DSEIS for the Upper Green River Area Rangeland Project ...a123.g.akamai.net/7/123/11558/abc123/forestservic...DSEIS for the Upper Green River Area Rangeland Project personal labor

DSEIS for the Upper Green River Area Rangeland Project Bridger-Teton National Forest

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Chapter 4: Environmental Effects

This chapter summarizes the potential changes to the social and economic, physical, and

biological environments due to implementation of the alternatives. It also presents the

scientific and analytical basis for the comparison of alternatives presented in Chapter 2.

Socio-Economic Resources___________ Overview of Issues Addressed Key Issue: Social and Economic Impacts Livestock grazing may affect local communities and permittees. Continuing to authorize

livestock grazing in the project area would support the custom and culture in surrounding

communities and contribute to Forest Plan goals for community prosperity. The concern

is that reducing livestock numbers or placing further restrictions on livestock grazing

would negatively affect permittees and local communities.

Issue Indicators

• Whether livestock grazing is authorized

• Relative amount of resources required of permittees to comply with design

features

Agriculture is one of the primary industries in Sublette County and in the state of

Wyoming. A large portion of employment in the Pinedale area is related to the livestock

industry. A segment of the local beef industry is dependent on the use of the National

Forest for summer livestock forage when private property is used to produce hay for the

cattle during the winter. The net cash income that these permittees receive would be

affected by reductions in their permitted use, see Figure 4.1.

Local businesses derive a portion of their income by providing goods and services to

support the livestock industry. Real estate markets are influenced by sales of ranches and

the availability of private agricultural lands as well as the aesthetic values associated with

these relatively undeveloped areas. Impacts to local communities can be assessed by

considering whether livestock grazing on National Forest System lands would be

authorized. Impacts to individual permittees may be compared by considering the number

of livestock that can be grazed, and the duration of time that the livestock may use and

occupy the grazing allotments. Since livestock removal may be required at any time prior

to the permitted “off date” in order to comply with grazing use requirements, the duration

of time that livestock can stay on the allotment depends largely on the permittees

effectiveness in managing the livestock to comply with those grazing requirements.

Permittee effectiveness can be highly variable as a result of differing financial resources,

personal commitment, and available labor pools. Therefore a more accurate measurement

of impacts to individual permittees is the relative amount of resources, including both

DSEIS for the Upper Green River Area Rangeland Project

personal labor and financial investment that they must ex

the allotment for the full grazing season.

Figure 4.1: Average Annual Net Cash Income for a Federal Land Ranching Operation with Reductions in Federal Grazing Permits. (Taylor 2003)

Examples of some efforts that are re

maintaining range improvements, moving livestock from natural congregation areas to

reduce impacts in those areas, monitoring vegetation to ensure compliance with forage

use standards, moving livestock from one p

scheduled for rest to insure that livestock do not use them, placing salt strategically in

order to draw livestock away from congregating areas, and removing dead livestock from

popular use areas in order to r

For the two alternatives that authorize livestock grazing, it was assumed that it is possible

to implement all of the design features associated with the alternatives, and graze for the

full permitted season of use, provided enough time, financial resources and labor are

expended by the permittees. This assumption is supported by grazing capacity

information that indicates enough forage is produced on the allotment for livestock,

wildlife, and watershed needs. Examples of variables that might change this assumption

would include severe drought, wildfire, or large increases in wildlife populations. In

reality, the permittees could make a financial decision at some point that the additional

costs to implement design features of the alternatives were greater than the benefits of

keeping the livestock on the allotment. They might then choose to remove the livestock

from the allotment prior to their required “off date”, rather than expending additional

effort to control livestock use. In either case, they would be required to implement the

-$30,000

-$20,000

-$10,000

$0

$10,000

$20,000

$30,000

$40,000

0

$31,556

Percent Reduction in Federal Grazing Permits


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personal labor and financial investment that they must expend to keep their livestock on

the allotment for the full grazing season.

Figure 4.1: Average Annual Net Cash Income for a Federal Land Ranching Operation with Reductions in Federal Grazing Permits. (Taylor 2003)

Examples of some efforts that are required of permittees include such things as



use standards, moving livestock from one pasture to another, observing pastures that are



popular use areas in order to reduce conflicts between predators and recreationists.



d season of use, provided enough time, financial resources and labor are



ed needs. Examples of variables that might change this assumption



ement design features of the alternatives were greater than the benefits of



t to control livestock use. In either case, they would be required to implement the

25 50 100

$31,556

$17,293

$867

-$24,998

Percent Reduction in Federal Grazing Permits

Teton National Forest

pend to keep their livestock on

Figure 4.1: Average Annual Net Cash Income for a Federal Land Ranching Operation with

quired of permittees include such things as



asture to another, observing pastures that are



educe conflicts between predators and recreationists.



d season of use, provided enough time, financial resources and labor are



ed needs. Examples of variables that might change this assumption



ement design features of the alternatives were greater than the benefits of



t to control livestock use. In either case, they would be required to implement the


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design features described under each alternative as well as the other requirements to

graze livestock on National Forest System lands. For this analysis to be most meaningful,

it is necessary to compare the relative amount of effort that it would take to implement

the design features prescribed in each alternative.

Spatial and Temporal Context for Effects Analysis The spatial context for this analysis is limited to Sublette County and some relatively

small portions of the project area outside of Sublette County. Economic information

about the county suggests that while agriculture (specifically ranches that are associated

with the allotments in the project area) is important to the county, it is less important to

the state’s economy, which is much larger and more diverse, thus less affected by

permitted use in the project area. The economic effects of this action are discussed in the

short-term as indicated by the relative effort and expense to comply with design features

of the alternatives. Longer term effects are discussed in terms of whether livestock

grazing would be authorized or not.

Effects Common to Both Action Alternatives Continuing to authorize livestock grazing on the six allotments would help meet Forest

Plan direction to support local communities and provide forage for livestock grazing. In

addition, authorizing livestock grazing would support the local community and the

custom and culture of domestic livestock grazing in this area.

The Forest Plan articulates a goal for community prosperity with one objective of

providing forage Forest-wide for approximately 260,000 AUMs of livestock grazing

annually. Because alternatives A and B authorize the currently permitted use of

approximately 46,000 AUMs, these alternatives are consistent with, and contribute to that

goal and objective.

Alternative A – Grazing as Currently Permitted

Direct and Indirect Effects

Implementation of Alternative A would not change livestock grazing as currently

authorized. Agriculture related employment, spending, and effects on the real estate

market and other impacts to the local community would not change as a result of

continuing to authorize livestock grazing as described in this alternative. No changes in

the local custom and culture of domestic livestock grazing would result due to taking the

proposed action.

Local communities, agriculture, and local customs would continue to be influenced by a

number of dynamic factors such as fuel costs, labor costs, feed costs, and cattle prices.

These changes may alter many of the current conditions that are outlined in Chapter 3;

however, the effects of implementing this alternative would not change the local

communities.


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Permittees would continue to conduct domestic livestock grazing and associated activities

on the National Forest. The level of effort that would be required to stay in compliance

with grazing requirements would not change as a result of implementing this alternative.

Implementation of this alternative would not cause a change to the current situation as it

affects local permittees.

The relationship of short-term uses and long-term productivity in the context of the social

and economic effects of this alternative can be described in the following way. The short

term annual use of the allotments by livestock contributes, although in a relatively small

way, to the stability of local ranches and the local economy. There is no loss to long-term

productivity in this context, because short-term uses are not changed from the existing

condition.

Cumulative Effects

Because there are no direct or indirect effects on socio-economic resources under

Alternative A, there are no cumulative effects.

Alternative B – Modified Grazing Management (Proposed Action)


Implementation of Alternative B would not change the permitted livestock numbers or

duration of grazing as currently authorized. Agriculture related employment, spending,

and effects on the real estate market and other impacts to the local community would not

change measurably as a result of continuing to authorize livestock grazing as described in

this alternative. Changes in the local custom and culture of domestic livestock grazing

would not be expected, as livestock grazing would still be authorized on National Forest

System lands.


number of dynamic factors such as fuel costs, labor costs, feed costs, and cattle prices.

These changes may alter many of the current conditions that are outlined in Chapter 3.

However, the effects of implementing this alternative would not change the local

communities.

Permittees would continue to conduct domestic livestock grazing and associated activities

on the National Forest. The permittees would need to monitor the vegetation and move

cattle away from natural congregation areas more frequently. They may be required to

pay for additional structural range improvements necessary to meet desired conditions.

Implementation of this alternative would likely increase the level of effort that is required

of permittees in order to meet the additional grazing use and occupancy requirements and

mitigation measures as outlined in Chapter 2.




207

term annual use of the allotments by livestock contributes, although in a relatively small

way, to the stability of local ranches and the local economy. The productivity loss for this

alternative is that the increased level of effort or resources to implement this alternative

would have more of an effect on the stability of local ranches and the local economy than

Alternative A.

Cumulative Effects

The financial success of businesses such as ranching operations is affected by a multitude

of factors. Those ranches that are in danger of financial failure would be most affected by

the increased level of effort that would be necessary to comply with the mitigation

measures outlined in this alternative. It would be difficult, if not impossible to determine

whether this is the case for any of the permittees that graze their livestock on the

allotments considered in this analysis. It is assumed that there is the possibility that these

additional requirements, when added to the other financial challenges inherent in small

business operation, may contribute to the failure of the individual ranch. This in turn,

could affect local real estate markets. The likelihood of individual ranch failures would

be greater under Alternative B than under Alternative A because while Alternative A

requires financial and personal efforts to stay in compliance with management

requirements, a number of additional requirements are prescribed in Alternative B.

Effects to local communities and agriculture would be limited because of the limited

numbers of ranchers directly affected by this alternative; however the level of risk to

communities would be greater under this alternative than under Alternative A since ranch

failure has a greater potential under Alternative B.

Alternative C – No Livestock Grazing (No Action)


Implementation of Alternative C would phase-out livestock grazing as currently

authorized in the project area. Agriculture related employment, spending, and effects on

the real estate market and other impacts to the local community would change as a result

of discontinuing livestock grazing as described in this alternative. Changes in the local

custom and culture of domestic livestock grazing may be expected, as livestock grazing

would not be authorized on National Forest System lands in the project area.


number of dynamic factors. These changes may alter many of the current conditions that

are outlined in Chapter 3. The effects of implementing this alternative could change the

local communities if a number of the permittees were unable to continue raising livestock

on their private land as a result of no longer being able to use the forage resources on

National Forest System lands in the project area. Since the net-cash income of these

ranches is closely tied to reductions in public land grazing (see Figure 4.1), the potential

to impact these ranches is high. Impacts to communities, agriculture in the area and local

customs is less likely because there are ranches outside the project area that would not be

affected by this decision and there are other ranches in the county that do not rely on

public land grazing.


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term annual use of the allotments by livestock is not authorized and thus this alternative

does not contribute to the stability of local ranches and the local economy.

Cumulative Effects

Under this scenario it is more likely that the local ranches that depend on their permitted

grazing-use on the affected grazing allotments would fail. It is also more likely that real

estate markets would be affected by more ranches being put up for sale. Real estate

markets in the local area might be affected, but affects outside the local area would be

unlikely. Cumulative effects to individual ranchers and local communities would be

greater under this alternative than under alternatives A and B, which authorize livestock

grazing.

Forest Plan direction that is relevant to the socio-economic effects of each alternative is

limited. The Forest Plan articulates a goal for community prosperity with one objective of

providing forage Forest-wide for approximately 260,000 AUMs of livestock grazing

annually. Because Alternative C does not authorize any domestic livestock grazing, this

alternative does not contribute to that goal and objective.

Range Resources____________________

The effects of livestock grazing on the environment will be described in terms of four

variables that characterize livestock grazing; they include timing, intensity, frequency,

and duration of grazing. The environmental effects will be estimated for each alternative

based on the expected results from the complex interactions of the four variables as they

are designed to take place in the proposed action and alternative actions.

Overview of Issues Addressed Key Issue: Rangeland Function Livestock grazing may affect vegetation and soils, which are the components of overall

rangeland function. Vegetation communities and watersheds that are not functioning

properly provide less than optimum conditions for wildlife and wildlife health.

Issue Indicators

• Change in groundcover

• Presence or establishment of invasive plants

• Change in desired plant species composition

• Change in shrub cover

• Stubble height remaining


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Introduction In order to estimate and compare the environmental effects of the alternatives, a couple of

assumptions must be made:

Assumptions

• Effective compliance with design features

• Effective placement of key areas to reflect changes in vegetation (Note:

key areas may be changed by the Interdisciplinary Team if monitoring

indicates that they are not effective.)

Livestock grazing has contributed to changes in vegetation in the project area. The

vegetation changes caused by livestock grazing are generally limited to species

composition changes within vegetation communities rather than broad changes in

vegetation/formation categories outlined in Chapter 3. Undesirable changes in vegetation

may be lessened or avoided by addressing or limiting the intensity of livestock grazing.

Limiting the amount of vegetation that is used by livestock may be accomplished by

establishing proper use standards and removing livestock from an area prior to exceeding

these standards. Proper use is defined as a degree of utilization/stubble height of current

year’s growth, which, if continued, would achieve management objectives established to

maintain or improve the long-term productivity of the site.

Adaptive Management

An adaptive management strategy will be used to monitor the implementation and

effectiveness of carrying out the selected alternative. Adaptive management is a system

of management practices based on clearly identified intended outcomes and monitoring

to determine if management actions are meeting those outcomes; and, if not, to facilitate

management changes that will best ensure that those outcomes are met or re-evaluated.

Adaptive management stems from the recognition that knowledge about natural resource

systems is sometimes uncertain. (36 CFR 220.3) The adaptive management strategy used

as part of the proposed action is illustrated in Chapter 2. Incomplete and Unavailable Information One pasture (Kinky Creek) was added to the Upper Green Allotment by an administrative

action. This pasture has not been grazed for several years. The pasture is just a portion of

a larger grazing allotment that is now vacant. Under either of the alternatives that

authorize grazing, this pasture may be grazed; however, no additional cattle will be

allowed to be added to the allotment. Until a key area can be established and baseline

groundcover data can be gathered, the pasture would only be grazed in an emergency

situation such as to resolve problems with large predators or to provide additional forage

in case of a large wildfire. The BTNF specific groundcover threshold for functionality

would be applied as the desired condition for the key area.

Spatial and Temporal Context for Effects Analysis The forage utilization and stubble height standards included as part of the two

alternatives that authorize grazing are designed to achieve a desired future condition.

They are short-term management indicators, not goals, objectives, or desired conditions.

The long-term objectives in this case are groundcover and species composition. While the


210

short term standards are annual indicators, the long-term desired conditions that are truly

indicative of our actions take longer to achieve. No studies are available to estimate how

long it would take to achieve desired conditions. Therefore, long-term desired conditions

are described in this analysis in relative terms. In order for changes to take place in

groundcover and species composition, the native vegetation would have to either

establish new perennial plants or plants would have to die out. These changes could take

place as quickly as a few years but should not take decades. Significant improvements

could therefore take up to twenty years, but would be measured at five or ten year

intervals.

Effects Common to All Action Alternatives The Forest Plan is a programmatic document that allocates resources, sometimes among

competing uses. The Forest Plan specifically authorizes livestock grazing as a valid use in

this area. If any stock use is permitted, some environmental effects would be sustained.

These may include displacement of soil and vegetation in stream crossing areas, on fence

lines, around water developments, and in salting areas. These soil and vegetation effects

may retard or prevent complete recovery of hydrologic systems. Generally these effects

are limited to very small areas; where this is not the case, it is likely that monitoring of

key areas would reveal more widespread effects.

In order to disclose the environmental effects of livestock grazing, it is necessary first to

put those effects into perspective. Numerous laws, regulations, and policies govern the

use and administration of rangeland resources on National Forest System lands. National

laws and regulations have also been interpreted for implementation in Forest Service

Manuals, Handbooks, and Regional Guides. All grazing activities authorized under

permit must comply with these laws, regulations, and policies, which are intended to

provide general guidance for the implementation of grazing practices and for the

protection of rangeland-related resources.

Most livestock grazing on National Forest System lands has occurred in the areas

presently grazed, in a variety of forms, for over a hundred years. Typically during that

time numerous grazing practices have been implemented along with accompanying range

improvements. Stocking rates and seasons of use have been adjusted; the timing,

intensity, frequency, and duration of grazing have been continually fine tuned over time.

More recently, further adjustments have been made on many allotments to provide for the

needs of species listed under the Endangered Species Act of 1973 (16 U.S.C. 1531 et

seq.), clean water, and archeological structures and artifacts. This dynamic evolution of

management, on most allotments, results in the ability to narrow the range of alternatives

that must be analyzed in detail.

Although management direction for rangeland resources would vary by alternative,

direction for all alternatives has been developed to maintain or improve rangeland

conditions on National Forest System lands. Rangeland resource goals and objectives

have been designed to achieve desired rangeland conditions over the long-term and to

maintain or restore sustainable levels of forage production, livestock use, and ecosystem

functions and processes. Rangeland standards and guidelines have been designed to


211

protect upland and riparian vegetation, as well as other resources that could be adversely

affected by livestock grazing activities. Management direction for other resource

programs, such as vegetation, soil, water, riparian, aquatic, wildlife, and recreation,

provides additional guidance and resource protection in an integrated manner. As natural

resource sciences result in better understanding of the effects of livestock grazing,

practices that were once designed to maintain or improve range vegetation may have to

be modified to achieve desired conditions.

Alternative A – Grazing as Currently Permitted Under this alternative, the permittees are currently managing their livestock in such a way

that their use is well below the maximum amount of forage utilization that is allowed. It

is possible that they, or their future counterparts, would choose to manage their livestock

in such a way that they reach the maximum allowable use. In addition, three of the six

allotments could still employ season-long grazing. For this alternative, the allowable use

must be analyzed rather than the existing use.

