Improvement [Entrenchment] Act Gains Legs, Threatens Hundreds of Millions of Acres of YOUR Public Land
The public land ranching industry is up to it again. They’re looking to further obstruct the proper administration of grazing on federal public lands by eroding public participation and further tying down the Bureau of Land Management and Forest Service’s ability to enforce environmental laws and act in the public interest for clean water, wildlife, ecosystem integrity, for all of those things you care about and enjoy of public lands in the west. The bill: The “Grazing Improvement Act”.
There exists a mounting pressure in the Department of Interior and the Department of Agriculture. Constrained by the political pressure to keep status quo grazing levels (both numbers and duration) on public lands despite significant environmental impacts, the agencies administering the grazing program (the Bureau of Land Management and at the U.S. Forest Service) are having trouble complying with their legal mandates to review the impact grazing has to public values, keep the water clean, provide for wildlife and ecosystem values, and otherwise act in accord with protecting the environment as demanded by law. They can’t do it. They can’t allow public land grazing at existing levels and comply with the law.
Because the environmental conditions are disastrous, agencies need to push a lot of paperwork justification if they are to feebly rely on judicial deference when confronted in court about existing levels of environmental impact. A backlog of 4,200 grazing permits lacking NEPA review has built at Interior. The agencies administering the federal grazing program continue to rely on legally questionable Categorical Exclusions and passage of Congressional riders annually relieving them of their obligation to provide environmental review of renewal of expiring permits and leases, a process normally required of them every 10 years. However, categorical exclusions don’t work when livestock inflict significant environmental impact to protected resources (and they get called on it in court) and annual renewal of grazing riders in Washington D.C. is taxing – it eats up political capital each year.
There exists a problem.
The public lands ranching industry would have you, and lawmakers, believe that the problem is the bureaucratic backlog itself and the economic instability this backlog creates for continued levels of livestock grazing on federal public lands. They are partly right, those issues do exist and it’s is going to be increasingly difficult to justify continued levels of grazing on federal public lands.
However, no such bureacratic mess at BLM or Forest Service would exist and no economic instability does exist if those ranchers leasing the commercial use of our public lands were leaving them in a legally defensible and ecologically acceptable condition. They are not.
The real problem the BLM, Forest Service, and public lands grazing industry are forced to confront is the culminating environmental consequences of public lands ranching. No bureaucratic crisis would exist if species were not being driven to extinction, if fish and wildlife habitats were in satisfactory condition, if our sources of drinking water were not being polluted or if a myriad of other environmental values protected by law were not being significantly impaired by public lands ranching.
Having failed administratively with the Bush Administration’s Grazing Regulations, the public land livestock industry hopes to relieve the bureaucratic pressure that threatens an inevitable confrontation with their continued (ab)use of public lands by achieving many similar outcomes of the defunct regulations by statute instead. They hope to do so without ever addressing the environmental consequences. The Grazing
Improvement Act would extend the duration of public land grazing permits from 10 years to 20 years, it exempts NEPA review of grazing permits, and sets up an administrative adjudication process where-by if public land ranchers disagree with a decision the Forest Service or BLM make, the Forest Service or BLM’s decision is set aside and continued levels of grazing are automatically locked-down until administrative adjudication has been exhausted, a process that can take years.
Until recently, the “Grazing Improvement (sic) Act” (S. 1129) sat moribund in the Senate Committee on Energy and Natural Resources for many months before its sponsor, U.S. Senator John Barrasso (R-WY), insisted on a hearing for the bill. That hearing recently took place in the Public Lands and Forests Subcommittee, and with lightening speed it got a companion in the US House of Representatives (H.R. 4234) and a hearing scheduled for March 29, 2012 in the Subcommittee on National Parks, Forests, and Public Lands of the House Natural Resources Committee.
Whether you’re a public lands advocate, a wolf supporter, a bighorn sheep enthusiast, an angler or hunter, a Yellowstone buffalo activist, a recreationist or in any way interested in public lands – this bill affects you.
Permit and lease renewal of grazing permits may not seem like the sexiest issue, but this process is where the rubber hits the road on a myriad of habitat and wildlife conservation issues. It’s where the source of habitat and wildlife conflict – i.e. livestock grazing – is initially introduced onto public land and every ten years the permit/lease renewal process is one of a few opportunities the public has a voice to weigh in on management in favor of wolves, bighorns, fish, buffalo, pygmy rabbits, mountain springs and streams, etc. etc. etc. and where federal land managers are legally obliged to listen – and managers should listen – the conditions of public lands on-the-ground are disastrous across the west.
