The BLM is at it again. As many readers know, the Draft Resource Management Plan Amendment (RMPA) to create a framework to attempt to conserve the greater sage grouse (GRSG) and its habitat of which the BLM manages about half (121 million acres) has been circulating for comment since March of this year. Many resource users and groups representing those users have sent comments to the BLM. Groups such as the Nevada Mining Association, the Nevada Cattlemen’s Association and the Public Lands Council have submitted comments.
The document covers hundreds of pages and has six alternatives and dozens of tables, citations, and appendixes. The RMPA is dense and full of enough scientific and bureaucratic jargon to drive a regular citizen to alternative methods of creating more familiar realities. Moreover, this publication and certainly this column is not big enough to comment on the whole document, but I would like to discuss a few of the areas it addresses and add my two cents. I would encourage a read for anyone who has a permit to use resources in GRSG or who is a visitor to public lands where sage grouse habitat is located to at least glance at the RMPA to familiar themselves with the breadth and scope of federal government regulation. It is simply breath taking. [eplanning.blm.gov/eplanning-ui/project/2016719/510]
From the Executive Summary we get this statement of purpose and need: “….Given continuing losses of habitat across all landownerships, and resulting population declines, the BLM’s purpose and need is to consider amending RMPs to update a sub-set of the GRSG goals, objectives, allocations, and management actions to ensure management on BLM-administered lands respond to changing land uses, improve efficiency and effectiveness of range wide GRSG conservation goals. The BLM is focusing [among other things] on the following range wide management actions:
• Mitigation for impacts to GRSG habitats
• Livestock grazing
• Minimizing threats from predation
• Areas of Critical Environmental Concern
The document acknowledges some management concerns are more effectively addressed at the local level. It is my hope the BLM will encourage local input from users who are on the resource every day and can be effective partners if asked by the agency to be included in the management planning and implementation process. As many readers will agree, it is generally accepted now that properly managed grazing can be beneficial to the range in many ways. Grazing enhances growth of forage and helps root systems to store carbon in the soil. The systematic grazing of fine fuel loads helps to protect landscapes from rapid and over hot wildfire progression. Grazing irrigated private land pastures next to public land and private sage grouse steppe produces insect levels that enable a sage grouse hatch to have a thriving start to life in an otherwise harsh environment.
The BLM says there should be no net loss of habitat. To achieve this result the “mitigation hierarchy” will be implemented- avoidance first, then minimization, and finally compensation. An example of minimization is reducing the footprint and buffer zones around leks. Increasing habitat would be much easier if the BLM would speed up the permit process for water pipelines and not interfere with stock water development applications at the state water resource departments. In Nevada, for instance, it is against the law to prevent wildlife from accessing historic water sources. So, if we are really interested in rehabilitating and enhancing sage grouse and wildlife habitat and mitigating damage, encouraging stock water development by private interests would be a positive gesture by the BLM.
The BLM admits raven populations have exploded in the past fifty years to nearly double the numbers which existed then. Ravens, among other less harmful species, are protected under the Migratory Bird Treaty Act. These birds are especially adapted to human caused influences such as structure and power lines. They are also very intelligent and find areas of sage grouse habitat and leks that they exploit quite easily by eating sage grouse eggs and young hatchlings. There is an admission by the BLM that raven densities and increased numbers in certain areas might be a greater threat to sage grouse than wildfire, but there is no concrete suggestion of a solution to the raven predation problem. However, rather than suggest that the raven numbers be reduced by amending the Migratory Act limitations on take, the document talks about transmission line and structural development as factors of concern. This is an excuse. Is the BLM afraid of offending a sister agency such as the Fish and Wildlife Service by suggesting amending the Migratory Bird Treaty Act to allow more ravens to be eliminated to help save the Sage Grouse?
In the FLPMA, Section103(a), an ACEC (Area of Critical Environmental Concern) is defined as an area on BLM- administered lands where special management attention is required to protect and prevent irreparable damage to, among other things, wildlife resources. It is true an ACEC designation does not automatically prohibit or restrict other uses such as livestock grazing. However, there is a concern that the RMPA is paying a great deal of attention to creation of ACECs and there may be consequent restrictions on grazing. What is irksome if that becomes an eventuality is the science is now clear there is a symbiotic relationship between animal agriculture and sage grouse viability and the BLM seems to ignore this reality, in my opinion. These four examples taken from this massive document with a few personal comments doesn’t begin to illustrate the scope of the BLM effort.
To me the answer to the question of how to protect the sagebrush steppe and all the dependent species boils down to some science, some experience and some common sense. The scientific literature is well-settled that sage grouse do well in areas where there is an irrigated agriculture presence. It is also well-recognized that ravens are a major factor in the decline of the sage grouse populations west-wide. Common sense says observe the areas where there are larger numbers of the birds and ask what the relevant factors for success are. It is also worth the time to observe the areas where there are declining numbers and ask why. Develop more water resources for livestock and other animals will benefit.
Fire is clearly one of the biggest reasons for a loss of sage brush steppe. Properly managed livestock grazing is one of the best tools to reduce fine fuel loads which contribute to catastrophic fire conditions. There are proven methods of grazing as a positive tool by changing seasons of use and placing larger numbers of grazing livestock on the ranges in a more strategic way. The agencies need to become more creative and add some common sense thinking to their processes. I would suggest the minimized use of ACEC designations because all the habitat can be effectively managed without creating another bureaucratic layer to the analysis and implementation of solutions.
Also, stay informed and become even more active in your dealings with all the agencies impacting your operations.
I’ll see you soon.