Direct and Indirect Effects The vegetative conditions on 7 key areas that are in less than desired condition would

remain in their current condition unless permittees chose to use the maximum amount of

forage available to them within the utilization limits of this alternative. Should maximum

use limits be reached, a downward trend in these sites would occur. The vegetative

conditions on 20 key areas of the allotment that are essentially at, or exceeding desired

future condition may remain in desired condition if the livestock grazing management

that resulted in those conditions are not altered. Again, should maximum use limits be

reached, a downward trend in these sites may result. A result of implementing this

alternative is that there would be no progress toward restoration of critical areas and the

one tall forb area that has been identified as at-risk because restorative design features

such as range improvements, hardened crossings, and removal of livestock from some

critical areas are not a part of this action.

Cumulative Effects

The interdisciplinary team identified approximately 40 past and present management

activities and a number of reasonably foreseeable future activities. This list is included in

Appendix A. Given the nature of these activities, the primary cumulative impact to

rangeland vegetation can be summarized into the following categories: livestock grazing

and fire management.

Historical grazing practices resulted in more environmental effects to vegetation because

historical numbers of livestock were higher and management considerations were not

focused on high use areas. Past fire management was largely confined to fire suppression.

The primary effect to rangeland vegetation was to reduce the diversity of age classes in

the sagebrush overstory.

The existing vegetation conditions described in Chapter 3 indicate that the majority of the

project area contains vegetation that contributes to properly functioning rangeland and

watershed condition. Impacts associated with livestock grazing were historically greater


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due to higher numbers of livestock. Reasonably foreseeable future activities would be

designed to minimize impacts. However, implementation of this alternative could result

in rangeland conditions that risk the functionality that currently exists. Fire management

activities combined with current management as defined in this alternative could exceed

the capacity of the resource to sustain itself. Although future prescribed burns and other

fire management activities would be designed to restore or otherwise minimize impacts

on range vegetation.

Suitability/Capability Analysis

The forest level analysis of capable grazing lands was completed and is documented as a

GIS layer that was used to map the intersection of grazing lands and management

indicator species’ habitats. Evaluation of this intersection of grazed lands and

management indicator species, habitats is located in the Wildlife section of this

document.

Lands capable of being grazed by livestock were also analyzed at the project area level

and similarly incorporated into a GIS layer. Comparing the two maps of lands capable of

producing forage for livestock use shows remarkable similarity in the resulting area

identified (see Appendix B). Further evidence of the physical capability of the land to

support livestock grazing is indicated by environmental analyses that fail to identify any

locations within the project area that show unacceptable accelerated erosion, evidence of

livestock grazing on slopes too steep to withstand grazing, or evidence of grazing taking

place outside of livestock use areas. In addition, acreages derived from the 1960s and

1980s range analysis data are similar to the Forest and project level GIS data. That range

analysis data indicated that less than half of forage available to livestock is being used,

even after allowing for adequate remaining forage to maintain watershed function and

wildlife forage. The recent data is consistent with the older data.

Areas suitable for livestock grazing include all the area that is capable of supporting

livestock grazing minus any lands that were removed from grazing due to social priorities

such as campgrounds and areas reserved for wildlife or other uses. The only area that has

been excluded from livestock under Alternative A is the Green River Lakes Campground.

This area is so small that it has virtually no impact on forage available for livestock in the

project area.



The vegetative conditions on 7 key areas that are in less than desired condition would

move towards desired condition as each of those areas has design features that move

towards attainment of desired condition. The vegetative conditions on 20 key areas of the

allotment that are essentially at, or exceeding desired future condition would remain in

desired condition and a monitoring plan would be in place to ensure this. Critical areas

and the one tall forb area that has been identified as at-risk would be restored as a result


213

of implementing this alternative, because restorative design features such as range

improvements, hardened crossings, and removal of livestock from some critical areas are

a part of this alternative.

The design features associated with this alternative include range improvements that are

designed to reduce livestock grazing in sensitive areas or to assist with implementation of

rotational grazing strategies. In addition, grazing use or stream bank trampling standards

would be implemented in order to improve ground cover or stream bank characteristics.

Recent scientific literature is full of examples of improvement in vegetation, hydrology,

and stream systems as a result of limiting livestock use. Because of the variability of

natural systems and the inability to control all variables in a real life situation such as

livestock grazing in the Upper Green River project area, no single conclusion has been

drawn regarding the appropriate use standard for a specific situation.

With these recommendations and findings in mind, vegetation on all key sites should

improve, because the design features and mitigation measures associated with this

alternative have been studied, designed and proven effective in similar situations at

improving vegetation as well as hydrologic and stream function. Critical areas would

improve because of reduced livestock use and efforts to restore damaged areas.

Improvement would be more rapid than under Alternative A, less rapid than under

Alternative C.

Cumulative Effects

Cumulative impacts to range vegetation would show improvement when compared to

effects of Alternative A. The alternative features designed to improve vegetation in

critical areas would improve these areas. Alternative B would include a prescription for

additional protection from cattle use in prescribed burn areas prior to recovery of those

areas, thus fewer cumulative impacts would be expected with this alternative than under

Alternative A.

The existing vegetation conditions described in Chapter 3 indicate that the majority of the

project area contains vegetation that contributes to properly functioning rangeland and

watershed condition. Alternative B is designed to improve the vegetation and other

resources that are not currently in properly functioning condition. Impacts associated with

livestock grazing were historically greater due to higher numbers of livestock.

Reasonably foreseeable future activities would be designed to provide additional resource

protections. Therefore, the magnitude and extent of environmental effects do not exceed,

nor are they expected to exceed, the capacity of the resource to sustain itself.

Grazing Capability and Suitability: The forest level analysis of capable grazing lands

was completed and is documented as a GIS layer that was used to map the intersection of

grazing lands and management indicator species’ habitats. Evaluation of this intersection

of grazed lands and management indicator species’ habitats is located in the Wildlife

section of this document.

Lands capable of being grazed by livestock was also analyzed at the project area level

and similarly incorporated into a GIS layer. Comparing the two maps of lands capable of


214

producing forage for livestock use shows remarkable similarity in the resulting area

identified (see Appendix C). Further evidence of the physical capability of the land to

support livestock grazing is indicated by environmental analyses that fail to identify any

locations within the project area that show unacceptable accelerated erosion, evidence of

livestock grazing on slopes too steep to withstand grazing, or evidence of grazing taking

place outside of livestock use areas. In addition, acreages derived from the 1960s and

1980s range analysis data are similar to the Forest and project level GIS data. That range

analysis data indicated that less than half of forage available to livestock is being used,

even after allowing for adequate remaining forage to maintain watershed function and

wildlife forage. The recent data is consistent with the older data.

Areas suitable for livestock grazing include all the area that is capable of supporting

livestock grazing minus any lands that are removed from grazing due to social priorities

such as campgrounds and areas reserved for wildlife or other uses. The area that has been

excluded from livestock under Alternative B is the Green River Lakes Campground, the

Green River elk feedground, and Roaring Fork Basin. The combined area of these sites is

at most 600 acres. If you assumed that these acres were very productive (2,000 pounds of

forage per acre) and that fully half of that forage was available to livestock, you would

remove 300 tons of livestock forage. That is less than 1 percent of the available forage in

the project area, and would not cause livestock to obtain forage from areas not capable of

sustaining grazing. Following the proper use standards associated with Alternative B

would ensure that.



The vegetative conditions on all key areas that are in less than desired condition would

move rapidly towards desired condition as the effects of livestock grazing would be

removed. This improvement would be more rapid under this alternative than either

Alternative A or B. Restoration of critical areas that are at risk as a result of livestock

grazing impacts would rapidly improve, although effects from uses other than livestock

grazing would remain (recreation trailing, vehicle crossings). Restoration of those critical

areas would not improve as a result of implementing this alternative, since restorative

design features such as hardened crossings are not a part of this alternative.

Cumulative Effects

The Interdisciplinary Team identified approximately 40 past and present management

activities and a number of reasonably foreseeable future activities. This list is included in

Appendix A. Given the nature of these activities, the primary cumulative impact to

rangeland vegetation can be summarized into the following categories: livestock grazing

and fire management.

Historical grazing practices resulted in more environmental effects to vegetation since

historical numbers of livestock were higher and management considerations were not

focused on high use areas. Past fire management was largely confined to fire suppression,

the primary effect to rangeland vegetation was to reduce the diversity of age classes in


215

the sagebrush overstory.

Implementation of this alternative would show improvement in rangeland vegetation in

all key and critical areas, with the exception of the critical areas that sustain impacts that

are primarily caused by activities other than grazing. Fire management activities would

result in the least impacts under Alternative C, since livestock would not contribute to

environmental effects on prescribed burn areas. The magnitude and extent of

environmental effects do not exceed, nor are they expected to exceed, the capacity of the

resource to sustain itself.

Ability to comply with Forest Plan Standards and Guidelines: Table 4.1 depicts the

ability of the alternatives to comply with Forest Plan standards and guidelines.

Table 4.1: Ability of Alternatives to Comply with Forest Plan Standards and Guidelines

Standard or Guideline

Ability to meet with Alternative A

Ability to meet with Alternative B

Ability to meet with Alternative C

Allotment Planning Standard

Meets Meets Meets

Allotment Management Plan (AMP) Standard

Does not fully meet. Needs for streamside vegetation is not fully addressed.

Meets Meets

Livestock Movement Standard

Meets Meets Meets

Livestock Grazing of Riparian Areas Standard

Does not fully meet. Stream banks are not fully protected.

Meets Meets

Forage Improvement Standard

Does not fully meet. Range in less than satisfactory condition would not be required to be improved.

Meets Meets

Structural Improvement Standard

Meets Meets Meets

Forage Utilization Standard

Does not meet for allotments where season-long grazing exists. Meets elsewhere.

Meets Meets

Fencing Riparian Area Guideline

Meets Meets Meets

Vacant Allotment Guideline

Meets Meets Meets

Proper Use Guideline

Does not fully meet. Most proper use standards are not based on site-specific objectives; they are based on maximum allowable standards.

Meets Meets

Livestock Grazing Coordination Guideline

Meets Meets Meets


216

Soil Resources______________________

Overview of Issues Addressed

Key Issue: Rangeland Function

Livestock grazing may affect vegetation and soils, which are the components of overall

rangeland function. Vegetation communities and watersheds that are not functioning

properly provide less than optimum conditions for wildlife.

Issue Indicators

• Soil compaction

• Active erosion

• Effective ground cover

Spatial and Temporal Context for Effects Analysis

The temporal effects of reduced ground cover, which leads to soil erosion can last

anywhere from 5 to 500 years depending on how much soil is lost and how fast the soil

organic matter is replaced from the vegetation it supports. Severely compacted soils that

limit root penetration can permanently reduce soil productivity if not treated. Light to

moderately compacted soils (not root limiting) can recover overtime with natural

freeze/thaw cycles and reduced use.

The spatial effects of reduced ground cover and soil erosion can be highly variable

depending on the inherent erodability of the particular soil types found within an

allotment. Soils can vary spatially within short distances depending on the type of parent

material in which they are derived. The allotment boundary generally is used as the

‘analysis area’ but effects may vary from soil type to soil type within an allotment. Often

effects are summarized for each allotment or by individual soil map unit where necessary.

Cumulative Effects Common to All Alternatives

Past and Present Actions Contributing to Potential Cumulative Actions in All Alternatives

Past timber harvest in the Upper Green River area has led to some erosion and

compaction along roads and in clearcut units.

Dispersed camping along major roads has led to some localized erosion and compaction

around the camping areas. This is mainly caused by vehicle and foot traffic around these

areas.

Soil compaction is present on the elk feedground in the Upper Green. About 4 percent of

the feedground area was found to be severely compacted (Winthers 2007).


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Alternative A would continue current grazing practices as currently permitted. Ground

cover in most key areas would remain in properly functioning condition. Ground cover at

sites identified in the Upper Green, Beaver-Twin, Noble Pastures and Wagon Creek

allotments that are not meeting desired conditions would continue to not meet desired

conditions. Compaction and erosion associated with cattle grazing would remain a

potential problem at already impacted sites.

Alternative A would not meet the Forest Plan’s ‘Proper Use Guideline’ for those key

areas identified in the Upper Green, Beaver-Twin, Noble Pastures and Wagon Creek

allotments that do not meet desired conditions.



Alternative B would make modifications to current grazing practices that would

implement management prescriptions and range improvements designed to improve

ground cover at sites identified in the Upper Green, Beaver-Twin, Noble Pastures and

Wagon Creek allotments that are not meeting desired conditions. These prescriptions

include reducing utilization from 65 percent to 50 percent and incorporating more

stringent stubble height requirements. These measures would leave more forage on site

allowing ground cover to improve over time. Key areas meeting desired conditions would

most likely remain in properly functioning condition. Compaction and erosion caused by

cattle grazing would be reduced because cattle would be spending less time on already

impacted sites.

Adaptive management criteria in Table 2.3 in Chapter 2 are features of this alternative

designed to raise stubble height standards or allowable use standards when key areas are

found to not meet desired conditions. The management criteria would help ensure that

ground cover is maintained at desired conditions.

Alternative B would meet the Forest Plan’s ‘Proper Use Guideline’ for those key areas

identified in the Upper Green, Beaver-Twin, Noble Pastures and Wagon Creek allotments

that currently do not meet desired conditions.



Alternative C would discontinue grazing in the Upper Green River area. Ground cover at

sites identified in the Upper Green, Beaver-Twin, Noble Pastures and Wagon Creek

allotments would improve over time. Key areas meeting desired conditions would most


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likely remain in properly functioning condition. Compaction and erosion associated with

cattle grazing would cease.

Alternative C would meet the Forest Plan’s ‘Proper Use Guideline’ for those key areas

identified in the Upper Green, Beaver-Twin, Noble Pastures and Wagon Creek allotments

that currently do not meet desired conditions .

Cultural Resources__________________

Overview of Issues Addressed The issuance of term grazing permits and the administration and management of

rangeland activities associated with term permits for National Forest System lands may

affect properties either listed in or eligible for listing in the National Register of Historic

Places.

Issue Indicators

• Damage to prehistoric and historic sites

• Damage to unknown sites

Effects Common to the Action Alternatives


Livestock grazing could have direct effects to cultural resources through trampling or

chiseling in damp and/or sandy soils and sloughing and collapse of stream banks. Fire

pits and other archeological features that are exposed in road cuts or lay on the surface of

a site can be damaged by livestock as they move across these site areas. Livestock also

have the potential for impacting historic structures if they congregate around these

structures in great numbers. However where cattle grazing activities are not intense, such

as across well managed and healthy pastures with low utilization rates, occasional use

would not be considered significant and impacts would not occur. The cultural resource

surveys and monitoring of site conditions in the Green River Allotments indicate that

direct effects are not occurring on historic and/or prehistoric sites. The trailing of

livestock along the Green River Lakes Road and other locations within the allotments is

not resulting in direct effects to cultural resources. This occasional use is not considered

significant.

Indirect effects could involve the removal of vegetation and trampling-induced

compaction that could lead to reduced infiltration rates and subsequent increased runoff

that causes sheet erosion. The loss of vegetation can cause the loss of artifact context

through down slope transportation, stream bank destabilization, and increased visibility

of surface materials and subsequent unauthorized artifact collection. Monitoring of site

conditions in the Upper Green River allotments has not detected areas where indirect

effects are occurring to historic properties.


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Cumulative Effects

It has been observed that the primary impacts to archeological sites on the BTNF results

from intensive human activity, such as two track roads, constructed roads, trails,

dispersed recreation activity, or un-controlled wild fire. When these activities occur on or

near significant historic properties, the result could lead to exposed subsurface soil

deposits or damaged historic structures. These exposed sites are then susceptible to

further damage from erosion process, human activity, and potentially from livestock

grazing activities. As the Upper Green River area continues to receive increased human

activity, there remains the potential for an increase in the cumulative effects to cultural

resources in the future.



There would be no direct or indirect effects to cultural resources under Alternative C.

Cumulative Effects

Because there are no direct or indirect effects, there would be no cumulative effects.

Recreation, Wilderness and Related Resources__________________________

Overview of Issues Addressed The issuance of term grazing permits and management practices such as construction of

rangeland improvements may adversely affect Visual Quality, Recreation, Access,

Wilderness, Wild and Scenic Rivers, Research Natural Areas, Special Interest Areas, and

Inventoried Roadless Areas within and adjacent to the project area.

The following three issues also have potential to affect compliance with Forest Plan

Regional, and National direction, law, or policy relating to specially designated areas

such as Wilderness, Wilderness Study Areas, eligible Wild and Scenic Rivers, Research

Natural Areas, Special Interest Areas, and Inventoried Roadless Areas:

Effects Common to the Action Alternatives

Direct, Indirect, and Cumulative Effects

Environmental effects to Visual Quality, Recreation, Access, Wilderness, Wild and

Scenic Rivers, Research Natural Areas, Special Interest Areas, and Inventoried Roadless

Areas are based upon known existing conditions, trends, and expected responses to the

proposed action and alternatives.


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Direct effects of livestock grazing are caused by presence of cattle within dispersed

campsites, along roads and trails, and within recreation corridors such as rivers and

streams. Livestock also have the potential to directly impact trail tread, create multiple

trails, and impact facilities such as kiosks, signs and sign posts, fences, and other

structures used as scratching posts. In addition, cattle on roadways pose a safety risk for

motor vehicle accidents, particularly on high speed roads such as Union Pass Road (FS-

37-600) and Green River Road (FS-37-650).

