FULL LETTER FROM PERRI JACOBS
April 22, 2015
BLM Field Office
ATTN: B.J. Rhodes
501 S. 2nd St. East
Malta, MT 59538
I am writing in regards to the APR request for several changes to their Flat Creek Allotment #15439 in Phillips County. The changes requested are as follows:
1. change the class of livestock from cattle to indigenous bison,
2. remove interior fencing and manage their public and private land as one common pasture, and
3. change the grazing season to year round.
I am opposed to all of these changes. First of all, I have no idea what APR means by indigenous bison so let us explore that issue. According to Miriam Webster online dictionary indigenous means produced, growing, living or occurring naturally in a particular region or environment. Under Montana law all indigenous species are monitored, managed, and under the control of the Montana Fish, Wildlife, and Parks. Therefore indigenous bison belong under the control of MT FWP. Also, BLM has no permitting process for indigenous species, so this request cannot be honored and the Flat Creek Allotment should still be managed for livestock such as cattle, sheep or bison classified as livestock.
According to a BLM fact sheet titled, Investing in Range Improvements on Public Lands, “there are two kinds of range improvements: nonstructural and structural. Fences or facilities such as wells or water pipelines are examples of structural improvements. Many structural improvements are considered permanent, as they are not easily removed from the land.” “Often the BLM, operators, and other interested parties work together and jointly contribute to the construction of structural improvements.” So I ask, “why would BLM remove a structural improvement that they financially supported and that they required of the operator in order for the operator to meet the terms and conditions of their permits or leases?”
Again, according to the previously mentioned fact sheet, “Why are range improvements needed? Such improvements enhance or improve livestock grazing management, improve watershed conditions, enhance wildlife habitat or serve similar purposes.” I would like to know how the removal of fences would enhance or improve livestock grazing management, improve watershed conditions and/or enhance wildlife habitat.
Livestock distribution is the greatest challenge in managing rangeland resources. Fences, mineral/salt placement, and water sources are commonly used for livestock distribution and improved forage production. Improved forage production enhances food and cover for wildlife and birds. Those natural resources are an important component of a healthy rangeland. How will BLM keep the rangeland healthy when
there is no control of livestock distribution? There are many anecdotal examples of BLM being chastised in the media for their lack of a healthy range landscape. I would think that creating one large pasture, with few, if any resources for adequate livestock distribution would only exacerbate the perception that BLM does not do its’ job.
I have reviewed the BLM Standards for Rangeland Health and Guidelines for Livestock Gazing Management for Public Lands Administered by the Bureau of Land Management for Montana and the Dakotas. There is a note that these standards and guidelines apply to the Lewistown and Malta Field Offices. Lewistown GUIDELINE #10 states, “Livestock management should utilize practices such as those referenced by the NRCS published prescribed grazing technical guide to maintain, restore or enhance water quality.”
From the Natural Resources Conservation Service Montana Conservation Practice Specification Prescribed Grazing Acres, Code 528 I quote the following:
“A prescribed grazing system shall be designed that is comprised of multiple pastures that are alternately rested from grazing in a planned sequence. A grazing schedule is developed in order to regulate the time of the year grazing is to occur, the length of the grazing period, and the frequency and extent of plant defoliations.
Scheduled rest periods for plant recovery after grazing are essential, and must occur within the current or following growing seasons of the plant species to be managed. The length and frequency of planned rest periods will determine the amount of grazing utilization possible without damage to plants.
The forage requirements of the animals to be managed must be balanced with the total forage supply of the pasture. Consider the accessibility of forage during the period when livestock (note it does not say indigenous bison0 are scheduled to graze. Forage production data may be field measured (clipped and weighed) or estimated using weight units of plant species on a site -specific basis. Refer to the National Range and Pasture Handbook for guidance regarding development of initial stocking rates and accepted inventory methods. Livestock breed, age, size, physiological stage and weight must be considered to assign the appropriate animal unit equivalent factor.
Facilities such as fences and water developments may need to be developed before initiating a grazing system. For optimum livestock performance, all livestock should have access to water within a 2-hour period. Check storage capacities of wells and springs, and seasonal availability of ponds, streams, or other live water sources.
The number, size, and arrangement of pastures will greatly influence and possibly dictate the type of grazing system to be applied. The system must be designed considering water availability, fencing, and natural barriers. It must be compatible
with labor resources, and ease of moving livestock (not sure how you move indigenous bison) must be considered.
In general, when designing the grazing schedule, no pasture should be grazed for more than half the growing season of key species, to avoid selective re-grazing of preferred plants. For specific circumstances if grazing occurs longer than half of the growing season in a particular pasture, then that particular pasture should be completely rested for two consecutive years or only grazed during the dormant season the next three years.
Periods of use throughout the grazing season (early, mid, late) will be alternated from year to year. To ensure reproductive recovery of key species, grazing may need to be deferred from initiation of growth until the dormant period at least once every three to four years. Where maintenance or enhancement of shrubs and/or trees is an objective, the season of use should be alternated from year to year, or the grazing prescription should provide for annual light use of browse species, to allow for woody species regeneration. Continued early spring use can reduce the potential forage production by eliminating new leaves needed to capture sunlight energy and may cause resource damage in areas where soils and streambanks are wet and more susceptible to compaction and animal trampling damage.
The season of use (spring, summer, fall, winter) within a pasture should be planned according to management objectives, plant physiological requirements, and animal nutritional needs. It must also coordinate with livestock management operations, such as breeding and calving periods.”
BLM’s own published guidelines, in my opinion, state that it would be inadvisable to remove fences and allow grazing year round.
Again, I reiterate that I am opposed to the changes requested by APR for their Flat Creek Allotment. I appreciate you taking the time to review my comments. I look forward to a response once you have reached a decision regarding the Flat Creek Allotment in Phillips County.
Perri A. Jacobs
cc: Jamie Connell, State Director
Mark Albers, Hi-Line District Manager