HomeMy WebLinkAboutBLM Response - MillicanIN REPLY REFER TO:
6000 (ORP060)
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Prineville District Office
3050 N.E. 3rd Street
Prineville, Oregon 97754
Deschutes County Planning Commission
117 NW Lafayette Avenue
Bend, Or 977501
Dear Mr. Blikstad:
I am writing in response to your request for a Bureau of Land Management (BLM) review of information
contained in Exhibit 3 of LUBA Case No. 2010-082, File Nos. PA -04-8 / ZC-04-8. Exhibit 3 is a letter
prepared by Roger Borine on September 5, 2014 in which Mr. Borine makes an assessment and conclusion for
the effect of development and full operation of the Spencer Wells Mine on livestock and ranching operations.
It is my intent in this letter to simply point out factual information that exists within the BLM records. The
BLM has not completed an effects analysis of the proposed Spencer Well Mine. The information provided is
based on existing BLM land management direction and the most recent sage -grouse population and habitat
data available:
Upper Deschutes Resource Management Plan, 2005 (UDRMP):
Horse Ridge Allotment - deferred rotational grazing system, allowable allocation of up to 1,624 Animal
Unit Months, and identified the allotment as being in an Improve category; page 247.
The Leslie Ranch Coordinated Resource Management Plan (CRMP) - Horse Ridge Allotment:
Allowable grazing use dates: 3/1 to 2/28 for the allotments; 7/1 to 10/31 for Flat pasture.
Objective for the allotment: Maintain or improve deer and antelope winter range and sage -grouse habitat.
Improve the ecological condition.
The Leslie Ranch CRMP identified that winter livestock feeding as an allowable action if it were analyzed
in an environmental assessment (EA) and designed to benefit wildlife habitat. Such analysis and EA was
never done.
Sage -grouse habitat:
There are two sage -grouse leks within two miles of the subject property line with the closest being 1.19
miles from the property boundary.
Male lek attendance on the closest lek has been declining between 20 to 26% every seven years since the
lek was first surveyed in 1986.
Telemetry data collected in the 1990s indicated that sage -grouse used the Flat Pasture year round.
Telemetry records indicate nesting taking place within .17 miles of the subject property. During the
telemetry survey there was concentrated winter use within the Flat Pasture area.
The Flat Pasture is identified as Low Density sage -grouse habitat in the Oregon Greater Sage -Grouse
Conservation Assessment and Strategy (Hagen, 2011). Subsequently the BLM identified this area as
Preliminary General Habitat (PGH) in our 2011 National Technical Team Report (USDI 2011).
Mr. Borine's letter appears to make a conclusion that the effects of the mining operation would be minimal
thus there would be no need to adjust grazing in the Flat pasture. Future grazing decisions within the Horse
Ridge Allotment and specifically the Flat pasture would need to be consistent with existing overarching land
management direction in the UDRMP and any subsequent amendments for sage -grouse, as well as, consider
all direct, indirect, and cumulative effects to sage -grouse and other management issues identified through the
NEPA process.
Because the BLM has not done an analysis of the effects of the proposed mining operation on sage -grouse we
are not in a position to evaluate Mr. Borine's conclusions relative to the effects to sage -grouse from the
proposed mining operation. However, the BLM is currently developing the Oregon Sub -Regional Greater
Sage -Grouse Resource Management Plan Amendment/EIS (Draft EIS). When completed the plan amendment
will revise management direction for sage -grouse and their habitats within the UDRMP. The plan amendment
is using the most recent science to develop proposed management actions. The Draft EIS also analyzes
expected effects to sage -grouse and other resources if these actions were applied. The proposed actions and
effects in the Draft EIS are specific to BLM managed lands; however, they may provide you with insight into
the validity of effects and conclusions that Mr. Borine makes in his letter. The Draft EIS was released in
November of 2013 and can be accessed at: http://www.blm.gov/or/energy/opportunity/sagebrush.php
If the BLM were to do an analysis of grazing management for the Horse Ridge Allotment, mining on adjacent
lands would not be considered a connected action to livestock grazing. However; if the mine is allowed to
proceed the effects of mining on sage -grouse may be considered as part of a cumulative effects analysis.
Should a cumulative effect of mining and grazing be identified through the NEPA process, future management
decisions would still need to consider factors such as the significance of the effect, the types of management
actions that could address the effect, the type of correlation between the two actions, and many additional
factors before making a decision to change the current grazing management direction. Without such an
analysis it is not practical to say what, if any, recommendations would be made for the Horse Ridge Allotment.
I hope the information provided helps with your assessment. If you have further questions regarding this
public land management adjacent to the proposed Spencer Well Mine please contact our Wildlife
Biologist,Monte Kuk or me at (541) 416-6700.
Sincerely
Molly M. Brown
Field Manager, Deschutes Resource Area