3.8 Key Issue: Grazing Economics

Transcription

1 3.8 Key Issue: Grazing Economics Several scoping respondents and EA commenters identified the economic impacts of the proposed actions as an issue. Many of the actions proposed in this document would have economic impacts, both short-term and long-term. Some of those impacts are obvious (Figure 98), while others are more obscure. For example, some alternatives propose cross-fencing pastures to facilitate succession of native grasses. The economic impact of the cross-fencing is relatively apparent: material costs (government expenditures) for each mile of interior fence would be approximately $3,200; contract labor costs for each mile of interior fence would be approximately $4,000. Thus there would be an additional $7,200 of direct economic activity in the local economy for each mile of fence proposed. Figure 98. Installation of range infrastructure, such as this water tank, would have an economic impact that is relatively easy to quantify. Maier Allotment, Cedar River National Grassland, October Photo by Dan Svingen. The economic effects of the native grass succession, however, while no less real, are much harder to describe, as many questions necessary to quantify that economic effect are unanswered. For example: if the cross-fence was in place from 2010 to 2024, how many more pounds of forage would be produced per acre? What would the difference in beef gain be with and without the fence? What would be the market value of those differences in 2024? Would the changed habitat conditions increase recreational use of the site? If so, what kind, level, and season of recreational use would occur, and what would its economic impact be? Even though the potential range of economic impacts from proposed actions are broad, the public input received specifically referred to the economic impacts to the adjacent communities associated with different levels of grazing. The remainder of this discussion, therefore, will focus on the impacts to the local economy from changes in grazing levels, and planned government expenditures. To assess the potential economic impacts of proposed grazing levels to permittees and the surrounding communities, an agricultural economist from North Dakota State University-Hettinger Research Center was consulted, using funding provided by the USDA Forest Service s Dakota Prairie Grasslands, the Grand River Cooperative Grazing Association, and North Dakota State University (NDSU). Detailed analysis was provided by a USDA Forest Service natural resource economist and a USDA Forest Service social scientist (see Appendix 1, Table 1-1). 129

2 3.8.1 Existing Condition (Grazing Economics) The geographic scope of the economic analysis includes Corson and Perkins counties, South Dakota and Adams and Sioux Counties, North Dakota. This is an appropriate scope of analysis because even though the project would occur in Perkins Co., SD, the adjoining counties provide important inputs to the cattle ranching operations and serve as markets for beef cattle produced in the project area. For analysis purposes, we have used head months (HM) as the unit of measure (again, head months is the number of months a grazing animal is present, regardless of its body size). In Perkins County, South Dakota, the current market value for pasture forage is approximately $25 per HM (Dan Nudell pes. comm.). The price charged for pasture forage on National Forest System lands, however, is a fraction of that amount. In 2008, the rate was $1.35 per HM, which is 5% of current market value. The federal grazing fee schedule was developed by the United States Congress; federal grazing fees are not set by the USDA Forest Service nor by the Grand River Cooperative Grazing Association. The net fee charged to federal permittees is even lower than $1.35 per HM. This is because at least one half of the grazing fee may be credited as a conservation or land-use practice (or CP ) cost. Conservation practices are structural and nonstructural rangeland treatments on National Forest System lands that are approved by the District Ranger and are necessary to properly administer a grazing agreement or grazing permit. The annual grazing value can be adjusted to allow for cost incurred by grazing associations in carrying out required land use practices, including conservation practices and administrative activities. The USDA Forest Service shall require and approve only those practices that are necessary to achieve desired resource conditions as described in the land and resource management plan, project decisions and rules of management (FSH , 24.3). In practice, these funds have been used almost exclusively to pay for range infrastructure (fences, pipelines, tanks, etc.), the purpose of which may have been to protect or enhance other resource values and uses or to facilitate livestock management. Although the USDA Forest Service charges its permittee (the Grand River Cooperative Grazing Association) $1.35 per HM (or after accounting for CP costs, $0.68 per HM), that is not the cost borne by individual ranchers. That is because the Grazing Association itself assesses its members a surcharge for each HM. The additional funding collected is then used to further defray the costs of Grazing Association activities, including paying for staff and conducting fence and other rangeimprovement maintenance. In 2008, the Grand River Cooperative Grazing Association charged its members a total of $8.75 per HM, which is 35% of current market value. The extent of grazing that occurs on the project area s National Forest System lands varies year-byyear in response to range conditions. The grazing level in 2007 was fairly typical for recent years. A total of 26,773 HMs were billed by the USDA Forest Service. This resulted in $36,145 of grazing fees (i.e. $1.35/AUM x 26,773 HMs). Of that amount, $18,075 was set aside as CP funds. Combined surcharge and Federal fees paid to the Grand River Cooperative Grazing Association by its members for Grand River 1-5 allotments would have totaled about $234,263 (i.e. $8.75/AUM x 26,773 HMs). A rough estimate of the range of economic contribution made by the forage provided from National Forest System lands in the project area can be calculated by first looking at the range of market value for animals grown on project area grasslands. The basis for this assessment of livestock grazing economics is a spectrum of the marketing values, ranging from the marketings of forage provided 130

3 only on National Forest System lands to the marketings of all animals which spend any of the year foraging on project area national grasslands. For example, in 2007, there were 1.7 million cows and 425,000 calves marketed in South Dakota. The marketed animals would have required about 24,052,000 head months of forage (i.e. 1.7 million cows x 12 months + 425,000 calves x 8 months). These animals generated $1.8 billion in cash receipts. The 26,773 HMS of forage from the project area would have provided of these animal s forage requirements, and thus would have made a proportionate contribution to state marketings worth $2,009,642. For the upper end of the range, a slightly different estimate could be derived by comparing the total number of head likely marketed from the project area (estimated as 4,462 animals) to the total number of animals marked in South Dakota (i.e. 2,125,000 head). In this analysis, the Allotments 1-5 project Figure 99. The Dakota Prairie Grasslands sells forage which is used to raise calves that in turn are sold at local sale barns, providing local economic activity. Lemmon, Perkins Co., SD. March Photo by Drew Anderson. area would have contributed about of those marketed cattle; and thus would have generated about $3,754,000 in cash receipts. This range of marketing values leads to a range of employment and labor income estimates currently contributed from project area allotments. The 2007 IMPLAN model for the four-county area reveals a cattle grazing employment multiplier of 1.982, meaning that for each direct job in that sector there is about one more indirect/induced job contributed to the economy, or roughly two part or full time total jobs explained in the economy. While this is lower than often suggested, it is based on economic data for this area when using a 100% regional purchasing coefficient. Considering the contribution of cash receipts from just the federal forage in the project area, 13 direct and 27 total part and full-time jobs are contributed. When all cows, yearlings and calves spending time on project area allotments are considered these part-and full-time job estimates increase to a range from 19 direct to 40 total jobs. Similar to job estimates, a range of labor income estimates currently attributable to the Grand River 1-5 allotments was also modeled. The total labor income contributed by NFS forage alone and which is a result of cows and calves in the Grand River 1-5 allotments being marketed each year represents roughly $368,601 dollars each year. Because of the high labor income multiplier, the portion of indirect and induced contributions are greater than the direct contributions that make up this total. This is because the 2007 IMPLAN model for the four-county area reveals a labor income multiplier of 3.7, meaning that for each dollar of direct labor income earned there are roughly four dollars of 131

4 total labor income earned in the economy, when using a 100% regional purchasing coefficient. This is based on 2007 IMPLAN economic data for this area. Considering the contribution of cash receipts from all the cows, yearlings and calves which rely on project area allotments for a portion of the year, total labor income is estimated at roughly $725,553 per year. The economic contributions described above, while small compared to all employment in the economic impact area, are still a valuable component of the local economy and are especially important to the permitees who have developed operations based on the Grand River Grazing Association s permit with the Grand River National Grassland. These estimates form the basis of jobs and labor income comparisons for all alternatives in the direct and indirect effects section Direct and Indirect Effects (Grazing Economics) Proposed alternatives would affect local economics mainly by authorizing varying grazing levels on National Forest System lands in the project area, but also through changes in infrastructure expenditures. The most direct calculation of economic impacts is determining the cost that livestock permittees would pay to replace any forage that is no longer available from National Forest System lands under alternatives B, C, or D. This can be simply calculated by comparing the current cost of that forage (i.e. $8.75/HM) to the replacement cost (i.e. $25/HM). The total cost would vary by year, as the forage reductions from the National Forest System lands proposed under Alternatives B, C, and D would be phased-in over time. As shown in Table 24, annual costs of replacing forage would range from $0/year under Alternative A, $42,071 during 2010 to $107,331 during 2020 under Alternative B, $43,453 during 2010 to $159,754 during 2020 under Alternative C, to a maximum of $435,078 starting in 2012 under Alternative D. While these would be costs to the livestock producers, they would be revenues to anyone providing that forage. The majority of South Dakota's current Conservation Reserve Program (CRP) contracts will expire between 2009 and At the end of the CRP contract period, most landowners will make an economically-based decision whether to reenroll those acres in CRP, use the land for crop production, or use the land for livestock grazing. Increased demand for pasture land in the economic impact area would likely result in a greater proportion of expired CRP land being subsequently used for livestock grazing than would otherwise occur in the absence of that increased demand. As a result, we expect that actual economic impacts would be closer to the lower end of the range displayed for the alternatives. This explains why only the low estimates are provided in Table 24. Note: forage replacement calculations for Alternative A assume that current livestock grazing levels could be ecologically sustained at least through the year analysis period. If range conditions deteriorated faster than expected under Alternative A, then additional forage replacement costs and/or lower calf weights would be expected. Conversely, any higher calf weights that might result from improved range conditions under Alternatives B and C have also not been accounted for, as projected beef gain has not been modeled. Another simple comparison of economic impacts would be the value of proposed infrastructure and other projects. Alternative A proposes no new infrastructure. Alternatives B, C, and D however, propose installing new fences, water tanks, pipelines, planting native species, etc. There are 132

5 approximately $56,974 of such annual expenditures proposed under Alternative B, $93,413 under Alternative C, and $41,950 under Alternative D. Another way to assess economic consequences is to estimate the range of part and full-time jobs each alternative would support (Table 24). For this analysis we calculated the range of those labor income levels with the input-output analysis method, using the IMPLAN Pro software (MIG 2003). Here again all the estimates are based on the range of consequences with only federal forage on one end and all animals that rely at some point in the year on this allotments as the other end. This model includes both direct labor income, such as that generated by ranchers, farmers, and agriculture support employees, and indirect and induced labor income, such as that generated by ranching expenditures and those by the direct laborers in the local community (i.e. indirect and induced labor income accounts for the economic ripple effect ). Job and income impact estimates are based on the assumption that replacement forage is not available, and they include planned infrastructure investments. Under Alternative B, a peak range of jobs would be supported from National Forest System forage and projects during 2010 and a low range of jobs would be supported from National Forest System forage and projects during Under Alternative C, a peak range of jobs would be supported from National Forest System forage and projects during 2010 and a low range of jobs would be supported from National Forest System forage and projects by Under Alternative D, a peak range of jobs would be supported for 2010 and 2011, and a low of 2 jobs would be supported starting in 2012, and continuing through 2020 (Table 18). As just stated, the lower numbers of jobs contributed by Forest Service allotments and expenditures, with lowest levels projected to occur between 2015 and 2020 would not necessarily mean that all the jobs would be lost to the local community under Alternatives B, C, nor D, as much of the economic activity associated with those jobs could possibly move to other lands. Yet another measure of the economic consequences of proposed alternatives would be a comparison of the ranges of labor income derived from the allowable grazing on National Forest System lands in the project area under each alternative. As shown in Table 18, the proposed infrastructure from Forest Service expenditures and authorized grazing would support $396,995 - $721,052 in total (direct, indirect and induced) labor income under Alternative B in This range of this contribution would decrease to $341,705 - $612,219 by The change in annual labor income associated with Alternative C would be a short boost to labor income followed by a more rapid and slightly more severe decrease than Alternative B. This difference is associated with the quicker implementation of grazing level adjustments. The proposed infrastructure from Forest Service expenditures and authorized grazing would support $436,918 - $761,009 in total (direct, indirect and induced) labor income under Alternative C in This range would decrease to $338,501 - $567,286 by 2016, continuing into the future. As shown in Table 24, the proposed infrastructure from Forest Service expenditures would support $48,506 of total (direct, indirect and induced) labor income under Alternative D in each year from This would be down from the peak range under this alternative during 2010 from $417,107 $774,059. Again, this does not reflect any income that might be gained from activities 133

