Decision Notice and Finding of Significant Impact

United States 

Department of 

Agriculture 

Forest 

Service 

April 2012 

Decision Notice and 

Finding of Significant Impact 

Priest Lake Grazing Allotments 

Priest Lake Ranger District, Idaho Panhandle National Forest 

Bonner County, Idaho

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Decision Notice and Finding of No Significant Impact 

Contents 

I. Decision and Rationale ................................................................................................................... 2 

II. Findings Required by Other Regulations and Policies ............................................. 14 

III. Finding of No Significant Impact ........................................................................... 16 

IV. Review and Appeal Opportunities .......................................................................... 20 

V. Implementation Date ................................................................................................ 21 

Appendix A – Response to Public Comments ............................................................ A-1 

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ii 

Location of the Grazing Allotments


Decision Notice 

& Finding of No Significant Impact 


United Stated Department of Agriculture, Forest Service 

Idaho Panhandle National Forests, Priest Lake Ranger District 

Bonner County, Idaho 

Introduction 

The Idaho Panhandle National Forests prepared an Environmental Assessment (EA) to analyze 

the environmental effects of various alternatives regarding livestock grazing on the Four Corners, 

Lamb Creek, and Moores Creek Allotments of the Priest Lake Ranger District. The EA was 

completed in February 2011 and distributed for public comment. This Decision Notice (DN) is 

based on that EA and the public comments that were received. It serves to document my decision 

on how to proceed with the Priest Lake Grazing Allotments. 

Purpose and Need 

The need to complete environmental analysis for the Priest Lake Grazing Allotments was 

triggered by the expiration of grazing permits for the allotments and the requirements of the 

Rescission Act. The need for action on the Priest lake Grazing Allotments and the passing of HR 

1944 (The Rescission Act) are closely linked. On June 30, 1995, the U.S. Senate passed HR 1944 

requiring each National Forest Unit to establish and adhere to a schedule for the completion of 

National Environmental Policy Act (NEPA) analysis and decisions on grazing allotments within 

the National Forest System unit for which NEPA analysis is lacking. There is also a need to 

determine conditions under which term grazing permits will be reissued and new allotment 

management plans prepared. 

The purpose of the project is to: 

Implement through the Allotment Management Plan (AMP) the direction and objectives of 

the Idaho Panhandle Forest Plan (1987). 

Evaluate the effects of livestock grazing on Endangered Species Act (ESA)-listed species, 

sensitive plant species and Forest species of concern. Since the AMPs were originally 

approved, several conditions have changed including the presence of ESA-listed species i.e. 

bull trout, Canada lynx, and grizzly bear. 

Redefine allotment boundaries to exclude non-National Forest System lands and National 

Forest System lands which may no longer be suitable for grazing. 

Continue to provide a social and economical base for appropriate livestock grazing in 

compliance with the Forest Plan. 

Comply with the Rescission Bill 

Background 

The grazing allotments are located in Bonner County, Idaho, on the Priest Lake Ranger District of 

the Idaho Panhandle National Forests (Figure 1). The following allotments were evaluated: 

Four Corners - BM, T. 57 N., R. 5 W., Sections 5, 6, 8, 9, 17, 18, 19; BM, T. 57 N., R. 6 W., 

Sections 1, 12, 13, 24. 

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Lamb Creek - BM, T. 60 N., R. 5 W., Sections 7, 8, 9, 10, 14, 15, 16, 17, 18, 19, 20, 21, 23, 

26, 27, 28, 29, 30, 33, 34, 35; WM, T. 35 N., R.46 E., Section 6; WM, T. 36 N., R. 46 N. 

Section 31. 

Moores Creek - BM, T. 58 N., R. 5 W., Sections 7, 8, 16, 17, 18, 20, 21, 22, 23, 27, 28, 29, 

33, 34. 

When this project was initially opened for public comment, the Boswell, Lower Squaw Valley 

and Upper Squaw Valley grazing allotments were included in the analysis. However, after 

conducting a suitability analysis, it was determined that these allotments were no longer 

providing viable grazing. These three allotments were removed from the project and closed to 

livestock grazing in an administrative action signed by the Forest Supervisor in July 2008. 

Hammond Ranch Pasture, part of the Boswell allotment, was to be left open to grazing through 

the 2010 grazing season, at which time it would be closed. The Hammond Ranch Pasture was not 

included in this analysis since the decision to close it at the end of the 2010 grazing season was 

made in the administrative action closure letter dated July 2008. The Priest Lake Allotment 

Closure letter and rationale for this decision are located in the Suitability Analysis for the Priest 

Lake Ranger District Livestock Grazing Allotment Closure, included in the project file. 

I. Decision and Rationale 

The Selected Alternative 

After careful review of the environmental assessment (EA) for the Priest Lake Grazing 

Allotments, the Finding of No Significant Impact (FONSI), comments from the public, resource 

reports, and the project file, I have decided to implement a combination of two alternatives 

that were analyzed in the EA. I have selected Alternative 2 (Proposed Action) for the Lamb 

Creek and Moores Creek allotments and Alternative 3 (Grazing Phase-Out) for the Four 

Corners allotment. Following is a description of the applicable portions of these alternatives: 

Alternative 2 - Lamb Creek and Moores Creek Allotments 

Lamb Creek 

Reduce size of the allotment from 6,181 to 3,911 acres and redefine the allotment boundary. 

Maintain the permitted head months at 128, which is equivalent to 25 cow/calf pairs from 

June 1 through October 31 and/or range readiness. 

Moores Creek 

Reduce size of the allotment from 2,984 to 1,925 acres and redefine the allotment boundary. 

Maintain the permitted head months at 128 which is equivalent to 31 cow/calf pairs from 

June 1 through October 2 and/or range readiness. 

An approximately 16-acre parcel lying west of Moores Creek in Sections 21 and 28 will be 

incorporated into the allotment. 

Following discussions with the permittee on the Moores Creek Allotment, I am adjusting the 

permitted grazing dates to reflect the period of likely livestock utilization. The Moores Creek 

allotment is generally not ready to graze until after June 1st, so I have changed the allotment 

opening date to June 1st (and/or range readiness) from the May 15th date presented under 

Alternative 2 in the EA. Most of the use on the Moores Creek allotment occurs after August 

31st. I have changed the end date of the permitted grazing season from September 15th to 

October 2 nd in order to more accurately portray and accommodate this use. The grazing 

season may still be extended or curtailed as warranted by conditions on the ground or 

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feedback from the Adaptive Management Implementation Team. The permitted 128 head 

months would not be exceeded in any case. I have conferred with the interdisciplinary team, 

and they are comfortable with these changes to the permitted grazing dates. We have a 

monitoring plan and adaptive management strategy in place to detect any problems and 

develop solutions as the need arises. 

Alternative 2 incorporates management flexibility by providing a range of allowable numbers of 

cows and seasons. This alternative also provides for adjustments in the timing and duration of 

grazing annually to reflect variations in resource conditions and management objectives over 

time. Annual permitted livestock kind, class, and numbers will be specified in annual operating 

instructions. Herd movements will be determined by utilization levels specified in the design 

criteria for this alternative. Forage conditions and water availability will be specified in annual 

operating instructions. The changes in management proposed under this alternative are designed 

to reduce grazing duration and improve livestock distribution. 

New allotment management plans (AMPs) will be developed for the Moore Creek and Lamb 

Creek allotments. The plans will include design criteria for this alternative and Best Management 

Practices (Appendix A of the EA) to avoid or minimize effects to vegetation, heritage resources, 

wildlife habitat, soil and water quality. Monitoring of forage availability and utilization, range 

readiness, and other resource conditions (Appendix B of the EA) would be used to determine 

whether management is being properly implemented and whether the actions are effective at 

achieving or moving toward desired conditions. 

Alternative 2 is designed to utilize adaptive management. Adaptive management is a type of 

natural resource stewardship that involves making decisions as part of an on-going process. 

Monitoring the results of actions will provide a flow of information that may indicate the need to 

change a course of action. Scientific findings and the needs of society may also indicate the need 

to adapt resource management to new information. If monitoring shows that desired conditions 

are not being met, then changes in livestock management may be needed. The intensity of 

livestock grazing could be adjusted up or down in the Annual Operating Plan. The 

implementation or tuning of herding, salting, water distribution, fencing, season of use, duration 

of grazing, and stocking rate could all be potentially utilized to make the necessary adjustments. 

Additional monitoring would then take place to see if adaptive management worked as planned. 

The monitoring plan and adaptive management strategy options associated with this alternative 

can be found in Appendix B of the EA. See Table 2 of the EA for a detailed description of the 

Moore Creek and Lamb Creek allotments, and the EA map packet for the changes to the 

allotment boundaries. 

Design Features for the Moore Creek and Lamb Creek allotments under Alternative 2 

Livestock Management 

Salt and supplements would be placed in a container at approved sites at least ¼ mile, 

where feasible, from water or as otherwise approved by the Forest Service. 

Existing improvements would remain, i.e. fences and cattleguards. Improvements and 

salt stations may be relocated or additional ones created as deemed necessary under the 

adaptive management approach. Improvements no longer needed would be removed as 

time and funding permit. 

The permittee may be requested to assist in noxious weed treatments within the 

allotment. This may involve hand pulling, bio-releases, or chemical treatment. 

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The permittee would notify the Forest Service permit administrator of the location of 

any new populations of noxious weeds located on the allotment. 

OHV use would be approved by the permit administrator prior to use. 

Forage Utilization Levels 

Riparian Areas: 

Forage utilization within the greenline must retain a minimum 6-inch median residual 

stubble height of key hydric species. Once reached, livestock would be moved to other 

areas or off the allotment. 

Mesic residual average stubble heights (3 inches) would apply to key forage species 

within riparian areas outside of the greenline. Once reached, livestock would be moved 

to other areas or off the allotment. 

Upland/mesic vegetative cover types: 

Forage utilization for upland areas would retain a minimum 3-inch residual median 

stubble height for key species. Once reached, livestock would be moved to other areas 

or off the allotment. 

Alternative 3 – Four Corners Allotment 

Under this alternative the Term Grazing Permits currently authorizing use on the Four Corners 

Allotment will be cancelled following guidance in 36 CFR 222.4 and Forest Service Manual 

2231.62. The allotment would be closed to livestock grazing on the fifth year (Table 1). Existing 

improvements will be removed as time and budget permits. Grazing will be phased out over a 

four-year period to give the permittee time to find alternative summer range or make adjustments 

in ranching operations. The year the decision is signed would establish the baseline. Stocking 

rate adjustments will be made annually through the AOI and calculated according to the schedule 

below. 

Table 1. Alternative 3 grazing phase out schedule 

Baseline (2012) Year decision is signed 

Year 1 (2012) 0% reduction from permitted livestock numbers 




Year 5 (2016) No grazing authorized 

As the 10-year term grazing permit expired prior to this decision, a temporary grazing permit, in 

accordance with FSH-2209.13, Chapter 30, will be issued each year authorizing the stocking rate 

specified in the schedule. As implemented, Alternative 3 will phase out the Four Corners 

Allotment based on a starting point of 50 cow/calf pairs which was the permitted number of 

livestock for the 2012 grazing season. 

Mitigation Measures 

Mitigation measures are prescribed to prevent or reduce adverse effects to the environment during 

project implementation. The following measures are applicable to both alternatives, unless 

otherwise specified. Applied to Alternative 3 (No Grazing) on the Four Corners Allotment these 

measures will only apply during the phase-out period only.

Measures Designed to Control Livestock Movement 

Lamb Creek 


A cattleguard will be installed in Section 28 or 29 on Forest road 639 to restrict access to the 

southwestern portion of the allotment. 

Measures Designed to Protect Soils and Aquatics 

Lamb Creek 

One well-used stream crossing on Lamb Creek, located on National Forest System land, 

will be improved by hardening approaches with angular rock in order to reduce sediment 

production. Rock would be treated or obtained from a weed-free source. 

Moores Creek 

Two new fences will be constructed along Moores Creek to keep cows out of the riparian 

area; one would be located in the northern portion of the allotment in the requested add 

on area and another in the south. See Appendix C of the EA for photos of each fence 

location. 

Measures Designed to Protect Plants 

Four Corners 

A qualified botanist will monitor Lycopodium dendroideum and Dryopteris cristata 

populations along Lower West Branch Priest River, annually. If livestock grazing is 

having an unfavorable impact on the population; then action will be taken to eliminate the 

conflict (i.e. exclosure). 

Lamb Creek 

A qualified botanist will monitor wetlands that support Hypericum majus populations, 

annually. If livestock grazing is having an unfavorable impact on the population; then 

action will be taken to eliminate the conflict (i.e. exclosure). 

Measures Designed to Protect Wildlife 

Allotment permittees will use non-lethal wolf deterrents in order to proactively decrease 

the risk of wolf depredations on livestock. 

Allotment permittees will be required to notify the Forest Service and the responsible 

wildlife agency of any wolf or grizzly bear depredations on livestock or any conflicts 

between wolves or grizzly bears and livestock, even if the conflict did not result in the 

loss of livestock, within 24 hours of discovery. 

Allotment permittees will be required to report to the Forest Service all livestock losses 

regardless of the cause, within 24 hours. 

All dead livestock will be removed from National Forest system lands, within 24 hours of 

discovery, to reduce the potential for grizzly bear or wolf conflicts with humans and to 

reduce the risk of mortality for these species. 

Monitoring and Adaptive Management Team 

Appendix B of the EA contains the Monitoring Plan for Alternative 2. Monitoring is key to 

adaptive management; it keeps us informed of a projects progress and provides the District the 

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information needed to make adjustments in management. Numerous potential monitoring items 

were considered and Appendix B of the EA displays the items the ID Team determined would 

provide the best information based on responsiveness to management actions, cost, practicality, 

and also what sort of temporal and spatial scale they represent. The intent was to pick monitoring 

items that reflect a variety of spatial and temporal scales. 

An Adaptive Management Implementation Team (AMIT) will be formed for this project. Their 

role is to oversee the implementation of adaptive management and help direct the best course of 

action to address specific issues or concerns. The functions of the Adaptive Management IDT are: 

Provide recommendations to the District Ranger regarding which management actions to 

implement and when they should be implemented 

Provide continuity regarding how monitoring is implemented and interpreted 

Conduct field reviews of specific areas of concern or interest on allotments 

Document information with a monitoring report 

Each year the District Ranger and the District Rangeland Management Specialist will decide if 

there is a need for the team to meet. At a minimum, the team would meet every five years to 

review implementation and monitoring. 

Composition of the AMIT may vary depending upon the issues being reviewed that year but 

would typically include the following: 

Idaho Panhandle National Forests Ecosystem Staff representative 

Zone Rangeland Management Specialist 

Zone Wildlife Biologist 

Zone Fisheries Biologist 

District Hydrologist 

District Ranger 

Forest Soils Scientist 

Zone Botanist 

Grazing permittee representation 

Rationale for My Decision 

I have made my decision to implement a combination of Alternatives 2 and 3 based on: 

The Priest Lake Grazing Allotments EA and associated Specialist Reports (February 2011) 

Consideration of Forest Plan standards and guidance for the project area as amended by the 

Inland Native Fish Strategy (INFS) 

Biological Assessments and Biological Evaluations 

How well the management actions analyzed in the EA address the project's purpose and need 

Consideration of issues that were raised through public involvement 

Compliance with Regulations and Policies 

The influence of these factors on my decision is outlined below. 

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The Priest Lake Grazing Allotments EA and Specialist Reports 

The NEPA process included the identification of environmental issues specific to the proposed 

action, considering alternatives to the proposed action, and disclosing the environmental effects 

of these actions. I reviewed the alternatives that the EA considered in detail to determine if they 

were responsive to the key issues and the purpose and need (EA, pp. 8-13). I also reviewed the 

alternatives that were considered but not given detailed study (EA, p. 7) to evaluate whether or 

not a reasonable range of alternatives was considered. I reviewed the scoping responses and 

comments that we received on the EA. This review lead me to determine that an acceptable range 

of alternatives was considered and analyzed. 

