Sunday, February 26, 2017

Comment Now! Siskiyou Crest Public Lands Grazing

Public lands grazing is impacting important high-elevation habitat for native pollinators and other wildlife, while creating erosion and water quality issues that have long-lasting impacts.

Siskiyou Crest Public Lands Grazing 
Have you backpacked on the PCT on the Siskiyou Crest and stopped to filter water from a spring or creek, only to find a big cow pie in the water and the smell of cow urine wafting in the air? Are you a butterfly or native bee enthusiast that cringes every time you see a productive wildflower meadow turned from pollinator paradise into a mowed down feedlot for cows? Are you a hunter that finds more forage and habitat consumed by cows than is available to elk or deer? Or are you birder who watches willow flycatcher habitat disappear on the Siskiyou Crest from cattle impacts in the flycatcher's sensitive riparian habitat?

Now is your chance to have your opinion regarding public lands grazing in the Siskiyou Mountains heard! The River-Siskiyou National Forest, Siskiyou Mountains Ranger District is beginning an Environmental Analysis (EA) process to update four grazing allotments in the Siskiyou Mountains.

Applegate Grazing Complex  

Cows damage sensitive dryland habitat on the Siskiyou Crest.
Applegate Grazing Complex
The proposed plan is to update four Allotment Management Plans (AMPs), collectively referred to as the Applegate Grazing Complex, including: Beaver-Silver, Carberry Creek, Elliott Creek, and Upper Big Applegate. The four allotments span across the vast majority of the Upper Applegate and Little Applegate watersheds, affecting hydrology, water quality, wildlife habitat, botanical values, roadless areas and pollinator habitat. The impacts are immense, widespread and far outweigh the benefit of providing income to a handful of ranchers.

The Forest Service issued the Scoping Notice for the EA on February 16, 2107 and they are currently accepting public comments during the 30-day public comment period. The Scoping Notice states: "The purpose of updating the AMPs is to consider the reauthorization of livestock grazing on the four allotments. The intent of the reauthorization is to provide the Forest Service and permittees with an updated legal document that defines how livestock grazing will be managed. Grazing on the allotments have generally been permitted since the early 1900s. This effort would ensure updated information is provided for the sustained health of rangeland and forest ecosystems.

The AMPs for these allotments have not been updated since the 1960s; an evaluation of the condition and trends of vegetation and soils within the allotments needs to be conducted. Based on the results of the evaluation, the Forest Service wold either allow for continued permitted grazing for the established numbers and seasons, adjust the permitted numbers and seasons allowable for grazing, or discontinue the permitted grazing. The analysis would provide updated information that reflects current management direction and resource objectives. Updated AMPs would provide direction that maintain or improve vegetation and riparian conditions through effective livestock management while providing for other uses."

Visible on the right of this photo are historic terraces created by the Forest Service to reduce erosion from overgrazing in the Silver Fork Basin on the Siskiyou Crest at the headwaters of Elliott Creek. Forest Service documents confirm that as early as 1918 Silver Fork Basin was badly overgrazed; unfortunately, impacts from grazing continue in Silver Fork Basin.

The Times They Are A'-Changin
As the scoping notice states, the last time these allotments were updated the Vietnam War raged on, the Beatles, Bob Dylan and the Rolling Stones were the most popular musicians, and no human had yet been to the moon — it's time to bring these grazing allotments in line with current science, ecological knowledge, and societal values. A lot has changed since the 1960s! Unfortunately, little has changed in regard to grazing management on the Siskiyou Crest.

Bovine bulldozers denude important meadow habitat for
declining native pollinator species on the Siskiyou Crest.
Impacts of Public Lands Grazing on the Siskiyou Crest
The Applegate Grazing Complex is located in Upper and Little Applegate watersheds and extends from the low elevation foothills to the high country of the Siskiyou Crest where most of the cows stay for the summer. Cattle routinely reach the Siskiyou Crest before the approved grazing season has begun and are often left to graze later in the season than is allowed under the current AMP, creating severe impacts and over-utilization of forage resources.