6 on non-national Forest System lands due to the moving of livestock grazing from National Forest System lands to those lands. In summary, Grand River 1-5 allotments currently help support a small portion of the economic impact area activity through direct ranching and indirect jobs and labor income. Permittees pay Federal grazing fees and grazing association surcharges for the forage used to grow beef. The three action alternatives would lead to different direct, indirect and cumulative impacts in the local economy. Rancher reactions would likely involve locating replacement forage, mainly from former Conservation Reserve Program (CRP) lands, as stocking level reductions were implemented on National Grassland allotments. This replacement forage would come at a higher cost than what is currently paid. As ranchers shift economic cattle production from Federal to other lands this would represent additional costs to current permittees, but at the same time it would be revenue to individuals with leasable forage. Alternatives B, C, and D, all include small levels of infrastructure expenditures which would partially counteract any negative impacts. Job and income impact estimates are based on the assumption that replacement forage is not available, and they include planned infrastructure investments. They do not include any potential range quality improvements which could enhance animal growth rates, and/or attract more recreation visitation to the local economy. Given these assumptions, Forest Service activities under Alternative B or C would contribute slightly fewer jobs and labor income than the existing situation, but far more jobs and labor income than would be supported under Alternative D after Because Alternatives B and C phase in changes to grazing levels, these alternatives would have less abrupt impacts to the local economic impact area than Alternative D. Table 24. Anticipated forage replacement costs, labor income and jobs estimates from permitted HMs authorized on National Forest System lands under Alternatives A-D. These represent the low end of impacts modeled using the two approaches because we believe that substitute forage availability will mean that impacts from implementation of alternatives will be limited to only those associated with the direct removal of federal forage marketings. ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D YEAR Cost to replace $0 $0 $42,071 $107,331 $43,453 $159,754 $0 $435,078 forage* Direct labor income $99,749 $99,749 $147,759 $132,797 $184,355 $157,722 $142,205 $42,256 Indirect labor income $268,852 $268,852 $249,236 $208,908 $252,563 $180,779 $275,102 $6,250 Total Labor Income $368,601 $368,601 $396,995 $341,705 $436,918 $338,501 $417,107 $48,506 Direct jobs Total Jobs Cumulative Effects (Grazing Economics) A wide variety of other factors affect grazing economics, including, but not limited to, market price for livestock and cost of other animal husbandry needs (vaccines, winter feed, etc.). Overall forage availability varies considerably year-to-year due to weather conditions. Forage availability from National Forest System lands elsewhere in the cumulative-effects area have also changed in recent years (see discussion above, p. 115). 134

7 3.9 Grasslands Plan Consistency The Grasslands Plan contains numerous goals, objectives, desired conditions, standards, and guidelines that are pertinent to this project. The full text of relevant goals, objectives, and desired conditions are listed above in Table 4. The full text of relevant standards and guidelines are available in the project file. One main difference between the alternatives would be the extent (i.e. quality) to which they contributed towards meeting Grasslands Plan goals, objectives, and desired conditions, as well as how many (i.e. quantity) of goals, objectives, and desired conditions were met. A summary of these differences is presented in Table 25. Table 25. Summary of proposed alternatives contribution to the Grasslands Plan s Goals, Objectives and desired conditions. NOTE: Y = yes, N= no, NA = not applicable. Refer to Table 1 for the full wording of each goal, objective, and desired condition ALTERNATIVE GOAL AND OBJECTIVES A B C D Improve and protect watershed N Y Y Y conditions Achieve 80% self-perpetuating riparian N Y Y Y areas & woody draws Achieve 80% PFC on streams N Y Y Y Provide for sustainable viable species Y Y Y Y Demonstrate positive trends in N Y Y Y populations or habitat Move forested landscapes toward N Y Y Y desired conditions Provide for wildlife during droughts N Y Y Y Increase or maintain grassland health Y - maintain Y - increase Y - increase Y-increase Move toward desired vegetative N Y Y Y composition & structure Retain useful range structures Y Y Y NA Improve protected areas Y Y Y Y Protect Special Interest Areas Y Y Y Y Annually provide livestock forage Y Y Y N Revise Allotment Management Plans to N Y Y Y meet desired conditions for Geographic Area Determine stocking rates using standard N Y Y NA method Improve capability to produce desired outputs N Y Y N Support plant, fish, and wildlife N Y Y Y Contribute toward desired conditions N Y Y Y for Grand/Cedar Geographic Area Contribute toward vegetative objectives N Y Y Y Contribute toward burn objective N Y Y Y Meet or exceed rest objective Y-exceed Y - exceed Y - exceed Y - exceed Improve or maintain sharp-tailed grouse habitat Y - maintain Y - improve Y -improve Y -improve 135

