HomeMy WebLinkAbout2/16/2005 - STAFF REPORTS ILI C�
Mayor, City Council—Dana L. Stewart and James F. McKinley of Palm Springs
(760)864-4181
Timing and Procedure changes
The folks in planning and city government have been tinkering with timing and
procedures for some time now. They've not noticed meetings properly, not answered
questions or challenges, approved mass-grading and boulder-trusting projects without
sufficient study and assurances or independent EIRs. Even the EIR for Palm Hills did not
mention this known fungus among us.
We see this limiting of time for public input, and making the timing for comment even
more difficult, as another blatant attempt to exclude and limit public participation in the
democratic process. Half of us cannot even make it by 7:00, let alone 6:00. WE WORK,
YOU KNOW. Many of us unfil six.When do we get to eat?or drive from here to there?
If we also have to fill in cards beforehand, it makes it doubly difficult. It seems that
they're shuffled to allow proponents of massive developments to have the last word. We
should have comment AFTER we listen to developers and city council members,who
have an unlimited time to drone on, and on, and on, and on, and on-Mr. Mills took over
forty minutes one night to answer 6 minutes of comment-about how wonderful their
monstrosities are. We have to look at drawings of the butchering of our hillsides for
hours on end, but can't have a sign about our initiative or referendum. We want a more
equal share of the time and funding as the developers get! Not less!
What happened to the Final Public Comments and Requests at the very end?
Sometimes, it is a person's only time to speak! Mr. Mills may now always have the last,
interminable words.And why is the Redevelopment function floating all over the
agenda'? How will we know when we can speak on an issue of concern?
There has been abuse of the bully pulpit in this town. We want to have a video copy of
the"State of the City"speech. How do we obtain it?We would like to see the accounting
projections that prove when, and if, these projects are truly revenue generators, or
revenue losers.We believe that you will be legally required to provide EIRs for mass
grading, and boulder-busting, and the increase in the resultant"Valley Fever"fungal
pneumonia. Healthy people die from it, let alone at-risk people!
People, who moved here for their health, and peace and quiet, are being threatened.
Stringent assurances that the hillsides will not be destabilized from terracing it
contradictory to the terrain, particularly during flood conditions, are absolutely necessary.
These hillside projects put life and property at risk. Mass grading is out of place.
Boulder-busting is out of place.
And you're out of line, if you do not put public safety first, over private profits.
And also, if you try to stop us from saying so.
So, NO to these changes in timing and procedures. And vote YES on B, No on C.
fllrnl 12 C) [M�
tAr. F. salu"'r' .%.L'E.
'4' f Ll L 171 S F,
-,r".--.m e r,�- 7, "I'v i 4
F p v 11Q5 R Lcl o f
T'.O. Ec'"z —'743
?=Tm Srm—�:,cq:g
SiecOL
"puiags
FAR Part TSO NmiEe ExTpoSjt+•e- ML" A�,pt,,jjce
F> cmrml j_on 'A rr-,n iEt rE,r iGCl
"Taos ovaluall-c-cl and acC.czjl:a'l -.rc Ex n�urc- n"rD2 A"-� ,,
I PF C.--- t T,
7MUZ fil-C-1 March - , -1�1-4, ,,,I
Lv yu= r2--lbaul ,duly
r_z erenco'l Tifooft. In 1021(n) 0"'
Fnt, TT.oi-H_ &La-e:n,-:;t Ac-
Han�, 2�h i I
Lh,--
t-hc -j1t7 7t , _71_ LF,
-uodc-- Lhiu Part, VhLe C'.2t' =Ln&',LUS[ -ie L]FOIPI Qft ",'I
and
M�rcll 3r
7-c"n C':O-OCLa ulad -u -"nr�-PE g
F='rtEd the ,f 7h:
CL %"Du- tl0ia.e =XL ,ZUfC- 41-'
ni-LLric..- ha Lhc. cans .7-ze ir, aCccrdarlca -,71"tll r ='-c"ju-cs,
? - n-t
i� �1 �.�,,1 ! -N Pa--,- slacJ
yn-jr -- -- -- ---
will a rnki� in -h-
Of thcm
Th_ F',Vl' 7 -,.rceph—
"'50
tnzinfse= a nn --P. -,.7pa----n
suu!=ct F- rFCr-- lla v2
-wdl c7--�ELLInf,
February 16, 2005
City Council Meeting
Dear Mayor and Council,
My prediction is more than the majority of you will not be seated on the Dias dismissing the
people of Palm Springs within the year.
Two terms of Mayor of the last mayor, and council and current Mayor and Council have made a
fatal error. You don't care what the people, who elected you, try to make you hear. And pay you
shall.
The violations of protecting the people from any form of harm, as well as the land, water, air, etc.
have become "routine practice. You flaunt the law, along with others who assist in the murder, at
the end of the day, the human species, as you allow water to be overdrafted, air to die, fail to
address PM 10 levels, ignore Federal and State endangered species and habitat critical to
life.....tool or ignore The General Plan, are in conflict of interests, fail to comply with California
CEQA Guides, Federal EPA laws, and others. Governmental Health and Safety code violations
take place within Re-Development.
There have been violations of the Brown Act, use of public funds to build private project, builders
forced to use "only certain local architects" or not get permits, final inspections have been held up
at whim, Planning was and is a wasteland of violations of zoning codes, etc.
And, you, who sit there could not tell anyone how water moves through soil, how much water we
have, nor can you explain what hundreds of plants, animals, birds, and other species will be
destroyed by your willful desire to kill for the builders. Boulders, is next on your list...and likely
the next lawsuit..-. t-C,q,T Nn,....Y_¢,.. �-I. C1.6 L. �,�o.n,CV';�,•, � cw -t4a r)+-;i-S
4%4, Co,_J&-r 11b1iC4p p�4t1 ecr n s .
You turn the Constitutional rights of the voters into a contest of how far you can confuse the
issues. As Bill Moyers, said, "You've lost your moral imagination". There is a special law that is
coming your way, the record of how many violations, in how many areekare routine. The result. A
body of experts in every area making certain this city follows the law in every area...which will
give the people time to live and enjoy their lives instead of spending their lives making this city
obey the law.
Jane Smith
6 years of my life lost attempting to make this city respect the people and the law.
W k., Q �
r
.w COACHELLA VALLEY TRAIL USERS COALITION*
Summary Critique and Recommendations
Re: "Trails Plan" portions of CVAG's Conservation Plan and
companion Environmental Impact Statement & Report (EIS/EIR)
The primary goal of CVAG's proposed Trails Plan is to reduce access to 75% (about 141 miles)
of public valley trails to protect the bighorn sheep. The Plan includes a voluntary trail avoidance
program, a quota permitting program and a hot season trail closure program. Each of these
programs would result in immediate loss to the public good.
SUMMARY CRITIQUE
It is our position that CVAG's Trails Plan and companion EIR/EIS are flawed on these grounds:
I. Absence of Relevant Data and Information
No time series data on population estimates of Peninsular bighorn sheep and Iamb/ewe ratios were
included in either document, despite their availability. The numbers of bighorn have increased in each
of the last eight years. As of December 2004, bighorn sheep population stood at a twenty-year high.
BLM trail-use data has little validity. ("...gathered without a proper protocol and has little if any statistical
validity." Jeff Morgan, vice chair of San Gorgonio Chapter of the Sierra Club, June 19, 2003, Santa
Rosa and San Jacinto Mountains National Monument Proposed Management Plan.)
II. Absence of Best Available Science
Authors of the Trails Plan did not adhere to the "best available science" standard asset forth in the
Executive Summary of the CVAG Plan and the 1973 Endangered Species Act.
The best available science on trail-use and bighorn sheen consists of five studies which confirmed that
bighorn adapt and habituate to regular, expected trail users; that up to 50 hikers daily did not adversely
affect the sheep; that the presence of numerous hikers did not cause the sheep to abandon adjacent
habitat; that distribution of bighorn is positively related to food sources and not negatively related to
human presence; that no incompatibility was found between trail users and bighorn. (Wehausenl997
and 2000, Hicks &Elder 1979, Purdy& Shaw 1981and Hamilton 1982)
The findings of the best available science provide no support for a policy of trail rationing or a quota
permitting system. These findings were ignored. The authors were unable to identify even one peer-
reviewed publication to support their policy of reduced public access to trails.
III. Absence of Required Analyses
No analysis was given on the affects of the trails policy on biological (bighorn) and recreation (trails
users) resources. In the EIS, the authors use description only without a supporting rationale. They
interchanged conditional verbs could and might with the certainty verbs would and will. Also, no
cost/benefit analysis was included in the EIS.
Our analysis of CVAG's data show that between years 2001-2003, trails users in the Santa
Rosa Mountains increased 38% and the population of bighorn sheep increased 45%.
----- ----------------------------------------
*Coalition members include: Coachella Valley Hiking Club, Desert Bicycle Club, Desert Cities Track
Club, Desert Riders, Desert Trails Hiking Club, Palm Springs Triathlon Club
(Continued on back of page]
ell z/i6 dv'e'6r � „
•
I
• The CoachellaValley Hiking
Club
•
i Critique & Recommendations
+ Presented in response to the 9
• "Trails Plan "
• in Public Review Draft
•
i
•
•
•
•
•
•
•
•
• TABLE OF CONTENTS
•
• Preface............................................................................................................ 3
Acknowledgements........................................................................................................................ 4
• Prologue......................................................................................................................................... 5
• I. Introduction .............................................................................................................................. 6
' II. Summary Critique and Recommendations............................................................................... 7
• III. Comments, Questions and Analyses regarding the Final Draft CVMSHCP and EIS/EIR
1. The Role of Economic Development.......................................................................................... 9
2. Population Data on Peninsular Bighorn Sheep........................................................................ 11
• 3. Seasonal Trail Program............................................................................................................ 26
• 4. Trails Permit Program.............................................................................................................. 31
• 5. San Jacinto Mountains: A Special Case................................................................................... 43
• 6. Trail Rerouting, Decommission and Removal......................................................................... 45
7. Perimeter Trails and New Trails Program............................................................................... 48
• 8. Trail Monitoring and Enforcement Program ........................................................................... 50
• 9. The Research Program: Effects of Recreational Trail Use on Bighorn Sheep........................ 51
• 10. The Research Question Worksheet: Trail Users and Bighorn Sheep .................................. 54
. 11. Model Building: Variables Affecting Population Levels of Bighorn Sheep ....................... 56
12 Restricting Mountain Biking Within,the Plan Area............................................................... 69
13. Effects of the Trails Plan Upon Recreation Resources and Opportunities ........................... 70
• 14. Effects of the Various Trails Plans (A, B, C and D)upon Biological Resources ................. 79
• 15. Terminology: Language Clarity and Objectivity................................................................... 82
16. Inconsistencies: Language and Rationale ............................................................................. 83
• 17. Trails Management Subcommittee....................................................................................... 88
18. An Analysis of the Preferred Alternative: Part A.................................................................. 89
• 19. An Analysis of the Preferred Alternative: Part B .................................................................. 91
. 20. An Analysis of Appendix C of the EIS/EIR ......................................................................... 94
21. The Best Available Science Standard................................................................................... 97
• 22. Miscellaneous Questions ...................................................................................................... 99
23. Coachella Valley Hiking Club's Trails Plan: An Outline.................................................... 100
• 24. The Public Comment Period ............................................................................................... 101
• IV. Concerns................................................................................................103
V. Selective Sources .................................................................................................................. 108
•
•
•
•
• - 1 -
•
•
•
•
•
TABLE OF CONTENTS, continued
•
•
• List of Tables
• Table 1: Population Estimates of Peninsular Bighorn Sheep .................................................. 13
• Table 2: Summer Water Hole Counts of Peninsular Bighorn Sheep....................................... 15
Table 3: Estimated Recruitment Rates of Peninsular Bighorn Sheep...................................... 20
• Table 4: Estimated Demand for Trail Permits......................................................................... 33
Table 5: A Human-Wildlife Interactions Model: Sheep Avoidance ....................................... 54
• Table 6: Modeling Factors Affecting the Population of Peninsular Sheep.............................. 67
Table 7: Qualitative Cost/Benefit Model for Recreation Resources........................................ 73
• Table 8: Analysis of Trail Access Lost and Trail Access Gained ........................................... 74
• Table 9: Coachella Valley Public Hikes/Trails........................................................................ 76
Table 10: Estimated Trail Users and Sheep Population in Santa Rosa Mts .............................. 81
• Table 11A: Studies Cited on"Trail Use, Human Disturbance and Bighorn Sheep"
' With No Information or Concepts on Trail Users and Bighorn Sheep...................... 95 ,
• Table 11B: Studies Cited in Appendix C on"Trail Use, Human Disturbance and
Bighorn Sheep"With Information or Concepts on Trail Use and
• Bighorn Sheep............................................................................................................ 96
t
• List of Figures
• Figure 1: Population Estimates of Peninsular Bighorn Sheep: Peninsular Ranges ..................... 17
• Figure 2: Population Estimates of Peninsular Bighorn Sheep: Santa Rosa Mrs.......................... 18
Figure 3: Recruitment Rates and PBS Population: Santa Rosa Mountains................................. 24
• Figure 4: Sample Day Use Permit: Museum/Skyline Trail......................................................... 41
Figure 5: Sample Day Use Permit: Art Smith Trail..................................................................... 42
r
•
s
•
•
•
•
•
•
•
•
•
2
•
•
•
•
• PREFACE
•
The response of a research institute* to its 2003 study of wildlife literature
sums up our stance on the overriding problem with the "Trails Plan"portion of
• CVAG's proposed Coachella Valley Multiple Species Habitat Conservation Plan:
•
• "While researching this topic, we noted several information gaps in the
• existing literature. The vast majority of research has reported short-term
responses of individual animals to recreation activities and used this
information to project potential impacts to wildlife population or
• communities...we are unaware of any study that has collected extensive
• data over several years to provide a true estimate of potential impacts to
population rates of change."
•
•
•
•
r
•
+ *Wright, Vita, Series Editor,Draft Volume 5: Backcountry Recreation Impacts to Wildlife: An
• Annotated Reading List, Aldo Leopold Wilderness Research Institute, Missoula, MT, September,
2003, p. 1
•
•
•
•
•
•
•
•
•
•
•
•
• 3
•
•
•
•
•
• ACKNOWLEDGEMENTS
I owe abundant thanks to the encouragement and contribution of a range of fellow trail users,
• wildlife biologists, wilderness experts, bighorn enthusiasts and friends. I'm deeply indebted to
• several experts for their willingness to help educate me and steer me onto rich source material. Jim
• Foote, of Palm Spring's Bureau of Land Management,was particularly patient, professional and
attentive in hearing my questions. To other obliging experts on diverse sides of the topic, I offer my
• heartfelt thanks.
•
• Special gratitude goes to those who reinforced this project with collegiality, study, criticism,proof-
reading and editing from as early as fall 2004, when my curiosity about and research on the issue of
`bighorn sheep and trail users' first took hold:
• Eric Baecht Jim Blakely Ron Chang
• Al Dempsey Tracy Kupferberg Peta Henderson
Ken Lamont Eric Larson Patricia Larson
Jim Miller Sandie Nisbet Robin Roth
• Chris Siems Earl Siems Ted St. John
• Elize VanZandt
The Coachella Valley Trail Users Coalition spearheaded what has become a grassroots move to keep
the valley's public trails open. Informed, dedicated members sparked interest in CVAG's proposed
• "trails plan"among other valley residents, trail users, and local elected representatives. Our
• Coalition includes the valley's primary trail-user organizations: Desert Bicycle Club, Coachella
Valley Hiking Club,Desert Riders, Palm Springs Triathlon Club, Desert Trails Hiking Club and
Desert Cities Track Club.
•
• Charles Nisbet*
• January, 2005
Palm Springs, CA
•
•
•
•
• *Author Chuck Nisbet, Professor Emeritus of Economics, taught at the University of Wisconsin
Madison,University of California Los Angeles and The Evergreen State College, Olympia,
• Washington. Among various areas of study, for 15 years he taught"Management in the Public
Interest"to college students. For over 30 years he conducted field research in the US and abroad,
• lectured in at least fifteen foreign countries, taught college students, supervised graduate student
• theses, published numerous peer-reviewed articles and a book on Latin American economic
development. He alone is responsible for all errors or shortcomings in this document.
•
•
•
•
•
• 4
•
•
•
•
•
• PROLOGUE*
• nere is it written that respectful use of trails harms our valley's magnificent
• bighorn sheep? As far as we can see, it's nowhere. A popular belief system
• leads some to assume the opposite.
•
Whether to close selected trails around the Coachella Valley is not a contest between those who want
• to protect the bighorn sheep and those who do not. On the contrary, if evidence pointed to recreational
use of the trails harming these incredible beasts, I'm convinced the majority of trail users would
• respect the restrictions with no fuss.
A Who treasures the mountains and desert and natural habitat more than those who seek them out? Who,
more then those who return repeatedly to the challenge of new trails--on mountain bikes, horseback
• and on foot? They come for the vigorous exercise, for camaraderie or solitude, fresh air, sheer beauty,
• and for the thrill of spotting cacti in bloom, or a bighorn high on a cliff. These are sights that make
• trail users pause or stop dead in their tracks to observe.
• We are all aware that human encroachment has pushed back the habitat of wildlife in a devastating
• way, around the world. To us, what is frustrating is the assumption that recreational trail users around
• Coachella Valley are part of that encroachment. They are not hunting or bulldozing or looking for a
• spot to dump trash. Yet, it appears they are being asked to give up the joy of rigorous exploring--up
high on public land—only on speculation that humans on certain trails wreak havoc with the sheep.
•
• Once these restrictions are stamped and sealed in black and white, we all know it will take decades to
• consider changing them. Your descendents and mine will not be allowed to reach for the physical
heights unique to this desert valley. In my view, such restriction based only on assumption seems
• short-sighted, at the very least.
•
• In his books on national parks, a century ago, John Muir waxed passionately about `man's'
relationship with nature. At one point, he says, "we are all, in some sense, mountaineers, and going
• to the mountains is going home." True, his experience was in the Sierras, largely Yosemite. But
• the parallel works. For many enthusiasts, it's not playing golf, but aiming for those desert peaks,
that is the joy and the appeal of this one-of-a-kind Coachella Valley. So, if in today's more and
more sedentary world, active trail users are doing no harm, why must we prevent them and future
• generations from pursuing a health-giving, ongoing activity that many might agree is `going home"?
• The loss of such privilege seems a sweeping, alarming price to pay for a widespread `belief or
• speculation.
•
•
• * Sandie Nisbet, responding to CVAG's trails plan, at the first of two public meetings,
• November 30, 2004, Cathedral City Council Chambers, Cathedral City, CA
•
•
5
•
•
•
•
•
•
• I. Introduction
The Coachella Valley Hiking Club (CVHC) fully supports the conservation objectives of the draft
CVMSHCP, referred to herein as `the Plan'. Our club members seek the continued use and
• enjoyment of the hiking trails in the Plan area in a manner compatible with the welfare of the
Peninsular bighorn sheep.
This Plan purports to seek a balance, for the public good, between the often competing interests of
economic development and environmental protection. We affirm the Plan's goals to protect
• biological and natural resources and to provide recreational and educational opportunities through
• public access to the natural environment. The primary public access to the geographic area of the
• Plan is the trails system. Our knowledge of these hiking trails affords us a unique opportunity to
review the draft proposal. We trust that our comments, questions and recommendations will
• contribute to the final"trails plan" segment of the CVAG Plan.
The proposed Plan includes a statement defining the difficult job of seeking a balance:
A public use and trails plan is needed to provide for trail use in bighorn sheep habitat
• that is compatible with sheep Conservation Goals and that affords a reasonable level
• of use to the public. (9-280)*
A key word in the above quote is "reasonable." How this word is defined and applied through
research and policy decisions will determine the net gain or loss to the public good produced by this
Plan.
•
•
•
s
•
•
•
•
•
•
*All references to Vol. 1,the Plan will be given as chapter and page number in bold, e.g., (9-280).
• All references to Vol. 4,the draft EIS/EIR will be given as (EIS/EIR)with chapter and page
number.
•
•
• 6
•
•
•
•
• II. Summary Critique and Recommendations
•
The central goal of the trails plan is to reduce public access to trails via a voluntary trail avoidance
program, a quota permitting program and a hot season trail closure program. These programs result in
• immediate reduction in the public good.
•
• SUMMARY CRITIQUE
It is our position that CVAG's Trails Plan and the EIR/EIS treatment of the Trails Plan are flawed on the
• following grounds:
•
(1)Absence of relevant data and information
Time series data on population estimates of Peninsular bighorn sheep and lamb/ewe ratios were included,
• despite their availability. The numbers of bighorn sheep have increased in each of the past eight years.
As of December 2004, bighorn sheep population stood at a twenty-year high.
i The BLM trail use data"... was gathered without a proper protocol and has little if any statistical validity."
(Jeff Morgan, vice chair of San Gorgonio Chapter of the Sierra Club, June 19, 2003, Santa Rosa and San
• Jacinto Mountains National Monument Proposed Management Plan ...)
•
. (2) Absence of the "best available science"
Authors of the trails plan did not adhere to the "best available science" standard as set forth in the executive
summary of the CVAG Plan and the 1973 Endangered Species Act.
•
• The best available science on trails use relevant to bighorn sheep consists of five studies confirming that
• bighorn adapt and habituate to regular, expected trail users; that up to 50 hikers per day did not adversely
affect the sheep; that the presence of numerous hikers did not cause the sheep to abandon adjacent habitat;
• that distribution of bighorn is positively related to food sources and not negatively related to human
presence; and that no incompatibility was found between trail users and bighorn sheep. (see Wehausen
• 1997 and 2000, Hicks and Elder 1979, Purdy and Shaw 1981 and Hamilton 1982)
• The findings of the best available science provide no support for a policy of trail rationing and a quota
• permitting system. These findings were ignored. The authors were unable to identify even one peer-
reviewed publication to support their policy of reduced public access to trails.
• (3) Absence of the required analyses
• No analysis was undertaken on the affects of the trails policy on biological and recreation resources. In their
• EIS, the authors use description only, without a supporting rationale. Authors interchanged conditional verbs
• could, might with the certainty verbs would and will. Also, no costibenefit analysis was included in the EIS.
• Our analysis of the CVAG's data demonstrated between 2001 and 2003 trails users in the Santa Rosa
• Mountains increased 38% and the population of bighorn sheep increased 45%.
(4) Misuse of the scientific literature
To support the trails plan, over 30% of the references cited originated from research on"intentional
cross country harassment trial studies of bighorn sheep". A full 90 % of all citations used had nothing
•
• 7
•
•
•
•
•
to do with trail users but with topics such as road building, off-road vehicle use, winter sports, dam
• construction, riverboat travel, housing developments and hunting sheep.
• (5) Adoption of a single variable model
• Authors of the trails plan gambled on and proposed action to modify the one variable with no
• established link to bighorn sheep: recreational trail users. The plan ignored the variables with
• proven connection to population levels of the bighorn sheep: habitat loss, habitat fragmentation,
habitat degradation, disease, predation, and climatic factors (temperature/drought).
•
(6) Proposed quota permitting system
• This quota permitting system is unnecessary, unworkable, unenforceable, and discriminatory. It is
the wrong type of permit, forever once in place, lacking public support, and not designed to
• provide the necessary new trail use information badly needed at present.
•
• RECOMMENDATIONS
• We conclude the Trails Plan must be rewritten. We recommend the following:
• (1) In 2005, gather data on trail use on as many trails as possible. Install on feasible trailheads a
• research oriented permit system-- similar to that used above the tram.
(2) In 2005, call for research proposals to analyze and determine the primary causes for the 1996-
• 2004 recovery of bighorn sheep; to analyze and determine the effects, if any, of trail users upon
• population levels of bighorn sheep; to analyze and determine why the San Jacinto herd remains
relatively small despite high lamb/ewe ratios and reintroduction programs; and to identify and
prioritize primary factors affecting population levels of bighorn sheep in the Santa Rosa and San
• Jacinto Mountains.
+ (3) Enforce the removal and decommission of trails only when clear need is established on a case
• specific basis, i.e., the unauthorized trails above the promontory of the Mirage Trail.
• (4) Make the Trails Plan consistent with the overall Conservation Plan by adopting an eco-systems
• approach to bighorn sheep and their habitat. Create educational programs to discourage cross-
country travel and dogs on trails with emphasis on the benefits of on-trail use.
• (5) Build the proposed system of perimeter trails to supplement--not substitute for--the existing
• trails system. These trails will serve as buffer between urban interface and bighorn habitat and
• provide lower level, moderate exercise opportunities. Inventory current parking and projected
• future parking for all access points to perimeter trails.
(6) Unless new findings prove otherwise, remove all elements of the Trails Plan not based on best
available science:
• • there is no science to support the "volunteer trail avoidance program". Remove signage;
• there is no science to support the program of"hot season"trail closures. Remove signage;
• • there is no science to support a trail rationing program and a quota permitting program.
Abandon this proposal.
•
•
• 8
•
•
•
•
•
• III. Comments, Questions and Analyses on and about the CVMSHCP and EIS/EIR
1. The Role of Economic Development
• How does economic development(i.e.,urbanization) affect the population of Peninsula bighorn
• sheep? Research shows that economic development is the singular agent responsible for habitat loss,
• habitat fragmentation, habitat degradation,the introduction of new disease, loss of water sources,
and fatal urban encounters. That is, economic development has caused the decline in the population
• of bighorn sheep and threatens their future recovery. Agency personnel sounded the alarm and
• warned of the adverse affects of economic development upon bighorn sheep more than thirty-five
• years ago (Tevis 1961, Mensch 1970)
• In the Coachella Valley,* economic development resulting from explosive population growth and
• the concomitant demand for single free-standing housing, sprawling retail and commercial
• structures, expansive gated golf course communities and agricultural enterprises is by far the
• dominant player in the conservation game.** Why does this Plan, dedicated to preserving and
recovering 27 endangered species, not address or discuss the greatest threat to these species? Won't
• the Plan's ultimate success hinge upon outlining how economic development's role will be mitigated
• in the future? We urge discussion on the topic.
Economic development and population growth go hand in hand in the Coachella Valley, yet population
statistics appear only in one paragraph(page 2) of the Executive Summary. Curiously,that population
• data is not connected to previous or subsequent paragraphs or discussed as an engine of economic
• development within the Plan area. The slight treatment of population statistics appears to give little
• importance to the data.
• In sharp contrast is the treatment of population in the Recovery Plan for Bighorn Sheen in the
• Peninsular Ranges, California, (USFWS 2000):
• Development and human populations along the eastern slope of the Peninsular Ranges
continue to grow at a rapid pace at the lower and upper elevation boundaries of
• Peninsular bighorn sheep habitat. The Coachella Valley Association of Governments
• anticipates that by the year 2010, the human population there will increase from 227,000
• to over 497,000, not including 165,000 to 200,000 seasonal residents. Bighorn population
• declines typically have been most pronounced in ewe groups adjoining the urban interface
in Coachella Valley. (P.39)
•
• -----------
• * Speaking of the Santa Rosa Mountain in 1961, Lloyd Tevis passionately argued that bighorn sheep
• "would be driven out soon by real estate developers." He referred to real estate developers as "the
sub-dividers—the despoilers of the natural scene. They are out to grab all possible acreage, no
• matter how rugged the terrain, in order to cut it up into building sites. These people are united and
• ruthless. Their only concern is to buy land cheap and sell it dear." (Tevis 1961)
**By 2003,the Coachella Valley featured 113 golf courses,with more on the drawing boards.
• Purportedly,the Valley has more golf holes per square foot than anywhere else.
•
•
9
•
•
•
•
•
• This recovery plan points out other southwest desert metropolitan areas that encroached upon sheep
• habitat with similar results: "The decline in local bighorn populations in the San Jacinto and north
Santa Rosa Mountains parallels the demise of sheep populations near Albuquerque,New Mexico
• and Tucson, Arizona." (p.40)
•
• For the next 10, 20 and 40 years,population forecasts abound for the Coachella Valley. Why aren't
• these population forecasts noted in the Plan? Why doesn't the Plan address how expected population
growth will not adversely affect the Peninsular bighorn sheep? The Executive Summary (p.3) states,
• "The Peninsular bighorn sheep conservation strategy was primarily based on the Recovery Plan for
• Bighorn Sheen in the Peninsular Ranges California (USFWS 2000)." Then, why isn't the
• population and urban development of the Coachella Valley featured in the same manner? Herein,
we,refer to this document as RPBS 2000.
•
• The Executive Summary (7) notes that the City of Palm Springs might choose not to be a Local
• Permittee. Apparently, several development projects--housing/golf courses-- currently on the.
drawing boards would result in further loss of habitat. Thus, the City of Pahn Springs might prefer
• to not be bound by this Conservation Plan agreement. hi a sense, it has been a battle between sheep
and developers all along. One observer claims that, until 1998, some developers effectively fought
• the listing of Peninsular bighorn sheep as endangered specie, and now they call themselves "victims
• of the U.S. Endangered Species Act." (Baumann,p. 16-17)
• In December 2003, The Smithsonian Magazine reported on two groups of California's endangered
• bighorn sheep. Regarding the bighorn living in the Sierra Nevada, the article stated: "The Sierra
• population has plunged in recent years from 300 to about 125, due mainly to depredation by resurgent
mountain lions, which not only kill sheep but drive them out of their prime habitat." In contrast,
• regarding the Plan area, the article noted:
In the Palm Springs area, the main culprit is development, which displaces and
• degrades bighorn habitat. Although the beleaguered sheep are popular with many
• homeowners, such by-products of development as golf courses, landscaping,
swimming pools and traffic present many threats.
•
• For years, Bighorn Institute has documented the adverse effect of economic development on the
• sheep population. In 1997,the headlines of their newsletter read "Urbanization—A Leading
Cause of Bighorn Mortality." Their 2001 Year End Report documents how urbanization directly
• affects lamb recruitment,the key to promoting the recovery of sheep population. In the Santa Rosa
• Mountains, during 1998-2001, 13 of the 14 lamb mortalities occurred within 1000 feet of the urban
• interface. (BI, 2001 Year End Report, Table 2) More importantly for model building, the Bighorn
• Institute suggested that urbanization indirectly affects sheep population by altering their habitat use
and diet, making them more prone to parasite infestation and more susceptible to predation.
• (Bighorn Inst, The Bighom, 1997, p. 1)
•
• In Anza-Borrego Desert State Park,the Carrizo Gorge also experienced a particularly steep decline
in sheep population. One observer claims, "off-road vehicles,trespassing cattle, poaching in the
• 1960s and early 70s, drought, disease and mountain lion predation have worked together to push this
• population to the edge." (Jorgensen, p.2)
•
•
•
• 10
•
•
•
•
•
• 2. Population Data on Peninsular Bighorn Sheep
What were the population estimates of Peninsular bighorn sheep over the last 20 years? As far as we
can see in 2,000-plus pages of the Plan and companion EIS/EIR, not a single page is devoted to a
• chart or graph displaying population data on the Peninsular bighorn sheep. Why? Where is the
time-series data on abundance, distribution and recruitment? Regardless of one's viewpoint on the
• bighorn sheep, a frame of reference and sense of history would assist the public in reading and
understanding the Plan. As is,the Plan's public policy recommendations are obscured by its lack of
• present population data.
•
• In 1971,the bighorn sheep in the Peninsular Rangers were first listed as threatened, by the State of
• California. In 1972,the bighorn were proposed for Federal listing as endangered, but some
observers believe that opposition by developers delayed that action. Finally, in 1998,the U.S. Fish
• and Wildlife Service classified Peninsular bighorn sheep as an endangered specie (i.e., threatened
• with extinction). For the sheep to be considered endangered, data on their decline were presented.
• Data on the bighorn sheep in the Plan area have been gathered for many years. For the Anza
Borrego Desert State Park, 2003 marked the 33`d annual bighorn sheep water hole count. Annual fall
• helicopter surveys of the sheep population began in 1983 in the Santa Rosa Mountains and in 1988
• in the San Jacinto Mountains.* Conducted jointly by the California Fish and Game and the Bighorn
• Institute, and acknowledged on page 8-81,these surveys have continued to the present. Ground field
work corroborates and supplements the helicopter surveys. The annual data for the past 20 years are
• available. Why are these data not included in the Plan and the EIS/EIR?
•
• For the future, authors of the Plan asked the Trails Management Subcommittee to conduct an annual
• review that assesses bighorn sheep population trends(6-11). How could the TMS conduct a review
without including population data for the 1980s, 1990s and early 2000s? Were the recent population
• figures on bighorn sheep shared among the 15-member TMS but not with the public at large? Since
the Monitoring Program administrator is charged with knowing the distribution and abundance of
• endangered species, wouldn't he or she need to compare current data with past figures? Finally, lay
people might want to know what progress is made in the recovery program to reclassify Peninsular
• bighorn sheep from "endangered"to "threatened." The first `down listing' criterion is that at least
• 25 ewes must be present in each of the rune regions of the Peninsular Ranges during each of six
. consecutive years. Since 1984, The California Department of Fish and Game has collected time-
series data, and the findings should be included in the Plan. Table 1** and Table 2 illustrate
--------------------
*Helicopter surveys are conducted during the fall breeding season when the rams and ewes are together in
• large groups. For the rest of the year, rams and ewes often separate.
• **The population estimates in Table 1 were computed by use of Chapman's(1951)modification of the
• Lincoln-Peterson estimator,which uses the proportion of radio-collared bighorn observed, and the total
• number of bighom seen. The standard error is computed at the 95%confidence level.
N=Mn =Lincoln-Peterson Estimator;
• R
• M=total number of collared bighorn
• R=number of collared bighorn observed
n=number of bighorn adults observed
•
•
•
• 11 '
•
•
•
•
• the progress. For each of the last eight years, the bighorn sheen population has increased. If this
• good news is shared by all, whatever one's viewpoint, everyone can work from the same data. It
• seems crucial that the Plan includes a table of bighorn sheep population data, describing the
• methodology used in gathering the estimates as well as an interpretive analysis.
• We offer a word of caution regarding population data. To illustrate the steep decline in the sheep
• population by the late 1980s, authors consistently cite the 1974 population figure of 1,171 Peninsular
• bighorn sheep. In retrospect,today the 1,171 number for 1974 (Weaver 1975) appears anecdotal.
For the balance of the 1970s and early 1980s,there is an absence of other measures for the sheep
• population. Also, there is the matter of accuracy. Unfortunately, Weaver's figures for the 1970s
• have been questioned because of his methodology, using ground-only measures of waterhole counts.
• and/or foot surveys (Wehausen, 1999). Thus, his population figures cannot be compared with the
helicopter statistical profiles put together since the mid 1980s (Rubin, et al, 1998). As noted in the
• Recovery Plan in reference to the Anza-Borrego region:
• Prior to 1993 no marked animals were present in the areas in which (water hole)
• counts were conducted. (Water hole) count data were, therefore, only appropriate
• for use as an index of abundance rather than for calculation of an absolute
population estimate. (USFWS 2000,p.205)..
