We just received word from Chugach National Forest (CNF) late January 28th that announced CNF's decision to rescind the llama ban in Chugach National Forest. (See previous blog posts for background/history on CNF's LMP and llama ban.) The "Reviewing Officer's Response to Eligible Objections" to the Chugach National Forest Land Management Plan (CNFLMP) was attached to an email sent to objectors. In the Conclusion section David Schmid (CNF Regional Forester) states:
"After considering the planning record, discussions with Forest staff, and the thoughtful dialog at the resolution meeting, I’ve decided to provide Forest Supervisor Schramm instructions to change FWWLGOAT-S (2) to the following: Personnel conducting Forest Service management actions or authorized activities (employees, contractors, cooperators, and special use permit holders) shall not use or keep domestic goats or sheep on National Forest System lands within the Chugach National Forest." (Note: verbiage related to llamas has been removed as requested by objectors.)
He further states: "I am also instructing Forest Supervisor Schramm to remove references to llamas (or lamas) as potential vectors for the transfer of pathogens to Dall sheep or mountain goats from the FEIS. This may be completed in an errata to the FEIS." (Copy of complete CNF response below picture.)
The CNF website states that a final Record of Decision will be issued by the Forest Supervisor. The Land Management Plan will be effective 30 calendar days after publication of the legal notice along with the approval of the final Record of Decision, in the newspaper of record, the Anchorage Daily News. The Record of Decision is expected to be signed in April 2020. Check here for updates Chugach National Forest Land Management Plan Updates and Information
It's worth noting that this was accomplished without any attorneys or legal assistance. This goes to show that if the llama community is vigilant and participates in the process, we can often make a difference Thanks again to all who participated. Also thanks to CNF for listening. Stay vigilant...
Chugach National Forest Land Management Plan Revision Response to Eligible Objectors, January 27, 2020
Issue Summary – Llamas as Disease Pathogens
There were multiple objectors who contended that the Forest Service violated NEPA for failing to provide public notice of a change between the DEIS and FEIS which would eliminate pack llamas and failing to support the analysis and draft ROD with science and rationale.
dynamics for South American camelids. However, the mere lack of documented transmission from
camelids to wild ungulates cannot be considered evidence that transmission has not or could not occur (Centre for Coastal Health 2017). NEPA allows for changes and clarifications between the draft and final EIS. However, I find that the change in the FEIS was not easily identified by the reader as llama was misspelled as ‘lama’. Also, the FEIS lacked rationale as to why lamas were the only domestic livestock species, aside from sheep and goats, which was identified as a potential vector for pathogens to Dall sheep and mountain goats. Chugach National Forest Land Management Plan Revision Response to Eligible Objectors, January 27, 2020
resolution meeting, I’ve decided to provide Forest Supervisor Schramm instructions to change FWWLGOAT-S (2) to the following:
Personnel conducting Forest Service management actions or authorized activities (employees,
contractors, cooperators, and special use permit holders) shall not use or keep domestic goats or
sheep on National Forest System lands within the Chugach National Forest. [Standard]
"After considering the planning record, discussions with Forest staff, and the thoughtful dialog at the resolution meeting, I’ve decided to provide Forest Supervisor Schramm instructions to change FWWLGOAT-S (2) to the following: Personnel conducting Forest Service management actions or authorized activities (employees, contractors, cooperators, and special use permit holders) shall not use or keep domestic goats or sheep on National Forest System lands within the Chugach National Forest." (Note: verbiage related to llamas has been removed as requested by objectors.)
He further states: "I am also instructing Forest Supervisor Schramm to remove references to llamas (or lamas) as potential vectors for the transfer of pathogens to Dall sheep or mountain goats from the FEIS. This may be completed in an errata to the FEIS." (Copy of complete CNF response below picture.)
The CNF website states that a final Record of Decision will be issued by the Forest Supervisor. The Land Management Plan will be effective 30 calendar days after publication of the legal notice along with the approval of the final Record of Decision, in the newspaper of record, the Anchorage Daily News. The Record of Decision is expected to be signed in April 2020. Check here for updates Chugach National Forest Land Management Plan Updates and Information
It's worth noting that this was accomplished without any attorneys or legal assistance. This goes to show that if the llama community is vigilant and participates in the process, we can often make a difference Thanks again to all who participated. Also thanks to CNF for listening. Stay vigilant...
