BLM, Sage Grouse, ODFW, and Smarter Public Policy
Updated October 14, 2023.

The Virtue Flat Shooting Range is a BLM lease held by PRSC since 1968.
This year, we are renewing the lease.

The Range is inside the Baker Sage Grouse Priority Area for Conservation (PAC).
Public land use within PAC's is subject to local, state, and federal rules for protecting sage grouse habitat.
Oregon PAC boundaries are established by ODFW, but BLM also has their own sage grouse habitat maps and boundaries.
BLM consults with ODFW on matters pertaining to wildlife in Oregon, but BLM policy is determined by more than just ODFW recommendations.

On our new lease, BLM wants to add two new sage grouse restrictions:
  1. If the Range is within 4 miles of an active lek, the range is subject to closure for the first and last two hours of each day from March through June. (The Range is about 3 miles from the nearest active lek.) Also, the Range may be subject to closures in other months if it is established that the range is within 4 miles of other types of sage grouse habitat.
  2. Noise control fixtures or methods may be required, but we haven't yet seen that specific language.
PRSC is attempting to convince BLM that these lease stipulations are not necessary because they will not improve sage grouse habitat in Virtue Flat.

Our arguments:
  1. Hwy 86 is the predominant human disturbance in the northwest corner of the Baker PAC. The Range is within 0.4 miles of Hwy 86. Sage grouse abandon habitat within 2 miles of highways, and don't come back. Even when no development or human activity is present along a highway, sage grouse will not make productive or successful use of habitat near highways. (References provided at the end of this document.)
  2. When human disturbance drives human-wary wildlife out of habitat, banning disturbances in the morning and evening while allowing disturbances to continue for the remainder of the day, is not an intelligent or effective strategy for convincing disturbed wildlife to return to disturbed habitat.
  3. Sage grouse populations were comparatively stable at Virtue Flat for about 30 years prior to the arrival of West Nile Virus in about 2004. The Range was constructed in 1968. The highway was constructed in 1917. There is no evidence to suggest that human activity at the Range had any measurable impact on sage grouse at Virtue Flat in the decades preceding the arrival of WNV. 
  4. The proposed new lease restrictions are pointless because they will not achieve any conservation objective.
The BLM Mission describes a "multi-use" approach to "maximize opportunities for commercial, recreational, and conservation activities" and to "support traditional land uses such as responsible energy development, timber harvesting, grazing, and recreation, including hunting and fishing."

PRSC seeks balanced consideration from BLM. Saddling us with ineffective "conservation restrictions" is neither balanced nor intelligent.

  • October 2022 - BLM informed PRSC that it was time to renew the lease. BLM Land Law Examiner Shelli Pence toured the Range with Spaugh.
  • December 2022 - BLM invoiced PRSC for 2023 annual rent; PRSC paid the invoice.
  • August 2023 - BLM presented new lease terms to PRSC.
  • September 2023 - The PRSC Membership voted to ask BLM to remove two new sage grouse stipulations from the lease.
    • BLM invited PRSC to a meeting in Baker: Spaugh, Asst Field Manager Sandra Tennyson, Specialist Melissa Primus.
    • After the meeting, BLM Field Manager Sarah Sherman called Spaugh to inform PRSC that the August lease offer was rescinded pending revision to add noise control stipulations.
    • Spaugh built this webpage and initiated public action to attempt to convince ODFW to exclude some portions of highway corridors from Oregon PAC boundaries.
Next step: wait for new lease terms from BLM.

Our Position:
  1. The Club does not want to accept pointless lease stipulations.
    • We do not favor "conservation" restrictions that achieve no conservation objective.
    • Broadly, we do not favor irrational public policy.
  2. BLM has the discretion and authority to exclude the previously described sage grouse stipulations from our lease. If BLM is unwilling to do so, the Club will want to know why:
    • Is it because BLM is unwilling to base land use decisions on scientific evidence?
    • Or is BLM unwilling to balance conservation objectives with public access and use?
    • Or is the BLM decision being guided by the "wrong kind" of conservationist?
      • We assert that "conservationists" can be sorted along a spectrum, from rabid, myopic zealots to laissez-faire observers.
      • We made a rational request and backed that request with a sound, evidence-based argument.
      • If BLM rejects our request, we will suspect that the decision may have been guided by the wrong kind of conservationist. And we will contest it.
The remainder of this document provides more details about our lease renewal process.

The Club may need its Membership to assemble to exert public influence on BLM. If that need arises, every Member will be informed.

