The American Sheep Industry Association joined the National Cattlemen’s Beef Association and the Public Lands Council in taking the opportunity to provide comment on the U.S. Forest Service’s proposal to amend the regulations related to nonmonetary settlement when unauthorized or excess grazing is determined to be non-willful.
“The livestock groups appreciate the agency’s efforts to respond to recommendations made by the Government Accountability Office (GAO) in their 2016 report to Congress entitled “Unauthorized Grazing: Actions Needed to Improve Tracking and Deterrence Efforts” (GAO-16-559). Among the recommendations in that report is a recognition that the USFS authority and policy for identifying, documenting, and remedying incidents of unauthorized and excess grazing lacked the nuance applied by other agencies, including those employed by the Bureau of Land Management in similar situations.
“Efforts to bring USFS policy into conformance with BLM policy will, in this situation, provide a great deal of clarity and reduce uncertainty for permittees who hold permits from both agencies. Further, federal agencies have sought to employ similar, complementary policies across agencies to facilitate ease of federal implementation. The livestock groups appreciate the efforts to do the same here.
“In the case of non-willful excess or unauthorized use, personal interaction should be the first step to allow a remedy to occur. The notice of proposed rulemaking provided that: ‘Informal resolution involves the permittee or non-permittee removing the livestock following a phone call from or face-to-face conversation with the authorized officer.’ The livestock groups wish to emphasize that in cases of informal resolution, livestock should not be removed by anyone other than the permittee responsible for the livestock, or an authorized officer. While the livestock groups do not believe the intent of the proposal is to provide for a non-permittee to remove livestock that do not belong to them or livestock for which they are not responsible, the groups believe clarification is warranted.
The letter also addressed the definition of “non-willful” unauthorized or excess use and addressed forage consumption.
Many affiliates of the national organizations signed onto the letter including the Montana and Wyoming Stock Growers Associations, South Dakota Cattlemen’s Association, Montana Public Lands Council, and the Wyoming Wool Growers Association.
American Sheep Industry
Montana Stock Growers Association