BLM opens public comment on grazing in SPRNCA

Fences along the San Pedro Riparian National Conservation Area are to be repaired or installed to prevent cattle from trespassing into the protected area. 

TUCSON — Four grazing allotments partially located within the San Pedro Riparian National Conservation Area are up for renewal by the Bureau of Land Management. Concerned parties may comment on the draft Land Health Evaluations and leases through June 18.

According to Amy McGowan, Gila District planning and environmental specialist in a press release, the 10-year leases are for the allotments known as Babocomari, Brunckow Hill, Three Brothers and Lucky Hills east and west of the San Pedro River. They encompass 6,903 acres within the SPRNCA.

Each has been analyzed and draft Land Health Evaluations are underway. Each LHE identifies a preliminary assessment toward the attainment of Arizona Standards for Rangeland Health for each allotment. Assessments include health of foraging vegetation, percentage of bare ground, fencing needed to protect the river and water quality. The BLM will have to add about 39,640 feet of fencing to provide a barrier along the SPRNCA boundary for the four allotments.

“Under the adaptive management model, the BLM has identified triggers and thresholds,” McGowan said. “Each trigger was selected because it can either be directly attributed to the influence on the objective by livestock grazing on the allotment or because it is an overall good indication of watershed health.”

In order to determine the current impact of grazing on the SPRNCA a team of BLM specialists, which include a range management specialist, a biological science technician, a hydrologist, a natural resource specialist, an outdoor recreation planner and a cultural resources specialist, has been conducting an LHE for each of the four allotments.

There are three standards on which the team rated the lands.

Standard 1: Upland soils exhibit infiltration, permeability, and erosion rates that are appropriate to soil type, climate and ecological site.

Standard 2: Riparian-wetland areas are in proper functioning condition.

Standard 3: Productive and diverse upland and riparian-wetland plant communities of native species exist and are maintained. It requires the creation of allotment-specific desired plant community objectives in the resource management plan objectives and how vegetation is impacted by the cattle.

The BLM determines whether or not an allotment is meeting its objectives by monitoring key areas meant to represent the overall condition.

All four allotments meet the standard for vegetation in the uplands, Standard 1, but fail when it comes to meeting the desired resource condition, Standard 3. Whether or not the allotments meet Standard 3 is based in part on if allotments are meeting their specific desired plant community objectives as observed in key areas.

For instance, if an allotment loses perennial grasses below a certain point, the BLM can establish a lower number of cattle on the range or remove stock entirely so the range can regrow.

In cases of water contamination by E.coli, cattle may be removed from the pasture site nearest the river. E.coli has been recorded above permitted levels in the river, but generally the high readings only occur during flood events.

As part of the BLM resource management plan, the federal agency allows public comment on grazing leases. The BLM interdisciplinary team has worked to identify a preliminary purpose as well as a range of alternatives and issues all included in the draft, McGowan said.

“All of this information is written up in a scoping packet which is available to help you develop your scoping comments. The BLM will use scoping comments to refine the range of alternatives and the issues as well as to inform the impact analysis which has not yet been written,” McGowan said.

The BLM asks the public to comment on both the draft Land Health Evaluations, alternatives and the proposed lease renewals regarding issues, opportunities, concerns and suggestions for the proposed projects. Public comments will be used to identify potential environmental issues related to the proposed actions and identify project alternatives that also fulfill BLM’s purpose and need for action.

“A substantive comment provides new information about the proposed action, suggests an alternative to the proposed action that should be considered for analysis, makes factual corrections, and/or identifies sources of credible research which could be considered in the analysis,” McGowan said. “Examples of non-substantive comments include personal opinions or comments in favor of or against the proposed action without adequate reasoning. To be most helpful, comments should be as specific as possible and may include references to page numbers and paragraphs.”

Comments must be in by June 18. After the scoping period, the BLM will revise the range of alternatives and issues and draft the impact analysis. The next opportunity for public comment will be on the draft Environmental Assessment in August, according to the timeline.

The scoping packet is available on ePlanning, the BLM National NEPA register at:

Submit written comments by June 18.

Comments may be submitted via email to or via mail to: Tucson Field Manager BLM Tucson Field Office 3201 E. Universal Way, Tucson, AZ 85756.