Presently, only one person is authorized to communicate with BLM on behalf of the Club. Any person can contact BLM at any time, but only Club-authorized persons can communicate with BLM on behalf of the Club.
If you would like to get involved, read this entire webpage and contact Spaugh (me). 541-519-7417. Start attending Club meetings. I will plug you in.


The PRSC Articles of Incorporation describe two objectives: conservation and shooting safety. We are a conservation org.

Sage grouse are a "near threatened" species.

The sage grouse conservation initiative gained national attention and traction in about 2010.

The US Fish & Wildlife Service decided in 2015 that sage grouse would not be listed as a threatened or endangered species. The 2015 press release described sage grouse as "relatively abundant and well-distributed across [their] 173-million acre range," and attributed the no-list decision to the effectiveness of BLM, USFS, state agency, and private landowner conservation programs that were implemented to protect sage grouse habitat and avoid the need to list the bird as endangered.

Those programs are still in place. Oregon has an executive order, several OAR's, and a statewide plan that establish policy for development and use of land inside sage grouse PAC's. Baker County has a Sage Grouse Local Implementation Team (LIT) with representatives from USFWS, BLM, ODFW, ODA, Baker Weed, Tri-County Weed, County Commissioners, Planning Department, etc.
The LIT is a beneficial organization: among other things, it promotes balanced public policy by creating a public forum open to all interested parties.

Things to know about sage grouse:
1 - Sage grouse are wary birds. Human activity and disturbances drive them away.
2 - Sage grouse need large tracts of relatively undisturbed habitat.
3 - Sage grouse want to use certain types of habitat for lekking, nesting, brooding, and wintering.
4 - Sage grouse are loyal to lekking and nesting grounds. They want to use the same ground every year.
5 - Nest success rates decrease when human disturbance drives sage grouse away from their preferred habitat.
6 - Sage grouse populations are declining everywhere, and have been since at least 1950.
7 - Hwy 86 was built in 1917. The shooting range was built in 1968. OHV - 1972. Interpretive Center - 1992.
8 - No sage grouse have been observed or documented within 1 mile of the shooting range land since before 1950.
9 - Our shooting range is about 3 miles away from the nearest active lek.
10 - Sage grouse populations plummeted about 2004, the same time that West Nile Virus arrived.
11 - West Nile Virus killed many sage grouse.
12 - Birds have an adaptive immune system. It is not known whether sage grouse are developing effective immunity to West Nile Virus. 

ODFW is currently finalizing its 2023 efforts to revise Sage Grouse PAC boundaries in Oregon.

In late September, the Club conducted a quick campaign asking Members and friends to send an email comment to ODFW, asking ODFW to exclude some highway corridors from PAC's at locations where highways entered PAC boundaries. The campaign was transparent: ODFW and BLM know we did it.  About 80 people sent the requested comment to ODFW. Not as many as we hoped, but much more than any other type of public comment ODFW received regarding PAC boundaries.

The goal of our quick campaign was to see if we could convince ODFW to revise the Baker PAC boundary such that the Shooting Range was no longer inside the PAC.
If ODFW agreed, then we might use that information to help us convince BLM to remove the sage grouse closure and noise control stipulations from our new lease.
Reminder: BLM has it's own sage grouse habitat maps and related policies. Even if ODFW decides to draw our Shooting Range out of the Baker PAC, that is no guarantee that BLM will remove closures and noise control stipulations from our lease.
The ODFW decision will probably be finalized before year end.

The big picture: BLM wants to add sage grouse restrictions to our lease. We presented a rational argument for why those restrictions are not necessary. Our argument did not immediately prevail. Thus it made sense to improve the argument. Convincing ODFW to remove us from Oregon PAC boundaries might improve our argument, and ODFW was already revising the boundaries, so it made sense to ask.
The eventual outcome was that our campaign attracted additional attention, leading to more discussion among more parties, which is likely in our favor.

The ODFW portal for public input on sage grouse PAC boundaries: https://www.dfw.state.or.us/wildlife/sagegrouse/cas_update_2023.asp .
Click on the Landscape Tool to use the map application.

In late September, BLM invited PRSC to meet at the Baker Office. Spaugh represented PRSC. Nothing new was accomplished at that meeting. The BLM lead at the meeting was a professional and courteous Assistant Field Manager named Sandra Tennyson. Also present was a Specialist named Melissa Primus. Primus was confrontational and dismissive. She rejected our highway argument.
After the meeting, a majority of PRSC Trustees agreed the Club should file a complaint with BLM. Spaugh filed the complaint, which primarily requested that BLM staff at future meetings be courteous, cooperative, and considerate.

Our overall strategy is to call public attention to BLM responses to our requests for rational lease terms.

