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July 20, 2008
BLM Lander Field Office RE: Lander Resource Management Plan Revision Dear Kristin, The Wyoming Wilderness Association appreciates this opportunity to comment on the Lander Resource Management Plan (RMP). The Wyoming Wilderness Association (WWA) is a 501 (c)(3) conservation organization with over 500 members statewide who are deeply concerned by the accelerated rate of development throughout Wyoming. Our primary concern is the preservation of official and proposed wilderness study areas and roadless areas throughout the state. This includes the protection of wildlife, plants and the various scenic, archaeological and geological resources within these areas. The maintenance of such pristine areas is important for multiple reasons: · Preservation of unique ecosystems and wildlife habitat · Visitors through hiking, fishing, hunting and horsepacking opportunities · Scientific study of natural environments As our wild lands nationwide continue to be consumed by human development, we feel our cause to be increasingly urgent. The Lander Management area also contains high plain and desert lands of extreme beauty and remoteness, and is one part of Wyoming we feel needs particular attention and good stewardship. The RMP, in providing future direction for 2.5 million acres of surface and 2.7 million acres of BLM administered minerals in Central Wyoming, needs to restore the balance of management in protecting these resources However, despite the Lander RMP area’s ample wildlife, plant, geological and historical resources, the BLM has been modest in its designation of wildlands. The region harbors numerous endangered, protected and rare plant and animal species in many different ecosystems, as well as several roadless areas large and preserved enough to qualify for wilderness. Our organization focuses specifically on officially designated wilderness areas as well as Wilderness Study Areas and Citizen’s Proposed Wilderness (CPW) areas. As we watch human evidence of human disturbance spread across the land and the rate of energy and industrial development accelerate, the use of CPW to promote and expand wild lands protection is highly warranted. Though Congress has not acted upon the designation of Wilderness areas, the BLM needs to meet the basic guidelines for managing WSAs as defacto wilderness. In this draft of the RMP, we hope that you closely examine the wilderness qualities of the WSA and CPW areas and consider extra protective measures, and designate the CPW as wilderness study areas officially. Our wildland treasures are diminishing at an unprecedented rate which must be stopped. Within a large portion of the Lander RMP area lies the Wind River Basin, containing several Citizen’s Proposed Wilderness areas and WSAs. These areas should be managed for the preservation of their unique wildlife and environmental qualities. ORV use, new grazing leases and mineral leases are prohibited. We also strongly urge a highly regulated buffer zone between them and less regulated areas. One highly valued WSA is the Dubois Badlands, which has also been designated by the BLM as an ACEC. With its herds of elk and trophy-producing Bighorn mountain sheep, visitors to the area may find ample hunting opportunities. Surveyors have found the Canada Lynx and Boreal Western Toad (both candidates for Federal Threatened and Endangered listing), as well as the highly uncommon red bat and river otter. Additionally, the area is inhabited by bald and golden eagles, prairie falcons and osprey, all of which are sensitive to habitat disturbances. In the wintertime the areas provide vital habitat for antelope, elk, and mule deer. The region contains numerous riparian zones that form vital habitats for plants and animals. Many sensitive plant species have been recorded here in the past five years, including the dubious milkvetch, nuttall Townshend-daisy, Jones’ columbine and sweet-flowered rock jasmine. Though complete archaeological surveys of this area have not been conducted, the Dubois Badlands contain several sites of value. Artifacts occur here from the valley floor to high peaks and represent human occupation over thousands of years. We ask that the Dubois Badlands continue to be managed as an ACEC and WSA and that the BLM consider and mitigate the impacts of development near or bordering the area. Whisky Mountain lies across the valley from the Dubois Badlands. Though the CPW area is 6,000 acres worth of wilderness designation, the BLM only protects 487 acres as a WSA. Whisky Mountain has plenty of wildlife, plant, and visual resources, all of which would be easily disturbed by human development. This Citizen’s proposed wilderness and WSA is nationally known for its herd of Bighorn Mountain sheep. Fishermen will find a large variety of cold stream fisheries in the area, supporting brook and brown trout. Whisky Mountain is frequented by horsepackers and visitors hoping to observe wildlife amid outstanding vistas of the Wind River Valley, Dubois Badlands and Absarka range. The area is geologically important as well. It