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To The Editor:

  I noticed a mistake in the predator kill story in the Jan. 30 edition of the Roundup. Mike Boyce of the Wyoming Game and Fish Department (WGFD) was quoted as saying that WGFD pays “seven-to-one for wolf kills.” I would like everyone to understand that wolf compensation only occurs within the former “trophy” zone. If the predation occurs in the former “predator” zone there is no compensation. 

When Judge Jackson put wolves back under federal control in September 2014, the state of Wyoming no longer had any authority over wolves. However, since the state had legislation in place regarding wolf management and compensation, they decided to continue their compensation program just as if they still had management control. So, as the situation now stands, the state of Wyoming is compensating some livestock producers and not others based upon some arbitrary “zones” that are currently useless, since a producer in the predator zone has no more ability to deal with the problem than the producer in the trophy area. 

I don’t know if Mr. Boyce was misquoted for the article or if he doesn’t understand the program.  I don’t understand how the State can run their compensation program in this manner when the wolves are under federal control.     


 Kelly Graham


Note from the Editor: We appreciate Mr. Graham for pointing out this oversight in the article. Thank you for clarifying this important distinction. No compensation is provided for wolf losses in the former “predator” zone.

To the Editor:

Wyoming agricultural producers welcome genetically engineered (GE) crops.  We all enjoy the economic and environmental benefits of GE crops.  We grow GE alfalfa, sugarbeets and corn.  Soon, more Wyoming crops will be GE.

In the upcoming session of the Wyoming Legislature, a resolution, HJ0001, “Labeling for genetically engineered items,” is sponsored by the Joint Agriculture, State and Public Lands and Water Resources Interim Committee.

This is a resolution “requesting Congress to enact legislation reaffirming the United States Food and Drug Administration as the primary authority in uniform food labeling related to genetic engineering.”

You can find HJ0001 at the Wyoming Legislature Service Office website,

Should food from GE crops be labeled as such?  I say no. The truth is that all crops are genetically modified in many ways and often using technology much less precise than GE.

HJ0001 is simply a resolution.  It has no power of law.  Yes, HJ0001 is well-intentioned.  But it must not be passed because it will make Wyoming look ignorant, stupid, or both. The anti-GMO crowd will jump all over the HJ0001 errors, inconsistencies and bad grammar.

HJ0001 states that it has to do with “labeling for genetically engineered items.”  But really, HJ0001 is about “food” or “crops” or “plants,” not “items.”  HJ0001 should have nothing to do with GE pharmaceuticals or industrial products.

HJ0001 is “requesting Congress to enact legislation reaffirming the U.S. Food and Drug Administration as the primary authority in uniform food labeling related to genetic engineering.”

But there is nothing to “reaffirm.”  The Food and Drug Administration (FDA) has nothing to do with GE labeling and never did.

The rationale for a resolution is built into its “Whereas” statements.  Let us consider the 11 “Whereas” statements in order.

Whereas 1: This refers to a “biogenetic organism.” This is a term that no agriculturist or biologist would ever use in this context.

Whereas 2: This Whereas does not go far enough.  It does not say that that GE plants are probably “safer than safe.” GE is so much more precise than classical plant breeding.

Whereas 3: The phrase “genetically engineered technology” is grammatically incorrect. The “technology” is not “genetically engineered.” Plants are. Otherwise, this is a fine Whereas.

Whereas 4: We’ve been growing GE crops for 20, not 25, years.  The first GE crops were grown in 1996.  It was a bit later that GE crops first appeared in Wyoming.  Since 1996, nearly 5 billion acre-years of GE crops have been grown world-wide, with excellent results, and excellent results in Wyoming.

Whereas 5: Okay. So much of our food comes from GE plants directly consumed by human beings or indirectly via livestock that consume GE feed.

Whereas 6: Excellent!  This is the core of HJ0001.  A “patchwork of state and local mandatory labeling laws” would be a disaster for both American producers and consumers.

Whereas 7: Regarding a “national solution,” it already exists in the U.S. Constitution. The “Commerce Clause” is found in Article I. The “Supremacy Clause” is found in Article VI. So many agriculture advocates, like me, observe that the several state and local mandatory labeling laws that were recently enacted, but not yet enforced, will be voided as unconstitutional.  Also, note that beyond a “national solution,” we need an “international solution.” It’s no secret that some other nations are using “anti-GMO” laws to impede American exports of food, feed, and seed.

