June
23, 2008
Paul
Steblein, Complex Manager
Sheldon-Hart
Mountain NWR
PO
Box 111

Lakeview,
OR 97630
Dear
Manager Steblein,
Thank
you for requesting public input on the development of the Sheldon
Comprehensive Conservation Plan (CCP), including holding five public
meetings in Nevada, Oregon and California and providing thorough
information on the Sheldon, planning issues and the planning process.
The information provided on the Refuge website is also
excellent.
On
behalf of the 5,000+ members of the Toiyabe Chapter of the Sierra
Club in Nevada and the eastern Sierra, we are submitting scoping
comments for the Sheldon CCP. The Sierra Club nationally and
the Toiyabe Chapter are dedicated to the protection of our natural
resources, wildlands, wildlife and water and to the public enjoyment
of these resources. Toiyabe Chapter members have directly
participated in the developing the existing Refuge Plan and in
subsequent planning efforts, in obtaining financial resources to buy
out grazing permits on the Refuge, in assisting the Refuge on many
other management issues, and in volunteering annually to remove
interior unneeded barbed wire fences and other activities requested
by Refuge managers.
We
strongly believe that National Wildlife Refuges are set aside to
ensure the future of key wildlife resources. These wildlife resources
rely on specific ecosystems. Soils, plants, insects, reptiles,
amphibians. birds, and mammals are interconnected. As an ecosystem
they are the examples, remnants, and living museums of our nation's
natural resource history. The refuges must retain their ecosystem
integrity. There was a time when sagebrush covered most of the
west. Not any longer. Now the sagebrush complex is retreating
and only places like the Sheldon harbor sufficient size, remoteness,
and diversity to preserve this unique ecosystem. Therefore, the
Toiyabe Chapter believes that any potential threats to protecting
thi s uniqueness must be addressed in this plan and, to the maximum
extent feasible, eliminated or mitigated.
Many
of these issues were raised in the planning document and in the
numerous scoping meetings. We will provide our comments on the
long list of threats (and opportunities) to the Sheldon NWR which
should be addressed in the CCP:
The
goal of Refuge Management should be to maintain/enhance the integrity
of sagebrush ecosystem on the Refuge:
-
Inventories:
Have inventories of Refuge plants and animals been done? Do
they need to be updated? What are the habitat needs of
sagebrush steppe ecosystem populations and how can the Refuge meet
them? Which populations are increasing and which
declining? How can declining populations of sagebrush steppe
dependent birds and other species be reversed on the Sheldon
where it is occurring?
- Wildlife
Habitat:
How can we improve wildlife habitat on the Refuge for plants,
vertebrates and invertebrates? Should wildfires be used or
prevented and what criteria is needed to make this decision on
specific areas on the Refuge? What kind, if any, wildfire
restoration should be done? How should degraded riparian areas
be restored? Or protected from wild horse and other impacts?
Are roads or other human uses negatively impacting wildlife
habitat, and, if so, how can these impacts be eliminated or reduced?
Should ATVs and other off-road vehicles be prohibited on the
Refuge and vehicle use be limited to street legal vehicles only?
How much interior fencing should be remove
d? Or made
wildlife friendly? How can the boundary fence be strengthened?
What are the conditions of aquatic habitats and how can they
be improved for both vertebrate and invertebrate species? How
will global warming impact wildlife habitat on the Refuge and how
should management be changed to address those impacts? Because
of the massive damage done to ecosystem health by decades of
livestock grazing, the Refuge plan should specifically prohibit
livestock grazing while restoration activities are being carried
out.
-
Water:
Water is critical for wildlife. The plan should
inventory all water resources, determine which are owned by USF&WS
and which may require filing with the Nevada State Engineer.
