Appendix C Response to Comments December, Appendix C

Transcription

1 Appendix C Response to Comments Table C- 1 lists the letters received on the Draft Review of New Information Pertinent to Domestic Sheep Allotment Management Plans in the Gravelly Mountains on the Beaverhead- Deerlodge National Forest (Review). Table C- 2 displays the letter number, comment number, the actual comment (in italics) and the interdisciplinary team response. The entire content of letters providing comments on the Draft Review are available on the project web page ( Please click on the Public Comment/Objection Reading Room link in the right hand column of the web page. As explained in the Purpose section of the Review, the BDNF s analysis is being undertaken to comply with the Court s Order that the Forest Service is to conduct a review of the five issued concerning big horn sheep raised by the Gallatin Wildlife Association, and any other pertinent new information, to determine whether any, or all of this new information warrants NEPA supplementation for the allotment AMPs. After evaluating the new information and considering public comment, the Madison District Ranger will determine if the new information is sufficient to show that allotment management is affecting the environment in a significant manner or to a significant extent such that a supplemental NEPA analysis must be prepared. CEQ regulations require supplemental NEPA analysis when there are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts. 40 C.F.R (c)(1)(ii). Specifically, Ninth Circuit case law provides: [i]f there remains major Federal action to occur, and the new information is sufficient to show that the remaining action will affect the quality of the human environment in a significant manner or to a significant extent not already considered, a supplemental EIS must be prepared. Friends of Clearwater v. Dombeck, 222 F.3 rd 552, (9 th Cir. 2000), citing Marsh v. Oregon Natural Res. Council, 490 U.S. 360, 374 (1989). As a result, agency review of public comment on the Draft Review departs from public involvement procedures commonly used during NEPA analysis where public comment is sought on a draft environmental analysis of potential environmental impacts of a proposal and alternatives. Here, since the focus of the Draft Review is on whether new information is significant in terms of existing management, the agency s review of public comments is looking at significant effects raised relating to new information. The Forest Service has responded to each public comment. The Forest Service s responses, provided below, are organized in the following manner. Each comment letter received is identified by the number correcting to each commenter as shown Table C-1. Then, the Forest Service reviewed each comment letter to identify specific issues raised. These issues were identified sequentially by number for each comment letter. Hence the issues are identified first by comment letter number then by issue number, ie. 1-1 stands for comment letter #1 and C-1

2 issue #1 within that comment letter. The Forest Service response to each issue is provided in the RESPONSE section for each issue. Table C- 1 Letter log for Comments Letter # Name 1 James Hagenbarth 2 Skyline Sportsmen Association 3 Allen Schallenberger 4 Beaverhead County Commissioners 5 Norman Bishop 6 Jim Bailey 7 Joe and Agnes Helle 8 Gallatin Wildlife Association 9 Western Watersheds Project 10 Cottonwood Environmental Law Center 11 Jane Yecny 12 Gilman IH Cattle Company 13 Madison County Board of Commissioners 14 Pat Simmons 15 Thomas Redman 16 Nancy Schultz, et al (44 form letters) 17 Bruce Nelson 18 Neil Barnosky 19 Montana Wool Growers Association 20 Ruby Valley Conservation District & Ruby Watershed Council 21 Nancy Schultz 22 Wild Sheep Foundation & Montana Wild Sheep Foundation 23 Reid and Kami Noyes 24 Bob Wallace 25 Zach Cardosi 26 Helle Livestock and Rebish & Konen Livestock Table C- 2 Comments and Responses After reading all the NEPA work done on the Gravelly Sheep Allotments, the various MOUs signed by all parties in regard to Green Mountain Big Horn Sheep introduction, reviewing all monitoring done by MFW&P of the 1-1 Greenhorn Big Horn Herd, and the Draft Review of Pertinent Information, it is obvious that all the significant environmental effects have been previously evaluated. Consequently it is a waste of time, money and effort to require a formal supplementation of the previous environmental analysis. C-2

3 2-1 RESPONSE: Thank you for reviewing the evaluation disclosed in the draft Review and your views on the lack of significant environmental effects to big horn sheep from allotment management. Going back to 1990, I was representative for sportsmen on the Snowline grazing Association near the Idaho border, the Garden Creek grazing Association in the Ruby Mountains, and for the Warm Springs Grazing Association in the Gravelly Mountains. These were all cooperative efforts with the Forest Service, Bureau of Land Management, Department of Natural Resources, and permittees and sportsmen groups. The MOU in the Gravelly Mountains has been in existence for about 13 years. It has been successful. There have been no conflict between Bighorn sheep and domestic sheep. There has been no transfer of pneumonia from domestic sheep to Bighorns. The population has steadily increased and hopefully will allow hunting opportunities in the future. Skyline Sportsmen believe in the concept of multiple use of our resources. Bighorn sheep and domestic sheep are examples of the multiple use concept and as such the grazing leases held by lessees there should not be retired. Those sheep operators have been there for generations. Apparently there is no damage to the resource RESPONSE: Thank you for reviewing the evaluation disclosed in the draft Review. I agree with the general findings of the report that domestic sheep on the Gravelly allotments have not been a problem for the Greenhorn bighorn sheep. Vigilance must be continued as well as the MOU because bighorns ;( especially rams) do travel away from their home range. The participants in the MOU should have the understanding that if a ram or two is in a domestic herd and seen leaving, the herder should take immediate action to kill the animal or animals if only a couple or so. By the time a distant warden or biologist could get there the bighorns would be gone and very difficult to find and identify again in rugged forested mountains. The herders must be skilled shooters so they don't miss. Larger numbers of bighorns would be a bigger problem and the herder should wait for FWP action. RESPONSE: Thank you for reviewing the evaluation disclosed in the draft Review. To improve the bighorn habitat in the Greenhorn Mountains I strongly recommend selective cutting and prescribed burning of conifers on winter ranges adjacent to and on escape habitat. Also opening corridors from winter to summer range could be helpful. C-3

4 3-3 RESPONSE: A proposal for vegetation treatment is being developed in the Greenhorn Mountains. Please refer to this web page: Page 7 the supposed low count of 17 bighorns in 2009 was not the true population then. See our citizen's count which showed at least 50 that year. The problem was lack of interest and effort by the Sheridan biologist at that time. For the record, I would like to mention I believe the data provided by Bill Fraser, Ph.D. wildlife research biologist living near Sheridan, showing 42 bighorns are quite accurate. I also have no reason to doubt data from the other persons who are excellent and experienced wildlife observers. I did not list the location of one ewe and two rams in that report and will do it now. I was concerned in 2009 about the action that would be taken by the Sheridan wildlife biologist. The ewe and one large ¾ plus curl ram were seen in the Devil's Hole of the Snowcrest Mountains by Erwin Clark, an outfitter with a lodge south of Alder RESPONSE: We added in the Review that a 2009 citizen s count showed at least 50 bighorn sheep. The young ram was seen on the Noble Fork of Wisconsin Creek by Jerry Pictkhorn and one other area resident. Pickthorn and his wife have a home on Wisconsin Creek. The three bighorns were unmarked. It is possible that the younger ram could have come from the Highland Mountain herd. Jack Atcheson, Jr. saw a number of rams in lower Hells Canyon near the Jefferson River. That is relatively close to the Noble Fork. The Noble Fork seems to be a popular spot for bighorns. Some of the 25 bighorns from the Sun River transplanted to Willow Creek in the NE Tobacco Root Mountains in 1964 showed up there. Soon after the Greenhorn bighorn sheep were released some of those were observed on the Noble Fork. Katie Benzel, BLM biologist in Dillon told me, BLM workers saw a young ram on the Noble Fork in recent years (2013?) in spring. The employees were setting up a prescribed burn. Potential problems are that there is a small domestic sheep herd on lower Wisconsin Creek near the highway and other small domestic sheep and goat herds in the Sheridan and Alder area. RESPONSE: Thank you for your comments regarding big horn sheep unverified reports of in the Noble Fork of Wisconsin Creek. It is unclear where the sheep may have originated. However, the Greenhorn big horn sheep are known to move north this is discussed in the Review. Wisconsin Creek and Noble Fork are located in the Tobacco Root Mountains. I recommend that the MT FWP Dept. set up a state data base of known domestic sheep and goat herds and hobby animals and also locations where they are used for weed control. Areas where pack goats are used also should C-4

5 be mapped. That information should be kept current. That seems to be necessary for the best bighorn management. Also I have not seen a brochure by the Dept. explaining the problems with domestic sheep and goats versus bighorns. If they don't have one, they should develop an excellent one soon for wide distribution in Montana. SD Game, Fish and Parks Dept. have the mentioned brochure as may other states and provinces RESPONSE: This recommendation can be adopted by MFWP at their discretion The report by the Wildlife Conservation Society discussed on page 21 should not be the defining document for bighorn sheep management as they have no responsibility for that. For example they say bighorn herds should be established or connected north and east of the Madison. Parts of the Tobacco Root Mountains could be ideal bighorn sheep habitat if there were not conflicts with small herds of domestic sheep. Bighorn sheep management is a long-term process and a report at one point in time should not be considered definitive on a larger landscape over a span of many years. RESPONSE: Thank you for reviewing the evaluation disclosed in the draft Review. The report by Wildlife Conservation Society is not the defining document for bighorn sheep management. Bottom line of page 22 should list forbs rather than forb. RESPONSE: This typographical error was corrected. On page 25 the bighorn winter range in the Snowcrest Mountains should be listed in the foothills to the north and also in the Greenhorn Mountains to the northeast. Some bighorns are also present in the Ruby Mountains in winter and move back and forth to the Greenhorns. RESPONSE: The Review has been updated to include all the observations of Greenhorns bighorn sheep in the Greenhorn Mountains and Snowcrest Mountains. FWP has received reports of Greenhorn bighorns observed at high elevation during summer months in the Ruby Mountains. However, FWP biologists are not aware if they remain there during all seasons or not and suspect not during most years, and have not observed any bighorn sheep at high elevation in the Ruby Mountains during the winter months. ( from D.Waltee 10/13/2017). There are major problems with the Appendices provided by the USFS in this Draft document. There should be a large scale map of one page (Appendix A) showing all the named domestic sheep allotments in the Gravelly Mountains. The map showing Bighorn sheep habitat modeled should be Appendix B. It C-5

6 should be pointed out in the legend that the bighorn winter and spring habitat did not consider snow depth. Also forested cover is not shown on this map RESPONSE: Thank you. We will add an allotment map as Appendix A. In addition, in terms of modeled sheep habitat we will move it to Appendix F Further, the Review already includes a discussion that the modeled habitat map lacks key components of winter habitat in terms of snow depth and also lacks tree cover considerations that impact bighorn sheep use of potential habitat. The model created by FWP is a starting point showing potential escape terrain habitat. The details of this model are also in Appendix F. The two pages with maps showing Bighorn Sheep observations October April 2016 and also May April 2016 are very confusing and should probably be Appendix C, D, E and F. The data should be separated by year and by season. To be a meaningful record for posterity the dots should show the actual number of bighorn sheep for each dot location. Because the dots now have numbers indicating only the line location on a data sheet they are worthless and misleading. The poor data could result in future lawsuits against the USFS from people who think they represent bighorn numbers. When the USFS uses data from the MT FWP without full understanding of the data's meaning and problems, bighorn management suffers. RESPONSE: We apologize the information was confusing. However, the information is disclosed as currently recorded by MFWP. Changing the display of the information would also change the integrity of the source document. Somewhere in the report should be actual numbers observed each year on winter ranges as opposed to summer ranges. Probably the observation effort is much smaller on the latter. If the bighorns are not moving to summer range and living on winter and spring range year around there are problems. It should be determined if conifers are blocking migration to summer range and also creating ideal habitat for predators to kill bighorns RESPONSE: A majority of the observations are winter observations due to the visibility of the bighorn sheep along main travel routes and other areas with high visibility. There are not very many summer observations of bighorn sheep in this herd, mostly due to survey effort. Both radio-collar and documented observations show some portion of the bighorn population migrates between low elevation winter range and high elevation summer habitats in the Greenhorn and Snowcrest Mountain ranges. Radio-collar data shows summer use in the Greenhorns occurs on both Baldy and Sheep mountains. FWP does not believe limited movement between high and low C-6

7 3-12 elevation habitats is limiting population growth. However, we agree that there is an ability to enhance summer habitat in the Greenhorn Mountains for bighorn sheep movement in the Greenhorn Mountains by removing conifer trees near preferred escape terrain. Therefore, the Forest Service has proposed specific vegetative treatment in the Greenhorn Mountains to enhance bighorn sheep habitat. Additionally, none of these areas involve the domestic sheep allotments. The 69 bighorns transplanted represented bighorns valued at approximately $50, The 36 radios on them cost an additional $ each. Due to very poor FWP work, little information was obtained from those bighorns with radios valued at $14, and no known reports were written for the public RESPONSE: Costs of transplanting and monitoring a species are quite high. We have considered the information that is available through MFWP. I made the original recommendation for a bighorn sheep transplant into the Greenhorn Mountains in the 1990's and worked five years with others to make it happen. The court case noted that while 69 bighorn sheep were transplanted there, only 31 head could be found in The wildlife management biologist at Sheridan opposed the project from the start and appeared to do what he could to scuttle it. He was supposed to keep track of the bighorns and their 36 radio collars and write an annual report. I believe that no reports were produced and that he put very little effort into the bighorn project. He was fired by the Montana Fish, Wildlife and Parks Dept. (MT FWP) in Because the biologist reported only about 30 bighorns were present and the herd was dying out in 2009, I organized a citizens' bighorn count in Dec We found that there were at least 50 bighorns present. I would like to say that I have the greatest respect for the extended Helle sheep ranching family and they have lived up to all of their part of the bighorn sheep transplant agreement for the Greenhorn Mountains. When working on the transplant agreement, I recommended that bighorns be killed which came close to the domestic sheep. The domestic sheep operation did not want bighorn rams breeding their domestic sheep and we did not want bighorns which had mingled with domestic sheep carrying disease back to the bighorn herd. I know of no disease outbreak in the Greenhorn sheep caused by domestic sheep in the Gravelly Mountains. RESPONSE: Thank you for support of multiple use on the BDNF, coordination with affected landowners and preventative measures for disease outbreaks. We added the citizen s report of 50 bighorn sheep in 2009 in the Review. Ideally, more information from the past years following the transplant would better inform the review. Your comments support our Review and we are using all current data provided to us by MFWP. C-7

