Proposed Colorado Packgoat Ban - URGENT!!!

[Nanno]

Last week a working draft preview came out for the revised forest plan for three major National Forests in southwest Colorado: Grand Mesa, Uncompahgre, and Gunnison. Page 27 of the proposed plan says: 

"FW-STND-SPEC-16: To maintain effective separation among species in habitat occupied by bighorn sheep, the use of recreational pack goats and the use of goats and sheep for invasives and/or noxious weed management is prohibited." 

Since most of this enormous territory can arguably be claimed as bighorn sheep habitat, this means we could lose access to all three of these National Forests. We held our 2017 Rendezvous in Uncompahgre NF, and our current NAPgA banner was taken on top of Uncompahgre Peak. We cannot lose access to these magnificent places! 

That said, we have a very unique opportunity to get in on the ground floor of this forest plan. The draft is not yet published and we are not even to the objection stage yet. This may be the earliest we have ever had access to one of these plans, and we may be able to change it before it hits the press. 

They are holding their Part 1 webinar on Monday, June 24th from 9:00-11.00 and 4:00 - 6:00 MST. Part 2 will be held on Wednesday Jun 26th from 9:00-11:00 and 4:00 - 6:00. It is especially crucial that our Colorado members try to attend these sessions so our voices can be heard. 

There will also be several public meetings held between July 9-18th in various locations in western Colorado. If any of our Colorado members can attend any of these public meetings, please do so! 

Links and instructions for attending the webinars, and dates and times for the public meetings can be found here: 
https://www.fs.usda.gov/detail/gmug/land...eprd638482

The working draft of the Forest Plan can be read here: 
https://www.fs.usda.gov/Internet/FSE_DOC...638492.pdf

I would like us to pay particular attention to page 8 under "Public Enjoyment". A long list of recreational activities is provided and goat packing is not on that list. If we can get ourselves added to this list, it will be much harder for them to slap us with a blanket ban. We are here and we are important! 

[Perry]

In addition to the webinars and public meeting information, the Forest Plan page also includes a link for submitting online comments. The comment period is open to July 29, 2019.

https://www.fs.usda.gov/detail/gmug/land...eprd638482

[Nanno]

Thanks to everyone who was able to attend the webinars for the Grand Mesa, Uncompahgre, and Gunnison (GMUG) forest plan last week. The interests of goat packers were represented at each of the four webinars! 

What we learned: 
- The working plan is currently in pre-draft stage, which means we have a chance to change it before the official objection process begins. The Forest Service is not required to release the plan or take comments during this stage, and I believe the GMUG FS may be the first to ever put a plan out for public input before the official release. This is a rare opportunity! 

- The proposed packgoat ban is coded FW-STND, which is a forest-wide standard. This means packgoats would be banned from all 3 million acres with no flexibility, wiggle-room, or exceptions. Exact wording on page 27:
FW-STND-SPEC-16: To maintain effective separation among species in habitat occupied by bighorn sheep, the use of recreational pack goats and the use of goats and sheep for invasives and/or noxious weed management is prohibited.   

- We have until July 29th to comment on the GMUG plan. These comments provide no standing for the later objection period, however what I think the GMUG folks are trying to do is edit the plan now so they can deal with fewer official objections later on. When the document goes into the objection phase, the FS is required to answer each and every objection. I believe they are trying to avoid some hassle by drafting a plan using public input now to avoid facing backlash later on. We don't want hassle either, so let's not miss this chance!

- The GMUG plan includes many allotments for grazing domestic sheep. As much as 2/3rds (1.9 million acres) of the GMUG is designated grazing area. Since grazing sheep continue to be allowed in the proposed plan, there is no logical reason why packgoats should be banned as a way to protect bighorn sheep.    

What to do next: 
- If you live in Colorado (or you really feel like traveling), consider attending one of these open houses to make sure goat packers are represented: 
 
July 9- Hotchkiss, Heritage Hall, 403 East Bridge Street
July 10- Palisade, Community Center, 120 West 8th Street
July 11- Montrose, Event Center, 1036 North 7th Street
July 16- Norwood, Lone Cone Library, 1455 Pinion St.
July 17- Ridgway, 4H Center and Fairgrounds, 22739 US-550
July 18- Gunnison, Fred Field Western Heritage Center, Van Tuyl Room, 275 South Spruce Street
All open houses are from 5:00 - 7:00 p.m. 