Further the USFWS should identify where wetlands and seeps
support vegetation and wildlife for possible filing as a vested
water right to prevent the usurpation of valuable water resources
by private and public entities (as has occurred elsewhere on
refuges in Nevada). In conjunction with the water
inventory, a policy regarding manmade reservoirs and the many small
"scoops" for providing water to animals should be
established. These may erode over time – should they be
kept, eliminated, or maintained? Management needs of Catnip
Reservoir which now houses a wetland bird complex, still supports a
pure Lahontan Cutthroat strain, and is very popular with human
visitors should be addressed: is public use impacting Catnip and
how can it be better managed? Also, the dam is leaking and
may need restoration if the Reservoir is retained.
-
Migration
corridors: Since we know that pronghorn move between Hart and
Sheldon Refuges, we believe that the population will thrive to the
extent that their access is facilitated. Scale is important to
successful ecosystem preservation. The Refuge plan should
develop a vision for linking the Hart and Sheldon Refuges,
including considering options for facilitating migration, acquiring
additional lands, purchasing conservation easements and/or
coordinating with local landowners, state agencies and nonprofits
to secure pronghorn migration corridors.
-
Inholdings
and border lands: Within the next 15 years, pressures to develop
inholdings and serious impacts on wildlife and wildlife habitat may
become the most severe threat facing the Sheldon. Development
of inholdings may include roads, transmission lines, manipulation
of water, OHV activity, weeds, etc. We would like the plan to
include a list (and map) of private land inholdings. Please
also develop a priority list of acquisitions to avoid these
problems. Similarly, lands with critical wildlife values may
exist outside the refuge - please identify these and their
acquisition opportunities.
-
Wild
horses and burros: In 1980, the Sierra Club supported the
proposed Refuge Plan levels of 75-125 wild horses and burros, It
is nearly 30 years later. Even with over 50% of the Refuge
budget now being spent on management of these herds, populations
have increased to between 800 and 1000 wild horses and burros.
Negative impacts to critical wildlife habitats and ecosystem
health from these elevated numbers are incompatible with the Refuge
mission or USFWS mandates. We no longer believe that the
USFWS is capable of managing the wild horse and burro population at
the 75-125 level without unacceptable impacts to wildlife, the
Refuge budget, and Refuge mandates. Please include an
alternative which zeroes out all wild horses and burros on the
Sheldon and introduces a future management plan which will keep
wild horses and burros at negligible levels while requiring minimal
costs. Wild horses and burros will always be present at some
level, but the issue here is to prevent the animals' management
from consuming the Refuge budget and wildlife managers' times.
-
Predators:
Predators are part of the natural environment and essential
to the integrity of the sagebrush steppe ecosystem. Efforts
to eliminate or reduce predator populations are incompatible with
Refuge mandates and with ecosystem health and processes. The
Plan should include predators as a positive member of the sagebrush
steppe ecosystem. If a "predator management plan or
subplan" is developed for the Sheldon, it should be subject to
Refuge purposes and a full public review process.
-
Sensitive
species: The Sheldon contains many sensitive species. Some
are listed under the Endangered Species Act and some are not, but
have declining populations and vanishing habitats. The Refuge
Plan should address the needs of protecting, maintaining, and
enhancing sensitive species.
-
Other
large mammals: Elk and buffalo have been seen on the Sheldon
over the last few years. Populations may become established
naturally or with our help. There is a buffalo restoration
plan for the western US. In the plan, elk and buffalo
management should be subject to the Refuge purposes, including
maintaining/restoring ecosystem health - or too many animals could
have serious adverse environmental impacts (such as by the current
over-populations of wild horses and burros and historic livestock).
- Other
uses and activities: There are many other potential uses of
the Sheldon Refuge. Some are compatible with the overall goal
of maintaining and enhancing the integrity of sagebrush ecosystems
and wildlife and wildlife habitat and should be continued Others
are incompatible with Refuge goals and should be prohibited. And
others may have impacts, but those impacts can be avoided, minimized
or mitigated. The USFWS should clearly identify in the Refuge
plan those activities which are compatible with the wildlife mandate
of the Refuge and which require more regulation or elimination.