Other impacts of livestock grazing, which include removal of vegetation, trampling,

compaction, and water quality impacts, can change the natural ecological function and/or

unique characteristics of specially designated areas such as Wilderness, Wilderness Study

Areas, Research Natural Areas, Special Interest Ares, and eligible Wild and Scenic

Rivers depending upon the severity, size and duration of the impact.

Livestock and Forest visitors tend to be attracted to the same or similar sites, which are

relatively flat and located within 100 yards of water. In addition, cattle and humans tend

to select similar shallow locations for stream crossings and the easiest, shortest paths to

and from water and other attractive features. For these reasons, sites impacted by cattle

are often cumulatively impacted by recreation use. Other actions contributing to

cumulative effects to Visual Quality, Recreation, Access, Wilderness, Wild and Scenic

Rivers, Research Natural Areas, Special Interest Areas, and Inventoried Roadless Areas

within the project area include dispersed camping, road and unauthorized off-highway

vehicle use, high stumps left from firewood cutting, and timber harvest.



Overall, livestock grazing within the project area is meeting national, regional, and Forest

Plan direction for Visual Quality, Recreation, Access, Wilderness, Wild and Scenic

Rivers, Research Natural Areas, Special Interest Areas, and Inventoried Roadless Areas,

with minor, site-specific impacts identified in Chapter 3.

With this alternative, livestock grazing would continue. Mitigation and monitoring

measures would be added but site-specific prescriptions designed to improve resource

conditions in key areas would not be implemented; therefore site-specific impacts would

continue. Conflicts between Forest visitors and livestock, although rarely reported, would

also continue with this alternative.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and

Plans: Existing conditions, trends, and effects identified in this DSEIS for other

resources (Wildlife, Fisheries, Hydrology, Soils, Vegetation, and Cultural Resources)

affect the desired primitive character and degree of naturalness of Wilderness, Wilderness

Study Areas, eligible Wild and Scenic Rivers, Research Natural Areas, Special Interest

Areas, and Inventoried Roadless Areas within the project area.


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Although current conditions within and adjacent to these specially designated areas meet

the intent of national, regional, and Forest direction for these designated areas, site-

specific impacts would likely continue and possibly increase in size, frequency and

severity with this alternative because new management prescriptions would not be

initiated.

Alternative A is therefore the least beneficial alternative of the three for Visual Quality,

Recreation, Access, Wilderness, Wild and Scenic Rivers, Research Natural Areas,

Special Interest Areas, and Inventoried Roadless Areas.



Under this alternative, conflicts between visitors and livestock, although rare, would

continue. Associated impacts to Visual Quality, Recreation, Access, Wilderness, Wild

and Scenic Rivers, Research Natural Areas, Special Interest Areas, and Inventoried

Roadless Areas would improve due to implementation of mitigations, monitoring actions,

and management prescriptions designed to improve vegetative conditions, ground cover,

fish and wildlife habitat, and hydrologic function, all of which affect the quality of the

recreation experience within the project area.


Plans: Existing conditions, trends, and effects identified in this DSEIS for other

resources (Wildlife, Fisheries, Hydrology, Soils, Vegetation, and Heritage Resources)

affect the desired primitive character and degree of naturalness of Wilderness, Wilderness


Areas, and Inventoried Roadless Areas within the project area.

Although overall conditions within and adjacent to these specially designated areas

currently meet the intent of national, regional, and Forest direction for these areas, site-

specific impacts in key areas would improve through implementation of mitigations,

monitoring actions, and management prescriptions in this alternative.

Alternative B is therefore more beneficial than Alternative A for Visual Quality,

Recreation, Access, Wilderness, Wild and Scenic Rivers, Research Natural Areas,

Special Interest Areas, and Inventoried Roadless Areas.



Under this alternative, livestock grazing would be phased out over the next five years for

the six allotments as current permits expire. Conflicts between visitors and livestock, and

livestock impacts to wildlife and fisheries habitat, hydrology, soils, vegetation, and


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heritage resources would improve when grazing permits expire. Livestock impacts to

Visual Quality, Recreation, Access, Wilderness, Wild and Scenic Rivers, Research

Natural Areas, Special Interest Areas, and Inventoried Roadless Areas would therefore

improve with this alternative.


Plans: Overall conditions within and adjacent to designated Wilderness, Wilderness


Areas, and Inventoried Roadless Areas currently meet the intent of national, regional, and

Forest direction for these designated areas. The desired primitive character and degree of

naturalness of Wilderness, Wilderness Study Areas, eligible Wild and Scenic Rivers,

Research Natural Areas, Special Interest Areas, and Inventoried Roadless Areas would

improve within the project area with this Alternative.

Of the three alternatives, Alternative C would have the most beneficial effects to Visual

Quality, Recreation, Access, Wilderness, Wild and Scenic Rivers, Research Natural

Areas, Special Interest Areas, and Inventoried Roadless Areas.

Hydrology Resources________________


Key Issue: Riparian and Aquatic Conditions

The concern is that livestock grazing may affect riparian and aquatic conditions. The

riparian and aquatic condition issue relates to maintaining the value and function of

riparian and aquatic habitats. Potential environmental effects of grazing, such as soil

compaction, the exposure of bare ground, and detrimental changes in riparian vegetation

should be considered for fish and aquatic organism health.

Issue Indicators

• Steambank alteration

• Wetland condition



Alternative A would continue current permitted grazing management practices (not actual

grazing practices as demonstrated by current permittees) which include annual

adjustments in numbers and seasons of use as needed.

Current conditions and trends would continue. Channel instability and channel widening

would continue on streams where this is currently occurring. Livestock impacts would

continue to occur in areas found to have higher amounts of stream bank alteration (e.g.,


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Lower Tosi Creek, South Fork Fish Creek), causing continued bank instability and

inhibiting channel and riparian recovery.

Compliance with Forest Plan and Other Direction: Current conditions and trends

would continue under this alternative.

• Stream bank Stability Guideline: Lower Tosi Creek, South Fork Fish Creek,

Raspberry Creek, Tepee Creek, and the lower section of Wagon Creek had more

unstable banks than what is prescribed under the Stream bank Stability Guideline.

• Livestock Grazing of Riparian Areas Standard: This standard is currently not

being met in all the areas listed under the Stream bank Stability Guideline.

• Water Development Standard: No new water developments would be proposed

under this alternative.

• State Water Right Standard: If existing water developments lack water rights,

those rights would be secured under this alternative. No additional rights would

be sought.

• Water Quality Standard: These allotments are currently meeting this standard.

• Watershed Restoration Standard: No restoration projects would be

implemented under this alternative.

The Memorandum of Understanding with the state of Wyoming would be met with

continued monitoring of best management practices and sharing of information with

Wyoming Department of Environmental Quality. Compliance with the Clean Water Act

is addressed via the Water Quality Standard. Executive Order 11990 would be met where

wetlands associated with streams are currently in good condition. Wetlands are in good

condition away from the stream banks, and where they were associated with stream

channels they were mainly altered along the waterline.



This alternative responds to the Bridger-Teton National Forest Plan goals for watershed

health, biodiversity and viability, social/economic contributions and objectives for

rangeland management. It provides for maintaining resource conditions where they are

currently meeting desired conditions as described in the plan, and moving the project area

resources toward desired conditions where they are not currently meeting the desired

conditions. This alternative implements updated grazing management including

benchmarks for desired conditions, continued and/or improved monitoring to determine if

benchmarks are being met, and adaptive management to ensure those sites which are

currently meeting Forest Plan desired conditions (e.g. ground cover, species composition,

soil disturbance, bank stability, fish habitat, and riparian grazing) continue to meet these

conditions while ensuring those sites currently not at desired conditions have at the very

least a stable if not an upward trend. This alternative includes monitoring which would be

used to make adjustments to livestock grazing as needed based on monitoring results.


224

The main differences between this alternative and Alternative A consist of the following:

• Utilization limits (upland and riparian areas) under Alternative B that are

generally more stringent than under Alternative A

• Use of current year bank alteration as an indicator of when to move cattle (along

with the forage utilization limits) under Alternative B

• Decrease the amount of time livestock spend in a pasture from season long to

only in June for the Roaring Fork South Pasture

• Change of grazing system from season long to deferred rotation for Badger

Creek Allotment and Beaver-Twin Creeks Allotment.

• Proposed range improvements within the Beaver-Twin Creeks Allotment. These

are two hardened stream crossing improvements within the North Beaver Creek

Pasture, fence reconstruction along Rock Creek Buttes within the Rock Creek

Pasture, and construction of a mile of drift fence in Twin Creeks Pasture.

• Proposed ditch maintenance standards within the Noble Pastures Allotment.

• Proposed range improvements within the Upper Green River Allotment. These

are one hardened stream crossing improvement and Wagon Creek exclosure

maintenance within the Mosquito SE Pasture, construction of a let-down fence

within the Upper Gypsum Pasture, and fence construction in the Kinky Creek

pasture.

• Critical Area Prescriptions. Critical areas within the analysis area are Waterdog

Lake, a small section of Rock Creek, Tosi Creek, and portions of the Roaring

Fork Allotment, the Elk Feedground, and the area around the Fish Creek Bridge,

Wagon Creek Exclosure, and Tepee Creek.

The changes from current management proposed under Alternative B would improve

cattle distribution and reduce allowable impacts on stream channels and riparian areas.

Herding would have to result in resources meeting prescribed vegetation and stream

channel conditions, or the Annual Operating Instructions would be changed.

Riparian areas that are currently showing impacts from grazing would improve in the

long term compared to Alternative A, but would not improve as much – or as quickly – as

under Alternative C due to continued livestock grazing impacts. Short-term stream bank

alteration would be reduced. Where stream bank alteration would be reduced, long-term

channel stability would improve. Continued cumulative impacts from dispersed

recreation and the road along Green River would impede recovery along that stream, so

benefits from the change in grazing strategy would be reduced in this area compared to

areas that do not experience these impacts.

Compliance with Forest Plan and Other Direction:

• Stream bank Stability Guideline: This guideline would be met over time, as

stream channels and riparian areas improved in condition.

• Livestock Grazing of Riparian Areas Standard: Measures listed under the

Livestock Grazing of Riparian Areas Standard, and in the Wyoming Grazing Best

Management Practices, would be used to improve stream bank conditions that are

not currently meeting standards.


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• Water Development Standard: No new water developments would be proposed

under this alternative.

• State Water Right Standard: If existing water developments lack water rights,

those rights would be secured under this alternative. No additional rights would

be sought.

• Water Quality Standard: These allotments are currently meeting this standard.

• Watershed Restoration Standard: No restoration projects would be

implemented under this alternative.

The Memorandum of Understanding with the state of Wyoming would be met with

continued monitoring of best management practices and sharing of information with

Wyoming Department of Environmental Quality. Compliance with the Clean Water Act

is addressed via the Water Quality Standard. Executive Order 11990 would be met where

wetlands associated with streams are currently in good condition. Wetlands are in good

condition away from the stream banks, and where they were associated with stream

channels they were mainly physically altered along the waterline.



Alternative C responds to concerns about the effects of grazing on vegetation, soil, and

native wildlife and fish habitats by discontinuing livestock grazing on the allotments. It

provides a comparison of the effects of authorizing grazing on all of the allotments with

the effects of not authorizing grazing. The Forest Service Handbook (FSH 2209.13. Ch.

10, 16.1) directs that a term grazing permit cannot be cancelled without a two-year

notification. The Responsible Official has discretion to implement a no grazing decision

phased over a longer but specified time frame.

Current conditions would be maintained or would continue to improve along all streams

and riparian areas where livestock grazing is the primary source of direct and indirect

impacts to these resources. Both short-term and long-term indicators would reflect these

conditions. Water quality would continue to meet water quality standards unless future

impacts occur due to future road projects or fuels treatments.

Compliance with Forest Plan and other Direction: All direction met under the

Alternative B (Proposed Action) scenario would also be met under this alternative.

Cumulative Effects Common to All Alternatives A number of fires have burned in the allotments over the past fifty years, affecting many

areas within these allotments. The most recent fire was the Salt Lick Fire, which burned

over 2,582 acres in 2007 and it was located within the South Gypsum Pasture in the

Upper Green Allotment. Fires that have burned within the analysis area are the Kinky

Fire (1991), Battle Mountain Fire (2006), North Gypsum Creek Fire (1961), South

Gypsum Creek Fire (1971) and the Jim Creek WFU Fire (2006). These fires burned a


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total of 6375.25 acres. Hydrologic changes would last approximately five years after the

burn with vegetative recovery, but changes in sediment loading and transport could

persist for a longer period of time. These hydrologic changes would also apply to any

fuels treatments that were applied in the project area or are proposed for the future. Also

with these treatments, new roads and increased use of current roads during fuels

treatments contribute to the production of sediment off these roads.

Impacts from roads would be the same under all alternatives. Sediment production from

roads and delivery to stream channels and riparian areas would continue at existing rates,

channels and floodplains would continue to be confined and altered by these facilities,

and water routing would be altered by roads and their drainage structures.

Impacts from trampling due to wildlife would continue. It is hard to determine the

amount of impact on channels due to these wild animals because of the difficulty in

determining the differences in hoof prints when monitoring stream bank trampling.

Wildlife impacts near the elk feedground as a result of feeding elk would continue but

water quality is meeting state standards, as confirmed in the hydrology specialist report

for the Long Term Special Use Authorization for Wyoming Game and Fish Commission

to Use National Forest System Land for their Winter Elk Management Programs EIS

(Simon 2008). There was little sign of impact by elk in the riparian area along the Green

River. Impacts (trailing, trampling) appeared to be from cattle, and overall stream

channel conditions were meeting Forest Plan direction.

Beaver activity, both past and ongoing activity, is a natural influence on almost all the

channels visited. Channel stability assessments and reported levels of fine materials in

channels are described, taking the effect of beavers into account.

Impacts from dispersed recreational use (unauthorized two track roads, bare camping

areas, etc.) would be the same under all alternatives. Dispersed camping and road impacts

would still continue to occur along the Green River within the Upper Green River

Allotment and also along South Fork Fish Creek.

There is no indication of water quality concerns related to grazing on any of the streams

in the allotments.

Wildlife Resources___________________


Key Issue: Effects on Threatened, Endangered, Proposed, and Sensitive Species, as well as Other Species of Concern

The concern is that livestock grazing may affect recovery of threatened, endangered,

proposed, and sensitive species, in addition to viability and habitat objectives for other

species in the project area. The Forest Plan provides direction for management indicator


227

species and ecological indicator species. Additional species conservation is directed by

laws, regulations, and policies.

Issue Indicators

• Condition of threatened and endangered species, management indicator

species/ecological indicator species and sensitive species habitat



Grizzly Bear - Threatened and Endangered Species: Determination: This

alternative may effect - likely to adversely affect the grizzly bear. There would be no

indirect or direct impacts to secure habitat, denning habitat or whitebark pine associated

with the activity because livestock grazing (reduction of herbaceous forage and presence

of livestock) typically does not impact these habitats. Livestock/grizzly bear conflicts are

likely to continue as a result of this alternative. Conflicts may result in the relocation of

problem bears inside or outside of the project area or result in direct mortality of

individuals, following the Interagency Nuisance Bear Guidelines (pages 51-70 of the

Interagency Grizzly Bear Guidelines, USFWS 1986). All Forest Plan amendment

guidelines and conservation measures identified in the Biological Opinion will be

adhered to under this alternative. Following all conservation measures and the Food

Storage Order will help to prevent human-grizzly bear conflicts, however,

livestock/grizzly bear conflicts would continue.

Canada Lynx and Critical Habitat - Threatened and Endangered Species:

Determination: This alternative may effect - not likely to adversely affect Canada

lynx or Canada lynx critical habitat. The direct effects associated with this action

include a slight potential for displacement of lynx from the presence of cattle or riders in

suitable habitat in the project area. By looking at known lynx locations within the project

area and consulting with WGFD nongame biologist Susan Patla, the Upper Green River

area has been used by lynx as a corridor between the Wyoming Range and Yellowstone

National Park. Individuals that were collared in the Wyoming Range went through this

area during ‘walkabouts’ to Yellowstone or to other areas in the Wind River Range.

Additionally, ongoing horizontal cover surveys that are being collected in mapped lynx

habitat within the project area have only documented snowshoe hare tracks within one

plot out of 56 that have been surveyed. So based on the low density of winter snowshoe

tracks recorded in the project area, and the assumption that lynx potentially using the

project area are using the area as a corridor to other more optimal habitats and are only

present for a short period of time, the likelihood of cattle or riders displacing lynx within

the project area is very minimal.

Direction in the Northern Rockies Lynx Management Direction for grazing activities in

lynx analysis units indicates that grazing should be compatible with improving or

maintaining lynx habitat. Grazing contributes to maintaining conditions that would have

occurred under historic disturbance regimes and in aspen stands and contributes to the

long-term health and stability of aspen. Utilization, stubble height, and stocking rates in


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this project are intended to maintain or improve upland range and riparian habitat.

Approximately 40 percent of the project area is not used by domestic livestock due to

distance from water, steep slopes, inaccessibility and/or insufficient amounts of forage

for cattle. These areas not typically used by cattle correspond with the optimal lynx

habitat within the project area because they are more heavily forested with down debris,

areas typically avoided by cattle. Continued grazing would not alter overall structure or

composition of native plant communities including shrub-steppe, riparian, and aspen

habitats or impact lynx habitat.

Gray Wolf – Experimental Population - Threatened and Endangered Species:

Determination: This alternative is not likely to jeopardize the continued existence of

the gray wolf. Livestock/wolf conflicts are likely to continue as a result of this activity.

