George Bailey

August 27, 1997

I am writing in regard to the "Rangeland Health Standard and Guidelines for California and Northwestern Nevada Draft EIS". My father and I are permittees in northeastern Lassen County and are directly effected by the proposed standards and guidelines.

After reading the Draft EIS, I am concerned that the standards and guidelines are rather vague and generalized. They could be viewed and enforced in different ways by different individuals. If enforced to the letter they could well remove livestock entirely from Federal Lands or at least make it impossible for permittees to continue to operate. If used with a common sense approach in cooperation with livestock producers, improved range conditions would be achieved without undue hardships on livestock producers.

The BLM needs to realize that ranchers have established methods of operation and even slight changes in AUMS, season of use, changes in turn-out dates, removal from grazing because of fires etc... have severe economic impacts. Such practices need to be held to a minimum when at all possible. Requiring extensive fencing and other expensive range improvements or time consuming tasks such as herding, could well be beyond the capabilities of smaller family owned ranches. Hopefully, any plans will be flexible and subject to compromise.

Forcing ranches into economic hardships or out of business should not be an option in any grazing plan. The loss of one home ranch to subdivision or non-farming uses has a much greater impact on wildlife, local economy etc.... than does the effect of grazing on hundreds of acres of range land.

Alternative 4 should not be considered as a current option. The cuts in AUMS, the additional cost of implementation and adverse effects on rural economies would be too severe. The DEIS at several points states that grazing systems will be established after consultation with ranchers and others involved. However, the report states that there will be a 5,124 AUM cut in Lassen County for 5 years and a reduction of 8,877 AUMs in Washoe County. This is recommended even before the standards and guidelines have been adopted, Where and when were ranchers consulted about these cuts?

The DEIS also makes no mention of an appeals process should there be a disagreement on any part of an established or proposed grazing system. There needs to be a period of time for permittees to respond to any changes before implementation.

The standards and guidelines make reference to water quality standards but are vague as to how or what standards will be applied in rangeland conditions. Stock watering ponds should not have the stricter standards that are applied where humans make use of the water. Even then, unless livestock are proven to have a detrimental effect, the stricter standards should not be used to eliminate or reduce grazing in the area.

The use of fire to affect grazing allotments is mentioned throughout the report. prescribed burns are a management tool but often they get out of control and are dangerous for this reason. Many allotments have considerable amounts of private land interspersed throughout the allotment and make large burns impractical. The problem with the burns is that for a year or more afterwards no grazing is allowed in the burn area and as a result the entire allotment may be lost for use by the livestock producer. This can create severe hardship for ranchers, especially in areas where few sources of alternative grazing exist. Small burns that could be fenced off may be an answer in some cases but in no instance should a series of burns in one allotment be instituted for several years in a row.

The definition of riparian area and the standards to be applied under different range conditions may be one of the biggest problems under any grazing system. Cattle are going to use the greener riparian areas before any others. To judge the utilization of the allotment based on the stubble height of riparian areas would be an injustice to livestock producers. Fencing and development of alternate water sources are the only way to effectively preserve riparian areas but, common sense must be applied. To remove all cattle from the entire allotment because a small riparian area is over-grazed should not be the answer. Standards and guidelines must be flexible enough to realize this.

This letter, I realize, is somewhat on the negative side. There is a feeling in the ranching community that the Federal Government is trying to revolve grazing from public lands. Every new plan of action almost always suggest cuts in AUMs, reducing season of use or requiring fencing or herding, expensive options to the permittees. Rather than compromise or working to increase or maintain current grazing levels the attitude of government seems to be to reduce and remove. Once grazing is eliminated the home ranchers are likely to be gone also. The impact on local economies, wildlife and the quality of life in these rural areas is likely to be significant. Strict and unreasonable interpretation and enforcement of standards and guidelines should not be the answer.

Respectively yours,

George Bailey, Jr.