The grazing strategy currently employed is referred to as "passive season long grazing," meaning little, if any, management occurs once the cows are placed on federal land. The cows simply manage themselves and congregate at preferred "pastures" in high-elevation wet meadows doing great damage to wetlands, streams and sensitive meadow habitat. Many sensitive habitats are being degraded or denuded by cows. Forage resources (grasses, forbs and shrubby growth) are being over-utilized by grazing cattle, leaving little for native elk and deer who prefer many of the same locations. Numerous springs, streams, wet meadows, and lakes that support populations of rare and sensitive plant species occur within the Applegate Grazing Complex.

According to government recommendations for livestock grazing and pollinator health, "Livestock grazing alters the structure, diversity, and growth pattern of vegetation, which affects the associated insect community. Grazing during a time when flowers are already scarce may result in insufficient forage for pollinators. Grazing when butterfly larvae are active on host plants can result in larval mortality and high intensity grazing can cause local loss of forb abundance and diversity."

Much of the most intensive grazing occurs in designated Botanical Areas, established to protect botanical values; instead, many of these areas are heavily degraded by grazing cattle. Rare plant populations are being impacted by public land grazing and the intact habitats identified by the Forest Service for Botanical Area protection are being compacted, denuded,  and mowed to the ground by unmanaged cattle grazing. Eight Botanical Areas are included within the Applegate Grazing Complex allotment boundaries: Big Red Mountain, Dutchman's Peak, Observation Peak, Scraggy Mountain, White Mountain, Cook and Green Pass, Whisky Peak and Hinkle Lake.

Roadless Areas at the headwaters of the Applegate River are also being negatively impacted. Roadless areas within the allotment boundaries include: Big Red Mountain, Glade Creek, Observation Peak, Condrey Mountain, Kangaroo, and Whisky Peak. Low elevation roadless areas, including the Little Greyback, Collings-Kinney, Elliott Ridge and Boaz Mountain Roadless Areas would also be impacted by proposals to release cattle at lower elevations, allowing cattle to migrate upward as the snow melts. The release of cattle at the lower end of Mule Creek, Palmer Creek and Beaver Creek — all fish bearing streams — is proposed under the Applegate Grazing Complex Scoping.

The proposal also includes grazing in the Red Buttes Wilderness, the largest intact wildland habitat in the Applegate River watershed. It has been many years since the Red Buttes Wilderness has been actively grazed.

Low grazing fees leave the federal government with a deficit
for administering public land grazing.
Welfare Ranching
The Federal grazing fee for 2017 is $1.87 per animal unit month (AUM). An AUM is the use of public lands by one cow and her calf. This irresponsibly low fee leaves the federal government with a large fiscal deficit for administering public land grazing, and leaves the American people with degraded water quality, wildlife habitat, soil productivity, floral resources for dwindling pollinator populations, etc. It's a lose-lose situation for everyone but a handful of ranchers.

Typically, grazing fees cover only a fraction of the cost of administering the allotment, and roughly half of the money received by the federal government goes back into "rangeland improvements" meant to facilitate grazing and mitigate the impacts. Thus, the public is paying a high price to subsidize the destruction of our headwater streams and the fouling of our pristine water sources.  The permittees make an easy buck while the public is stuck with the cost of restoration and mitigation

AUM breakdown for the Applegate Grazing Complex

Grass-fed cattle can sell for anywhere between $1,200-$1,700 dollars on the market.

Cow manure and trampled wetland habitat on the Siskiyou Crest.
Provide a Public Comment on the Applegate Grazing Complex
Applegate Grazing Complex Scoping comments are due on March 18, 2017.

Written comments can be sent to:
Donna Mickley, District Ranger, c/o Greta Smith, at 6941 Upper Applegate Road, Jacksonville, Oregon 97530.

Electronic comments may be submitted to:

For further information about the project contact Mark Hocken, Project Team Leader, Siskiyou Mountains Ranger District: or via phone: 541-899-3830.

Sample Scoping Comment

Re: Applegate Grazing Complex Scoping Comment 
Attention: District Ranger Donna Mickley c/o Greta Smith
6941 Upper Applegate Road
Jacksonville, Oregon 97530

The Applegate Grazing Complex is a very significant land management project, encompassing vast acreages of federal land and creating both direct and indirect impacts across the Applegate River watershed and the Siskiyou Crest. Federal land livestock grazing is associated with widespread impacts to riparian areas, water quality, wetlands, fisheries, hydrology, native plant habitat, rare plant habitat, wildlife habitat and pollinator habitat. The scope and scale of the project requires an Environmental Impact Statement (EIS), rather than a less comprehensive Environmental Assessment (EA). 