Conflicts may result in direct mortality of individuals responsible for depredations. Since

pack social structure is very adaptable and resilient, breeding members can be quickly

replaced either from within or outside the pack and pups can be reared by another pack

member should their parents. Consequently, wolf populations can rapidly recover from

severe disruptions, such as very high levels of human-caused mortality or disease. After

severe declines, wolf populations can more than double in just 2 years if mortality is

reduced; increases of nearly 100 percent per year have been documented. Therefore, this

alternative will not likely jeopardize the continued existence of the species.

Sage-grouse – Candidate Species: Determination: This alternative may impact

individuals but is not likely to cause a trend toward federal listing or loss of

viability. While grazing management has limited effect on sagebrush, grazing does affect

the height and density of herbaceous material available for hiding cover and food for

sage-grouse using the suitable habitats within the project area (WGFD 2009a). Grazing,

as proposed under this alternative, may reduce herbaceous vegetation understory of the

sagebrush community (ibid). According to Grazing Influence, Management and

Objective Development in Wyoming’s Greater Sage-Grouse Habitat (WGFD 2009),

moderate utilization would maintain sites in preferred sage-grouse plant communities and

maintain cover for sage-grouse in nesting and early brood-rearing habitat. According to

monitoring data, utilization measurements on pastures in the Upper Green River

allotment have not exceeded 35 percent (the low end of moderate utilization) on any of

the upland monitoring sites measured in the last 10 years. Utilization (documented from

10 years of monitoring data for the project area) for the other allotments was also well

below the maximum allowable use, because stocking rates were considerably lower than

the use on the Upper Green River allotment, the highest stocking rates of any allotment in

the project area (see Chapter 2). This utilization however, is below the maximum

allowable utilization in this alternative. Utilization and AUM numbers prescribed in this

alternative are designed to maintain the appropriate ground cover percentage to ensure

proper functioning condition of the range type, but are above the moderate utilization

recommended for sage-grouse plant communities. Ground cover measurements collected

in the past 10 years for pastures within the Upper Green River allotment have not been

recorded below 88 percent, with 6 out of 11 monitoring sites recording 100 percent

ground cover. High ground cover reduces the risk of nonnative plants establishing in the

understory, which is a positive impact for sage-grouse plant communities.


229

The closest lek to the project area is the occupied Warren Bridge 2 lek, approximately 4

miles to the southwest of the Beaver-Twin allotment. In this area of Wyoming, about 75

percent of hens nest within 4 miles and about 66 percent nest within 3 miles of the lek

where they are bred. The majority of the allotments are farther than this distance from an

occupied lek, so the amount of hens using the project area for nesting and brood-rearing

is a minority of the breeding population of sage-grouse associated with that lek. The

sagebrush habitat within the allotments in the project area are known sage-grouse brood

rearing and nesting habitats (WYNDD 2009), however, lands associated with 75 percent

of sage-grouse nesting is on highly used neighboring BLM lands south of the project

area.

Even though grazing utilization has not exceeded 35 percent in a majority of the project

area over the last ten years, utilization, allowed in this alternative, is higher than

moderate, the level recommended to maintain sites in preferred sage-grouse plant

communities. When grazed at maximum utilization as allowed under this alternative,

there is a potential to impact sage-grouse that may use the project area for nesting and

brood rearing habitat by impacting the understory vegetation. However, the impacts

would be minor due to the low number of sage-grouse using the project area and the

absence of any leks.

Trumpeter Swan – Sensitive Species: Determination: This alternative may impact


viability. The direct and indirect impacts to trumpeter swans from current grazing

management may include: impacts to breeding habitats from the changes in the

composition and structure of riparian vegetation which may alter stream bank stability;

stream bank trampling from livestock that may also alter stream bank stability; pollution

of water sources from livestock waste and veterinary products; and disturbance from the

presence of cattle and riders (cattle herders) within the area.

Security and availability of food are the two most important factors that determine adult

and young survival. If a wetland does not produce enough food resources for trumpeters

(each adult eats 2 pounds dry weight and 10 pounds wet weight of aquatic vegetation a

day), young would develop very slowly and be vulnerable to predators, may die from

malnourishment or may not be strong enough to fly during migration (Patla and Lockman

2004). As allowed under this alternative, 55 percent utilization of riparian areas could

result in a 2-inch stubble height (Clary and Webster 1989) increasing the potential for

stream bank alteration, reducing ground cover and potential changes to the water table

(Clary and Leininger 2000), which could negatively impact nesting swans by altering

otherwise suitable nesting habitat.

According to Patla and Lockman (2004), optimum conditions for nesting swans include

8-15 acres of open water with at least 5 acres of shallow water. Altering the water table

due to impacts from cattle within a riparian area could negatively impact nesting habitat.

Survey results from monitoring the Upper Green River area in 2008 indicate that

extensive use by swans with one out of seven pairs nesting (WGFD 2009a). In 2009,

there were three territorial pairs of swans in the Upper Green River allotment. Of the

areas with documented swans, two were classified as occupied in 2008 and one of the


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two (Mosquito Lake) was classified as occupied in 2009. Riparian utilization measured in

this allotment in the past eight years at the measured key sites has not exceeded 55

percent, indicating that the current management provides for adequate vegetation

protection of trumpeter swan breeding habitat at the Mosquito Lake site. However, the

current conditions do not adequately represent the potential utilization under this

alternative. To graze riparian areas throughout the project area at 55 percent utilization,

as explained before, could negatively impact riparian areas, and therefore, potentially

impact wetlands and associated swan nesting habitat within the project area. Impacting

nesting swans in this farthest upstream section of the Green River would not likely cause

a trend towards listing or a loss of viability within the population. The habitat within the

project area is known to support nesting swans; however it is at very high elevation and is

often subjected to very late winter weather into nesting season that may be limiting the

productivity of the area for swans (pers. com. Patla 2009). The Green River population of

trumpeters that is identified in the project area has continued to increase annually

(USFWS 2009c) due to continued expansion in prime breeding habitats.

Columbia Spotted Frog – Sensitive Species: Determination: This alternative will

affect individuals or habitat with a consequence that the action may contribute to a

trend towards federal listing or cause a loss of viability to the population or species. The direct and indirect impacts to Columbia spotted frogs from current grazing

management may include: impacts to breeding habitats from changes in the composition

and structure of riparian vegetation, which may alter stream bank stability; stream bank

stability that may alter the structure of overwintering sites or alter the water table;

pollution of water sources from livestock waste and veterinary products; and direct

mortality from trampling. Some beneficial impacts may include an increase in food

sources due to eutrophication and the opening of basking areas.

According to Patla and Keinath (2005) and other references, livestock grazing can pose a

variety of problems for amphibians. However, applied research on this topic is scant and

documentations of impacts are primarily anecdotal. Livestock impacts to riparian areas

however, have been widely studied and are categorized as impacts to the stream bank

from the removal of vegetative protection and impacts from stream bank trampling (Clary

and Leininger 2000; Clary and Webster 1989). Even though there are no studies that

specifically address utilization levels and the impacts to amphibians, moderate utilization

of riparian areas has been shown to produce stubble heights that may approach a degree

of grazing stress that could result in a failure of the riparian area to recover (Clary and

Leininger 2000). This information however is difficult to interpret because each site is

unique in regards to its impacts from specific utilization rates and suitable habitat for

Columbia spotted frogs vary within the areas grazed. According to Clary and Leininger

(2000), taller forage heights indicate that cattle have spent less time in the area. This

lessens the chance of noticeable trailing and increases the stabilization of stream-banks.

Stream bank vegetation and stability affects the amount of stream bank alteration the

stream can repair annually (Platts 1991 in Cowley 2002). Streams able to repair

themselves from damage would continue to be suitable amphibian habitat and not be

impacted beyond repair. Therefore, measurements of bank stability that were collected in

2009 will be used to analyze the impacts on bank stability under Alternative A, and the

associated impacts to Columbia spotted frogs. Additionally, riparian stubble height


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information will also be used to summarize the potential indirect impacts to Columbia

spotted frogs under this alternative.

Columbia spotted frogs are known in three areas within the project area; however the

entire project area has not been surveyed. Therefore, all slow moving, low gradient

streams will be considered suitable breeding habitat and impacts to these areas will be

extrapolated from available monitoring data collected within the appropriate riparian

watersheds. Assumptions to impacts will be made, as no vegetation data was collected

specifically at known Columbia spotted frog locations.

The condition of streams documented with Multiple Indicator Monitoring transects in

2009 (as detailed in the Chapter 3), do not adequately address the effects of this

alternative (current management) on Columbia spotted frogs in the project area. Currently

a majority of the low gradient streams within the project area are in ‘good condition’

(hydrologist specialists report located in project record). However, some do not meet

stream bank stability guidelines (ibid). A majority of the streams in good condition have

not been exposed to 55 percent utilization (as allowed in this alternative), and are grazed

at a lower utilization due to low stocking rates.

If utilization reaches the 55 percent maximum in any riparian area suitable for Columbia

spotted frogs, stubble height measurements be only 2 inches (Clary and Webster 1989),

increasing the potential for stream bank alteration, reducing ground cover and causing

potential changes to the water table (Clary and Leininger 2000). These impacts to riparian

areas would potentially have negative impacts to Columbia spotted frogs and their

breeding, foraging and overwintering habitats. Due to variation of the stream banks and

cattle use, some areas may see greater impacts from grazing then other areas within the

project. Under this alternative, stubble heights and bank alteration could reach a level in

some areas that could potentially alter long-term bank stability and stream bank

vegetation, negatively impacting Columbia spotted frog breeding habitat and impacting

the population within the Upper Green River area.

Western Boreal Toad – Sensitive Species: Determination: This alternative will affect

individuals or habitat with a consequence that the action may contribute to a trend

towards federal listing or cause a loss of viability to the population or species. Impacts to the boreal toad would be similar to the effects to the Columbia spotted frog

(see Columbia spotted frog analysis), even though toads spend significantly more time in

terrestrial habitats. Even though the toad is more widespread throughout the project area

and the watersheds within the project area than the Columbia spotted frog, known

breeding sites are limited. Therefore, impacts to these breeding sites would be similar to

that of the Columbia spotted frog.

If utilization reaches the 55 percent maximum in any riparian area suitable for western

boreal toads, stubble height measurements may reach near 2 inches (Clary and Webster

1989), increasing the potential for stream bank alteration, reducing ground cover and

causing potential changes to the water table (Clary and Leininger 2000). These impacts to

riparian areas would potentially have negative impacts to toads and their breeding,

foraging and overwintering habitats. It is possible, due to variation of the stream banks


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and cattle use, that some areas may see more use from livestock then other areas within

the project. Under this alternative, stubble heights and bank alteration could reach a level

in some areas that would potentially alter long term bank stability and stream bank

vegetation, negatively impacting western boreal toad breeding habitat and impacting the

population within the Upper Green River area.

Elk – Management Indicator Species: The direct and indirect impacts to elk from

current grazing management stem from the impacts on available forage and the presence

of cattle in the allotments. Literature shows that grazing systems and grazing intensities

influence herbage production on western rangelands (Poollen and Lacey 1979). Under

this alternative, two allotments (Beaver-Twin and Badger Creek) and one pasture

(Roaring Fork) are managed under a season long grazing system. Season long grazing

allows grazing throughout the growing season every year, not permitting the vegetation a

period to recover from past grazing influences. It also does not allow seed maturity in the

key forage species, not permitting the plants to gain vigor and reproduce. The grazing

system in these allotments may cause an impact to the forage available to elk by

negatively impacting the vigor of the vegetation remaining after the grazing season and

not allowing the plant to regrow in the fall.

In allotments grazed under a season-long system, approximately 36,000 acres are mapped

as elk spring, summer, and fall range and roughly 25 percent of that is mapped as capable

cattle grazing lands. Approximately 400 acres of elk winter range is mapped in the south

east corners of the Beaver Twin and Badger allotments and 50 percent of that is mapped

as cattle capable lands. In the Roaring Fork allotment, 4,500 acres are mapped as crucial

winter/year long habitat and 67 percent of that is mapped as cattle capable land. This is

associated with the Green River Lakes Feedground and mapped elk parturition near the

feedground (Pinyon Ridge). Approximately 1,361 acres of elk parturition habitat that

overlaps with cattle capable and suitable lands are mapped in the Beaver-Twin and

Badger allotments. Reduction of forage in these areas may also negatively impact elk. A

majority of the elk that use the project area winter on feedgrounds, reducing the negative

impact that a reduction of available, good quality forage would have on the elk

population. Supplemental feeding maintains a higher number of elk then available winter

habitat would sustain (Smith 2001).

The other allotments in the project area either have a rest or deferred-rotation grazing

system, allowing the vegetation a period to recover from past grazing and in each pasture

rested, allowing seed maturity. Grazing in the beginning of the growing season has been

shown to improve elk forage, having beneficial impacts to elk. Properly timed grazing

(with the use of rest-rotation or deferred-rotation) has been shown to increase nutrients in

the aboveground parts of the plant, improving fall and winter forage for elk (Vavra 2005).

Research has also shown that grazed pastures provide high quality regrowth in fall and

winter and greater access to new green growth in the spring; although the quantity is

reduced. Rested pastures provide more current–year forage, but the growth lacked

nutritional quality equal to the grazed pastures (Vavra and Sheehy 1996). Of the 123,000

acres mapped as elk spring, summer or fall range, roughly 45 percent of this corresponds

with lands capable for cattle grazing. Higher forage quality resulting from rest or deferred

rotation grazing would positively impact elk. The majority of the elk wintering on this


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feedground are associated with the Green River herd unit, which is above population

objective (WGFD 2009).

In addition to impacts from the selected management system, the amount of utilization

and number of stock in the allotment has been shown to have a greater effect on herbage

production than the type of grazing system (Poolen and Lacey 1979).

Removing vegetation by grazing reduces the amount of forage available to elk in these

areas, even though studies have been shown that in the areas under a rest or deferred

rotation, the quality of forage can be increased (Vavra 2005). Utilization and AUM

numbers prescribed in this alternative are designed to maintain the appropriate ground

cover percentage to ensure proper functioning condition of the range type. Ground cover

measurements collected in the past 10 years for pastures within the Upper Green River

allotment have not been recorded below 88 percent, with 6 out of 11 monitoring sites

recording 100 percent ground cover. Even though the permitted utilization is defined as

high use, because of the relatively low stocking rates (especially in the Roaring Fork

allotment), utilization in the Upper Green River allotment has not been more than 35

percent in the last 10 years. Low utilization and low stocking rate has also been shown to

positively impact the elk use within the allotment that is grazed season-long. Slovlin et al.

(1968) in Clark 1994 reported that under light cattle use, elk use was greatest on

allotments with season-long grazing, because of the higher availability of ungrazed

plants.

Even though there is considerable forage overlap between cattle and elk, it varies during

different times of the summer, limiting the impact on elk forage. During early summer,

cattle diets consist of mostly grasses, while elk diets consist of a mix of grasses, shrubs

and forbs (Kie et. al. 2005). Because of this difference, some habitats available to elk in

the project area would not be impacted by cattle grazing (i.e. vegetation on steeper

slopes). Cook (2002) found that in winter and spring, elk preferably elected feeding sites

where cattle had grazed moderately during the previous summer, but in the fall, elk

selected sites where cattle use in the summer had been light.

Another impact to elk from Alternative A is the presence of cattle within the allotments.

Skovlin et al. (1968) reported in northeastern Oregon that elk use in pastures where cattle

were excluded was significantly higher than on pastures where both big game and cattle

were allowed to graze. Mackie (1970) in Clark 1994 noted that elk selected areas which

had not been used by cattle during the same forage year. Steep terrain and forested areas

were used in favor of open ridges and canyon bottoms where cattle normally grazed. This

research would point to displacement of elk by cattle under this alternative. However, on

the Medicine Bow National Forest, elk and cattle were considered ‘socially compatible’

based on numerous instances where cattle and elk were observed foraging in close

proximity of each other (Ward et al. 1973 in Clark 1994). So it appears that the impact to

elk from the presence of cattle within the allotments is unclear.

The impacts of this alternative to the elk herd units in the project area is minimal due to

the presence of the feedground within the project area which causes only a small number

of elk to use native winter ranges, the presence of high quality forage produced by


234

grazing, and the availability of forage for elk not accessed by cattle. Studies have shown

that grazing can positively impact forage available to elk, and the feedground maintains a

higher number of elk than the available native winter habitat would support. The herd

units using the project area are roughly at or above objective numbers, showing that

management under this alternative is not negatively impacting the elk population within

the project area or on the BTNF (USDA 2008).

Mule Deer – Management Indicator Species: The direct and indirect impacts to mule

deer from current grazing management stem from the impacts on available forage and the

presence of cattle in the allotments. These impacts are generally the same as would occur

for elk (see analysis above). The main differences between impacts to mule deer and

impacts to elk are: 1) mule deer use slightly different habitats than elk; 2) there is no

mule deer winter range within the project area; and 3) the presence of cattle in an area is

less of a deterrent to mule deer.

As described previously, cattle diets typically have more grasses while mule deer diets

have more shrubs and forbs, which minimize the potential for competition (Mackie 1970

in Clark 1994). Even though utilization rates have not averaged over 35 percent

throughout the Upper Green River allotment, the maximum utilization of 55 percent for

upland habitat must be analyzed. According to Habitat Guidelines for Mule Deer in the

Intermountain West (WAFWA 2009), heavy grazing, characterized by more than 50

percent utilization should be avoided and land managers should aim for utilization rates

of 30-40 percent in mountain sagebrush habitat types, similar to the project area.

According to those guidelines, grazing is considered sustainable in the ecoregion (in

relationship to mule deer) if stocking rates/utilization rates are at these suggested levels.

The utilization in this alternative is higher than recommended for mule deer, so negative

impacts to mule deer from the reduction in forage is possible. It is important to note that

research has shown (Skovlin et al. 1968), there was no significant difference in mule deer

use between pastures which were lightly stocked, moderately stocked or heavily stocked.