•
• In summary, over and over again government agencies, private research groups and individuals and
• now the Plan (9-286)make the comparison between 1,170 sheep in 1974 to 276 sheep in 1996 or
334 sheep in 1998. These numbers cannot be accurately compared. Nor does this approach
• accurately document the dramatic decline in bighorn sheep population.* This method compares to
• taking a body temperature with one's hand rather than with a thermometer. The counting in those
• early years cannot compare accurately with statistical estimates used more recently.**
• The Plan authors make this same methodological error on (9-286)by comparing waterhole counts in
the early 1970's with helicopter survey estimates of the 1990's.***
Considering the above, we urge the Plan authors to correct for this important omission by presenting
detailed time-series population data gathered on the bighorn sheep during the helicopter surveys in
• the Final Plan. Examples of time-series data on bighorn sheep can be found in Tables 1 and 2.
The Bighorn Institute's annual fall population estimates of sheep in the Santa Rosa Mountains for
the past twenty years are presented in Table 1 and graphed in Figure 2. One sees that the bighorn
• population declined steadily in the 1980s. "Long-term suppressed recruitment following a disease
• epizootic in the late 1970's caused a 69 percent population decline from 1984 to 1994 ... The
• compounded effects of disease and low recruitment, 4 years of drought beginning in 1987, and high
• incidence of mountain lion predation in recent years presumably had a cumulative influence on the
--------------------
• * Earlier counts often included lambs whereas later estimates excluded lambs
** For a recent example of this practice of combining population estimates from helicopter surveys
with water hole counts, see Table 6 in DeForge, 1997
•
*** This population information was taken directly from the Recovery Plan 2000. CVAG elected
• not to incorporate range wide bighorn population figures currently available for 2000 and 2002.
•
• 12
•
• • i • ii • • • iii • • • i • iiiii • iii • • • • • • • ii • • • iii • i •
Estimated Adult Population of Reninsular-Bgtiorn Sheep in.Nme=Recovery Regions_
Totals 9 Santa
Recovery Rosa Northern Central Southern San Jacinto Anza-Borrego
Year Regions Mts. SRM SRM SRM Mts. Desert State Park
Set a Set b
1982 60
1983 300
1984 374 14
1985 247 40
1986 46
1987 203 52 4
1988 230 52 5
1989 212 50 0
1990 115 41 5
1991 120 30 4
1992 114 35 1
1993 117 27 17 20
1994 347 116 23 17 17 214
1995 120 24 15 20
1996 276 94 21 16 19 163
1997 115 22 22
1998 334 129 22 24 181
1999 152 29 87 36 21
2000 416 136 32 53 51 24 256
2001 198 45 57 96 30
2002 668 239 40 115 84 24 405
2003 248 61 87 100 30
2004 760 298 32 430
- 13 -
Table 1 — Continued:
Notes: Population estimates gathered through helicopter surveys and using Chapman's (1951) modification of the Peterson estimator
(Seber1982)
Totals represents the sum of the nine designated recovery areas by Fish and Wildlife Recovery Plan 2000
Northern Santa Rosa Mountains (North of Highway 74)
Central Santa Rosa Mountains (Deep- Martinez Canyons)
Southern Santa Rosa Mountains (Sheep Canyon and south)
Helicopter survey of Santa Rosa Mts began 1982 and San Jacinto Mts. in 1996
Figures for 2004 are unofficial. As of January 15, 2004, the final data analysis and adjustments were not completed.
Two polygons in Anza-Borrego State Park were not surveyed due to high winds. San Jacinto Mountains and the Northern
Santa Rosa Mountains were not surveyed in 2004.
Sources: Santa Rosa Mts.: 1983-1994 DeForge, 1995
San Jacinto: 1993-1999, The BigHorn, Spring 2000
for Santa Rosa Mt. and San Jacinto Bighorn Institute, Annual Helicopter Survey of Peninsular Bighorn Sheep, various years
1983 the BigHom, Spring 2000
forAnza-Borrega:94/96/98 Recovery Plan 2000
for Anza-Borrega:00,02, "Results of the 2002 bighorn sheep helicopter survey in the Peninsular Ranges south of the Santa Rosa Mts."
NSRM: 1985-1998, Ostermann, 2001
14
Table 2: Summer Water Hole Counts of Peninsular Bighorn Sheep: Anza-Borrego Desert State Park
year ewe Iamb yearlings ram unknown total total adults Iamb/ewe ram/ewe
1972 86 27 14 63 0 190 163 31.4% 73.3%
1973 112 45 21 52 0 230 185 40.2% 46.4%
1974 88 21 24 45 7 185 164 23.9% 51.1%
1975 92 31 28 36 9 196 165 33.7% 39.1%
1976 72 13 7 37 5 134 121 18.10/6 51.4%1
1977 81 4 10 33 0 128 124 4.9% 40.7%
1978 80 12 13 76 6 187 175 15.0% 95.0%
1979 154 361 17 74 9 131 117 23.3% 48.1
1980 69 14 7 36 5 131 117 20.3% 52.2%
1981 114 17 16 29 5 181 164 14.9% 25.4%
1982 107 36 15 29 3 190 154 33.6% 27.1
1983 65 15 12 20 4 116 101 23.1% 30.8%
1984 66 17 11 34 3 131 114 25.8% 51.59/.
1985 103 23 15 56 2 199 176 22.30/. 54.40/.
1986 74 29 18 44 3 168 139 39.20/. 59.5%
1987 62 20 9 28 0 119 99 32.39/6 45.2%
1988 79 24 15 25 2 145 121 30.4% 31.6%
1989 99 11 32 30 0 172 161 11.1% 30.3%
1990 69 14 10 27 0 120 106 20.3% 39.1%
1991 77 18 9 25 1 130 112 23.4% 32.5%
1992 69 26 8 43 3 149 123 37.7% 62.3%
1993 61 28 9 27 3 128 100 45.90/. 44.30/.
1994 75 38 13 21 1 148 110 50.70/. 28.0%
1995 72 29 17 27 3 148 119 40.3% 37.5%
1996 59 21 15 33 0 128 107 35.60/. 55.99/.
1997 43 24 10 26 4 107 83 55.8% 60.5%
1998 51 22 16 32 3 124 1021 43.1%
1999 52 21 24 28 0 125 1041 40.4% 53.8%
2000 64 24 17 45 0 150 126 37.5%j 70.3%
2001 47 24 13 30 2 116 92 51.1% 63.8%
2002 94 43 23 36 0 996 153 45.70/. 38.30/.
2003 76 38 26 441 1 185 147 50.0% 57.9%
mean 154 mean 130 mean 32%
source: Anza-Borrego Desert State Park annual summer water hole counts 1972-2003
1979 seem totally unrepresentative with other years
1980 a fire prevented counts at several sites 15 -
taking out 1979 and 1980, the average number of adults was 130 over the period
•
•
•
i
•
• SRM bighorn population" (Deforge 1995). The early 1990s represented a period of relative stability
i within the herd with a population of around 120 sheep. In 1996, there was a low of 95. In 2004,the
• total estimated population of 298 represented a new high--a level not seen since the early 1980s.*
To our knowledge, the Plan and the EIS/EIR do not include any of the following points about the
population of bighorn sheep in the Santa Rosa Mountains. Table 1 illustrates:
• 1. The late 1980s marks a period of steady decline in the sheep population.
• 2. The first half of the 1990s represents a time of relative stable population.
• 3. 1996 marks a record low for estimated sheep population in all areas.
4. Since 1997 the Peninsular bighorn sheep population has been in recovery.
• 5. By the end of 2004, the Peninsular bighorn sheep population was at its highest
• level in nearly 20 years.
• 6. The bighorn sheep population experienced four years of recovery before the voluntary trail
avoidance program began in 2001.**
• 7. Beginning in 1994 recruitment rates (Table 3 and Figure 3) rose dramatically fueling the
• subsequent population increases. This began seven years before the voluntary trail avoidance
• program began in 2001. By 2004, recruitment rates had been at levels to provide for an
• expanding population for eleven straight years(of course this assumes a normal mortality rtes
were in existence over the same period).
• 8. By 2004, ewes for each of the three Santa Rosa Mountain recovery regions were at the
• Recovery Plan 2000 targeted down listing criterion level of 25. That level must now be
• maintained for six years.
9. In 2001-2003, the bighorn sheep population continued to recover, despite the estimated 40%
• trail users who failed to comply with the voluntary trail avoidance program. Note, 40%went
• ahead and used the trails despite the signage and a person(sheep ambassador) asking them
• personally not to use the trail! In the absence of a sheep ambassador to personally request
' they not use the trail was the non-compliance rate 60% or 80%? However high the non-
compliance rate, the point is that recruitment rates remained high and continued to provide for
• an expanding population of sheep.
• 10. Between 2001-2003 trails users in the Santa Rosa Mountains increased 38% and the
• population of bighorn sheep increased 45% (see Table 10,page 81).
-------------
• * The important role played by the Bighorn Institute must not be overlooked. "Since 1985, 103
• lambs have been born at Bighorn Institute's facility, 93 healthy bighorn have been released into the
i wild, and 36 sick or injured lambs brought in from the wild have been successfully rehabilitated.
• Currently, approximately 30% of the bighorn population in the NSRM is comprised directly of sheep
released from BI." (The Bighorn, Winter 2003,p. 2)
•
i **If agency personnel credit the voluntary trail avoidance program with sheep recovery,they
• confuse correlation with causation, a common statistical mistake.
•
•
•
- 16 -
•
•
•
•
•
•
—
10"Llim Oil
• WWpMP°x -- '�w�waxe+w"i�awu�wu�r„�,w •-+µr;+�•..wwr�wwiw+�++��xrm�xrr�w+�w•�wwy �,
,. Mnwwuwtlwwwwwaw writeww ..,_www »�ww �wM +'
•
• � � »�www�,w�ewunwiMw�am«.,�„��ww�w�aw�u�rawu�w�v+
• 1MWWIMWMIMNWIIWIY�i_r �ewxrr�wr�ww�,..�w+,w�,w++nma•�nrww�w�+��rw��wwmw,��
• ���V�, �ow+wuxrw 4•wNaaw�«wrww��w;w��Mxrr,
�wwr�ww . --
+W
• � �. .. �NP4IMWMA�'dIMY+4MW.NgiNr�'LGkrVPNrk'ArIgIM�y
• W �� �W .rv..rwp�w�4h"Y:wk'"�Na,rw�rMw+�ruu�,r� �
• k� - -
�'3tlM�'�'+YM"k9".T�"Em fp�+gra-anx,.Tmn
• �fl�r�r C � � . ��w»w=MNww�rw�rr�� aaM�eW�,a� "`
• � i+rt�war ;wui.+wwa;Yxwyp�wyvkwM�«+w
b
N
+Y!
•
Y
• '� .,Syr;aw+r•�kw�«+nwM�f+�Irr�aw,xrYw»»y� .
• A
MWwVMRI +�mY
iN ,+emwtx
.�no-amgnmunw
bMr
`Mow"
., r leg-,no+a Mri'
Mm
T
OT
LO
rrxM Me/rw
yMM
rR cn
" ., t..
T
TYF i ti�n r. l
w �Y
pM^Wr4 lTM'Fen. T
� O T
L,
co
/�1 T
F...
.-,r..r«e...�.m_.x✓wwrwwhu:.v«mewk-..u..>,.Y�.,,rc,,,.,y„-.yr._....„..r..._,., .. ,.
• r-I
•
•
•
•
• 11. By 2004,range wide estimates of adult sheep were 760. This unofficial estimate for 2004
• puts the bighorn population at the de-listing target recovery average of 750 sheep set by the
"Recovery Plan for Bighorn Sheep in the Peninsular Ranges, California."*
• 12. By 2004, the southern area of the Peninsular Ranges, Anza-Borrego Desert State Park
• contained more bighorn sheep, 430 (Table 1), than 1972, some thirty-one years earlier when
• (Jorgensen and Turner 1973), estimated some 392 sheep.
• 13. The earliest date for the"trails plan"to be implemented is 2006. By then the de-listing target
average of 750 may have existed for two years and bighorn recovery for a decade. This "trails
• plan"is out of touch with the present reality and written for another era.
The steep bighorn sheep population decline of one-year in 1996 puzzled the experts. Some
suggested a likely cause was extreme draught conditions and sheep weakened from lack of nutrients
• became vulnerable to mountain lion predation.
•
• Curiously, in the Santa Rosa Mountains, the bighorn sheep have been in recovery for the past
eight years. Table 1 shows that recovery took place in each of the three subsections of the
• Santa Rosa Mountains. This corresponds to the same time that early hiking clubs started to
• expand membership in the Coachella Valley. Despite the positive correlation between the
• recovery of the sheep and hikers using the trails, we do not suggest that hikers caused this
• result! Nonetheless, given the dramatic sheep recovery results, how can some people insist
that use of trails endangers the recovery of the sheep population and, thus,propose to ration
• trail use? Is a popular"belief system"blocking a look at science?
Table 2 provides the longest view of sheep abundance in the Plan Area. For the past 32 years,
waterhole counts have been gathered in Anza-Borrego Desert State Park.** These counts do not give
• us population figures for the region, but they provide a potential index of sheep abundance. The
• counts paint a macro-picture of trends that inform of the general direction of sheep population. To
• calculate the mean count over the 32 year period,we eliminated 1979 because it was twice the
• average mean and rejected as non-representative (a statistical outlier) and 1980 because a fire
prevented too many areas from inclusion. The 30 remaining years produced an annual mean count of
• 130 adult sheep with three distinct periods:
+ Period One--1972 through 1982 averaged 157 adult sheep. This was the period
of greatest abundance and remarkably stable numbers.
•
• Period Two--1983 through 1999 averaged 109 adult sheep. Years 1985 and 1989
• were eliminated because they averaged 168 and were not representative of the
• second period. The second period was a time of decline in abundance with the mean
number 31%below period one
• --------------
*Helicopter surveys were not undertaken for the Northern Santa Rosa and San Jacinto Mountains in fall 2004.
Also two polygons in Corrizo Canyon were not surveyed due to high winds. Final data adjustments were not
• competed at the time this response was submitted to CVAG.
•
• **Researchers and volunteers sit near waterholes during the peak of the summer heat and dry season and
record the number, age and sex of the sheep coming to drink.
•
•
• - 20 -
•
•
•
•
•
•
• Table 3: Estimated Recruitment Rates of Peninsular Bighorn Sheep
• (Iambs per 100 Ewes )
•
• sa Mts _
• Lambs/100 Totals Santa Ro NSRM Mts San Jacinto Mts. Anza-Borlf
Year LIE rate rate LIE rate LIE
•
• 1984 144 L- 117 0.38 1 L----8 E 0.12
1985 39 L-86Y 0.45 4 L--22E 0.18
• 1986 49L-135Y 0.36 3--25 0.12
1987 12 L-56Y 0.21 0 --30 0.00
1988 12 L-80Y 0.15 2--33 0.06
• 1989 12 L-60Y 0.20 1--32 0.03
• 1990 5 L-39Y 0.13 0--24 0.00 2 L----2 E 1
• 1991 0.25 1--21 0.05
1992 0.30 2--24 0.08
• 1993 0.15 1--17 0.06 2 L----7 E 0.29
. 1994 20 L-39Y 0.51 3--11 0.27 _
1995 17 L-43Y 0.40 0--10 0.00 5 L----6 E 0.83
• 1996 12 L-35Y 0.34 2--10 0.20 3 L----5 E 0.60
• 1997 21 L-64Y 0.33 1-9 0.11 4 L----6 E 0.67
1998 20 L-37Y 0.54 7--10 0.70 1 L----4 E 0.25
• 1999 23 L-49Y 0.47 1-- 12 0.08 4 L----5 E 0.80
• 2000 15 L-38Y 0.39 9-- 10 0.90_2 L ----3 E 0.67
2001 33 L-54Y 0.61 0--7 0.00 2 L----6 E 0.33
• 2002 28 L-56Y 0.50 3 -- 10 0.30 2 L----3 E 0.67 44L-- 1031
• 2003 28 L-69Y 0.41 6-- 15 0.40 3 L ----4 E 0.75
•
•
• note 1991-1993 UY rates estimated from Figure 1: 1990-1991 Bighorn Institute
1987-1998 NSRM Table 4, Ostermann 2001
• annual fall helicopter surveys results from Bighorn Institute
•
•
•
•
•
•
•
•
i
•
•
• Period Three--2000 through 2003 averaged 130 adult sheer Tentatively, period
• three represents a period of recovery or expansion in sheep numbers. The last two
• years, 2002 and 2003 numbers were the same magnitude as period one, the years of
greatest abundance.
•
• While the preceding analysis is preliminary and general, we believe identifying the broad trends is
• instructive. Thus, in the entire Plan area(as graphed in Figure 1)--Anza-Borrego Desert State Park,
Santa Rosa Mountains, and San Jacinto Mountains--the bighorn sheep are in a state of recovery and
• their numbers increase across the Plan area.
In 2004, the range-wide helicopter surveys estimated 760 adult bighorn sheep for the nine recovery
regions in the Plan area! (see Figure 1)This represents a 175% increase since 1996 estimates of
• only 276 sheep, and a 20% average annual increase in the bighorn sheep population. All nine
• recovery regions participate in recovery experience, albeit some greater than others.* This estimate
• of 760 adult bighorns could represent the largest number of sheep in the Peninsular Ranges in the
• last 25 years. How can one interpret this data other than that the bighorn sheep have been
recovering successfully for the past eight years? Why wouldn't 2005 become the ninth year?** In
• our view,this evidence calls into question the Plan's proposal to put trail rationing public policies
into effect in 2005. What scientific evidence serves as a basis for the proposed rationing of trails
i use?
• Each spring an estimated 90% of adult ewes give birth but many of the lambs do not survive the first
• six months (DeForge and Jenner 1977). Table 3 presents the estimated lamb-to-ewe ratios for the
• Peninsular bighorn sheep over the period 1984 to 2003. The value of this ratio is often called the
recruitment rate. Each October, the Bighorn Institute gathers this data through helicopter surveys.
• The lambs counted are at least six month old and fully weaned since most births take place in
• February, March and April. The final, year end recruitment ratios will be somewhat less than
• presented in Table 3 to account for losses in November and December.
• According to waterhole counts, the Santa Rosa Mountains experienced a steep decline in population
• in the 1970s. This sudden loss of bighorn sheep"correlated with a disease epizootic causing high
• lamb mortality." (DeForge, 1982 and 1995) It is suggested that something similar occurred in the
• San Jacinto Mountains area during the same period.
i Table 3 offers insight into the population figures shown in Table 1. In the Santa Rosa Mountains, .
• for the period 1977 through 1982, the lamb/ewe ratio averaged .14 (DeForge & Scott 1982). Since it
• takes about 25 lambs per 100 ewes to maintain a stable population, the bighorn population in the
-------------
• *Carrizo Canyon, Vallecito Mountains, South San Ysidro Mountains, and the Santa Rosas show the largest
• gains while slight increases occurred in the San Jacinto and North San Ysidro Mountains regions. The
• numbers in Coyote Canyon remains fairly stable since 1996.
• **The Bighorn Institute believes the heavy rains in early 2005 bodes well for spring recruitment. Also see
• Epps 2004)
•
•
•
•
• - 22 -
•
•
i
•
• Santa Rosa Mountains was in decline over this period. For the years 1987-1993, the average
• recruitment ratio was only .20. Again, this low ratio corresponds with a declining population under
• conditions that existed in those years. But the northern section of the Santa Rosas was in trouble.
From 1985 through 1997, its recruitment ratio was only 7.8 lambs per 100 ewes. What caused this
• very low average recruitment ratio and correspondingly high annual lamb mortality? The Bighorn
• Institute undertook a four-year study to find answers. In spring of 1998-2001, 34 lambs were captured,
• radio collared and released. Of 14 cause-specific deaths that occurred, 43%were attributed to
urbanization and 57%to predation. And 13 of the 14 mortalities occurred within 300 meters of an
• urban interface. Researchers at Bighorn Institute hypothesize respiratory disease might have
• predisposed some lambs to predation. (DeForge, 2002)
By the second half of the 1990s, the situation was about to change. From 1994 through 2003, the
average lamb-to-ewe average for the Santa Rosa Mountains was .45.* In the northern SRM, the
• average lamb to ewe ratio shot up to .40 for 1998-2003. Table 2 illustrates the same held true for
• Anza-Borrego Desert State Park. The average recruitment ratio for the 32 years was .32, but for
i 2001-2003,the ratio was .50** It is estimated a lamb recruitment ratio of about .25 (lambs per 100
ewes) is needed to maintain a stable sheep population. Thus, a rate of greater than .30 could permit a
i growing population.*** Over the most recent years, a growing population is just what Tables 1 and
2 demonstrate.
• Figure 3 provides a graphic representation of how recruitment rates can affect the sheep population.
• The yellow bars represent the estimated adult bighorn population in the Santa Rosa Mountains.
• Read left hand axis for numbers of sheep. The green bars represent the .25 recruitment rate standard
• for maintaining a stable population, assuming normal mortality rates. Thus,the standard is
• represented as a constant or .25. Read right hand axis for values of the recruitment rate. The sheep
population will likely decrease if the recruitment rates is less than .25. The sheep population will
i likely increase if the recruitment rate is greater than .25. Lastly, the red line represents the estimated
i recruitment rates in the Santa Rosa Mountains. Note from 1987 to 1993, recruitment rates were at or
• below the .25 standard for all but one year. This is consistent with a falling population, which is
what is represented. Beginning in 1994, the recruitment rates jump to levels permitting a population
•
•
• *In 1995,the Bighorn Institute initiated efforts to construct a bighorn proof fence at the urban interface of the
• City of Rancho Mirage. A 4.5 mile fence was begun in 1999 and completed in fall, 2002. Institute
• researchers believe this fence will substantially reduce the lamb mortality in this region of the Coachella
• Valley.
i **The waterhole counts in Anza-Borrego are taken in July,while the helicopter surveys in Santa Rosa and
• San Jacinto are taken in October. Thus,the recruitment rates aren't comparable because Anza-Borrego's
• rates would experience some decline between July and October.
• *** Population changes result from(1)recruitment rate or lamb to ewe ratio and(2)rate of adult mortality.
• Both these rates can vary significantly and vary independently from each other.Also,potential stochastic
variation in lamb sex ratios can affect population numbers. But as a first approximation, one could say that a
• lamb to ewe ratio greater than .25 might generally be a necessary condition for an increasing population, even
• though it is not a sufficient condition. For example, a declining sheep population could occur even with a
• lamb to ewe ratio of 35, if the adult mortality rate was particularly high.
•
23
O 00 I-. ico In V' CO. N
C7 O O O O O O O >^^.
7'77
- .., - .
'_ M�lIL�n,mm. .n*aro✓xbnwow�„ fm'+n*w�`wwawr«Mwwo-nhynulaM��rtwrw+ "„.,�
O
p. Mrv+:r mmmM+pA��Mn .nee,
•rvYm+ P'«a!Y^wwnkna n7+ r _
Imrn*ayn.rvx�x wnr• m�+aTMnwva Yn mo �N swrv,
. .IMIw�r�iaM I
rw w.,.+«, n -»,r »��p!>K�M�. MwnMwl�"!plxw!•M+n`��'un}g41jDl >`�
n "vw' 'ef wn,uar nai O ,
�Y45«w4^**+NM"MwM'y^+ Aµ9fldMmhYMeW�. ,.. Md1.w ..n O ,
.0 ,.+br+nM *aMwl�+ d•'� nM*rwlwngr?a ,w
•..•rrM .ro. ..Jr NIwo
r rt«k r.,�y. , .vawrw»YYn+6an�NWa+wgF�, e4pAW1�1 Q]
w ���w, ` er..�xrv•ula•nd*,nrmarMwam,emc•xpp*mm"r?'Rsrvt�xra � Mw+*.v. '
:��e wnmr, a ............ 00
vwwt
m«MavYa w w wawlmww«wnaxW� „•=�aa
_...•Nue" r �� 'ICM�fA1�WMf 1�4nMrw+nL W"'WI 0)
' ,MIeRxwra �+mwi4w��m.Y+w,w!.rlrvewwarie«dilwreu«gi+iinM�IHm:KI pa�wM,eerw�Mut*kr,+rvM+er^rr4MFl � ,••,+'+!
.•� ��' wrn'mvx,+r�."`YC•rw�4TwM^'�`4Md+^tµ?N^"1ll�w�^'kprm•M++..�'" �w'1wPwYMnWINreiNry�',AIlY �
my. x CA p�ri'rw v.w.�r5w:�wmn,�humwm... n .
JJ ai +w'w*rPoWe'm;wy .,rrr%�d-m+niy�WrkN�Ya' CO
,r1�n M n rv+Mwsv4 YnyuMvwus'wnxalWM�b t,. _ .n .w"'y
. „ . ,, ea.- .wxrfiwymm�.r4an�vwti+tni.lxetiay^a� "'g r- mmw,.n,.
��i � RMrveww7+
. n. „F,,.pxu4�n r "krtu.Mws' Fp+ivflNnO �rv.'�R[b i.a
w gii . Mp !M1W5^"a Y,Y� LO i t
•�»wy+w.w+w www�mxau" "'*MirYrR: _ 0) .,,.
w
77
"....n�nm wwFM-w".�t,WMM'^,dW^M MP M +MxWkxriu>FhiM�i <- `nrv�+' �'
.,.. 'w�.,+ „�, ,r*wu:�j�,h+wi•µtrwu.+ri!�*~rnc+�`nrrr�wu nhu ?rar�r r�w�'www�Yw wk+�RMrpipYnM4Yw" mm��wx
I ' ++r �.+.m.mm�*w*r•n*'rv�fe .'' w+nrvrarrn� ,.. � $Y>
• 'r. p.�q1'I���,1�I��] r•+�«+.+t»rann+sw+�.«^d✓eYm�e: ^r�aw � O7 auwr+m�
M V rr« r�w>aro�wwrvo-'W�'xwwmaEw:n �uwuWiA�Ynmrw�lenr
.mv'x'h^'Mre^ fq rvm �« ,.x xe.w.:,rw»xai ^m•*^^mr�+n�.." Wvww�"^+nN+rHrunAF'ANa � .wxewF�wr "iXP P,� �
" wwM r -+ me+rmw aren,."t"rv'". *4"rt' + w'w^rrv5na� �uM.w B+r a, MMik�I��-
+�anw.emwlw CY) .,.
r� .awn�ru n�e•S e*n4^'N'+W ^I aanwx.taa�Yr,�M,hfi O .+
++ra«Yxairmmxnrv+rr .,, eY .:n„ .mw•.ar , ,. mYarwnwrvmgrpYisrm+m'*rm �... �... 0)
e� ANn*n•MMMn^ W* r>nt++•n ,.wi +WM14x+rvM'w+XYgWY+�a-w wnx.AVM NrtA Ik*m' �Am
i.rmwnx r e+ �n
�nr�
M} "M+tlHdFkwM!W"d ,. �i .w•rw pxtt1u+nnr.rpny,wegm,NNaMurnNarv'M rMFeY, +W.
� �,Fw+" wm 'ri�'*wmww �✓wvm`nharinw+mmx+, rvyn+wxmrnyw.�, x" yrv. *1^.
r�N•a �46^r. " rw.Y+r+w.r+mrcamwtw wwrd.,+.im.tin'rvF+Y+wwxaji:w•^a« ww +«
�'eRnW 4raurrvrw.rx^.ry
wYrw�� rl+n w. as 4 wrn
n•«rrxel `emrvn „ry«� an.m. m+ wwra+ rv, CO
a rvr�n+M+o-eN%wxmw.w 9 ,.. < w, , . w ,rvr,wwMxMxxsnnn n�, �amd W
xrt'ed"enx+n,m�nnwrva "-, ,-� +wn e�*,.,."•w.n^,m+Mb^'"^'YP'"'rMRI'P"YAw'Aw�^.rngn4`�rnM�^ad+w.kihmo-+AwMwne r ,,...,w„q
9d4 wm•eyuvM III,WrIMAY'. r � wrm+v'^+c Y+� ;wn�*rlfmwkM .a.B �. YYP'.w,wr Me aart*.m�i'+1MKw,
,mnmrv%^^M1"1 .. uwa.m M wmwnro"xwrv""+fin• OD
r M moo. wwxawaMpM +x!a.yw+Hlpe �'Td' ,w.bm+«r" 0)
..., r ..,::r.« «,:, ..w.„an•ea+ v* a«m.,e. �:arv,.n 0
" 1�'.a. 'w,ry+Mr,k.` +n nM`Ar*-r.+�vm.M•»«rw �`•M» r r+ *Rrv* -+r "�w�.^n+iw,. •eea. .
w w>wn�m'»mw+v W - , m>n«w+a a+ v. rcarMr xux i v rry 1
00 rvmm
y. . .»wen � .pF„ t-..,,mwi -:;wew +x•„w! I..ew .w m.,.m»xa rrr'a^ m+.ro�a« r,,,., ww,r a w»•mrnw. '. ', �ne�c»rax+ wwwrr+wm..ww.. �*1'tlM.; +i
W
0)
w+ +www+ +awY.gmn. n•. Oftil CD O O C) 0 'O ...
+n..x«M.aa'aVnrn> w •w O 47 O m,
co4lJ O L7
��wa ,.n*p*m".rya+'+�W�'n+irvM+�d^.>ammkmk✓i,«�W.. N N � �
•
•
•
• increase(that is above .25). For each year of the period 1994 to 2003, recruitment rates remained
high and at levels permitting a population increase. The major point or the seeds of recovery can be
• traced back to 1994.
• A key conclusion drawn from data presented in Tables 2 & 3 points to sheep recovery not as a
• problem of reproduction but of lamb survival. Over the past ten years, lambs have been born in
• sufficient numbers to permit a recovery of the sheep population. We can infer from this information, then,
• that trail users do not adversely impact sheep conception or reproduction.
• leadin
One question remains: do trail users affect Iamb mortality? According to researchers, the g
• agents of lamb mortality are (1)high temperatures of their first desert summer; (2) viruses-- "recent
• studies of high lamb death rates focus on viruses possibly introduced by domestic livestock, to
which the native bighorn have little or no immunity." (Jorgensen,p.2); (3) weakness--"when a lamb
• is sick and pneumonia renders it helpless, coyotes become superb predators." (Jorgensen, p.2); (4)
golden eagles--they swoop down and capture lambs from terrain no safe from other known
• predators; and (5) a four-year study of cause-specific mortality of desert bighorn lambs found
urbanization and predation the two culprits (Deforge, 2002). Also see, ass 1989
H , Kalinows ki
• 2001, and Woodward 1972. No research suggested trail users cause Iamb mortality.
•
• A twelve year study of bighorn sheep in the Santa Rosa Mountains concluded that significant lamb
• mortality occurs between April and October(see DeForge 1995). Trail usage during this six month
period is considerably less than the six month period November through March primarily because
• higher temperatures during April through October cause trail users to seek trails around Idyllwild,
• Joshua Tree National Park and above the train in Palm Springs. Does this pattern of trail usage
• suggest hikers present a problem for the recovery of bighorn sheep?
• Considering the information in Tables 1 and 3 and our analyses of this data, why does the Plan
• assume that trail users adversely affect the population of bighorn sheep? It offers no evidence to link
• trail use and sheep population numbers. In fact, our evidence and analyses suggest just the opposite.
S Most likely, in the past eight years,people using trails have increased in number. During the same
period,the sheep population has expanded because of recruitment rates averaging 45 to 50 lambs per
• 100 ewes. To accelerate the recovery of bighorn sheep even faster, the policy variable available is
lamb mortality. Why doesn't the Plan focus on this critical variable? There is reason to believe a
• direct intervention in the Santa Rosa Mountains in 1981 was helpful in reducing lamb mortality due
to pneumonia(DeForge, 1982). Also, constructing the 4.5 mile fence in 2002.
•
Finally, we should point out that a major article was published in 1998 (Rubin et al.) to highlight and
• analyze the decline of Peninsular bighorn sheep between the years 1994 and 1996. Curiously, in the
• past six years, nothing has been published by the"recovery team" authors exploring the dramatic
recovery in Peninsular bighorn sheep over the period 1996 and 2004.
•
• In summary,time series population data on Peninsular bighorn sheep were not included in the Plan
• or in the EIS/EIR. Why not? The Plan authors possessed the data. Plan authors included time series
data on the fringe toe lizard from 1986 to 2002 (see Appendix I, page 212). Why didn't the bighorn
• sheep warrant similar treatment?
•
•
25
•
•
•
•
• 3. Seasonal Trail Program (7-55-60)
• What are the origins of the "seasonal trails program?" Roughly, we believe this program can be traced
• back to (1)the Bureau of Land Management, Palm Springs, (2)U.S. Fish& Wildlife Service, Recovery
• Plan for Bighorn Sheep in the Peninsular Ranges, California, 2000 and (3) a lawsuit by the Center for
• Biological Diversity and the Sierra Club. The initial seemingly benign phase was a voluntary trail
avoidance program undertaken as a joint BLM-CDFG effort. It was first announced on March 3, 1998,
• in The Desert Sun, and applied to seven trails. But that year there were no signs installed and no further
• newspaper coverage. On January 24, 1999, The Desert Sun ran another article about the voluntary trail
• avoidance program, again citing the same seven trails. Starting January 29, 1999, The Desert Sun
. printed weekly notifications of the voluntary avoidance program in its "Great outdoors" section, usually
next to "hikes &events". That year informational signs about the avoidance program were installed. A
• follow-up article in The Desert Sun on March 12, 1999, focused on trail users' not complying with the
• request to avoid the subject trails. On March 16,2000, a lawsuit was filed in U.S District Court against
• BLM by the Center for Biological Diversity, Sierra Club and Public Employee's for Environmental
Responsibility. BLM and plaintiffs negotiated a private out-of-court settlement agreement approved by
• the court on March 20, 2001. The plaintiffs forced an agreement that deployed five sheep ambassadors
• on all trails to urge users to comply with voluntary trail closures, and expanded the voluntary trail
. avoidance program from seven to eleven trails, adding Clara Burgess, Dunn Road, Bear Creek Oasis and
Morrow Trails. Unfortunately, neither the Center for Biological Diversity, Sierra Club,BLM nor
• U.S. Fish and Wildlife offered any evidence or rationale for implementing and continuing the trail
• rationing policies. They simply made unsupported claims. Nothing more than a "belief system"
• became public policy.
• The Seasonal Trail Program applies to trails during the lambing season, January 15a'through June 301h
• According to the Plan,the Seasonal Trail Areas encompass about 67% of essential bighorn sheep habitat
• or 126,612 acres. The Plan does not define"lambing areas." What is the definition? What proportion of
• the Seasonal Trail Area would constitute lambing habitat given the prerequisite escape conditions?
• Part of the best available science is that of McKinney et al, 2003 who authored an important new study
• on escape terrain. We can find no reference to this study in the Plan or EIS/EIR. Why is that? Was
• escape terrain taken into account when developing the area to be covered by the Seasonal Trails
• Program? If yes, how was that done? What science supported the decisions? If none, why not?
