Why the Comanche and not the Pawnee National Grasslands?

Anne Boswell Taylor
Nov 16
5 min read

~Norman L. Kincaide, Ph.D.

Why the Forest Service interest in revising the management plan for the Cimarron and Comanche National Grasslands (CCNG) with 108,000 and 440,000 acres, respectively? These grasslands are supposedly threatened with urbanization, agricultural development, and overgrazing, that may compromise cultural sites and stress Species of Conservation Concern (SCC). The CCNG Draft Assessment is rife with issues concerning SCCs, along with interest in designating the Purgatoire River as Wild and Scenic. There are currently sixty grazing permit holders for the Comanche National Grasslands for the Carizzo and Timpas Grazing Units.

Rep. Jeff Hurd, holding the Compendium of Published Articles on the Comanche Draft Assessment, in conversation with Sheriff Shawn Mobley, Rocky Ford Fire House, November 8, 2025

Otero County has 18,000 residents, Baca County, 3,500, and Las Animas County, 14,500 for a total of 36,000 for three counties with Comanche Grassland allotments. Add in Prowers, 12,000, Bent, 5,800, Crowley, 5,600 and Kiowa Counties, 1,400=60,800 for seven counties near the grasslands. None of these counties are burgeoning with growth. The largest city within reasonable distance to the Comanche Timpas Grazing Unit is Pueblo, Colorado, with a population of 111,000. To the south is Amarillo, Texas, two hours away from the Carizzo Grazing Unit, with a population of 203,000 in 2024. The Draft Assessment estimated that 245,647 people lived within the area of influence surrounding the CCNGs.

Meanwhile, far to the north and bordering Wyoming are the Pawnee National Grasslands (PNG) comprising 193,000 acres (half the size of the Comanche), entirely within Weld County. Recreational activities have been curtailed in recent years because of extractible oil and natural gas development. There are 63 active vertical oil and natural gas wells on the PNGs. Less than 3,000 acres are protected against drilling.

Grazing is managed through the Pawnee Cooperative Grazing Association. The association holds the primary permit for 100,000 acres primarily in the eastern unit, with 47 permit holders as of 2025, who graze cattle over 79 allotments. The Crow Valley Unit to the west near Briggsdale and Ault has a few grazing permits, but is primarily for recreation including the Crow Valley Recreation Area. The Pawnee is governed by a 1997 management plan, the original notice of intent to prepare an Environmental Impact Statement for a revised management plan was published on July 10, 1990 in the Federal Register. Due to a delay in that process a second notice of intent was published in the Federal Register, September 15, 1995. There is no mention of areas of influence in the Pawnee Management Plan. Weld County has a population of 370,000, while Greeley, nearer to the PNGs has 114,000. The population of Weld County has grown 42% since 2010. Larimer County by 24%, Morgan County by 7.5%, Logan County declined by 8.6%, Boulder County increased by 12.4%, Adams County by 22% in 2024.

Adding the populations of Larimer, Logan, and Morgan Counties there is a population of 775,000 surrounding the Pawnee Grasslands. If Adams (543,000) and Boulder Counties (330,000) are added in that makes 1,600,000 people within a two-hour drive of the PNGs. If any National Grasslands are threatened with urbanization, it would be the Pawnee with the growth of Adams, Larimer and Weld Counties. Does the disparity in population between the two grasslands justify Forest Service the motivation for a revised management plan for the CCNGs? This disparity again calls into question the motivation, initiation, timeline for completion, lack of communication with allotment owners, and the shoddy process thus far initiated.

Is this interest in the Cimarron and Comanche Grasslands another “test case” for a planning rule establishing a revised management plan? The Pawnee Grasslands are far more subject to urbanization, oil and gas exploration, and growth stress than the Comanche Grasslands. There is no oil or gas exploration on the Comanche with only the possibility of helium as an extractible commodity.

That this situation should come to the attention of Rep. Jeff Hurd, U.S. House District 3, is understandable. Rep. Hurd was invited to the Otero County GOP Lincoln Day Dinner in May 2025. However, Hurd was unable to attend as he was chosen for a delegation from Congress to meet the new Pope at the Vatican. To make up for this conflict in scheduling, Hurd attended a meet and greet with the Otero County GOP central committee and other GOP members at the Rocky Ford Fire House EMT conference room on Saturday, November 8, 2025 between 4-6 P.M. The entire executive committee and several precinct chairs along with Sheriff Shawn Mobley, Anne Boswell, candidate for Bent County Clerk & Recorder, and Michele Coutts Gray, Pueblo County Chair, and candidate for Colorado House District 60, attended.

Rep. Hurd engaged every person attending, asking for a brief biography and their most pressing issue. For Dr. Ky Davis, Harris Pharmacy, Rocky Ford, it was the closing of Safeway stores in La Junta and Lamar, further restricting choices veterans have for filling their prescriptions. If a script needs to be filled right away, a veteran would have to drive to Pueblo. For Zane Leininger, retired DVM, La Junta, the fact that more and more women have been accepted into veterinary schools, of which few want to go into large animal practice, illustrates the decline of that practice in rural areas. For Cuco Ruiz, Rocky Ford, Public Works Foreman, it was maintaining water quality and the expense of hooking up to the Arkansas Valley Conduit. Jermiah Mason, Fowler, Blue Ribbon Processing, was concerned with maintaining a competitive margin while meeting USDA standards for meat processing.

Barb Leininger, La Junta, was concerned about the power of nongovernmental organizations (NGO) to unfairly influence land management along with the troubling issues that arose with the Comanche National Grassland Draft Assessment process. The grazing allotment holders desire the removal from the Draft Assessment of NGO influence, the extraneous Species of Conservation Concern, the proposed Wild and Scenic River designation for the Purgatoire River while preferring the development of a practical, usable, resource management plan that emphasizes grazing.

The same was for Norman Kincaide, Rocky Ford, who placed in the hands of Rep. Hurd a compendium of recently published articles on the Comanche National Grassland Draft Assessment issue as well as copies of his books on defeating National Heritage Areas. Rep. Hurd said that he would give special attention to the compendium, citing the Congressional Review Act as a possible means to rescinding an unacceptable management plan.

It remains curious that the Forest Service would choose an area of lesser population density for a revised plan, rather than a region of greater population density where the stressors of burgeoning population are definitely more evident. The Forest Service appears to hold a much lower threshold for environmental concerns, stresses and threats towards the Comanche Grasslands than it does for the Pawnee. Whether the reasons for this disparity become clear through a Freedom of Information Act (FOIA) document dump remain to be seen. The recent FOIA request pertaining to the CCNG Draft Assessment has been on hold because of the recent federal government shutdown.