December 15, 2014

USDA Forest Service

Mesa Ranger District
Attn: Kelly Kessler
5 140 E. Ingram St.
Mesa, AZ 85205
Via email: comments-southwestern-tonto-mesa@fs.fed.us
RE:

Sunflower Allotment Grazing Authorization

To Whom It May Concern:

The American Wild Horse Preservation Campaign (AWHPC) appreciates the opportunity to
submit preliminary comments regarding the proposed renewal of livestock grazing on the
Sunflower Allotment in the Tonto National Forest in Arizona.
AWHPC is dedicated to preserving the American wild horse and burros in viable free-roaming
herds for generations to come, as part of our national heritage. Our grassroots efforts are
supported by a coalition of over 60 historic preservation, conservation, horse advocacy and
animal welfare organizations representing over 10 million people nationwide.
The U.S. Forest Service (FS) proposes to reinstate grazing after 12 years of rest on the 158,000acre Sunflower Allotment. The 2013 decision to authorize grazing by more than 500 head of
cattle on the Sunflower allotment was remanded by the FS after receipt of an appeal by the
Center for Biological Diversity, which raised concerns about effects to sensitive species,
watersheds, riparian areas and wildlife habitat.
These concerns remain with regard to the new planning process, which seeks to authorize the
grazing of a maximum 525 head of cattle on this allotment.
The Sunflower allotment encompasses a sensitive Sonoran desert ecosystem, which, according to
the CBD, has been severely degraded by past and current land management. In addition,
conditions have changed on the Allotment since livestock grazing was rested 12 years ago. The
area is now heavily used for recreation purposes, including wildlife viewing, that are
incompatible with livestock grazing. Additionally, predictions of persistent drought in the West
and southwest due to climate change render livestock grazing untenable on these fragile desert
lands.
American Wild Horse Preservation Campaign, PO Box 1048, Hillsborough, NC 27278

Following are issues that AWHPC requests the FS to analyze in its Environmental Assessment
for this grazing authorization planning process:
1. Analyze and disclose the type, level and intensity of all recreational activities, including
wildlife viewing, and the impact that resumption of livestock grazing (Including fencing,
presence of livestock, equipment, etc.) would have on recreational uses of this area.
2. Analyze the impacts of forage consumption by livestock on forage availability for
wildlife in the area.
3. Analyze the impacts of livestock grazing on sensitive species in the area.
4. Consider the cumulative effects of livestock grazing in conjunction with current uses and
activities in the area, including motor vehicle use and fire suppression efforts.
5. Analyze the economic affects of the proposed reinstatement of grazing, including costs
incurred by the government to manage the Sunflower Allotment grazing program and
disclose what percent of those costs are covered by grazing fees charged.
6. Assure a transparent process that uses public and peer reviewed data and scientific
models, and places a high value on public opinion.
7. Clarify through more precisely detailed close-view maps the areas of exclusion and
inclusion for grazing, and the boundaries between the two; also clarify if those
boundaries are currently fenced or unfenced and will be allowed to be fenced in the
future.
8. Consider the impacts of grazing reinstatement in conjunction with climate change and
drought predictions for the geographical area in which this allotment is located.
9. Consider the impacts on the watershed and riparian areas caused by the presence of up to
525 cattle in this area.
10. Consider the social impacts of the proposed action, including the prevailing social
preference for use of this area for recreation, including wildlife watching.
11. Fully consider all viable alternatives to this proposed action, including the permanent
closure of this allotment to livestock grazing.
12. Fully analyze the cumulative impacts of the proposed action in conjunction with range
degradation caused by past mismanagement and overgrazing on the Sunflower
Allotment.
Please add the American Wild Horse Preservation Campaign, PO Box 1048, Hillsborough, NC
27278, sroy@wildhorsepreservation.org to your interested party list for this planning action.
Thank you for your consideration.
Sincerely,

Suzanne Roy, Director