June 3, 2002

Aaron Harp, Director
University of Idaho
Caldwell Research and Extension Center
16952 S. Tenth Avenue
Caldwell, ID 83607-8249

Dear Mr. Harp:

We read with great interest about your proposal to do a report on our public lands grazing permit retirement concept. We welcome your study and hope that you will consider the following issues and information in the report.

COST OF GOVERNMENT MANAGEMENT. What is the economic cost to the government of public lands grazing? We hope you will include all costs including the preparation of allotment management plans, Environmental Impact Statements, and other documentation that is required before livestock grazing occurs. Many have argued (Donahue 1999, Jacobs 1991) that costs of managing livestock on public lands vastly exceed revenues.

IMPACTS ON WILDLIFE. What are the wildlife values precluded by continued livestock production? In other words, is the presence of livestock preempting greater production of native wildlife on these public lands?

For instance, one cow consumes the same amount of forage as 1.5 elk and 5 deer. How many more elk, deer, or antelope, or even prairie dogs would be produced on our public lands in the absence of forage competition with livestock? Elk, for instance, have high value to hunters, wildlife watchers, and as prey for other charismatic wildlife like wolves and grizzlies. How many more wolves, for example, could be supported by the additional elk?

Another way of saying this is, what is the economic value of reallocating the forage now consumed by livestock to native herbivores like elk, bighorn sheep, and other species? Every economic study done comparing elk, deer, trout, waterfowl, wolves and even songbirds to livestock demonstrates that native wildlife has a higher economic value (Duffield et al 1994, Campbell 1970, Loomis et al. 1989, Duffield 1989).

The single biggest factor affecting hunting opportunities is competition between livestock and wildlife for forage and water. For instance, a study of antelope and domestic livestock in New Mexico showed that pronghorn diets overlapped 39% with domestic sheep and 16% with cattle (Howard et al. 1990) And Mackie (1970) reported forage competition between deer, elk and livestock in Montana's Missouri Breaks. Similar findings of dietary overlap of deer and elk with livestock were reported in Oregon (Miller and Vavra. 1982) and Alberta (Teller 1994).

Moreover, the mere presence of domestic livestock often causes a shift in habitat use by native species. Often these shifts place native ungulates in less suitable habitats with a resulting decline in vigor and survival. For instance, mule deer were found to shift their habitat use in response to livestock (Lott et al. 1991). Elk in Montana also moved out of
pastures that were actively grazed by cattle (Frisina, M.R. 1992). Elk and mule deer in Arizona also decreased after cattle were introduced (Wallace and Krausman 1987). And both deer and elk shifted use from preferred habitats in Alberta after livestock were introduced into the area (Teller 1994).

Many gamebirds are also negatively affected by livestock production. For instance, sage grouse populations are in decline throughout the West due to a host of problems created by livestock production (Connelly et. al. 2000). Loss of hiding cover in heavily grazed rangelands exposes nesting grouse and other species like quail and sandhill crane to higher predation rates (Gregg et. al 1994, Brown 1982, Littlefield and Paullin 1990). Grazing of wet meadows used by grouse chicks reduces food availability and increases losses to predators. And fences used to contain livestock become perching sites for avian raptors that prey on grouse. Haying operations, along with grazing, negatively impacts many ground nesting bird species (Kirsh et al. 1978). Waterfowl production also suffers as a result of grazing and haying operations, which reduce hiding cover and result in higher nest failures (Greenwood et. al. 1988, Gilbert et al. 1996).

Disease transmission is another problem. Many bighorn sheep herds in the West are decimated by disease transmitted from domestic livestock (Goodson. 1982, Berger 1990, Krausman et al. 1996). Indeed, the presence of domestic livestock is the major factor that precludes the restoration of wild sheep to many former, but potentially suitable ranges throughout the West.

WEEDS AND COWS. Livestock are considered a major factor in the spread of weeds. What is the cost to the public of controlling weeds? What are the costs to ecosystem values, such as reduced forage for wildlife because of the spread of exotic plant species (Belsky and Gelbard. 2000, LeJeune and Seastedt 2001)? Trampling of biocrusts by livestock can also facilitate weed colonization and spread (Belnap et. al 2001). What are the ecological and economic costs?

EFFECTS ON FIRE REGIMES. Livestock, by trampling soils and reducing the competitive pressures of grass plants, facilitate an increase in trees. High stocking rates are implicated in structural changes in western forest ecosystems that are causing higher fire suppression costs. (Baker, and Ehle 2001,Cave and Patten 1984, Rummell 1951).