8 ALTERNATIVE GOAL AND OBJECTIVES A B C D Contribute toward desired conditions N Y Y Y for MA 2.1 Support desired conditions for MA 3.64 N Y Y Y Support desired conditions for MA 6.1 N Y Y Y Maintain, to maximum extent possible grazing program at current levels & provide habitat for grassland species N Y N N # of Goals, Objectives and desired conditions Alternative will not contribute towards meeting # of Goals, Objectives and desired conditions Alternative will contribute towards meeting Another difference between the alternatives would be their compliance with Grasslands Plan standards and guidelines. All alternatives would implement Grasslands Plan standards and guidelines except as highlighted in Table 26. Table 26. Grasslands Plan standards and guidelines that would not be met by proposed alternative(s). DIRECTION TYPE LRMP NOTES Manage land treatments to conserve site moisture and to protect long-term stream, wetland, and riparian area health from damage by increased runoff. Allow only those actions next to perennial and intermittent streams, seeps, springs, lakes, and wetlands that maintain or improve long-term proper functioning of riparian ecosystem conditions. Design activities to protect and manage the riparian ecosystem. Maintain the integrity of the ecosystem, including quantity and quality of surface and ground water. For streams identified as "non-functioning" or "functioning at risk with a downward trend, begin corrective action within 3 years of stream inventories. Modify livestock grazing practices as needed to reduce adverse impacts of drought to food and cover for prairie grouse and other wildlife. Standard 1-9 Alternative A would perpetuate the current conditions that are not adequately conserving site moisture or protecting long-term riparian health. Standard 1-9 Alternative A would allow current livestock grazing practices to continue. Some of those practices are not maintaining or improving long-term proper functioning of riparian ecosystems. Standard 1-9 Alternative A would allow current livestock grazing practices to continue. Some of those practices are not maintaining ecosystem integrity. Guideline 1-11 Alternative A proposes no corrective actions for stream segments rated as "non-functioning" or "functioning at risk with a downward trend. Note: this guideline applies to both perennial and intermittent streams. Guideline 1-13 Alternative A would continue to use the current case-by-case reaction to drought; that approach has not been effective in reducing adverse impacts to wildlife. 136

9 DIRECTION TYPE LRMP NOTES Use the following criteria at the project level to help determine where to manage for high structure habitat in as large of blocks as possible in upland areas for waterfowl, prairie grouse, and other ground-nesting birds: presence of moderate to highly productive soils; dominance of mid to tall grass species; proximity to waterfowl pairing ponds and or/prairie grouse display grounds; proximity to wetlands with well-developed emergent vegetation; proximity to cooperative waterfowl/wetland development projects and other major wetland complexes. Design and implement livestock grazing strategies to provide for thick and brushy understories and multi-story and multi-age structure in riparian habitats, wooded draws, and woody thickets, contingent on local site potential. Guideline Emphasize quality nesting and brooding habitat, consistent with Geographic Area objectives, within 1.0 mile of active greater prairie chicken and sharp-tailed grouse display grounds and 3.0 miles of active sage grouse display grounds. Consult Appendix H for a description of quality habitat for prairie grouse. Manage livestock grazing to maintain or improve riparian/woody draw areas. Implement the following practices: Avoid grazing activities, such as feeding, which concentrate livestock in riparian/woody draw areas. Control the timing, duration, and intensity of grazing in riparian areas to promote establishment and development of riparian species. When allotment management plans are revised, adjust stocking levels to account for the variations in liveweight of livestock if needed to meet desired vegetative conditions (see Appendix C). Guideline 1-13 Alternative A would continue current livestock management practices, which have resulted in very low levels of high structure vegetation in past years; that structure has not been retained in any purposeful pattern in relation to these criteria. Guideline 1-13 Alternative A would perpetuate the current quality of riparian habitats, wooded draws, and woody thickets. No quantitative monitoring has been done regarding the understories, structure, or age of wooded draws and woody thickets, though incidental observations have pointed out a lack of both understory structure and young age classes (example see figures in EA Chapter 3 regarding native tree stands). As explained in EA Chapter 3 and in the Soil and Watershed Briefing Paper, Proper Functioning Condition surveys have been completed on the project area's riparian areas, and have documented some segments of concern related to vegetative structure and age classes. Guideline 1-14 Alternative A would not result in attainment of Geographic Area objectives. Alternative B might result in that attainment, whereas Alternative C and D would achieve those objectives. Any habitat achieved would be generally well-distributed across the project area, as are current grouse display grounds (see Figure 84). Guideline 1-19 Alternative A would continue to degrade project area riparian areas. Alternatives B-D, however, would improve them. Guideline 1-19 Livestock weight would be accounted for under Alternative C. Livestock weight would not be accounted for under Alternatives A or B. No grazing would occur under Alternative D. 137