The Siskiyou Crest is a botanical wonderland and a regionally important connectivity corridor. It is one of the most significant concentrations of biological diversity on the West Coast of North America. For many years this botanical paradise has been subjected to severe overgrazing. Please consider the following substantive issues in the upcoming NEPA analysis for the Applegate Grazing Complex.
  • Consider discontinuing grazing allotments on the Siskiyou Crest, especially in allotments that are not currently meeting water quality standards; in allotments that have severe stream/wetland degradation; in allotments that have significant impacts to Botanical Areas and botanical values; and in allotments that create conflicts with other appropriate uses like the Pacific Crest Trail.
  • End "passive season long grazing" on the Siskiyou Crest and require all permittees to actively herd cattle from "pasture" to "pasture." Do not allow cattle to congregate in preferred locations for more than 14 days.
  • As part of the environmental review, it is essential that qualified Forest Service specialists assess stream, wetland and meadow conditions in order to determine and disclose whether streams, wetlands and meadows are functioning properly ecologically. If there are streams, wetlands and meadows on these allotments which are not functioning properly, Forest Service  managers must determine how cattle grazing is impacting properly functioning condition and adjust grazing practices, including the number of livestock allowed to graze, the season of grazing at different elevations, and the grazing system that will be used to end the degradation and return streams, wetlands and meadows to properly functioning ecological condition.
  • Stream, riparian and wetland exclosures should be established, and where they have been removed, they should be restored. Livestock exclosures are the only valid method to determine if grazing is significantly altering the composition and structure of riparian and wetland vegetation.
  • Analysis must identify all provisions of the Clean Water Act that apply to the grazing allotments and require all grazing allotments to be consistent with the mandates of the Clean Water Act.
  • Analysis must identify impacts to Botanical Areas and require that AMPs are consistent with Botanical Area designation.
  • Analysis must identify impacts associated with early season grazing along low-elevation stream corridors, especially along fish bearing streams such as Beaver Creek, Mule Creek, Palmer Creek and Kinney Creek.
  • Analysis must identify the impact of competition between cattle and the growing elk population on the Siskiyou Crest. Cattle numbers, seasonality of use, intensity of use and the lack of herding must address the issue of competition between cattle and elk for available forage resources.
  • Analysis must identify the existing condition of willow flycatcher habitat (an agency sensitive species) in the EA, document impacts associated with cattle grazing, and limit the number of cattle or seasonality of use to mitigate impacts to willow flycatcher habitat.
  • Implement the recommendations for Livestock Grazing written in the Federal publication, Pollinator-Friendly Best Management Practices for Federal Land. Utilize these guidelines for pollinator habitat and to identify impacts to pollinator habitat from grazing activities. Limit the number of cattle and seasonality of use to mitigate the impacts of grazing on pollinators. Special attention should be taken to restore, enhance and promote the maintenance of habitat for the Sierra blue butterfly (an agency sensitive species), Western bumble bee, Franklin's bumble bee, and the monarch butterfly.
  • Analyze the impact of historic grazing on dry bunchgrass habitat and in "cattle barrens" created by historic and contemporary overgrazing. Review the restoration of dry bunchgrass habitat in vacant or unused areas and compare them to areas that are actively grazed. Create guidelines within the AMPs to address the loss of historic dry bunchgrass habitat and the restoration of these communities due to non-use.  
          [your name and address]                                                                                                                            

Erosion and downcutting from overgrazed riparian areas
on the Siskiyou Crest.
2015 Siskiyou Crest Grazing Report
The Campaign to Reform Public Land Grazing in Northern California has created a must-read 2015 report on grazing allotments on the Siskiyou Crest. This is the most comprehensive report available that details the ecological impacts of public land grazing on the Siskiyou Crest.