In future years, we will conduct sage grouse habitat improvement measures at the shooting range, including weed control, invasive annual grass control, native plant restoration, and elimination of predator roosts and subsides. Some of us may volunteer manpower for habitat improvement projecvts in the Baker PAC. If you want to get involved, come to Club meetings.

Stay tuned for updates.

David Spaugh
Powder River Sportsmen's Club

Highway Citations:
1 - Connelly et al evaluated 804 leks within 100 km of I-80 in Wyoming and Utah. No leks were located within 2 km of either side of the highway. Only nine leks were located within 4 km. Distance from the highway was a significant predictor of lek activity: activity declined faster at leks within 7.5km compared to leks located between 7.5 and 15km from I-80.
Connelly JW, Knick ST, Schroeder MA, Stiver SJ and Wildlife Agencies. “Conservation assessment of greater sage-grouse and sagebrush habitats.” (2004).

2 - Knick et al evaluated 3,184 lek locations across 920,000 km2 to model minimum habitat characteristics essential to sage grouse persistence. Sage grouse abandon leks when the density of highways located within 5km exceeds 50 meters per km2, or when the density of interstate highways located within 5km exceeds 10 meters per km2.
Knick ST, Hanser SE, Preston KL. “Modeling ecological minimum requirements for distribution of greater sage-grouse leks: implications for population connectivity across their western range, U.S.A.” Ecology and Evolution 3 (2013): 1539 - 1551. 
3 - Wann et al, in collaboration with BLM, evaluated 6,615 lek locations across the entire U.S. sage grouse range to model habitat characteristics most conducive to lek persistence. Some environmental factors influenced lek persistence in consistent ways across the entire range of habitat, whereas other environmental factors exhibited regional variation in degree of influence. For example, encroaching pinyon/juniper may serve as sage grouse roosts in some areas, whereas the presence of >16 meters per km2 of major road surface within 3.2km of habitat predicts lek extirpation everywhere within sage grouse range. Major roads are negatively associated with lek persistence regardless of adjacent landscape conditions. Distance matters: nearby disturbances impact bird behavior more than distant disturbances.
Wann GT, Van Schmidt ND, Shyvers JE, Tarbox BC, McLachlan MM, O’Donnell MS, Titolo AJ, Coates PS, Edmunds DR, Heinrichs JA, Monroe AP, Aldridge CL. A regionally varying habitat model to inform management for greater sage-grouse persistence across their range. Global Ecology and Conservation. 2023; 41.
4 - Holloran: male lek attendance was significantly diminished by the presence of oilfield main haul roads within 3 km of leks. Attendance rates were negatively associated with traffic volume and also road length greater than 5 km.
Holloran MJ. “Greater sage-grouse (centrocercus urophasianus) population response to natural gas field development in western Wyoming.” (2005).
5 - Aldridge et al observed that female Gunnison grouse avoid nesting in proximity to BLM Class 1 and Class 2 roads. At the patch scale, threshold response curves indicated very low probability of nest occurrence within 8 km of major roads, and sharply higher probability at distances greater than 8 km from major roads.
Aldridge C, Saher D, Childers T, Stahlnecker K, Bowen Z. "Crucial nesting habitat for Gunnison sage-grouse: A spatially explicit hierarchical approach." J of Wildlife Management. 2012; 76:391-406.
6 - Tack demonstrated that proximity to roads is negatively associated with lek occurrence. The impact of roads within 3.2km is detrimental for all leks, but comparatively more pronounced for large leks with 25 or more birds.
Tack, JD. "Sage-grouse and the human footprint: implications for conservation of small and declining populations." (2009). University of Montana Graduate Student Theses, Dissertations, & Professional Papers #856. 
7 - Berkeley et al: At the landscape scale, distance to nearest road is a primary variable affecting sage grouse selection of nest sites. Hens select nest sites farther away from county roads and highways compared to two-track roads, and avoid landscapes that have a higher density of gravel or paved roads.
Berkeley L, Szczypinski M, Helm J, Dreitz V. "Sage Grouse Grazing Project - Fiscal Year 2019 Annual Progress Report." Montana Fish, Wildlife, 7 Parks W-158-R.  https://fwp.mt.gov/binaries/content/assets/fwp/conservation/wildlife-reports/sage-grouse/2019aug_sagegrouse_progress_report_final1.pdf
8 - Lyon et al: Light traffic disturbance of 1-12 vehicles per day during the breeding season may reduce sage grouse nest-initiation rates and increase distances moved from leks during nest site selection.
Lyon AG, Anderson SH. "Potential Gas Development Impacts on Sage Grouse Nest Initiation and Movement.” Wildlife Society Bulletin. 2003;31(2):486–91.  
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