Livestock Grazing and Range Management

Photographer: Mary O'Brien

Note: In order to detect differences between Alternatives B, C, and D for livestock grazing, it was necessary to do a word search in text for “FW-RANGE-“  within the section on Environmental Consequences. The DEIS contains no chart comparing provisions of Alternatives B, C, D for livestock grazing.

GOALS

Conservation Alternative Goals (FW-RANGE-GL): 01-03

1. Permitted livestock stocking rates will become more conservative throughout the Forest in light of climate trends, especially  increased temperatures, earlier snowmelt, soil aridification, and reduced effective precipitation (i.e., the difference between total precipitation and actual evapotranspiration).

   
   

2. A balance of MLNF areas grazed by livestock and not grazed by livestock will be made achievable through voluntary grazing permit retirement.

   
   

3. Public participation in livestock grazing decisions will be encouraged.

Proposed Management Plan (Management Plan, Vol. 1) Goals (FW-RANGE-GL): 01-03

1. Permittees and the forest work together to adjust the timing, intensity, and duration of livestock grazing to respond to livestock needs and  changing resource conditions, including following  major disturbances, such as flood and fire.

   
   

2. Work with other federal, state, county, and local  government entities; nongovernmental organizations; and pueblos, tribes, nations to  maintain or improve rangeland conditions.

   
   

3. New partnerships with stakeholders increase maintenance and construction opportunities. 

Description of Alternatives: All, B, C, D (DEIS, Vol. 2) Goals 

[The DEIS has no alternatives for livestock  grazing and range management Goals] 

Common to All Alternatives - All alternatives would continue to provide forage for livestock and continue to support grazing operations on the Manti-La Sal National Forest. None of the alternatives would change allotment acres, number of permitted animals, or the process for authorizing or implementing grazing permits  including changes to permit terms and conditions.  Under all alternatives, the Forest Service will  determine the site-specific permit actions  necessary to meet desired conditions both for  rangelands and ecological integrity. 

All alternatives should continue to support  traditional and cultural ways of life for ranching  communities and Nations, Tribes, and Pueblos. 

Elements in Alternative B [Management  Plan]

Under alternative B, plan components are designed  to evaluate allotments for change of condition to  determine if management action is warranted at a  specific site or allotment.

DESIRED CONDITIONS

Conservation Alternative Desired Conditions (FW-RANGE-DC): 01-09

1. Livestock grazing continues to be permitted as a commercial activity on portions of MLNF and with practices that are monitored and demonstrated to not impair native productivity of upland, riparian, and aquatic ecosystems. 

   
   

2. Livestock grazing is being adaptively managed in light of climate change: increasing heat, rain-to-snow ratios, drought, and fires; and earlier snowmelt.

   
   

3. Animal Unit Months [or Head Months] authorized for a given season are altered as needed to protect native resources and conditions in response to predicted and developing resource limitations (e.g., fire, heat, and drought).

   
   

4. Pollinator resources (i.e., native forbs and shrubs) are present throughout the growing season for support of the Forest’s  native bees, bumblebees, and hummingbirds.

   
   

5. Some areas of the Forest are not grazed by livestock,e.g., erodible slopes, reference areas, wetlands and springs, Research Natural Areas, some Special Inter Areas, and portions of vegetation types poorly represented in livestock-free condition on the Forest (e.g., sagebrush communities).

   
   

6. Livestock grazing is maintaining or restoring, native plant community structure and function, native wildlife habitat, appropriate infiltration and water  storage of soils, and soil stability.

   
   

7. Streambanks within a given reach retain overhanging banks and vegetation cover suitable to stream and soil type and remain 85% free of combined bank trampling and vehicle impacts.

   
   

8. Shrubs and saplings palatable to ungulates retain reproductive capacity and recruitment into multi-storied stands.

   
   

9. Riparian woody vegetation provides support for beaver in potential beaver habitat (Beaver Restoration Assessment Tool).

Proposed Management Plan (Management Plan, Vol. 1) Desired Conditions (FW-RANGE-DC): 01-02

1. Sustainable levels of livestock grazing and associated management activities are compatible with ecological functions and processes.

   
   

2. Livestock grazing supports local rural communities, the agricultural economy, and local employment.

   1. Range infrastructure and improvements function to maintain or improve livestock management and the condition of forest ecological and cultural resources, while minimizing conflicts.

OBJECTIVES

Conservation Alternative Objectives (FW-RANGE-OB): 01-06

1. Within one year of plan approval, a list of processes available for public participation in livestock management decisions, and how concerns raised by the public is processed.

   
   

2. Within one year of plan approval, a list of options is distributed to permittees and the public for adaptive livestock management in response to between- and within-year predicted and developing drought and/or above-normal heat.

   
   

3. Within eight years of plan implementation, revisions of all Allotment Management Plans (AMPs) that are older than 10 years will be complete. 

   
   

4. Within two years of plan approval, processes by which permittees may apply for (a) reduced use for conservation and restoration purposes (while retaining existing permit numbers); and/or (b) voluntary closure of all or part of an allotment based on capability, suitability, ecological values, location within wilderness, conflicts with other forest uses, and/or lack of sufficient production for economic sustainability shall be developed.

   
   

5. Within two years of plan implementation, update maps of all allotments for:

05.1 Fences and other livestock developments

05.​2 Functional exclosures

05.​3 Long-term trend monitoring locations

05.​4 Areas ≤10% in slope

05.​5 Springs and wetland

05.​6 Perennial and ephemeral waterways

6. Within three years of plan approval, a Programmatic Agreement with the Utah State Historic Preservation Office will be established and implemented to faithfully conform to NHPA Section 106 process and implementing regulations at 36 CFR part 800 for all new and renewing grazing permits.

Proposed Management Plan (Management Plan, Vol. 1) Objectives (FW-RANGE-OB): 01-04

1. Evaluate a minimum of 6 allotments for  changed conditions over the life of the plan. 

   
   

2. Every 5 years, treat a minimum of 1,000 acres of  non-forested rangeland communities to maintain or enhance the herbaceous understory for livestock  and wildlife forage. 

   
   

3. Annual [sic] remove, improve, reconstruct, or  construct a minimum of 6 existing livestock water  developments, such as ponds, stream diversions,  and spring developments. 

   
   

4. Over the life of the plan, update or develop  allotment management plans for all allotments that  do not currently have a site-specific National  Environmental Policy Act decision.

Description of Alternatives: All, B, C, D (DEIS, Vol. 2) Objectives (FW-RANGE-OB)

[Alternative B ; i.e., the Management Plan] FW RANGE-OB-03 is designed to prioritize the  removal, improvement, or reconstruction of a  minimum of six existing livestock water developments, such as ponds, stream diversions,  and spring developments, annually. 

[Alternative C] FW-RANGE-OB-01 is designed to  compel evaluation of nine allotments for changed  conditions over the life of the Plan. 

Alternatives C and D] FW-RANGE-OB-03 would  apply to a minimum of 10 existing livestock water  developments, such as ponds, stream diversions,  and spring developments annually, 

[Alternative D] Under alternative C, [sic – means  Alternative D; this is in a section on Alternative D  and differs from Alternative C OB-01; see DEIS at  3-253] FW-RANGE-OB-01 is designed to compel  evaluation of all allotments for changed conditions  over the life of the Plan. 

[Alternative C] An additional [unnumbered] standard, FW-RANGE-ST, is designed to limit new  livestock water developments in contoured,  trenched, or furrowed areas, and where feasible,  remove existing water developments in these areas.

STANDARDS

Conservation Alternative Standards (FW-RANGE-ST): 01-21

1. Permits will be based on available forage. The utilization limit of available forage is 30% (25% during drought) of palatable, native riparian and upland herbaceous species

   
   

2. Infrastructure to create additional pastures for distribution of livestock will not be permitted if 30% utilization has not been maintained on the allotment for three years prior to the proposal.

   
   

3. No new drilling, spring development, water trough, or excavation of additional stock ponds will be permitted for livestock watering without an equal decrease by documented volume of water extraction elsewhere at the time of the proposed development.

   
   

4. Seeding of perennial, non-native species for forage is prohibited.

   
   

5. Livestock Annual Operating Instructions must recommend non-lethal methods of avoiding predator depredations (e.g., guard dogs, portable electric fencing and fladry, herders, range riders, etc.), especially during high-risk time periods (e.g., calving/lambing).

   
   

6. Predator control to protect livestock cannot be undertaken without documentation of the failure of predator avoidance efforts by livestock operators.

   
   

7. A written response must be provided, within 10 business days, to Forest user/visitors who have documented evidence that a livestock grazing term and condition, standard or AMP requirement is being violated and/or natural resources are being significantly compromised. The response will (a) indicate mitigation or responsive action that will be taken; or (b) explain why the comment does not warrant further agency response.The response will (a) indicate mitigation or responsive action that will be taken; or (b) explain why the comment does not warrant further agency response.