RIPARIAN DAMAGE AND COSTS. Because livestock are known to damage riparian areas, significant funds are being used to mitigate this damage, including fencing of streams, development of water sources, and so forth. Proposed solutions like fencing riparian zones are exceedingly costly and have other ecological consequences as well (Platts and Wagstaff 1984). What are these costs?

Sport and commercial fisheries are also affected by livestock production. Livestock trampling of streamside riparian habitat has greatly altered aquatic habitats (Chaney et al. 1990, Kauffman and. Krueger. 1984) reducing their carrying capacity for native fish. Livestock grazing is responsible for major declines in fish populations throughout the West, in particular species sought after by anglers such as trout and salmon (Li, et al. 1994, Dudley and Emburgy 1995, Duff 1977, Platts 1981, Shepard 1992). Comparisons of trout populations in ungrazed streams have demonstratively higher numbers of trout than grazed sections (Marcuson 1997, Keller and Burnham 1982).

In addition to these direct impacts to fish habitat from livestock trampling and grazing, livestock production accounts for the greatest water withdrawals in the West (Reisner and Bates 1990). Irrigation, particularly of hay and alfalfa, is the largest consumer of water in the West and one of the major factors in the decline of native fish due to stream dewatering (Minckley and Deacon 1990, Moyle and Williams 1990). Loss of fish in irrigation ditches is also significant problem (Good and Kronberg 1986). Needless to say, dewatering not only causes a decline in water quality with higher temperatures and greater concentration of pollutants, but also eliminates spawning and feeding habitat for fish.

Trampling and degradation of riparian zones and watersheds also contributes to greater flooding (Campbell, 1970, Chaney 1990). What are these costs?

RECREATIONAL CONFLICTS. What are the effects of livestock production on recreation? Many backpackers, hikers, bird watchers, anglers, and others tend to avoid places that are actively being grazed. What is the economic cost of this potentially lost income to local communities?

BASE RATE OF RANCH CONVERSION. What is the base rate of ranch subdivision in the West? One can't assume that all ranches that are subdivided following permit retirement would be the result of permit retirement without some estimate of the baseline rate. Right now nearly all subdivisions occur on former agricultural lands of some kind, despite having access to public lands grazing allotments. According to one study in California, ranchers make more money through real estate appreciation than from raising livestock (Huntsinger 2002). This is one reason why ranchers are often anxious to sell to developers. So what is this base rate of conversion?

WATER QUALITY AND QUANITIES. What are the effects and costs on water quality and quantity? Trampling of soils and compaction reduces water infiltration and increases run-off. Cow manure and urine pollutes streams (Strand and Merritt. l999, J. Carter 2001).

Livestock forage production (e.g. hay) is the major consumer of western water in every state (Reiser and Bates 1990). Yet the cost of providing this water is heavily subsidized Reiser and Bates 1990, Myers and Kent 1998) in multiple ways, including the cost of water storage impoundments and delivery systems. Even the electricity used to power irrigation systems is often subsidized (Myers and Kent 1998)

EFFECTS OF LIVESTOCK WATER DEVELOPMENT ON MOLLUSKS. Development of springs as water sources for livestock is a common practice on public lands. What effect does this have on native snails, amphibians, and other species dependent on these water sources for their habitat (Frest and Johannes 1995)?

ECONOMICS OF PUBLIC LANDS FORAGE. What is the economic contribution of public lands forage to the West's total economy? According to Power (1996) the amount of economic contribution made by public forage is insignificant in regional economies. The 1994 Rangeland Reform (USDA 1994) published by the federal government also noted that federal lands forage contributed little to overall livestock production and economics. So what contribution does the public AUMs make relative to the total contribution of livestock agriculture to the employment and income of the West?

Assuming there is no permit retirement program, what will happen to permittees over the long run in the absence of a program? In other words will ranching grow even less economically viable and more marginal in the future (Knight et al. 2002)?

What is the economic value of the permits turned to cash and reinvested? I.e., ranchers will be spending their money to reduce debt, invest in new land, or otherwise using that money for other economic endeavors.