-
Roads:
does the USFWS have an inventory of all of the roads on the
Sheldon? How many are “official” and how many have been
created by off-road pioneering? How many are actually
necessary to provide access for the public? How many “routes”
have already been closed? How many routes still need to be
closed and rehabbed? We would like to strongly urge the USFWS
not to “pave” the roads in the Sheldon nor “improve” them
beyond the needs of public safety and maintenance ease. Where
roads are causing erosion or other resource damage, they should be
re-routed or eliminated We note that there is a paved highway
segment which does provide viewing opportunities for wildlife.
Should the USFWS identify sites along the highway beyond the
one already developed in virgin Valley where viewing opportunities
should be provided to the public? 
-
Mining:
Most mining is very destructive of wildlife habitat. While
the existing Refuge Plan provided for opal mining as a long
established use whose impacts can be minimized, we strongly urge
the Refuge Plan to consider seeking mineral closure for the entire
Refuge. If the USFWS cannot prevent mining operations before
closure can be secured, we highly recommend that procedures to
avoid, minimize and mitigate adverse impacts of mining be
established in the Refuge Plan. These should include a very
large bond commensurate with the amount of disturbances a mine
would cause.
-
Campgrounds:
The current number, location, and character of primitive
campgrounds are adequate for the Sheldon. But in the face of
increasing human populations and demands for recreational
facilities, they may not be enough in the future. We
recommend that the Refuge Plan examine a number of additional
campground sites which could be added, if demand increases. Any
negative impacts of existing campgrounds on wildlife or wildlife
habitat should be avoided or minimized or the campground should be
relocated. The Virgin Valley campground should be improved
and camping fees charged to fund the improvements as its increasing
popularity is leading to crowded and unpleasant conditions.
Campground hosts should be secured each year during the high
use seasons to help maintain order and public safety. Interpretive
programs should be offered to acquaint visitors with the purposes
and goals of the Refuge.
-
Utility
corridors: Utility corridors through the Refuge have serious
negative impacts on wildlife and on wildlife habitat, from
construction disturbances to providing perches for predators of
Sage Grouse to spreading invasive species and facilitating off-road
vehicle use. The Refuge should be closed to utility corridors
as an incompatible use.
-
Wild
Character: The Refuge Plan should address how to continue
maintaining the wild character of the Sheldon. Limiting
“improvements” to roads and other facilities, prohibiting
mining, oil and gas leasing, restricting street-legal vehicles to
designated routes, managing increasing recreational uses, restoring
ecoystem health to degraded wildlife habitats, closing pioneered
routes, and managing/minimizing invasive species are some of the
ways the USFWS should be using to maintain Sheldon's wild
character.
- Cultural
& Prehistoric Resources: The Sheldon is rich in historic,
prehistoric, and Native American cultural resources. The Plan
should address ways both to protect these resources and provide
opportunities for the public to enjoy some of these resources.
Native American tribes in the area should be consulted on
which areas should be protected and how to interpret some sites for
the public.
Lastly,
while budget priorities don't exactly fit into the Plan scoping
process, we are concerned that the new Refuge plan will not be
adequately funded. Priorities for the Refuge budget should be
discussed in the Plan, so that the public will know how budget
shortfalls will affect Refuge programs.
Thank
you again for providing opportunities for the Sierra Club and the
public to present scoping issues to you for the development of the
Refuge CCP.
Sincerely,
Rose Strickland
|
Dennis Ghiglieri
|
| Public Lands Committee |
Conservation Committee
|
Photos credits: D.
L. Ghiglieri: (All from Sheldon NWR in order from top, Pronghorn
Antelope; Springtime; Entrance sign; Pronghorn doe with "kids";
Greater Sage Grouse; Pygmy Rabbit; Catnip Canyon; Historic Ranch House.
)
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