Payette National Forest

Transcription

1 United States Department of Agriculture Forest Service Payette National Forest 800 W Lakeside Ave McCall ID File Code: 1570 Date: December 20, 2010 Debra K. Ellers Western Idaho Director Western Watersheds Project P. O. Box 1030 McCall, ID CERTIFIED MAIL RETURN RECEIPT REQUESTED Dear Ms. Ellers: This is my decision on the appeal you filed on behalf of Western Watersheds Project regarding the Meadows Valley Grazing Allotment Decision Notice signed by District Ranger Kim Pierson on the Payette National Forest. My review of your appeal was conducted pursuant to, and in accordance with, 36 CFR My review focused on the project documentation and the issues raised in your appeal. I specifically incorporate in this decision the project record, the references and citations in the project record transmittal documentation, as well as the Appeal Reviewing Officer (ARO) analysis and recommendation. After considering your issues and the project documentation, the ARO recommends the District Ranger s decision be affirmed. A copy of the recommendation is enclosed. Based upon a review of the project documentation provided, I find the issues were adequately considered. I agree with the ARO analysis and conclusions in regard to your appeal issues. I find the District Ranger made a reasoned decision and has complied with all laws, regulations, and policy. After careful consideration of the above factors, I affirm the District Ranger s decision to implement the Meadows Valley Cattle & Horse Project. Your requested relief is denied. My decision constitutes the final administrative determination of the Department of Agriculture [36 CFR (c)]. Sincerely, /s/ Suzanne C. Rainville SUZANNE C. RAINVILLE Appeals Deciding Officer Enclosures cc: Kim Pierson Caring for the Land and Serving People Printed on Recycled Paper

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3 Western Watersheds Project Appeal Number A215 Meadows Valley Cattle and Horse Allotment Grazing Analysis Appeal Issue Responses APPEAL ISSUE 1: The decision to authorize continued grazing on the Meadows Valley Allotment will cause continuing degradation of ecological integrity and environmental conditions. RESPONSE: Environmental conditions were discussed in detail in the EA. Long-term trend monitoring tracks rangeland changes over time and the achievement of goals and objectives that are stated in the project decision and Forest Plan (FSH ). Grazing effects to both upland and riparian vegetation in relation to invasive species, water resources, soil, recreation and vegetation are addressed (EA, pp ; EA, pp ; EA, pp ; Rangeland Specialist Report, pp , 31, 49). The effects analysis of implementation of the adaptive management strategies also discusses how the decision will not continue to degrade the allotment (EA, pp ). Further discussion and comparison of the effects on the environmental conditions are located in the Summary of the EA (EA, p. 50). A summary of the data gathered addresses the concern with the effects to the Corral Creek unit (where Duck Lake is located), as well as all other units on the allotment (EA, Appendices, pp. 100, 101). These documents adequately disclose and address concerns with the grazing effects and ecological integrity of the proposed action on the allotment. APPEAL ISSUE 2: The Forest Service did not sufficiently address appellant s comments/concerns, did not analyze them, and did not draw appropriate conclusions. RESPONSE: A legal notice beginning the comment period for this action was published on August 26, Only one comment letter was received during the comment period. The Forest Service prepared and published a Response to Comments document with the EA (EA, Appendix E, pp ). The responses are clear and considered comments received. Many of the appellant s comments indicated a difference of opinion or interpretation and did not require analysis. In many cases the Forest Service did not draw the conclusion preferred by the appellant. Appellant s comments were sufficiently addressed. APPEAL ISSUE 3: The Forest Service did not consider a reasonable range of alternatives. RESPONSE: While there is a requirement to consider a reasonable range of alternatives (40 CFR ), no specific number of alternatives is required (FSH , Chapter 10, Section 14). Alternatives are driven by unacceptable impacts from the proposed action. In this case, unacceptable impacts of continued grazing were avoided in the development of the proposed action (EA, pp ) and confirmed in the effects analysis (EA, Chapter 3) and the Finding of No Significant Impact (DN/FONSI, pp ). In cases where the design and configuration of the proposed action can mitigate resource concerns to acceptable levels, the proposed action may be the only viable action alternative (FSH , Chapter 90, p.10). In their comments on the review EA, appellants suggested an alternative that would reduce the numbers of livestock and/or season of use to bring impacts to acceptable levels. These 2 options are included in the 1