contains 600,000 year-old layers of volcanic ash from Yellowstone, the only known ash-deposit site in the northwest part of the wind-river basin. Cultural history in the area is generally believed to have sprung up about 12,000 years ago, when the first groups entered the region and existed relatively uninterrupted until present times. The town of Dubois itself has stated they would like to see no ORV use on Whiskey Mountain and that it be managed for protection of the Bighorn sheep. Both Whisky Mountain and the Dubois Badlands lie in the greater Dubois area where WWA advocates for no new leasing on any BLM mineral estate in the area. The area is part of the primary recovery area for grizzly bear habitat, as well as providing important winter range for elk and Bighorn sheep. According to the Wyoming Outdoor Council, there is little potential for successful oil and gas exploration here. Therefore, we believe wildlife and wildlands should take precedence in the protection of the area. The BLM must carefully consider how they are going to monitor and enforce the implementation of the RMP. There is evidence of the BLM’s lack of attention in many places. For example, in the Dubois area, it seems the BLM has been unable to enforce their own ORV closure. This can be seen in the badlands, where the steep canyon walls are riddled with ORV tracks. Public testimony has repeatedly indicated that an ORV closure should be enforced in the area, regardless of wilderness designation, and we concur. The BLM must work out a more effective plan to ensure their policies are being abided. Northeast of Dubois, near Shoshone are the Lysite Badlands and Lysite Mountain. These areas contain grasslands, badlands formations, and sand dunes which provide excellent primitive recreation opportunities and avian habitat. The area contains golden eagles and Ferruginous hawks- both candidates for Federal protection. The area also provides a suitable environment of Porter’s sagebrush, a rare endemic not represented in the wilderness preservation system. The Lysite Badlands have been recommended by the Nature Conservancy for special management status due to the high occurrence of Porter’s sagebrush in these areas. The badlands contain rock formations from numerous geological epochs with a multitude of fossils. The Lysite Badlands also contains soils of unusual geologic makeup. Here, the springs and creeks are naturally so alkaline, the Badlands were declared to be “one of the most poisonous areas in North America” (Love, 10/6/92). Lysite Mountain itself is one of the most geologically significant areas in the state as it is the only place where the late Cenozoic record is preserved. Considering the high occurrence of drought and low forage area, we recommend the BLM should manage livestock levels to alleviate severe over-grazing and to improve conditions for Porter’s sagebrush and wildlife. Twelve sections surrounding the WSAs and CWP areas should be designated as an ACEC. Copper Mountain area is another CPW located near the popular Boysen Reservoir and Boysen State Park. The fascinating topography of drainages, peaks and outcroppings ensure visitors seclusion and solitude as well as presenting exceptional recreational challenges. Copper Mountain provides nesting sites for endangered peregrine falcons, bald eagles and crucial winter range for mule deer and pronghorn antelope. Townsend’s big eared bats- a State Priority Species—have been observed hibernating in the Copper Mountain. The area contains two valuable plant species, Owl Creek miners candle, and Hapeman’s Sullivantia, both candidates for Federal listing and require special management. No cultural resource inventories have been completed in the CPW area, but the region has been occupied by humans for at least 12,000 years. The Birdseye Pass Stage Line ran along the eastern boundary of the study area from the 1880s to the early 1900s and deserves special attention for its significance to the history of Wyoming. The Sweetwater Rocks region is the one CPW and WSA in the Natrona County region of the Lander RMP. This region contains Lankin Dome, Split Rock, Miller Springs, and Savage Peak. The region is renown for its jagged rock formations and contains several key landmarks of wagon trains on their way to Oregon, California, and Utah. This is an area in various degrees of recovery from past exploitation. Here once lived the Big Horn sheep, grey wolf and peregrine falcon, none of which have been seen for decades. Currently, the area provides crucial winter habitat for mule deer, as well as yearlong habitat for golden eagles, prairie falcons, red-tailed hawks, sage grouse, bobcats, coyotes and other species. Sweetwater Rocks contains an ancient buffalo jump and butchering site as well as fields of arrowhead and scraper chippings. The Rocks represent a complex intertwining or rock and vegetation. This region has already been exploited enough, as far as rare species, but still qualifies for wilderness designation. WWA urges the BLM to provide this delicate region with additional protection. Aside from the CPW and WSAs, the issues of