8 3-14 MT FWP, the USFS, ranchers and others should be aware that while bighorn ewe-lamb groups seem to remain in their established transplant areas, bighorn rams often explore throughout their life-time. That is why the MOU which required a lot of original effort should be retained. Rams could move to the Gravelly domestic sheep or north or west to small farm flocks. Herders present can immediately handle the problem with large domestic herds but they are not present with the small farm flocks. Owners of those should be encouraged to report bighorn presence immediately to FWP because removal by shooting may be difficult where there are people and many homes. Any delay in either case could allow bighorns to return to bighorn herds and infect them with disease RESPONSE: Additional information about the presence of domestic sheep and goats in Beaverhead and Madison Counties (some of which are farm flocks) will be added to the final Review. The new MT FWP biologist Dean Waltee who arrived in 2013 found 58 bighorns in and 48 in the present year. He pointed out his counts probably missed a number of animals. It is nearly impossible to see them from an airplane and difficult from the ground in the steep and forested mountains. RESPONSE: Difficulty obtaining an accurate count is noted in the Review. The USFS and others should be aware that bighorn sheep are susceptible to stress and can die out even though no domestic sheep are present. The Sun River herd is an example. Die-offs occurred there 1925, 1932, 1934 and The next die-offs occurred in 1984 and Livestock and elk grazing may have helped create the earlier die-offs on winter range. The 1984 and 2010 die-offs had no cattle grazing pressure nor were domestic sheep present. High numbers of bighorn sheep, about 900 each respective year and too many elk may have contributed to the latter die-offs along with conifer trees returning to old burns. Wolves chasing bighorns may have also stressed those wintering along Gibson Lake in RESPONSE: Thank you for this information about other factors potentially influencing the health of a bighorn herd herds. We are not aware that competition from elk and predation of wolves is a particular concern specific to the Greenhorn herd or a cause of stress leading to die-offs in this area. In addition, the information is not speaking of an effect of the permitting of domestic sheep in the Gravelly Mountains. When I made the recommendation for the bighorn transplant to the Greenhorn Mountains I knew that there were problems present. A major concern was how the bighorns would impact the local sheep ranching C-8

9 industry. The area contains much more conifer timber than is ideal for bighorns both on and next to steep escape terrain in winter habitat and also between winter and high elevation summer range on Sheep Mountain. That could be improved with some intelligent cutting and prescribed burning practices. Elk numbers have continued to build up to the present on the bighorn winter range and I believe they could be causing stressful forage competition in winter. I believe Dean Waltee's count this winter was about 670 elk on the west side of the Greenhorn Mountains. Wolves have been observed chasing the bighorns in Barton Gulch and causing stress. Because of the dense conifers in much of the area, the high population of mountain lions is probably more successful at predation than they would be in more ideal bighorn sheep habitat. I think there is still opportunity to improve the habitat for bighorns in the Greenhorn Range and increase the bighorn sheep population there in the future. Apparently not many have found the high elevation summer range so burning access corridors could be helpful. Bighorns usually don't flourish if spending too much time on winter ranges RESPONSE: A vegetation treatment proposal is being developed for the Greenhorn Mountains. Please refer to the response to Comment 3-2, 3-11 and The groups and the individual leaders in those groups who brought suit against the USFS for having domestic sheep in the Gravelly Mountains seem to be united in one agenda. That agenda is to remove domestic livestock from USFS and other lands. Please look into the history of the Gallatin Wildlife Association (GWA), Western Watersheds Project (WWP), Wild Earth Guardians, (WEG) out of New Mexico and the Yellowstone Buffalo Foundation (YBF). It seems that GWA, WWP, and YBF have some of the same leaders and advocates. For example, according to an article Sheep vs Sheep in RANGE magazine Winter, 2016, by Dave Skinner- Glenn Hockett, volunteer president of the GWA since 1976, was once hired to be executive director of the WWP in Montana. He may have learned some of his lawsuit tactics then and when he also worked with Sara Jane Johnson founder of Native Ecosystems Council, and former USFS biologist on the Gallatin National forest who has sued the USFS many times over the years. My understanding is that Sara and her family members in SD make up the council. There has been an apparently orchestrated barrage of letters in the Bozeman Daily Chronicle containing highly inaccurate and inflammatory material about domestic sheep in the Gravelly Mountains. It is claimed they are causing severe problems for bighorn sheep and also grizzly bears. Some of those using the big lie technique claim to have a scientific background. C-9

10 RESPONSE: Advocacy is part of our social/political process, we accept it as part of our process and will strive to make reasoned decisions about resource allocations. Glenn Hockett and others continually stress that bighorn sheep must be returned to the 10,275 foot elevation Bighorn Mountain in the Gravelly Mountain Range. That may have been bighorn sheep summer range in the distant historic past but I seriously doubt many bighorns were able to live there in winter due to snow depth. They probably migrated many miles to lower elevation winter habitat, much of which may be currently private land. RESPONSE: The Review considers the practicality of returning bighorn sheep to high elevations in the Gravelly Mountains. And, the Review agrees with your assessment that the snow depth is too deep in the Gravelly Mountains to support big horn sheep winter range. Big horn sheep would need to migrate to other range. I have never flown in an aircraft in SW MT but have looked at the Greenhorn and Gravelly Ranges on Google Earth. I have also spent considerable time in both mountain ranges over the past 25 years. The former mountains seem to have more of the steep terrain which bighorns require for escape cover. There are south and west aspects with less snow which are most suited for bighorn sheep winter range. The Gravelly Mountains have more rolling type terrain in many areas which is good for elk and livestock but not so good for bighorn sheep. Also there is much heavily forested land close to the very limited potential ranges with the required steep, escape habitat. Relatively few elk winter in the higher Gravelly Mountains due to snow. They are able to function in greater snow depths than bighorns RESPONSE: This comment appears to support information considered in the Review. Historic photographs and researchers have documented how our Montana forests have changed over the years with conifer tree cover much more common now. Lewis and Clark reported that the Tobacco Root Mountains had only scattered timber at mid elevations. Contrast that to the present. Other factors which stressed bighorns and caused their decline included market hunting, unrestricted hunting practices, and high numbers of domestic livestock in the past which depleted forage needed by bighorns. Disease was probably a factor. Cattle have been grazing SW MT since the 1850's as was documented by Granville Stuart, The Montana Frontier , 1925, 272 pp. pub. U. Neb. Press. RESPONSE: This comment supports information considered in the Review. C-10

11 3-22 I know from experience that much more can be done for fish and wildlife by working cooperatively with ranchers and agencies rather than using lawsuits. For example I started the Jefferson River Watershed Council in 1998 and served on it for seven years. If the USFS and MT FWP let these radical groups dictate land and bighorn management in Montana it will be the death of sensible and cooperative bighorn restoration efforts which have been succeeding in many cases since Please realize very little has been done in the Greenhorn Mountains to improve the habitat for bighorns. If the right things are done, the herd population could improve and impact on the domestic sheep herds probably would not occur. Dropping the memorandum of understanding which was reached with much effort would be a mistake. I am old enough to remember when we had a respected USFS which functioned well and got productive things done on the land. Now much time and money are wasted responding to outrageous nuisance lawsuits and revising forest plans. We are long overdue for sensible reform of federal laws and courts which encourage these despicable lawsuits by harmful groups. Congress must get to work and overhaul the laws. In Montana the media do a very poor job of reporting the harm the radical groups and individuals do to forest, range, wildlife and water management RESPONSE: Please refer to our response to Comment 3-2 and The Beaverhead County Commissioners support the U.S. Forest Service (USFS) Livestock Management Practices on 7 (seven) Allotments permitted for Domestic Sheep grazing on the Beaverhead-Deerlodge (B-D) National Forest in the Gravelly Mountains. This review should include facts that show the quality of the current permittees. Helle Brothers Livestock and Rebish/Konen have a solid reputation in the Sheep Industry for their constant attention to detail regarding the health of the entire resource/land. These 7 (seven) Allotment Management Plans (AMP s) have been closely studied, monitored and documented by the USFS for 60+ years. Throughout these years, multiuse management has been administered, while maintaining a stable eco system. The decades of correct rotation grazing have provided a healthy rangeland, while increasing wildlife populations, a mosaic vegetation landscape that aids in fire protection, water improvements for wildlife/livestock and weed control. RESPONSE: This comment supports the information considered in the Review The threat of listing the Big Horn Sheep as a sensitive species is a topic that would have a negative impact on all public land stakeholders/users that enjoy the multi-use practices administered on our public lands in Southwest Montana. Various seasonal recreation activities will change dramatically C-11

12 with additional regulations and controlled access. All public land stakeholders/users need to be able to enjoy all the values of any and all public lands for a stable and viable economic tax base RESPONSE: Bighorn sheep have been listed as a Sensitive species by Region 1 of the US Forest Service since The Review does not attempt to change this listing. We value the contribution public land makes to the local economic tax base. Please review all 7 domestic sheep allotments and the associated miles of trailing to and from the allotments under NEPA. I suggest the allotments be closed to livestock use due to conflicts with native wildlife, including but not limited to bighorn sheep and grizzly bears. I encourage the BDNF to work with the Montana FWP to restore bighorn habitat and eventually bighorn populations on this vast landscape of public lands. RESPONSE: All seven domestic sheep allotments were considered in the Review. Further, trailing routes were also discussed including description of the routes, dates, mitigation measures, and analysis showing no know commingling during trailing. The Review was updated to include a map of the trailing routes Appendix A and the approximate distance is miles. The BDNF does work to restore bighorn populations and habitat as shown by the MOU and vegetation proposal in the Greenhorn Mountains. Unfortunately, I find the draft Review inadequate and disturbing. Rather than an objective analysis, I believe it is a non-objective interpretation of selected information, clearly written to protect the status quo for domestic sheep grazing on the Beaverhead/Deerlodge Forest (BHDL). It is not befitting the Forest Service (FS). Essentially, this is a public trust issue. Do the many owners of this public land prefer an emphasis on public resources; or do they defer public benefits to an incompatible private use of the public trust land? FS has avoided an investigation of this question. RESPONSE: Opinions such as those expressed by this reviewer can form the basis for why people chose to advocate for specific resource uses (please refer to the response to Comment 3-18). FS deference to Montana Fish, Wildlife & Parks (FWP) as an authority on population ecology of bighorn sheep is also disturbing. It suggests that FS lacks the expertise for managing public trust wildlife on FS lands and also lacks the resources to contact other experts and much of the scientific literature. For these and the more specific reasons provided below, I believe the Review must be restarted to provide a complete and objective analysis of the issues. Merely editing and defending the draft and appending public comments will not suffice. C-12

13 6-3 RESPONSE: MFWP has legislated authority to manage wildlife in the state of Montana, including bighorn sheep. As a result, they are the best source for information concerning the State s plans for management of the Greenhorn bighorn herd and potential for translocation of a new herd in the Gravelly Mountains. MFWP also has on staff professional wildlife managers with decades of experience managing wildlife in Montana and in depth, on-theground knowledge. Ignoring the wealth of expertise these biologists and wildlife managers would withhold information from the responsible official for his consideration, withhold information from reviewers and risk reaching a decision incompatible with management intentions of the agency tasked with the responsibility for managing the existing and any potential herds. FS concludes (p. 11) that the Greenhorn bighorn herd is adequate as the only bighorn population in the Gravelly-Snowcrest-Greenhorn mountain complex and that a presence of domestic sheep in the Gravelly Range is "unlikely" to negatively impact the Greenhorn herd. Adequacy of the Greenhorn bighorn herd. FWP's objective for the Greenhorn herd is 125 animals. FWP contends that 125 bighorn are a minimally viable population. The Greenhorn herd's ability to reach the FWP goal of 125 animals has not been tested. It has taken 13 years to reach 59 observable bighorn. FS does not recognize abundant literature demonstrating that 125 bighorn are certainly not genetically adequate and very likely not demographically viable. FS lauds the fact that the Greenhorn herd has reached about 59 animals and that FWS may soon allow ram-hunting of this herd. Considering its population history, the Greenhorn herd has certainly been inbreeding for 13 years. A herd of about 60 bighorn has a genetically-effective population, Ne, of about 20 animals. Abundant literature demonstrates that inbred populations have poor resistance to disease, and that following episodic disease, some inbred animals can remain as disease carriers. This is a reasonable hypothesis for the persistence of lamb mortality following disease events in bighorn sheep. In addition, such small bighorn populations are losing genetic diversity (loss of alleles), have little evolutionary potential, and lose adaptive characteristics due to genetic drift. (See references in Population Genetics and Wildlife Management at jamesabailey.com). RESPONSE: We are relying on the FWP 2010 Montana Bighorn Sheep Conservation Strategy and its analysis to support the determination for herd unit size and objectives for the Greenhorn reintroduced herd. The new information review considers the risk of disease transmission, site-specific habitat components and state-agency population management objectives. The 2010 Conservation Strategy describes parameters for a minimum viable population for potential transplanted herds specifically citing research for C-13

14 bighorn sheep. Berger (1990), Geist (1975) and Smith et al (1991) found bighorn sheep herds of individuals persisted for up to 70 years (MFWP, 2010, pg. 61). This comment references 59 bighorn sheep in the Greenhorn herd. In 2015, the local MFWP observed a minimum of 59 bighorn sheep (Appendix B). However, this is an observed number and the MFWP has made clear that because bighorn sheep readily blend in with their environment, the numbers represent the absolutely minimum number alive at those points in time and not the total population. We have place the cited document in the project record noting the author represents documents on the referenced web page as retrospective, personal views of wildlife management and related issues based on five decades of experience. While there is certainly peer reviewed published scientific literature documenting concerns about genetically effective populations consideration of such impacts must also include habitat availability, including all seasonal components and, in the case of bighorn sheep, the potential for exposure to pathogens from domestic sheep or other bighorn herds. FWP is considering hunting the Greenhorn bighorns. FS uses the FWP population criteria for allowable hunting of bighorn rams (p. 7) to support its argument that the Greenhorn bighorn are, or are becoming, a quality herd. However, removing breeding-age rams from this small herd will reduce the Ne even further below 20, exacerbating genetic problems RESPONSE: The Greenhorn herd will continue to be managed within objectives established by MFWP. Removing individuals from hunting is not expected to result in genetic problems within the herd or as the commenter states reduce the Ne further below 20. The criteria used to propose a hunting season are based on current science with hunted herd units and are not putting the species at risk for extinction. According to FWP data, the ram:ewe ratio was 136:100 in :100 in 2016 and 56:100 in 2015; which is well above the 30:100 ratio recommended before a hunting season. FWP does not expect that a limited male harvest (one ram) to prevent population growth because that is influenced by female survival, fawn production and recruitment. FWP area biologist also states that an annual harvest of one ram is currently sustainable (Appendix F). Additionally, a project designed to enhance bighorn sheep habitat is currently being developed. Refer to comment 3-2. FS commends the adequacy of FWP measures to prevent commingling of Greenhorn bighorns with domestic sheep as evidence of the security of the C-14