4 decision as part of the adaptive management strategy to be used if necessary to bring impacts to acceptable levels (EA, p. 26). See also the response to Appeal Issue 15. APPEAL ISSUE 4: The Forest Service did not take the hard look at environmental impacts in the decision to authorize continued grazing on the Meadows Valley Allotment. RESPONSE: The Forest Service thoroughly analyzed and disclosed the environmental effects (EA, Chapter 3). The appellant mentions impacts on Wild and Scenic Rivers, Inventoried Roadless Areas, Endangered Species Act (ESA) listed species, R4 sensitive species, riparian habitat, and recreation. Impacts to each of these resources are discussed in detail in the EA (Chapter 3). Appellant s concerns with the adequacy of the analysis of these impacts are discussed in detail in response to Appeal Issues 8, 10, 11, 12, 13, 14, and 17. APPEAL ISSUE 5: The Forest Service did not assess capability and suitability in compliance with NFMA. RESPONSE: The implementing regulations for the National Forest Management Act (NFMA) direct the Forest Service to address rangeland resources during forest planning. The Forest Plan must identify lands capable and suitable for grazing and identify their condition and trend. In addition, range management prescriptions should consider land treatments, grazing practices, potential conflicts with other resources, and restoration of deteriorated lands (36 CFR ). The EA and Rangeland Resource Capability and Suitability Analysis address capability and suitability and the Forest compliance with NFMA (EA, pp ; Rangeland Resource Capability and Suitability Analysis, p. 15). Further documentation of site specific validation is located in the ID Team meeting notes of July, The EA, and the Rangeland Resource Capability and Suitability Analysis clearly document how the Forest met the NFMA requirements identified for capability and suitability for this project (EA, pp ; Rangeland Resource Capability and Suitability Analysis, pp. 1-15). See also Appeal Issue 16 relating to Capability and Suitability Analysis. APPEAL ISSUE 6: The Forest Service violated the Administrative Procedure Act. RESPONSE: The Administrative Procedures Act (APA) requires that agency actions have a rational foundation and not be arbitrary and capricious, or abuse discretion. The purpose and need for this project describes the regulatory and policy framework for livestock grazing on the National Forest (EA, p. 10). The purpose and need also shows how under current grazing management There are isolated areas of impact within the allotments that are not in or moving towards desired conditions for soil, water quality and riparian conditions (EA, p. 10). The need for the proposed action is then described as these specific isolated areas of impact will be addressed with existing grazing management and administrative authorities and an effective adaptive management strategy (EA, p. 10). Key issues addressed in the EA include Rangeland vegetation and health, riparian resources, soil productivity and fisheries (EA, pp ). These resources are addressed in Chapter Three of the EA, where the existing condition and direct, indirect, and cumulative effects from the Proposed Action and No Action alternatives are discussed in detail (EA, pp ). The Ranger, in the DN/FNOSI, clearly explains the rationale for the decision made based on the analysis in the EA and in the project record, and 2

5 describes the how the decision is in compliance with other laws and regulations (DN/FONSI, p. 5-16). APPEAL ISSUE 7: The Forest Service should have prepared an EIS because of the significance of effects and unique characteristics of the area. RESPONSE: The factors to consider in determining the significance of effects are specified by the council on environmental quality (CEQ) at 40 CFR The Finding of No Significant Impact (FONSI) associated with this decision thoroughly discusses these factors explaining the rationale for the determination of no significant impact. Based on the analysis of effects disclosed in the EA, the FONSI appropriately concludes that preparation of an EIS is not necessary (DN/FONSI, pp ). The impacts of this action are found to be limited in both context and intensity. APPEAL ISSUE 8: The Forest Service does not comply with NFMA by failing to adequately assess effects on wildlife and use best available science. RESPONSE: The Forest Plan (2003, p. IV-6) requires that population trends and habitat changes for Management Indicator Species (MIS) be determined annually. Results of annual monitoring can be found on the Payette National Forest website ( Monitoring is ongoing for the two species of woodpeckers and bull trout, which are the three MIS selected