INTRODUCTION
The Bureau of Land Management (BLM) administers certain public lands, within which cattle grazing allotments are present. BLM has a mandate to ensure that within those grazing allotments the rangeland condition is managed in a condition of "sustained yield". That is, the cattle grazing should not lead to long term depletion of the resource (forage/browse). To this end the number of cattle per allotment is determined by an animal unit per month (AUM), which is defined as the amount of forage needed to sustain one cow and her calf, one horse, or five sheep or goats for a month.
BLM proposes to acquire land now held privately, in order to improve access to public lands. They intend to fold that land into an existing allotment without first evaluating the range condition and determining that it is in a condition of sustained yield. This goes against their mandate of managing public lands for a variety of uses while ensuring natural, cultural, and historic resources are maintained for the present and future use.
COMMENTS
March 28th, 2021
BLM Safford Field Office,
Attn: Scott Cooke,
711 South 14th Avenue,
Safford, AZ 85546
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Re: Aravaipa Canyon Recreation Access and Wildlife Corridor Land Acquisition. DOI-BLM-AZ-G010-2021-0011-EA. Public Comments Due 4-2-21
Dear Mr. Cooke:
I have reviewed the Draft Environmental Assessment for the Aravaipa Canyon Recreation Access and Wildlife Corridor Land Acquisition (EA). The EA analyzes and discloses the potential environmental effects of the proposal by the Bureau of Land Management (BLM) to acquire 2,802 acres of private land (the Proposed Action). I approve of the Proposed Action, but am concerned about Issue 4 in Section 1.6 of the EA: How would land acquisition affect the grazing permit/lease for the existing grazing allotments?
Section 3.4.3 of the EA states “The Aravaipa South Allotment would gain 2,440 BLM-administered acres and would change from 168 AUMs to 522 AUMs (based on current use rates for public land AUMs on the allotment) and the corresponding change in number of head permitted would change from 14 cattle-year-long to 43 cattle-year-long.” The number of AUMs and head of cattle should not be tripled until a formal evaluation of range condition is completed.
BLM has a backlog of permits needing evaluation for renewal, which has been increasing for more than a decade. To allow for continuity in grazing operations, Section 3023 of Public Law (P.L.) 113-291 made permanent the automatic renewal (until the evaluation process is complete) of permits and leases that expire or are transferred. However, (Section 3023) does not allow for an increase in AUMs and/or head of cattle, merely for an automatic renewal of the previous lease. Given that those 2,440 acres of private lands will be folded into the existing South Aravaipa allotment, and were undoubtedly used by the owner for grazing, those acres must be formally evaluated before additional AUMs are added to the existing South Aravaipa allotment.
BLM is directed by Congress to manage the public rangelands to achieve multiple use and sustained yield of the renewable resources. The BLM must not increase the AUMs and number of cattle in the grazing permit for the South Aravaipa allotment until a formal rangeland health assessment has been completed that determines rangeland condition is in a condition of sustained yield.
When responses to these comments are available, please email those or notify me where they can be viewed if they are posted for public viewing on your website.
Sincerely yours,
Janet Fox, B.S.
Senior Reviewer (Associate in Arizona)
Environmental Review Workshop
(Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Corporation)
1792 Rogers Avenue
San Jose, CA 95112