BLM’s multi-state HORRIBLE fuel break proposal includes areas where there are wild horses & burros.  The BLM’s plan is to use chemicals, bulldozers, livestock grazing and chaining to make an 11,000 mile (500 feet wide) vegetation-free land scar across our public lands. (Laid end-to-end, from Reno it would stretch roughly to Antananarivo, Madagascar.)

Public comments are due August 5th.  Tell the BLM that you support Alternative A – No Action Alternative

Comment by Grandma Gregg

July 16, 2019

U.S. Department of the Interior

Bureau of Land Management

DOI-BLM-ID-0000-2017-0001-EIS (Programmatic EIS for Fuel Breaks in the Great Basin)

As an experienced Environmental Researcher, I require that these public comments be included in the Administrative record for the above EIS proposal. Alternative “A” (NO ACTION) is the only viable, legal and worthwhile option currently proposed by this Environmental Impact Statement (EIS). Scientific reasoning and information for this NO action alternative is hereby provided.

Exhibit #1

“Fuel breaks are ineffective” By George Wuerthner – George Wuerthner is an ecologist who has published 38 books, including “Wildfire: A Century of Failed Forest Policy.”

In June the BLM released a draft “Programmatic EIS for Fuel Breaks in the Great Basin.” The proposal would authorize creation of 11,000 miles of fuel breaks (linear vegetation removal) primarily in sagebrush ecosystems across parts of Nevada, California, Utah, Idaho, Washington and Oregon.

This plan is a government boondoggle that will cost a significant amount of money, likely will not work and in many cases make wildfire spread worse. Under the plan, more than a million acres will be cleared with herbicides, bulldozers, mowers and livestock grazing. Not only will this series of fuel breaks fragment sagebrush ecosystems, but there is significant evidence that this kind of disturbance enhances the spread of cheatgrass, an annual grass that is highly flammable. The goal is to reduce massive wildfires; the kind that burn hundreds of thousands of acres. That is an admirable goal because fires are burning up vast amounts of sagebrush habitat with dire consequences for sagebrush dwellers like sage grouse.

But here’s the problem. Climate/weather conditions primarily drive large wildfires. Extreme fire weather with low humidity, high temperatures, extended drought and, most importantly, high winds is the primary driver of large blazes. Under such conditions, windblown embers easily cross any “fuel break.” Worse, disturbance of soils is the main factor in the spread of Bromus tectorum, better known as cheatgrass.  For instance, in a paper in Applied Ecology titled “Conditions Favoring Bromus Tectorum Dominance of Endangered Sagebrush Steppe Ecosystems,” the authors concluded that destruction of biocrusts and loss of native bunchgrasses enhance the spread of cheatgrass. And grazing, mowing, bulldozing and other treatments all destroy biocrusts and native bunchgrasses and therefore only exacerbate the spread of this alien grass. In effect, fuel breaks will become super-highways for the spread of cheatgrass.

In a recent paper on fuel breaks with the title “The ecological uncertainty of wildfire fuel breaks: examples from the sagebrush steppe,” the authors warn that fuel breaks are of unproven effectiveness in the face of extreme fire weather. They suggest that an extensive system of fuel breaks would “create edges and edge effects,” “serve as vectors for wildlife movement and plant invasions” (like cheatgrass) and “fragment otherwise contiguous sagebrush landscapes.”

The idea that livestock grazing can be used to reduce wildfires is widespread in the ranching community, but like the idea that fuel breaks are sufficient, the real story is in the details. In a widely cited paper, “Targeted Grazing in Southern Arizona: Using Cattle to Reduce Fine Fuel Loads,” the authors write glowingly about how grazing can be used as a tool to reduce fire spread. However, in the next-to-last paragraph, they write that “targeted grazing will be most effective in grass communities under moderate weather conditions.” In other words, livestock grazing doesn’t work to reduce wildfires under extreme fire weather conditions. There are other negative consequences as well.