by the Payette. Sensitive and MIS species that are known to occur and utilize habitat affected by grazing were all addressed for direct, indirect and cumulative effects (2010 Wildlife Specialist Report, pp ; EA, pp ). Bull trout, the only MIS fish, was addressed within the Fisheries Report and EA (Fisheries Specialist Report 2009, pp. 5-18; EA, pp ). Sensitive and MIS species that do not occur within the analysis area, or their habitat is not affected by grazing, were not analyzed for effects. There was no failure to assess direct, indirect and cumulative impacts to sensitive wildlife species and Management Indicator Species. The EA states that generally speaking habitat conditions/diversity is moderate in the project area. Past activities such as timber harvest, road construction, fire suppression, livestock grazing, recreation, and firewood gathering in the project area, as well as on adjacent Federal, State and private lands, have affected habitats for various wildlife species (EA, p. 126). Diversity was reviewed by evaluating 4 families of species that represent habitat and seral types (EA, pp ). Throughout the EA habitat needs of the various species and potential effects are documented by literature references and indicate the use and review of best science (EA, pp , Appendix C, Bibliography pp ). Based on the review of the project record, specialist reports, the EA and DN/FONSI, the Forest is in compliance with the Forest Plan and NFMA requirements, and used the best science available. APPEAL ISSUE 9: The Forest Service did not adequately assess the effects of grazing on candidate Wild and Scenic River. 3

6 RESPONSE: Potential impacts to eligible Wild and Scenic Rivers from continued livestock grazing were identified as an issue in the EA (EA, p. 20). The issue was not analyzed in detail because there were no upstream projects being considered as part of the project that would impact the free flowing nature, water quality, or outstandingly remarkable values (ORV) of Hard Creek (EA, p 20). Management direction includes Standard 0601 that requires Hard Creek and Hazard Creek to be managed as eligible river corridors to their assigned classification standards (Wild) and to preserve their ORVs and free-flowing status until the segments undergo a suitability study and the study finds them either suitable for designation by Congress, or releases them from further consideration as Wild and Scenic Rivers (PNF FP, p ). The Hard Creek and Hazard Creek Wild and Scenic River segments were identified as eligible for wild status because of their free flowing nature (Recreation Specialist Report, p. 14). There is one three mile section of the Hard Creek Wild and Scenic River corridor within the Meadow Valley Allotment Project area (Water Specialist Report, p. 5). Hazard Creek is outside and upstream of the project area, and there are no tributaries of Hazard creek within the allotment (Water Specialist Report, p.14). The ORVs identified for Hard Creek are geologic and hydrologic (Recreation Specialist Report, p.14). The geological component refers to the geology of the river corridor, and the hydrological ORV refers to the waters flow down its course forming unique waterfalls. Proposed livestock grazing would not affect the ORVs of Hard Creek (Recreation Specialist Report, p. 16). The ORVs of Hard Creek can be maintained, and the future eligibility and suitability of this river would not be impacted with the proposed grazing project. APPEAL ISSUE 10: The Forest Service did not adequately assess the effects of grazing on Inventoried Roadless Areas. RESPONSE: The potential impacts from livestock grazing on the undeveloped character and/or wilderness characteristics within the Inventoried Roadless Areas (IRA) was identified as an issue during scoping (EA, p. 19). The issue was not analyzed in detail because continued permitted grazing would not result in measurable change to roadless characteristics or wilderness attributes of the IRAs within the allotments (EA, p. 20). There are portions of two IRAs in the Meadows Valley Allotment; French Creek and Patrick Butte IRAs (Recreation Specialist Report, p. 10). Assessment of these two IRAs was completed in the Southwest Idaho Forest Plan (SWID FP) revision process. The French Creek IRA was determined to have a high degree of apparent naturalness and moderate opportunities for solitude and challenge with some special features (SWID FP, pp ). The Patrick Butte IRA has a high degree of apparent naturalness, opportunities for solitude and challenge, and special features (SWID FP, pp ). Livestock grazing has had a long history in these IRAs and does not compromise either the roadless characteristics or the wilderness attributes of the IRA (Recreation Specialist Report, p. 12). The EA considered the potential impacts from continued livestock grazing on IRAs and analyzed it within the context of the Recreation Specialist Report. The level of analysis conducted to determine the potential impacts to IRAs from continued livestock grazing was appropriate for the scale of the project. APPEAL ISSUE 11: The Forest Service did not adequately assess the effects of grazing on fish and critical habitat. 4