Also, under a rest-rotation system, mule deer selectively used pastures where cattle had

grazed previously that season (Yeo et al. 1993). This is similar to the impacts to

vegetation reported on elk mentioned above; grazed pastures provide high quality

regrowth in fall and winter and greater access to new green growth in the spring, although

the quantity of the forage is reduced (Vavra 2005).

The presence of cattle in the project area has been shown as an impact on mule deer

distribution; however, Skovlin et al. (1968) in Clark 1994 reported mule deer use in

pastures where cattle were excluded was not significantly different than in pastures where

big game and cattle were allowed access. Deer habitat selection was different in pastures

where cattle were present than in pastures where cattle were absent, showing

displacement effects on mule deer. This research indicates that even if mule deer use in

the pastures was not changed by the presence of cattle, how they use the habitat does

change. Therefore, this alternative may negatively impact mule deer by reducing high

quality forage otherwise available to mule deer.

Due to the presence of high quality forage produced by grazing, the availability of forage

for mule deer not accessed by cattle (higher slopes and shrubs and forbs not selected by


235

cattle), and the lack of winter range within the project area, the impacts of this alternative

to the Sublette mule deer herd is minimal. Utilization rates under this alternative are

higher than recommended for big sagebrush ecoregions, so there is a chance that if the

project is grazed at maximum utilization, spring, summer and fall forage for mule may be

impacted.

Moose – Management Indicator Species: The direct and indirect impacts to moose

from current grazing management stem from the impacts on availability and quality of

summer and winter forage. The two moose herd units that overlap the project area

(Jackson and Sublette) are currently below objective and have been for a number of years

(WGFD 2009). Research was initiated to try to understand why the Jackson moose herd

unit is well below objective and that research is currently ongoing. According to Becker

(2008), it is unclear what is currently limiting the Jackson moose herd population. His

research did show that the moose involved in the study were in moderate physical

condition but appeared to have deficiencies in several important nutrients. Having

deficiencies in important nutrients may make moose more susceptible to environmental

stressors that could result in increased mortality and decreased reproductive performance

(Becker 2008). Becker hypothesized that a combination of low quality forage, moderate

physical condition and environmental conditions (harsh winters) near the third trimester

of pregnancy combined with the deficiencies in several nutrients to create physiological

imbalances that compromised reproductive performance.

Approximately 80 percent of the mapped moose crucial winter/yearlong habitat within

the project area is mapped as lands capable and suitable for cattle grazing. The habitat is

associated with the Green River, located within the Upper Green River allotment. This

habitat is generalized as riparian and transition zones; however it does include some

upland coniferous and deciduous habitats. This corresponds to the habitat that Becker

showed moose in his study preferred. Moose selected winter habitats with a high

proportion of riparian/deciduous shrub vegetation, low elevation, high habitat diversity,

and near coniferous forests (Becker 2008). It was also shown that even though wintering

moose selected areas dominated by shrubs, they did not select homogeneous stands of

willows. Adult female moose selected areas of high habitat diversity, which suggests that

they require a variety of resources to meet their nutritional and energetic needs (Becker

2008). Becker’s research also indicated that forage availability was more important than

cover during the entire winter.

Since a variety of habitats and high forage quality are important to wintering moose

populations, the direct and indirect impacts from cattle grazing can vary based on the

type of habitat. Riparian vegetation, like early season upland grasses and unlike willows,

have larger amounts of protein available early in the growing season. As protein levels

decrease, cattle increase the amount of forbs and browse in their diets and move to the

riparian zone (Kolvachik and Elmore 1991 in Holland et. al 2005). There is little change

in the protein content in twigs of willows from early to late summer (Thilenius 1990 in

Holland et. al 2005).

Under this alternative, riparian habitats may have a maximum utilization of 55 percent.

At these utilization rates, mid-to-late season grazing indicates that cattle begin using the


236

current annual growth on the willows (Kolvachik and Elmore 1991 in Holland et. al

2005), which could reduce the amount of current willow growth available to wintering

moose. It is important to note that even though this alternative (current management)

allows a maximum utilization of 55 percent in the riparian areas, a majority of the

riparian stubble heights measured from 1998-2008 exceed 6 inches, which indicates

average utilization of 24-32 percent (Clary and Webster 1989). The impacts from cattle

grazing to willow are likely low if there is adequate herbaceous forage available to cattle

during the grazing season (Kauffman et al. 1983 in Holland et. al 2005). This historic low

utilization rate indicates that there is adequate herbaceous forage available in the riparian

zone for moose and other ungulates, and also implies that willow utilization (at low

utilization rates) is minor (ibid). The high snow fall in the project area also dictates the

available winter forage for moose that overlaps with cattle use. Areas previously grazed

by cattle may be covered by high snowfall, minimizing the impacts on wintering moose

forage.

In the research conducted by Becker, summer and winter ranges may be equally

important components of moose habitat. Moose selected summer habitats that were

moderate in elevation, close to cover and avoided lodgepole, mixed conifers and aspen.

Summer habitats appeared to be associated with habitat and landscape features that may

reduce the effects of thermal stress rather than a preferred vegetation type. Summer

provides moose with many forage choices, resulting in a high level of individual variation

in habitat selection patterns across the summer range. It is possible that moose use habitat

patches within different vegetation classes to take advantage of changes in quality of

forage throughout the summer, similar to other ungulates. Grazed pastures have been

shown to provide high quality regrowth in fall and winter and greater access to new green

growth in the spring, although the quantity of that forage is reduced. Since it appears

habitat selection is more associated with cover that reduces the effects of thermal stress

than a type of vegetation, forage reduction from grazing in this alternative is an impact

but is not likely contributing to a below objective herd population.

Pronghorn Antelope – Management Indicator Species: The direct and indirect impacts

of this alternative to pronghorn are similar to that of other ungulates addressed in this

report: impacts associated with the removal of forage quantity; and impacts to the quality

of forage (see elk and mule deer analyses). However, there is even less overlap with

habitat impacts and disturbance from presence of cattle within the allotments.

Pronghorn prefer forbs when succulent, nutritious forbs are available and only shift to a

greater diet of shrubs when forb availability declines (Yoakum et al. 1996; Yoakum and

O’Gara 2000). Grasses are least preferred. In shrub steppe environments throughout their

range, shrubs comprise an estimated average of about 63 percent of the pronghorn diet.

Forbs comprise an estimated average of about 29 percent, and grasses compromise an

estimated 7 percent. Since grasses are the primary component of forage used by cattle

during the majority of the grazing season, forbs make up a relatively small portion of

their diet. Since livestock typically do not make more than light use of shrubs, utilization

of shrubs by livestock currently is not diminishing habitat suitability for pronghorn.

According to the vegetation data collected in the Upper Green allotment, utilization for

the past 10 years has not exceeded 35 percent. However, this alternative permits a


237

maximum utilization of 65 percent, which is identified as unsustainable for mule deer in

this shrub-steppe ecosystem. Pronghorn, like mule deer, forage mainly on forbs and

shrubs, so impacts to these two ungulate species are similar. However, the spring,

summer and fall habitat for pronghorn that overlap with lands suitable and capable for

cattle grazing encompass less than 1 percent of the spring, summer and fall habitat of this

large herd unit. There is no pronghorn parturition areas mapped within the project area

However, parturition may occur within the project area. Impacts to this potential

parturition habitat are similar to impacts to the spring, summer and fall habitat, limiting

forage availability and impacting forage quantity. Limiting forage availability and

quantity during parturition may negatively impact the population by reducing fitness of

the offspring.

Limiting factors contributing to population fluctuations have been identified from

impacts to winter habitat and drought. There is no crucial winter habitat within the

project area, so there would be no direct or indirect impacts associated with these types of

habitat. The Sublette herd unit is well above population objective, despite the recent

drought, and has continued to rise (WGFD 2009). Barriers to pronghorn migration due to

development and fencing have also been addressed as limiting factors. All fences

associated with this alternative meet the WGFD standards for wildlife friendly fencing so

there are no negative impacts to pronghorn from the existing fences throughout the

project area.

In addition to the impacts to forage, the presence of cattle within the allotments may also

impact pronghorn that use the project area during the grazing season. The majority of the

pronghorn that use the project area are present during migration, which does not overlap

with the permitted grazing season.

Brewer’s Sparrow – Management Indicator Species: The direct and indirect impacts

to Brewer’s sparrows from current grazing management stem from the impacts on

availability of nesting habitat and cover, impacts to preferred food sources, i.e. insects

and seeds, and direct impacts from trampling and brown-headed cowbird parasitism.

Literature shows that grazing systems and grazing intensities influence herbage

production on western rangelands (Poollen and Lacey 1979). Under this alternative, two

allotments (Beaver-Twin and Badger Creek) and one pasture (Roaring Fork) are managed

under a season long grazing system. Season long grazing allows grazing throughout the

growing season every year, not permitting the vegetation a period to recover from past

grazing influences. It also does not allow seed maturity in the key forage species, not

permitting the plants to gain vigor and reproduce.

Approximately the entire project area mapped as capable and suitable cattle grazing lands

is suitable nesting habitat for Brewer’s sparrows in these areas managed for season long

grazing (see Affected Environment section). Season long grazing may negatively impact

the vigor of the vegetation remaining after the grazing season and does not allow the

plant to regrow in the fall. This may cause negative impacts to Brewer’s sparrows by

reducing the available cover for the species to nest build and potentially reducing the

amount of seeds and insects available for forage by reducing the herbaceous vegetation.


238

Utilization in the Roaring Fork allotment is typically not measured due to low stocking

rates and a voluntary deferred rotation system by the permittees (pers. comm. C.

Hayward). Utilization in the Beaver-Twin and Badger Creek allotments is also not

physically measured because stocking rates are very low and landscape appearance

utilization estimates have not exceeded 45 percent (pers. comm. C. Hayward).

The other allotments in the project area either have a rest or deferred-rotation grazing

system, allowing the vegetation a period to recover from past grazing and in each pasture

rested, allowing seed maturity. Research has also shown that pastures with a rest or

deferred rotation grazing system provide high quality regrowth in fall and winter and

greater access to new green growth in the spring, although the quantity is reduced. Rested

pastures also provide more current–year forage (Vavra and Sheehy 1996). Rested

pastures therefore provide more current year vegetation available for Brewer’s Sparrow

nests and associated seeds and insects for foraging.

Average ground cover within the Upper Green River allotment from 1997-2008 was 98

percent, with the lowest ground cover recorded at 88 percent. According to O’Brien et al.

2003, the minimum ground cover for proper functioning sustainable watersheds for

mountain big sagebrush is 85 percent. No pasture within the Upper Green River allotment

has been below this threshold in the last 10 years of surveying. This threshold was

developed to represent a point at which the site would lose basic functionality defined by

increased soil erosion and loss of site sustainability, which would have indirect impacts to

Brewer’s sparrow by impacting habitat within the allotment. The soil base needs

adequate ground cover for protection from erosion, rain and use (O’Brien et al. 2003).

High ground cover percentages measured within the allotment show that under the

current management system, average utilization has been low and ground cover is very

high, providing a stable and sustainable soil base and available nesting habitat, cover and

forage opportunities for Brewer’s sparrows. Under higher utilization, ground cover could

be less, and impacts to the understory would be greater, thus negatively impacting

foraging Brewer’s sparrows by reducing seeds and insects. With increased pressure from

grazing on the understory vegetation, the balance of species in the area could be tipped

toward less palatable species such as sagebrush, creating dense sagebrush stands (Holmes

and Johnson 2005). It’s not clear that this situation would be detrimental to sage-

dependant species (ibid).

According to the Region 2 Conservation Assessment of the Brewer’s sparrow (Holmes

and Johnson 2005), as cattle graze, they select grasses and forbs and avoid browsing on

sagebrush. Since utilization is low and ground cover near 100 percent, current impacts

from grazing on available sagebrush nesting habitat is minimal. Heavier utilization from

grazing, allowable under this alternative, would result in the removal of more herbaceous

understory plants, potentially allowing sagebrush to spread and create dense sagebrush

stands with minimal understory. But as mentioned previously, the literature is not clear

on whether this would be detrimental to sagebrush species, such as the Brewer’s sparrow.

Another impact to Brewer’s sparrows would be direct impacts from trampling. Livestock

trample and disturb nests, resulting in nest failure and the presence of livestock can

increase the abundance of brown-headed cowbirds (nest parasites), potentially impacting


239

Brewer’s sparrow productivity (Holmes and Johnson 2005). In summary, there may be

some negative impacts to Brewer’s sparrows under this alternative, however, population

trends in Northwest Wyoming have been increasing and the impacts associated with this

alternative are not the limiting factors identified as detrimental to Brewer’s sparrow

populations throughout the state (habitat loss).

Boreal Chorus Frog – Management Indicator Species: Impacts to boreal chorus frogs

would be similar to the effects to the Columbia spotted frog (see Columbia spotted frog

analysis). However, the boreal chorus frog is more widespread throughout the project

area and the watersheds within the project area, minimizing the impacts of this alternative

on the population at the forest level.

Aspen - Management Indicator Species: Livestock grazing use and management under

Alternative A would adversely affect individual aspen trees, suckers/saplings, and small

parts of stands. Direct effects include grazing and trampling of understory vegetation and

very light browsing on suckers and saplings. An indirect effect would be that grazing and

trampling in aspen stands would reduce fine fuels and ladder fuels, reducing the potential

for the stand to regenerate through planned or unplanned fire ignitions. There also would

be the potential for opportunities for planned fire use to be forgone due to complications

with an allotment in active status.

Migratory Birds: The impacts to migratory birds from this alternative would be similar

to that of Brewer’s sparrows. Impacts would be from a reduction in herbaceous

understory plants, negatively impacting birds by reducing seeds and insects. Impacts

would also be associated with a reduction in cover for nest building. Riparian associated

species would see minimal impacts, because the stubble heights under this alternative

would prevent further negative impacts to riparian corridors. Trampling effects, as

discussed in the Brewer’s sparrow section, would also impact migratory birds that nest on

the ground.

Cumulative Effects

Grizzly Bear - Threatened and Endangered Species: With the implementation of the

Conservation Strategy, the 1993 Recovery Plan was updated with the 2007 Demographic

Recovery Criteria because the 1993 version was no longer considered the best technique

to assess recovery of the Yellowstone grizzly bear populations. The end result was

revised methods for calculating population size, estimating the known to unknown

mortality ratio and estimating sustainable mortality levels for the Yellowstone grizzly

population based on best available science (72 FR 11376; 72 FR 11376-11377). The

allowable mortality limits for each bear class are calculated annually based on total

population estimates for the current year. The Interagency Grizzly Bear Study Team

(IGBST) calculates both the total population size and the mortality limits within an area

designated by the Conservation Strategy that overlaps and extends beyond suitable

habitat, which includes the project area.

Based on this information, grizzly bear mortalities associated with this alternative will

be incorporated into the allowable mortality threshold for the Yellowstone grizzly

population. These mortalities are monitored and calculated by the IGBST and


240

maintaining these thresholds should allow a stable to increasing population 95 percent of

the time and not hinder the recovery of the species.

Communication with the WGFD implementing the nuisance bear guidelines and

responding to grizzly bear/livestock conflicts is crucial to ensure compliance with the

allowable mortality thresholds throughout the Greater Yellowstone Area. Strict

compliance with all conservation measures and food storage requirements would also

help minimize potential conflicts. Annual meetings between the Forest Service, WGFD,

USFWS and permittees are required to discuss the effectiveness of the conservation

measures. Additionally, if new information reveals effects which may impact grizzly

bears or their habitat in a manner or to an extent not considered in this assessment or the

action is subsequently modified in a manner that causes an effect which was not

considered in this assessment, the Forest Service will immediately reinitiate formal

consultation.

Therefore, based on the implementation of the guidance in the Conservation Strategy

(complete with all monitoring and reporting guidelines), compliance with the grizzly

bear Forest Plan Amendment and implementation of the conservation measures detailed

in the project description; the cumulative effects of this action would have negative

impact to the species but would not impact the recovery of the Yellowstone grizzly

bear population and not have negative cumulative impacts on the population.

Canada Lynx and Critical Habitat – Threatened and Endangered Species: The

cumulative effects analysis is based upon the standards and guidelines outlined in the

Northern Rockies Lynx Management Direction (USDA 2007). As mentioned previously,

this document provides guidelines for livestock management in lynx habitat and this

alternative is in compliance with that direction. Therefore, based on this guidance,

Alternative A would not have negative cumulative effects to Canada lynx or Canada

lynx critical habitat.

Gray Wolf – Experimental Population – Threatened and Endangered Species: The

cumulative effects analysis area is the NRM population boundary, the area within which

the USFWS (combined with state management plans) manages this distinct population

segment. The entire NRM wolf population increased in 2009 and was estimated at 1,706

wolves in 242 wolf packs and 115 breeding pairs. This is up from 2008 estimates. In

response to the 214 cattle, 721 sheep, 24 dogs, and 7 other livestock (4 llamas and 4

goats) depredations that occurred in 2009 throughout the NRM, 272 wolves were lethally

removed. This was 12 percent of the calculated minimum population estimate of the

NRM population (an estimated 1,706 wolves living on December 31 plus all known wolf

mortality - 272 by agency control, 206 by hunting, and 108 by all other known causes).

Based on the documented annual increase in the wolf population throughout the NRM

since 2002 and the related increase in the Wyoming wolf population despite numerous

management removals due to livestock depredations, this alternative would not have

negative cumulative effects to the NRM distinct population segment of gray wolves.


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Sage-Grouse – Candidate Species: The cumulative effects analysis area for sage-grouse

is the Wyoming Basin Management Zone. Currently within the state there are numerous

cumulative actions that are contributing to the decline of the greater sage-grouse

(Connelly et al. 2000). These mainly stem around impacts to ‘Core’ sage-grouse habitats.

