Volume 4, Number 6 - May 6, 2004
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Good stewardship not acknowledged
It's the single largest grazing allotment in the national forest system, yet the draft environmental impact statement for grazing management in the Upper Green River region of the Bridger-Teton National Forest drew only 17 letters of comment.
While a few environmental groups and agencies had some heavy criticism for cattle grazing in the area, local ranch families had an entirely different view, one that comes from the saddle and working the land.
Most of the permittees who submitted letters of comment expressed dismay that although the Forest Service usually maintains that permittees in this region are good stewards of the land, even undertaking their own voluntary range-monitoring program, such stewardship wasn't mentioned in the document. Most of the permittees don't like the agency's preferred alternative, instead urging the agency to continue with existing management.
Grubbing Hoe Ranch representatives, all members of the Swain family, submitted a total of five comment letters in support of continued management as currently permitted. All of the letters pointed out that livestock operations and public land grazing in Sublette County are a vital part of maintaining open spaces and the economic value of the community. The Swains are permittees in the allotment.
Permittee Eddie Wardell took issue with the overall negative tone of the DEIS, not toward just livestock but toward "other users of the forest who produce the goods and services we all need in our day-to-day lives."
Wardell's letter pointed out that some of the problems discussed in the DEIS are the result of government agency action or management, such as transplanting brook trout into streams, aiding the demise of the native cutthroat trout populations.
Wardell maintains that it is impossible to implement the Forest Service's proposed alternative with the mitigation measures it proposes and still meet the goals and objectives of the forest plan. He urged the agency to continue with the existing management alternative.
Wardell also pointed out, "There are many errors, omissions and misstatements of fact in this document," a problem pointed out by other permittees as well.
Natural resources consultant Kelly Crane, now of Oregon, has extensive experience monitoring the Upper Green range in his former role as the extension range specialist for the University of Wyoming. He submitted a letter of comment addressing technical matters, pointing to flaws in the analysis. Crane asserted "at a landscape scale, the current management strategy is consistent with forest plan standards and management objectives."
Crane concluded: "The existing ecological conditions on the Upper Green River allotment do not warrant major changes in livestock management." He suggests that some of what the Forest Service has proposed in the preferred alternative "seems a little reckless."
Crane wrote: "My overall assessment of this DEIS is that the preferred alternative is not consistent with the information presented. The U.S. Forest Service proposes relatively subtle changes in livestock management to address what is portrayed as catastrophic environmental conditions. This apparent contradiction between the preferred alternative and the affected environment will undoubtedly haunt the Forest Service in future land management planning."
Permittee Charles Price wrote comments noting that the range evolved with a heavy grazing ungulate, the bison, as a necessary and important part of the ecosystem. Price suggests: "To maintain a healthy ecosystem, it is imperative that this part of the ecosystem be maintained and conserved. The cattle fill this need today. The range in the Upper Green River must have the heavy grazing ungulate in order to reach its full natural potential."
Price wrote, "One of the things that surprised me as I read through this report was its very negative portrayal of grazing on the Upper Green River," especially since the agency usually maintains that the permittees are doing a good job of managing their grazing on the forest allotments.
Permittee Albert Sommers agreed with Price. He wrote, "I find it personally very frustrating that the Forest Service never acknowledged in the DEIS what good stewards of the land we have been."
Sommers pointed out: "Over the years, when concerns have arisen about cattle impacts to the resource, the Upper Green River Cattle Association has worked diligently to solve the problems. We have hired additional riders, tried electric fencing, developed a monitoring program, reduced numbers in drought, moved cattle off the allotment early, and tried different grazing regimes. We have conducted these management options with the help of the Forest Service, but rarely at its insistence. ... We have accomplished or exceeded nearly every expectation the Forest Service has had for our allotment."
Sommers' 16-page comment letter addressed three major areas of concern: the scope of the document, mitigation measures and the fisheries analysis. Sommers, in a detailed manner, questioned the methodology of the fisheries analysis and the science behind the mitigation measures, suggesting a personal bias was a factor.
Sommers maintains that current management allows for changes to meet the needs on the allotment, with permittees dedicated to responding to concerns, and the result has been an upward trend in conditions.
"Current grazing management has a system to respond to areas of concern, and positive results have occurred from that process," Sommers wrote. "This process allows a forum in which the Forest Service and permittees can visit an area of concern, establish objectives, develop solutions, and monitor progress."
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