Alternative 2 was developed to fully address the project’s purpose and need (EA, p. 8). My 

review of the EA leads me to select alternative 2 for the Lamb Creek and Moores Creek 

allotments. The Lamb Creek allotment is intermixed with the permittee’s land. Primary livestock 

use is centered on the meadows and riparian areas in the vicinity of the private pastures with 

some use occurring in adjacent timber harvest units (EA, p. 6). Grazing on NFS lands would be 

authorized on less than 6 % of the total stream length of Lamb Creek. It is unlikely that grazing 

in the proposed allotment would have detrimental effects on Lamb Creek or its tributaries (EA, p. 

26). As with the Lamb Creek allotment, primary livestock use in this allotment is centered on the 

meadows, riparian areas and adjacent timber harvest units in the vicinity of the private pastures 

(EA, p. 15). It is unlikely that grazing along Moores Creek on NFS lands would lead to degraded 

water quality if riparian vegetation remains intact and cattle do not access the stream (EA, p. 26). 

In recent years within the Moores Creek allotment, the area east of Highway 57 has not been 

grazed due to a lack of forage and difficulties with livestock management. The redelineation of 

allotment boundaries in Alternative 2 that will be implemented through my decision makes sense. 

The EA shows that alternative 2 is the best balance between resource protection considerations 

and forage utilization on these two allotments. My conclusion is based on the analysis of effects 

disclosed in the EA, as well as the implementation of a monitoring plan and adaptive 

management strategy. This approach will be used to adjust allotment management plans to 

achieve desired environmental conditions throughout the term of the permits (EA, Appendix B). 

The implementation of Alternative 3 is the right course of action for the Four Corners allotment. 

This allotment has a long history of conflicts with other uses. Issues with intermingled 

ownership, decreases in forage and access to open range have been issues since the late 1950s. 

Due to the decline in forage opportunities on the allotment, lack of riders, and exterior fencing, 

the livestock are not using the allotment. Each year cattle drift off the allotment and onto other 

National Forest and private lands to meet forage needs (EA, p. 15). 

Issues with intermingled ownership, decreases in forage and access to open range, were cited in 

both the 1959 and 1981 environment analysis. After the 1981 environmental assessment, there 

was a reduction in the number of permits issued over the following five years. While the record is 

not explicit, one gets the impression that the root of the earlier conflicts was multiple permittees 

and others competing for available resources. This differs from the genesis of the current 

controversy which revolves around open range grazing in an area that has become predominantly 

residential (Range Report p. 5). 

As stated in the analysis of the environmental assessment, phasing out grazing on the Four 

Corners allotment will provide benefits to a variety of resources. Discontinuing cattle grazing 

would remove the potential for the disruption of western toad breeding, deterioration of breeding 

habitat, or possible direct mortality of adult and juvenile toads due to trampling by permitted 

cattle (EA, p. 43). Phasing out grazing will also lead to improvements in water quality (EA, pp. 

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21-22) and fish habitat (EA, pp. 27-28). It would also lead to improvements in the area’s soil 

resource (EA, pp. 31-32), and would eliminate the potential for permitted cattle to affect rare 

plants and suitable rare plant habitat (EA, p. 50). 

Consideration of these benefits in concert with public sentiment and safety concerns encapsulated 

both in the EA and in response to comments we received on the EA (DN/FONSI, Appendix A) 

lends credence to my decision to phase out grazing on the Four Corners allotment. 

Consideration of the Forest Plan standards and guidance for the 

project area as amended by the Inland Native Fish Strategy (INFS) 

The Idaho Panhandle Forest Plan establishes management direction for all resource management 

programs and resource activities on the Idaho Panhandle National Forests. Designing and 

implementing projects consistent with this direction is the means to move the Forest towards the 

desired future condition as described in the Forest Plan. 

Forest-wide management direction is provided in the form of Forest Plan goals. The Forest Plan 

goal for range management is to manage forage production for domestic livestock at current 

levels (1987) with additional emphasis to protect stream banks, riparian zones, and threatened and 

endangered species of animals and plants. A forest-wide standard for range management is to 

manage opportunities for grazing and other uses of public range resources to serve the welfare of 

local residents and communities. An additional standard states that the needs of threatened and 

endangered and sensitive species have priority in managing existing range allotments. 

Forest Plan Management Area (MA) direction also influenced my decision. Management Area 15 

includes lands considered primary range. These grassland meadows are treated as permanent 

forage areas. Management goals for MA 15 include managing for continued grazing use while 

protecting other resource values and maintaining vegetation conditions and livestock forage 

productivity. Management standards for MA 15 include the maintenance of natural channels and 

adequate streamside vegetation with allotments managed to obtain more than five percent 

streambank trampling. The Forest Plan-designated range areas are surrounded by lands 

designated for timber production (MA1) with small inclusions of lands unsuitable for timber 

production (MA9). The Forest Plan direction for MA1 is to utilize available forage for livestock 

consistent with demand, cost efficiency and wildlife needs. 

The 1995 Inland Native Fish Strategy (INFS) amendments to the Forest Plan provide stringent 

requirements to protect riparian areas and describe goals to establish “characteristics of healthy, 

functioning watersheds, riparian areas, and associated fisheries habitats”. These goals are to 

maintain or restore water quality, stream channel integrity, instream flows, natural timing and 

variability of the water table, diversity and productivity of riparian vegetation, riparian vegetation 

that provides large woody debris, thermal regulation, and natural rates of surface erosion. 

Direction from both the Forest Plan and INFS were utilized in the development of specific 

direction for managing grazing on these three allotments through the EA. It was also used to 

establish sideboards for the development of alternatives to the proposed action and considered 

when responding to public issues. I then used the analysis of effects in the EA to help me decide 

the appropriate level of grazing and identified resource management needed to meet Forest Plan 

standards. 

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My decision strives to reconcile this somewhat conflicting direction to manage for forage 

resources with requirements for aquatic protection and enhancement. I sought to accomplish this 

while also giving consideration to the impacts of permitted grazing on area residents. 

The Four Corners allotment contains less than 200 acres suitable for grazing and almost half of 

those acres are located in riparian areas (EA, p. 16). Of the three allotments analyzed, Four 

Corners has the largest proportion of suitable grazing acres located in riparian areas. The 

corresponding potential for the occurrence of unacceptable impacts on aquatic systems in the 

Four Corners allotment was a key consideration in my decision to phase it out. 

Effects on Threatened, Endangered, and Sensitive Species 

The decision will have no effect on bull trout or their habitat (EA, p. 28). 

The decision may impact westslope cutthroat trout individuals or habitat, but will not likely 

result in a trend toward federal listing or reduced viability for the population or species (EA, p. 

28). 

The decision will have insignificant and discountable effects on grizzly bears (EA, p. 40). 

The decision will not affect critical habitat for Canada lynx (EA, p. 34). 

The decision will have insignificant and discountable effects on gray wolves (EA, p. 37). 

I reviewed the Biological Evaluations for Region 1 Sensitive Species and the associated specialist 

reports. I determined that the management actions authorized through the implementation of this 

decision will not lead to the federal listing of sensitive species. 

The decision may impact individual Townsend’s big-eared bats, western toads or their habitat, 

but would not contribute to a trend towards federal listing or cause a reduction of viability to 

the population or species (EA, pp. 42 and 45). 

Continued grazing on the allotments may impact individual western toads or habitat, but would 

not contribute to a trend towards federal listing or cause a reduction of viability to the 

population or species. After the Four Corners allotment is fully phased out, there would be no 

impact to western toads or their habitat from grazing on this allotment (EA, pp. 42 and 45). 

The decision is expected to have minor negative effects on some forest landbirds, but priority 

habitats would be improved and it will not likely cause a local or regional change in habitat 

quality or population status, and viable populations would be maintained (EA, p. 46). 

No endangered plant species are suspected to occur in the IPNF, and no listed threatened plant 

species are suspected to occur in Bonner County, Idaho (EA, p. 51). Occurrences of Blechnum 

spicant (Lamb Creek), Hypericum majus (Lamb Creek), Lycopodium dendroideum (Four 

Corners), and Dryopteris cristata (Four Corners) are documented in proposed allotments under 

all alternatives. Suitable habitat for these species may be impacted by livestock grazing; 

however, with the mitigation measures described in Chapter 2, such impacts would not be 

expected to lead to a trend towards federal listing or a reduction in species or population viability 

(EA, pp. 51-52). 

The original rare plants report was completed for this project in September 2008. Since that time, 

a Region 1 review of sensitive species has occurred, resulting in a few changes. One change 

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related to nomenclature is shown in the December 2011 plant list for the Kaniksu Zone of the 

IPNF. In addition, two species, whitebark pine (Pinus albicaulis) and yellow lady’s slipper 

(Cypripedium parviflorum v. pubescens ) have been added to the sensitive species list. Both of 

these species were previously on the IPNF Forest Species of Concern list and were actively 

sought out during surveys where suitable habitat occurs. 

Whitebark pine occurs in subalpine forest habitats, none of which is present within the Priest 

Lake Allotment Management Plan area. Yellow lady’s slipper occurs in wet forest, peatland, and 

deciduous riparian habitats, and although some wet forest and peatland habitat occurs in the 

project area, no occurrences of this plant were observed. Impacts to wet forest and peatland 

habitat have been addressed in the rare plant report. 

The rationale behind these conclusions is further detailed in the Specialist Reports, Biological 

Assessments and Biological Evaluations for the corresponding resource area. 

Meeting the Purpose and Need 

How a Combination of Alternatives 2 and 3 Responds to the Purpose and Need 

This project was initiated to comply with Rescission Bill (Public Law 104-19, section 504a), 

which requires the Forest Service to complete an analysis and update allotment management 

plans (AMP’s) on all Forest grazing allotments. In compliance with this bill, my decision to 

implement a combination of Alternatives 2 and 3 (DN p. 3) will be implemented by updating the 

AMP’s for the Four Corners, Moores Creek and Lamb Creek Grazing Allotments. 

The overarching desired condition for the allotments is to maintain soil productivity, water 

quality, and water quantity on all allotments. For upland areas, desired conditions would include 

providing conditions conducive to maintaining healthy, vigorous vegetative cover that would 

provide forage and cover for wildlife habitat, soil stability, as well as livestock forage. For 

riparian areas, desired conditions would include improving the vigor and production of key 

wildlife browse species, and managing riparian vegetation, including shrub and overstory tree 

cover along all perennial streams with defined channels, to provide shade, to maintain streambank 

stability and in-stream cover, and to promote filtering of overland flows. Ideally, this would be 

accomplished while continuing to provide a social and economical base for appropriate livestock 

grazing in compliance with the Forest Plan. 

The project was also undertaken to evaluate the effects of livestock grazing on Endangered 

Species Act (ESA)-listed species, sensitive plant species and Forest species of concern. Since the 

AMPs were originally approved, there have been several changed conditions, including the 

presence of ESA-listed species, i.e. bull trout, Canada lynx, and grizzly bear. 

My decision achieves the purpose and need of the project by: 

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Reauthorizing grazing for 10 years in the Moores Creek and Lamb Creek allotments 

Phasing out grazing on the Four Corners Allotment 

Redefining allotment boundaries to exclude non-National Forest System lands and 

National Forest System lands which are no longer be suitable for grazing 

Increasing the forage utilization standard to a minimum of six inch stubble height in 

riparian areas


Establishing a monitoring plan and Adaptive Management Team 

Monitoring and an adaptive management plan will be integral to the successful achievement of 

desired environmental conditions throughout the term of the permit. 

Under Alternative 2 the stocking rate for the Moores Creek allotment is very low compared to the 

estimated suitability analysis allowable use (Range Report p. 8). The stocking rate for Lamb 

Creek is also well below the estimated allowable use (Range Report p. 7). This analysis supports 

my conclusion that grazing on these allotments is sustainable without undesirable impacts. 

Why Another Alternative Was Not Selected 

Alternative 1 

The Grazing Permit Administration Handbook (FSH 2209.13) directs that current management be 

analyzed in detail if it meets the stated purpose and need for action. Initially, this alternative was 

not to be included as an alternative considered in detail because it clearly does not meet the stated 

purpose and need. However, it was been carried forward to provide a baseline from which to 

compare alternatives. 

Alternative 1 would meet the need to provide livestock grazing opportunities for local livestock 

producers. However, under Alternative 1, there would be no improvement in channel stability, 

erosion, hydrologic function, riparian condition, temperature or Properly Functioning Condition 

in either Lamb Creek or the Lower West Branch (EA, p.19). Continued loss of large woody 

debris recruitment in Lamb Creek would further limit fisheries potential and possibly encourage 

the persistence of brook trout by limiting the development of stable and diverse habitat features 

preferred by native species. Since streambank instability in the Lower West Branch exceeds 18% 

and there would be no changes in allotment management under this alternative, it is unlikely that 

streambanks in the Four Corners Allotment would improve and is therefore unlikely INFISH 

goals and other water quality standards would be obtained. Stream and fisheries conditions within 

the Moores Creek allotment would continue to benefit non-native brook trout (EA, p.24). 

Further, Alternative 1 would not allow for improvement in soil conditions or productivity and 

may result in additional soil disturbance (compaction and displacement) from livestock grazing. 

Alternative 1 would increase the risk of adversely affecting known and potential rare plant 

species on the allotments (EA, pp.51-52). 

Alternative 2 

This alternative was developed to fully address the purpose and need. It incorporates 

management flexibility by providing a range of allowable numbers of cows and seasons, and 

adjustments in the timing and duration of grazing annually to reflect variations in resource 

conditions and management objectives over time. 

Alternative 2 was not chosen for the Four Corners allotment because of the continued potential 

for negative resource impacts. A primary consideration was the cows would continue to 

congregate in the wet/moist areas of the allotment and continue to trample and erode stream 

banks and compact soils in the wetter areas (EA p. 16). 

Forage on the Four Corners allotment has been continually declining. Over time, changes in 

timber management practices and fire suppression have resulted in less open meadows and more 

timbered stands. This change in available forage has changed livestock use patterns. Due to the 

decline in forage opportunities on the allotment, lack of riders, and exterior fencing, the livestock 

11


are not using the allotment. Each year cattle drift off the allotment and onto other National Forest 

and private lands to meet forage needs (Range Report p. 5). 

Under Alternative 2, the Lamb Creek allotment stocking rate is well below the estimated 

allowable use for this allotment (EA p.15). Boundary realignment within the Lamb Creek 

allotment will remove riparian reaches of the North Fork Lamb Creek located on NFS lands. In 

combination with an increase of minimum greenline stubble height these changes will lessen the 

potential for resource impacts. 

Riparian fencing would reduce cattle access to sensitive stream segments. In unfenced areas, the 

Adaptive Management Strategy will be used to offset any potential adverse impacts. Using a 

combination of fencing and adaptive management practices, it is expected that there would be no 

adverse impacts to channel stability, erosion, hydrologic function, riparian condition, and 

temperature in the mainstem of Moores Creek (EA, p. 23). 

Alternative 3 

This Alternative was chosen for the Four Corners allotment. The allotments would be closed to 

livestock grazing on the fifth year. Under this alternative the Term Grazing Permits currently 

authorizing use on the three allotments would be cancelled following guidance in 36 CFR 222.4 

and Forest Service Manual 2231.62. 

On the Moores Creek and Lamb Creek allotments, National Forest System lands make up only a 

small portion of suitable grazing land and are intermixed with blocks of privately owned lands. 

Under the grazing phase out alternative, the other landowners would likely continue grazing on 

their lands, making it extremely difficult to keep livestock from crossing and using National 

Forest System lands. Fencing and riding would be necessary to restrict unauthorized cattle 

movement. Permitted grazing on National Forest System lands allows coordinated grazing 

management with adjacent landowners. 

Fence Four Corners Allotment 

An option to fence the allotment and restrict livestock access to the riparian areas of Lower West 

Branch and Moores Creek was considered but eliminated from detailed analysis in the EA 

because it was determined not to be a viable alternative. Fencing would dramatically reduce the 

available forage acres, maintaining the fence would be an ongoing problem due to the broken 

terrain and predominately treed vegetation, and the cost was estimated to be in excess of 

$125,000. Therefore, this alternative was eliminated from detailed study. 

