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Field Notes


SOS: Save our sage-grouse and the places they call home

SOS: SAVE OUR SAGE-GROUSE AND THE PLACES THEY CALL HOME

Your voice makes a difference! Will you urge the Bureau of Land Management to take assertive action to save the Greater sage-grouse and Wyoming’s unmatched sagebrush habitat? Find suggested talking points to help you write your comment below.

It’s no secret that the Greater sage-grouse, a symbol of the West’s sweeping sagebrush landscapes, is imperiled. Dire statistics on habitat loss and dwindling populations — echoed across studies and countless articles — paint a sobering picture for the beloved bird:

“Remaining sagebrush covers less than half its historic extent.”

“We are losing 1.3 million acres of sagebrush annually.” 

“Sage-grouse populations have declined 80% since 1965.”

“Greater sage-grouse numbers have been cut almost in half over the past 20 years.”

From the heart of sagebrush country in Wyoming, where the ravages of invasive annual grasses and wildfire have yet to create the mass devastation they have in places like Nevada, it can be hard to comprehend how precarious the situation has become. But unfortunately, Wyoming is not immune to the threats eating away at sage-grouse populations and their habitats. Our state stewards the lion’s share of the world’s remaining sage-grouse and sagebrush — all the more reason to confront these threats head-on.

Of course, Western states have worked collaboratively for years to counteract threats and stave off an endangered species listing (read more here), but it’s clear more needs to be done to support sage-grouse. Fortunately, the Bureau of Land Management is now in the process of updating sage-grouse management plans across the whole of the bird’s range. What does this process mean for us? It means we have a chance to encourage strong action from the agency that manages more sage-grouse habitat than any other, including about 18 million acres right here in Wyoming.

The sagebrush steppe is home to a rich tapestry of over 300 species. How the BLM manages sagebrush habitat has far-reaching implications for an entire ecosystem of plants and animals that need our help, including pronghorn, mule deer, pygmy rabbits, ferruginous hawks, sage thrashers, parasol buckwheat…. The list goes on! As go the sage-grouse, so go our Western rangelands and sagebrush dependent species — which is why it’s imperative the BLM take assertive action to protect sage-grouse and shore up the best remaining sagebrush habitat with this plan.

We can all play a role in guiding the agency to do just that. The BLM is accepting public comments through June 13, and your comments have the power to shape the final plan the BLM adopts.

Will you take action today by urging the BLM to protect irreplaceable sage-grouse habitat in Wyoming? Your comments can be brief, but be sure to share your personal connection to sage-grouse and the broader Wyoming sagebrush biome. We’ve also shared some suggested talking points below to help you write your comment.

Deadline: June 13, 2024

In addition to sharing your personal connection to sage-grouse and the sagebrush ecosystem in Wyoming, you can also can urge the BLM do the following:

  • Grant Wyoming’s irreplaceable sage-grouse habitats the strongest protections. Wyoming is home to over a third of the world’s sage-grouse population because it contains the best remaining habitat. Chief among these, the Golden Triangle in southwest Wyoming boasts the densest populations of sage-grouse on the planet. The unmatched habitat in the Golden Triangle should be granted the strongest possible protections.
  • Direct development away from healthy habitat. There are many demands on BLM lands, but there is also ample acreage available to meet those demands. Infrastructure and energy development should be directed outside of Priority Habitat Management Areas to ensure sage-grouse are afforded the quality habitat they need to thrive.
  • Rely on the best available science to guide management decisions. Efforts to conserve the sage-grouse and its habitat can best be achieved by taking advantage of the latest research and science. The final management plans should lean heavily on the wealth of new data available to allow nimble, adaptive management responses to aberrant declines in sage-grouse populations across jurisdictional boundaries.
  • Maintain gene flow and habitat connectivity. Wyoming has the most robust population of remaining sage-grouse, but we shouldn’t keep all our eggs in that one basket. Critical connectivity areas, on the Montana border in northeast Wyoming and on the Utah border in southwest Wyoming, must remain open to allow for gene flow and dispersal between Wyoming’s populations and those in neighboring states.
  • Take bold action to conserve the habitat sage-grouse rely on. Western states, federal agencies, and private partners have been working together for over a decade to halt sage-grouse population declines, yet population indicators show we are losing this bird across its broader range. Because of this, stronger conservation measures should be adopted at every turn when weighing various management actions.