15 Greenhorn herd (p. 9). Commingling of Greenhorn bighorns with domestic sheep has been accomplished largely, if not entirely, by killing wandering bighorns, diminishing the Greenhorn herd, exacerbating genetic and other small-population problems. Many established bighorn herds in Montana have experienced episodic dieoffs with several apparently disease-free intervening years. That the Greenhorn herd did not experience a dieoff in 2010 (p. 9), or since 2003, provides no evidence that commingling and disease of bighorns is impossible, or even "unlikely" (p. 9). Indeed, FS admits there is a risk of the Greenhorn herd contacting domestic sheep to the West and North and experiencing episodic dieoffs (pp. 11, 15). FS notes (p. 8) that FWP annually observes some members of the Greenhorn bighorn herd and can promptly decrease the risk of commingling with domestic sheep on BHDL. In fact, some of the bighorns are observed rarely, and commingling/disease exposure could occur within any few days. FS relies upon FWP for its understanding of and standards for bighorn population quality. It does not consider the possibility that FWP ignores principles of population genetics and is a very politically-motivated agency prone to avoiding controversial issues. (See The Modem Tragedy of the Commons on my website.) 6-6 RESPONSE: The Review does not state commingling of members of the Greenhorn bighorn herd and domestic sheep or an episodic die off at some future time is impossible. The Review discloses that the Greenhorn herd did not experience an episodic die off in 2010 when numerous bighorn herds in Montana did. Agreed upon landowner and agency cooperation and monitoring by MFWP reduces the risk of commingling which in combination with terrain features, known movements of the Greenhorn herd and quantity and quality of habitat in the vicinity of the domestic sheep allotments located on the BDNF further reduces the risk of commingling. Based on this information, it was reasonable to conclude that commingling is unlikely and corresponds to the description disclosed by MFWP in their 2001 analysis for transplanting the bighorn herd. However, if bighorn sheep begin to move south into the Gravelly mountains, the Forest Service maintains the authority to manage grazing use under federal and state law requirements. FS does not recognize there has been one observation of a bighorn ewe, found dead in 2013, near Black Butte within or near the domestic sheep allotments (database, Dillon office, FWP). Since ewes seldom travel alone, it is likely that more than one wild sheep has visited the allotments at some time. C-15

16 6-7 RESPONSE: The BDNF was unaware of this observation at the time of the draft Review. We have discussed this observation with MFWP. MFWP could not verify the observation and recommended that there was no need to adjust management of the domestic sheep allotments. This information was added to the final Review and documentation is included as Appendix D. FS recognizes habitat barriers as preventing Greenhorn bighorns from contacting domestic sheep on the BHDL. I also note that, dispersing animals have been unlikely with the small numbers of bighorn sheep that have been in this herd. If the Greenhorn herd should attain a larger, more adequate size, given sufficient time, contact with domestic sheep on the allotments certainly is not "unlikely", at least not without unlikely diligent observation on public land and prompt removal of dispersing bighorns. RESPONSE: MFWP has established a population objective for the Greenhorn herd of 125 individuals and have not informed us of any decisions otherwise. At this point, the best information available is that the Greenhorn bighorn herd will be managed at approximately 125 bighorn sheep on National Forest, BLM, State and private property for the foreseeable future. There is no information to suggest that a larger herd would increase the likelihood of contact. FS focus on the Greenhorn bighorn herd implies that providing habitat sufficient for the Greenhorn herd fulfills a Forest Service obligation to provide habitat for native species on a large part of the Beaverhead/Deerlodge Forest. About 67% of observations of Greenhorn bighorn have been off BHDL land, indicating that the Forest is contributing little to any success of the herd, and suggesting that BHDL habitat could be improved with vegetation management to attract and hold bighorn. 6-8 RESPONSE. The percentage of Greenhorn bighorn sheep observed off the BDNF is partially attributed to the visibility of individuals near County Road 248 the primary access route into the Greenhorn/Gravelly/Snowcrest Mountains and the only route plowed for year-around access of permanent residences located south of Alder, Montana. Frequent use of County Road 248 by residents, agency personnel and visitors naturally increases the frequency of individuals observed from the road, versus the less frequently used lands on the BDNF with seasonal road use restrictions. These observations also indicate frequent use by bighorn sheep of lands near, but not on the BDNF and increase the value of coordinating management of the herd among all landowners. Please refer to the response to Comment 3-2 concerning potential vegetation management proposals on National Forest lands in the Greenhorn Mountains. C-16

17 Please also see the reference in the Review to the report Potential Bighorn Sheep Interactions with Domestic Sheep on the Beaverhead-Deerlodge NF Report to the Chief (USDA 2011) concerning management of bighorn sheep on the Forest. In essence, FS contends that having a minimally viable, genetically inadequate and inbred, at risk bighorn herd requiring frequent culling to prevent contact with domestic sheep, with 2/3 of its range off the Forest, is sufficient to comply with the NFMA mandate to provide adequate habitat for native species on the Forest. I strongly disagree. FS focus on the Greenhorn bighorns avoids the intent of the GWA complaint. GWA contends that the small bighorn herds on the BHDL Forest, all on the peripheries of the Forest, are not adequate for maintaining a public resource. The Greenhorn herd is one of the inadequate herds, as noted above. Bighorn herds on the BHDL Forest do not provide evidence that the Forest is providing adequate habitat for a native species, as required by NFMA RESPONSE: Species viability requirements of NFMA apply to the planning area in this case the 3-million plus acre BDNF, not the distribution of the Greenhorn bighorn herd limited only to National Forest lands. Please refer to the Draft SEIS for the BDNF Land and Resource Management Plan to Comply with the District Court Order (Bighorn Sheep) for information about bighorn sheep on the entire BDNF. Analysis in the Review focuses on a review of pertinent new information to determine if it warrants NEPA supplementation for the allotment AMPs. This reviewer s opinion finding MFWP s population objectives and amount of habitat used by the bighorn herd on non-bdnf lands inadequate is noted. This comment does not suggest potentially significant environmental effects from permitting domestic sheep on 7 allotments in the Gravelly Mountains not previously disclosed. Changing management of permitted domestic sheep near Black Butte does not alter population objectives or use of lands off the BDNF. Culling occurs when something is picked out and put aside as inferior ( The Greenhorn bighorn herd has never been culled. Some bighorns were removed to reduce the risk of exposing the overall herd from potential exposure to pathogens. Such action were part of managing herd health, not the removal of individuals considered inferior. Removals to prevent possible pathogen exposure have not been frequent. The inadequate Greenhorn bighorn population detracts FS from fully considering the opportunity for an adequate bighorn herd centered in the Gravelly Range. FS notes the number of domestic sheep and goats in Beaverhead and Madison Counties far exceeds the number of domestic sheep ever on allotments of the Forest (p. 8); and that the diversity of C-17

18 domestic sheep operations on private lands decreases ability for controlling disease transmission on those lands (p.15). FS does not recognize that this is exactly why there is a need for a relatively disease-secure bighorn habitat in the interior of the Forest, distant from private lands. RESPONSE: Please refer to consideration in the Review of the potential for MFWP to translocate bighorn sheep into the Gravelly Mountains. We agree that disease-secure bighorn habitat in the interior of public lands buffered from private domestic lands is desirable. However, it is the view of the MFWP (and the FS agrees) that due to the high amount of snow (multiple feet) in the Gravelly Mountains, reintroducing bighorn sheep is borderline impossible logistically for personnel to get there and the bighorn sheep would not survive the winter due to the deep snow. The 2010 Montana Bighorn Sheep Conservation strategy defines winter habitat as escape habitat (slopes 60% or greater) that is south facing and receives less than 10 inches of snowpack annually. MFWP commented that bighorn sheep translocated into the Gravelly Mountains would likely need to migrate to suitable winter range outside of the Gravelly Mountains. From the FWP comment letter (Appendix E), the most likely winter habitat that the bighorn sheep translocated into the Gravelly would seasonally migrate to and from would be those winter habitats currently occupied by the Greenhorn herd. To date, the Greenhorn bighorn herd has shown no tendency to establish this migration. Therefore, the most current understanding is that the summer habitats along the top of the Gravelly Mountains are isolated from known suitable winter habitats. I contend that public, mostly Forest Service lands including and surrounding the Gravelly Range, provide the best opportunity on the BHDL Forest for a large, contiguous area of public lands for bighorn habitat sufficient for a large population having minimal contact with domestic sheep on the periphery of the public lands. In arbitrarily dismissing this possibility (Issue # 5), FS does not adequately address this basic issue of the GWA complaint RESPONSE: We are unable to draw the same conclusion based on existing data, specifically existing timbered vegetation with mild topography that limits Bighorn movement, annual snow pack requirements being much more in the Gravelly Mountains than survivable for Bighorns paired with small quantities of unconnected escape terrain (60% slopes) for bighorn sheep. On-the-ground knowledge and observations by agency wildlife biologists also confirms this information. Information disclosed in Appendix A identifies other areas of the BDNF with larger quantities of interconnected C-18

19 6-12 modeled habitat and these are areas with current Bighorn herds (see Review pg ). See response to Comment The Forest Service disputes the conclusion of its own biologists that bighorn sheep are a sensitive species. FS notes that the Montana Natural Heritage Program lists bighorn as "apparently secure" in the state (p. 11). FS conducts no independent analysis of the status and trend of bighorn sheep in Montana. FS does not recognize that the MT NHP conducted its analysis of bighorn in conjunction with MT FWP, and that both agencies are subject to scrutiny from a politically wellpositioned livestock industry with a history of successfully diminishing wildlife competition for public lands. (For example, see MCA (3) providing free, unanalyzed trailing for domestic sheep through Robb/Ledford Wildlife Area and across the Snowcrest Range.) FS notes that bighorn numbers have increased in Montana since 1970 and that FWP estimated 5,694 bighorn in Montana in 2010 (p. 11). FWP's optimistic presentation of bighorn numbers in Montana is influenced mostly by a few, larger herds, some in relatively new, untested transplants. A majority of Montana herds do not have the FWP (inadequate, see above) standard of 125 animals (FWP Strategy 2010:82-83). However, for evaluating the Forest Service sensitive species classification, FS should analyze the trend of bighorn numbers on MT Forest Service lands. (A cursory analysis based on the 2010 FWP Bighorn Strategy and recent data, indicates that, of 27 bighorn herds on FS lands in MT, 13 have declined, 9 are stable and 5 are increasing. For the BHDL Forest, 5 herds have declined, 2 are stable and 1 is increasing.) RESPONSE: The purpose of the Review is to determine whether any or all of the new information raised as issues in District Court warrants NEPA supplementation for the allotment AMPs at issue (draft Review, pg. 1-1). The Review is not disputing the Region 1, Forest Service listing of bighorn sheep as a Sensitive Species; it provides the Montana Natural Heritage Program s listing as apparently secure. The information is disclosed in the Review to provide context for how permitted sheep grazing on BDNF lands in the Gravelly Mountains may influence existing bighorn sheep herds and management in Montana. Because established bighorn sheep herds are not co-mingling with permitted domestic sheep in the Gravelly Mountains they are not influencing the health of bighorn sheep herds located elsewhere on the BDNF or in Montana Please see the reference in the Review to the report Potential Bighorn Sheep Interactions with Domestic Sheep on the Beaverhead-Deerlodge NF Report to the Chief (USDA 2011) concerning management of bighorn sheep on the Forest. C-19

20 Current observation numbers of the 8 Montana bighorn sheep herds that utilize the BDNF indicate that 4 (50%) of the herds have increased in number of sheep observed since the 2010 publication of the MT Bighorn Conservation Strategy and that 4 (50%) have experienced die-off s or active removal (Tendoy herd) Herd Last Survey Numbers Observed 2010 Numbers Observed Increase or Decrease from 2010 Garrison Decrease Anaconda/Lost Decrease Creek Spanish Peaks Increase Greenhorns Increase Upper Rock Decrease Creek Highlands Increase Taylor/Hilgard Increase Tendoy Decrease The final Review includes a summary discussion in the section 2011 Listing of Bighorn Sheep as a Sensitive Species of the effects of the allotments on the Greenhorn herd as a sensitive species. FS accepts the FWP "small population strategy for bighorn sheep as having "merit'' (p. 12). FS does not evaluate FWP's position in light of modern population genetics. Issues of inbreeding, genetic drift, loss of alleles and evolutionary potential, and the small numbers of animals available for natural selection are ignored. FS accepts all the costly bighorn management by FWP (occasional transplants, removal of wandering bighorn, depopulations) as acceptable, perpetual management for public wildlife, despite the fact that it has not been an effective long-term strategy. RESPONSE: The above quoted phrase is included in a sentence supporting the introductory statement in the paragraph of Further, there is no indication that the 2011 change in status of bighorn means that each population or herd has increased in importance to the species as a whole. The paragraph uses management of the Tendoy bighorn herd (currently being depopulated) as an example and states However, MFWP also gives merit to the strategy of managing smaller herds for the benefit of the species because population density is known to be a risk contributing to pneumonia outbreaks. Large herds of any species, especially when they C-20

21 threaten exceeding the capacity of existing habitat and become stressed, are susceptible to disease. Clearly, MFWP intends to manage for small herds (where habitat capacity is limited) and large herds (where habitat capacity is extensive). In short, the BDNF accepts the management strategy of MFWP because they have the legislated authority for management of bighorn sheep in Montana and bighorn habitat crosses landowner boundaries. Neither FWP nor FS consider the accentuated effects of predation upon small prey populations. Predation is much more likely to be limiting for small bighorn herds with their relatively high predator/prey ratios RESPONSE: Due to the limited quantity of bighorn habitat, including some seasonal components, the carrying capacity of the Greenhorn and Gravelly Mountains for bighorn sheep herd, even in the absence of domestic sheep on the National Forest, will likely trend towards small herd size. Permitting domestic sheep on the National Forest does not increase the risk of natural predation to the existing bighorn herd. As a result, this comment does not suggest potentially significant environmental effects from permitting domestic sheep on 7 allotments in the Gravelly Mountains not previously disclosed. FS claims that few, if any, bighorn declines in Montana have been due to disease transmission from domestic sheep on FS allotments (p. 11). FS fails to note that the numerous disease epidemics that have occurred in bighorn herds that are all or partly on FS land, presumably coming from contacts with domestic sheep or goats on non-fs lands, indicates that the FS has little or no bighorn habitat secure from adjacent or interspersed non-fs land where disease transmission could occur. FS does not note that the Gravelly Range could provide such relatively secure, but rare, bighorn habitat within the interior of Forest Service land. RESPONSE: As noted in the Draft Review (pg. 18), habitat conditions in the Gravelly Mountains do not appear to provide sufficient year-round habitat needed for a bighorn sheep herd. See also Comment response Other than disease, FS provides little recognition and no analysis of any other demographic or habitat factors contributing to the poor status of bighorn sheep on FS lands in Montana. These include predation in small bighorn herds and conifer encroachment on bighorn habitat. RESPONSE: Please refer to the purpose of the review and responses to Comment and 6-14, above. In summary, FS challenges the Region 1 position on the status of bighorn on Forest Service lands. FS does not adequately analyze the sensitivity of C-21

