RECEIVED + MAR 2 2 2017 c,llorttarta 'Fisft, MADISON RANGER DISTRICT J'Wi e 1400 South 19 th Avenue Bozeman MT 59718-5495 March 20, 2017 Dale Olsen Madison Ranger District 5 Forest Service Road Ennis, Montana 59729 Thank you for the opportunity to comment on the Review of New Information Pertinent to Domestic Sheep Allotment Management Plans in the Gravelly Mountains on the Beaverhead-Deerlodge National Forest (hereafter Review). We appreciate that opportunity. Reintroduction of Bighorn Sheep In paragraph two on page 7, the Review states that a hunting season may be recommended when "the following four criteria have been met for a minimum of three consecutive years:" 1. The population is at least 75 observable sheep; 2. There are at least 30 rams: 100 ewes; 3. More than 30% of the rams are at least 3/4 -curl; 4. There are at least 30 lambs: 100 ewes; To clarify, the Montana Bighorn Sheep Conservation Strategy (2010) states that a hunting season may be recommended when at least three of the four aforementioned criteria have been met for at least three consecutive years. Three of the four criteria (ram: ewe ratio; percent ¾-curl ram, and lamb: ewe ratio) were met in years 2015 and 2016. There were no monitoring efforts during years 2010-2014. The next monitoring effort will be in March 2017. In paragraph three on page 7, the Review reports 59 and 48 bighorn sheep tallied in the Greenhorn herd during 2015 and 2016 monitoring efforts. MFWP feels it is important to recognize that these numbers represent the absolute minimum number of bighorn sheep documented alive at those points in time and does not represent a total population. Because of the size and geography of the area occupied by the Greenhorn bighorn herd, and the difficult nature of surveying bighorn sheep in that environment, it has not proven feasible to efficiently observe all individuals within the population within a narrow timeframe. The actual population is higher than the minimum numbers reported. How much higher is unknown. Page E-1
Paragraph one on page 10 state states, "In 2016, MFWP doesn't have to assume, they know, what habitat bighorns have occupied for 13 years and are likely to continue to occupying in the Greenhorn Mountains and surrounding areas." Montana Fish, Wildlife and Parks (MFWP) agrees with the statement in that we know what habitats have been occupied by bighorn sheep since they were reintroduced in 2003 and 2004, and better understand the initial dispersal desire than prior to the bighorns being released. However, we caution the portion of the statement that indicates we know what habitats the bighorn sheep will continue to occupy. Bighorn sheep, especially young males, are known for short- and long-range dispersals. Such movements could facilitate subtle or measurable shifts in home range through time. Each movement type occurred in 2016. A bighorn ram was observed in Warm Springs Creek in November, which was 2.3 miles from the closest previously known observation. Another bighorn ram was observed in lower Cherry Creek, on the east side of the Greenhorn Mountains, in November 2016. This was 9.3 miles from the closest previously known observation. It is not known at this time if this ram dispersed from the Greenhorn bighorn herd or from another bighorn herd. As with all wildlife species, the habitats bighorn sheep rely on are dynamic and influence distribution change through time. i.e. large scale wildfires could rapidly transition habitats in a way that increases current distribution of bighorn sheep, shifts in predation pressure could facilitate shifts in population distribution or habitats occupied, extreme annual weather conditions could facilitate exploratory movements, or population increase could facilitate distribution increase. In paragraph 2 on page 10, the Review states, "Bighorn sheep leaving the Greenhorn transplant area generally traveled west and north away from the BDNF - not south into the Gravelly Mountains and towards the permitted allotments." Although no bighorn sheep have been documented moving into the Gravelly Mountains, a portion of the Greenhorn bighorn herd dispersed southwest along the west side of the Snowcrest Mountains as far as Ledford Creek. Although this dispersal has not narrowed the distance between the Greenhorn bighorn herd and the Gravelly Mountains domestic sheep allotments, it has narrowed the distance between the Greenhorn bighorn herd and the domestic sheep trailing route from 13 to 5 miles, and the distance between the Greenhorn bighorn herd and private lands used for domestic sheep production from 12 to 5 miles. The westward dispersals