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Sheep Grazing And Painter Basin

The Ashley National Forest released a scoping document this summer and is in the early stages of preparing an environmental analysis of the Painter Basin (headwaters of the Uinta River) and Tungsten (headwaters of the Yellowstone River) sheep grazing allotments, both in the High Uintas Wilderness.

It is imperative the allotments be reviewed with a full Environmental Impact Statement with the appropriate context: Is grazing on these two allotments appropriate and, if so, at what levels in order to maintain properly functioning ecological conditions and maintain the ecological integrity of the area? This assures a more objective management context and doesnt bias the data collection and the alternative formulation from the start. Far too often the analysis starts with a pre-determined answer, 'grazing should be continued, maybe with some restrictions,' then directs the analysis to compose information to meet the answer!

We also suggested that a phase out alternative be considered wherein the allotment would be phased out from domestic grazing status over the next decade in order to emphasize the natural values. A time certain phase out date would allow the permittee an opportunity to prepare for alternative grazing and pasture. There are numerous issues, including determining ecological trend in the context of properly functioning condition. The issue is only partially alpine and subalpine vegetation - the real question is condition and trend of vegetation on the allotment and whether that condition and trend is meeting proper ecological conditions. Is 20, 30 or 40 years to achieve such conditions appropriate and, if so, why? Over the recovery time frame what will be the impacts to water quality, soil productivity, the physical characteristics of soil, as well as a broad range of impacts to wildlife, big and small, avian, aquatic and terrestrial?

Also of consequential importance are the issues of impacts of grazing upon a plethora of wildlife species and habitat. This is particularly important with respect to predators, indicator species, particularly lynx, and numerous avian species, including goshawk. Livestock grazing in many areas throughout the West has helped reduce populations of goshawk prey species due to loss of herbaceous ground cover. Bighorn sheep represent a crucial and framing issue. Almost all the literature now recognizes bighorn sheep must be "buffered" by at least 9-10 miles from domestic sheep in order to provide the minimum security bighorn need from disease transmission.

Impacts and trend to riparian systems are of deep concern. Constantly fencing off some riparian areas and building troughs/pipelines to distribute sheep (and cattle) is not an indication of creative management but of the actual low ecological capacity for grazing, a defining issue. How many grazing "enhancement" structures are on the allotments?

These allotments are within the High Uintas Wilderness. This represents special concerns/issues both from a recreational standpoint and a resource concern. These areas are of special importance, in some cases crucial wildlife sanctuaries, and certainly harbor unique values and characteristics that need consideration. The simple fact that the allotment is in a designated wilderness precludes the Forest Service from unilaterally declaring grazing to be unwelcome. But under no conditions does it prohibit analysis and resolution of impacts. In fact, if impacts to the physical, biological and social resources are significant, then the Forest Service has no choice but to decide how to respond, including termination or phasing out of grazing. Grazing impacts on wild, natural and wilderness values (outstanding opportunities for solitude and primitive and unconfined recreation, primeval character, without permanent improvements, preserve its natural conditions, primarily affected by the forces of nature, etc.) must be considered with a determination of how grazing should be moderated, modified or eliminated due to those values. The goal of wilderness management is to increase the "purity" of wilderness and decrease the impacts of humans on the natural forces that primarily guide the context of wilderness.

Also of significant concern is the economics of grazing. The issue is not only about a "local economy." The issue is much broader. Social and economic impacts are important, but if the Forest Service insists on suggesting only the permittee (or other permittees, by way of inference), his neighborhood or community are the target of the analysis, then the analysis is suspect from the outset. A great many people place wide, important social and economic values on this area and its surrounding environs and must be considered as part of any true, meaningful social and economic valuation.

Rangelands on todays national forest lands have a much broader value than pasture land. That is the issue. The ecological values--the definition of this system--are an issue
here. This cant be passed over or passed off!

Dick Carter

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