April 16, 2002
Mr. Jack Kelly
Bureau of Land Management
Lander Field office
P.O. Box 589
Lander, WY 82520
REFERENCE:
GREEN MOUNTAIN COMMON ALLOTMENT (GMCA)
GRANITE MOUNTAIN OPEN ALLOTMENT (GMOA)
Dear Mr. Kelly:
I wish to direct the comments contained herein toward both the Green Mountain Common Allotment (GMCA) and the Granite Mountain Open Allotment (GMOA). The situation and problems of habitat depletion relative to these two Public Lands are so common to each other that I feel both can be addressed in a single letter thereby saving you time and effort.
1. For a number of years the habitats of these Public Lands have experienced a slow but continuous depletion of resources that support the natural inhabitants of this fragile ecosystem. In more recent years drought has exacerbated these concerns.
2. The one most single factor accelerating the depletion of these Public Lands is commercial cattle ranching on these fragile environments. The abusive use through over grazing of these Public Lands must be brought to a halt, and steps MUST be taken to reverse the damage and begin a recovery towards a healthy, BALANCED habitat.
3. While commercial cattle grazing is recognized as one of the multiple uses of these Public Lands it is also recognized that such use can be allowed ONLY in a manner of techniques that does not develop into the slow and continuous depletion of the Public Lands and natural resources, to include the wildlife of the habitat. It is imperative that new techniques be developed and put into operation to protect these fragile environments and the wildlife native to these lands.
While this organization does not call for the total elimination of commercial cattle ranching on public lands we are alarmed at the lack of concern and lack of understanding of responsible use as displayed by the ranching community during recent meetings. It is VERY CLEAR through the comments of some of the ranching community that they have NO INTEREST in a balanced, responsible use of these PUBLIC LANDS. Consequently, we must depend upon the actions of the Bureau of Land Management to enforce responsible use and to protect the natural habitat of these Public Lands.
POINTS OF MAJOR CONCERN
1. The wetlands of these Public Lands are at a point of severe depletion and will not recover without immediate AGGRESSIVE action.
2. Birds and waterfowl are indicator species as to the health of these Public Lands. Population decline in the various species is a concern that could lead to the THREATENED or ENDANGERED listing of some species.
3. The decline of rodent species is a threat to the well-being of raptor species and some mammals that also hunt rodents. Such occurrences of rodent depletion can bring pressures upon other species not normally hunted predator inhabitants.
4. Items 2 & 3 can be traced directly to the effect mentioned in item 1, depletion of the wetlands.
5. There is an apparent lack of long-term planning. Temporary micro-steps will not address the long-term health of the Public Lands habitat. Long-range planning and enforcement is required if responsible multiple use and a healthy habitat is the goal.
PREFERED APPROACH
1. REST THESE ALLOTMENTS FOR A PERIOD OF THREE YEARS. NO CATTLE GRAZING FOR THREE YEARS. NO FENCES - NO EXPENDATURE FOR FENCES.
2. TAKE ACTION. Expend funds to repair hammocked areas and wetlands to accelerate recovery.
3. PLAN NOW. At the end of the three-year rest period, have ready to put into operation a ROTATIONAL GRAZING gazing plan or other option. Each allotment could be divided into 4 sections with plans to cycle through one section per year. This would provide for a cycling 4-year rest period for each section of the allotment. Such a plan could require a reduction of available AUM or a reduction in the number of permittees, or both. Plan now for long-range effectiveness of habitat recovery and maintenance.
If control of rotational grazing is accomplished by fencing this approach will have a direct effect upon the feral horse and wildlife management. The effects upon the migratory paths of the natural inhabitants must be taken into consideration. Herding by horseback has been observed to be poorly implemented and ineffective on these allotments. This is not to imply that horseback herding could not be used; the matter of expense and effective implementation are the deciding factors in its use.
ALTERNATIVE APPROACH I
1. Fence all riparian areas. FENCES ARE DANGEROUS TO BIRDS. Fences for riparian areas require SET BACKS. Any fencing of riparian areas require that fences be set back at least ¼ mile on each side of the riparian area. Bird flight path consideration is a must. Tall sagebrush areas must also be considered in planning the placement fences; the tall sage areas are escape areas for sage grouse and other birds.
