California Cattlemen's Association
1221 H Street
Sacranento, CA 95814-1910

July 7, 1997

The California Cattlemen's Association appreciates the opportunity to provide Comments on the "Rangeland Health Standards and Guidelines for California and Northwestern Nevada" Draft Environmental Impact Statement (DEIS), published in May 1997. We have a number of concerns and suggestions that we believe should be addressed in the final document and decision notice.

The California Cattlemen's Association (CCA) represents California's beefcattle producers on local, state and federal legislative and regulatory issues. With over 3,100 members statewide, CCA represents the vast majority of the ranchers who hold grazing permits and leases on the Bureau of Land Management (BLM) lands covered by the DEl S.

The National Environmental Policy Act (NEPA) requires agencies to analyze the direct and cumulative impacts of proposed actions. While this DEIS in most cases sufficiently analyzes the direct impacts, it fails to analyze the cumulative impacts of this and other actions (including the federal Endangered Species Act, PACFISH, etc.).

While CCA remains concerned about the potential for the Resource Advisory Councils (RACs) mandated by Rangeland Reform `94 to be dominated by interests opposed to grazing on federal lands, we are supportive of the process undertaken in California for ensuring balance on these councils. Furthermore, while we will outline below our concerns with the standards and guidelines developed by each California RAC, we are supportive of the process by which these standards and guidelines were developed. With modification, CCA supports Alternative 1 as the preferred alternative.

Finally, CCA compliments grazing permittees and BLM for two-plus decades of improved resource conditions on California's federal rangelands. Our members are committed to the long term sustainability of rangeland resources, and both research and anecdotal evidence demonstrate considerable progress in range management over the last 20 years. Cooperation is the cornerstone of this success, and we encourage BLM to implement these new standards and guidelines in a manner which enhances this spirit of cooperation.

The following comments are organized by chapter.

Chapter 1: Introduction

Any effort to improve rangeland health must include both an analysis of current conditions and of the causes of any documented unhealthy conditions. Changing grazing management will obviously not improve unhealthy rangelands if the condition is caused by roads, recreation, wild horses and burros, or other multiple uses. While CCA understands that the DEIS addresses standards and guidelines for grazing only, the document should indicate in stronger terms that grazing management will not be changed where it is already providing for healthy rangelands or where it is not contributing to documented rangeland health problems. We support the statement in Chapter 1 that "there will be no arbitrary removal of livestock. If removing livestock will not fix a problem..., then livestock will not be removed."1 In the analysis of the impacts of the four alternatives, however, removal of livestock is consistently the preferred method of addressing rangeland health problems.

Chapter 2: Description of the Alternatives

CCA has serious concerns with BLM's strategy for implementing the preferred alternative. Specifically, the screening process to be employed by BLM is extremely subjective. By the agency's own admission it has neither the personnel nor the financial resources to "classify each allotment or manageable grazing unit into one of three categories based upon available data and the professional judgement of the staff."2 According to agency staff, these will be subjective determinations based on existing knowledge or on evidence brought to BLM's attention by the public. CCA believes that such a method is both improper and inefficient. Interest groups with publicly state positions in opposition to grazing on public lands will demand action on allotments despite the lack of range science expertise or documented resource problems. Likewise, BLM will be forced to haphazardly deal with individual allotments as demanded by the public.

Furthermore, white the term "significant" is extremely subjective, permittees will not be afforded the opportunity to appeal a determination that "significant progress is not being made toward meeting the standard(s), and livestock grazing is a significant contributor to the problem..3 until an action is taken on their permit. As an alternative, CCA suggests that BLM incorporate these new standards and guidelines into the terms and conditions of grazing permits and leases as they are renewed or issued. Such an implementation strategy would ensure an orderly and efficient update of the grazing program while maintaining the agency's ability to act quickly in documented emergency situations. This strategy would also eliminate the arbitrary nature of the proposal contained in the DEIS while fostering continued cooperation.

