Gunnison BLM Domestic Sheep EIS

[Oak]

Sexy, sexy stuff here, folks! That's why you clicked!

The Gunnison BLM Field Office has (finally!) released a draft EIS to public comment for the renewal of 9 domestic sheep allotments, three of which are smack in the middle of the Tier 1 RBS-21 (S21/S33) bighorn sheep herd. I wrote my first scoping comments on this analysis over 7 years ago when an EA was being proposed. Then they went to an EIS process in the spring of 2015 and 4 years later we have a draft to review. You can read the draft EIS by clicking the "Documents" tab at this link.

After all of that, the proposed action is to continue grazing all nine allotments and to use terms and conditions in individual permits (listed in the EIS) to reduce the risk of contact with bighorn sheep. The EIS notes that:

Terms and conditions added to grazing permits are assumed to be most effective for allotments in open, gentle habitat where domestic sheep can be easily controlled and monitored, with a large buffer between the two species (Wild Sheep Working Group 2012). A majority of the allotments are located in close proximity or overlap bighorn sheep summer range [alternatively referred to as core herd home range (CHHR) throughout this document], contain suitable connectivity habitat between allotments, and contain remote, rugged terrain where control of domestic sheep, locating strays, and monitoring Rocky Mountain bighorn sheep is difficult.

The EIS also says:

The S-21 herd is one of the few remaining indigenous bighorn herds in Colorado (Diamond and Banulis 2012); S-33 bighorns are also indigenous but have received augmentation. Recent years have seen a decline from an estimated 400 bighorn in RBS-21 in 2013 to a 2015 estimate of 305 bighorn. There may have been an outbreak of disease in RBS-21, as blood samples from bighorn captured for a telemetry study showed high levels of M. ovipneumoniae in the winter of 2012–2013, and then lamb recruitment dropped to 13 per 100 ewes in the following season’s survey (CPW, unpublished data). The RBS-21 plan assumes an expected population of 400 to 500 animals and assumes densities that do not exceed 2.0 bighorn/km2 of modeled winter range.

Here's a map I put together of overall and summer range of bighorn sheep as mapped by CPW, overlaid with the nine allotments. Click for larger version. Hopefully it doesn't get reduced too small to read.


There are two public meetings this week if you're local and don't have something more important to do like clean the cat litter box. I'll probably be at both, so if you show up, say hi!

July 17, in Montrose from 5 p.m. to 7 p.m., at the Uncompahgre Field Office, 2465 S. Townsend Ave
July 18, in Lake City from 5 p.m. to 7 p.m., Coursey Annex (BOCC meeting room), 311 N. Henson St.

 

[Oak]

Here is a band of domestic sheep from the American Lake and American Flats allotments mapped above that was taken in late August of last year. However, this basin is in an adjacent allotment called the Bighorn Allotment, which was closed in 2009 to protect bighorn sheep. The American Lake Allotment is behind the photographer.

 

[Oak]

Although very difficult to see, this photo includes 5 bighorn sheep and 9 domestic sheep from the American Flats allotment on that flat in the middle. The photo was taken on Oct. 6, 2016, after the grazing season was over and the majority of domestic sheep had been removed from the allotments.

 

[Deleted member 28227]

1. Do you think commenting on that draft would be helpful.

2. Are there specific areas/themes we should focus on that would be most impactful?

Seem like this alone is a very compelling argument to get rid of the allotments:

 

[Oak]

1. It is definitely worth commenting on the draft EIS, with substantive comments.

2. The most compelling information to focus on is found in Appendix C, although it will make your eyes cross in short order if you're not familiar with the Risk of Contact model. The total herd contact rate is the important metric. A nearby USFS DEIS for renewal of some of their allotments stated:

An analysis of bighorn sheep disease outbreak intervals on the Payette NF (USDA Forest Service 2010d) concluded that using a moderate probability of disease transmission given contact (25% of contacts result in a disease transmission event), disease return intervals greater than about every 46 years (total contact rate less than about 0.08) had a high probability of maintaining long-term herd viability. Slightly higher contact rates were predicted to be likely to maintain long-term viability, but disease return intervals more frequent than about every 46 years could produce a low probability but high consequence event. Disease return intervals more frequent than about every 31 years were increasingly less likely to maintain long-term herd viability.

Their conclusion for that USFS analysis preferred alternative stated:

Therefore, under Alternative 4, the action alternative most likely to maintain bighorn herd persistence in the long term, concern remains for the potential for a disease transmission event in the Weminuche Landscape due to a number of allotment/bighorn herd combinations having predicted total herd contact rates more frequent than the levels thought necessary to maintain herd persistence for the long term.

