July 21, 2014
CWF submitted comments to the US Forest Service in July on the Weminuche Landscape Grazing Analysis. Our comment letter appears below. Note that on August 2 the US Forest Service decided to stop its work on the environmental assessment and to undertake an environmental impact statement process. We understand the reasons given were the complexity of the issue and the level of public interest.
July 19, 2014
Columbine District Ranger
PO Box 439
367 S. Pearl Street
Bailey CO 81122
Columbine District Ranger
Draft EA for the Weminuche Landscape Grazing Analysis
Transmitted by email to email@example.com
Dear Mr. Madrid:
Colorado Wildlife Federation thanks you and the US Forest Service for opening a second comment period on this very important matter.
Colorado Wildlife Federation (CWF) is the oldest continuously active wildlife conservation organization in Colorado, a 501(c)(3) nonprofit whose members consist of hunters, anglers and other wildlife enthusiasts. CWF’s mission is to promote the conservation, sound management, and sustainable use and enjoyment of Colorado’s wildlife and habitat through education and advocacy. CWF understands that wildlife habitat and healthy populations are critical to conserving Colorado’s unique wildlife, hunting and fishing heritage, and wildlife viewing opportunities. These wildlife-related recreation pursuits enrich the well-being of residents and visitors and form a substantial segment of Colorado’s economy. CWF members fish, hunt and recreate on federal lands in Colorado that will be impacted by land use planning and management decisions intended to maintain long-term viability of bighorn sheep populations.
The Weminuche bighorn sheep herd is classified by CPW as a Tier 1 population, meaning that it is among the most important bighorn herds in the state, and, therefore, is of highest management priority (Weinmeister 2012, http://cpw.state.co.us/Documents/Hunting/BigGame/DAU/BighornSheep/RBS20DAUPlan.pdf ). It also is important to note that this herd is primarily native rather than a product of translocations.
We support the aspects of Alternative 4 (Adaptive Management with Closing Vacant Allotments) that would permanently close the seven vacant grazing allotments and convert the Canyon Creek allotment to cattle grazing.
Unfortunately, Alternative 4 would pose a high probability of contact between this prized bighorn herd and the domestic sheep. The potential risk of disease transmission between domestic sheep and goats and bighorn sheep is one of the most serious issues affecting the long-term viability of bighorn sheep populations (WAFWA Recommendations for Domestic Sheep and Goat Management in Wild Sheep Habitat 2012). The Forest Service recognizes, “…[p]hysical contact between domestic sheep or goats and bighorn sheep increases the risk of disease transmission from domestic animals to bighorn sheep, with potential for a subsequent bighorn sheep mortality event and/or extended period of reduced recruitment.”
The potential loss of 75 percent of the bighorn sheep populations in the planning unit under Alternative 4 is beyond dismaying. Worse, the Forest Service’s claim that a disease event affecting 75 percent of the bighorn sheep population in the forest would not result in a loss of viability in the forest is not well substantiated and likely would not hold up to scientific scrutiny (Risk assessment, p.96). In addition, the economic analysis should include economic values of hunting and wildlife viewing. See the economic report released by Colorado Parks and Wildlife earlier this year, “The Economic Contributions of Outdoor Recreation: A regional and county-level analysis. Hunting, wildlife viewing and fishing in southwest Colorado produce $405 million in economic output. Hunting output in Hinsdale, LaPlata and San Juan Counties is shown as $14,221,000, before adding on the salaries and wages, gross domestic product contribution, taxes and jobs. There would be an economic impact if bighorn sheep in the planning unit were decreased by 75 percent.
The three-pronged adaptive management approach in the EA to identify and address future conflicts simply does not appear to recognize the expected outcome for the bighorn sheep population from any contact with domestic sheep: loss of a Tier 1 herd. The total herd contact rates for S-28 indicate under the allotment configuration proposed in Alternative 4 there is concern for the potential for physical contact with the Endlich Mesa, Virginia Gulch and Tank Creek allotments, respectively. In fact, Alternative 4 alters the boundary of the Endlich Mesa allotment, effectively increasing the risk of contact with bighorn sheep, per the risk assessment (pg 43). The total herd contact rates for these three allotments exceed the levels thought likely to maintain long-term bighorn herd persistence (one disease event every 46 years), even under an assumption of moderate (25%) or low (10%) disease transmission probability (Risk assessment, pg 95). What is needed is a design that provides effective temporal and spatial separation between domestic and wild sheep. We note that the EA does not consider or analyze the potential for moving current permittees to vacant allotments that would provide for effective separation of bighorn sheep and domestic sheep. Are there opportunities to convert to cattle grazing on lower elevation ranges? Also, is the Forest Service exploring other potential replacement allotments that would not risk contact between domestic sheep and bighorn sheep?
Again, thank you for the opportunity to comment on this very important land management decision.
Executive Director, Colorado Wildlife Federation