Wyoming is home to the largest, healthiest remaining swaths of sagebrush on the planet and your local perspective on how this habitat should be managed matters! Send your comment today urging the BLM to take assertive action to save the Greater sage-grouse and Wyoming’s unmatched sagebrush habitat.

Thank you for standing up for sage-grouse and all the creatures they share the steppe with.

Field Notes


A dream for the Red Desert

It’s the heart of winter in Wyoming and, for many of us, it’s a favorite time of year. The days are short and the nights are cold, but the snow brings a quiet, peaceful stillness and lends a special beauty to everyday life. For some, that means skiing, snowmobiling or ice fishing. For others, hunkering down with a hot drink and good book or movie is the best way to enjoy the season. 

The midwinter weeks are also a time to take stock of the past year and plan for the one ahead. These days, a lot of us at the Wyoming Outdoor Council have been daydreaming about the Red Desert. 

The Red Desert is commonly described as the largest unfenced area in the Lower 48. While its size and remote nature are impressive in themselves, this doesn’t paint the full picture. The desert is truly unique, with sweeping views, thriving wildlife, and mind-bending geological features. The ruts of the Oregon, California, and Mormon trails crisscross land that has been used by Indigenous peoples since time immemorial. The few nondescript county roads meander to the horizon.

Even in Wyoming, it can be hard to believe a place this rugged still exists. But there is life here. Wildlife abounds, including elk, mule deer, and Greater sage-grouse. Ranchers run cattle, and many hunters, hikers, mountain bikers, and off-road enthusiasts consider the desert their best-kept secret. From the sand dunes, buttes, and badlands to the aspen oases and expanses of sagebrush, the Red Desert is as diverse as the people who care for it. 

For generations the Red Desert has sustained a way of life that is undeniably Western and provided opportunities for work, play, and quiet contemplation to anyone who seeks it. There is a balance that works, and we as Wyomingites have the power to uphold it. That’s why the Outdoor Council has spent years working to keep the desert the way it is — a working landscape rich with wildlife, history, and open space. 

In 2020, we joined together with like-minded people from all walks of life in Citizens for the Red Desert, a coalition of Wyoming citizens and organizations who love the desert. We also hired a new staff member, Shaleas Harrison, to coordinate the effort. The people in this group all have different reasons for taking part, but they recognize that there is a common ground when seeking to preserve all the diverse values and uses of the desert. 

While Citizens for the Red Desert is relatively new, the passion for the Red Desert is anything but. Wyoming residents first proposed that a portion of the desert be permanently protected as a winter game preserve in 1898, and in the century that followed, a host of other conservation efforts were considered. 

These public lands have seen relatively little new development in recent years. A patchwork of agency-level protections helps sustain the Red Desert elk herd, the White Mountain Petroglyphs, the sand dunes, and other values. But it is a tenuous balance that could easily unravel. Increasingly, dramatic shifts in federal land management priorities add an additional layer of uncertainty about the future. 

As Wyomingites, the Red Desert helps tell our story. Now, we want to tell the story of the desert. 

In the coming year the Outdoor Council will be working with citizen and tribal partners to chart the course to permanent protection of this special place — based on the existing framework that respects the full range of opportunities this land provides. For more than 130 years, Wyomingites have shown their support. An enduring, Wyoming-grown solution can make that dream a reality and keep the special values of the Red Desert intact for generations to come. 

Field Notes


Safeguarded: Prime wildlife habitat in Little Snake River Valley

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Some good news to report! Oil and gas operator Greater Rocky Mountain Resources has abandoned plans to drill more than a dozen wells in some of the most important and sensitive wildlife habitat in the state.

In March, investment firm-backed GRMR (based in Colorado) notified the Bureau of Land Management Rawlins Field Office it would “release” federal permits to drill the wells — which could have set the stage for major industrial development spanning 136.5 square miles in the Little Snake River Valley near Baggs. The development would have taken place inside mule deer crucial winter range, migration corridors, and priority (“core”) habitat for Greater sage-grouse. The area is also home to the largest population of Columbian sharp-tailed grouse anywhere in the Rockies.

