LETTERS

to the five-year average of $2.05 per pound. Leg quarters had been doing similar to last year through about April, but are failing to reach the high peak in price of last year. Chicken breast prices are similar to the five-year average and about 60 percent below last year.

Broiler production has been up moderately from last year so far this year. Hatchery output this

Submit your letters to: Editor, Wyoming Livestock Roundup, P.O. Box 850, Casper, WY, 82602, or e-mail to roundup@wylr.net. We reserve the right to edit letters. It is the policy of the Wyoming Livestock Roundup that we do not print letters attacking individuals, groups or organizations within the Wyoming agricultural community.

Dear editor, American Agri-Women (AAW) opposes the new rule language defining the nonuse of Bureau of Land Management (BLM) land as part of its multi-use mandate.

AAW believes agriculture is conservation.

BLM’s new rule could potentially bankrupt ranchers. Many ranches exist because they have grazing allotments. Ranchers can graze their livestock on BLM or Forest Service lands, which makes those ranches economical and improves the land by reducing the fuel loads for wildfires.

Animals are critical to the natural biological cycle. Grazing is an quarter is running slightly below a year ago, consistent with profitability in late 2022 and in 2023 to date. Reduced hatchery output will lead to slightly less chicken production in the second half of this year.

The weakness in the chicken sector prices is a bit puzzling given its relative bargain to beef at the retail level. Chicken is essential tool for managing land. If grazing is prohibited, ranchers will go bankrupt, invasive species will take over landscapes and we will have more catastrophic wildfires. Wildlife will suffer and multiple uses will become impossible.

BLM was formed in 1946. Thirty years later, the agency’s mission was set with the passage of the Federal Land Policy and Management Act (FLPMA). FLPMA gave the BLM its “multiple use mandate.”

Public land management means public lands have many resources, such as forage, timber, energy, habitat, etc., and public lands have many uses, well positioned in the meat case domestically, and LMIC expects to see an uptick in part prices later this year. such as grazing, recreation, mining, etc.

However, some of the discrepancy is the difference between wholesale chicken prices and retail chicken prices. Processors are expected to take some of this margin back later in 2023, supported by less production.

The multiple use mandate through FLPMA states the resources and uses on public land must be utilized in a balanced combination to best meet the needs of the people.

BLM published a proposed rule change in the Federal Register on April 3. This rule could effectively eliminate traditionally mandated multiple uses of BLM-managed lands.

Under this new rule, conservation would be a use like mining, grazing or timber. The new language defines nonuse as use and opens leases to be controlled by environmental groups or non-governmen- tal organizations (NGOs). Ranchers could lose their leases because of competition from deep-pocketed environmental groups or NGOs, which can now claim priority and compete for leases.

Under the new proposed rule for conservation leasing, BLM lands could be leased by thirdparty NGOs, which would cut off any other uses for decades and will likely become the administration’s primary vehicle for their 30 x 30 initiative.

Prior administrations have used the 1906 Antiquities Act which was created for emergency use for administrations to preserve delicate cultural artifacts and relics with the “smallest area compatible” for protected objects.

Recent administrations, however, have abused the century-old law to lock up land and create quasinational parks with our congressional approval.

This new rule change makes one wonder if BLM intends to lock up land by prioritizing conservation leases. It appears their objective is to end all economic use of public lands and stop grazing as a source of conservation management on public lands.

It should be noted a recent Supreme Court ruling in Sackett vs. EPA states agencies cannot gift themselves unlimited power.

Sincerely, American Agri-Women which is widely opposed by ag industry stakeholders across the West.

Public lands rule

Archuleta explained the idea behind the proposed public lands rule is multi-pronged.

“There are five areas the rule addresses. I won’t say they are good or bad, they simply just address them,” he stated.

“The rule emphasizes habitat restoration and provides some tools to make it a little easier and more efficient for BLM to undertake restoration,” Archuleta explained. “It also broadens the use of land health standards, which many permittees are familiar with through their grazing program, but will apply to all programs including oil and gas, coal and recreation as well.”

According to Archuleta, intact large landscapes are vast pieces of land across the West which haven’t been split apart or subdivided, and through their proposed rule, BLM hopes to keep them this way.

“We want them to remain intact and not split them up in any way, whether it be through energy development, housing, etc.,” he said.

BLM’s proposed rule also addresses the allocation of conservation leases – the idea a third-party entity could apply for a 10-year conservation lease – and facilitating compensatory mitigation – offsite habitat restoration to mitigate onsite impacts, such as those caused by a transmission line development.