2. If fences are a necessary evil, fencing should be MINIMAL. Fences should be used ONLY to divide the allotments into quarters as a tool for the effective implementation of a ROTATIONAL GRAZING PLAN or for the protection of riparian areas. Fencing can inhibit the migration paths of the natural in habitants; Wyoming Game and Fish department input is essential. The use of lay-down fencing where practical should be a consideration.
ALTERNATIVE APPROACH II
REDUCE AVAILABLE AUM. It is clear from the continuous and repetitive depletion of the habitat of these Public lands that the calculation of the available AUM is incorrect. Calculate the AUM at a level that will sustain grazing at a level that will allow appropriate recovery from season to season. Techniques that will appropriately protect the desert wetlands must be in place. The Experience of the past year showed that horseback cowboy type herding was poorly implemented and totally ineffective. Consequently, such herding should not be considered as a control option. Such an evaluation may well indicate that there are too many permittees assigned leases on the Green Mountain common allotment.
GENERAL CONCERNS
1. There are general concerns about the stubble height standard and its use. As we understand it, cattle were to be removed from the area when the stubble height was down to 4 - 6 inches. In the recent meeting there appeared to be an inference that cattle could be put out if there WAS a re-growth to 4 - 6 inches. We fail to understand how such an approach could allow for any recovery. Experience with the past year's season has show there has been NO recover from the past season's grazing effects.
2. Through observance of the meetings over the past couple of years we have developed the opinion that the AUM calculated for these allotment are far too high. We would suggest a re-valuation of available AUM across the allotments. It would be wise and consistent with ROTATIONAL GRAZING PLANNING to downsize the available AUM number in light of the experienced carrying capacity of the allotments. It could be possible to allow SUPLIMENTAL AUM in good wet years. Such an approach would be beneficial to the long-term health of commercial cattle grazing on public lands.
3. FENCING is dangerous to birds and wildlife. In a very recent tour of the allotments it is clear that most of the fence wire is all but invisible to the human eye and even more so for birds in flight. Strike deaths and the accumulative effects are a concern. Effective maintenance of fences and the associated cost is also a concern.
4. There is elevated concern about the "freeman" type mentality and threatening behavior displayed by some of the ranching community relative to the Interested Public and conservationists. Those who are co-operative in the development of long-range planning should be given every possible assistance in weathering the storm of change. Those individuals who are uncooperative and threatening towards others should have their grazing leases revoked.
Throughout the course of the various meetings, not once was it noted that the ranching community provided comment toward the development of long-term planning that would benefit multiple uses of these Public Lands. The ranching community vision appears to be limited to the season at hand. Also, the ranching community having been forewarned on multiple occasions by BLM, about the condition of the rangeland, appears unable to plan ahead for poor grazing conditions. It is NOT the responsibility of the public to bear the brunt of this lack of foresight. Taxpayer's funds have been spent to the benefit of commercial ranching use of Public Lands; it is time these Public Lands receive the protection deserved of them.
While this organization has never made a call for the permanent removal of commercial cattle ranching from Public Lands it becomes increasingly easier to understand why more individuals and groups join the call for its end.
In closing, I would like to thank you and your staff of the Lander, WY office of the BLM for stepping up to the plate and taking the hard knocks. The courage of being willing to initiate and implement change for the LONG_TERM benefit of all is noted. Change never comes easy, and change is always resisted. We of the Conservancy of the Phoenix, Inc. encourage you to continue the lead and set the standard for others to follow.
Sincerely,
Reginald D. Atkins
President
Conservancy of the Phoenix, Inc.
A 501(c)(3) Corporation.
CC:
Dr. James R. Fisher, Ph.D.
Dr. Jill Morrow, Ph.D.
Dr. Sigrid Mayer, Ph.D.
Dr. Michael Hudak, Ph.D
Mr. John Likins BLM
Mr. Tom Rinkes BLM
Mr. Ray Corning IP