22 bighorn sheep on FS lands in Montana, and holds itself blameless for any bighorn problems. Instead, FS takes a narrow view of the sensitivity listing, concluding that it does not prove that domestic sheep allotments in the Gravelly Range impact the Greenhorn bighorn herd. FS assumes no responsibility to use Forest Service lands to contribute to improving the status of bighorn on the BHDL Forest or to contribute to improving the statewide status of bighorn sheep RESPONSE: The draft Review discloses the change in listing status, and that identifying the bighorn as a sensitive species did not represent specific concerns for the species on National Forest System lands or the BDNF. As stated, the bighorn sheep was listed as sensitive in 2011, largely due to the die-offs of 2009 and A species listed as sensitive under federal policy is one whose viability is of concern supported by significant current or predicted downward trends in populations or density or in habitat capability that would reduce a species existing distribution. The fact the BDNF is working closely with MFWP and others under an MOU demonstrates its commitment and support for Montana s bighorn sheep populations and continued viability, on the BDNF and in Montana. The final Review includes a summary discussion in the section 2011 Listing of Bighorn Sheep as a Sensitive Species of the effects of the allotments on the Greenhorn herd as a sensitive species. Issue #5, Consideration by MFWP for Reintroducing Bighorn in the Gravelly Range. (pp ). FS contends there is no year-round habitat, including winter range, for bighorn sheep in the Gravelly Range (pp. 18, 22). Bighorn historically used the Gravelly Range. Presumably, Bighorn Mountain in the Range was named for the presence of bighorn sheep. Bighorns were observed at Black Butte, as recently as Their past seasonal movements and distribution in the Gravelly Range are unknown. Conclusions about how bighorns might use the Gravelly landscape today are speculation, at best. RESPONSE: We agree bighorn sheep historically occupied the Gravelly Landscape (draft Review, pg. 7). The commenter states bighorn were observed at Black Butte in This same statement is made in Comment 8-40 and 8-55 citing to USDA The commenter further states that assumptions about how bighorn sheep might use the Gravelly Mountains, including varied ownership at lower elevations, are speculative. However, the conclusions made in the Review are based on existing terrain, existing vegetation and current seasonal features (such as snow depth) in the Gravelly Mountains and research on the habitat needs and preferences of bighorn sheep. It is unclear from Junior Ranger Reports from 1926 and 1928 C-22

23 6-19 (USDA 1926 and USDA 1928) if the bighorn sheep range mapped is yearround habitat or strictly summer habitat as the observations were likely made in the summer do to difficulty accessing these areas in the winter. Further, MFWP s views regarding the translocation of bighorn sheep into the Gravelly Mountains are not speculative. The MFWP s views are that due to the high amount of snow (multiple feet) in the Gravelly Mountains, reintroducing bighorn sheep is impossible logistically for personnel to transport bighorn sheep to the area and further, the bighorn sheep would not survive the winter due to the deep snow. (The 2010 Montana Bighorn Sheep Conservation strategy defines winter habitat as escape habitat (slopes 60% or greater) that is south facing and receives less than 10 inches of snowpack annually.). FS contends that failure of bighorn from the Greenhorn population to pioneer into the Gravelly Range indicates that the Gravelly Range is inadequate habitat (p. 22). However, FS neglects one observation of a dead bighorn ewe at Black Butte in Moreover, the Greenhorn herd and other surrounding bighorn herds have small populations not prone to produce dispersing animals that might find the Gravelly Range. Failure of bighorns to naturally establish in the Gravelly Range is not valid evidence that the Range is inadequate habitat. The only way to test the adequacy of the Gravelly Range as bighorn habitat would be to transplant effective numbers of bighorn into the Range RESPONSE: Please refer to Appendix D and E of the Review (MT FWP comment letter) and response to comment We recognize that there is Bighorn sheep habitat on the BDNF in the Gravelly Mountains where domestic sheep are permitted. MFWP has stated that they could not successfully transplant bighorn sheep on the Gravelly Mountains. Please see comments 6-10, 6-11 and In terms the 2013 observation of a carcass on Black Butte please see response to Comment 6-6. FS uses snow survey data to conclude that the Gravelly Range would be unusable for bighorn sheep during winter through May (p. 18). Snow survey transects (by NRCS?) are not a random sample of snow distribution on the landscape. They are purposely located where important snow/water resources can be measured. I know of no studies linking NRCS snow survey sites to the landscape distributions of bighorn sheep. Moreover, FS uses the most extreme measure of snow depth (maximum average depth) from these inappropriate snow survey sites, to denigrate the Gravelly Range as bighorn winter/spring habitat. This suggests an impartial analysis of information. FS does not use aerial photos or satellite images of snow distributions in the Gravelly Range to evaluate winter bighorn habitat. Such images are likely C-23

24 available, suggesting FS is using an impartial selection of information in this analysis RESPONSE: Satellite images and aerial photos display snow cover, not snow depth. All of Southwest Montana is periodically covered by snow. The Montana NRCS Snow Survey Program provides mountain snowpack and precipitation information in order to issue stream flow forecasts. Common applications of snow survey products include water supply management, flood control, climate modeling, recreation and conservation planning ( The Clover Meadows snow survey site provides the only long-term (decades) consistent measurement of snow depth in the vicinity of the BDNF domestic sheep allotments for comparison to the bighorn sheep winter range receives less than 10 inches of snowpack annually. In order to survive winter conditions, bighorn sheep herds must be capable of surviving extended periods of maximum snow depth. If they can survive the maximum snow depth, they likely will survive lower snow depths. Since 2000, average maximum snow depth at high elevations in the Gravelly Mountains ranged from 49 to 79 inches. Snow depths well in excess of 10 inches annually persist into May. This information is not used to draw a conclusion that all of the modeled habitat in the vicinity of the domestic sheep allotments is unusable by bighorn sheep. Rather, the information is part of consideration of whether MFWP would likely reintroduce bighorn sheep to the Bighorn Mountain/Black Butte area if the domestic sheep allotments were closed. Snow depth, and other factors, indicate the area does not provide sufficient year-round habitat. Review of snow cover from satellite imagery or aerial photos would not provide additional information addressing consideration of whether MFWP would likely reintroduce bighorn sheep to the area if domestic sheep allotments were closed. Noting that "some (bighorn) herds in the Southern Mountains ecological region" migrate to lower elevations for lambing habitat, BHDL contends that bighorn would not lamb in the Gravelly Range. This is a selective use of limited information. I am aware of bighorn herds in the Rocky Mountains that migrate to higher elevations for lambing, for example in Rocky Mountain Park. RESPONSE: While migratory bighorn herds may behave differently elsewhere in the United States, the best predictor of behavior of a new herd is the behavior of existing herds in the same general area. Most bighorn herds in southwest Montana do not annually migrate between wintering and lambing areas. An exception to this behavior are a few herds in the C-24

25 6-22 Southern Mountains ecological region (located east of the Gravelly Mountains), as noted in the draft Review. However, snow depth limits the movement of ungulates like bighorn sheep. Snow depth at Clover Meadows averages 52 inches on May 1 which limits ungulate movement. The behavior of bighorn sheep in Rocky Mountain National Park, while perhaps possible in the Gravelly Mountains, is unlikely based on observations of other herds in Southwest Montana and persistent snow depth. FS notes that GIS analysis (Appendix A) indicates that the Gravely Range generally lacks occasional rock outcroppings for escape terrain, diminishing its value as bighorn habitat (p. 18). FS also notes that escape terrain is least abundant west of the top of the Gravelly Range (p. 18). For interpreting the map of potential bighorn habitat (Appendix A) I find no requirement that bighorn escape terrain requires "occasional rock outcroppings", not in the 2 pages following the map nor in the cited description of the Habitat Evaluation Model (FWP Bighorn Strategy, 2010:60-64). BHDL is using a standard exceeding that of FWP. I agree there is less bighorn habitat west of the top of the Gravelly Range, in the Ruby River corridor. However, the literature on bighorn movements indicates that neither the Ruby River corridor nor the limited, dispersed habitat northwest of the Gravelly Range (Appendix A) would be barriers never allowing exchange of animals between the Gravelly Range and the Greenhorn or Snowcrest Ranges. (Lack of clear evidence of bighorn moving from the Greenhorn Range to the Gravelly Range during the last 13 years [p. 25] is equally explainable based on the small Greenhorn population size, as noted above.) For genetic support to maintain allelic richness, only a few animals may need be exchanged between populations per generation. There is no evidence that a Gravelly Range bighorn population would never exchange animals with the Snowcrest or Greenhorn Ranges. RESPONSE: The 2010 Bighorn Sheep Conservation Strategy (FWP 2010) on page 71 defines bighorn sheep escape cover or terrain as slopes 60% or greater with occasional rock outcroppings. Bighorn sheep are generally found within 100 to 300 meters of escape terrain. Assumptions made by MFWP when modeling the bighorn habitat displayed in Appendix F are described in the Review starting at the bottom of page 23. MFWP comments provide additional discussion of the modeled habitat stating that modeled habitats in the Gravelly Mountains would not be expected to function as bighorn sheep winter habitat because of annual snowpack depth that is too deep. The MFWP process to reach such a decision would require an in-depth habitat analysis, public involvement and consideration of a commitment of resources for bighorn sheep management C-25

26 6-23 across the entire state of Montana (draft Review, pg ).The Review is not intended to take the place of an in-depth evaluation by MFWP. Rather, it considers generalized habitat attributes in the vicinity of the domestic sheep allotments and existing agency policy to assist the responsible official in determining if the new information (consideration by MFWP that bighorn sheep could be reintroduced to closed allotments) warrants supplementation of the original EIS prepared for the AMPs. This cursory review, coordinated with MFWP, indicates bighorn sheep habitat, even in the absence of domestic sheep on the BDNF in the vicinity of Black Butte, does not appear to provide sufficient year-round habitat needed for a bighorn sheep herd of 125 individuals or larger. The review does not conclude that allelic exchange would never occur. It simply considers the potential of MFWP reintroducing bighorn sheep to the Black Butte area if the domestic sheep allotments were closed. FS dismisses the Conservation Assessment of the Madison Valley's conclusions that potential bighorn habitat exists in the Gravelly Mountains and that a priority should be to restore bighorns to the Gravelly and Centennial Mountains (p. 21). In dismissing this report, FS rejects organizations, including the World Wildlife Fund, and authors who are well respected as sources of objective biological information. Moreover, FWP biologists participated in developing the Madison Valley Conservation Assessment. Instead, FS defers to FWP to develop arguments against the Madison Valley Report. FS states "there is no evidence" that the Madison Valley strategy is "proposed or supported by FWP" (p. 21). However, on this page, FS presents no evidence that FWP disagrees with conclusions in the Madison Valley strategy and ignores FWP participation in developing the Assessment. FS notes that FWP "questions the concept of metapopulations." (p. 21). However, in citing only one FWP EA, BHDL neglects to note that FWP recognizes both positive and negative aspects of metapopulations and relates all negative aspects to potential disease transmission (FWP Strategy 2010, pp ). Thus, the relative benefits from metapopulations can be achieved or increased by removing or reducing the risks of disease contacts. FS also neglects the abundant scientific literature on the necessity for metapopulations to maintain both genetic and demographic support for small populations. RESPONSE: The draft Review considers A Wildlife Conservation Assessment of the Madison Valley within the context of the intent and analysis assumptions of the report. Please do not interpret disclosure of habitat modeling attributes and analysis assumptions identified by the authors as dismissal of the report. The draft Review notes the author s conclusions that bighorn sheep might find suitable habitat in the absence of C-26

27 human influences and suggests a priority to restore bighorn sheep to the Gravelly and Centennial Mountains to complete meta-population connectivity. The potential habitat identified in this report does not include human activities, land use parameters, seasonal habitat components, juxtaposition of habitat patches and whether meta-population connectivity is desirable considering such connectivity potentially exposes foraying animals to pathogens. FS asserts that the amount of modeled habitat in the Gravelly Range is of limited size to support a herd of 125 animals (p. 24). Appendix A clearly shows that the base habitat for bighorn sheep in the Gravelly Range greatly exceeds 6.5 square miles, which is the FWP standard for supporting 125 animals (FWP Bighorn Strategy, 2010:62). FS presents no data to demonstrate that the Gravelly Range does not have 2.5 square miles of winter range, which is the FWP standard for supporting 125 animals (FWP Strategy, 2010:62). FS does not analyze Appendix A to measure indicated amount of summer range. Clearly, Appendix A indicates more than 3.6 square miles of summer range, which is the FWP standard for 125 animals (FWP Strategy, 2010:62) RESPONSE: The Review recognizes that there is historic and current modeled BHS habitat in the Gravelly mountain. The Review explains The amount of modeled habitat does not appear to be adequate as seasonal habitat components are lacking for sufficient year-around habitat and the modeled habitat is of limited size to support a bighorn sheep herd of 125 individuals. Other site-specific information must be considered along with the modeled habitat (Review, Section Consideration by MFWP that Bighorn Sheep Could Be Reintroduced to Closed Allotments ). As described in the Review, other factors include small-sized scattered areas of habitat, tree cover, snow depth that is too high for BHS survival, and capacity of available ungulate winter range and potential seasonal migration paths. The quantity of modeled habitat forms a starting point for consideration of Bighorn transplant locations. As disclosed in the 2010 Conservation Strategy and Appendix F, additional characteristic beyond those included in the model should be evaluated by site specific assessment by trained biologists to determine the validity of the model. The cursory analysis considered in the Review, and coordinated with MFWP, indicates current habitat conditions and characteristics would prevent reintroducing bighorn in the Gravelly Mountains in the winter and re-introduction would need to occur on suitable winter range and BHS would need to find their way to suitable summer habitats in the Gravelly Mountains. The Review states that no bighorn from the Greenhorn herd have knowingly dispersed into the Gravelly Mountains and it is thought because of the mild topography (less C-27

28 6-25 than preferred for escape from predators) and large expanses of forested cover (which BHS tend to avoid) in between summer habitats and the Greenhorn herd. FS notes that Appendix A indicates little bighorn sheep habitat within the domestic sheep allotments (pp. 14, 26). FS' own analysis of domestic/bighorn sheep disease transmission and needed separation distance (pp ) indicates that domestic sheep on these allotments will eliminate opportunities for a persistent bighorn population across many miles, to include, not just the allotments, but essentially all the potential bighorn habitat in the Gravelly Range (Appendix A). Noting that there is little bighorn habitat on most of the allotments is a diversion from relevant information RESPONSE: The Review characterizes potential modeled bighorn sheep habitat within the domestic sheep allotments but also within the Gravelly Mountains, the Gravelly Landscape (an area of nearly 2-million acres) and the BDNF in general to put the modeled habitat in context with other known Bighorn herds FS blames conifer encroachment for degrading bighorn habitat in the Gravelly Range (p. 26). I agree that conifer encroachment degrades bighorn ranges. However, considerable potential bighorn habitat remains in the Gravely Range (Appendix A). Conifer encroachment is the responsibility of the Forest Service. It has been accelerated for decades by Forest Service fire suppression. Conifer encroachment on bighorn habitat is rectifiable by strategically located timber removal or prescribed burns. RESPONSE: We agree that habitat enhancement projects designed for Bighorns would benefit the species, Please see the response to Comment 3-2 above on the current proposal for vegetation management in the Greenhorns, FS asserts that, following removal of domestic sheep, reintroduced bighorns in the Gravelly Range would endure a "high level of risk of contact with domestic sheep on nearby private lands." {p. 19). FS has not analyzed the potential risk of contact. There is no summary of domestic sheep operations in the Madison Valley. FS does not recognize that, if Gravelly Range bighorns were to migrate to winter range in the Madison Valley, the Wall Creek Wildlife Management Area could provide isolation from any domestic sheep. Moreover, a migration corridor to Wall Creek WMA could be developed with strategic use of prescribed fire. Based on poor isolation of bighorn habitat, inholdings and distance from the Forest perimeter, FS accepts a higher level of risk for contacting domestic sheep for most, if not all, bighorn herds on the Forest. Based on distance from the Forest perimeter, the Gravelly Range offers the highest potential for a bighorn herd isolated from domestic sheep. C-28

