East Paradise Grazing Plan Seeks to Expand Livestock Production


The Six Mile North drainage is currently vacant, but the FS proposes grazing the allotment. It was burned by the Emigrant Fire but grasslands are robust. Photo by George Wuerthner

Below are my comments concerning the expansion of grazing of the East Paradise Grazing Allotments. This is some of the most important wildlife habitat north of Yellowstone NP. Readers are encouraged to write the District Ranger supporting ALT 1 the No Livestock Grazing option. Please put East Paradise Range Allotment Management Plan in the subject line and send comments to the FS at comments-northern-gallatin@usda.gov

Alex Sienkiewicz

District Ranger, Yellowstone Ranger District,

5242 Highway 89 South, Livingston, Montana, 59047,

SUBJECT: East Paradise Range Allotment Management Plan Comments

Dear Mr. Sienkiewicz:

I apologize up front for the disjointed comments. Trying to figure out how best to present this information has been problematic. Hopefully, you can work your way through my comments in a reasonable fashion.

I first visited Paradise Valley in 1971 and periodically lived in Park County beginning as early as 1972 and intermittently since that time. I consider the Yellowstone Ranger District my psychological home since I purchased several lots in Gardiner in 1973 and later a home in Livingston in 1986. My former wife worked as a wilderness ranger and later biologist on the Yellowstone Ranger District of the CGNF, giving me even more opportunities to explore the area.

At one time, or another, I have visited all these allotments (except Elbow), and in some cases, a dozen or more times in a single year.  I have firsthand knowledge of the terrain in every one of the allotments.

Furthermore, I have an academic background in range management, wildlife biology, and botany. I studied range management at the U of Montana. Subsequently, I went to grad school in range science at Montana State University, so I am familiar with many of the basic principles of livestock management.

Plus, I subsequently worked for the BLM in Idaho, doing range appraisals, along with other biological assessments.

Please permit me to make a negative comment about this analysis. In my view, this analysis is heavily skewed towards trying to justify expanding livestock production on these allotments.

Indeed, while I was in grad school in range science, all the other students were pro livestock advocates, as were the professors.  Whenever possible, they presented reasons to justify livestock production by maximizing the presumed “benefits” and minimizing/ignoring the “negatives.” It is important to note that without cows, range professors and range programs would not have a reason to exist. No cows. No job. No money. This incentive distorts much of the information and values of most (but not all) range cons.


The following are my comments concerning the six grazing allotments discussed in the East Paradise Range Allotment Management Plan. The Yellowstone Ranger District (district) of the Custer Gallatin National Forest proposes to authorize commercial livestock grazing under an adaptive management framework for the East Paradise range’s six grazing allotments. The six allotments are Suce Creek, Mill Creek, Pine Creek, Elbow, Sixmile North, and Sixmile South.

I believe the best alternative from a public interest, wildlife, ecosystem integrity, and wildlands restoration perspective is Alternative 1, the No Action/No Grazing option.

I agree with the concluding remarks in the Range Allotment Management Plan that says: “For most resource areas, the removal of livestock grazing (alternative 1) would provide the most benefit. Livestock would not be present to impede recovery of riparian/stream conditions or compete with other species for forage and space. Removal of livestock would also eliminate any threats to wildlife resulting from depredation or human encounters.”

Currently, vacant allotments Mill Creek, Suce Creek, and Six Mile South should be permanently retired and closed, as should the remaining open allotments.

Mill Creek allotment is currently vacant, but the FS proposes restocking with cattle. Photo by George Wuerthner

While livestock grazing is permitted on Forest Service, it is not required. And in this area, other natural resource values like wildlife habitat, ecosystem function, and wilderness recreation are all far more valuable than the small amount of forage that might be made available to private ranchers for their profit. Whenever there is a conflict between the public’s interest and private businesses, the default should always be towards the public’s interest.

However, let me articulate further why Alternative 1 is the best option from a public policy perspective and provide some alternative views on the Range Management Plan document’s statements.

In my view, in far too many instances, the benefit of the doubt regarding when and how to manage any of these allotments is skewed towards benefiting the ranchers, not the public.  An example of the skewed perspective is the continuous reference to livestock’s absence as “no grazing.”

These allotments are “grazed” by wildlife, insects, and other native species, from grasshoppers to elk, even to bears who consume a lot of grass in early spring. The absence of livestock does not mean the absence of herbivory. The lack of livestock is an important distinction. There is an abundance of native species that utilize grass and shrubs.


The Forest Service should manage these lands for the public benefit, not the profit of private individuals (ranchers).

To quote Jim Bailey, a retired wildlife biology professor: public trust resources include air, water, public lands, and public wildlife. They are owned by all the people and managed to benefit the people, primarily by elected “trustees” in legislatures and government administrations. Under the law and historically accepted policy, public trust ownership of wildlife is the foundation of North American wildlife management. However, private interests have gained considerable control over legislatures and administrations to steer the management of public trust resources toward private benefits, with resource deterioration.”

Bailey goes on to say: “Public-trust resources are a result of, and the basis for, democracy. The gradual erosion of public control of trust resources, with a decline in the qualities and availabilities of these resources for all the people, diminishes the value and expression of democracy.”

Throughout this document, there is an attempt to justify the continued livestock grazing of public lands and even its expansion. This emphasis on promoting livestock on public lands is undoubtedly not in the public interest. There is no reason to have livestock on any of these allotments, especially given the high wildlife and wildland values of these lands.

Furthermore, as acknowledged by the range con, the only way you can graze livestock without seriously impacting and harming the public’s property requires extensive new “range developments” such as fencing, water troughs, pipelines, and other infrastructure—all of which have their share of impacts not acknowledged in this document.

But the question is, why should the taxpayer fund the infrastructures to protect its property from private businesses? Any rancher living in Paradise Valley is a millionaire- simply because the land is so valuable. Why should the public have to subsidize their business operations—significantly when the use of OUR property is damaged in the process.

That is the ultimate question that needs to be answered. If you can’t justify it, then the only reasonable alternative to implement is Alt 1 No Action and No (Livestock) Grazing.


In the United States, grazing has contributed to the demise of 22 percent of federal threatened and endangered species – nearly equal to logging and mining combined (USDI-BLM and USDA-Forest Service 1995, Czech et al. 2000, USDA-NRCS 1997). In this discussion, grazing was separate from other impacts associated with livestock production—like dewatering rivers, vegetation community changes (spread of weeds like cheatgrass), and the destruction of wildlife like prairie dogs and predators wolves, and other impacts that are a direct result of livestock production. If they were included, the percentage of wildlife negatively impacted by livestock production would be far greater.

Flather et al. (1994)reviewed the geographic distribution of endangered species, and not surprisingly, many western states had high levels of endangered animals.

