Rocky Mountain Bighorn Society P. O. Box 8320 Denver, Colorado

Transcription

1 Rocky Mountain Bighorn Society P. O. Box 8320 Denver, Colorado May 1, 2012 Divide High Country Range Analysis Divide Ranger District W. Highway 160 Del Norte, CO Dear Sirs: The Rocky Mountain Bighorn Society (RMBS) welcomes the opportunity to comment on the Divide High Country Range Analysis during the initial scoping process. Our organization represents approximately 800 members, with a mission to promote and enhance the well being of Colorado s state animal, the Rocky Mountain bighorn sheep (BHS). The primary focus of RMBS when evaluating domestic sheep and goat grazing allotments for reauthorization is whether there is potential for interaction between domestic livestock and BHS herds. It is widely accepted by wildlife and land management agencies that respiratory disease transmission from domestic sheep to BHS through direct interactions can cause large-scale die-offs within affected BHS herds. Herds affected by these epizootics often remain depressed for 5-15 years following a die-off due to low recruitment rates. Therefore, reducing the risk of interaction between domestic sheep and BHS is of primary importance for maintaining stable populations of BHS. The Western Association of Fish and Wildlife Agencies (WAFWA) has developed recommendations for domestic sheep and goat management in BHS habitat. These guidelines are based on the most current science available regarding BHS and domestic sheep interaction, and include recommendations for all stakeholders involved when domestic sheep are grazed in close proximity to BHS. While the scoping document for this range analysis cites the 2007 WAFWA recommendations, it should be noted that WAFWA updated their guidelines in 2010, and are currently in the process of updating them again. The RMBS supports the use of WAFWA recommendations by both wildlife and land management agencies to guide management of BHS and domestic sheep in close proximity. When a risk of interaction between domestic sheep and BHS is present within a grazing allotment, there are three potential courses of action that may be taken to reduce that risk: domestic sheep may be excluded from grazing in occupied BHS habitat within the allotment; domestic sheep may be

2 restricted to grazing BHS habitat within the allotment to times of the season when BHS are not present; or domestic sheep may be moved to a vacant allotment where there is little or no risk of interaction with BHS. The RMBS prefers to recommend the least disruptive course of action for domestic producers while maintaining adequate separation between domestic sheep and BHS to reduce the likelihood of interaction. This range analysis focuses on two domestic sheep grazing allotment complexes in the Divide Ranger District, the Fisher/Ivy/Goose Lake (FIGL) Allotment and the Snow Mesa/Table/Miners (SMTM) Allotment. We will comment on each allotment individually below. Fisher/Ivy/Goose Lake Allotment The FIGL Allotment occurs at the heads of Ivy and Fisher Creeks on the north side of the Continental Divide, directly north of South River Peak (SRP). The allotment is within the Colorado Parks and Wildlife (CPW) BHS management unit S-15, and lies right at the northern extent of mapped BHS overall range as mapped by CPW (Figure 1, attached). The allotment overlaps BHS range along Ivy Ridge at the heads of Ivy and Fisher Creeks, and along the upper portion of the divide between Fisher and Goose Creeks. Mapping of overall BHS range in this area is considered to be quite accurate by CPW. Bighorn sheep classification flights have found sheep wintering on Ivy Ridge and SRP, and Divide Ranger District personnel have observed sheep in the same areas during the summer. These observations support the position that BHS use the southern portion of the FIGL Allotment year around. The S-15 BHS are part of the larger Weminuche Herd, comprising sheep from management units S- 15, S-16 and S-28. This herd is managed by CPW as Data Analysis Unit (DAU) RBS-20, and is classified as a Tier 1, primary population based on the Colorado Bighorn Sheep Management Plan, which ranks state herds by population size, population performance, and the lack of transplanted bighorns into the population. In April 2012, CPW completed the management plan for RBS-20, which calls for CPW to manage the herd for an increasing population and expansion of distribution within the DAU. The RMBS has several concerns about the potential for interaction between BHS and domestic sheep in the FIGL Allotment, and the possible implications of such interaction. The SRP area at the southern extent of the FIGL Allotment is used extensively by both BHS that winter on Ivy Ridge and by herds that migrate south to the Wolf Creek Pass area to winter. Large ewe/lamb bands have been classified on the south side of SRP and south to Red Mountain. In addition, approximately 90% of hunter-harvested BHS rams in S-15 have been taken within one air mile of the south side of SRP. This area is obviously very important to the BHS herd in S-15, and is used extensively. The migratory nature of many BHS using the SRP area creates a concern that if these sheep interact with domestic sheep, they may carry respiratory disease to winter range and infect sheep throughout the unit. Excellent BHS habitat occurs on Beautiful Mountain in the southeastern portion of the FIGL Allotment. Although BHS have not been observed on the mountain, it is a likely area for the herd

