CWF Comments re Snow Mesa Allotments Grazing Analysis

February 10, 2014

Below is the comment letter submitted by CWF on February 9, 2014 to the US Forest Service in the public scoping process for the Snow Mesa Allotments Grazing Analysis.


February 9, 2014

Rio Grande National Forest
Attn: Debra Mollet, Acting District Ranger
Divide Ranger District
13308 West Highway 160
Del Norte, CO 81132

Transmitted via email to

Dear Ms. Mollet:

Thank you for the opportunity to provide input to the Public Scoping Process for the Snow Mesa Allotments Grazing Analysis.

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 is 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’s 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 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 Snow Mesa Allotments lie completely within the potential range of two important legacy (native) bighorn sheep herds located in Game Management Units S-22 and S-53.

It is entirely likely that co-mingling of wild and domestic sheep will occur in the future under the existing grazing management framework. Indeed, there are documented and undocumented reports of that happening in 2005, 2010 and 2011. As stated in the unpublished report: Bighorn Sheep Surveys Rio Grande National Forest – Divide RD 2010, p13: “Future Bighorn die-offs are considered likely without modifications to these allotments.”

Therefore, CWF applauds your commitment to complete a Risk of Contact Analysis evaluating the potential for direct contact between domestic and bighorn sheep. If that analysis shows a high risk of contact, we encourage the Divide Ranger District to fully consider the risk of disease transmission and to implement, in cooperation with Colorado Parks and Wildlife (CPW), the WAFWA Recommendations (pp 11-16) to maintain “effective separation” between domestic and wild sheep.

In the past, it has been suggested that an Adaptive Management Strategy may be used to identify and address future conflicts. Adaptive Management is a structured, iterative process of robust decision making in the face of uncertainty, with an aim to reducing uncertainty over time via system monitoring and may not be an appropriate method for addressing situations such as domestic sheep grazing in bighorn sheep habitat. In the case of the Snow Mesa Allotments, there is documented evidence of past co-mingling of domestic and wild sheep and a high probability of interaction again in the future. The expected outcome of such contact is well documented. Therefore, the assumption of uncertainty is not met. And so, the final Allotment Management Plan should contain specific measures designed to provide effective temporal and spatial separation between domestic and wild sheep.

Again, thank you for the opportunity to comment on this very important land management decision.


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