Our criteria for evaluating these standards and guidelines are their conformity with underlying statutes and regulations, their scientific validity, their connection with the issue they are attempting to address, and the ability of the agency to implement them. CCA supports the general statement contained in the preambles to both the Bakersfield RAC and Ukiah RAC standards and guidelines that "where historical grazing use has been compatible with meeting the standards..., no permanent changes should be mandated in the existing grazing patterns without specific scientific evidence that changing the existing grazing pattern will improve the ability to achieve the standards."4 This statement should applied to all BLM rangelands. We also support the assertion that "for any standard, guideline, term or condition to work, it must be capable of being achieved, based on sound science or good common sense, and be measurable, understandable, and economically feasible."5 We support the recognition in the preamble to the Susanville RACs standards and guidelines that healthy rangelands and the social and economic well being of rural communities are linked. Finally, we believe that successful implementation requires BLM to realistically analyze its personnel and financial resources.

Alternative 1:

The Bakersfield RAC refers to the need to provide habitat for special status species including BLM sensitive species. Please provide information regarding the process by which the agency designates species as sensitive.

The standard for riparian management states that "riparian/wetland vegetation, structure and diversity and stream channels and floodplains are, or are making significant progress toward, functioning properly and achieving an advanced ecological status."6 CCA believes that the concept of meeting or moving toward a standard should be added to each standard developed by the three RACs. The underlying regulations simply require progress toward healthy rangelands, and such a statement would ensure that grazing management need not be changed if progress is being made.

The Bakersfield RAC's Guideline 2 indicates that "continuous season-long grazing use is allowed if it has been demonstrated that it can be consistent with achieving a healthy, properly functioning ecosystem."7 While CCA supports changing management to address documented resource concerns, we are uneasy about several aspects of this statement. First, please define the term "properly functioning ecosystem" and provide the underlying authority for the definition Second, we believe that the burden of proof should lie with the agency. In other words, the guideline should be restated as follows: Continuous season-long grazing use will be allowed to continue unless the agency has scientifically demonstrated that it is not consistent with rangeland health. We have similar concerns with the Ukiah RAC's guideline 12.

Guideline 9 proposed by the Bakersfield RAC indicates that rangelands will be rested "during critical times of plant growth."8 Please define this guideline further. Does this mean that all rangelands will be rested during critical times of plant growth, or does this simply apply to recovery from the "episodic events" cited in the guideline? The Ukiah RAC addresses this issue in a more concise manner.

The standards and guidelines proposed by the Bakersfield RAC indicate that "local managers must have the flexibility needed to determine which grazing practices will work best in each area, and to change those practices when necessary to achieve the desired rangeland conditions."9 However, the guidelines contain very specific stubble height requirements for all riparian areas in the Bakersfield District. While stubble heights can be an effective tool for monitoring proper use and addressing streambank stability and erosion concerns, these levels must be set on a site specific basis. Some sites do not support vegetation that achieves four inches of height in an ungrazed state. Furthermore, recent research suggests that much lower stubble heights can provide for plant vigor, streambank protection and sediment entrapment. Please refer to Volume 18, Number 4 of Rangelands magazine (published by the Society for Range Management) for more information on this issue. Additional research indicates that "evaluation of the effectiveness of grazing management should be based on trends in resource attributes that are directly affected by grazing rather than attributes of a particular grazing treatment. For example, grazing use levels or degree of streambank trampling are not resource attributes and are inappropriate management objectives."10

Again, CCA supports the concept of meeting or moving toward standards contained in the standards and guidelines proposed by the Ukiah RAC. The concept should be applied throughout the standards and guidelines. However, the Ukiah RAC's standard for riparian areas also states that riparian health is indicated by a "diversity of insects and amphibians."11 Amphibians are declining worldwide for a wide range of reasons unrelated to grazing. What actions will the agency take to address amphibian populations where grazing is not the underlying problem? CCA supports the recognition that point bars require time to become vegetated. Finally, CCA supports the exceptions and exemptions from the riparian standard listed on page 16.

The Ukiah RAC's guideline 4 indicates that all livestock handling and management facilities will be located outside of riparian areas. Does BLM propose to move all facilities currently located in riparian areas? If so, the cost must be borne by the agency.

We strongly support the Ukiah RAC's guidelines 18 and 20. Guideline is recognizes the need to coordinate range management activities with other multiple uses to address rangeland health, ensuring that grazing management will not be changed when another use is causing a resource concern. We also support aggressive action to reduce the invasion of exotic plants and noxious weeds.