This project is not within ‘Core’ sage-grouse habitat; there are no leks within 4 miles of

the project area. Habitat in the project area is marginal due to elevation and weather, and

the project area is a minimal percentage of the 42,000 square mile Wyoming Basin

Management Zone. Based on this information, a major limiting factor to sage-grouse is

from loss or modification of sagebrush habitats. The Forest Service only manages 4

percent of the available habitat in this management zone. The minimal indirect impacts to

sage-grouse associated with this Alternative A may add minor cumulative effects to

sage-grouse but would not further impact the population viability of the species.

Trumpeter Swan – Sensitive Species: The cumulative effects analysis area for

trumpeter swans is the Green River Basin. Currently, this population segment is

increasing and expanding throughout the basin (USFWS 2009c). Since the habitat within

the project area is marginal due to high elevation and late freeze events and low water,

the indirect and direct impacts to trumpeter swans associated with this alternative would

not add substantial cumulative effects to the Green River trumpeter swan

population that would further impact the population viability of the species.

Columbia Spotted Frog – Sensitive Species: The cumulative effects analysis area for

this species is the associated 5th level watersheds within the project area (see fisheries

report for details on these watersheds). Currently, within these watersheds there are few

documented breeding locations and these locations are relatively isolated from each

other, limiting dispersal. According to the fisheries specialist report, the watersheds were

impacted within the project area (tie-hacking) and this alternative would add to this

current state of the watershed. The breeding habitat in the project area may be negatively

impacted by similar past, present and future foreseeable actions within the watersheds,

similar to the impacts to the fishery. Without proper monitoring that would trigger site

specific adaptive management, the indirect and direct impacts to Columbia spotted frogs

from this alternative, when added to past, present and future actions within the watershed

could add cumulative effects to this frog population that would further impact the

population viability of the species in the area.

Western Boreal Toad – Sensitive Species: The cumulative effects analysis area for this

species is the associated watersheds within the project area. Currently, within these

watersheds there are few documented breeding locations. The habitat in the project area

is documented as breeding habitat and other issues that may be negatively impacting the

watershed could be adding cumulative effects to this species. According to the fisheries

specialist report, the watersheds are currently degraded within the project area from past

actions and this alternative could add to this currently degraded state. Without proper

monitoring that would trigger site specific adaptive management, the indirect and direct

impacts to boreal toads from this alternative, when added to past, present and future

actions within the watershed could add cumulative effects to this toad population that

would further impact the population viability of the species in the area.


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Elk and Pronghorn - Management Indicator Species: The cumulative effects analysis

area for these species is the associated herd unit boundaries for the herds that overlap the

project area (see Affected Environment). There are multiple past, present and future

foreseeable actions within these analysis areas that would impact foraging, wintering and

parturition habitat for these species, similar to this alternative. These actions are federal

and private vegetation treatments (timber sales, prescribed fires) and natural activities

(wildfires, beetle kill, drought). Other activities that would impact these species include

impacts from recreation, such as roads, hunting pressure, and OHV use. When the

impacts of this alternative is added to these past, present and future activities that impact

forested vegetation or cause disturbance/displacement due to human presence there may

be minor cumulative effects on these herd units but would not further impact the elk

and pronghorn populations. These effects are assumed to be minor, because these herds

are above management objectives designated by the WGFD. Also, impacts to winter

range is often identified as the limiting factor for these species, and this alternative does

not impact this habitat (pronghorn) or the impact is mitigated by the state due to a higher

population objective than can be naturally supported by the available winter range (elk

feedgrounds).

Moose and Mule Deer - Management Indicator Species: The cumulative effects

analysis area for these species is the associated herd unit boundaries for the herds that

overlap the project area (see Affected Environment). There are multiple past, present and

future foreseeable actions within these analysis areas that would impact foraging,

wintering and parturition habitat for these species, similar to this alternative. These

actions are federal and private vegetation treatments (timber sales, prescribed fires) and

natural activities (wildfires, beetle kill, drought). Other activities that would impact these

species include impacts from recreation, such as roads, hunting pressure, and OHV use.

When the impacts of this alternative are added to these past, present and future activities

that impact forested vegetation or cause disturbance/displacement due to human

presence, there may be minor cumulative effects on these herd units but would not

further impact the population of the species. These effects are assumed to be minor,

because impacts to winter range is often identified as the limiting factor for these species,

and this alternative does not substantially impact these habitats. Also, another impact to

mule deer is the spatial separation of mule deer and elk. It is possible that elk populations

over objective may be contributing to the lower numbers of mule deer throughout the

herd unit due to displacement, minimizing the impacts from a reduction in forage in this

alternative.

Brewer’s Sparrow - Management Indicator Species and Migratory Birds: The

cumulative effects analysis area for Brewer’s sparrows and migratory birds is Wyoming,

the unit that the Rocky Mountain Bird Observatory monitors for state populations of

birds. Currently within the state there are numerous actions that are contributing to the

decline of many migratory bird species; these mainly stem from the reduction/removal of

habitat. The impacts to these species associated with this alternative may add minor

cumulative effects but due to the small scale of the project and the minor negative

effects to the habitat, the action would not further impact the population viability of

the species within the project area.


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Boreal Chorus Frog - Management Indicator Species: The cumulative effects analysis

area for this species is the associated watersheds within the project area. Currently, within

these watersheds there are few documented breeding locations. The habitat in the project

area is documented as breeding habitat and other issues that may be negatively impacting

the watershed could be adding cumulative effects to this species. According to the

fisheries specialist report, the watersheds are currently degraded within the project area

from past actions and this alternative could add to this currently degraded state. Without

proper monitoring that would trigger site specific adaptive management, the indirect and

direct impacts to boreal chorus frogs from this alternative, when added to past, present

and future actions within the watershed could add cumulative effects to this frog

population that would further impact the population viability of the species in the

area.

Aspen - Management Indicator Species: The cumulative effects analysis area for aspen

is the associated watersheds within the project area. Insufficient frequency and extent of

fire is the most influential factor that has diminished ecological conditions in aspen.

Historic livestock grazing in the associated watersheds has contributed to the increased

fire-return interval on rangelands by reducing the biomass of herbaceous vegetation (fine

fuels) annually produced on rangelands and in aspen stands. Reduced fire spread on

rangelands has reduced fire spread to adjacent aspen stands.

Other impacts to aspen include invasive plant species, unauthorized motor vehicle use,

elevated browsing rates by elk due to sustained high population levels, browsing and

trampling by livestock, and climate change. Trends in climate change indicate that future

precipitation levels will be lower than the current long-term average. Drier conditions

would inhibit aspen stand health and regeneration.

Several factors have offset the downward trend in aspen communities by a small extent

by encouraging aspen regeneration, including unplanned fires, planned fires, mechanical

treatments, and insect infestations that are killing conifer trees. Drier conditions due to

climate change would also benefit some aspen stands in that drier forest conditions would

increase the potential for greater fire spread. Drier conditions would also increase

susceptibility of conifer trees to insect outbreaks, which would also benefit aspen.

The damage to individual trees and the inhibitions to aspen regeneration created by

livestock grazing is a very minor contribution to the health or decline of aspen stands.

When considered in relation to past, present, and reasonably foreseeable actions that

affect aspen within the cumulative effects area and those that offset those effects, no

cumulative effects are expected as the result of livestock grazing in aspen stands as

described in Alternative A.


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Threatened and Endangered Species: Direct and indirect effects to grizzly bears, gray

wolves, Canada lynx or Canada lynx critical habitat under this alternative are similar to

Alternative A. Determinations are also the same as detailed in Alternative A.

Sage-grouse - Candidate Species: Determination: This alternative may impact

individuals but is not likely to cause a trend to federal listing or loss of viability.

Under this alternative, maximum utilization would be 50 percent in upland habitats, and

all allotments would be in a deferred or rest rotation system, reducing impacts to

herbaceous material used by sage-grouse. Similar to effects described in Alternative A,

grazing affects the height and density of herbaceous material available for hiding cover

and food for sage-grouse using suitable habitats within the project area (WGFD 2009).

Grazing, as proposed under this alternative, may reduce herbaceous vegetation understory

of the sagebrush community (ibid). According to Grazing Influence, Management and

Objective Development in Wyoming’s Greater Sage-Grouse Habitat (WGFD 2009),

moderate utilization would maintain sites in preferred sage-grouse plant communities and

maintain cover for sage-grouse in nesting and early brood-rearing habitat.

Since there are no documented leks within the project area and the closest lek is

approximately 4 miles to the southwest of the Beaver-Twin allotment, it is unlikely that

sage-grouse make high use of the project area. In this area of Wyoming, about 75 percent

of hens nest within 4 miles and about 66 percent nest within 3 miles of the lek where they

are bred. The majority of the allotments are farther than this distance from an occupied

lek, so the amount of hens using the project area for nesting and brood-rearing is a small

part of the breeding population.

The allotments in the project area are known sage-grouse brood rearing and nesting

habitat (WYNDD 2009); however, lands associated with 75 percent of sage-grouse

nesting is on highly used neighboring BLM lands south of the project area. Therefore,

grazing utilization as proposed in this alternative is at the moderate level recommended to

maintain sites in preferred sage-grouse plant communities. This alternative would not

negatively impact these plant communities and sage-grouse using the project area.

The range improvements associated with this alternative may have beneficial impacts to

sage-grouse by improving dispersal of cattle (additional fences) and implementing

rotational grazing systems. Improving dispersal of cattle and implementing rotational

grazing systems has been shown to reduce impacts to forage, therefore reducing the

impacts to potential sage-grouse nesting and brood-rearing habitat throughout the project

area. There is a potential for sage-grouse collisions with additional fencing, but with the

low sage-grouse use within the project area, this impact would be minor and discountable

to the status of the species.


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Trumpeter Swan - Sensitive Species: Determination: This alternative may impact


viability. The direct and indirect impacts to trumpeter swans from this alternative may

include: impacts to breeding habitats from the changes in the composition and structure

of riparian vegetation which may alter stream bank stability; trampling may also alter

stream bank stability; pollution of water sources from livestock waste and veterinary

products; and disturbance from the presence of cattle and riders (cattle herders) within the

area.

The crucial difference in this alternative from Alternative A is the increase in stubble

height requirements in riparian key areas and some critical areas, and the adaptive

management criteria that are applied if objectives are not being met (see alternative

comparison table and adaptive management). Riparian habitats in key areas and in critical

areas under this alternative would have more stringent stubble heights and lower

utilization than under Alternative A, thus reducing the impacts to riparian areas and

trumpeter swan breeding areas. The stubble heights for most key areas (the most

palatable location within the allotments) are 4 to 6 inches with some critical areas having

stringent stream bank stability requirements. Elmore (1988) in Clary and Leininger

(2000) suggested that 3 to 4 inch stubble heights would provide stream bank protection

and aid deposition of sediment. Stubble heights of 6 inches or more sometimes may be

required to protect ecosystem function (Meyers 1989 in Clary and Leininger 2000).

Reducing grazing use and thereby increasing stream bank stability would reduce the

negative impacts associated with cattle grazing on suitable trumpeter swan nesting

habitat.

Impacting nesting swans in this farthest upstream section of the Green River would not

likely cause any trend towards listing or a loss of viability within the population. The

habitat within the project area is known to support nesting swans; however, it is at very

high elevation and is often subjected to very late winter weather into nesting season that

may be limiting the productivity of swans in the area (pers. com. Patla 2009). The Green

River population of trumpeters that is identified in the project area has continued to

increase annually (USFWS 2009c) due to continued expansion in prime breeding

habitats.

The range improvements associated with this alternative would have no impacts on

trumpeter swans because the locations of the stream bank stabilizing improvements are

not near suitable nesting/breeding habitat.

Columbia Spotted Frog – Sensitive Species: Determination: This alternative may

impact individuals but is not likely to cause a trend toward federal listing or loss of

viability. The vital differences between this alternative and Alternative A are:

• the increase stubble height requirements in riparian key areas and some

critical areas

• reduced utilization in upland key sites

• change from pastures using a season long grazing system to a deferred or rest

rotation


246

• and adaptive management criteria applied when objectives are not being met

(see alternative comparison table and adaptive management).

The direct and indirect impacts to Columbia spotted frogs from this alternative may

include: impacts to breeding habitats from the changes in the composition and structure

of riparian vegetation which may alter stream bank stability; stream bank alteration that

may change the structure of overwintering sites or alter the water table; pollution of water

sources from livestock waste and veterinary products; and direct mortality from

trampling. However, impacts would be reduced, when compared to Alternative A, due to

increased stubble heights, stability requirements and adaptive management techniques if

riparian areas are below objective. Some beneficial impacts may include an increase in

food sources due to eutrophication and the opening of basking areas.

Even though there are no studies that specifically address utilization levels and the

impacts to amphibians, moderate utilization of riparian areas has been shown to produce

stubble heights that may cause a degree of grazing stress that could result in a failure of

the riparian area to recover (Clary and Leininger 2000). This information however is

difficult to interpret because each site is unique in regards to its impacts from specific

utilization rates, and suitable habitat for Columbia spotted frogs vary within the areas

grazed. According to Clary and Leininger (2000), taller forage heights indicate that cattle

have spent less time in the area, thereby lessening the chance of noticeable trailing and

increasing the stabilization of stream banks. Stream bank vegetation and stability affects

the amount of stream bank alteration the stream can repair annually (Platts 1991 in

Cowley 2002). Streams able to repair themselves from damage would continue to be

suitable amphibian habitat and not be impacted beyond repair.

Currently a majority of the low gradient streams within the project area are in ‘good

condition’ (Clark 2010); however some do not meet stream bank stability guidelines

(ibid). Mitigation in this alternative would prevent monitored areas from exceeding

stability guidelines and enforce stubble heights that, according to Elmore (1988) and

Meyers (1989) would protect or enhance stream bank stability and protect ecosystem

function (Clary and Leininger (2000).

Monitoring requirements would be implemented in this alternative, to observe known

Columbia spotted frog breeding areas and accurately measure impacts from the

alternative. If additional mitigation is required to protect these breeding areas (i.e. fencing

of certain known breeding sites), monitoring of the amphibian breeding activity would

identify the need and allow for site specific mitigation.

The stream bank stabilizing range improvements associated with this alternative may

have beneficial impacts to Columbia spotted frogs because the improvements would

reduce impacts from stream bank trampling. All range improvements would be

implemented after the frog breeding season, therefore reducing the potential for direct

impacts to frogs in the areas identified.


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Elk - Management Indicator Species: The vital differences between this alternative and

Alternative A is the same as in Columbia spotted frogs above. All of these differences

reduce potential direct and indirect impacts of this alternative on elk.


elk by improving dispersal of cattle (additional fences) and implementing rotational

grazing systems. Improving dispersal of cattle and implementing rotational grazing

systems has been shown to reduce impacts to forage, therefore reducing the impacts to

forage available to elk. Additional fences in Kinky Creek allotment could impact elk by

creating a new barrier to movement. An electric fence would be erected for the first two

years, to determine the most appropriate location of the fence for cattle and wildlife,

reducing potential impacts to elk. Fencing the elk feedground would also impact elk.

Cattle would not be able to graze on the feedground, increasing the amount of forage

available for wintering elk. However, this may displace cattle into elk transition range,

reducing quantity of forage in these areas. Grazing can improve fall and winter forage

quality for elk (Vavra 2005), so impacts to forage from this alternative outside the

feedground would likely be minimal.

Mule Deer – Management Indicator Species: The vital differences between this

alternative and Alternative A is the same for mule deer as it is for elk (see Columbia

spotted frog above). The direct and indirect impacts to mule deer from this alternative are

similar to what would occur for elk. The main differences between impacts to mule deer

and impacts to elk are: 1) mule deer use slightly different habitats than elk; 2) there is no

mule deer winter range within the project area; and 3) the presence of cattle is even less

of an impact on the presence of mule deer within an area.

The impacts of this alternative on the Sublette mule deer herd is minimal because of the

presence of high quality forage produced by grazing, the availability of forage for mule

deer not accessed by cattle (higher slopes and shrubs and forbs not selected by cattle),

and the lack of winter range within the project area. Studies have shown that grazing can

positively impact forage quality, and winter range crucial to mule deer overwinter

survival is not impacted by the project. Utilization rates in this alternative are higher than

recommended for big sagebrush ecoregions; so there is a chance that if the project is

grazed at a high level, spring, summer and fall forage for mule may be impacted, but

not to a level that would negatively impact the population at the forest level.


mule deer by improving dispersal of cattle (additional fences) and implementing

rotational grazing systems when compared to Alternative A. Improving dispersal of cattle

and implementing rotational grazing systems has been shown to reduce impacts to forage,

therefore reducing the impacts to forage available to mule deer throughout the project

area. Additional fences in Kinky Creek allotment could impact mule deer by creating a

new barrier to movement. An electric fence would be erected for the first two years, to

determine the most appropriate location of the fence for cattle and wildlife, reducing

potential impacts. The new fence would be installed following WGFD ‘Wildlife Friendly

Fencing Guidelines.”


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Moose – Management Indicator Species: The vital differences between this alternative

and Alternative A is the same for moose as it is for elk (above). All of these differences

reduce potential direct and indirect impacts of this alternative on moose.


have beneficial impacts to moose because the improvements would reduce impacts from

stream bank trampling and reduce impacts to streamside vegetation, an important

component of this species’ diet.

