Letter on the APR Bison Grazing Plan

Dear BLM,

These comments are directed to the proposal you have received from American Prairie Reserve (APR) requesting major modifications to the 18 grazing allotments controlled by APR.

This request would change the class of livestock from cattle to bison and extend the grazing season to permit year-round grazing for bison with the bison restricted to a proposed “fortified external boundary fence”. According to the information included with The Glasgow Courier article of Wednesday, March 28, 2018, this request will be analyzed in one Environmental Assessment (EA).

My comments are directed to the process identified by the BLM which is being used to consider the APR request:

An Environmental Assessment (EA) would be the correct procedure if the underlying question had been identified within the original Environmental Impact Statement (EIS). Most if not all of these grazing allotments were included within the CMR Final Environmental Impact Statement of August 1985. There was never any consideration for the single-species management of these public lands for bison contained within the original EIS.

In order for the BLM to consider this request with an Environmental Assessment it will be first necessary to revisit the original EIS and its reliance on the multi-species usage of these public lands.

The proposed “fortified external boundary” will not only keep the bison within the identified area but will also keep out all of the other native species that have historically used these public lands.

The original EIS envisioned limited grazing (seasonal) because of the native species that also rely on these public grounds for grazing and habitat. The proposed “fortified external boundary” will have a major impact on the movement of native species in and around the requested area.

There is no Environmental Impact Statement foundation for the use of an Environmental Assessment regarding this request because it is not simply a request to replace cattle with bison.

Removing a substantial portion of public ground from historic use will require modifications to the underlying EIS and extensive study to determine the impact on the rest of the ecosystem and the other affected native species.

This request would also appear to ignore the historic public’s use and access to these public lands and, if permitted, will effectively remove these public lands from public use and enjoyment to the exclusive use and benefit of the American Prairie Reserve group.

It is hard for me to believe that this request would make it to an actual review given that it is contrary to everything that provided the historic basis for the seasonal usage for cattle (non-native species) in the first place. For the BLM to permit these changes to the historic use of these public lands would amount to giving the public ground to the American Prairie Reserve for their exclusive use without offering the property up for sale to the public first.

The fact that the BLM is considering this request using an Environmental Assessment, rather than going back and revisiting the underlying Environmental Impact Statement first, will find this request in court as an overstep of BLM authority.

It is difficult to consider this request on its merits under the circumstances. I hope that the BLM will stop this process and go back to the underlying EIS to make a serious study of this request. This evaluation needs to identify the true impacts to both the surrounding native species who rely on these public lands and on the public’s use and enjoyment of these public lands.

Should you have any questions regarding these comments please feel free to contact me at 406-688-8466.

Sincerely,

John E Lamb

Land Use Planner (Ret.)