mentioned in the Review narrowed the distance between the Greenhorn bighorn herd and private lands used for domestic sheep production from 7 to 3 miles. During November 2016, a single bighorn ram was observed on the east side of the Greenhorn Mountains near the mouth of Cherry Creek. It is currently suspected that this bighorn dispersed from the Greenhorn herd, but that has not been confirmed. If this is the case, it would represent an easterly dispersal. The review correctly states that none of the dispersal events have facilitated known bighorn-domestic sheep comingling to date. Regardless of direction and landownership, all Greenhorn bighorn dispersals have and will require continued collaboration between MFWP and public and private land managers. Paragraph 4 on page 10 states, "Based on estimated carrying capacity and known movements/distribution since 2003 it is not reasonable to expect herd distribution to expand in a southerly direction into the Gravelly Mountains. There is a lack of escape habitat and Page E-2
preferred foraging habitat to the south. Specifically, the terrain between the current south distribution of the Greenhorn herd (near Upper Canyon Ranch) and permitted domestic sheep allotments in the Gravelly Mountains lacks escape habitat (cliffs) desired by bighorn sheep and lodgepole pine forest dominating north facing slopes (beginning at Warm Springs Creek) deter southerly movement of individual bighorn sheep." To clarify, the 2010 Montana Bighorn Sheep Conservation Strategy defines escape habitat as slopes 60% or greater with occasional rock outcroppings, with abundant open foraging areas adjacent to it. It also defines winter habitat as escape habitat that is south facing and receives less than 10 inches of snowpack annually. Geographic modeling, completed by MFWP, demonstrates that slopes meeting escape and winter habitat criteria do exist to the south of the existing Greenhorn bighorn homerange in both the Gravelly and Snowcrest Mountains. Since release in 2003 and 2004, the Greenhorn bighorn herd has dispersed into said habitats in the Snowcrest Mountains, but not into said habitats in the Gravelly Mountains. The primary difference between these habitats is that those in the Snowcrest Mountains are contiguous with the existing Greenhorn bighorn herd homerange, while those habitats in the Gravelly Mountains are isolated from the existing Greenhorn bighorn herd homerange by a geographic area that contains minimal escape habitat and is dominated by dense evergreen forests. This combination of habitat types is thought to have deterred bighorn sheep dispersal to modeled suitable summer habitats in the Gravelly Mountains, and is expected to continue to deter said dispersal as long as those habitats are present. Currently, the existing evergreen forests are expanding and slope and aspect will not change. Because of annual snowpack depth across the Gravelly Mountains, there exists no winter habitat within the isolated escape habitats existing across the high elevation portions of the Gravelly Mountains. Therefore, it should not be expected to establish an independent herd within the existing habitats in the Gravelly Mountains. Those habitats could only be occupied during snow free months by bighorn sheep that migrate to suitable winter range elsewhere. The existing suitable winter range most expected to support such a migratory population are those already occupied by the Greenhorn bighorn herd. Existence of MOUs Please reference the comment letter submitted by MFWP on the Supplemental Environmental Impact Statement covering the MO Us. Updated Information Regarding Disease Transmission Between Domestic Sheep and Bighorn Sheep Paragraph 3 on page 15 states, "all documented Greenhorn bighorn sheep forays have been to the north and west." As previously mentioned, bighorn sheep from the Greenhorn herd have also dispersed to the southwest along the west slope of the Snowcrest Mountains, and one bighorn ram suspected to be from the Greenhorn herd dispersed to the east along the east slope of the Greenhorn Mountains. Paragraph 4 on page 15 states, "Co-mingling and risk and contact resulting in pathogen exposure and possible disease transmission is much more likely to result for Greenhorn bighorn sheep venturing onto adjacent private lands west and north or their current home range." Page E-3