These corridors are often used by predators like coyotes, avian predators like ravens and others to search for vulnerable prey like sage grouse. In justifying these fuel breaks as a means of “saving” sage grouse, they may only increase sage grouse losses. The real problem is that changing climate is enhancing extreme fire weather that is ultimately driving large wildfires. Without addressing climate change, such proposals like fire breaks are like sticking your finger in the dike as the entire barrier collapses.”

Exhibit #2

The BLM wants to dig 11,000 miles of fuel breaks to stop Western wildfires — will it work? Benjamin Spillman, Reno Gazette Journal (excerpts)

The Bureau of Land Management pitching plan to build 11,000 miles of fuel breaks across west, critics say it would damage Nevada without solving problem. Benjamin Spillman, bspillman@rgj.com

[The proposal] calls for creating 11,000 miles of fire fuel breaks across six western states by removing, reducing or changing vegetation in wide swaths mostly along roads and highways. Officials from the Bureau of Land Management, who would be in charge of building and maintaining the fuel breaks, say they need a big plan to tackle a problem as big at the West, which has lost about half of the 247 million acres of the dominant sagebrush ecosystem. Critics, however, say it’s a boondoggle in the making.

They point to construction costs that could approach $275 million and annual maintenance costs that could $25 million to more than $100 million.

And they say the very design of the plan is such that it could allow government officials to circumvent environmental regulations aimed at protecting the Interior West’s scenic landscapes and vulnerable species such as the Greater sage-grouse.

“BLM is essentially doubling down on a century-and-a-half of mismanagement of our rangelands,” said Patrick Donnelly, the Center for Biological Diversity director in Nevada, which where BLM would be doing most of the work. “There is no proof that blading 500-foot-wide swaths of destruction across the Great Basin stops fires.”

Critics of the government’s approach to the problem, however, say the fuel breaks could create or enhance more problems than they solve. They point to a number of issues, including the expected cost, Without maintenance, Peterson said, the fuel breaks would fill in with cheatgrass and make the fire problem worse, not better. “It really creates the disturbance cheatgrass loves to move into and cheatgrass is the number one reason these fires are spreading, If you get this thing started and walk away from it … it becomes an ignition source.” Donnelly highlighted other ideas in the proposal, such as using targeted cattle grazing to control cheatgrass, as impractical. “The idea of targeted grazing depends on deploying massive numbers of cattle all at once right when the cheatgrass is ready to be eaten,” he said. “What do you do those cows for the other 49 weeks a year?” Another, even greater, concern for Donnelly is the very structure of the proposal. He said the document contains opportunities for the government to bypass environmental regulations, despite assurances from the BLM that environmental groups and concerned citizens would get a chance to weigh in on types and placement of individual fuel breaks. “This is basically just gutting NEPA to allow these projects to move forward with no environmental review,” Donnelly said, saying it’s wrong to characterize environmental regulations as bureaucratic red tape to be avoided. “That red tape is what protects our water, is what protects our wildlife, protects our clean air.”

Donnelly said working to restore native plants and wildlife habitat would be a better way to reduce the rangeland fire problem. Native bunch grasses tend to me more resilient to fire than cheatgrass and other invasive annuals. And a healthy rangeland ecosystem tends to burn much less frequently than areas that are compromised by invasive grasses. “They want to industrialize these landscapes, fragment them more, convert them more to man-made landscapes,” Donnelly said. “That is just the wrong approach.”  https://www.rgj.com/story/news/2019/07/15/bureau-land-management-11000-miles-fuel-breaks-stop-wildfires/1688502001/

Exhibit #3

Despite the potential for fuel breaks to help reduce unwanted wildfire, scientific research on their ecological effects as well as their effectiveness (ie to restrain wildfire) is scarce for many ecosystems (Shinneman et al. 2018). Many scientists and resource managers are therefore concerned that the ecological costs associated with fuel breaks may outweigh any potential benefits (eg Keeley 2006). These projects are likely to result in thousands of linear miles of fuel breaks that will have direct ecological effects across hundreds of thousands of acres through habitat loss and conversion. These projects may also affect millions of acres indirectly because of edge effects and habitat fragmentation created by networks of fuel breaks.