• Regarding lambing areas, others have described them as follows:
• (a) ewes use steep, rugged slopes and canyons for lambing areas (Wehausen 1980);
• (b) "when ewes are ready to give birth they will typically seek out the most precipitous terrain,
where their lambs will presumably be safest(Geist 1971);
• (c) ewes use steep terrain for predator evasion and lambing. (P. 6 F&W 2000);
• (d) "lambing areas usually consist of steep cliff complexes intermixed with small terraces and/or
• ledges. Terrain commonly used for lambing is rugged and remote in order to provide ewes
• security and isolation for the lambing period." (Chum Creek Protected Area Mgt. Plan,p.80);
(e) "lambing areas are associated with ridge benches or canyon rims adjacent to steep slopes or
• escarpments...ewes and lambs frequently occupy steep terrain that provides escape cover and
• shelter from excessive heat." (Fish and Wildlife, July 5, 2000);
•
•
26
•
•
•
•
•
•
• (f) ewe groups often establish nursery systems—one ewe remains with a group of lambs while the
• other mothers briefly move to another area to feed and drink," (Bighorn Institute, The Bighorn,
Summer 1997,p.2; and Bighorn Institute, The Bighorn, Spring 2004, p. 5)
• (g) ewes and lambs seek habitat containing fewer predators and more escape terrain(Bleich 1997)
• (h) In a contemporary review of the literature on the habitat requirements of desert bighorn sheep,
• McCarty and Bailey 1994 wrote, "bighorn most frequently select steep terrain for lambing sites
(Geist 1971, Ravey 1984, Etchberger 1993). Wilson et al. (1980) and Armentrout and Brigham
• (1988) suggested that lambing areas are steeper than areas considered only as escape terrain.
• Creeden(1986)made no distinction between lambing topographic cover and escape terrain,
• only stating: "Ewes preferred inner canyon habitat for lambing. They often select ledges at the
• bases of sheer canyon walls and above steep talus slopes. All sites were located on escape terrain."
What proportion of the trails earmarked by the Plan for the Seasonal Trails Program runs through
• such terrain? What portion of the eight-mile Art Smith Trail passes through a lambing area?
The Seasonal Trail Program was put into effect during the lambing season(January 15 through June
30). While the Plan does not offer data to support such a program, one must assume it exists
• because someone saw reproduction as a problem linked to the trails. Since 2001, a voluntary trail
• avoidance program has been in effect on 38 miles of trails. Each trail was posted with signs asking
• the public not to use it during lambing season. Most of these trails are in the Santa Rosa Mountains:
• Please refer back to Table 2, and note that in the Santa Rosas for the six-year period 1987-1993 the
average recruitment rate was but 20 lambs per 100 ewes. Clearly,this was a period of declining
• population. One could assume that reproduction or at least lamb mortality was a major problem. But
• starting in 1994,things changed dramatically. For the ten-year period 1994 to 2003,the average
• annual recruitment rate was 45 lambs per 100 ewes; more than double the earlier period and
sufficiently high to produce a growing population of bighorn sheep. (see illustrated in Table 1.)
• Certainly,reproduction could no longer be seen as a problem and lamb mortality rates had improved
• enough to insure an expanding population. Why, then, was a voluntary trail avoidance program put
• into place when seven years of data(1994-2000) indicated no need for such a program?
• The Seasonal Trail Program contains six elements:
• 1. A,quota permitting program on seven trails
• 2. A voluntary trail avoidance program on six trails
• 3. Closure of five trails during the"hot season"
4. A public awareness and education program
• 5. Annual review of seasonal trails program
• 6. A research program
• 1 would like to look more closely at each element:
• One: Permit System
• The quota permitting program is addressed in section 4 (pp. 31-42), following this section.
Two: Voluntary Trail Avoidance Program
The names of trails not covered by a seasonal trail permit program will be posted, with
• requests that the public not use them between January 15 and June 30. The voluntary trail
• avoidance program covers all or parts of six trails. It provides no penalty for non-compliance.
•
•
• 27
•
•
•
•
•
•
• Three: Hot Season Trail Closure
• Closing five trails during the hot season from July 1 through September 30 should cause little
inconvenience to the public.* Few users are on these trails, usually preferring trails at higher
• elevation. Why is this closure even necessary in the Coachella Valley when the mean
• temperatures in July are 108, in August are 106, and in September are 102 (Baumann, Table
• 1)?. How many users are on the trails in this heat?Under the most favorable conditions of the
year, BLM estimates an average of only nine users a day between January and June for the five
• most popular trails! More important is the assumption behind this measure that trail users
• prevent or disturb sheep from drinking at water sources. Another untested assumption and
unsupported claim. Where is the science to support such a claim?
• Four: Public Awareness and Education Prog am
• The public awareness and educational program showing that vehicle drivers and passengers
• should wear seat belts succeeded because scientific research supports it. The public believes and
• trusts the government studies confirming that seat belts save lives. Periodic crash photos in the
• media validate the government claims.
• Unfortunately,those in charge of the "public awareness and education program" for the trails
• plan have a daunting task. They have no research to back up their rhetoric. They have no
evidence to present to the public. They have no dramatic photos or videos to back up their
• assumptions and claims. How,then, will the public trust them? Those who gain trail experience
• in sheep habitat will become skeptical of claims that trail users adversely affect sheep. The
• public awareness and education program is destined for failure.
The Bureau of Land Management acknowledges the problem:
...it is reasonable to anticipate that compliance with the program could diminish if
• the public perceives the voluntary closure program to reduce disturbance to bighorn
• sheep during lambing season as unreasonable. (BLM Decision Record, 2000,p.16).
• What BLM does not say is the public might consider the program unreasonable since no
published study exists to link trail use with the population of bighorn sheep in the Plan area,
• and public agencies have not been forthright with the news of bighorn sheep recovery.
Five: Annual Review
This review will consist of an annual review of the effectiveness of the seasonable trails
• program. How is "effectiveness" defined? What are the standards being applied in this case?
• Where is the monitoring research described? How can the annual review take place if the
• monitoring research is not in place? What are the "other trail management prescriptions?"
• Who is responsible for fleshing out the details of the "annual review?"
• --------------
*Contrast this period with January,February and March,the busiest time of the year for local trails. Trail
• restrictions or rationing will cause public inconvenience and tourist dissatisfaction during these three months.
On Monday,April 5,2004, a man walked into the Visitor's Center on Highway 74 and asked directions to Art
Smith. He was told the trail was under voluntary closure.He said,"but my wife just dropped me off and I
• can't call her back for three hours."He stormed out the door heading across the Highway..
•
•
• 28
•
•
•
•
•
• Six: Research
• The December 1, 2003 draft Plan contained a brief discussion of a research program The later
draft, October 2004, contained only one phrase describing planned research: "research
• designed to ascertain bighorn sheep response to, and any significant adverse impacts from,
• recreational trail use in the Santa Rosa and San Jacinto Mountains." (7-55-56). Why was the
• discussion in the 2003 draft deleted from the 2004 draft? Was the information and/or treatment
• of research in the earlier draft deemed deficient? If, yes, how so?
• This seasonal trails program will affect full time residents,part-time "snow birds," and short term
• tourists alike. Roughly, day trail users are made up of organized groups such as Desert Riders,
• Desert Trails Hiking Club, Coachella Valley Hiking Club, Sun City Hiking Club, The Living Desert,
Siena Club, Desert Cities Tract Club, Desert Bicycle Club, Palm Spring Triathlon Club and
• individual users. The organized groups will become aware of these programs and most likely will
• comply. Individuals on their own would be less likely to know about the programs, understand
• them, or sympathize with them. They could find the restrictions unreasonable. With no penalty for
non-compliance, individuals might ignore the signs and continue using the trails. This opens up the
• possibility that compliant group users would be penalized because the actions of individual users
• might result in permanent trail closure. We recall that during the period January to June 2001-2003,
• 41% of the individual trail users contacted by sheep ambassadors at the trailhead refused to comply
• with the voluntary trail closure(BLM Decision Record, 2001, p.9). In contrast, with one exception,
we believe the organized groups mentioned above did not schedule hikes on trails subject to
• voluntary closure.
One step toward making the public take seriously trail closure restrictions is to impose monetary
fines upon violators. The word would spread, and greater compliance would probably prevent a need
• to penalize compliant citizens with trail closures. However, if the responsible agency is not sure that
• trail use directly affects population levels, it might not be enthusiastic about imposing monetary
• fines.
• Finally, The Executive Summary (page 3) states, "The Peninsular bighorn sheep conservation
• strategy was primarily based on the Recovery Plan for Bighorn Sheep in the Peninsular Ranges,
• California and(USFWS 2000)." This acknowledgement seems benign enough but upon closer
• inspection it tells an unfortunate tale. The "Recovery Plan" suggested some trails were potentially
in conflict with lambing, rearing and water requirements and should be addressed through
• management tools, such as seasonal restrictions or closures (p. 87-88). In 2000,not one iota of
• evidence was presented to support this position. Despite the 1973 Endangered Species Act mandate
• for the use of "best available science", "Recovery Plan" authors put forth unexamined claims and
• assertions, a standard unacceptable in the scientific community. Then, four years later, with no
research to support its position, CVAG presented its "trails plan" and merely adopted the earlier
• "Recovery Plan" suggestions for restrictions on the same trails, despite lack of an evidentiary base.
• How can it be that two major publications on bighorn sheep (Recovery Plan and CVAG's Plan) put
• forth major policy positions that have no basis in science? For more than six years a dogmatic
"belief system"has been in place, solidified and credentialed by the "Recovery Plan." Is this a
• victory for non-science?
•
•
•
• 29
•
•
•
•
•
•
! We should be mindful, that for more than six years the holders of a dogmatic"belief system"had
• time to undertake research to substantiate that"belief system." Our research suggests that during
that six year period,true believers did not write even a single research proposal to test their"belief
• system." Could it be that holder of this "belief system"have no interest in testing their claims?
• Could it be that holders of this "belief system"believe they can prevail without putting their"belief
• system"to a test? Could it be that holders of this "belief system" fear that such a test of their"belief
• system"would find no basis in reality? Is their friction among the government agencies such that
one stands in the way of another when it comes to undertaking research?
•
•
!
!
!
•
•
•
!
•
!
•
•
!
!
•
•
i
•
•
•
•
•
•
•
•
•
•
30
•
•
•
•
•
4. Trails Permit Program (7-57-58)
• For the public good, a trails permit program at first appears a major improvement over the
• alternative of seasonal trail closures. But upon closer inspection,the trails permit program ratchets
• up explicit trail rationing in such a manner that trail users can't exonerate themselves from fault.
More importantly, there is no science to support either the seasonable trail closures or a quota
• permitting program. Furthermore, the bighorn sheep population has been in recovery for the past
eight straight years, providing no empirical support for programs of reduced public access to our
• trails. Lastly, the Plan presents no operational details for their quota permitting plan, and probably
• for good reason. Such a plan would be a nightmare to design and impossible to administer. All the
• inevitable bureaucratic snags and snafus would bring down the program with a crashing thud!
• We will first analyze CVAG's Preferred Alternative proposed by the Plan. Next, we will outline our
• (CVHC's) alternative proposal.
I. CVAG's PREFERRED ALTERNATIVE--Proposed by the Plan:
• Set the total number of individual-user permits at 2,300 and the group-permits at 50
• For the seven designated trails (see Table 4)*, CVAG's Preferred Alternative sets an average of 329
• individual permits per trail per season or 60 individual permits per month per trail or two individual
• permits per day per trail.** If the least used trails in Table 1, Cathedral Canyon and North Lykken, are
removed and only five trails used for the 2,300 permits, the average number of permits per day per trail
• would still be a paltry 2.8!. When individual users are concerned, it is difficult to imagine that an
average daily use of 2.8 users per day per trail is grounds for rationing trail use or developing a
• management program of trails. Since no empirical studies linking trail use
• to a decline of sheep population exist, how can an average of three-users per day, which is almost
no-users per day, be considered reasonable usage or in the public good? Or for that matter, in the
• best interests of the bighorn sheep!
Wildlife biologists and field managers seem to agree that bighorn sheep have and can habituate to
humans. This happens when sheep encounter people in predictable places (see DeForge 2004, Hicks
• and Elder 1979, Wehausen 2000, Campbell and Remington 1981, Hamilton et. al. 1982 and Hansen
• 1982). In the wild, hiking trails represent predictable places for sheep to see humans. To facilitate
•
• -------------------
*Two of the most unique trails in the Coachella Valley are The Art Smith and The Skyline. The Art Smith
• allows one to traverse 17 miles from Palm Desert to Palm Springs with spectacular views of the Valley floor.
The Skyline offers the steepest one-day climb in America-22 miles and 12,000 feet.No other trails in the
• Plan area replicate the experience gained from these two trails. No new trails under consideration will offer
• anything close to what these trails currently provide users. Thus,restricting these trails without empirical
evidence clearly results in a decline in the public good.
•
• ** 2300 permits divided by 7 trails equals 329 permits per trail per season—329 permits per trail divided by
• 5.5 months equals 60 permits per month per trail—60 permits per month per trail by 30 days equals 2 permits
per day
•
•
• 31
•
•
•
•
•
•
• the process of adaptation of sheep to people,the trails need to be used. Restricting the seven
• designated trails in Table 4 to an average of 2.8 individual users per day per trail doesn't represent
predictability. Thus,the proposed rationing program of 2,300 individual permits is not in the
• interest and welfare of the public or bighorn sheep.
A total of 50 group permits will be issued per year. In the Plan, a group is defined as a gathering of
12 to 30 people. Thus, a total of 50 permits times a maximum of 30 individuals equal 1500 total
• users. Again, this bench mark number of 50 will result in a failed program. If during the 5 '/z month
• period, one user group seeks a permit approximately once every other month for the seven trails this
• would represent 21 total permits (7 trails x 2.75 times a season= 19.3 permits). Thus, if just three
• user groups applied for permits there would not be enough to go around(demand 58 and available
supply 50). All other user groups would be left out! The stampede for permits would result in
• further rationing among the user groups.
The total number of trail users allowed under the permit system would be 2300 individuals and a
maximum of 1500 group users for a total of 3800 users.* The BLM estimated the demand for the
• five most popular trails scheduled for permitting at 9 users per day (see Table 4). CVAG cut in half
• the adjusted BLM estimate and proposed a permit system that would limit these same five trails to a
• maximum of 4.6 users per day.
• One study, done in the summer of 1981, evaluated recreational use of hiking trails in the San Gabriel
• Mountains of California. The three most popular trails on Mt. San Antonio averaged 40 hikers a day
• without adverse affects upon the Bighorn sheep (Hamilton et al., 1982). CVAG's "trails plan"
• proposes a permit system that would limit the five most popular trails to a maximum of 4.6 users per
day(see Table 4).
•
• From January through June, 2001 through 2003,the Bureau of Land Management collected trail-use
• data:
• These data were not collected using a statistically valid sampling scheme. They are
intended to provide the reviewer with an estimate of observed and potential use to
• ascertain possible effects that may result from implementation of a permit system that
• would limit the number of available permits for use of selected trails from January 15
• through June 30." (BLM, "Actual...."p.1)
• Similarly, the current number of 2,300 individual-use permits does not represent an adequate base
• line figure or norm. The program on this basis would be set up to fail. Why? The normal use of the
• seven trails in this program ranges from low to medium to high, however one quantifies the levels.
Please refer to Table 4 below for an estimated demand for these trails.Notice that the most popular
• trail, The Art Smith Trail, would probably use or exceed the total available 2,300 individual permits
• allowed leaving no permits for access to the other permitted trails.
•
• *The actual number of group users would most likely be closer to 1000 than 1500 because user groups rarely,
• if ever,take groups as large as thirty people on the trails. An average of fifteen people in each group
• produces 750 group users and a total of 3050 total users.
•
•
• 32
•
•
•
•
•
• The key to a successful permit program starts with the total number of permits granted. Why? That
• number becomes the base line or the norm to be achieved under the program and is the Plan's
measure of the acceptable level of users. From the standpoint of the Plan, it becomes the proper
• level of use consistent with the conservation plan for the bighorn sheep. Once the quota exists in
• print it will prove very difficult to change. Thus, it is of paramount importance to get it right the
• first time. If the number of permits used is equal to or less than the total number allowed, the
• program in practice can be judged a success (assuming all trail users have permits).
•
• Table 4
• Estimated Demand for Trail Permits: January-June 2001-03
•
• Coachella Vll T� BLM estimate* Adjusted BLM Estimate**
• Art Smith 2,400 3,120
• Clara Burgess 1,595 2,074
• Skyline 1,575 2,048
North Lykken -0- 130
• Bear Crk Canyon/Oasis 1,159 1,507
Boo Hoff 868 1,128
• Cathedral Canyon 100 130
•
• Total 7,697 10,137
•
• If all individual and group permits are issued and monitoring programs discover the use levels (users
• with and without permits) exceed the base line total of 3800,then from the perspective of the Plan,
• too many trail users are in the environment. Then, the Plan could judge the program a failure and the
program stopped in favor of trail closures.
•
•
•
-----------------------
*Bureau of Land Management, "Actual and Potential Use of Trails Subject to the Permit Program,"BLM,
• Palm Springs,January 2004, Table 7.
• **(a)The BLM estimated demand for permits was adjusted arbitrarily upwards by ten%to account for
• compliant users who never returned after a one time experience when the trail was subject to voluntary
• closure. This adjustment was made necessary because a downward bias in the BLM estimate is produced by
not accounting for these compliant users who never returned to the trail after their initial contact with the
• BLM's"sheep ambassador."
• (b)The BLM estimated demand for permits adjusted arbitrarily upward by an additional twenty%to
• account for group users who refrained from scheduling use of the trails subject to voluntary closure. Thus,
the total count doesn't reflect total estimated demand because group users were never in the original count.
• (c)It is assumed the demand for permits on North Lykken will be the same as the Cathedral Canyon trail.
• (d)No adjustment was made for the known increase in trail use over time or 2001-2006,thus the estimated
demand of 10,137 in certainly a conservative estimate.
•
• 33
•
•
•
•
•
•
•
• In a June 19, 2003 letter of public comment, Jeff Morgan of the Sierra Club San Gorgonio Chapter
• wrote, " The NM Plan's assertions about trail use based on data gathered by Sheep Ambassador's
should be qualified by the fact this data was gathered without proper protocol and has little, if any,
• statistical validity. To compound statistical invalidity of this information, it should be noted that it
• was common knowledge among trail users what type of vehicle the Sheep Ambassadors drove and
• the ambassadors were regularly spotted and avoided." (BLM, 2003, Appendices M 26-27)
• Despite Morgan's critique, CVAG went ahead a year later and based its quote permitting system
• upon flawed data. This resulted in completely arbitrary numbers for its permitting program.
Reasonable questions arise regarding the Plan's foundation logic:
(1) Does the Plan identify how many different user groups exist in the Plan area? Does the Plan
• have any idea how many group permits will be requested by the various user groups? Essentially,
• the proposed allotment of 50 total permits would put user-groups out of business on the seven trails
covered. An unintentional consequence of such a small number of permits might be to discourage
• membership in user groups, since an individual acting alone would have greater access to the
• permitted trails,rather than with a club or organization. In our view,this would be counterproductive
• since user-groups provide an educational function,teaching respect for the environment and support
• for the conservation goals of the Plan.
• (2) What was the rationale for the 2,300 individual permits and 50 group permits? The maximum
• number of users with the permit system will be 3,800. But the average size of group hikes is closer
• to a maximum of about 14. Thus the total users would be 3,000 and represents 30 percent of total
adjusted BLM estimated demand of 10, 137. This will create an estimated excess demand of 7,137
• users. Seven out of every ten permit seekers would be turned away without a permit.
• (3) Can a government rationing system work effectively without public approval and without public
• support?* What happens when the public discovers that the bighorn sheep population has been
increasing in numbers for eight straight years without the drastic government action of permitting
• trails? What happens when the public learns there is no published research linking trail use to sheep
• population problems? What happens when the public learns that CVAG's proposed trail permitting
• plan is based solely upon a dogmatic "belief system" of a few wildlife agency people? The stage is
set for diminished public support, increased non-compliance and program failure.
•
• *In 2000 the BLM began installing signs on some valley trails that said, "Dogs prohibited beyond this point
• to protect the bighorn sheep." The CVHC supported this decision by banning dogs from all their club hikes.
One such sign can be found after climbing about 400 feet on the Garsten Trail in Palm Springs. Although
• anecdotal, in four years I never saw a dog walker turn around once he/she encounters the sign on their way
up. All my queries obtained the same general responses: "...been walking my dog up here for years,there
• aren't any sheep here,"or"...who is going to stop me?." Despite three signs at the parking lot to the Art
Smith Trail,dog walkers continue to ignore them as we witnessed on Wednesday and Saturday of the 2"d
• week of October 2004. The dog walking public doesn't appear to believe in or respect the message contained
in the signs. This is a failed program.
•
•
• 34
•
•
•
•
•
(4)How did the Plan arrive at a maximum of 3,800 users? The BLM estimated actual total trail use
• at 3,974 in the period 2001-2003, based upon a 10 hour day(see Appendix J-10,Table 7). That is,
an estimated 3,974 trail users were non-compliant. They elected to use the trails despite a sheep
• ambassador and signs posted asking them not to use the trails. Could the 3,800 have come from the
• estimated number of non-compliant trail users?
• (5)How did CVAG arrive at January 15 to June 30t', for the seasonal trail program? It would
• appear those dates were selected to cover the lambing season. The dates should be changed to
• February 1st through April 30th because 87% of lambs are born during this time frame(BLM 2003).
• Lastly,we think it useful to look at the bighorn sheep population data to date and trace a possible future
• scenario on sheep population under CVAG's proposed permit system that would ration trail usage.
• Included are CVHC's conclusions drawn from the data and likely future conclusions drawn by CVAG.
AScenario:Rationing Trail Usage and Installing a Permit System
• 1. From 1997 through 2000,there was unlimited access to all trails in the Santa Rosa Mountains, yet the
Peninsular bighorn sheep increased their numbers each of these four years.
Our Conclusion: trail usage does not negatively affect sheep population
• thus there is no evidence or logic for rationing trail usage
•
• 2. From 2001 through 2004, voluntary trail closures for eight trails in the Santa Rosa Mountains
• resulted in some reduced trail usage, yet the Peninsular bighorn sheep increased their number each of the
three years.
• Our Conclusion: trail usage does not negatively affect sheep population
• thus there is no evidence or logic for rationing trail usage
• 3. Given the increased rainfall this year, it is likely that 2005 will be the ninth straight year of recovery
• for the Peninsular bighorn sheep in the Santa Rosa Mountains with little to no restrictions on trail use.
•
• Our Conclusion: trail usage does not negatively iyely affect sheep population
• thus there is no evidence or logic for rationing trail usage
• 4. The earliest year to ration trail usage by issuing permits under CVAG's Preferred Alternative will be
• 2006.
(a) If 2006 is the tenth straight year of Peninsular bighorn sheep recovery in the Santa Rosas:
Our Conclusion: trail usage does not negatively affect sheep population
• thus there is no evidence or logic for rationing trail usage
CVAG's Conclusion: the trail rationing plan we put in place is working,
• so continue to ration usage in the future.
i
•
• 35
•
•
•
•
• (b)If 2006 is the first time in ten years the bighorn sheep population does not increase:
• Our Conclusion: this being the first year out of ten that the sheep
• population has not increased, look at the widely accepted causal factor of disease.
• predation and climatic factors (temperature and precipitation)
+ CVAG's Conclusion: trail usage negatively affects sheep population, so
ration trail usage even more in the future and limit the number of permits even more
•
•
•
• In other words, from CVAG's perspective (the adopted "belief system") no matter what happens
• to the population of bighorns, the permit system could appear to be working and no changes will
be forthcoming. If the sheep population increases, the permit system stays in place; if the sheep
• population decreases,the permit system stays in place. This presents a Catch-22. Once a limited
• permit system begins, trail users will not be able to exonerate themselves from having no impact
• upon the population of bighorn sheep.
•
We have tried to illustrate that a public policy decision to ration trail use gives the impression of taking
• positive action on behalf of the endangered bighorn sheep. Ironically,this action likely masks the other
• changes taking place which allow the sheep population to recover.
• What's Wrong with CVAG's Quota Permitting Plan can be Summarized as Follows:
➢ It's unnecessary
Bighorn sheep are increasing, not declining
• More sheep and more hikers are getting along fine
Permitting plan has no support of"best available science"
➢ It's unworkable
Imagine the outcry: "Who gets a permit? Where do I get one?
• Why are they closed today? The office is too far away! I didn't
• know you needed a permit! There aren't any more left? Seven out
• of ten people won't get permits! But, I'm just here for the weekend."
•
• ➢ It's unenforceable
• No monies to hire trail deputies
Too many trails to cover for trail deputies
• Public won't buy into program
•
• ➢ It's discriminatory
• Favors residents over tourist
Favors organized groups over the individual
• Favors long range planners over"it's a pretty day, let's go hiking
• 36
•
•
•
•
i
•
• ➢ It's the wrong type of permit
• Quota permitting restricts and rations trail access
Quota permitting provides no detailed trail data
•
• ➢ It's forever once in place
• There is no return once we start down the permitting road
Getting bureaucrats to change course is highly unlikely
• ➢ It will lack public support
• Plan has no science to support it.
Encourages people to leave existing clubs that honor permitting system
• People learn sheep in recovery,plan unjust, inequitable & unnecessary
•
• ➢ It provides no new information
We don't learn who uses trails,how often,what size group,what time of
• day, or for what portion of the total length of the trail.
•
➢ It prevents trails users from being adjudicated "not guilty"
If sheep continue to recover, rationing is working, keep it up
• If sheep numbers dip, not rationing enough, restrict access even more
At present, the main problem is that we have no statistical valid trail-use data. The data we have are
• guesstimates. We need to gather trail-use data and undertake research on trails within sheep habitat.
• The permit system of seven trails as proposed by CVAG is unworkable, no matter what number of
• permits would be issued, no matter what standard of rationing was agreed upon, no matter what
• means of distributing permits was utilized. The system would simply collapse under the weight of
bureaucratic entanglements.
•
• Since the proposal of 2,300 individual permits and 50 group permits will not be adequate and will
• frustrate the public participants of our valley, and since the Peninsular bighorn sheep have been
recovering for seven years, and since we are not sure how many people want to use the seven
designated trails, we recommend that, at this time,no limit be set on the number of trail users.
• It is important to remind ourselves that a trail-user taking out a permit at the trailhead does not mean,
• automatically,that he or she intends to walk the entire distance of the trail. For example,the Art
Smith Trail climbs more than 1200 feet in elevation gain within its eight miles. Only a fraction of
• permit holders will walk the 16-miles round trip of this trail. Most likely, the majority of users will
• turn around and return to the trailhead before they reach the half way point. So, we cannot assume
• that permit usage means full trail usage. In other words, there will be far fewer miles of trail used
• than the number of permits issued would imply.
Finally, and most important, without comprehensive trail data, no type of trail rationing will clarify the
fact or fallacy of the trail users' role in the diminishment or recovery of the bighorn sheep population.
•
• 37
•
•
•
•
•
The Case of The Clara Burgess Trail
• The Clara Burgess Trail doesn't qualify for season restrictions because it does not meet the criterion
of intersecting a lambing area. The Clara Burgess Trail in the Santa Rosa Mountains is included as
! part of the "seasonal trail area." Furthermore,this trail is one of seven trails covered by the
proposed"trail permit program."This program seeks to restrict trail use during the lambing season.
However,the Palms Hills Project's team of five field biologists successfully refuted claims by the
CDFG and the Bighorn Institute that sheep currently inhabit the project area or have utilized this
• area in recent years.
! The prime area in question consists in and around Eagle Canyon. If no ewe groups exist in this
• area, then,this Palm Springs development project apparently does not conflict with the species
! conservation goals and objectives pertaining to Peninsular Bighorn sheep as spelling out in(9-279-
! 280). But if no ewe groups exist in this area then the Clara Burgess Trail should not be included in
the seasonal trail area and not subject to the trail permit program. On the other hand, if the claims by
• the Palms Hills Project are incorrect and if ewe groups do exist in the Eagle Canyon area, then,
• rationale for placing the Clara Burgess Trail in the seasonal trail program appears supported.
. However, now the Palms Hill Project would be in conflict with species conservation goals and
• objectives pertaining to Peninsular Bighorn sheep outlined in the Plan (9-279-280). A major
inconsistency exits somewhere. Apparently, it is now settled that there cannot be both a permitted
Clara Burgess and a Palms Hill Project:
"CDFG correspondence dated February 13, 2001 from Deputy Director Terry M.
• Mansfield, Wildlife and Inland Fisheries Division, acknowledged that the CDFG
has no scientific data recording of Peninsular Bighorn Sheep ever using the Palm
• Hills site." (The Keith Companies, June 2003, section II, pg 15).
•
• Also, Jim DeForge, Executive Director of the Bighorn Institute, stated in interviews in 1994 and
1999 that the bighorn sheep were rarely seen in the Eagle Canyon area(Cornett, 1999, p.26)
• Additionally,the BLM stated, "Data from USFWS (2000) show few observations made of bighorn
• sheep in the Murray Hill area...Given the level of reported use of Murray Hill area by bighorn
! sheep, the impacts from people using these facilities would likely be minimal." (BLM, 2002, ch. 4,
! page 1. It is necessary,therefore, to totally remove restrictions to access of the Clara Burgess Trail.
•
!
•
!
!
•
!
•
•
!
! 38
!
•
•
•
•
•
• II. CVHC ALTERNATIVE PROPOSAL---Unlimited Trail Access with Research Oriented Permit
System on Two Trails: the Art Smith Trail and the Skyline Trail Proposed by the CVHC as the
. Preferred Compromise.
• Since the bighorn sheep are in recovery, since the best available science concludes trails users don't
• adversely affect bighorn sheep, and since no valid data currently exist on trail use, the sole
• alternative is to allow the public unlimited access to the trails in the Plan area. That is, we must end
• the voluntary trail avoidance program and scrap the proposed quota permitting program.
• A research oriented permit system would place permit boxes at two trailheads, the Art Smith and
. Skyline Trails. These research permits could gather the currently missing data. Imagine permit
• boxes being posted at trailheads, similar to the Forest Service procedure at the top of the Tram. The
only requirement for using the trail would be to fill out a permit detailing name, city of residence,
• type of user, number of people,portion of trail to be used(1, 3, 5 or 10 miles), date, and time of day.
• The original would go into trail box and the copy kept with the user until he or she returned.
• For example, on the Art Smith(i.e., sample permit on next page), users could list less than one mile,
• one to three,three to five, or five to eight miles. By issuing permits to all users, all trails could be
• monitored for actual usage. With this data,the Trails Management Subcommittee could evaluate the
• actual usage patterns on a monthly basis and determine whether to continue the unfettered program
• as is, or to snake restrictive adjustments on a trails-specific basis.
• The Skyline and Art Smith Trails would be placed under the research-oriented permit system
• because these trails can be monitored with the greatest ease. Once each day, the trailhead boxes
• would be checked for operable pens, replacement packets of permits, and the picking up of permits
from inside the box. A trailhead box can be placed at the end of the parking lot for Art Smith Trail
• and serviced by volunteers at the Santa Rosa and San Jacinto National Monument Visitors Center
• across the highway from the trailhead. A trailhead box could be placed above the Palm Springs
• Desert Museum parking lot at the trailhead for the Skyline Trail. Once a week, during January,
• February and March, a trail monitor would ask to see each trail user permit. This monitoring would
provide control data on compliance rates and accuracy of data on the permit form*
•
• This alternative will be supported by trail user groups. Most importantly, this alternative will
• generate an array of data soon, rather than years down the road. This data will allow a trail specific
analysis. The earliest date for the start of the research oriented trail permitting program is 2005 and
• could be 2006. It is possible that by then, bighorn sheep will have been proven to be in recovery for
• ten years. This alternative does not result in immediate reduction of the public good. It is not
• punitive. It allows for trails-use while the bighorn are in recovery.
•
• ----------
*The CVHC could supply volunteers to service the Skyline Trailhead and provide trail monitors for weekly
sampling of permit compliance.
•
•
•
•
• 39
•
•
•
•
•
•
• This alternative should be in place for a minimum of two years. After the second year, an evaluation
• can be made whether to continue as is or to modify. If a dramatic decline in the sheep population
• took place in a particular area due to disease, climatic factors or predation,then trail specific changes
could take place. But with continued sheep recovery and unlimited trail access, this alternative
• would set up the circumstance where trail users could at least potentially exonerate themselves from
• their implied guilt as adversely affecting bighorn sheep, something CVAG's Preferred Alternative
• does not allow.*
•
•
•
•
•
•
•
•
•
•
•
•
•
* The Cathedral Canyon and North Lykken Trails usage is much lower than all other trails (see
Table 4). There is no need to enroll these trails in a research oriented permit system because their
• use levels are so low. However,these trails would be available for individual research projects.
•
•
•
•
•
•
•
•
•
•
•
•
•
• 40
•
•
•
•
•
•
•
• Figure 4: Sample Day Use Permit: Museum/Skyline Trail
•
•
• Day Use Permit: Museum/Skyline Trail
•
• Santa Rosa and San Jacinto Mountains
• National Monument Visitor Center
• (760) 862-9984
•
• Name Time
City State
• Date of Entry No. of people
•
Type of User: hiker_ runner_walker_other
•
• Round trip distance you expect to travel on the trail today:
Picnic tables and return warning sign_4500 ft level and return
Aerial tramway_ San Jacinto Peak_ 4 miles_ 6 miles 8 miles_
•
• Organization:
• - (10 or more trail users)
•
•
• Place original in the brown box and carry copy with you.
• Upon your return put copy in the silver mail box.
•
•
•
•
•
•
•
• 41
•
•
•
•
•
•
•
•
• Figure 5: Sample Day Use Permit: Art Smith Trail
•
•
• Day Use Permit: Art Smith Trail
•
• Santa Rosa and San Jacinto Mountains
• National Monument Visitor Center
• (760) 862-9984
•
•
• Name time
City state
• Date of Entry No of people
• Type of User: hiker horseback mt. bike runner walker
• Round trip distance you expect to travel on the trail today:
1 mile 2 miles_ 4 miles_ 8 miles 16 miles
• Organization:
• (10 or more trail users)
•
•
• Place original in the brown box and carry copy with you.
• Upon your return put copy in the silver mail box.
•
•
•
•
•
•
•
•
•
•
• 42
•
•
•
•
•
• 5. San Jacinto Mountains: A Special Case
Of the nine recovery regions delineated by the Recovery Plan 2000,the San Jacinto Mountains
stands out as a special case. The size of its herd was small but stable throughout the 1980's and
• 1990's. The population estimates for this twenty year period fluctuated between the high teens to
• the mid-twenties. In the past five years,this population has experience some success. By 2004, this
• population was estimated to be 32 adult bighorn or 60% above the average size of 20 for the 1990's.
