Letter to Secretary Zinke
April 18, 2017
Dear Secretary Zinke,
I write today to express my concern with the Bureau of Land Management’s (BLM) guidance for livestock grazing management related to Approved Resource Management Plan Amendments (ARMPAs). The current approach to Greater sage grouse management has the potential for a negative impact on Wyoming. Wyoming agriculture and Greater sage grouse management have a symbiotic relationship. They should not work in opposition.
Viable ranching operations in Wyoming provide one of our most important assets – open, unoccupied space. This space allows for open landscapes, recreational opportunities, clean air and water, food production and intact ecosystems. The Greater sage grouse thrives here in great part because of our agricultural operations. Livestock grazing on public lands and flexible livestock grazing are necessary for viable ranching operations. Flexibility benefits agriculture and Greater sage grouse habitat conservation.
I have worked to conserve Greater sage grouse habitat and to prevent an Endangered Species listing. Wyoming’s Greater Sage Grouse Core Area Protection strategy is based on the principle that conservation of important Greater sage grouse habitat and development of resources are not mutually exclusive. Wyoming’s strategy addresses grazing management and recognizes a process to deal with improper grazing practices that might impair Greater sage grouse habitat. BLM adopted this concept in its ARMPAs. Despite repeated attempts by the State of Wyoming, local governments and producer groups such as the Wyoming Stock Growers Association, to resolve issues with BLM guidance, concerns with consistency remain. Consistency exists between the ARMPAs and Wyoming’s strategy, but guidance does not provide the necessary elements to make it consistent with these same documents.
BLM lacks guidance that recognizes the relationship between proper grazing practices and Greater sage grouse conservation. My concerns have not been addressed in existing guidance and are not covered by your planned re-evaluation of mitigation policies under Secretarial Order 3349. Clear guidance is needed to address livestock grazing on federal lands. For example, seasonal habitat objectives could be applied as standards. As a result of the lack of guidance on this issue, BLM might, for example, use a one-time measurement of stubble height to determine if an objective is met and treat a failure to meet that objective as a reason to change livestock grazing permit terms and conditions. This example would be unjustified and not based on reason or science. Addressing this concern and others like it through guidance will assure management isn’t done to the detriment of Greater sage grouse and agriculture.
I ask that you work with local producers and local and state governments in evaluating guidance for Greater sage grouse management. Our local producers understand the areas they operate on and should be consulted.
If I can be of assistance, please contact me.
Matthew H. Mead,