SOIL EROSION AND BIOCRUSTS. What is the economic cost of soil erosion occurring as a result of livestock production? This should also include an analysis of soil nutrient losses due to trampling of bio-crusts which would otherwise contribute to soil nitrogen and other nutrients ( Anderson et al. 1982, Anderson et al 1981. Belnap. 1996, Belnap et al. 2001)

SPECIES ENDANGERMENT. Livestock production is the second leading cause of species endangerment in the US according to the USDA (1997a). How much are we spending to save species endangered by livestock production? What is the potential cost to ecosystem stability resulting from the loss of these species?

CONDOS AND COWS. In the so-called condos and cows debate, one assumption is that urbanization is affecting a significant amount of the West. However, a review of published data do not support this notion (USDA. 1997b, Vesterby and Krupa. 2001). Even in California, the most urbanized state in the West, agricultural land use vastly exceeds the amount of land urbanized and developed (California Natural Heritage Division 2002). Please explicitly provide the total acreage or physical footprint of urbanized areas in the West by state (information available through USDA web site and state GAP analyses) and compare this to the amount of land used to support livestock production, including lands used for grazing, haying, and so forth (Wuerthner 1994, Wuerthner 1997).

Agriculture uses many resources in the West including water, yet contributes little overall to the economy. For instance, in California, agriculture uses 85% of the water consumed in the state but only contributes to 3% of the economy (Myers and Kent 1998). This suggests that development actually contributes more to the regional economy than agriculture. Assuming some ranches are subdivided and built upon, what are the economic contributions of that development-if any-compared to the regional economy.

Much development and new housing in the West is driven by immigration of new residents (Vesterby and Krupa 2001). How can ranching do anything to prevent this immigration?

Throughout the West the growing of irrigated crops including hay and other forage for livestock is the major consumer of water (Reiser and Bates 1990). In general urbanization actually uses less water per "acre" of land developed than most agricultural operations. What is the effective water savings of reducing or eliminating livestock in terms of freeing up water for other uses such as preservation of fish or other wildlife?

What is the cost in property taxes to have ranching continue in the West? I.e., in most cases ranch lands are taxed as "agricultural property," a much lower rate than is paid by owners of other types of property. Other taxpayers are, in effect, subsidizing the low tax rate of ranchers (Spahr and Sunderman 1996).

How many ranchers expect to sell their ranch for development? A recent article in the Journal of Range Management ( Petersen and Coppock 2001) found that about half of all permittees surveyed were planning to sell their property for development, and others were clearly thinking about it if the economics continued to be marginal-a likely scenario.

What is the geographical distribution of development? This is a critical point since not all parts of the West are vulnerable to rapid development. Most development occurs as growth on the outskirts of existing cities or the occasional resort area where jobs, housing and other amenities are easily obtained (Kolankiewicz and Beck. 2001, Wuerthner 1997).

What role does demand, thus rising land prices, have in driving development and subdivision? In other words, when land prices rise, prospective buyers cannot consider buying a ranch and paying off the mortgage by simply selling cows. This reduces the flexibility of the livestock industry to adjust to changing market demands. Even in California, which possesses the most valuable agricultural lands in the nation, marginal agricultural production cannot complete with urbanized land uses (California Dept. of Conservation. 2000, California Dept. of Food and Agriculture. 1998), so how can even less valuable western livestock operations compete against rising land values and development?

What role does global competition play in marginalizing western ranching operations, and thus contributing to the sale of the ranch?

What other recognized and proven means of reducing or preventing sprawl exist? For example, Oregon has strong land use laws that curb rural development and urban sprawl. Florida is currently attempting to purchase half of the private land in the state to protect its biological values and recreational opportunities ( Florida Dept. of Environmental Protection and Greenways Program. 2001). What proven alternatives are available for protecting rural and undeveloped private lands?

What might the future of ranching be in the face of growing concerns over the health impacts of eating meat? For example, the discovery of "mad cow disease" in Europe has brought about a significant reduction in meat consumption in Europe (Lyman 1998). New revelations about the negative effects of a meat diet occur on a regular basis, including both meat-borne pathogens and "lifestyle" illnesses such as obesity and colon cancer.

Are western livestock operations viable over the long-term? If open space protection is predicated on ranching, then any major economic change could seriously jeopardize this strategy.

If you have any questions, I may be reached at:

PO Box 3156
Eugene, OR 97403
541/684-7872 voice
541/684-7872 fax
wuerthne@teleport.com

Thank you for your consideration.

Sincerely,

George Wuerthner
Western Representative, NPLGC

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