“I know this topic has raised a lot of questions, and I’m sure BLM hasn’t thought of everything,” Archuleta said. “The devil is in the details, so I’m hoping public comment will illuminate a lot of areas we haven’t thought about.”

Producer concerns

Following his speech, Archuleta opened the floor to questions, concerns and comments from convention attendees.

An overarching concern shared between many producers is the affect conservation leases will have on livestock grazing.

“The intent of this rule is not to affect ongoing activity, but there is the potential, which is something we need to seriously consider when issuing a conservation lease,” Archuleta stated.

BLM Wyoming Range Program Lead Mark Gortel commented, “As it stands right now, a conservation lease would not impact preexisting uses. With this, if a producer has a grazing permit or lease, it would continue as it normally has, meaning they are issued for 10 years and once they expire, the preexisting preference holder has the first right to apply and renew, as long as they’re in good standing.”

Producers also voiced their unease regarding how conservation leases would be issued. Since permit leasing for grazing is a difficult process, many wonder if the same will be true for those who apply for a conservation lease, and they question what information would determine if someone was granted such a lease.

Producers also expressed their desire to be involved in granting third-party conservation leases, since lessees will have to be intimately involved with grazing planning or sagebrush treatment, for example.

In response, Archuleta explained a conservation lease application would have to go through environmental analysis.

“I would want to see some type of monitoring activity and benchmark to show they are achieving what they intend, or we stop the lease. But, those details haven’t been worked out,” he shared. “Obviously we can’t be biased about who applies for a permit, but we do need to get all of the information on what they intend to use the lease for.”

As for existing lessee involvement, Archuleta commented, “I think it would be critical. Who knows better how an activity will impact the land than a producer who has been grazing it for years. From my perspective, the existing lessee would have a say.”

Convention attendees also expressed their wish to have proper grazing techniques recognized under the definition of conservation.

“It is interesting the Federal Land Policy and Management Act of 1976, which guides the basis of BLM, doesn’t actually define con- servation,” Archuleta stated. “I come from the old-school Aldo Leopold way of management, who defined conservation as the wise use of resources, and two tools to accomplish this are the cow and the plow.”

He concluded, “I support public lands grazing, and I don’t want to see producers’ livelihoods impacted by another thing thrown on top of them. They lead busy lives and have a lot going on, and I don’t want to throw on another layer of burden.”

Ag industry opposition

In addition to the attendees at WSGA’s summer convention, opposition for the public lands rule has been felt from a plethora of ag industry stakeholders across the West.

In fact, on June 15, the House Committee on Natural Resources held a legislative hearing to require BLM to withdraw the proposed rule.

Wyoming Gov. Mark Gordon was among those to testify.

“This proposed rule was rushed forward without material input from Wyoming or other states,” Gordon said. “It did not have the benefit of the views of impacted public land users. The proposed rule mischaracterizes conservation, seeks to preempt wildlife management from the states and oversteps the bureau’s statutory authority. The best solution is to rescind the rule.”

Gordon also joined a handful of Western governors in penning a letter to the U.S. Interior Secretary Deb Haaland, describing the rule as “a solution in search of a problem.”

“Tens of millions of acres of BLM lands across the Western U.S. are already protected under strict federal designations such as national monuments, wilderness areas, wilderness study areas, areas of critical environmental concern, etc.,” the governors wrote.

“Of the remaining BLM lands still open to multiple use, there is still a very high bar set before any kind of surface disturbing activities can be authorized and many barriers to development in existing BLM resource management plans,” they added.

Additionally, on June 19, the Public Lands Council (PLC) announced the launch of a grassroots campaign against the proposed rule.

“The BLM must follow the law in managing our nation’s public lands for multiple use and sustained benefits for all,” said PLC Executive Director Kaitlynn Glover. “Public lands grazing is an important conservation tool which protects these landscapes and is integral to national food security.”

“We must remind BLM grazing is an essential use of our nation’s public lands, and I hope the public will join us in sending a letter to agency leadership underscoring their responsibility to be good partners – especially since they’ve fallen short in this rule,” she continued.

Those interested in sign- ing PLCʼs letter can visit p2a.co/VB9vf0B. Questions can be directed to Hunter Ihrman by e-mailing hihrman@beef.org.

In response to this slew of opposition, BLM extended the comment period for the proposed rule for another 15 days, bringing the total comment period to 90 days. The comment period will now close July 5.

Hannah Bugas is the managing editor for the Wyoming Livestock Roundup. Send comments on this article to roundup@ wylr.net.