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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


What’s next for Wyoming’s big game?

This winter, Gov. Mark Gordon signed an executive order detailing how mule deer and pronghorn migration corridors will be identified and managed in the state. The Wyoming Outdoor Council was heavily involved in the advocacy, collaboration, and negotiations that led to this order, and we were pleased the governor took this important step. But what does this new policy mean? It means now the real work begins.

The governor’s order affirmed the designation of three corridors that had gone through the Game and Fish Department’s analysis and public process: the Sublette mule deer corridor (also known as the Red Desert to Hoback) and the Baggs and Platte Valley mule deer corridors. While the Sublette corridor has already gone through a risk assessment to evaluate landscape-level challenges affecting this herd and habitat, neither the Baggs nor the Platte Valley have. 

We anticipate new information on these assessments in the near future, and have communicated with Game and Fish staff about our suggestions for best conducting these analyses. When these assessments are completed, they will be released as drafts for public feedback and discussed in public meetings before being finalized. After designation, the executive order prescribes the formation of local working groups for each corridor to discuss ongoing management challenges and opportunities.

When the executive order was signed, two corridors were in draft status (i.e. not yet formally designated): the Sublette antelope corridor (the Path of the Pronghorn) and the Wyoming Range mule deer corridor. These corridors will be the first to move through the entirety of the new designation process. We anticipate seeing the Path of the Pronghorn discussed at a Game and Fish Commission meeting later this year, and will continue to advocate for designation. 

The Game and Fish Department will also continue to identify other migration corridors around the state. Though the governor’s order only applies to mule deer and pronghorn, the department will continue its work to identify and manage elk migration corridors. We will continue to advocate for a formal corridor designation process for other ungulate species. Stay tuned for new developments.  

While the governor’s order puts the weight of law behind the value of wildlife migration corridors, the future of our big game herds depends on us. Advocacy from Wyoming people about the value of our large, migratory herds was critical in getting us to this point, and will continue to be necessary in the long term.

Please watch for updates about the next opportunities to be involved in corridor advocacy, and reach out to us if you have interest in any of the specific migration corridors currently being studied.  

Field Notes


Governor tours the Red Desert with citizens group and Outdoor Council staff

Gov. Mark Gordon spent Thursday, June 11, visiting Wyoming’s iconic Northern Red Desert for a firsthand look at one of the state’s wildest landscapes. The tour was organized by the Wyoming Outdoor Council and our partners to familiarize the governor and his staff with some of the most beautiful and treasured corners of the desert as well as introduce him to citizens representing a variety of interests who value, work in and recreate on this important landscape. Many representatives of Citizens for the Red Desert, a grassroots group, also participated in the trip.

The Northern Red Desert contains nationally-significant cultural and ecological resources, including the greatest concentration of Bureau of Land Management wilderness study areas in Wyoming, crucial winter range and migration corridors for mule deer, pronghorn, and a rare desert elk herd, North America’s largest living sand dunes, historic trails including the Oregon and Pony Express National Historic Trails, and indigenous cultural sites including petroglyphs, buffalo jumps, and other respected places. It is a vast landscape that offers a range of potential for outdoor recreation and hunting, supports ranching, and is considered the largest unfenced area in the Lower 48.

The tour was designed to provide the governor an overview of these special values. Along the way, the governor visited sites such as Whitehorse Creek and the dramatic Honeycomb Buttes wilderness study areas; visited with local rancher Jim Hellyer and his family; heard about the Oregon Trail and westward expansion from Todd Guenther, a Central Wyoming College professor and historian; and met with Rick Lee, director of the Rock Springs Chamber of Commerce and Bobbi Wade, a local outfitter, to discuss outdoor recreational opportunities. Jason Baldes, an Eastern Shoshone tribal member and the tribal buffalo coordinator for the National Wildlife Federation accompanied the trip to highlight the history of indigenous use and current tribal values within this landscape. John Mionczynski, an ethnobotanist and expert on the desert provided additional background on the ecology, geology and history.

Bobbi Wade, a local outfitter, discusses outdoor recreation at Chicken Springs.