10 DIRECTION TYPE LRMP NOTES Prioritize and remove fences or water developments that are not contributing to achievement of desired conditions. Design and implement range management strategies for meeting desired vegetation objectives using existing monitoring information and stocking rate guidelines for livestock grazing (see Appendix I). Control the timing, duration, and intensity of livestock grazing to achieve desired structure and species composition objectives. Manage for high vegetative structure in areas where it would enhance nesting habitat for sharp-tailed grouse. Emphasize areas characterized by: presence of moderate to highly productive soils and range sites; proximity to sharp-tailed grouse display grounds; proximity to shrub habitats, private croplands and other sharp-tailed grouse foraging habitats. In areas used by wintering sharp-tailed grouse, maintain and enhance shrub patches and shrub components in wooded draws and riparian habitats. Prohibit livestock grazing in the following Special Interest areas: The Bog, Grand River Sand Dunes, White Butte, Black Cottonwood, and Burning Coal Vein/Columnar Junipers. Management activities that contribute to a loss of ecological integrity will be discouraged. Guideline 1-19 No range infrastructure would be identified for removal under Alternative A, regardless of their utility to achieving desired conditions. Guideline 1-20 Current range management strategies, which would be continued by Alternative A, were not, and are not designed to meet the Grasslands Plan s desired vegetation objectives. Guideline 2-7 Alternative A would perpetuate current livestock grazing timing, duration, and intensity; such grazing is not achieving desired vegetative structure or composition objectives. Guideline 2-7 Alternative A would continue to result in very low levels of high vegetative structure. Any such structure would not be purposefully managed to occur in these emphasis areas. Guideline 2-8 The entire project area receives some use by wintering grouse, although most winter use is concentrated on intermingled private lands (tree claims, hay pastures, feedlots, etc.). Alternative A would allow current livestock management patterns to continue, even though some of those practices are degrading shrub patches and components. Guideline 3-10 Livestock grazing would occur on White Butte under Alternatives A, B, and C. Guideline 3-43 Alternative A would allow continuation of current livestock management practices which are degrading ecological integrity, particularly in regards to riparian functionality, vegetative structure diversity, and vegetative composition diversity. 138

11 3.9.1 Consistency with Other Policy and Direction Environmental Justice Executive Order 12898, issued in 1994, ordered federal agencies to identify and address the issue of environmental justice (adverse human health and environmental effects of agency programs that disproportionately impact minority and low income populations). U.S. Census Bureau 2000 data reported 3,363 people living in Perkins County, South Dakota. Demographically, Perkins County was approximately 2% American Indian persons and 96% white persons. In 2007, 13.7% of the people in Perkins County lived below the poverty line, compared to an overall South Dakota state average of 13.2%. No adverse human health effects have been identified in regards to the management proposed under Alternative A-D. As shown above, current environmental effects from livestock grazing on the Grand River National Grassland are low to moderate. Alternative A would perpetuate the current level of effects, whereas Alternative B and C would lessen those effects. Alternative D would remove most of those effects. Executive Order also directed agencies to consider patterns of subsistence hunting and fishing when an agency action may affect fish or wildlife. Although the alternatives considered in this analysis have differing impacts on wildlife habitat, no alternative would alter opportunities for subsistence hunting and fishing by Native American tribes. Native American tribes holding treaty rights for hunting and fishing on the Grand River National Grassland have been provided an opportunity to comment on this proposal. Clean Water Act None of the project area streams are listed as impaired (303(d) list). The proposals contained in this document are consistent with the Clean Water Act of 1972, as amended in 1977 and Historic Preservation Act The proposals contained in this document are consistent with the National Historic Preservation Act of 1966, as amended in

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