current management uses within season triggers established in Amendment 2 of the Forest Plan. See response to IRC4. See response to IRC16 for rationale on the inclusion of Alternative 3 (the “No Grazing” Alternative). Response to IRC 81: See response to IRC67.

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Response to IRC82: This response includes all vegetation related comments found under heading V, Issue 4: Vegetation (pages 106-178). Vegetation is just one resource area analyzed in determining which alternative best meets the stated purpose and need. Data was collected as time and funding allowed. Any shortcoming of data is disclosed in the DEIS (page 52-54). The DEIS makes no claims to have covered every possible allotment/plant combination but it does use all available data in the project area to reasonably disclose current conditions. Conclusions of current condition are based on the evaluation of the data including methodology, sampling date, and how well the site represents the conditions found across the allotment. The Matrices score sheets provide criteria and direction for evaluation of a site’s current ecological condition. Instructions allow adjustments to be made in ecological condition with additional data or documented site-specific knowledge. The Matrices have measurable parameters to assess site-specific soil conditions that have a localized effect on ecological condition. These assessments may be reasonably correlated to vegetation conditions throughout the project area. Repeat photography is an accepted protocol. The DEIS agrees that results are site-specific and may not be representative of the allotment/project as a whole. Repeat photography is only available on sites that had documentation from prior site visits. The basis for the development of Alternative 2 is that the best available science indicates practices allowable under current management are not adequate to protect and maintain ecological conditions in the project area. Current management uses within season triggers established in Amendment 2 of the Forest Plan. See response to IRC4. See response to IRC16 for rationale on the inclusion of Alternative 3 (the “No Grazing” Alternative). Response to IRC83: See response to IRC82. Response to IRC84: See response to IRC82. Response to IRC85: The analysis of available data supports your conclusion. The DEIS is unable to support an upward, static, or downward trend at this time. Response to IRC86: See response to IRC85. RESPONSE IRC87: The aggressive treatment of noxious species is an important component to all of the alternatives, but would not in itself drive the adoption or rejection of an alternative. The alternative must meet the purpose and need. RESPONSE IRC88: While repeat photography can be useful in determining condition and trend, it is limited to existing sites, is mainly used to support other data collection efforts, and is not required in the NEPA process. Every effort was made to use repeat photography in the Martin Basin analysis. We agree that more detailed information regarding the collection of this photographic information and the circumstances of the management of these photographed areas would provide greater context for interpretation. The point of the photos is to show that the uplands have been improving over time with current management. See response to IRC82. Response to IRC89: While repeat photography can be useful in determining condition and trend, it is limited to existing sites, is mainly used to support other data collection efforts, and is not required in the NEPA process. Every effort was made to use repeat photography in the Martin Basin analysis. See response to IRC82. Response to IRC90: See response to IRC82.

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Response to IRC91: See response to IRC82. Response to IRC92: See response to IRC82. Response to IRC93: See response to IRC82. Response to IRC94: This response includes all socioeconomic related comments found under heading VI, Issue 5: Socio-Economics (pages 179-183). Socioeconomics is just one resource area analyzed in determining which alternative best meets the stated purpose and need. The extent of the analysis is at the discretion of the interdisciplinary team. The Socioeconomics section seeks to compare the effects of the alternatives on this topic. The purpose was never to calculate the actual or potential economic benefits to the permittees or any wider group. As noted in chapter 1 of the DEIS, there are other economic factors and influences well beyond Forest Service control that significantly affect the economic viability of individual ranching operations. To compare the effects of the alternatives on Socioeconomics, change in AUMs was used as the measurement indicator. The DEIS acknowledges that Alternative 2 could result in a loss of AUMs. Response to IRC95: See responses to IRC3, 7, 15, 55, 66, 69, 76, 80, and 82. Response to IRC96: Data are collected using widely accepted protocols. The same protocols are used for collecting data used with the Matrices evaluation. Data collected in 1995 can still be evaluated using the Matrices. Response to IRC97: This response covers all Matrices related comments on pages 71-73 of the comment letter. The Matrices are designed to evaluate the current ecological condition without regards to the disturbance. The Matrices are not used to assess the conditions of pastures managed as seeding units of crested wheatgrass. Forage kochia and other non-native species have been used for rehabilitation projects. Areas maintained as non-native seedlings are not assessed by the Matrices. When trend data is available, the interpretation of trend data is included. Appropriate trend data, if available, would be considered during the development of the AMP. The proper use criterion establishes only the maximum utilization based on condition. Forest Service management is based on multiple uses. Also, see responses to IRC21, 45, 48, 69, and 82. Response to IRC98: The AMPs included in the DEIS were incomplete drafts that contain the pertinent information required by NEPA and Forest Service directives. These draft AMPs have been revised for the FEIS. The final versions of the AMPs will be developed by the Forest Service, permittees, and interested parties. Response to IRC99: While impacts to soils may be unavoidable, that in itself is not justification to preclude management options that could reduce impacts in these areas. Although these areas do constitute a small percentage of the project area, their importance to the environment is critical to the overall health of the system.