A good overview of livestock production ecological impacts is Fleischner’s (1994) the Ecological Costs of Livestock Grazing in Western North America. While not all the points in Fleischner’s review apply to the East Paradise Allotments, but it is excellent as a generalized guide to the kinds of questions one must ask about any proposed livestock production. Freilich et al., 2003 identify six ways livestock grazing impacts ecosystems that the authors believe cannot be fully mitigated by livestock management.


On page 12, Alt. 3 proposes changing the turn out season for most of the allotments from July to June. This earlier turn out would pose conflicts for elk calving and other wildlife use of the area (ground-nesting birds, breeding amphibians, etc.) from social displacement (in the case of elk) to trampling of amphibians.

In particular, grass and other green forage are an essential food in early spring for bears, so putting cattle out on these allotments when bears are most likely to be present sets up a natural conflict. (Horejsi 1992)

Late-season grazing also has impacted and identified by Kauffman et al. (1993), with 4 plant communities out of 10 sampled displayed some significant species composition and productivity differences. Two meadow types and the Douglas hawthome (Crataegus douglasii) community type had substantial differences in standing phytomass. These also were utilized more heavily than any other communities sampled. On gravel bars, succession appeared to be retarded by livestock grazing.

In many cases, soils will be wetter and more susceptible to compaction both early in the year and alter in the fall when soil moisture increases (Kauffman et al. 1983).


Also, on page 12, utilization rates are discussed. The unitization rates are simply based on the presumed ability of grasses to recover from grazing by livestock. Because range cons design these, they are biased towards livestock.

Numerous studies show that the remaining vegetation height that meets utilization rates often does not provide sufficient cover for wildlife. For example, it is well established that many grouse species require 10 inches or more of residential grass for hiding cover. In many instances, the utilization rates applied by range cons are insufficient for hiding cover (Doherty et al., 2014).

While the above study refers to sage grouse, the basic principle that hiding cover is critical to wildlife applies to more than grouse. Ground nesting birds, amphibians, small mammals, and other wildlife all benefit from taller residual grass. In other words, utilization standards, which may be sufficient for reducing the negative impacts of livestock grazing on plant communities, may not meet other wildlife’s needs. (Fogarty et al., 2017).

An additional problem is that some native grasses, like bluebunch wheatgrass, can require up to ten years to recover from a single grazing event.  Thus, in heavily used pastures, even those meeting utilization standards, may still be exploiting the native grasses beyond their ability to recover from a grazing event (Anderson 1991).


The basic idea behind adaptive management is to provide “flexibility” for ranchers and the F.S. in livestock management. The problem is that it is an open-ended process and does not have definitive boundaries. This management discretion could easily be abused. For instance, the document states: “Adaptive management also allows managers to respond to positive outcomes. For example, should conditions in the Sixmile North allotment meet DFC and monitoring demonstrate a continuing positive trend, management could allow additional livestock numbers, a different kind of livestock, or a longer season. The established AUMs likely would not change absent an increase in total acres available to forage in an allotment.”

The definition of what is a “positive trend” is missing. I’ve seen examples where some range people suggest an allotment is “improving” because it is 1-2% better, easily in the range of statistical error, using that as an excuse to suggest the overall trend is improving. Then this statistical trend is used as a rationale for more livestock or a longer season of use.

Any proposal for adaptive management must have explicit numbers about what is being monitored and measurements that can be duplicated and verified by outside observers. The usual “ocular method” of determining range condition is not scientific or duplicatable.

At the very least, the F.S. must provide specific numbers about conditions like amount of bank disturbance, forage height, plant species abundance, turn on and turn off dates under what circumstances, and range and riparian condition trends, and so forth. Without such measurable standards, anyone can assert the conditions are improving and thus allot more cattle.

Furthermore, the document suggests that the monitoring program will occur every five years. A lot of damage can happen in five years. Monitoring should be done annually if livestock grazing is to continue. Also, the F.S. should ensure, if this alternative is chosen, that there is sufficient funding to do monitoring with some fallback if monitoring cannot be accomplished, like closing the allotment until monitoring can be affected.

Often there is a lot of happy talk about how we will “monitor” the condition of the range, but there is no monitoring that occurs. For instance, a GAO report on monitoring found that many allotments were never monitored at all. (GAO, 1991). To quote from the report: “of the 9,217 grazing allotments in the Service’s 6 western regions, range managers identified 2,183 allotments as in declining condition or overstocked; (2) the Service made little progress in conducting the follow-up monitoring necessary to identify improper grazing practices and devise corrective action.” Although the GAO report is several decades old, it is generally acknowledged that federal agencies do even less monitoring today.

So how can the public be assured that monitoring—even on the five-year level—will occur?


On page 17, the F.S. proposes, “In riparian areas, stubble height is an annual use indicator that may provide a measure of the herbaceous vegetation remaining after grazing. It is applicable in low gradient alluvial channels and could require that end of season stubble height be 10 centimeters to 15 centimeters (4 to 6 inches) along the green line.”  Again, the stubble height standard was created without consideration of other resource values.

While having some minimum amount of vegetation is desirable, again, this standard is inadequate for wildlife. For instance, 4 inches would barely hide the body of a frog. It certainly would not provide hiding cover for a bird or small mammal.  To give just one example of the standard stubble height is inadequate for other wildlife, the great gray owl is a species dependent on meadows with at least 12 inches of residual stubble height AFTER grazing, Great gray owls are considered a species of state concerns and declining state-wide. http://fieldguide.mt.gov/speciesDetail.aspx?elcode=ABNSB12040

For instance, one overview notes: “Meadow breeding habitat is key to this species’ survival. Owl researchers found a strong correlation between meadow vegetation height, the absence of heavy grazing, and great gray owl reproductive success. Researchers hypothesize this trend is linked to voles’ presence, the owl’s primary prey species, in meadows with tall vegetation. The 2001 SNFPA protected important owl breeding sites by requiring 12″ of vegetation in meadows occupied by breeding Great Gray.” https://www.sierraforestlegacy.org/FC_SierraNevadaWildlifeRisk/GreatGrayOwl.php

The research also suggests that grazing meadows earlier than late August can negatively impact great gray owls. https://www.birdpop.org/docs/pubs/IBPConservationStrategyVersion1.0.pdf

I give the example of the great gray owl as one of many harmed species if stubble height of 4 inches is the standard.

Cattle damage to the riparian area on The North Fork of Big Lost River, Challis NF, Idaho

Furthermore, in many, many instances, stubble height is often far below this standard. Here’s a photo of an allotment on the Challis NF taken this past October, which also has the same end of season standard 4-6 inch stubble height. Looks like a golf course to me.

Anyone who has worked for federal agencies can attest that stubble height in actively grazed allotments is seldom met.

Furthermore, there is nothing in this document that specifies what happens if the stubble height standards are exceeded? Will the permittee be fined? Will the allotment be closed? Without consequences, what you get is at best “I’m sorry” from the permittee and the public landowners—U.S. citizens suffer the damage to their property.

