Pack Goat Ban in the Wind River Range

[Saph]

As many of you know, the Shoshone National Forest in Wyoming is revising its Forest Plan. One of the proposals is to close most of the Forest, including the spectacularly scenic and popular Wind River Range, to Pack Goat use. Many of us have submitted comments regarding this huge issue. Closing the Wind Rivers will set a precedent for ALL other Federal Lands that are also considering a ban on Pack Goat Usage.

Next week (January 20), the Final Environmental Impact Statement will be released. The following is a letter from the Shoshone National Forest. I apologize for any formatting errors:

Message from the forest supervisor
Dear forest plan enthusiast ,
I am happy to announce the upcoming release of our revised Land Management Plan (Plan), Final Environmental Impact Statement (FEIS), and draft Record of Decision (dROD) scheduled for January 24. The revised Plan is the culmination of several years of work for the Shoshone supported by your input and interaction.
The Plan, FEIS, and dROD will be available for your review on our website
(http://www.fs.usda.gov/detail/shoshone/l.../planning/? cid=stelprdb5379153) beginning the week of January 20. You are also welcome to request a compact disk containing the documents and maps by emailing us at Shoshone_forestplan@fs.fed.us or by calling the Shoshone at 307‐527‐6241. Compact disks will also be available at our Lander, Dubois and Cody District Offices as well as at the Shoshone Supervisor’s Office in Cody. Hard copy documents will be available for your review at local libraries and at our offices.
We will be holding four public meetings (see back page for dates and locations) during the week of February 24 to share information and answer any questions that you may have regarding the documents or the planning process.
The next steps in the planning process are a 60‐day objection period that will begin on January 24, followed by a 90‐day objection resolution period. The objection process is described in detail on the Shoshone website. Following the resolution of objections, the final Record of Decision will be signed and plan implementation will begin.
I think that we have a great revised Plan that will serve the public and the Shoshone well by providing quality visitor experiences and healthy ecosystems. We will continue to work with you as we design and implement projects that will move the Shoshone toward the desired conditions identified in the Plan. Thank you for your continued interest and input in our forest plan revision.
Joe Alexander
Issue 36 January 2014
The official publication for the Shoshone National Forest’s
Forest Plan revision :
the first national forest, planning in a new century

Please spread the word & join us in getting involved as this issue continues to develop--Saph

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Here is a list of important meeting dates:

Plan Revision Important Dates
Jan. 24, 2014 Release of revised Land Management Plan, FEIS and dROD ; objection period begins
Feb. 24, 2014 Public meeting: Cody, Grizzly Hall, Park County Library, 5 ‐ 7 p.m.
Feb. 25, 2014 Public meeting: Dubois, Headwaters Art & Convention Center, 17 Stalnaker St, 5 ‐ 7 p.m.
Feb. 26, 2014 Public meeting: Lander, Monarch Hall, Pronghorn Lodge, 150 East Main St, 5 ‐ 7 p.m.
Feb. 27, 2014 Public meeting: Thermopolis, Big Horn Federal Savings Bank, 643 Broadway St, 5 ‐ 7 p.m.
Mar. 24, 2014 Objection period ends
June 2014 End of objection resolution period
July 2014 Publication of Record of Decision

[Jake Levi]

Any updates on this?

This is bad news and an even badder wrong precedent.

Shortsighted buearcrats never ever make wise long range decisions, all is predicated on making themselves look good to those who handle their purse strings.

[Saph]

The objection period ends March 26, 2014.

Only those who provided substantive formal comments during the public comment period (which ended in March of 2012) are eligible to file an objection. So, if you filed a public comment period during that time, you can still file an objection.

How To File an Objection (reprinted from the Federal Register website):

Mailed, emailed, faxed or hand-delivered objections concerning this
action will be accepted for 60 calendar days following the publication
of this notice in the newspaper of record. The publication date is the
exclusive means for calculating the objection filing period. Those
wishing to object should not rely upon dates or timeframe information
provided by any other source. It is the responsibility of the objector
to ensure that the reviewing officer receives the objection in a timely
manner. The regulations prohibit extending the length of the objection
filing period.
Objections must be submitted to the reviewing officer at Thomas
Tidwell, Chief, USDA Forest Service, Attn: EMC--Administrative Reviews,
1400 Independence Ave. SW., Mailstop 1104, Washington, DC 20250-1104.
Objections may be mailed electronically to objections-chief@fs.fed.us
or by facsimile to 703.235.0138. The office business hours for those
submitting hand-delivered objections are: 8 a.m.-5 p.m. Monday through
Friday, excluding Federal holidays. Electronic objections must be
submitted in a commonly used format such as an email message, plain
text (.txt), rich text format (.rtf), or Word (.doc). In cases where no
identifiable name is attached to an objection, a verification of
identity will be requested confirming objection eligibility. If the
objection is supported by documents, with the exceptions listed in 36
CFR 219.54(b), all documents must be provided with the objection; a
bibliography is not sufficient.
At a minimum an objection must include the following (36 CFR
219.54©):
(1) The objector's name and address along with a telephone number
or email address if available;
(2) Signature or other verification of authorship upon request (a
scanned signature for electronic mail may be filed with the objection);
(3) Identification of the lead objector, when multiple names are
listed on an objection. The Forest Service will communicate to all
parties to an objection through the lead objector. Verification of the
identity of the lead objector if requested;
(4) The name of the plan, plan amendment, or plan revision being
objected to, and the name and title of the responsible official;
(5) A statement of the issues and/or the parts of the plan, plan
amendment, or plan revision to which the objection applies;
(6) A concise statement explaining the objection and suggesting how
the proposed plan decision may be improved. If applicable, the objector
should identify how the objector believes that the plan, plan amendment
or plan revision is inconsistent with law, regulation, or policy; and
(7) A statement that demonstrates the link between prior
substantive formal comments attributed to the objector and the content
of the objection, unless the objection concerns an issue that arose
after the opportunities for formal comment.
All objections are open to public inspection and will be posted to
the Forest Service Web site.