7 RESPONSE: Under Endangered Species Act (ESA) the Forest Service is required to consult with the National Oceanic and Atmospheric Administration (NOAA) - Fisheries on all projects involving anadromous fish. This allotment was first consulted on in 1993, as a result practices were modified and new standards were incorporated into management (EA, p. 2). Current grazing management has been approved through consultation with NOAA Fisheries and the U.S. Fish and Wildlife Service (EA, p. 12.). Chinook salmon and steelhead have designated critical habitat in the project area. Critical habitat for bull trout is only proposed at this time (EA, pp ). Three indicators were chosen to represent the effects of grazing on the fisheries community: temperature, cobble embeddedness and threatened, sensitive, and management indicator species. These indicators are used as surrogates of a wider array of habitat needs and conditions. For example temperature is governed by a variety of factors, including overhanging bankside vegetation, canopy over story, topography, stream orientation or aspect, and latitude. Cobble embeddedness is representative of the local bank stability conditions and parent geology (EA, pp ). Each indicator was judged as to the effects of grazing by alternative (EA, pp ). It is apparent from the EA that the Watershed Condition Indicators (WCIs) as defined in the 2003 Payette Forest Plan have been further defined through more site specific watershed studies to better determine the natural capability for the WCIs of temperature and embeddedness (Nelson and Burns 2007, Nelson and Burns 2005). Analysis of monitoring data has looked at how temperature trends in grazed sites compare to temperature trends in un-grazed control sites. With the exception of Goose Creek, temperature trends at all monitoring sites within the project area appear to be similar to non-grazed control sites, which suggest that grazing is not having an effect on trends (Zurstadt 2004). Temperatures in Goose Creek are probably strongly influenced by Brundage Reservoir and do not show an upward or downward trend (Zurstadt 2004). Based upon discussions in Chapter 3 of the EA concerning threatened and endangered plant, fish, and wildlife species, correspondence with NOAA-Fisheries Service and US Fish and Wildlife Service, and detailed discussions contained in the Watershed Biological Assessment/Biological Evaluation, it was determined that the project is not likely to adversely affect listed species or critical habitat (DN/FONSI, p. 10). The Forest followed ESA requirements for addressing livestock grazing effects on fish and critical habitat and disclosed those effects in the EA and DN/FONSI. APPEAL ISSUE 12: The Forest Service did not adequately assess the grazing effects of sediment yield on fish. RESPONSE: The EA cites that the proposed grazing management strategy has been shown to be fair with respect to fish habitat protection (Platts 1991), and increased embeddedness (an indicator of sedimentation) is a potential problem (EA, p. 113). The project has been through ESA consultation with National Marine Fisheries Service and U.S. Fish and Wildlife Services (Olson and Burns 2007, and Fish and Wildlife Service 2009, pp. 9-11). Mitigations have been prescribed to avoid adverse effects to listed species, and these would protect resident native salmonids as well (EA, p. 113). Coupled with other project design features (e.g. water gap 5

8 armoring), adaptive management actions to reduce grazing damage when it becomes apparent, and protection of isolated areas of impact already identified as needing revegetation, the proposed action will not retard attainment of properly functioning embeddedness conditions (EA, p. 113). The EA and Fisheries Specialist Report show that listed, sensitive, MIS, and other fish species would not be adversely affected under either alternative relating to embeddedness (EA, pp ). Data indicates the no action alternative would be expected to maintain or improve instream sediment conditions, but that the potential for improvement could be small because it is currently not clear that watersheds in the allotment are not functioning appropriately with respect to this indicator (EA, pp ). In addition, adaptive management actions under the proposed alternative would be expected to increase vegetative cover and reduce erosion from isolated areas of impact (EA, ). Over time, reduced sediment delivery from these areas would be expected to yield improvement (lower sediment yields) in downstream substrate conditions (EA, pp. 