29 (A possible exception is the Tobacco Root Range, which is large but has more private inholdings that may harbor domestic sheep, and perhaps has more forest encroachment problems.) Regarding the position of FWP on this risk of contact in the Gravelly Range, FWP has recently considered, with EAs, 2 transplants with far less isolation from private lands where there may be domestic sheep (The Bridger Range and an area near Whitehall) RESPONSE: The Review, Section Consideration by MFWP that Bighorn Sheep Could Be Reintroduced to Closed Allotments describes Bighorn habitat conditions at the high elevations in the Gravelly Mountains where the domestic sheep allotments are located. Due to the multiple feet of snow these high elevations receive, it is reasonable to assume bighorn sheep would have to migrate to lower elevation BLM and private lands to live during the winter. FWP comment letter (Appendix E) acknowledges that there is no bighorn habitat on Wall Creek WMA and the neighboring habitat receives too much snow to function as bighorn sheep habitat. While MFPW considered transplants in the Bridger Range and near Lewis and Clark Caverns (near Whitehall), neither transplant has proceeded due to concerns expressed to private landowners and potential exposure of bighorn sheep to pathogens. FS argues that FWP has not determined that reestablishing bighorns in the Gravelly Range would be a priority, if domestic sheep were removed {pp. 19, 26). FS support for this argument is a personal communication with a retired FWP biologist (p. 19). We do not know the context of this statement. For potent political reasons, FWP has conducted no detailed, objective review, with public participation, of any possibility for reestablishing bighorns in the Gravelly Range. FWP silence on the possibilities for bighorn in the Gravelly Range is based on political pressure from the woolgrowers industry. The degree of FWP submission to political pressure on this issue is illustrated by FWP policy (Strategy 2010:3): "FWP believes that any localized removal, transfer, or conversion of established domestic sheep allotments on public lands for the benefit of bighorns should only come with the willing participation of the producer." This statement provides any one domestic sheep producer with veto power over decisions for managing Forest Service land! Such veto power is not legal on Forest Service land. However, in supporting the status quo for domestic sheep in the Gravelly Range based upon an argument that FWP is not interested in discussing a transplant, the Forest Service is recognizing this illegal position. This is a self-generated public agency catch-22. Forest Service will not remove domestic sheep because FWP, allegedly, will not reintroduce bighorns anyway; and FWP will not reintroduce bighorns so long as the Forest Service will not remove domestic sheep. C-29

30 RESPONSE: Please review the letter from MFWP commenting on the draft Review found in the final Review Appendix E. (Also available at: The FWP s letter identifies numerous factors leading to their statements releasing bighorn sheep into the Gravelly Mountains is unlikely to occur and that removal of domestic sheep from the Gravelly Mountains will not directly facilitate establishment of bighorn sheep onto summer habitats of the Gravelly Mountains. See Appendix E. This letter is in support of domestic sheep grazing on the Beaverhead- Deerlodge National Forest in the Gravelly Mountains. We believe the U.S. Forest Service fully addressed all requirements of The Review. We trust The Review completed in compliance with the June 14, 2016 District Court Order requiring the U.S. Forest Service to review five issues raised by the Gallatin Wildlife Association and others. This confirms that the analysis is significant and relevant to environmental concerns. Our family is hopeful you will acknowledge the importance of domestic sheep grazing, as a form of multiple use, in the management of the Beaverhead-Deerlodge National Forest on the Gravelly Mountains. RESPONSE: Thank you for reviewing the document. (1) The reintroduction of bighorn sheep; The BDNF claims: The Greenhorn bighorn sheep herd has now been established and the overall population is reproducing and moving towards providing hunting opportunities (p 13). FWP bighorn monitoring data reveal that even a minimally viable population of bighorn sheep has failed to establish within the Greenhorn Mountain Range. FWP counts have never been larger than the 80 animals counted in 2006 (FWP 2010(a)). The most recent FWP counts from 2015 observed 59 animals and 48 animals in 2016 (USFS 2017). These numbers are far below even the FWP stated Minimum Viable Population of 125, which according to the best available science is an arbitrary figure that is vastly too low (personal communication from Dr. Val Geist to J. A. Bailey, May 5, 2015 and Dr. Fred Allendorf, Thursday Oct 13, :35 pm). See also Traill et al (2010), which critically reviewed minimum population size requirements for species based on empirical and theoretical estimates made over the past few decades. This literature collectively shows that thousands (not hundreds) of individuals are required for a population to have an acceptable probability of riding-out environmental fluctuation and catastrophic events, and ensuring the continuation of evolutionary processes. Lande (1988) also points out that demographic factors (in addition to genetic factors) cannot be ignored when estimating a MVP. Factoring in such considerations often requires larger numbers for population persistence over time. Regardless, a MVP of bighorn C-30

31 sheep limited to the relatively small Greenhorn Range has never been realized as a result of this reintroduction much less a population level that will provide sustainable hunting opportunity. 8-2 RESPONSE: An established herd is not the same as a minimal viable herd or a minimal viable population. We used the term established to differentiate between the existing Greenhorn bighorn sheep herd and the analysis of a proposal in the 2001 by MFWP to transplant individuals to the Greenhorn Mountains. A bighorn sheep herd has been established through successful translocation by MFWP in 2003 and 2004, in the Greenhorn distribution area (see DSEIS, pg. 10). Individual members of this herd are residing year-round in the area and reproducing. Population surveys have not yet confirmed a desired herd size of 125 or more individuals. The FWP documents bighorn sheep observations and emphasizes that the classified sheep reflect the minimum number of bighorns alive at the time during each yearly survey. The total population is an unknown number higher than the minimum number alive. See Appendix B. The 2010 Conservation Strategy describes parameters for a minimum viable population for potential transplanted herds specifically citing research for bighorn sheep. Berger (1990), Geist (1975) and Smith et al (1991) found bighorn sheep herds of individuals persisted for up to 70 years (MFWP, 2010, pg. 61). The minimum viable population size studied in Traille, et al (2010), Lande (1988) and others is associated with persistence or risk of extinction of a species. For a species like bighorn sheep that are distributed across a vast geographic area (the Rocky Mountains) and are highly mobile, the minimum viable population sizes described in these studies are not intended to be restricted to the herd level. MFWP estimates there are over 1,000 bighorn sheep in ten herds located, in part, on the BDNF and more than 5,000 bighorn sheep in Montana. The Natural Heritage Program ranks bighorn sheep (as a species) as apparently secure in Montana and globally. Permitted domestic sheep grazing on the BDNF in the Gravelly Mountains pose a risk of exposing individual bighorn sheep to pathogens if both species occur in the same location at the same time. Commingling of the species on the BDNF is unlikely. Shaffer (1981) proposed the concept of the minimum viable population (MVP). He defined the MVP as the smallest isolated population (of a given species in a given habitat) having a 99% chance of remaining in existence for 1,000 years, despite the foreseeable effects of demographic stochasticity, genetic drift, environmental stochasticity (random changes in the environment), and natural catastrophes (Shaffer,1981). C-31

32 Shaffer chose the percentage and times to represent what most scientists consider a good chance for survival of a species. Populations smaller than the MVP are considered to be at significant risk of entering in to the extinction vortex and becoming extinct. A conservation program can be considered successful only if it raises the effective population size above the MVP. The effective population size (Ne) is the number of individuals in a population who contribute offspring to the next generation (adults), which is generally much lower than the actual or census population size (Nc). A generally proposed genetically effective population size, Ne, was outlined by Franklin (1980) as being 500 breeding animals. Consideration of demographic factors would likely require even a larger effective population (Lande 1988). Thus, rather than being considered established it is more likely the Greenhorn herd, at 59 observed animals in 2015 and 48 observed animals in 2016, and never more than 80 animals observed (2006) since its reintroduction in 2003/2004, is in the extinction vortex described by Shaffer (1981). Regardless, there is little doubt that, for long-term evolutionary persistence, the Nc or census population size to ensure genetic viability is likely to be in the thousands rather than the hundreds (Jamieson and Allendorf 2012). Even if there is considerable uncertainty and disagreement over both the estimates of Ne at a minimum desirable drift mutation equilibrium point and estimates for the Ne/Nc ratio, the argument that evolutionary potential will be retained in population sizes in the thousands and not hundreds is likely to be true (Jamieson and Allendorf 2012). 8-3 RESPONSE: Please refer to the response to Comment 8-1. Shaffer (1981) does not speak specifically to bighorn sheep or even ungulates and the author stresses his definition for MVP is tentative and arbitrary. Jamieson and Allendorf s (2012) proposal for application of the 50/500 rule was met with scientific rebuttal and discussion (see Frankhem, et al [2013] and Jamieson and Allendorf [2013]). Regardless, there is no indication the authors intended the principles proposed in their articles to be applied to an ungulate population at the limited geographic scale of the Greenhorn bighorn herd or potential effects of permitted domestic sheep grazing in the vicinity of Black Butte. Furthermore, USFS/FWP Maps on page 5 of Appendix B reveal that most observations of the Greenhorn bighorn sheep from Oct 2013 through April 2016 have occurred off the BDNF land confined within the Greenhorn Mountain Range. Bighorns appear to be moving northwest to private, State and BLM lands near the Ruby River Reservoir Dam and southwest to BDNF land within the Snowcrest Range and adjoining FWP Wildlife Management Areas, DNRC State Lands and a few BLM parcels, which are substantially closer to the domestic sheep trailing route through the Notch a few miles C-32

33 further to the southwest. As well, thirty four bighorn sheep have been removed either lethally (16) or physically (18) by the FWP from because they left the limited landscape offered in the Greenhorn Mountain Range (FWP 2010(a)). RESPONSE: Please see the response to Comment 6-8. Please refer to the Review section Reintroduction of Bighorn Sheep and the DSEIS for additional information about removal of transplanted bighorn sheep between 2003 and 2008 and presence of domestic sheep trailing west of the BDNF. The BDNF claims: Habitat in the Greenhorn Mountains is capable of sustaining a quality bighorn herd, above the FWP objective of 125 animals, and providing hunting opportunities (p 11 and elsewhere). The Greenhorn herd s ability to reach the FWP goal of 125 animals has not been tested. It has taken 13 years to reach having 59 observable bighorn in 2015 and 48 in 2016 (USFS 2017). Hanski et al. (1996) note the assumption that metapopulations occur at a steady state, common to many models, may be frequently violated because of the high rate of habitat loss and fragmentation in many landscapes. Scores of rare and endangered species may already be "living dead," committed to extinction because extinction is the equilibrium toward which their meta-populations are moving in the present fragmented landscapes. To conserve these species we should reverse the process of habitat loss and fragmentation (Hanski et al. 1996). 8-4 RESPONSE: A metapopulation is a set of populations distributed over a number of patches that are connected, to varying degrees, by dispersal. A patch in relation to a bighorn sheep metapopulation is a defined portion of the landscape that contains all the elements that support a subpopulation of the metapopulation. Montana has 5 separate metapopulations of bighorn sheep. Benefits of a viable metapopulation include maintaining or increasing genetic variation and producing populations that are thought to be less vulnerable to extirpation than small, isolated populations due to demographic or stochastic events or contact with domestic sheep. (MFWP, 2010, pg ). However, increased connectivity of subpopulations increases the prevalence, incidence and rate of disease spread in the overall population, and increased contact can enable a disease to persist with the metapopulations (MFWP, 2010, pg ). In Montana, there is a need to focus research efforts to ensure long-term maintenance of existing metapopulations and protecting corridors that provide connectivity within the metapopulations rather than trying to restore corridors after fragmentation (MFWP, 2010, pg. 42). Because the Greenhorn bighorn herd has not been identified as part of a metapopulation, it is reasonable to C-33

34 8-5 expect MFWP will focus herd management within the mapped distribution area of the herd and continue considering removal of individuals risking commingling with domestic sheep with the intent of reducing disease spread to the herd itself or a different herd. See comment 8-1 regarding the distribution of bighorn sheep across the state in terms of risk of extinction. Many established bighorn herds in Montana have experienced episodic dieoffs with several apparently disease-free intervening years. That the Greenhorn herd did not experience a dieoff in 2010 (p. 9), or since 2003, provides no evidence that commingling and disease of bighorns is impossible, or even unlikely (p. 9). BDNF admits a risk of the Greenhorn herd contacting domestic sheep and experiencing episodic dieoffs exists to the West and North (pp. 11, 15) RESPONSE: The Review does not state that commingling, pathogen exposure and disease are impossible. The Review considers if the 2001 MFWP evaluation that commingling of individual Greenhorn bighorn sheep and domestic sheep permitted on the BDNF is unlikely remains valid. About 67% of observations of Greenhorn bighorn have been off BDNF land, indicating that the Forest is contributing little to any success of the herd, and suggesting that BDNF habitat could be improved with vegetation management to attract and hold bighorn. BDNF notes there are more domestic sheep and goats in Beaverhead and Madison Counties than the number of domestic sheep ever on allotments of the Forest (p. 8); and that the diversity of domestic sheep operations on private lands decreases ability for controlling disease transmission (p.15). BDNF implies that, because resulting risks of bighorn disease are greater off the Forest, the lesser risks on the Forest can be justified. BDNF does not recognize the risks off the Forest are exactly why there is a need for disease-secure bighorn habitat in the interior of the Forest, distant from private lands. BDNF does not recognize abundant literature demonstrating that 125 bighorn are certainly not genetically adequate and very likely not demographically viable (Traill et al. 2010). RESPONSE: Please refer to the Responses to Comments 6-8, 6-10 and 8-1. BDNF lauds the fact that the Greenhorn herd has reached about 59 animals in 2015 (only 48 were observed in 2016) and that FWP may soon allow ramhunting of this herd. However, considering its population history (FWP 2010(a)), the Greenhorn herd has certainly been inbreeding for 13 years. Abundant literature demonstrates that inbred populations have poor resistance to disease, and that following episodic disease, some inbred animals can remain as disease carriers. This is a reasonable hypothesis for the persistence of lamb mortality following disease events in other bighorn C-34