Pronghorn – Management Indicator Species: The vital differences between this

alternative and Alternative A is the same for pronghorn as it is for elk (above). The direct

and indirect impacts of this alternative to pronghorn are similar to that of other ungulates

addressed in this report. However, there is even less overlap in habitat and possibility of

disturbance from presence of cattle within the allotments; thus there would be less

negative direct and indirect impacts to this species.


pronghorn by improving dispersal of cattle (additional fences) and implementing

rotational grazing systems when compared to Alternative A. Improving dispersal of cattle

and implementing rotational grazing systems has been shown to reduce impacts to forage,

therefore reducing the impacts to forage available to pronghorn throughout the project

area. Additional fences in Kinky Creek allotment could impact pronghorn by creating a

new barrier to movement. An electric fence would be erected for the first two years, to

determine the most appropriate location of the fence for cattle and wildlife, reducing

potential impacts. The new fence would be installed following WGFD ‘Wildlife Friendly

Fencing Guidelines” which would reduce the negative impacts associated with fencing.

Brewer’s Sparrow – Management Indicator Species and Migratory Birds: The vital

difference between this alternative and Alternative A in relationship to impacts to

Brewer’s sparrow and other migratory birds is the reduced utilization in upland key sites,

the change from a season long to a deferred or rest rotation grazing system in three

allotments, and the requirement that an adaptive management approach be implemented

if objectives are not being met (see alternative comparison table and adaptive

management).

Reduced utilization and the elimination of season-long grazing would reduce impacts to

Brewer’s sparrow and migratory birds when compared to Alternative A. With lower

utilization rates and higher stubble heights, impacts from grazing to identified Brewer’s

sparrow habitat would likely be reduced.

Installing fences to allow conversion of allotments grazed for season-long grazing to a

rest-rotation may have beneficial impacts to Brewer’s sparrow and other migratory birds.

A rest rotation system allows the vegetation a period to recover from past grazing and in

each pasture rested, allowing seed maturity. Research has also shown that pastures with a

rest or deferred rotation grazing system provide high quality regrowth in fall and winter

and greater access to new green growth in the spring, although the quantity is reduced.

Rested pastures also provide more current year vegetation available for nests and


249

associated seeds and insects for foraging (Vavra and Sheehy 1996 in Vavra 2005).

Other range improvements would have no impact on Brewer’s sparrows or other

migratory birds because they do not impact their preferred habitat. Range improvements

would be implemented outside of the nesting season, to reduce the potential for direct

impacts to Brewer’s sparrows or migratory birds.

Western Boreal Toad - Sensitive Species and Boreal Chorus Frog – Management

Indicator Species: Western Boreal Toad - Determination: This alternative may

impact individuals but is not likely to cause a trend to federal listing or loss of

viability.

The crucial differences between this alternative and Alternative A is the same as for the

Columbia spotted frog above. Riparian habitats in key areas and in critical areas under

this alternative would have more stringent stubble heights requirements and lower

utilization than under Alternative A, reducing the impacts to riparian areas and western

boreal toad and boreal chorus frog breeding areas. The stubble heights for most key areas

(the most palatable location within the allotments) are 4 to 6 inches with some critical

areas having stringent stream bank stability requirements. According to Clary and

Leininger (2000), Elmore (1988) suggested that 3 to 4 inch stubble heights would provide

stream bank protection and aid deposition of sediment. Stubble heights of 6 inches may

be required to protect ecosystem function (Meyers 1989). Reducing use and the potential

beneficial effects from stream bank stability would reduce the negative impacts

associated with cattle grazing on suitable frog and toad breeding habitats.

Mitigation in this alternative would prevent monitored areas from exceeding stability

guidelines and enforce stubble heights that, according to Elmore (1988) and Meyers

(1989) would likely protect or enhance stream bank stability and protect ecosystem

function (Clary and Leininger 2000). Monitoring of known boreal toad and boreal chorus

frog breeding areas would be required to accurately monitor breeding activity. If

additional mitigation is required to protect these breeding areas (i.e. fencing of certain

known breeding sites), monitoring of the amphibian breeding activity would identify the

need and allow for site specific mitigation.


have beneficial impacts to boreal toads and boreal chorus frogs because the

improvements would reduce impacts from trampling and road crossings. All range

improvements would be implemented after the breeding season, therefore reducing the

potential for direct impacts to toad and frogs in the areas identified for improvement (see

alternative comparison table).

Aspen - Management Indicator Species: Livestock grazing use and management under

Alternative B would adversely affect individual aspen trees, suckers/saplings, and small

parts of stands. Direct effects include grazing and trampling of understory vegetation and

very light browsing on suckers and saplings. An indirect effect would be that grazing and

trampling in aspen stands would reduce fine fuels and ladder fuels, reducing the potential

for the stand to regenerate through planned or unplanned fire ignitions. There also would


250

be the potential for opportunities for planned fire use to be forgone due to complications

with an allotment in active status. The effects described for Alternative A and Alternative

B are the same.

Cumulative Effects

Threatened and Endangered Species: The cumulative effects associated with

Alternative B are similar to those discussed in Alternative A for grizzly bears, lynx and

wolves due to the same number of cattle in each alternative providing grizzly bears and

wolves the same opportunity for predation; and a slight potential for lynx to be displaced

by cattle and riders continues to exist.

Candidate Species, Sensitive Species and Management Indicator Species: Habitat for

sage-grouse, trumpeter swans, Columbia spotted frogs, western boreal toads, elk, mule

deer, moose, pronghorn and Brewer’s sparrows would still potentially be affected by

trampling and reduction of forage due to grazing. However, the reduced impacts of

Alternative B when added to the effects of past, present and future foreseeable actions

would result in less negative cumulative effects than would occur under Alternative A but

would not be as beneficial as the cumulative effects under Alternative C.

Cumulative effects on aspen would not vary from Alternative A to Alternative B due to

the same number of livestock bedding down for the same amount of time in aspen stands.

Migratory Birds: Cumulative effects for ground nesting and foraging migratory birds

would be similar to the cumulative effects on Brewer’s sparrows.



Grizzly Bear - Threatened and Endangered Species: Determination: This

alternative would have beneficial impacts to the species. There would be no indirect or

direct impacts to secure habitat, denning habitat or whitebark pine associated with

Alternative C. Cattle/grizzly bear conflicts are likely to end and the need to relocate

problem bears from cattle depredation would cease.

Canada Lynx and Critical Habitat - Threatened and Endangered Species:

Determination: This alternative would have no impact to Canada lynx or critical

habitat. Under this alternative there would be no direct or indirect impacts to Canada

lynx or Canada lynx critical habitat.

Gray Wolf - Threatened and Endangered Species: Determination: This alternative

would have no impact to the gray wolf. There would be no direct or indirect impacts to

the Northern Rocky Mountain distinct population segment of the gray wolf. There would

be no cattle/wolf conflicts in the project area and therefore fewer wolves would be

removed by management actions.


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Sage-grouse – Candidate Species - Threatened and Endangered Species: Determination: This alternative would have minor beneficial impacts to greater

sage-grouse. Under this alternative, no grazing would be authorized. In the absence of

cattle grazing, more grasses and forbs would be available to sage-grouse using the project

area during all times of the year. The project area is not a known sage-grouse winter

concentration area; however it is documented as nesting/brood-rearing habitat. In

Wyoming, it is documented that approximately 75 percent of nesting hens nest within 4

miles of the lek they were bred at, and 66 percent nest within 3 miles. The closest lek to

the project area is approximately 4 miles to the southwest of the southernmost portion of

the project area so it is assumed that only a small fraction of the nesting sage-grouse

population may be using the project area. It is highly unlikely that any additional leks

would be initiated in the project area in the absence of grazing, because the more ideal

sage-grouse nesting/brood-rearing habitats are currently and historically on lower

elevation sagebrush lands, south of the project area on BLM lands. Due to these factors,

this alternative would have minor beneficial impacts to sage-grouse.

Sensitive Species - Trumpeter Swan, Columbia Spotted Frog and Boreal Chorus

Frog: Determination: This alternative would have minor beneficial impacts to the

trumpeter swan, Columbia spotted frog, and boreal toad. Under this alternative, no

grazing would be authorized. In the absence of cattle grazing, riparian areas would not

see disturbance from cattle. Potential trumpeter swan nesting habitats and frog and toad

breeding habitats would not have disturbance from cattle presence or see use from cattle

utilization. Trumpeter swans have been successful at nesting in the project area due to

reintroductions, however with late springs, the suitable trumpeter swan habitat within the

project area remains covered in ice, preventing swans from nesting successfully. When

climate conditions allow open water for nesting, trumpeter swans have been successful in

the area, and under this alternative, would continue to nest successfully. No water would

be depleted from cattle using the riparian habitats for drinking, and contamination of

water from feces would not occur. Under this alternative there would be minor beneficial

impacts to these riparian associated species.

Management Indicator Species - Elk, Mule Deer, Moose, and Pronghorn: Under this

alternative, no grazing would be authorized. There would be no overlap with cattle

utilization on spring, summer, fall, or winter habitats, or on parturition habitats for elk,

mule deer, moose or pronghorn. These species would continue to use the project area and

likely maintain populations at or above herd objectives. Management of elk at suitable

herd levels has not been limited by cattle use (WGFD 2009). However, with additional

forage in the project area, more preferred vegetation would be available to elk throughout

the year. Mule deer, moose and pronghorn would continue to use the project area with

additional forage available in the project area and more preferred vegetation would be

available to all species throughout the year.

Brewer’s Sparrow - Management Indicator Species and Migratory Birds: Under this

alternative, no grazing would be authorized. In the absence of cattle grazing, more

grasses and forbs would be available to Brewer’s sparrows and other migratory birds

using the project area during nesting season. With the absence of cattle, direct impacts

from trampling or presence of cattle in the allotments would be null.


252

Boreal Chorus Frog - Management Indicator Species: Under this alternative, no

grazing would be authorized. In the absence of cattle grazing, riparian areas would not

see disturbance from cattle. Therefore, boreal chorus frog breeding habitats would not see

disturbance from cattle presence, trampling, or see use from cattle foraging on riparian

vegetation. Water levels would not be impacted from cattle using the riparian habitats for

drinking, and contamination of water from feces would not occur. Under this alternative

there would be minor beneficial impacts to this species.

Aspen - Management Indicator Species: Under this alternative, no grazing would be

authorized. Livestock grazing would not adversely affect individual aspen trees,

suckers/saplings, and small parts of stands by grazing and trampling of understory

vegetation or browsing on suckers and saplings. Fine fuels and ladder fuels would not be

reduced by livestock grazing and trampling in aspen stands increasing the potential for

the stand to regenerate through planned or unplanned fire ignitions. There would be no

livestock related restrictions concerning planned fire.

Cumulative Effects

Grizzly Bear - Threatened and Endangered Species: The cumulative effect to the no

action alternative would have minor beneficial impacts to the Yellowstone grizzly bear

population by reducing grizzly bear mortality in the Greater Yellowstone Area. No cattle

related mortalities would take place in the project area. This action would have minor

beneficial impacts by not impacting the population of grizzly bears due to cattle conflicts.

Canada Lynx and Canada Lynx Critical Habitat – Threatened and Endangered

Species: There would be no cumulative effects from this alternative on Canada lynx or

Canada lynx critical habitat.

Gray Wolf – Threatened and Endangered Species: There would be beneficial

cumulative effects from this alternative by reducing the number of wolves that are

removed from the population due to wolf/livestock conflicts.

Sensitive Species, Management Indicator Species and Migratory Birds: All

cumulative impacts associated with this alternative would be beneficial to all species

analyzed by increasing the amount of habitat available for foraging/nesting/breeding, and

reducing disturbance from cattle presence and browsing/trampling on aspen suckers.

Therefore, this alternative, when added to all past, present and future foreseeable actions

in the associated species’ home ranges, herd units or statewide management units, would

be beneficial and not further impact the population of the species.


253

Fishery Resources___________________

Information provided in this draft supplemental environmental impact statement about

fishery resources is excerpted from the Fisheries Specialist Report and Biological

Evaluation by Fisheries Biologist Joseph Neal.

Incomplete and Unavailable Information: Distinguishing inherent bank instability

from domestic livestock-caused damage can be difficult without reference streams and

there are none within the project boundaries. There were some stream bank

stability/trampling measurements taken to analyze the stream banks in this DSEIS but

more need to be conducted to give a complete overall picture.

Fine sediment in spawning areas is one stream measure that is directly related to

salmonids reproduction and population health. Generally, the higher the amount of fine

sediment in spawning gravels, the lower the survival of salmonid embryos and juveniles.


Key Issue: Effects on Threatened, Endangered, Proposed, and Sensitive Species, as well as Other Species of Concern

The concern is that livestock grazing may affect recovery of threatened, endangered,

proposed, and sensitive species, in addition to viability and habitat objectives for other

species in the project area. The Forest Plan provides direction for management indicator

species and ecological indicator species. Additional species conservation is directed by

laws, regulations, and policies.

Issue Indicators

• Riparian condition

• Management indicator species present and reproducing

• Sedimentation in the streams that could possibly be attributed to

grazing

Key Issue: Riparian and Aquatic Conditions The concern is that livestock grazing may affect riparian and aquatic conditions. The

riparian and aquatic condition issue relates to maintaining the value and function of

riparian and aquatic habitats. Potential environmental effects of grazing, such as soil

compaction, the exposure of bare ground, and detrimental changes in riparian vegetation

should be considered (for fish and aquatic organism health).

Issue Indicators

• Condition of management indicator species/ecological indicator species

and sensitive species habitat

• Riparian condition


254

Cumulative Effects Common to the Action Alternatives

Analysis Time Frame The time frame for fishery resources is one hundred years into the future, which

represents a period spanning several generations for the salmonid species present within

the project area. This time frame is relevant to Forest management, and the delayed

response time of aquatic habitats to Forest management activities.

Geographic Scope Project impact zone for this analysis is the watershed level (5

th level hydrologic unit code,

see Table 4.2). Watershed level analysis was chosen for two reasons. First was the

potential for contributed stream sediment to travel downstream and reduce aquatic habitat

production. Second, it is likely that migratory forms of fish may travel up and

downstream at the watershed scale and possibly throughout the sub-basins.

Table 4.2: Summary of Area and Perennial Stream Miles Displayed by Watershed

Watershed Name HUC 5 Area (sq. mi.)

Perennial Stream Miles on BTNF (Forest boundary buffered by 5 miles)

Fish Creek 1704010201 229 497

Upper Gros Ventre 1704010202 201 467

Green River - Roaring Fork 1404010101 210 336

Green River - Big Twin Creek 1404010102 260 500

Middle Beaver Creek 1404010103 148 264

Identified Other Actions - Past, Present, and Foreseeable Future Actions

Existing conditions are the result of past and ongoing management activities such as

forest roads, recreational activities, fisheries management, forest and rangeland

management. An emphasis upon roads is due to cumulative human use, and roads’

contribution to the disruption of hydrologic function and increased sediment delivery to

streams. Roads provide access, and the activities that accompany access magnify their

negative effects on aquatic habitats. Activities associated with roads within the analysis

area include fishing, recreation, timber harvest, livestock grazing, and agriculture. Roads

also provide an avenue for stocking non-native fishes.

The Interdisciplinary Team identified approximately 40 past and present ground

disturbing activities, and about 20 foreseeable future ground disturbing activities. Given

the nature of these activities, the primary cumulative impact to aquatic habitat and fish

populations can be summarized into the following four categories:

• Historical and current livestock grazing;

• Past, present and future forest roads management;

• Past introductions of non-native fish species; and

• Future watershed restoration.


255

Past effects on streams include reduced stream productivity from high percentage of bank

erosion; high sediment delivery to streams from eroding uplands; loss of riparian

vegetation and fish cover; and increased water temperatures resulting from loss of

riparian habitat. During this time of presumably highly degraded fish habitats, non-native

trout species were transported to headwater streams throughout the BTNF and the west

(Behnke 1992). Hybridization with rainbows and other cutthroat species and replacement

by brook and brown trout virtually eliminated the Colorado River cutthroat trout.

Yellowstone cutthroat have managed to resist hybridization and competition by other

trout (Behnke 1992).

Significant road erosion occurs on forest roads that are not adequately maintained (i.e.

ditches, culverts, ruts, and dished surfaces) (Tysdal et al. 1999; Kennedy 1997). Sediment

delivery to streams from roads can mask the effects from livestock grazing sources

(Myers and Swanson 1995). Stream crossing assessments (Stream Crossing Inventory

data on file at Pinedale Ranger District office) indicates the high density of roads and

numerous stream crossings within the project area are impacting aquatic resources. The

relationship between road density and fish populations are: sediment delivery to streams

with resulting loss of habitat and reduced embryo survival; population isolation and

fragmentation from migration barriers at road crossings; and introductions of non-native

fish species. Stream crossing assessment data suggests that over 80 percent of the road

crossings on the BTNF are point sources of sediment delivery to streams and partial to

full migration barriers to various life stages of cutthroat trout.

Historically, fires have burned within the project area and will continue to do so into the

future. Sedimentation washing off the hillsides with each spring runoff, rainstorm, or

wind event (as can be witnessed in the South Fork of Gypsum Creek) would contribute to

the fine sediment in the stream system for many years – possibly up to 20 years after each

fire. The loss of vegetation shading the stream could lead to the stream warming,

undercut banks collapsing, and bank stability weakening. Cumulatively, these conditions

result in reduced salmonid populations but will continue under all the alternatives.

Fuel treatments and prescribed fire treatments have been conducted in the past and are

being proposed to be carried out in the near future. With these treatments, new roads and

increased use of current roads contribute to the production of sediment. These projects

will continue no matter which alternative is selected.

There is the potential for a water development dam to be built on the main stem of the

Green River below the Forest boundary that would back water up to the Forest. The

construction of this dam could change the way recreation users would use the Forest and

could potentially introduce more exotic fish species and aquatic nuisance species, further

impacting the native cutthroat trout.