The Susanville RAC's standard on streams includes the criterion that "gravel bars and other coarse textured stream deposits are successfully colonized and stabilized by woody riparian species."12 CCA believes that the concept of "moving toward" colonization should be added to this statement.

CCA supports the manner in which the Susanville RAC has addressed stubble heights for stream side areas. Local managers should have the flexibility to establish thresholds that reflect local conditions and site potential, and we support using this concept in both the Bakersfield and Ukiah districts as well. We also support guideline 4. Again, other uses may impact rangeland health.

We question the authority and the need for the transitional guidelines (guideline 14) proposed by the Susanville RAC. The agency currently has the authority to take action on grazing allotments with serious resource problems. The implementation process we proposed above will provide for the timely update of permits for allotments that are already well-managed. We believe, therefore, that guideline 14 should be eliminated.

Alternative 2:

Since alternative 2 retains the guidelines proposed by each of the RACs, CCA's concerns are identical to those raised with respect to guidelines for alternative 1.

Alternative 3:

The No Action or Fall-Back Standards and Guidelines, by the agency's own admission, are less comprehensive that alternative 1. Furthermore, CCA believes that several fall-back guidelines are contrary to the Spirit if not the letter of current law. Specifically, guideline 11 indicates that "the timing and duration of use periods shall be determined by the authorized officer."13 The guideline fails to indicate that these types of determinations must be made in careful and considered coordination, cooperation and consultation with permittees and lessees.

Alternative 4:

The Rapid Improvement/Rapid Recovery Standards and Guidelines are based on the erroneous assumption that exclusion of livestock provides the most rapid improvement of degraded resources. According to the document, the "guidelines contain all of the necessary tools and direction to ensure rapid improvement and recovery of rangelands in at-risk or non-functioning condition."14 This statement fails to recognize other factors that may be contributing to at-risk or non-functioning condition. Furthermore, the statement assumes, without concrete evidence, that excluding livestock improves range conditions more rapidly than any other management option.

Guideline 2 is confusing. According to the document, table D will be used to determine utilization levels for allotments that are in unsatisfactory condition. The footnote to the table, however, indicates that "ranges in good condition and/or grazed in the dormant season can withstand the higher utilization level."15 According to the footnote, then, table D applies to all rangelands. Furthermore, guideline 2 seems to indicate that any utilization by domestic livestock impairs rangeland. CCA believes that rangelands require grazing to maintain health and function. We also object to the 4-6 inch stubble height requirement contained in guideline 6. Current research indicates that stubble heights above 6 inches may not provide additional sediment entrapment and streambank stability because vegetation will simply lay flat in high water events. Again, please refer to Rangelands, volume 18, number 4 and volume 19, number 3 for more discussion on utilization levels.

Even without the apparent bias against livestock grazing contained in alternative 4, the costs of implementing the alternative (in terms of both personnel and financial resources) would be prohibitive. CCA believes that alternative 4 should be eliminated from further consideration.

Chapter 3: Affected Environment

In its discussion of range improvement, the document fails to recognize the benefits of range improvements for uses other than livestock. In many cases, springs, wells and other off-Stream water developments benefit wildlife as well as cattle and sheep. Rancher-maintained water facilities may be the only sources of water for wildlife on some BLM lands. The agency should evaluate the added costs of continuing to provide this water if a permittee is put out of business by these regulations.

The discussion of monitoring techniques appears to be comprehensive. The key to rangeland utilization and trend monitoring, we believe, is up-front agreement on what to measure, where to measure, and how to measure. This type of preliminary work helps to avoid misunderstandings between BLM, other government agencies, permittees and the public. Furthermore, given BLM's statutory requirement to consult with permittees, all monitoring must occur in close coordination with permittees. In establishing utilization and residue objectives, the DEIS indicates that if "key species are grazed conservatively they will improve in vigor."16 Plant vigor varies by species and by grazing level; a more correct term may be "grazed appropriately." Finally, CCA supports the establishment of confidence intervals for interpreting monitoring data. Monitoring techniques are estimates at best, and confidence intervals help ensure that management changes are not made arbitrarily.