35 sheep herds on the BDNF (FWP 2010). Diminished resistance to disease due to inbreeding has been documented in wild and domestic populations. In wild vertebrates, inbreeding has been shown to reduce resistance to invertebrate parasites (bighorn sheep, sea lions) (Acevedo-Whitehouse et al. 2006, Luikart et al. 2008) and to bacterial pathogens (wild boar, finches) (Acevedo- Whitehouse et al. 2005, Hawley et al. 2005). Most recommendations are to maintain at least several hundred breeding animals to avoid levels of inbreeding that will significantly depress reproduction and/or survival. A genetically-effective population (Ne) of 500 breeding animals is a commonly accepted recommendation (Franklin 1980). A herd of about 60 bighorn has a genetically-effective population, Ne, of only about 20 animals because many animals in a population will not breed (lambs, young rams, old females for example). This is perilously low. In addition, such small bighorn populations are losing genetic diversity (loss of alleles), have little evolutionary potential, and lose adaptive characteristics due to genetic drift RESPONSE: Please refer to responses to Comments 8-1, 8-2 and 8-4. Luikart, et al (2008) presents similar findings for susceptibility to lungworm by small-sized herds as research described in the previous comments. Research about bacterial pathogens and invertebrate parasites for sea lions, finches and wild boars are not readily applicable to bighorn sheep. Research (see response to Comment 8-1) does not identify concerns about inbreeding of isolated bighorn herds within 18 years. Rather, bighorn herds of appear to persist over a 70-year period (FWP 2010) BDNF uses the FWP population criteria for allowable hunting of bighorn rams (p. 7) to support its argument that the Greenhorn bighorn are, or are becoming, a quality herd. However, removing breeding-age rams from this small herd will reduce the Ne even further below 20, exacerbating genetic problems. BDNF failure to recognize this issue is but one demonstration of the inadequacy of the Review. RESPONSE: Please refer to the response to Comment 6-3 and 6-4. Genetic problems have not been noted in the Greenhorn herd In essence, BDNF contends that having a minimally viable, genetically inadequate and inbred at risk bighorn herd requiring frequent culling to prevent contact with domestic sheep, with a 2/3 of its range off the Forest, is sufficient to comply with the NFMA mandate to provide adequate habitat for native species on the Forest. GWA strongly disagrees. This BDNF conclusion avoids the intent of the GWA complaint. GWA contends that the small bighorn herds on the BDNF Forest, all on the peripheries of the Forest, are not adequate for maintaining a public resource. The Greenhorn herd is just one of the inadequate herds, as noted above. Bighorn herds on the BDNF C-35

36 Forest do not provide evidence that the Forest is providing adequate habitat for a native species, as required by NFMA. GWA contends that public, mostly Forest Service lands including and surrounding the Gravelly Range, provide the best opportunity on the BDNF Forest for a large, contiguous area of public lands for bighorn habitat sufficient for a large population having minimal contact with domestic sheep on the periphery of the public lands. The Review does not address this basic issue of the complaint RESPONSE: Please refer to responses to Comments 6-3, 6-9 and 8-1. BDNF relies upon FWP for its understanding of and standards for bighorn population quality. It does not consider the possibility that FWP ignores principles of population genetics and is a very politically-limited agency prone to avoiding controversial issues. RESPONSE: Please refer to the response to Comment 6-3, 6-4, 6-28 and 8-1. The BDNF claims: Commingling of Greenhorn bighorn with domestic sheep on the BDNF Forest has not occurred and is unlikely due to habitat barriers (p 11). BDNF does not recognize there has been one observation of a bighorn ewe, found dead in 2013, near Black Butte within or near the domestic sheep allotments (FWP database, Dillon office). Since ewes seldom travel alone, it is likely that more than one wild sheep has visited the allotments at some time and FWP s monitoring is limited because none of the remaining bighorn sheep have radio collars any more. RESPONSE: Please see the response to Comment 6-6. The BDNF claims: The bighorn monitoring data for the Greenhorn herd show a population increase from 17 bighorn counted in 2009 to a minimum of 59 bighorn in 2015 and a minimum of 48 bighorn in the spring of 2016 (p 7). FWP monitoring data indicate a count of 30 total bighorns in 2009 not 17 (FWP 2010(a)). Furthermore, a total of 69 bighorns were reintroduced into the Greenhorns 30 in 2003 and 39 in The latest FWP counts found only 59 in 2015 and 48 in The largest count recorded by FWP was 80 in 2006, which is substantially more than the 48 observed in The data does not reveal a population that is increasing since the point of reintroduction ( ) or the highest count observed (2006), rather exactly the opposite. RESPONSE: The 2010 Conservation Strategy disclosed A total count of 31 sheep in April 2007 is the latest high observed count available (MFWP, 2010, pg. 221). Monitoring data from MFWP is included in the Review as Appendix B. MFWP cautions using annual fluctuations in numbers of observed bighorn sheep to indicate population changes). C-36

37 Furthermore, Berger (1990) in a study of persistence of different-sized populations of bighorns found that populations of 50 individuals or less, even in the short term are not a minimum viable population. Indeed, 100% of bighorn sheep populations reviewed in this study with less than 50 individuals went extinct within 50 years. This is the current situation facing the Greenhorn herd, the only small herd across the entire 2 million acre Gravelly Landscape. The cumulative effect of the domestic sheep use of the allotments on the BDNF and the associated trailing across miles of landscape to and from the allotments each spring and fall, including some use of BLM lands along the way, which were not revealed in the analysis is indeed significant to habitat suitability for bighorn sheep RESPONSE: Berger (1990) found populations of less than 50 individuals went locally extinct within 50 years while populations greater than 100 individuals persisted for up to 70 years providing support for MFWP population objective of at least 125 individuals in the Greenhorn herd. Later discussion by this author (Berger, 1999) poses augmentation of small populations (less than 15) as potential management intervention. Information about the historic and current herd size of the Greenhorn herd has been added to the Review. Concerning analysis of trailing impacts and cumulative effects, the Review discusses the location of the trailing routes and the potential for trailing routes to affect bighorn sheep due to commingling. In addition, the 2001 MFWP Reintroduction EA considered the potential for commingling of the species along trailing routes (p.10). The analysis shows that in the 13 years since the establishment of the Greenhorn bighorn sheep herd there has been no known bighorn-domestic sheep commingling either from trailing or use of the BDNF sheep allotments. Further, the analysis discusses how the timing and manner in which trailing occurs creates effective practices to limit the possibility of commingling. We will add to the analysis a discussion of effects of trailing to the BDNF allotments across other lands, including BLM lands. Please also see Appendix A map. The BDNF claims: Research done by Brock et al (2006) pointing out the importance of the Gravelly Range for bighorn sheep is not supported by FWP or BDNF (pp 21&22). To the contrary, numerous FWP and BDNF Wildlife Biologists and Range Ecologists are acknowledged in Brock et al (2006) (p1) for assisting with focal species identification (Bighorn Sheep were one of the focal species identified), threats analysis (domestic sheep were identified as a significant threat to bighorn sheep and grizzly bears, another focal species), and for reviewing the models used as well as the assessment overall. Some of the Biologists we recognize from FWP at the time include Kurt Alt, Keith C-37

38 Aune, Bob Brannon, Craig Jourdannais, Tom Lemke and Dave Pac. The Biologists and Ecologists we recognize from the BDNF at the time include Mark Petroni, Andy Pils, Art Rohrbacher, Ron Schott, Kevin Suzuki and Ron Wiseman. Many of the BDNF Biologists/Ecologists are pictured in the full report (Brock et al. 2006(a)) on page 27, looking over maps. As well, please see the write-up and maps in Brock et al (2006(a)) for bighorn sheep on pages Jim Roscoe, a Wildlife Biologist from the BLM at the time was also acknowledged for his help as well RESPONSE: Brock et al (2006) acknowledges the assistance of numerous individuals on the title page. However, acknowledgement of assistance does not indicate agency, or individual, agreement with the recommendations of the authors (Brent Brock, Eric Atkinson, Craig Groves, Andra Toivola, Tom Olenicki and Lance Craighead). Please consider the findings published in Brock et al (2006) within the context of the applicable section of the Review. The recommendations from Brock et al (2006) were considered as part of an assertion from Gallatin that MFWP would reintroduce bighorn sheep into the Gravelly Mountains in the domestic sheep allotments on the BDNF that were closed. Review of this assertion begins specific review of recommendations from Brock et al (2006) in the section Consideration by MFWP that Bighorn Sheep Could Be Reintroduced to Closed Allotments. Please note Brock et al (2006) did not consider potential for disease spread between bighorn herds from foraying bighorn sheep as they encountered domestic sheep or other bighorns and whether this connectivity is desirable. Brock et al (2006) points out: Domestic Sheep: Sheep create unique wildlife conservation challenges because of their potential to spread disease and their vulnerability to predation. Native bighorn sheep and domestic sheep cannot be managed in the same area because domestic sheep carry several diseases that are lethal to native bighorns. In addition, domestic sheep are relatively small and defenseless and thus are more prone to predation by large carnivores such as bears and wolves than are larger species of livestock. Several contiguous sheep allotments in the Gravelly Mountains are located within high quality potential bighorn sheep habitat as well as within an area currently being recolonized by grizzly bears. These allotments should be retired or relocated to allow the establishment of a native bighorn herd in the area and to reduce potential conflicts with recovering grizzlies. Disease: Disease was identified as a potential threat for 3 of our focal species. Bighorn sheep are susceptible to several diseases carried by domestic sheep to the extent that the two species cannot inhabit the same areas. Chytrid fungus and ranavirus are two amphibian diseases that have caused major die-offs in other areas whereas only ranavirus is known to occur in the Madison Valley. In addition, brucellosis does not directly C-38

39 threaten wildlife in the valley but its presence in elk could potentially alter management of the species as it has for bison outside Yellowstone National Park. Finally, chronic wasting disease is not currently present in the region but remains a potential threat. At present, wildlife in the valley, with the exception of bighorn sheep, do not appear to be significantly impacted by major diseases but monitoring is warranted. Bighorn Sheep: There are several opportunities to improve the long-term viability of bighorn sheep in the Madison Valley. There remain three significant blocks of habitat that are currently unoccupied and may support reintroduced populations of sheep. The Tobacco Roots appear to offer extensive areas of high quality habitat and do not contain domestic sheep allotments. The Gravelly and Centennial Mountains contain significant amounts of potential habitat that historically were occupied. However, domestic sheep grazing in those areas would need to be mitigated before their value for bighorn sheep could be realized. Connectivity between isolated patches of habitat needs to be maintained to allow bighorn to naturally re-colonize patches where sheep have disappeared. Fragmented populations typically experience periodic local extinctions within isolated habitat patches. Restoring bighorn to as many suitable patches as possible and maintaining connectivity between patches will help to maintain a robust meta- population without the expense and uncertainty associated with artificial relocation programs. A priority of immediate concern should be to maintain connectivity across Jack Creek to allow expansion of the Spanish Peaks herd into the Fan Mountain area. A long-term priority should be to restore bighorn to the Gravelly and Centennial Mountains, which could provide complete metapopulation connectivity among all bighorn herds within the Madison assessment area. Mitigating the use of salt for winter snow maintenance should reduce mortality caused by vehicles. Bighorn are drawn to salt that accumulates in the vicinity of the confluence of US Hwy 191 and MT Hwy 64. Where practical, efforts should be made to discouraging sheep from congregating near the road where they are likely to be involved in an accident. Alternative methods of snow abatement should be explored to reduce this threat. In addition, the stretch of US Hwy 287 in the vicinity of Quake Lake runs in proximity to moderately good bighorn habitat. Potential impacts of road salting on bighorn sheep in this area should be considered. RESPONSE: Permitting grazing by domestic sheep on allotments near Black Butte does not influence translocation by MFWP of bighorn sheep to the C-39

40 8-16 Tobacco Root or Centennial Mountains nor does it alter expansion of the Spanish Peaks herd into the Fan Mountain area (Madison Range). Translocation of bighorn sheep to the Gravelly Mountains, even in the absence of permitted domestic sheep, is not a priority for MFWP for the reasons disclosed in the Review and the MFWP comment letter. Further, the Gravelly Mountains bighorn sheep habitat has limited escape terrain and lacks available winter range. Also, permitted domestic sheep grazing near Black Butte in the summer does not alter winter snow maintenance on highways located off the BDNF in the valley bottom. Brock et al (2006) points out: Grizzly Bear: It is difficult to overestimate the potential role of the Madison Valley in securing the long-term future of grizzly bears in the Northern Rockies. Vast areas of unoccupied habitat lie to the west of the Madison Valley with a narrow strip of high quality habitat through the valley providing the best potential linkage between these unoccupied areas and the GYE. Maintaining this relatively small strip of habitat as a high quality corridor will allow grizzly bears to continue to expand into formerly occupied range to the west. In addition, this linkage zone will provide a conduit for genetic exchange between the GYE and surrounding grizzly populations. This corridor extends south from Wolf Creek to Raynold s pass with highest connectivity value where Papoose Creek cross US Hwy 287. Most of the unsubdivided land in this area has already been placed under conservation easement but the subdivided properties are currently at less than 20% buildout. Efforts should be made to work with landowners in the area to maintain the area as the highest quality, and most effective wildlife habitat linkage corridor possible. A second potential corridor from Norris to Meadow Creek and the Tobacco Root Mountains should be considered a priority for conservation action and wildlife value. In order to ensure long-term success of grizzly bear recovery in the area, efforts should continue to minimize humanbear conflicts and the subsequent removal of grizzly bears. Both the Beaverhead-Deerlodge and Gallatin National Forests have implemented mandatory bear safe food storage regulations for backcountry users. Obviously enforcement and user education are essential tools to ensure these regulations are effective in reducing conflicts. Domestic sheep allotments in the Gravelly Mountains where grizzly bears are already beginning to recover should be retired or relocated to avoid conflicts. As previously mentioned in this report, those areas also occur in potential bighorn sheep range so the removal of these allotments would have multiple wildlife benefits. C-40

41 Many grizzly bear mortalities occur when hunters who are confronted by bears choose to defend themselves with firearms. While self-defense with a firearm is a legal bear killing, studies indicate that bear spray is more effective at stopping a charging bear than a bullet. Hunters entering bear country should be required to carry bear spray and be trained in its efficacy and use. Existing state and local laws prohibiting the feeding of wildlife and improper food and garbage storage should be strictly enforced, particularly within areas designated as high quality linkage habitat where the loss of a single bear significantly diminishes grizzly bear recovery progress RESPONSE: Permitted domestic sheep grazing near Black Butte does not influence potential subdivision of private property (currently managed for agricultural purposes) in the Madison Valley from Wolf Creek to Raynold s Pass (Madison Range to the Island Park area in Idaho) or from the Norris to Meadow Creek (Madison Range to the Tobacco Root Mountains), potential human-bear conflicts from backcountry recreation/hunting use, or enforcement of laws restricting feeding of wildlife and food/garbage storage. The Forest Plan (pg. 49) includes a provision for closing vacant domestic sheep allotments in the Gravelly Landscape. The Review discusses the potential for MFWP to reintroduce bighorn sheep to the Gravelly Mountains. The BDNF claims: Citing Brock et al (2006) The Tobacco Root Mountains appear to offer extensive areas of high quality habitat for bighorns and they do not contain sheep allotments. We agree and feel the Tobacco Root Mountains are an important piece of the historical habitat for bighorn sheep that is currently unoccupied on the BDNF. Protecting and connecting the Tobacco Root Mountains with the Gravelly Landscape and Madison Range while establishing various meta-populations of bighorn sheep is a concept we and Brock et al (2006) support. RESPONSE: At this time, bighorn sheep do not occupy historic habitat in the Tobacco Root Mountains. Potential consideration of the area as a priority for translocation is considered in the Review. The desirability of connecting a potential bighorn herd in the Tobacco Root Mountains (assuming a herd is established at some future time) with the Greenhorn herd currently established in the Gravelly Landscape and the Spanish Peak and Hilgard herds in the Madison Range must also consider potential disease transmission from domestic sheep and goat herds The BDNF claims: FWP has revealed no indication it supports a strategy to protect and connect large landscapes of public lands to provide complete C-41