- Write a letter requesting that goat packing be included in the list of activities important to the GMUG NF, that the ban on page 27 be removed, and that the reference to packgoats on page 143 be removed since packgoats are NOT an example of disease transmission to bighorn sheep (there is not one documented case of a packgoat giving disease to bighorns). Exact wording on page 143: 
To increase awareness, educate partners and visitors of the potential for pathogen transmission affecting native plants and animals (e.g., recreation pack goats and bighorn sheep, the need to decontaminate wading boots to reduce spread of chytrid fungus, or whirling disease, etc.).  

The Forest Service is looking for reasonable, substantive, and unique comments on this forest plan. They do not want form letters, and for this reason I have not written one up for those of you who have trouble coming up with the right words. However, I have attached a list of bullet points that may be helpful to you in drafting your own letter. If you ever visit Colorado, be sure to mention it in your letter since tourism has economic value to the state. Keep in mind that NAPgA sometimes holds Rendevous in Colorado (our 2017 Rendy was held in the Uncompahgre NF). 

Comments can be submitted to:  
gmugforestplan@fs.fed.us     

Or to the online comment form here: 
https://cara.ecosystem-management.org/Pu...ject=51806  

Or by old-fashioned paper letter this mailing address: 
Grand Mesa, Uncompahgre and Gunnison National Forests
Attn: Plan Revision Team
2250 South Main Street
Delta, CO  81416

Already written comments can be read here: 
https://cara.ecosystem-management.org/Pu...ject=51806

List of bullet points to consider when writing your letter: 

  PackgoatComments.pdf (Size: 26.7 KB / Downloads: 6)

[Kat]

Done, thanks for the list of helpful points!

[Perry]

I finally got mine entered today too.

[Nanno]

Thanks Perry! It looks like we have a lot of great comments submitted. I'd say there are more packgoat comments than on any other subject. Let's not get too comfy. It looks like we've got another comment period on the Sequoia and Sierra NF plans in California. There might be one on the Inyo (also CA) as well, but I can't remember if the Inyo is an open comment period, or if it's one where you have to have made a comment previously. I'll keep you posted and get some links up this week.

[Duck-Slayer]

I commented yesterday on the subject, hope they squash this proposal!
Matt

[Nanno]

Celia Adamac, Chris Cook, Vicky Jordan, Phil and I all had a meeting with the GMUG FS yesterday afternoon and I felt like it went really well. They learned a lot about packgoats and I think were able to voice their own concerns about bighorn sheep. We were given plenty of time to explain why packgoats are not only an extremely unlikely disease source, but also why they are unlikely to ever come in contact with a bighorn sheep. I feel like we were heard and I hope this shapes their plan in a positive direction.

Some disturbing news, though--Rio Grande NF is already in the objection phase of their plan and seem to have pushed it through without adequate scoping. The plan contains a packgoat ban. Since we were not informed until this stage, we may not have standing for an objection. However, if they did in fact violate procedure in their scoping process, we may be able to still get our foot in the door. Since I'm in Utah for the next two weeks I'm hoping Celia can take the reins on this one. It sounds like Colorado Parks & Wildlife are the ones pushing these bans, and this is very similar to what I just heard from the Sierra/Sequoia folks in California. Out there, CA and US Fish & Wildlife are the ones pushing the packgoat ban agenda, and in the Sierra/Sequoia case, bighorn sheep were not even a species of concern in the area but F&W pushed the packgoat ban on them anyway as a preemptive measure, and probably to give precedent for Inyo where the BHS actually are. It's a very frustrating situation. But one of the best things to come out of yesterday's GMUG meeting is that they have said they'd like to put NAPgA in touch with the CO Parks & Wildlife people and arrange a meeting with them so we can discuss the packgoat/bighorn issue with them directly. I think this would be a big step in the right direction since they influence what happens in all of the FS/BLM plans in the state.

[blackie's maiden]

Oh, goodness. I hope and pray you all win your battle with these folks.