wildlife, habitat, geology and history are pertinent to the regions surrounding them. Sections of the Lander Management Area may have been developed, but still contain valuable ecosystems. The plant and wildlife species should be given special protection and mitigation throughout the Lander RMP, as they are important resources for the state of Wyoming. Development scenerios will have substantial impacts on the experience of visitors and quality of life for those who live and recreate here. That said, the BLM would do well to ensure their decisions are made using current data. Thus, the EIS should include thorough inventories of all wildlife, ecosystems and plants within the area. Additionally, the BLM should carefully research the effects of the implementation of the past RMP. The cumulative impacts analysis should include detailed information of the amount of wildlife habitat and open space lost to development over the life of the last plan, and the effects of these losses on the overall population and health of the ecosystems within the management area. The BLM should look closely before building new roads. Habitat fragmentation from development can have serious repercussions for migration routes and other ecological linkages. Current corridors should be maintained whenever possible, as opposed to new ones being created. Where ORV use is allowed, in a CPW or anywhere, motorized use and trails should only be located to minimize damage to soil, watershed, vegetation, air and other resources of the public lands. To prevent impairment of wilderness suitability areas and trails should be located to minimize harassment of wildlife or significant disruptions of wildlife habitats, with special attention being given to the habitat of endangered species. Areas and trails should be located to minimize conflicts between off-road vehicle use and other existing or proposed recreational uses of the same or neighboring public lands. FLPMA explicitly provides that the alternative plans that are developed need not accommodate all resource uses on all lands. BLM must fully consider placing areas off limits to oil and gas leasing, subjecting areas to leasing subject to No Surface Occupancy stipulations, as well as making areas available for leasing subject to appropriate timing and controlled surface. While creating the RMP please take into consideration and note mitigation in detail for the following in the entire Lander Resource Management area, not just the CPW areas mentioned above: RARE PLANT SPECIES: Please inventory plant communities and species for rare, threatened or endangered plants that may reside in the area. WILDLIFE CRITICAL HABITAT and MIGRATION CORRIDORS: identify and protect. WATERSHEDS AND FISHERIES: maintain 300 feet buffer on all streams and watersheds. Require stream crossings to be protected from sedimentation. Close temporary roads after roads. Enforce closures. SOIL DISTURBANCE: Proper mitigation and avoidance of some areas will reduce soil disturbance to ensure regeneration.. It is the vision of the Wyoming Wilderness Association that the Lander RMP areas that are currently protected remain as such and that, in thoroughly researching and inventorying the resources of the area, any new areas may be identified and protected. For it is the responsibility of the BLM to protect these resources. Our members advocate for land use that includes quiet recreation, great fishing and wildlife hunting and wilderness appreciation. Legally speaking, in many cases the BLM is fully required to consider the necessities for maintaining the pre-existing habitat above the necessities of commercial development. In the legal case of Mineral Policy Center v. Norton, 292 F. Supp.2d 30, 42 (D.D.C. 2003) “Congress’s intent was clear: (The Department of) Interior is to prevent, not only unnecessary degradation, but also degradation that, while necessary to mining, is undue or excessive…FLPMA, by its plain terms, vests the Secretary of the Interior with the authority—indeed the obligation—to disapprove of an otherwise permissible mining operation because the operation, though necessary for mining , would unduly harm or degrade the public land”. Thus, it is clear that despite an area being leased for private, corporate use, the BLM has ample authority to put the best interest of the environment above any potentially destructive capitalistic needs of the leasee. That is, in the face of potential development, the BLM is obligated to ensure that the land may continue to not only exist, but thrive in its most natural state. We are all doing what we can as individuals to be good conservationists in our own homes and lives. We expect the stewards of our public lands to do likewise. The BLM must begin to think locally and plan globally and maintain the wildlife and quality of life that we have enjoyed for generations. We ask that you take the greatest good of the Lander Area RMP wildlife and environment in to consideration. Please put us on your mailing list for future RMP public comment opportunities. Sincerely,
Sally Western, Intern
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