This past December 2018 the Bureau Field office of the Bureau of Land Management (BLM) released a final EA for the Battle Creek, East Castle Creek, and Owens Allotments Grazing Permit Renewal, at least partially within the Little Jacks Creek Wilderness, part of the stunningly beautiful Owyhee Canyonlands Wilderness Complex in Idaho.
The BLM grazing permit renewal would authorize extensive “range developments” including 30 miles of new fencing, 12 new troughs, and 9.6 miles of new water pipeline as well as motorized access—all this to accommodate increased livestock numbers.
Proposing new range “developments” is a typical ploy of the BLM to avoid eliminating or reducing livestock numbers. The BLM has been modifying the natural landscape to accommodate livestock for decades. The proposed new range developments would add to the already existing 24 stock ponds, 32 developed springs, and 494 miles of fence on the allotments.
The BLM authorized livestock Animal Unit Months (AUMs) utilization in this area is well above the much lower current use. This tactic is known in the agency as “paper AUMS,” and it’s another way the BLM can give the appearance of modifying livestock use without actually making any changes on the ground.
For instance, the Battle Creek allotment plan authorizes 11,399 AUMs per grazing season, a slight reduction from currently approved level of 11,477 AUMs. However, according to BLM’s estimates, average actual use on the Battle Creek allotment from 2008 to 2016 was 5,329 AUMs.
Therefore the agency can “reduce” authorized AUMS to give the appearance of decreasing livestock use, when, the current much lower use causing degradation can continue without any modification.
There are several reasons the BLM supports such proposals. First, range management responsibilities are under the authority of “range conservationists” or range “cons” as they are called.
The moniker is an appropriate name because range conservationists “con” the public into believing they are managing public lands for the public benefit when nearly all range cons identify more with the concerns of the ranchers than the public.
There is the recognition by at least some of the smarter range cons if there were no cows, there would be no employment for range cons. So, the BLM will do all kinds of gyrations and machinations to avoid eliminating livestock from our public lands-even when livestock removal is the most effective, and most economical action.
Finally, if you are a BLM officer whose responsibility is to manage these lands, you know that there will be political hell to pay if you call for a reduction in livestock numbers.
A further reason why range developments are almost always proposed to alleviate well-established livestock-induced damage is such measures give the appearance of taking “action.” Since the results and the “expected” improvements in rangeland health takes years to manifest, it effectively pushes off any responsibility for lack of progress unto some future BLM officials.
Even the BLM acknowledges that such ground disturbance, including the use of heavy equipment, and machinery will likely spread exotic species like cheatgrass. Cheatgrass is a severe threat to sagebrush ecosystems because it burns readily and is one of the significant factors in fire-induced sagebrush losses across the West.
Amazingly the BLM has concluded that all this development will not cause any significant impacts, not alter the natural, undeveloped character of the wilderness areas, nor harm sage grouse and riparian areas. Worse for the public interest, their proposed management lacks any measurable conditions or “thresholds” that would trigger livestock reductions or changes.
This landscape is terrain I know well, in part, because I worked for the BLM in the Owyhee country as a botanist where I witnessed firsthand the on-going livestock induced destruction of our public lands. Back in the 1980s, the BLM concluded that only a tiny fraction of the landscape was in “excellent” range condition and nearly 3/4 was in poor or fair condition which means the majority of plants favored by livestock that are supposed to be found on the site are absent or rare. Since that time the BLM has implemented numerous studies and issued revised grazing plans, but few real on the ground improvements have occurred.
In 2001 the BLM promised to prepare a new EIS to address the on-going degradation to our public lands by private livestock. Eighteen years later, the BLM has still not released any EIS.
In a 2008 review of a portion of the Owyhee area, the BLM concluded that livestock grazing violated every rangeland health standard from impacts to sensitive species to damage to wetlands and riparian areas. Sadly, this is the situation to one degree or another across the entire Owyhee region.
The public, not the ranchers, will be paying for many of these developments, and at the same time, it will expand on-going damage to our lands.