Interesting to note that the total herd contact rates for the BLM proposed action in this analysis are in the range of contact rates for the above FS analysis, and well above the rate determined by the Payette to have a low probability of maintaining long-term herd viability. In fact, with the three high elevation allotments overlapping bighorn sheep summer range, the ROC model does not even produce an output (it measures the probability of a bighorn foraying outside of that range and contacting an allotment, so overlap equals constant contact).

So based on their own analysis and the findings of the courts in similar analyses, their proposed action results in a risk to bighorn sheep higher than levels thought necessary to maintain bighorn sheep in S21/S33. Important to note that the BLM policy manual (MS 1730) that guides management of domestic sheep and goat grazing in bighorn sheep habitat states:

Policy
The BLM’s policy will be to (1) achieve effective separation of BLM authorized domestic sheep or goats from wild sheep on BLM lands, and (2) to minimize the risk of contact between the species. Effective separation is defined as the spatial or temporal separation between wild sheep and domestic sheep or goats, resulting in minimal risk of contact and subsequent transmission of respiratory disease between animal groups (see glossary). Currently, physical separation of domestic sheep or goats from wild sheep is the only effective means to reduce the potential for pneumonia-type disease transmission. Domestic sheep and goat authorizations and other uses will be implemented to ensure that effective separation results in a high degree of confidence that there will be a low to no risk of contact with wild sheep.

 

[Big Fin]

The amount of work Oak and a few other Colorado Hunt Talkers do for wild sheep is astounding. Thanks for all you do and thanks for sharing this information here.

 

[Oak]

There are two public meetings this week if you're local and don't have something more important to do like clean the cat litter box. I'll probably be at both, so if you show up, say hi!

July 17, in Montrose from 5 p.m. to 7 p.m., at the Uncompahgre Field Office, 2465 S. Townsend Ave

July 18, in Lake City from 5 p.m. to 7 p.m., Coursey Annex (BOCC meeting room), 311 N. Henson St.

Welp, I was the only public at the first meeting. About 8 BLM, 1 CPW, 1 NPS, and me.

 

[noharleyyet]

Welp, I was the only public at the first meeting. About 8 BLM, 1 CPW, 1 NPS, and me.

...even odds tho. ; )

 

[Oak]

...even odds tho. ; )

I told them all I was just there to gather information so that I could lower the boom tonight. They all love me.

 

[Nameless Range]

Welp, I was the only public at the first meeting. About 8 BLM, 1 CPW, 1 NPS, and me.

I know nothing about Colorado sheep issues, but this is disheartening to hear.

 

[Big Fin]

I know nothing about Colorado sheep issues, but this is disheartening to hear.

I agree. I hope this is not indicative of the norm and that some strange circumstances were the cause of such paltry attendance by hunters. Thanks for all you do, Oak.

 

[Oak]

Last night's meeting had 3 BLM, 2 CPW, 1 county commissioner, 1 Cory Gardner rep (slept through the presentation), and me.

I learned that the BLM "preferred alternative" was Alt. C, but the WO told them to put the DEIS out for comment without a preferred. The effects determination for Alt C (emphasis theirs):

The BLM sensitive species determination for Rocky Mountain bighorn sheep is that Alternative C may impact individuals or habitat and may contribute locally towards need for federal listing. The primary reasons for this determination are close proximity of allotments or pastures to CHHR, potential for Rocky Mountain bighorn sheep forays intersecting allotments or pastures, mountainous terrain that makes monitoring for effective separation extremely difficult, and the risk associated with straying sheep. This alternative would reduce risk of contact between domestic and wild sheep by eliminating direct overlap of permitted pastures with bighorn sheep CHHR, but it would not eliminate the risk associated with potential bighorn sheep foray movements as described above.

I could write a couple of pages of absurdity from the last two nights when I asked pointed questions....

If anyone is interested in submitting substantive comments by the Aug. 11 deadline you can message me your email address and I will provide you some bullet point ideas to incorporate into your own comment letter.

 

[Khunter]

Last night's meeting had 3 BLM, 2 CPW, 1 county commissioner, 1 Cory Gardner rep (slept through the presentation), and me.

I learned that the BLM "preferred alternative" was Alt. C, but the WO told them to put the DEIS out for comment without a preferred. The effects determination for Alt C (emphasis theirs):



I could write a couple of pages of absurdity from the last two nights when I asked pointed questions....

If anyone is interested in submitting substantive comments by the Aug. 11 deadline you can message me your email address and I will provide you some bullet point ideas to incorporate into your own comment letter.

you have my email please send

 

[Oak]

The domestic sheep industry has gone from denying that pathogens from domestic sheep are an issue at all, to blaming other species for the pathogens, to now asserting that the BLM has no statutory authority to manage for separation of domestic and wild sheep.

Sheep Producers Support No Action Alternative in Colorado

The American Sheep Industry Association and the Public Lands Council completed comments this week concerning grazing permits administered by the Gunnison Field Office of the U.S. Forest Service.