Consideration of Public Comments and Issues 

Public Involvement Activities 

The proposal was first listed in the July – September 2006 Quarterly Schedule of Proposed 

Actions and has remained on the Schedule ever since. A public scoping letter was mailed on 

August 14, 2006 to 130 individuals, agencies and organizations. A Notice of Comment was 

published in the Spokesman Review on August 17, 2006. The comment period was open for 

thirty three days, commencing on August 17, 2006 and ending on September 18, 2006. On March 

20, 2007 a second letter was mailed to those who submitted comments informing them that the 

anticipated decision date had been moved from May 2007 to May 2008. Those that commented 

were also made aware that they would have an opportunity to comment on the completed 

Environmental Assessment (EA) prior to any decision being made. A third letter was mailed on 

July 26, 2010 to those that commented explaining the delays that have been encountered, letting 

12


them know the EA would be released soon, and asking what format they would like to receive the 

EA. 

As a result of public scoping, a total of thirty responses were received. All comments were 

considered, including the six received after the September 18, 2006 deadline. Comments 

included concerns over livestock management, soils, water quality/fisheries, native plants, 

noxious weeds, recreational OHV use on trails, and public safety. Nineteen responses were 

related, specifically to livestock management/open range on the Four Corners Allotment. In 

addition, twelve op-ed letters addressing the same topic were published in local newspapers. All 

information related to public involvement related to the scoping process can be found in the 

project file. 

The Priest Lake Grazing Allotments EA was released to the public for comment on February 10, 

2011. A legal NOTICE FOR COMMENT was published in the Coeur D’Alene Press on 

February 14, 2011. Comments on the EA were accepted for 30 calendar days following the 

publication of this notice. Fourteen letters containing comments on the EA were received during 

the comment period. The specific comments that these letters contained and the response to these 

comments are appended to this DN/FONSI. 

We received comments from many individuals and several organizations and agencies on our 

environmental assessment. Responses to these comments are contained in Appendix A of this 

DN/FONSI. 

Through my interactions with the public and reading the letters we received, it became quite 

obvious that there are strong feelings associated with permitting cattle to graze on NFS lands on 

the Priest Lake Ranger District. Summarized in the following sections are some of the 

comments we heard more than once and discussion of the trade-offs I weighed as I evaluated each 

comment; all comments and our responses to them are located in an Appendix A to this 

DN/FONSI. 

Consideration of Issues Arising From the Public Involvement Process 

Elimination of Open Range 

We received many comments regarding livestock management and open range, particularly on the 

Four Corners Allotment (Appendix A). The majority of the comments were in favor of 

eliminating the open range designation. The Open Range Law (Idaho Code 25-2401) is an Idaho 

State Law that does not apply to Federal Lands. The State of Idaho has given each County the 

delegated authority to determine which private lands within the County are “open range” or “herd 

districts”. Since this Law does not apply to Federal lands it was not carried forward in this 

analysis, however a brief discussion of the history and the rationale for eliminating it from 

detailed study follows. 

The project area is designated as Open Range under Idaho Code 25-2401, permitting livestock to 

run at large within unenclosed, unincorporated areas of the county. Property owners wishing to 

deny livestock access to their private land are required to construct adequate fencing. However, 

National Forest System lands are exempt from this statute. Under Federal regulations, a livestock 

owner is responsible to keep unauthorized livestock off of NFS lands. For this reason the 

allotments remain mostly unfenced, allowing livestock to move freely between NFS land and 

non-NFS land. 

13


The private land adjacent to the National Forest boundary used to be largely unoccupied, being 

used for agriculture and forest products. Now, a large portion of these private lands have been 

developed for residential use. This shift from agricultural to residential, most notably in the Four 

Corners area has resulted in increasing conflicts both in frequency and intensity between 

permittees and local residents. The degree of controversy may best be demonstrated by the fact 

that nineteen of the thirty responses received during the scoping period, and twelve op-ed letters 

published in local newspapers, dealt specifically with this issue. 

From the permitee’s perspective open range grazing has been part of the family-ranch lifestyle for 

generations. Meanwhile, neighbors question why they should have to build and maintain 

expensive fences to keep someone else’s cows off of their private property; trampling across their 

lawn; and destroying their garden. 

The letters and articles generated by this topic (Appendix A and project file) express the stronglyheld 

opinions on both sides of the issue. It is equally obvious that without resolution the tensions 

will continue to escalate. However, the fact remains that any decision resulting from this process 

pertains only to grazing on NFS lands and will not alter the open range designation under State 

statute. A livestock owner can still allow their livestock to run on unenclosed, unincorporated 

areas of the county. This issue was eliminated from detailed analysis because it is already decided 

by law and is outside the scope of the project. 

Public Safety 

One of several factors influencing my decision to phase out grazing on the Four-Corners 

Allotment was our inability to keep cows from the allotment off of Highway 57. Closing this 

allotment will eliminate this threat to public safety. Fencing the allotment was considered but 

found to be economically unfeasible (EA p. 7). 

II. Findings Required by Other Regulations and Policies 

To the best of my knowledge, this decision complies with all applicable laws, regulations, and 

policies (DN/FONSI, p. 7; EA pp. 13-52; Hydrology Report pp. 26-29; Fisheries Report pp. 18- 

19; Wildlife Report pp. 1, 15, 20, 29, 33 and 36; Range Report p.10; Noxious Weeds Report p. 10 

and Botany Report pp. 9-10). 

Clean Water Act 

The Clean Water Act requires each state to provide guidance and direction to protect and restore 

water bodies (40 § 131.12), and the Forest Service is required to meet or exceed State Best 

Management Practices (BMPs) to protect water quality (IPNF Forest Plan, p. II-33). 

The selected alternative will be consistent with the requirements of the Clean Water Act, 33 

U.S.C. §1251 (Hydrology Report pp. 17-19, Fish Report pp.17-19). Key to this compliance will 

be the utilization of BMP’s and the implementation of an adaptive management plan 

Endangered Species Act 

The selected combination of alternatives is consistent with the Endangered Species Act 

(Wildlife, Fisheries and TES Plants Reports). Refer to item 9 in the Finding of No 

Significant Impact section below. Also refer to Effects on Threatened, Endangered, and 

Sensitive Species under decision rationale above. 

14


National Historic Preservation Act 

The selected alternative complies with the National Historic Preservation Act. Reports are 

completed for this project area and no cultural sites will be impacted with the selected alternative 

(project file). Native American tribal representatives were given the opportunity to comment and 

no concerns were expressed (project file). 

Executive Orders 11988 and 11990 - Floodplain Management and Protection of Wetlands 

The selected alternative meets the requirements of Executive Order 11988, which apply to 

protection of floodplains. These features are protected through implementation of best 

management practices and Forest Plan standards and guidelines (Hydrology Report pp 5-7, 26-27 

and 29 and EA Appendix A). A monitoring plan and adaptive management strategy (EA 

Appendix B) will be used to verify that the management activities are implemented as designed 

and effective in meeting project objectives, achieving Forest Plan standards and meeting the 

intent of other regulations and policies including Executive Orders 11988 and 11990 (Hydrology 

Report pp 29-30). 

Executive Order 12962 – Recreational Fishing 

The objective of this order is “…to improve the quantity, function, sustainable productivity, and 

distribution of U.S. aquatic resources for increased recreational fishing opportunities by: (h) 

evaluating the effects of federally funded, permitted, or authorized actions on aquatic systems and 

recreational fisheries and document those effects relative to the purpose of this order.” The 

selected alternative is consistent with this executive order regarding aquatic systems and 

recreational fisheries (Fisheries Report pp. 17 and 19). Of particular relevance is the Moores 

Creek fishery in the Moores Creek allotment. The project as implemented would provide for 

protection and regular evaluation of the fishery resources in Moores Creek, as well as in other 

streams within the allotments (Fisheries Report pp. 13 and 24). 

State of Idaho Governor’s Bull Trout Plan 

The mission of the Governors Bull Trout Plan is to “…maintain and/or restore complex 

interacting groups of bull trout populations throughout their native range in Idaho.” In the Plan, 

the Panhandle Basin, Upper Priest River and the Priest River are a Bull Trout Key Watersheds. 

The Bull Trout Plan requires the US Forest Service to follow standards in its Forest Plan and 

those conservation strategies required by INFS. My decision is consistent with the direction in 

the Governor’s Bull Trout Plan because it follows this direction and these standards (Fisheries 

Report pp. 1-3, 17 and 18) and will have no effect on bull trout or their habitat (EA, p. 28). 

Executive Order 13112 (February 1999) 

Executive Order 13112 directs Federal agencies to: “…prevent the introduction of invasive 

species and provide for their control and to minimize the economic, ecological, and human health 

impacts that invasive species cause…” 

The issue of cattle grazing creating conditions that could favor noxious weed establishment and 

spread was analyzed in detail (Noxious Weed Report, pp. 1-10). At the project level, noxious 

weeds have been identified and weed prevention measures have been incorporated into the 

proposed action. Monitoring for noxious weeds will help identify areas needing treatment and 

follow-up treatments (EA, pp. 9-10). The potential for weed spread was disclosed for the 

alternatives (Noxious Weed Report, p. 10). The risk of the cattle increasing weed spread or acting 

as mechanisms for new weed introductions, would be low (EA, p. 51). The selected alternative 

15


will meet the intent stated in Executive Order 13112 for moderate control, through the 

implementation of design features and an adaptive management strategy. 

III. Finding of No Significant Impact 

The following is a summary of the project analysis to determine significance, as defined by Forest 

Service Handbook 1909.15_05. “Significant” as used in NEPA requires consideration of both 

context and intensity of the expected project effects. 

Context means that the significance of an action must be analyzed in several contexts (i.e. local 

regional, worldwide), and over short and long time frames. For site-specific actions significance 

usually depends upon the effects in the local rather than in the world as a whole. This project is 

limited in scope and duration. The project was designed to minimize environmental effects 

through the utilization of a monitoring plan and adaptive management approach to grazing. The 

project will be implemented for five months a year over a period of ten years (EA, pp.7-10). 

Intensity refers to the severity of the expected project impacts. The following factors were 

considered to evaluate intensity. 

1. Impacts that may be both beneficial and adverse 

Both beneficial and adverse impacts have been considered in the evaluation of the environmental 

consequences of the proposed action and alternatives actions. Beneficial effects have not been 

used to offset or compensate for potential adverse effects. Singularly and collectively, the 

resources affected by the proposed activities in all alternatives are not expected to cause 

significant impacts. 

The adverse impacts associated with the decision include the following: 

The loss of grazing opportunity on the Four Corners allotment will likely result in a reduction 

in the number of cows that the permittee would be able carry on their land. 

Given that the cattle would still have full access to the reduced allotment, channel banks 

would continue to be trampled in select areas of the Lamb Creek allotment. Trampling of the 

banks, where it occurs, could result in localized sediment delivery and altered channel 

morphology (EA, p. 20). 

May impact individual sensitive or rare plants or habitat, but would not likely contribute to a 

trend toward federal listing or loss of viability to the population or species (EA pp.51-52). 

There is a possibility that the implementation of Alternative 3 (Grazing Phase Out) on the 

Four Corners allotment could result in established weeds spreading over larger areas (EA p. 

51) 

May impact westslope cutthroat trout individuals or habitat, but will not likely result in a trend 

toward federal listing or reduced viability for the population or species (EA p. 28). 

Grazing may result in the disruption of western toad breeding, deterioration of breeding 

habitat, or possible direct mortality of adult and juvenile toads due to trampling (EA, pp.43). 

Minor negative effects on some forest landbirds are expected, but priority habitats would be 

improved and it will not likely cause a local or regional change in habitat quality or population 

status, and viable populations would be maintained (EA, p. 46). 

16

The beneficial effects of the decision include the following: 


Provision of relief to private landowners in the Four Corners area from the depredations of 

open- range cows originating from the NFS allotment. The removal of livestock from the 

allotment would resolve the open range issues brought up by the public. 

Channel bank stability, hydrologic function and riparian function of Lamb Creek would 

improve slightly. Where riparian grazing is eliminated, channel banks would gradually 

stabilize resulting in improved shading, more favorable width to depth ratios and a minimal 

improvement in stream temperature (EA, p. 20). 

In the short term, the fencing and riparian planting on Moores Creek is expected to improve 

riparian vegetation and in turn improve channel bank stability, hydrologic function and 

riparian function. A reduction in channel width, with a greater potential to maintain water 

temperature is a possibility. Over the long term, it is likely that Moores Creek would show an 

improvement in channel stability, erosion, hydrologic function, riparian condition, temperature 

and properly functioning condition class (EA, p. 20). 

The decision will lead to an improving trend in soil resource conditions in all allotments (EA, 

p. 30). 

Project activities would not adversely affect floodplains or wetlands. Reducing livestock 

access to the RHCAs would provide a net improvement to the form and function of both 

floodplains and wetlands (EA p. 29). 

The implementation of Alternative 2 on the Moores Creek and Lamb Creek Allotments would 

result in a slight decrease in the risk of a substantial weed spread and/or new introductions in 

those areas due to grazing (EA p. 51). 

The decision will have no effect on the following: 

Phasing out of the Four Corners allotment in combination with project design features 

developed for Alternative 2 on the Moore’s Creek and Lamb Creek allotments effectively 

eliminates, or reduces to negligible levels, most of the potential environmental impacts; 

therefore, implementation of the selected alternative would result in no effect to the following 

resources: cultural and heritage resources (Project File); bull trout or their habitat (EA p. 23); 

In addition, the Wildlife, Fisheries and Botany reports contain lists of species that were not 

analyzed in detail because there would be no effects to those species from the alternatives 

analyzed. 

2. The degree to which the action affects public health or safety 

This decision will have no significant or unacceptable effects to public health or safety. Livestock grazing 

has been a common practice in the project area for over 100 years. During this time there have been no 

unacceptable effects to public health and safety on the Moores Creek and Lamb Creek allotments. The Four 

Corners allotment does have a long history of conflicts with other uses. Issues with intermingled 

ownership, decreases in forage and access to open range have been issues since the late 1950s (EA, p. 15). 

Public safety was one of the factors influencing my decision to phase out grazing on the Four Corners 

allotment. We have been unable to keep cows from the allotment off of Highway 57. There have been 

interactions between permitted bulls and local residents. My decision will eliminate these threats to public 

safety. 

3. Unique characteristics of the geographic area 

The selected alternative will not have a significant effect on unique resource characteristics. Surveys to 

locate heritage resources within the potentially affected grazing areas have been completed (project file). 

17


Several cultural properties are known to be located within the area of potential effect. The Forest Cultural 

Resource Specialist made a determination that the project would have No Adverse Effect to these 

properties. SHPO concurrence with this conclusion was received (project file). No concerns were 

expressed by any potentially affected tribes. Project activities would not adversely affect any floodplains 

or wetlands (EA p. 29) or prime farmlands. 

4. The degree to which the effects on the quality of the human environment are 

likely to be highly controversial 

As used in the Council on Environmental Quality’s guidelines for implementing NEPA, the term 

“controversial” refers to whether substantial dispute exists as to the size, nature, or effects of the 

major federal action rather than to the existence of opposition to a use. There is wide 

professional and scientific agreement on the scope and effects of the selected alternative on the 

various resources, as cited in the discussion of effects to resources and in references to specialist 

reports (EA pp. 13-52). 

Further analysis and conclusion about the potential effects are available in reports for each 

resource and other supporting documentation cited in those reports (EA p. 13). 

Based on the findings of the analyses, the effects of the activities on the Priest Lake Grazing 

Allotments on the quality of the human environment are not highly controversial. 

5. The degree to which the possible effects on the human environment are highly 

uncertain or involve unique or known risk 

Analysis of the selected alternative considered the effects of past actions and events, as a frame of 

reference in conjunction with scientifically accepted analytical techniques, available information, 

and best professional experience and judgment to estimate effects to the human environment. 

The mitigation measures and design feature detailed in the EA (pp. 8-9 and 11-12), the adaption 

of a monitoring plan and adaptive management strategy (EA pp. 12-13 and Appendix B) and the 

utilization of Best Management Practices (EA Appendix A ) are intended to eliminate or 

minimize any potential adverse effects on the human environment. These protection measures 

and strategies are based on science and/or past monitoring. They have been incorporated into the 

design of the selected alternative. There are no uncertain or unique effects of project activities 

that have not been previously encountered or that would constitute an unknown risk to the human 

environment. 