113). Data also indicate these alternatives would be expected to maintain or improve instream sediment conditions and that the trends are likely improving in the project area (Olson 2009, Fisheries Specialist Report, pp. 8-11, and 66-69; and also Nelson 2010, Fisheries Specialist Reports, pp. 7-9). APPEAL ISSUE 13: The Forest Service did not adequately assess the effects of grazing on wildlife, Management Indicator Species (MIS), and Threatened Endangered Proposed Candidate Species (TEPCS) species. Furthermore, forests in this area provide habitat for a number of Region 4 sensitive species, including fisher, northern goshawk, flammulated owl, white-headed woodpecker, wolverine, great gray and boreal owl, three-toed woodpecker, and spotted frog. Lynx habitat is also present in the Management Area in which the allotment is located. RESPONSE: For MIS wildlife and TEPCS see response to Appeal Issue 8. There is limited suitable lynx habitat, no denning habitat, and only one sighting of a migrating Canada lynx reported in 2003 (EA, p. 19). The grazing proposal is compliant with Lynx Conservation Strategy (Ruediger et. al 2000). Effects to lynx on the Payette National Forest from livestock grazing are expected be negligible. This is because evaluations show allotments are being managed to be consistent with the LCAS and because allotment management meets other conservation measures (EA, p. 122). Management activities related to timber harvest and fire suppression are listed as having had the greatest impact on lynx habitat (EA, p. 127). The selected alternative may affect, not likely to adversely affect the Canada lynx (EA, p. 134) Gray wolfs occur seasonally in the area and habitat is not affected by grazing, though there is a potential for depredation actions (EA, p. 120). The recovery goal for wolves in central Idaho was 10 breeding pairs for three consecutive years. Wolf populations now exceed their numerical recovery goals under the Endangered Species Act in the Northern Rocky Mountains of Montana, Idaho, and Wyoming (EA, p. 129). The proposed action may affect, not likely to jeopardize the recovery of gray wolves (EA, p. 135). The Northern Idaho Ground Squirrel (NIDGS) has potential habitat available, but has not been observed in the project area (EA, p. 119). The species is considered to be threatened primarily as a result of habitat loss and fragmentation caused by fire exclusion and forest encroachment into 6

9 former montane meadow habitats (USDI-Fish and Wildlife Service 2003). Affects were analyzed in the EA (EA, p. 119, , and 134). Alternative 2 will have utilization standards that provide for adequate seed head and forb production that NIDGS need as part of their forage base. In the event that NIDGS are documented through ongoing field surveys, alternative livestock management such as timing restrictions may be necessary to address NIDGS concerns. Alternative 1 would have No Effect to NIDGS and Alternative 2 and may affect, not likely to adversely affect the northern Idaho ground squirrel. The EA assessed the effects and it was determined that there are no major effects to any listed species. APPEAL ISSUE 14: The Forest Service did not include specific alternatives for reduced stocking level and season of use. RESPONSE: The Forest is required to consider a reasonable range of alternatives (40 CFR ). Timing of grazing, areas of use, number of livestock, including whether livestock are allowed, can be and often are adjusted under current agency administrative authorities and policies set forth in CFR These directions are referenced on page 5-6 of the EA. Season of use and reduced stocking levels are addressed as part of adaptive management and are included in the proposed action (EA, pp ; 57-60; 81-84; ; ; 140; and ). Upland and Riparian Vegetation and Health, Invasive Weeds, Water Resources, and Soil Productivity also addressed Adaptive Management in the Specialist Reports. Reduced stocking level and season of use are included as part of the proposed action in the Adaptive Management strategy. See also response to Appeal Issue 3. APPEAL ISSUE 15: The Forest Service did not adequately address slope, soil, and vegetation conditions in capability analyses. RESPONSE: Interdisciplinary meeting notes from July 28, 2010 describe how the team reviewed the range suitability map and validated the data based on current available information. The only capable but not suitable land is about 10 acres in the Meadows Valley Allotment - the Grouse Campground (Meeting Notes, p. 62). The Forest also documented that they discussed in the office and field verified the capability/suitability maps on July (Meeting Notes, pp. 1-2, 47, and 62). In the Section 1.7 of the EA, the forest-wide and project specific rangeland suitability and capability analyses processes are summarized and describe the use of slope, topography, vegetation, and soils in the analysis for describing lands that are capable for grazing as part of the capability analyses (EA, pp , and Table 1-3 on p. 13). In the Rangeland Specialists Report, Capability and Suitability Analysis, the range specialist describes the analyses process and the use of slope, vegetation, and soils in the model (Rangeland Resource Capability and Suitability Analysis, pp. 1-15). The Forest has shown that they did factor in slope, vegetation, and soils as part of the capability analysis. APPEAL ISSUE 16: The Forest did not adequately address grazing/recreation conflicts. 7

10 RESPONSE: The primary land uses and resource management activities in the Goose Creek/Hazard Creek Management Unit (MA 06) are developed and dispersed recreation, special uses, timber management, and livestock grazing (Payette Forest Plan, pp. III-164 to III-179). Recreation was identified in the EA as a Non-key Issue (EA, p. 18). Non-key Issues were analyzed in terms of environmental consequences but did not lead to a new alternative (EA, p. 16). The issue addressed in the EA was Permitted domestic livestock grazing may conflict with recreational use of camping areas, trails, high mountain lakes and meadows (EA, p. 18). Recreation activities in the Meadows Valley allotment include dispersed camping, developed campgrounds, fishing hiking and other activities (EA, p. 146). Livestock can impact these activities by their presence in developed campsites, impacts to trails from hoof action and impacts at developed sites by the presence of cattle or the evidence of their presence (EA, p. 146). The potential effects of the proposed action on recreation activities are described in both the EA and Recreation Specialist Report. The Goose Lake Inlet site is currently in a degraded status based on the Water Resources Report. However, even with either Alternatives A and B the status would still be degraded without the additional adaptive management strategies prescribed in the Water Resources Report, which includes a recreation management project (EA, pp , and 64). The Range Specialist Report also discusses the expectations of the Goose Lake Inlet Recreation project and that it would control people and would most likely implement additional control activities for domestic livestock areas around the lake (Range Specialist Report, p. 30). Based on the material presented in the EA, the Forest adequately displayed the potential effects of livestock grazing on recreation activities. APPEAL ISSUE 17: Adaptive Management is not an adequate measure to address the ongoing degradation. RESPONSE: Adaptive Management and the strategies described are ways of addressing short term and long term monitoring results and their implications to the resources. The strategies used in Adaptive Management are appropriate measures to address concerns on the allotment and fall within the guidelines of the current agency administrative authorities and policies in CFR 222.4; Forest Service Manual and Handbook, and Payette Forest Plans goals and objectives for rangeland management (EA, p. 5; Rangeland Vegetation and Invasive Weeds Specialist Report, p.5). The adaptive management strategies as described in the specialist report and EA would address timing, intensity, frequency, and duration of livestock as it relates to the use in the proposed action (Rangeland Vegetation and Invasive Weeds Specialist Report, p. 24). Examples of how the strategies would be used are also included in the Specialist Report. APPEAL ISSUE 18: Areas of Concern are degrading. The Table on p. 63 of the EA lists the status of Areas of Concern with grazing allotments. In the Meadows Valley Allotment, 15 of these areas are listed as degrading in the existing status. 8

11 RESPONSE: There is not a Table on page 63 of the Final September 2010 EA relating to the appeal point or to any references to Areas of Concern in the EA. The EA however, describes the Watershed Existing Conditions and more specifically describes that 38 Isolated Areas of Impact were identified as isolated locations or reaches in which conditions (riparian, vegetation, bank stability, soil disturbance, etc.) were not meeting or moving towards the desired condition prior to (EA, pp ). In the Water Resources Report, the areas are described as Areas of Concern (Water Resources Report, pp , and 15-16). Recently these sites were revisited and it was found that 8 were improving, 15 were maintaining, and 15 were continuing to degrade (EA, p. 71; Water Resources Report, p. 12). Both the EA and Water Resources Report describe by alternative and trend the number of isolated areas of impact/areas of concern (EA, pp ; Water Resources Report, pp ). These reports show that under alternative two, 27 areas would improve based on the adaptive management approach proposed (application of mitigation, improvement of water resources, new water