Working for responsible management of public land grazing

Ideas for Reforming National Forest Grazing

Felice Pace, Grazing Chair, Redwood Chapter SC and Coordinator, Project to Reform Public Land Grazing

These ideas are aimed to stimulate thinking within Sierra Club and other public land activist networks about what might be accomplished to reform National Forest Grazing, both administratively and via legislation, with a new administration and new Congress in 2021. Some of the suggestions also apply to grazing on federal lands administered by the US Bureau of land Management. My hope is that there can be a process within these networks leading up to January 2021 which is focused and ready to push for reforms if conditions are favorable.

The ideas are informed by ten years monitoring grazing management on the ground in Northern California and Southern Oregon and using that monitoring to advocate for on-the-ground management reforms. I believe they are consistent with the Sierra Club Policy for “Grazing on Public Lands” adopted by the Board of Directors in 2000.


Administrative Reforms (some may require rule-making or other processes):

  1. National Forest Grazing BMPs: NF Core BMPs require site specific BMPs for grazing allotments and the use of Annual Operating Instructions (AOIs) to permit holders to implement the BMPs once NEPA has been completed. However, grazing NEPA has slowed to a crawl. Direction from the FS Chief (or USDA Under Secretary) would instruct responsible federal officials (district rangers) to develop site specific BMPs and to implement them via AOIs whether or not NEPA has been completed.

  2. Much of the grazing on western national forests targets or includes headwater basins with wetland cores. But BMP’s that apply to national forest wetlands have not been implemented on national forest grazing allotments. A directive from the Chief of the Forest Service (or USDA Under Secretary) would order implementation of the wetland BMPs on all grazing allotments.

  3. Automatically close and abolish any and all national forest allotments which are at the time of promulgation or in the future “vacant” for five years or more.

  4. Instruct all rangers (the responsible federal officials) to adjust the number of livestock permitted to graze allotments (“stocking”) via Annual Operating Instructions in order to provide adequate forage for native grazers, including wild horses.

  5. When completing environmental analysis for grazing allotments, require calculation of forage available for grazing based on actual conditions and data, adjusted for the amount of forage needed to provide for native grazers. In completing those calculations, consult with State Fish and Wildlife agencies.

  6. Require implementation of Multiple Indicator Monitoring (MIM) to the BLM Protocol on all riparian areas on all national forest and BLM grazing allotments.


Legislative Reforms:

A) Standard Legislative Process:

  1. For a variety of reasons, including not wanting to rile congressional grazing supporters, the Forest Service refuses to actually close allotments even when they have been “vacant” for many years, are not good allotments in terms of forage availability, are unwanted by any ranchers and unlikely to be wanted anytime in the future. Therefore, it would be good to have a legislation that requires the FS to “retire” any grazing allotment that has been “vacant” for a decade or more.

    In the 1995 Rescission Bill (Public Law 104-19) Congress gave the FS authorization to reissue ten year term grazing permits even if environmental review had not been completed. That has resulted in FS completing fewer and fewer grazing EAs every year since then. This is documented in FS Rescission Act Reports to Congress. One is attached; see the appendix at the end for EA completion by region. In 2016, for example, Regions 4,8 and 9 did no grazing NEPA; REGION 5, California, did one. It would be good to get legislation, or language in an appropriation bill, rescinding the Rescission Bill language or prohibiting the FS from issuing a grazing permit unless environmental review of the decision has been completed within the past five years.

  2. There have been a number of provisions added to wilderness bills or within proposed wilderness bills that allow grazing permit holders to use motorized equipment inside designated wilderness to maintain “improvements” (add photo of MM Wild cabin here). It would be good to have a section added to a larger wilderness bill which specifying that, not withstanding those provisions, management agencies should approve motorized use only where there is no feasible non-motorized alternative

B. Appropriations Process:

Many but not all of what can be accomplished via the standard legislative process can also be accomplished via language inserted into the annual bills which provide funding to the Forest Service and BLM. For example, language can be added to the bills that:

  • Mandates implementing inter-agency Multiple-Indicator Monitoring (MIM) on all grazing allotments.

  • Instructs agency grazing managers to implement modern rotational grazing on all allotments in order to reduce impacts to water qyuality and riparian areas.

  • Instructs agency managers to rest from all grazing any allotment which does not meet riparian and water quality standards for two successive years or for the amount of time needed to restore riparian areas and water quality to standard.

  • Reversing the Appropriations language that gave FS managers the ability to issue new 10 year grazing permits even if NEPA review had not been completed. The new language would require new NEPA review and and a new decision, and the implementation of modern grazing management practices like rest-rotation grazing, before a new or renewed grazing permit can be issued.


Provisions added to appropriations bills can be designed to apply from thence onward; they do not need to be renewed each Appropriations Cycle. What is required in order to get such language added to an Appropriations Bill, however, is participating in the entire Appropriations Process and securing a champion on the proper Appropriations sub-committee who has the power to get bill language added.


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