Print Page
August 14, 2012
In Reply Refer To:   
1610/4100 (210/220) P
Instruction Memorandum No. 2012-169
Expires:  09/30/2013

To:                   All Field Office Officials

From:               Assistant Director, Renewable Resources and Planning

Subject:           Resource Management Plan Alternative Development for Livestock Grazing

Program Areas:  Land Use Planning, Livestock Grazing

Purpose:  This Instruction Memorandum (IM) communicates policy guidance regarding resource management plan/environmental impact statement (RMP/EIS) alternative development for livestock grazing.

Policy/Action:  Alternative development is one of the critical steps in the land use planning process, and the range of alternatives forms the “heart of the environmental impact statement”   40 C.F.R. § 1502.14. This IM focuses specifically on the RMP/EIS (i.e. revisions and amendments) alternatives development for livestock grazing and provides the Bureau of Land Management (BLM) with guidance to meet the requirement of the National Environmental Policy Act (NEPA) to analyze the environmental impact of alternative proposals to government action and to “[r]igorously explore and objectively evaluate all reasonable alternatives.” 40 C.F.R. § 1502.14; see also 43 C.F.R. § 1610.4-6.
The range of alternatives sharply defines the issues and provides a clear basis for choice among options by the decision-maker. The required land use plan decisions for the livestock grazing program are (1) identification of lands as available or not available for grazing; and (2) identification of the amount of forage available for livestock on an area-wide basis (see Land Use Planning Handbook (H-1601-1), Appendix C, II.B.). Each livestock grazing alternative for a land use plan should address unresolved conflicts concerning various uses of available resources. The BLM will develop a range of alternatives for an RMP/EIS by varying which lands in the planning area are available for grazing, by varying the amount of forage available for livestock grazing, or both. The RMP/EIS alternatives also may vary according to the season of use, kind of livestock, terms and conditions, and levels of range improvement development. 

What constitutes a reasonable range of alternatives depends on the specific facts of each RMP/EIS. In nearly all cases, however, the range of alternatives for an RMP/EIS will include one or more alternatives with a meaningful reduction in either lands available for grazing, forage amounts, or both.  An increased grazing alternative also may be appropriate (where increased grazing would meet the goals and objectives of the RMP, such as to reducing fuels for wildfires or designating areas as available for livestock grazing that were previously unavailable), and a "no-grazing" alternative should be considered in detail where it is appropriate, and may be beneficial to show trade-offs between resource uses.

There are a variety of factors to consider in developing the range of alternatives for livestock grazing. Field offices must consider actual or potential resource conflicts and competing or alternate uses of available resources. Specific issues to consider during alternative development will vary depending on the planning area, scoping comments, analysis of the management situation, current resource conditions, desired future conditions and existing resource competition and/or conflict. The following non-exhaustive list describes examples of areas where the BLM could consider reducing, increasing or eliminating livestock grazing within its range of alternatives for detailed analysis in an EIS for an RMP.
  • Rangeland Management Program Adjustments:
o   Areas not meeting or not making significant progress towards achievement of rangeland health standards (particularly in areas where current livestock grazing is identified as a significant contributing factor);
o   Areas identified for restoration;
o   Areas identifying where livestock grazing would be used as a vegetation management tool to meet resource objectives (i.e. wildlife habitat or fire management objectives);
o   Areas establishing Reserve Common Allotments;[1] or
o   Areas where forage and grazing preference would not be reallocated upon receipt of a voluntary grazing relinquishment [2].
  • Potential Conflicts with Forage or Habitat Needs for Other Species: 
o   Reduced forage availability based on a vegetation inventory;
o   Areas identified as preliminary priority sage-grouse habitat;
o   Areas with habitat for threatened, endangered or sensitive species (where livestock grazing is listed as one of the threats to the species);
o   Areas of crucial winter or summer habitat range for wildlife species with forage needs that are similar to livestock; or
o   Areas designated as Wild Horse and Burro Herd Management Areas.
  • Potential Conflicts with Management of Specific Areas:
o   Units of the National Landscape Conservation System (based on the objects or values for which the area was designated);
o   Areas of Critical Environmental Concern (based on the relevant and important criteria for the area); or
o   Areas close or adjacent to the urban interface or residential development.
  • Potential Conflicts with Other Resources or Uses:
o   Areas with isolated tracts or “checkerboard” lands that make grazing difficult;
o   Areas with traditional cultural properties or other cultural resources (where livestock grazing is listed as a site impact);
o   Areas where conflicts with recreational uses could occur or areas with developed recreation facilities;
o   Lands identified as available for disposal;
o   Areas with valid existing rights, mining operations, or other land uses that make grazing difficult; or
o   Areas identified for future energy development, such as solar energy zones.

If a reduced grazing alternative decreases animal unit months (AUMs) for areas or allotments to resolve conflicts with other uses or resource issues, the AUMs identified in the RMP must be fewer than the average actual use for those areas or allotments. Otherwise, the reduced grazing alternative would not provide a meaningful difference from the no-action alternative for analysis.