42 meta-population connectivity among all bighorn herds within the Madison/Gravelly assessment area (p 21). To the contrary, FWP recognizes the positive aspects of connecting and protecting habitat and metapopulations of bighorn sheep across larger landscapes (FWP 2010 pp 40-42). FWP also acknowledges risks to such a strategy, but these risks center on the presence of domestic sheep and goats and the likelihood of disease transmission between the native bighorns and the exotic species. Thus, to the degree the BDNF promotes or allows domestic sheep use of historic public land bighorn sheep habitat such as in the Gravelly Range near Bighorn Mountain, the BDNF ties the hands of the FWP from exploring large landscape and meta-population connectivity solutions. RESPONSE: Please refer to the response to Comment 8-4. For bighorn sheep, connectivity is influenced by factors other than just the absence of domestic sheep and goats, including the presence of other herds and connected suitable habitat. While a few individuals have proposed the Gravelly Mountains as a corridor those proposals have not considered which herds or metapopulations would reasonably use such a corridor. Brock, et al (2006) suggests a corridor through the Gravelly Mountains connecting bighorn sheep habitat in the Centennial Mountains to the south. However, there are no bighorn sheep herds in the Centennial Mountains and at this time, no plans by MFWP or Idaho Fish and Game to establish a herd. As a result, removal of permitted sheep on the BDNF would not connect a herd in the Centennial Mountains or immediately south of the Montana/Idaho border with the Greenhorn or other herds. Geographically, it appears the Gravelly Mountains could be used as a corridor between the Hilgard and Tendoy bighorn herds. However, the Tendoy herd is currently being depopulated due to persistent disease. At this time, it is unknown when a herd of sufficient size to begin forays into other areas may become established in the Tendoy area, if they would cross the large area lacking modeled habitat between the Tendoy and Gravelly Mountains (see Review, Appendix F) or the risk of exposure to pathogens from domestic sheep and goats between these areas (most of the area between the Gravelly and Tendoy Mountains is not administered by the BDNF). Assuming the reverse, that individuals from the Hilgard herd may proceed west across the Gravelly Mountains. While Idaho Department of Fish and Game (IDFG) recognizes a potential travel corridor with these herds and the Yellowstone ecosystem they caution the corridor could provide an avenue for spread of disease and parasites among sub-populations. IDFG also recognizes a risk of pathogen exposure due to the presence of domestic sheep on private property in Idaho (IDFG, 2010, pg ). While connecting Montana/Wyoming s Yellowstone metapopulation with Idaho s metapopulation in the Salmon C-42

43 8-19 River country would provide genetic exchange described as advantageous in other comments, the desirability of such a connection remains rife with uncertainty. Some researchers have found pathogens in the respiratory tracts of bighorn sheep with disease symptoms absent in the herd. Until such management challenges with pathogen spread are adequately resolved, the MFWP and IDFG are focusing management efforts on existing metapopulations, not connecting metapopulations at the large scale conceptualized for the Gravelly Mountains and beyond. The BDNF Claims: The terrain between the Greenhorn Mountains and the top of the Gravelly Mountains, while frequently meeting the 60%+ slope habitat characteristic, generally lacks occasional rock outcroppings, especially between the Ruby River and the top of the mountain range. In addition, lodgepole pine forests dominate the north facing slopes beginning at Warm Springs Creek and subsequent drainages to the south. These forests do not provide desirable bighorn sheep foraging habitat (grass and shrubs) in the understory and are so dense that visibility for detection and avoidance of predators is limited. The presence of these bands of dense, forested vegetation likely deter southerly movement of individual bighorn sheep (p 25). These statements are contradicted by the BDNF discussion under Vegetation/Soil/Water (p 22): A little less than half of the area within the sheep allotments are open grasslands and sagebrush/grass plant communities. The dominate grassland plant communities classify as Idaho fescue (Festuca idahoensis)/ bearded wheatgrass (Agropyron caninum) or Idaho fescue/tufted hairgrass (Deschampsia cespitosa) habitat types (Mueggler and Stewart, 1980). Wet meadows found in the allotments generally fit the tufted hairgrass/ Sedge (Carex spp.) habitat type. Shrub dominated communities are generally found toward the lower elevations of the allotments. The dominant habitat type here is mountain big sagebrush (Artemisia tridentate)/idaho fescue with a sticky geranium (Geranium viscosissimum) phase. The bulk of permitted domestic sheep grazing occurs within these plant communities. The remainder of the allotments are dominated by forests with small, scattered rock cliff and scree slopes. The dominant tree species found in the area are lodgepole pine (Pinus contorta), subalpine fir (Abies lasiocarpa) and whitebark pine (Pinus albicaulis). In the less dense more open forest communities ground vegetation can be well established. This low vegetation is comprised of various grasses and forb. These areas can be grazed by permitted sheep. Furthermore, the entire area described was mapped as suitable and occupied habitat for bighorn sheep in 1890 (FWP 2010) and in 1950 (Couey 1950). As well the USFS documented bighorn sheep near Black Butte in 1926 (USFS 1926) and Brock et al (2006) notes the importance of the Gravelly Range for bighorn sheep. C-43

44 8-20 RESPONSE: Please consider the vegetation and terrain description referenced in this comment within the context of the area described in the Review in the section Bighorn Sheep Habitat Assessment Analysis. The first sentence describes terrain located between the Greenhorn Mountains (where bighorn sheep currently reside) and domestic sheep allotment in the center of the Gravelly Mountains. This information considers whether MFWP would reintroduce bighorn sheep if the allotments were closed and considers potential wintering areas and the likelihood of seasonal migration to lower elevation lands where risk of contact with domestic sheep is higher. The remainder of the paragraph describes vegetative conditions on the domestic sheep allotments without consideration of wintering needs for bighorn sheep. Further, the Review in the section on Reintroduction of Bighorn Sheep discusses bighorn sheep historically occupied the Gravelly landscape. Even if the heavier stands of forested vegetation currently degrade bighorn sheep habitat and thus deter bighorn sheep movements through some of the area, the BDNF is instructed to take special management actions to improve degraded habitat because bighorn sheep are a sensitive species. Letting natural fires burn, initiating a prescribed fire management plan and modifying livestock management to ensure herbaceous vegetation is not out competed by trees and sufficient fine fuels are present to carry a fire are also discretionary actions the BDNF could undertake to restore/improve the historical/existing bighorn sheep habitat and migration corridors (USFS 1993) RESPONSE: Please refer to comment 3-2. The BDNF claims: First, sufficient habitat exists in the Greenhorn Mountains to support the population objective of 125 individuals. The 2001 EA estimated sufficient habitat in the Greenhorn Mountains for bighorn sheep. While the population is gradually expanding, it remains well below the carrying capacity of available habitat so individuals have not left the area in search of additional habitat. These statements are contradicted by FWP data in USFS (2017) and FWP (2010(a)). Population monitoring data in FWP (2010(a)) reveals the highest count of bighorns after the 2003 Greenhorn reintroduction was 80 in 2006 with declining observations since then. The most recent observations by FWP counted 59 in 2015 and 48 in 2016 (USFS 2017). Thus, FWP has not documented nor have the Greenhorn Mountains revealed they can produce even 100 bighorn sheep without habitat improvements and/or access to additional habitat beyond the confines of the Greenhorn Mountains. Furthermore, there is indeed no data that indicates the population is gradually expanding; rather the data indicates the population may be declining. And, many individuals have left the Greenhorns C-44

45 in search of greener pastures. Indeed, the most recent observations of the bighorn documented on the maps on pages 5 of Appendix B (USFS 2017) reveal that many if not most of the observed bighorn sheep have left the BDNF lands limited to the Greenhorn Mountains. This points to the failed experiment that bighorn sheep can survive in the limited landscape in the Greenhorn Range as outlined in the Greenhorn MOU. Even if the Greenhorn Range can support 125 individuals or even 200 individuals, such a low number of animals in an isolated population is likely not viable over the long term (Traill 2010) RESPONSE: Sufficient habitat to reintroduce bighorn sheep in the greenhorns was determined by FWP and is not contradicted by observation of individuals. FWP clearly has identified these counts as showing the minimum number alive at the time of survey and not a population estimate. The population estimate is much higher than the observed number (Appendix B, FWP 2017 count data. Additionally, population counts do not indicate a declining population and that the count represents minimum number of bighorns known alive and not the total population. There are a number of factors that influence populations of bighorn sheep and distribution of sheep: from annual weather conditions, predator pressure or wildfires or natural vegetative succession. Refer to Comment 8-1, 6-3 and 6-4. The BDNF claims: Other recent observations by the MFWP area biologist concern the juxtaposition and capacity of ungulate winter range surrounding the Gravelly Mountains. Winter range located east of potential modeled bighorn sheep habitat (MFWP modeled habitat 2012) within and north of the Lyon-Wolverine grazing allotment is largely located in the general vicinity of the Wall Creek State Wildlife Management Area (WMA) and private property in the Madison Valley. While the WMA and private property contains winter range potentially suitable for bighorn sheep, it receives abundant use by wintering elk and deer, approaching the range s carrying capacity for wintering ungulates. In addition, bands of relatively dense lodgepole pine forests occur midslope (between the modeled habitat near the grazing allotments and the lower elevation winter range) that would likely deter bighorn sheep movement. If use by wintering native wildlife (elk and deer) is approaching the carrying capacity for the Wall Creek WMA and surrounding winter range on BDNF lands to the point it is a limiting factor for bighorn sheep restoration to historic habitat, why do FWP and BDNF permit use by domestic livestock on these same public lands? If this is a limiting factor for bighorn sheep recovery, why isn t the level of livestock use on these winter ranges reviewed in this analysis? Such use would undoubtedly reduce the amount of vegetation available for bighorn sheep. C-45

46 RESPONSE: The Review was corrected to include FWP s comment on the Wall Creek WMA and the capacity of winter ungulates (Appendix E) There is no suitable bighorn habitat within or in close proximity of the Wall Creek WMA. According to FWP comments, the bulk of the modeled habitat is on Forest Service lands from the Dry Fork of Ruby Creek through Standard Creek however the snowpack is too deep for wintering bighorns. Wildlife or livestock use during the winter is not the limiting factor for bighorn sheep in the Gravelly Mountains it is the snow depth level. Pallister (1974) found that 100 percent of the winter use by bighorn sheep in the Beartooth Mountains of Montana occurred on the high elevation Alpine Tundra type, indicating bighorn sheep can winter at very high elevations in high snow environments. South and southeast slopes received the greatest overall use. As well, even though livestock competition with bighorns was found to be minimal on his study site, Pallister (1974) still recommended discouraging future livestock use of the Stillwater winter range. RESPONSE: Statement regarding Beartooth Mountains is not applicable to Gravelly Mountains due to snow depth level. There is no question that Bighorns can winter in high snow environments, however they require areas that receive annual average of 10 inches of snow or less to survive the winter (FWP 2010). Indeed, the USFS Fire Effects data base for mammals notes that bighorn sheep do not compete well with livestock (USFS 1993). The BDNF has known this for a very long time (at least 24 years). Furthermore, because livestock don t eat trees, such use would likely contribute to the ongoing encroachment of conifers into former grasslands/winter ranges important to bighorn sheep. Wouldn t livestock use and aggressive fire suppression policies also contribute to denser forests by favoring trees over herbaceous vegetation? Is it surprising that these policies on historic bighorn sheep habitat degrade visibility, migration corridors and forage available for bighorn sheep (USFS 1993)? We suggest the BDNF/FWP can cease grazing livestock on important bighorn sheep winter ranges and migration corridors if this is a limiting factor. As well, BDNF can implement let burn and/or prescribed fire management policies in such areas to restore historic bighorn habitat (USFS 1993). RESPONSE: Livestock grazing on BDNF lands follows utilization standards in the forest plan which does not contribute to ongoing encroachment of conifer into grasslands/winter ranges. Lack of fire is a main contributing factor to natural succession. Additionally, effects from livestock grazing are not identified as a limiting factor for the Greenhorns Bighorn Sheep. Refer to C-46

47 response to Comment 3-2 on the proposed project to enhance Bighorn sheep habitat in the Greenhorn Mountains, which includes prescribed fire specifically for Bighorn sheep habitat (2) The 2011 listing of bighorn sheep as a sensitive species; The BDNF claims: The conclusion of its own biologists that bighorn sheep are a sensitive species are not valid (pp ). BDNF notes that the Montana Natural Heritage Program lists bighorn as apparently secure in the state. However, BDNF conducts no independent analysis of the status and trend of bighorn sheep specifically on the BDNF. BDNF does not recognize that the MT NHP conducted its analysis of bighorn in conjunction with MT FWP, and that both agencies are subject to political scrutiny from a politically well-positioned livestock industry. The score from MT NHP was 3.5, which was founded up to 4 to give bighorn sheep an apparently secure status whereas if they had rounded down to a score of 3 bighorn sheep would score vulnerable in Montana. Idaho and Wyoming both score bighorn sheep as vulnerable. Furthermore, bighorn sheep are declared a sensitive species in the 10 states that make up Regions 1, 2 & 4 of the USFS, which includes the BDNF. BDNF notes that bighorn numbers have increased in Montana since 1970 and that FWP estimated 5,694 bighorn in Montana in FWP s optimistic presentation of bighorn numbers in Montana is influenced mostly by a few of the larger herds, some in relatively new, untested transplants. In contrast, BDNF does not analyze the trend of bighorn numbers on the BDNF, where many historic herds have been extirpated and existing herds have suffered disease die-offs, declines and/or are confined to small isolated populations. For the 10 bighorn herds that utilize as least some of the BDNF Forest (West Rock Creek, Garrison, Lost Creek, Elkhorn, Highland, Spanish Peaks, Greenhorn, Taylor/Hilgard, Tendoy and Beaverhead herds) 8 appear to be declining (2 of these 8 herds may be stable but have very few total numbers) and only 2 appear to be increasing. The 2 that may be increasing have a large part of their habitat protected as Wilderness (Taylor/Hilgard and Spanish Peaks) and the Spanish Peaks herd spends most of its time on the Gallatin National Forest. Seven of the ten herds have observed counts well below 100 animals and none of the herds exceed 200 observed animals. All of these herds are well below what could be considered even a minimally viable population over the long term (Traill et al 2010). RESPONSE: The Review did not state that the identification of bighorn sheep as sensitive in Montana and North Dakota was not valid. Rather, the Review discussed the basis for the sensitive species listing -- due to die-offs in C-47

