Grazing EIS begins

by Cat Urbigkit

The continuance of cattle grazing in the Upper Green River region of the Bridger-Teton National Forest is the subject of an upcoming U.S. Forest Service-initiated environmental impact statement, but so far the agency has received little in the way of official public comment.

Monday was the deadline for comments during the initial public scoping phase of the planning process that will eventually result in a decision whether cattle grazing will continue in six allotments in the Upper Green: Badger Creek, Beaver-Twin Creeks, Noble Pastures, Roaring Fork, Upper Green River and Wagon Creek.

In total, six comment letters were submitted to the Forest Service, including three from environmental groups. Interestingly, two of the letters used some of the exact wording; that of the Western Watersheds Project, signed by Wyoming Office Director Jonathan Ratner, and the Greater Yellowstone Coalition's letter, signed by Jen Gamett.

Although some of the wording was exactly the same, WWP's letter was four pages long, compared to GYC's seven pages.

GYC stated: "The Forest cannot legally continue grazing per the status quo, and therefore cannot choose such an alternative ... The Forest must analyze a full range of alternatives. This includes an alternative which allows for ecosystem restoration following past livestock grazing but prohibits future grazing."

GYC's letter also suggests "it is reasonable to measure any proposed alternative against an alternative that would restore the resource to a primarily pristine condition."

The GYC letter raises concern for endangered species, for trout, for biological corridors, for water quality, for the cost of predator control to the taxpayers, and for numerous other resources. The letter also calls for a complete accounting of all the costs associated with livestock use of the allotments and for complete documentation of any violations of existing grazing permits.

WWP's letter hits on some of the same highlights as GYC, but questions the fundamental issue of the "capability and suitability" of the area for livestock grazing.

"We suspect a proper analysis will show that grazing these cattle in the Upper Green is a losing proposition for the Forest Service in that: it collects less in fees than it costs to manage; and that the contribution of these permits to the local economy is insignificant when compared to normal rates of growth or other values such as hunting, fishing, wildlife watching and recreation," according to the letter.

WWP stated: "The Upper Green River area is a key area for many reasons. We encourage the Forest Service to develop and choose an alternative that will place its public trust responsibilities ahead of short-term private profit, and protect this unique and precious area from further degradation."

Montana's Predator Conservation Alliance submitted a letter stating that it supports the development of an alternative that would "encourage the use of these allotments by wolves, grizzly bears and other wildlife, and prevent substantially impairment of the allotments due to livestock grazing, which we believe would include any and all activities that kill or displace this wildlife from the area."

One of the six letters was from a citizen from Connecticut who requested he be sent a copy of the draft EIS when it becomes available.

The Environmental Protection Agency's Denver office submitted a nine-page letter detailing what the agency believes should be included in the EIS. The letter noted that EPA was "pleased" to see the no-grazing alternative would be included in the EIS.

"Though not generally practicable, the public and decision-makers can better understand grazing impacts with a no-grazing alternative evaluated," the EPA letter stated. "Some areas within allotments may have important wildlife species (e.g., listed species under the Endangered Species Act or rare and sensitive species), riparian and watershed resources, intensive recreational demands and so forth. The reduction, elimination or relocation of grazing can be used to protect sensitive resources."

Recreational uses can be positively impacted by maintaining or restoring natural landscapes, according to EPA, so impacts from grazing can be negative.

"Impacts from cattle, sheep and horse grazing - manures, eroded streams, degraded springs and riparian areas and trampled wetlands - all detract from the recreation experience and will reduce both the number of visitors and the value of their experiences," the EPA letter stated. "Education materials should prepare recreation visitors for livestock conflicts in areas that are grazed. The allotment management plans should address the number and value of recreation experiences with and without continued livestock grazing."

On the other hand, the EIS must also consider the positive socio-economic impacts of continued livestock grazing, according to the letter, including the "open space and wildlife habitat values that are sustained on those operators' ranches, the agricultural/ranching culture, and other social and environmental impacts that are associated with local ranchers sustaining their private ranches and incomes with the benefits of grazing on the forest."

The Wyoming Farm Bureau Federation submitted its official comment letter as well, questioning the necessity of doing this EIS when the overall forest plan decided that livestock grazing in the area was an acceptable use.

"We are somewhat puzzled why the Forest Service is seeking to address the issue again, when on the forest-wide EIS it was allowed," the letter, signed by Ken Hamilton, stated.

Hamilton suggested that if the agency insisted on moving forward with the EIS, the document should "look at issues affecting grazing which affect costs to operators. A goal of the agency should be to look at ways to enhance grazing and food production off of the forest. The agency should investigate management methods which would allow for livestock producers to become more efficient."