Comments regarding livestock grazing on state wildlife areas
Conservation Northwest / Sep 25, 2020 / Public Lands, Ranching, Sagelands, WDFW
Ecological objectives, particularly fish, wildlife and habitat values, must take priority over grazing or other private commercial uses on State Wildlife Areas. We respect that in some cases grazing may occur on State Wildlife Areas, but only with proper guidelines and stewardship.
The Washington Department of Fish and Wildlife (WDFW) has been updating its policies for livestock grazing on State Wildlife Areas and other Department lands. Conservation Northwest engaged early in this process, providing initial feedback, as well as submitting organizational comments (available as a PDF) during this month’s public input period.
The WDFW Mission is to preserve, protect and perpetuate fish, wildlife and ecosystems while providing sustainable fish and wildlife, recreation, and commercial opportunities. The roughly one million acres of public land in 33 wildlife areas managed by WDFW provide essential fish and wildlife habitat, including for many threatened and endangered species, as well as First Foods and other culturally important species. WDFW lands contribute to landscape habitat connectivity with other public lands, and provide other crucial ecological services.
State Wildlife Areas are not “multiple use” lands in the same manner as federal national forests managed by the Department of Agriculture’s U.S. Forest Service, or state public lands managed by the Washington Department of Natural Resources (DNR).
State Wildlife Areas were purchased with the primary objective of maintaining and protecting a variety of fish and wildlife species and the habitats needed for them to survive, as well as providing the public access to fish and wildlife opportunities—from birding and wildlife watching to fishing and hunting.
We strongly believe that ecological objectives, particularly fish, wildlife and habitat needs and values, must take priority over grazing or other private commercial uses on State Wildlife Areas. This prioritization is reflected in our comments.
Overall, WDFW presents a reasonable approach to considering and authorizing grazing on State Wildlife Areas. Still, there is room for improvement.
For instance, the section on the role of grazing to meet WDFW mission presents grazing benefits, but nothing on potential negative effects. It comes across as a pitch, rather than a fair assessment of risks and opportunities. Addressing risks openly and evenly will improve the utility of the guidance document.
Other feedback (September 2020):
- Clearly define the ecological or habitat objectives for which grazing may be used as a tool, and monitor using quantifiable metrics to assess whether or not these objectives are being achieved. Establish as a condition of range use the attainment of ecological or habitat objectives, including after fire. Provide sufficient resources for regular monitoring and evaluation, and annually review and adjust plans as needed to meet ecological and wildlife habitat objectives.
- Better incorporate information into management guidance about harmful impacts of fencing, especially with respect to habitat connectivity and collision hazard. Mark, modify or remove fencing interfering with wildlife recovery or habitat permeability. When building or replacing fencing, use wildlife and bird compatible fencing.
- Identify WDFW lands to hold in reserve to provide emergency pasture in case of fire or wildlife conflict. Our experiences over the last decade, last six months, and last two weeks highlight the critical need to plan and prepare for emergencies. As the climate warms, weather will become more unpredictable and lands more susceptible to fire events. As the region’s population grows and recreation pressures increase, it’s likely that the number of human-caused fires will also increase. There are also places in Washington with persistent, ongoing conflicts with livestock or risk of conflict that could be best addressed by providing alternative range. This guidance document is the appropriate place and time to address the growing need for significant reserve lands for emergency use.
- Specify more clearly the conditions for termination for non-compliance. Clear communication on the terms of the agreement will benefit all parties. The guidance document should be very clear that grazing requires active herd management and supervision, supported by monitoring and evaluation by WDFW. A checklist alone is not sufficient.
- For monitoring, establish benchmark values for riparian and species-specific habitat conditions and monitor annually (not “attempt”; do!) to ensure habitat conditions exist.
Additional background, feedback and talking points on livestock grazing on Washington’s State Wildlife Areas
Each purchase of lands for Washington’s State Wildlife Areas was critically analyzed for wildlife and recreation values and typically required a diverse partnership of stakeholders to recommend that the acquisition should occur in a way that protected the community character while spending public dollars.
Often, commercial uses of these lands, such as grazing or timber harvesting, occurred before the purchase was made. Frequently, private landowners sold these lands to the state via WDFW with the promise that managed grazing would be allowed to continue. That agreement made sense to all parties to obtain the lands for wildlife and public access, and yet allow livestock grazing where this was compatible with WDFW’s mission. We respect that in some cases grazing and other commercial uses may continue to occur on State Wildlife Areas, but only with proper guidelines and stewardship.
Proper grazing takes considerable active management, monitoring and evaluation in a grazing management plan, especially where maintenance of the ecological integrity of the landscape is priority number one. This has become more evident with the advance of large mega-fires, increasing use of wildlife lands for year-round outdoor recreation, and livestock conflicts arising from predators such as cougars, coyotes and most recently wolves.
Ranchers who continue to graze on WDFW Wildlife lands will be required to stay flexible and adaptive if the primary goal of WDFW is to manage for coexistence with all wildlife, as well as the values of all Washingtonians. Requirements of stocking rates, timing of grazing, post-fire rest, and avoidance of conflict with predators and recreationists will all be expected and under careful scrutiny to maintain grazing as a compatible use.
Impacts from grazing will need to be evaluated not only for maintaining the forage base, but for grazing effects on all of the fish and wildlife using that land. Where that is being accomplished to the benefit of both the wildlife and grazing operation, it will be proof of the potential for compatible uses of our lands. Where it is not being done, adjustments will need to be made, and where the grazing management plan is just not being followed putting wildlife species at risk, grazing may need to be discontinued to avoid grazing–related damage to the resources of the state. Not all State Wildlife Areas will be suitable for livestock grazing indefinitely.
- State Wildlife Areas are not multiple use lands, and ecological objectives, particularly fish and wildlife needs and values, must take priority over grazing or other private commercial uses.
- Grazing needs to be done with ecological objectives clearly defined that allow for agreed to and appropriate grazing uses.
- Meeting Ecological Site or range condition goals in an agreed to time span, should be imperative to continued grazing use of WDFW lands.
- Proper grazing use of WDFW lands should be scientifically supported, regularly monitored, and restrictions, deferred grazing, stocking rates and seasons of use strictly enforced.
- Where grazing interferes with the primary goal of WDFW lands, to support wildlife and a healthy ecosystem, grazing plans, agreements and previous grazing history should all be up for review and appropriate changes.
- The effects of grazing on fire regimes and burn intervals should be considered in any grazing plan allowing multiple use of state lands.
- Obvious negative affects from grazing such as invasive weed infestations, watering area disturbance, or just plain over-use should be dealt with quickly by WDFW and the leasee to continue to allow grazing to occur.