The wildlife values of this landscape were in constant view, and the connection of this Red Desert habitat to what’s known as the “Golden Triangle” to the north along the Wind River Front — so named for its wealth of big game and sage-grouse populations — was highlighted by wildlife experts on the trip. Lauren Heerschap, with WyoClimbers and a Wyoming Outdoor Council board member, also shared information about the value of this landscape as the recreational scenic gateway for national and international climbers accessing renowned climbs in the Wind River Range.

Jason Baldes, an Eastern Shoshone tribal member and the tribal buffalo coordinator for the National Wildlife Federation, discusses the historical significance of the Red Desert to indigenous and current tribal members.

John Mionczynski discusses the Red Desert’s fascinating geological history in front of the Honeycomb Buttes.

The Outdoor Council is tremendously grateful for the governor’s time to take this trip, and we and others benefited from the questions and perspectives he and his natural resource and energy staff shared with us. Gov. Gordon engaged in thoughtful conversations throughout the tour, and was obviously seeking to understand this diverse landscape and the perspectives presented. 

The Red Desert is largely comprised of public lands managed by the BLM. This agency revises its management directives about every 20 years through a public planning process resulting in a resource management plan. The Red Desert’s fate is currently under debate due to the ongoing revision of the BLM’s Rock Springs Resource Management Plan, which will determine how 3.6 million acres of public lands, including the Red Desert, will be managed over the coming decades. Recent plan revisions from elsewhere across the West have stripped designations that protect wildlife habitat, cultural sites, and more.

It is our hope that through the direct experience of this landscape, and his conversations with people who cherish it, Gov. Gordon will see that the Northern Red Desert is a national treasure worth protecting — a place beloved by a diversity of Wyomingites for its many values and uses and deserving of a BLM management plan that will ensure its special values remain for future generations.

Gov. Mark Gordon stands with members of the tour while visiting the Northern Red Desert on June 11.

Field Notes


We’re on the move to support our migratory mule deer

Migration is hard work for Wyoming’s mule deer, especially for the thousands that move 150 miles each way between their winter range in the Red Desert and their summer range in the slopes of the Hoback. Muleys have to contend with weather, disease, predators, fencelines, and human traffic across an increasingly fragmented landscape. One thing they don’t need more of? Challenges that pose a life-or-death threat by closing off or destroying critical habitat — especially when mule deer populations statewide have declined by more than 30 percent in recent decades.

That’s why the staff of the Wyoming Outdoor Council has been on the move this spring and summer, too, working to support these selective critters by advocating good wildlife policy that defends their future. 

SURFING THE GREEN WAVE INTO SUMMER

During late spring and early summer, we joined friends in Lander, Rock Springs, Laramie, and Casper to “Surf the Green Wave” into summer. We were thrilled to see so many of you at these events! Together, we explored the latest science, chatted policy and land management challenges faced by our deer, and talked about how you can take action to support Wyoming’s muley herds (which you did!). We also replicated a mule deer migration by “pub crawling” to various “stopovers” — those places along migration routes harboring the highest quality green “groceries” — and celebrated with our version of high-quality summer forage: a special beer brewed by our friends at Square State Brewing in Rock Springs! 

Thanks to the many, many volunteers, hosts, donors, and members who made these events possible, including Pedal House in Laramie and Backwards Distilling in Casper.

ADVOCACY UPDATE: GOV. GORDON’S MIGRATION ADVISORY GROUP

Your commitment to learn about and take action for mule deer has been essential as we’ve engaged with Gov. Gordon’s Wildlife Migration Advisory Group, which began meeting at the end of June. This eight-person citizen group, comprised of Wyomingites from a range of backgrounds, has been hard at work this summer. The group is considering scientific, conservation, policy, and economic data as it crafts a recommendation for the governor about how Wyoming should manage migration corridors. 

The Outdoor Council had the opportunity to present to the group on July 8 on behalf of the conservation community, and we worked diligently to represent the hopes and concerns you’ve shared with us about the state’s mule deer. I was honored to be able to talk about our conservation priorities for migration corridors and our recommendations for protecting migrating big game — especially mule deer. The committee’s conversations afterward were thoughtful, and I came away encouraged about the prospect of a strong, Wyoming-based solution for our migratory big game.

