June 21, 2014 David Whittekiend Uinta-Wasatch-Cache National Forest Supervisor 857 West South Jordan Parkway South Jordan, UT 84095 Dear Mr. Whittekiend, Comments on Forest Service High Uintas Domestic Sheep proposed EA Jeffrey Shaun Sims Qualifications I appreciate the opportunity to comment on the High Uintas Domestic Sheep proposed Environmental Analysis. I have over 20 years of experience and on the ground knowledge of the allotments that the EA will be analyzing. I also have practical knowledge of grazing management and husbandry practice associated with sheep production and specifically as it pertains to the High Uintas grazing allotments. I have served on the Uinta County Conservation District Board of Supervisors for over 14 years. In that time I have represented the districts on several federal land management planning processes, BLM Kemmerer RMP, Moxa Arch Infill, Rock Springs Travel management plan, I also have represented the district on the Coalition of Local Governments in southwest Wyoming. I am submitting the following comments: 1. The forest service made a settlement agreement on the High Uintas without any knowledge or input from any of the permittees, the forest service should now be willing to take all their input with an open mind.
2. There has been only circumstantial evidence that the Bighorn sheep have been in these areas. I would request that any and all information and documentation including physical and historical information that was used to arrive at the conclusion of this being Big Horn sheep historic range be made available for review. 3. Since the demise of the hoop lake transplant herd I would ask for evidence that any contact has been made with domestic sheep on these allotments and have that available for review. 4. The Forest Service needs to document scientifically the reasons for the demise of this herd. I believe there was predation and lack of sufficient winter range. The effects of natural and environmental stressors obviously play a role in Big Horn sheep survival and the potential for Die Off as demonstrated in herds with no known contact with domestic sheep. The effects need to be taken into consideration in any future designations and removal of Domestic sheep. 5. I would request that the Forest Service take into account the declaration of Dr.Donald P. Knowles, JR and Dr.Margret A.Highland. Case no.12-cv- 00469-BLW DOCUMENT# 38 and follow the conclusions reached by USDA Animal Research Service, Animal Disease Research Unit. 6. Economic impact of removal of sheep from the Wasatch-Cache and Ashley national Forest would result in the direct loss of jobs in Uinta County, Wyoming, without any corresponding benefit. I would ask that the forest service do an economic analysis of the impact of lost employment and economic impact to the local economies. 7. Domestic sheep should not be removed on the basis of controversial and incomplete studies of the transmission of disease between Bighorn sheep and Domestic sheep interactions. No large-scale studies of actual conditions on the ground have ever been completed at this time. 8. With the recent advances in the development of vaccines and other solution to the alleged problems it seems premature to remove sheep from the forest that have coexisted for decades. These developments should be investigated with the same enthusiasm as those incomplete studies that
show interaction between Bighorn sheep and Domestic sheep cause transmission of disease between the species. 9. The study only addresses grazing on the forest perhaps it should be enlarged to consider all threats to the sensitive species i.e. mountain goats, domestic goats, and other currently unknown threats to their viability. 10. The die off of herds that have had no contact with Domestic sheep for decades indicate there may be many reasons that the Big Horn sheep contract the disease and that Domestic sheep may not be the cause of Bighorn disease die offs. Other factors that play a role in disease outbreaks should be thoroughly investigated. 11. The removal of Domestic sheep will greatly reduce predator control in and around the forest.this will result in a large increase in predation on the wild sheep. Predation has been shown to be one of the major causes of mortality in wild sheep. The interaction of predation, predator control, and viability of herds should be thoroughly investigated before any decision is made. The predator control that is now being funded for by producers will cease of sheep are removed and those predators will not be controlled. The resident predators will no longer have domestic sheep to prey on and will search out and predate on other species. Bighorn sheep are susceptible to these same predators. Perhaps the law of unintended consequences might be happening in this area. Any decrease from disease transmission between Domestic sheep and Bighorn sheep might be more than offset from the real and documented losses to predation. 12. The decline in sheep numbers on the forest and the decline in mountain sheep have occurred simultaneously, another indication that the cause may be much more than disease transmission and many other factors are at work. Perhaps the Bighorn sheep and domestic sheep are more compatible than any studies have shown. This should be thoroughly investigated to make sure that the decline is not coincidental. To my knowledge no one has made any studies on why the declines in domestic sheep and wild sheep have occurred over the last couple of decades. This interaction should be investigated before any drastic reductions in domestic sheep are made.
13. Transhumance agriculture is a historic and cultural benefit to the local economy. There is a direct benefit to having the sheep in the forest. They provide firsthand experience for many urban visitors with actual livestock that is impossible to get anywhere else. The gentle nature of the sheep provided a wonderful experience for these people. Except for a few vocal individuals, most people are very tolerant and excited to see the sheep. 14. The transhumance sheep business as practiced on this forest is one of the most sustainable agricultural practices in the United States. This is a goal that everyone wants to achieve 15. This environmental analysis should be carefully done to remove any bias that the forest service has against livestock grazing. The Forest Service shall also carefully follow the Wilderness Act of 1964 and subsequent acts designating Wilderness. In 1990, House Report 101-405 (commonly known as the Congressional Grazing Guidelines) states: "There shall be no curtailment of grazing in wilderness areas simply because an area is, or has been designated as Wilderness, nor should Wilderness designation be used as an excuse by administrators to slowly 'phase out' grazing." I would question after the guidelines that congress has stated concerning grazing in the wilderness the validity of studying the effects of domestic sheep grazing on wilderness values 16. The grazing of Domestic sheep on the Forest following our approved allotment management plan provides a wealth of benefits to the forage resource. The grazing plans provide the framework in which forage can be harvested by the domestic sheep. The grazing of plants causes new growth to take place and reduces hazardous fire fuels providing a dual benefit for forest health and wildlife, while also providing for the needs of the permittees and local economies as a whole. Grazing in the High Uintas also reduces the fine fuels that carry fire. Grazing can have a very positive effect on fire suppression. With the state of the forest, the very high percentage of beetle killed trees and the encroachment of conifers into the open spaces grazing is a tool that can be
used to help in fire suppression and to help stop the very devastating effects that an uncontrolled fire would have. 17. If alternate allotments are to be proposed for movement of Domestic sheep to mitigate conflicts with Bighorn sheep the allotments should have all NEPA work done before the decision to move the sheep is made. The allotments and forage reserves that were promised to be made available need to be NEPA compliant and ready to be grazed before any removal of domestic sheep from existing allotments. If a permittee is required to move his sheep to another allotment that allotment should be economically feasible for the producer and NEPA compliant before any action is taken on the allotments. 18. Grazing on these allotments should continue as is consistent with the ANF LRMP and the UWCNF plan. 19. Trailing of domestic sheep should be allowed to continue to access these allotments. 20. I do not support closing allotments to grazing or changing class of livestock on these allotments as these alternatives are not consistent with the ANF LRMP or the UWCNF plan. Thank you for allowing me to comment on the environmental analysis being conducted by the forest service. Sincerely Jeffrey Shaun Sims 122 Brookhollow dr Evanston WY 82930