While most National Forests have been slow to make use of this new loophole, there must have been a call from the Washington Office over the winter for Forests to get on the ball and start pushing as many allotments as possible through this exemption because, all of a sudden, the Bridger-Teton National Forest has announced their intention to exclude from NEPA analysis close to half of the all of the Forest’s allotments over the next few months.

    I have been scrambling to cover as much of the areas on which the Forest Service proposes to use their CE authority. Besides making observations of current conditions, I have also been analyzing water samples to determine if current management is meeting Forest Plan and state water quality standards. What I am finding is not pretty: down-cut streams, collapsing stream-banks, degraded fisheries habitat and water teaming with pathogens and silt with elevated temperatures approaching lethal levels for fish and macroinvertebrates. Most of the sites sampled fall below state water quality standards for fecal coliform by 10+ times, exceed temperature standards by 5+ degrees and exceed turbidity standards by 5 to 50 times.

    Documents that I have obtained through FOIA are replete with descriptions such as “heavily trampled”, “excess sediment”, “blown out streambeds”, “numerous head-cuts”, “gully is down to bedrock”, “excessive surface erosion and rilling”, “rapid incising”, “this stream is hammered”, “this place needs help” and most descriptive “YIKES !!” So at least there are a few honest people in the Forest Service who tell it like it is. It is too bad the higher ups have lost such moral clarity and professional integrity.

    Included with this article are a few photographs of conditions that the Forest Service thinks are meeting Forest Plan Standards and Guidelines and thus, can be catagorically excluded. I have sent copies of these photos and others as well as WWP’s water quality data to the Ranger Districts involved as well as to the Supervisors Office, the Regional Office, the Washington Office, the EPA and the press in the hope that the decision-makers involved will be embarrassed into upholding their public trust responsibilities over the wishes of a few permittees.

    I was out on the BLM’s Gold Creek allotment for the first time a few weeks back, I noticed large numbers of cattle roaming about nearly all of the pastures of this allotment. When I called to report this trespass (andutilization levels that violated the AMP) the BLM could not even tell me in which of the pastures cattle we supposed to be in and which pastures they were not. 

    Well if that were not a good enough introduction to BLM “management” on the allotment, it just so happened that the BLM was scheduled to be out on the allotment doing PFC stream assessments the following week, so I joined them for 2 days. We were also joined by the permittee’s daughter and the same 200-300 cows and calves in trespass that had been there the weekbefore. It seems that the BLM did not even bother calling the permittee about the previously observed trespass, nor did the permittee, knowing that the BLM was coming to inspect the allotment, even make an attempt to cover up this massive level of trespass by moving his cattle to the correct pasture.

    As the day progressed and we passed 50, 75, 100, 125, 150 then 200+ pair in trespass, the BLM folks were strangely silent on this bit of basic range management. And it was not until I was about to leave that there was even a brief discussion among the group that utilization was estimated at 70% throughout most of the areas toured. No mention was made of the fact that the AMP specifies a maximum utilization rate of 40% or that utilization was nearly double what was permitted. Why bother mentioning such inconvenient facts when the BLM is too “cowed” to even mention to the permittee that something is amiss, let alone actually take permit action for the flagrant trespass and the violation of the AMP. 

    Filled with admiration and respect for the moral and professional integrity of the BLM (not to speak of the permittee), I was then off to the half million acre Green Mountain Common allotment, where I was met by a similar high moral fiber and long-term management perspective. On this allotment, trespass as usual had mowed every riparian area down to less than half the minimum in the AMP long before cattle were even legally allowed to be there. With all the riparian areas already grazed to below 2’ with ‘just’ 200-300 pair in trespass, you can just imagine what they will look like once the rest of the 1,400 pair show up during the allotted time. Here again, the BLM thanked me for my documentation of 210 pair in trespass and the excessive utilization and promptly when back to ‘business as usual’.

Jonathan Ratner is Wyoming Director of WWP.  He lives near Dubois, Wyoming.   Photos in original document are copyright Jonathan Ratner.