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Grayback Mtn-Bigelow Lakes & Cows Action Alert

Help Protect Grayback Mountain!

Comment on the Big Grayback Grazing Allotment.

Comments are due March 13, 2005.
Cows trample-graze Bigelow Lakes Botanical Area
Cows trample-graze Bigelow Lakes Botanical Area
The Big Grayback Allotment encompasses almost 20,000 acres on Grayback Mountain, in the Siskiyou Mountains of Southern Oregon. The allotment includes a wide variety of ecotypes, including many sensitive riparian areas, areas of unusual botanical diversity, high Siskiyou meadows, and ancient forest.

Brief Sample Comment Letter (add in points from fact sheet-see below):
March X, 2005

Erin Connelly, District Ranger

Applegate Ranger District, RRNF

6941 Upper Applegate Rd.

Jacksonville, OR 97530

(email:  comments-pacificnorthwest-rogueriver-applegate@fs.fed.us)

Re: Environmental Assessment for the Big Grayback Allotment AMP Update

Dear Erin Connelly and Applegate Ranger District,

I am writing to express my concern regarding the serious impacts that continue to occur as a result of the Big Grayback Allotment. The EA understates and does not adequately analyze the environmental impact resulting from cattle grazing on water, botanical, wildlife, and recreational resources, and instead promotes an expansion in extent and duration of grazing activity on Grayback Mountain. The area is extremely sensitive, containing numerous springs, streams, wet meadows and lakes that support populations of rare and sensitive plant species. The Bigelow Lakes area has been particularly hard-hit by grazing that has been well-documented by local citizens.

The permittee's history of violations in extent, intensity, and duration of grazing activity does not inspire confidence in the ability of the Forest Service to continue grazing in a manner consistent with the Aquatic Conservation Strategy and the National Forest Management Act. The permittee, as you are well aware, pays extremely low fees ($379 per year) to the Forest Service and chronically violates the terms of his grazing permit and tramples various popular recreation sites including miles of trails, streams, and the Bigelow Lakes Botanical Area.

Lastly, the Forest Service's attempt to redraw the boundary of the Allotment is ridiculous. The "Buck Peak Agreement" has been unknown to the public, and the Forest Service has in the past threatened the permittee with cancellation or limitation of grazing due to trespassing in the Bigelow Lakes Botanical Area. The Forest Service is wasting the public's time by suddenly revisiting and redrawing boundaries. We urge the removal of all cows on Grayback Mountain, as neither the Forest Service nor the permittee has demonstrated the intent or ability to protect the natural environment of Grayback Mountain.

Sincerely, Your Name

Grayback Facts

3,942 acres or 20% of the allotment are designated as "riparian reserves" under the Northwest Forest Plan.

The permittee pays $379 per year in fees to graze cattle. ($1.35 per AUM)

The Forest Service has redrawn the boundary of the Big Grayback Allotment. The "Buck Peak Agreement," which the Forest Service claims caused the inclusion of the Bigelow Lakes Botanical Areas into the allotment area, was not publicly reviewed, nor should it be used as a reasonable starting point for consideration of this allotment. Given the well-documented, repeated history of degradation in these areas, it is unreasonable for the Forest Service to propose including them in the Allotment. The Forest Service claims regarding the Grayback Allotment boundary are particularly outlandish considering the Forest Service, in many discussions and communications in the past several years, has regarded the Bigelow Lakes as outside the allotment boundary. Furthermore, the Forest Service sent a letter to the permit holder which instructed him to "take corrective action and demonstrate your ability to keep your livestock within your allotment boundaries throughout the grazing season, and remove them by the off-date specified in your grazing permit. Failure to do so will result in permit action in the form of partial or full suspension or cancellation of your permit." The letter was sent in response to repeated instances where the permittee's cattle were found to be damaging the Bigelow Lakes area—an area which the Forest Service clearly considered to be outside the allotment boundary.

Oregon Caves National Monument has asked the Forest Service to remove cows from the Lake Creek Watershed (the drinking water source for the Monument). In a letter to the Forest Service they warned that "the potential of cattle in the watershed poses a significant threat to this public water system from contamination by cryptosporidium."

Trespass violations: Annually, the cows trespass into the Bigelow Lakes Botanical Area and cause significant damage to the lakes, streams, and springs in the area. Cows also pollute Lake Creek below Bigelow Lakes. This stream is the water source for the Oregon Caves National Monument.

Botanical areas: In addition to the Bigelow Lakes Botanical Area the Miller Lake Botanical Area is also being degraded by cattle grazing because of the Big Grayback Allotment.

On/off date: The permittee regularly has failed to retrieve the cows by the off-date (September 30th). Often the permittee has allowed his cattle to stay out on the allotment into November.
The mitigation measures proposed in many of the alternatives—fencing, herding, and the salting away from sensitive areas—will not be successful. Although the Forest Service asserts that the allotment's history of trespassing and overutilization is "out of scope", we assert that this is not out of scope because the history of degradation and inability to control cattle movement establishes the unlikelihood that anything short of removal of cattle from high altitude areas will be successful.

The analysis of rare and sensitive plants included in Appendix B is inadequate, and it contains unfounded assumptions about the possible effects of the future grazing regime. Essentially, the Forest Service has failed to establish an adequate baseline in this case from which to measure the impacts on various rare and sensitive species.

The EA fails to adequately analyze cumulative effects to the Carberry and Grayback/Sucker watersheds. The sensitivity of their analysis is inadequate to detect the significant cumulative impact of numerous past, current, and proposed actions on these watersheds.

The Forest Service should not attribute all negative impacts to long-ago grazing activities, as field monitoring has indicated substantial soil and vegetation disturbance associated with recent grazing activity under the current permit.


homepage: homepage: http://www.oregonwaters.org
phone: phone: 541-251-FLOW