Booth

August 15, 1997

I began visiting the area within the Susanville District (SD)of the Bureau of Land Management in 1969. Since then I have seen a good portion of the district. I'm concerned about the management of the public lands (I guess I'm a part owner), therefore I would like to provide comments on the Rangeland Health Standards and Guidelines for California and Northwestern Nevada Draft ElS.

After reading 1.2 Purpose and Need saw no mention of any economic considerations. It is based on a healthy environment for the benefit of all users of the public lands. Since this document is for the public benefit the economic analysis should include an analysis of benefits for all of the public, not just economic analysis of the benefits to the livestock industry.

1.8 states The viability of native plant and animal communities must be addressed in the standards and guidelines. It is not adequately addressed. The only standard that mentions wildlife in the SD is 5. Biodiversity. states Healthy, productive and diverse populations of native plant and animal species, including special status species are maintained . Now I wonder if the California Department of Fish and Game (DFG) or US Fish and Wildlife Service (USFW) would characterize the native plant and animal species within the SD as healthy, productive and diverse? Has the BLM asked the DFG? Sage grouse populations are down, deer populations are lower than they have ever been, Lahontan cutthroat trout are extinct (originally present in Smoke Creek), mountain quail are almost gone (small remnant populations on several of the desert mountain ranges in Lassen County) and willow flycatchers in very low numbers in a small portion of their historic range.

Alternative 4 represents the best alternative for the general publics interests. Rapid recovery will benefit all users of the public lands including livestock producers in the long run.

Surface and groundwater quality in all California BLM Districts should comply with all California, Tribal and Federal water quality standards Apparently the Susanville RAC feels that their interests are best served by polluted wate users if polled would disagree.

Guideline 1 SD. Stubble height requirements are necessary on all habitats within the Susanville District, not just within the stream-side areas. Ground nesting birds have been eliminated or greatly reduced by the grazing levels of the past 100 years. Mountain quail for example have been totally eliminated from many of the desert mountain ranges in Modoc, Lassen and Washoe Counties. They are impacted by lack of stubble and excessive browsing of brush has also eliminated much chokecherry, ceanothus, serviceberry, mahogany, quaking aspen and bitterbrush.

Guideline 8 SD. Who will determine if grazing use by livestock is providing for habitat requirements of fish and wildlife? If it is the same body that has led to the current situation I do not feel comfortable. I suggest this should be determined by the DFG or USFW.

Guideline 14 SD. 50% utilization of browse species is to much. The brush species will continue to decline under this grazing pressure.

Appendix 12 left out Special Status Animal Species that no longer occur on BLM lands within the project area (Lahontan cutthroat trout). Are there others? This is not appropriate, I would hope that the Appendix be reviewed for similar omissions and corrected or at least state that extirpated species are left out and there is no intent to manage habitats for extirpated species.

Rangeland health and livestock grazing are not mutually exclusive. Rangeland health and heathy. productive and diverse wildlife populations are not mutually exclusive. Livestock grazing and healthy, productive and diverse wildlife populations are not mutually exclusive. What is mutually exclusive is the past and present level of grazing, time of use, and lack of management and healthy, productive and diverse wildlife populations. Healthy, productive and diverse wildlife populations are an economic asset to the local state and national economy. Now go do your lob correctly and develop Standards and Guidelines that will protect the public interest.

Sincerely,

Jack Booth
Ukiah,CA