Category Archives: Land Issues

Andy Irvine’s Response to Shoshone RADT and EIS

NAPgA’s lawyer, Andy Irvine, recently put together a wonderful response to the Shoshone NF Risk of Disease Transmission and Supplemental Draft Environmental Impact Study, which both contained faulty science to justify banning packgoats from Bighorn Sheep territory. Every issue brought up in the Shoshone documents is addressed in detail. This is a long document but well worth the read. This is one of the things NAPgA’s money pays for, and the comments may well be applied to similar situations as they arise in other areas. Click the link below to access the full document.

Andy Irvine Comments

Potential Packgoat Ban in White Clouds Area, Idaho

Once again we stand to lose even more access to the wilderness in the new Idaho Land Use Plans being considered as we speak.
There is much in the Draft version of these plans to be of concern, but the primary information that needs to be responded to is in the EA’s for each of these plans. One is called the Hemingway-Boulders plan (HBWC), and the other the Jim McClure-Jerry Peaks plan (JMJP). BOTH must be responded to. The Deadline for Comment is November 26, 2017. 

The documents I have attached outline the problems that I see in each of these plans. However, there is one paragraph in each of the Environmental Assessments that is completely wrong in its entirety. It is found on Page 48 of the HBWC plan, and Page 46 of the JMJP plan. Our legal advisor, when presented with this paragraph noted, ‘There isn’t anything in this paragraph that is correct!’

This paragraph can be refuted in its entirety, and therefore needs to be the focus of your comments.

PLEASE, read over the attached document, and/or download the actual plans, and send in your comments as soon as possible. Even if you never think you will access or want to access this section of the white cloud wilderness, we desperately need your comments to add weight to what I will be sending.

Read Larry Robinson’s “Problems with Idaho Land Use Plans”


Comments for the Hemingway-Boulders need to be sent to:

Written comments must be submitted to the responsible officer:

• Send an email to: Please indicate “Wilderness Plan” in the subject line. Electronic comments must be submitted as an e-mail message, plain text (.txt), rich text format (.rtf), or Word document (.docx).

  • Send a hardcopy letter to Sawtooth National Forest, 2647 Kimberly Road East, Twin Falls, Idaho 83301. For those submitting hand-delivered comments, business hours for the Sawtooth National Forest Supervisor’s Office are 8:00 a.m. to 4:30 p.m. Monday through Friday, excluding holidays.
  • Comments may also be submitted by fax to (208) 737-3236. Include your mailing address and phone number.

Comments for the Jim McClure-Jerry Peaks need to be sent to:

Written comments must be submitted to the responsible officer:

  • Send an email to: Please indicate “Wilderness Plan” in the subject line. Electronic comments must be submitted in a format such as an e-mail message, plain text (.txt), rich text format (.rtf), and Word (.docx).
  • Send a hardcopy letter to: Salmon-Challis National Forest, Attn: Wilderness Plan; 1206 S. Challis Street, Salmon, ID 83467. The office business hours for those submitting hand- delivered comments are: 8:00 am to 4:30 pm Monday through Friday, excluding holidays.
  • Comments may also be submitted by FAX to 208-879-4198. Include your mailing address and phone number.

August 10 Deadline for Shoshone Wilderness Plan Comments–YOUR Help Needed!

URGENT! YOU have the opportunity to comment on the use of domestic sheep, goats and pack goats in the Shoshone National Forest.

The comment deadline of August 10th is fast approaching!

The outcome of the final decision by the Shoshone National Forest regarding pack goat use will very likely have a domino effect on how other National Forests address pack goat use.

The Shoshone National Forest has prepared a Supplemental Draft Environmental Impact Statement (SDEIS) for Use of Domestic Sheep, Goats, and Pack Goats, which is a Supplement to the Shoshone National Forest Plan, which was revised in May of 2015.

The Shoshone National Forest proposes to limit areas where domestic sheep allotments are stocked and restrict the use of domestic goats and pack goats on the Forest to reduce the risk of disease transmission to bighorn sheep.

Follow the links to the documents below.  Neither is extremely long and you will find plenty to comment on regarding the possibility of disease transmission from pack goats to big horn sheep.  The new best science available is not being used in these documents!…541051.pdf…541057.pdf

After reading these two documents please submit your comments.  Alternative #3 is NAPgA’s preferred alternative.  It permits pack goat use in the Shoshone National Forest with the least amount of risk for the Bighorn Sheep.

The 2016 GOAT MOVI STUDY CONDUCTED BY DR. MAGGIE HIGHLAND, a Veterinary Medical Officer and Researcher with the USDA-ARS-Animal Disease Research Unit, in collaboration with USDA-APHIS personnel is the most current best science available regarding the possibility of disease transmission from pack goats to Bighorn Sheep.

From spring through fall of 2016, 576 goats (419 packgoats and 157 housed on premises with packgoats), from 83 premises located in 13 states, were sampled 3 times at 4 week minimum intervals to test for nasal presence/shedding of Movi. Nasal swab samples were collected in duplicate at each time point, with one nasal swab from each sample collection being tested in Dr. Highland’s laboratory and the second swab from the first sample collection being tested in an independent laboratory. Repeat nasal swab sampling of the goats in this study has confirmed the presence of Movi on just 5 of the 83 premises (6% of premises).  Premises that had Movi detected in any of the goats had between 7 to ≥15 goats present on the premises.  Movi was confirmed to be present on the nasal swabs collected from 30 of the 576 goats tested; this means 94.8% of the goats tested had NO Movi detected on nasal swab samples. Of the 30 total confirmed Movi positive goats, 27 (or 90%) of them were ≤1 year of age (23 of them were <5 months).

