Delta County Commissioners have released an official position on the BLM's proposed management prescriptions for the Gunnison sage grouse (GSG).
In general, the county's comments, based on extensive citations from scientific literature, seek to expose and correct a bias against livestock grazing seen in the BLM proposals.
The commissioners say that one of the proposed alternatives "presumes that grazing is inherently bad for the Gunnison sage grouse and fails to recognize that properly managed grazing is consistent with conservation of the species."
The county's comments add, "To further clarify, it is scientifically accepted and recognized by (U.S. Fish and Wildlife Service) that livestock grazing is compatible and can even enhance sage grouse habitat."
In another passage the commissioners say "concerns exist in this document where BLM states that livestock grazing is a threat class on [BLM managed public] lands," and then they go on to advise, "BLM needs to be cautious when including broad statements that are derogative towards grazing and assuming adverse impact from the continuation of [grazing] activity."
According to commissioners, the BLM document also uses ill-defined and unscientific terminology in "a veiled attempt to once again concentrate on a listing factor [i.e. grazing] that is not a major threat" to the Gunnison sage grouse.
The county's 20-page comment letter, signed by all three commissioners and dated Jan. 9, was written with major input from county administrator Robbie LeValley, a range management specialist. It is the county's official statement on the BLM's GSG draft management plan.
In 2014 following a federal listing of GSG as a "threatened species," the BLM undertook to develop management policies for the bird across its entire public lands range including 10 Colorado counties and one Utah county. The result of the agency's undertaking is the "Gunnison Sage Grouse Rangewide Draft Resource Management Plan Amendment and Draft Environmental Impact Statement" (RMP) that the commissioners issued their official comments on earlier this month.
The BLM, quoting other sources, states that "the primary threat to, and principal cause of past decline of, the Gunnison sage grouse population [is] the loss, degradation, and fragmentation of habitat." But the Delta County position statement takes strong exception to inferences and statements that livestock grazing is the principle cause of GSG habitat loss. The commissioners' letter states, "It is important to mention when there were significantly more grouse on the landscape, there were [also] substantially more livestock and for longer periods of time. In addition, where there is no livestock grazing permitted, there has been no increase in [GSG] population levels."
The county's comment letter also notes that a review of scientific literature "found no experimental research that demonstrates that grazing is responsible for reduction in sage grouse numbers."
A BLM idea for prohibiting all surface activity within four miles of a GSG nesting site "is in fact arbitrary with no consideration of geography or topography," the county position states and adds, "Management and environmental conditions should be considered as opposed to relying on an assumption which is not scientifically supported."
One of the Delta County Commissioners' foundational principles on public lands issues has long been the doctrine of multiple use. The county finds that the BLM's management proposals for the bird fall short on that count by stating, "Establishing GSG habitat as the dominant or primary land use ... reduces BLM's ability to address requirements for multiple use on these lands"
The county's other bedrock principle on public lands policy is protection of private property rights. Almost all human activity including making fences, driving vehicles, finding and using energy, building houses and growing crops has been said to have some potential negative impacts on Gunnison sage grouse. BLM estimates of employment that would be lost by forced grazing reductions are too low because "sole- and owner-operators do not show up [in job statistics used] and they are the majority of permit holders and contributors to ag based counties." The BLM economic models used are seen as outdated and not reflecting actual impacts to livestock business employment. Livestock is a major component of Delta County's largest industry -- agriculture.
"Delta County continues to support full multiple-use opportunities balanced against the positive and negative impacts and the protection of private property rights within the GSG area," state the commissioners.
Two of the BLM's proposed action alternatives come in for especially strong opposition from commissioners. The RMP's Alternative B "would close all BLM surface in occupied and unoccupied Gunnison sage grouse habitat to livestock grazing" note the commissioners. That would be a total 623,346 acres closed. "All habitat lands would be designated ... to preserve grouse values" at the expense of livestock grazing and other uses.
The Alternative B "is a critical overreach of the BLM and an abuse" of applicable public lands use designations. Delta County is strongly opposed to Alternative B," states the commissioner's letter.
Another of the RMP's alternative management actions, Alternative C, would also have direct negative impacts on livestock grazing. "Alternative C would retire [grazing use permits] in both occupied and unoccupied habitat when a permittee relinquishes grazing preference on an allotment." Delta County is also opposed to Alternative C and its "permitted forage" approach "insofar as it would likely result in more of a reduction" of grazing uses over the long than would Alternative A."
Alternative A, favored for Delta and Montrose counties, would continue current management practices on the 1.7 million acres that BLM wants converted to "critical habitat" for Gunnison sage grouse.
Also objectionable to the county is alternative D2 which "moves the management of public lands towards single species management and away from multiple use."
According to published accounts, it was in 2000 that the Gunnison sage grouse first attained distinct species status. That year the U.S. Fish and Wildlife Service (FWS) said the bird was "warranted" for protection, but that other species deserved more immediate attention.
In 2007, the FWS lost a lawsuit by environmental groups for declining to give the bird a protected status listing.
A third FWS rebuff to pro-listing groups in 2010 led to a negotiated agreement to include GSG in an omnibus listing of 250 species.
In 2013 GSG was listed under the federal Endangered Species Act as "threatened." That finding by the FWS opened the door to BLM's current draft rangewide management planning initiatives.
Though the BLM's proposed rules apply only to public lands administered by the agency, there is the concern among some ag producers that the rules could spill over into private enterprises if they become review requirements for ag program qualification. Others see the BLM's management plans for GSG as setting the stage for new regulations based on the far more widespread populations of the greater sage grouse.