6. The degree to which the action may establish a precedent for future actions 

with significant effects or presents a decision in principle about future 

consideration 

The selected alternative consists of activities that are not new or unique in type, size or intensity 

and are consistent with all laws, regulations and policy including management direction in the 

Forest Plan. All future actions, except those analyzed and incorporated into the selected 

alternative, would be analyzed on their own prior to implementation. Implementation of the 

selected alternative would not establish a precedent for future actions. 

7. Whether the action is related to other actions with individual insignificant but 

cumulative significant impacts 

According to the Council on Environmental Quality (NEPA) regulations “cumulative impact” is 

the impact on the environment which results from the incremental impact of the selected 

alternative when added to other past, present, and reasonably foreseeable future actions regardless 

of what agency (Federal or non-Federal) or person undertakes such actions (40 CFR 1508.7). 

18


The relevant boundaries and projects assessed for cumulative effects vary by resource. Each 

resource cumulative effects analysis area can be different and possibly larger or smaller. Relevant 

cumulative effects are discussed for each resource area in the EA and associated specialist reports 

(Hydrology pp. 24-26; Fisheries pp. 11-12, 16, 18; Wildlife pp.19-20, 25-26, 28-29, 32-33, 35-36; 

Range p. 10; Threatened and Endangered Plants p. 9; Soils pp. 16-18 and Weeds pp. 6-8). Each 

cumulative effects analysis for each environmental component or resource area is guided by and 

consistent with the Cumulative Effects Considerations of Past Actions (40 CFR 1508.7) in 

accordance with the Council on Environmental Quality Guidance Memorandum on the 

“Consideration of Past Actions in Cumulative Effects Analysis” dated June 24, 2005. A listing of 

potentially relevant related past, present and future management activities is provided in the EA 

(p. 14) and was considered by all resource specialists. 

The effects of the selected alternative combined with the effects of past, present, and reasonably 

foreseeable actions will not have any significant cumulative effects. The selected alternative will 

have no effect on some resources (see #1 above) and no cumulative effects. 

8. The degree to which the action may adversely affect districts, sites, highway 

structures, or objects listed in or eligible for listing in the National Register of 

Historic Places, or may cause loss or destruction of significant scientific, cultural, 

or historic resources 

An appropriate inventory was conducted for the project and cultural properties are known to be 

located within the area of potential effect. The Forest Cultural Resource Specialist made a 

determination that the project would have No Adverse Effect to these properties because the 

project was designed to avoid significant effects to components/features associated with Class I 

and II properties. SHPO concurrence with this conclusion was received (project file). 

Consultation with the Kootenai Tribe of Idaho, Kalispel Tribe of Indians, Coeur d'Alene Tribe, 

and the Confederated Salish and Kootenai Tribes on this project was done by our North Zone 

Heritage manager. No concerns were expressed about the proposal (project file). 

9. The degree to which the action may adversely affect an endangered or 

threatened species or its habitat that has been determined to be critical under the 

Endangered Species Act of 1973 

Bull trout – The implementation of a combination of Alternatives 2 and 3 would have no effect on bull 

trout or their habitat (EA p. 28, Fisheries BA p. 12). 

Canada lynx – The decision to implement a combination of Alternatives 2 and 3 effectively excludes all 

potential lynx habitat from the allotments (EA p. 33). Approximately 600 acres of the western portion of 

the Lamb Creek allotment within the Kalispell LAU would be removed from the allotment (Wildlife 

Report, p. 13). Grazing would not occur in any critical habitat for Canada lynx. Consequently, it was 

determined that the implementation of the decision would have no effect on Canada lynx or their habitat 

(Wildlife BA p. 17). 

Grizzly bear - The decision would have insignificant and discountable effects on grizzly bears (Wildlife 

Report p. 26) leading to a may affect, not likely to adversely affect determination (Wildlife BA p. 10). 

Wildlife Biological Assessment and U.S. Fish and Wildlife Service Informal Consultation – A 

Biological Assessment was completed for this project and is available for review. On October 25, 2011, 

the U.S. Fish and Wildlife Service issued a letter concurring with our determinations of effects to 

threatened and endangered species in the project area. 

19


10. Whether the action threatens a violation of Federal, State, or local law or 

requirements imposed for the protection of the environment 

The selected combination of alternatives meets Federal, State, and local laws for water quality, 

fisheries, wildlife, threatened and endangered species, noxious weeds as referenced through the 

EA (pp. 13-52) and associated individual resource reports. 

Several cultural properties are known to be located within the area of potential effect. The Forest 

Cultural Resource Specialist made a determination that the project would have No Adverse Effect 

to these properties and SHPO concurrence with this conclusion was received (project file). This 

project also meets National Environmental Policy Act disclosure requirements (Priest Lake 

Grazing Allotments EA). 

Conclusion 

Based on the information presented in the environmental assessment and associated specialist 

reports, the Priest Lake Grazing Allotments will not have a significant effect on the human 

environment; therefore, an environmental impact statement does not need to be prepared. 

IV. Review and Appeal Opportunities 

The documents cited in this decision notice can be obtained from the Priest Lake Ranger District 

office in Priest Lake, Idaho or from the Idaho Panhandle National Forests website: 

www.fs.fed.us/ipnf/eco/namage/nepa/index. 

This decision is subject to appeal pursuant to 36 CFR 215.11. A written appeal must be submitted 

within 45 days following the publication date of the legal notice of this decision in the Coeur 

d’Alene Press, Coeur d’Alene, Idaho. It is the responsibility of the appellant to ensure their appeal 

is received in a timely manner. The publication date of the legal notice of the decision in the 

newspaper of record is the exclusive means for calculating the time to file and appeal. Appellants 

should not rely on date of timeframe information provided by any other source. 

Paper appeals must be submitted to one of the following: 

USDA Forest Service, Northern Region USDA Forest Service, Northern Region 

ATTN: Appeal Deciding Officer ATTN: Appeal Deciding Officer 

PO Box 7669 200 East Broadway 

Missoula, MT 59807 Missoula, MT 59802 

Office hours: Monday through Friday, except national holidays, 7:30 a.m. to 4:00 p.m. 

Electronic appeals must be submitted to: appeals-northern-regional-office@fs.fed.us. In 

electronic appeals, the subject line should contain the name of the project being appealed. An 

automated response will confirm your electronic appeal has been received. Electronic appeals 

must be submitted in MS Word, Word Perfect, or Rich Text Format (RTF). 

It is the appellant’s responsibility to provide sufficient projector activity-specific evidence and 

rationale, focusing on the decision, to show why my decision should be reversed. The appeal 

must be filed with the Appeal Deciding Officer in writing. At a minimum, the appeal must meet 

the content requirements of 36 CFR 215.14, and include the following information: 

The appellant’s name and address, with a telephone number, if available: 

A signature, or other verification of authorship upon request (a scanned signature for 

electronic mail may be filed with the appeal); 

20


When multiple names are listed on an appeal, identification of the lead appellant and 

verification of the identity of the lead appellant upon request; 

The name of the project or activity for which the decision was made (Priest Lake Grazing 

Allotments) the name and title of the Responsible Official (Glenn Klingler, District Ranger), 

and the date of the decision; 

The regulation under which the appeal is being filed, when there is an option to appeal under 

either 36 CFR 215 or 36 CFR 251, subpart C; 

Any specific change(s) in the decision that the appellant seeks and rationale for those changes; 

Any portion(s) of the decision with which the appellant disagrees, and explanation for the 

disagreement; 

Why the appellant believes the Responsible Official’s decision failed to consider the 

substantive comments; and 

How the appellant believes the decision specifically violates law, regulation, or policy. 

If an appeal is received on this project, there may be informal resolution meetings and/or 

conference calls between the Responsible Official and the appellant. These discussions will take 

place within 15 days after the closing date for filing an appeal. All such meetings are open to the 

public. If you are interested in attending any informal resolution discussions, please contact the 

Response Official or monitor the following website for postings about current appeals in the 

Northern Region of the Forest Service: http://www.fs.fed.us/r1/projects/appeal_index.shtml. 

V. Implementation Date 

If no appeal is received, implementation of this decision may occur five business days from the 

close of the 45-day appeal filing period. If an appeal is received, implementation may not occur 

for 15 days following the date of appeal disposition. 

I am the responsible official for this decision. For more information regarding this project, please 

contact Pat Behrens, North Zone Range Staff, (208) 267-5561 at the Bonners Ferry Ranger 

District or A.J. Helgenberg, IDT leader, (208) 263-5111 at the Sandpoint Ranger District. 

/s/ Glenn Klingler April 16, 2012____ 

GLENN D. KLINGLER Date 

District Ranger 

21

Appendix A – Response to Public Comments 

List of Respondents to Letters Received during comment period ending March 17, 2011 

Letter # Agency, Organization, Business, or Individual 

1. Kathy Anderson 

2. Robert Hagman 

3. Anne Chamberlain 

4. Patricia Andrews, PhD 

5. Rosetta Brockway 

6. Belinda Melton 

7. Carolyn Halkias 

8. Roger Gregory 

9. Paul Sieracki 

10. Idaho Conservation League – Brad Smith 

11. The Lands Council/Alliance for the Wild Rockies – Jeff Juel 

12. Kinnikinnick Native Plant Society – Molly O’Reilly 

13. Barbara Egolf 

14. William Egolf 


A-1


Respondent #1: Kathy Anderson– March 8, 2011 

Comment 

# 

Comment Issue Response 

1 

Supports Alternative 3 for the Four Corners Allotment with one 

exception; the permit should be phased out in less than four years. 

Preferred Alternative 

The phase out schedule follows guidance in 36 CFR 

222.4 and FSM 2231.62. 

Four Corners Allotment does not include T57N R5WSection 7 

Federal occupancy trespass laws do not require 

although grazing has been allowed there and cattle routinely utilize 

NFS lands to be fenced for trespass to occur. 

2 

that NFS timbered area for cover during summer grazing. This is 

one of several areas within the allotment where I have observed 

cattle frequenting during warm summer days or when migrating to 

Permit 

Compliance/Suitability 

Under Federal regulations, the owner of the 

livestock is responsible to keep livestock off of nonpermitted 

NFS lands. Corrective action will be taken 

or from northern parts of the allotment west of the LWB. It’s not 

if cattle are found to be utilizing T57N R5WSection 7 

apparent that any suitable grazing exists in Section 7. 

A map of alternative allotment boundaries is contained in the 

during permit compliance checks. 

project documents however there was no discussion of the how the 

Private lands were not considered in the suitability 

boundaries were determined nor private lands considered. For 

analysis. Alternative 2 considerably reduces the 

3 Alternative 2, how were non-NFS lands considered for suitability in Suitability Analysis size (>30%) of all three of the allotment boundaries. 

developing this alternative and analyzing the effects? Did that take 

These reductions reflect actual use which is related 

into account whether those non-NFS lands were accessible to 

cattle or excluded by fences or other barriers? 

to grazing suitability. 

4 

Nowhere in the EA or other documents did I find any analysis of 

social or economic issues other than mention of historical conflicts 

and concern expressed during scoping. Is an analysis of social or 

economic issues in the project file or is the economic and social 

base for grazing simply presumed to exist so long as someone is 

interested in holding a grazing permit? 

Under Alternative 3, nothing would prohibit the permittee from 

continuing state-allowed open range grazing on other nearby 

Social and Economic 

Analysis 

The decision to phase out the Four Corners 

allotment is being driven in part by social issues. 

Refer to the Social Assessment for the Idaho 

Panhandle National Forests Final Report (2002) for 

details. 

private properties. Herd size would be dependent on available 

This decision does not address, nor can it address 

graze and utilization of their own pastures during the summer, 

Idaho’s open range law. Corrective action will be 

5 

much like the rest of livestock owners. The permit holder routinely 

exercises those state rights by releasing cattle a few days prior to 

Permit Compliance 

taken if cattle are found to be utilizing NFS lands 

prior to the Forest Service permit date. Corrective 

the June 1 Forest Service permit date. In 2010, not unlike other 

action will be taken if cattle are found to be utilizing 

years, the cattle actually were on NFS lands prior to June 1 as a 

result of that early release with no apparent or effective actions 

taken to control movement. 

NFS lands prior to the permit opening day. 

A-2



Comment 

# 


As it has been decided to phase out the Four 

Corners Allotment, it is likely that only minimal 

economic investments in improvements are likely to 

be warranted. Two new fences would be 

6 

…Based on this rationale I have to assume that under any 

alternative wear grazing is authorized, only isolated short segments 

of fencing might occur and by the same rationale extensive fencing 

along Hwy 57 would not occur. 

Fencing 

constructed along Moores Creek to exclude cattle 

from the riparian areas; one would be located in the 

northern portion of the allotment in the requested 

add on area and another fence exclusion area in the 

south. Additionally, existing improvements would 

remain and be repaired as needed, i.e. fences and 

cattleguards. Improvements may be relocated or 

additional ones created as deemed necessary under 

the Adaptive Management approach. 

Although the current permitted use of 257 head months is higher 

Alternative 3 will eliminate grazing on the Four 

than the analysis (Table 4) shows as allowed, the Range Report 

Corners Allotment over a 4 year period. The 25% 

only generalizes regarding actual use. What has been the actual 

reduction in the second year of the phase out would 

use over the past 10 years or during those years when monitoring 

be below the analysis-derived allowable permitted 

7 occurred. If actual use was lower than permitted use, the 

Allotment Baseline use. The model used to determine allowable use 

conditions observed during surveys and monitoring would be the 

only provides an estimate. Monitoring is the primary 

effects from fewer cows than permitted and could falsely lead to a 

guide to determining stocking rate. In recent years 

conclusion that a reduction in head months under Alternative 2 

the actual use has been lower than the permitted 

would result in a reduction of impacts. 

use (project file). 

Salt stations would be located away from lowland 

meadow areas, stream bottoms and at least ¼ mile, 

8 

Salt blocks I have observed in recent years have been placed 

directly on bare ground, such as the salt block last summer on the 

side of Bear Paw Road at approx. MP 4.5 


where feasible, from any body of water. Salt and 

supplements would be placed in an appropriate 

container so as not to contaminate the ground. 

Corrective action will be taken if conditions 

(including salt block placement) are found to be in 

violation of the grazing permit. 

How would herd movement actually be controlled given the several 

Livestock distribution practices will be carried out by 

9 comments throughout the range report and EA about fewer riders Permit Compliance the permittee under supervision of the District 

and the thick timber in much of the area? Would ATV use increase 

Ranger or Forest Service representative. This 

A-3



Comment 

# 


in off-road areas? Is the FS staffed and funded of adequately 

direction is incorporated into the allotment 

monitor the permittee’s compliance with AMP? 

management plan and the annual operating plan. 

The annual operating plan becomes an integral part 

of the grazing permit and provides current Forest 

Service instructions. These instructions will reflect 

current allotment conditions and vegetative trends. 

Given direction in the Annual Operating plan, we do 

not anticipate an increase in off road ATV use. We 

expect to be sufficiently funded to monitor the permit 

holders’ compliance with the AMP. 

On Four Corners in Table 4 (Table 2 in the Range Report) the 

Estimated allowable use levels were calculated using 

Allowable Use was calculated at 0.8 head months per each 1.0 

data from two previous forage-production studies 

suitable acres for both Alternatives 1 and 2. Similarly, the Riparian 

conducted on the Idaho Panhandle NF’s (Project File). 

Suitable acres if looked at alone equates to 1.67 head months per 

The studies were conducted in similar areas, which 

10 

each suitable riparian acre in both alternatives. The lack of 

differences between Alternatives 1 and 2 in this Table indicates to 

me that the change in stubble height (6” greenline) was not taken 

into account when calculating allowable head months for 

Alternative 2. That seems like an important consideration given that 

Riparian is a significant (48%) portion of all Suitable acres under 

Alternative 2. It also seems contrary to many of the environmental 

summaries that conclude stable or improving conditions for 

Alternative 2 and reduced effects to the riparian areas or resources 

through higher stubble height, herd reduction or better dispersion. 