The picturesque Little Snake River Valley is treasured hunting grounds, and home to sheep, cattle, and irrigated agriculture operations. As the conservation group EcoFlight put it, “The Little Snake River Valley is one of the few remaining intact river valleys in the West that has not experienced rampant development.”

In places where oil and gas development is appropriate the Wyoming Outdoor Council works hard to see it “done right” by advocating that operators mitigate impacts to air, water, and wildlife. But in other places, mitigation is not sufficient.

“This is a great example of an area that should never have been leased in the first place,” Senior Conservation Advocate Dan Heilig said. “These are rare habitats, and there’s simply no way to accommodate an industrial development here without sacrificing native wildlife, open spaces, clean air and water, and tranquility in the Little Snake River Valley.”

The Wyoming Outdoor Council worked with local ranchers and partner organizations to advocate more effective stipulations to protect vital mule deer and sage-grouse habitat. We reviewed BLM’s analysis and permitting, and asked for revisions to correct deficiencies in the federal plans. WOC, along with Little Snake River Valley locals, The Nature Conservancy, National Audubon Society, Theodore Roosevelt Conservation Partnership, and the Wyoming Game and Fish Department advocated better analysis of cumulative impacts of the overall development.

“It was evident that GRMR and the BLM hadn’t done their homework,” Heilig said. “Thanks to the dedication of local ranchers and advocacy among many partners, the operator decided to abandon the project — a huge win for some of Wyoming’s most precious wildlife habitat that simply can’t be replaced.”

 

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Field Notes


Conserving Greater sage-grouse requires more than lip service

It took nearly 10 years for western states and the federal government to agree on a plan to save the imperiled Greater sage-grouse — along with the health of the sagebrush ecosystem that it relies on. Yet the actual work of implementing the plan and testing its potential for success has only just begun.

That’s why the Wyoming Outdoor Council is closely examining plans to expand uranium mining in prime sage-grouse habitat in the remote Great Divide Basin in south-central Wyoming. Recent mining activities here have already “moderately” degraded the habitat, and a proposal to expand the mining operation would nearly double the area already disturbed.

In its eight-volume review of the proposed expansion, the U.S. Bureau of Land Management concludes that the mine’s increased degradation of prime sage-grouse habitat is acceptable and falls within the legal parameters of its own sage-grouse management plan. WOC staff disagrees.

“The BLM has not lived up to its own commitments,” Outdoor Council Conservation Advocate John Rader said. “They misapplied their own density calculation tool to suggest a smaller surface disturbance than the actual disturbance, they incorrectly assessed baseline noise levels, and they barely mention the cumulative impacts of the proposed expansion. They claim to make up for ongoing and future damages with an ‘adaptive management plan,’ yet no adaptive management plan exists.”

Rader said that carefully scrutinizing the BLM’s draft environmental impact statement for the Lost Creek mine expansion provides an important opportunity to improve not just this project, but the implementation of Greater sage-grouse management plans more broadly. Holding industry and permitting agencies accountable at Lost Creek will help ensure that standards and expectations are met in sage-grouse country around Wyoming.

“Essentially, this is an opportunity to test the larger effort to save the Greater sage-grouse,” Rader said.


A full accounting for surface disturbance

The Lost Creek in-situ uranium mine 40 miles northwest of Rawlins consists of a series of small wells that tap into a shallow formation containing uranium ore. A solution of mostly carbonated water is pumped into the formation to dissolve the metal, and pumped back to the surface where metals are recovered in a treatment facility.

The proposed mining expansion would nearly double the size of the project area to 10,000 acres — all inside an area known as a BLM Priority Habitat Management Area. That means the mine operates within one of Wyoming’s protected sage-grouse “core areas” — important nesting, breeding, and lekking habitat that’s vital to the bird’s health. As such, the BLM must apply several prescriptions to limit damage to the bird and its habitat.

One key stipulation that applies here is how much surface inside a sage-grouse core area is allowed to be disturbed at any one time. New development activities may not disturb more than 5 percent of suitable habitat per an average of 640 acres. To calculate this, officials use a “Density and Disturbance Calculation Tool.” The formula requires BLM to consider disturbed sage-grouse habitat, even outside of the project’s footprint.