Exhibit #4

Wasting Owyhee forests  – Katie Fite is public lands director of WildLands Defense.

The Bureau of Land Management has delayed the massive Bruneau-Owyhee Sage-grouse Habitat deforestation project, following appeals filed by WildLands Defense and others. The project targets western junipers across 617,000 acres of the Owyhee region. It would destroy nearly all forests except pockets of junipers in wilderness. The Owyhees are the only place in Idaho where this long-lived native tree grows in abundance.

The project would lay waste to the public land with jackpot burning, pile burning, clearcutting and mastication. Jackpot burning consists of cutting trees to dry out, then igniting them so fire spreads to the surroundings. In pile burning, heaped cut trees are set ablaze. Junipers were called asbestos trees by past BLM managers because they are difficult to burn except under extreme conditions. Mastication machines travel cross-country, grinding up whole trees and reducing them to piles of wood chips smothering the ground surface.

Similar projects in the Middle Fork Owyhee and other areas have caused rapid-fire infestation of cheatgrass. Cheatgrass invades the areas disturbed by burning and heavy equipment. Then it moves out cross-country in the wake of livestock disturbance. Diverse wildlife species inhabit juniper forests. Mountain bluebirds and kestrels nest in cavities of centuries-old trees. Ferruginous hawks, flycatchers, even hermit thrushes and many other migratory birds nest here. Flocks of robins and Townsend’s solitaires feast on juniper berries in winter. The trees provide habitat security for deer and elk, protection from poaching and emergency food in harsh winters. Junipers are often the only shade and bank protection for streams home to remnant populations of redband trout.

BLM proposes to willy-nilly denude even the streambanks, paying no heed to the needs of fish and wildlife or the beauty of the trees and the cooling shade they provide. Old-growth trees are not identified or protected. BLM claims trees must be purged for several miles around sage-grouse leks to boost dwindling populations. It seeks to pioneer new habitat in mountainous sites where trees are the natural plant community. Even with all trees removed, many areas would be only marginal grouse habitats. The birds prefer less rugged terrain.

Owyhee public lands cattle ranchers have long sought to have BLM kill junipers to promote more forage grass. Range personnel in federal agencies and at Land Grant colleges have developed elaborate models with faulty inputs that model the trees out of existence. These are used to justify forest clearing. Juniper eradication projects like the Bruneau-Owyhee Sage-grouse Habitat project are taking place across the region. They are a very expensive distraction from BLM taking better care of existing sagebrush habitats. The political power of the public lands livestock industry prevents BLM from acting to effectively protect existing sagebrush communities. At the same time the Bruneau-Owyhee Sage-grouse Habitat project aims to raze forests ostensibly to benefit sage-grouse, Bruneau BLM is devising a plan to expand intensive cattle grazing by Simplot and other public lands ranchers. New harmful stock water pipelines, more fences and inflated cattle numbers are proposed in prime sage-grouse habitats in Battle Creek and Castle Creek.

Imagine if the vast sums being spent turning arid forests into hotter, drier, windier, weedier more fire-prone sites were used on a Manhattan project for cheatgrass control instead. If federal agencies and politicians want to “save” sage-grouse, then reining in public lands grazing, fully funding a biocontrol or other solution to cheatgrass and effectively recovering millions of acres of seedings and failed fire rehabs must be paramount. It’s time to abandon radical deforestation schemes like the Bruneau-Owyhee Sage-grouse Habitat project and get serious about real restoration of the West — not irreversibly destroy more wild places.

Exhibit #5

WildLands Defense

The quickest way from Boise to Yellow Lupineland (see previous post) down in the Jarbidge country Humboldt-Toiyabe Forest runs through some of the most abused BLM lands around. This is the landscape hideously “managed” by Jarbidge BLM. Grazing in the Jarbidge country has long been dominated by various members of the Brackett family and the Simplot cow-pesticide-phosphate mining-potato empire. Over the years, BLM has “converted” vast areas of sagebrush habitat to sterile crested wheatgrass seedings for cattle forage.

