December 5, 2013

The Honorable Sally Jewell, Secretary
Department of the Interior
1849 C Street NW
Washington D.C. 20240

Dear Secretary Jewell:

The conservation groups listed below are writing to you to express our concern about growing issues regarding the current and future management of greater sage-grouse on federal public lands and the impending decision whether to list the sage grouse under the Endangered Species Act by the US Fish and Wildlife Service (FWS). Our organizations have extensive experience in wildlife policy and management, including sage grouse, and many of our members are leading authorities on the management of federal public lands and wildlife. Our credibility is based on knowledge of the best available science and extensive experience among our members. Our motive is to help prevent the listing of sage grouse through coordinated and consistent application of policy and management.

In reviewing several Bureau of Land Management (BLM) Resource Management Plan (RMP) revisions or amendments, regional BLM Environmental Impact Statements (EISs), and state sage grouse plans, coupled with our observations and discussions at professional meetings (e.g., Association of Fish and Wildlife Agencies, Western Governors Association, Western Association of Fish and Wildlife Agencies, local sage grouse working groups), we have generated several concerns regarding the current direction of sage grouse conservation and management. Our primary concerns can be summarized as follows:

• Lack of consistency in alternatives and actions contained within the BLM RMPs and associated environmental documents that have been released to-date including identified preferred alternatives that will not result in positive benefits for sage grouse and their habitats;
• Lack of coordination between BLM, the FWS and the state fish and wildlife agencies during the development of the RMPs;
• Absence of a clear articulated standard of actions or management coordinated by the FWS that could prevent a listing;
• The lack of clear process or policy to deal with the state sage-grouse plans under development;
• Attempts by some special interests to attack the BLM National Technical Team report (NTT) and FWS Conservation Objective Team (COT) report and the underlying science behind those reports – also, the potential political influence on BLM and FWS to not use these reports;
• Consequences that a listing would have on the management of sage grouse habitat and other wildlife that occupy the same ecosystems , primarily mule deer, pronghorn and other numerous other species;
• Attempts to limit or close hunting of sage grouse as a step to prevent a listing, even though hunting has not proven to be a factor threatening the sage grouse populations range wide;
• Adherence to the NEPA process that clearly is not able to deal with an issue of this magnitude and one that focuses more on process and timelines rather than substance;
• The fear from landowners, state agencies, and other stakeholders that no matter what they commit to voluntarily, the FWS will still move forward with a listing - this fear is evident in areas where the lesser prairie-chicken (LPC) and Gunnison sage grouse processes have taken place;
• The unwillingness of BLM to put a hold on mineral leasing and development in key sage grouse habitats while EISs and RMPs are being written.
• A facilitated rulemaking process that would lead to the development of a “standard” for all federal lands that establishes minimum DOI requirements for policy, management, and coordination, based on the best available information including the NTT and COT reports;
• Building coordinated management and policy guidance for each of the 7 sage grouse eco-regions utilizing WAFWA and the WGA;
• Targets for sage grouse habitat and populations for each sage grouse eco-region;
• The inclusion of state management plans into an integrated sage grouse policy and management plan;
• Identification of priority habitat on federal lands and proposed priority restoration areas within each eco-region;
• A workshop bringing together scientists, managers, decision-makers and key stakeholders to review the available science, identify gaps and needs, and chart a path forward to work with the states and public to understand the science and its implications in policy and management;
• A process for working with WAFWA to manage sage grouse across geopolitical boundaries similar to that used in the LPC Range-wide Plan;
• The establishment of an independent sage grouse review team to conduct periodic review of the sage grouse management without interference from politics, special interests and other distractions;
• The establishment of a sage grouse liaison who works directly with state fish and wildlife agencies and western governors and reports directly to the Secretary of Interior;
• The establishment of incentives for state and private landowners using existing conservation tools – Candidate Conservation Agreements, Candidate Conservation Agreement with Assurances, Working Lands for Wildlife, etc. in return for regulatory and operation security and a process for identifying opportunities for enhancing sign-ups within sage grouse priority areas for conservation (landscape scale);
• A national sage grouse summit and working group consisting of diverse stakeholders, including federal and state agencies, NGOs, academia, industry, and sportsmen. Such an effort could be modeled off those employed for the northern spotted owl in the Pacific Northwest;
• Appointment of a Secretarial Rapid-Response Strike Team that would be available to quickly respond and react to specific urgent problems and issue management related to sage grouse biology, scientific interpretations and habitat management.

As a proposed solution to our concerns we recommend the following actions:

While we applaud the efforts to date and your personal interest in sage grouse, we fear it may not be enough to prevent a listing unless a change of course and clear direction is established and accountability upheld. The recent lobby efforts and media reports of interest groups attacking the science need to be addressed immediately and in a public way. The key to sage grouse conservation lies with a transparent process to integrate state and private efforts into the federal approach, based on science and geared to preventing a listing and addressing future needs.

Our groups are ready to help and request a meeting to discuss our concerns and help chart out a path forward. Thank you for your attention and we look forward to working with you.

Sincerely,

Steve Riley
North American Grouse Partnership

Whit Fosburgh
Theodore Roosevelt Conservation Partnership

Miles Moretti
Mule Deer Foundation

Howard Vincent
Pheasants Forever/Quail Forever

Jon Haufler
Ecosystem Management Research Institute

Gaspar Perricone
Bull Moose Sportsmen Alliance

Steve Williams
Wildlife Management Institute

cc: Jim Lyons, Counselor to the Assistant Secretary of Land and Minerals Management – DOI
Michael Bean, Counselor, DOI, US Fish and Wildlife Service
Neil Kornze, Principal Deputy Director – Bureau of Land Management
Dan Ashe, Director – US Fish and Wildlife Service
Carter Smith, Executive Director – Texas Parks and Wildlife and President, WAFWA
James Ogsbury, Executive Director – Western Governors Association
Governor Matt Mead (WY) – co-Chair WGA sage grouse Task Force
Governor John Hickenlooper (CO) – co-Chair WGA sage grouse Task Force