Overall for Alternative 2 the improving condition may be the case 

for areas removed, but it seems with the modified (6”) forage 

utilization criteria that further herd reductions would be needed. 

Cattle will still have the same feeding needs and habits. And if 

further head month reductions were not made then it would seem 

Allowable Use 

contain comparable riparian acres. In these studies, 

the average head month per acre was 1.1 and 0.8, 

respectively. As a conservative approach, 0.8 head 

months per acre was used to represent the three 

allotments being analyzed. This figure was used as a 

multiplier in the suitability analysis to determine 

allowable use. This also results in a conservative 

estimate of suitability. Regarding the 6” greenline 

stubble height – This standard generally has little 

bearing as greenline stubble height typically far 

exceeds that standard on the Priest Lake allotments 

and utilization of the forage adjacent to the greenline is 

a far better indicator (Project File). The selected 

alternative will eliminate grazing on the Four Corners 

Allotment over a 4 year period. The second year of the 

phase out would be below the analysis-derived 

that increased herd management and monitoring would be needed, 

allowable permitted use. We are confident that the 

and that more rapid reductions in stubble height could be expected 

allotment will move towards desired conditions during 

to occur elsewhere. Would Desired Conditions be met? 

the phase out process. 

A-4



Comment 

# 


In addition to the herd and allotment reductions it also seems that 

Grazing is being phased out on the Four Corners 

many of the environmental conclusions are riding on the 

Allotment over a 4 year period. On the other 

effectiveness of adaptive management (e.g. Pg. 41 Townsend Big 

allotments, there will be some reduction in acreage. 

Eared Bat Alternative 2), despite the fact that the ratio of head 

Additionally, the allowable forage utilization within 

months to suitable and riparian suitable acres 

the greenline would be decreased, requiring the 

11 

essentially doesn’t change. Under Alternative 2 the spatial extent of 

grazing would be reduced. The elimination of grazing on part of the 

current allotment is what primarily will improve overall conditions. 

Adaptive 

Management 

retention of a minimum 6-inch median residual 

stubble height of key hydric species. Once a 

minimum stubble height is reached, livestock would 

Where grazing continues however, the future allotment may be no 

be moved to other areas or off the allotment. We are 

better off. 

confident that with these measures along with the 

rest of the Adaptive Management Strategies, that 

indeed the overall conditions of the Allotments will 

improve. 

12 

Regarding authorized dates for grazing, in Four Corners with the 

light and patchy nature of suitable upland graze, cattle seem to 

fully utilize an area then move on. I’ve not observed any herd 

management to move cattle based on utilization levels (i.e. stubble 

height). 

While I understand the need to follow regulations and policy, I have 

concerns about waiting until the 5th year to close the allotment. Of 

first concern are the ongoing environmental effects of continued 

Permit Administration 

Forage utilization for upland areas would retain a 

minimum 3-inch residual median stubble height for 

key species. Once reached, livestock would be 

moved to other areas or off the allotment. 

cattle use and the level of herd management and monitoring that 

As implemented, Alternative 3 will phase out the 

13 

may occur during this period (i.e. the risk of less attention being 

paid during declining use). Second is the question of whether the 

actual use has in recent years been as high as the permitted use. I 

Alternative 3 - 

Baseline 

Four Corners Allotment based on a starting point of 

50 cow/calf pairs. The phase out schedule follows 

guidance in 36 CFR 222.4 and FSM 2231.62. 

think not. It would seem that if the actual use is lower, then the 

schedule of phase out could be accelerated (e.g. if 25% less than 

the allowed head months is already occurring, then 2011 would 

equate to Year 2 on the schedule.) 

Please see response #11. 

A-5



Comment 

# 


I presume this means only for NFS lands. If so, when the cattle are 

The grazing permit will require the permittee to map 

moving between private and NFS the weed problem would not be 

and notify the Forest Service permit administrator of 

identified and dealt with until after NFS land is affected. This 

any new populations of noxious weeds located on 

doesn’t allow for preventative or cooperative actions on adjoining 

the allotment. The permittee may be requested to 

14 private lands. Noxious Weeds assist in noxious weed treatments within the 

allotment. This may involve hand pulling, bioreleases, 

or chemical treatment. This does not rule 

out preventative or cooperative actions with 

adjoining private land owners. 

The Range report states that the expected benefit of a cattleguard 

Last year (2010), in an effort to address issues 

in this location and a fence along Hwy 57 “should eliminate 

associated with permitted cattle accessing Hwy 57 

livestock straying onto the highway, a serious public safety 

and creating public safety concerns, a fence was 

concern”. Although it may deter cattle from entering the Hwy at that 

installed just west of Hwy 57 to the south of the 

point, my observations are that cattle more often cross the Hwy 

Bonner County solid waste transfer site. This fence 

near Torelle Falls which is outside the allotment. 

dramatically decreased the number of times that 

cattle were seen in the vicinity of Hwy 57. Further to 

the south of where the new fence was installed, in 

the vicinity of Torelle Falls, we have not observed 

the permitted cattle accessing the Hwy. However, 

we certainly acknowledge the potential of this 

15 

Cattle Guard 

occurrence. We recognize that cattle could travel 

south and east from the allotment, via the Johnson 

Cutoff and/or Bear Paw Roads, and access the 

Hwy. We will monitor this situation during the 

upcoming grazing season and if the situation 

warrants, we will consider working with Bonner 

County to identify solutions. Those roads are under 

county jurisdiction and cattleguards, fencing or other 

improvements along those roads would require 

permission from the county. 

A-6 

The recognition on the commenter’s point was a 

consideration leading to the selection of Alt 3.



Comment 

# 


16 

17 

Given the FS has had minimal funds to support grazing 

administration, it seem unlikely this level of staff involvement could 

be effectively done except on the minimum cycle. Although it has 

merit for monitoring conditions, it also seems like a waste of 

government funds to invest this level of effort in support such small 

herd sizes. Why isn’t the permit holder held responsible to hire 

qualified persons to conduct several of the listed steps of 

monitoring since they are gaining the benefit of grazing NFS land 

at a very low cost and the impacts are caused by their activities? 

Ole Creek flows through a corner of my property in Section 6. 

Cattle grazing under the NFS permit over the past decade have 

routinely damaged fences along my south property line to access 

the waters of Ole Creek in an area my livestock have been 

excluded for the past 10 years. Some of the fence breech has also 

occurred by separated cow/calves and bulls seeking cows. I’ve 

observed cattle congregating and defecating in Ole Creek at this 

location, trampling existing vegetation and causing erosion and 

disturbed soils on the steep bank. The stream bottom sediments 

and disturbance has eliminated aquatic plants on that stretch and 

introduced a new population of knapweed that has required spot 

spraying and pulling 4-6 times per year to control. In 2009 I 

installed a new secondary fence which (at least for now) is 

protecting this steep bank and creek access. Based on the 

enormous effort it has taken to exclude cattle with fences from a 

very small riparian area and also treat weeds where soils were 

constantly disturbed, I think it would be highly impractical and 

unlikely the FS could succeed in reducing impacts to riparian areas 

anywhere cattle grazing is allowed. 

Adaptive 

Management 

Riparian 

Areas/Fencing 

We expect to have the funding/staff to monitor the 

allotments and implement an adaptive management 

strategy. The permit holder is responsible for 

monitoring vegetation utilization and moving 

livestock once utilization is met to ensure end of 

season compliance. 

We are aware of the conflicts being caused by cattle 

permitted to use NFS lands exercising their right to 

utilize open range in the area. The Four Corners 

Allotment is being phased out following guidance in 

36 CFR 222.4 and FSM 2231.62. Until this phase 

out is complete, property owners wishing to deny 

livestock access to their private land are required to 

construct adequate fencing under Idaho Code 25- 

2401 which permits livestock to run at large within 

unenclosed, unincorporated areas of the county. 

A-7



Comment 

# 


How will better livestock circulation occur given a reduction of 

Livestock distribution practices will be carried out by 

acreage for Alternative 2? In Four corners the cattle already 

the permittee under supervision of the District 

circulate to all NFS lands that contain graze. The cattle will 

Ranger or Forest Service representative. This 

continue to congregate in riparian and other historically heavily 

direction is incorporated into the allotment 

used areas until either graze is depleted (see 

management plan and the annual operating plan. 

18 

Photos 1 and 2) or when FS monitoring indicates that cattle need 

to be removed and that action is taken. I am unaware of the permit 

Utilization 

The annual operating plan becomes an integral part 

of the grazing permit and provides current Forest 

holder or FS taking action based on over-utilization within the 

Service instructions. These instructions reflect 

allotment, despite that condition routinely occurring. 

current allotment conditions and vegetative trends. 

The implementation of the Adaptive Management 

Strategies will further correct and/or eliminate 

adverse environmental effects. 

Regarding soils specific to Four Corners. The Alternative 2 

You are correct; the wrong number was used in the 

reduction of 722 acres is only a 36% reduction. Regardless, neither 

EA. The 722 acre reduction considered in 

Alternative 1 or 

Alternative 2 represents a 36% reduction in 

19 

2 would comply with regulatory requirements. How is the 60% 

reduction calculated? It doesn’t appear that Table 7 or Table 4 

Soils 

allotment size and overall soil disturbance. That 

being said, the implementation of Alternative 3 will 

could be the source for that conclusion. Most specialists “reduction” 

eliminate grazing and the potential for associated 

numbers vary slightly from Table 4, but the soils report appears to 

soil disturbance on the Four Corners Allotment over 

be the most significantly differing. 

Why the conclusion that “increased distribution practices” would 

occur for Alternative 2. On Four Corners according to Table 4 the 

allotment size on NFS acres would be reduced by 36% (41% for 

total acres) and the head months by 40%. This would equate to the 

same head months per acre however the ratio of riparian to 

a 4 year period. 

suitable acres would increase and no modification to the grazing 

Recognition of this was a major consideration 

20 season is proposed. I don’t see how this is increasing distribution Suitability/Utilization leading to the selection of Alternative 3 for the Four 

nor reducing effects for any environmental issues where grazing 

would still be allowed. Where grazing occurs the affect would be 

the same or greater than for Alternative 1 and cattle would continue 

to congregate in the LWBPR riparian areas. Private lands within 

the allotment are increasingly being fenced, further reducing 

distribution 

Corners Allotment. 

A-8



Comment 

# 


The Riparian Grazing acres of Table 7 for all allotments are 

The design criteria were different as the purpose of 

inconsistent with the Suitable Riparian Acres of Table 4 on Pg. 16. 

each table was to demonstrate different things. 

Although the defining criteria may differ, it seems odd that the 

There is also a good deal of professional judgment 

acreage variations are both higher and lower and in some cases 

involved. Table 4 attempted to estimate allowable 

substantial. 

use. Table 7 was used to derive the data for use in 

Table 6 which was used to determine whether or not 

21 

Suitability 

soil standards could be met. Table 6 is actually 

mislabeled as it does not reflect the “existing” 

disturbance, but rather assumed that every square 

inch of riparian was detrimentally impacted (which it 

is not). This is a conservative approach in that it is 

possible to occur, but highly unlikely. If you 

substitute the riparian acres from Table 4 into Table 

6, the end result is the same. 

In T57N R5E Section 6 significant populations of knapweed exists 

We understand and acknowledge this. The entirety 

along the LWBPR. Houndstounge is widely scattered away from 

of T57N R5E Section 6 is privately owned. This 

22 

roads in timbered and brushy locations that cattle have used for 

cover during the warm days and evenings. 

Although the numbers of cattle would be reduced the allotment size 

would also (be reduced). The ratio of head months to suitable 

Noxious Weeds 

limits both our responsibility to treat these 

populations and the potential set of solutions 

available to us. The District’s noxious weed 

manager has been made aware of this situation. 

23 

acres and the season of use will not change under alternative 2, so 

the risk of cattle spreading weeds would remain the same on the 

reduced allotment area. Weed spread from cattle would only be 

reduced where cattle can no longer graze. 

Concerned by increasing incidence of knapweed and 

Noxious Weeds Acknowledged. 

24 houndstongue infestations spread by permitted cattle which are a 

significant threat to the welfare of her pastures. 


A-9



Comment 

# 

Comment 

Believe the FS has an obligation to conduct follow-up treatments 

and monitoring for several years after the active use of all 

allotments particularly where the presence and invasion of weed 

Issue Response 

25 

populations exists such as in Four Corners. Sees no support in the 

EA related to Four Corners for the statement on pg. 52 …with the 

exception that noxious weeds would no longer be treated by 

permittees…..The only statement related to this activity is in the 

wildlife section regarding Lamb Creek. 


Several items related to streambank and riparian monitoring 

In addition to USFS monitoring, the permittee’ has a 

indicate late summer or fall for annual or 2-3 year monitoring visits. 

responsibility to insure that standards are met. The 

Visits that late in the grazing season on Four Corners may be 

baseline data for this analysis was collected in the 

beneficial to observe trends but would not be timely to change 

fall and in order to compare data, future collections 

26 current grazing season practices. Believes grazing impacts on 

Monitoring would need to be gathered at the same time as 

these areas occurs earlier and if monitoring found adjustments 

previous years. Having said that, in the Adaptive 

were warranted, changes could be implemented for the remainder 

Management Strategy, the FS will respond and 

of that season. 

change grazing practices if grazing thresholds are 

exceeded regardless of the time of year. 

27 

Did not see discussion in the AMP or Monitoring regarding 

monitoring changes to noxious weed populations. 

Two weed species of particular concern relative to cattle movement 

are knapweed and houndstounge. Both plants are generally intact 

following winter which allows cattle to graze on knapweed seed 

heads from the prior year and transport houndstounge seed that 

becomes attached to their hair. So although I agree with the 


28 comment from the weed report (above )for some species, it doesn’t 

dismiss the risk with knapweed or houndstounge. Although the risk 

at turnout is relatively small compared to season-long transport of 

weeds in the allotment it could be mitigated by controlling where 

cattle graze a few days prior to turnout and cleaning hair coats 

before release. 


A-10



Comment 

# 

Comment 

Although reduced or lost funding may occur under Alternative 3, 


29 

the FS has the prerogative to determine areas for (noxious weed) 

treatment and understandably this area should be prioritized based 

on need relative to other areas. 

Range Report Pg. 5 - Four Corners Allotment: 


30 

“Over the past few years livestock have had access to highway 

57 due to a timber sale removing the fence. This 

highway access problem is in the process of being resolved by 

replacing the removed fence line”. 

The fence paralleling Hwy 57 that was removed through the 

57BearPaws project had for the most part not been maintained in 

any recent times and was ineffective. Presumably maintenance 

had ceased due to the dense nature of timber stands that created a 

natural barrier and shaded out grasses. Although the timber sale 

activities have changed conditions slightly, the fence was not 

replaced at that time since an analysis and decision on the 

allotment permit was forthcoming and could change the need. 

Fencing 

Last year (2010), in an effort to address issues 

associated with permitted cattle accessing Hwy 57 

and creating public safety concerns, a fence was 

installed just west of Hwy 57 to the south of the 

Bonner County solid waste transfer site. This fence 

dramatically decreased the number of times that 

cattle were seen in the vicinity of Hwy 57. 

Respondent #2: Robert Hagman – March8, 2011 

Comment 

# 


1 

Would support adaptation of Alternative 3 if its’ “flaws” were 

corrected. 


Acknowledged. 

A-11


Respondent #2: Robert Hagman – March8, 2011 

Comment 

# 

Comment 

Sees a glaring flaw with Alternative 3. The way it is written it 

appears that the permittee can start the wind down of the herd 

based on having 83 cow/calf pairs. Is surprised that the FS is not 


aware that less than half that many pairs is the number being 

As implemented, Alternative 3 will phase out 

2 

grazed in recent years. To allow the permittee to start with the 

wrong number would let him/her impose on us for four years 

about the same number of pairs that have been out there for 

Alternative 3 - 

Baseline 

the Four Corners Allotment based on a starting 

point of 50 cow/calf pairs. The phase out 

schedule follows guidance in 36 CFR 222.4 

several years. I have been told that there are about 30 pairs that 

will be out there this year and that number should be the starting 

one to be reduced 25% each year. Feels that a 4 years phase out 

is way too generous and 2 or 3 should be adequate. 

and FSM 2231.62. 