Tax dollars are not the only subsidies we provide these welfare ranchers. The real cost is the ecological damage done to our property by livestock producers.
Cattle grazing removes grasses and flowers that would otherwise support native species from butterflies to bighorn sheep. Cattle consuming forbs (flowers) rob sage grouse chicks of a vital source of food critical to early growth. Cows trample biocrusts that protects the soil from erosion and invasion by alien grasses like cheatgrass.
Cattle congregate in riparian areas damaging streambanks and consuming the green vegetation found along streams, seeps, and wetlands — their hooves compact soil reducing its water holding capacity.
These wetlands are critical habitat for sage grouse chicks, yet the BLM acknowledges that 59% of the springs and seeps, as well as 40% of the stream riparian areas, are non-functioning or functioning at risk.
In response to documented livestock impacts on our public resources, the BLM proposes construction of more water pipelines, fencing and water troughs. These developments are designed to “distribute” livestock impacts across more of the landscape. It is analogous to building a taller smoke stack to “distribute” toxics more widely. Indeed, the proposed developments will intensify cattle use of uplands that currently experience few livestock impacts.
These “solutions” create their own ecological impacts. Removal of water from springs and seeps for pipelines and water troughs means less water for native species like Columbia spotted frogs to birds that rely on natural water sources. Water troughs become breeding grounds for West Nile Virus which has been found to impact sage grouse negatively.
Fences constitute a significant impact on sage grouse survival. Fences are utilized as lookout posts by avian predator. There is some evidence that nesting sage grouse avoid fence lines, effectively removing significant amounts of prime habitat. Fences are also well known as a mortality source for sage grouse which frequently collide with them.
Riparian areas and wetlands are a critical brood-rearing habitat for sage grouse chicks. Indeed, one of the major causes of sage grouse decline is the documented loss of functioning riparian areas as a result of livestock utilization. Fencing riparian areas and spring areas may preclude livestock damage but could also prevent their use by sage grouse. Again, since avian predators use fences as lookout posts, and sage grouse tend to avoid fence lines, utilizing fences to protect water sources could permanently remove this habitat from sage grouse as well.
In response to these impacts and clear violations of BLM’s responsibility to manage these lands for the benefit of the public, not private ranch interests, Western Watersheds Project and Wilderness Watch have filed an appeal of the 2018 grazing decision and are asking for a stay of the proposed range developments, though supporting a proposed 40% reduction in grazing numbers.
These groups argue that the Environmental Assessment, Finding of No Significant Impact and Final Decisions violated the National Environmental Policy Act (NEPA) because BLM refused to take a comprehensive look at the direct, indirect and cumulative impacts of its grazing decisions on the habitat and populations of greater sage-grouse. BLM also violated NEPA because it failed to adequately consider the effective impacts of more range developments to the Wilderness characteristics of the Little Jacks Creek Wilderness.
For instance, there are narrowly defined instances that permit motorized use by ranchers in wilderness (an exception that is inconsistent with the Wilderness Act’s central tenets) where there is no other “practical” alternative. But the BLM provides no analysis of what options (like horses) were considered and rejected.
One of the big failures of the BLM is its rudimentary review of “cumulative impacts.” The BLM is required to address the effect of any previous decisions on new decisions. The BLM analysis did not consider that since 2015 the Bruneau and Owyhee Field offices have issued 170 livestock grazing permits, including 128 of them without any environmental review at all.
It would be one thing if such a bias toward maintaining damaging livestock on our public lands—and proposing significant developments at public expense to “mitigate” impacts from private livestock were unique to the Idaho BLM. Sadly, the situation on the Owyhee District of the BLM is typical of the agency’s response to on-going and clear evidence that livestock damages our public property across the West.
The single best way to restore these public lands is to remove livestock. The Federal government is under no obligation to subsidize private interests by permitting the degradation of public resources. Indeed, the laws governing the management of public lands only authorize uses like livestock production if they do not damage public values. In the case of the Battle Creek, East Castle Creek, and Owens Allotments Grazing Permit Renewal, that standard is being violated.