First this was done in projects where BLM admitted it was outright DESTROYING sagebrush habitat to plant the exotic weedy crested wheatgrass for cow food. Then it was done by BLM using every fire (and there have been a whole lot of fires including blazes started by the Air Force at their Saylor Creek Bombing Range and in other activities) as an excuse to plant even more crested wheatgrass under the guise of “emergency fire rehab”.

NOW BLM’s excuse for densely planting even more of this crested wheatgrass fire hazard is the false claim that it is a fuel break. A series of huge fires have burned in these Jarbidge crested wheatgrass seedings over the years. And as for the Fuelbreaks, there have long been crested wheatgrass fuelbreaks near part of the Saylor Creek Bombing Range, They have increasingly become infested with cheatgrass. The combination of dense crested wheatgrass and cheatgrass in the interspaces creates an extreme fire hazard once the cwg dries out.

Then around 3 years ago, Jarbidge BLM destroyed some of the only remaining sagebrush south of the Air Force fuel breaks to densely plant even more crested wheatgrass as a supposed fuel break. This was in an area near Winter camp where a few sage-grouse were still managing to persist.

So BLM herbicided and killed mature and old growth Wyoming big sagebrush. Parts of the area now are a thicket of combustible two feet tall crested wheatgrass. Others are solid cheatgrass. Cheatgrass will only increase over time. BLM planted the tallest maximum “forage production” cwg it could find. This crap is 2 feet tall. No one in their right mind plants grass that grows two feet tall densely – and claim it is a ‘fuel break”.

This is instead a bonanza of even more cow chow for wealthy politically connected public lands welfare ranchers. And BLM has issued a Draft EIS to plant a million acres more of this crap across Idaho, Nevada, Oregon, Utah … and call it a Fuelbreak. They want to destroy intact sagebrush and pinyon-juniper forests and do THIS to it. It’s habitat fragmentation and a hazardous fuels INCREASE project at a massive scale. It’s another huge handout to the welfare ranchers and Monsanto and other plant poison purveyors. Just like all the insane “treatments” that destroy PJ and sage to “save” sage-grouse – this is another Orwellian project that will do just the opposite.

Exhibit #6

This is a MILLION ACRE cow forage scheme – purging more sagebrush and pinyon-juniper over vast areas and uglifying entire landscapes. Not to mention it being a MILLION ACRE windfall for Monsanto/Bayer and other herbicide poison purveyors, as a profusion of weeds will invade the “treated” cow grass “fuelbreaks”. So they will be doused in toxic chemicals. It’s a “grand experiment” in public land and wildlife habitat DESTRUCTION. It must be stopped.

https://news.bloombergenvironment.com/…/interiors-grand-exp…

Exhibit #7

The Deforestation of Juniper – Some Thoughts (Edited by K.R. Gregg)

Deforestation is a global problem. We are rightly concerned about the current destruction of forests in other parts of the world, but it isn’t always so apparent that humans have been clearing and destroying juniper woodlands here in the West.

Deforestation has also caused changes in the structure and fertility of the soil. Woodlands are more effective at retaining nutrients than overgrazed grassland, and so the loss of woodland cover can result in the soil becoming impoverished. Trees also intercept rainfall, retain moisture in the soil and send moisture back into the atmosphere via a process known as transpiration.

Centuries of ranching that involves rearing then removing animals from the land, means that high concentrations of nutrients have been lost when the meat was sold elsewhere (e.g. in towns and cities).Dead wood, standing and fallen, is a vital part of a healthy forest, supporting a wide range of organisms. Forest clearance and intensive management of forests has resulted in a huge decrease of this crucial resource (slash piles are usually burned on site or sent to a bio-plant after logging or juniper removal).

Deforestation and domestic livestock overgrazing also result in the loss of the shrub layer and changes to the ground flora. When the structure becomes simplified, there are fewer niches for wildlife. Where areas may formerly have had rich floral communities, overgrazing and loss of the canopy can reduce the vegetation to non-native grasses. While wildfire is a natural part of any ecosystem and is a valuable part of the natural landscape mosaic, human interference has created an unnaturally high proportion of species-poor invasive grasses such as cheat grass, where juniper woodland would otherwise have thrived.