In summary, not only does the behavior and handling of pack goats drastically decrease the risk of a domestic pack goat coming into contact with a bighorn sheep, it would seem highly improbable based on this large scale study that a domestic pack goat would even be shedding Movi should such an unlikely contact occur.

Comments on the SDEIS must be submitted via mail, fax, or in person (Monday through Friday, 8AM – 4:30 PM, excluding holidays) to:

Casey Mc Quiston, Resource Staff Officer
Shoshone National Forest
808 Meadowlane Avenue
Cody, WY  82414
Fax: (307) 578-5112

Electronic comments including attachments may be submitted by email in Word format (.doc), portable document format (.pdf), rich text format (.rtf), text (.txt), and hypertext markup language (.html) may be sent to:

If you’re not sure what to say or how to say it, we have a form letter that you may use as a guide. We encourage you to rephrase it into your own words and add any further concerns of your own. Please remember to be courteous and professional in your wording.
Form Letter:

Articles about NAPgA’s Court Win

Casper Star Tribune – “Judge holds Forest Service in contempt over Wyoming goat and sheep ban”

An Idaho federal judge found the U.S. Forest Service in contempt of court Tuesday, concluding the Forest Service used a flawed study as the basis to ban domestic sheep and goats from some of its lands…. full article.

Jackson Hole News & Guide – “Goatpackers Score Win Over Shoshone”

High-ranking federal officials are being held in contempt of court for using invalidated reports to support a Shoshone National Forest prohibition against packgoats…. full article.

Capital Press – “Idaho Judge Holds Forest Service, Top Leaders in Contempt”

BOISE — An Idaho federal judge has held U.S. Forest Service Director Tom Tidwell, his agency and U.S. Agriculture Secretary Tom Vilsack in contempt of court for ignoring his 2009 order against heeding conclusions of a questionable report on disease transmission from domestic sheep to wild bighorn sheep…. full article.

NAPgA Wins Important Court Battle

Secretary of Agriculture and Chief of the Forest Service Held in Contempt of Court for Use of Illegal Reports on Disease Transmission from Livestock to Bighorn Sheep

Article by Andy Irvine

On February 23, 2016, Chief Judge B. Lynn WiRufus, my packgoat, after climbing 4000' and covering 9 miles of trail. Ben Lomond Peak is the location.nmill of the United States District Court for the District of Idaho held the Secretary of Agriculture and Chief of the United States Forest Service (“Forest Service”) in contempt of court for relying on two illegal reports on disease transmission from livestock to bighorn sheep. The reports were used in the Shoshone National Forest’s recent Land Management Plan (LMP) revision to ban domestic sheep and goats from the Shoshone. The Shoshone National Forest covers nearly 2.5 million acres in northwest Wyoming….

 Click here to read the complete article!


PACKGOAT RESEARCH Needs Your Participation

Finn_EarsTo all concerned citizens of the packgoat community: please read the following summary of an ADRU* research project to screen packgoats throughout the United States for pathogens and how you can participate. For packgoats it involves 3 serial nasal swabs and one blood test.

We strongly believe that without packgoat participation in this ADRU project we will continue to lose our access with packgoats on Public Lands.There is little hope without your participation.

Purpose: Collect nasal and eye swabs from packgoats across the United States to screen for presence of Mycoplasma ovipneumoniae and agents associated with “pink eye”.

Justification: Packgoat use on public lands defined as bighorn sheep habitat is being prohibited across the Western United States.  This prohibition is based on the potential that packgoats can carry a primary bacterial agent associated with bighorn sheep pneumonia, and pinkeye. In order to understand the prevalence and distribution of the bacteria of concern as well as to get a significant number of packgoats tested, NAPgA request packgoat owners from across the United States participate.  While this may not directly impact packgoat owners outside of bighorn sheep habitat, the implications of placing limitations on public land use without justification impacts us all by limiting the rights of individuals.  Beyond that, identifying carrier goats and distribution of the pathogens M. ovipneumoniae (Movi), and Chlamydia spp. (pink eye), may lead to future investigations into potential ways to clear reservoir goats of these pathogens.

There are two suggested protocols:
1.     The first is for packgoat owners that use or live in the Western US where bighorn sheep live. This involves 3 consecutive monthly nasal swabs, one blood test, and one eye swab2.     The second protocol is for packgoats outside of, or never brought into, states that are home to bighorn sheep. This involves a single point nasal swabs, eye swab, and blood test.

Please Note: All costs will be covered by ADRU to perform this prevalence/surveillance study, including veterinary charges (if applicable), supplies, shipping, and testing. All we need at this point are names, address, and number of goats. For questions see attached documents, contact Charlie Jennings, NAPgA President 435-764-1111, or . To request copies of sample research documents or to participate email Nancy Clough, NAPgA Member at  208-699-2702

What will the outcome be if this project goes forward?
The end goal will be to publish this M. ovipneumoniae prevalence data in a peer-reviewed journal (possible venues: JAVMA or Small Ruminant Research). This is a good way to not only compile our packgoat data, but to also make it accessible and referenceable for the US Forest Service Land Management Revision Teams who are making decisions to deny access to packgoats on public lands.
*Animal Disease Research Unit-ARS-USDA (Pullman, WA)

Important Links:
– Owner Information, Survey, and Goat ID form
– Sample Consent Form for Packgoat Participants
– Frequently Asked Questions
– PDF Download of Above Posted Overview

Blue Mountains Forest Plan Meeting Tues. 11/10

44Blue Mountains Forest Plan Revision to discuss whether or not to allow packgoats. Please attend if you can!

Tues., Nov. 10, 2015
11 a.m. – 3 p.m.
(doors open at 10:30)
Technical Pack Goat Meeting
Blue Mtns. National Forests
Pendleton Convention Center
1601 Westgate
Pendleton, Oregon 97801


Blue Mountains Forest Plan Revision Documents: