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Help protect the Rio Grande del Norte National Monument!

Your comments are needed to respond to BLM’s Proposal to “treat” nature in Rio Grande del Norte National Monument!

The Bureau of Land Management has proposed a “treatment” of 106,634 acres of the Rio Grande del Norte National Monument in northern New Mexico in order to recreate “appropriate vegetation communities” so that the species that depend on them will thrive.

To accomplish this 50-70% of 70,000 acres will be subject to prescribed burns. Thinning will be prescribed on about 15,000 acres, “providing fuelwood and wood products for local industries,” according to the Taos News. And up to 70% of the 20,000 acres dominated by sagebrush could be treated with the herbicide tebuthiuron, banned in Europe since 2002.

The first thing to know about this is that the Rio Grande del Norte National Monument was established on March 25, 2013, in order “to preserve its cultural, prehistoric, and historic legacy and maintain its diverse array of natural and scientific resources, ensuring that the historic and scientific values of this area remain for the benefit of all Americans.” The consortium that is submitting comments with The Sangre de Cristo Audubon Society notes in its comments that: “We note the emphasis in the proclamation on the preservation of the Objects of the Monument [their bolding] which include the significant ecological diversity and the cultural, wildlife, ecological, geological, and archaeological resources of the monument.”

Bottom line, the BLM has not produced a general management plan for the monument in the seven years of its existence, and the proposed “treatment” analysis is based on a 2012 Taos Area Resource Management Plan conceived before the national monument was declared. No “treatment” of the national monument should even be considered before a management plan is prepared.

Here are some points to make in responding to the BLM draft Rio Grande del Norte National Monument Cones Fire Project Environmental Assessment.

* A management plan must be developed for the monument before any major “treatment” is attempted which should be based on scientific inquiry into whether there is any need for a project like Cones Fire Project;

* While there is no doubt that livestock grazing and fire exclusion have altered Pinyon-Juniper woodlands in the Monument, no scientific evidence supports the BLM claim that Monument woodlands are “overstocked” or “unhealthy.”

* As Sangre de Cristo Audubon and its consortium note, “Unless the specific natural or human causes can be distinguished for a site, restoration is likely to be ineffective or possibly misdirected. The first step in effective restoration is to identify and then modify the cause of degradation.”

* Although Cones is presented as a “Fire Project,” it includes the use of the herbicide Tebuthiuron and disking and seeding to suppress Sagebrush on a large scale. Unregulated grazing in the 20th century is the likely cause of the condition of Sagebrush stands in the Monument, so while grazing is allowed there, the impact of continued grazing should be considered in the draft Environmental Assessment, but it is not. A Monument management plan based on science should consider how grazing should be managed before any restoration prescription is attempted.

* The restoration methods proposed have been widely used elsewhere on BLM land, but the Draft EA contains no analysis of how successful they have been at enhancing grasses and forbs in Sagebrush. The Audubon consortium comments that: “There is a history here of these types of activities and if adaptive management is to mean anything at all, past results of these activities should inform this analysis.” They continue, “if those past activities were unmonitored, there can be no justification for their use in this case. Just because they have been used before is not a justification for continued use.”

Goshawk having lunch on Cerro de la Olla, RGdNNM © John Miles

* The proposed “treatment” will affect several species of birds in the Monument identified as threatened by the New Mexico Avian Conservation Partners, especially Juniper Titmouse, Pinõn Jay, Woodhouse’s Scrub Jay, and Virginia Warbler, among many others.

* The proposed “treatment” includes the proposed Cerro de la Olla Wilderness which was introduced as legislation in January by New Mexico senators Martin Heinrich and Tom Udall. The BLM seemingly does not recognize this proposal and proceeds to manage the area under its general 2012 Regional Management Plan, which is unacceptable in light of pending legislation.

The overall goal of the Cones Fire Project seems to be to remove forest and Sagebrush in order to encourage native grasses and forbs, which the ranching community enthusiastically supports. History shows, however, that the proposed methods often lead to invasion by species such as Cheatgrass. The proposal favors grazing over other Monument values and should not be implemented until all such values have been described, their condition assessed, and a plan to manage for these values developed.

TIME IS SHORT! How you can help Rio Grande del Norte National Monument:

Please submit comments online by September 5, 2020, to the Taos BLM at Eplanning.blm.gov/eplanning-ui/project/2001177/510

Or send written comments postmarked no later than September 5, to
Bureau of Land Management,
Attention Kyle Sahd
226 Cruz Alta Road,
Taos, NM 87571

The environmental assessment and related maps can be viewed online at
Eplanning.blm.gov/eplanning-ui/project/2001177/510

Featured Image: Cerro del Yuta from Cerro de la Olla, RGdNNM © John Miles

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