If Alt. 1, the No Livestock Grazing Option, were implemented, we would not have to worry about riparian damage from cattle.


According to Table 8, many of the streams on these allotments will only be monitored every five years or as “needed.” Again, this is very infrequent and not adequate to protect the stream function. A lot of bank degradation and channel modification could occur during a five-year interval.

While riparian ecosystems occur on less than 2% of the West’s total land area, they provide habitat for about one-third of the plant species. In the arid Southwest and similar arid regions, about 60% of all vertebrate species and 70% of all threatened and endangered species are riparian obligates (Poff et al., 2012).

According to Kauffman (2002), as much as 81 percent of the forage in an allotment can come from 2 percent of the area occupied by a riparian zone.

Gniadek (1987), in a study of cattle used in Southwestern Montana, found the location of water sources was a significant determinant in cattle distribution, with three-fourths of cattle observations within 200 m of water.

This study suggests, as has been evident throughout the West, that most cattle use is focused on areas near water—the same places as noted above by Poff that are of most importance to nearly all wildlife.

Besides, intact riparian areas reduce flooding, filter out sediment, pollution (like cow manure), and protect aquatic ecosystems (Kauffman, B., and W C. Kruger. 1984).

Suce Creek proposed addition to AB Wilderness is currently a vacant allotment which the FS proposes to open to livestock grazing. Photo by George Wuerthner

Besides the obvious connection between fish, amphibians, and other water-dependent species, the majority of bird species in the western U.S. are associated with riparian zones as well (Kauffman 2002).

Kauffman et al. (2004) documented huge differences in total soil biomass between grazed riparian areas and areas where cattle were excluded. In a study along the Middle Fork of the John Day River in Oregon, Kauffman and his colleagues found that ungrazed dry meadows total belowground biomass (TBGB consisting of roots and rhizomes) was ;50% greater in exclosures (1105 and 1652 g/m2 in the grazed and exclosed sites. In exclosed wet meadows, the TBGB was 62% greater than in the grazed sites (1761 and 2857 g/m2, respectively).

Soil bulk density was significantly lower, and soil pore space was higher in exclosed sites of both meadow types. The mean infiltration rate in exclosed dry meadows was ;13-fold greater than in grazed dry meadows (142 vs. 11 cm/h), and in wet meadows the mean infiltration rate in exclosures was 233% greater than in grazed sites (24 vs. 80 cm/h). In exclosed wet meadows, the rate of net potential nitrification was 149-fold greater (0.747 vs. 0.005 mg NO3-N·[g soil]21·d21), and the rate of net potential mineralization was 32-fold greater (0.886 vs. 0.027 mg N·[g soil]21  ·d21, respectively) when compared to grazed sites (Kauffman et al. 2004)

The health of riparian areas is critical to many wildlife species. As Kauffman (2002) has opined, “the removal or reduction of livestock from vital riparian and wetland habitats throughout the West needs to be given serious consideration by all those concerned with ecosystem health.”

The document states on page 18 that if monitoring demonstrates the plan’s riparian goals are not being met, the F.S. can:

  • Construct permanent fencing to control livestock movement, protect seeps/springs, exclude livestock from riparian areas, or address other concerns with livestock movement and patterns as identified by monitoring
  • Construct additional water developments if monitoring indicates the need for better distribution of cattle

The solution for livestock damage is to invest more public funds into “range developments,” which is typical of range managers’ response to livestock damage—spend more taxpayer money to allow the continued use of public lands when any rational person would simply close the allotment.

Plus, all the above remedies have their externalities that are not mentioned in the document. For instance, constructing fences can hinder the movement of wildlife (Jakesa, A. et al., 2018), and often fences are not maintained. Livestock can quickly get into fenced areas.

Water developments take water from natural sources like springs and pipe it to a trough. These developments remove the available water for native wildlife from mollusks like snails (Freist 2002) to amphibians such as frogs (Engle 2002).  No mention of this potential damage to native wildlife is in the document.

In the document, the F.S. admits, “the condition of some seep/spring and wetland areas within the Sixmile North allotment have been impacted by livestock and wildlife use. However, the fact that the allotments have been grazed for the last 60 to 90 years suggests that current wetland conditions, though impacted by grazing in some locations, represent a relatively stable state.”

“Stable” does not mean good. Stable could mean the conditions aren’t getting any better due to the continuous degradation from livestock. Furthermore, the reversal of things like soil compaction, riparian hydrological function (as opposed to vegetation recovery) often requires decades without livestock use.

Greater attention to their condition should be given if livestock production is permitted. Of course, if Alt. 1 the no livestock grazing option were implemented, this would be unnecessary.


On page 20, the document mentions spring development. While fencing springs are a good way to protect the water source area, livestock use could still harm wildlife. For instance, mollusks (snails) migrate to and from springs for breeding. So if the area around a spring is trampled and grazed (so there is less stubble height), it could harm native snails. Snails are important decomposers in the ecosystem. They are particularly common in limestone areas, so they could be expected in the Suce Creek and Mill Creek allotments, though they are also found in other regions.


Freist (2002) believes that livestock grazing is the biggest threat to native snails.  As he says: “Livestock production is the primary source of decline for many mollusks species. Livestock trample habitat, and smail colonies, compact soils, remove vegetation, alter plant communities, and reduce water quality. Spring development, water diversion, and groundwater pumping associated with livestock production seriously threaten many species” (Freist 2002).

At one time, snails were super abundant. In his journal of travels from Salt Lake City to Yellowstone, Ferdinand Hayden (for whom Hayden Valley is named) repeatedly commented on the abundance of snails he encountered along this route (Hayden 1873).

The East Paradise document asserts that “other sensitive species occurring in the Yellowstone River Watershed include the Northern Leopard Frog and Western (boreal) toad. Neither of these species has ever been documented in any of the sub-watersheds within the project area (Atkinson and Peterson 2000, Montana Natural Heritage Program 2014)”

However, the presence of the western boreal toad is contradicted by local knowledge. In the East Paradise Area, according to MDFWP biologist Carol Endicott, there are at least three sensitive amphibians in the area, including Columbia spotted frog western boreal toad, and Pacific Chorus Frog (personal comm. Carol Endicott MDFWP). All are vulnerable to impacts from range development.

There is no significant discussion of the impact that proposed water developments and water diversions may have on mollusks, amphibians, and other water-dependent species in the document.

Engle (2002) finds that spring developments, water diversion, water pollution (from manure), and trampling of wetlands are among the factors causing amphibian species decline in many areas.

Bull (2005) notes that snails are a major food source for Columbia Spotted frogs, so spotted frogs’ well-being is connected to the well-being of mollusks. And the well-being of mollusks is connected to the well-being of springs, seeps, and other wet areas—all of which are impacted by livestock grazing or things like spring developments.