Humans have and continue to drastically denude and degrade the juniper forest. While no one can say for certain what the forest would be like had humans never interfered, we can safely say that it would be much more extensive and connected, and would contain a much richer array of wildlife than it does at present.

Who would have ever thought way back when, that at some time in the future, trees or shrubs native to their own historical territories & habitats would be treated like some invasive alien species brought over from another part of the world only to get loose and wreak havoc on the environment? Our Juniper forests have been unfairly demonized as an invasive in its home territory for many years now because it encroaches into precious grassland which is used for the privately owned, non-native, domestic cattle and sheep industry.

Much of this has not only been the result of climate change, but also the lousy over-grazing practices of ranchers which have created a more favorable condition for its spread. So what is the future for the forest? Most forest remnants are still struggling to expand (known as forest succession), or even survive, largely because of overgrazing by excessive numbers of domestic livestock. There is a need for a wide range of forest uses, including the provision of timber and other forest products. To balance this, there is also the need for large wild areas free of intensive human management – ‘self-willed land’, to use a term coined by ecologist Aldo Leopold.

Before it is too late, we must restore or allow a large area of wild diverse forests to restore itself, which would include a wide range of habitats including the juniper forests.  The aim is not to recreate a forest of the past; it is to allow the forests to evolve naturally within their ever-changing ecosystems. The goal is to restore the key elements in the forest to allow evolution and natural processes a freer reign. There is no doubt that the presence of wild forests nourishes the human spirit, as well as being essential to the health of the Earth.

Before Americans moved into the West, woodlands covered a large area of the land and the forest was rich and diverse. The structure of the forest was varied, and included a mosaic of denser woodland, different kinds of scrub, as well as open desert and prairie, which were all important parts of the whole matrix.  Each ecosystem had unique communities or niches of specialist wildlife which overlapped into neighboring ecosystems – giving a healthy environment to our West. Before intrusion by Euro-Americans, western wildlife flourished. Mountain lions, grizzly bears and wolves prowled the denser forest, and large herds of deer, antelope, elk, and other herbivores grazed open clearings, while skunks, beaver, porcupines, raccoons and other small mammals foraged through the ground plant litter. Bears scooped salmon from the rivers, elk grazed in the meadows created by the dams of beavers and birds were nourished by plants and animals.

Then, farmers and ranchers moved in with their non-native grazing animals – domestic cattle and sheep. In many areas farmers and ranchers harvested and burned the trees and resinous woods to encourage fresh growth of grasses for their domestic livestock. The combination of burning and grazing forced the woodland juniper into retreat as well as preventing it recolonizing bare areas. Their activities profoundly altered and continue to alter the natural ecosystem. In the American West, through the past century or two, trees were felled for timber, fuel and to make way for agriculture.

Grazing of domestic livestock severely limited the scope for regeneration. The forest was forced into smaller, fragmented pockets. For example, removing even scattered trees affects the hydrology of the land. Removing trees takes away important seed sources, leads to erosion and removes the source of leaf litter which itself plays a key role in converting dry or depleted soils to more favorable nutrient rich soil which is healthy for all plant growth. Various kinds of exploitation continues and especially in burned areas of forest where heavy grazing by domestic livestock occurs it is pastoral activity – fire and teeth – that are the most consistently destructive human activity. Large-scale, long-term ecological destruction is totally transforming the Juniper forest while many other habitats have already been degraded or lost.