The year 2004 total of 32 sheep is the highest number in twenty years, but this sub-population still
• remains small.
•
• Why has this region not shared the same level of success in bighorn recovery as the other eight? The
• scientific literature contains no clear answers. Some experts think it is too isolated and cut off by
urban development. Others suggest the small size of this sub-population is too vulnerable to
• predation. Still others point out that, in the past, efforts to augment and increase the size of this sub-
group have proved unsuccessful.
• The Trail Plans affects and restricts access to two trails in the San Jacinto Mountains and 14 trails in
• the Santa Rosa Mountains (see Table 8). Put another way, 12% of affected trails reside in the San
• Jacinto Mountains and 88%reside in the Santa Rosa Mountains.
• The Trails Plan targets two trails in the San Jacinto Mountains for rationing,North Lykken and
• Skyline Trails. The San Jacinto Mountains contain four of the Coachella Valley's thirty public
• trails: South Lykken,North Lykken, Museum Trail and Skyline Trail (see Table 9). All but the
• Skyline are rather low elevation trails that traverse the San Jacinto Range. The Skyline Trail begins
• at about 1,000 ft and travels eight miles up to the Tram at about 8,000 ft. Thus,the San Jacinto
Mountains has but one trail that travels up into and through bighorn habitat. By contrast,the Santa
• Rosa Mountain contains many such trails.
By any standard, the North Lykken Trail gets little use. The Skyline Trail is popular for some
months of the year,namely October and November in the fall and April, May and June in the spring.
• Because the lower portion of this trail is too hot in July, August, and September, the Skyline gets
• few takers during the summer months. Typically, snow covers the upper portions of the trail in
• December, January, February, and March, so that hikers, runners and fitness types don't attempt the
• arduous climb during these months. That is to say, during key months of the lambing season this
trail gets little to no use. That was the history of this trail before anyone proposed permits and it
• will be the history in the future, permits or no permits. The point is that if permits are for the
• purpose of restricting trial-use during lambing season, the weather has been restricting Skyline use
• for years during lambing season and this hasn't help augment the sub-population in the region.
Could it be that disease and predation do not take time off?
•
• Unlike almost any other trail in the valley,the Skyline Trail is not an"up and back" trail.
• That is, one doesn't typically climb to 4500 feet turn around and come back down. Why? Because
• most trail-users avoid the knee-pounding from turning around at 4500 and taking the steep climb
back down. Hikers start out at the Museum intending to hike the full 10 miles and 8,000 ft to the
• Tram.
•
•
•
• 43
•
•
•
•
• In summary, restricting trail access is unnecessary in the San Jacinto Mountains because trail users
. do not adversely affect the bighorn, because winter weather already restricts access to the Skyline
Trail during lambing season, and because the North Lykken Trail has few takers any time of the
• year.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• 44
•
•
•
•
•
• 6. Trail Rerouting,Decommission and Removal (7-60-64)
• It appears that the trail rerouting proposal awaits data availability on bighorn habitat use patterns,
• home range and distribution. On the other hand, trail rerouting could proceed on a case by case
• basis in the absence of data. However,the Plan doesn't indicate who will generate such data and
• when such data collection will begin. Also, to what extent is trail rerouting primarily part of the
• perimeter trails program?
• Unfortunately, it is a net loss for the public good when trails are removed before new trails come on
• line. The Plan suggests a possible nine-year lag for new trail completion. A greater loss for the
• public good will result if the new trails never come on line. Funding problems could result in delays
or cancellation for new trails construction. Currently, according to media reports, the budgets for all
• levels of government look grim. Also, the inability to obtain private land or easements could
• prevent new construction. Wisely, old bridges spanning rivers are not torn down until new ones are
• constructed. Likewise, the trails are our public bridges to the natural environment.
• The success of the seasonal use program seems more promising if other trails are not removed until
• new trails are completed. However, if trail removal starts with a lag of nine year or more before new
• trails are opened,the seasonal trail use program might lose credibility to the public.
• At this point, the Plan's criteria for trail decommission and trail removals are quite open ended. It
• describes the trails to be pinpointed as (a) redundant trails and(b)trails supporting recreational use
• where disturbance to sensitive resource values should be avoided. Redundant trails are defined as
• "those serving the same or similar purpose as other trails"and "providing the same or similar
recreation experience."This definition might apply to a wide range of existing trails that appear in
• no sense redundant. The phrases "connecting the same two points" and "secondary or tertiary
• braided trails and trail shortcuts"more accurately define a redundant trail. The second criterion(b)
• assumes a link between trail usage and population levels of sheep that so far has not been
• established. Thus,this criterion will be operational only if clear links are found.
• According to the Plan, trail rerouting, trail decommission and trail removal take place in part to
• reduce or eliminate adverse impacts to resource value (i.e., sheep) or where there is disturbance to
• sensitive resource values (i.e., sheep). The Plan authors propose to undertake research to determine
what effect, if any, takes place due to trail use. (see ES -27). To date, no finished research has
• verified adverse effects due to trail use. Only after completing such study and with results that
• clearly demonstrate trail users adversely affect bighorn sheep should policies and guidelines to
• regulate public access be put in place.
• Do the trails listed for decommission and removals on page 7-63-64 satisfy criterion (a) and (b) or
• only(a), or only(b)? Also, would you please review the above definition of these criteria?
Case Study: The Mirage Trail
The Mirage Trail,known affectionately by many users as the `Bump and Grind", is targeted by the
• PLAN to be shortened as the upper portion is scheduled for trail decommission and removal
• (EIS/EIR 5-47). This trail is one of the most unique trails in the valley. Why? Because the Mirage
• Trail isn't a hiking trail used by hikers. It's an exercise trail used by valley residents who seek a
•
• 45
•
•
•
•
•
•
• demanding outdoor workout. It's a one of the kind in the valley. It's a jewel for the city of Rancho
• Mirage. No other trail in the valley experiences the volume of people who come daily for just plain
exercise. Literally,hundreds of people a day sometimes use this trail. Just ask residents who live
• near the trailhead. Why? Its location. It's centrally located mid-valley and right next to Highway
• 111. It fits the requirements of exercise enthusiasts with approximately 1000 feet of gain over the
• approximately two-mile road/trail. The climb up generates a solid 40 to 60 minutes of aerobic and
• physical workout for all. The descent can be completed in less or about the same time.
• Women seem to prefer this trail as they feel safer with the knowledge that other people are to be
• found using the trail at all hours. Valley residents can get a terrific workout in 1.5 his and then go
i about their regular business. Removing approximately the top 300 feet and %miles will
significantly alter this trail and make it much less attractive to users. This would mean a net loss of
the public good. The proposed connecting perimeter trail(Hopalong Cassidy Trail)won't be
• attractive to current users because it does not offer the same elevation gain and will take them away
i from their starting position.
• The sad fact is there isn't a single scientific reason to restrict it. People go to the top and come down.
They don't go to the top and wander off into Magnesia Canyon or into the mountains. One can see
i at the trailhead how people are dressed and equipped. Most likely, they have a fanny pack with a
• bottle of water,rather than gear for a ten or twelve mile day hike. Put a monitor at the top and check
this out. We believe the data gathered will confirm our claim.
•
Why not decommission and remove the"numerous unauthorized trails that take off from the flat
. overlook at the top of the Mirage Trail."? Apparently this approach has been taken in the Coral Reef
• Mountain area(page 5-48). Or put a fence at the top blocking access to proceed further into the
mountains? Put signage on the fence asking people not to venture beyond this point. These exercise
enthusiasts are not interested in day hiking for another two or four hours;they want to gent to work or
i on with other obligations.
i The purported problems at the top of the Mirage trail presented on page 5-47 of the EIS/EIR simply
i do not exist. No evidence was offered to support these concerns. The trail doesn't intersect a
i lambing area. There isn't a ewe group home range close to this trail. The trail satisfies the 6/10 of a
i mile criterion adopted by the EIS/EIR for the Palm Desert to La Quinta connector trail. Also,the
• discussion on page 5-21 is erroneous: "...The upper segment of the Mirage Trail leads to a flat
overlook, overlooking sensitive lamb rearing habitat in Magnesia Canyon." The overlook is so far
• away one would need binoculars and even then you cannot see into Magnesia Canyon. Using
i (MacArthur 1979) this as an example of"hikers"being above sheep and corresponding sheep
i cardiac response is not valid. MacArthur didn't study trail users, he studied cross county
researcher/observers who directly stalked sheep. In addition, if the authors choose to cite
i (MacArthur 1979), they must also include(Papouchis 2001). Papouchis used exactly the same
i methodology as MacArthur and came up with totally different findings. That is, sheep approached
• directly showed a greater response than sheep approached from above. However, the problem not
discussed--probably because it had nothing to do with bighorn sheep—is that of parking at or near
i the trailhead. Currently,the City of Rancho Mirage is working to address the parking problem.
•
s
•
• 46
i
•
•
•
•
•
Finally, again we find contradiction in the reasoning and decision making. The CDFG supposedly
• wants to take away the top portion of the`Bump and Grind' because it lies in the Magnesia Springs
• Ecological Preserve. But then,the CDFG gave its approval of a new perimeter trail to be built
straight into the Magnesia Springs Ecological Preserve and to connect with the "Bump and Grind" at
• a lower level, still in the Preserve.
The Trails Management Subcommittee needs to receive trail maps identifying lambing, rearing and
watering areas of bighorn sheep. This will allow the TMS to evaluate proposals for trail rerouting,
• decommission and removal with the best available data. Then,they can make sure the proposal for
new trails is compatible with the ongoing recovery of the Peninsular bighorn sheep.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
47
•
•
•
•
•
•
• 7. Perimeter Trails and New Trails Program (7-60-62)
• Trail users welcome the addition of new trails in the Coachella Valley. What we look forward to is a
• statement of philosophy or intent for creating new trails. For example,the USFWS 2000 contains a
clear statement:
• New trails in bighorn habitat should be avoided, except in select areas along the urban edge,
• where they provide two benefits—alleviate pressures on trail that intrude deeper into sheep
habitat, and provide a disturbance barrier to discourage potential sheep attraction to urban
• sources of food and water. " (p. 88-89).
• Does the preceding statement describe CVAG's philosophy for new trails?
• Re: Perimeter Trails. Why is there no stated purpose in the Plan for the building of perimeter trails? Are
• these trails designed for people to walk their dogs at an elevation level that will not impact the sheep? Are
• these walking trails, a move to provide expanded opportunity to those who prefer walking to hiking? Are
• the perimeter trails meant to augment the existing trails system to accommodate increasing numbers of
valley residents and visitors? Are they meant to create a buffer zone below the 700 feet level, i.e.,the
• beginning of the sheep habitat area? How does this correspond to the urban interface elevation at the
• northern and southern ends of the Coachella Valley? Is there a danger that new perimeter trails--with 200
• to 400 feet elevation gain and low-quality vistas--could ever count as substitutes for existing moderate to
• strenuous trails with up to 1000 feet of elevation gain and spectacular panoramic views of the Coachella
Valley and surrounding mountains?If so,this perimeter trails program is a great loss to the public good.
•
•
• Re:New Trails. The new trails program includes a proposal for making a connector trail from the
Palm Desert Visitors Center to La Quinta. A portion of this trail would pass close to the Bighorn
• Institute and within sight of their captive breeding recovery center. In late 2003, The Bighorn
• Institute informed CVAG of their opposition to the proposed trail and requested an alternative route.
• that would not compromise the work of the Institute. The Coachella Valley Hiking Club believes in
• and supports the research and conservation work of the Bighorn Institute. The BI is the key local
organization in the battle to rebuild the population of Peninsular bighorn sheep in the Plan area.
• Therefore, we oppose the construction of this new trail and join the Bighorn Institute in asking
• CVAG to fmd an alternative route. We urge CVAG to work together with the Bighorn Institute to
• develop an alternative segment of the proposed trail that would not interfere with the work of the
Institute.
•
• The EIR/EIS contains a 13-page presentation of their case for the Palm Desert Visitor Center to La
• Qunita Connector Trail. The authors make their case through the use of conditional reasoning
• (MAY)that permeates the entire trails plan presentation. For example, "increased human activity
(near the Bighorn Institute's captive sheep pens) MAY NOT disturb them(captive sheep) as much
• as it would wild sheep populations." (EIS/EIR 5-33) This is making your case not by presenting
• empirical evidence or marshalling a theoretical arginnent but simply putting forth an assumption or
• conditional statement. The persuasive power of such an approach is about zero within the scientific
community.
•
•
•
•
48
•
•
•
•
• Also, CVAG produced a map showing the breeding pens for captive sheep at 6/10 of a mile away
• from the connector trail and, thus, no problem. If that is the case, then the Bump and Grind being
1.2 miles away from Magnesia Canyon, and Murray Peak being 1.2 miles away from Eagle Canyon,
• cannot be the problem that trails plan authors claim. Here again, is contradiction within the Plan.
Finally, the authors cite Papouchi 2001 as the source for their standard--that the connector trail be
200 meters away from lamb rearing habitat—and, thus, not adversely affecting the captive sheep. If
• one applied this same standard to the trails targeted for permitting and voluntary avoidance, I believe
• most if not all the trails would not qualify for rationing. But there is an additional problem.
• Papouchis 2001 puts forth no such standard in that study. One can only speculate how the authors
came up with that standard from the Papouchis study. It appears the authors looked at Table 5 and
• saw that the average distance sheep fled from cross country hikers walking directly towards them
• was just less than 200 meters. Thus, the authors may have reasoned, if hikers were at least 200
• meters away from sheep, no disturbance would take place. Also, Table 7 showed that sheep more
• than 200 meters from a road didn't flee when a vehicle or mountain biker passed on the road, but the
sheep were"alerted." For a more complete description of the Papouchis 2001 study, see page 64 of
• this response.
Which way do the authors choose to proceed? Adopting the 200-meter standard frees them from
accusations that the corrector trail will disturb and adversely affect captive sheep in the pens at the
• Bighorn Institute. But, also, adopting the 200-meter standard will scuttle the trails rationing
• approach of the trails plan since most trails can comply with the 200-meter standard.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• 49
•
•
•
•
•
8. Trail Monitoring and Enforcement Program ES 30-33 and 8-81
• We urge the CVAG to include details for the proposed trail monitoring and enforcement program.
• The Plan states, "The monitoring program will address permit compliance and levels of use." Where
• is the"statistically valid protocol' described? Who will do the monitoring and who will be the
• employer? How many person-hours will be involved on an annual basis, and what will the program
• cost on an annual basis? Also,the Plan states that trail monitoring will allow a"trail specific
approach." Samples of each trail could be drawn to determine daily use by type of users, by day of
• the week, and by distance traveled on the trail. With this information, all trails could be ranked.
•
• To build a budget for the enforcement program,the Plan must estimate the number of full-time
employees needed. What is the cost implication? Will citations be issued to those using trails
• without permits? If issued, would citations include a monetary penalty or a warning only? What
• feature in the enforcement program will most likely insure its success given the Plan specifies that
• the trails can be closed for noncompliance?
What are the cost implications for city governments? Will there be new administrative costs for
• them? Will the cities need to hire employees to administer any aspects of the proposed trails plan?
We assume that dogs will be restricted to trails below the lower levels of the sheep habitat. Thus,
perimeter trails, or at least some of them, would be dog-friendly. Can we assume the enforcement
• program will be responsible for keeping dogs off all other trails?
•
• The paragraph Section 8.4.7.1.2 on page(8-81) needs clarity. It reads, "...approved public uses will
be monitored to ensure that compliance with any conditions is achieved, and the use does not result
• in significant adverse impacts over time." What"approved public uses" are implied here? What are
• "any conditions" or examples of"significant adverse impacts over time"? The next sentence refers
• to "specific recreational issues". How would the issue of"cross country travel'be monitored?
• What is the issue with the Murray Hill Facilities? On Murray Hill there are two square picnic tables
and a horse-tie. Does the word "facilities" suit this Spartan arrangement? What is the issue with
• "organized group activities?"
•
•
•
•
•
•
•
•
•
•
•
•
•
• 50
•
•
•
•
•
• 9. The Research Program: Effects of Recreational Trail Use on Bighorn Sheep
• Until about the late 1970s, research on the recreational impacts on wildlife has been mostly
• unscientific. Mainly, it has consisted of personal conjecture fortified occasionally by personal
• observation. Often, evidence was only anecdotal. Some publications offered no evidence and only
• emotionally charged advocacy. See, for example, Tevis 1959 and 1961. Research from the 1980s to
• the present has been more evidentiary based, analytical and rigorous, often subjecting data to an
array of statistical tests on hypotheses. Thus, one must be aware that citing pre-1980 studies may
• offer little or no scientific evidence.
In its review article of 1985, 'Effects of Nonconsumptive Recreation on Wildlife: A Review,"Bolye
and Sampson concluded"much of the current information on recreation effects on wildlife consists
• of casual observations or reported incidents of disturbance or mortality, without quantitative
• assessments of long-term ecological effects." Unfortunately, this highly personal, anecdotal
• reporting passes as research and that orientation continues into the present. In introducing the 2003
Draft Volume 5: Backcountry Recreation Impacts to Wildlife: An annotated Reading List, editor
• Vita Wright, stated:
• While researching this topic, we noted several information gaps in the existing
• literature. The vast majority of research has reported short-term responses of
• individual animals to recreation activities and used this information to project
potential impacts to the whole wildlife population or communities...we are unaware
• of any study that has collected extensive data over several years to provide a true
• estimate ofpotential impacts to population rates of change.
That is, researchers are not formulating testable hypothesis, setting up experimental frameworks,
gathering and/or analyzing time series data.
•
• The Plan's research program merits just two pages in section 8.5.1 of the December 1, 2003 draft
• Plan. But in the October 2004 draft, the Plan's research program merited only a sentence or so. It is
• not clear that the Plan's research will rise above the shortcomings outlined in the preceding
paragraph by Bolye and Sampson and Vita Wright. Is there a policy agenda driving the research?
• Shouldn't the research drive a policy agenda? What assumptions in the research are explicit?
Will research questions progress as a sequence? If so,how ? For example, "does passive recreation
disturb bighorn sheep?" Then, what would"disturbance" look like if encountered? Presumably,
• various forms of disturbance could be identified along with implications. One could separate
• minimal disturbance from moderate disturbance and from extreme disturbance. Why is the key term
• "disturbance"not defined in the Plan?
• The negative connotation of the word "disturbance" suggests the activity must cease. To use the
• term "human disturbance"rather than "human impact" implies one knows that humans on trails
• adversely impact the sheep and must be stopped.* Shouldn't the research determine if and how
• humans affect the population levels of the bighorn sheep? Please identify relevant studies for us, if
such studies have been done for the Plan area.
• ---------------------
*The most recent survey of the literature on bighorn sheep utilizes the category"human impacts."
• (Eaton-Gonzales and Martinez-Allardo, 2001)
•
•
• 51
•
•
•
!
! In the final"Trails Plan", word usage will guide Coachella Valley conservation measures for
• decades to come. It is essential to review the language. For example, these phrases seem to be used
! as synonyms, but are not neutral with respect to each other: effects of recreation, effects of
recreational disturbance, effects of human disturbance, effects of trail usage, effects of hikers.
• photographers, and effects of passive recreation. Is "proximate response"the same as "immediate
• behavioral response"?
• In the December 1, 2003 draft Plan,the authors offer a disclaimer, "It is unlikely that there are clear,
! black and white answers. There are many existing perturbations in the environment and there may be
• many confounding factors as well." This makes sense. For the reader, it would be useful for the
authors to describe the complexities. Are sheep reactions to humans difficult to observe and
• measure in the wild? Is it possible that existing research has not found a correlation, let alone
causation,between recreation trail use and population trends in bighorn sheep? Does the Plan take
! its stance from the assumption that no future research will find a link? Are shifts in bighorn sheep
. population a multi-faceted and interactive problem? How many different possible causal factors can
• be identified? Is it possible that benign humans in the wild are not in the equation? Is it difficult to
separate the causal factor for humans and most importantly, the power of the human factor within
! any regression equation?
•
• In a perfect world, how would one seek answers to these questions? In your opinion, what is the
most effective, reasonable option--personal observation, controlled experimentation, computer
• simulation, or electronic monitoring? What are other possibilities?
•
Finally, the broader, critical question is raised and answered: "what effect does recreation have on
! bighorn sheep population dynamics can be inferred from modeling exercises, using empirical data
collected to answer questions related to proximate response." Which modeling exercises? How can
• the effect be inferred without reference to the kind of multi-variable models of section 9.8.4.2? How
! does the research outlined in section 8.5.1 establish a link between recreational trail use and
• population of bighorn sheep? The single variable approach in this section will provide little, if any
power of explanation. How is it valid to hold all other variables constant, (the"everything else"
• being equal assumption) while varying the variable of"human disturbance?"
•
• In our view,the basic questions seem to provide little assistance to policy makers. Essentially the
• inquiry was reduced to one or more of the following `yes or no' questions:
1. Do trail users impact sheep?
• 2. Do trail users affect sheep?
• 3. How do sheep react to trail users?
• 4. Do sheep respond to trail users?
!
!
•
•
!
•
•
• 52
•
•
•
•
•
• Mostly the terms impacts, effects, and response are defined in terms of stress.* That is, "trail users
• cause stress in sheep". For a moment, let's consider one of the most stressful situations encountered
• by bighorn sheep. The Bureau of Land Management explained:
Capture of wild ungulates causes intense, short-term stress to the animal. Heart rate, body
• temperature, energy expenditure, hormone levels, and blood pressure have all been shown to
elevate under stress --- typically,population surveys are conducted via helicopters. The
aircraft must be close enough to the animals for the observers to determine sex and age. This
• is closer than the 100 meters suggested. (so as to not adversely affect the sheep) —Although
• capture indisputably does cause stress and habitat displacement to bighorn sheep, most
• captured and collared sheep appear to have few, if any, longterm effects from the capture.
Sheep generally resume normal feeding, movement, activity patterns, and social status within a
• few days of helicopter surveys and capture. (BLM Decision Record 2000, p. 11)
Relative to capture by helicopter, how much stress would a trail-user likely impart to the bighorn? If
the above capture experience has no long term effect on the bighorns,why would one assume there
• might be such effects from trail-users?
The four questions posed earlier get ayes and/or no answer,but we are still left with the crux of the
matter; simply stated:
• -Is the sheep population inversely related to trail usage?
• -Does trail usage cause the sheep population to decline?
-Does trail usage slow the recovery of the sheep population?
That is, in the regression equation explaining the rise and fall of the bighorn sheep population, is
• trail-usage a causal variable?
•
• Finally, and most importantly, because the Plan presents no population data, the Plan wasn't able to
• present and analyze the recovery in the sheep population over the past eight years. It focuses upon
"human disturbance" and the potential adverse effects of trail users upon sheep population when it
• should be asking: What happened? What has changed to cause the number of sheep to increase
every year since 1996? Why has the six-month recruitment rate in the Santa Rosa Mountains been
nearly 50 on average for a decade?
• * James DeForge, Executive Director of the Bighorn Institute in Palm Desert California,played a key
• role in propagating the notion that bighorn sheep suffered stress as a result of their contact with
• humans. This htmian produced stress can lead to greater susceptibility to disease and possible death.
• See Deforge, 1972, 1976, 1981, and 1982. It took about twenty years to discredit the use of this
term/concept that had spread its way throughout wildlife literature, government agencies, field
• managers and wildlife biologists. A 1992 panel discussion at the 36t" annual meeting of Desert
• Bighorn Council found no agreement on a definition of the term "stress". They were troubled by
• proposals to reduce"stress"without an accepted definition, found its use arbitrary, found researchers
• mixing up correlation with causation, and suggested the word"stimulus" would serve just as well.
One panelist summarized, `Everybody knows what it is and nobody knows what it is." Another
• panelist stated"we should go out of here and say we don't agree on the terminology of stress, or
• maybe even the concept and where it leads,but is it beneficial to bighorn sheep in general, or is it not
• beneficial." (Panel Discussion, Desert Bighorn Council Transactions,Vol. 36, 1992)
•
• 53
•
S
•
•
•
•
10. Research Question Worksheet: Trail Users and Bighorn Sheep
Question Worksheet
If a link exists between recreational trail use and population levels of bighorn sheep,what would
happen to the sheep after being in the proximity of humans?
• a) Sheep become ill after contact,
• b) Sheep do not forage after contact,
c) Sheep move to and remain in inferior habitat,
• d) Sheep neglect their young,
e) Sheep vacate lambing areas,
• 0 Sheep do not mate after contact,
• g) Sheep will not bring young to a waterhole if close to the trail.
• Has research in the Plan area documented any of the effects listed above?
Can we agree to make the following assumptions about sheep behavior?
a. When hikers traverse trails in areas of bighorn sheep,the sheep know of
• the hikers' presence within some minimum distance.
• b. Sheep move across existing trails in the normal course of their movements
• but do not typically use the trails.
c. Bighorn sheep are wilderness animals;therefore, they will seek to avoid contact with
• humans in the wild. If sheep see,hear or smell hikers approaching,would they take some
evasive action such as waiting and watching until hikers pass, climbing to higher ground to
• wait and watch, or moving in a direction opposite of the hikers? That is, by so doing they
avoid human contact. Sheep avoidance action can be reviewed in terms of a Human-
Wildlife Interactions Model presented in Table 5.
•
Table 5
A Human-Wildlife Interactions Model: Sheep Avoidance
•
Human------sheep avoidance -------(a)-action harmful (detectable/harmful)
• Sheep don't resume normal activities
Human----- sheep avoidance ------ (b) action neutral (undetectable)
• Sheep resume normal activity while taking avoidance
• action
• Human-----sheep avoidance ------- (c) action benign(detectable/harmless)
• Sheep resume normal activity after
taking avoidance action
•
•
•
•
•
• 54
•
•
•
•
•
i
A non-hiker example of(a) action harmful would be research helicopter pursuit and capture of wild
• ungulates that causes intense, short-term stress to the animals.
i "Helicopter surveys may significantly alter the movement, habitat use, and foraging
efficiency ofsheep so that survivorship or reproduction is reduced(Bleich et al. 1990,
• Bleich et al. 1994). Unlike other forms of human disturbance such as hiking, bighorn
• sheep do not become habituated or desensitized to repeated helicopter flights (Stockwell
• 1991 in Bleich et al. 1994, Bleich et. al. 1990, Harris 1992, Miller and Smith 1985)"
(BLM, 2002, Chap 4,pg 3)
• Another non-hiker example of(a) action harmful was reported by Etchberger and Krausman(1999).
• They observed the abandonment of lambing habitat while construction activities were ongoing(p. 45
• USFWS). The Bureau of Land Management has reported that"several concepts are reasonably well
i established. Dogs and helicopters can cause more severe reactions (in sheep)than other types of
activities." (BLM, "Status of Science,"no date)
• An example of(b) action neutral would be sheep proceeding up a ridge line 500 feet above a group
• of hikers in the wash below. The hikers continue to proceed along the trail and the sheep continue
up and over the ridge line. The sheep continue their normal activity while taking avoidance action.
An example of(claction benign would be sheep stopping forge activity to observe a group of distant
• hikers round a switchback across the canyon. Once the hikers are out of view, the sheep resume
their foraging activity.* The following descriptions appear to be away from hiking trails.
i "When ewes are ready to give birth they will typically seek out the most precipitous terrain,
where their lambs will presumably be safest. The presence of such steep terrain for predator
• evasion and lambing is, therefore, a crucial component of sheep habitat. "RPBS 2000 p.6—
• Also, The Bighorn Institute reports "lambing areas are comprised ofsteep, rocky terrain and
are used by ewes with lambs year after year. Being tremendously vigilant, ewes and their
• young spend much of their time in steep escape terrain within lambing areas, safe from
• predators. "
• Here's an important, definitive question: have the Plan's authors identified sections of existing trails
• targeted for the permit program that pass within 50 feet, 200 feet or 500 feet of lambing areas?
Finally, a personal anecdote may be instructive. On three occasions, in fall 2002 and spring 2003,
• we hikers approached Magnesia Falls Canyon and saw bighorn sheep beginning to head down the
canyon walls to drink at the newly established watering hole on the canyon floor. On each occasion,
i hikers immediately stopped and remained quiet, and the sheep while aware of the hikers' presence
• continued their descent for a drink. Once all the sheep had taken on water, they left by the same
i route they entered. This human/sheep interaction experience seems consistent with the latest
research on Sierra Nevada bighorn by John Wehausen(2000).
•
*Three CVHC hikes during December, 2004 encountered bighorn, one group of 12, in the Cathedral
. Canyon and Dunn Road areas that behaved in this manner.
•
i
55
i
•
•
•
•
11. Model building: Variables Affecting Population Levels of Bighorn Sheep
• Formulation# 1
•
Only three(9-202-205) of the 900 plus pages of the December 1, 2004 draft Plan are dedicated to
sketching out an elementary model for thinking about or undertaking research on population trends
in bighorn sheep. The model identifies key independent variables affecting the decline in Peninsular
• bighorn sheep. This formulation suggests the bighorn sheep population is inversely related to (1) loss
• of habitat, (2) fragmentation of habitat, (3) disease and(4)predation. Intuitively,this formulation is .
• persuasive. But, the real importance rests with the power of individual variables. For purposes of
• public policy,the key is to identify the explanatory power of each variable. Why does this clear,
important elementary model appear at the end of the long document instead of in the Executive
Sun unary or the planned research section? Why did this elementary model completely disappear
• from the October 2004 draft Plan?
• The Executive Summary of USFW Recovery Plan 2000 acknowledges urban related sources of
• mortality and suggests a more complex model for population trends in bighorn sheep. Earlier still, in
• the Federal Register,the Fish and Wildlife Service stated,
• The synergistic effects of disease; low recruitment; habitat loss, degradation and
. fragmentation; non-adaptive behavioral responses associated with residential and
commercial development; and high predation rates coinciding with low bighorn
• sheep population numbers threatens the continued existence of these animals in
• Southern California. " (U.S. Fish and Wildlife Service, 1998).
• Why did the Plan depart from the modeling groundwork of the U.S. Fish & Wildlife Service?
• A fundamental problem with the preceding formulation is that the beacon independent variable in
the Coachella Valley appears to be economic development. The U.S. Fish and Wildlife Service,the
• lead federal agency developing the recovery plan for bighorn sheep has spoken out on the role
• played by economic development:
• The U.S. Fish & Wildlife Service determined that Peninsular bighorn sheep were in
• danger of extinction throughout a significant portion of their range due to: (1) disease
• from domestic cattle; (2) insufficient lamb recruitment; (3) habitat loss degradation and
fragmentation by urban and commercial development and(4)predation coinciding with
• low population numbers.(Center for Biological Diversity)
•
• Habitat Loss
• The Plan quotes an article "Peninsular bighorn sheep" from the CVMSHCP website: "Habitat loss is
considered to be one of the greatest threats to the bighorn sheep's continued existence."
• However, the subsequent sentence from that text is not transferred to the Plan:
• As humans encroach into the habitat, the resources, and the survival potential of a
• particular ewe group that depends on them, may be eliminated. Habitat loss can
impact the sheep's ability to reproduce,find water, avoid predators, and move among
• important resource areas. "(http•www.cvmshcp.org/sp 01.htm
•
•
•
• 56
•
•
•
•
•
• The crucial lost habitat had provided lambing, rutting and feeding areas, escape terrain, water
sources and travel routes. Thus, while the Plan avoids using the words residential and commercial
development, these terms appear to be appropriate. The 2000 RPBS plan claims,
• ...at least 7,490 hectares (18,500 acres or about 30 square miles) of suitable habitat
• has been lost to urbanization and agriculture within the range of the three ewe
• groups that occur along the urban interface between Palm Springs and La Quinta. "
(page 38). "In 1997, golf courses outnumber bighorn in the Palm Springs area 91 to
• 75. Dozens of additional golf courses and developments are even now scheduled to
• destroy the bighorns dwindling habitat" (Center for Biological Diversity).
• With mapping,the Plan should demonstrate how development in the 1970s, 1980s and 1990s
has encroached upon sheep habitat in the Valley. This would help to place economic
• development into perspective relative to other variables, and possibly shed light on the
• inverse relationship between sheep population and economic development.
Habitat Fragmentation
The Plan suggests habitat fragmentation is recognized as a major threat to bighorn sheep. Again,
• this variable derives from economic development, e.g., roads, power lines, highways, dams,
• subdivisions, aerial tramways, golf courses, fences, agriculture and canals. The Plan doesn't make '
that connection clear. Instead,habitat fragmentation seems to exist without a reason. The Plan
should illustrate that bighorn sheep in the Peninsular Ranges are made up of interconnected
• subpopulations. Thus, fragmentation can sever connections between ewe groups and prevent
• movement among the subpopulation resulting in loss of cross-mating and mixing of the gene pools.
• Some observers believe that long term survival of bighorn sheep depends upon interaction among
subpopulations.
•
• Habitat Degradation
. Habitat degradation or a lowering in the quality of habitat could be a fifth variable. The Plan
• suggests the spread of tamarisk(a non-native genus of small trees or shrubs)threatens the bighorn
habitat because this foreign and water-dependent plant crowds out smaller indigenous plants,thus,
• creating cover for predators. Why must the Plan area rely upon volunteers to clear out tamarisk?
• Why isn't there a major action program proposed and dollars allocated to eliminate tamarisk? Many
• researchers have noted that fire suppression policies lowered the quality of sheep habitat and thus
contributed to lower population numbers (Holl, et al., 2004). Why doesn't the Plan call for
• "prescribed fire" as apractical tool for improving Peninsular bighorn sheep habitat?
•
• Predation
• In California, mountain lions were trapped for a bounty from 1906 to 1963. Since 1972 mountain
lions have been protected from hunting. Some observers believe mountain lions are more numerous
• and widespread today than they were 30 years ago (Wehausen, 1996, Wood, 1998, Holl, 2004).
• Depredation permits are used in some areas to address the mountain lion problem but that usually
• takes place after the damage is done. Mountain lions appear to be the primary culprits of predation,
though the Plan contains no discussion about this predator or others in the Plan area. Why is that?
• Again,the earlier RPBS 2000 suggested a predation level above any natural equilibrium. Their
recovery plan for the bighorn sheep claimed, "Mountain lion predation currently is the primary cause
• of death of adult radio-collared sheep in most ewe groups in the Peninsular Ranges, and threatens
• population viability." (p.100 and Bighorn Institute, Summer 1997). Esther Ruben adds, "In the
•
• 57
•
•
•
•
•
• 1990s we documented a high predation rate on sheep. Mountain lions were responsible for about
• 60% of all deaths of sheep that we were monitoring with radio telemetry." (Rubin, 2002,p2) With
so many researchers seeing predation as a major mortality factor--the most recent, Mooring 2004--
why doesn't the Plan contain a literature review on this important variable? Why doesn't the Plan
• target this variable for an action program?