In certain cases, a no-grazing alternative may not be necessary or appropriate for an RMP. When this is the case, BLM field offices should document the reasons that a no-grazing alternative was considered but eliminated from detailed analysis.  An alternative may be eliminated from detailed analysis for a number of reasons, e.g., if it does not respond to the purpose and need for the action, is technically or economically infeasible or is substantially similar to an alternative analyzed in detail (see NEPA Handbook, H-1790-1, Section 6.6.3). For example, if the no-grazing alternative would make an entire planning area unavailable to livestock grazing, but the purpose and need of the RMP/EIS does not concern livestock grazing or livestock grazing-related issues in the planning area, then analysis of the no-grazing alternative is unnecessary as part of the alternatives development for the RMP. This may be the case when the RMP/EIS concerns a planning area (for example in Alaska) where livestock grazing does not occur, the RMP/EIS is focused on oil and gas leasing, or BLM is undertaking an amendment to an RMP that does not concern livestock grazing. In addition, if the RMP/EIS considers and includes reduced grazing levels as part of its alternatives analysis, then analysis of the no-grazing alternative would likely be unnecessary to fulfill the BLM’s NEPA obligation for development of a reasonable range of alternatives. 

Although the BLM has discretion through its grazing regulations to adjust stocking levels, seasons of use, and grazing management activities during the permit renewal process, this is not a basis for declining to consider a reduced grazing or a no grazing alternative. The purpose of planning is to take a broad-scale look at the planning area and make large-scale allocation decisions; adjusting grazing levels on a permit-by-permit basis generally cannot substitute for this level of analysis.  In addition, while it can be useful to explain in an RMP/EIS that under the Federal Land Policy and Management Act (FLPMA) the BLM manages the public lands for multiple use and that FLPMA identifies livestock grazing as one of the principal, major uses of public lands, FLPMA’s multiple-use mandate does not, in itself, provide a basis for not analyzing a reduced grazing or no grazing alternative. Although multiple use does not require that all lands be managed for livestock grazing, it also does not mean that analyzing a no grazing alternative in an RMP/EIS is automatically unreasonable. This is because NEPA’s focus is informed decision making. Analyzing an alternative that provides a contrast to other action alternatives (such as no-grazing or a reduced grazing) can sharpen the focus on impacts from grazing as well as provide insight into what is not causing impacts to resources.
Considering a no-grazing alternative as part of the alternatives analysis under NEPA—or explaining why analysis of the no-grazing alternative would be unnecessary—is beneficial to the BLM’s RMP development process. Documenting this information creates a stronger record of the interdisciplinary team’s process of developing the alternatives and tailoring the scope of the analysis to the identified issues. Additionally, the BLM has the discretion to analyze in detail an alternative that might otherwise be eliminated if such analysis would help inform the decision.   Analysis of a no-grazing alternative could be useful, for example, to help identify potential conditions in the absence of livestock grazing and provide a baseline of conditions for comparison with other alternatives.  

The range of alternatives analyzed in detail in an RMP/EIS has implications for the NEPA analysis of subsequent livestock grazing permit renewals. For example, if the RMP/EIS did not analyze making a particular area unavailable for livestock grazing, it becomes more critical at the permit renewal stage to analyze a no-grazing alternative. Conversely, if the RMP/EIS analyzed making that area unavailable to livestock grazing, the subsequent NEPA analysis could tier to the analysis of the RMP/EIS. 

Timeframe:  This guidance is effective immediately. 

Budget Impact:  None.

Background:  The range of alternatives helps the BLM and its stakeholders understand the differing management scenarios and the various ways of addressing identified planning issues. Reviews of recent RMP/EISs have demonstrated that there is a need for additional guidance for the range of alternatives for livestock grazing, particularly with regard to consideration of reduced and no-grazing alternatives.

Manual/Handbook Sections Affected:  This guidance supplements existing guidance found in the BLM’s Land Use Planning Handbook, H-1610-1, and NEPA Handbook, H-1790-1.

Coordination:  This IM was developed by the Division of Decision Support Planning and NEPA (WO-210); the Division of Forest, Rangeland, Riparian, and Plant Conservation (WO-220); and the Office of the Solicitor.

Contact:  If there are any questions concerning this IM, please contact Sam Gaugush, Planning and Environmental Analyst, 202-912-7217, Kimberly Hackett, Rangeland Management Specialist, 202-912-7216, or Andrew Tkach, Planning and Environmental Analyst,
Signed by:                                                                   Authenticated by:
Edwin L. Roberson                                                      Robert M. Williams
Assistant Director                                                       Division of IRM Governance,WO-560
Renewable Resources and Planning

[1] A “Reserve Common Allotment” (RCA) is a BLM-administered grazing unit (allotment or pasture) used by permittees/lessees participating in land restoration or recovery efforts. Areas that have been closed to grazing are not considered RCAs. The purpose of RCAs is to facilitate rangeland restoration, recovery and/or management objectivesover broad areas in the general vicinity of the allotment.
[2] A grazing “relinquishment” is the voluntary and permanent surrender by an existing permittee or lessee, (with concurrence of any base property lienholder(s)), of a grazing permit or lease along with their preference (i.e. the permittee’s priority position against others to receive the permit or lease). Relinquishment is not a decision to close areas to livestock grazing and does not require the consent or approval by the BLM.

Last updated: 08-16-2012