Passage of the Grazing
Improvement Act would foreclose the public’s opportunity to be heard and codify acceptance of the negative environmental impacts that characterize the condition of public lands across the west.
Statement of Western Watersheds Project on Grazing Entrenchment Act (H.R. 4234 & S. 1129)
Western Watersheds Project works to protect and restore western watersheds and wildlife through education, public policy initiatives and litigation with a primary focus on the negative impacts of livestock grazing on 250,000,000 acres of public lands. Western Watersheds Project includes a staff and active volunteer membership of scientists, former agency personnel, and citizens who have intimate first-hand knowledge and on-the-ground experience with the management and conditions of wildlife populations and the hundreds of millions of acres of public lands that are the subject of the legislation being considered at this time.
WWP’s active involvement in public lands management includes public oversight of Department of Interior and Department of Agriculture federal regulation and rule-making efforts, federal landscape-level management plans, federal site-specific grazing decisions, and all federal actions involving the administration of livestock grazing on federal public lands. Our day-to-day activities involve reviewing, documenting and often challenging agency implementation of federal laws. It is with this interest and experience that Western Watersheds Project urges the U.S. House Subcommittee on National Parks, Forests, and Public Lands and the U.S. Senate Subcommittee on Public Lands and Forests Committee on Energy and Natural Resources to oppose H.R. 4232 and S. 1129, respectively, in its entirety.
The Grazing Entrenchment Act Misses the Mark
Proponents of the Grazing Entrenchment Act and Western Watersheds Project share a common recognition that there exist significant problems in the administration of the federal grazing program. It is true that the federal grazing programs need improving. However, the main problem with the federal public lands grazing program is not the permit length, the National Environmental Policy Act requirements, or the administrative review process that The Grazing Entrenchment Act seeks to remedy. The problem is that federal agencies’ administration of public lands across the west has failed to meet very basic environmental standards as directed by Congress in the agencies’ respective organic acts1 and as established by other environmental statutes and direction. This failure to lawfully administer grazing on federal public lands is ubiquitous across the western landscape2. The current bill is designed less to improve conditions on-the-ground and more to entrench them in spite of a great majority of Americans’ clear interest in clean water, abundant wildlife, and healthy ecosystems.
Each substantive part of The Grazing Entrenchment Act would change federal public lands grazing policy to the detriment of land managers’ ability to properly manage, to the detriment of the public interest, and to the detriment of the condition of the landscape itself. For example:
The Grazing Entrenchment Act extends grazing permits and leases to last 20 years instead of the current 10-year terms.
- Grazing permits and leases would outlast the Resource Management Plans that guide them, making overarching changes harder to implement.
- Limits opportunities for public and agency oversight, since most allotments only get evaluated and monitored in advance of permit or lease renewals, and limits opportunities to identify and address adverse impacts.
- Fails to address the need for change in response to changing public values, environmental conditions, and legal obligations in a timely fashion.
- This would affect thousands of permits that have already been reissued for ten years under Congressional riders that have endured decades of environmental degradation given agency inattention. In some cases, a 20 year renewal would mean up to 40 years without environmental oversight.
Backlog in the permit renewal process exists because the on-the-ground environmental conditions of allotments are problematic, thus environmental review and scientifically justifiable response is properly demanded of the agency under the law. Arbitrarily deferring attention and responsive management for an additional decade would sweep those problems under the rug and violate the public trust responsibilities of the agencies.
The Grazing Entrenchment Act directs agencies to lock in Terms and Conditions of permit until the permit or lease is reissued
- Where a permit was extended for 20 years, this proposed change would mean that agencies would not be able to incorporate new information based on overarching guidance such as that in a land use plan or for emerging science for nearly two decades.
The Grazing Entrenchment Act Categorically Excludes permit and lease renewals from the requirement to prepare an environmental analysis if the decision continues the current grazing management of the allotment.
- The determination to continue the current management of the allotment should be made in the context of a range of alternatives and only after taking a hard look in a full environmental analysis. The change proposed under The Grazing Entrenchment subverts NEPA by requiring the land managers to determine at the outset what the outcome would be. Without a full assessment of resource conditions, a review of the environmental context, an updated compilation of current management and public resources, there is no basis for determining to continue current management.
- Categorically excluding permit renewals disenfranchises public lands users by limiting their ability to participate in the full NEPA process. Without environmental review, there is no opportunity for the agency to solicit and consider new information and evidence that could help in decision-making.
OR, If only minor modifications to the permit are required, a Categorical Exclusion will be applied when monitoring indicates conformance with Land Use Plan objectives and there are no extraordinary circumstances.
- Any modifications to a permit should be considered within the context of full NEPA. This subpart fails to identify who would be making the determinations about which modifications are necessary, fails to define “minor,” and leaves the application of the categorical exclusion to manager discretion, with no public involvement.
- Monitoring results should be documented, disclosed and compared with Land Use Plan objectives in a way that is transparent and defensible, i.e. through a full environmental analysis.
Taken together, subparts 1 and 2 of this section would essentially allow nearly all management to be done without any public participation, contrary to the provisions of NEPA, the Federal Lands Policy and Management Act (FLPMA) and National Forest Management Act (NFMA).
The House bill (H.R. 4234) permanently exempts crossing and trailing permits from environmental analysis.
- Environmental impacts to sensitive resources can occur even during short-duration grazing regimes. Disease transmission to native wildife, impacts to sensitive species, and seasonal considerations should be given full consideration in NEPA analysis.
The Grazing Entrenchment Act allows Secretary the sole discretion to set the timing for grazing permit renewals where an EA does need to be completed under (e)(1) and (2), and the analysis to be scheduled with consideration of the environmental significance of the allotment and the available funding.
- Paired with § 405(c), this would allow grazing permit renewals to be deferred indefinitely on lands where an environmental analysis is required, i.e. the lands where monitoring does not support conformance with Land Use Plan objectives, where more than minor modifications are necessary, and where management changes are necessary.
- This incentivizes underfunding the range program, because without funds, no full NEPA analysis could be required and no changes would have to be made. Too much is left to Secretarial discretion that remain legally mandated instead.
- Basing environmental analysis on funding considerations allows congressional budgets to dictate the conditions of our public lands and undermines other regulations requiring oversight at regular and frequent intervals.
Ultimately, this section emphasizes maintaining the status quo on most allotments and limits the application of NEPA to very few permit renewals. Without full oversight and public participation, the non-livestock uses of these federal lands are de-prioritized and the current conditions and management will persist indefinitely.
SEC. 4. APPLICABILITY OF ADMINISTRATIVE PROCEDURE ACT TO GRAZING APPEALS. (a) and (b) amend 16 USC 1612 and 43 USC 175 to establish permittee appeals in accordance with the APA.
- This section creates separate appeals processes for the permittee and the public, which is unfair since all Americans have equal stake in public lands management.
- Permittee appeals cause the decision to automatically be suspended pending resolution, creating a de facto automatic “stay” that could last years. (Unless the Secretary declares an “emergency regarding the deterioration of resources.”) This is the reverse of the burden on the public, which requires the demonstration of likely irreparable harm if the decision is to go forward. The burden of proof to stay a grazing decision should be the same, no matter who brings the appeal.
- Appeals processes can last years, and under the proposed legislation, permittee appeals would automatically forestall agency-approved changes while the appeals are resolved, rather than the current process wherein a petition for stay must be granted in consideration of the facts of the appeal. Even frivolous appeals could thwart management for years.
- Permittee appeals would also be provided an evidentiary hearing, which would make FS grazing decisions subject to external review rather than line officer adjudication. This differs from the current public appeals process and will be very different if the appeals regulations are modified to the “objection process” as described under the Healthy Forests Restoration Act (HFRA).
None of these legislative changes to agency regulations would address the real problems of the public lands’ grazing programs: the direct and indirect ecological impacts of this land use in the arid west and the mismanagement that has plagued the agency administration since the Taylor Grazing Act was enacted. Instead, The Grazing Entrenchment Act effectively directs the land management agencies to turn a blind eye to the environmental impacts on the ground, reducing and outright eliminating the frequency by which those publicly supported environmental standards are monitored, considered and enforced pursuant to law.
Grazing Entrenchment Act Ignores the Environmental Consequences of the Livestock Grazing Program
Public lands ranching is the most ubiquitous use of public lands in the country, occurring on over 250,000,000 acres of land, an area roughly the size of the states of California and Texas combined. Make no mistake, despite the unfounded claims of proponents of The Grazing Entrenchment Act, researchers have suggested livestock grazing is “the most severe and insidious of the impacts on the rangeland” and that grazing is the “most insidious and pervasive threat to biodiversity on rangelands.”3 Wildlife and species populations have declined as direct conflict with livestock and shared habitats sustain a myriad of ongoing impacts from public lands ranching. Direct impacts associated with livestock includes the widespread pollution of water,4 the removal of vegetation – i.e. direct competition with wildlife for food,5 the alteration of complex habitat structures and composition including the most significant contributor to desertification of the western landscape,6 the physical impairment of stream-bank (riparian) habitats7 that a majority of wildlife depend on for survival in the semi-arid and arid west, soil disturbances which allow for displacement of native vegetation with exotic weeds,8 the introduction and continued exposure of disease and a host of additional direct impacts.
