Guardians of the Range

Issues

BLM ISSUE

TALKING POINTS ON GRAZING FOR USE IN DEVELOPING THE BUREAU OF LAND MANAGEMENT'S (BLM)

BIG HORN BASIN RESOURCE MANAGEMENT PLAN

Cody & Worland Field Offices

CONCERNS AND PERSPECTIVES GUARDIANS OF THE RANGE & WYOMING STATE GRAZING BOARD

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COMMUNICATION

-- The BLM should ALWAYS consult, cooperate, and coordinate, with the permittees on ALL issues that affect the permittee at an early point in the process so that the permittees can provide feedback to the BLM and themselves be prepared for the ramifications of those subjects

-- BLM and permittees need to jointly develop site specific allotment resource objectives, ( desired plant communities, maximum/minimum bare ground cover objectives, bank stability on the green line, etc. ), and jointly develop a monitoring program to collect field data using science based methods to evaluate if those objectives are being achieved.

-- BLM should clearly convey to the permittees specifically what information about their ranch is REQUIRED by the BLM to be placed into the files, ( and convey what is NOT required ) and convey that ALL information in the allotment BLM files is available to the public.

-- The new RMP should clearly convey an intention by the BLM to give adequate notice to the permittees of BLM activities in their respective allotments, ( Standards reviews, upland rangeland health assessments, monitoring, "Interested public" tours, etc. ) and invite the permittees to attend those activities. BLM should ALWAYS provide duplicate copies to the permittee of ALL qualitative and quantitative information collected by the BLM in their respective allotments.

-- The new RMP should convey an intention by the BLM to advise the permittee of anyone signing up as an "interested public" on their respective allotments.

-- The BLM should inform the permittee a year in advance of the date for the renewal of a term grazing permit and convey to the permittee how the rancher can help the BLM in the renewal process.

-- If a "no grazing" alternative is to be developed either in a permit renewal EA or an EIS for the RMP, the narrative about what the land would look like under a "no grazing" alternative MUST be factual and reflect the current state of the art on this subject. ( Rangelands in the Big Horn Basin would become unhealthy and NOT look like the Tall Grass Prairie under a no-grazing situation ).

-- The BLM should periodically offer to review the allotment files with the permittee and offer to review the current AMP to insure that this document represents the current situation(s) in the allotment. Any changes in terms and conditions in the grazing permit/AMP, and any significant policy proposals in an RMP, ( on subjects like ACEC's and sage grouse for examples ), should consider the economic and practical impact of those changes on the permittee and other local entities such as county government and Conservation Districts.

-- BLM should recognize that their, ( BLM ), approval of Wyoming Game and Fish wildlife Department objective numbers to be maintained on lands within the boundaries of the Field Office Area means that these wildlife numbers must also be accommodated by the owners of the private lands and State leases in this geographic area.

-- This same principal applies to BLM decisions on what will be the AML numbers of "wild" horses in an HMA. Most horse management areas contain private and State land in-holdings that are unfenced and intermingled with the BLM lands. BLM horse use on private and State lands is an "unfunded mandate" imposed on these lands by the BLM.

-- Permittees should provide early communications, ( 6 months before the action is contemplated and in writing ), of the desires of the permittee to maintain their range improvements and/or construct new projects. BLM should respond within 30 days of the receipt of the request(s) from the permittee.

WILD HORSES & BURROS

IMPACTS OF 'WILD HORSES & BURROS ACT' WILL CONTINUE TO NEGATIVELY IMPACT RANGELAND RESOURCES AS IT RELATES TO GRAZING OPPORTUNITIES OF PUBLIC LAND RANCHERS. THIS RMP SHOULD ADDRESS THE NEED TO EFFECTIVELY PRECLUDE 'POLITICIZING THIS ISSUE' TO THE DETRIMENT OF RANGELAND RESOURCES AND PUBLIC LAND GRAZING.

MONITORING AND RANGELAND HEALTH TRENDS

THIS RMP SHOULD EMPASIZE THE NEED FOR GOOD DOCUMENTATION, AND THE AGENCY'S PUBLIC RESPONSIBILITY TO PROVIDE THE HUMAN RESOURCES NEEDED TO CARRY OUT THIS RESPONSIBILITY SO THAT AGENCY DECISIONS CAN BE SUCCESSFULLY DEFENDED IN APPEALS AND COURT CHALLENGES.

SPECIAL MANAGEMENT AREAS

ESTABLISHMENT OF ' SPECIAL MANAGEMENT AREAS'(SMA) AND THEIR VARIATIONS WOULD MARGINALIZE GRAZING OPPORTUNITIES AND GRAZING RIGHTS AND THIS IS A SERIOUS CONCERN AND ISSUE. PROPER IMPLEMENTATION OF EXISTING PUBLIC LAND LAWS AND REGULATIONS SHOULD PRECLUDE THE NEED FOR ANY SUCH RESTRICTIVE 'OVERLAYS'.

