Letter

15 Wildlife Scientists Urge Interior Secretary Sally Jewell to Finalize Strong Plans for Greater Sage-Grouse Habitat

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United States Department of the Interior
Attn: Secretary Jewell
1849 C Street, NW
Washington, DC 20240

Dear Secretary Jewell,

We are writing to you today to express our concerns regarding the management plans drafted by the Bureau of Land Management (BLM) for the greater sage-grouse. As scientists who have spent considerable time in our careers studying the life history and habitat relationships of wildlife, including the greater sage-grouse, we appreciate and applaud the BLM’s effort to revise applicable management plans to effectively conserve this important species for the long-term. We recognize the substantial advancement in science-based management approaches the draft management plans represent. Despite our enthusiasm and support for the agency’s effort, we are writing to express concerns over the lack of consistency and scientific rigor in the management plans drafted by BLM for the greater sage-grouse. We believe that if the currently-proposed preferred alternatives in the 15 sub-regional draft resource management plan amendments are carried forward to final decisions, the resulting plans will be scientifically inadequate.

We understand that BLM leadership is reviewing these draft plans and also holding Federal Family meetings to discuss consistency and adequacy of conservation measures in these plans relative to recommendations within the National Technical Team (BLM) and Conservation Objectives Team (USFWS) sage-grouse reports. We realize that final plans will likely differ in substantial ways from the draft plans. We applaud and encourage these efforts, and we urge you to encourage the BLM to normalize and strengthen – using the best available science – proposed management restrictions in their sub-regional sage-grouse plans, and to make certain that BLM has put in place rigorous approaches needed to accomplish this task, including increased support from other DOI agencies.

Our concerns stem from two basic observations about the 15 draft management plans released over the last 2 years:

  • First, there are significant variations in the proposed management prescriptions across the draft management plans, essentially creating 15 different management approaches to sage-grouse conservation within and across state boundaries.
  • Second, there are several gaps between best available science regarding sage-grouse conservation findings and the extent these findings are addressed by management prescriptions in the preferred alternatives of draft management plans.

The greater sage-grouse is an indicator species for the health of the interior West’s sagebrush steppe ecosystem, and management and conservation of its habitat must be considered at landscape scales. Today, the bird is present in just over half its historical range and lek size for the majority of populations (71%) across the range of the species has declined since the 1960s. Declining populations and reduced distribution led the USFWS to conclude that the greater sage-grouse warrants protection under the Endangered Species Act. There exists a vast library of published literature on sage-grouse to assist the development of conservation and management measures for the bird and the sagebrush-steppe ecosystem; this literature is extensively summarized in volume 38 of Studies in Avian Biology (Greater sage-grouse: ecology and conservation of a landscape species and its habitats edited by Dr. S. T. Knick and Dr. J. W. Connelly) as well as the USGS’s science summary report: Summary of science, activities, programs, and policies that influence the rangewide conservation of Greater sagegrouse (Centrocercus urophasianus) (Manier et al. 2013). However, we recognize that not everything is known, especially in regards to managing sagebrush ecosystems to improve the quality of those habitats for sage-grouse (e.g., mitigation). As such, a consistently applied and rigorous approach to management direction, evaluation and adaptation is critical—this includes the incorporation of the best available biological and spatial data in a transparent, repeatable and defensible process meant for informing and evaluating on-the-ground management actions.

We believe the BLM must make conservation measures more consistent in its final sage-grouse plans.

Our first point concerns inconsistency in the BLM’s preferred management prescriptions across the 15 draft plans. We recognize that some variation is driven by differences in habitats across individual states as well as the sagegrouse conservation plans developed by the individual states. As such, some variation in conservation measures might be appropriate based on differences in the ecology of sagebrush habitats. However, variability within and across state boundaries established by the draft plans has little to do with variability in sage-grouse habitat or life history, resulting in a confusing, scientifically unjustifiable set of standards across the range of the species. Despite the explicit need for a landscape-level approach to sage-grouse conservation, the individual and highly inconsistent 15 draft plans result in different rules for different places determined primarily by administrative boundaries. For example, proposed regulations for fluid mineral development span from a 5% surface disturbance threshold with a 0.6-mile No-Surface-Occupancy (NSO) buffer around leks in priority habitats in Wyoming, to a 3% surface disturbance threshold and no NSO in priority habitats in South Dakota, to a 3% surface disturbance threshold with a 4-mile NSO in priority habitats in Oregon, to an NSO in all priority habitats in Montana, to a no net unmitigated loss of priority habitat in California and Nevada. The result of these observations is a high degree of management inconsistency between and among plans, despite the need for shared common management approaches based on the best available science. We recognize that some of the inconsistency stems from a lack of criteria provided by the USFWS especially for the identification of Priority Areas for Conservation (PACs), but coordination among managing agencies at both federal and state levels is necessary for consistent and effective management of the species across its range. For the most part, we believe that both the science and policy guidance exists; the plans simply need to manifest this information in a more consistent fashion to address threats to sage-grouse within their preferred alternatives.