• Along the West Coast, from Los Angeles to San Diego, urbanization has moved eastward into the
mountains putting pressure on the regular habitat of the mountain lion.
This pressure has resulted in some mountain lions moving farther eastward into the
• mountains creating a high density of animals. In addition, the number of lions has
• increased since 1991 when California made it illegal to hunt them. With increased
numbers and expansion of urbanization, the mountain lion has become a more active
• predator impacting the bighorn's population. The lion and urban expansion has
• forced the bighorn to find a new habitat in the lower elevations near Palm Springs
• and other communities along the eastern edge of the Santa Rosa Mountains. "
(Baumann,p. 13-14).
• Also, declining populations in Anza Borrego's Coyote Canyon region are attributed to mountain
lions. Mark Jorgensen writes, "in a recent three-year period, mountain lions were documented
taking over 40 radio-collared Bighorn Sheep in Anza-Borrego."(Jorgensen, p.2) One study found
mountain lion predation accounted for 69 percent of all Bighorn sheep mortalities in the Peninsular
Ranges, California between 1992 and 1998 (Hayes, et al. 2000).*
Other potential native predators are bobcats, coyotes and golden eagles. Some observers believe
• there's a high incidence of predation and recommend selective removal programs to increase lamb
recruitment and adult survivorship rates. In 1997, The Bighorn Institute estimated mountain lions
• accounted for about 50% of mortalities in the San Jacinto Mountains and 28% in the northern Santa
Rosas. Why doesn't the Plan recommend selective removal in the San Jacinto Mouurtains to test the
• effectiveness of this technique? Researchers have proposed this policy (Schaefer et al. 2000).
Recent research by Ernest et al. 2002 warned that populations with less than 15 females have a high
• probability of extinction after five years. Doesn't this describe the small population in the San
Jacinto range? Why isn't the Plan seeking population figures for mountain lions, bobcats and other
• predators in the plan area?
*Mountain lion predation is a major contributor to bighorn sheep mortality in the Sierra Nevada,
• accounting for more than 50 percent of recorded deaths in the past quarter century (USF&WS, 2003)
Finally, some observers believe predation as a mortality factor decreases in importance as the size of
the sheep population increases (Mooring 2004).
s
•
•
• 58
•
•
•
•
•
•
Disease
In the Plan, disease is noted as a variable but not fleshed out in detail. Why is that? A consistent
theme in the literature is that diseases, particularly those of livestock, may be the major factor in the.
decline of the sheep population. Again, the document most relied upon by the Plan, the RPBS 2000,
discusses the role of disease. The Plan needs to explain: is disease more important, less important or
of the same importance over time? Are sheep exposed to new diseases as a result of foraging in
• newly developed areas? What about exposure to pathogens, chemical herbicides and insecticides?
U.S. Fish and Wildlife writes, "Infectious diseases do not currently appear to play an important role
• in population dynamics of bighorn sheep in most of the Peninsular Ranges." (US WS 2000,p. 102)
• The Bighorn Institute's disease research indicates that in the late 1970s and 1980s several diseases
• severely impacted wild populations of bighorns. Interestingly,this is precisely the time period when
. steep declines in population were noticed. Other observers claim that the desert bighorn sheep are
• particularly susceptible to bacterial pneumonia. (Toweill,p. 39) "Pneumonia epizootics can lead to
massive all-ages die off that decimate or extirpate entire populations" (USF&WS, 2003)
•
• In summary, disease may have played a major role in the steep declines of the sheep population in
• the 70s and 80s, but during the recovery years of 1997 to now, disease seems to be contained and
• pointing to disease containment as an important causal factor to focus upon.
Formulation 4 2
A second formulation was offered on page 7-205 of the December 1, 2003 draft Plan. The bighorn
sheep population is inversely related to (1)habitat loss, (2) disease, (3) human disturbance and(4)
• predation. This model is exactly the same as the preceding one except for the addition of one new
• variable, human disturbance.
Human Disturbance
• "Human disturbance" or anthropogenic disturbance is never defined. We are left to imagine.
Human disturbance doesn't offer the same common sense or intuitive logic of the other variables. It
• seems tacked on to support a point of view, or at best, it becomes a residual variable for everything
• else. If the power of this residual variable turned out to be small,the implications for the Plan's
current policy would be dramatic. RPBS 2000, the document most relied upon for preparing the
• Plan, did provide examples of human disturbance. They stated that construction noise from a
development project caused sheep to flee a feeding area and helicopters flying over and adjacent to
sheep enclosures causing sheep to run uphill. (p.19) Isn't this urban or economic development?
The 2003 Draft Recovery Plan for the Sierra Nevada Bighorn Sheep by United States Fish and
Wildlife Service concluded, "While unregulated hunting may have played a role in early population
• declines (Wehausen 1988),there is no evidence that commercial, recreational, scientific, or
• educational activities currently are significant threats. Further, poaching of these bighorn sheep has
not been documented in recent decades. Effects of recreation use should be further evaluated but
currently appear to be minor." (USF&WS, 2003) In contrast, human disturbance, in the form of trail
users, in the 2000 Recovery Plan for Bighorn Sheep in the Peninsular Ranges, California by United
• States Fish and Wildlife Service takes on a central role and becomes a major policy variable. How
•
59
•
•
•
•
•
and why did this happen? The same peer reviewed scientific literature on human disturbance was
• available to these recovery plan teams.
• Considerable research exists on the effects of human disturbance upon bighorn sheep. It has become
• standard in wildlife literature to refer to all impacts produced by humans upon bighorn sheep as "human
• disturbance." This unfortunate practice produces a catch-all term that obfuscates more than it informs:
• As I mentioned earlier, "disturbance" is not neutral but obviously negative in tone and meaning. Human
disturbance includes every possible anthropogenic affect from hunting down bighorn and shooting them
• to sitting quietly on the side of the trail and photographing a herd at a watering hole. A few authors
prefer a more neutral term, "human impacts." From 1897 to 1999, 627 publications regarding bighorn
• sheep in the United States were documented. Fifty of these studies involved"human impacts"upon
bighorn sheep (Eaton-Gonzalez, Ricardo B.,p. 27 and 34). None of the 50 works included information
• on trail users in the Coachella Valley.None of the 50 studies established a link between recreational trail
use and population level of bighorn sheep.
Almost every conceivable action is referred to as human disturbance or human impacts. And only the
primary source identifies the root of each"disturbance or impact". Examples includes bighorn sheep'
• response to jeeps,motorcycles and other off road vehicles (Jorgensen and Turner 1973), to uranium
• mining (Dean 1977), to cattle (Dean 1976, McQuivey 1978),to construction projects (Campbell and
• Remington 1981) and(Etchberger and Krausman 1999)to roads (Blong 1967),to mining activities
(DeForge et al. 1981),to river based recreation and livestock grazing (Goodson 1999), to aerial surveys
• (Krausman and Hervert 1983), to simulated jet aircraft(Weisenberger et al. 1996), to dogs and camping
• (Goodson, et al. (1999),to encroachment upon water sources by construction project(Leslie and
Douglas 1980), to riverboats (Stranger, et al. 1986),to helicopter surveys (Bleich et al. 1994), to
helicopter over flights (Stockwell et al. 1991), to recreational vehicles (Jorgensen 1974) and to hunting
• (Horejsi 1976). Horejsi found that on ranges where bighorn are hunted, they are more sensitive to the
• presence of humans. Another note: "Helicopter surveys may significantly alter the movement, habitat
• use, and foraging efficiency of sheep so that survivorship or reproduction is reduced. Unlike other
• forms of human disturbance such as hiking, bighorn sheep do not become habituated or desensitized to
repeated helicopter flights (Bleich et al. 1990, Bleich et al., 1994)" (BLM 2002, p.3).
•
• Too often, as in the previous paragraph, studies of human disturbance are cited without informing the
• reader about the agent of the human disturbance. A classic example of this omission practice can be
found in Recovery Plan for Bighorn Sheep in the Peninsular Ranges, California, 2000, page 43-45.
• Thus, the reader is left to plug into the citation whatever form of human disturbance comes to mind.
• When the human disturbance is defined as hikers on trails, available research is limited to five studies.
• All five studies find little to no impact of hikers upon bighorn sheep. None of these five studies
provided support for a policy of trails rationing as proposed in the Plan. Since the 1973 Endangered
• Species Act requires that species protection be based upon the best available science,why wasn't this
approach followed by the Plans authors? Each of these five studies is summarized below.
•
•
•
•
•
60
•
•
•
•
•
• Wehausen, et al., 1977
• "Bighorn Sheep Management in the Sierra Nevada," Desert Bighorn Council Transactions
• Studer California--May-August 1976
Methods: Bighorn and hikers on Baxter Pass were observed with spotting scope and
• binoculars from a rock blind so that neither was aware of the observers. Also,hikers were
interviewed.
• Findings: First hypothesis tested: bighorn can not tolerate repeated human presence and abandon use
of areas receiving regular human use. No permanent special displacement among the sheep was
• found. The first hypothesis was refuted. Second hypothesis tested: frequent human encounters
• significantly affect the yearly nutrient budget of a bighorn due to the disruption of feeding patterns.
• Bighorn reaction to humans generally found to be mild. The energy cost was insignificant. The
population was increasing. These findings refuted the second hypothesis.
•
• Hicks and Elder 1979
• "Human Disturbance of Sierra Nevada Bighorn Sheep,"Journal of Wildlife Mana eg ment
• Stud} area: California—May-August 1976
• Methods: Bighorn and hikers on Baxter Pass were observed with spotting scope and
• binoculars from a rock blind so that neither was aware of the observers. Also, hiker interviews and
• pellet transects.
Findings: "Foot-trails through areas of the Mt. Baxter summer range did not adversely affect sheep
• movements." "Bighorn-human encounters were limited to specific locations and were not adversely
• affecting the bighorn population." "The herd is not declining due to recreational use of the area."
• "Overall distribution of bighorn was related positively to food resources and not negatively to human
presence and use." "Bighorn continue to return to Baxter Pass despite repeated encounters with
• humans, and have become conditioned to hikers on the Baxter Pass trail."
•
• Purdy and Shaw 1981
• "An Analysis of Recreational Use Patterns in Desert Bighorn Habitat: The Pasch Ridge Wilderness
Case,"Desert Bighorn Council Transactions
•
• Study ararea: Arizona-- Sept 1979—Sept 1980
• Methods: photoelectric trail traffic counters, unmanned survey stations, self-administered
questionnaires,telephone surveys and direct observation
• Findings: Estimated average daily trail use was 72, 18 and 6 people. The majority of trail users
• appear to present little threat of bighorn disturbances. Most use was limited to hiking on or near trails.
• "desert bighorn sightings by PRW users appear to be rare occurrences."
Hamilton et al., 1982
• "An Evaluation of The Effects of Recreational Activity on Bighorn Sheep in the San Gabriel
Mountains, California," Desert Bighorn Council Transactions
• Study area: California—summer 1981
Methods: Bighorn use of the mineral licks was monitored by direct observation from behind natural
• blinds and with the use of time-lapsed cameras. Hiker use of trails was determined from Wilderness
• Permits and compared with bighorn sightings recorded on topographic maps.
• Findings: Study tested the hypothesis that bighorn were abandoning habitat receiving high levels of
• human use. "the presence of large numbers of hikers located in sheep summer range, did not cause
• 61
•
•
•
•
•
•
• sheep to abandon adjacent habitat." "there was no correlation between number of people using the
• canyon and numbers of bighorn using the mineral lick." The three most popular trails averaged 40
hikers a day. Less than 1 percent saw bighorn sheep
•
• Wehausen 2000
• "Locations of Human Interface with Sierra Nevada Bighorn Sheep," (unpublished paper)
• Study area: California—mid 70's to present
• Methods: personal observation and evaluation of five Sierra Nevada herds since the 1970's.
• Findings: Is human use limiting sheep population growth? "Efforts to recover these sheep need to
• focus on the primary factors affecting population dynamics and not place emphasis on factors like
human disturbance that appear to be at most very minor influences." Sheep show a high degree of
• habituation to humans in predictable places. Sheep have not been displaced from their habitat.No
• evident conflict between human use (hikers/backpackers) and the sheep.
• These studies find no incompatibility between trail users and bighorn sheep. These studies did not
• find that trail users adversely affect bighorn sheep. These studies found no link between trail users and
• the population of bighorn sheep. These studies found that sheep adapt and or habituate to the incidence
• of regular and expected trail users.
• A few agency people,wildlife managers and wildlife biologists have firmly held for more than a
decade a "belief system" that trail users adversely affect sheep population. This "belief system"
• consists of unsupported and untested claims, assumptions,value judgment and assertions.* Why
• aren't there research results by now to support this "belief system?" Why is this "belief system"
still intact and driving public policy in the absence of research to support it? Where is the
• evidence of"adaptive management" among present day wildlife managers? Where is the evidence
of the best available science being utilized in the preparation of the trails plan?
• Finally,before we close the discussion of human disturbance, we must look at the area of
• Researcher/Observer Harassment. The following five articles are often cited as studies on the
• impact of hiking upon bighorn sheep or comparing hiking versus other forms of recreational use.
The Papouchis et al. 1999 and 2001 (same article) was referenced six times (p. 14, 39, 43, 45, 83,
• 84) in Recovery as an example of"human disturbance"that is detrimental to bighorn sheep.
Unfortunately,these five articles adopted a methodology that can best be described as "intentional
• researcher/observer harassment." Or these studies teach us nothing about the effect of"recreational
•
• From the US Fish and Wildlife Service: "Peninsular bighorn sheep are sensitive to human disturbance
• during critical periods, such as lambing. For example,hikers can detrimentally affect the survival and
• recovery of this animal when this activity is in close proximity to lambing areas." (US FWS, July 5,
• 2000, p. 3) Also, BLM wrote "What is clear, however, it that people in bighorn habitat can cause
• disturbance during critical times of the year." (BLM, Palm Springs, 2002) No references or evidence
was offered in either case.
•
•
•
•
• 62
•
•
•
•
•
•
• trail users"upon bighorn sheep. They do confirm for us that when researchers intentionally stalk
• bighorn by walking directly at them via a cross country route, the sheep do respond. Take special note
that four of the five studies were conducted in areas of hunted sheep populations. The Peninsular
• bighorn sheep do not live in such hunted areas. Remember Horejsi 1976 found that sheep in hunted
• areas have a stronger reaction to humans than sheep in non-hunted areas.
• Finally, Appendix F contains BLM responses to the public comments on the Preliminary Draft Trails
• Management Plan (June 2002) and Draft Santa Rosa and San Jacinto Mountains National Monument
• Management Plan (March 2003). BLM stated,
• "A few experimental studies have been conducted that have tested the hypothesis that
recreation has a deleterious effect on bighorn sheep ((e.g, MacArthur et al. 1985 (should be
• 1979 and/or 1982); Papouchis et al. 2001)); however, in both these cases, the experiment tested
• the effect of researchers deliberately disturbing bighorn sheep. This is not necessarily the
• same as treatments on trails that use actual hikers who are likely to behave differently than
• researchers." (p.6)
Despite BLM's knowledge back in 2003 that the above studies are not of trails users but of intentional
• cross country harassment trails on bighorn sheep by researchers/observers,these same studies are cited
in Appendix C as a source of information on trail use.
Intentional Researcher/Observer Harassment of Bighorn Sheep*
MacArthur, et al., 1979—Canada
• Title: "Factors Influencing Heart Rate in Free-Ranging Bighorn Sheep: A Physiological Approach to
• the Study of Wildlife Harassment,"
Research/observer travels cross country directly stalking sheep to gage their reaction and measure
• heart rate response.
. Research project undertaken on a hunted sheep population.
• Author refers to their methodology as"standardized harassment trials"
Response of sheep greatest with appearance of free ranging dog and man with leashed dog.
•
• MacArthur, et al., 1982 -- Canada
• Title: "Cardiac and Behavioral Responses of Mountain Sheep to Human Disturbance"
• Researcher/observer travels cross country directly stalking sheep to gage their reaction
Research project undertaken on a hunted sheep population.
• Authors refer to their methodology as "standardized harassment trials" when field assistants directly
is approach sheep to gage their response. Response of sheep greatest when approached from over a
• ridge.
• ----------
*harassment for research purposes is defined as intentional hurnan disturbance, where the
• researcher/observer stalks or walks directly at bighorn sheep until the sheep respond, usually by
• fleeing their previous undisturbed location. Researcher/Observer then records the flight behavior
response of the sheep.
•
•
•
•
• 63
•
•
•
•
! Miller and Smith 1985—Arizona—
! Title: "Human Activity in Desert Bighorn Habitat: What Disturbs Sheep?"
Researcher/observer travel cross country directly stalking sheep to gage their reaction
! Research project undertaken on a hunted sheep population.
! Human activity consisted of one or two researcher/observers sighting sheep and then directly
approaching the sheep and recording the reaction of the sheep. This is not how recreational trail users
! encounter sheep. Rarely will it be reported that hikers were proceeding along and there ahead of them
! on the trail were bighorn sheep. Instead,in rare instances,trail users might see sheep off to the side
• crossing a ridge line or coming down a steep cliff to drink at a watering site or stopping to watch a
group of hikers pass in the dry wash below. When this happens educated trail users don't leave the
! trail and walk directly at the sheep, but typically stop dead in their tracks, remain quiet in hopes of
! soaking in a few minutes of these magnificent creatures. Walking directly at sheep is a form of
! harassment intent upon scaring them away. In the region of Western Arizona, the authors
! acknowledged hunting is an important disturbance to sheep and that walking directly at the sheep may
remind sheep of hunters. This article provides no insights into recreational disturbance.
!
King and Workman 1986—Utah—
Title: "Response of Desert Bighorn Sheep to Human Harassment: Management Implications"
! Researcher/observer travel cross county directly stalking sheep to gage their reaction
! Research project undertaken on a hunted sheep population.
• More heavily hunted sheep responded more than less heavily hunted. A higher percentage responded,
fled greater distances, were more wary and spent less time feeding.
!
!
• Papouchis, C. M., et at. 1999 and 2001 —(same article) U
! Title: "Responses of Desert Bighorn Sheep to Human Recreation"
Researcher/observer travel cross country directly stalking sheep to gage their reaction
! Sheep were located electronically, then"field assistants" were sent off cross country directly at the
sheep. This study makes the illegitimate comparison of mountain bikers and vehicles that used only
! park roads with"field assistants"who walked cross country directly stalking bighorn sheep. These
"field assistants" were called hikers. Thus, "hikers (field assistants) surprised bighorns,"whereas .
! mountain bikers and vehicle did not surprise sheep. Thus, road users were compared with non-
trail/road users. Sheep response was greatest when approached directly in comparison to from below
! or above because sheep were surprised. Authors recommend ban on "cross country hiking" which was
! adopted by CVAG's "trails plan."
! Human Activity
! The RPBS 2000 inventories a variety of human activities that have the potential to adversely affect
• bighorn sheep. They include hiking, mountain biking, hang gliding,horseback riding, camping,
hunting, livestock grazing, dog walking and use of aircraft and off-road vehicles. The RPBS did not
! rank these activities from the least to most potential, but the examples offered as problematic were
dogs, off-road vehicles, helicopters and motorcycles. (p 43-44) Why isn't the management policy
! for trail usage in the Plan directed toward these examples?
!
! 64
!
•
•
•
•
Another Population Model
In thinking through the population trends in the bighorn sheep, we could develop a more
• comprehensive multi-variable model such as: The bighorn sheep population is inversely related to
• (1) habitat loss, (2)habitat fragmentation, (3)habitat degradation, (4)predation, (5) climatic factors
• (temperature and precipitation), (6) disease (7) loss of water sources, (8) fatal urban encounters, (9)
low lamb survival rate, (10) high male sex ratio, and(11) recreational trail usage. Table 6 presents
• this eleven factorial model with the derivation of each factor. Obtaining time-series data on each
• variable would be the ideal, but even orders of magnitude from a ranking scale could shed some
• light.*
-----------------------------
*Variables (1), (2), and (3) are proxies for urban development and population growth. Often the
• variable "human disturbance" is a catch-all for economic development but rarely explained as such.
• Variables (4), (5) and (6) are independent variables encountered in the natural environment, a natural
disturbance:
Variable (4): predation predominantly represented by the mountain lion, but can include
• bobcats, coyotes and golden eagles. Some observers believe a weakening of this variable in
• recent years might help explain the expansion of the bighorn sheep population
• Variable (5): climatic factors (temperature and precipitation) can negatively affect the sheep by
limiting water sources and impacting forage quality. "During drought years, the concentration
• of bighorn near remaining water sources may increase competition for forage as well as water,
• thereby limiting population growth through density dependent regulation. In addition,
• increased density potentially rends animals more susceptible to diseases or parasites." (p.42,
• USFWS 2000). "The primary limiting factor for most desert bighorn sheep populations is
adverse climatic conditions, primarily drought, resulting in the reduction in free standing water
and succulent forage." (Lee, 1999, p.71) Global warming has some wildlife biologists
• believing the time has come to shift from primarily focusing on habitat to climate. (Epps, et al.
• 2004)
Variable (6): disease is also a proxy for economic development and population growth. In fact,
• this variable alone may provide the explanation for the rapid decline of the bighorn sheep
• population in the middle of the 20a'century. Cattle and domestic sheep ranching brought
• previously unknown disease into wild sheep herds. But disease doesn't appear to be prominent
in present context and less disease may help explain the population increase in the bighorn
• sheep. In conclusion, these six variables appear to dominate the causal relationship for the
sheep population.
• Variables (7), (8), (9) and(10) are not true independent variable but secondary effects or
• indirect results from the previous six variables. For policy purposes, elaboration on the
following could be important: (7)loss of water sources, (8) fatal urban encounters, (9) low
• lamb survival rate and (10)high male sex ratio.
• Variable (7): loss of water sources is a major limiting factor to abundance of Peninsular
• bighorn sheep in the Santa Rosa Mountains. (According to Blong 1967 and BLM 1980) Blong
• found that bighorn sheep abandoned the Magnesia Spring water source as development
encroached. Also, in some areas of the Peninsular Range, "water has been pumped from
• aquifers and diverted away from springs for use by ranchers and private residences, reducing
• and eliminating the water sources upon which sheep depend." (p.45, USFWS 2000)
•
•
• 65
•
•
•
•
•
•
• Variable (8): fatal urban encounter is a catch- all variable for unfortunate outcomes, as
! illustrated with this example. "Between 1991 and 1996, 34 % of adult bighorn mortalities in
the northern Santa Rosa Mountains were directly attributed to the effects of urbanization. Five
! sheep were killed by automobiles, 5 by eating toxic landscaping plants and 1 by strangulation
• in a wire fence." (Bighorn Institute 1997)
! Variable (9): low lamb survival rate could be a key policy variable for the conservation Plan.
According to the Bighorn Institute, since 1982, 90%of lambs in the Northern Santa Rosa Mountains
! have died before reaching yearling age. Recent data shows wide swings in the lamb survival rate.
i Apparently, in the year 2000 all 12 lambs born in the Northern Santa Rosa Mountains survived. But,
! in 2001, nine of the twelve bighorn sheep lambs died. Currently, The Rancho Mirage Fencing
! Projects is expected to dramatically lower fatal urban encounters and raise lamb survival rates. The
Bighorn Institute estimates the population of sheep can increase even with a lamb survival rate as
• low as 30 percent. Also, some portion of new-born lambs are lost each year to accidents. "Some fall
• from cliffs, others twist a leg, still others may drown at steep-sided waterholes." (Toweill, p.39)
! Finally,two researchers found that precipitation during the pregnancy period markedly influenced
the lamb survival rate. (Douglas and Leslie 1986)
• Variable (10): high male sex ratio means too many male lambs among new born make it more
! problematic for an expanding population. "high male sex ratio may be caused by demographic
! stochasticity, a higher mortality rate for females than males, nutritional stress or inbreeding
! depression." (source unknown)
Variable (11) is recreational trail use. Again, this represents a human disturbance resulting from
! economic development. Variable (11), unlike the previous ten variables, has no established link to
i population levels of bighorns and is most likely `weak to unimportant' in impacting population
! trends.
!
!
•
•
•
•
!
•
•
•
i
•
•
•
•
•
• 66
•
•
•
•
•
•
• Table 6
•
• Modeling Factors Affecting the Population of Peninsular Bighorn Sheep
•
• I. Factors With Established Links to Population Levels of Bighorn Sheep
primary or direct
• factors cause by man results from caused by nature
• 1 loss of habitat human disturbance economic development
2 fragmentation of habitat human disturbance economic development
• 3 degradation of habitat human disturbance economic development
• 4 predation natural disturbance
5 drought natural disturbance
• 6 disease human disturbance economic development natural disturbance
•
• secondary or indirect
•
+ 7 loss of water sources human disturbance economic development
8 fatal urban encounters human disturbance economic development
• 9 low Iamb survival rate human disturbance economic development natural disturbance
• 10 high male sex ratio human disturbance economic development
•
• Il. Factors With No Established Link to Population Levels of Bighorn Sheep
secondary or indirect
• 11 recreational trail use human disturbance economic development
•
•
•
•
•
•
i
•
•
•
•
•
•
•
• 67
•
r
•
•
•
• Two final notes on research--The BLM's twelve-page report Status of the Science, (published March
• 2001) surveyed the published literature on disturbance response of bighorn sheep. (i.e. On Questions
that Relate to BLMPlan Amendment Decisions and Peninsular Ranges Bighorn Sheep.) Though
• problems exist in applying results from a wide range of projects in various regions of the United
• States, a summary remark is acutely germane to our CVHC Response to the Plan. Referring to
• Bighorn Response to Hiking,the BLM report states: "To date, research has not established a link
between hiking and population level effects on bighorn sheen." (page seven) As far as we know,
• there is no consideration or reference in the Plan to this important finding. Also, to date we are not
• aware that any researchers have put together a proposal to test for any such linkage. Why would that
• be?
• Also,the U.S. Fish and Wildlife Service's July 2000 fact sheet"Peninsular Bighorn Sheep," stresses,
• "Further habitat losses resultingfrom urban development and human population growth will
• likely have a significant negative effect on remaining populations of bighorn sheep in
southern California. " Why aren't these crucial f ndings included in the Plan? Why have
• they been left out entirely? This lack is particularly troubling since the Plan's Executive
• Summary assures its readership that, "The conservation plan was developed in consultation
• with the SAC, using best available science. " (page two).
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• - 68 -
•
•
•
•
• 12. Restricting Mountain Biking within the Plan Area Through Trail Closures
The EIS/EIR places new restrictions upon mountain bikers' use of trails. It is reasoned that
mountain biking"may result in impacts to trails such as increased erosion or other alteration of trail
• tread or location." (page 5-75) or"the closure of some trails to bikes would reduce disturbance
! impact to sheep and degradation of their habitat in these areas. In addition, mountain bike use may
• result in accelerated erosion of trails causing soil loss and other impacts (vegetation impacts,
sedimentation, and decrease in water quality), adversely affecting sheep habitat. (page 5-32) The
• authors go on to claim trail closures to bicycles in each of the four plan alternatives "would have
• similar effects,namely reduction in bike disturbance to sheep and reduction in degradation of sheep
habitat."(page 5-32)
• So called"redundant trails"in the Murray Hill Complex and Murray-Hill/Eagle Canyon/Goat Trails
• area will be decommissioned and removed. Currently, these trails are used by mountain bikers and
• hikers. These "goat trails" offer variety in distance, route and scenery: spectacular views canyon
walls, canyon bottoms, San Jacinto, San Gorgonio, and of the Coachella valley floor below for all
• who use them. Decommission and removal of these"goat trails" result in immediate reduction to
• the public good with no benefit to bighorn sheep.
Authors speculate that the existence of the Goat Trails in Palm Springs "may result in disruption to
feeding,resting and ruminating." How can that be if no ewe group currently occupies this area as a
• home range? In fact,this area has not been a home range for over twenty years according a Fish and
• Wildlife Service employee who works in this area.
• Reducing mountain bikers' access to trails in this valley was proposed and accepted by trails plan
• authors without a single piece of evidence to support this policy change. The claim of disturbance to
• sheep and degradation of sheep habitat was never supported. Why is it that despite the expenditure
• of hundreds of thousands of dollars,plus the value of in-kind services, authors of CVAG's trails plan
• could not produce one study through a literature review? Gary Sprung, Member Resource Advisory
Committee to the BLM for Southwest Colorado, did a literature review in 2004 entitled"Natural
• Resources Impacts of Mountain Biking: A Summary of Scientific Studies that Compare Mountain
• Biking to other Forms of Trail Travel.," (see Sprung 2004) After reviewing twelve studies, he
• concluded"no scientific studies show that mountain bikers cause more wear to trail than other
users," and "no scientific studies indicate that bicycling causes more degradation of plants than
• hiking." Isn't this another example of the authors of the "trails plan"not using the best available
• science?
•
•
•
•
•
s
•
•
•
• 69
•
•
•
13. Effects of the Trails Plan Upon Recreation Resources and Opportunities
(pages 5.82-5-98) = 16 pages
• (1) What Terra Nova Did: Offered Only Description
! Terra Nova Conclusion I
• Authors of the EIS/EIR concluded that"Potential adverse impacts to recreational resources
! resulting from implementation of the proposed Trails Plan would occur at levels that are less than
! significant as substantial opportunities for trail based activities would continue. Additionally,
positive effects are expected from the construction of new trails that would be facilitated by the
! Trails Plan." (5-98)
•
We intend to demonstrate once one takes a close look at the various impacts of the trails plan,the
• above conclusions no longer are supported.
• (1) The trails plan produces an immediate net loss of hiking opportunities. As soon as the permit
• system takes affect fewer valley residents and visitors will be allowed on the trails.
(2) The new perimeter trails, if and when they become available will provide new hiking
• opportunities. But it isn't a certainty that the new trails will be built and the time lag (up to nine
! years) involved will generate further losses in the public good. Even if all new trails magically
! came into existence all at once in 2006,there would still be a net loss because lack of
• substitutability. among new trails and those existing trails taken away. Thus, the PLAN
incorrectly assumes the new trails will make up for those trails designated for permitting and
• voluntary avoidance.
(3) The new perimeter trails are not substitutes for the trails in the permitting and voluntary
avoidance programs. Perimeter trails are "low elevation trails,"just above the toe of the slope,
• close in trails that follow along the urban interface of the valley. These easy to moderate trails
• will appeal to a different group of hikers than those who value the "back country,"high
• elevation, strenuous trails targeted for permitting and voluntary avoidance.* One exception to
! the "not substitutes"point just discussed is the proposed Palm Desert to La Quinta Connector
Trail. But this trail may never be built.
• * For the substitutability rule to hold, one must be indifferent between the new trail and the
permitted trail. That would mean, for example, a hiker would be indifferent between hiking the
Art Smith and the Hopalong Cassidy Trail. Or the Skyline Trail and the Hopalong Cassidy Trail.
• The vast majority of hikers who enjoy the Art Smith or Sky Line trails would not be willing to
• substitute the Hopalong Cassidy trail. Or one could use the market test for substitutability. Put the
• trails up for sale. If they are real substitutes,their prices will be the same or nearly the same. I
! don't think it controversial to say 8 miles or either the Art Smith or the Skyline Trail would
command a much higher price than 8 miles of a Hopalong Cassidy type perimeter trail.
• Conclusions: perimeter trails are not substitutes for permitted trails. There is a net loss in the
public good by reducing public access of permitted trails and offering the same miles of perimeter
! trails in their place.
!
! 70
•
•
•
•
•
• (4) Unfortunately, the authors do make the mistake of assuming new trails, permitted trails and
• alternate trails are substitutes for each other. I don't know a single experienced hiker who
would make such a claim. Are any of the new perimeter trails a substitute for the Art Smith
• Trail, the Skyline Trail, the climb to Murray Peak, the Boo Hoff Trail,the Bear Creek Trail, or
• the Hahn-Buena Vista Trail. Clearly no,not even close. Any who steadfastly holds that position
• should hike the trails for a first hand evaluation.
• (5) The trail decommission and removal of the goat trails results in a net loss to mountain bikers and
• hikers since this eliminates the"loop routes" (regular and figure eight configured) currently
• available,reduces the total miles currently available and eliminates the option of taking shorter
• routes currently available.
• (6) The estimated demand for the permitted trails is roughly 10,000* and the supply is 3,000.** The
• excess demand of 7,000 is substantial. Some 7 out of 10 people will be denied permits. This
• outcome alone will nullify the above conclusion.
• (7) Authors admit"opportunities for group (read hiking clubs) activities on the subject trails would
• be reduced" (5-86). But then rationalize away this problem by asserting, "the quality of
• recreational experience may be higher for those acquiring a permit.....for many people, the back.
• country experience is heightened when few other are encountered." (5-86) In other words, if you
are lucky enough to obtain a permit,the value to you will be even higher once you realize few
• others will have such permit. The converse of this, of course, is those not fortunate enough to
• obtain a permit will experience an even greater sense of loss from not being able to Bike the trail
than before permitting began. Thus,the net loss is even greater than under the earlier analysis
that did not make the above"solitude" asswnption.***
•
• (8) Authors claim, "although the total number of trails may be reduced in the projects area,
• opportunities for biking, mountain biking and horseback riding would no be substantially
• affected." (5-87). This claim is not supported by the facts. The total number of trails is less and
strenuous, back country, high elevation gain trails are replaced by easy/moderate, close in, low
• elevation gain trails.
*see Table 4,page 33 of this response
** 2300 individual permits plus 50 group permits. The PLAN allows a group to be 30 people. Our
• experience with group hikes is about an average of 14 people. Thus, 2300 individual permit holders
• plus 50 group permits with be the average of 14 people totals to 3000 users under the permitting
• system.
• ***Our estimates are 3000 people will gain permits and 7,000 people denied a permit. If an
ordinary hiking experience garners 1 unit of satisfaction, then the total satisfaction benefit is 3,000
• units and the total satisfaction loss if 7,000 units. The net total loss to the public good is 4,000 units
• of satisfaction. However, if plan authors are correct and"solitude"hiking brings additional
• satisfaction then the following could be the result. The new, special biking experience garners 3
units of satisfaction. Now the 3,000 people with permits obtain 9,000 units of satisfaction and the
• 7,000 people who were denied permits sustain 21,000 units of satisfaction loss. The net total loss to
• the public good is 12,000 units of satisfaction. Siummary,the permitting system results in a greater
• loss in the public good under the "solitude" assumption.
s
71
•
•
•
•
•
•
• (9) Year round access to back country peaks and desert washes such as Haystack Mountain, Toro
• Canyon and Aqua Alta Canyon would now be limited to a period of 106 days. That amounts to
a 70 percent reduction in cross-country access. This constitutes a significant and substantial
• restriction in access to open space.
•
• Our Conclusion(1)
• Summing up the losses in access, opportunities, and experiences from the preceding nine points does
not produce "less than significant" adverse impacts to those wanting to take advantage of public
• recreational resources in our valley. There are no present or current benefits, only expected or
• possible future benefits from new trails. Therefore, Conclusion I drawn by the authors as quoted at
• the outset of Section 13 from(5-98)is not supported.
