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EPIC Grazing Reform Project—Protecting the Marble Mountain High Country


As 2012 rushes forward, the Environmental Protection Information Center (EPIC) continues to work around the clock to protect and restore Northern California’s treasured environmental resources. Not surprisingly, certain high-profile matters rightfully capture the public imagination and spotlight. From its flagship Save Richardson Grove Campaign, to its efforts to safeguard Northern Spotted Owl habitat, to its endless monitoring of timber harvest plans on private industrial forestlands, EPIC has proven itself to be an effective, hardworking, and enduring champion of Northern California’s beloved flora and fauna.

In the midst of these preeminent initiatives, it’s not hard to overlook EPIC’s work on less eye-catching sources of environmental degradation. Among the many unsung endeavors is EPIC’s effort, in cooperation with the Klamath Forest Alliance (KFA), to reform livestock grazing in the Klamath National Forest. Felice Pace of KFA spearheaded the collaboration in 2010. A longtime environmentalist, wildlands explorer, and resident of Scott Valley, Pace has witnessed firsthand for over 35 years the environmental impacts of public lands grazing.

Appalled by the conditions, Pace took matters into his own hands. He would begin conducting compliance monitoring across select grazing allotments in the Trinity Alps, Marble Mountain, and Russian Wilderness Areas of Klamath National Forest.


Streambank trampled by cattle resulting in reduced riparian vegetation, streambank instability and sedimentation, Shackleford Allotment.


Before we proceed, let me briefly sketch a picture of how public lands grazing works.

An individual or permittee pays a small fee – often below market value – to the United States Forest Service (USFS) in order to gain access to a piece of land or allotment on which they will have exclusive rights to grazing. On the one hand, the FS acts as the representative of the government and is thus responsible for implementing and enforcing applicable laws, regulations, and rules. On the other hand, the permittee is responsible for managing their cattle in a manner that is consistent with the terms and conditions of their contract.

However, with inadequate enforcement by the USFS, the permittees are not held accountable and our natural resources are degraded. Hence, the need for a third party to hold the FS accountable.

As a rookie intern with EPIC, I started working with Pace to reform the way in which this process manifested. We began by submitting a Freedom of Information Act request to the USFS soliciting myriad documents relating to each grazing allotment. Upon receiving this trove of information, we reviewed the documents bearing two chief objectives in mind: 1) learn the rules of the road; 2) identify any aberration from those rules. As relative outsiders, we had to educate ourselves in order to be effective agents of reform.


Cattle waste adjacent stream between Lower and Upper East Boulder Lake, Mill Creek Allotment.


Thereafter digesting this information, we selected particular grazing allotments on which to conduct compliance monitoring. This is truly when the fun begins.

During 2011, Pace and I spent many days hiking throughout the awe-inspiring landscapes of the Klamath National Forest. With only the bare essentials crammed into our backpacks – save the chocolate and cheese – we trudged up and down mountains, traversed streams, wandered through old-growth forests, and glided across rolling pastures. The extensive diversity and distinct beauty of the Klamath National Forest is spectacular to behold. Our objective was straightforward: identify patterns of degradation and mismanagement that are not permitted within the contours of applicable environmental protections, and thereafter present our findings to the FS so as to stimulate reform that ensured more controlled grazing practices. Initially this process of identifying unacceptable environmental conditions was challenging; however, with practice and guidance from Pace, the task progressively became second nature. In essence, we sought to illuminate in-the-field conditions in order to hold accountable responsible parties for ecological injuries as well as excite a grazing management regime that manifestly safeguards our natural resources.


Bovine waste in wetland with surface scum near Upper East Boulder Lake, Mill Creek Allotment


Our findings suggest a rather entrenched mismanagement regime that unfortunately renders at risk certain natural resources. The most ubiquitous and worrisome observations included: 1) cattle waste having been directly deposited in wetlands and/or adjacent waterbodies; 2) cattle trampling streambanks leading to erosion and sediment pollution; 3) overutilization of vegetation in preferred meadows; 4) mechanical damage to vegetation in wet pastures and wetlands; 5) browse lines on willow and alder brush stands. The signature shortcoming of the existing management regime is the absence of a rule requiring regular range riding and herding by permittees. Our research suggests this regulatory inadequacy permits cattle to concentrate in preferred – often-unsuitable – locations for extended durations of time. This inevitably translates into concentrated ecological injuries. It’s a rather straightforward concept: if cattle are left to their own devices, they will adhere to their inherent preferences, notwithstanding environmental implications. In order to mitigate these impacts, we recommend the FS implements a mandatory minimum herding requirement for all permittees as well as require all permittees to keep and submit to the FS an annual management log. We believe the former measure alone would curtail the degree to which livestock grazing negatively impacts natural resources, whereas the latter would provide greater transparency and accountability.


Browse line on willow stand in Back Meadows, Big Meadows Grazing Allotment.


The politics of public lands grazing are not cut-and-dry. They are historically rooted in the contentious competition between the attainment of multiple-use objectives. Among these competing values are recreation, riparian management, wildlife habitat, endangered species management, and cultural resource protection. Understandably, stakeholders representing these various interests engage the decision-making process in order to buttress their particular use.

Meanwhile, the government strives to create a legal environment whereby multiple-use objectives are achieved. This balancing act, we recognize, is incredibly challenging and requires significant resources and commitment even in times of budget shortfalls and staff downsizing.

Nevertheless, it is the responsibility of government to adequately implement and enforce regulations that are on the books. This feature is cut-and-dry.


Victor Reuther overlooking Upper Albert Lake, Etna Creek Allotment.


At the end of the day, even environmental protection regulations crafted to perfection will fall short of safeguarding our natural resources if not adequately enforced. This realization is at the heart of our initiative. In the imperfect world in which we reside, civil society must learn to take matters into its own hands. As concerned critics of the existing grazing system in the Klamath National Forest, our vision isn’t one of eliminating grazing, but rather, ensures that an adequate enforcement regime exists so as not to leave vulnerable our precious natural resources. We believe it is the responsibility of mankind to safeguard the world’s treasured environmental diversity for future generations of all flora and fauna.

Victor Reuther has been interning with EPIC since September 2011. He is a recent graduate of Humboldt State University where he studied Political Science.  He will be attending law school this fall.

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