In Bull’s review (2005), livestock production benefited frogs by creating stock ponds that serve as habitat. However, it must be tempered because such water sites only help because livestock often has destroyed the natural habitat.  Claiming that such livestock developments benefit amphibians is somewhat analogous to saying that birdhouses benefit cavity-nesting birds after logging has removed the dead snags that would otherwise provide birds with cavities.

Overall, the impacts of livestock grazing are negative. Bull summarizes her findings on livestock habitat impacts on amphibians: “Reaser (2000) believed the presence of cattle was one of the most important human-caused factors that negatively affected the distribution of Columbia spotted frogs in central Nevada. Fecal contamination may cause eutrophication of water and an increase in planorbid snail numbers, number of nematode parasites, and the rate of parasite infection that causes limb deformities in amphibians (Johnson et al. 1999). Grazing may negatively affect movements of recently metamorphosed frogs by removing vegetation and compacting the soil, which could decrease hiding cover and increase their rate of desiccation when traveling (Engle 2001).”

The Columbia spotted frog is considered vulnerable to extinction just south of Paradise Valley in Wyoming, mainly due to livestock production, combined with climate change that may be drying out habitat. While the boreal toad has also suffered a significant decline in Montana (Maxell & Hokit 1999), the state has listed the boreal toad as a “species of concern.”

Though the focus for amphibians is on wetlands and springs, recent research demonstrates that both the Columbia spotted frog travels a significant distance from springs in terrestrial landscapes. Bored toads are even more terrestrial though they breed in aquatic habitats. So, loss of vegetation from grazing (4-inch stubble height is not adequate), trampling of soils, and vegetation cover. Experts recommend 75% residual vegetation, though 100% retention is considered the best alternative.

Another impact from livestock is soil compaction, making it difficult for toads to burrow to overwinter, and trampling can crush rodent holes, which are also used for refuge and overwintering. http://fwp.mt.gov/mtoutdoors/HTML/articles/portraits/westerntoad.htm   Plus, loss of vegetation which shields toads and frogs from desiccation can also harm amphibians  (Doug Keinath and Matt McGee 2005)

Nutrient enrichment from concentrated livestock and their manure can increase parasites that harm amphibians (Debra A. Patla and Doug Keinath 2005)


While livestock impacts on riparian vegetation, bank stability, and stream function are all briefly acknowledged in the document, there was no discussion of water quality issues resulting from manure and urine. As previously mentioned, nutrient enrichment of water can increase the parasites that may infect mollusks.

Livestock is one of the most significant factors in non-point pollution around the West (Carter, 2002). Livestock has the potential of polluting streams with E-coli bacteria but also other diseases harmful to humans.

For example, Myers et al. looked at 14 streams in the Sierra Nevada before and after livestock were placed on allotments. They found 194 water quality violations of either state or federal regulatory standards for recreational contact, all of which occurred once cattle were on the forest.

However, the presence of E coli is not the only pollutant commonly associated with livestock. A report by the Washington State Extension Service Water Quality Risks for Grazing Areas notes: “scientists and regulators have historically used fecal coliforms (and, more recently, E. coli) as an indicator for the possible presence of other pathogenic (disease-causing) microorganisms, such as Cryptosporidium, Giardia, or Salmonella, for example.”

There was no discussion of this impact upon the public’s right to have clean water flowing from its lands. Not to mention, one of the joys of being in natural areas is the ability to drink directly from a stream. This pollution is a “cost” to the public that was not analyzed in this document.

OVERVIEW OF ALT 1 No Action and No (Livestock) Grazing.

On page 21, there is an evaluation of eliminating livestock, and in general, the review is accurate. Still, there is a bias evident throughout where the Range Con always comes up with a reason why removing livestock would have some negative impact.

For instance, while acknowledging that the removal of livestock grazing would likely improve vegetation, we are warned that livestock removal might not bring about any improvements. And god forbid, we might even get too much biomass.

To quote from the document: “Vegetative composition would not necessarily improve in some areas due to competition from existing non-native species like timothy and Kentucky bluegrass. These plants are so well-adapted and competitive that no amount of release from grazing will allow native plants to dominate their former ranges. In the absence of grazing, timothy can produce so much biomass that it can self-shade and create extensive tiller mats which prevent native grass colonization (Esser 1993).”

This is an example of looking for a problem to fix where no problem exists.

Not only is this an attempt to find any reason to question livestock removal, but it also simply isn’t a problem. Timothy is abundant in the Lamar Valley, and many other places in the A.B. Wilderness, and I haven’t noticed the ecosystem collapsing because of too much biomass. Again, one forgets that we have plenty of native herbivores, from grasshoppers to elk to remove biomass, and cattle are unnecessary.

In the next paragraph, the range con worries about too much late seral vegetation—i.e., trending towards ecological excellence.

To quote from the document: “The overall long-term trend of vegetation in the project area would likely be toward late seral plant communities. This would affect and may be a problem for plant species dependent upon early seral habitats. In many areas, removal of domestic livestock from rangelands may result in a decrease in species diversity in the plant community where those plant communities depend on disturbance regimes like grazing.”

Again, the range con equates to the removal of livestock with no grazing. It’s like they can’t imagine that anything else is around to graze on vegetation. Indeed, there are many insects, fungi, nematodes, voles, grasshoppers, rabbits, ground squirrels, deer, bears, elk, and potentially even bison.

The absence of livestock does not mean no grazing.

The next paragraph is similar. While acknowledging that removal of livestock from the Suce Creek allotment has led to increased vegetation vigor. The range con tries to downplay this improvement by saying there are limits to progress due to exotic plant species.

Then in the next paragraph, the same kind of critique is again used.

The range con admits that ”the absence of livestock grazing is not likely to result in a noticeable difference in vegetation composition or canopy cover.”

Then goes on to say: “Study results (Holland et al. 2005) suggested that while livestock removal may be effective in initiating rapid recovery of deteriorated montane riparian ecosystems, it may not be necessary for recovery. The long-term exclusion of livestock from riparian areas could lead to a closed canopy, reduced willow vegetative stem recruitment, and reduced species diversity.”

This is contrary to nearly all the available literature that finds that livestock removal is the quickest and cheapest way to restore riparian function (Belsky 1990).

Numerous studies have documented the remarkable changes due to livestock removal (Kauffman, B., and W C. Kruger. 1984.)

For instance, Batchelor et al. 2015 did an inventory of Hart Mountain NWR where livestock had been removed for 23 years. They found: “that channel widths and eroding banks decreased in 64 and 73 % of sites, respectively. We found a 90 % decrease in the amount of bare soil (P\0.001) and a 63 % decrease in exposed channel (P< 0.001) as well as a significant increase in the cover of grasses/sedges/forbs (15 % increase, P = 0.037), rushes (389 % increase, P = 0.014), and willow (388 % increase, P< 0.001)”

There are wonderful before and after photos, and they are remarkable. Worth checking out.


The rest of the review of ALT 1 is pretty accurate and honest, basically listing all the benefits of livestock removal.