We believe the BLM must strengthen its final sage-grouse plans to conform with the best available science.

Our second point, concerning gaps between best available science and the preferred management prescriptions across plans, is based on a comparison of peer-reviewed scientific literature regarding sage-grouse sensitivities to human activities and the means through which the 15 plans propose to mitigate these impacts. For example, the scientific evidence supporting the use of prescribed fire for sage-grouse conservation is scant while considerable information documenting negative effects of fire on sage-grouse exists (as summarized by the Sage and Columbian Sharp-tailed Grouse Technical Committee 2009). Examinations of fire rotation intervals suggest that fire exclusion – or fire suppression efforts – had little effect on sagebrush ecosystems; instead, the amounts of fire have greatly increased relative to historic variation, especially in western portions of the species’ range (see Baker 2006 and 2011). Fire can lead to rangeland conversion from sagebrush-dominated to exotic annual grasslands, decreased ecosystem stability, and increased fragmentation in sagebrush systems—all known to be detrimental to sage-grouse population persistence. Prescribed fire might be of value in mountain big sagebrush communities (i.e., sagebrush communities that receive relatively high levels of moisture), but even in these communities the science suggests there often are limited benefits. Several published papers as well as the BLM’s Report on National Greater Sage-Grouse Conservation Measures (NTT Report 2011) conclude that managers should not consider prescribed fire as a management alternative for enhancing xeric sagebrush habitats, and that the use of prescribed fire in other sagebrush habitat types should be considered only when direct evidence warrants the use of this management alternative. Additionally, post-treatment management is critical to successful implementation and must be considered as part of the treatment process. And yet, the preferred alternative in many of the plans still maintains prescribed fire as a viable management option for improving all sagebrush habitats for sage-grouse, and post-prescription management generally is addressed cursorily. While we have chosen prescribed fire as an example to underscore the disconnect between and among BLM’s preferred management prescriptions and best available science, similar gaps exist in the draft plans regarding fluid mineral development and other surface disturbances, scientifically-rigorous approaches to habitat management, and the management of livestock grazing.

In summary, we believe that the inconsistencies of the current preferred alternatives do not add up to effective, landscape-scale conservation of sage-grouse habitats on federal public lands in the interior West that are administered by the BLM. We strongly urge the Department to review the draft BLM plans in this light to ensure that each one is stronger and consistently based on the best available science, and that the plans, in totality, achieve effective and consistent landscape-scale management to adequately address all threats to sage-grouse habitat. We are available to consult with you and your staff about how science can better guide conservation of the greater sage-grouse on our federal public lands.

Sincerely,

Matthew J. Holloran, Ph.D.
Edward B. Arnett, Ph.D.
Jeffrey L. Beck, Ph.D.
Joseph R. Bohne
Clait E. Braun, Ph.D.
John W. Connelly, Ph.D.
Gregory D. Johnson
Thomas E. Remington, Ph.D.
Terry Z. Riley, Ph.D.
E. Thomas Rinkes
Brian A. Rutledge
Alan R. Sands, Ph.D.
Michael A. Schroeder, Ph.D.
Steven J. Slater, Ph.D.
Rollin D. Sparrowe, Ph.D.

Cc: John Podesta, Senior Advisor to the President, White House; Mike Boots, Acting Chair, Council on Environmental Quality; Jay Jensen, Associate Director for Land and Water Ecosystems, Council on Environmental Quality; Neil Kornze, Director, Bureau of Land Management; Dan Ashe, Director, U.S. Fish and Wildlife Service; Sarah Greenberger, Counselor to the Secretary of the Interior, Department of the Interior; Jim Lyons, Counselor to the Assistant Secretary for Land and Minerals, Department of the Interior; Michael Bean, Counselor to the Assistant Secretary for Fish, Wildlife and Parks, Department of the Interior.

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