Whereas 8: Here the proposed resolution would “affirm the Food and Drug Administration as the nation’s authority for the use and labeling of genetically modified foods.”

Nonsense! The Wyoming Legislature must not resolve to “affirm” an “authority” that FDA does not have and has never had.  Once FDA has determined safety of a GE plant or any genetically improved plant FDA requires no labeling. Yes, FDA has authority for oversight of labeling of ingredient composition and nutritional content of processed foods. But, no, FDA has no authority regarding labeling of GE content of foods and never did.

It is important to acknowledge that not only FDA has responsibility for determining safety of GE plants in America.  USDA-APHIS and EPA are involved too.

World-wide, we have grown nearly 5 billion acres with overwhelmingly positive results.  GE crops save our soil and reduce our carbon footprint.  Yes, GE biotechnology must be deployed judiciously to avoid evolution of weed, pest and pathogen resistance. We can do that.

Whereas 9: Here HJ0001 proposes that a national solution will require the FDA “to conduct a safety review of all new genetically engineered ingredients before they are introduced into commerce.” But FDA already does this.  And no labeling of safe ingredients is required. Here HJ0001 invites federal overregulation. Why do that?

Whereas 10: Pointless.  Companies are already free to voluntarily label their products as GE or non-GE.

Whereas 11: Bad. Surely, the Wyoming Legislature does not want the FDA to define the word “natural,” do they?

The missing whereas: It is unfair that food labeling laws would disadvantage GE foods and food ingredients when many classical plant breeding and plant biotechnologies are more likely to result in unexpected and undesirable outcomes in terms of human health, economy, and environment.

In the early days of GE, 20 years ago, it was we in the plant genetics, breeding and biotechnology community that insisted on intense scrutiny of newly emergent technologies for crop improvement.  Job done.

Now we know. GE biotechnology is safe. Safer than some traditional technologies for plant genetic improvement. Safer than some other emergent biotechnologies.

Years ago, in 2004, a thorough evaluation of plant genetic improvement by the National Academy of Sciences concluded that GE plant biotechnology is safe.  And safer than many traditional technologies and emergent biotechnologies.Now, 10 years later, as GE biotechnology has become more precise, we must conclude that plant GE technology is “safer than safe.”

Today, GE is heavily overregulated at the federal level. An invitation from Wyoming for even heavier federal regulation makes no sense.

OK. Now let us move on to the four sections that would “Now, therefore, be it resolved by members of the Legislature of the State of Wyoming:

Section 1: “That the Congress of the United States enact bipartisan legislation that reaffirms the Food and Drug Administration as the primary authority in uniform food labeling related to genetic engineering, based on scientific standards regarding health, safety and nutrition.”

But, as I have emphasized, FDA has no authority regarding GE labeling.  Why would Wyoming invite FDA overreach?

Section 2: “That existing Food and Drug Administration labeling rules and guidance, as well as the U.S. Department of Agriculture’s National Organic Program, provide sufficient standards to address consumer interest in food production practices through the use of truthful and non-misleading voluntary labeling.”

Regarding processed food ingredients and nutrition, FDA has great responsibilities.  But the FDA has no authority to label food regarding genetic modification, whether GE or non-GE, or whether by the vast diversity of classical plant breeding or ultra-modern biotechnologies. Also, FDA has no authority to label food regarding “food production practices.” Moreover, the USDA’s Organic Program is antiquated.

Section 3: “That the Commissioner of the Food and Drug Administration adopt policies, regulations and rules setting standards to address consumer interest in food production practices through voluntary labeling.”

My question: Is labeling “voluntary” when it must meet FDA “policies, regulations and rules?”

Section 4:  This last section of the HJ0001 would transmit the joint resolution to the President, the Senate and the House of Representatives of the United States.

Again, I ask, why would Wyoming invite federal overregulation of proven genetic technology for improvement of our state’s crops?