The bias towards justification of livestock grazing is evident throughout this portion of the document. For instance, on page 24, the range con notes that “Conifers and timber regeneration crowds out open meadows and understory vegetation in the allotments, reducing the production of forage.”

Reduction of forage is only a problem for the permittees.

The temporal scale is essential. Conifer expansion is an entirely natural consequence of the typical fire regime of the area. Wildfire is the main factor that precludes conifer invasion, but wildfires in this region are often decades to hundreds of years apart. During the interlude between fires, it is quite natural for conifers to expand into meadows until the next fire resets the stage by killing conifers.

Another example is on page 25, where the Range Con says: “Reintroduction of grazing into the three vacant allotments may help plant composition in some areas. There likely would be loss of plant vigor and litter accumulation. The district has observed in the vacant Suce Creek allotment that plant communities are trending toward late seral stages. Reintroduction of grazing into the vacant allotments likely would reduce the stagnant vegetation growth.”

The idea that vegetation is “stagnant” is similar to the scam that the timber beasts use about “decadent” and “overmature” timber when trying to justify more logging of old-growth forests. This perception is again indicative of a lack of ecological understanding. As plant communities approach a late seral state, they can no longer change in an upward trend. It is similar to filling a glass with water; you can’t add more water to the glass once you reach the vessel’s top. Late seral states are like a full glass of water.

In the very next paragraph, the Range Con says: “Because of the detrimental effects of the fire and run-off events to riparian areas in Sixmile South, enclosures would keep livestock out of degraded stream reaches on Sixmile, North Fork Sixmile, and Big Pine creeks to ensure post-flood recovery of riparian vegetation.”

Again, the solution to grazing impacts that would otherwise result is to spend taxpayer money to build exclosures to keep the cows out of the riparian areas. If there were no cows, we would not need exclosures.

Why is it OK to spend public money to facilitate resource exploitation (and unavoidable damage) by private businesses to public property? This question of public vs. private benefits is a fundamental question that the document fails to answer.

Alternative 3 suggests that weeds are a problem on the Mill Creek allotment and no doubt to a degree elsewhere. While it is commendable that Mill Creek will not be grazed until weeds are reduced, nowhere in the document is there any acknowledgment that domestic livestock is among the major factors in the spread of weeds ( Belsky, A.J. and J. L. Gelbard. 2000).

Livestock spread weeds in their manure, on their hide, and by creating the conditions favorable for the spread of weeds, including trampling of soil crusts ( Root, Heather, et al., 2019). These conditions include disturbance of soil crusts and preferential selection for desirable grasses, which results in a competitive disadvantage for native plant species (Condon Lea and David Pyke. 2018)


The idea that grazing does little harm to plants is more wishful thinking than reality. Livestock can significantly influence vegetation (Anderson, J.E., and R. S. Inouye, 2001).

By cropping before seeds are set, grazing can reduce the recruitment of preferred forage. Cropping is always damaging to vegetation since the plant requires leaves to photosynthesize. When livestock consumes the leaves, the plant says May Day and translocate carbohydrates from roots to produce new leaf material (Belsky 1993).  If there is a short period of recovery, the plant can die. In some grasses like bluebunch wheatgrass, full recovery may take a decade (Anderson 1991).

Of course, since the plant is now producing more leaves, the above-ground biomass’s overall annual production is increased. Livestock proponents suggest that this indicates that livestock grazing has a positive influence on vegetation. However, this increase comes at the expense of root development, and when the plant is stressed by drought or competition with other plants for nutrients, the cropped plant is at a disadvantage and can die (Belsky 1993).

Using above ground biomass production as an indicator of livestock’s positive influence is like suggesting that coyote’s “benefit” from trapping and shooting because it results in more pup production.

Native herbivores generally do less harm to plants because they are typically less concentrated than livestock, especially in the summer months when they tend to move to a higher elevation as they follow the green-up. Even when they are more focused, as in the winter month, much of the grazing on plants occurs when plants are dormant.

Cropping is not the only impact on vegetation. Livestock can trample and break vegetation. Trampling can increase bare dirt and weed invasion (Amiri If, Ali Ariapour, and S. Fadai 2008).

Heavy “hoof action,” as advocated by Allan Savory and others, can also compact soils, reducing water infiltration, causing desertification (Warren et al. 1986).


Like other parts of the document, the range con always attempts to put a positive spin on anything to do with livestock. While admitting on page 42 that there is forage competition between elk and livestock,  this impact is minimized: “various researchers defining elk-cattle interactions as some form of competition but that the conflict can be reduced through management. Generally, there can be high dietary overlap during the summer between livestock and elk. The overlap is not often perceived as a problem where range conditions were good, or intensity of cattle use was light.”

So once again, the range con discounts the impacts of livestock or suggests that it can all be fixed by some kind of management. Plus, she ignores the forage loss that occurs on summer range that would provide elk and other wildlife food in the ensuing non-summer months; however, if much of the forage is gone (and with 4 inches of stubble—most of it is gone—then this is a cost to native herbivores—which again is more than elk or deer.

She goes on to say: “Spatial competition may occur if both livestock and elk utilize areas during the same time period or if livestock displaces elk from preferred to more marginal grazing areas. Elk may tend to avoid livestock but are better able to adapt to terrain that is less suitable for livestock. Elk may move to alternative habitats for security or thermoregulation needs even in the absence of livestock. Spatial overlap may also produce positive effects of increased forage palatability of plants desired by elk due to the removal of litter by livestock.”

She suggests “there is no evidence of There is no indication that spatial competition is an issue on the East Paradise allotments.”

Again, this is spin—Of course, there is no evidence of spatial competition because elk typically avoid places with active grazing. And suggesting that because elk can use steeper terrain than livestock, what’s the big deal. It’s like saying, “let them eat cake.” Spatial displacement may still reduce the competitive fitness of elk.

Then she goes on to conclude: “Overall, elk and mule deer would benefit from practices that improve available forage on the allotments. The proposed alternatives would maintain or improve the availability of all foraging habitats, with only minimal differences in relation to effects on elk and big game occurring between alternatives 2 and 3.”

Again, this is range “con” spin. Numerous studies contradict her sunny conclusions, as well as observation of natural situations. Elk in Yellowstone National Park, in the A.B. Wilderness, Teton Wilderness, Grand Teton National Park, Rocky Mountain N.P., and many other livestock-free areas do just fine without the “improvement of forage and habitat” resulting from domestic livestock grazing.

Restocking Six Mile North at some point in time and continued livestock grazing in Six Mile South is particularly damaging to other resources. These allotments are immediately adjacent to the Dome Mountain Wildlife Management Area and a critical corridor for wildlife migration. They are also essential wintering areas for elk. In the future, they may even sustain bison.

Another minimized impact is the social displacement of other herbivores. Elk, for instance, avoid areas actively being grazed by livestock (Clegg 1994).  If one presumes that the elk are in a particular location because it is the “best” habitat, then displacement harms them.

