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This page was last updated on January 06, 2009 .

An Open Letter to the Sierra Club Board of Directors in support of a "Zero-Cud" Conservation Policy
July 16, 1999

The Bureau of Land Management Has Failed to Implement the Federal Land Policy and Management Act of October 21, 1976

In One Third of the Nation's Land: A Report to the President and to the Congress by the Public Land Law Review Commission (1970), the commission found:

The result of present practices is an over-commitment of land to support recognized dependent properties; continued pressure to upgrade forage production on land that should be removed from the recognized grazing land base; and a continuous pressure to satisfy the standing deficit of permitted use grazing capacity assigned to qualified base properties many years ago. (page 108)


Historically, all public lands which could be physically negotiated by livestock have been grazed. Lands with steep topography and unsuitable soils, as well as lands in delicate ecological balance have been subjected to such use. Failure to recognize the limitations imposed by nature on lands of this sort has caused extensive damage to property and other resources and has required massive expenditures for rehabilitation. The results have not been desirable for either the livestock operators or society.

Such frail and deteriorated lands should be identified, as well as those chiefly valuable for grazing. Once identified they should be classified as lands not suitable for grazing, and we recommend that grazing in such areas should be prohibited to the fullest extent practicable. (page 116)

These passages accurately portray the situation as it exists to this very day. This is in spite of passage of the Federal Land Policy and Management Act (FLPMA) of 1976 in which, among many other things,

... The Congress declares that it is the policy of the United States that ...

(8) the public lands be managed in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resources, and archeological values; that, where appropriate, will preserve and protect certain public lands in their natural condition; that will provide food and habitat for fish and wildlife and domestic animals; and that will provide for outdoor recreation and human occupancy and use; (Sec. 101(a)(8))

Given the livestock grazing situation described by the Public Land Law Review Commission, it should be more than obvious that the policy set forth in FLPMA Sec. 101(a)(8) cannot be satisfied with regards to any use other than domestic animals without the Bureau of Land Management (BLM) making very substantial reductions in both the extent of lands being grazed and the magnitude of grazing on lands that are grazed.

It should be equally obvious from the graph on the preceding page (compiled from Public Land Statistics 1976-1999) that the needed reductions in livestock impact subsequent to 1976 have yet to be addressed in the twenty-three years (nearly a quarter of a century) since passage of FLPMA! The exigency of the situation is such that present efforts which tinker around the edges with grazing systems, temporary non-use, riparian fencing, land and vegetation treatments, and so forth pale to insignificance.

While more difficult to document, the situation is similar where National Forests, Military Reservations, Reclamation Projects, and even National Wildlife Refuges and National Parks and Monuments are being grazed.

What does this have to do with the Sierra Club's "Grazing on Public Lands Policy"? First, that policy is so broad that you could drive a truck through it. Second, it is not dissimilar from goals, objectives, and other rhetoric contained in BLM and other federal agency land use plans and environmental impact statements. As I again refer to the graph, this just has not worked, and there are no indications that it can be expected to work in the future.

The vast areas of public lands that make up our natural heritage in the west have the potential to serve as interconnected reservoirs and buffers for biological diversity (both terrestrial and aquatic) and watershed stability. Given the value of this potential contribution to ecological integrity, and the role that such a network of biodiversity reserves could play in mitigating the adverse habitat impacts from development of private lands, I recommend that the Sierra Club seriously give consideration to adopting a Conservation policy opposing grazing on public lands.

We just do not know as much as we thought we did about the ability of the arid and semi-arid lands of the west to support any level of grazing while maintaining the biological integrity of endemic organisms and the hydrologic functions of watersheds. The plight of the western sage grouse is a case in point. When such a widespread and previously abundant species approaches the point of qualifying for listing under the Endangered Species Act, it should serve as a red flag that entire ecosystems are at risk. Until such situations can be reversed and we know with certainty just which ecosystems can be grazed and under what circumstances without detracting from the inherent biodiversity and watershed stability, grazing on public lands should be the exception-rather than the rule!

My background for making these statements is that I grew up on ranches in northern New Mexico, I hold a B.S. (with honors) from New Mexico State University with a major in Range Management, and I recently retired as a Range Conservationist on the staff of the Oregon/Washington State Director of BLM after thirty-one years of federal service. My qualifications for submitting these statements to the Sierra Club Board of Directors are that I am a member in good standing (at least so far) of Sierra Club.


Larry Walker
(street address omitted from web version)
Portland, OR

Copies of the following materials were attached to the letter: