Our western lands

[Oak]

The point is that the BLM is failing at managing these lands, based on their own land health standards. The agency is chronically underfunded, and the easy place to make cuts is to grazing NEPA. There is nothing to keep the BLM (or FS) from renewing grazing permits without NEPA until your grandkids have grandkids. And why would you subject yourself to it when you know you're not meeting standards, and you know you have a multitude of conflicts such as Greater Sage-Grouse, Gunnison Sage-Grouse, bighorn sheep, cutthroat trout, etc.? NEPA analysis will lead inevitably to lawsuits.

The grazing system is broken. There is no flexibility. Most permittees are not in the position to just rest an allotment for a year or two if there is a drought or fire. The FS lets permittees use their permits as collateral for bank loans. The agency people making grazing decisions have kids that go to school with the kids of the permittees. They see each other in church and at the grocery store. How are they going to make a (correct) decision to reduce or eliminate grazing if it's necessary for the health of the land?

There will be a report out tomorrow that highlights just how few of the grazing permits on these BLM lands failing land health standards have been fully processed under NEPA. The vast majority have been renewed via the FLPMA 402(c)2 exception.

How do you think the health of these lands affects wildlife, like all of those missing pronghorn in WY? I asked the BLM for the allotment management plan for a single allotment near me earlier this year. They told me I had to submit a FOIA request and they would sent it right over. Once I did that, they assigned my request to the "complex track," which means 21 to 60 days to send me that single document. I told them that in that case I would exhaust my administrative remedies on the NEPA that was currently in process. They replied that there was a mistake and they sent me the document the next day. The allotment management plan in question was written in 1976! One part from the Objectives section really stood out to me:

A. Objectives
1. Provide 2227 AUM's of livestock forage on a sustained yield basis by
increasing the density and composition of desirable species, as shown below.
2. Provide 492 AUM's of wildlife forage to sustain existing populations by
increasing the density and composition of desirable species, as shown below.

I'm on vacation or I would write more.

Here is the StoryMap that came out this week, which I referenced above, regarding the number of BLM grazing permits which are not fully processed. Set aside the name of the organization at the top if you can, and just read through the information closely (the StoryMap app does not work on a phone well at all. Too much data). The information in the maps came straight from the BLM.

If you are not familiar with StoryMaps, the maps are fully interactive. You can zoom in and click on allotments for more information, etc. There are pop-up legends on the left side.

The takeaway is that an increasing number of BLM grazing allotments are being renewed without any environmental analysis. And this is especially true for allotments that are known to not be meeting land health standards and/or have wildlife conflicts.

StoryMap: Renew or Review

 

[mottlet]

Following up on Oak's post, here's the article from DC's major enviro/conservation trade publication on the report:

Many BLM grazing permits renewed without NEPA review, group says​

Western Watersheds Project says its review of federal data shows that 54 percent of permit renewals last year didn't receive a site-specific environmental analysis.

BY:
SCOTT STREATER
| 03/23/2022 04:20 PM EDT

Cows grazing in 2011 along a section of the Missouri River that includes the Upper Missouri River Breaks National Monument near Fort Benton, Mont.Matthew Brown/AP Photo

E&E NEWS PM | The Bureau of Land Management is failing to conduct an environmental analysis before renewing many livestock and sheep grazing permits across millions of acres of public lands in the West, an environmental advocacy group says.

Western Watersheds Project says its analysis of federal data shows that last year, more than half — 54 percent — of federal grazing allotment permit renewals were authorized by BLM without conducting site-specific environmental analysis of the rangeland as mandated by the National Environmental Policy Act.

The result is likely degraded federal rangelands, affecting everything from the survival of greater sage grouse habitat to the health of congressionally designated wilderness areas, argued the group, which has opposed livestock grazing on federal lands.

WWP officials said they shared the data earlier this month with BLM Director Tracy Stone-Manning, as well as Deputy Director of Policy and Programs Nada Culver, along with other senior bureau officials.
"Essentially, the Bureau of Land Management … has been failing to manage grazing on public lands to a large extent," said Josh Osher, WWP's public policy director, during a Zoom call with reporters. "The bureau has largely failed to comply with the law, and has a massive backlog of permits that don't have current NEPA analysis and don't have current land health evaluations."

BLM did not respond to a request for comment in time for publication.

But Kaitlynn Glover, executive director of natural resources for the National Cattlemen's Beef Association and executive director of the Public Lands Council, acknowledged in an emailed statement that NEPA backlogs "continue to plague many agencies."

But, she added, "to say that range conditions aren't being monitored is blatantly false. Ranchers and grazing permittees engage in regular range monitoring that informs their grazing decisions, and because their ecological data is accurate and timely, they are able to make responsible management decisions in real time."

The problem, according to Western Watersheds Project, has its origins in a 2014 congressionally authorized loophole amending the Federal Land Policy and Management Act to allow BLM to reauthorize the 10-year grazing permits without making any changes in the permit conditions, pending completion of NEPA analysis.

The idea, from lawmakers' perspective, was to allow grazing activity to continue while granting BLM more time to whittle down the backlog of NEPA reviews.

But WWP said its review of BLM's publicly available schedule information database shows that many of these NEPA reviews aren't being scheduled and completed, making it difficult to know the exact condition of specific rangelands at a time when drought is gripping most of the West.

The WWP review follows a report earlier this month from Public Employees for Environmental Responsibility that found roughly half of the 108 million acres of land that has been leased by BLM for livestock grazing does not meet baseline rangeland health standards (E&E News PM, March 14).
WWP says its review of federal records shows the volume of grazing permits being renewed without NEPA review has steadily gotten worse.

The data reveal that in 2013, about 28 percent of grazing allotment permit renewals on federal lands were authorized without any NEPA analysis.

By 2017, that number rose to 38 percent; last year, it grew to 54 percent.

"The bureau has actually sharply reduced the number of new NEPA analysis for grazing allotments, and is still woefully behind on land health evaluations, as well," Osher said. He characterized the lack of action as negligence.

"There's clear evidence that the lands under the bureau's protection are unhealthy due to grazing, and the bureau's land managers are just willfully disregarding the law," he said. "They're just simply not doing what's necessary to be done. It's really unacceptable, and it needs to be dealt with as soon as possible."
The backlog in NEPA reviews has broad implications for federal lands, the group says.

Among other things, Osher said the data shows that many of the grazing permits that have not undergone NEPA analysis are in areas containing designated priority habitat for the greater sage grouse, or in areas designated as sagebrush focal areas — habitat that BLM and the Fish and Wildlife Service have deemed critical to the bird's survival.

In addition, BLM resource management plans, which outline landscape health condition goals and parameters for grazing within the boundaries of each land use plan, specifically don't take effect until after site-specific NEPA reviews are done.

If those reviews aren't done, the grazing goals and conditions in the resource management plans "aren't worth the paper they're written on," Greta Anderson, WWP's deputy director, said during today's Zoom call.

This lack of commitment by BLM to conduct the site-specific NEPA reviews raises questions about the Biden administration's commitment to sweeping conservation measures like the "America the Beautiful" initiative to conserve 30 percent of public lands and waters by 2030, Osher said.

"It's disingenuous for the administration to go forward with a program like 'America the Beautiful,' and ignore the impacts of livestock grazing, and ignore the fact that they're not even looking at the impacts of this activity," he said.

Osher said BLM must make the site-specific NEPA reviews a top priority for federal rangeland managers, and it needs to beef up rangeland staff at the bureau to address the backlog.

"I think we all have hope that the Biden administration is receptive to this information and intends to take it into account in their future planning," Anderson said. "We just really want to raise the awareness for everybody that this is a huge, ongoing problem on Western public lands."

 

[kwyeewyk]

Here is the StoryMap that came out this week, which I referenced above, regarding the number of BLM grazing permits which are not fully processed. Set aside the name of the organization at the top if you can, and just read through the information closely (the StoryMap app does not work on a phone well at all. Too much data). The information in the maps came straight from the BLM.

If you are not familiar with StoryMaps, the maps are fully interactive. You can zoom in and click on allotments for more information, etc. There are pop-up legends on the left side.

The takeaway is that an increasing number of BLM grazing allotments are being renewed without any environmental analysis. And this is especially true for allotments that are known to not be meeting land health standards and/or have wildlife conflicts.

StoryMap: Renew or Review

I think in general this is a pretty fair assessment of the situation, but it does miss some details of certain aspects that would provide some context.

For example, historic grazing certainly lowered the baseline of forage availability and in many areas set the stage for transition to annual grass dominated states that will never recover without cost-prohibitive restoration. These areas don't meet land health standards and current grazing contributes, but removing cattle at this point won't fix it, so better to focus on areas that can still be improved or maintained.

And as you mentioned, staffing/funding shortages and lots of competing priorities, conflicting direction and litigation makes completing the assessments and NEPA on time extremely difficult. I think just in WA where there's comparatively little BLM there's close to 300 allotments, and currently 1 full time range specialist. 21000 allotments across the west.

But there is no doubt that BLM has always had a hard time standing up to grazing operators that over stock and don't follow AMPs and other regs. Bundy was the ultimate demonstration of that. Managers don't want a fight, and Directors put their thumb on any that do, and congress continues to send the message that it's what they want.

Until BLM is given clear direction and the teeth to enforce, the appropriations act will continue to be used and abused to avoid conflict with grazing operators. After the feds essentially got their asses handed to them twice by the Bundys, the appetite for challenging is pretty small. Unfortunately I don't see it changing any time soon.

I'd encourage people interested to learn about the 17 indicators of land health and how the evaluation/assessment process works. I think it's actually a good approach and it's encouraging to see some honesty in the land health assessments, it's the first step to fixing problems and BLM could easily have easily influenced the results to tell a more positive story.

 

[Thx1138]

I'm curious how people get paid 1600 bucks for wild horses? And they go to a slaughter house?

Apparently thousands……….https://returntofreedom.org/its-time-to-shut-down-the-slaughter-pipeline/

 

[BWALKER77]

Apparently thousands……….https://returntofreedom.org/its-time-to-shut-down-the-slaughter-pipeline/

We have to get those numbers up!

 

[Oak]

2/6/2018

Dear Oak:

The domestic sheep grazing permit on the [allotment 1], [allotment 2], [allotment 3],
[allotment 4], and [allotment 5] allotments will expire on Feb 28. 2018. The
domestic sheep grazing permit on the [allotment 6] Allotment will expire on March 31, 2018.
Due to other priority workloads the resources staff is not be able to complete an environmental
assessment before the permits expire. Therefore new permits will be issued for a three year term
under the authority of Section 402(c)(2) of FLPMA. 1976 as amended, and contain the same terms
and conditions as the previous permits.

Sincerely,

BLM Acting Assistant Field Manager


11/6/2020

Dear Oak:

This letter is to update you on the status of the grazing permit renewals in the XXXXXXX
area.

This summer the XXX Field Office resources staff performed land health
evaluations on [all those] Allotments. My staff will be compiling the
information collected in the evaluations.

Our plan was to complete an environmental assessment for the XXXX Ranch livestock grazing
permits this winter that are set to expire on March 31 , 2021. However, a combination of the
following issues has complicated our timeline.

Based on the current issues and vacancies I have decided to delay the start of the environmental
assessment until next fall.

Sincerely,

BLM Field Manager


4/7/2022

Dear Oak:

I wanted to keep you in the loop on what's going on with the XXXX sheep permits in [that] area.
We issued those permits last year for a 1 year period and planned on completing the NEPA to review
those permits this past winter. Due to other priorities, we were not able to complete NEPA this winter
and will issue the permits again under the FLPMA provisions. We intend to revisit this project
within the next few years and will reach out for more input at that time.

[no signature]

 

[longrunner]

2/6/2018

Dear Oak:

The domestic sheep grazing permit on the [allotment 1], [allotment 2], [allotment 3],
[allotment 4], and [allotment 5] allotments will expire on Feb 28. 2018. The
domestic sheep grazing permit on the [allotment 6] Allotment will expire on March 31, 2018.
Due to other priority workloads the resources staff is not be able to complete an environmental
assessment before the permits expire. Therefore new permits will be issued for a three year term
under the authority of Section 402(c)(2) of FLPMA. 1976 as amended, and contain the same terms
and conditions as the previous permits.

Sincerely,

BLM Acting Assistant Field Manager


11/6/2020

Dear Oak:

This letter is to update you on the status of the grazing permit renewals in the XXXXXXX
area.

This summer the XXX Field Office resources staff performed land health
evaluations on [all those] Allotments. My staff will be compiling the
information collected in the evaluations.