Shamhart (2012) found that elk preferentially used “rested” pastures in a rest rotation system, in part because there was more forage available.

Frisina (1992) found a similar avoidance by elk of areas actively being grazed by livestock at Fleecer Mountain Wildlife Management Area. Ninety-four percent of observed elk were in pastures not occupied by cattle during July and August.

Stewart et al. (2002) also reported the social displacement of both mule deer and elk by the presence of domestic livestock. They specifically say that ”Elk used lower elevations when cattle were absent and moved to higher elevations when cattle were present, indicating shifts in niche breadth and competitive displacement of elk by cattle.”

Gniadek (1987) noted in his study of elk and cattle in Southwestern Montana that “elk generally avoided pastures being grazed, making relatively greater use of rested pastures and grazed pastures before and after grazing. Elk also used steeper slopes than cattle, apparently as a response to the presence of cattle. Elk avoided meadow sites heavily used by cattle during the previous year during the early summer. Elk were rarely observed in close proximity to cattle.” All of this points to social displacement of elk by cattle.

Forage competition also occurs, particularly between elk and cattle, but can also affect bears and bison if they are ever allowed to roam on this portion of the CGNF.

Another recent global review assessment (Schieltz and Rubenstein (2016) of all the literature on wildlife-livestock interactions found: “community-level total abundance of small mammals typically declines with grazing. Species richness of small mammals either declines or stays the same, as many studies found a change in species composition from ungrazed to grazed sites while the number of species remained similar. Individual species responses of small mammals vary. Voles, harvest mice, cotton rats, and shrews show consistently negative responses to grazing.”

With regards to larger wild ungulates, Schieltz and Rubenstein found more negative (n = 86) than positive (n = 34) ungulate responses overall, however, most studies have been on browsers and mixed feeders, namely deer and elk, and there is little available data for another group.


The presence of domestic livestock also impacts native predators.  The most apparent impact on predators like wolves and bears is that they are often killed in retribution for preying upon domestic animals. Putting livestock on these allotments is likely to cause conflicts with the native predators bearing the brunt of any management actions (i.e., they will be killed or infrequently relocated).

The other noticeable impact is that livestock competes with native herbivores like elk for forage and, as discussed above, can socially displace elk. Thus social displacement and forage competition reduce the prey base for predators.

One less evident impact is that wolves, in particular, den in areas where native ungulates are abundant. Since denning occurs in late winter, wolves are residing in lower elevations near winter ranges. With pups in the den, the wolves cannot easily move elsewhere, so if livestock are moved on to the allotments (June 1st), they can socially displace the elk and deer upon which the wolves depend. With the heavy demands of feeding pups, livestock may be attacked and killed to feed the young wolves. I know of at least one instance further south between Chico and Gardiner where wolves denned in the middle of an elk winter range, but once the cattle were placed on the allotment, the elk disappeared, and the wolves killed cattle. The entire pack was destroyed.

It seems immoral to set predators up to die by placing domestic livestock in their midst. Indeed, maintaining high native prey numbers is critical to avoiding livestock-wolf conflicts (Chavez and Gese, 2006). If there is sufficient prey on public lands, wolves are less likely to wander on to private lands. Wolves tend to avoid human activity and preferentially use public lands for prey selection so long as native prey is abundant.

Research shows a positive relationship between predation by wolves and the number of livestock Wielgus RB, Peebles KA (2014).  Also, predator control increases the likelihood of future predation, likely because predator control reduces the experience, age, and cultural knowledge of packs.  In their study, they found the odds of livestock depredations increased 4% for sheep and 5–6% for cattle with increased wolf control (Wielgus RB, Peebles KA (2014)

Bears are directly and indirectly impacted by livestock.

Putting cattle back on these allotments would harm bears who graze extensively on vegetation in the spring. Changing the turn out date to June will result in direct competition between cattle and bears, but more importantly, it increases the likelihood that bears will feed on cattle. Even if bears do not feed directly on live cattle, they often feast on dead animals. If the carrion is a dead cow, it can predispose them to feed on cattle in the future. This can result in the removal (killing) of bears.

The displacement of native ungulates by livestock can either reduce available prey for the bears or force bears into less secure areas as they seek to find prey. Bears seek out carrion and elk calves at lower elevations in the spring. These are often the same places where livestock are first permitted to forage on public lands, creating a potential livestock depredation situation by bears. Especially if turn out occurs in June as proposed in Alt. 3, the potential overlap is greatly increased.

The Range con suggests in the document that “effects of cattle grazing on foraging conditions for grizzly bears under Alternative 2 would be minor overall. She suggests areas outside suitable and capable grazing lands and other areas not used by cattle within the allotments would yield herbaceous forage for grizzly bears.” She claims there is limited dietary overlap between grizzly bears in the Yellowstone Ecosystem with livestock (page 53).

This is simply not true. While bears may only compete for forage with cows early in the season, this is a critical time for bears since other foods are not readily available.

Riparian areas have historically been used by bears for feeding, travel, and resting. Livestock production impacts on mesic grizzly habitat along Montana’s Rocky Mountain Front was documented by Stivers and Irby (1997).

For instance, along the Rocky Mountain Front, grizzlies utilize riparian areas for foraging in the spring. The research demonstrated a preference for ungrazed areas (Horesji, 2002). While bears may only rely on these habitats for a short period in the spring and early summer, they are considered essential because other food resources are limited.

Some biologists also believe the degradation and use of riparian areas by livestock is limiting grizzly bear recovery (Horesji 2002).

Cattle also trample and compact soils in riparian areas. Many plants preferred by bears are found in soft productive riparian soils but are harmed by livestock trampling. For instance, cow parsnip is a preferred food of grizzlies but is reduced with sufficient soil compaction and trampling (Campbell 1991).

Livestock grazing in aspen groves has been shown to reduce preferred understory bear foods like berries and other vegetation (Irwin and Hammond 1985).



Although none of these allotments currently sustain wild bison, the restoration of bison on CGNF lands is highly likely in the future. It is quite natural for bison to migrate out of Yellowstone Park north over Dome Mountain and into the Six Mile drainage. The presence of cattle would automatically set up a conflict. One, because of the false assertion that bison can transmit brucellosis to cattle, two, forage competition. It makes more sense to close these allotments to livestock grazing now rather than deal with future conflicts.


While the Wilderness Act explicitly says that livestock grazing can continue in designated wilderness, it impacts wilderness values. To most wilderness visitors, the presence of exotic animals impacting vegetation, depositing manure, trampling riparian areas, and supplanting native wildlife through social displacement are real impacts to the Wilderness Act’s values (Watson 2012).

Selecting Alt. 1, which would close all these allotments, including those that overlap with wilderness like Suce Creek, Pine Creek, and Elbow Creek, would improve most visitors’ wildlands experience.