Currently, there exists an undefined risk of bighorn and domestic sheep co-mingling and disease transmission on forest service lands to the south, and some private lands in all other directions from the Greenhorn bighorn herd home range. The risks associated with individual private ownerships can change at any time. Because of these risks, management of the Greenhorn bighorn herd has and always will require a collaborative effort between MFWP and public and private land managers. Consideration bv MFWP That Bighorn Sheep Could Be Reintroduced to Closed Allotments Paragraph 7 on page 18, which continued onto page 19, states, "Due to the lack of quality winter range, if bighorn sheep were translocated by MFWP to the Gravelly Mountains where domestic sheep grazing allotments currently exist, then bighorn sheep would likely have to seasonally migrate to BLM and private lands for the winter where risk of contact with domestic sheep will be high." M FWP agrees with the portion of the statement suggesting that bighorn sheep translocated into the Gravelly Mountains would likely need to migrate to suitable winter range outside of the Gravelly Mountains. The most likely winter habitat that bighorn sheep translocated into the Gravelly Mountains would seasonally migrate to and from would be those winter habitats currently occupied by the Greenhorn bighorn 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. It is MFWP's current understanding that significant habitat enhancement, in the form of evergreen forest removal, would need to be approved through NEPA and implemented to connect the summer habitats along the top of the Gravelly Mountains to known suitable winter habitats lower in the Ruby River Watershed. If this habitat work were to be approved and implemented, the existing Greenhorn bighorn herd would still need to find and establish this seasonal migration, or management efforts would need to be implemented to help facilitate this seasonal migration. Each of these processes would require extensive resources to complete. The statement "bighorn sheep would likely have to migrate to BLM and private lands for the winter where risk of contact with domestic sheep will be high" is speculation. The existing Greenhorn Bighorn herd utilizes winter habitats on both private and BLM lands. If bighorn sheep began migrating from existing winter habitat on private and BLM lands to summer habitat on top of the Gravelly Mountains, there would be no increased risk of co-mingling with domestic sheep and disease transmission than what currently exists on said private and BLM lands. This would only become the case if the BLM or a private landowner(s) within or neighboring said bighorn sheep winter habitat permitted new domestic sheep grazing. Bighorn Sheep Habitat Assessment GIS Analysis Paragraph 4 on page 25 states, "While the WMA (in reference to the Wall Creek Wildlife Management Area (WMA)) and private property contains winter range potentially suitable for bighorn sheep, it receive abundant use by wintering elk and deer, approaching the range's carrying capacity for wintering ungulates." Page E-4
Unless the USFS has data to support the claim that wintering ungulates have neared, reached, or exceed their carrying capacity within or around the Wall Creek WMA, MFWP cautions making this statement. The area within and surrounding the Wall Creek Wildlife Management Area was used by an average of 2,518 (range= 2,240-2,937) wintering elk from 2011 through 2015. Trend data for calf: cow ratio, a population vital rate used as an index of herd health, across the Gravelly Elk Management Unit and the for elk wintering on the Wall Creek WMA for the most recent two years (2014 and 2015) was above the longterm average. This suggests that the primary wintering ungulate is within its carrying capacity. Very few deer currently winter on the Wall Creek WMA. Paragraph 4 on page 25 states, "Winter range located east of the potential modeled bighorn sheep habitat within and north of the Lyon-Wolverine grazing allotment is largely located in the general vicinity of the Wall Creek State Wildlife Management Area and private property in the Madison Valley." As illustrated by the MFWP habitat model, there is no suitable bighorn sheep winter habitat within or in close proximity of the Wall Creek WMA. This statement is inaccurate and misleading. The MFWP habitat model clearly illustrates that the bulk of said winter habitat exists on USFS lands from the Dry Fork of Ruby Creek through Standard Creek. However, because of typical snowpack across these suitable winter slopes, they are unlikely suitable bighorn winter habitat. Paragraph 5 on page 25 states, "once reaching the Snowcreast Mountains, suitable winter range is further to the east and once again located on the private, BLM, and State lands (Blacktail State WMA and Robb Ledford State WMA, where wintering