In analyzing the existing situation, the DEIS indicates that little effort has been made to interpret current data regarding grazing allotments. However, the document follows by stating that 16 percent of the 705 allotments analyzed are not meeting one or more of the fundamentals of rangeland health. Please provide additional information about this data and about the type of analysis undertaken to make this determination. In addition, please provide further information about whether management changes will be made on those allotments that are progressing towards meeting these fundamentals.

In discussing the relation of grazing to soils, the DEIS States that "removal of vegetation by livestock grazing can reduce litter production and accumulation. Litter provides surface cover which protects the soil from erosion and contributes organic carbon and nutrients to the soil."17 Without removal of plant material, however, too much litter may accumulate. Residual dry matter levels are developed to leave the appropriate level of litter for erosion protection and replacement of organic matter. The document also states that roughly 120,000 acres are not currently meeting soil condition standards, but it fails to analyze the causes for these failures.

Vernal pools are a microcosm of the ecological and economic importance of grazing on public lands. Sheila Barry's research demonstrating the benefits of properly managed grazing for maintaining and enhancing vernal pool vegetation indicates that California's rangelands require grazing to be sustainable. Furthermore, most of California's remaining vernal pools are on privately owned rangeland. The continued viability of this habitat (and of habitat for numerous other plants and animals) depends on the continued profitability of livestock production. On a large scale, the availability and affordability of federal rangelands influences the profitability of ranching in California. Not only are the private lands and federal grazing allotments of permittees interdependent economically; the continued ecological integrity of private rangeland habitat depends upon a permittee's ability to utilize federal rangelands for at least part of the year. These proposed standards and guidelines must be analyzed for their collateral effects on private lands as well.

The DEIS states that "the sagebrush steppe vegetation of today is greatly different from that of presettlement times."18 Unfortunately, the document fails to detail these differences. Furthermore, the DEIS indicates that domestic livestock grazing has greatly altered the "pristine" vegetation in the Great Basin. Some research indicates that these "pristine" communitieS evolved in coexistence with large grazing ungulates. Perhaps changes in the frequency and intensity of fire have had a much larger impact that the substitution of cattle and sheep for other large herbivores. Please refer to "Herbivory in the Intermountain West" by Dr. J. Wayne Burkhardt (University of Idaho Station Bulletin 58 (October 1996)).

Riparian habitat and wetland sites are certainly a critical issue for range managers. The DEIS correctly indicates that these areas "are focal points for recreation, including fishing, hunting, camping, boating, hiking, nature observation, photography and picnicking."19 The document further states that these activities contribute high economic value. This paragraph raises several important questions that the agency fails to analyze fully. First, each of the uses cited above have tremendous potential to degrade riparian habitat by contributing to the removal of vegetation, the destabilization of streambanks, the compaction of soil, and the impairment of water quality. Furthermore, the statement regarding high economic values is misleading if it is not qualified. The agency does not receive user fees for these types of activities (while grazingpermittees pay grazing fees). Furthermore, while recreation does generate economic activity. most of this activity does not occur in the rural communities nearest to BLM lands. Discussions with long-time residents of Lassen County indicate that most recreational visitors make the majority of their recreation expenditures in their home communities. Unsubstantiated statements like the one cited here are inappropriate for this document.

Citing research by Kattelmann and Embury, the DEIS states that "riparian vegetation degraded by overgrazing generally recovers within a decade once grazing pressure is removed."20 CCA objects to the assumption that the only option for restoring degraded riparian sites is to remove livestock. A variety of other management options are available and can achieve similar results. In stating that removal of grazing pressure is the most effective option, the document is unnecessarily biased. Members of the public who are nOt familiar with grazing management may automatically assume that all grazing is harmful.

Proper grazing management has been demonstrated to improve mule deer habitat. The decline in mule deer numbers since 1960 may be related to several trends involving the livestock industry. First, reductions in deer coincide with reductions in grazing on pubic lands, indicating that more grazing may benefit deer populations. Second, private rangelands contribute significantly to winter habitat for deer. As ranching becomes less profitable (due in part to government regulations), some of these private rangelands have been developed, destroying or fragmenting habitat. Finally, California's protection of the mountain lion has resulted in the proliferation of one of the mule deer's main predators.

While livestock and elk do not share dietary preferences, conflicts do arise from this relationship. Transplanted tule elk in Lake County have destroyed fences on private rangelands. Rocky Mountain elk, beginning to migrate onto the Modoc Plateau, have caused problems in riparian areas that influence some ranchers' ability to graze these rangelands.

Riparian dependent species are an important consideration in managing public rangelands. The DEIS indicates that the "conservation of neotropical migratory land birds in the Western United States depends greatly upon the protection and restoration of riparian woodlands."21 CCA believes that recognition of the harmful effects of pesticide use in Central and South America would also be appropriate in this analysis.

Evaluating proper functioning condition of stream habitats provides useful information, but an analysis of the reasons for which some streams were determined to be functioning at risk or non functional is necessary before management changes can be proposed or implemented. The discussion on page 52 of Chapter 3 fails to provide such analysis.

CCA appreciates the statutory challenges faced by BLM in managing wild horses and burros on its rangelands. However, the DEIS indicates that the rangelands analyzed in this document currently support 45 percent more horses than the agency's "appropriate management levels." The analysis fails to adequately discuss the implications of this overpopulation on the fundamentals of rangeland health.

With respect to recreation, the DEIS values local economic contributions at $400-500 million. Please provide references to substantiate this figure. While the DEIS does briefly describe the potential environmental problems associated with recreation, it improperly attributes water quality problems (specifically giardia) entirely to livestock. Current research indicates that wildlife and humans are significant sources of giardia. CCA recommends that BLM review research conduced by Dr. Rob Atwell at the U.C. Veterinary Medicine Teaching and Research Center in Tulare. His analysis indicates that all mammals shed giardia, and that many Scientists still debate whether giardia cysts obtained from livestock can infect humans.

The DEIS states that "historically, ranching (starting with the Spanish missions) has directly conflicted with Native American Traditional lifeway values; in many cases, totally destroying people's ability to practice those lifeways."22 The term "total destroying" is much too strong and indicated bias on the part of the author of this section. While the religious nature of the Spanish missions certainly did have a tremendous impact on Native American culture and religion in California, CCA believes that blaming grazing for the total destruction of Native American Culture is completely inappropriate.

The economic analysis of the livestock industry is for the most part very complete. Several inconsistencies and inaccuracies, however, do require comment. As the DEIS indicates, cattle prices dropped by more than 50 percent between 1991 and 1995. Costs of production during that same period, on the other hand, at least kept pace with inflation. Furthermore, complying with local, state and federal regulations represents an ever-increasing cost for most ranchers. Indeed, Table 3.10.1.3(a) (page 64) reveals that those ranches with the lowest dependency on federal rangelands (and, therefor, lower regulatory costs) were the most profitable. In analyzing BLM's costs of administering its program, the document fails to recognize that some of the activities currently charged against grazing management (Ii.e., vegetation management, watershed analysis, etc.) would be incurred even if grazing was eliminated.

A study produced by the U.C. Agriculture Issues Center in 1992 indicates that California's farms generate approximately $58 billion annually in personal income for Californians. The same study indicates that agriculture supports 1.4 million jobs in California (nearly 10 percent of all the jobs in the state). In 1995, on-farm income generated approximately $22 billion in economic activity. The U.C. Study reveals that California's farms are the beginning of a cycle that adds $63 billion in value to the state's economy (about 9 percent of the annual total value added by all California businesses).23 This information indicates that the data presented in Tables 3.11.2.1(a) and (b) is in error. The document itself recognizes this error, stating on page 67 that California agriculture sales generated $17.05 billion in 1992 and on page 71 (Table 3.11.3.2.(b)) that agriculture income was roughly $7.2 billion in 1996. Agriculture income has certainly not fallen by nearly $10 billion in the last 4 years (it has, in fact, increased $22 billion).

The cattle inventory numbers cited in Table 3.11.2.2(b) are also misleading. Including dairy cattle, California did indeed have 4.7 million head of cattle in 1992. Dairies are not typically BLM grazing permittees, so dairy cattle should be eliminated from this analysis. California's beef cattle inventory for 1995 was as follows: approximately 890,000 cows, 1,125,000 stockers (weaned calves), and 595,000 cattle in feedlots (for a total of 2,610,000 head of beef cattle). These numbers have trended downward over the last several years due to the depressed cattle market and the drought of the late 1980's and early 1990's.