However, Rader and other Outdoor Council staff discovered that the BLM didn’t do this. The agency misapplied the formula by not accounting for areas between actual wells, roads, and other new structures. Yet science shows that because these physical structures and roadways fragment the habitat, impacts to the species go beyond just where the infrastructure sits. If the BLM’s measurement tool had been correctly applied to include the in-between acreage, it is likely that surface disturbance would have exceeded the 5 percent threshold, Rader said. He also noted this in the Outdoor Council’s comments to BLM Rawlins Field Office.

We want the BLM to correctly apply its own formula for determining how much surface area may be disturbed by mining operations at Lost Creek. Getting it right here will help ensure it’s done right across all critical sage-grouse habitat in Wyoming and the West.


Setting the bar for noise and cumulative impacts

Our review of the BLM’s Lost Creek mine expansion proposal also revealed flaws in how baseline noise levels are measured. And we found that cumulative impacts (such as the loss, alteration, and fragmentation of habitat, and various stresses of industrial activity) were not accounted for — a troubling omission.

Human-caused noise and activity may reduce lek attendance, which can harm sage-grouse. Therefore, another key stipulation requires that no development activity exceeding 10 decibels above an area’s baseline noise level is allowed at the perimeter of a lek from 6 p.m. to 8 a.m. during the spring breeding season. But the BLM’s flawed calculation of baseline noise levels grossly underestimated potential impacts, Rader said, and would allow for potentially harmful noise levels during the lek season.

Rader also noted that there’s too much variation in equipment used to measure ambient baseline noise, and too much variation in how the equipment is placed during testing. For example, sometimes microphones were placed much higher than a sage-grouse’s ears, allowing for more wind noise.

Based on ambient noise studies and the negative effects of noise on sage-grouse in Wyoming, we suggested that a clearer protocol be developed for establishing background noise levels and for monitoring. This is something that industry has also requested, noting that it would help avoid confusion and ensure clarity. We also suggested a statewide presumption of background noise levels based on peer-reviewed studies in sagebrush habitat in Wyoming, and recommended ensuring that human-caused noise levels do not exceed 26 decibels during lekking hours.

This presumption would decrease cost to industry by eliminating the need for baseline measurements, and reduce the risk of inaccurate measurements from flawed studies.

The BLM’s draft environmental impact statement for the Lost Creek mine expansion is troubling not only for its flawed analysis, but also for its failure to address cumulative impacts.

The BLM’s cursory evaluation — just two sentences — addressing the compounding effects of habitat fragmentation and other human-caused stresses associated with the mine’s activities risks weakening the broader, multi-state effort to protect the Greater sage-grouse. Curiously, the BLM defends these flaws by stating that any negative impacts to the bird and its habitat would be addressed in its Adaptive Management Plan for the project. But no such adaptive plan exists.


Why it matters, and what we’re doing

This project is not just about the habitat near Lost Creek. As we see opportunities for public input on these admittedly complicated processes diminish, it’s more important than ever to hold industry and permitting agencies accountable for protecting the Greater sage-grouse throughout sagebrush country. Agreeing on and using a clear set of science-based management prescriptions is necessary to ensure that mining, drilling, and other activities don’t further harm the species’ habitat.

“The sage-grouse management plans are more than a set of documents,” Rader said. “The bird is still in peril, and we must ensure that science-based plans are put into practice. State and federal permitting authorities are obligated to make sure they are properly measuring impacts and accounting for protections to avoid decimating some of the last best habitat that plays a major role in the survival of the species. That’s what we’re doing at Lost Creek.”

Field Notes


Speak out for the Greater sage-grouse, and our western heritage

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We need your help to protect the Greater sage-grouse from a political effort to weaken the Wyoming-led plan that helped avoid an endangered species listing of the iconic western bird. You can help by submitting comments to the Bureau of Land Management by August 2, 2018.

BACKGROUND—

The BLM’s Wyoming State Office is accepting written comments from the public on its draft plan to amend a multi-year planning effort finalized in 2015 to conserve the species. The Trump administration wants to re-do the plans to give greater weight to state and industry concerns. This is unnecessary and risky. Although the draft plan for Wyoming contains many of the essential features of the 2015 plan, it also removes key elements that biologists believe are necessary to avoid the need for listing the species as threatened or endangered under the Endangered Species Act.

