Public Comment on American Prairie Reserve Bison Grazing

On July 21, 2021, PERC policy director Hannah Downey presented public comment before the Bureau of Land Management in support of the American Prairie Reserve’s request to graze bison instead of cattle on their federal grazing allotment.

Transcript of statement:

Hello—my name is Hannah Downey, and I’m the policy director at the Property and Environment Research Center. PERC is a conservation research institute dedicated to improving environmental quality through property rights and markets based in Bozeman. Thank you for the opportunity to share a comment in support of the American Prairie Reserve Bison Change of Use Environmental Assessment and the finding of no significant impact. 

Contrary to the lobbying and litigation model that can make conservation a source of conflict, APR seeks to establish a large nature reserve by purchasing private lands from willing sellers, operating grazing leases on neighboring public lands, and incentivizing neighbors to adopt wildlife-friendly practices. As PERC’s research has shown, federal grazing regulations too often exacerbate conflict and APR’s alternative market- and property-rights based approach can promote better conservation outcomes. For these reasons, we support Alternative B to allow APR to convert their public grazing permits from cattle to bison. 

The draft EA acknowledges that APR’s plan would likely improve the health of federal lands and the wildlife that rely on it. Plans to remove or upgrade fencing will reduce habitat fragmentation, facilitate big game migration, and improve Greater-Sage Grouse habitat. Additionally, the BLM has concluded the proposed action will help the agency meet and exceed standards for rangeland health and improve the overall health of riparian areas due to the unique grazing patterns of bison. 

As the EA also explains, APR’s request to convert some of its public grazing allotments from season cattle to year-round bison grazing will not harm the public’s interest in these lands. Here, an organization seeks to use its property rights and associated grazing privileges to pursue conservation. So while APR’s goals may differ from other grazers, the BLM’s consideration should be the same: are the landowner’s plans consistent with the health and improvement of public land? In this case, the answer is clearly yes. And this approach is nothing new—the BLM has approved bison grazing on at least 39 allotments in the West, including authorizing year-round bison grazing on two allotments leased by APR. To deny the change of use request would attack the public grazing rights of everyone by undermining flexibility for all permit holders. 

Montana’s ranchers and agricultural producers are important conservationists, and I appreciate their concerns over the future of their industry. People can disagree with the goals of APR, but there is no reason for believers in individual liberty, property rights, and free markets to abandon those values when a conversation group’s rights are at stake. Allowing APR to graze privately-owned bison on its federal allotments respects APR’s rights and, ultimately, honors all landowners’ rights to exercise their grazing privileges while promoting the health of federal lands. 

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