December 25, 2015
Steve Spangle, Field Supervisor
Arizona Ecological Services Office
2321 West Royal Palm Road
Phoenix, Arizona 85021
602/242-0210, x-244
Comment on Gila Chub Draft Recovery Plan, FR Doc No: 2015-27259
sent by email to Steve_Spangle@fws.gov
ISSUE: Impact of elk on grazing and on riparian areas
The recovery plan has neglected to address an important factor in the impacts on riparian areas. It
focuses solely on domestic cattle and livestock grazing as a threat to riparian areas and critical habitat. It
entirely neglects to account for elk, which add significant grazing impacts in the Gila. The word “elk” does
not appear even once in the recovery plan.
In this comment we are providing information on elk in the Gila, which should be added to the recovery
plan in order to present a complete and balanced view of total ungulate impacts on riparian areas.
The following references should be added to the recovery plan list of cited literature.
The study “Forage Utilization” examines five riparian areas in the Gila to compare forage utilization by elk
and cattle. We note that in 1997 the authors were already commenting that elk populations were too high
for the available forage. At reference 3 below, the NMDGF estimated the elk herd at 72,000 in 1999, and
the Rocky Mtn Elk Foundation estimated 80,000 in 2009..
In 2014, NMDGF prepared a presentation for the New Mexico Legislature on the state’s elk herd, this can
be found on line as WNR 090414 Item 3 Dept. of Game and Fish-Elk Overview. The need to reduce the
population is so urgent, that the number of cows harvested in 2014 (approx. 6,200) almost equal the bulls
(approx. 8,000). Since 2008 over 10,000 animals per year are harvested. The presentation shows the
estimated numbers for the elk herd by region:
North Central & Jemez: 29,600- 31,700 elk
South Central (Ruidoso & Sacramento): 10,664-11,078 elk
Southwest Greater Gila herd: 20,693-21,923 elk
Southwest Lesser Gila Herd: 1,046-4,258 elk
Southwest Datil herd: 2,939-3,314 elk
Southwest San Mateo herd: 2,066-2,155 elk
The total of 67,008 to 74,428 elk indicates that NMDGF has probably stopped the population growth, but
the herds are “stabilized” at levels that are still too high.
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1. FORAGE UTILIZATION BY ELK AND LIVESTOCK IN SELECTED RIPARIAN AREAS IN THE GILA
NATIONAL FOREST authors Treadway, Howard Jr., Allison, Wood, Boren
Report 47 Range Improvement Task Force
Agricultural Experiment Station, Cooperative Extension Service
College of Agriculture and Economics, New Mexico State University February, 1997
At page 4:
In portions of the Gila National Forest in southwestern New Mexico the present outlook on forage
utilization between cattle and elk is that elk populations have grown so large that they are
consuming most of the forage on deferred pastures in deferred rotation grazing systems.
Because of the large amount of elk utilization on these deferred pastures, available forage
is not sufficient to support current livestock numbers.
At page 5
The rapid growth in elk numbers has resulted in numerous challenges, including the
management of forage for both livestock and wildlife species. Excessive utilization of
herbaceous and woody vegetation may exist in areas with high elk concentrations in spite
of low livestock densities. Additionally, where livestock are scheduled to graze these
areas, utilization standards frequently are estimated by the land permittee to be exceeded
before livestock arrive. In some areas this excessive utilization appears to occur only during the
spring while other areas experience this level of grazing year-round, especially in riparian/cienega
areas where vegetation is more appealing to herbivores.
The study examined five riparian areas over two seasons, to determine relative use, forage by elk and
combined forage by elk and livestock. The five riparian sites studied are:
-Cameron Creek near Santa Clara
-Dry Blue Canyon near Luna, on Arizona border
-Bill Lewis cienaga, northeast of Bear Wallow Mountain
-Confluence of north and south Nigreto Creek, on private land southeast of Reserve
-Largo Canyon, on private land directly south of Quemado Lake.
These tables at page 15 show the elk far out-number (and “out-eat”) the cattle, in terms of days of use.
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The study goes on to discuss the challenges of allotting forage to wildlife and cattle. Our point here is to
show the huge numbers of elk that utilize riparian areas, compared to livestock. The impacts of so many
large animals in a riparian area cannot be ignored.
2. Elk in New Mexico, New Mexico Department of Game and Fish
The NMDGF provides an elk history timeline in their document Elk in New Mexico. The native Merriam’s
elk was extirpated by 1909. Initially fewer than 100 nonnative Rocky Mtn elk were brought into the state.
By 1934 there were 4,000 elk. The population was estimated at 8,000 in 1958. Importation of elk stopped
in 1966. The harvest exceeded 10,000 in 1994, and the estimated population in 1999 was 72,000
animals. Also in 1999 the Department approved herd reduction in 21 management units. (Rocky
Mountain Elk Foundation published a figure of 80,000 New Mexico elk in 2009.)
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3. Impact of Elk in Catron County, J.M. Jackson, Rangelands 13(6) Dec 1991
This article cites the official estimates of elk population, and this was over 25 years ago.
At page 287:
A BLM news release states that "the improving trend in rangeland condition is reflected by
the large increases in wildlife populations since 1960. Elk, for example, have increased
almost 800 percent, from 18,278 in 1960 to 142,870 in 1988." (Zilicar, 1990). Estimates of the
increase in the elk herd in the West, are from less than 100,000 in 1930 to about 600,000 in 1987
on all the Federal Lands (Thomas, 1990). The New Mexico Department of Game & Fish has
increased elk hunting licenses on public lands by 47% from 9,500 to 14,000 over the past
five years. "Given a chance, elk have done well..." (NM Dept. of Game & Fish, 1989).
We note the statement that improving rangeland condition has benefited the elk. This is contrary to the
claims in the recovery plan about overgrazing by cattle. Apparently good range management by the
USFS and BLM combined with the efforts and the cooperation of ranchers resulted in improved
conditions over 30 years. We also note that a 47% increase in available elk hunting licenses reflects on
the population explosion and the need to reduce the herds.
4. Herbaceous Utilization by Elk in Selected Meadows in the Gila Wilderness, Gila National Forest
Report 49, Range Improvement Task Force, New Mexico State University
Authors Allison, Boren,Baker
This study is particularly useful since it studies elk in Wilderness area meadows where livestock have
been excluded since 1952.
At page 3: (bold added)
Excessive use of herbaceous vegetation may occur in areas with high elk
concentrations despite low livestock densities. In some areas, this excessive use
appears to occur only during the spring, while other areas experience this level of
grazing year-round, especially in riparianlcienega (saturated, sub-irrigated meadow
area) areas, where vegetation is more appealing to herbivores.
Because of the ecological, aesthetic, and recreational values associated with mountain
meadows, information on elk use of herbaceous forage was monitored in the Gila
Wilderness in the Gila National Forest in seven mountain meadows that had been
excluded from domestic livestock grazing since 1952. These data should provide
valuable information on the impact elk might have on mountain meadows and other
habitats, thus helping natural resource managers improve management practices for elk
in the Gila National Forest.
Page 4:
For example, elk utilization during the 1997 growing season exceeded the 50% utilization
standard followed by the Gila National Forest Supervisor's Office in the more mesic
areas of Diablo, McKenna, and Lilley Parks (Table 1). This standard also was exceeded
in the more xeric area of Prior Creek during that' same year. Following the 1998 growing
season, elk utilization exceeded the 50% standard in the more mesic areas of McKenna
and Woodland Parks and, once again, in the more xeric area of Prior Creek (Table 1).
These patterns were more evident following the 1999 growing season. The 50%
standard was exceeded dramatically in the more mesic areas of Diablo, McKenna, Lilley,
and Woodland Parks (Table 1). During that same year, the 50% utilization standard was
exceeded in the more xeric areas of McKenna and Woodland Parks, Creel Canyon, and
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along Little Creek (Table 1). Despite these dramatic site-specific utilization levels at specific sites,
average utilization over the three-year study period, and across mesic and xeric areas within
mountain meadow sites, was below the 50% Gila National Forest utilization standard.
The Gila National Forest utilization standard for forage is 50% and the elk were using all that and more in
the mesic areas, and sometimes exceeding it in xeric areas. If this had been an area where livestock
grazing was allowed, there would be no forage left for the cattle. The relevant message for the Gila chub
discussion is the sheer number of large animals (elk) that are in the mesic areas, and the impacts they
must cause to the critical habitat.
Thank you for the opportunity to comment.
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