POINTS TO CONSIDER IN YOUR LETTER —

  •  Tell the BLM to keep the 2015 Greater sage-grouse conservation plans in place. These plans  — covering all of the western states where sage-grouse are found — were the result of years of scientific study and collaborative efforts in Wyoming and in the other western states, and the deal should be honored. Any changes or “tweaks” that experts deem necessary can be accomplished through minor plan amendments, or so-called maintenance actions. A complete rewrite is an unnecessary waste of federal resources, and risks upending the official finding made by the U.S. Fish and Wildlife Service that a listing under the ESA is not needed. The certainty provided by the 2015 plans is now being called into question as changes to the plans are proposed based on political, rather than scientific, considerations.
  • Tell the BLM that a state-by-state approach to conserving the Greater sage-grouse is counter productive. The Greater sage-grouse is a landscape scale species that needs expansive, undisturbed tracts of intact sagebrush habitat to survive. The 2015 plans recognized this, and contain science-based conservation measures that applied uniformly across the species’ range. The proposed state-by-state plan amendments will lead to a patchwork of efforts, some with sound conservation measures (like Wyoming) and others with wholly inadequate measures. Will Wyoming be left “holding the bag” because other states have failed to develop adequate conservation strategies? A landscape-scale approach with all states participating in good faith is the best way to ensure effective conservation of the species.
  • The plans proposed by BLM must do a better job of protecting core population areas, also known as Priority Habitat Management Areas, by reducing the main threat to Greater sage-grouse: oil and gas development. Tell the BLM to make core population areas off limits to new oil and gas leasing. Development on existing leases should be managed under strict regulations now in place that limit surface occupancy and disturbance, but new leasing that would allow for even more development should be prohibited. More energy development in the bird’s most important habitat will not help conserve the species.
  • The BLM’s proposal strips the fundamental mitigation goal of “net conservation gain” from the plans. Tell the BLM that a no net loss of habitat that merely prevents additional habitat loss (i.e., stops the bleeding) is not adequate to conserve the Greater sage-grouse. The science shows that the plans must achieve a net conservation gain if the species is to stand any chance of long-term recovery.
  • The BLM should improve plan monitoring and oversight, and must do a much better job following its plans. Our experience over the past several years has revealed that the BLM routinely failed to follow its own 2015 plan, largely because BLM failed to provide training to field staff and the necessary incentives to ensure proper implementation. The best plan in the world is worthless if agency personnel fail to enforce it. The plan should contain metrics by which conservation success can be measured — statements that the plan is working without objective evidence to support those claims will not be sufficient to convince the USFWS that the plans are effective conservation tools.
  • Tell the BLM that the proposed plan does not provide for adequate openness and transparency of important planning decisions. For example, the BLM would like to be able to modify habitat designations (e.g., core vs non-core) via an internal process, rather than going through a formal plan amendment. Tell the BLM to follow its own regulations and use an open process to make important changes to the plan. The public should have a say in how public lands and wildlife are managed.

NOW, TAKE ACTION —

You may submit comments by U.S. mail to the Wyoming BLM state office.

Mail your letter to:
Mary Jo Rugwell
State Director
BLM Wyoming State Office
5353 Yellowstone Road
Cheyenne, WY 82009

(Be sure to include “attn: Greater Sage-Grouse EIS.”)

Alternatively, you may submit comments via email to:
Jennifer Fleuret McConchie
Planning and Environmental Coordinator
Bureau of Land Management
Wyoming State Office

(Be sure to include “attn: Greater Sage-Grouse EIS” in the subject line)

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Please personalize your letter. We are witnessing an alarming trend in federal agency decision-making that discounts comments that appear to be based on “form letters.” Your letter will be given greater weight if it contains specific comments that relate to your experiences concerning sage-grouse. For example, if you enjoy watching the males engaging in the flamboyant mating display on leks, or hope to do so in the future, please consider including that bit of information in your letter.

Click this link for additional information related to the BLM planning process.

Thank you for speaking up for Wyoming’s amazing Greater sage-grouse!

 

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Field Notes


Your comments can help uphold historic sage-grouse protections

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Wyoming citizens can tell Interior Secretary Ryan Zinke not to scrap commonsense protections for sage-grouse and the sagebrush ecosystem at two BLM meetings later this month.