Range cons frequently attempt to justify public lands grazing by arguing it is crucial to the local economy. Fortunately, this was not done in the East Paradise plan. But one can ask why the public should suffer any environmental impacts or have to spend money to mitigate those impacts (pipelines, water troughs, fencing, etc.) to minimize these impacts when livestock from these allotments makes almost no contribution to the local economy. Indeed, as I will show below, there is an excellent case to be made; it costs the local economy in multiple ways.

University of Montana economist Thomas Power has researched public lands grazing and concluded that across the West, that grazing on federal lands contributes only a “tiny sliver of economic activity to the local economies—usually a small fraction of 1 percent of total income and employment” (Powers, 2002).

He notes that during the 1990s, local economies grew by this much in a few weeks. He goes on to say that the “rapid economic growth has been fueled by families and businesses relocating in the pursuit of higher quality living environments” (Power 2002).

Indeed, given the changes in the regional economy of Park County since the 1990s, this is even more true today.

Recent articles in national magazines talk about how Bozeman, Livingston, and other communities are “booming” due to in-migration of people and money drawn by the outdoors and, in some cases, to escape Covid restriction in more urban areas.  https://www.washingtonpost.com/national/coronavirus-montana-escape-property-gold-rush/2020/10/20/9e36e858-0340-11eb-a2db-417cddf4816a_story.html

Even though Agriculture occupies 39.7% of Park County, agriculture makes almost no contribution to the country’s economic activity. According to Headwaters Economics, only 1.8% of the income in the county is derived from Ag. By contrast, 31.5% of the county’s income is the result of travel and tourism. Indeed, the government accounts for 11% of the county’s wages and employment.

Furthermore, Agriculture in Park County consists of more than livestock production. There is wheat, and small garden crops, and other agricultural endeavors. Thus the contribution of cattle ranching is something less than 1.8%.

Throughout the West, public lands forage often play a small part in cattle operations’ total forage requirements. Power finds that only 10% of the forage consumed by livestock in Montana is produced on federal lands. Power estimates that public land forage contributes to only 0.11% of Montana’s income (Power 2002).

In terms of employment, the contribution is even smaller. This makes sense since there is little employment needed to raise cattle, and in general, the pay is low for any ranch hands. According to Power (2002), federal grazing contributes to only one out of every 1400 jobs (in 1990) or 0.0011 percent of employment. That’s right—there are two zeros in front of the 11. While I do not have exact figures for ranching employment in Park County, there is no reason to believe it is significantly different.

Since public lands grazing only provides a small fraction of the available forage or AUMS, the actual contribution of public lands grazing to the local economy must be subtracted from the 1.8 % of all agriculture and the subset of livestock forage production (AUMs) that occurs on private lands.

I do not have those figures; nevertheless, it’s reasonable to suspect that public lands forage contributes to something less than 1% of all income in Park County.

Suitable Range: On Page 4 of the document, the amount of suitable range instead of the total acreage of the allotment is discussed. As acknowledged in the document, in all of these allotments, the amount of non-suitable acreage vastly exceeds the amount of the “suitable” range due to steep, rocky terrain. Suitable range includes both primary and secondary range. Although there is no breakdown of the percentage of primary range vs. secondary range, in my experience, the amount of secondary range almost always exceeds the amount of primary range. As implied, livestock’s secondary range is seldom used, and most grazing is focused on the primary range.

Consequently, the amount of forage we are discussing in any of these allotments is relatively insignificant.  The total amount of suitable acreage is a relatively small amount of land and forage in all cases. Even the largest available suitable range is about 1500 acres, most are under 1000 acres, and the primary range where the bulk of livestock grazing habitat is available will be some subset of even these small acreages.

Just the limited amount of available forage makes any livestock grazing in these allotments of questionable utility.

Some ranch boosters argue that ranchers “depend” on federal lands for forage. Still, again this is a rhetorical device since livestock “depend” on feed from many sources—hay, feed grain, and buy additional feed from other sources. There are alternatives—just not as cheap as the federal grazing subsidy of$1.35 an AUM.

It must be mentioned that Ag boosters attempt to inflate the contribution of Ag to state economies by including the income of “Ag related workers.” Thus in Vermont, the State Department of Agriculture had the wages of waitpersons in restaurants, the checkout people at Safeway’s, the people of made Green Mountain Coffee (even though the coffee was grown elsewhere), and the employees at Ben and Jerry’s ice cream plant as “ag-related workers.” By including these other incomes, Ag’s contribution to local, regional, and state economies is greatly exaggerated. The Montana Dept of Agriculture uses this same fundamental “multiplier” trick to inflate Ag’s economic contribution to the state.

Across the West, Power’s calculated that even if you eliminated all federal grazing, the loss of jobs would be replaced in eight days (Power 2002).

Furthermore, most ag operations today depend on outside income to be viable. Whether driving a school bus, working on the county road crew, or being a county commissioner, outside income contributes to the overall economic feasibility. In a sense, it is the local economy that supports ranching, not the other way around. With the Rocky Mountains, non-farm income contributes to 90% of the income received by farm and rancher operators (Power 2002).

All of this suggests that Alt. 1 the closure of all six East Paradise grazing allotments would have no significant economic impact, except the individual ranchers feeding at the public trough.

By contrast, the ecological impacts of livestock grazing harm the local economy. For example, it is typically agreed that one cow/calf consumes the same forage as approximately 2 elk and 5 deer. Since there is 261 cattle/calf that would graze under the proposed management plan, one can conservatively estimate that these cattle consume the forage that would support 522 elk or about 1350 mule deer.

Realistically it is not that simple, and the forage competition will vary year to year, perhaps greater in drought years, and so on. Nevertheless, it is reasonable to suggest that livestock grazing on these public lands occurs at some cost in elk production. Given that elk are far more valuable than cattle, especially to the public, grazing on the East Paradise Allotments is a real cost to the American people.

Plus, forage competition exists even when livestock are absent. If they have chewed vegetation to 4-inch stubble height, this results in a significant reduction in forage in the fall and winter when elk and other herbivores need it. Although, as suggested, some of this forage is in valley bottoms that may be inaccessible due to snow, this situation does not exist in all years, nor throughout the winter. Loss of access to this forage during winter stress can contribute to the loss of native animals due to starvation.

Given that hunting and wildlife viewing are essential factors for tourism-related travel in Park County, the potential loss of hundreds of deer and elk would translate into a significant loss of income.

The real cost of maintaining a livestock grazing program is never fully explored or analyzed. Nor is there any information about the costs of range developments and who is paying for these structures.  On page 13, the document lists an abundance of new range developments that would have significant costs to the taxpayer to facilitate livestock grazing by private interests.

Current federal grazing fees are $1.35 an AUM. Alt. 3, for instance, proposes 474 AUMS. That means the public receives only $640.00 in grazing fees per month. Given that even if the grazing season were extended to begin June lst and ending Oct 15, the overall maximum grazing fee paid by permittees for utilization of authorized allotments would be about $2880.00 annually.