   
   

8. No more than 15% of the length of any 200 feet of streambanks may be trampled within areas grazed by livestock.

   
   

9. Stubble height limits for an allotment must be altered if either of the following are not being achieved due to ungulate use: (a) multi-height and multi-age palatable, native, woody composition; or (b) bank trampling of less than 15% within any 200 feet.

   
   

10. Livestock cannot enter a pasture for the season of use until permittee-maintained fences, water developments, and other livestock developments are maintained to standard. 

    
    

11. All livestock water developments must provide access and escape to and from water for all types of wildlife.

    
    

12. Proposals for treatments to restore native vegetation communities or riparian areas in locations grazed by livestock must describe post-treatment native vegetation goals and livestock management that will achieve those goals.

    
    

13. Grazing systems must be designed in a manner to provide rest at least once every 3 years to forage and forb species during the growing season in order to promote pollinator pollen and nectar, ground cover, species diversity, reproduction, and productivity.

    
    

14. No salting or mineral supplementation shall occur on or within 500 feet of known populations and/or habitat of at-risk plant species, highly erosive soils, biological soil crusts; within 0.25 mile of a water body or riparian management zone; nor in known archeological sites and other historic properties.

    
    

15. Within watershed improvement/protection areas (contour trenched or furrowed areas), research natural areas (RNAs), botanical areas, developed campgrounds that are not fenced, and areas containing highly erodible soils:

    15.1 No new livestock water developments will be allowed and where feasible, existing water developments will be removed;

    15.2 No salt or supplemental nutrients and no sheep bedding may be placed.

    15.3 The permittee will not intentionally move livestock into these areas; incidental use will be mitigated and prevented.

    
    

16. Rest burn areas from livestock grazing for at least three years after a fire.

    
    

17. Livestock grazing will not be authorized post-fire in pinyon-juniper or sagebrush communities until the majority of native grasses have seeded and the Forest Service determines that production will support grazing without exceedance of 30% utilization. 

    
    

18. Livestock grazing will not be allowed in post-fire aspen until aspen are meeting the abundance and height delineated in Appendix C of the 2015 Final Environmental Impact Statement for Monroe Mountain Aspen Ecosystems Restoration Project).

    
    

19. Livestock will not be returned for the first time to an area that has burned if, on March 15, the Evaporative Demand Drought Index (EDDI, which estimates atmospheric demand on available soil moisture), indicates at least moderate drought (D02) in its 3-month index.

    
    

20. To minimize soil compaction and impacts to subalpine, alpine, and riparian areas; and at-risk species, bed grounds for sheep may be used 1-2  days. Bed grounds must be located on rocky or otherwise hardened sites, and be located at least 0.25 mile away from riparian management zones, at-risk or rare plant species, or known at-risk native pollinator habitat.

    
    

21. Infrastructure for additional pastures for distribution of livestock will not be permitted if 30% utilization has not been maintained on the allotment for three years prior to the proposal.

Proposed Management Plan (Management Plan, Vol. 1) Standards (FW-RANGE-ST): 01-02

1. Livestock management and grazing activities  shall be designed to allow at-risk plant species to persist in the plan area over the long term.

   
   

2. New, reconstructed, or replaced livestock water  developments shall be designed to retain hydrologic conditions and to facilitate animal  escape for all types of wildlife.

Alternatives C (DEIS, Vol. 2) Standards (FW-RANGE-ST)

[Alternative C] Additionally, an additional  [unnumbered] standard, FW-RANGE-ST, is  designed to limit placement of salt, supplemental nutrients, or sheep bedding in these areas in  contoured, trenched, or furrowed areas.

GUIDELINES

Conservation Alternative Guidelines (FW-RANGE-GD):01-06

1. Livestock permittees should be allowed to voluntarily relinquish or retire all or portions of allotments for the purpose of removing livestock grazing where absence of livestock would contribute to watershed resilience; reduction of soil erosion; or restoration of native species and/or water quality or water quantity.

   
   

2. Term permit renewal should be open and responsive to public input.

   
   

3. Where livestock-related infrastructure is the  responsibility of the MLNF and is not functional, the permittee should notify the  MLNF

   
   

4. Permittee access for permit administration  that differs from access available to the general public under travel management plans, wilderness and recommended wilderness should be specified and authorized in the Annual Operating Instructions or Allotment Management Plan or included in Part 3 of the Grazing Permit.

   
   

5. Engineering tools to minimize recreation  and livestock grazing conflicts could include, but are not limited to, trail design  that avoids stock tanks, incorporation of self-closing gates, use of all-terrain vehicle  cattle guards, and gates around cattle guards for horseback riders. 