Cows on the Siskiyou Crest
Cow Quotes
"Unlike a factory discharging waste through a pipe into a stream, livestock grazing impacts to water quality are non-point sources of water pollution. Other "non-point" sources include logging, road construction, road maintenance and recreation. Because activities which can cause "non-point source" water pollution are widespread across Western landscapes, they are difficult to regulate as compared to distinct "point sources" like sewage plants and factories. For that reason, regulation of non-point source pollution under the Clean Water Act has lagged far behind point source regulation. To control water pollution from non-point source activities like livestock grazing, regulators rely on public land managers and livestock owners to implement Best Management Practices (BMPs) which research and experience have shown are effective in controlling water pollution if applied correctly in the appropriate locations." -Campaign to Reform Public Land Grazing in Northern California

"The ecological costs of livestock grazing exceed that of any other western land use. In the arid West, livestock grazing is the most widespread cause of species endangerment. By destroying vegetation, damaging wildlife habitats and disrupting natural processes, livestock grazing wreaks ecological havoc...causing significant harm to species and the ecosystems on which they depend." -Center for Biological Diversity

"In the United States, livestock grazing has contributed to the listing of 22 percent of federal threatened and endangered species — almost equal to logging (12 percent) and mining (11 percent) combined. Nationwide, livestock grazing is the 4th major cause of species endangerment and the 2nd major cause of endangerment of plant species. No other human activity in the West is as responsible for the decline or loss of species as is livestock production." -Sierra Club Grassroots Network

"Explanation: Livestock grazing alters the structure, diversity, and growth pattern of vegetation, which affects the associated insect community. Grazing during a time when flowers are already scarce may result in insufficient forage for pollinators. Grazing when butterfly larvae are active on host plants can result in larval mortality and high intensity grazing can cause local loss of forb abundance and diversity." -Pollinator-Friendly Best Management Practices for Federal Land

Siskiyou Crest Public Lands Grazing Photo Essay

Cows within the Applegate Grazing Complex eat down available forage, depleting available food for native wildlife, especially elk populations that are struggling to repopulate the Siskiyou Mountains after being extirpated in the early 1900s. Notice that this intensively grazed area has been "over-utilized" and herbaceous species are not setting seed due to intensive cattle grazing.

Cows within the Applegate Grazing Complex trample wetland habitats and denude them of vegetation, impacting aquatic invertebrates, water quality, bird habitat, and creating massive soil compaction that has long-lasting hydrological impacts.

In many areas on the Siskiyou Crest, dry slopes are denuded of all vegetation by cows, eliminating important plants for wildlife and creating erosion. Dry bunchgrass meadows have been particularly hard hit on the Siskiyou Crest, creating "cattle barrens" devoid of vegetation.

Willow welands are important habitat for the willow flycatcher.  This photo demonstrates how cows within the Applegate Grazing Complex are destroying willow habitat in wetlands and along streams.

Cows within the Applegate Grazing Complex trample wetland habitats and denude them of vegetation, impacting aquatic invertebrates, water quality, bird habitat, and creating massive soil compaction that has long-lasting hydrological impacts.

Aspen is an uncommon tree species in the Siskiyou Mountains and within the Applegate Grazing Complex; however, cows are having a major impact on their ability to spread and survive. This photo demonstrates how cows are denuding the new shoots of aspen that are needed for their continued reproduction and survival. 

Cows within the Applegate Grazing Complex trample wetland habitats and denude them of vegetation, impacting aquatic invertebrates, water quality, bird habitat, and creating massive soil compaction that has long-lasting hydrological impacts.

A cattle exclusion fence on the Siskiyou Crest demonstrates the stark contrast between areas where cows are allowed to graze in wet meadows, and what that habitat would look like after a few years of cattle exclusion. 

Within the cattle exclusion fence the native plants are protected from overgrazing.  Marsh grass of parnassus (Parnassia palustris), a flowering wetland species, provides forage for native bees and other pollinators within the cattle exclusion fence. Outside the fence there are no flowers available for bee forage due to overgrazing.

Once overgrazed and barren like you see outside the fence, the area within the cattle exclusion fence has been allowed to heal and provide floral resources for native pollinators again.

The stark reality: Overgrazed versus recovering habitat where native plants can flower and go to seed, ensuring their survival and long-term presence in the area.

Cows on the Siskiyou Crest

Cows on the Siskiyou Crest

Cows on the Siskiyou Crest

Cows on the Siskiyou Crest