Sunflower Grazing Allotments Reauthorization Action Alert

Comments Due By Thursday, December 24th!

Denuded livestock pond with trampling and overgrazing around the pond

The “Sunflower Grazing Reauthorization and Wildlife Habitat Improvement Project” Environmental Assessment’s Proposed Action (alternative 2) would reauthorize cattle grazing on Ochoco National Forest public/treaty lands on the Paulina Ranger District despite widespread severe over-grazing and long-term riparian damage to creeks and springs threatening Sensitive Redband trout and Columbia Spotted frogs, downstream Threatened Mid-Columbia Steelhead trout, and many Sensitive or declining bird species, including the Greater Sage Grouse, as well as harming meadow habitat for Sensitive native Bumblebees and a Sensitive butterfly, and removing needed forage for native Mule deer, Rocky Mountain elk, and Pronghorn.  Many Sensitive plants, especially riparian plants, would also be at risk from continued cattle grazing.

You can submit comments by Thursday, December 24th, to:

The Forest Service online comment system at:
Or mail comments to: Johanna Kovarik, District Ranger, 3160 NE 3rd Street, Prineville, OR  97754

You can access the Forest Service’s Environmental Analysis (EA) on the project web page: under the “Analysis” tab.  For questions or a fax number for sending comments, contact Jacob Young at (541) 416-6409 or via email at   There is also more information about the proposed action alternative below.                                                                                                              

Redband trout in creek (Sunflower Livestock Grazing Allotments)

Following are some of our key concerns about the proposed action and reasons to support either the No Action alternative 1 in the Forest Service’s EA, or a modified alternative we are suggesting that would phase out livestock grazing over two years as with No Action and include proposed active riparian restoration, but not the extensive conifer thinning planned unless it is reduced to the typical non-commercial size limit of 9” dbh and is done by hand only.

  1. The No Action or a modified No Action/Active Riparian Restoration Only alternative would have far greater benefits for riparian recovery and the for the viability and recovery of Threatened Mid-Columbia steelhead trout, Sensitive Redband trout, Sensitive Columbia spotted frog, and other aquatic life and riparian plant biodiversity than the proposed continuance of livestock grazing under Alternative 2 and would better meet Forest Plan standards and objectives and Clean Water Act requirements.
  • The proposed action would increase already widespread detrimental soil impacts to levels that would likely exceed Forest Plan standards, while the No Action or modified No Action/Active riparian restoration alternative would greatly decrease detrimental soil conditions and more quickly restore riparian areas and plant biodiversity.  The Environmental Assessment analysis supports our concerns.
Mating dragonflies (Sunflower Livestock Grazing Allotments)
  • Wildlife species that would be threatened by the proposed cattle grazing reauthorization but would benefit from the No Action or modified No Action/Active riparian restoration alternative include:  the Sensitive Greater Sage grouse; the Silver-bordered Fritillary butterfly; the Western bumble bee and the Morrison bumble bee; the Fir Pinwheel snail; Rocky Mountain elk, Mule deer, Pronghorn, and wild horses; Northern goshawk; Lewis’ woodpecker; raptors; and a number of Birds of Conservation Concern, including:  Calliope hummingbird; Olive-sided flycatcher; Willow flycatcher; Loggerhead shrike; Sage thrasher; Brewer’s sparrow; and Sage sparrow; as well as Focal bird species:  Chipping sparrow; Nashville warbler; Red-naped sapsucker; Red-eyed vireo; Yellow warbler; MacGillivray’s warbler; Western wood peewee; Warbling vireo; Vesper sparrow; Lincoln’s sparrow; and Savannah sparrow.
  • Sensitive plants that would be harmed by continued livestock grazing but would benefit from either the No Action alternative or our suggested modified No Action/Active riparian restoration alternative include the following, which are either documented or suspected to be in the area and are mostly associated with riparian areas such as creeks, springs, or wet meadows:  Henderson’s needlegrass; Wallowa needlegrass; South Fork John Day milk vetch; Bastard kentrophyta; Upward-lobed moonwort; Crenulate moonwort; Botrychium lunaria; Mountain moonwort; Twin-spiked moonwort; Peck’s mariposa lily; Lesser panicled sedge; Idaho sedge; Slender sedge; Retorse sedge; Bolander’s spikerush; Least rush; Ochoco lomatium; Northern adderstongue; Rafinesque’s pondweed; Wolf’s willow; Arrowleaf thelypody; Lesser bladderwort; Richardson’s calliergon moss; Star campylium moss; Great mountain flapwort; Schistidium moss; Pinkstink dung moss; Mucronleaf tortula moss; and Little brownwort. 
Garter snake in livestock pond (Sunflower Livestock Grazing Allotments)

The Proposed Action would increase the introduction and dispersal of exotic invasive plants.  Exotic invasive plants that would be increased by extensive ground disturbance through continued cattle grazing, extensive tree thinning, water development construction and reconstruction, and more fencing, plus the use of heavy equipment such as bulldozers for riparian restoration, include the already existing:  Bull thistle; Butter and eggs; Canada thistle;  Common mullein; Common St. Johnswort; Dalmatian toadflax; Diffuse knapweed; Houndstongue; Hardheads; Jointed goatgrass; Leafy spurge; Medusahead; North Africa grass; Oxeye daisy; Scotch cottonthistle; Spotted knapweed; Sulphur cinquefoil; and Whitetop, for a combined total acreage over the three allotments of 744.90 acres of invasive plants—before they are dispersed further by ground disturbance.

  • Procedural concerns about the Environmental Assessment violating the National Environmental Policy Act include:  an inadequate range of alternatives; inadequate cumulative effects analysis; inconsistency between the proposed action and the stated purpose and need; failure to use best available science or inaccurate use of the science in analysis of some of the issues; and failure to analyze the effects of continued cattle grazing reauthorization and other proposed actions in contributing to climate change.
Garter snake in livestock pond (Sunflower Livestock Grazing Allotments)

The proposed action would reauthorize cattle grazing of 800 cow/calf pairs on the Sunflower allotment and 263 cow/calf pairs on the Wind Creek allotment  from May 1-October 31, and 200 cow/calf pairs on the Dry Corner allotment from April 15 to October 31. These long grazing seasons allow cattle to consume early spring, summer, and late fall forage at the expense of wild deer, elk, and pronghorn. The proposed action  would include adaptive management (changes to livestock management such as changing the number of allowed cattle, changing the season of livestock use, and/or requiring active herding if cattle use reaches specified damage thresholds.  The proposed action would also construct eight new water “developments” that use wells or springs to supply water to the cattle at the expense of  local plants, wildlife, and hydrologic flows, erect four miles of new fence, reconstruct 26.2 miles of fencing, and also reconstruct 50 of the existing water developments. The proposed alternative would also plant riparian hardwoods lost to over-grazing and fell trees into stream channels to add missing large wood structure lost to past logging.  Additional riparian restoration using heavy equipment would be done on Begg, Columbus, and Cougar Creeks. Unusual for livestock reauthorization, the Forest Service would also implement 1,966 acres of non-commercial thinning of pines and firs up to 16” dbh (which is mature commercial size) and junipers up to 20.9” dbh–excluding juniper from felling that have old growth characteristics—to create more forage for the cattle that have over-grazed the allotments.  Conifers up to 20.9” dbh would be felled if they are considered to be encroaching on some of the last existing riparian hardwoods such as aspen and willows, or on Mountain Mahogany or historic shrub/grass habitat.  This seems to be a lot of subsidizing of destructive cattle grazing by private ranch permittees at public expense.

Thank you for sending comments to show public opposition to cattle over-grazing of public/treaty lands and to expensive and intensive management to justify its continuance when there are more ecologically sound alternatives.

Mountain blue bird drinking from polluted livestock pond (Sunflower Livestock Grazing Allotments)

If you would like to donate needed funds to support our ecological protection work please donate on our website at or by mailing donations to: 27803 Williams Lane, Fossil, OR  97830.  In-kind donations are also helpful, such as working digital cameras, binoculars, dbh forestry measuring tapes, compasses, tree-free or recycled paper, and non-perishable food such as coffee, tea, cooking oil, or nut butters for volunteers.

To volunteer for our field season, please leave a detailed message with your name & phone number at (541) 385-9167.

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