TAKING ACTION TO SUPPORT OUR MULE DEER

The committee’s final meeting will be held in Pinedale on August 12 and 13. If you are able to attend, we would love to see you there. Watch your inbox for information about the meeting and how to participate. 

Also, the state offered several oil and gas leases in migration corridors this month — including some in critical stopover habitat. We’d like to ask that these leases be canceled until stronger rules — already in development through the Governor’s task force — are in place to make sure that mule deer corridors aren’t harmed. Join us in asking the State Board of Land Commissioners (a group which includes Gov. Gordon) not to approve the sale of seven leases in corridor and stopover habitat.

FINALLY: Do you want to get your hands dirty and help support the world’s longest mule deer migration?

The Wyoming Game and Fish Department and the Rock Springs Bureau of Land Management are organizing a habitat improvement project on Saturday, August 10. Volunteers are needed to help replace fence. It’s a big job with some heavy lifting involved, and will help migrating mule deer access a key stopover in the Red Desert to Hoback corridor. If you’re interested in joining WOC staff to volunteer, please email me: kristen@wyomingoutdoorcouncil.org. We’ll provide a WOC t-shirt or hat to anyone who volunteers, and will help arrange carpools to Farson! More details about the volunteer day can be found at this link

Thank you for being a passionate advocate for Wyoming’s mule deer and other big game! Your voice is making a difference as we strive to negotiate a permanent conservation solution for our iconic migratory herds.

Field Notes


Wyoming must do more to protect mule deer migrations

Wyoming has been in the world spotlight since the discovery of the longest known mule deer migration, which runs 150 miles between the northern Red Desert and the Upper Hoback. That such an ancient migration still exists — despite roads, fences, housing, energy development, and other human activities — is amazing.

And new science is conclusive on two points: mule deer avoid development, and once a route is impeded, the deer don’t adapt. Unfortunately, under the new energy dominance policy, the BLM is offering oil and gas leases inside this corridor and other crucial wildlife habitat. And unless they hear from state wildlife managers, they’ll continue to do so.

The existence of the longest known mule deer migration is something Wyoming can no longer leave to chance. If we allow oil and gas activity here, the loss of this unique pathway will be on us.

Wyoming Game & Fish Department must step up

Wyoming’s wildlife is a tremendous part of our outdoor culture and a driver of our statewide economy. Big game hunting alone brings in about $300 million annually. According to a recent poll from Public Opinion Strategies, an overwhelming majority of all Wyoming voters — 89 percent — agree with Gov. Mark Gordon that protecting wildlife corridors does not have to be at odds with Wyoming’s energy industry.

Even former Interior Sec. Ryan Zinke understood the importance and popularity of protecting big game herds for westerners. Last year, he signed an executive order “to enhance and improve the quality of big-game winter range and migration corridor habitat on Federal lands.”

Yet the BLM continues to sell leases inside these habitats.

The thing is, states have the power to push back. When western states have asked the feds to pull oil and gas leases that have been offered in vital big game habitat, we’ve seen the BLM respond. Last year, the agency pulled more than a quarter of a million acres in Colorado from oil and gas lease sales at the request of state leaders.

And on the few occasions when the WGFD has asked the BLM to defer leasing parcels that fall entirely within a designated migration corridor — a very small percentage of the total number of oil and gas leases being offered in corridors — the BLM has granted its request.

This should be good news. But a state has to believe that the science matters, and then it must have the will to speak up. Unfortunately, that’s not what we’re seeing in Wyoming. Right now, the WGFD is operating under the flawed premise that if only a portion of a particular lease parcel falls within a wildlife migration corridor, there’s no threat to our wildlife. But that isn’t the case.

The WGFD has developed a “strategy” that endorses leasing inside migration corridors so long as at least 10 percent of a parcel falls outside the corridor. The rationale — which the WGFD admits is not rooted in science — is based on the hope that energy operators will “do the right thing,” and locate infrastructure in the portion of the lease parcel that’s outside the designated migration corridor. Unfortunately, operators are not legally bound to do so.