With the increase in human population throughout the mountain west, recreational use (in

both developed and dispersed sites) will increase over the next few decades. This

recreational use would tend to be centered on the stream systems possibly degrading

stream banks and increasing sedimentation into the system both by recreationist-use and

by the road system that the public would use to access the area.


256

Bank trampling would continue under all alternatives due to the wild ungulates that also

use the project area but would decrease proportionally as you go from Alternative A

(current management) to B to C. While the numbers permitted under Alternative A and B

are the same, the use is higher under A than B thus more trampling would occur in A than

B.

Fish Creek Watershed: Cumulative impacts to aquatic habitats with implementation of

Alternative A would result in maintaining current conditions and a high risk to this

Yellowstone Cutthroat trout population. Some improvement by reducing sediment

delivery would result due to road closures and reducing erosion at stream crossings.

However, response by fish populations would be insignificant in relation to existing

conditions and the minor amount of watershed improvements planned. There would be

improved fish habitat conditions with implementation of Alternative B due to planned

road restoration. However, projected time for improved stream habitat conditions under

adaptive management grazing could be 10 to 20 years. Fish population trends would

reflect this delay in hydrologic recovery and would remain at risk until habitat is

recovered. Implementation of Alternative C along with watershed restoration projects

would result in the quickest recovery of habitat and resulting fish populations because

livestock would no longer be grazed on the allotments. Fish population response may

take 5 to 10 years before responding to improved aquatic habitat and hydrologic function

following removal of livestock.

Upper Gros Ventre Watershed: Considering the small amount of project area within

the watershed, implementation of Alternatives A, B, or C is not likely to contribute

significantly to cumulative effects. Implementation of Alternative C would have the most

beneficial cumulative effect to aquatic resources due to the removal of livestock impacts.

Green River – Roaring Fork Watershed: Cumulative impacts to aquatic habitats with

implementation of Alternative A would result in maintaining current conditions. There is

no risk to Colorado River cutthroat trout or Snake River cutthroat trout populations since

this watershed contains neither in pure form. Some improvement to aquatic habitats by

reducing sediment delivery would result due to road closures, reducing erosion at stream

crossings, and increasing fire intervals. However, response by fish populations would be

insignificant in relation to existing conditions and the minor amount of watershed

improvements planned. There would be improved fish habitat conditions with

implementation of Alternative B along with planned road restoration. However, projected

time for improved stream habitat conditions under adaptive management grazing could

be 10 to 20 years. Fish population trends would reflect this delay in hydrologic recovery

and would remain at current condition until habitat is recovered. Implementation of

Alternative C along with watershed restoration projects would result in the quickest

recovery of habitat and resulting fish populations. Fish population response may take 5 to

10 years before responding to improved aquatic habitat and hydrologic function


Green River - Big Twin Watershed: Cumulative impacts to aquatic habitats with

implementation of Alternative A would result in maintaining current conditions and high

risk to Colorado River cutthroat trout, Yellowstone cutthroat trout, and Rainbow trout


257

populations in Tepee, Jim, and Gypsum Creeks. Colorado River cutthroat trout,

Yellowstone cutthroat trout, and Rainbow trout populations in Rock Creek appear to be

holding steady but population estimates to be completed in 2010 and later will confirm.

Some improvement by reducing sediment delivery would result due to road closures and

reducing erosion at stream crossings. However, response by fish populations would be

insignificant in relation to existing conditions and minor amount of watershed

improvements planned. There would be improved fish habitat conditions with

implementation of Alternative B along with planned road restoration. However, projected

time for improved stream habitat conditions under adaptive management grazing could

be 10 to 20 years. Fish population trends would reflect this delay in hydrologic recovery

and would remain at current condition until habitat is recovered. Implementation of

Alternative C along with watershed restoration projects would result in the quickest

recovery of habitat and resulting fish populations. Fish population response may take 5 to

10 years before responding to improved aquatic habitat and hydrologic function


Middle Beaver Creek Watershed: Considering the relatively small amount of project

area within the watershed and the large amount of private land ownership,

implementation of Alternatives A, B, or C is not likely to contribute significantly to

cumulative effects. Implementation of Alternative C would have the most beneficial

cumulative effect to aquatic resources. Watershed restoration opportunities to improve

aquatic habitat (i.e. restoration of roads, stream crossings, etc) should be pursued to

minimize potential cumulative effects and to meet Forest Plan goals and objectives.

Alternative A is the most damaging to the resources, especially when it is considered

cumulatively. The effects of the past 100 years of grazing will probably continue to be

seen on the ground for the next 50 - 100 years even if Alternative C is selected. Healing

would be slow to non-existent if Alternative A is selected with fish populations reflecting

the delay in hydrologic recovery and would remain at current population numbers until

the habitat is recovering.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans Goal 3.3: All sensitive species are not currently petitioned for listing, due largely to

diligent work accomplished by the WGFD. Alternative C would only strengthen this

stance; Alternative A would continue more of the same; and Alternative B would be a

mix of the two, more than likely leading to all sensitive species not being listed within the

state of Wyoming.

Goal 4.7: Alternative C would meet this goal. Alternative A may not be able to meet this

goal over the long-term as the use tends to compound. Alternative B could meet this goal

through adaptive management and following the mitigations described by the various

specialists.


258

Sensitive Species Management Standard: All sensitive species have survived one or

more listing petitions largely through habitat and population work that has been

conducted by the WGFD. It appears that this standard would be met under all three

alternatives.

Fish Habitat Management Guideline: It appears that this guideline is being met and

would be met under all three alternatives. Additional inventory and monitoring work

needs to be conducted specifically for Colorado River cutthroat trout which would in turn

tell the Forest more about the other sensitive species.

Stream bank Stability Guideline: Visually, it appears that most of the streams (except for

the occasional “disturbed” or sensitive reach) within this project are meeting this

guideline with the possible exception of the streams along fence lines that experience

congregated cattle (primarily in the fall when livestock congregates trying to leave the

Forest), and wild ungulate, grazing and trampling. Alternative C would best address this

guideline with Alternative B coming in a close second. Field measurements were

performed, and more measurements need to be conducted using the Multiple Indicator

Monitoring protocol to determine whether Alternative A would meet this guideline or

not; it appears it would not at present with a very limited sample size.

Livestock Grazing of Riparian Areas Standard: Alternative C would most easily meet this

standard. Alternative B would also meet this standard. Most allotments, managed under

Alternative A, appear to be meeting this standard with the exception of some sensitive

areas in a few of the pastures where centuries of use have cumulatively impacted those

reaches.

Fish, Wildlife, and Threatened, Endangered, and Sensitive Species Standard: Alternative B and C would meet this standard. Alternative A is trending towards meeting

this standard.



Short and long term impacts are not differentiated because short-term (2 - 5 years)

sediment delivery to streams can have long-term impacts to aquatic resources. This

assumption is based upon the length of time required (possibly decades) for stream

systems to move sediment (Bunte and McDonald 1999), stream bank natural recovery

rates (Platts 1985), and fish population responses to changed habitat conditions (Platts

1981).

Rangeland and aquatic systems evolved with ungulate grazing by deer, elk, moose, and

bison. It has been hypothesized that current livestock management emulates these natural

use patterns and livestock grazing is necessary to maintain landscape vegetation patterns

and watershed health. While elk and bison herds would have tended to create a high level

of disturbance in relatively localized areas, these use patterns may not have occurred each

year or in the same locations, allowing rest and recovery. Domestic livestock are


259

managed to graze the same ground each year (allotments and pastures) creating more

chronic impacts (Wuerthner 1997). Even though domestic livestock grazing might occur

at a lower intensity than native ungulates, cattle tend to remain near streams unless

moved (Makie 1970). This pattern of management does not allow the periodic rest

necessary for vegetation recovery (Platts and Nelson 1985). Chronic habitat degradation

reduces the ability of small headwater streams to recover; and native cutthroat and other

dependent organisms would continue to exhibit depressed populations.

Implementation of Alternative A would result in maintaining current habitat conditions

assuming no change in grazing management. Direct effects of selecting this alternative

would continue the current bank alteration which can be high at localized locations

within the allotments (Chapter 3, Figure 3.47). It is unlikely that the stream bank stability

desired future conditions or short-term objectives (5-years) would be met by

implementing Alternative A. Indirectly, this adds sediment to the streams and potentially

decreases salmonid reproduction and macroinvertebrate populations (salmonid food).

Colorado River cutthroat trout are in a precarious position in all of the streams they

currently inhabit and any continued degradation of habitat could push them past the point

of recovery. Yellowstone cutthroat trout are stable in the streams they occupy within the

project area. Rainbow trout are maintaining stable to declining populations in the project

area due primarily to lack of stocking by the WGFD. These fish are not native to the

project drainages and the loss of the population does not indicate a decline in habitat

conditions. Kendall Warm Springs dace, while protected with a 160 acre exclosure fence,

would probably stabilize or continue to decline in numbers as the warm springs channel

stabilizes over time.

Determination: The project as described in Alternative A would have a will impact


towards federal listing or cause a loss of viability to the population or species on the

sensitive Colorado River cutthroat trout AND a may impact individuals or habitat, but

will not likely contribute to a trend towards federal listing or loss of viability to the

population or species on the endangered Kendall Warm Springs dace and the sensitive

Yellowstone cutthroat trout and management indicator Rainbow trout species (Table 4.3).



This alternative responds to the Bridger-Teton National Forest Plan goals for watershed

health, biodiversity and viability, social/economic contributions and objectives for

rangeland management. It provides for moving the project area toward and/or

maintaining the desired conditions described in the plan. This alternative implements

updated grazing management including benchmarks for desired conditions, continued

and/or improved monitoring to determine if benchmarks are being met, and adaptive

management to ensure those sites which are currently meeting Forest Plan desired

conditions (e.g. ground cover, species composition, soil disturbance, bank stability, fish

habitat, and riparian grazing) continue to meet these conditions while ensuring those sites


260

currently not at desired conditions have at the very least a stable if not an upward trend.

This alternative includes monitoring which would be used to make adjustments to

domestic livestock grazing as needed based on monitoring results.

Direct effects of implementing this alternative would be a decrease in bank alteration and

a corresponding increase in bank stability, assuming that all of the sensitive stream

reaches identified are affected primarily by livestock. This would indirectly lead to a

decrease in sedimentation in the stream systems and potentially an increase in salmonid

reproduction and macroinvertebrate production due to the lack of smothering of eggs and

macroinvertebrates by fines. Adaptive management strategies (see Alternative B Design

Features Table 2.3 in Chapter 2) would allow for rapid removal of domestic livestock

once thresholds are reached and sensitive areas are being monitored. This is especially

important along the Teepee and Tosi Creek drainages as this is where the majority of

current grazing impacts are seen and where pure Colorado River cutthroat trout still

reside. Yellowstone cutthroat trout are stable in the streams they occupy within the

project area and would remain so under this alternative. Rainbow trout are maintaining

stable to declining populations in the project area due primarily to lack of stocking by the

WGFD. These fish are not native to the project drainages and the loss of the population

does not indicate a decline in habitat conditions. Kendall Warm Springs dace, while

protected with a 160 acre exclosure fence, would probably stabilize or continue to decline

in numbers as the warm springs channel stabilizes over time.

Cumulative Effects

See Cumulative Effects Common to the action alternatives above. Cumulative Effects

under this alternative would fall somewhere between Alternatives A and C; leaning

heavily towards Alternative C if all “adaptive management” strategies and specialist

mitigations are implemented. Projected time for improved stream habitat conditions to

reflect improved rangeland conditions could be 10 to 20 years. Fish population trends

would mirror the habitat conditions with a 1 to 3 year delay.

Determination: The project as described in Alternative B would have a may impact

individuals or habitat, but will not likely contribute to a trend towards federal

listing or loss of viability to the population or species on the endangered Kendall

Warm Springs dace, the sensitive Colorado River cutthroat trout and Yellowstone

cutthroat trout and management indicator Rainbow trout species (Table 4.3).



Scientific literature provides abundant documentation of the positive effects on stream

habitat conditions and fish population responses upon eliminating streamside grazing of

domestic livestock (Platts 1981; Myers and Swanson 1995). Local examples also show

dramatic habitat improvement once stream bank disturbance from livestock is removed.

For example, Klondike Creek in Noble Pastures allotment (pasture #4 – partially fenced

for 20 years) maintains bank stability at 71 percent, compared to 34 percent bank stability

in adjacent Tosi Creek (pasture #1, which never had an exclosure fence installed). Fish


261

populations increase in response to improved stream habitat once livestock grazing is

removed. Platts (1981) reported fish densities were more than ten times higher in lightly

grazed or no grazing in comparison to heavily grazed stream sections. It is highly

probable that the desired conditions and habitat objectives listed for the project area

would be met by implementing Alternative C. Therefore, implementation of Alternative

C would result in improving current habitat conditions and increasing salmonid

populations within the analysis area.

The impact to warm springs that large ungulates have can be observed in Yellowstone

National Park by observing the current hot spring systems. These same large ungulates

once (and some still do though in limited numbers) grazed and trampled the banks around

Kendall Warm Springs; Native Americans and early European settlers also trampled the

banks as they used the warm springs. Kodric-Brown and Brown (2007) surmised that

these types of springs require large and frequent disturbances to keep the endemic species

alive within the spring system. The 1,200 foot spring is doing what a normal flowing

water system would do with little bank disturbance; it is getting narrower and deeper,

thus reducing habitat for the small Kendall Warm Springs dace. This alternative is the

worst of the three available when you consider the long-term viability of this endangered

dace. Any alternative that allows grazing in the project area would also allow incidental

livestock impacts to the Kendall Warm Springs as no fence or gate is 100 percent

livestock proof. Removing all livestock from the Upper Green removes all incidental

bank trampling and alteration from within the warm spring’s exclosure.

Cumulative Effects

There would not be any cumulative effects for this alternative as it would be improving

habitat conditions by removing domestic livestock grazing from the Forest. Other factors

impacting the aquatic environment would however remain on the landscape (i.e.

road/stream crossings, recreational impacts, timber sales, fire, etc.). However, projected

time for improved stream habitat conditions to reflect improved rangeland conditions

could be 3 to 10 years. Fish population trends mirror the habitat conditions with a 1 to 3

year delay.

Determination: The project as described in Alternative C will have a beneficial impact

on the sensitive Colorado River cutthroat trout, Yellowstone cutthroat trout, and

management indicator rainbow trout species analyzed in this report but will impact


towards federal listing or cause a loss of viability to the population or species for the

endangered Kendall Warm Springs dace (Table 4.3).


262

Table 4.3: Summary of Effects Determinations

Common Name Scientific Name Alternative

A B C

Colorado River cutthroat

Oncorhynchus clarki pleuriticus

WIFV MIIH BI

Rainbow trout Oncorhynchus mykiss MIIH MIIH BI

Yellowstone/Snake River cutthroat

Oncorhynchus clarki spp. MIIH MIIH BI

Kendall Warm Springs dace

Rhinichthys osculus thermalis

MIIH MIIH WIFV

NI = No Impact BI = Beneficial Impact NE = No Effect MIIH = May Impact Individuals Or Habitat, But Will Not Likely Contribute To A Trend Towards Federal Listing Or Loss Of Viability To The Population Or Species WIFV = Will Impact Individuals Or Habitat With A Consequence That The Action May

Contribute to a Trend Towards Federal Listing Or Cause A Loss Of Viability To The Population Or Species

Other Required Analyses_____________

Irreversible and Irretrievable Commitment of Resources An irretrievable commitment of a resource is one in which the resource or its use is lost

for a period of time. It is possible that rangeland functioning conditions would not be

entirely achieved for the duration that these alternatives are in place due to the time it

takes to recover functionality. Recovery would be more rapid under Alternative C than

Alternatives A and B. There would be no irretrievable loss of resources for the other

resources analyzed in this document.

An irreversible commitment of a resource is one that cannot be reversed (e.g., the

extinction of a species or disturbance to protected cultural resources). Irreversible

commitments would only apply to rangelands if they became non-functional. This

threshold of non-functioning condition has not been determined. It is unlikely, however,

that this threshold would be crossed considering the relatively pristine existing conditions

in the presence of historic livestock grazing. There would be no irreversible commitment

of resources for the other resources analyzed in this document.

Relationship between Short-Term Use and Long-Term Productivity The indicators of rangeland function directly describe the effects to long-term

productivity. In other words, when rangeland function is at risk, long-term productivity is

at risk. The short-term use of livestock grazing as described in Alternative A may affect

long-term productivity. Currently productivity is only at risk in seven of the 27 key areas.


263

The short-term use of livestock grazing as described under Alternative B would not affect

long-term productivity as design features and monitoring are set up to address

functionality.

There is no short-term use of livestock grazing as described in Alternative C, so no long

term effects would result due to short term commitments. Implementation of this

alternative would show improvement in rangeland vegetation in all key and critical areas,

with the exception of the critical areas that sustain impacts that are primarily caused by

activities other than grazing.

Other Required Disclosures National Environmental Policy Act (NEPA): NEPA at 40 CFR 1502.25(a) directs “to

the fullest extent possible, agencies shall prepare draft environmental impact statements

concurrently with and integrated with…other environmental review laws and executive

orders.”

National Historic Preservation Act: Section 106 requirements (36 CFR Part 800) are

most effectively met when the process is initiated early in project planning. For this

grazing supplemental analysis the Forest Service notified the State Historic Preservation

Officer as well as three Tribes to determine their interest, assess existing information, and

identify known sensitive areas. A Class I Overview was completed in 2009 for this

DSEIS analysis and submitted to the State Historic Preservation Officer for review

(USDA Forest Service, Schoen 2009).

Documents

DSEIS for the Upper Green River Area Rangeland Project ...a123.g.akamai.net/7/123/11558/abc123/forestservic...DSEIS for the Upper Green River Area Rangeland Project personal labor