Opinion by Dick Loper

Grazing Community Must Weigh In On Lander BLM Draft Plan
By Dick Loper, Rangeland Consultant, Wyoming State Grazing Board  

 Last September the Lander BLM issued its draft Resource Management Plan and Environmental Impact Statement (RMP/EIS) for public comment, and the office must receive comments on this three-volume, 1,700-page draft Land Use Plan and EIS on or before Jan. 20.
    The draft RMP/EIS contains an alternative preferred by the BLM and three additional alternatives for consideration. Each alternative contains proposals for the management of all of the multiple uses present on BLM-administered lands in the Lander Field Office. After considering the public comments, the BLM can pick and choose from any of the alternatives to develop the Final RMP and Record of Decision (ROD), and at that time will issue a Final RMP and ROD, which will contain the management actions to be applied to BLM lands for the next 15 or more years.
    We encourage everyone in the livestock, banking, government and business communities who will be affected by these RMP decisions to obtain a copy of this document and provide substantive comments to the BLM by the deadline. The Wyoming State Grazing Board (WSGB) was established in 1979 by the Wyoming Legislature to provide technical assistance to Wyoming ranchers who hold Section 3 grazing permits, and we are currently assisting ranchers who requested help in developing their comments on this draft RMP/EIS.
    The WSGB does not want to convey that the entire contents of this draft, with respect to livestock grazing, are problematic, but our review of those narratives that apply to livestock grazing has identified a number of serious concerns.
Reduction in AUMs
    Of major concern is the proposed reduction of over 25 percent of the livestock AUMs now available to present or future permittees for the life of the plan.
    The document appears to convey that this level of reduction will be justified as the primary management action required to correct the current influence from livestock grazing and related activities on their interpretation of what is, or is not, healthy rangelands. The WSGB is in agreement with the vast majority of the range science community, in that BLM grazing regulations that convey what constitutes “healthy” or “unhealthy” rangelands are not consistent with the state-of-the-art science on this subject. We will provide a comment to this draft RMP that, should the BLM determine that livestock grazing is a contributor to rangelands that are “unhealthy,” in their opinion, the BLM should, in consultation with the permittee, the local county commission, and the state of Wyoming, seriously consider the use of all of the management tools available and not focus on reductions in AUMs as the panacea solution.
Unfounded Statements
    The draft also contains language that we feel is most inappropriate for inclusion in this document. The draft conveys that a justification for the proposal to reduce AUMs by 25 percent over the life of this plan is an opinion that the livestock industry is an aging industry, and hints that this fact will reduce the demand from local ranchers for BLM AUMs. We are at a loss to understand the logic behind these types of statements, and we will comment that the average age of the ranching community in the Lander area has absolutely nothing to do with the future demand for livestock AUMs from BLM lands in this area.
    The draft also conveys that perhaps another justification for the proposal for reductions is that some local ranches are being sold to out-of-state buyers who might not have as much interest in grazing livestock on BLM lands as the current owner.
    It will be our comment to the Lander BLM that neither of these “justifications” should be the basis for a proposed significant reduction in the ability of Lander-area ranches to purchase federal AUMs to support their families and continue to contribute to our local customs, culture and economy.
Comprehensive Grazing Plans
    This draft RMP also introduces the livestock community to the concept that any and all proposals from permittees to develop range improvements, such as water developments, fences, etc., must be part of a “Comprehensive Grazing Management Strategy” (CGMS).
    Yes, the glossary in Volume Three does contain a definition of that term, but many of us are of the opinion that the current definition does not adequately convey what subjects would be included in a CGMS, or whose responsibility is it to develop a CGMS. It is logical to assume that an Allotment Management Plan, or AMP, would be the quintessential CGMS procedure, but the WSGB cannot find any reference to the AMP process in the draft.
    The WSGB will provide a comment that the concept of a CGMS could be a very good idea, but it must be further defined and developed under a process of meaningful consultations with local permittees, the Fremont County Commission and the Department of State Lands for Wyoming.
Draft lacks record of AUMs
    This draft RMP also fails to include a table that states the preference level of federal AUMs that were adjudicated to the private lands that serve as base property for these grazing permits, and it does not document the amount of “suspended” AUMs that might someday become available for active use by these permittees.
    This omission is important because the BLM’s grazing regulations clearly convey that the BLM is only required to recognize and authorize the type and number of federal AUMs that are documented in the Land Use Plan. To protect the AUMs in each classification category, (Preference level, suspended use, if any, and the active use level), each category of AUMs for each grazing permit in this BLM Field Office area must be in the Land Use Plan.
    There are a number of other issues in this draft that deserve comment from our industry and elected government and business communities. The WSGB encourages everyone to provide high-quality comments on the subjects of importance to you, and we request your vigilance on issues of importance to our industry when your local area undergoes an RMP/EIS process.
    Those who “show up” really run the world, and commenting on a draft RMP is considered “showing up.”
    For more information about commenting on RMPs, contact Dick Loper at 307-332-2601 or wsgb@wyoming.com.