   
   

6. Areas below 50% of HCPC, mid-seral or fair  condition should not be authorized for livestock use until recovery objectives have  been met.

Proposed Management Plan (Management Plan, Vol. 1) Guidelines (FW-RANGE-GD): 01-07

1. To ensure the sustainability and resiliency of  vegetation in riparian areas, a four-inch or greater stubble height of hydrophytic plant species should  be present on the greenline at the end of the grazing season, unless monitoring or site-specific  review demonstrates a more appropriate stubble height.

   
   

2. To maintain or improve the resiliency of  riparian and upland ecosystems and associated  flora and fauna, livestock grazing utilization should be established under current term grazing permits or Allotment Management Plans. New or revised allotment management plans should include grazing practice design measures such as stocking  levels, length of grazing season, and timing of grazing, and shall be adjusted if allotment  monitoring indicates a need for change.

   
   

3. To sustain livestock grazing,  determinations on  the best practices and management of grazing  allotments following a major disturbance – including, but not limited to, fire or flood – should  occur on a case-by-case basis, i.e., after consideration of site-specific resource conditions.  Areas should be evaluated to determine if rest from livestock grazing is necessary for recovery of  desired vegetation conditions and related  biophysical resources.

   
   

4. New or modified range improvements should be  designed to sustain and enhance healthy soil and water conditions; minimize negative livestock and  wildlife interactions; allow wildlife movement; to protect plants and springs of importance to  Nations, Tribes, and Pueblos; and minimize recreation user conflicts.

   
   

5.  To ensure vegetative ground cover is retained in  areas of livestock grazing, continuing mitigation or rest-rotation practices and follow-up maintenance activities should be designed to ensure vegetative ground cover exceeds 80 percent of  adjacent, similar, undisturbed sites.

   
   

6. To maintain the resiliency of ecological systems,  new livestock corrals should be located away from communities of biological soil crust, riparian  areas, springs, wetlands, and other water features.

   
   

7. To facilitate livestock loading and unloading,  new livestock containment corrals should be  located adjacent to roads.

Description of Alternatives: All, B, C, D (DEIS, Vol. 2) Guidelines (FW-RANGE-GD)

[Alternative B; the Management Plan] FW RANGE-GD-02 is designed to establish utilization levels at the site-specific level and not set in the Forest Plan under this alternative, the utilization levels should be more reflective of site  conditions and more responsive to the specific needs of individual allotments. This should help move trends towards  desired conditions for rangelands. 

[Alternative C] An additional guideline [unnumbered] FW-RANGE-GD, is designed to make vacant allotments available for pasture  during times or events when other active allotments are unavailable.

[Alternative D] FW-RANGE-GD-01 will set the minimum stubble height at five-inches. 

[Alternatives C and D] With standard [sic? This is a guideline] FW-RANGE-GD-02 utilization is not determined at the site-specific level but is set at no greater than 50 percent of the year’s growth, unless monitoring demonstrates a different level.10

The DEIS does not compare livestock grazing/range alternatives A, B, C, and D side-by-side. The only charts comparing the alternatives are for the  three issues the Forest felt are significant: (Issue 1: Sustainable Recreation; Issue 2: Traditional and cultural ways of life; and Issue 3: Ecological  Resilience). Livestock grazing appears in two of the 23 rows comparing the forest plan alternatives. The row in Table 2.6-3 is particularly confusing:

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ABOUT THIS COMPARISON

All text in this chart is copied and pasted from the Conservation Alternative, the MLNF proposed Management Plan, and the MLNF DEIS except for any text in brackets and in italics font.

YELLOW HIGHLIGHTED TEXT

Provisions for Livestock and Range Management that were submitted in the Conservation Alternative. 

Yellow-masked text: Conservation Alternative provisions that are particularly important, but since the Conservation Alternative was not included in the DEIS, they have not been offered to the public as options for their comment.  

BLUE HIGHLIGHTED TEXT

Provisions for Livestock and Range Management in the Forest’s proposed Management Plan (which is Alternative B in the DEIS)

Blue-masked text: Forest Plan provisions that differ in important ways with the Conservation Alternative. 

 GREEN HIGHLIGHTED TEXT

Alternatives to the Management Plan in the DEIS for Livestock and Range Management.

Green-masked text: Anything noteworthy re: “All Alternatives” and/or Alternatives B, C, or D.

Note only two (minor) Standards  in the DEIS to manage the entire livestock use throughout nearly 100% of the MLNF. Note also the extremely weak Guidelines (e.g., 4” stubble height at the “greenline”, which is the immediate edge between a streambank and the stream and does not include the much broader riparian area).