According to BLM, approximately one-third of the authorized AUMs went unused in 1996. This would seem to indicate that even with grazing fees at $1.35 per AUM, grazing on BLM lands is not cost effective for some permittees.

Table 3.11.3.2(c) provides information about the economic contributions of tourism. Unfortunately, no source is included for this data. Please provide the references used to make these estimates.

Finally, the DEIS states that California rural land prices in 1995 averaged $2,215 per acre. This average is extremely misleading. Vineyard land in California is worth well over $lO,000 per acre. Rangeland in northeastern California, on the other hand, is comparable in value to Nevada agricultural lands. Most ranchers that utilize BLM rangelands in California would be thrilled to learn that their ranches were worth $2,215 per acre.

Chapter 4: Impact Analysis

The introduction to this chapter states that the fallback standards fail to address all of the fundamentals of watershed function, nutrient cycling and energy flow, water quality and wildlife habitat. Alternative 3 should therefore be removed from further consideration.

Chapter 4 seems to emphasize reductions in grazing as the primary option for addressing resource concerns. While reductions may be simple to analyze economically, they are by no means the only option available to range managers. By emphasizing reductions, the agency is telling the public that grazing is detrimental to rangeland health and that elimination of grazing is the best option for improving these environments.

Annual grasslands will likely experience no change in fire frequency under any of the alternatives, according to the document, although prescribed fire may be used "establish perennial grasses, to improve the habitat for special status species, or to manage fuel levels."24 CCA supports the use of prescribed fire to improve and/or increase forage for livestock as well.

CCA finds the assertion that all resource conditions will improve most quickly under alternative 4 to be inappropriate and misleading. By creating the perception of punishing livestock operators (by reducing or eliminating grazing permits where resource concerns exist) alternative 4 will create a sense of mistrust with BLM's most important land management partners. Furthermore, research and experience indicate that properly managed grazing can often improve rangelands faster than the cessation of grazing. CCA does concur with 1993 research by Rosgen stating that "it has been demonstrated that good grazing practices can actually improve the stream and riparian condition..."25

The section describing impacts on wildlife indicates that the standards would result in a trend to later seral stages with more grass and herbaceous cover. Later seral stages, however, may not be best for all species of wildlife, including mule deer. BLM predicts that implementation of the standards and guidelines would improve or maintain elk habitat. What are the potential environmental impacts of larger elk populations, both on BLM and on private lands?

According to the DEIS "25 of the 149 special status plants known to occur within the project area are negatively impacted by Current grazing management practices...."26 Please provide the research upon which this statement is based.

The agency claims that the issue of wild horse and burro overgrazing is outside of the scope of this analysis. Since problems associated with wild horses and burros are often blamed on domestic livestock, CCA disagrees with this assertion. Implementation of these standards and guidelines will only be successful if BLM changes grazing management where domestic livestock grazing has caused resource concerns. If grazing management is changed to address a problem caused by another use, the situation will not improve.

An additional question posed by the Section dealing with wild horses and burros is the assertion that implementation of the standards and guidelines will increase the potential for wild horses and burros to be gathered and removed. Please provide the rationale for this assertion. In addition, if wild horse and burro populations will grow more rapidly with the new standards and guidelines, please provide an estimate of the increased costs of management that wilt be incurred by BLM.

We agree with BLM's finding that "recreational activities wilt continue to contribute to environmental degradation."27 CCA supports holding recreationists to the same standards to which grazing permittees will be held.

With respect to wilderness, the document seems to indicate that the standards and guidelines will reduce livestock in wilderness areas, and that such reductions will make these areas "appear or actually be more natural."28 Why is reduction of livestock the agency's first choice? The term "more natural" is very subjective and seems to indicate that at least some within BLM do not feel that grazing is an appropriate use of these resources.

In evaluating the differences between alternatives, the DEIS states that under alternative I. currently authorized grazing use would be reduced by over 16000 AUMs in the first five years. The document adds that these reductions would result from partial exclusions, not from excluding entire allotments. The agency apparently assumes that permittees who receive partial reductions will remain in business. Past experience indicates, however, that when reductions exceed a certain critical level, permittees will opt to abandon the permit and/or exit the industry. The DEIS must analyze this phenomenon and its potential impact on the industry, on communities and on the environment.