•
• (2) What Terra Nova Didn't Do: Provide Data and Undertake Analysis of the Data
• Terra Nova Conclusion II
• Authors of the EIS/EIR, Terra Nova also said, "in summary, trail closures, use limits and
implementation of the permitting program proposed .... would result in trail use limits that
• approximate estimates of annual use for the years 2001 through 2003. This would not constitute a
• significant restriction overall on trail use opportunities and access to open space." (5-86)
• Terra Nova reached this conclusion without providing any data or undertaking any analysis.
But in the Santa Rosa and San Jacinto Mountains National Monument Management Plan and
Environmental Impact Statement,* Terra Nova provided the following trail use data gathered by
• BLM. The estimated annualized trail use was 3,136 in 2001, 4,180 in 2002 and 4,312 in 2003. That
is, non-compliant trail users increased 37.5 percent in two years (Appendix N-16-17,USID and
• UDAD 2003). Assuming the same rate of increase in estimated trail users, 2005 would have 5,929
non-compliant users on the trails. With 2005 being the first year for implementing the permitting
• system, we have total estimated demand of 5,929 non-compliant trail users (40%) and 8,894
• compliant trail users (60%) or a total of 14,822 potential trail users.
We estimated that roughly 3,000 users would obtain permits under CVAG's proposed permitting
system. That would mean 11,822 potential trail users would be denied access to trails. Or, putting it
• another way, 8 out of every 10 trail users would be denied a permit.
•
• Our Conclusion(2)
• Denying trail access to 8 out of every 10 tourists and residents of the Coachella Valley produces a
significant restriction overall on trail use opportunities and access to open space.** Thus,the
• proposed trails plan results in significant adverse impacts to those wanting to take advantage of
• public recreational resources in our valley. Therefore, Conclusion II drawn by the authors as quoted
• at the outset of this section (2) (5-86) is not supported.
• *Hereafter referred to as (USDI and USDA 2003)
** Even using our earlier more conservative estimate of 10,000 potential trail users still results in 7
• out of 10 not obtaining a permit and still amounts to a significant restriction.
•
72
•
•
•
•
•
•
•
• (3) What Terra Nova Didn't Do: A Qualitative Cost/Benefit Analysis
Another way to evaluate the conclusions drawn by EIS/EIR authors would be to undertake a
• qualitative cost/benefit analysis. The outline for such an approach is given in Table 7 below. One
• need only list the elements of the trails plan and determine whether that element, on balance,
• represents a cost or benefit to recreational resources. It seems non controversial, that only element
•
• Table 7
Qualitative Cost/Benefit Model for Recreational Resources
• Elements of trail plan cost benefit
+ 1. Trail avoidance program xxx
2. Hot season closures xxx
• 3. Trail permitting program xxx
• 4. Trail decommission and removal xxx
• 5. Cross country ban xxx
6. Restrictions on bicycle access xxx
• 7. New trails xxx
•
seven, new trails represents a benefit. All other elements of the trails plan represent costs, that is,
loss of access, loss of opportunities and loss of trail experiences. Assuming, 2005 is first year of the
trails plan, it could be that no new trails are built,thus for 2005 only costs would be present. How
• then,is it possible to conclude, "Potential adverse impacts to recreational resources resulting from
implementation of the proposed trails plan would occur at levels that are LESS THAN
• SIGNIFICANT?"
•
• Even in the best of all scenarios for 2006 that all new trails came on line,there would still be a
• substantial net cost. The new trails can't compensate for element 3,the permitted trails because of
• the lack of substitutability. Again,there would be substantial net costs since all elements 1 through
6 represents costs.
•
• Our Conclusion(3)
• Summing up the losses in access, opportunities, and experiences from the preceding qualitative
cost/benefit analysis does not produce "less than significant" adverse impacts to those wanting to
• take advantage of public recreational resources in our valley. There are no present or current
• benefits, only expected or possible future benefits from new trails. Therefore, Conclusion I and II,
• drawn by the authors as quoted at the outset of this section(1) (5-98) and(2) (5-86) are not
S supported.
•
•
•
• 73
•
•
•
•
•
•
•
• (4) What Terra Nova Didn't Do: Quantitative Analysis
• Terra Nova should have undertaken some quantitative analysis of the proposed Trails Plan. In what
• follows, we offer a few examples of quantitative analysis applicable to the Trails Plan.
Table 8 below lists in the column entitled the Proposed Trail Actions,the number of trails and miles
of trails affected. Since all these actions result in reduced public access,they are all considered
• "costs." The next column entitled New Trails, lists proposed number of new trails and total miles
• proposed. New trails are considered"benefits"to trail users.
• Table 8
•
• Analysis of Trail Access Lost and Trail Access Gained
• Costs to Trail User Benefits to Trail Users
•
• Proposed Number Miles Number Miles
• Trail Action of trails of trails of Trails of Trails
• Quota Permit program 9 27
• Trail Avoidance program 6 10
• Trail Closed * 1 5
• Hot Season Trail Closures **
New Perimeter trails 6 16
• New Connector trail 1 8
16 42 7 24
*Carrizo Canyon is closed for January 1 —June 14 and Hot Season, July 1 — September 30
• ** Art Smith and Bear Creek Canyon of Permit program are closed for the hot season
• Schey Trail of Trail Avoidance program is closed for the hot season
•
Table 8 illustrates that 16 trails with a combined 42 miles in length will have limited public access
• for some of the year under the proposed trails plan. This represents a cost to the public in terms of
• reduced access, lost opportunities, and lost experiences. These costs are current and will be incurred
• immediately, if the trails plan is adopted as written. The benefits are not current, but future and only
• proposed not guaranteed. The benefits would be 5 new trails with combined 24 miles. These trails
would be open all year. If the proposed new trails are never built,there would be only costs and no
• benefits. If the proposed new trails were to come on line in 2005, the costs would still exceed the
benefits in terms of number of trails and miles of trails. When one considers only one of the new
• proposed trails is a substitute for the trails targets for permitting, trail avoidance and hot season
closure,the costs of the trails plan will exceed the benefits even more.
•
a
•
•
74
•
•
•
•
•
The Trails Plan affects o&public hikes/trails, that is,those hikes/trails that are free to the user.
• Table 9: Coachella Valley Public Hikes/Trails presents an inventory of Coachella Valley public
hikes/trails. Public hikes/trails are free to the trail user. Not all trails/hikes are free to the trail user
• but charge an entrance fee or tram fee. These hikes/trails are not considered public for this analysis.
• Thus hikes/trails in the Indian Canyons, above the tram and at the Living Desert are not included.
• Hikes in Joshua Tree National Park, Idyllwild and Mecca are not includes as they are not in the
Coachella Valley.
•
• Our inventory came up with 30 public hikes/trails in the Coachella Valley. Table 9 groups the
. hikes/trails according to easy, moderate and strenuous. Thus,there are 4 easy, 16 moderate and 10
• strenuous hikes/trails. The summary of Table 9 shows that 17 or the 30 public hikes/trails or fifty-
seven percent will be negatively affected by the trails plan through reduced public access. Note that
• nine of the ten strenuous (long and steep) hikes/trails are negatively affected by the trails plan. Fifty
• percent of the moderate hikes/trails are negatively affected. None of the four easy hikes/trails are
• affected by Trail Plan.
• The Coachella Valley contains approximately 195 miles of public hikes/trails.* Seventy-two percent
• of the total miles or 141 miles will be negatively affected by the trails plan through reduced public
• access.
• As far as location, nearly 60 percent of the 30 hikes/trails are located in Palm Springs with the other
• hikes/trails fairly evenly divided among the other valley cites.
• Thus,Table 9 demonstrates that the Trails Plan significantly reduces the opportunities for PUBLIC
• trail based activities in the Coachella Valley. For the plan to suggest there are plenty of other hiking
• opportunities available elsewhere is to impose a tax on the public without their consent. Many other
• Valley hiking opportunities are not free and impose user fees (Living Desert, Indian Canyons,
• Above the tram). Most, like Idyllwild, Mecca and Joshua Tree National Park, are at least an hour
outside the Coachella Valley
•
• Where is the Socio-Economic Impact Report?
• Terra Nova wrote one for the Santa Rosa and San Jacinto Mountains National Monument
• Management Plan and EIS. (see, Appendix N,USDI and USDA, October 2003)
•
• Authors of the Management Plan for the Santa Rosa and San Jacinto Mountains National Monument
• said:
"Commercial eco-tourism, camping,hiking, mountain biking, and equestrian use have also
• become progressively more important local economic benefits, enhancing the resort
• industry in the Plan area and providing opportunities for increased employment in nature
• and outdoor oriented industries and programs." (3-95, USD1 and USDA 2003)
• ----------
*Exact miles for some trails was not included in the trails plan. Our December 22, 2004 request to
•. CVAG for mileage clarification was not answered as of January 20, 2005
•
• 75
•
•
•
•
•
•
l able 9 - Coachella VaaleyPubllc•Meg
lTralls*
• Affected by
Hikes/Trail Miles Trails Plan Difficulty Location
• 1 Pushawalla Palms and Canyon 6 no easy 1000 Palms
• 2 Willis Palms and West Mesa 3 no easy 1000 Palms
• 3 Earl Henderson 3 no easy Palm Springs
4 Theilman 3 no easy Palm Springs
• Totals 15
1 Carrizo Canyon 5 yes moderate Palm Desert
2 Shannon Loop 7 no moderate Palm Springs
• 3 Araby 3 no moderate Palm Springs
• 4 Garstin 3 no moderate Palm Springs
5 South Lykken 5 no moderate Palm Springs
• 6 North Lykken 4.5 yes moderate Palm Springs
• 7 Palm Springs Desert Museum 2 no moderate Palm Springs
8 Mirage 4 yes moderate Rancho Mirage
• 9 Eagle Canyon 2 yes moderate Palm Springs
. 10 Magnesia Falls 5 no moderate Rancho Mirage
11 Clara Burgess 3.5 yes moderate Palm Springs
12 Cathedral Canyon 6 yes moderate Cathedral City
• 13 Berns 1 no moderate Palm Springs
14 Schey 4 yes moderate Palm Desert
15 Wildhorse 3.5 no moderate Palm Springs
• 16 Goat Trails 2 yes moderate Palm Springs
• Totals 60.5
• 1 Garstin/Wildhorse 9 no strenuous Palm Springs
2 Eagle Canyon/Clara Burgess/Murray Hill 8 yes strenuous Palm Springs
3 Araby/Clara Burgess/Murray Hill 10 yes strenuous Palm Springs
4 Bear Creek Canyon Ridge 8 yes strenuous La Quinta
• 5 Boo Hoff to Lost Canyon 10 yes strenuous La Quinta
• 6 Art Smith 16 yes strenuous Palm Desert
7 Hahn-Buena Vista Loop 16 yes strenuous Palm Springs
• 8 Skyline 10 yes strenuous Palm Springs
• 9 Palm Desert to Palm Springs 17 yes strenuous Valley Wide
• 10 Guadalupe to Sugarloaf Cafe 15 yes strenuous La Quinta
• Totals 119
Summary:
• Total Valley Public Hikes/Trails: 30
Total Valley Public Hikes/Trails Affected by Trails Plan: 17
• Total Valley Public Hikes/Trails Unaffected by Trails Plan: 13
Total Miles of Valley Public Hikes/Trails: 195
Total Miles of Valley Public Hikes/Trails Affected by Trails Plan: 141
Total Miles of Valley Public Hikes/Trails Unaffected by Trails Plan: 54
•
• Note: *Public means free to user. This excludes Indian Canyons and Eisenhower Peak Loop with entrance fees and hikes above the tram.
Hikes in Idyllwild, Mecca, and Joshua Tree National Park are considered outside of the Coachella Valley.
• Source: Ferranti 2000, CVAG and EIS/EIR p. 3-83-86
•
• 76
•
•
•
•
•
• Terra Nova took the BLM figures of 4,250 persons who were estimated to have used the nine trails
• during 2001 and 2003 and assumed these nine trails represent ten percent of Coachella Valley trails.
Thus, Terra Nova authors wrote, "42,500 persons annually hike in the Coachella Valley trail system.
• It has also been assumed that all these persons are tourist,not residents." (Appendix N-21, USDI and
USDA, 2003) The average visitor spends $335.46 per day in the valley for a three day visit.
• "Extended to include the 10,625 visitors who are assumed to be lost due to trail closures, the total
animal loss to all Valley businesses would be $10,692,787.50." (Appendix N-22, USDI and USAD
• 2003) Additionally, "Local jurisdictions in the Coachella Valley could experience a total annual loss
• of$435,000 (lost tax revenues). This produces an estimated annual economic loss from reduced
. tourism of up to $11.1 million dollars.*
• While this figure is undoubtedly small relative to the total value of tourism for the Valley, surely the
• valley would rather take in another$11.1 million dollars than lose it. Also, where is there $11.1
• million dollars in benefits to cancel out this loss? Apparently, it isn't there.
• Terra Nova downplayed this loss of recreation opportunities (reduced trail access)by suggesting
• tourists can travel an hour to Idyllwild or pay$20 and take the Aerial Tramway. Nothing was said
• about hiking temperatures for those areas in January, February and March, not to mention the added
• costs to hike there in lieu of the free Valley trails closed off to them. So here was an area of
additional costs to tourists and residents alike. Terra Nova didn't recognize and attempt to quantify
• these additional costs of the proposed trails plan.
•
• Can you imagine the Valleys' various visitors centers telling prospective visiting tennis or golf
• enthusiast that they are sorry some of the best valley courses and courts are now restricted to 30
percent of actual demand. All those who have used these facilities in the past might want to try out
• Yucca Valley, Idyllwild, or Borrego Springs!
Finally, Gary Sherwin, vice president of market development for the Palm Springs Desert Resorts
Convention and Visitors Authority said of the approximately 3.5 million people who visit the valley
• annually, "an estimated 35 percent take part in outdoor recreations like hiking or a tour." (Guzman,
• 2004). This offers another measure of the costs the Trails Plan will impose upon the tourist industry
• of Coachella Valley.
• Our Conclusion(4)
• The cost/benefit analysis of trail access lost and trail access gained revealed the public is in a net
• cost position. The costs exceed the benefits of the Trails Plan. The inventory of public (free)trails
. in the Coachella Valley revealed more than 50 percent hikes/trails and more than 70 percent of total
hike/trail miles will be negatively affected by the Trails Plan. All but one of the Valley's strenuous
• hikes/trails are negatively affected by the trails Plan. Our review of Terra Nova's data analysis,the
• proposed trails plan will cause a loss of tourist visits, loss of tourist dollars and loss of tax revenues
• to local jurisdictions that amounts to millions of dollars. Terra Nova produced no dollar benefits
• that would result from the proposed trails plan. Thus, the socio-economic impact of the proposed
trails plan is a serious monetary loss to the Valley. Therefore, Conclusion I and II, drawn by the
• authors as quoted at the outset of section(1) (5-98) and (2) (5-86) are not supported.
*Even if one cuts this figure in half and concludes the total loss is but$5.5 million dollars, everything else
still follows
•
• 77
•
•
•
•
•
•
In summary,we have explored in four different ways,the trails plan impacts recreation resources
and opportunities. Each alternative look came up with significant adverse impacts to recreational
• resources and opportunities via significant restrictions to trail use opportunities and access to open
• space. The proposed trails plan produces significant social and economic costs to valley residents
• and the tourism industry with no certain benefits.
• Finally, it appears that the trails plan does not even meet the legal requirements of the Santa Rosa
• and Santa Jacinto Mountains National Monument Act. This trails plan doesn't preserve recreational
. values in the Monument. The Plan restricts, takes away,reduces, limits recreational values in the
Monument. The trails plan doesn't secure the opportunities to experience and enjoy the vista,
• wildlife, land forms and natural and cultural resources of the monument, it takes them away.
•
• As the management plan points out, "The BLM and Forest Service are required, under the National
• Monument Act of 2000,to prepare a Management Plan which:
1. Preserves the nationally significant biological, recreational, cultural, geologic, educational
• and scientific values in the Monument;
• 2. Secures the opportunity to experience and enjoy the vistas, wildlife, land forms and natural and
• cultural resources of the monument, and the opportunity to recreate within it;" (Appendix
N-3, USDI and USDA 2003)
•
• Lastly, A Note on Perimeter trails, PARKING and Adverse Impacts
The"trails plan"calls for a system of perimeter trails that will extend from Palm Springs to La
Quinta. The EIS/EIR states, `Beneficial impacts associated with the proposed Perimeter Trail
• system included improved access for residents in the vicinity to this trail system." (5-14) These
• low elevation trails will "provide alternative hiking opportunities." (5-32). The EIS/EIR is
• deficient on the issue of potential adverse impacts of new perimeter trails on parking. The
document contains no inventory of the current trailheads or access points to the existing perimeter
• trails for the purpose of determining the type of and parking capacity (paved lot with individual
• slots, on city streets, unimproved lots, or ad hoc). This document does not list new perimeter
• trails and identify new trail heads or access points and indicate whether parking is available, what
• type and how much. The EIS/EIR has no information on current usage of the perimeter trails and
expected usage of future expanded perimeter trails system. That is, how will the new perimeter
• trails system impact existing parking facilities? Is there a need to create expanded parking
• facilities? Are there likely to be future conflicts with neighborhood residents because of expanded
• usage? The Mirage Trail provide and apt example. Currently that trail has a parking problem. A
perimeter trail connecting to the Mirage Trail will allow people to come from Palm Desert to
• Rancho Mirage and hikers up the Mirage Trail on to Palm Desert. This means the parking
• turnover time will be extended at the access points to the Mirage Trail exacerbating the current
• parking problem. This results from hikers not just going "up and back," but on toward Palm
• Desert and returning later. Shuttle parking brings more cars to the area, adding to the problem.
•
•
•
•
• 78
•
•
•
•
•
• 14. Effects of the Various Trails Plans (A, B, C and D) Upon Biological Resources
• (pages 5-17 to 5-32 and 5-46 to 5-69) =38 pages
• Terra Nova was to evaluate four trails plan alternatives: (A) continue trail avoidance program on 15
• trails, (B) institute a trails permit system on 9 trails and continue voluntary trail avoidance program
• on 6 trails, (C) close 26 trails from 1/1 to 6/30, and(D) allow unlimited access on 40 trails year
• round. Each alternative was to be evaluated in terms of its effects upon Peninsular bighorn ship.
• To determine the effects of each proposed alternative trails plan upon biological resources (namely
. bighorn sheep),the following criterion was put forth. "The trails Plan and the Alternatives would
• have a significant effect on biological resources if they have a substantial adverse effect, either
directly or indirectly , or through habitat modification, on any species identified as a Covered
• Species." (EIS/EIR page 5-17)
In order to operationalize and utilize the above criterion in a definitive manner, it is necessary to first
define"significant effect" and"substantial adverse effect." Terra Nova didn't define either of these
• key phases. In the absence of definitions the conclusions made by Terra Nova appear totally
• arbitrary.
Some 52 pages after stating their criterion„the authors concluded, "The impacts of the Proposed
Action/Preferred Alternative(B)would be less than significant." (5-69) What evidence was put
forth over 52 pages to support this conclusion? What analysis was put forth over 52 pages to
. support this conclusion? We can find no evidence and no analysis between page 5-17 and 5-69).
• What we did find was a series of claims and assertions. For example, nine times the authors
repeated the following:
•
"This trail is subject to the permit system as previously described,the intent of which is to
• minimize potential disturbance to Peninsular bighorn sheep. The level of use associated
• with the permit system is expected to result in minimum disturbance to bighorn sheep."
(page 5-24-5-69)
s
• We have a conditional reasoning model of the type, if(A), then(B). If(A), "intent"then (B)
"minimize"and if(A) "expected,"then(B) "minimum."No evidence, no theory, no logical way to .
• arrive at the above conclusion except to merely assert that it is true.
•
• We could just as well have said the following:
This trail is subject to unlimited permit system, as previous described(page 38-42 of this
response), the intent of which is to minimize potential disturbance to Peninsular bighorn sheep.
• The level of use associated with the unlimited permit system is expected to result in minimum
• disturbance to bighorn sheep.
• Why wouldn't this statement be equally valid? Answer: Because the authors hold an
• unsubstantiated belief that trail users adversely affect sheep.
•
•
• 79
•
•
•
•
• When it came to the other alternatives, Terra Nova concluded, "Alternatives A and D would have
• impacts to biological resources that could be significant." (5-69) Here again no data was presented
and no analysis undertaken. The authors offer up conditional verbs would and could. Authors
• assert Alternatives A and D would have impacts,not might have impacts. There is a certainty here
• that isn't supported by anything. But then the "impacts"are treated conditionally, they could be
• significant. When the authors were treating alternative B, the Preferred Alternative, they are now
certain about the impacts and say would be less than significant.
•
• Is it an acceptable practice for EIS/EIR authors to pick and chose conditional verbs to suit your
• purposes without subjecting the findings to evidence and analysis?
• Trail use
• Two paragraphs out of 100 pages were devoted to trail use (page 5-34). There are five published
• studies that deal with trail use and bighorn sheep (see pages 56-58 of this response).reve Only one of the
• studies was included here, (Hamilton 1982), even though a reading of Appendix C als EIS/EIR
authors were aware of the other four. Furthermore, the authors did not accurately convey
• Hamilton's finding. The author's wrote, "In a study in the San Gabriel Mountains, Hamilton 1982
• documented that bighorn sheep avoided areas when humans were present, but did not entirely
• abandon the area. The bighorn sheep may develop activity patterns in these areas that avoid times
• when trails are used by people." (EIS/EIR page 5-34)
• A summary of Hamilton's findings are:
. a. there was no correlation between number of people using the canyon and number of bighorn
• using the mineral lick
b. the presence of large numbers of hikers on the Devil's Backbone Trail, (over 50 per day) did
• not cause sheep to abandon adjacent habitat
• c. bighorn sheep using the mineral lick were not displaced by the presence of people in the canyon.• d. there was no significant difference in sheep distribution between the trail with heavy use and trail
• with light use.
• The authors cited(Campbell and Remington 1981) as source for their statement, "the bighorn sheep
• may develop activity patterns in these areas that avoid times when the trails are used by people."
• Campbell and Remington 1981 studied the influence of construction activities on water use patterns
of bighorn sheep. There research had nothing to do with trails!
•
sentence with the use of conditional and speculative language. "Alternatives A
Finally, when it came to an analysis of alternative trails plans A and D, they were dismissed in one
• and D would have
• impacts to biological resources that could be significant." (EIS/EIR page 5-69)
•
• What Terra Nova Could Have Done: compare Trail Use Data and Sheep Population Numbers:
• Table 10, on the next page, demonstrates for the Santa Rosa Mountains between 2001 and 2003, the
• number of trail users increased 38% and over that same period, the estimated sheep population
• increased 45%. That is, increased trail use apparently did not adversely affect the bighorn sheep. In
• fact, increased trail use of 38% in two years had no negative effects whatsoever. While this analysis
•
•
• 80
•
•
•
•
•
• is only a preliminary one, it is based upon the only evidence available. That would make it an
• improvement over Terra Nova that presented no evidence and no analysis.
• Table 10
•
• Estimated Trail Users and Bighorn Sheep Population
In the Santa Rosa Mountains
•
• Year Year
• 2001 2003 percent change
• Trail Users 3136 4312 38%increase
•
• Bighorn
• Population 102 148 45% increase
• ----------------------------------------------------- — ---------------------------
• notes: estimated trail use data from Terra Nova, (Appendix N— 16-17, USDI and USDA 2003)
• estimated sheep population for San Jacinto,Northern and Central Santa Rosa
• Mountains, (Table 1 of this response)
• The comparison of trail users and bighorn population in Table 10 covers the Northern and Central
. sections of the Santa Rosa Mountains. Eight-eight percent of the trails subject to the proposed Trails
• Plan restrictions reside in the Northern and Central Santa Rosa Mountains. It would appear from the
preliminary analysis provided in Table 10,the proposed Trails Plan isn't necessary and runs counter
• to the only evidence available.
•
• For the period 1996 to 2004,the sheep population in the San Jacinto and Santa Rosa Mountain
increased from 103 in 1996 to 330 in 2004. That amounts to over a 200% increase in sheep. While
• trail use data does not exist for that period, we know organized groups such as the Sierra Club,
• Desert Riders, Coachella Valley Hiking Club, Sun City Hiking Club, Desert Trails Hiking Club,
• Desert Cities Track Club, Desert Bicycle Club and Palm Springs Triathlon Club were using the trails
• along with individual residents and tourists. It would not be unreasonable to assume the number of
trails users increased over this eight year period. Thus increased trail use did not adversely affect the
• sheep population as it increased over 200%.
•
• We seem to have a strong direct correlation between trail use and sheep numbers. We don't suggest
that there exists a causal relationship between trail use and sheep number. However, if any data
• produced a strong inverse correlation between trail use and sheep numbers, we feel confident no one
• would bring up the caveat that this isn't causation. That would be sufficient for holders of the
• "belief system to call for trail restrictions. Why then, can't this be done in reverse?
•
•
•
•
•
81
•
•
•
•
•
• 15. Terminology: Language Clarity and Objectivity
• We find troubling a considerable number of phrases and generalities in The Plan.Notice the emotive
value(negative or positive) in the samples below. Then, there is the larger issue of few specific
• definitions, which makes comprehending difficult. For example, it appears that"minimal human
disturbance" is acceptable (see 7-68). But what constitutes "minimal human disturbance"? What
constitutes a"human disturbance?" Are these terms absolutes or relative? If relative,how do we
• make the following sample terms operational on some continuum? Why didn't CVAG's "trail plan"
follow the lead of The Endangered Species Act and contain a section at the beginning entitled
• "Definitions?"
ES 27 ---"significant adverse impacts"
• ES 28 --- "adverse impacts"
• ES 29 "passive recreation"
• ES 29 --- "minimal disturbance"
5-17 --- "potential disturbance"
• 5-17 --- "potential adverse effects"
• 7-68 --- "passive recreation"
• 7-68 --- "least sensitive"
7-63--- "disturbance to sensitive resource values"
• 7-68 --- "minimal disturbance"
9-286--- "human disturbance"
• 9-280 --- "reasonable level of use
• C-I --- "sensitive periods"
• Doesn't"sensitive periods" mean lambing season? If so why not say"lambing season?" If not just
lambing season, then some explanation should be given. The word"sensitive" is emotive use of
• language when nothing has been established through science to justify that word usage.
• The following quote appears twice in the Plan, once in the executive summary page 29 and again on
• page 7-68: "Excessive or uncontrolled access within the Conservation Areas can result in Habitat
• degradation and disruption of breeding and other critical wildlife functions at certain times of the
• year." In both incidents, the statement occurs without explanation, without defmition, and without
supporting evidence. Or as a conclusion derived from damaging evidence? Why was this? What
• standards are being applied? What constitutes "excessive access? Does "uncontrolled access"
• automatically imply"excessive access?" What would normal access look like? What unstated,
• untested assumptions lie embedded within this opinion statement? What assertions come forth
without support?
•
•
•
•
•
• 82
•
•
•
•
•
•
• 16.Inconsistencies: Language and Rationale
• After a close reading of the "trails plan" and considerable research, we are troubled by
• inconsistencies and lack of empirical support in the document. We are troubled by obvious
• contradictions and use of arbitrary standards. Some examples:
One:
Plan authors say, "A public use and trails plan is needed to provide for trail use in bighorn sheep
• Habitat that is compatible with bighorn sheep Conservation Goals and that affords a reasonable
. level of use to the public." (9-280) Since the sheep have been in recovery for eight straight years,
• are at a twenty year high in our area and appears to have reached the targeted recovery level of 750
this year, how can a trails plan the ratchets tip trail rationing to where seven out of ten citizens who
• will seek permits in 2006 be considered reasonable from any standpoint? These draconian
• measures would seem appropriate if the sheep had been in decline for eight straight years, if the
• sheep were at a twenty year low and were at fifty percent of their targeted de-listing level.
• Two:
• One paragraph (page 7-68)within the large Plan document asserts that passive recreational activities
• (i.e., hiking, bird watching,photography) do not impact land within the MSHCP Reserve System
• and cause a minimal disturbance to biological resources. Even though minimal disturbance is not
defined, it's hard to believe a minimal disturbance would be viewed as a significant factor in bighorn
• population trends. Why would the Plan give rationing trail usage such a priority position? This
• paragraph seems at odds with the rest of the Plan.
• Three:
• The Clara Burgess Trail in the Santa Rosa Mountains is included as part of the "seasonal trail area."
• Furthermore,this trail is one of seven trails covered by the "trail permit program." This program
• seeks to restrict trail use during the lambing season. However,the Palms Hills Project's team of five
• field biologists successfully refuted claims by the CDFG and the Bighorn Institute that sheep
currently inhabit the project area or have utilized this area in recent years. The prime area in
• question consists in and around Eagle Canyon. If no sheep exist in this area then this Palm Springs
• development project will apparently not be in conflict with the species conservation goals and
• objectives pertaining to Peninsular Bighorn sheep as spelled out in(9-201-202). But if no sheep
exist in this area then the Clara Burgess Trail must not be included in the seasonal trail area and not
• be subject to the trail permit program. On the other hand, if the claims by the Palms Hills Project
• can be found incorrect and if sheep do exist in the Eagle Canyon area then rationale for placing the
• Clara Burgess Trail in the seasonal trail program appears supported. However, now the Palms Hill
• Project would be in conflict with species conservation goals and objectives pertaining to Peninsular
bighorn sheep outlined in the Plan (9-201-202). A major inconsistency exists somewhere. One
can't have both a permitted Clara Burgess and a Palms Hill Project. This dichotomy is apparently
• now settled. "CDFG correspondence dated February 13, 2001 from Deputy Director Terry M.
• Mansfield, Wildlife and Inland Fisheries Division, acknowledged that the CDFG has no scientific
data recording of Peninsular bighorn sheep ever using the Palm Hills site." (The Keith Companies,
• June 2003, section II,pg 15). Also, Jim DeForge, Executive Director of the Bighorn Institute stated
in interviews conducted in 1994 and 1999 that the bighorn sheep were rarely seen in the Eagle
• Canyon area(Cornett, 1999, p.26). Additionally,the BLM stated, "Data from USFWS (2000) show
•
• 83
•
•
•
•
•
• few observations made of bighorn sheep in the Murray Hill area--- given the level of reported use of
• Murray Hill area by bighorn sheep, the impacts from people using these facilities would likely be
minimal." (BLM, 2002, chapter 4, page 10)
•
• Four:
• CVAG acknowledges one document served as the basis of the trails plan. The Executive Summary of
the ADP states on page 2: "The Peninsular bighorn sheep conservation strategy was based primarily on
• the Recovery Plan for Bighorn Sheep in the Peninsular Ranges. California." (USFWS 2000) Our
research finds the Recovery Plan deficient in scientific support, relying on claims and assumptions and
• containing inconsistencies. For example, on page 87 of the Recover,the authors say, "Trails that
are currently known to result in disturbance to lambing and rearing habitat are listed in Table 10."
• However,when one turns to Table 10 on page 88, it is entitled"Trails and Areas with Potential
• Conflicts That Should be Addressed in an Interagency Trails Management Plan." We can't determine
• the correct term because data are not supplied. Which of these terms potential or known is supported by
the data? Which of these terms potential or known was subsumed when writing the trails plan?
• Again on page 14 of the Recovery PI the authors claim"human presence or activity in many cases
• has been found to detrimentally alter normal behavior and habitat use patterns." But the "human
• presence or activity"turns out not to be recreational trail users but paved roads and their traffic,
• motorcycle activity, and researcher/observer intentional harassment(cross country stalking) of
bighorn sheep. Then again on page 43 of the Recovery Plan the authors refer to a variety of human
• activities (including hiking)that have"potential"to harm bighorn sheep. The point here is that the
• "recovery plan" shifts back and forth between saying"potential,"they don't know at present and are
• speculating or"known," suggesting there are studies documenting such outcomes.
• Five:
• The "trails plan" does not appear to be based upon an analysis of the best empirical evidence. It
• provides no references to recent bighorn sheep population data. The record of past seven years'
• sheep population growth, which we provided CVAG at the March 25, 2004 Project Advisory Group
Meeting, does not support a policy of trail rationing.
•
• Six:
• The BLM estimated the demand for the five most popular trails scheduled for permitting at 9 users
per day (BLM, 2004). CVAG then proposed a permit system that would limit these same five trails
• to a maximum of 4.6 users per day(see Table 4). What is the empirical support for this level of use?
In the summer of 1981, researchers studied recreational trail use in the San Gabriel Mountains. The
• three most popular trails on Mt. Antonio averaged 40 hikers a day without adverse effects upon the
bighorn sheep (Hamilton and Douglas, 1982). Isn't this an example of empirical support for
• considerably more use than allowed in the PLAN?
•
• Seven:
• We can find no evidence that the "trails plan" evolved from a review of published research. From
1897 to 1999, 627 publications of bighorn sheep in the United States were documented. Fifty of
• these studies involved human impacts upon bighorn sheep. We have found none of these 50
publications produced data and findings linking the population of bighorn sheep to recreational trail
• usage. Thus, evidentiary foundation for the trail rationing policy in the PLAN doesn't exist.
•
• 84
•
•
•
•
•
•
• Eight:
• Studies in California have concluded that bighorn sheep do adapt or habituate to expected,regular
and predictable human activity such as hikers on trails. For the Sierra Nevada see (Wehausen 1977,
• Hicks and Elder, 1979 and Wehausen 2000). For the San Gabriel Mountains, see (Hamilton 1982,
• Holl and Bleich 1987). In 1994,the bighorn sheep in the Santa Rosa Mountains began their
• recovery. This recovery continued each year along with Lmrestricted access to trails for seven years
• or until 2000. Now for 2006, the PLAN proposes trail rationing despite yearly increases in the sheep
population. The PLAN proposes for 2006, 60 percent fewer trail users than existed in 1999. This
• would average to about 3 or 4 people per day! How does this fit the conditions for habituation that
• require expected,regular and predictable human activity? If the Plan champions the use of
• "adaptive management," why doesn't the Plan's policy proposals adapt to conditions that will allow
the bighorn sheep to successfully habituate to trail users?
•
• Nine:
• Because no scientific evidence exist claiming trail users adversely affect bighorn sheep,the authors
of the Plan must use conditional language. When the plan wants to promote a trail, the conditional
• language goes one way and when they don't want a trail used the conditional language goes another
• way. For example,the Plan wants to place new restrictions upon mountain biking so they say
• mountain biking"MAY result to trails such as increased erosion or other alteration of trail tread or
• location." (EIS/EIR page 5-75) Then when they want the Palm Desert to La Quinta Connector
Trail built,they say, "increased human activity (near the Bighorn Institute's captive sheep pens)
• MAY NOT disturb them (captive sheep) as much as it would wild sheep populations." (EIS/EIR
• page 5-33) This is making your case not by presenting empirical evidence or marshalling a
• theoretical argument but simply putting forth a possibility or conditional statement. The persuasive
power of such an approach is about zero within the scientific community.