The open-house meetings, to be held in Cheyenne and Pinedale, will provide an opportunity for the public to learn more about — and comment on — an ill-conceived BLM proposal that would eliminate habitat protections developed as part of a historic, West-wide conservation plan.

That plan, which Wyoming Governor Matt Mead helped craft and which was approved with broad bipartisan support in 2015, would help maintain healthy sage-grouse populations, as well as vibrant mule deer, elk, and pronghorn herds, and hundreds of other species that rely on intact sagebrush habitat. The plan’s conservation measures are widely credited with keeping the Greater sage-grouse off the endangered species list.

 

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MONDAY,
JUNE 25

4–7 p.m.
Laramie County Library
Cottonwood Meeting Room
2200 Pioneer Ave.
Cheyenne, WY

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WEDNESDAY, JUNE 27
1:30–4:30 p.m.
Sublette County Library
Lovatt Meeting Room
155 S. Tyler Ave.
Pinedale, WY

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A Collaborative West-wide Conservation Plan
Scrapped in the Name of “Energy Dominance”

Although the Trump administration touts the importance of state engagement and local input, its actions tell a different story.

In what many see as an egregious concession to mining and oil and gas lobbyists, Secretary Zinke last fall ordered his agency to reconsider the historic sage-grouse conservation plans that western stakeholders took years to craft.

These plans, which apply to 11 western states, are a wildly successful example of state engagement and local input. They were endorsed by western governors, conservationists, sportsmen, and many in the agricultural and oil and gas communities. The plans’ protections were modeled after Wyoming’s own strong sage-grouse conservation measures; the best available science, attention to balance development and wildlife management needs, and to keep the Greater sage-grouse from being listed as a threatened or endangered species. The approval of these plans in 2015 was a resounding success story. And Wyoming citizens know it.

Wyoming Citizens Stand Behind the Plans

Last December, Wyoming citizens turned out in force, along with Governor Matt Mead and other state leaders, to demand that the protections for Wyoming’s sage-grouse remain in place. Senator John Barrasso, too, publicly defended Wyoming’s plan.

The Interior Department listened . . . sort of. The BLM has now released draft amendments for each of the 11 states that signed on to the 2015 conservation plan. The amendments to Wyoming’s plan propose keeping some of our good protections. But taken as a whole, the amendments don’t do enough to ensure that sage-grouse populations across the West will be protected.

As Secretary Zinke must understand, keeping the Greater sage-grouse off the endangered species list goes beyond ensuring smart management only in Wyoming. Protecting the species — and its sagebrush habitat — across the west is essential. But the BLM is drastically reducing habitat protections in eight of the 11 states that are part of the West-wide plan, leaving just three — Wyoming, Montana, and Oregon — to carry the weight of protecting this iconic western species. And several changes in the plan proposed for Wyoming will hurt sage-grouse populations right here.

Tell Secretary Zinke: Honor the Deal!

The Department of Interior is currently taking public comment on its draft amendment for Wyoming. If you’re in Pinedale or Cheyenne next week, please attend a BLM open-house meeting to learn more. The BLM is taking public comment on the proposal right now. Come learn more and ask questions at the open houses next week as we prepare to send comments on behalf of our members in August.

Here are a few key points to make in your comments:

  • Without reliable, West-wide measures to address ongoing and increasing threats to the Greater sage-grouse and its habitat, we’re likely to find ourselves right back where we started: facing a listing under the Endangered Species Act. That’s not good for the sage-grouse and it’s not good for westerners.
  • Wyoming, Montana, and Oregon should not be the only states responsible for range-wide support of the sage-grouse population. The remaining states must help carry the weight. All 11 states that signed on to the 2015 conservation plan must be accountable for their share of the habitat and bird populations.
  • The proposal doesn’t do enough in terms of mitigation. The BLM must do everything in its power to improve habitat that has been lost or degraded due to development.
  • The proposal provides for more flexibility for “adaptive management.” Although flexibility might make sense, any departures from the original conservation directives must be transparent and backed by the best available science.  

Want to know more? Email the Outdoor Council’s Senior Conservation Advocate, Dan Heilig at dan@wyomingoutdoorcouncil.org.

Thanks for standing up for Wyoming!

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