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Following the close of the objection filing period, the reviewing office shall issue a written response or
otherwise resolve the objections within 90 days. The reviewing officer may extend this time when it is
determined necessary to provide adequate response to objections or to participate in discussions with the
parties.

The Record of Decision for the revised plan will not be issued until the reviewing officer has responded to
objections and any work necessary to make the decision consistent with the response to objections is
completed. The final Record of Decision is expected to be issued in July of 2014.

More information is available on the Shoshone National Forest website at:
http://www.fs.usda.gov/shoshone/

[Saph]

Bump to keep this thread on top. The last day to file an Objection is this Wednesday, March 26, 2014. If you provided ANY type of comment during the official Comment Period in 2012, I strongly suggest you exercise your right to file an Objection.

[Nanno]

Oh, so does this mean that since I sent a letter in 2012 that I can send another one now? It sounded like I had to have lodged a more "official" comment or something so I was kind of confused. I'm also not sure what #4 and #7 should say. Can you post the information we need for #4 and clarify what #7 means?

[Saph]

Nanno, you do qualify, because you responded during the "Official" comment period.

Here is the information for #4:

Final Environmental Impact Statement (FEIS) and the Revised Shoshone Land Management Plan (EIS No. 20140007). The Responsible Official is Daniel J. Jirón, Regional Forester.

The objection must clearly state that it is an Objection to the Shoshone Land Management Plan Draft Decision. In electronic objections, the subject line should contain: Objection to the Shoshone Land Management Plan Draft Decision.

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For #7, you will need to refer to the following document:
http://www.fs.usda.gov/Internet/FSE_DOCU...446260.pdf

It is the response to all the comments that were received during the "Official" comment period.
You can do a "search" on Pack Goats to see how well they responded to your comment. Depending on what you see, and how you interpret the response, you can use that as a basis for your objection.

Basically, my response had to do with the fact that I didn't think they adequately analyzed the very tiny, marginal difference in risk between having a few carefully-managed, controlled pack goats, and having no pack goats at all, with respect to disease transmission between pack goats and wild sheep. And also the fact that they continued to lump pack goats with other domestic livestock (sheep and free-ranging goats) with respect to their analysis.

I told them to go back and do a better, more site-specific Risk Analysis. I told them to include Probabilities of Risk, not just the Risk itself. I told them to include mitigation measures & best management practices. I also asked them why they didn't include members of NAPGA and/or Pack Goat Users in their collaborative process & why they weren't listed as Contributors to the Plan.

I also said they inadequately analyzed the "ripple effect" (their words, not mine) that this Decision would have on the entire community of Pack Goat users on all Federal Lands that have Wild Sheep Habitat, because all Federal Land Managers are going to be using this Plan as a model when the the time comes for them to revise their own respective Land Management Plans. This Decision will not just affect the Wind River Range; it could potentially affect a HUGE area in the Western U.S.

So, depending on your comments, you can decide if you have grounds for an objection. I do know that NAPGA has hired a lawyer & that they plan on also filing an objection. I am going to file an objection because 1)what could it hurt? 2)I feel strongly enough about this Issue, and 3)the greater the number of people that object, perhaps the better chance we have of at least sitting down & discussing the issue with the Forest Service.

[Nanno]

That's helpful. Thank you.

[vigilguy]

FYI -
NAPgA's Attorney has submitted our official objections to the Shoshone National Forest in Wyoming. These were filed on March 20th, both by email and by certified mail. Our Attorney did a thorough job of providing well thought out objections for the USFS to consider.

More to come...

Charlie Jennings
NAPgA Land Use Chair

[vigilguy]

Hello friends and fellow goatpackers -

Here is the link to our attorney's website, with info on the latest appeal to the USFS Land Management Plan Revision. http://andrewirvinelaw.com/news/

I thought that all of you would be interested and would want to be kept in the loop.

Charlie Jennings
UTAH

[Saph]

Thanks, Charlie.

I sent in my Objection Letter via email this evening, one day short of the deadline.

Did the attorney give the name and title of the responsible official in the objection? Just want to make sure we have all our "Ts" crossed and "Is" dotted.

Again, The Responsible Official is Daniel J. Jirón, Regional Forester.