All of our woodlands have been influenced by humans in some way and the ecological effects have been complex and varied; some of the key ones are outlined below: When a habitat is fragmented, as is now the case, the species within the isolated patches become more vulnerable to inbreeding and disturbance such as fire and disease. Connectivity is essential for the robustness of an ecosystem. Large, wild juniper forests are dynamic habitats which exhibit ecological processes such as succession, and are influenced by natural disturbances such as fire, storms and disease. These keep the overall ecosystem varied, with healthy habitats. Small, fragmented woodlands cannot withstand disturbance in the same way, and the ecosystem becomes less complex. Not only has woodland cover been lost, but overgrazing in the remnants has also selected out the most palatable species, which in turn affects the specialist species that depend on them (i.e. sage grouse for example). Native woodland remnants are therefore less diverse than they would otherwise be.

A number of key wildlife species have been or on the brink of being lost, because of both habitat destruction and direct persecution. This has had a catastrophic effect, since all the animals and other life forms that dwell in the forest play a crucial role in keeping this diverse ecosystem healthy and robust. When key species are removed, the tapestry begins to unravel, affecting the health of the whole system. In some countries and in some areas of the American West, the top predators – wolf, bear and mountain lion – were all hunted to extinction by humans.

These animals each had an important, unique influence on the forest, keeping it rich and diverse. For example, predators keep herbivore numbers in check – a lack of natural predators is a major reason why our ecosystems are out of balance and unhealthy. Numerous other, less obvious creatures have also been lost or had their numbers drastically reduced. Although BLM and USFS and livestock ranchers will say otherwise, Juniper trees are a succession species that grow slowly and naturally in high desert ecosystems and are very beneficial for the land through their ability to stop erosion, provide shelter and forage for wild animals and transpire moisture throughout the year.

However, the livestock community wants them eradicated in order to provide more grassland for grazing and BLM is accommodating this on a large scale – paid for with our tax dollars and at the sacrifice of the health of our public land.

(the basis for these thoughts was inspired by and excerpts borrowed from the following)

http://www.treesforlife.org.uk/forest/humanimpacts/deforestation.html   http://creating-a-new-earth.blogspot.com/2014/04/pretzel-logic-denial-of-science-is.html

Exhibit #8

Fuel breaks act as corridors for invasion by invasive species due to reductions in canopy cover and competing vegetation.

FUEL BREAKS AFFECT NONNATIVE SPECIES ABUNDANCE IN CALIFORNIAN PLANT COMMUNITIES Merriam K.E., J.E. Keeley, and J.L. Beyers (Ecological Applications, 16(2), 2006, pp. 515-527) Abstract. “We evaluated the abundance of nonnative plants on fuel breaks and in adjacent untreated areas to determine if fuel treatments promote the invasion of nonnative plant species. Understanding the relationship between fuel treatments and nonnative plants is becoming increasingly important as federal and state agencies are currently implementing large fuel treatment programs throughout the United States to reduce the threat of wildland fire. Our study included 24 fuel breaks located across the State of California. We found that nonnative plant abundance was over 200% higher on fuel breaks than in adjacent wildland areas. Notably, while the EA purports to monitor invasive species, given the expansive use of fuel beaks, mitigation appears grossly inadequate. We request that you include a literature review on problems and limitations of fuel breaks, and more substantial invasive species containment measures. This is of particular concern as fuel breaks will require periodic maintenance (adding to undisclosed project costs), could become de facto roads for ORVs and cattle that act as vectors of invasive species spread along with uncharacteristic fire ignitions. In particular, if fuel breaks are colonized by grasses (especially cheatgrass), they will contribute to fire spread and dangerous conditions for firefighters.”

Exhibit # 9

The Troubles of “Invasive” Plants: Collateral Damage, Monsanto, and the Tragedy of Pinyon-Juniper eradication by NICOLE PATRICE HILL – KOLLIBRI TERRE SONNENBLUME (excerpt)

In this part we discuss: a) the negative effects of invasive plant removal methods, b) the involvement of Monsanto in popularizing invasion biology, and c) the tragedy of Pinyon-Juniper forest eradication in the western U.S. under the rubric of “native invasive species management.” The U.S. federal government defines it as “an alien species whose introduction does or is likely to cause economic or environmental harm or harm to human health.” Similar accusations of “encroachment” by native flora are currently playing out with tragic circumstances in the western USA, where native Pinyon-Juniper forests are being eradicated. Commercial interests have also been involved in defining what species are invasive and in drafting the official policies that guide the “management” of such species. As we discuss below, Monsanto has played no small part in the US federal stance. They and other chemical companies profit from the sale of herbicides used in so-called “restoration.” “Invasive” plant species are removed using a variety of methods that can be classified into three broad categories: mechanical, biological and chemical. Few are effective at removing their targets without killing non-targets, and only then at very small scales. As the size of a particular project grows, so does the likelihood of unintended consequences and collateral damage.

