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Toiyabe Chapter
Nevada and Eastern California
PO Box 8096
Reno, NV 89507

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Sheldon National Wildlife Refuge Plan

Fall leaves in Lake Tahoe Creek  (NV State Park)
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The Sheldon National Wildlife Refuge, located on the Nevada-Oregon border, is developing a comprehensive conservation plan to address threats and opportunities in managing this vast, remote area of the sagebrush-steppe.  After livestock were removed in the 1990's, the primary Refuge purpose was restoration of damaged Refuge lands which are critical to pronghorn antelope, sage grouse, bighorn sheep and many other sagebrush-dependent critters.  The small population of wild horses and burros in 1990 has now burgeoned into nearly 1,000 animals, reversing restoration efforts and consuming over 50% of the Refuge budget. Wild horse advocates have so far successfully objected to US Fish and Wildlife Service efforts to reduce numbers and impacts to the Refuge.  The threats of increasing population pressure, new mining and utility corridor proposals, as well as global warming should also be addressed in the Plan.

Please send your comments to the US Fish and Wildlife Service and make these points:
  • The Sheldon Refuge should continue to be managed to restore and maintain healthy habitats for sagebrush-dependent animals and plants.

  • Wild horses and burros should not be allowed to displace native wildlife and damage the sagebrush ecosystem on the Refuge.

  • Human uses, including recreation, roads, inholdings, mines and utility corridors, should also be managed to restore and maintain a healthy sagebrush ecosystem on the Refuge.

While the formal comment period has ended, it is important for wildlife managers to hear from the public about their concerns.  You can send your concerns to: SheldonCCP@fws.gov

You may also send via US Mail:

Paul Steblein, Complex Manager
Sheldon-Hart Mountain National Wildlife Refuge
PO Box 111
Lakeview, Oregon 97630

For more information:
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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 is
sues 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:
  1. 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?

  2. 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 removed?  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.

    • Vegetation management:  Junipers are well-established on the Refuge and provide habitat for many vertebrate species.  Where should they be removed or thinned and where should they be conserved?  Have invasive species inventories been done? What invasive species control and management is needed on the Refuge?

    • 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.pygmy rabbit

    • 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).

  1. 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. 
    • Recreation:  public uses of the Refuge which do not negatively affect wildlife or wildlife habitat should be encouraged.  Other uses, such as off-road vehicles should be prohibited.

    • 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?  sheldon table land scene

    • 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.

    • Oil and Gas leasing:  these uses are incompatible with a national wildlife refuge.  We recommend that the Refuge be closed to these uses.

    • 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.

  1. 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.historic ranch

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.
)