Under alternative 1, the agency anticipates the eventual increase in sustainable grazing capacity above current levels. In the event that the selected alternative increases this capacity, CCA looks forward to working with BLM to ensure that increased AUMs are made available to grazing permittees.

By BLM's own admission, alternative 4 exceeds the agency's current staffing and funding levels. As Congress moves to balance the federal budget, CCA believes that additional funding is unlikely, making alternative 4 inappropriate financially. Furthermore, much of Chapter 4
indicates that ecological improvement will occur faster under alternative 4 than under the other three simply because alternative 4 will be implemented more rapidly. The DEIS presents little if any scientific evidence to support this assertion. As indicated previously, CCA believes that alternative 4 should be abandoned.

In its economic and employment impacts analysis, BLM indicates that 32.3 percent of authorized AUMs were unused in 1996. The agency predicts that alternatives 1-3 will result in an additional reduction of 4.8% from current AUMs. As we requested previously, please provide some estimate of those permittees who will opt to take non-use or to terminate their permit because the reductions caused by these standards and guidelines will make such action more attractive. Possessory interest taxes, while a relatively minor portion of counties' overall tax revenue, should be analyzed by this document. Please provide at least an estimate of possessory interest taxes for 1996.

BLM anticipates the loss of permit value caused by these standards and guidelines to be offset by increases in real estate value. In California, increases in the value of rangelands are driven by demand for development. The agency's assumption, therefore, implies that development will provide a viable economic alternative for ranchers who are dependent upon BLM rangelands. As a result, CCA strongly believes that the agency must analyze the impacts of conversion from rangeland to real estate on the environment and on local communities. BLM admits that the costs of conversion are not considered 29 but fails to explain its reasons for this omission.

Conclusion

Again, CCA appreciates the opportunity to comment on the proposed Rangeland Health Standards and Guidelines for California and Northwestern Nevada. While we have some concerns with the standards and guidelines and with the analysis presented in the DEl S, we compliment each of California's three resource advisory councils for their efforts. We look forward to working with BLM to ensure that the final ElS is based on sound science and to ensure that the final standards and guidelines are implemented equitably.

Sincerely,

Daniel K. Macon
Assistant Vice President

1: "Rangeland Health Standards and Guidelines DEIS," Chapter 1, p. 8; 2: Ibid, Chapter 2, p. 3.; 3: Ibid; 4: Ibid, Chapter 2, p. 6.; 5: Ibid; 6:Ibid, Chapter 2, p. 8.; 7: Ibid, Chapter 2, p. 9.; 8: Ibid, Chapter 2, p. 10.;9: Ibid, Chapter 2, p. 6.; 10: Burkhardt, J. Wayne, "(Grazing Utilization Limits: An Ineffective Management Tool," Rangelands (19(3)3, June 1997, p. 9.; 11: Ibid, Chapter 2, p. 15.; 12: Ibid, Chapter 2, p. 20.; 13: Ibid, Chapter 2, p. 30.; 14: Ibid, Chapter 2, p. 32.; 15: Ibid., Chapter 2, p. 33.; 16: Ibid, Chapter 3, p. 14.; 17: Ibid., Chapter 3, p. 17.; 18: Ibid, Chapter 3, p. 26.; 19: Ibid, Chapter 3, p. 38.; 20: Ibid, Chapter 3, p. 42.; 21: Ibid., Chapter 3, p. 51.; 22: Ibid, Chapter 3, p. 60.; 23: Carter, Harold O., and George Goldman, "The Measure of California Agriculture: Its Impact on the State Economy," U.C. Agriculture Issues Center, 1992.; 24: "Rangeland Health Standards and Guidelines," chapter 4, p. 5.; 25: Ibid, chapter 4, p. 12.; 26: Ibid., chapter 4, p. 15.; 27: Ibid, Chapter 4, p. 19.; 28: Ibid.; 29: Ibid, Chapter 4, p. 38.

[Home][News][Information][Recreation][What We Do][BLM Facts][Directory]