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United States Department of the Interior 
Montana State Office
5001 Southgate Drive
Billings, Montana 59101-4669
February 14, 2012
4130 (MT923) P 
Instruction Memorandum No. MT-2012-042
Expires: 9/30/2013
To:             Montana Dakotas Leadership
From:         State Director
Subject:     Guidance to Address Alternative Development in Livestock Grazing Permit Renewals
Program Area: Rangeland Management
Purpose:  The purpose of this Instruction Memorandum (IM) is to ensure that Montana/Dakotas Bureau of Land Management’s (BLM) proposed grazing regulations are fully supported through adequate NEPA analyses.
Policy/Action: Follow the guidance in the grazing regulations (43 CFR 4100) and the BLM NEPA Handbook (H-1790-1) as clarified in this memorandum.
The “purpose and need” should be clearly articulated when preparing an environmental assessment for issuing/renewing a livestock grazing permit or lease. The purpose and need statement indicates the range of alternatives because, action alternatives are not “reasonable” if they do not respond to the purpose and need for the action. See the H-1790-1 handbook for an example of the purpose and need statement. The proposed action and any reasonable alternatives should address the purpose and need of issuing new livestock grazing permit.
When preparing an environmental assessment for issuing /renewing a livestock grazing permit or lease, you must consider a range of reasonable alternatives. Each environmental assessment must describe and analyze alternatives that address the resource concerns identified through rangeland health or watershed assessments, monitoring, Endangered Species Act consultation, public scoping, etc. The alternatives considered in the environmental assessment should be based on specific conditions, resources of concern and results of current livestock grazing activities. A range of reasonable alternatives may therefore include increased, reduced or static grazing, no grazing, or modification of grazing via use levels, season of use, timing and/or range improvements
At a minimum, an environmental assessment must address the following alternatives: (1) issuing a new permit with the same terms and conditions as the expiring permit (no action alternative); (2) issuing a new permit based on the application (proposed action); (3) any reasonable alternative the field office may develop that differs from the applicant’s proposal or the no action alternative; and (4) a “no grazing alternative.” If the application for permit is the same as the expiring permit (no changes to the terms and conditions), then the proposed action and the no action alternative are the same. In this case, document that they are the same and analyze them as a proposed action.
When site-specific circumstances indicate no grazing or reduced grazing alternatives are not appropriate (e.g., limited Federal land ownership, isolated parcels, etc.), then document this in the environmental assessment as an alternative(s) considered but eliminated from detailed analysis. For any alternative considered but not analyzed in detail, a clear, concise justification is needed to demonstrate consideration of a range of reasonable alternatives.
In addition to the alternatives identified above, alternatives that address unresolved conflicts for the specific permit(s) should be considered. An altered grazing strategy (i.e., changed stocking levels, length of season, location/configuration of range improvements including pasture boundaries, and/or season of use) must be considered in detail when unresolved conflicts include not meeting land health standards, and current livestock grazing may be determined to be a significant factor, or when not meeting resource management plan - or activity – level objectives and a grazing alternative can facilitate movement towards meeting those objectives.
Timeframe: This IM is effective upon receipt.
Budget Impact: None.
Background: Some field offices’ productivity in achieving other workload targets may decline due to more rigorous NEPA analysis on some permit renewals
Manual/Handbook Sections Affected: None.
Coordination: Statewide coordination to develop this guidance occurred through the Deputy State Director and Montana/Dakotas District and Field Managers. Comment regarding the draft were incorporated into the final release.
Contact: If there are any questions regarding this IM, please contact Floyd Thompson, State Range Program lead, at 406-896-5025.
Signed by:                                                                   Authenticated by:
Jamie E. Connell                                                          Janie Fox
State Director                                                              Staff Assistant (MT923)

Last updated: 06-28-2012