Believes that open range designation of the Four Corners Area is 

Acknowledged. Private property in the project 

way out of tune with the way things are today. 

area is designated as Open Range under 

Idaho Code 25-2401, permitting livestock to run 

3 

Open Range 

at large within unenclosed, unincorporated 

areas of the county. As the State law currently 

stands, property owners wishing to deny 

livestock access to their private land are 

required to construct adequate fencing. 

Concerned about the lack of animal husbandry in the permittees 

Throughout the grazing season, allotments will 

grazing plan and the potential for continued environmental 

be monitored/reviewed to determine if 

damage - particularly to creek beds and swimming holes. 

livestock are moved on time, total animal 

numbers are in compliance, cattle ownership, 

4 

Aquatics 

forage utilization, allotment improvements, and 

BMP effectiveness. Permitees will participate 

with permit administrators in these reviews. 

Notices of noncompliance will be issued for 

violations. Immediate action will be taken on 

resource threats, trespass, or other violations. 

Concerned about damage that happens to private property 

Acknowledged. 

5 including cut fences, knocked down fences, young tree plantings 

ruined salt licks placed on other’s property etc. 

Open Range 

A-12


Respondent #3: Anne Chamberlain- March 5, 2011 

Comment 

# 


Concerned about the effects of “free range” cattle on private 

Private property in the project area is 

property. 

designated as Open Range under Idaho Code 

25-2401, permitting livestock to run at large 

1 

Open Range within unenclosed, unincorporated areas of the 

county. Property owners wishing to deny 

livestock access to their private land are 

required to construct adequate fencing. 

Was advised that the “open range” doesn’t extend as far east as 

There is no established herd district west of 

her mother’s home. If this is true, questions what recourse her 

Hwy 57 in the Four Corners area. The Forest 

mother has as to the continual damage done to her property by 

Service jurisdiction does not extend to privately 

“free range” cattle. 

managed lands. The permittees must adhere 

2 

Open Range to the allotment permit when utilizing Forest 

Service ground. However, private property 

owners wishing to deny livestock access to 

their private land are required to construct 

adequate fencing (Idaho Code 25-2401). 

Respondent #4: Patricia Andrews, PhD – March 5, 2011 

Comment 

# 


Questions why the starting cattle count for the Four Corners 

As implemented, Alternative 3 will phase out the 

Allotment would be 83 cow/calves when the current permittee has 

Four Corners Allotment based on a starting point 

1 only been running about 30-40 head. Feels that using this starting Alternative 3 - Baseline of 50 cow/calf pairs. The phase out schedule 

point would effectively double the allotment and cause twice the 

follows guidance in 36 CFR 222.4 and FSM 

problems in the area. 

2231.62. 

A-13



Comment 

# 


Her lawn grass, gardens, fishpond, wild orchids, and fences have 

We are aware of the conflicts being caused by 

been damaged by the permitted herd. 

cattle permitted to use NFS lands exercising their 

right to utilize open range in the area. The Four 

2 

Open Range 

Corners Allotment is being phased out following 

guidance in 36 CFR 222.4 and FSM 2231.62. 

Until this phase out is complete, property owners 

wishing to deny livestock access to their private 

land are required to construct adequate fencing. 

Mass die-offs of western toads as a result of 

trampling by grazing livestock have been 

reported in the literature (see Maxell 2000 for 

review). However, this type of event is more 

typical in areas with heavy grazing use (usually 

domestic sheep) near breeding habitats. Given 

3 

Had toads in the woods until this year’s trampling; now they are all 

gone. 

Wildlife - Toads 

the level of grazing in proposed allotments and 

the widespread availability of potential breeding 

habitat in the Priest River basin, continued 

grazing in remaining allotments is unlikely to 

result in considerable impacts to this species. 

Instead, the presence of lethal pathogens, such 

as the chytrid fungus, have been implicated as a 

more likely causal agent of population declines. 

A-14 

4 

5 

Concerned that permittee takes cows from others and mixes them 

with their own. 

Doesn’t agree that it should be the driver’s responsibility to replace 

cows killed when driving at or below the posted speed limit. 


Grazing permits will be monitored for 

compliance. Corrective action will be taken if 

conditions are found to be in violation of the 

grazing permit. 

Open Range Acknowledged.



Comment 

# 


Commenter must be hopeful that if she leaves during the months of 


“free range” that upon return her yard, woods, and what would 

area is designated as Open Range under Idaho 

have been winter food would not be a disaster. 

Code 25-2401, permitting livestock to run at 

6 

Open Range large within unenclosed, unincorporated areas of 

the county. Property owners wishing to deny 

livestock access to their private land are required 

to construct adequate fencing. 

Respondent #5 – Rosetta Brockway – March 7, 2011 

Comment 

# 


1 Supports phasing out the Four Corners Grazing Allotment 

Preferred Alternative Acknowledged. 

2 Over the last 30 years encounters with the permitted cattle have 

increased as their open grazing areas have decreased. There is 

not enough open land for the cattle to graze. 

3 Breaches in her fences have allowed permitted cattle to destroy 

her hay, yard, garden and allowed them to degrade the Lower 

West Branch where it runs through her property. 

Range Suitability Acknowledged. 

Open Range 




large within unenclosed, unincorporated areas of 




Respondent #6 – Belinda Melton – March 8, 2011 

Comment 

# 


1 Supports phasing out the Four Corners Grazing Allotment. Preferred Alternative Acknowledged. 

2 Would prefer that bulls not be turned loose as they are dangerous 

and particularly destructive. 

Public Safety Acknowledged. 

A-15


Respondent #6 – Belinda Melton – March 8, 2011 

Comment 

# 


3 Feels it would be a waste of time and money to put up a cattle 

guard on Johnson Creek as the cows would just go through the 

creek and around. 

Cattle Guard Acknowledged. 

4 Concerned that permittee allows cows belonging to other, 


unpermitted owners to mix with their own to run on the allotment. 


compliance. Corrective action will be taken if 

conditions are found to be in violation of the 


5 Concerned that permitted cattle have vectored weeds including 

knapweed and daisies on to private property including her own. 


6 Commenter was surprised to learn that the allotment was 

supposed to be monitored annually as they have never seen a 

rangeland management specialist in the area. 

Monitoring/Permit 

Compliance 

Grazing permits will be monitored for compliance 

throughout the grazing season. 

7 Believes that permitted cows are not off the allotment on time. 


Cows and the bulls have come of NFS lands on to her property up Monitoring/Permit compliance. Corrective action will be taken if 

to 2 weeks after they are supposed to be off the allotment. 

Compliance conditions are found to be in violation of the 


Respondent #7 – Carolyn Halkias – March 10, 2011 

Comment 

# 


1 Supports phasing out the Four Corners Grazing Allotment Preferred Alternative Acknowledged. 

A-16


Respondent #8 – Roger Gregory –March 3, 2011 

Comment 

# 


1 Opposed to open range in the Four Corners area. He is unable to 


maintain fences and open range cattle are trampling and killing 


seedlings on his property. 


Open Range large within unenclosed, unincorporated areas of 




2 Would prefer an immediate end to open range, but sees Alternative 

Acknowledged. As implemented, Alternative 3 

3 as a compromise that would work with one year cut out of it. 

will phase out the Four Corners Allotment based 

Preferred Alternative on a starting point of 50 cow/calf pairs. The 

phase out schedule follows guidance in 36 CFR 

222.4 and FSM 2231.62. 

Respondent #9 – Paul Sieracki – March 16, 2011 

Comment 

# 


1 Favors elimination of all three allotments due to impacts on 

Acknowledged. The Forest Service is not 

wetlands and wildlife and damage to streams. An enhanced 

charged with the management of animal 

Alternative 3 would be wise if cattle are excluded from all wetlands 

populations. For this project area, all animal 

during the reduction of stock and if beavers are actively 

populations are managed by the Idaho 

encouraged to repopulate areas like West Fork Moores Creek 

either naturally or through reintroduction of family groups 


Department of Fish and Game. The Forest 

Service is charged with enhancing wildlife 

populations where appropriate. There is nothing 

in the AMP that would prevent beavers from 

repopulating any of the streams flowing through 

NFS lands. 

A-17



Comment 

# 


2 Any off road use by OHV’s is unacceptable due to the potential of 

impacts to wetlands, displacement of wildlife, mechanical 

destruction of undiscovered rare and sensitive plant populations, 

and the unintentional spread of noxious weeds, and non native 

plant species. In addition ATV use behind gates and on usercreated 

trails may displace gray wolves and grizzly bears from 

utilizing the area. 

OHV Use Acknowledged. 

3 Grazing must be excluded from all wetlands to avoid impacting 

Wetlands that support the population of 

Hypericum majus. 

Hypericum majus in the Lamb Creek allotment 

would be protected by a drift fence to preclude 

use by livestock. A qualified botanist would 

Rare plants 

specify the location of the drift fence and would 

monitor its effectiveness annually (Weeds Report 

p. 6). If livestock grazing is having an 

unfavorable impact on the population; then 

action will be taken to eliminate the conflict (EA 

p. 12). 

4 Concerned that Table 3. “Past, Present, and Reasonably 

The word beaver was not “sanitized” from the 

Foreseeable Actions” in the EA is incomplete in its’ failure to list 

EA. It was only mentioned “briefly” in the wildlife 

removal of beaver populations through trapping and breaching 

report in the context of: 1) providing prey for 

dams which is one of the crucial elements to functioning riparian 

gray wolves, and 2) providing shelter for 

ecosystems. Feels the word beaver may have been sanitized from 

hibernating toads or habitat for toad breeding. 

the EA and is concerned that beaver aren’t mentioned in the 

The issue of beaver presence (or lack thereof) 

hydrology report and only mentioned briefly in the wildlife report. 

was never raised in scoping or at any point in the 

Beaver analysis, and the first mention of the species by 

this (or any) commenter was after the EA was 

released. This species was not previously 

brought up in comments; is not identified as a 

species of greatest conservation need in Idaho 

or Washington; and is not federally listed, Region 

1 sensitive or MIS on the IPNF. 

A-18



Comment 

# 


5 The EA Fails to address the effects of the lack of a keystone 

species, the beaver, either present or present in recent history, 

which is a native species and crucial to proper function of these 

riparian ecosystems. 

Hydrology/Wildlife 

Please see comment #1. We acknowledge the 

role of beaver in the riparian ecosystems. 

6 Concerned that the removal of beaver populations through trapping 

Acknowledged. The management of animal 

and breaching of dams was not considered in the cumulative 

populations is outside of purview of the USFS. 

effects analysis. 

The occasional removal of a beaver dam 

Hydrology/Wildlife threatening a USFS Road culvert is outside the 

limits of a reasonable cumulative effects analysis 

because it is simply part of regular road 

maintenance. 

7 Should consider re-introduction of beavers to the area, or the 

cessation of beaver trapping in the entire Moore’s Creek watershed 

allowing beavers to repopulate naturally. 

Hydrology/Wildlife 

Acknowledged. The management of animal 

populations is outside of purview of the USFS 

8 Moores Creek, a fish bearing stream, has been channelized by 

dredging in 2006 (est) without permit, causing additional 

dewatering of the wetlands the creek flows through. This 

astonishing lack of stewardship by the adjacent landowners would 

likely be reflected in the allotment on Federal lands. The effects of 

dewatering the private side of dual ownership wetlands must also 

be analyzed in detail as the dewatering may affect wetlands on 

adjacent Federal Lands. 

Hydrology 

Aware and acknowledged. This was addressed 

in Table 4 and page 24 of the Hydrology Report. 

9 Both Moore’s Creek and Lamb Creek Allotments encompass 

There is allocated old growth in the allotments 

allocated (special use 9) old growth stands. There is no discussion 

noted in this comment, but cattle do not utilize 

of the impacts of biomass removal in these stands in relation to 

maintaining ecological integrity, old growth management indicator 

Old Growth 

these old growth stands due to the lack of 

available quality forage. Therefore, grazing is 

species and sensitive species. 

not expected to have impacts in old growth 

stands. 

A-19



Comment 

# 


10 

The potential effects of the various alternatives 

on western toads are discussed in detail in the 

Wildlife Report (p. 31-33). Western toad 

presence has been documented throughout 

Disagrees that Alternatives 1 and 2 will not contribute towards 

much of the Priest Lake Ranger District (project 

federal listing of Western Toads because there is no 

file). There is no habitat “proxy” for this species, 

documentation of Western Toads in the area, just an assumption of 

and it is not MIS on the IPNF. The analysis 

presence based on habitat (proxy on proxy), the cumulative effects 

focuses on breeding habitat, since the species 

analysis is not quantitative or spatial; cattle are allowed to graze on 

uses a variety of upland habitats and loss of 

wetlands. Grazing reduces plant biomass that contributes to the 

breeding habitat is a primary risk factor for the 

production of insects that are required by Western Toads. Beaver 

species (Wildlife Report p. 30). While cattle 

are not being encouraged to repopulate the streams so that historic 

grazing may affect breeding habitat within the 

hydroloc disturbance regimes can be restored, along with 

Toads allotments themselves, breeding habitat likely is 

increased wetland area. There is an ongoing chronic reduction in 

not limiting in the Priest River basin due to an 

wetland area in the West Fork Moores Creek drainage, which in 

abundance of wetland habitat – including several 

itself is not properly functioning, and therefore any active allotment 

large wetland complexes on USFS lands within a 

causes a reduction Western Toad breeding habitat that could be 

few miles of the permit areas (Wildlife Report p. 

alleviated. The same is true for Lamb Creek. Repopulation of 

31). Habitat alteration from livestock grazing is 

these ecosystems with beavers and elimination of grazing would 

not believed to be a primary cause of toad 

provide additional breeding and wintering habitat for the Western 

declines (Loeffler 1998). We do not agree that 

Toad. 

there is an “ongoing chronic reduction in wetland 

area” in West Fork Moores Creek or Lamb 

Creek. In fact, there is evidence that beavers 

recently occupied West Fork Moores Creek. 

A-20 

11 Without the reintroduction of beavers to the riparian habitats, the 

existing condition and all alternatives are a major negative impact 

to riparian and wetland dwelling neotropical songbirds of interest. 

Forest landbirds 

Beaver populations are managed by the State of 

Idaho, not the US Forest Service. Reintroduction 

of this species is outside the scope of a project 

that is focused on livestock grazing. There is no 

reason to believe that grazing has led to beaver 

population declines, or is inhibiting recolonization 

of these areas by this species.



Comment 

# 


12 Fisher are not assessed in detail and likely should be due to the 

While some old growth exists within the Lamb 

presence of old growth, and riparian areas that have been heavily 

Creek and Moores Creek allotments, these are 

impacted by allotment management and cattle themselves. 

western redcedar-dominated stands with very 

little herbaceous vegetation in the understory. 

Consequently, they would have little forage value 

for cattle, and are unlikely to be utilized by 

livestock to any considerable extent. As a result, 

potential effects to fisher habitat from cattle use 

of old growth stands would be virtually non- 

Fisher 

existent. Similarly, the conifer-dominated 

riparian areas preferred by fisher would have 

relatively little cattle use, and potential changes 

to fisher habitat structure would be 

inconsequential. It is also important to note that 

nearly all of the riparian habitat in the vicinity of 

the Lamb Creek allotment, and most of that 

around the Moores Creek allotment, is under 

private ownership and would not be affected by 

this permit. 

13 Fishers also feed on snowshoe hares, impacts to snowshoe hares 

should also be analyzed in all allotments. 

Snowshoe hare 

Livestock grazing is expected to have little, if 

any, effect on snowshoe hare densities. Cattle 

are primarily grazers (eating herbaceous material 

such as grasses and forbs), while hares are 

primarily browsers (subsisting on the woody 

vegetation) – so there would be little competition 

for available forage. Hares select habitats based 

on the presence of dense understory cover, 

rather than food; and the main mortality source 

of hare populations is predation. Cattle presence 

would have very minor effects to vegetation 

structure in forested areas where fisher may be 

present. Potential reduction of vegetative 

A-21



Comment 

# 


biomass in open (meadow) areas would be of 

minor consequence to hares, and would not 

affect fisher. 

