What grazing activity is authorized in the proposed decisions?
:: Proposed decisions to renew grazing permits for the Garat, Castlehead-Lambert, Swisher Springs, and Swisher Fenced Federal Range (FFR) allotments offer permits for an up-to 10-year term, under additional terms and conditions that relate to ensuring rangeland health objectives on each allotment. These decisions support rangeland resource objectives established in the 1999 Owyhee Resource Management Plan (RMP) and the Idaho Standards for Rangeland Health, finalized in 1997.
Why did the BLM complete an environmental assessment (EA) as part of the permit renewal?
:: Environmental analysis under the National Environmental Policy Act (NEPA) of applications to renew grazing permits for these allotments assists the Owyhee Field Manager in making informed decisions about renewing these permits, by enhancing understanding of the environmental consequences of authorizing various levels of grazing.
Why were the Group 1 permit renewals analyzed in an EA and not an EIS (environmental impact statement)?
:: The BLM believes that an EA was the most efficient and effective way of analyzing these four permit renewals while meeting its legal and regulatory obligations as steward of the public lands in these allotments. On a practical level, these permit renewals are among a group of 75 for which to BLM must complete NEPA analysis and issue decisions by December 2013. On a management level, the BLM was able to develop proposed decisions that it believes will meet resource objectives without causing significant impacts, which would require completion of an EIS.
Why are these four permit renewals analyzed in a single EA?
:: These four allotments are similar geographically and ecologically, which makes it sensible administratively and scientifically to consider them in one NEPA document.
What does the EA analyze?
:: As required by NEPA, the EA ‘takes a hard look at’ the relationship among authorized livestock grazing, rangeland health, other uses of lands in the allotments, natural events like wildland fires, and other factors identified during scoping.
What issues does the analysis address?
:: The EA examines the condition of riparian vegetation in each of the four allotments, conditions in upland areas and in the broader watershed; the condition of sage-grouse habitat found in and near the allotments; the presence of invasive species, juniper encroachment, potential impacts of trailing, and various dimensions of grazing management. These factors are considered in the framework of the Idaho Standards for Rangeland Health – whether these Standards are being met or there is evidence that significant progress toward meeting them is being made.
In what ways has the public been involved in the decisions on these permit renewals?
:: The BLM highly values and relies on public input and involvement when developing information for any resource management decision. Anyone with an interest was invited to submit comments during scoping for the EA (Jan. 31-Feb. 29, 2012). All comments on the EA were similarly encouraged and welcome.
What various alternatives were analyzed?
:: There are five alternatives, ranging from No Action (Alt. 1) to No Grazing (Alt. 5). Alternative 1 provides a baseline along which to compare environmental effects of the other alternatives and so represents continuation of actions that have led to current conditions. Alternative 5 is one of the reasonable alternatives the BLM is required to analyze for meeting the purpose and need for authorizing grazing. Alternative 2 is the applicants’ proposed action: renewing the permits at the stocking levels applicants have proposed.
Alternative 3 is called the Performance-Based Alternative. It incorporates monitoring and adaptive management that have proven to be successful on other allotments in the Owyhee Field Office, along with terms and conditions that would allow for improving sage-grouse habitat in addition to meeting rangeland health standards. Alternative 4, the Season-Based Alternative, would limit livestock grazing during important periods in the sage-grouse life-cycle.
How does the EA incorporate current BLM policy for analyzing impacts to sage-grouse?
:: The EA incorporates available site information collected using the Sage-grouse Habitat Assessment Framework in evaluations of current resource conditions. The alternatives incorporate grazing management practices designed to keep adequate residual plant cover and understory diversity, and changes in season-of-use in meadows, mesic habitats and riparian pastures to conserve forbs, and in pastures that contain priority habitat during spring nesting periods.
Which alternatives underlie the proposed decisions?
