It’s said that nothing dies harder than a bad idea, and that seems to be increasingly true when it comes to public lands livestock grazing. From gutting mandatory provisions to protect sage-grouse to clearcutting native trees for the sake of livestock forage, the Trump Administration seems to be rolling out bad ideas as fast as it can write them down.

The latest bad idea to rear its ugly head again is a revision of the Bureau of Land Management’s grazing regulations. Our members and supporters will remember that Western Watersheds Project, allies, and our attorneys at Advocates for the West overturned the 2006 BLM attempt to do a similar thing. We don’t yet have much information about what they plan to do this time around, but it doesn’t sound good:

1. Unauthorized grazing – the notice suggests that the BLM should adopt new regulations for informally addressing unauthorized grazing, meaning that instead of complying with existing regulations to document violations and assess penalties, the agency will likely come up with a way of hiding what it knows about grazing trespass or overuse.
2. Expediting grazing authorizations as “a tool to reduce wildfire” or to “improve rangeland conditions.” There is no positive correlation in the scientific literature that suggests grazing can achieve either outcome and a large body of evidence to the contrary, but it’s clear that BLM seeks to expedite these types of permits under the guise that it will benefit public lands. In fact, grazing leads to the increase of invasive annual grasses and larger, more frequent wildfires.
3. Streamlining protests and appeals – This is likely a reference to a desire by the agencies to reduce timelines for public involvement, increase or codify exhaustion requirements, and to further limit opportunities for the public to be informed about and participate in .
4. Removing the requirement to assess Land Health Standards on every allotment – The regulations say that the new regs will consider “where and how the BLM will evaluate the Land Health Fundamentals and Standards.” The agency is currently required to complete these as part of the permit renewal process. The agency has also been failing to meet Land Health Standards on many, many public lands allotments throughout the west. Instead of meeting the standards, it appears BLM plans to lower the bar of having to meet them.
5. Expanding the use of categorical exclusions – i.e. completing fewer full and fair environmental analyses – and undermining public participation opportunities in the process.

Taken together, just these few items in the scoping notice are raising our concerns that we’re going to have to fight to keep grazing permits on public lands in the public sphere of the National Environmental Policy Act. More information about the proposal (as described by BLM) can be found at this website: https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=200000312

The BLM is taking comments on its proposal to change the grazing regulations now through March 6, 2020. 

You can provide your comment online here, or by mail to: 

Bureau of Land Management
ATTN: Seth Flanigan
3948 S Development Ave.
Boise, ID 83705

You can also attend a public open house* and fill out a comment card. The scheduled open houses are:

• Miles City, Montana: February 6, at the Sleep Inn and Suites, 1006 S. Haynes Ave., from 4:30-7:30 p.m.;
• Las Cruces, New Mexico: February 11 at the Las Palmas Grill, 201 East University Ave., from 4:30-7:30 p.m.;
• Elko, Nevada: February 18 at the Elko Convention Center, 700 Moren Way, from 4:30-7:30 p.m.; and
• Casper, Wyoming: February 20, at the Casper Events Center, 1 Events Dr., from 4:30-7:30 p.m.

**Let wwp@westernwatersheds.org know if you plan to attend and we’ll be sure to link you up to staff at the events!

We support BLM correcting its published regulations to conform with our 2006 court win, but we don’t support any additional tweaking.

If BLM is going to change the grazing regulations, we suggest they improve them for the benefit of the myriad plants and animals that depend on these public lands and for non-extractive users. Any new regulations should:

• Allow for grazing permit retirement and long-term non-use for conservation purposes.
• Create no new categorical exclusions and expand use of EAs and EISs.
• Facilitate greater levels of public engagement, including through posting monitoring reports online for public review, inviting the interested public to attend field visits, and notifying the public of all grazing permit decisions.
• Require grazing management to improve carbon sequestration in soils and analyze grazing in context of the climate crisis.
• Ensure grazing management preserves the habitat value of grazed lands for native plant and wildlife species.
• Ensure grazing management does not impede grazed lands from serving as habitat for native predators.
• Ensure NEPA analyses appropriately considers the habitat of species in crisis and the broader extinction crisis underway.
• Honestly evaluate the contribution of livestock grazing to cheatgrass and accelerated fire cycles and provide more opportunity for the public to evaluate site-specific proposals for fire-related livestock actions.
• Forbid destruction of native vegetation to increase forage for livestock.
• Ensure that the Land Health Standards are evaluated at least once a decade using peer-review scientific and quantifiable methods.
• Include water quality monitoring as part of the land health evaluations.
• Include an accurate and site specific economic analysis of grazing with every permit renewal, revealing the money obtained from grazing fees against the cost of administering the permit.
• Disclose underlying Indigenous land claims and address environmental justice issues.
• Require grazing management to maintain and improve wilderness characteristics and other special values of grazed lands.
• Require use of the best available science in livestock grazing decisions.
• Set a fair and equitable grazing fee based on comparable private land prices.

Feel free to let BLM know all of your best ideas for how they could improve grazing permit administration, all the reasons public lands livestock grazing affects you, and all the ways you want to feel more engaged in their processes.

Please do weigh in!  The future of 155 million acres of public lands is at stake! 

Contact wwp@westernwatersheds.org with any questions.