AUMs

WE ARE CONCERNED THAT REDUCTION IN 'AUMS' WILL BE SEEN AS THE QUICK FIX FOR ANY ISSUES RAISED RELATIVE TO RANGE RESOURCES. THIS ENVIRONMENTAL ASSESSMENT REQUIRES A POLICY SOPHISTICATION AND MATURITY FOR FINDING SOLUTIONS WHICH REFLECT FAIRNESS UNDER THE LAW AND RESPECT FOR ALL STAKEHOLDERS.

WATER QUALITY

WATER QUALITY CHALLENGES MUST BE ADEQUATELY ADDRESSED IN THE REVISED RMP. WE WANT TO SEE SERIOUS SCIENCE DOCUMENTED AND USED TO ESTABLISH THE WATER QUALITY SITUATION IN THIS RESOURCE AREA. WE DO NOT WANT THE BLM TO SIMPLY AGREE WITH ANY CHALLENGES TO WATER QUALITY, WE WANT TO SEE THE AGENCY CLEARLY ESTABLISH ITS OWN CREDIBLE ASSESSMENT OF ANY WATER QUALITY CHALLENGES, AND NOT SIMPLY ASSUME A PROBLEM EXISTS. WE WANT THE BLM TO BE AHEAD OF THE CURVE ON THIS, AND NOT EXPEND TIME AND MONEY BEING SIMPLY REACTIVE TO OUTSIDE INTERESTS.

ADAPTIVE MANAGEMENT

ADAPTIVE MANAGEMENT IS A PROACTIVE MANAGEMENT TOOL THAT WE WOULD WANT TO SEE FULLY EMBRACED RELATIVE TO LIVESTOCK GRAZING IN THIS REVISED RMP. WE WANT THIS RMP TO BE FLEXIBLE ENOUGH TO RESPOND QUICKLY TO BOTH PROBLEMS AND SOLUTIONS------------. THIS DOCUMENT SHOULD RELFECT A PUBLIC POLICY MATURITY AND FLEXIBILITY WHICH BENEFITS THE RANGE RESOURCES AND RESPECTS RESONABLE MANAGEMENT APPROACHES TO PUBLIC LAND GRAZING.

WEED AND INVASIVE SPECIES

THIS IS A SERIOUS AND INCREASINGLY SIGNIFICATE ISSUE IN THE BIGHORN BASIN AND NEGATIVELY AFFECTS BOTH WILDLIFE AND LIVESTOCK HABITAT. WE WANT TO SEE SERIOUS EFFORTS SETFORTH TO RECOGNIZE, ADDRESS AND FUND MITIGATION MEASURES TO TURN THIS DESTRUCTIVE ISSUE AROUND.

RANGE IMPROVEMENTS

THIS IS A 'SLEEPER' ISSUE AND ONE THAT IS SIGNIFICANTLY AFFECTED BY BUDGETARY CONSTRAINTS. PUBLIC LAND RANCHERS ARE ALL TOO OFTEN JUDGED IN THE COURT OF PUBLIC OPINION WHEN PEOPLE SEE DETERIORATED AND DEGRADED RANGE CONDITIONS AND PROJECTS. WE WOULD WANT THIS RMP TO SUBSTANTIVELY RECOGNIZE THAT RANGE IMPROVEMENTS SHOULD NOT BE 'BACK BURNERED' AD INFINITUM TO THE DETRIMENT OF BOTH THE RANGE RESOURCES AND THE PUBLIC LAND RANCHERS. WE FULLY RECOGNIZE AND RESPECT THE FACT THAT ALL RANGE IMPROVEMENT FUNDS ARE NOT EARMARKED FOR THE SOLE PURPOSE OF LIVESTOCK. HOWEVER, WE WANT TO SEE THAT THE NEED TO KEEP UP WITH RANGE IMPROVEMENTS FOR THE BENEFIT OF BOTH WILDLIFE AND LIVESTOCK IS RECOGNIZED AND IMPLEMENTED IN THIS REVISED PLAN.

SAGE GROUSE & ADAPTIVE MANAGEMENT

WE SUPPORT THE ADAPTIVE MANAGEMENT (Recommended Management Practices-RMPs) OF LIVESTOCK ON PUBLIC LAND AS SET FORTH IN THE BIGHORN BASIN SAGE-GROUSE LOCAL WORKING GROUP CONSERVATION STRATEGY PLAN AS ADOPTED IN NOVEMBER 2007 BY THE WYOMING GAME AND FISH COMMISSION. THE APPROACHES SET FORTH IN THIS PLAN, RELATIVE TO LIVESTOCK MANAGEMENT, WILL RESPOND EFFECTIVELY AND REASONABLY TO SAGE-GROUSE HABITAT MANAGEMENT AND PRODUCTIVE LIVESTOCK MANAGEMENT.