48 which were not associated with management on the National Forests or BDNF lands. Also, the Review discussed the increase in population statewide and the Montana Heritage Ranking. Next, in response bighorn populations on the BDNF. The MFWP is managing consistent with the 2010 Bighorn Sheep Strategy. Current population data is presented in response to comment 6-12 and shows that of the 8 Montana bighorn herds, 4 herds have decreased in number since the 2010 observed numbers and 4 herds have increased in numbers. However in the state of Montana there are currently (2017) 6500 Bighorn Sheep and there were less than 6,000 in Information from Domestic Sheep/Wild Sheep Symposium Feb 9-10, 2017, Helena, Montana. All videos available The BDNF claims: The FWP suggests a small population strategy for bighorn sheep has merit in the Greenhorns. BDNF does not evaluate FWP s position in light of modern population genetics. Issues of inbreeding, genetic drift, loss of alleles and evolutionary potential, and the small numbers of animals available for natural selection are ignored. Indeed the highest count of observed bighorn sheep within the limited Greenhorn Range has been 80 animals. Rather than make management changes that will restore and/or improve bighorn sheep habitat, BDNF forces FWP to undertake costly bighorn management actions in an attempt to establish even a small isolated herd of animals limited to the Greenhorn Range (occasional transplants, removal of bighorns leaving the Greenhorns, depopulations). RESPONSE: Reintroduction decisions and population size are decision made by MFWP utilizing a public NEPA process with public comment. Many factors go into their decisions as expressed in their comment letter and the 2010 Bighorn Strategy. Please see response to Comment 8-1. The 2010 Conservation Strategy describes parameters for a minimum viable population for potential transplanted herds specifically citing research for bighorn sheep. Berger (1990), Geist (1975) and Smith et al (1991) found bighorn sheep herds of individuals persisted for up to 70 years (MFWP, 2010, pg. 61) In contrast, the BDNF not only has the opportunity but the responsibility to provide sufficient habitat for long term viable bighorn sheep recovery in the larger Gravelly Landscape. Removing the domestic sheep conflict on BDNF lands in the Gravelly Range is the required first step. The BDNF s failure to C-48

49 provide sufficient habitat perpetuates this small isolated population management paradigm, which has not been an effective long- term strategy. We know of no bighorn herd in Montana that approaches a thousand animals as suggested by Traill et al (2010), much less so the BDNF. However, the research completed in Brock et al. (2006), which the BDNF and FWP assisted with, points to the opportunity to establish various metapopulations of bighorn sheep in the Gravelly Landscape including the Tobacco Root Mountains to the north and the Madison Range to the east if the domestic sheep allotments are removed from the Gravelly Range. This will also benefit grizzly bears (Brock et al. 2006). RESPONSE: There is no indication that the BDNF is not providing sufficient habitat for reintroduced sheep. Also, as discussed above there has been no known conflict with the 7 domestic sheep allotments and the Greenhorn herd. Further, FWP has made clear that releasing bighorn sheep into the Gravelly Mountains is unlikely to occur even if there is no domestic sheep grazing (Appendix E). Refer to Comment 3-2 and Furthermore, FWP does speak to the value of establishing inter-connected meta- populations of bighorns while noting there are some risks, in particular in regards to disease transmission from domestic sheep (FWP 2010). However, if the seven domestic sheep allotments are closed within the Gravelly Range and the trailing ceases through the Snowcrest Range, the risk of disease transmission from domestic sheep on the BDNF and FWP WMAs is gone. This opens up a landscape of 469,399 contiguous acres on BDNF land in the Gravelly Landscape for bighorn sheep restoration and conservation work. This landscape expands to more than 500,000 acres with the addition of the three surrounding FWP Wildlife Management Areas that were specifically purchased as big game winter ranges, and substantially larger yet if the Tobacco Root Range to the north and the Madison Range to the east is added in. All of these areas were mapped as historic bighorn sheep habitat by FWP in FWP (2010) and Couey (1950) as well as by Brock et al. (2006). RESPONSE: As explained in the MT FWP comment letter (Appendix E), closing the 7 domestic sheep allotments on the Gravelly Mountains is unlikely to result in MFWP reintroduction of bighorn into the area. FWP acknowledges the pros and cons of metapopulations in the 2010 Conservation Strategy. Additionally, FWP explains there is no modeled bighorn habitat on either the Blacktail, Robb-Ledford or Wall Creek WMAs, which are the three neighboring WMAs to the Gravelly mountains. See Comment 8-18 on the habitat in the Tobacco Roots bighorn sheep habitat. C-49

50 8-29 The BDNF claims: Few, if any, bighorn declines in Montana have been due to disease transmission from domestic sheep on BDNF allotments. BDNF does not note this indicates a lack of secure bighorn habitat on much of the BDNF lands. BDNF fails to note the numerous disease epidemics that have occurred in bighorn herds that are all or partly on BDNF lands, presumably coming from contacts with domestic sheep or goats on non- BDNF lands. This indicates that BDNF has little or no large blocks of contiguous bighorn habitat secure from adjacent or interspersed non- BDNF land where disease transmission could occur. However, BDNF fails to point out that the 469,399 acre Gravelly Landscape which includes the Gravelly, Snowcrest and Greenhorn Range could provide such relatively secure, but rare, bighorn habitat if seven domestic sheep allotments are removed and some additional habitat improvement projects are undertaken. RESPONSE: Commenter seems to agree that bighorn declines in Montana have not been due to disease transmission on BDNF allotments but provides no basis for their assertion that this is due to a lack of secure bighorn habitat on BDNF lands. There are only 7 domestic sheep allotments on the BDNF these are all in the Gravelly Mountains. See comment 6-10, 6-11, 6-18 and As discussed above, removal of the domestic sheep allotments in the Gravelly Mountains is unlikely to lead to FWP reintroduction of bighorns in the Gravelly Mountains. See comment The BDNF claims: Presently, bighorn sheep remain on the Region 1 Sensitive Species List but this status is not significant new information related to management of bighorn sheep on the BDNF. Bighorn sheep have been declared a sensitive species on the BDNF and throughout Region 1 of the USFS since This occurred only after we filed our complaint with the BDNF. As well none of the current AMPs have been revised since This is significant new information indicating a declining trend for bighorn sheep across the BDNF and throughout Region 1. RESPONSE: Sensitive species listing occurred in The Gallatin Wildlife Association lawsuit was filed in This Review is a consideration of whether the bighorn sheep in the Greenhorn Mountains is significant new information requiring supplemental NEPA analysis for the allotments. C-50

51 8-31 BDNF claims: Consideration of the Region 1 sensitive species listing of bighorn sheep does not lead to a conclusion that potential significant environmental impacts to the Greenhorn herd exist from the continued presence of permitted domestic sheep on seven allotments on the BDNF in the Gravelly Mountains as well as the miles of trailing to and from these allotments each spring and fall. Sensitive species designation means bighorns have been declining and may need protection under the Endangered Species Act unless the trend is reversed. A sensitive species is defined by the Regional Forester as any species of plant or animal that has been recognized to need special management in order to prevent them from becoming threatened or endangered. The Greenhorn herd has never established numbers sufficient to even be considered a minimally viable population. Furthermore 34 bighorn sheep have been either lethally or physically removed by FWP at least in part due to the Greenhorn MOU/agreements, which limit bighorns to the Greenhorn Mountain Range and/or due to conflicts with domestic sheep that are trailed to and from the BDNF allotments in the Gravellies or BLM allotments or lands controlled by the permittees along the way (FWP 2010(a)). RESPONSE: The Review and the 2011 Report to the Chief explains the basis for the state-wide sensitive species listing due to die-offs unrelated to management on the BDNF. The FWP Bighorn Conservation Strategy (2010) does identify removal of 34 Greenhorn herd bighorn sheep from the original 69 sheep released. However, no bighorn sheep have been lethally or physically removed from the Greenhorn population due to the Greenhorn MOU or domestic sheep grazing on the BDNF and there have been no known conflicts with domestic sheep either on the allotments or on trailing routes Indeed, the Forest Service is completely aware that domestic sheep carry diseases lethal to bighorn sheep and the mere presence of domestic sheep destroys the suitability of the habitat for bighorn sheep for a distance of at least 9-14 miles surrounding any domestic sheep (Schommer and Woolever 2001, Schommer and Woolever 2008, Suminski 1991, Western Association of Fish & Wildlife Agencies 2007, Wild Sheep Working Group 2012). Thus, the presence of domestic sheep on the allotments in the Gravelly Mountain Range near Bighorn Mountain precludes the use and/or reintroduction of bighorn sheep not only to the area encompassed by the allotments, but also the vast landscape of public land historic habitat that surrounds the outer C-51

52 edge of these allotments for a distance of 9-14 miles radius. This would include the 7,067 acre Wall Creek Wildlife Management Area, a critical winter range owned by the Montana Department of Fish, Wildlife & Parks on the eastern front of the Gravelly Range. RESPONSE: See response to comment 8-28 and Rather than implement special management that would help reverse the declining populations of bighorn sheep on the Forest (close the allotments to domestic sheep and stop the trailing through bighorn sheep habitat), the Beaverhead-Deerlodge National Forest continues to authorize domestic sheep use and trailing in the heart of historically important habitat for bighorn sheep (USFS 1926, Couey 1950, Brock et al 2006, FWP 2010). Such use renders the entire Gravelly/Snowcrest Range and surrounding public lands, Wildlife Management Areas and winter ranges unsuitable for bighorn sheep. The domestic sheep that use the allotments in the Gravelly Range are trailed approximately miles each way each spring and fall across a vast landscape of intermingled public and private land. BDNF does not reveal the entire trailing route in its analysis, which is an action tied to the use of the allotments in the Gravelly Range. The trailing route also includes some BLM lands near bighorn sheep habitat. Did the BDNF consult with BLM on this issue? On BDNF lands the trailing route slices through the middle of approximately 100,000 acre of the Snowcrest Mountain Range, which is historic bighorn sheep habitat entirely within the Beaverhead-Deerlodge National Forest just west of the Gravelly Mountains. Bordering these National Forest lands on the western edge of the Snowcrest Range is the Bureau of Land Management s Blacktail-Deer Creek Wilderness Study Area (approximately 6,000 acres) and the Montana Department of Fish, Wildlife & Parks Blacktail (17,781 acres) and Robb-Ledford (28,097 acres) Wildlife Management Areas. Together these public lands include over 50,000 acres of additional bighorn sheep habitat that are rendered unsuitable for bighorn sheep because of the domestic sheep trailing through the Notch in the Snowcrest Mountain Range. There are also tens of thousands of acres of State Department of Natural Resource Conservation lands and additional BLM public lands scattered along the domestic sheep trailing route that suffer the consequences of this use. However, this portion of mile trailing route is not adequately revealed in the BDNF analysis even though BLM is signatory to the Greenhorn MOU. RESPONSE: The comment response from the MFWP includes discussion that there is almost no modeled bighorn sheep winter habitat on either the C-52

53 Blacktail, Wall Creek, Robb-Ledford WMAs (Appendix E). The Review was updated to include an analysis on effects of the trailing routes. See response to comment 8-28 and There are also at least eight domestic sheep allotments administered by the BLM Dillon Field Office and four of these are leased to the permittees signatory to the Greenhorn MOU (Big Sheep, Nyhart, Rock Creek and Hoffman Creek Isolated) (Dec from BLM). Where are these allotments located? The analysis does not reveal the locations of these BLM allotments or whether they are part of the trailing route. Indeed the entire 2 million acre (3,000 square miles) Gravelly Landscape Area as defined by the BDNF (p 1) has only 48 observed bighorn sheep in What role does this domestic sheep trailing route play in limiting bighorn sheep across the rest of the Gravelly Landscape, which includes significant amounts of BLM lands? RESPONSE: The Review was updated to include a map of the BLM domestic sheep allotments and a discussion on trailing. The trailing location does not limit or prevent movement of bighorn sheep or reintroduction of bighorns into the Gravelly mountains. See response to comment 6-18 and USFS (2011(a) and personal communication with John Vore FWP (2017) indicate there are 9 other bighorn herds in addition to the Greenhorn herd that use at least part of the BDNF. The monitoring data we reviewed indicate these herds are also small, isolated and have a history of significant disease related die-offs (Montana Fish, Wildlife & Parks. 2010). Indeed in 2016, 70% (7 of 10) of the bighorn sheep herds on the BDNF had counts below 100 animals while 100% were below 200 ( Dec. 27, 2016 from John Vore Montana FWP and Jan. 6, 2017 from Chris Gaughan Idaho Fish & Game). The Beaverhead herd spends some time in Idaho and is not monitored by Montana FWP. These small herd sizes are perilously low (Traill et al 2010) especially in the presence of disease epizootic threats. RESPONSE: Domestic sheep grazing on the BDNF occurs only in the Gravelly Mountains. There is no BDNF domestic sheep grazing in the vicinity of the other bighorn sheep herds that utilize the BDNF. There is no information that any die off in bighorn sheep has been associated with BDNF domestic sheep grazing. FWP is not aware of any conflicts or management removals associated with domestic bighorns and BDNF domestic sheep allotment (Report to the Chief, USFS 2011). C-53

54 There are 8 bighorn sheep herds that utilize the BDNF that are managed by MFWP. One other herd (Beaverhead/Medicine Lodge) spends sometime on on the BDNF but it spends most its time in Idaho and is managed by the State of Idaho. In the December 27, referenced by the commenter, the State of Montana provided the following counts of observed animals (not a population estimate) for the 8 bighorn sheep herds were: Please see Review section 2011 Listing of Bighorn Sheep as a Sensitive Species for current update of this Table reflecting latest surveys. It should be noted that in terms of the Tendoy herd, the MFWP is in the process of depopulating the herd. Further, more recent observed bighorn sheep show for 2017 based on tracking count a minimum of 90 to 100 bighorn sheep (per. communication Vanna Boccadori, FWP wildlife biologist, 11/2/2017). For the North Beaverhead bighorn sheep, the State of Idaho data reflected in the dated January 6, 2017 shows the North Beaverhead bighorns at a 13 year high observation count of 116 bighorns. This is up from a low count of around 30 bighorns in 1992 and an increase in 55 from The Idaho Fish and Game biologist stated that the 2016 numbers are the most complete and best to use. The commenter s comparison of the observed numbers of bighorn sheep to totals of 100 and 200 sheep has no relationship to the population objectives of the MFWP as presented in the Bighorn Conservation Strategy. As an example, the Spanish Peaks population objective from the Conservation Strategy is or 20% (ie. 120 to 180 sheep). (2010, p. 82). Further, as MFWP has made clear the observed numbers do not reflect population estimates. C-54