Scott Fluer
Lander Field Office
Bureau of Land Management
P. O. Box 589
Lander, WY 82520

10/6/01

Dear Scott;

We appreciated you taking the time and effort touring the Granite Mountain Common Allotment with interested public and permittees on September 26th. We would like to express our concern for the condition of GMCA and make some comments about how BLM proposes to manage these thousands of acres of public land. As residents of Jeffrey City who hunt, fish and enjoy the GMCA year-round, we believe some plan of action should be implemented quickly. As biologists we have observed declines in many species of wildlife, the degradation/destruction of riparian areas by cattle causing erosion, loss of fishing opportunities and amphibian habitat, pollution of creeks and ponds with livestock feces/urine, lack of forbs and tall grasses essential for sage grouse nesting and innumerable other problems. As you pointed out, the current plan of "management" is inadequate to improve the condition of the transects of the riparian areas within the allotment. It is high time do try something else.

We believe a decrease in the number of livestock grazing this arid allotment is crucial to allow the land to heal itself and a long-range plan must be implemented with the goal of bringing about sustainable grazing. The proposed 28 miles of fencing and water development projects are too expensive ($200,000 was quoted at the field tour) and will further degrade the allotment for the sake of only 5 permittees. We feel that there must be alternative management programs the BLM could develop to bring GMCA up to rangeland standards.

A) Fencing riparian habitats and making pastures for holding livestock is very detrimental to wildlife, extremely offensive visually, prevents public access by indiscriminately cutting roads and simply will not work if BLM relies on the permittees to maintain and use this new fencing as proposed. To illustrate this point is very easy. We are out in the Red Desert for recreation and informal biological surveys on a year round basis. The exclosure fencing around Lost Creek Reservoir has been rendered nonfunctional. Many times we have visited the area the gate had been let down. It was either unlatched or had the wires cut, thereby allowing livestock free access to the riparian habitat. Our feeling is that installation of any additional fencing by BLM is a complete waste of the taxpayer's money and will be treated by the permittees as something in their way to be destroyed or ignored so their livestock range freely as they have always done in the past. Private rangeland is not treated with such disregard and, consequently, is in much better condition than BLM lands.

B) BLM should require frequent riding and herding of livestock as an integral part of the livestock grazing management plan for any arid landscape. Lack of cooperation by the permittees should be anticipated, as it requires them to put more effort into being ranchers. However, since they directly benefit from BLM's extremely low fee per AUM, the permittees must become more diligent to prevent damage to the resource. In addition, we feel that the water developments will not be properly maintained, similar to the Badger Hills and South Sweetwater wells that weren't taken care of by permittees for a period of 12 years. Why would livestock permittees use new wells and fencing when they currently do not use and maintain similar existing facilities?

C) As in the Green Mountain Common Allotment plan, there should be a minimum stubble height goal for riparian areas. This plan is enforceable and will trigger removal of livestock from the areas where the stubble becomes too short due to overgrazing, whether livestock AUMs are too many in times of drought or whether wild horse numbers are too high. The fact remains that all wildlife on these public lands depends on the riparian areas and when they are degraded or destroyed by overuse, everything suffers. Built into the plan must be repercussions for noncompliance with new BLM grazing management procedures. It is disgraceful that the BLM allows overgrazing on GMCA to continue unabated year after year.

D) Wild horses are a serious problem on Granite Mountain Allotment. The "wild" horse is a misnomer, as they are really feral animals not native to North America. The BLM and ranchers both claim that "wild" horses are the reason for the poor condition of riparian areas. We believe there is something to that statement, there were hundreds of horses there this season and they are doing damage. There is no point in controlling livestock numbers if "wild" horses are allowed to get to such high populations and degrade the habitat.

E) All of the proposed changes in management of GMCA may be for naught if the sage grouse becomes listed by the federal government as Threatened or Endangered under the Endangered Species Act. With the precipitous decline in sage grouse populations over their entire range, it was estimated that listing of sage grouse as Threatened or Endangered is imminent. Petitions to U.S. Fish and Wildlife Service to list sage grouse are expected soon. Andy Kerr, who was involved in the spotted owl listing and subsequent controversy, is behind an agenda to "get cows off public lands". A threatened or endangered listing of sage grouse will accomplish this goal. Their proposal is to have the federal government simply buy out the grazing privileges on public lands. The memo estimates federal listing could occur in 3-5 years if the states do not stop the sage grouse population decline. Therefore, each state and BLM agency in states within the range of sage grouse should address the sage grouse issue immediately before the U.S. Fish and Wildlife Service takes over.

Here is a brief recap of our main objections to BLM proposals for management of GMCA.
A) Fencing is not the answer.
B) Herding should be required, however they will likely not do their part, i.e. maintaining fences and wells and herding livestock.
C) BLM must come up with a new range management plan that is enforceable; for example stubble heights in riparian areas dictate rotation of livestock out.
D) "Wild" horse populations should be strictly controlled.
E) Sage grouse should be a priority issue since they may be becoming an endangered species.

Please know that the public wants to see improvement in the environment within the multiple-use public lands. BLM must remember that grazing permittees are a very small (but powerful) user group. Unfortunately livestock interests are making any meaningful changes very difficult for BLM to implement. Please keep in mind that lands in GMCA belong to everyone and BLM is obliged to protect it for future generations. Best of luck in your efforts…

Sincerely,

Lance & Jill Morrow (Biologist)
Interested and Concerned Citizens