Response to Objection Instruction F-1.

Clarify how direct contact from disease-carrying domestic sheep and goats is believed to contribute to 

the death of individual wild sheep, herds of wild sheep and entire populations and review the 

WAFWA Wild Sheep Working Group updated recommendations on disease transmission from 

domestic sheep and goats to wild sheep. Include review findings in the project record and clarify the 

reasons for special designation of the SNF bighorn sheep population. 

Clarify how direct contact from disease-carrying domestic sheep and goats is believed to contribute to 

the death of individual wild sheep, herds of wild sheep and entire populations

Risk Analysis of Disease Transmission between Domestic Sheep and Goats and Rocky Mountain Bighorn 

Sheep (April 2012; Document #02235)

This document provides a thorough assessment of the risks to wild sheep from domestic sheep and 

goats. It reports that although there is no direct evidence of domestic goats and specifically pack goats 

infecting wild sheep with life/herd/population threatening diseases, there is an abundance of connected 

actions that lead to a reasonable conclusion that domestic sheep and goats are the vectors. The analysis 

also provides evidence that wild sheep are unpredictable in their movements and have been shown to 

travel great distances which can bring them into contact with domestic sheep and goats as well as other 

wild sheep. The methodology and conclusions in this document demonstrate consistency with national 

guidance for a risk analysis of this type as well as consideration of best available science, and 

recommendations from the Western Association of Fish and Wildlife Agencies (WAFWA), Wild Sheep 

Working Group, and biologists from the WGFD.

The Risk Analysis of Disease Transmission document provides evidence from a variety of peer reviewed 

and anecdotal sources of the threat to wild bighorn sheep populations from contact with domestic 

sheep and goats. Furthermore, the BE summarized these threats and provides an evaluation of potential 

outcomes and impacts to bighorn sheep under each alternative. There was limited discussion of reliance 

on mitigation measures provided by the public because the risk of any contact between domestic goats 

and the core populations of bighorn sheep was considered to be too great. This concern was addressed 

by the SNF in Response to comments: Public Concern #228 and reiterated within the DEIS. 

The following is taken from: 

Wild Sheep Working Group. 2012. Recommendations for Domestic Sheep and Goat Management in 

Wild Sheep Habitat. Western Association of Fish and Wildlife Agencies.

• “it is WAFWA’s collective opinion that enough is known about potential pathogen 

transmission from domestic sheep or goats to wild sheep that efforts toward achieving 

effective separation are necessary and warranted. “

• “Reducing risk of disease transmission on the landscape by minimizing or preventing association 

between wild and domestic sheep or goats is a key management strategy for WAFWA agencies.”
Considering the above, it is only prudent to err on the side of caution to remove the potential for 

disease transmission to core native herds of bighorn sheep on the Shoshone while the use of pack goats 

is relatively limited on the forest. In the future, should research find there is no threat of disease 

transmission from goats, this protection measure may be changed by amending the LMP. Sadly, the 

potential impact to the Shoshone’s unique bighorn sheep population could be devastating if the SNF 

continues to allow pack goats until research reaches a definitive conclusion regarding the mechanism of 

disease transmission from domestic sheep and goats.

Review the WAFWA Wild Sheep Working Group updated recommendations on disease transmission 

from domestic sheep and goats to wild sheep. Include review findings in the project record.

The following recommendations are taken from: 

Wild Sheep Working Group. 2012. Recommendations for Domestic Sheep and Goat Management in 

Wild Sheep Habitat. Western Association of Fish and Wildlife Agencies.

Updated recommendations:

• It is WAFWA’s collective opinion that enough is known about potential pathogen transmission 

from domestic sheep or goats to wild sheep that efforts toward achieving effective separation 

are necessary and warranted. 

• The higher the conservation value of a wild sheep population (e.g “sensitive species” status, 

core native herds), the more aggressive and comprehensive wild sheep and domestic sheep or 

goat separation management strategies should be.

Specifically, land management agencies, such as the Forest Service should:

• Prohibit the use of domestic sheep or goats as pack animals by persons that travel in 

identified wild sheep habitat (WAFWA specifically cites the “Shoshone National Forest 

Supervisor’s Office Order02-14- 00-12-01. Temporary Area Closure to Domestic Goat Use” for 

this recommendation). Where legislation or regulations are not already in place, an outreach 

program to inform potential users of the risks associated with that activity should be 

implemented to discourage use of domestic sheep or goats as pack animals.

• Land management agencies that regulate or are responsible for domestic sheep or goat grazing 

allotments, trailing routes, vegetation management, use as pack stock, or any other uses 

involving domestic sheep or goats should only authorize such use(s) outside of occupied wild 

sheep range.

• Land management agencies should require marking of all permitted domestic sheep and goats 

to provide for rapid ownership identification of stray animals.

• Land use or resource management plans should explicitly address the potential for domestic 

sheep or goats to associate with wild sheep. Land use plans should evaluate the suitability of 

permitting activities involving domestic sheep or goats, and determine the best course of action 

with respect to wild sheep conservation. Plans should also identify general areas of public land 
where domestic sheep or goats cannot be permitted for weed control, commercial grazing, 

recreational packing, vegetation management, or other uses.

• Reduce risk of association by eliminating overlap of domestic sheep or goat allotments or 

grazing permits/tenures within wild sheep habitat; 

Clarify the reasons for special designation of the SNF bighorn sheep population.

Risk Analysis of Disease Transmission between Domestic Sheep and Goats and Rocky Mountain Bighorn 

Sheep (April 2012; Document #02235)

Northwestern Wyoming contains eight core native bighorn sheep herds in the Absaroka, Teton, Gros 

Ventre, and Wind River Ranges (WGFD 2010a). Core native herds are those herds that have never been 

extirpated and re-populated with transplanted bighorn sheep (Wyoming State-wide Bighorn/Domestic 

Sheep Interaction Working Group 2004). These are Wyoming’s largest bighorn sheep populations and 

are the highest priority areas for bighorn sheep management in Wyoming (Wyoming State-wide 

Bighorn/Domestic Sheep Interaction Working Group 2004). The core native herds in northwestern 

Wyoming account for over 90 percent of the statewide total of bighorn sheep.

The Shoshone is occupied by six of the eight core native bighorn sheep herds in Wyoming. These core 

herds include: Francs Peak, Younts Peak, Whiskey Mountain, Trout Peak, Wapiti Ridge, and Clark’s Fork. 

These core herds currently occupy 67 percent (1.65 million acres) of the Forest.

From Objection Response:

In addition, bighorn sheep are considered a Sensitive Species on the Shoshone. The Forest Service policy 

for sensitive species has been established for many years. Sensitive Species are designated as they are at 

risk for various reasons and were chosen to focus management efforts as a priority to preclude a trend 

toward listing. 

We must also consider the special designation by Wyoming Fish and Game of the SNF bighorn 

population as being critical to the viability of the species range-wide.