Are these costs (subsidies) justified?

If there were no livestock grazing, these are costs (and the many externalities) that are avoided, along with the monitoring costs, personal costs of writing up the allotment management plan, and doing range surveys. Etc.

Clearly, from a purely economic perspective, the only people who benefit from the presence of livestock grazing are the range con and the permittees.

Given the low fees paid by permittees, are these costs of range developments, monitoring, etc., really in the public interest?

Proposed livestock improvements in the new Sixmile North allotment include:

  • Constructing fencing and cattle guards to define the new pasture(s) boundaries and around Gold Prize Trailhead and Sixmile Trailhead.
  • Install a cattle guard on Forest Service Road 348 near the Forest boundary to protect against gates being left open while cattle are in the pasture.
  • Constructing temporary fence to protect the southern pasture(s) from grazing until noxious weeds are treated.
  • Extending the Ridge Top Water System from its original location west to an open meadow to help distribution of livestock, and replace old red wood water tank on an unnamed tributary in Section 23, T6S, R8E that is leaking.
  • Protecting the riparian area in the Gold Prize pasture near the Colley/Gold Prize pasture drift fence and around the water system in the unnamed tributary to Gold Run Creek that is associated with a livestock water system.
  • Evaluate riparian areas within the new pastures and design additional resource protection improvements.
  • Develop alternative water sources and drift fences in the new pasture if monitoring indicates a need.
  • Reconstructing the drift fence in Section 16 to keep livestock from entering the Sliding Mountain Research Natural Area. The FS proposes building a fence around the Pine Creek campground at taxpayer expense to facilitate livestock grazing of this area. Photo by George Wuerthner. 

Other costly range developments like fencing the campground at Pine Creek are not disclosed. It is truly ironic and perverse that the public must fence out someone’s private cows to camp without cow manure and animals wandering through the campground.

Many of the costs are externalized—for instance, the water pollution of streams from cow manure or the forage consumed by cattle that might sustain an elk. These are real costs but are not given sufficient weight in this document. Even if one could not articulate the exact amount and value of the externalized costs, the F.S. should acknowledge they exist. https://www.westernwatersheds.org/sustainable-cowboys-welfare-ranchers-american-west/

There is a necessary cost to the taxpayer (subsidizing these operations) when livestock is permitted to graze these lands. While the Forest Service is not required to be fiscally responsible, it nevertheless should weigh whether the benefits to the public (who are, after all, the owners of these properties) outweighs the cost of maintaining them.

Nevertheless, if one considers the cost of the production and writing of this document, staff time analyzing and responding to comments from people like me, the time of staff to monitor allotments, the cost of “range improvements,” not to mention the environmental costs—most of which are ignored or downplayed in the document, it’s hard to justify these costs, especially when the Federal Government receives less than $3000 a year for grazing privileges.

However, I would like to address why this alternative is the best from a public policy perspective and comment upon some of the pro-livestock bias of the analysis.

Money spent on fencing troughs his money taxpayer money could be paid for other things on the federal lands, including repairing past livestock grazing damage. Money spent fencing campground is money that could be spent on other recreational options like trail improvement.

There is no free lunch. Forage consumed by livestock is not available for wildlife like grizzly bears, elk, deer, ground squirrels, grasshoppers, etc., not to mention the social displacement that also occurs. All these wildlife have value. If one considers that the public will receive something in the neighborhood of $640 per month,  if any of that forage could support just one more elk, the public’s public’s net benefits would be greater than the amount paid by the permittees. And clearly, there are trade-offs.


All of these allotments are adjacent or even partially within the A.B. Wilderness. https://www.gallatinyellowstonewilderness.org/ The areas outside are all potential additions to the wilderness. Indeed, the Gallatin Yellowstone Wilderness Alliance has proposed draft legislation that would make all the roadless lands in these allotments part of the A.B. Wilderness. While livestock grazing where it existed before wilderness designation is permitted to continue, numerous studies of wilderness visitors have demonstrated that people would prefer to hike and camp on lands without domestic livestock (Watson 2012).  So, most people would choose Alt 1, the No Action and No (Livestock) Grazing alternative.



To quote Debra Donahue, a former F.S. wildlife biologist and now a law professor at the U of Wyoming: “Livestock production is a chief contributor to many significant and intractable environmental problems. This article examines the causal role of livestock (especially beef) production in global climate change, predator control in the western United States, and winter elk feeding in Wyoming. It argues that ending livestock grazing on western public lands is a cost-effective first step for dealing with these problems and is readily achievable under existing law. Removing livestock would lead to improved watershed conditions and make reintroduction of predators politically feasible, which would promote further recovery of landscapes impacted by native ungulate populations.” (Donuhue 2010)

Clearly, from a public trust perspective, Alt 1, the No Action and No (Livestock) Grazing alternative is the best option. It would have the least negative impacts on water, wildlife, soils, vegetation, and recreation values. I encourage the Forest Service to close all these allotments, and if necessary, to avoid political interference, seek permit retirement through private funding.



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  1. Beeline Avatar

    Here we go again:

    I just learned that the Forest Service has filed (on 2 Nov 2020) to change the Code of Federal Regulations (CFR) for Assessing the Fees for Exess and Unauthorized Grazing.

    The General Accounting Office found that incidents of unauthorized grazing on Forest Service lands are largely unknown because the agency does not document them. Oh, really! So now the USFS wants to NOT have to request penalty fees for “unintentional” trespass grazing. More free forage on public land.

    I quote-“The proposed rule provides flexibility to resolve incidents informally without charging unauthorized grazing penalties, while retaining the option for monetary relief for willful excess or unauthorized grazing.” Another case of prime double speak.

    The proposed change further reads ” The incident should be noted in the files as non-wilful and the settlement would be considered non-monetary as no Bill for Collection would be issued”. Notice the word “should” instead of must be noted etc..

    Have these people no responsibility and no shame for giving away more public land resources? Why the hell do we pay these guys? This a really good reason to get rid of livestock on public lands period.

    info available at http://www.federalregister.gov/documents/2020/11/02/2020-24164/assessing…….

    I suggest writing/calling to Senator Jon Tester
    Avant Courier Bldg
    1E Main St Suite 202
    Bozeman, MT 59715
    406 586 4450

  2. rastadoggie Avatar

    Debra Donahue must have been one heck of a FS Wildlife Biologist (and likely a great professor now). My local National Forest Biologist just rubber stamps all of the biased Foresters’ wet dream cutting projects. Not much grazing where I live now; just tons of old downed barbed wire in the woods,ripping up wildlife and human visitors (I speak from experience). I can’t wait to see the EA response to these excellent comments. I learned a lot.


George Wuerthner is an ecologist and writer who has published 38 books on various topics related to environmental and natural history. He has visited over 400 designated wilderness areas and over 200 national park units.

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George Wuerthner