A. Water Quality
Mismanagement of public lands ranching has resulted in the diminished quality and quantity of water originating from mountain springs and streams, many of which once ran clear and clean enough to drink from directly, a western American pastime. On several public land allotments in Wyoming, the Bighorn National Forest conducted water quality testing on streams running through permitted allotments and found levels of E coli so high that the water was unsafe to touch with exposed skin, let alone drink from as is the intent of state standards promulgated by Congress as established by the Clean Water Act. In 2010, the Journal of Water and Health published the results of an independent study that was conducted in the Sierra Nevada Mountains of California, a chief source of drinking water for over 40 million American citizens.9 Researchers found livestock grazing on public lands to be the primary source of fecal coliform and E. coli contamination of drinking water. In addition, researchers found that livestock may be depositing enough Giardia-transmitting protozoa to infect the entire city of Los Angeles each day. The Forest Service refuses to appropriately respond by reducing livestock impact to California’s drinking water supply. On a vast majority of waters originating on public lands grazed by livestock, agencies refuse to test, let alone adequately consider water quality impacts in their environmental reviews of permit.
In addition, livestock grazing infrastructure, commonly bought and paid for by the American tax-payer, has quite literally tamed the once wild West. Hundreds of thousands of miles of fencing on public lands have obstructed natural wildlife movement and migration, and water developments built to facilitate livestock use of public lands have dewatered springs, seeps, and streams which serve as critical habitats for a variety of wildlife across the west.
In administering public land ranching, agencies have subjected public lands to widespread habitat alteration projects. One example took place on public lands just outside of Yellowstone National Park, a renowned public landscape celebrated by a majority of Americans for its wildlife attraction and breathtaking beauty. On one grazed public landscape near the Antelope Basin/Elk Lake area of Madison Valley over 50 square miles of open, mountain sagebrush grassland habitat was subject to aggressive habitat manipulation, managers prescribed herbicide eradication of sagebrush and forbs, multiple prescribed burnings, and other impacts significantly diminishing wildlife habitat to provide more forage for livestock use of the public land. This type habitat manipulation to maintain and increase livestock use has occurred, and continues to occur, on millions of acres of western public lands that once teemed with wildlife and championed other recreational opportunities impaired by livestock that the Department of Interior recently found contribute an order of magnitude greater economic value to local economies than public lands ranching.10
C. Species and Habitat
As a direct consequence of agencies’ continued prioritization of livestock use on public lands and the widespread failure of management to make “significant progress” toward improving public lands habitat conditions on the ground on a significant number of permits throughout the west, species endangerment continues to escalate at an alarming rate. Livestock grazing is a contributing factor to more than 175 threatened and endangered species,11 twenty one percent of imperiled species considered for listing on the Endangered Species Act, an amount roughly equal to logging and mining combined.12 Agencies have been unable or unwilling to adequately respond by reducing the duration of livestock use or the number of livestock permitted in order to curtail impact.13 Political pressure ensures that livestock is always the unchanged factor in management decisions and managers spend reams of bureaucratic resources and time justifying status quo levels of use in light of the obvious impact on the ground. As habitat continues to diminish, species continue to decline and the administrative burden in response to clear Congressional intent to prevent species extinction, make significant progress toward habitat improvement, and protect environmental values continues to build.
Grazing Entrenchment Act Does Not and Cannot Solve the Problems of Public Lands Ranching
The livestock industry wants The Grazing Entrenchment Act to protect it from “instability,” and claims 20-year permits are critical for securing bank loans and leveraging assets. Grazing permits are a privilege, not a right, and they can be withdrawn at any time. This was the intent of the Taylor Grazing Act (43 U.S.C. § 315b), has been articulated in agency regulations (e.g. 36 C.F.R. 222.3(b)), and upheld by the Supreme Court as recently as 2000.14 The stability of a livestock operation comes from the operators’ conformance with the applicable laws and regulations; if a grazing operation is in compliance with management parameters, the permit will be renewed. Current grazing operations have priority to renew on the allotment, and in many cases, multiple generations of the same family have held onto the same allotment. We know of very, very few cases where grazing privileges have been revoked, and those instances involved long-term trespass or other legal violations. The industry has not been destabilized by ten-year permits and has not provided compelling evidence that a longer permit would do anything other than disenfranchise and diminish other public land users and the agencies’ opportunities to review their operations impact on the ground and conformance with the law.
The livestock industry also claims that The Grazing Entrenchment Act will prevent fragmentation of western landscapes by preserving continuous open space. This is flatly unfounded. The sale of private lands is independent of grazing lease renewal; private land owners sell for a variety of reasons, none of which are tied to grazing permit expiration dates.
Whereas pro-conservation litigation gets blamed for administrative difficulties, in reality, this litigation is brought in an attempt to improve the process. Conservation interests cannot win lawsuits unless the agency is found to be in violation of the law, which requires of conservationists that they demonstrate the lofty legal standard that agency has acted in an “arbitrary and capricious” manner in making their decisions. The Grazing Entrenchment Act seeks to undermine this pro-active participation by eliminating opportunities for non-industry interests to weigh in. It allows the fox to guard the hen house and prevents the farmer from ever counting the flock. It is for these reasons that the conservation community opposes The Grazing Entrenchment Act and, presumably, why the agencies themselves have serious concerns and oppose the bill15.
Because the Grazing Entrenchment Act does nothing more than promote administrative practices that would further degrade our public lands and deter public participation, the bill should be soundly rejected. It offers no remedy for the problems that do exist with the federal lands grazing programs, and instead guarantees that those problems will get worse. We strongly urge the House Subcommittee on National Parks, Forests, and Public Lands and the U.S. Senate Subcommittee on Public Lands and Forests Committee on Energy and Natural Resources to reject H.R. 4232 and S. 1129, respectively and acknowledge that the administrative problems with the federal public lands grazing program cannot be solved by entrenching special interests, removing public and administrative oversight, and the existing protection of federal laws.
- Federal Land Policy Management Act, National Forest Management Act, etc. [↩]
- GAO. 1993. Rangeland Management: BLM’s Range Improvement Project Data Base Is Incomplete and Inaccurate. RCED-93-92. General Accounting Office. Washington, DC. GAO; GAO. 1992. Rangeland Management: Interior’s Monitoring Has Fallen Short of Agency Requirements. RCED-92-51. General Accounting Office. Washington, DC. GAO; GAO. 1990. Public Rangelands: BLM Efforts to Prevent Unauthorized Livestock Grazing Need Strengthening. RCED-91-17. General Accounting Office. Washington, DC. GAO; GAO. 1988. Public Rangelands: some riparian areas restored but widespread improvement will be slow. RCED-88-105. General Accounting Office. Washington, DC; GAO. 1988. Public Rangelands: More Emphasis Needed on Declining and Overstocked Grazing Allotments. RCED-88-80. General Accounting Office. Washington, DC. [↩]
- Fleischner. 1994. Ecological Costs of Livestock Grazing in Western North America. Conservation Biology 629; Noss and Cooperrider. 1994. Saving Nature’s Legacy, Island Press. 221, 230, 258. See also generally Lauenroth et al., “Effects of Grazing on Ecosystems,” 69. [↩]
- Nearly all surface waters in the West are fouled with livestock wastes that produce harmful waterborne bacteria and protozoa such as Giardia. Suk, T., J. L. Riggs, B. C. Nelson. 1986. Water contamination with giardia in backcountry areas in Proc. of the National Wilderness Conference. Gen. Tech. Rep. INT-212. USDA-Forest Service, Intermountain Res. Stn. Ogden, UT: 237-239. Livestock grazing is the single largest contributor to non-point source pollution in New Mexico, accounting for approximately 15 percent of the water quality impairments statewide. J. Rankin. Plan to take better care of water quality is earning accolades; conservationists disagree. Albuquerque Journal (May 15, 2005). [↩]
- In one study, scientists found that domestic livestock grazing consumed 88.8 percent of the available forage (cattle and [domesticated] horses 82.3 percent, free-roaming horses 5.8 percent, sheep 0.7 percent), leaving 11.2 percent to wildlife species(mule deer 10.1 percent, pronghorn 0.9 percent, bighorn sheep 0.1 percent, elk 0.1 percent). Cited in R. R. Kindschy, C. Sundstrom, and J. D. Yoakum, 1982, Wildlife habitats in managed rangelands-the Great Basin of southeastern Oregon: pronghorns, Gen. Tech. Rep. PNW 145, USDA-Forest Service; USDI-BLM, Portland, OR: 6. [↩]
- “Improvident grazing…has been the most potent desertification force, in terms of total acreage [affecting 225 million acres or 351,562 square miles], within the United States.” Chaney, E., W. Elmore, W. S. Platts. 1993. Livestock grazing on western riparian areas. Northwest Resource Information Center. Eagle, ID: 5 (fourth printing; produced for the Environmental Protection Agency). Council on Environmental Quality. 1980. The global 2000 report to the president of the United States: entering the twenty-first century. Pergamon Press. New York, NY. [↩]
- Livestock grazing has damaged 80 percent of the streams and riparian ecosystems in the arid West. Belsky, A. J., A. Matzke, S. Uselman. 1999. Survey of livestock influences on stream and riparian ecosystems in the western United States. J. Soil & Water Conserv. 54(1): 419 (citations omitted). “Extensive field observations in the late 1980s suggest riparian areas throughout much of the West were in the worst condition in history.” Chaney, E., W. Elmore, W. S. Platts. 1993. Livestock grazing on western riparian areas. Northwest Resource Information Center. Eagle, ID: 5 (fourth printing; published by the Environmental Protection Agency). In 1988 the General Accounting Office concluded that “poorly managed livestock grazing is the major cause of degraded riparian habitat on federal rangelands.”GAO. 1988. Public Rangelands: some riparian areas restored but widespread improvement will be slow. RCED-88-105. General Accounting Office. Washington, DC: 11 [↩]
- “At the community scale, livestock may be the major factor causing weed invasions.” Livestock cause weed invasion by grazing and trampling native plants; clearing vegetation, destroying the soil crust and preparing weed seedbeds through hoof action; and transporting and dispersing seeds on their coats and through their digestive tracks. Belsky, A. J. and J. L. Gelbard. 2000. Livestock grazing and weed invasions in the arid west. Oregon Natural Desert Association. Bend, OR (citations omitted). [↩]
- Derlet, R.W., C.R. Goldman, and M.J. Connor. 2010. Reducing the impact of summer cattle grazing on water quality in the Sierra Nevada Mountains of California. Journal of Water and Health. 8(2): 326-333. [↩]
- DOI Report: The Department of Interior’s Economic Contributions – June 21, 2011 [↩]
- USDI-BLM, USDA-Forest Service. 1995. Rangeland Reform ’94 Final Environmental Impact Statement. USDI-BLM. Washington, DC: 26. See also B. Czech, P. R. Krausman, P.K. Devers. 2000. Economic associations among causes of species endangerment in the United States. BioSci. 50(7): 594 (table 1) (reporting that authors’ analysis of several studies suggests that 182 species are endangered by livestock grazing) and USDA-NRCS. 1997. America’s private land: a geography of hope. Program Aid 1548. USDA-Natural Resources Conservation Service: 154 (stating that grazing is a contributing factor in the decline of 26 percent or 161 species on the federal threatened and endangered list). [↩]
- Wilcove, D. S., D. Rothstein, J Dubow, A Phillips, E. Losos. 1998. Quantifying threats to imperiled species in the United States: assessing the relative importance of habitat destruction, alien species, pollution, over-exploitation and disease. BioScience 48(8): 610. [↩]
- Candidate Species List – U.S. Fish and Wildlife Service [↩]
- See Public Lands Council v. Babbitt, 529 U.S. 728, 741 (2000)e [↩]
- Statement of Mike Pool, Deputy Director Bureau of Land Management, U.S. Department of the Interior. Before the Senate Energy and Natural Resources Public Lands and Forests Subcommittee. March 22, 2012; Statement of Leslie A. C. Weldon, Deputy Chief National Forest System, U.S. Forest Service – United States Deparment of Agriculture. Before the Senate Energy and Natural Resources Public Lands and Forests Subcommittee. March 22, 2012 [↩]
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Idaho Hunting 138 Idaho Trapping 13 Idaho Illegal 7 Idaho Control-IDFG 7 Idaho Control-WS 73 Idaho IDFG-authorized 3 Idaho Legal take 3 Idaho Unknown 5 Idaho Vehicle 3 Montana Hunting 97 Montana "other" 93 Wyoming Hunting 52 Wyoming "other" 25 Wisconsin 219 Minnesota 130 Michigan 20 TOTAL 888
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