Mechanical means include mowing, tilling, prescribed burning, chaining, or scraping the land with a dozer or grader. Each of these processes varies in its precision (as measured by how many non-target species are also affected). Some, such as burning affect all plants in the area of application. The particularity of others depends on the tools or materials used and on the operator’s skills, attention and concern. The result is damage to non- “invasive” plants, the ones whose well-being is ostensibly of such strong interest.

Further, non-target species are not limited to plants. Animals can also be displaced, injured or killed by all of the above methods. Burrowing mammals and reptiles can be chopped up, buried, asphyxiated, drowned or have their homes excavated. Insects are harmed in their various life-stages. The time taken to recover from the disturbance made by mechanical means differs depending on method, climate, season, etc. A much longer time is needed when a Pinyon-Juniper woodland is “chained,” a process in which a very large chain is dragged between two tractors, uprooting everything in its path. Not only do trees need multiple decades to grow back, but the time required for certain soil-borne mosses in these ecosystems to completely regenerate might be well over two centuries. Additionally, mechanical means can actually encourage the reproduction of particular plants that thrive on certain disturbances. Too often, saving a buck is more important than doing the best job. Domesticated animals are also used to eradicate invasive plants, but their role in these efforts is quite small compared to other methods. More significantly, cattle and sheep have played a major role in the distribution of non-native plant species, and in some areas—such as the arid non-agricultural west of the USA—have been one of the main vectors.

Chemical methods for eradicating invasive plants are the most common because they are cheap and effective. Of course, they are also effective at killing non-target plants, and that result is quite common. In fact—and shockingly—less than 1% of a sprayed herbicide application ends up being delivered to the intended target. The remainder—if one can use that word to mean “the vast majority”—is dispersed into the surrounding environment. As a science, it’s quite a far cry from “exact.” A 1% success rate in just about any other endeavor would be considered a dismal failure.

What do the “extra” chemicals do? Let’s look at glyphosate, the most commonly used herbicide in the world, which is manufactured by Monsanto and is the active ingredient in their notorious product, Round-Up. As a “broad spectrum” agent, it kills many kinds of plants, both terrestrial and aquatic, including algae. Additionally, glyphosate destroys beneficial bacteria and microorganisms in the soil, complicating recovery for native plants who no longer have the soil components required for health. As if that wasn’t enough, the bacteria that break down herbicides increase in number, further throwing off soil balance. Soil structure is also detrimentally effected. In the Animal Kingdom, glyphosate is also highly problematic. It can cause genetic damage in fish, and also disrupt their immune systems… can cause genetic damage in insects… [and] can harm amphibians in a variety of ways, including causing genetic damage and disrupting their development.” In humans, “symptoms of exposure to glyphosate include eye irritation, burning eyes, blurred vision, skin rashes, burning or itchy skin, nausea, sore throat, asthma and difficulty breathing, headache, lethargy, nose bleeds, and dizziness” and it has been associated with “increased risks of the cancer non-Hodgkin’s lymphoma, miscarriages, and attention deficit disorder.

The use of any herbicide at all that kills non-target, native species reduces the area’s biodiversity, and not just of the plants. Any animals and insects that depend on those plants are also impacted. Furthermore, these holes punched in the ecosystem adversely affect the natural processes of succession that previously existed. Direct exposure to herbicides is not necessary to suffer from them. Through a process known as “biomagnification,” levels of toxins increase in the natural food chain. So, a tainted plant is nibbled by a mouse who is eaten by a snake who is caught by a bird of prey. Not only is the bird poisoned, but the resulting level of accumulation is at a higher concentration than would happen through direct exposure. The more that herbicides are used, the more that certain target plants can adapt and survive. “Pesticide resistance” has become a real issue, and the solution so far has been to apply more poisons, which of course leads to more “collateral” damage. It’s a vicious cycle that we cannot afford to continue.

