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I. DRAFT EIS on the West Fork Blacks Fork Grazing Allotment

The Evanston Ranger District (ERD) on the Wasatch-Cache National Forest (WCNF) has released the Draft Environmental Impact Statement for the West Fork Blacks Fork Grazing Allotment (DEIS), most of it in the High Uintas Wilderness (HUW). Comments are due by 3 OCTOBER:
Steve Ryberg, District Ranger
ATTN: West Fork Blacks Fork AMP
Evanston Ranger District
Wasatch-Cache National Forest
PO Box 1880
Evanston, WY 82930
1. Note in the subject line, West Fork Blacks Fork AMP comments.
2. You must provide your mailing address on your email.
3. If you can, sign your email.

A Comment on Public Comments:
Comments are needed. They do help. Our collective cynicism, exasperation and lack of time can’t be allowed to override the only process available to us to set the record, to set the direction, to build the common theme of wildness. Whether we step forward believing from experience, from commitment or simply to bear witness, we must step forward.


For almost a decade the ERD has tried to justify grazing on this drainage, considered by many to be one of the most stunning drainages on the North Slope of the Uintas. In 1995 an Environmental Assessment (EA) was started and released in 1999, authorizing grazing but conceding impacts were significant and that it would take up to 40 years to bring the area into compliance with the forest plan standards. This disconnect between the data and the decision was so pronounced the Forest Service withdrew the EA and started over. Five years later this DEIS was released.


The ERD proposes to continue grazing (Alt. C) for 1,075 ewes and their lambs from early July to mid September with half the alpine unit (Deadhorse Lake and benches) rested for two years while the other half is grazed. Nearly 1,000 additional sheep are allowed to use the West Fork Blacks Fork for trailing up the drainage and onto the Ashley National Forest. Alternative A discontinues grazing, but allows trailing of Ashley sheep, and Alternative B discontinues grazing in the alpine unit only.

  1. Stream bank and riparian impacts from sheep trailing and grazing are noted as significant, but “localized” and dismissed as being inconsequential, given the impacts to the West Fork Blacks Fork from a natural recent landslide which is adding sediment to the stream.
  2. The effects of grazing on alpine soils are dismissed because, “It is impossible to determine what percentage of the disturbance to natural integrity is resulting from the management of grazing activities.” According to the DEIS, this is due to inherent natural geomorphic actions, long lasting snowbeds, and disturbance from native pocket gophers!
  3. Impacts to upland soils (subalpine and montane) from sheep grazing are “expected to continue…In localized heavily used areas, soil movement by wind and water is expected to continue.” This is DISMISSED because it is considered localized and often intermixed with recreational impacts.
  4. Wilderness as resource other than recreation was DISMISSED because grazing is specifically allowed in wilderness and cannot be curtailed “simply because it is designated as wilderness.” The fact that grazing can’t be curtailed because of wilderness designation (it can be restricted and reduced) IS NOT A REASON TO CONCLUDE, AS THIS DEIS DOES, THAT GRAZING HAS NO IMPACTS ON WILDERNESS VALUES.
  5. Wilderness recreation impacts are played down, believe it or not, because recreation use is low and because, as you travel up or down the drainage and the sheep are not within sight or in the grazing unit that you happen to be hiking in, you will experience no effects of sheep grazing!
  6. The DEIS concludes there are no impacts to wildlife from sheep grazing, including lynx, because summer range is not limiting and wildlife can move or they reside in the forest where sheep don’t graze. Predator control was dismissed as an issue because the Forest Service conveniently turned predator control over to the federal Wildlife Services (formerly Animal Damage Control.)
  7. In its socio-economic section, the DEIS pairs two statements: one from us, “Rangelands on today’s national forest lands have a much broader value than pastureland,” vs. ‘public lands grazing permits play an important role in the vitality of the local economy and any reduction (emphasized with bold and underline) has significant negative impacts on the permitee’s ability to continue the livestock operation.” Not the least bit surprising, the only analysis in the DEIS is the impact upon the specific rancher if grazing is reduced, altered or discontinued. The conclusion is he would not go out of business but would suffer economic stress.
  1. The DEIS does highlight geomorphic and natural effects occurring within the wilderness!
  3. Where grazing was analyzed, it was shown as being significant and threatening ecosystem integrity and not meeting standards. These impacts were dismissed because they were localized! This is an awfully convenient way to dismiss every impact to forest service lands—remember, this is a designated wilderness!
  4. Summer habitat is LIMITING. Wildlife is constrained by territories and the ability to move in and out of a drainage. Both are limited and grazing occurs in adjacent drainages further restricting habitat.
  5. Ironically, the analysis in the “no grazing alternative” shows that every resource category would be enhanced if grazing were eliminated. Their own arguments that there are no impacts from sheep grazing is bogus and disingenuous.