:: Alternative 4 has been selected for the proposed decisions associated with the Castlehead-Lambert, Swisher Springs, and Swisher FFR allotments. The new terms offered in the proposed decision associated with the Garat allotment are based on a combination of certain terms and conditions found in Alternative 3 for managing riparian areas and Alternative 4.
How were the AUM and cattle numbers in Alternative 4 derived?
:: Under ideal conditions and maximizing livestock use of forage, approximately 4.9 acres would be required to support one AUM in a normal year in these allotments. At this time, ideal conditions are not present, and management objectives set for these lands in the Owyhee RMP limit livestock use of forage to 50%. A stocking rate of 10 acres per AUM was identified as being most appropriate for these allotments to achieve desired conditions with the seasonal limitations included for sage-grouse conservation purposes.
It seems that implementing Alternative 5 (No grazing) might be the quickest or surest way to meet your resource objectives. Why was it not selected?
:: Selecting Alternative 5 would have resulted in the greatest socio-economic impacts, while not yielding proportionately better results in terms of rangeland health. Our analysis showed that conditions on the allotments could meet resource objectives or make significant – that is, measurable and observable – progress toward meeting them without removing all livestock.
AUMs would be reduced on three of the four allotments. By how much?
:: On the Castlehead-Lambert allotment, AUMs in active use would be reduced 35% (3,244 AUMs to 2,101 AUMs), which equates to a 25% reduction compared to average actual use over the last 10 years (2,817 AUMs).
On the Garat allotment, the proposed decision reduces AUMs by 47% compared to active use (19,500 AUMs to 10,343 AUMs). That’s a 30% reduction compared to average actual use (14,802 AUMs).
For the Swisher Springs allotment, AUMs would be reduced 39% from currently authorized levels (345 AUMs to 210 AUMs), which would be a 26% reduction compared to average actual use from 2002 through 2011 (285 AUMs).
Conditions on the Swisher Springs FFR allotment are meeting all applicable Standards, so no adjustments to grazing management – including AUM authorizations – are necessary.
What would it take for those AUMs to be allowed to go back up on the allotments where reductions are proposed?
:: Once the decision to reduce AUMs on an allotment is final, AUMs could be increased only after the BLM had reviewed resource conditions on the allotment and determined that additional forage was available and that increasing active AUMs would not run counter to the goal of meeting or making measurable and observable progress toward meeting Rangeland Health Standards and resource objectives in the Owyhee RMP. Modifying the permit terms and conditions this way would require an additional round of NEPA analysis and decision.
Did the BLM consider the socio-economic effects of these AUM reductions?
:: The BLM recognizes that reducing AUMs has immediate socio-economic impacts for permittees and local communities. We did not begin by assuming that we would have to reduce AUMs. Rather, we set out to ensure that our management decisions allow us to meet rangeland health objectives. Those objectives were developed with the specific intent of allowing continued multiple use of the lands in these allotments. The only way we can see to meet those objectives is to issue permits for use that’s sustainable. The socio-economic impacts of unsustainable use would be far greater.
Beyond acknowledging that the proposed management actions will have socio-economic impacts, how did you address these effects?
:: The BLM’s primary obligation is ensuring that new grazing permits protect resources in a manner consistent with Idaho Rangeland Health Standards and the Owyhee RMP. The EA discloses the predicted economic and social effects of the actions selected for each permit, and the respective proposed decisions provide the associated rationale. We attempted to develop a way of implementing Alternative 4 that would have ameliorated the initial impact, but regulations require that following a determination that an allotment is not meeting Standards due to current livestock use, the next new permit must lead to significant progress.
Was any thought given to phasing in the AUM reductions, as a way of mitigating the socio-economic impact?
:: Phasing-in AUM reductions at a rate that would have meaningfully lessened socio-economic impact would have meant authorizing AUMs for initial years at approximately the levels of Average Actual Use over the last 10 years – leaving no reasonable expectation that rangeland health conditions would improve measurably and observably, as required to meet resource objectives and regulatory requirements. Phased implementation would also have increased uncertainty for the permittee.