Crossing our fingers that private energy companies will do what’s best for our wildlife is no way to manage one of Wyoming’s most important resources. But unless the WGFD finds the will to ask the BLM to pull these leases, blind hope is all we’ve got for now, because there’s no legal way to ensure that energy operators will limit development to outside corridor boundaries.
Even more troubling, when pressed, both the WGFD and the Wyoming Game and Fish Commission — the bodies charged with protecting Wyoming’s wildlife — have said they can’t ask to defer leasing in this tiny portion of Wyoming’s most important big game habitat for fear of retribution from the legislature and the oil and gas industry. This is despite an overwhelming and bipartisan majority of Wyoming voters agreeing that protecting wildlife corridors does not have to be at odds with energy development.

The bottom line is that there is no need to offer oil and gas leases in Wyoming’s migration corridors. Even if every lease that abutted the Red Desert to Hoback mule deer corridor were made off limits tomorrow, millions of acres of public lands are still available to lease — and develop. Wyoming is not so poor that (for as little as $1.50 per acre — less than a slice of pizza or a cheap cup of coffee) we should give away to energy companies our most crucial big game habitats and the very future of our big game herds.

Working to save Wyoming’s muleys — and how you can help

We’ll continue to review every BLM oil and gas lease sale in Wyoming and file protests when the agency ignores our concerns. We’ll keep testifying at Game and Fish Commission meetings, respectfully urging this body, charged with protecting Wyoming’s wildlife, to heed the science and take a stronger stand. We’ll keep meeting with WGFD leaders — and with the governor and his policy staff — to pore over maps and advocate better strategies. We’ll work with with partners, sportsmen and women, and citizens around the state to get the word out.

And we will continue to weigh all our options, including filing a legal challenge. That’s not a step we’d take lightly, but it’s one we’ll consider if it means protecting the future of Wyoming’s mule deer.

Wildlife and the vast open lands they need to survive define us in Wyoming. The Wyoming Outdoor Council is more committed than ever to work on behalf of Wyomingites to defend these irreplaceable resources and protect the state’s migration corridors for future generations.

 

Field Notes


An update: our ongoing efforts to protect Wyoming’s migration corridors

These past few months, we’ve been asking the state to urge the Bureau of Land Management to take a more precautionary approach to oil and gas leasing in migration corridors until legally binding wildlife protections can be put into place. New and existing science clearly shows that drilling in migration corridors is bad for mule deer herds, and we want to know that any leases offered will have the stipulations in place that will protect Wyoming’s wildlife.

And thanks to you, the BLM is hearing a loud and clear message from the public. More than 260 of you signed our petition — which we submitted as formal comments — asking the BLM to defer leasing in Wyoming’s mule deer migration corridors and crucial winter ranges. To learn more about this issue, you can read our fourth quarter sale fact sheet.

In September, too, a west-wide court ruling forced the BLM to temporarily withdraw hundreds of thousands of acres of Greater sage-grouse habitat from its oil and gas lease auction scheduled for December, in order to allow for more public participation. The court found the BLM’s attempts to shorten public participation periods are likely in violation of several federal laws. As a result, just three parcels will go up for auction in Wyoming in December while the remaining 584 parcels spanning 790,462 acres will go on the auction block in February.

It’s the biggest lease sale in the state’s recent history, and it’s an indication of what the Trump administration’s “energy dominance” mandate continues to mean for Wyoming — a state where nearly half our lands are public. We’re letting the BLM know that we won’t stand for leasing in our most vital wildlife habitat.

We submitted a second round of comments listing several concerns regarding the BLM’s failure to consider a more measured approach. We continue to ask the BLM to defer leases that overlap big game migration corridors and crucial winter range until science-based and legally-enforceable stipulations are put into place to protect these habitats.

This week we testified before the Wyoming Game and Fish Commission to let them know that Wyomingites overwhelmingly support protecting these migration corridors, and we continue to encourage state officials to simply honor that support by asking the Interior to defer leasing. To find out what our “next steps” are, you can read our recent letter with our recommendations to Gov. Matt Mead’s policy advisor.

 

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


Wyoming must stand up to feds to save mule deer

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The U.S. Bureau of Land Management’s reckless oil and gas leasing actions may be the death warrant for a prized mule deer herd that relies on the renowned 150-mile Red Desert to Hoback migration corridor in western Wyoming — the longest big game migration measured in North America.

Wyoming’s political leaders and wildlife officials can avert this crisis, but there is little time left to take action. The next lease sale is Sept. 18.