•
• Ten:
• The authors cite (Papouchis 2001) as the source for their standard that the Palm Desert to La Quinta
• Connector Trail be 200 meters away from lamb rearing habitat and thus not adversely affecting the
captive sheep. If this same standard was applied to the trails targeted for permitting and voluntary
• avoidance, I believe most trails would not qualify for rationing. But there is an additional problem.
• Papouchis 2001 puts forth no such standard in that study. One can only speculate how the authors
• came up with that standard from the Papouchis study. A major inconsistency exists! Which way do
the authors want to proceed? They can't have it both ways! The authors feel that adopting the 200
• meter standard frees them from the accusations that the corrector trail will disturb and adversely
• affect the captive sheep in the pens at the Bighorn Institute. But adopting this 200 meter standard
• will scuttle the trails rationing approach of the trails plan, since most trails or trail segments can
• comply with the 200 meter standard.
• Eleven:
• Why did the Plan feel it wasn't necessary to present bighorn population trend figures when
• presenting their plan to the public and then turn around and say one of the first annual tasks of the
Trails Management Subcommittee "would include an assessment of bighorn population trends."
• (EIS/EIR page 2-63) What are the authors saying? The public doesn't need to know but the
• subcommittee does not!
•
•
• 85
•
•
•
•
•
• Twelve:
• We previous questioned why no population data weren't present. Now at the end of EIS/EIR
treatment of the "trails plan" (page5-98) it claims an Adaptive Management approach can allow
• greater trail access (more permits) provided this is "consistent with progress in recovery of bighorn
• sheep." That should read upward trend figures for numbers of sheep. What would be considered
• progress? How about eight straight years of increase with a jump of 150%? What standard is being
• applied?Why are authors talking population figures now at the end, when the authors were
unwilling to do so at the outset?
•
• Thirteen:
• California Fish and Game wildlife biologist Kevin Brennan who studies bighorn sheep in the Plan
area said, "there is no evidence to support limiting permits in the Coachella Valley to 2,300
• individuals. That number is completely arbitrary." ( Spillman, Benjamin, 2004)
•
• Fourteen:
When CVAG wanted to justify the connector trail between Palm Desert and La Quinta, it had Katie
• Barrows, during the December 4"'public comment meeting, show a power point slide indicating the
• trail was 6/10 of a mile away from the breeding pens of the Bighorn Institute. In others words,the
• trail being that distance away posed no problem for the captive sheep. Then when it comes to trails
CVAG does not want used, a distance of twice that much of 1.2 miles isn't enough for bighorn in the
• wild. Witness the arguments CVAG made on the Clara Burgess Trail and the Mirage Trail.
•
• Fifteen:
• When CVAG wants a trail to be built or used this is how they reason:
"A potential indirect impact of constructing a trail in this area could include hiker leaving
• the trail and traveling cross country ... The limited visibility and rugged intervening
• terrain are expected to limit this potential, which is considered to be low. Given the limited
• line of sight visibility between the pens and the trail, due to distance and intervening
• terrain, and the nature and predictability of the use, hikers on this trail will have a less than
significant effect on captive sheep." (5-40)
•
• When CVAG doesn't want a trail to be built or used:
• "Trail users would have access to the US property, could leave the trail, and may a
adversely impact ongoing research studies. This Alignment would impact a large area of
• alluvial fan habitat in Deep Canyon which has previously not had recreational disturbance.
The may negatively affect the station's conservation and educational objectives." (5-41)
When CVAG does want a trail to be built or used:
• "The Bighorn Institute is located immediately south of this Alignment.... The alignment
• would impact the conservation buffer established to insulate the Bighorn Institute from
• adjacent residential development. Trail users would have access to and a view of the
• Institutes facilities. Trail users could leave the trail and may adversely impact Institute
research activities." (5-42)
• Note the verbs highlighted in the above three quotes. WILL and WOULD are verbs expressing
certainty. MAY is a verb expressing a possibility. In the first quote CVAG uses, WILL, the verb of
• certainty to make its case for the trail alternative it wants. In the second and third quotes, CVAG
•
• 86
•
•
•
•
•
•
• arbitrarily uses MAY and COULD,the verbs of possibility when its wants to build negative case
• results. It also uses WOULD, the verb of certainly to build negative case results. No evidence is
offered and these verbs are used arbitrarily. For example, trail uses WOULD have access under the
• second and third quotes, but the first quote leaves one with the impressing that hikers would not
• have access. These three quotes bear witness to arbitrary and sloppy reasoning and statements that
• are logically inconsistent.
• Sixteen:
• Terra Nova, author of the EIS/EIR claimed 4,000 individual permits and 50 group permits, up to
• 5,500 people would exceed the estimated use levels for the period 2001-2003. Terra Nova went on
• to argue "further increasing the number of individual permits (to 4,000) is considered to be an
increased impact to bighorn sheep that would not accomplish the project objective of balancing
• recreation use and bighorn sheep conservation." But in May 2003, Terra Nova, estimated actual
• annual trail use at 3,126 in 2001, 4,180 in 2002 and 4,312 in 2003. (BLM 2003, Appendix N 17).
• All figures are for estimated non-compliant users. Thus between 2001 and 2003, estimated actual
users increased 37.5% and the estimated sheep population increased 45% for the same period. More
• trail users and more sheep.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• 87
•
•
•
•
•
• 17. Trails Management Subcommittee
• This group of people will play an important role in evaluating the effectiveness of all trail
• management policy decisions. It will interpret data from monitoring programs and evaluate research
• results. The 15-member body will be comprised of trail user groups, research interests, environment
• interests, city governments, county governments, state and federal agencies. We suggest that at least
eieht of the 15 members should be drawn from Coachella Valley trail user groups which include
• hikers, horseback riders, trail runners, and mountain bikers. These users are out on the Plan area
• trails on a regular basis and are in a strategic position to help interpret data and formulate
• recommendations for the Plan area as a whole.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• ss
•
•
•
•
•
• 18. An Analysis of the Proposed Action/Preferred Alternative B: Part A
• From early December 2003 to early November 2004 we studied the Final Administrative Draft of
• the CVMSHGCP and attended the monthly Project Advisory Group meetings. Every time we raised
• questions at CVAG's monthly project advisory group meetings about evidence, and rationale for the
• PLAN, we were told by Katie Barrows and Jim Sullivan that all the evidence, rationale and analysis
would be found in the EIS/EIR. November 5, 2004 the EIS/EIR was released to the public.
•
• What follows is our analysis of the Proposed Action/Preferred Alternative B as presented in
• Chapter 5 of the EIS/EIR along with Appendix C and J.
• The authors specified the following criterion for determining "significance." of a trails plan upon
• biological resources (bighorn sheep). The Trails Plan and the alternatives would have a significant
• effect on biological resources (bighorn sheep) if they have a substantial adverse effect, either directly
• or indirectly or through habitat modification on the bighorn sheep (page5-17). Unfortunately, the
authors failed to operationalize their criterion"substantial adverse effect"because no definition was
• formulated.
•
• Appendix C contains a literature review of 38 articles on human disturbance and bighorn sheep.
Only five of the 38 articles were studies of recreational trails user and bighorn sheep. All five of
• these articles concluded that recreational trail users did not adversely affect bighorn sheep. Thus, the
• best available science available to the authors of the EIS/EIR concluded there was no "significance"
• of past and current recreational trail users. Since there was no adverse effect,there certainly was no
• "substantial adverse effect." The foundation support for Proposed Action/Preferred Alternative B is
not to be found in Appendix C and its review of the scientific literature. For a more detailed look at
• Appendix C,refer to the next section, 19.
•
Now what? The fall back position for the authors is to now talk in only in terms of"potential"
• impacts to bighorn sheep." (page 5-17) (page 2-59)
• When the recovery team wrote the Recovery Plan for PBS in 1999 there wasn't any science to
• support trail closures or trails rationing so when the report came out it referred over again to
• potential conflict between certain trails and bighorn sheep. Now FIVE years later there still
isn't any science to support trail closures or trail rationing so the authors just repeated the
• recovery line about potential conflict. But now they think that is enough to support a policy of
• trail rationing. (page 2-69)
• The authors repeated eight times, between pages 5-24 and 5-28, that the intent of the permit system
• is to minimize potential disturbance to Peninsular bighorn sheep. An action is proposed to cure a
• problem that has never been established. Claiming an intent to do good does not establish that the
• action is in fact a good one. In this case recreational trail users are being punished for their actions—
• hiking, when the fact of hiking has never been established as harmful to bighorn sheep.
• Occasionally,the authors slip and forget to use the conditional language of MAY or CAN and
• express themselves in the semantics of certainty. For example, "This program(public awareness
•
•
• 89
•
•
•
•
•
•
• and education) would increase the likelihood of trail users complying with the Season Trail Program,
• thereby reducing the adverse impact upon sheep." (page 2-63 and 5-31)
• In conclusion,the authors have failed to demonstrate that any of the four trail plan alternatives
• would"have a substantial adverse effect, either direct or indirect or through habitat modification" on
• bighorn sheep. The word"have" subsumes knowledge, awareness, and an evidentiary base. The
authors failed to satisfy the only criterion they put forth because they had to fall back on the
• possible, the potential, and the maybe. This produced the unfortunate result that the authors had no
• empirical or theoretical foundational support for their trails plan and were left with nothing more
• than an undocumented, untested"belief system"that goes against the best science available today.
• Appendix C indicates an Interagency Wildlife Biologist Working Group met eight times. This group
• undertook"a critical evaluation of trails and areas listed in Table 10 of the Recovery Plan for-
• Bighorn Sheep in the Peninsular Ranges, California as having potential conflicts that should be
• addressed in an interagency trails management plan." What constitutes a"critical evaluation?"
What data was used in this "critical evaluation?" What specific scientific literature was used in this
• "critical evaluation?" What written work resulted from this "critical evaluations?" Did "potential
• conflicts"remain potential or after the "critical evaluation" did they become"known and established
• conflicts?" Would CVAG be willing to publish the minutes from the eight"working group"
meetings?
•
• Appendix C states, "knowledge of how sheep react or interact with trail users"was identified as a
• key element in the development of a logical and biologically meaningful trails management plan for
• PBS (C-3). What did the literature review uncover? What specific sources can be identified that
studied how sheep react or interact with TRAIL USERS?
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• 90
•
•
•
•
•
• 19. An Analysis of the Proposed Action/Preferred Alternative: Part B
Section 11, Model Building: Variables Affecting Population Levels of Bighorn Sheep identified
eleven variables (see Table 6). To hopefully play a positive role in the by then decade long
• successful recovery of bighorn sheep the Plan adopted a preferred alternative that included specific
. policy action on only one of the eleven variables, recreation trail users. Recreational trail users
• include, hikers, horseback riders,trail walker/runners, mountain bikers, photographers,bird watchers
and landscape painters. Nowhere in the plan is there a specific course of action to affect any of these
• six variables for the specific purpose of aiding the recovery of the sheep. There are objectives and
• general goals but no actions. (see, 1, 2, 3, 5, and 6, 9-203). But one, variable RTU(recreational
• trail use) is selected for specific action(see 4, 9-203). It is true, however,that the Plan seeks to
maintain and expand habitat for ALL 27 species through land swaps, purchases and designations.
•
Nowhere in the Plan or the EIS/EIR can we find an analysis of the decline in bighorn sheep that
• suggests the sheep became endangered because recreation trail use was a key variable bringing about
• their decline in numbers. However, some combination of variables 1 through 6 appears consistently.
in research as the responsible agents causing the decline in sheep population. These models look
• like equation(1):
• (1) BSP=f(HL, HF, HD, P, CF, DI)*
•
•
• The dependent variable, bighorn sheep population is inversely related to the independent variables;
• habitat loss,habitat fragmentation, habitat degradation, predation, climatic factors and disease. A
sample of research highlighting these causal variables include.**
•
• Equation(2) appears a favorite of most researchers to account for most of the decline of sheep in the
• post WWII period:
• (2) BSP=f(P, DI)
------------
* In equation(1): BSP =bighorn sheep population, f=is a function of, HL =habitat loss, HF=
habitat fragmentation, HD =habitat degradation, P=predation, CF=climatic factors: temperature
• and precipitation, and DI=disease.
**HL,HF,HD (Center for Biological Diversity 2003, Hansen 1982,Holl 2004, USF&WS 1998);
• P (Bodenchuk et al. 2002, DeForge et al. 1995, DeForge 2002, Ernest 2002, Hass 1989, 1982,
Hayes, et al. 2000, Holl 2004, Jorgensen 1998, Mooring, et al. 2004, Rubin et al. 1998, Rubin 2002,
• Schaefer 2000, Sawyer and Lindzey 2002, Torres et al. 1996,USF &WS 2003, Wehausen 1996,
• Wood 1998); CF Douglas and Leslie 1986, Jorgensen 1998, Goodson 1999, Epps 2004, Wehausen
• et al. 1987); and DI (DeForge and Scott 1982, DeForge, et al., 1982, DeForce 2002, DeForge 1984,
Hansen 1982, Mouton et al. 1991,Mullens and Dada 1992, Toweill 2003, USF&WS Recovery Plan,
• 2000,USF&WS 2003
•
•
•
• 91
•
•
•
•
•
• Predation and disease appear to be the main culprits. Public policy interventions took place to
• reduce the power of these two variables in the 80's and 90's. Given the bottoming out of the
population in 1996, these interventions appear to have been in some degree successful. We can
• identify no researcher investigating the decline of the bighorn Sheep population of the Post WWII
• period that suggested equation(3):
• (3) BSP = f (RTU)
•
• That is,the decline in the bighorn sheep population is inversely related to one variable,
• recreational trail use.
• Since 1997, the population of bighorn sheep has been in recovery. Certainly, the sheep remain
• endangered, but for the first time in the Post WWII period their numbers are increasing. By the
• time US Fish and Wildlife published Recovery Plan for Bighorn Peninsular Sheep in the
• Peninsular Ranges, California in 2000,the sheep had been in recovery for four years (see Table 1).
The year 2006 could be the earliest date for implementing the Preferred Alternative and by then it
• is possible the sheep will have been in recovery for a decade.
•
Presumably the aim of any public policy action now is to further the successful recovery already
underway and move them off the endangered list. Why then is the preferred alternative nothing
• more than BSP=f(RTU) or equation(3)? Why was this one variable singled out as the key
• variable? How is it that equation(3) is unidirectional? That is,taking the stand that decreasing
• recreational trail use will increase the sheep population, when in the 50's, 60's, 70's and 80's it was
never suggested that increasing recreation trail use caused a decline in the sheep population.
•
• To become more precise in our analysis,we need to refine the definition of bighorn sheep
• population. We have already demonstrated in section 2, that the problem of population is not
• connected to rutting,mating, or conception. That is,the population problem is not one of
reproduction but survivorship. Thus we modify equation(3) into (3A)to focus on lamb survival.*
•
• (3A) LS =f(RTU)
• The preferred alternative equation becomes centered on lamb survival and is inversely related to
• recreation trail use. Putting it another way, (3A) says lamb survival increases with decreased
recreational trail use.** We can find no research that posits this relationship?. So the Plan is poised
• to spend thousands, maybe hundreds of thousands of dollars on research to establish the relationship
• presented in equation(3A). It will likely take ten years to issue the call for proposals, to review
• ------------
• * In this general formulation sheep survivorship takes on three forms, lamb,yearling, and adult. Equation
(3A)could be modified to include YS and AS. Why is it that neither the Plan nor the EIS/EIR focuses upon
• lamb survival? Where is the analysis in the Plan and EIS/ElR of factors affecting recruitment rates?
•
• * * The seasonal trail closures begin January 15 and end June 30. Thus,these closures assumes trail users
adversely affect lambs (increase lamb mortality)during the first six months of life
•
•
92
•
•
•
•
•
•
• proposals, to fund projects,to complete the research and publish the results. We believe that future
• research, like all research of the past, will produce no definitive answers to establish the link of the
Preferred Alternative or equation (3A). By this late date, 2016,the Peninsular bighorn sheep could
• very well be off the list of endangered species. Or if Peninsular bighorn sheep are not de-listed what
• will be the course of public policy ten years from now? Probably back to equation(4) because
• researchers have suggested all along that equation (4) is important in explaining lamb mortality:
• (4) LS =f(P, DI, CF)*
•
• Two of these three variables can become policy variables. The third, climatic factors: temperature
• and precipitation cannot. Why wasn't predation selected as the policy variable to increase the
survival of lambs (and adult sheep)through a program of selective removal. We know lowering
• predation works. Disease can be monitored and intervention taken to counteract an outbreak.
• New water sources can be created in case drought becomes a key variable in any year or years.**
• These proactive actions are proven to enhance survival rates.
• While public policy interventions have worked for the variables predation, disease and
drought,*** we have absolutely no evidence that recreational trail use has any link to lamb
• survival rates. Why would the lead agency, U.S. Fish and Wildlife Service want to GAMBLE the
future of the bighorn sheep population on a variable that offers no historical support or logical
• preference?
•
• We don't question that some field biologists and agency public policy personnel BELIEVE that
• recreational trail users are a key variable in the recovery of sheep. Whereas belief systems may be
necessM to initiate a public policy decision, they are not sufficient grounds for'public_policy
• legislation. In order for a public policy decision to avoid reducing the public good, it must be
• evidence based along with a supporting rationale that is consistent with the evidence.
Why would the U.S. Fish and Wildlife Service RISK jeopardizing the positive initial steps in
recovery that have taken place by endorsing the newly Preferred Alternative, in preference to an
• alternative that contains variables that have historical support? Why did the U.S. Fish and Wildlife
• Service not choose to endorse a preferred alternative that addressed habitat fragmentation and
• habitat degradation? Could it be that recreational trail users are the weakest link? The easiest
• target? The group with the least political power and or constituency? Is the preferred alternative
the easiest course of action to provide the impression that action has been taken on behalf of an
• endangered species?
*CF: precipitation and temperature: some lambs never survive the high temperatures of the summer
months and lack of precipitation during gestation can increase lamb mortality
•
• ** Public policy intervention using three variables of equation(4)will likely also cause increases in
yearling and adult survivorship.
•
• *** Mother public policy intervention used to augment and stimulate the population of bighorn sheep is a
• release program. In the spring of 2004,the Bighorn Institute released young ewes into the Tahquitz Canyon
area of the San Jacinto Mountains. Director Jim DeForge believes the small and stable population that
• existed for years in this region may finally getjump started to new levels. "Bighorn Institute has released
• 96 adult bighorn fi•om captive breeding facilities into the wild since 1985."(Bighorn Institute,2004,p. 5)
•
• 93
•
•
•
•
•
• 20. An Analysis of Appendix C of the EIS/EIR
• Authors of the EIS/EIR wrote, "Appendix C provides the primary information and concepts about
• bighorn sheep that resulted in formulation of the Trails Plan" (page 5-1). If the"information and
• concepts"presented in Appendix C prove to be not applicable, misleading, and not the best science
• available, then it would follow that the Trails Plan is likely flawed. In what follows we shall make
• just that case.
• Appendix C: Santa Rosa and San Jacinto Mountains Trails Plan Technical Appendix was prepared
• by the Bureau of Land Management in Palm Springs. The BLM staff did a literature review that
• "focused on available knowledge of the effects of TRAIL USE on bighorn sheep, including captive
sheep" (C-1). According to the authors one of the key elements identified for"the development of a
• logical and biologically meaningful trail management plan for Peninsular bighorn sheep was
• "knowledge of how sheep react or interact with TRAIL USERS" (C-3)They went on, "With these
• understandings, it is possible to begin to determine how human activity may influence, or at times,
disrupt an individual bighorn use of its habitat and to what degree that disruption may impact the life
• cycle of an individual or threaten its existence" (C-3)
•
In the section, "Trail Use, Human Disturbance and Bighorn Sheep,"the authors cite various studies
• that purportedly contain information and concepts about trail use, human disturbance and bighorn
sheep. Tables 11A and 11B lists the studies cited. A total of 39 studies were cited 126 times in this
• section of the technical appendix. ONLY FIVE of the 39 studies dealt with trail users (see Table
• 11B).* Interestingly, none of the five studies of trail users provided any rationale or support for a
• trails plan that incorporated trails rationing. All five studies concluded that trail users were not
harmful to bighorn sheep. The other 34 studies (see Table 11A) contain no information or concepts
• on trail users and bighorn sheep and these studies were cited 87 percent of the time in Appendix C.
• Section A of Table 11A shows five of the studies that utilized a methodology best described as
• intentional researcher/observer harassment trials of bighorn sheep.** One third of all citations used
in this section were from these five studies that have no relevance to trail users. These studies were
• cited as containing information and concepts about trail use, human disturbance and bighorn sheep
despite BLM's disclaimer back in 2003 that actual hikers are likely to behave differently than
• researchers undertaking these harassment trials. Section B of Table 11A contains six studies of non-
recreational human disturbance such as construction projects, urbanization/housing and roads,
helicopter over flights and travel corridors. Again these sources have no information or concepts on
• trail users. Section C of Table 11A lists six studies on non-trail user recreation such as, camping
and dogs, all terrain vehicle use, hunting bighorn, winter sports and river boats. Finally, Section D
• of Table I IA includes general studies on bighorn sheep,not specific studies of human disturbance
• or trail use. Examples include studies of sheep habitat,mineral licks, diet, disease and general
bighorn sheep ecology.
•
* For a detailed description of these five studies, see pages 61-62 of this response
** For a detailed description of these five studies, see pages 63-64 of this response
•
•
•
•
94
•
•
•
•
•
• Table 11A: Studies Cited on "Trail Use,Human Disturbance and Bighorn Sheep"
• With No Information or Concepts on Trail Users
• Author and Year Times Cited
• A. Intentional Researcher/Observer Harassment of Bighorn Sheep
• MacArthur et al. 1979 4
• MacArthur et al. 1982 10
Miller and Smith 1985 9
• King and Workman 1986 7
• Papochis et al. 2000 11
• Blong 1967 1
42
• B. Non-Recreational Human Disturbance of Bighorn Sheep
Leslie and Douglas 1980 3
Campbell and Remington 1981 3
Bleich et al. 1994 1
• Ough and Devos 1984 2
Etchberger et al. 1989 3
• Martucci et al. 1992 1
• 13
• C. Non-Trail User Recreational Disturbance of Bighorn Sheep
• Jorgensen 1974 4
• Light and Weaver 1973 4
• Goodson et al. 1999 1
Harris 1992 1
• Thorne et al. 1978 1
• Horejsi 1976 1
12
D. Non-Trail User,Non-Human Disturbance: General Bighorn Studies
Hansen 1980 1
Rubin et al.2000 1
• DeForge 1997 1
• DeForge 1972 1
• Wehausen 1980 13
Wehausen 1983 3
• Geist 1971 9
• McCarty and Bailey 1994 4
Holl and Bleich 1983 1
• Cunningham 1982 1
• Wagner and Peek 1999 2
• Krauseman et al. 2000 1
Dunaway 1971 1
• Platt 1964 1
• Quinn and Dunham 1983 2
Berger 1978 1
• 43
•
• 95
•
•
•
•
•
•
• Table 11B: Studies Cited in Appendix Con "Trail Use,Human Disturbance and
• Bighorn Sheep"With Information or Concepts on Trail Users
• Author and Year Times Cited
• Wehausen 1977 2
• Hicks and Elder 1979 4
Purdy and Shaw 1981 2
• Hamilton et at. 1982 7
• Wehausen 2000 1
• 16
•
•
•
• In conclusion, all source material cited in Appendix C has been examined. Authors of
• the EIS/BIR claimed, "Appendix C provides the primary information and concepts about
• bighorn sheep that resulted in formation of the Trails Plan." There was NO information
or concepts in this appendix to support a trails plan of trail rationing. The trails plan is
• not an example of using the best available science. Because the best available science
• consisted of five studies that concluded trail users were not harmful to bighorn sheep and
• these finding were ignored when formulating the trails plan. Thus, there is no empirical
• or theoretical foundation under the proposed"trails plan." No evidence exists to support
it.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• 96
•
•
•
•
•
• 21. The Best Available Science Standard
• The Executive Summary opens with a statement about the Plan development:
• "The conservation plan was developed in consultation with the Scientific Advisory
• Committee, using best available science." (ES-3)
Also, in establishing the conservation planning methodology to be followed wlrile developing the
conservation Plan,the authors of the Plan asserted the adoption of the "best available science"
• standard as described below: (Appendix I, page 17-18).
"From the outset, a goal was established to base the preparation of this Plan on a strong
foundation of scientific data and ecological principles. The importance of establishing a
• baseline of scientif c credible data has been emphasized in several recent reviews of the
• HCP process (Noss et al. 1997, Hood 1998, Harding et al. 2001). The USFWS addresses
• the need for use of the "best available science in their policy document on HCP
preparation,including the Habitat Conservation Planning Handbook(USFWS and NMFS
• 1996). This handbook calls for the availability of up-to-date biological information on the
• species being considered within the Plan area. It also recognizes, however, that for
• habitat-based HCPs the protection of habitat types for a particular species through an
• HCP and associated mitigation program may obviate the need for additional distribution
studies. The California Natural Communities Conservation Plan (NCCP) guidelines state
• as a criterion: "The Plan provides a conservation strategy that is based on recognized
• principles of conservation biology, as well as the best available scientific information
• about species and habitats. "
• "In the initial phases of this Plan's development efforts were focused on gathering all
• available information on the Covered species and conserved natural communities. The
• effort to obtain and review up-to-date biological information was ongoing throughout the
• preparation of the Plan. "
• Unfortunately when it came to the "trails plan"and bighorn sheep, the "best available science"
• standard described above was not adhered to.
• The"trails plan" contained no science as a foundation. Not a single peer reviewed published study
• on trail users was cited as evidence for"trail plan"policies.
The trails plan consisted entirely of untested assumptions, conditional statements, and value
• judgments.
• Instead, "trails plan" authors improperly cited five studies of intentional/researcher/observer
• harassment trials of bighorn sheep that had nothing to do with trail users. (see, pages 58-60 of this
• response)
• The "best available science"on trail users consisted of five studies that were ignored by"trails plan"
• authors because these studies were in conflict with the policies suggested by "trails plan"authors.
•
•
• 97
•
•
•
•
•
•
Population estimates of Peninsular bighorn sheep from 1983 to 2003 was available to Plan authors,
yet they elected not to include the data in any of their analyses or to provide it to the public as
• informational background. Plan authors acknowledge on page 8-81 that population data on bighorn
• sheep has been gathered regularly over the years. Thus, again the"best available science"was not
• included in the draft Plan.
• In summary, authors of the"trails plan" failed to live up to and abide by the standard of the"best
• available science" as set forth in the Plan documents. Authors of the "trails plan"failed to live up to
• and abide by the standard of the "best available science" as set forth in the 1973 Endangered Species
• Act.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• 98
•
•
•
•
•
•
• 22. Miscellaneous Questions
•
• Appendix C: Is there published research on bighorn sheep response to recreation-trail use in the
• Plan area? I am not aware that the Plan identifies any.
• 7-68-7.4.2.2,under heading 2: Where are the least sensitive portions? Can a map be referenced?
• Are there currently trails in these areas?
•
• 7-69: What does it mean, "...trail heads will be sited at the edge of the resource area"?
• 7-70 point 10: "The Reserve Lands will be patrolled on a regular basis in order to insure that visitors
• stay on trails and observe other rules and guidelines." Patrolled by whom? What does `regular'
• mean? How strictly enforced? Estimated agency budget?
• It appears that cross-country hiking is discouraged or even prohibited. Will you please present the
• evidentiary basis for this policy position?
•
• The December 1, 2003 draft Plan stated on(page 7-56) and the October 2004 draft Plan stated on
• (page 8-77) , "...research designed to ascertain bighorn sheep response to, and any significant
adverse impacts from, recreational trail use." Again, the December 1, 2003 draft Plan (page 7-60)
• and the October 2004 draft Plan (page 7-60) mentions "a cooperative research program among
• Wildlife Agencies, CVCC and BLM to examine bighorn sheep response to recreational trail use."
• Can we know more details?
• EIS/EIR 5-67—What is the basis for the statement, "the already successful Voluntary Trail
• Avoidance Program?"
•
•
•
i
•
•
•
•
•
•
•
•
•
•
•
•
• 99
•
•
•
•
•
•
•
• 23. Coachella Valley Hiking Club's Trails Plan: An Outline
• The following is an outline of a trails plan we believe the general public could understand, would see
• as reasonable and therefore respect and support. The decade long recovery of Penisular bighorn sheep
• calls not for major surgery but minor surgery. This plan would provide trail user data that is sorely
• lacking at present. This plan would facilitate improved trail behavior of those venturing into the
mountains. This plan would use the scarce government resources to enforce a failed BLM dogs on
• lease and no dogs beyond this point program. This plan will reinforce and maintain the current
• standard of respectful trail use. Humans and bighorns sheep will be well served by this plan.
1. Year round open access to trails within the Plan area
2. A research oriented permitting system for designated trails modeled after the system used
• above the tram. Each year the Trails Management Sub-Committee would monitor the research
• oriented permitting system as well as the population estimates of bighorn sheep, that is, the
• recovery progress.
3. Removal and decommission of trail segments and unauthorized trails on a case specific basis
• with demonstrated cause, e.g., at the promontory of the Bump and Grind trail
• 4. A ban on cross country travel during lambing season(sheep adapt and habituate to regular and
. expected sight of humans on trails)
5. A program to educate trail users to stay on trails
• 6. An enforcement system on trail segments that are posted no dogs
• 7. A perimeter trail system that offers low level hiking opportunities from Palm Springs to La
• Quinta
• 8. A call would go out for research proposals to (1) analyze and determine, the effects, if any, of
trail users upon population levels of PBS, (2) analyze and determine the primary causes for the
• 1996 to 2004 recovery of PBS, (3) analyze and determine why the San Jacinto herd remains
• relatively small despite high lamb/ewe ratios and reintroduction programs and(4) identify and
• prioritize the primary factors affecting population levels of PBS in the Plan area.
9. Re-routing of trail segments only if they are deemed"critical"to the continued recovery of
• bighorn sheep
• Under our program there would be no "volunteer trail closures," no "hot season" trail closures and
• no "quota permitting system." There is no evidence, analysis.or best available science to support
and justify the draconian reduction in public access to trails proposed by CVAG. The trails
• Management Subcormnittee would monitor the sheep population. As long as the sheep population
• continues to increase or oscillate around and close to the targeted de-listing objects, no changes
• would be necessary.
• Perimeter trails are not being built for the purpose of substituting for higher elevation trails such as
• the Art Smith and Sky Line Trails. Perimeter trails are being constructed to expanding low level,
• moderate exercise/hiking opportunities. Perimeter trails will compliment the series of strenuous
• trails that currently exist. Perimeter trails will serve as a buffer between the urban interface and the
bighorn habitat.
•
•
•
100
•
•
•
•
•
• 24. The Public Comment Period
• I. Two public meetings with agenda "Proposed Trails Plan" only.
• First meeting on November 30, 2004 at Cathedral City Hall Chambers, and
• second meeting on December 4, 2004 at Palm Desert City Hall Chambers.
Between the two meetings, about 250 trails-users attended. Roughly, 60 citizens passionately
addressed the "proposed trails plan" and, with one exception, each expressed in detail why
• they found the"trails plan" wanting.
•
• In CVAG's document, Appendix I(pages six and seven) lists eleven trail-users who participated in
the Bighorn Sheep and Trails Working Group.None of these people spoke in favor of the trails plan,
• or made themselves known at either public comment meeting. To our knowledge, none of them
• submitted written comments favoring the "trails plan".
In both meetings, Katie Barrows, Associate Director of Coachella Valley Mountains Conservancy,
provided a 45-minute overview of CVAG's proposed"trails plan."At each, it was conveyed that the
• process of building the "trails plan"was consultative and cooperative, with various trails-user groups
• from the Coachella Valley contributing their input. Curiously, not one of the 250 people present
• identified themselves as a trail user who participated in the process of building the plan. No one
present, outside of the panel, spoke in favor of the plan or to an aspect of the plan to which they
• contributed during the development process. Which elements were advocated by trail-users? It
• would be useful if CVAG named the participating trail-users who now support the "trails plan".
• Talking with them might help us understand the rationale for the plan.
• Several statements given by Katie Barrows were confusing to us, and raised serious questions:
•
• • On December 4th: "We don't have the trail use data that we need now." How can
• CVAG obtain such data under a trails avoidance and quota permitting system?
According to the Plan,usage under these programs would be at a 50% level of 2001-
• 2003 estimated demand. Only with removal of both the trails avoidance program and
• the proposed quota system can such data be gathered.
• • "The Scientific Advisory Committee advised all aspects of the Plan except that
• dealing with Peninsular bighorn sheep." Unfortunately, for the trails plan, CVAG
• apparently relied only upon the authors of the Recovery Plan 2000. Therefore, the
• trail plan lacks "best available science"because CVAG adopted without revision the
• Recovery 2000 which also lacked the best available science on issues related to
bighorn sheep and trail users.
•
• • Barrow's presentation was identified as CVAG's "summary". Then, why was new
• information presented that had not been included in the plan? For example:
• (1) On bighorn population data on"ewes"between 1996 and 2002 for three of the
• four Plan area regions. Why was this data not included in the draft Plan or the
•
101
•
i
i
i
•
i draft EIS/EIR? Why wasn't range-wide bighorn population data presented
i on adult sheep? Why wasn't data presented on lamb/ewe ratios for the plan area?
i Why wasn't there analysis of the bighorn population data? What factors
contributed to the bighorn population increase each year from 1996 to 2004?
i
(2) Why was information presented on future research plans that was not included
i in the thousands of pages of the Plan and EIS/EIR?
i (3) Why did Barrows say the trails plan had"limited science?"We cannot find
i any such acknowledgement and disclaimer in the Plan or accompanying EIS/EIR?
i What did she mean by "limited science?" How would that have impacted the
i trails plan's policy decisions?
i (4) She pointed out that the whole Plan takes an "eco-system" approach. Why
i was that approach not taken in the case of the "trails plan" and bighorn sheep?
i Instead of spending money on a permitting program, why not allocate funds to
i educating trails users to stay on trails and protect the fragile desert eco-system?
Why not educate trail users on the importance of leashing their dogs and keeping
i them off trails that are posted "no dogs beyond this point?"
i II. Two Public Meetings with agenda: "CVAG Conservation Plan" as a whole:
First meeting on November 17, 2004 at La Quinta City Hall Chambers. About 25 people
i present. No one spoke to the Plan except four members of the Coachella Valley Hiking
Club, who addressed several trails plan issues.
Second meeting on December 9, 2004 at Palm Springs City Hall Chambers. About 19
people present. There were four speakers only: two spoke against the trails plan, and two
i raised property rights issues with the Conservation Plan.
•
i III. Final (and fifth) Public Meeting on the Conservation Plan and the Trails Plan:
i to be held on January 24, 2005 at Palm Desert City Council Chambers.
