REVISED DRAFT POLICY III (June 29, 2000)
Livestock Grazing: Federal Public Lands
The Sierra Club advocates an end to commercial livestock grazing on federal public lands. Subsequent to the removal of livestock, the Sierra Club supports the restoration of natural processes and the restoration of native plants and wildlife. The Sierra Club further supports the preservation, as open space, of the private land portions of ranches holding federal public land grazing leases or permits.
Commercial livestock grazing: The production of livestock as an economic commodity accomplished in part through the granting of long-term grazing privileges (typically for ten years) on federal public land allotments as permits or leases to private individuals or corporations. The permits/leases are perpetually renewable and characterized as both inheritable and transferable with the sale of the private base property of the entity holding the permit/lease. A permit/lease is further characterized by the allowing of a permittee/lessee to put the preference for it in escrow, hence using that escrow as loan collateral in all but name. Commercial livestock grazing on federal public lands is further characterized by the subsidized goods and services provided to the permittee/lessee by the land management agency including, but not limited to, fencing, roads, water developments, fire control, vegetation management and predator/competitor control. Commercial livestock grazing on federal public lands is an instance of the “multiple-use” mandate as established by the Multiple Use Sustained Yield Act (MUSYA) and the Federal Land Policy and Management Act (FLPMA).
Federal public lands: Lands under the jurisdiction of the US Forest Service, US Bureau of Land Management, National Park Service or US Fish and Wildlife Service. They do not include Indian Reservations or lands under the jurisdiction of the Bureau of Indian Affairs, US Army, Navy, Air Force, Marines, Coast Guard, Corps of Engineers, Bureau of Reclamation, Department of Energy, Agricultural Research Service or Department of Transportation.
I. For Sierra Club members interacting with federal land management agencies prior to the legislated termination of federal public lands grazing programs:
Prior to achieving the goal of legislatively terminating commercial livestock production on federal public lands, Sierra Club members should strive to achieve the greatest protection for these lands under existing laws and regulations. This can best be done through promoting meaningful guidelines within a conservation biology framework of biodiversity reserves, corridors, and buffers during interactions with management agencies, users, and others; and when making comments on land use plans, activity plans (including allotment management plans, coordinated resource management plans, habitat restoration plans, and so forth), and other opportunities for public participation. The following non-comprehensive guidelines are offered as suggestions for public comment.
A. On federal public lands commercial livestock grazing must not occur:
1. In riparian areas and wetlands in order to protect water quality and to avoid and stop erosion of soils;
2. In hot deserts;
3. On burned, clear-cut logging, and vegetation restoration areas, in order to protect native vegetation and native wildlife and their habitats;
4. On archaeologic and historic sites;
5. On areas found to have soils contaminated with toxic, hazardous or radioactive wastes and residues;
6. Where conflicts arise with native wildlife—including, but not limited to, free-roaming buffalo, bear and wolves;
7. Where it hinders the success of threatened, endangered and candidate species and their habitat’s recovery;
8. Where it contributes to the introduction, persistence or dispersal of exotic species;
9. Where it alters habitat to such an extent that the geographic range of native wildlife species is altered;
10. Where it contributes to soil erosion which may be evidenced by pedestalling, rills, gullies, scouring, sheet erosion, sedimentation or dunes;
11. Where it destroys beaver complexes, leading to alteration of habitat structure, fire regimes, stream flow regimes and water tables;
12. Where it is in conflict with the land’s long-term health and function as characterized by:
a. Fully functioning soil with well-developed microbiotic components and a high capacity for water infiltration and water retention;
b. Plant litter accumulation adequate to help protect soil, retain moisture, provide habitat complexity, provide safe sites for germination of indigenous plants and help carry low-intensity ground fire;
c. Healthy, diverse indigenous plant communities resistant to disease and invasion by exotic vegetation;
d. Diverse vertebrate and invertebrate communities with adequate forage and cover;
e. “Normal” behavior of wildlife populations and “normal” interaction between predator and prey.
B. Cumulative impacts must be considered in assessing “suitability” for commercial livestock grazing on federal public lands.
C. The Sierra Club supports the removal from federal public lands of fences whose function can no longer be determined, and the removal of water diversion structures that adversely impact wetlands and instream flows.
D. The Sierra Club supports the removal from federal public lands of exotic vegetation.
II. For Sierra Club support of legislation seeking the termination of federal programs for commercial livestock grazing on federal public lands:
A. Toward easing the economic burden on permittees/lessees with small federal public lands allotments, the Sierra Club supports giving a one-time economic transition grant based on income derived from the livestock operation on the allotment. Grants should have minimum and maximum value limits to be determined by economic research into the characterization of the term “small rancher.” The providing of “transition grants” is distinguished from the “buying out of permits,” which may be construed as conveying a “right to graze” on public lands. The transition grant is intended to aid small ranchers in diversifying their income-producing operations and to defray the impact of relinquishing grazing permits/leases that have been used as collateral for loans as allowed under the Taylor Grazing Act and the 1938 Memorandum of Understanding between the secretary of agriculture and the Farm Credit Administration.
B. As the Sierra Club supports the preservation, as open space, of privately owned ranch properties holding federal public lands grazing permits/leases, which are 1) deemed significant wildlife habitat, and 2) susceptible to development that would destroy those wildlife values, the Sierra Club supports, in principle, the use of federal moneys for offering conservation easements on, or for purchase of (particularly of inholdings), such private ranch properties. Conservation easements must be made contingent on allowing free public access to federal public lands where such access is deemed necessary for the enjoyment of those lands by the public.
C. The Sierra Club supports the protection of legal and civil rights of indigenous peoples, including treaty requirements. Nevertheless, the Sierra Club does not recognize a preference, beyond that which may be necessary to fulfill treaty requirements, for individuals of any racial, ethnic, economic or social group holding federal public lands grazing permits/leases.
III. For the use of livestock for vegetation management purposes on federal public lands following enactment of legislation terminating commercial livestock grazing:
A. The use of livestock for vegetation management purposes on federal public lands is not categorically excluded, but support for their use is subject to the following conditions:
1. Authorization of the livestock must not be based on a preference system of long-term permits or leases, but rather by non-renewable competitively bid contract for a term not to exceed five years. Each contract must specify age, class and number of livestock; seasons, duration and frequency of use; and such other terms and conditions as may be necessary to ensure achieving the vegetation management objective. Contracts must not provide services that may be harmful to wildlife such as predator/competitor control or water developments.
2. The managing agency must demonstrate in an appropriate document compliant with the National Environmental Policy Act that the use of livestock is superior, in an environmental sense, to all other options (e.g. native grazers, fire, herbicides, mechanical manipulation) for achieving the vegetation management objective(s) that are consistent with the governing land use plan.