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Grazing Permit Renewals, New Mexico

Under contract with the Lincoln National Forest in New Mexico, Cirrus has completed the NEPA analysis required to issue grazing permits for 10 cattle and horse allotments on the Forest.  The allotments spanned from desert to high alpine ecosystems.  The proposed actions included adoption of recent changes in Forest Service grazing permit administration regulations, particularly the change to an adaptive management approach, as well as construction and maintenance of a number of range improvements.  Six separate Environmental Assessments (EAs), with associated Biological Assessments, Biological Evaluations, and technical reports, were completed as part of this effort.  Cirrus was responsible for assistance in all phases of the NEPA process except scoping, which was completed prior to issuance of the contracts.

The full range of physical, biological, and socioeconomic issues identified through scoping and internal, interdisciplinary review were assessed and documented in the EAs, identifying potential direct, indirect, and cumulative effects of the proposed action and alternatives on:

  Arrow Competition for Forage New Mexico
Arrow Federally Listed Plant and Wildlife Species
Arrow Noxious Weeds
Arrow Other Special Status Species
Arrow Recreation
Arrow Watershed and Riparian Conditions

Cirrus assisted the agency in determining the list of substantive issues to be addressed, finalizing the proposed actions, and developing alternatives.  We drafted detailed pre-EA mailings (i.e., summary of pertinent NEPA and Forest Service regulations, description of the proposed actions and alternatives, discussion of the public involvement process, the issues to be addressed in the EAs, and comment procedures) to solicit formal comment.  We then analyzed and responded to formal comments.  We managed an interdisciplinary team of employees to complete the technical analysis documented in the EAs and project record.  We completed all GIS-based analysis and mapping required in preparation of the EAs.  We wrote and produced the EAs itself, then compiled and indexed the administrative record.

The allotments included habitat for several federally llisted plant and animal species. We prepared Biological Technical Reports documenting detailed analysis of impacts on these species and on Forest Service sensitive species and Management Indicator Species.  We also prepared Watershed Resources Technical Reports addressing effects on watershed, soil, geological, and water resources.

Some of the agency’s decisions based on these EAs were appealed but upheld and were not litigated.  The grazing permits were successfully issued and grazing operations continued.  Some of the EAs and decisions have not been released due to the agency’s desires regarding timing.  The first EAs were begun in 2004, and the last were completed early in 2007. 

North Sheep Grazing Authorization EIS

Under subcontract, Cirrus worked with the Sawtooth National Forest to complete NEPA analysis of grazing permit issuance and Allotment Management Plan (AMP) revisions for four sheep and goat allotments on the Forest.  The project was highly controversial because of strong pro and con sentiments regarding grazing in the local community, recreational conflicts, and a range of environmental concerns, including potential impacts on a number of federally listed species. 

The Forest was under federal court order to complete this EIS by the start of the 2004 grazing season, which allowed 8 months to complete the entire process, from Notice of Intent through Record of Decision.  The project was completed on schedule as well as on budget.  Along with the EIS, we completed a Biological Assessment and Biological Evaluation.  These documents addressed direct, indirect, and cumulative effects in the following areas:

  Arrow Fisheries Resources North Sheep
Arrow Heritage and Cultural Resources
Arrow Rangeland Resources
Arrow Recreation
Arrow Soil and Watershed Resources
Arrow Vegetation Resources
Arrow Wildlife Resources

The Cirrus team assisted the agency in preparation and publication of the Notice of Intent and associated legal notices and press releases, in fleshing out the proposed action, in completing the scoping process and analyzing the results, in developing responsive alternatives, and in completing the analysis and documentation compiled in the Draft EIS.  We then organized and responded to comments on the Draft EIS and prepared the Final EIS to reflect changes driven by comments on the draft.  Finally, we compiled and indexed the administrative record for the project.

The project began in 2003 and was completed in 8 months.  The Forest Service decision was appealed unsuccessfully then litigated.  The federal court decision upheld the agency on points of the complaint related to the EIS but found for the plaintiffs on other points related to the Forest Plan.