Our plan was to complete an environmental assessment for the XXXX Ranch livestock grazing
permits this winter that are set to expire on March 31 , 2021. However, a combination of the
following issues has complicated our timeline.

Based on the current issues and vacancies I have decided to delay the start of the environmental
assessment until next fall.

Sincerely,

BLM Field Manager


4/7/2022

Dear Oak:

I wanted to keep you in the loop on what's going on with the XXXX sheep permits in [that] area.
We issued those permits last year for a 1 year period and planned on completing the NEPA to review
those permits this past winter. Due to other priorities, we were not able to complete NEPA this winter
and will issue the permits again under the FLPMA provisions. We intend to revisit this project
within the next few years and will reach out for more input at that time.

[no signature]

To be renewed under FLPMA, the allotment must be meeting land health standards, most are not, thus are ineligible. See the Range section starting on page 45.

https://www.blm.gov/sites/blm.gov/files/AboutUs_LawsandRegs_FLPMA.pdf

 

[Oak]

To be renewed under FLPMA, the allotment must be meeting land health standards, most are not, thus are ineligible. See the Range section starting on page 45.

https://www.blm.gov/sites/blm.gov/files/AboutUs_LawsandRegs_FLPMA.pdf

There is no requirement that the allotment be meeting land health standards to be renewed under 402(c)2. An allotment must be meeting standards to be renewed with a CE.

 

[Big Fin]

This information is not in a report, rather my first-hand experience as the Trustee of a Trust that holds a 6,400 acre allotment in a Designated Wilderness Area.

We have been trying to retire the allotment for sometime. There are high user conflicts, high predation from wolves and grizzlies, and it is a tough place to run cattle. Far better suited for other animals to forage; animals accustomed to that landscape. This allotment has been in the family's corporation for many, many decades.

The landowners want to retire the allotment and have asked the USFS for language that would allow the allotment to stay vacated and retired if this corporation/trust were to retire and vacate their forage rights under the allotment. As the representative in this matter, I am told the Forest Service cannot or will not provide such protection.

In other words, if this conservation-minded family vacates the allotment, there is risk it will be reissued. The family is doing this to reduce user conflicts and get cattle off a landscape that has little forage and allow that forage for wild foragers. They are not doing this so another producer can grab the allotment and run the same 90 AUMs. That defeats every reason for doing this. They have already used most of their allowed "open" years of not grazing the allotment, due to how low the forage has been in the recent drought years.

Point being, some landowners want to do the right thing, yet the institutional inertia in the grazing departments of USFS/BLM don't allow for doing the right thing, especially when the politicians start putting pressure on them to open more lands to grazing, not less.

I have no problem with public land grazing done correctly and in consideration of disease and other impacts to native flora/fauna. It can add benefit in many instances. The water infrastructure is now essential to wildlife in many states where human development and P-J encroachment has removed all surface water historically used by wildlife. Yet, in my years of working on this allotment retirement and trying to negotiate public access easements across these private lands, I'm finding it rather difficult to do the right thing for the land and native flora/fauna.

 

[kwyeewyk]

Point being, some landowners want to do the right thing, yet the institutional inertia in the grazing departments of USFS/BLM don't allow for doing the right thing, especially when the politicians start putting pressure on them to open more lands to grazing, not less.

I think it's even deeper, I believe the BLM grazing regulations actually say basically that if a permitee doesn't make use of an allotment the grazing rights to the allotment will be awarded to the next most appropriate applicant for the allotment.

That also makes it hard to establish a "grazing bank" of lands where use can be shifted to following wildfire etc to allow proper rest and recovery of burned or otherwise disturbed allotments.

 

[OntarioHunter]

A lot to digest here. Thanks for all the input.

 

[Hydrophilic]

Groups say BLM ignoring environmental concerns when issuing grazing permits • Oregon Capital Chronicle

Environmental groups found BLM renewed grazing permits in Oregon without full environmental review, livestock allowed on overgrazed land.

oregoncapitalchronicle.com

 

[Oak]

Update:

Suit: BLM environmental reviews lacking for grazing in Colorado, other states

A new lawsuit accuses the Bureau of Land Management of often failing to do required environmental reviews of grazing permits in Colorado and other western states, particularly in areas in

www.gjsentinel.com