3 to expand as the population increases. This will increase the risk of interaction between BHS and domestic sheep. The FIGL Allotment was most recently grazed in 2010, and was not grazed previously since During years of no grazing, domestic sheep were grazed on an alternate allotment, suggesting that the FIGL Allotment is not critical to domestic sheep producers in the Divide Ranger District. Also of concern to RMBS is the fact that the 2010 Annual Operating Instructions for the FIGL Allotment made no mention of BHS in the area and the potential for interaction, and did not include guidelines for the permittee on how to minimize potential conflicts as recommended by WAFWA guidelines. The FIGL Allotment is the only high-risk active domestic sheep allotment within RBS-20. In summary, there is a high potential for interaction between domestic sheep and BHS on the FIGL Allotment. There is suitable BHS habitat within the allotment that is not yet occupied, and the BHS herd is managed for an increasing population and expanding distribution. Domestic sheep producers have alternatives to grazing the FIGL Allotment that pose much lower risk to BHS, and this is the last high-risk active allotment in proximity to BHS in RBS-20. There is no way to achieve effective separation between domestic sheep and BHS within the allotment as recommended by WAFWA guidelines. Given these facts, the RMBS feels that the appropriate action is to permanently close the FIGL Allotment or convert it to a cow and horse grazing allotment. Snow Mesa/Table/Miners Allotment The SMTM Allotment occurs on the south side of the Continental Divide north of the town of Creede, and encompasses large portions of the Miners and Willow Creeks drainages. The allotment is within the CPW bighorn sheep management units S-22 and S-53. Only the far western portion of the allotment is not within CPW mapped BHS overall range (Figure 2, attached). Much of the BHS overall range mapped within the SMTM Allotment boundary captures potential movement corridors between S-22 and S-53 sheep, and does not pose a high risk of interaction for much of the year. However, there is high likelihood of interaction on the Continental Divide along the northern boundary of the allotment. Units S-22 and S-53, along with unit S-52, comprise the La Garita Herd, managed as DAU RBS-22 by CPW. There is currently no management plan in place for this herd. In recent years, the population has trended downward slightly, with approximately 210 BHS estimated in the herd currently. Lamb recruitment has been poor in this herd in recent years. The RBS-22 herd is native, and has received relatively few transplants of sheep in the northern sub-population. The S-53 subpopulation has received three large transplants totaling 58 sheep over the years. The RMBS is concerned that adequate separation does not currently occur in the SMTM Allotment, particularly along the northern boundary. Bighorn sheep regularly occur in the headwaters of Mineral and Rough Creeks on the north side of the Continental Divide. Domestic sheep regularly graze right above the BHS on the divide, and several salt grounds created by permittees in this area provide an attractant to BHS and potential interaction areas. The S-53 population to the south

4 of the allotment precludes gaining adequate separation by moving grazing activities in that direction. The RMBS believes that the best alternative for protecting the RBS-22 sheep herd is to close the SMTM Allotment to domestic sheep grazing. Lamb recruitment rates the herd provides anecdotal evidence to suggest respiratory disease may already be suppressing the herd. If closure of the allotment is not possible, we recommend that the northern boundary of the allotment be altered, through consultation with CPW biologists, to reduce the risk of interaction with BHS along the Continental Divide. In summary, we would like to point out that BHS was listed as sensitive species in Region 2 in The Biological Evaluation and Conservation Assessment for Rocky Mountain Bighorn Sheep (BE) completed by the Rio Grande National Forest in 2010 considers domestic grazing in the southern portion of the FIGL Allotment to pose a considerable risk to BHS in S-15. Colorado Parks and Wildlife biologists consider this a high risk area for disease transmission. The BE also states that the SMTM Allotment poses a high risk for BHS in S-22 and S-53. The USFS issued a new directive to Regional Foresters on August 19, 2011 requiring a comprehensive bighorn sheep viability analysis when making forest planning decisions requiring National Environmental Policy Act (NEPA) analysis. This directive states in part: Where viability assessments indicate a high likelihood of disease transmission and a resulting risk to bighorn sheep population viability across the forest, the goal of spatial and/or temporal separation between domestic sheep/goats and bighorn sheep is the most prudent action we can use to manage risk of disease transmission. Thank you for giving RMBS the opportunity to comment on this range analysis. Please do not hesitate to contact me if you have any questions or concerns about our comments. Also, please apprise us of future opportunities to comment on this analysis or on other bighorn sheep management issues. Sincerely, Terry E. Meyers Vice President Rocky Mountain Bighorn Society meyers.terry@gmail.com (970) Attachments: Figure 1, Figure 2

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6 Figure 2