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August 8, 2021


Andrew Johnson

Bighorn National Forest USDA Forest Service

2013 Eastside Second Street Sheridan, WY 82801



Thank you for the opportunity for the Bighorn Audubon Society to comment and ask questions on the draft “Invasive and Select Plant Management” plan.

Please take note of this as you consider our comments and questions: Forest birds are in decline, with over one billion North American forest birds lost since 1970, and a 30% (2.9 billion) overall loss of wild breeding bird adult populations. “Habitat loss is likely to be a driving factor in these declines particularly agricultural intensification and development..”

The Bighorn Audubon Society opposes the Bighorn National Forest (BNF) draft EIS preferred alternative, "Invasive and Select Plant Management," June 2021. The proposal to "treat" up to 5,100 acres annually of the BNF 163,000 acres of mountain big sagebrush, especially by aerial spraying of herbicides, to obtain the BNF "desired condition" with a focus on increased livestock foraging opportunities we believe will further reduce bird habitat and populations in the Bighorn National Forest.

The USFS lists sensitive species that rely upon mountain big sagebrush habitat, and USFS acknowledges that “more than 90 bird species have a facultative relationship with big sagebrush ecosystems, while sage-grouse, sage sparrow, and Brewer's sparrow are sagebrush obligates that frequently use mountain big sagebrush communities.”


The USFS also lists Emphasis Species in the Bighorn National Forest Revised Land and Resource Management Plan  “Emphasis species were selected as a surrogate for addressing the viability of all species that may inhabit the Forest. The use of such categories has been encouraged at the national and regional offices of the Forest Service….” Brewer’s Sparrow is among the listed emphasis species.

Do you have a regular, established monitoring program for these birds in their habitat and can we see the data?


 Per the draft EIS: “The goal for treating mountain big sagebrush is to mimic historic disturbance patterns in mountain big sagebrush ecosystems prior to the introduction of fire suppression. Desired conditions are not intended to be specific to the habitat needs of any one species. Rather, the management of multiple species such as elk, mule deer, sagebrush obligates and other bird species, are considered using best available science.”

How will this desired condition benefit multiple species with a 40% (at least) reduction of mountain big sage?  Will this plan be most beneficial for livestock foraging and have a negative impact on birds and wildlife by reducing habitat?

“Numerous bird species use mountain big sagebrush for food and cover, and their needs are important to consider when managing these communities with fire.”

“The importance of sagebrush in the diet of adult sage-grouse is impossible to overstate.”

USFS Database on Mountain Big Sage Consideration of Birds, Small Mammals, and Wild Ungulates,

See the USFS database of species that are dependent upon mountain big sage habitat:


Please note that the Bighorn Audubon Society strongly supports safely and effectively controlling invasive species, and the use of proven wildland fire mitigation practices. We also understand BHF Mr. Berrett’s primary focus, as rangeland management specialist, is to increase livestock foraging. Still, please understand Bighorn Audubon Society’s mission is to protect birds and their habitats in our region. Our request to protect the BNF mountain big sagebrush ecosystem for birds and other wildlife with a sensible balanced plan within this multi use Forest is not unreasonable. The BNF preferred plan to treat up to 5,100 acres annually of the 163,000 acres of mountain big sage for years to come, and by aerial spraying of chemicals, is a very unreasonable plan that purposely further reduces bird and other wildlife habitat, therefore populations, in the Forest.


We are interested to know in which areas of the Forest are invasive species most prevalent. Is it on current grazing areas? Is there a correlation between livestock grazing areas and increased invasive plant species?


Larkspur is a native plant that migrating birds depend upon including the Broad-tailed Hummingbird.

Is the treatment of Larkspur included in this plan, and if so what is the plan? 


Note the USFS role of science in planning: “ Role of science in planning. The responsible official shall use the best available scientific information to inform the planning process required by this subpart for assessment; developing, amending, or revising a plan; and monitoring. In doing so, the responsible official shall determine what information is the most accurate, reliable, and relevant to the issues being considered. The responsible official shall document how the best available scientific information was used to inform the assessment, the plan or amendment decision, and the monitoring program as required in §§ 219.6(a)(3) and 219.14(a)(3). Such documentation must: Identify what information was determined to be the best available scientific information, ex-plain the basis for that determination, and explain how the information was applied to the issues considered.”


The public concerns for aerial spraying of herbicides are many, as stated in the draft EIS, for not only wildlife but for humans. What are the cumulative effects of each chemical on humans and wildlife?


Which brings us to one last question in our comments: if the list of threatened and/or sensitive species changes, and/or harmful effects of herbicides becomes better known will the proposed plans be altered?


Again, thank you for this opportunity to comment and ask questions.


Bighorn Audubon Society

Sheridan, WY

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