Robin W. Groose, PhD

Retired Professor of Genetics, Agroecology and Plant Breeding


To the Editor:

The recent article “Day looks at factors affecting climate change” was an interesting article, as my perception of the situation is that recently farmers in my part of the world – central Nebraska – either have or are coming to a consensus that climate warming is a problem that will have to be dealt with. Mr. Day makes the argument that there is some consensus of one leg of the stool, CO2 rise, but limited scientific consensus of the impact on water cycling and clouds, which in a sense are one and the same, and then infers no policy changes should be made.

Another interpretation of his article it is that it is an attempt to create a red herring, climate change, and beat it to death to distract folks from the real problem that is much larger. That problem is man-made environmental damage, of which climate change is a negative component, debatable as to the quantity man contributes, but it certainly is not zero.

Another component is the damage being done to the landscape. Strip mining is not without environmental impact. Yet another component is potential damages to water tables by fracking. All of these and more are the result of extractive energy industries and all are man-induced. It strikes me that anything done in the way of reducing extractive energy demands will have beneficial impacts on the planet – regardless of whether the policy change is for mitigating climate change, limiting fracking because of groundwater issues or preventing the massive reshaping of the landscape.

So if policy becomes mitigating climate change, either large or small scale, then how is that a problem? Advancing the argument we should not change policies because policies might cost money seems sort of weak to this writer.

For example, say we enact an expensive policy based on a faulty climate model that predicts a 20-foot sea rise, and it turns out to be only five feet. Is that really a disaster? That policy would have certain economic costs. However we should not overlook that even limiting sea rise to only five feet, based on a mistake, would still have a monstrous positive economic impact.

It is true that doing nothing costs nothing when the doer or industry is passing the full costs of their doing off onto the general public in the form of sea rise, erosion or water pollution. But it is a cost nonetheless and must be paid. Doing something like reducing fossil fuel use might cost the public something, but there are opportunity costs to doing nothing also – like Dade County in Florida disappearing under the Gulf of Mexico. I recently discovered the elevation in most of Miami is less than 20 feet above sea level and present hurricane surges are likely more than 15 feet. The highest points in town are apparently the landfills at maybe 30 feet. We apparently don’t need to worry about the rats. So what is the loss of Miami worth or what is the cost to build a sea wall probably 20 feet high or more to protect it? Don’t forget the pumps either.

Doing nothing regarding climate change might not be the best option.


John Hannah

Columbus, Neb.

Editor’s Note: This letter was sent on Nov. 4 to Neil Kornze, director of the U.S. Bureau of Land Management, from a group of 20 U.S. Senators and Representatives, including Wyoming’s Sens. John Barrasso and Mike Enzi and Rep. Cynthia Lummis.

Dear Mr. Kornze:

Across the West, management strategies of the wild horse and burro populations have been largely unsuccessful, resulting in significant rates of overstocking in both designated Herd Management Areas (HMA) and holding facilities, poor herd health and established herds in non-HMA locations. Almost half of the 100,000 horses under the purview of the Bureau of Land Management (BLM) are located in holding facilities off the ranges, and adoptions have fallen almost 70 percent in the last 10 years. Your agency has estimated a lifetime cost of $50,000 per horse that remains in long-term holding after failure to be adopted. These are unnecessary costs – costs that are the clear result of poor management of populations that have exploded and recent Congressional actions that have limited agency purview.

Your agency estimates that the wild horse and burro populations have grown by more than 18 percent in the last year alone, resulting in significantly overstocked HMAs and overflow into non-HMA locations. Overstocking combined with failure to dispose of horses and burros has resulted in significant ecological damage to riparian areas, overgrazing and compromised water resources. Efforts to return HMAs to sustainable, appropriately stocked levels have resulted in costly litigation, which diverts valuable resources from the animals that require immediate active management. Delays in desperately needed agency action jeopardize not only the health of wild horses but other wildlife that rely on these land and water resources.

As we return to our states, we see firsthand the necessity of immediate action to address deficiencies in the management strategy. Improper management compromises equine health, habitat conservation efforts and allows for resource degradation and encroachment by invasive species that will affect wildlife, livestock producers and recreationalists for decades to come. As such, we ask that BLM provide information regarding the following items:

How many HMAs are currently stocked at rates greater than the appropriate management level (AML)?

How many horses or burros would need to be removed to meet range-wide AML?

How many horses or burrows would need to be removed to meet range-wide low AML?

The BLM has reported that adoption rates in recent years have decreased from historic highs more than a decade ago. Over the past five years:

How many horses and burrows have been adopted through the program?