“ASI and PLC join with their affiliate the Colorado Wool Growers Association in supporting the Bureau of Land Management’s Alternative B – No Action Alternative. Under the No Action alternative, livestock grazing allotments would continue to be permitted and successfully managed as they have over recent years,” read comments from ASI President Benny Cox and PLC President Bob Skinner. “Conversely, we strongly oppose Alternatives C, D, and E. The DEIS contemplates direction consistent with the BLM released manual MS-1730 Management of Domestic Sheep and Goats to Sustain Wild Sheep. ASI objects to the consideration of this guidance, as it is beyond the agency’s scope as designated by Congress. The authority to manage for spatial or temporal separation between domestic sheep and wild sheep is not contained in the document’s referenced statutory authorities. The agency’s prescribed management practices cannot exceed the scope authorized by Congress under relevant statute. Therefore, it is improper for the agency to cite, reference or apply MS-1730.

“In the alternative, should the agency find there is relevant statutory authority to consider separation based on concerns over pathogen transmission as part of its habitat management duty then it must also consider separation among bighorn populations. The DEIS incorporates Secretarial Order 3362, Improving Habitat Quality in Western Big-Game Winter Range and Migration Corridors as supporting the ‘long-term sustainability of Rocky Mountain bighorn sheep populations in Colorado.’ Specifically, ‘maintaining connectivity between populations (or between herds).’ Research in Wyoming and Montana has shown that in 77 percent of bighorn herds tested, Mycoplasma ovipneumonia (M ovi) was detected (Butler, et. Al. 2018). While the objective in that study was to determine how commonly the pathogens associated with respiratory disease are hosted by bighorn sheep populations, the study noted that minimizing the introduction of novel pathogens from domestic sheep and goats remains imperative and that ecological factors often determine population-level effects. Therefore, it follows that if minimizing the introduction of novel pathogens from domestic sheep is imperative, it must also be imperative between and among bighorn sheep. While this action broadly by the agency ‘would not create or influence this issue,’ the inclusion and implementation of Secretarial Order 3362 would, therefore it’s reference should be removed.”

Click Here to read the full comments.

 

[cur dog]

So, what's the story? Was it invite only? Did sportsmen not know about the meeting? Are these issues not of concern to people?

 

[justdada]

Shame on me for not becoming involved earlier... what can I do now to help pass along a message for the cause?? How do I find public input meetings and who needs to get an email from me?

 

[Dinkshooter]

A couple of things are going here:

1. We have a family man, everyday employee( Oak) fighting the fight for BHS regardless of his future employment opportunities. And this is a absolute concern.
2. It seems that that some of the biggest self proclaimed sheep advocates still have their hands in their pants about this stuff, Ah shucks keep doing what you do public land sheep grazers, we will work around you, Signed CPW and WSF.
3. So far the science is there regarding BHS advocates vs domestic sheep production. If you hear different please post up.

Colorado currently has a Governor that is sympathetic to wildlife problems as well as animal rights issues. He is also pro predator and pro wolf introduction thanks to the "first gentleman" (WETFTMs). So...................... what should be the call here? Do we continue to cater to domestic pubic land sheep grazers? Or should people in Colorado take the current opportunity with the people at the helm and try and get things straight?

 

[Art Vandelay]

A couple of things are going here:

1. We have a family man, everyday employee( Oak) fighting the fight for BHS regardless of his future employment opportunities. And this is a absolute concern.
2. It seems that that some of the biggest self proclaimed sheep advocates still have their hands in their pants about this stuff, Ah shucks keep doing what you do public land sheep grazers, we will work around you, Signed CPW and WSF.
3. So far the science is there regarding BHS advocates vs domestic sheep production. If you hear different please post up.

Colorado currently has a Governor that is sympathetic to wildlife problems as well as animal rights issues. He is also pro predator and pro wolf introduction thanks to the "first gentleman" (WETFTMs). So...................... what should be the call here? Do we continue to cater to domestic pubic land sheep grazers? Or should people in Colorado take the current opportunity with the people at the helm and try and get things straight?

So I’m reading between the lines here and you’re trying to tell us to shoot domestics. That is out of line sir!

 

[Ben Sellers]

So I’m reading between the lines here and you’re trying to tell us to shoot domestics. That is out of line sir!

I read his comment as a call to action to work within the political process that is underway to exclude sheep.

 

[onpoint]

I agree. I hope this is not indicative of the norm and that some strange circumstances were the cause of such paltry attendance by hunters. Thanks for all you do, Oak.

It's fun being the town crier ain't it Oak. Good work on behalf of the resource and the users.
On a more serious note, I had an interesting email communication a while back with the folks at Voormi wool products (Colorado - for those uninformed), they assured me that their company had an environmental and wildlife conscience. So, there is that.....