Chuck Sylvester's response to an attack
Colorado Cattlemen’s Association
8833 Ralston Road
Arvada, CO 80002-2239
Arvada, CO 80002-2239
Public Lands Council
National Cattlemen’s Beef Association
1301 Pennsylvania Avenue NW, Suite 300
Washington DC 20004
Dear CCA, PLC and NCBA, February 22, 2017
It has just been brought to my attention that your organizations, the Public Lands Council (PLC), Colorado Cattlemen's Association (CCA) and the National Cattlemen's Beef Association (NCBA) filed a joint objection to my involvement with the Range Allotment Owners Association (RAO).
From my years of observation, I’d have to agree with your collective claim, “Public Lands Council is the only organization in Washington, DC, who solely represents the 22,000 ranchers who operate on public lands.”
Please understand though, that as a Range Allotment Owner, PLC doesn’t represent me. And because I couldn’t find an entity that does protect Property Rights on Range Allotments, I helped co-found RAO.
RAO is only concerned about the Property Rights of Range Allotment Owners. PLC represents ranchers on public lands. These two needs are wholly different.
I like to exercise preventive maintenance by resolving situations before they get out of hand and end up in court. RAO is an essential form of preventive maintenance.
Due to the vast difference between RAO and PLC, it is my assessment that the PLC should be relieved they don’t have to add another department beyond their long-standing representation of the public on public lands.
Now you know why I enthusiastically co-founded the Range Allotment Owners Association.
Thank you in advance, for supporting my endeavor to protect my Property Rights on my Range Allotments.
Charles W. Sylvester
Ranch Owner and Retired General Manager of National Western Stock Show
|FOR IMMEDIATE RELEASE|
PLC and Legal Community Comment on the
WASHINGTON (Feb. 20, 2017) -- Ethan Lane, executive director of the Public Lands Council, today released the following statement and open letter regarding the Range Allotment Owners Association:
"The Public Lands Council is the only organization in Washington, DC, who solely represents the 22,000 ranchers who operate on public lands. Since 1968, PLC has had boots on the ground in the halls of Congress and the federal land management agencies, working to ensure that rancher’s voices are heard.
"Recently, a group has materialized, claiming to be the only organization that represents the public lands rancher. This group, called the Range Allotment Owners Association, is advancing a compelling but dangerous theory, that ranchers who hold grazing permits on public lands are not merely permittees, but allotment owners. While we at PLC fight every day for the preference and property rights of ranchers, we feel that this particular theory goes beyond our legal rights and could ultimately result in the loss of permits and subsequent destruction of family ranches.
"We are lucky in this industry to have a deep bench of legal talent that is focused on our issues and represent our interests in the courts. These assembled legal minds have released the following open letter on this general topic, which we present to you independent of our opinions and analysis. That so many of the names on the attached letter will be familiar to you is a testament to their commitment to our industry and their years of work on behalf of ranchers."
PLC has represented livestock ranchers who use public lands since 1968, preserving the natural resources and unique heritage of the West. Ranchers who utilize public lands own nearly 120 million acres of the most productive private land and manage vast areas of public land, accounting for critical wildlife habitat and the nation's natural resources. PLC works to maintain a stable business environment in which livestock producers can conserve the West and feed the nation and world.
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1301 Pennsylvania Avenue NW, Suite 300 Washington DC 20004
Open Letter February 21, 2017
Open Letter as to status of Grazing Permits issued by BLM and USFS
We understand that there is a movement currently underway to encourage federal permittees/lessees to take matters into their own hands and ignore their grazing permits/leases and attempt to unilaterally modify grazing permits/leases on the grounds that a “grazing allotment” and “grazing rights” are absolute and cannot be modified without the permittee/lessee’s consent. This movement has been motivated by frustrations regarding management of federal grazing allotments and treatment of permit/lease holders. In many cases, these frustrations are well founded. Often management of federal lands has harmed families and agriculture businesses, as well as the working landscapes upon which grazing allotments exist. We share these frustrations and believe that reasonable reform of livestock grazing rules and regulations is long overdue, but we discourage permittees/lessees from ignoring their existing permits/leases and from attempting to take unilateral action to change the terms of their permits/leases. We stand ready as a resource to help advise those who seek to obtain reform of existing laws, regulations, and guidance so that livestock grazing on USFS and BLM grazing allotments can thrive and benefit local economies, ranching businesses and families, and rangeland health. In many cases, federal agency personnel would also benefit from training as to what consult, cooperate and coordinate, as stated in existing law and regulations, means in terms of directly involving and listening to the permittees/lessees. Many conflicts can be addressed administratively. Unilateral action by permittees and lessees, however, poses a real risk that such action(s) will result in adverse action upon the grazing permits/leases and that it will be difficult or very expensive to remediate the consequences of those actions. Therefore, we discourage permittees/ lessees from ignoring terms of their permits or undertaking unilateral permit modifications. We, the undersigned attorneys, encourage ranchers dependent upon federal lands to work with the federal land management agencies to maintain and enhance their ability to graze upon the federal land. This can be done by, among other things, monitoring of the resource, applying for permit/lease modifications, applying for range improvements (i.e. removal, modification, installation), actively participating in any NEPA analysis and decision-making processes, defending against permit/lease actions by the federal agencies, and defending permits/leases in cases filed by adverse interests seeking to undermine grazing on federal lands. In addition, we encourage ranchers to take the opportunity – via livestock associations or other similar organizations — in this new Congress and new administration to obtain statutory and regulatory reform that will maintain and enhance the existing grazing statutory and regulatory framework on federal lands. Sincerely, Constance E. Brooks Karen Budd-Falen Frank Falen Scott Horngren Elizabeth Howard Caroline Lobdell Bill Myers W. Alan Schroeder