Wild sheep and disease


Really interesting article, thanks for posting @Oak. This part is interesting:

“Colorado Parks and Wildlife can manipulate hunting licenses, improve habitat or move bighorn sheep, but when it comes to conflicts with domestic sheep on federal grazing lands, it is up to federal agencies to make changes.”

This speaks to a conflict I have discussed before- states manage the wildlife while the feds manage the land they require for their survival. With respect to Colorado bighorn management, this arrangement does not appear to be working well.
 
Great piece. Thank you @Oak for bringing statewide attention to this important issue. Another example of the great work by the consummate professionals at CPW and passionate volunteers at RMBS.
 
@Oak Are there any good options for the general public to put pressure on the federal agencies?
Mountain Studies Institute (MSI) https://www.mountainstudies.org/ has a bighorn sheep monitoring program and has extremely knowledgeable staff and volunteers doing work and advocacy. CO chapter of BHA has been financially supporting them for three years.
 
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@Oak Are there any good options for the general public to put pressure on the federal agencies?
There are probably not a lot of good options under the current administration, given their initial signaling of support for less oversight of public lands vs more oversight. Especially when NEPA is likely to lead to more stringent management of those lands. Likely the only effective pressure would be Congressional direction to prioritize processing of allotments with resource conflicts, along with the funding to do the work. As it is, the agencies have a free pass on the grazing programs, so there is no incentive to spend limited budgets there.

Mountain Studies Institute (MSI) https://www.mountainstudies.org/ has a bighorn sheep monitoring program and has extremely knowledgeable staff and volunteers doing work and advocacy. CO chapter of BHA has been financially supporting them for three years.
I worked with Dan to move the bighorn observation program to MSI years ago, and RMBS has been funding it annually since then (2018?). It has done a lot to bring public attention to the issue, and has provided valuable data that has contributed to our efforts on compensated permit waivers. The data will also prove valuable if/when NEPA is ever completed on grazing allotments. Here's an old article about the program.
 
Here's a short CPR hit from yesterday on CO bighorn sheep disease. Scroll down to Segment 2. Andy did a good job, but I'm going to have to question him on the "hundreds" of CPW staff working on bighorn sheep issues. ;)

 
On the same day the 10th Circuit issued their corner-crossing decision, oral arguments were happening on the appeal of a USFS decision to continue grazing a high-risk domestic sheep allotment in SW Colorado. The FS completed a risk assessment and found the allotment to be extremely high risk to wild sheep, then arbitrarily used "local conditions" to give it a "moderate" risk rating. Things like having a highway and the Rio Grande River between the bighorns and the allotment, being close to the highway for better detection of contact between wild and domestic sheep, having no overlap between mapped bighorn range and the allotment (0.5 mile separation), etc. You can listen to the 35-minute or so proceeding on YouTube here. Hard to say for sure, but I'm not convinced the judges were buying the FS arguments.
 
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On the same day the 10th Circuit issued their corner-crossing decision, oral arguments were happening on the appeal of a USFS decision to continue grazing a high-risk domestic sheep allotment in SW Colorado. The FS completed a risk assessment and found the allotment to be extremely high risk to wild sheep, then arbitrarily used "local conditions" to give it a "moderate" risk rating. Things like having a highway and the Rio Grande River between the bighorns and the allotment, being close to the highway for better detection of contact between wild and domestic sheep, having no overlap between mapped bighorn range and the allotment (0.5 mile separation), etc. You can listen to the 35-minute or so proceeding on YouTube here. Hard to say for sure, but I'm not convinced the judges were buying the FS arguments.
I forgot to update this in May, but indeed the 10th Circuit Court of Appeals did not buy the USFS arguments for using arbitrary "local conditions" to approve grazing. A rare win for bighorn sheep. Court opinion attached.
 

Attachments

  • opinion (3).pdf
    600 KB · Views: 4
The primary grazing management issue for federal agencies is that they don't have the staff/funding to complete NEPA analysis of all grazing allotments at permit renewal. Congress has given the agencies a permanent pass on this issue by allowing them to renew grazing permits under existing terms and conditions "until the date on which the Secretary concerned completes any environmental analysis and documentation for the permit or lease required under the National Environmental Policy Act of 1969 and other applicable laws.”

This is essentially "forever" for grazing permits with resource conflicts like bighorn sheep, sage grouse, and other T&E species, because those require complex, time-consuming analyses. The agencies complete analyses (EAs, DNAs, etc.) on the low hanging fruit allotments with no conflicts and few land health issues, and renew the permits with conflicts without analysis. Renewals are generally for 10-year terms, meaning that the line officer signing the renewals will likely never have to revisit the issue.

In December 2024, the BLM addressed this backwards management by released a "permanent" instruction memorandum (PIM) directing BLM offices to prioritize allotments with high value resources:

"Field Offices (FOs) must give the highest priority to the work necessary to meet applicable legal requirements (e.g., court orders, compliance with the Endangered Species Act and associated regulations, etc.). FOs must then use the criteria listed below to develop a prioritization schedule for fully processing[1] active grazing allotments with high-priority resources. Sage-grouse and Bighorn Sheep habitats are the two highest priority resources based on the ongoing rangewide efforts to conserve the Greater Sage-Grouse (GRSG) and the potential long-term nature and degree of potential impact of disease on bighorn sheep populations."

A couple of months ago, the current administration moved the PIM to "inactive" status. So we are back to business as usual, and now with even less capacity to complete NEPA due to staff reductions.

IMG_4117.JPG
 
The primary grazing management issue for federal agencies is that they don't have the staff/funding to complete NEPA analysis of all grazing allotments at permit renewal. Congress has given the agencies a permanent pass on this issue by allowing them to renew grazing permits under existing terms and conditions "until the date on which the Secretary concerned completes any environmental analysis and documentation for the permit or lease required under the National Environmental Policy Act of 1969 and other applicable laws.”

This is essentially "forever" for grazing permits with resource conflicts like bighorn sheep, sage grouse, and other T&E species, because those require complex, time-consuming analyses. The agencies complete analyses (EAs, DNAs, etc.) on the low hanging fruit allotments with no conflicts and few land health issues, and renew the permits with conflicts without analysis. Renewals are generally for 10-year terms, meaning that the line officer signing the renewals will likely never have to revisit the issue.

In December 2024, the BLM addressed this backwards management by released a "permanent" instruction memorandum (PIM) directing BLM offices to prioritize allotments with high value resources:

"Field Offices (FOs) must give the highest priority to the work necessary to meet applicable legal requirements (e.g., court orders, compliance with the Endangered Species Act and associated regulations, etc.). FOs must then use the criteria listed below to develop a prioritization schedule for fully processing[1] active grazing allotments with high-priority resources. Sage-grouse and Bighorn Sheep habitats are the two highest priority resources based on the ongoing rangewide efforts to conserve the Greater Sage-Grouse (GRSG) and the potential long-term nature and degree of potential impact of disease on bighorn sheep populations."

A couple of months ago, the current administration moved the PIM to "inactive" status. So we are back to business as usual, and now with even less capacity to complete NEPA due to staff reductions.

View attachment 384901
Death sentence for more wild sheep. As if acknowledgment of contagion is off limits to this administration.
 
Just proves that propaganda works.

Speaking of propaganda, The American Sheep Industry Association (ASI) is doing everything they can to take advantage of this administration's public lands deregulation efforts and sent the attached propaganda letter regarding bighorn sheep disease to the USFS Chief and BLM acting Director, as well as their elected members of Congress.
 

Attachments

  • ASI Concerns Public Lands Bighorn Policy.pdf
    462.9 KB · Views: 9

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