How many of these have been over five years of age?

How many horses and burros have been placed in short- and long-term holding facilities?

How many have been placed in refuges or paid-for long-term holding facilities controlled by entities other than the agency?

Is the agency currently utilizing technological platforms to facilitate adoption?

Within the context of management and conservation of sage grouse habitat, wildfire prevention and general land health:

What would the agency require to achieve AML in three-, five- and 10-year time frames?

What would the agency require to achieve the low level of AML in currently overstocked HMAs within the existing tools and authorities in three-, five- and 10-year time frames?

At the agency level, what changes can be made to address pervasive overstocking, population explosion and environmental degradation?

What Congressional action could be taken to provide additional flexibility to facilitate effective management?

It is our understanding that fertilization suppressants like Porcine zona pellucida (PZP) immunocontraception have been largely ineffective in limiting reproduction on a perennial basis. If this is indeed the case, what other reproductive suppressants is the BLM currently considering?

If chemical castration/neuter alternatives to PZP do not exist, what action will the agency take in the interim until novel, more effective products exist?

In the most critical situations, what barriers exist to the effective utilization of pilot population control products to return HMAs to AML?

Do/will these pilot programs include a combination of sterilization, fertility, suppression, humane euthanasia and generally-based herd selections to impede future population escalation that would result in surpassing AML?

To this point, what combination of the above strategies has been most effective, and are there more effective options?

Going forward, what potential roles does the agency identify for Governors of states where wild horses and burros currently exceed AML?

Will the agency commit to engaging with state officials to devise and implement strategies for return to AML?

In addition to the above, we ask that you compose and provide us with four to six options, with various timeframes, and the costs associated with each that would effectively curb the overarching trend of overstocked HMAs. Included in these various action plans should be an accounting for impacts to the range that have already been incurred due to overstocking and the estimated time required to return these lands to healthy conditions for horses, wildlife and livestock. These impacts should include loss of forage due to overgrazing by wild horse and burro herds, treatments for invasive species, wildfire damage where applicable and other costs related to good range management.

At least one of these options should be a baseline. This baseline should represent the current path of the agency in which populations are increasing dramatically year on year, long-term holding facilities serve as permanent homes and gathers have been postponed or halted. This option should clearly delineate the number of horses and burros that will be on the range and in the holding facilities if current management practices are maintained, as well as financial and environmental costs of this approach.

At least one of the options should include actions required to achieve low AML for range-wide HMAs to allow for range recovery. It is our hope that the agency has already identified various ways to address the critical situation facing the wild horse and burro population. We also hope that the agency will rectify internal policy to allow for increased use of fertility controls including sterilization and fertilization suppressants, depending upon long-term efficacy.

We believe it is clear that the current management strategy of wild horses and burros has proven ineffective. Wildfire, drought and invasive species exacerbate poor range conditions caused by overstocked HMAs. Across the 10 western states where the BLM manages wild horses and burros, every state exceeds AML. In some cases, like Arizona, there are HMAs that surpass the agency-determined AML by more than nine times the allowable herd size. We understand long-term fertility control methods take time to develop and, once implemented, will maintain horse populations at more appropriate levels. In the interim, however, steps must be taken to decrease herd sizes to allow for rangeland recovery and effective management of future populations. As such, we ask for your thorough and timely consideration of these issues so that wild horses and burros do not continue to damage natural resources that are vital to ecological stability. We thank you for your review and timely response to this inquiry.


Sens. John Barrasso (R-Wyo.)

Mike Crapo (R-Idaho)

Steve Daines (R-Mont.)

Mike Enzi (R-Wyo.)

Jeff Flake (R-Ariz.)

Orrin Hatch (R-Utah)

Dean Heller (R-Nev.)

Mike Lee (R-Utah)

John McCain (R- Ariz.)

James Risch (R-Idaho)

Reps. Cynthia Lummis (R-Wyo.)

Mark Amodei (R-Nev.)

Jason Chaffetz (R-Utah)

Paul Gosar (R-Ariz.)

Raul Labrador (R-Idaho)

Steve Pearce (R-N.M.)

Adrian Smith (R-Neb.)

Chris Stewart (R-Utah)

Ryan Zinke (R-Mont.)