Let it sing vitally, vigorously, with these and your own talking points.
A sample letter might look like this:
Dear Mr. Ryberg:
Please accept these comments on the West Fork Blacks Fork grazing DEIS.
While the DEIS analyzes a number of geomorphic and natural process occurring on the West Fork Blacks Fork, it does not analyze grazing impacts by thousands of sheep grazing in fragile high elevation and alpine landscapes. Rather, the DEIS simply concedes that, because geological processes are active and native pocket gophers are found at higher elevations, it is too hard to document sheep grazing impacts. This is absurd, disingenuous and ironic because the DEIS concludes there are notable sheep grazing impacts to soils and stream crossings, but because they are localized they lack importance.
This is just wrong. After nearly a decade of analysis, the DEIS shoves the issue of alpine grazing in the High Uintas Wilderness aside by admitting an analysis wasn’t done or impacts are localized. This is a highly convenient way to ignore environmental impacts. Presumably, if the whole drainage were trashed, the Forest Service could conclude that it represents only 10% of the HUW and is thus localized.
The DEIS does show that these impacts are real in the no grazing alternative by noting that all resource values would improve if grazing were eliminated within the two year time frame.
Furthermore, dismissing impacts to wilderness values simply because grazing is allowed makes no sense. This must be reconsidered. Recreation is also allowed in wilderness yet the Forest Service wouldn’t hesitate to analyze wilderness recreation impacts. As a wilderness user I can assure you there are impacts from sheep grazing to the natural setting, water quality and wilderness experience.
And finally, the ultimate unfairness in the DEIS is found in the section on economics where the only analysis is of the personal financial impacts to the rancher with no consideration to the broader social and economic values associated with wilderness.
It is clear the best solution is to phase out grazing so the rancher will have time to alter his grazing permits and protect the HUW and the ecosystem integrity of this high elevation region.
Thank you.

II. Authorize continued grazing in the Hessie Lake and Gilbert Peak Sheep

The ultimate irony: this same ERD is proposing to continue sheep grazing on two additional High Uintas Wilderness allotments, HESSIE LAKE (HL) and GILBERT PEAK (GP), both on the Henrys Fork! Both would authorize grazing of 1,400 ewe/lamb pairs! COMMENTS ARE DUE 23 SEPTEMBER at the ERD address above.

This time around the Forest Service has decided to categorically exclude the analysis of these allotments from having to prepare an Environmental Impact Statement. A Categorical Exclusion (CE) allows the Forest Service to avoid preparing a proposal, analyzing alternatives and subjecting the analysis to public comment and appeal. We only have one opportunity for public participation and that is without the benefit of a detailed analysis and with only the promise that the allotments are meeting grazing standards. The WFBF analysis has made it clear that promise is meaningless!
A decade to prepare the WFBF analysis and ignore the impacts of sheep grazing and then less than a month without analysis to authorize it on the Henry’s Fork!

The only issues identified in the HL/GP proposal are impacts to upland vegetation and riparian areas and to sensitive, rare or threatened wildlife. The document doesn’t even mention the High Uintas Wilderness and the maps don’t even show the wilderness! Ironically, this proposal runs counter to Forest Service guidelines which require preparation of an Environmental Impact Statement (EIS) when wilderness is involved if the wilderness is likely to be impacted!

  1. Tell the Forest Service that, because these two allotments are within the HUW and account for over 25,000 acres, an EIS with a full array of alternatives and complete and open public review should be prepared. Don’t mince your words—the irony with the WFBF is deep and profound and tells us the ERD wants to eliminate your voice.
  2. If you know these areas, tell the District Ranger just how wild this place is and why it is meaningful to you as both a wilderness advocate and wilderness user. Portray precisely how thousands of sheep hurt wilderness values and your own experience.
  3. Remind the District Ranger that there are other values than sheep on the Uintas! Tell them they need to analyze wilderness values, broad socio-economic values, and water quality

A sample letter might look something like this:

Dear Mr. Ryberg:

Please accept these comments on the proposal to allow grazing to continue on the Gilbert Peak and Hessie Lake Allotments.
Both of these allotments, some 25,000 acres of public lands, are within the High Uintas Wilderness. Because of this, they should be incorporated into a full scale Environmental Impact Statement as they notably influence wilderness values and wilderness recreational experiences. Although your proposal and scoping document don’t mention designated wilderness and the maps in the document don’t even show the wilderness boundary, wilderness is the defining resource and on these allotments. They are in the very heart of the HUW. Sheep grazing impacts wilderness values and wilderness experiences at a fundamental level because it impacts the sense of naturalness, pollutes drinking water and becomes a dominant human activity in an environment where Mother Nature’s forces are supposed to dominate.
There are other values than grazing on these areas. I object to your effort to categorically exclude these analyses from a full, open and accountable environmental process. I want my voice to be heard, not just that of the sheep rancher. Thank you.


High Uintas Preservation Council
PO Box 72
Hyrum, UT 84319

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