The Coachella Valley Desert Trail Users Coalition* will present a 45-minute power point program
i critiquing the Trails Plan and the trails plan segment of the EIS/EIR. The Coalition expects more
i than 150 members to turn out to demonstrate their support for the presentation. Our goal is to
i convince the Coachella Valley Mayors, City Council members and Riverside County
Commissioners that we perceive a serious need to change course and call for a major rewrite of the
i trails plan, for the public good for decades to come.
•
•
•
*Desert Riders, Coachella Valley Hiking Club, Desert Trails Hiking Club, Desert Bicycle Club,
Desert Cities Track Club and Palm Springs Triathlon Club.
i
•
•
•
i 102,
•
•
•
•
•
•
• IV. Concerns
• The Coachella Valley Hiking Club supports the overall conservation objectives of the CVAG
• Conservation Plan. We applaud its mission to finalize useful conservation goals for the desert.
• However, we have not read the entire Plan and have no opinion on the Plan as a whole. We believe
• trail users are the best eyes and ears in this vast beautiful Coachella Valley region. We love the
natural and biological environment we pass through each day. We educate our members to respect
• and appreciate nature and her inhabitants. We believe we can stand the test as your natural and best
• conservation allies that are out in the field. We want to support this PLAN and the "trails"portion,
• but we cannot as presently written. We hope you will bring us together by addressing our concerns
• and adopting our recommendations. In good faith, we submit the following concerns:
• 1. We urge the CVAG to describe fully the role of economic development in reducing sheep habitat
• in the valley. Many experts see the loss ofsheep habitat as the major and critical reason for the
• decline of sheep population. Therefore, we request documentation that shows the impact of
urbanization upon sheep population in terns of habitat loss, habitat fragmentation and habitat
• degradation.
•
• 2. We urge the CVAG to include the population data on Peninsular bighorn sheep from the early
• 1980s to the present. This addition will allow all parties the benefit of key information. The absence
of discussion of the bighorn sheep's dramatic recovery during the past eight years could appear
• evasive to the public. To avoid this perception,we have presented time-series data on the population
• of Peninsular bighorn sheep and lamb recruitment rates. We find that the bighorn sheep population
• has been in recovery over the entire Peninsular Range for the past eight years, with lamb recruitment
rates in the Santa Rosa Mountains averaging 45 lambs per 100 ewes for the past ten years.
• Ironically, if current trends continue, it is likely that by the time the Plan implements trail rationing
• in 2006,the bighorn population will have already reached and surpassed the de-listing target
• recovery average of 750 sheep set by the"Recovery Plan for Bighorn Sheep in the Peninsular
• Ranges, California". Also, lowering lamb mortality rates in the fixture will support even greater
recovery in the sheep population. Can the CVAG include research that demonstrates how trail users
• affect lamb mortality rates?
3. We urge the CVAG to study the recovery of the bighorn sheep in the Santa Rosa Mountains over
the past eight years. This period of recovery corresponds to the same time the core hiking clubs
• expanded their membership in the Coachella Valley. Despite the positive correlation between the
• recovery of the sheep and hikers use of the trail,we do not suggest that hikers caused this result. On
• the other hand, given the dramatic sheep recovery results, how can some insist that use of trails
• endangers the recovery of the sheep population and thus,propose the rationing of trail use? Is there
in place a"belief system"that stands impervious to evidence? Where is the use of the best available
• science in the CVAG's trail rationing proposal?
4. We urge the CVAG to include specific rationale or evidence for the Seasonal Trails Program. In
looking for empirical evidence, such as presented in Tables 1 and 2, we find that recruitment rates
• and population figures for the Santa Rosa Mountains do not support the need for seasonal trails
•
•
103
•
•
•
•
•
• programs. According to the data, perhaps more appropriate programs would be aimed at reducing
• lamb mortality, i.e., reducing predation, disease, and fatal urban encounters
5. We believe the CVAG's proposed preferred alternative of seasonally permitting seven trails is
i destined for failure when the public learns that the trail plan lacks any basis in science, when the
• public learns the trails plan is based solely on a doctrinaire "belief system,"when the public learns
• the bighorn sheep have been increasing in numbers for eight straight years, when the public learns
• that by the time the trails plan goes in force in 2006 the bighorn will have been in recovery for a
decade and close to be down listed as an endangered species, when the public learns an enforcement
• system is for all practical purposes non-existent, when the public learns the actual number of people
i who wish to use the trails is four to five times the mnnber of permits granted, and when the public
i learns that the much talked about new trails for the valley are not substitutes for trails targeted for
rationing.
•
• 6. We urge the CVAG to include a statement ofpurpose for the construction of perimeter trails.
i 7. We urge CVAG to develop an alternate segment of the Palm Desert to La Quinta trail, working
+ with Bighorn Institute as a planning partner. We oppose the making of any new trails that might
• compromise the work of Bighorn Institute. Specifically, we oppose the construction of the segment
i of the new Palm Desert to La Quinta trail that passes close to Bighorn Institute and in sight of their
• captive breeding pens. The CVHC fully supports the Bighorn Institute in its opposition.
• 8. We question the need and purpose for the proposed Trail Monitoring and Enforcement Program.
• (Please see our section 8 for a list of relevant questions.) In the context of the Plan, monitoring and
• enforcement appear to amount to the same thing. Our analysis (see sections 2, 3 and 4) demonstrates
no need for a seasonal trails program, no need for a fixed and arbitrary limit on permits, and
• therefore, no need for an enforcement program. However,to produce summaries of trail usage for
i analyses, there would be a need to collect the research oriented permits at the trailheads and tabulate
i the results by trails.
• 9. We believe trail user groups should hold at least eight of the fifteen seats on the Trails
i Management Subcommittee. .
i
• 10. We urge the CVAG to simplify sections of language in the Plan. We urge the CVAG to remove
emotive language and to define key research terms in operational forms. Please see recommended
i list on page 82,
i
i 11. We urge the CVAG to broaden the research perspective with more tentative and open questions.
i A major revision could avoid single variable models and embrace multi-variable models that look at
time-series data on the population dynamics of the bighorn sheep. Such revisions raise greater hope
i for answering important policy questions. A starting point might be a systematic review of"Status
• of the Science: On Questions that Related to BLMPlan Amendment Decisions and Peninsular
i Ranges Bighorn Sheep, " March 14, 2001. This revision would not be to affect research results, but
to review methodology and develop a framework for generating even more meaningful results.
•
i 12. We urge the Plan to fund research on such questions as: Why have recruitment rates in the past ten
i years more than doubled from those in the previous decade in the Santa Rosa Mountains? What
•
•
i 104
•
•
•
•
•
• explains the substantial yearly increases in sheep population over the past eight years? Are disease and
predation weaker in the present environment? Why is the sheep population increasing in face of
reduced habitat? To facilitate the current excellent progress being made in the sheep population over
• future years,we need answers to these questions.
13. We urge the CVAG to include more empirical evidence and a theoretical foundation in the
document. Since science is at the heart of this Conservation Plan, shouldn't there be a scientific
• approach to the trails portion of the Plan? Without data, this section contains no serious analysis and
• without a theoretical base the Plan is left to stand on only one arbitrary option for policy
• formulation.
• 14. We conclude that trail users are placed in a Catch 22 position by the Plan*. Due to the Plan's
• proposal of public policy guidelines without the process of research and support, we project a great
• loss of public good. Therefore, we respectfully propose (1) all trails in sensitive sheep habitat be
• subject to an unlimited permit system, as long as the sheep continue their annual recovery begun in
1997; (2) all trails in sensitive sheep habitat be monitored for usage; and(3) usage data be analyzed
• on a trail by trail basis by the Trails Management Committee.
•
• 15. Given that the Clara Burgess Trail does not bisect a lambing habitat and the Clara Burgess Trail
area does not contain a home range ewe group, it was incorrectly included in the Seasonal Trails
• Program. To make sure similar errors were not committed on the other six trails included in this
• program; we urge that the Trails Management Subcommittee be given detailed maps of lambing,
rearing and watering location for the other six trails.
• 16. The "2000 Bighorn Recovery Plan"covers nine regions on the Peninsular Ranges. The "trails
• plan" is written primarily for one region, the Santa Rosa Mountains. The Santa Rosa Mountains'
• bighom population was in decline in the 70's and 80's due to low lamb/ewe ratios. These low ratios
• were attributed to disease, primarily pneumonia. The population stabilized in the first half of the
90's and grew in the second half of the 90's and early 2000's, due to lamb/ewe ratios approximating
• 50. The 2006 "trails plan" seems written for the past and conditions that no longer prevail in this
• century.
•
•
*i.e., the Plan sets arbitrary standards such as limit of 2,300 individual & 50 group trail permits &
• seasonal trail closures. These limits will prove difficult if not impossible to change in the future. If in
2006 the sheep population continues to recover,there could be no policy change because it would be
• held that the policies are working whether or not they have any impact whatsoever on the sheep
• population. If in 2007 the sheep population continues to recover, there could be no policy change
• because the trails research program under-written by the Plan will have just been submitted or just
• undertaken and no results are available. Even when research results come in, which could be 2015 or
later,the results will likely be inconclusive, again supporting a `no change in policy' course. Thus,
• implementing a limited permit program will immediately causes a reduction in the public good that
• could continue for years in the flrture, even though the sheep population continues to increase.
•
•
105
•
•
•
•
•
•
• 17. If there must be a six month period of trail rationing, we suggest the period should be from April
1 through October 31. A twelve year study of bighorn sheep in the Santa Rosa Mountains concluded
that significant lamb mortality occurs between April and October(see DeForge 1995). Fewer people
• use the seven designated trails during this six month period April—October because higher
temperatures cause trail users to seek out trails around Idlewild, Joshua Tree National Park and
• above the tram in Palm Springs. The six month period November through March represents the high
• use trail period. This new division of the year would bestow the greatest benefit to the bighorn
• sheep as well as the residents and visitors to the Coachella Valley. Thus, the Plan would predictably
• receive greater public support.
• 18. We urge reexamination of the proposal to decommission and remove that portion of the Mirage
• Trial that lies above the intersection of a new permimetrer trail. The trail doesn't intersect a lambing
. area. There isn't a ewe group home range close to the trail. The trail satisfies the 6/10 of a mile
criterion adopted by the EIS/EIR for the Pahn Desert to La Quinta connector trail. Users don't
• currently go from the top off into Magnesia Canyon or further into the mountains. Monitor this trail
at the top and data will confirm this claim. If you like put a fence at the top to blocking access for
• proceeding further and place signage asking people no to go beyond this point. The valley's most
• unique and most popular exercise trail should not be dismantled and dismembered into just an
ordinary valley trail. Instead, decommission and remove the "numerous unauthorized trails that take
• off from the flat overlook at the top of the Mirage Trail." This is exactly the approach you are taking
• with "unauthorized trails" in the Coral Reef Mountains area(EIS/EIR page 5-48)
• 19. We urge the reexamination of The Preferred Alternative that asserts BSP =f(RTU) or
• (bighorn sheep population is a function of recreational trail use). Targeting the only variable with no
• established link to the population of bighorn sheep in preference to variables with empirical and
• historical backing lacks logic and prudence. We acknowledge this relation BSP = f(RTU) is
supported by a belief system of a few individuals. Whereas belief systems may be necessary to
• support a public policy position, they are not sufficient. In order for a public policy decision to
avoid reducing the public good, it must be evidence based along with a supporting rationale that is
• consistent with the evidence. The Preferred Alternative does not meet these conditions.
• 20. The Plan said, "A trail use and public access plan is needed to provide for trail use in bighorn
• sheep habitat that is compatible with sheep Conservation Goals and that affords a reasonable level of
• use to the public." (see, 9-203) The Plan made no case that a trails plan is needed other than putting
• forth unsupported claims to that affect. Bighorn sheep have been in recovery every year for the past
eight without rationing trail use. How can a trails plan that cuts back trail use levels in 2006 to half
• or one third that of 2000 be called "reasonable"when the bighorn will be at or above the targeted de-
listing population of 750 sheep in 2006? Such drastic action could only be reasonable if the bighorn
• population had been in a steady decline over the past seven years.
•
•
•
•
•
• 106
•
•
•
•
•
•
i 21. Finally, we presented an outline of an alternative trails plan in section 23. We hope you will
! give this serious consideration.
The Coachella Valley Hiking Club members look forward to the period of public comment to hear
the views of others and to share our views as well. We stand ready to serve on the Trails
• Subcommittee, to provide assistance such as reviewing research outlines and to help in any way
i others deem valuable for the CVMSHCP.
•
•
!
•
!
•
i NOTE:
• To review the final draft of the CVAG Plan (i.e., CVMSHCP) upon which
• this response was based, access their website www.cvmshcp.org_
•
! The following 46 pages of the CVMSHCP contain material specific to and
• relevant to trail users:
• ES -27-34; chapter 6: 6-11; chapter 7: 53-71; chapter 8: 77-78 and 81-85
• and chapter 9: 279-286.
•
• The following pages of the draft EIS/EIR contain the information and
analysis of the "trails plan."
• chapter 2: 58-81; chapter 5: 1-105; Appendix Q Appendix F and
• Appendix J
i
•
•
•
•
•
•
•
i
•
•
i 107
•
•
•
•
•
•
• Selected Sources for this CVHC Response:
•
• Baumann, Paul, R., "The Endangered Peninsular Bighorn Sheep: Coachella Valley," Department of
• Geography, State University of New York, College at Oneonta, 2001,p.37
• Bighorn Institute, `Bighorn Institute Announces Release of Bighorn Sheep," June 24, 1997, pl
•
• Bighorn Institute, "Bighorn Institute Reaches 20 Year Milestone," The Bighorn, Winter, 2003
• Bighorn Institute, "Bighorn Predator: The Mountain Lion," The Bighorn, Summer 1997
•
• Bighorn Institute, "Fact Sheet: Fall 2003,"Palm Desert, CA. 4 pp
• Bighorn Institute, "Research Updates,"The Bighorn, Spring 2004
•
Bighorn Institute, "Summary of the San Jacinto and Santa Rosa Mountains Peninsular Bighorn
• Sheep Helicopter Survey, "Palm Desert, CA. Fall, various years
• Bighorn Institute, "2001 Year-End Report,"Palm Desert, CA, December 2001
•
• Bleich, V. C. et al., "Sexual Segregation in Mountain Sheep: Resources or Predation?' Wildlife
• Monograph No 134, 1967
• Bleich, V.C., et al., "Responses of Mountain Sheep to Helicopter Surveys," California Department
• of Fish and Game, Vol. 76, 1990
• Bleich, V. C., et al., "Mountain Sheep Ovis Canadensis and Helicopter Surveys: Ramifications for
• the Conservation of Large Mammals,"Biological Conservation, Vol. 79, 1994
•
• Blong, B., "Desert Bighorns and People in the Santa Rosa Mountains," California-Nevada
• Transaction, 1967
• Bodenchuk, Michael, et. al., "Economics of Predation Management in Relation to Agriculture,
• Wildlife, and Human Health and Safety,"National Wildlife Research Center, Fort Collins, Co. 2002
• Boyle, S. A., and Samson, F. B., "Effects of Nonconsumptive Recreation on Wildlife: A Review,"
• Wildlife Society Bulletin, Vol. 13, 1985
•
• Bureau of Land Management, "Actual and Potential Use of Trails Subject to the Permit Program,"
• Palm Springs, unpublished paper, January 2004
• Bureau of Land Management Palm Springs, "Decision Record for Programmatic Research Activities
• in Peninsular Ranges Bighorn Sheep Habitat, Riverside and Imperial Counties," Palm Springs, CA.
• October, 2001
•
• 108
•
i
•
•
•
•
Bureau of Land Management Palm Springs, Santa Rosa and San Jacinto Mountains Trails
Management Plan, Chapter 4, Environmental Consequences, Palm Springs, Ca., 2002
•
Bureau of Land Management, "Trails Plan Briefing Prepared for CVAG Project Advisory Group,"
May 22, 2003
•
• Bureau of Land Management, "Status of the Science: Do You Want to Know More About Bighorn
• Sheep,"Palm Springs,no date,pp. 2
• Bureau of Land Management, "Status of the Science: On Questions That Relate to BLM Plan
• Amendment Decisions and Peninsular Bighorn Sheep," Palm Springs, updated March 14, 2001
Campbell, B. H., and Remington, R., "Influence of Construction Activities on Use Patterns of Desert
Bighorn Sheep," Wildlife Society Bulletin, 1981, Vol. 9
•
• Campbell,B and Remington, R., "Influence of Construction Activities on Water-Use Patterns of
• Desert Sheep, Wildlife Society Bulletin, Vol. 9 1981
• Center for Biological Diversity, Internet news release, May 21, 2003, pl
•
• Chapman, D.G., "Some Properties of the Hypergeometric Distribution with Applications to
Zoological Sample Censuses," University of California Publications in Statistics, 1(7)pp. 131-160
• Churn Creek Protected Area Management Plan,March 2000
Cornett, James, Biological Assessment and Impact Analysis of Palm Hills
• Development. James Cornett Ecological Consultants, Palm Springs, Ca.,November, 1999
• CVMSHCP ( Coachella Valley Multiple Species Habitat Conservation Plan), Background on
"Peninsular bighorn sheep", Website http://www.cvmshcp.org/sp 01.htm
• Dean, H.C., Desert Bighorn Sheep in Canyonlands National Park, M.S. Thesis, Utah State
• University, Logan Utah, 1977
Dean,H. C. and Spillett, J. J., "Bighorn in Canyonlands National Park," Desert Bighorn Council
Transactions,Vol. 20, 1976
•
• DeForge, James, R., "A Four Year Study of Cause Specific Mortality of Desert Bighorn Lambs Near
• an Urban Interface and a Community Response," Desert Bighorn Council Transactions, 2002
Deforge, James R., et al., "Disease Investigations into High Lamb Mortality of Desert Bighorn in the
• Santa Rosa Mountains, California,"Desert Bighorn Council Transactions, 1982
•
•
109
•
•
•
•
•
•
• DeForge, James R. et al., "The Loss of Two Populations of Desert Bighorn Sheep in California,"
• Desert Bighorn Council Transactions,Vol. 25, 1981
• DeForge, James R., "Man's Invasion into Bighorn's Habitat,"Desert Bighorn Council Transactions,
• Vol. 16, 1972
• DeForge, James R., "Stress: Changing Environments and the Effects on Desert Bighorn Sheep,"
• Desert Bighorn Council Transactions,Vol. 25, 1981
• DeForge, James R., ""Stress: Is It Limiting Bighorn," Desert Bighorn Council Transactions, Vol.
• 20., 1976
• DeForge, J.R., Barrett, E.M., Ostermann, S.D., Jorgensen, M.C., and Torres, S.G., "Population
• Dynamics of Peninsular Bighorn Sheep in the Santa Rosa Mountains, California, 1983-1994,"
• Desert Bighorn Council Transactions, 1995,Vol. 39:50-67
• DeForge, J. R., Ostermann, S.D., Wilhnontt, C.W., Brennan, K.B., and Torres, S.G., "The Ecology
• of Peninsular Bighorn Sheep in the San Jacinto Mountains, California," Desert Bighorn Council
• Transactions, 1997, Vol. 41:8-25
• DeForge, J. R. and Jenner, C., "Achievement Status Report, San Gabriel Mountains Bighorn
• Research Project,"unpublished manuscript, 1977
DeForge, James and Scott, Joan, "Ecological Investigations into High Lamb Mortality," Desert
Bighorn Council Transactions, Vol. 26, 1982
•
• DeForge, James R., "Population Estimate of Peninsular Desert Bighorn Sheep in the Santa Rosa
Mountains,"Desert Bighorn Council Transactions, Vol. 28, 1984
• Douglas, C. L. and Leslie, D. M., "Influence of Weather and Density on Lamb Survival of Desert
• Mountain Sheep," Journal of Wildlife Management, Vol. 50, 1986
Dunaway, D. J., "Status of Bighorn Sheep Populations and Habitat Studies on the Inyo National
Forest,"Desert Bighorn Council Transactions,Vol. 14, 1970
•
• Dunaway, D. J., "Bighorn Sheep Habitat Management on the Inyo National Forrest, a New
• Approach,"Desert Bighorn Council Transactions, Vol. 15, 1971
• Dunaway, D. J., "Human Disturbance as a Limiting Factor of Sierra Nevada Bighorn Sheep,"
• Transactions first North American Wild Sheep Conference, April 1971, Colorado State University,
• Ft. Collins, Colorado
• Eaton-Gonzales B. and Martinez-Gallardo, Roberto, "Analysis of the Current Knowledge of
• Peninsular Bighorn Sheep and its Implications for the Conservation and Management in the State of.
Baja California," Desert Bighorn Council Transactions, Volume 45, 2001
•
•
• 110
•
•
•
•
•
•
• Epps, Clinton W., et al., "Effects of Climate On Population Persistence of Desert-Dwelling
• Mountain Sheep in California," Conservation Biology, vol. 18.,No 1., February 2004
• Ernest, H. B., et al., "Fecal DNA Analysis and Risk Assessment of Mountain Lion Predation of
Bighorn Sheep," Journal of Wildlife Management, Vol. 66. 2002
• Ferranti, Philip, 100 Great Hikes in and near Palm Springs, Westcliffe Publishers, Englewood,
• Colorado, 2000
•
• Geist,V., Mountain Sheep: A Study in Behavior and Evolution, University of Chicago Press,
Chicago, Ill. 1971
•
• Goodson,N. J., et al., "Effects of River Based Recreation and Livestock Grazing on Desert Bighorn
• Sheep on the Navajo Station," Second North American Wild Sheep Conference, April 6-9 1999,
• Reno,Nevada
• Guzman, Richard, "Nature's Playground,"The Desert Sun, Happenings, p. 18-19
Hansen, Michael C., "Desert Bighorn Sheep: Another View," Wildlife Society Bulletin, Vol. 10,
1982
•
• Hamilton, K., Holl, S.A., and Douglas, C. L., "Ali Evaluation of the Effects of Recreational Activity
• on Bighorn Sheep in the San Gabriel Mountains, California, Desert Bighorn Council Transactions,
• 1982,Vol. 26.
• Harris, L. K., Recreation in the Mountain Sheep Habitat. Ph D. Dissertation University of Arizona,
• Tucson, 156 pp.
Hass, C.C., "Bighorn Lamb Mortality: Predation, In Breeding and Population Effects," Canadian
• Journal of Zoology, Vol. 67, 1989
•
• Hayes, C.L. et al., "Mountain Lion Predation of Bighorn sheep in the Peninsular Ranges,
• California," Journal of Wildlife Management, Vol. 64, 2000
• Hicks, L. L., Human Disturbance of the Mt. Baxter Herd of Sierra Nevada Bighorn Sheep, M.S.
• Thesis, University of Michigan, Ann Arbor, 1977
• Hicks, L. L., and Elder, L. M., "Human Disturbance of Sierra Nevada Bighorn Sheep," Journal of
• Wildlife Management,Vol. 43, 1976
•
• Hirsch, Karen, "Bighorn Institute Fights to Save Desert Sheep from Extinction," California
• Biodiversity News, no date, 2 pp
• Holl, S.A. and Bleich,V.C., "Mineral Lick Use by Mountain Sheep in San Gabriel Mountains,
• California,"Journal of Wildlife Mana eg ment, Vol. 51, 1987
•
• III
•
•
•
•
•
• Holl, S. A., et al., "Population Dynamics of Bighorn Sheep in the San Gabriel Mountains, California,
• 1967-2002," Wildlife Society Bulletin,Vol. 32. 2004
• Horejsi, B., "Some Thoughts and Observations on Harassment of Bighorn Sheep" in T. Thorne,
• Chairman, Proceedings of the Biennial Symposium of North American Bighorn Sheep Council,
• Jackson,Wyoming, 1976
• Jorgensen, Mark, "The Plight of Anza-Borrego's Desert Bighorn Sheep," (3-part series), Desert
• USA Magazine, March 1998, 7 pp
Jorgensen, Marc C. and Turner, Robert E., "The Desert Bighonr Sheep of Anza-Borrego Desert
State Park,"Desert Bighorn Council Transaction, Vol. 17, 1973
•
• Kalinowski, S.T. and Heddrick, P.W., "Inbreeding Depression in Captive Bighorn," Animal
• Conservation, Vol. 4, 2001
• Keith Companies,Palm Hills Specific Plan, Los Angeles, Ca., June 2003
•
• King, M. M., and Workman, G. W., "Response of Desert Bighorn Sheep to Human Harassment:
Management Implications," in Transactions 51st North American Wildlife and Natural Resource
• Conference(R. E. McCabe, ed.) 1986
•
Kruasman, P.R., et al., "Can Mountain Sheep and Humans Coexist,"in Field, R.S., et al., (eds.)
• Wildlife, Land and People: Priorities for the 215t Century. Proceedings of the Second International
Wildlife Management Congress, The Wildlife Society, Bethesda, MD., 2001
•
• Krausman, P. R. and Hervert, J. J., "Mountain Sheep Responses to Aerial Survey," Wildlife Society
• Bulletin, 1983, Vol. 11
• Krausman, R. R., and Shaw, W. W., `Bighorn Sheep in the Pusch Ridge Wilderness Area: Current
• Knowledge and Research Needs," Unpublished report prepared for the U.S. Forest Service,
• Coronado National Forest, Arizona
• Lee, Ray, "A Working Hypothesis for Desert Bighorn Sheep Management," Desert Bighorn Council
• Transaction, 1999
•
• Leslie, D. M. and Douglas, C. L., "Human Disturbance at Water Sources of Desert Bighorn Sheep,"
• Wildlife Society Bulletin, 1980, Vol. 8
• MacArthur, R. A., et al., "Factors Influencing Heart Rate in Free-Ranging Bighorn Sheep: A
Physiological Approach to the Study of Wildlife Harassment," Canadian Journal of Zoology, Vol.
• 57, 1979
• MacArthur, R. A., et al., "Cardiac and Behavior Responses of Mountain Sheep to Human
Disturbance,"Journal of Wildlife Management, Vol. 46, 1982
•
•
112
•
•
•
•
•
• McCarty, C. and Bailey, James, "Habitat Requirements of Desert Bighorn Sheep," Special Report
• Number 69, Colorado Division of Wildlife, Terrestrial Wildlife Research, May 1994
• McKinney, et. al., "GIS-Based Evaluation of Escape Terrain and Desert Bighorn Sheep Population
in Arizona," Wildlife Society Bulletin, Vol. 31, 2003
• McQuivey, R. P., "The Desert Bighorn Sheep of Nevada,"Nevada Department of Fish and Game,
• Biological Bulletin, Vol. 6, 1978
•
• Mensch, Jerry, ""Survey of Bighorn Sheep in California,"Desert Bighorn Council Transactions,
• 1970
• Miller, G. D and Smith; E. L., "Human Activity in Desert Bighorn Habitat: What Disturbs Sheep?"
• Desert Bighorn Council Transactions, 1985, Vol. 29
• Mooring, M. S., et al., "Vigilance, Predation Risk and the Allee Effect in Desert Bighorn Sheep,"
• Journal of Wildlife Management, Vol 68, 2004
•
• Mouton, Rodney et al., "A Desert Bighorn Sheep Decline in Aravaipa Canyon, Arizona,"Desert
Bighorn Council Transactions, Vol. 35, 1991
•
• Mullen, B. A and Dada, C. E., "Spatial and Seasonal Distribution of Poetential Vectors of
• Hemorrhagic Disease Viruses to Peninsular Bighorn Sheep in the Santa Rosa Mountains of Southern
• California," Journal of Wildlife Diseases, Vol. 28, 1992
• Nelson, M., "Problems of Recreational Use of Game Ranges,"Desert Bighorn Council Transactions,
Vol 10, 1966
• New Mexico Department of Game and Fish, Draft Long Range Plan for the Management of Rocky
• Mountain Bighorn Sheep in New Mexico 2004-2014, Wildlife Management Division, Santa Fe,
• New Mexico, 2004
Ostermami, Stacey, et al., "Captive Breeding and Reintroduction Criteria: A Case Study of
Peninsular Bighorn Sheep," Conservation Biology, Vol. 15, 2001
•
• Panel Discussion, Desert Bighorn Council Transactions, Vol. 36, 1992
• Popouchis, C. M., et al., "Effects of Increased Recreational Activity on Desert Bighorn Sheep in
• Canyonlands National Park, Utah," in Singer, F. and Gudorf, M. A., (eds.) Restoration of Bighorn
• Sheep Metapopulations in and Near 15 National Parks: Conservation of Severely Fragmented
• Species,Volume III: Research Findings. U. S. Geological Survey File Report 99-102, Mideontinent
• Ecological Science Center, Fort Collins, Colorado, 1999
• Popouchis, C. M., et al., "Responses of Desert Bighorn Sheep to Increased Human Recreation,"
• Journal of Wildlife Management, Vol. 65, 2001
•
•
113
•
•
•
•
•
• Purdy, Ken G., and Shaw, William W., "An Analysis of Recreational Use Patterns in Desert Bighorn
• Habitat: The Pasch Ridge Wilderness Case,"Desert Bighorn Council Transactions, 1981
• Purdy, Ken G. and Shaw, William W., "Progress Report: Recreational Use of Desert Bighorn
• Habitat in Pasch Ridge Wilderness, "Desert Bighorn Council Transactions, 1980
Rubin, Esther, "An Update from Bighorn Sheep Habitat in Anza-Borrego Desert State Park," Desert
• Update,No 36, Summer 2002,pp 8
•
• Rubin, Esther, Boyce, Walter, Jorgensen, Mark, Torres, Steve, Hayes, Charles, O'Brien, Chantal,
and Jessup, David, "Distribution and Abundance of Bighorn Sheep in the Peninsular Ranges,
• California," Wildlife Society Bulletin, 1988, 26(3), 539-551
•
• Rubin, Esther, interview, December 19, 2001,p.5, San Diego Zoo .org,
• Rubin, Esther, Botta, Randy and Torres, Steve, "Results of the 2002 Bighorn Sheep Helicopter
• Survey in the Peninsular Ranges South of the Santa Rosa Mountains,"unpublished memo,
• September 2003
Sawyer, Hall and Lindzey, Fred, A Review of Predation on Bighorn Sheep, Wyoming Cooperative
• Fish and Wildlife Research Unit, Laramie, Wyoming, 2002
•
• Schaeffer, R. L., et al., "Survivorship and Cause-Specific Mortality in Sympatric Populations of
• Mountain Sheep and Mule Deer," California Fish and Game,Number 86, 2000
• Seber, G. A. F., The Estimation of Animal Abundance, London, England, Charles Griffin and
Company. 1982
Spillman, Benjamin, "Valley Trail Users: Permits no Necessary," The Desert Sun, December 1,
• 2004,A-1
•
• Sprung, Gary, "Natural Resource Impacts of Mountain Biking: A Summary of Scientific Studies that
• Compare Mountain Biking to Other Forms of Trail Travel,"unpublished, 2004
• Steinhart, Peter, "Bighorn's Last Stand," California Wild, Spring 2000
Stockwell, Craig, et al., "Conflicts in National Parks: A Case Study of Helicopter and Bighorn Sheep
Time Budgets at thje Grand Canyon,"Biological Conservation, Vo. 56, 1991
•
Stranger, Mark C., et al., "Desert Bighorn Sheep—Riverboat Interactions in Cataract Canyon, Utah,"
• Desert Bighorn Council Transactions. 1986
Tevis, Lloyd, "Man's Effect on Bighorn Range in Santa Rosa Mountains of California," Desert
• Bighorn Council Transactions, Vol. 3. 1959
•
•
•
114
•
•
•
•
•
• Tevis, Lloyd, `Battle to Save the Bighorn Range in Santa Rosa Mountains of California,"Desert
• Bighorn Council Transactions, 1961
• Torres, S. G., et al., "Mountain Lion and Human Activity in California: Testing Speculations,"
Wildlife Society Bulletin,Vol. 24, 1996
Toweill, Dale E., Desert Bighorn Sheep, Palm Springs, CA.,Nature Trails Press, 2003, pp.56
• U. S. Department of Interior and U. S. Department of Agriculture, Santa Rosa and San Jacinto
. Mountains National Monument Proposed Management Plan and Final Environmental Impact
• Statement, October 2003
• U. S. Fish and Wildlife Service, "Final Rule,"Federal Register, March 1998
U.S, Fish and Wildlife Service, "Frequently Asked Questions About Critical Habitat and the
• Peninsular Bighorn Sheep,"July 5, 2000
• U. S. Fish and Wildlife Service, "Peninsular Bighorn Sheep," Carlsbad, CA., July 2000
U. S. Fish and Wildlife Service, "Proposed Determination of Critical Habitat for the Peninsular
Bighorn Sheep," Federal Register, July 5, 2000, pp 7
•
• U. S. Fish and Wildlife Service,Recovery Plan for Bighorn Sheep in the Peninsular Ranges,
• California, U.S Fish and Wildlife Service, Portland, OR, 2000
• U.S. Fish and Wildlife Service, Draft Recovery Plan for the Sierra Nevada Bighorn Sheep, U.S. Fish
• and Wildlife Service, Portland, OR., May 2003
Wehausen, John D., "Locations of Human Interface with Sierra Nevada Bighorn Sheep,"
unpublished paper,November 2000,p. 3
• Wehausen, John D., "Nelson Bighorn Sheep,"unpublished paper, 2000
• Wehausen, John D., "The Historical Distribution of Mountain Sheep in the Owens Valley Region,"
• pages 97-105 in Mountains to Desert: Selected Inyo Readings, Friends of the Eastern Sierra
• Museum, Independence, Ca.
Wehausen, John D., "Rapid Extinction of Mountain Sheep Populations Revisited," Conservation
Biology, Vol. 13, 1999,pp. 278-384
•
• Wehausen, John D, `Effects of Mountain Lion Predation on Bighorn Sheep in the Siena Nevada
• and Granite Mountains of California," Wildlife Society Bulletin, Vol. 24, 1996
• Wehausen, John D., et al., "Recruitment Dynamics in a Southern California Mountain Sheep
• Population,"Journal of Wildlife Management,Vol, 51, 1987
•
•
• 115
•
•
•
•
•
• Wehausen, et al., "Bighorn Sheep Management in the Sierra Nevada," Desert Bighorn Council
• Transactions, 1977
• Weisenberger,M. E., et al., "Effects of Simulated Jet Aircraft Noise on Heart Rate and Behavior of
• Desert Ungulates, Journal of Wildlife Management, 1996, Vol. 60
Wood,Daniel, B., "Californians Butting Heads Over Bighorns," The Christian Science Monitor,
March 23, 1998
• Woodward,T., et al., "Bighorn Lamb Mortality Investigations in Colorado,"NWSGC Proceedings
• 1972
• Wright,Vita, Series Editor,Draft Volume 5• Backeountry Recreation Impacts to Wildlife: An
• Annotated Reading List, Aldo Leopold Wilderness Research Institute, Missoula, MT, September
• 2003, p. 1
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• 116
•