sources, rest-rotation and deferred rotation to reduce impacts on problem areas so that conditions improve), that 10 would maintain, and 1 would likely to continue to degrade (because of multiple reasons including cumulative grazing, reservoir water level fluctuation between high and low reservoir levels and associated bare banks above the receding reservoir level, and recreation)(water Resources Report, pp ). This degraded reach (Goose Lake Inlet) would continue to be managed under the adaptive management approach but will likely need additional management and monitoring from other resources to lift it to a maintaining or improving trend (EA, p. 87; Water Resources Report, p. 19; EA, Appendix D, p. 52, 55-59; Appendix E, p ). In the EA, areas of concern are referred to as isolated areas of impact. This change was made because the environmental analyses showed that these areas are isolated and scattered throughout the allotments, and when viewed in the larger context of the grazed areas, are comparatively small in area and extent (EA, Appendices, p. 62). The intent of the proposed action (to authorize continued grazing in a manner that meets or moves toward desired conditions and incorporate an adaptive management and monitoring strategy) is to reverse the degrading trend at specifically isolated areas of impact to maintaining or improving trend (EA, Appendices, p. 62). As described and cited above, there is monitoring, adaptive management, BMPs, and a proposed project (dispersed recreation) in place to improve the Goose Lake Inlet and other degraded sites. APPEAL ISSUE 19: Given the importance of the Goose Lake area to recreationists and the intense grazing use by livestock, full NEPA analysis of these cumulative effects should occur before a decision is issued on the Meadows Valley Allotment. RESPONSE: Along with the direct and indirect effects of the alternatives on various resources, the effects of other actions with similar effects are also analyzed for each resource (EA, Chapter 3). The effects contributed by recreation activities in the overall project area are discussed in the cumulative effects section of each resource (EA, p. 50, p. 61, p. 87, p. 105, p. 117, and p. 142). While the possibility of a future project that would manage dispersed recreation specifically at Goose Lake is acknowledged (EA, p.87), that project is conjectural. Its impacts are not reasonably foreseeable and cannot be analyzed in a meaningful way. 9

12 APPEAL ISSUE 20: There is evidence of continuing degradation/non-compliance with Forest Plan Standards submitted by the Appellant. RESPONSE: The allotments have been regularly monitored for compliance with current requirements for more than ten years (EA, p. 35). Recent monitoring indicates that the health of rangeland vegetation has improved positively throughout the project area (EA, p. 35). Table R-1 titled Long Term Upland Rangeland Vegetation Monitoring Sites shows the Percent of Ground Cover as being within the Desired Conditions in (EA, p. 35). Recent riparian vegetation health monitoring shows that improvement throughout the allotments has occurred or conditions are within the desired conditions for the allotment (EA, pp , and Table R-2, p. 7). The general improving trend of the allotments is a result of substantial management changes to livestock grazing practices over the past 10 to 15 years and expressed in the vegetation communities through diversity in plant composition and increased ground cover (EA, p. 36). However, some isolated areas of impact within the allotment are currently in a degraded status despite the overall and general conditions improving or being within the desired conditions within the allotment (Table WQ-4 of the EA, pp ). In the final version of this EA, areas of concern are referred to as isolated areas of impact (could include newly identified disturbed areas as well as isolated areas of impact in a general sense). This change was made because the environmental analyses showed that these areas are just that, isolated and scattered throughout the allotments, and when viewed in the larger context of the grazed areas, are comparatively small in area and extent. The intent of the proposed action (to authorize continued grazing in a manner that meets or moves toward desired conditions, and incorporates an adaptive management and monitoring strategy) is to reverse the degrading trend at specific disturbed areas, both previously known or new sites that are discovered, to a maintaining or improving trend (EA, p. 62). There are monitoring plans (EA, Appendix D), an adaptive management strategy to implement, monitor, and adapt as described in Appendix A and in the Response to Comments (EA, Appendix A; EA, pp. 62, and 64), Allotment Management Plans (Appendix F), Annual Operating Instructions and BMPs in place to identify and improve degraded or disturbed sites. 10