Exhibit #10

A pointless, brutal tragedy is currently taking place in the Great Basin of the US American west: the destruction of native Pinyon-Juniper forests. Old growth trees are being clear-cut, shredded and mulched. Collateral damage is being suffered by the vibrant community of flora and fauna these forests host. As noted by biologist Katie Fite, this campaign against Pinyon-Juniper forests is the third wave in a series of massive assaults in US history. The first happened in the second half of the 19th Century when “trees were clearcut over vast areas—even their roots dug out—to produce charcoal to process gold and silver ore.” The purpose of the second wave, after WWII, was to clear land for ranchers. Trees were cut, chained, sprayed and burned on a large-scale basis until the 90’s. Three million acres were converted to pasture between 1950 and 1964, and more than a third of a million acres between 1960 and 1972, in Utah and Nevada alone.

The current wave is being spearheaded by the BLM and the Forest Service and once again for the benefit of ranchers, though that’s not how it’s being presented. Instead, the ostensible reasons are to improve Sage- G rouse habitat, control wildfires, and halt the spread of so-called “native invasive” species, a new label being pinned on the Pinyon and Juniper trees. How can the Pinyon tree be “encroaching” when it has lived in the area for so long? The Single-Needled Pinyon (Pinus monophylla), which is the dominant Pinyon species in Nevada and to the west, originated around 20 million years ago as a mutation of the Colorado Pinyon (Pinus edulis).[4] That makes P. monophylla 100 times older than Homo sapiens, which only goes back 200,000 years.

The BLM “treatments” in the Great Basin, both proposed and ongoing, include “lop and drop,” mastication, herbicides and chaining. Chaining involves attaching a huge anchor chain from a battleship between two tractors and dragging it along the desert floor, ripping trees and bushes from the ground, wrecking delicate soil crusts, and killing or injuring countless other creatures in their dens, nests and hideouts.

Exhibit #11

NEPA requires that an agency take “a hard look” at the impacts of an action prior to making an irreversible and irretrievable commitment of resources;

(Quote from Page 36 of EIS)

“The locations of cultural resources are recorded through site- and project- specific inventories. Only portions of the project area have been inventoried to current standards, so the affected environment for cultural resources can be described in general terms only, until the fuel breaks locations are defined and required site- and project-specific inventories and analyses are conducted. The identification and location of tribal resources and tribal interests in projects is also determined on a site- and project-specific basis. Although tribal members may use BLM-administered land resources for cultural, religious, and subsistence purposes, the BLM may not know specific locations of resources or the traditional importance of some areas. Tribal members may be reluctant to share knowledge of areas of traditional importance outside their own communities based on maintaining cultural values and religious perspectives. While specific locations of tribal resources relevant to fuel breaks cannot be determined, tribal resources that have been identified as part of the affected environment of the project area.”

The above EIS statement proves the bias and inadequacy of the current proposal. The NEPA law requires that all relevant scientific information be provided to the American public and that that information be taken a “hard look” at by the decision makers. The National Environmental Policy Act (NEPA) requires that to ensure that environmental assessment statements reflect a careful consideration of the available science, and that areas of disagreement or uncertainty are flagged rather than being swept under the carpet. Thus, the public and the decision makers must resist the urgings of agencies that low-probability risks of very serious harms be dismissed from consideration or that the risk is evaluated only under the agency’s favored theoretical model without taking into account the possibility that other credible models might be correct.

Summary – As an experienced Environmental Researcher, I require that my above public comments be included in the Administrative record for the EIS proposal. Alternative “A” (NO ACTION) is the only viable, legal and worthwhile option currently proposed by this Environmental Impact Statement (EIS).