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Resurrection Bay as seen from the Lost Lake Trail, Chugach National Forest (Alaska)
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CHUGACH NATIONAL FOREST
LAND MANAGEMENT PLAN
Reviewing Officer Response to Eligible Objections
LAND MANAGEMENT PLAN
Reviewing Officer Response to Eligible Objections
Chugach National Forest Land Management Plan Revision Response to Eligible Objectors, January 27, 2020
Issue Summary – Llamas as Disease Pathogens
There were multiple objectors who contended that the Forest Service violated NEPA for failing to provide public notice of a change between the DEIS and FEIS which would eliminate pack llamas and failing to support the analysis and draft ROD with science and rationale.
Objectors
Alexa Metrick, Barbara Baker, Bonnie Borowiec, Chela Grey, Dan Marshall, Dr. Kris Bogovich, Elain Partlow, Eran McCarty, Geri Rutledge, James Cook, JC Sheppard, Jeanine Jenovino, Jerrika Mumford, Joy Pedroni, Kaitlyn Lewis, Kaitlynn Virgo, Lanea Burns, Leigh DiNatale, Linda Hayes, Linda Nuechterlein, Michelle Kutzler, Phil Nuechterlien, Ramona Simpson, Robert Rutherford, Scott Woodruff, Shelley Loveless, Sona Gardner, Stan Ebel, Steven Auld, Thad Okerlund
Objectors’
Proposed Remedies
Do not identify llamas as a disease threat to wild sheep or other wildlife as referenced in the FEIS and the Land Management Plan. Rewrite the Land Management Plan FW-WLGOAT-S (2) to exclude llamas
Background
Between the DEIS and FEIS the Forest Leadership Team met with the Forest Land Management Planning Team and discussed the potentially catastrophic and the ecological consequences that could potentially result from transfer of pathogens from domestic livestock, including llamas, to Dall sheep and mountain goats. The Forest Leadership Team determined that due to those potential consequences, and in the absence of past or current use of domestic sheep, goats or llamas by Forest Service personnel, contractors or special use permit holders, prohibiting the use of these animals by Forest Service employees, contractors or special use permit holders on the Chugach National Forest would minimize the risks to three important and highly valued wildlife species (Dall sheep, caribou, and mountain goats) inhabiting the Chugach National Forest and the vast interconnected network of public and private lands without affecting any current Forest users (Meeting Notes from 12/18/2018 Record # 6053). Such changes between the DEIS and FEIS to supplement, improve or modify its analysis are allowed in NEPA (40 CFR 1503.4 (a)(3)). After this meeting, the response to concerns about Dall sheep and mountain goat populations was revised to include the (misspelled) word “lama,”
Response
Currently, there is little peer-reviewed literature addressing the prevalence and pathogen transmissiondynamics for South American camelids. However, the mere lack of documented transmission from
camelids to wild ungulates cannot be considered evidence that transmission has not or could not occur (Centre for Coastal Health 2017). NEPA allows for changes and clarifications between the draft and final EIS. However, I find that the change in the FEIS was not easily identified by the reader as llama was misspelled as ‘lama’. Also, the FEIS lacked rationale as to why lamas were the only domestic livestock species, aside from sheep and goats, which was identified as a potential vector for pathogens to Dall sheep and mountain goats. Chugach National Forest Land Management Plan Revision Response to Eligible Objectors, January 27, 2020
Conclusion
After considering the planning record, discussions with Forest staff, and the thoughtful dialog at theresolution meeting, I’ve decided to provide Forest Supervisor Schramm instructions to change FWWLGOAT-S (2) to the following:
Personnel conducting Forest Service management actions or authorized activities (employees,
contractors, cooperators, and special use permit holders) shall not use or keep domestic goats or
sheep on National Forest System lands within the Chugach National Forest. [Standard]
I am also instructing Forest Supervisor Schramm to remove references to llamas (or lamas) as potential vectors for the transfer of pathogens to Dall sheep or mountain goats from the FEIS. This may be completed in an errata to the FEIS.
As scientific literature addressing the prevalence, and pathogen transmission dynamics for South American camelid pathogens becomes available the Forest may choose to once again address this issue. With the above instructions, I consider these objections resolved.