ungulate presence is again, likely approaching capacity. As illustrated by the MFWP habitat model, the vast majority of suitable bighorn sheep winter habitat across the Snowcrest Mountains is located on USFS property. Again, most of these modeled slopes would not be expected to function as bighorn sheep winter habitat because of annual snowpack depth. Much of the suitable winter habitat on the west side of the Snowcrest Mountains is currently being used by the Greenhorn bighorn herd. There is almost no modeled bighorn winter habitat on either the Blacktail or Robb-Ledford WMAs. This portion of the statement is inaccurate and misleading. Again, unless the USFS has data to support the claim that wintering ungulates have neared, reached, or exceed their carrying capacity of the WMAs, MFWP cautions making this statement. Although the presence of domestic sheep is a major factor in any bighorn sheep reintroduction decision, MFWP agrees with the assessment that there is more to consider than just the presence of domestic sheep when assessing the potential re-introduction of bighorn sheep into the Gravelly Mountains. Habitat modeling efforts completed by MFWP indicates the presence of slopes, geography suitable for bighorn sheep, exists across portions of the Gravelly Mountains. However, snowpack data from the Gravelly Mountains shows the annual average greatly exceed what the literature suggests bighorn sheep will tolerate. Therefore the modeled habitats in the Gravelly Mountains would not be expected to sustain bighorn sheep themselves. At most, they would be expected to provide summer habitat for bighorn sheep than seasonally migrate to suitable winter range elsewhere. In such a scenario, the standard approach is to reintroduce bighorn sheep onto suitable winter habitats during the winter Page E-5
season. This is the standard approach because: 1) bighorn sheep captures are completed during the winter when source populations are concentrated on winter range; 2) because of heat stress to bighorn sheep during capture and relocation efforts, said efforts are not completed when the daytime temperature nears or exceeds 40 degrees Fahrenheit; 3) bighorn sheep are released onto suitable winter range because they need that habitat for immediate survival and they must become familiar with the location of suitable winter habitats to survive future winter seasons. Because capture and relocation efforts occur during the winter and the modeled bighorn habitat in the Gravelly Mountains would be expected to have multiple feet of snowpack, a release directly onto those habitats would not be feasible. Any bighorns released during the winter would have to be snow machined or air-lifted to the modeled habitats, and would not be expected to survive that initial winter season. Any attempts to capture and relocate bighorn sheep to the Gravelly Mountains during snowfree months would be expected to lead to very high mortality associated with heat stress. Surviving bighorn sheep would need to find suitable winter range on their own. Because of these factors, releasing bighorn sheep into the Gravelly Mountains is unlikely to occur. Any re-introduction would need to occur on suitable winter range and bighorn sheep would need to find their way to suitable summer habitats in the Gravelly Mountains. In terms of the Gravelly, Snowcrest, and Greenhorn mountains, the standard re-introduction approach was implemented when bighorn sheep were released onto suitable winter habitats in the Greenhorn Mountains in 2003 and 2004. Since that release, bighorn sheep have dispersed to summer habitats in the Greenhorn, Snowcrest, and Ruby Mountains, but none have knowingly dispersed to the summer habitats in the Gravelly Mountains. As the Review states, this is thought to be because of mild topography and large expanses of evergreen forest that exists between the summer habitats in the Gravelly Mountains and the current Greenhorn bighorn home range. Without landscape-scale wildfire or significant public investment into evergreen forest removal, it is unknown if the Greenhorn bighorn herd will establish a season migration between summer habitats in the Gravelly Mountains and the winter habitats they have already been established on. These challenges also mean that removal of domestic sheep from the Gravelly Mountains will not directly facilitate establishment of bighorn sheep onto summer habitats in the Gravelly Mountains. That removal would only be step one of a several step effort that currently has not been approved or had recourses allocated to it. Sincerely, Sam B. Sheppard Region 3 Supervisor Page E-6