A-22 

14 All TES and MIS species need to be analyzed in more detail. 

Wildlife analysis 

When making decisions requiring National 

Environmental Policy Act (NEPA) analysis, the 

level of analysis should be commensurate with 

the complexity of the proposed action. Given 

that the proposed action would have only minor, 

if any, effects on most TES and MIS species, the 

level of analysis is appropriate. The commenter 

gives no examples where additional analysis of 

these species would be further illuminating, or 

result in a more informed decision. 

Respondent #10 – Idaho Conservation League – Brad Smith – March 16, 2010 

Comment 

# 


1 

Registration of support for Alternative 3 in order to help improve 

water quality and aquatic habitat. 

Preferred Alternative Acknowledged. 

2 The EA indicated that many of the areas where noxious weeds 

In 1997, a FEIS and ROD were completed that 

would be treated are covered in the Priest Lake Ranger District 

authorized the treatment of noxious weeds on 

ROD for Noxious Weed Control. After a review of that ROD, it does 

the Priest Lake Ranger District of the IPNF 

not appear that all of the locations are included. If “analysis of site 

(USDA Forest Service, 1997). The treatment 

characteristics to ensure treatment would not add significantly to 

effects described in the FEIS,” has occurred in any of the areas 

Noxious Weeds 

plans in those documents have guided the weed 

management and control activities across the 

referenced in the EA, details should be included in the Final EA 

District, including the project area that 

and Decision Notice. Otherwise, we are concerned that ongoing 

grazing will violate requirements limiting the spread of invasive 

weeds and the related executive order. 

encompasses the grazing allotments.


Respondent #11 – The Lands Council/Alliance for the Wild Rockies – Jeff Juel – March 16, 2010 

Comment 

# 


1 Appreciation of the range of alternatives analyzed. Alternatives Acknowledged. 

2 We recognize state laws govern open range, however your agency 

Acknowledged. 

cannot just deny accountability when a decision to continue grazing 

would result in continuing conflicts with landowners near national 

forest lands. 

Social acceptability 

3 The EA does not specifically discuss suitability of the Four Corners, 

The Regional criteria for determining suitability 

Lamb Creek, and Moores Creek Allotments in terms of the criteria 

were used. The analysis is in the project record. 

the FS uses for determining suitability. Display of Table 4 does not 

suffice. We believe that a detailed analysis ought to be a 

NEPA/public process, a part of this EA. 

Range suitability 

4 The EA does not disclose why the FS originally (in scoping) felt the 

The original proposed action for this allotment, as 

Four Corners allotment ought to be reduced to 520 acres 

described in the August 2006 scoping letter, 

redefined the Four Corners allotment boundary to 

Public disclosure/NEPA 

520 acres. This allotment acreage was 

determined to be too small to support the 

minimum number of cows required for a grazing 

permit and was eliminated from detailed study (EA 

p. 7). 

5 Given that so much of the forage base is “transitory” and relies 

No such activities are planned in the allotments. 

upon logging and/or burning, how that factors into the FS’s 

Suitability was based on existing conditions/forage 

determination of the “suitability” of the allotments must be better 

disclosed. Does the FS believe that the agency has a responsibility 

to create forage on these allotments via logging and/or burning? 

Range suitability availability. 

6 The use of other FS management actions to create “suitability”— 

Past, present and reasonably foreseeable FS 

even if they are an unintended side effect, requires full analysis 

and disclosure. 

Cumulative effects 

management actions including those potentially 

resulting in the creation of “suitability” were 

considered in the cumulative effects analysis. 

7 Alternative 2 relies upon permittees to carry out monitoring of 

noxious weeds, and then committing their own resources to assist 

Acknowledged. 

in treatments. We are concerned that the permittee would lack 

motivation for notifying the FS of new noxious weed sites if they 

then had to take the time to treat them. 

Noxious weeds 

A-23



Comment 

# 


8 The EA notes the threat to Sensitive plants, but does not propose 

A botanist would monitor wetlands that support 

to keep livestock away—only monitor and create an exclosure if 

Hypericum majus populations, annually (EA p. B- 

necessary. The EA does not disclose the threshold level of 

2). If livestock grazing is having an unfavorable 

damage to these plant populations when action would be taken. 

impact on the population; then action will be taken 

Since the EA does not disclose the degree of already accumulated 

to eliminate the conflict (exclosure creation). If 

damage to these Sensitive plant populations, we wonder how the 

necessary, populations of Lycopodium 

FS can know if a compelling threshold hasn’t already been 

dendroideum and Dryopteris cristata along Lower 

crossed. 

West Branch Priest River in the Four Corners 

Sensitive plants 

allotment would be protected by a fence to 

preclude use by livestock. A botanist would 

determine the need for such protection through 

annual monitoring and specify the location of the 

fence. (EA p. 12). With this mitigation, grazing 

will not result in a trend toward federal listing or a 

loss of species or population viability for any rare 

plants. Drift fences or other exclosures would be 

removed following the last season of grazing on 

the Four Corners allotment. 

9 There is no discussion of the impacts of livestock grazing in old 

There is allocated old growth in the allotments as 

growth and other forest stands in relation to maintaining habitat 

noted in this comment, but cattle do not utilize old 

components and thus viability of old growth management indicator 

species and sensitive species. 

Vegetation/MIS 

growth stands within this allotments given the lack 

of available quality forage. Therefore, grazing is 

not expected to have impacts in old growth 

stands. 

A-24



Comment 

# 


10 The EA also provides too limited discussion of the birds and other 

The USFS has entered into a Memorandum of 

wildlife that depend quite heavily upon intact, fully functioning 

Understanding (MOU) with USDI Fish and Wildlife 

riparian ecosystems. 

Service that defines the responsibility of the 

Forest Service to protect migratory birds. In the 

MOU, the USFS agreed to evaluate the effects of 

agency actions on migratory birds within the 

NEPA process, focusing first on species of 

management concern along with their priority 

habitat and key risk factors. For the IPNF, the bird 

species of management concern are those 

species designated as sensitive and MIS. 

Consequently, the IPNF is in compliance with the 

MOU by analyzing the potential effects to these 

bird species and their habitat at the project level, 

such as in this document. 

Riparian-dependent 

wildlife 

As the EA points out, it is impractical to undertake 

a species by species analysis of forest landbirds 

due to the large number of species that can occur. 

Instead, the analysis addresses priority habitats 

identified by Idaho Partners in Flight (2000) – in 

this case riparian and non-riverine wetland 

habitats. Grazing allotments would affect a 

relatively small proportion of these priority habitats 

in the Priest River basin, and habitat conditions 

are expected to improve through reduction of 

allotment sizes and elimination of grazing in the 

Four Corners allotment. Once again, it is not 

apparent that additional analysis or discussion 

would lead to a more informed decision regarding 

this proposal. 

A-25



Comment 

# 


11 The EA entirely fails to consider the impacts of livestock grazing on 

Acknowledged. The Forest Service is not charged 

an important keystone wildlife species, the beaver. 

with the management of animal populations. For 

this project area, all animal populations are 

managed by the Idaho Department of Fish and 

Beaver Game. The Forest Service is charged with 

enhancing wildlife populations where appropriate. 

There is nothing in our Allotment plan that would 

deny beavers from repopulating any of the 

streams flowing through NFS lands. 

12 “Each year the District Ranger and the District Rangeland 

Acknowledged. The AMS is a dynamic process. 

Management Specialist would decide if there is a need for the 

It is highly probable that the team will meet far 

(Adaptive Management Implementation Team - AMIT) to meet. At 

more often than once every five years. The 

a minimum, the team would meet every five years to review Adaptive Management thresholds established in the AMS allow the 

implementation and monitoring.” Since Alternative 2 heavily relies Implementation Team permit administrator to correct problems 

upon instituting a new management regime here, it would be more 

immediately without having to wait to convene the 

appropriate to commit to an active AMIT for several years—starting 

as soon as a decision is made. 

AMS team. 

13 Under Alternatives 1 and 2, “…cows would continue to congregate 

We disagree. In the Hydrologist Report from 

in the wet/moist areas of the allotment and continue to trample and 

pages 26 to 30, there is detailed narrative 

erode stream banks and compact soils in the wetter areas.” The 

EA does not provide enough analysis, including discussion within 

Forest plan consistency 

regarding how each alternative meets/exceeds 

Forest Plan Standards and Guidelines and all 

the context of Forest Plan Standards and Guidelines, to 

demonstrate consistency with the Forest Plan. 

other pertinent rules and regulations. 

14 “Where cattle access was not hampered, the banks were heavily 

Grazing is being phased out on the Four Corners 

trampled and the channel beds had noticeably more silts. … 

Allotment over a 4 year period. On the other 

Ongoing grazing in the remainder of the Four Corners Allotment 

allotments, allowable forage utilization within the 

would continue to degrade the main stem of both Moores Creek 

greenline would be decreased, requiring the 

and Lower West Branch through bank trampling and subsequent 

delivery of sediment to the streams.” How is this consistent with 

the Forest Plan/INFISH? 

Forest Plan/INFISH 

Consistency 

retention of a minimum 6-inch median residual 

stubble height of key hydric species. Two new 

fences would be constructed along Moores Creek 

to keep cattle out of the riparian area; one fence 

would be located in the northern portion of the 

allotment (in the requested add on area) and 

A-26



Comment 

# 


another fence would be erected in the southern 

portion of the allotment. See Appendix C of the 

EA for photos of each fence location. The Inland 

Native Fish Strategy adherence is documented on 

page 28 of the Hydrology Report. We recognize 

that while each of the action alternatives would 

result in a positive trend for the RMOs, overall the 

target RMOs would not be achieved for many 

years because of the existing level of damage to 

the channel banks in specific locations. 

15 The EA indicates that “continued grazing would not allow for 

improvement to already degraded stream segments” in the Lower 

West Branch, and that “the channel would continue to have point 

sources of sediment and failing banks.” This does not seem 

consistent with the Forest Plan or the Clean Water Act. The EA 

also does not demonstrate how continued grazing would be 

consistent with the TMDL for sediment written for the Lower West 

Branch. 

Clean Water Act 

The phase out of the Four Corners grazing 

allotment should allow for recovery of banks and 

eliminate some sediment sources associated with 

grazing on the Lower West Branch. This is 

addressed on page 28 of the Hydrology Report. 

One section of the report specifically states: “In 

the Four Corners Allotment, there would be some 

reduction in sediment delivery through the 

removal of the western most portions of the 

allotment. However, in the vicinity of the CCC 

camp (within the Four Corners Allotment), 

sediment delivery would continue because fencing 

this portion of the riparian zone is not feasible. 

When summing up the effect of the cattle 

allotments within the Lower West Branch 

drainage, there will be a net benefit to the stream 

from the implementation of the proposed 

alternatives. Because there is a positive trend 

towards reducing the pollutants of concern 

(sediment) for the Lower West Branch drainage, 

the proposed alternatives would adhere to the 

A-27



Comment 

# 


Antidegradation Policy to provide water quality 

protection of existing uses (IDAPA 58.01.02.051). 

16 Regarding damage to soils from livestock grazing, the EA states, 

In fact, the approach used is far more 

“Soil quality standards are applied to ‘activity areas’ or individual 

conservative than existing conditions. Table 6 

allotments.” Is this saying that the entire allotment is an “activity 

reflects the “potential” disturbance. A detailed 

area?” Regardless the EA fails to disclose the existing and 

cumulative amounts (quantity, percent of detrimental disturbance) 

within any “activity area.” This means that consistency with the 

Forest Plan and Regional Soil Quality Standards is not shown. In 

fact, Table 6 seems to indicate a situation of violation already. 

Soils 

discussion of how Table 6 was developed is 

contained in the soils specialist report. 

17 The EA also does not disclose the extent of overall noxious weed 

The EA and associated noxious weed report 

occurrence in the allotments, so that weeds’ effects on land 

Noxious weeds describe and disclose the noxious weed situation 

productivity can be estimated. 

on the allotments (EA p. 47). 

18 The EA contains no economics analysis. The amount of federal 

The IPNF Forest Plan directs that range forage 

resources expended to maintain livestock on these allotments 

production be managed at current (1987) levels 

under any alternative is not disclosed. Therefore there is no way for 

with additional emphasis to protect stream banks, 

the public to understand the value of continuing livestock grazing 

riparian zones, threatened and endangered 

on these allotments. The EA doesn’t disclose even the monetary 

value the allotments have to the permittees. Why is this issue 

species and wildlife values. 

irrelevant to the FS? 

It is in this context that the IDT used criteria 

developed from Region 1’s Rangeland Suitability 

for Livestock Grazing Desk Guide (03/06/03) to 

Economics 

determine rangeland capability and suitability of 

the allotments. 

A-28 

The regional desk guide directs that areas should 

be subtracted from the allotments where the IDT 

determines that livestock grazing is not 

economically feasible when considering the costs 

of complying with applicable laws, regulations and 

Forest Plan standards. 

The guide directs that this should not be



Comment 

# 


interpreted as making decisions for a free market, 

but rather should evaluate the costs of mitigations 

and constraints and management activities that 

would be needed to ensure compliance. 

19 Regarding Appendix B, the Monitoring Plan’s frequency must be 

We disagree. The Adaptive Management 

specified. “Throughout the grazing season” doesn’t have a lot of 

Strategy provides clear direction and yet gives the 

meaning. Also, the “Trigger” for the Adaptive Management is quite 

most flexibility to “correct” any problems/concerns. 

vague for most Indicators. Given that Appendix B is the turnkey for 

The flexibility is important because sometimes it is 

Alternative 2’s projected success, it is vital that its components be Monitoring not just one threshold that is of concern. For 

more detailed and the public better understand the FS’s 

example, if the threshold of one trigger is being 

commitments. 

approached, we could conceivably take action 

before the threshold is exceeded. Taking swift 

action would be the key to success. 

Respondent #12: Kinnikinnick Native Plant Society – Molly O’Reilly – March 8, 2011 

Comment 

# 


1 

Registration of general support for the preferred alternative. Preferred 

Alternative 

Acknowledged. 

Concerned that it does not go further in protecting riparian areas. 

As part of the decision, all of the grazing (riparian and non- 

Disproportionate amount of suitable grazing acres located within 

riparian) in Ole, Tunnel and Big H would be eliminated 

riparian areas on the Four Corners Allotment. Potential for grazing 

from grazing within the Four Corners Allotment. The Four 

to affect Botrycium and other species of interest. Would like to see 

Corners Allotment was reduced by 36% under Alternative 

2 

more steps to limit the number of cattle and limit access to 

streams. 

Sensitive plants. 

2. The remaining riparian acres within the Four Corner 

Allotment would be monitored to attempt to prevent further 

degradation. Fencing was explored and determined to not 

be reasonable (Hydrology Report, pages 23 and 24). 

Finally, the Four Corners allotment will be phased out, and 

within five years, there would be no grazing in any of the 

riparian areas associated with the Four Corners Allotment. 

Stocking rates on the Lamb Creek allotment are well 

below the estimated allowable use (EA p. 15). A 

A-29


Respondent #12: Kinnikinnick Native Plant Society – Molly O’Reilly – March 8, 2011 

Comment 

# 


cattleguard/drift fence on Forest road 639 will restrict 

access to the southwest portion of the Lamb Creek 

allotment (EA, p. 15). Sensitive plant populations and 

habitat (including the Hypericum majus populations in the 

Lamb Creek allotment) will be monitored annually and 

changes made under the adaptive management strategy 

to reduce impacts of grazing as necessary. 

Concerned about the presence on non-native canary grasses in 

Agree and acknowledge. Increasing riparian stubble 

the Moores Allotment as well as “a lack of trees and a spirea shrub 

height, fencing within the northern and southern 

component. 

boundaries of the allotment, planting as needed and 

utilizing an AMP could result in improvement in growth 

and viability of desired riparian species along Moores 

3 

Non-native plants. Creek on National Forest land and result in improved 

streambank and riparian conditions. Changing the 

forage utilization standard from a minimum of 4 inch 

stubble height to a minimum of 6 inch stubble height in 

riparian areas would reduce the intensity of grazing in 

and near the riparian areas. 

Request that a botanic survey be done four or five years after 

As part of the monitoring and adaptive management 

4 

implementation to determine the effect of management actions. 

Monitoring 

strategy, sensitive plants and habitat within the 

allotments would be monitored annually by a qualified 

botanist (EA, p. B-2). 

Respondent #13 – Barbara Egolf – March 14, 2011 

Comment 

# 

Comment 

I have intimate knowledge of the history of the grazing allotments 


1 and the natural resources in the Four Comers and Moore Creek 

area as well as the conflicts with a small portion of the neighbors. 

Background Acknowledged. 

A-30



Comment 

# 


In the Introduction of the EA you refer to a Suitability Analysis for 

Regarding the vacant Priest Lake allotments that 

Priest Lake Ranger District Livestock Grazing Allotment Closure. I 

find the word closure quite telling because it is a document to 

were closed: 

justify eliminating grazing allotments before the EA. This reference 

Boswell – Term permits expired in 1989 and 

2 

was the first I have heard of such a declaration of the Flat Creek 

and Boswell Allotment being unsuitable for grazing. My husband 

Flat Creek and Boswell 

Allotments 

were not re-issued due to nonuse. 

and I were not consulted nor made known of this decision. 

In fact the Hammond Ranch, which we have for many years either 

leased privately or had permits to graze was left out of 

consideration and is a very large parcel of good forage. It was 

Flat Creek –A term grazing permit was issued in 

2001. This permit was canceled in 2005 for 

nonuse. The allotment was never stocked in the 

5 years the permit was held. 

stated that the Hammond Ranch would be in the EA. From earlier 

The Hammond Pasture would not support 

3 

communications we were led to believe that the fore mentioned 

allotments would be in the EA as well. My contention is that the 

Hammond Ranch 

enough head months to justify issuing a term 

grazing permit. Regional guidelines establish a 

Flat Creek and the Boswell allotment are suitable for grazing and 

should be included in this EA. Random closure of allotments does 

not exemplify the US Forest Service mission of multiple uses nor 

does it meet forest plan objectives. 

There seems to be a bias in the EA towards reducing or eliminating 

allotments. For example newly opened land from a Forest Service 

thinning project as transitory grazing areas have increased in the 

minimum stocking rate for issuing term permits. 

4 

Four Comers allotment. The EA wants to exclude these areas. The 

opening of new ground is an opportunity to improve the forage 

resources and prevent new weed infestations. The FS should 

stress improvement of these resources not a status quo 

management plan without implementation. There is no doubt that 

land in the Lower West Branch drainage grows good grass and 

always has. 

Range Improvement 

Opportunities 

The Four Corners thinning project retained a 

crown cover density that resulted minimal 

transitory grazing opportunities. 

A-31



Comment 

# 

Comment 

Cattle grazing can improve forage and decrease noxious weeds. 

You pull the cattle, the grass quality decreases and weed 


5 infestation increases. The allotments can be a cross utilization with 

thinning projects where resources and management goals have 

more than one purpose. 

The small business is the backbone of our local economy. The 

social benefit of responsible livestock producers is great. The 

producers provide local products for the farmers markets, protect 

large acreage from being developed, provide ranch jobs and spend 


6 

their hard earned money that supports other local community 

business. The EA recognizes the harmful effects of other private 

developments in the area as having negative impact on streams, 

plants and wildlife. If local producers are forced give up their right 

to graze on Federal land there will be more private development. 

Increased development with even more human impact will have a 

larger deleterious effect on the flora and fauna. Let’s focus on 

keeping the large private holdings intact and keep grazing as a tool 

to improve the forage that benefits the other forest resources… 

Impacts of Allotment 

Closures 

We acknowledge the important contributions of 

small businesses and livestock producers to the 

local economy. 

…I would like to tell you that last year we had a large number of 

Forage quality and quantity do not appear to be 

7 

deer and several bears grazing on our new seeding of clover in a 

hay field 

Wildlife 

limiting deer and black bear populations in the 

Priest River basin. 

A-32 

8 

The EA mentions conflicts in the area with other landholders but 

neglects to mention that there are a significant number of people 

who do not have conflicts. The conflicts are misguided and should 

be directed towards the open range law. If given a choice the area 

residents would prefer to keep open ranch land than have 20 acres 

parcels everywhere. I know that our use of the Hammond Ranch 

for grazing with our physical presence and our maintenance of a 

fence line have kept the big illegal high school party events and the 

illegal mud boggers to a minimum. 

Open Range Acknowledged



Comment 

# 


Please support the small producers by building a relationship of 

The implementation of our monitoring and 

mutual respect and a goal: improving the forage to keep cattle 

adaptive management strategy will necessitate 

grazing. The ranchers fill a beneficial niche to us all. 

awareness of allotment conditions, opportunities 

9 

Social Effects 

for improvements and communication with the 

permitees. I am hopeful that this will nurture a 

relationship of mutual respect. 

10 

I am not in favor of the alternatives presented because the EA is 

skewed with a bias towards less or no range. The history of range 

administrators showed no enthusiasm towards range improvement, 

time on range became shorter and shorter regardless of the 

resiliency of vegetation from year to year and there was an obvious 

push to declare closure of allotments before this analysis. 

Alternatives 

Alternative 1 in the EA analyzed the effects of 

current management plans with no reduction in 

available range. Initially, this alternative was not 

going to be included because it did not meet the 

purpose and need for the project. However, it 

was carried forward to provide a baseline from 

which to compare alternatives. 

Respondent #14 – William Egolf – March 15, 2011 

Comment 

# 


1 … all the information and analysis has been biased or slanted towards 

The EA provides sufficient, unbiased information 

reduction and or elimination of grazing. This I believe makes for faulty 

on the effects of a wide range of alternatives on 

decision making. This has been done in this EA and in this process. I 

urge the Forest Service to realize the consequences of biased analysis 

and choose the path of honest management and fair analysis. 

Analysis which to base my decision. 

2 Allotment permits are necessary to meet multiple use requirements. 

Multiple use management requires a balance to 

be struck between resource utilization with many 

Forest Plan 

Consistency 

other requirements. These requirements include 

(but are not limited to) management for healthy 

aquatic systems and their ability to provide clean 

water, as well as the provision of habitat for TES 

plants and wildlife. 

A-33



Comment 

# 


3 Allotments support the local economy (directly through cattle sales and 

We acknowledge this. I think that my decision 

the hiring of seasonal help and indirectly through farm supply 

regarding the future management of these three 

businesses, farm equipment purchases and repairs, feed stores, 

allotments does a good job balancing the 

hardware stores etc.) Economics demand for, and the utilization of available range 

resources and associated economic benefits to 

the local economy with the need to provide for 

other, harder to quantify uses. 

4 Public land grazing helps to keep the price of beef lower. 

Economics 

Acknowledged 

A-34 

5 Grazing helps reduce fire danger (by keeping flash fuels along roads 

down). 

6 Management direction contained in the IPNF Forest Plan, the 

Suitability Analysis and the EA have not been followed. All of these 

documents talk of managing forage production at current levels, but 

none of the steps to do this have been done on the ground. 

7 None of the alternatives in the EA move grazing toward goals, 

objectives and standards put forth in the guiding documents. 

Fire/Fuels 

Forest Plan 

Consistency 

Alternatives 

Grazing can modify fuels and thus fire behavior 

by reducing the amount, the height and the 

arrangement of fuels. This type of vegetative 

modification ultimately could reduce rate of 

spread and intensity. The area on Forest 

Service land that could be altered through 

grazing is limited, and therefore overall reduction 

in fire risk would be low. In summary, grazing 

can reduce fire danger to a degree, but the 

scope of the project limits the reduction in fire 

risk. 

Direction in the IPNF Forest Plan, the Suitability 

Analysis and the EA has been followed. Forage 

production and utilization must be considered in 

the context of heightened concern over properly 

functioning aquatic systems, demands for clean 

water and the provision of habitat for TES 

species. 

The proposed action incorporates National 

Forest Land and Resource Management Plan 

standards and guides and allows for permitted 

livestock grazing that meets or moves toward 

desired resource conditions (EA p. 4).



Comment 

# 


8 All the study and information in the EA point at larger problems (than 

The hydrology and fisheries analyses consider 

grazing) for hydrology and fisheries but the blame is laid on grazing 

the effects of grazing within the context of the 

multitude of factors affecting the aquatic systems 

in the allotments at a variety of scales. It is 

obvious that there are many things affecting 

Hydrology/Fisheries aquatic health and function within the project 

area. By focusing on the effects of grazing that 

would result from the implementation of any of 

the three alternatives, the analysis was on target. 

This is the information I needed to make an 

informed decision. 

9 “A considerable portion of the land producing livestock forage on the 

Improvements were considered. The piles in this 

three allotments is considered to be transitory range ... “there are 

area have been burned. Reseeding was deemed 

portions of Section 1, Twp 57N, Range 6 & Section 7, Twp 57 N, 

not necessary as native vegetation will 

Range 5W that are currently within the Four Corners allotment 

boundaries. (according to the maps included in the EA) These areas 

repopulate the disturbed areas. 

have been recently logged and 

Livestock Regardless, the quality and transitory nature of 

brush piled that if burned and seeded would produce forage (transitory Management- the range that will result is not expected to 

range). The alternatives in the EA exclude this acreage from the 

allotment. According to Appendix A, Practice: 17.03, Section e, range 

improvements should include prescribed burning and seeding. 

Practice: 17.04, rangeland Improvements says' Reseeding and/or 

fertilization may be done …" 

It does not appear that any of these practices have been followed. 

Transitory Range greatly improve forage quality or availability. 

10 There are also approximately 10 to 15 acres of prime, flat, productive 

The Johnson Ranch may be within the Four 

ground in Section 5, Twp 57 N, Range 5 which before a recent survey 

Corners allotment boundary, but the specific 

by the Forest Service, were inside the fence on the Johnson Ranch 

location referenced in this comment appears to 

and used for hay production. These acres are included within the Four 

be describing private land. The District is not 

Corners Allotment boundaries. These prime forage producing acres do Range Suitability aware of another foraging area ion NFS lands in 

not appear to have been considered in either the EA or the Suitability 

Analysis and will produce a large amount of high quality forage. None 

of the land I have mentioned is along streams and all is flat to gently 

sloping. 

proximity to the location described. 

A-35



Comment 

# 


11 The issue with intermingled ownership is raised with the Four Corners 

Issues associated with intermingled ownership 

Allotment. (p.15 EA) I do not believe the percentage of private or 

are not a new development on the Four Corners 

National Forest ownership, within the allotment boundaries, has 

allotment (EA p. 15). At least some of the 

changed since the allotment was started. I do not understand how this Open Range heightened controversy is rooted in the 

intermingled ownership can now become an issue. Ownership of the 

private land has changed but the acreage of land in private ownership 

has not. 

ownership of the private land having changed. 

12 It is with this (following) information from the hydrology report that it is not 

surprising that according to the EA, no improvement in hydrologic function 

Spending time, resources and funds on the 

(of the Lower West Branch) would occur under any of the proposed 

alternatives because grazing is not the major cause or reason for the 

LWBPR not properly functioning or functioning at risk. 

largest contributors of sediment to the lower 

West Branch would be advantageous. The FS 

has completed several projects that reduce 

sediment delivery to the Lower West Branch. 

Still as you mentioned, considerably more work 

is needed. 

A-36 

Page 18 EA; “According to 2001 DEQ reports most of the sediment in the 

watershed is generated off of the existing road network (Hydrology 

Report, p.14}.” Alternative 1" Continued grazing in the Lower West 

Branch drainage along with the activities described as contributing to the 

cumulative effects would cumulatively cause the main stem of the Lower 

West Branch to not improve beyond its current level of Not Properly 

Functioning.” P.19 EA. Alternative 2 "Under this alternative there would 

be minimal improvement in channel stability, hydrologic function and 

riparian condition in the Lower West Branch where cattle are physically 

excluded from streams." p. 20 EA. “Stream conditions in the Lower West 

Branch are not expected to improve because of increasing development 

pressures on privately managed land in the watershed.” P.21 EA. "The 

Forest Service manages about 75% of the entire Lower West Branch 

drainage." P.18 EA. Alternative 3 "Phasing out grazing would result in 

some improvement to bank stability, hydrologic function and riparian 

vegetation. The channel would remain in a degraded state and the main 

stem of the Lower West Branch would not improve beyond its current 

condition class of Not Properly Functioning." P. 22 EA 

It appears from this information that the effect of livestock grazing on 

National Forest Land in the Lower West Branch Drainage is minimal or not 

Hydrology 

Lower West Branch 

It is important to reiterate that grazing in the 

LWBPR is limited to a relatively small percentage 

of the overall drainage (Hydro Report, page 25). 

Still, as part of the TMDL goal of reducing 

sediment delivery and improving stream 

temperatures, the Forest Service must establish 

and maintain a positive trend towards reducing 

the pollutants of concern (sediment and 

temperature) for the Lower West Branch 

drainage. Maintaining this positive trend is how 

we will continue to meet the Antidegradation 

Policy in the Clean Water Act. 

The cessation of grazing on the Four Corners 

Allotment is expected to partially eliminate the 

contributions made by cattle towards degraded 

conditions on the Lower West Branch of the



Comment 

# 


significant enough to effect change in conditions. Yet all of the Alternatives 

talk about limiting or decreasing grazing. How can this possibly follow? 

Priest River. 

Remember 75% of the land in the Lower West Branch Drainage-is- 

National Forest and I would estimate the 95% (or more) of the many miles 

of roads are National Forest roads and all of these roads are either poorly 

maintained or not maintained at all, 'Spending time, resources and fundson 

the "largest contributor of sediment to the lower West Branch would be 

advantageous. 

We look forward to working with all neighboring 

property owners to continue to improve aquatic 

conditions in the LWBPR. 

13 'The Lower West Branch of the Priest River (LWBPR) watershed is 

over 44,000 acres, 27% of which is privately owned," P. 23 EA. 

Grazing on the Four Corners allotment is being 

phased out. The cessation of grazing on this 

“The entire drainage is listed by the State of Idaho as not meeting 

allotment is expected to eliminate any 

beneficial uses for coldwater species due to sediment, and the 

contributions made by cattle towards degraded 

drainage has TMDL requirements for sediment," P. 23 EA. 

conditions on the Lower West Branch of the 

Priest River. 

Surveys indicated that within the allotments over 18% of the stream 

banks appeared unstable, with several inferences to cattle use along 

the LWBPR, though direct observations of instability caused by cattle 

were not made." P. 23 EA. 

Alternative 1 “The LWBPR status as a 303(d) listed stream by the 

State of Idaho would also remain unchanged since its listing is likely 

the result of many historic and ongoing actions within the watershed 

and not entirely the result of grazing. Cattle use along the LWBPR is 

highly localized though those degraded areas are probably substantial 

contributors to the conditions in the LWBPR." P. 25 EA. 

Alternative 3 ”Local conditions in each allotment would likely improve 

by eliminating authorized grazing by cattle. However, the effects of 

historic and ongoing actions on federal and private land would 

continue to compromise large-scale riparian, water quality, and habitat 

conditions in those watersheds regardless of ending authorized 

grazing in the allotments." P. 28 EA 

Fisheries 

Lower West Branch 

Improving the aquatic health of the Lower West 

Branch is not the only factor driving this decision. 

A much-reduced allotment size and 

corresponding potential for allowable head 

months resulted from the range suitability 

analysis. The recommended level of grazing 

does not justify the continued issuance of a 


Additional factors bearing on my decision to 

phase out the Four Corners allotment are social 

concerns and safety issues. 

The number of permitted heads is not being 

reduced on the Lamb Creek or Moores Creek 

allotments. Permitted head months are based 

on the completed range suitability analysis. 

Increased stubble height requirements, limited 

A-37



Comment 

# 


Appearances, probabilities, conjecture, and inferences rather than 

fencing and a monitoring program in concert with 

direct observations and real sediment reductions from the largest 

an adaptive management strategy will be used to 

causes are used to make the case for grazing reductions. This does 

reduce or eliminate the potential effects of cattle 

not make a defendable position. 

on channel processes on these allotments. 

A-38

Decision Notice and Finding of Significant Impact

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