“That we still have some of the most intact big game corridors in the world is a rarity worth protecting,” Wyoming Outdoor Council Executive Director Lisa McGee said. “It’s time for Wyoming to stand up for our wildlife.”

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Oil and gas development takes priority over all other uses and values for public lands under President Trump’s energy dominance mandate — drawing a target on Wyoming where much of the surface and underground mineral estate is owned by all Americans and managed by the federal government.

In a rush to implement the mandate and limit options for the public to have a say in future land management, the BLM has tripled the size of its quarterly oil and gas lease sales across the West. More than 1 million federal mineral acres across Wyoming are up for grabs in the Third- and Fourth Quarter oil and gas lease sales. Just a small fraction of those acres overlap the migration corridor and threaten its functionality.

The Outdoor Council and other organizations have asked the BLM to defer these leases, along with others in crucial wintering habitat statewide — a necessary action that does not impede an industry that already has filed 10,000 applications to drill across the state.

So far, the Wyoming Game and Fish Department seems satisfied with the BLM’s claim that “lease notices” attached to these parcels will “mitigate” impacts. But this assertion is incorrect.

Unlike formal lease stipulations, which are legally enforceable modifications to the terms and conditions of a standard BLM oil and gas lease, the notices proposed by BLM provide no authority to halt or significantly modify operations if necessary to protect migrating wildlife. State officials recently appeared to affirm this reality when the Wyoming Office of State Lands and Investments insisted that legally enforceable “lease stipulations” must be in place before offering oil and gas leases on state lands in the corridor. Such science-based stipulations should apply to federal leasing in the same corridor as well. Wyoming’s national preeminence in mule deer migration research positions us with the best expertise to craft these important stipulations.

So far, the BLM has been deaf to these arguments, as well as objections from Wyoming residents who value healthy wildlife populations, and the American people who own these public lands. However, the BLM has shown that it is willing to listen to two voices of influence: Wyoming Gov. Matt Mead and the Wyoming Game and Fish Department.

At the governor’s request earlier this summer, the BLM agreed to withdraw three oil and gas lease parcels from the migration corridor, as well as sensitive habitats in the Greater Little Mountain Area where the state and feds previously had agreed to hold off from leasing.

Both Sweetwater and Teton counties, home to the southern and northern ends of the Red Desert to Hoback migration corridor, have asked the BLM to defer all leasing in the corridor for the irreversible damage it would do to wildlife and the local outdoor recreation and tourism economy. They need Gov. Mead and the Wyoming Game and Fish Department to reinforce and carry their message. Respecting local governments is a mantra of this administration, yet it now rings hollow. The BLM has ignored these counties altogether.

Dan Heilig, the Outdoor Council’s senior conservation advocate, wrote to Wyoming Game and Fish Director Scott Talbott urging him to take action and to use the agency’s influence to insist that the BLM defer Third- and Fourth Quarter leases for sale in the corridor.

“Our big game herds are world-renowned and contribute to our collective sense of pride and quality of life we share in Wyoming,” Heilig wrote in the August 21 letter. “Surely the state can and should advise against sales that risk the future of our mule deer population.”

For more information, read our fact sheet about the issue and how you can effectively advocate for protecting big game migrations in Wyoming. Also, read the Outdoor Council’s August letter to Wyoming Game and Fish Department Director Scott Talbott, urging the agency to stand up to federal overreach to protect Wyoming’s migrating wildlife.

 

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Field Notes


Your voice makes a difference in wave of leasing actions

This summer we asked you to weigh in on several oil and gas leasing actions that would degrade wildlife habitat and other special landscapes in Wyoming. You responded by submitting comments and letting officials know that some places just aren’t right for development. Thank you! Because of your quick action, we have a few successes to report.

But first some context.

In western states, U.S. Bureau of Land Management lease sales are growing exponentially in size. This year, the number of federal acres offered for oil and gas development in Wyoming ballooned from 170,509 in the first quarter to a whopping 700,000 acres in the fourth.

“I’ve never seen a lease sale in Wyoming of that size, ever. Seems like it’s a firesale,” Outdoor Council Senior Conservation Advocate Dan Heilig said.