Your regulations only require you to adjust grazing when conditions aren't meeting Standards or making significant progress. How do you determine when grazing activity is a significant factor in sub-Standard conditions and therefore must be adjusted?
:: Each rangeland health standard includes indicators that the BLM examines when assessing land health on an allotment. Grazing management guidelines that accompany the Standards help determine whether a Standard is not being met or not making significant progress because of grazing activity, along with data on actual use of the allotment.
Why are changes in grazing activity proposed for pastures not meeting Standards but where grazing is not a significant factor?
:: In instances like this, adjustments to grazing activity are proposed to meet enhanced resource objectives in the Owyhee RMP.
Did the BLM consider authorizing increased grazing levels on these allotments?
:: The EA analyzed proposed increases in active AUMs on the Castlehead-Lambert and Garat allotments as Alternative 2. The proposed decisions do not authorize AUM increases because those levels of grazing activity would not meet resource objectives.
Why don't any of the proposed decisions authorize grazing as a tool for reducing wildland fire fuel loads on these allotments?
:: Considering and authorizing targeted grazing cannot be done within the scope of permit renewal. Fuels management projects – whether or not they would use grazing – must comply with NEPA and other laws and regulations in ways other than those that apply to livestock grazing authorizations. Objectives for fuels projects have to be clearly defined and based on sound fire science; the permit renewal process is not the place to evaluate these aspects of fuels projects that would use grazing as a tool.
Why don't any of the proposed decisions authorize range improvements?
:: From the outset, we have said that proposals for new range developments would not be accepted. On an immediate practical level, there simply is not enough time to complete proper on-the-ground surveys, consultation and coordination, layout and design, etc., to support NEPA analysis of new developments before the December 31, 2013, deadline in the court-approved settlement agreement for processing the permits these four are among (see Qu. 3 above). More broadly, since Rangeland Health Standards were finalized in 1997, additional range developments implemented with the purpose of helping meet those Standards have met with little success. Finally, in the current budget climate, there is no way of guaranteeing that new range developments authorized today could be constructed during the life of a renewed permit.
How will the BLM ensure that these are more than just "paper" cuts in grazing?
:: The Owyhee Field Office will monitor resource conditions and supervise livestock use on the allotments as needed to ensure that permit terms and conditions are leading to the management goals stated in the decisions.
What happens next?
:: Proposed decisions will be mailed to respective applicants by certified mail. Applicants, Tribes, the State, local governments, and other of-record interested members of the public have 15 days after delivery to appeal a proposed decision to the BLM authorized officer, in this instance, the Owyhee Field Manager. Absent timely protest, proposed decisions become final without further notice. When a timely protest is received, it is considered when preparing a final decision. Anyone may appeal a Final Decision for 30 days after it is issued with the Office of Hearings and Appeals (OHA) and request a stay. Final decisions cannot be implemented until an OHA judge rules on the stay. Once final decisions are issued, the BLM will have met the terms of a court-approved settlement for these four allotments (see Qu. 3 above).
Is sage-grouse habitat the only wildlife resource considered in the EA?
:: No. The analysis for the Garat allotment looks at potential impacts to Davis peppergrass in playa areas. More generally, improvements in sagebrush habitats that immediately address sage-grouse concerns will also benefit other species known to inhabit these allotments: pygmy rabbits, elk, mule deer, pronghorn, kit fox, Piute ground squirrel, Wyoming ground squirrel, coyote, dark kangaroo mouse, and others.
Why don't you just wait until regional sage-grouse planning is complete to address those habitat issues for these allotments?
:: Under the terms of the 2008 settlement agreement, the BLM must finish processing these permit renewal applications by December 2013 – a year before the sage-grouse plan amendments are scheduled to be completed. By adhering closely to the interim policy for sage-grouse management when preparing these EAs, the BLM expects not to have to re-visit decisions on these permits after regional sage-grouse planning is done. The goal is to provide permittees and other interested parties with clarity and predictability regarding activities and expectations for the lands in these allotments.