Following the president’s “energy dominance” directive, the BLM is also offering shorter timeframes for the public to review and respond to lease sales, while also ignoring its previous commitments to not lease in areas undergoing planning revisions. This has led to leases being sold in areas that have less than adequate protection.

And the public isn’t even getting a fair return. Many lease parcels offered in these sensitive areas are selling for the federal minimum of $2 per acre, whereas parcels in developed areas “in play” can go for $3,200 per acre.

This year, the number of federal acres offered for oil and gas development in Wyoming ballooned from 170,509 in the first quarter to a whopping 700,000 acres in the fourth. (Wyoming BLM)

“It’s not benefiting the public treasury,” Heilig said. “They’re not getting the best value per acre for these parcels.”

According to a July 2018 article by Reveal, “Some energy experts say the Trump administration is trying to lease lots of federal land that oil companies don’t even want. Of the 11.9 million acres offered by the administration in 2017, 792,823 [acres] received bids, considerably less than the 921,240 acres out of 1.9 million under the Obama administration in 2016.”

The sale of a lease parcel conveys a legal right to develop. Because neither the state nor the federal government is carefully analyzing where it sells, or allows citizens time to comment, the public stands to lose.

Back in 2012, citizens rallied to help purchase and retire nearly 60,000 acres of oil and gas leases in the Upper Hoback of the Wyoming Range. These were leases originally bought on the cheap, which citizens then spent $8.75 million to purchase and retire. Today’s wave of federal leasing poses similarly costly threats far into the future, whether leases must be bought out in some places, or development robs the public of productive wildlife habitat and outdoor and tourism dollars.

Your voice matters

In the July Wyoming state lease sale your emails, letters, and phone calls to state officials helped result in a handful of lease parcels being pulled — one at the foot of Boar’s Tusk. This is fantastic news. Unfortunately, the State Board of Land Commissioners approved the sale of nearly two dozen other parcels that we and many partners opposed.

This shortsighted lease sale not only threatens critical wildlife habitat and rare cultural resources in the Red Desert, it also highlights several deficiencies in the state leasing process. First, the state’s public notice for oil and gas lease sales is woefully inadequate. The state allowed only 30 days for the public to review 187 proposed leases statewide. Second, although the public may access and comment on proposed lease sales, the state provides no formal avenue to do so.

With your help we will continue to push officials to resolve these deficiencies. And, recognizing that Wyoming’s constitution prioritizes uses of state lands to generate revenue for Wyoming schools, we’ll also keep touting a better alternative to leasing special state landscapes for energy development: exchanging those lands for BLM parcels better suited to industrial development.

On the federal front

The state’s July lease sale precedes two federal oil and gas lease sales that also include parcels in sensitive areas, such as Greater sage-grouse core areas, crucial winter range, and the Red Desert to Hoback mule deer migration corridor.

So far, the Wyoming Game and Fish Department has been reluctant to weigh in on recent federal leasing actions with its own expertise. We continue to urge the state to guide federal agencies on matters best understood by expert biologists citing the best available science.

The state has so far failed to note that federal stipulations attached to oil and gas lease parcels don’t take into consideration 15 years of published research by wildlife biologist Hall Sawyer. The research shows such stipulations do not adequately protect wildlife from oil and gas development.

Rather than keeping its foot on the gas pedal, the BLM needs to hit the brakes on oil and gas leasing in and near migration corridors. The agency needs to take time to adhere to the best available science and to amend existing stipulations to ensure protections actually work as intended.

This year we also asked you to submit comments on BLM oil and gas lease sales, and many of you responded. Thanks to your advocacy and the urging of Gov. Matt Mead, the BLM agreed to defer the sale of nearly 5,000 surface acres of federal lease parcels that intersect with the Red Desert to Hoback mule deer migration corridor. This is a good start to defending this corridor, and it showed the BLM that Wyoming citizens are resolute in protecting the state’s critical wildlife habitat.

Thank you for staying engaged and helping us keep the promise that we owe to future generations.

— Read the Wyoming BLM Third Quarter oil and gas lease sale protest letter filed (August 11, 2018) by Wyoming Outdoor Council, National Audubon Society, The Wilderness Society, and Wyoming Wilderness Association.

 

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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