State of California - The Resources Agency
Department of Fish and Game
1416 Ninth Street
P.O. Box 944209
Sacramento,CA 94244-2090

August 27, 1997

In response to your request for comments, the Department has reviewed the Bureau of Land Management's draft Environmental Impact Statement for "Rangeland Health Standards and Guidelines for California and Northwestern Nevada." Attached are the Department's specific comments. We have put a great deal of staff time into this review, and I hope our comments are used to improve the subject document.

A significant policy of this State is to encourage the preservation, conservation, and maintenance of wildlife resources. The Department has the lead responsibility in this regard, and we desire to work closely with the Bureau to assist you in meeting your goal of achieving and maintaining healthy, sustainable rangeland ecosystems on the 4.2 million acres of rangeland addressed by this document. As our trustee responsibility encompasses all of California, I request that your final Standards and Guidelines for the three major resource areas (Bakersfield, Ukiah, and Susanville) be as consistent as possible.

Several million Californians use and enjoy the State's wildlife and public land resources for a variety of reasons. In recent years, the public have been increasingly expressing their opinions and desires about public lands grazing to the Department. Our comments reflect this, and they are also based on the extensive interaction my staff has had with Bureau staff regarding livestock grazing, particularly in northeastern California and on the east side of the Sierra Nevada.

I look forward to the implementation of appropriate Standards and Guidelines on public rangelands. Thank you for your consideration of the Department's input.

Sincerely,

Jacqueline E. Schafer
Director

Comments by the California Department of Fish and Game
on the Draft Environmental Impact Statement for
"Rangeland Health Standards and Guidelines for
California and Northwestern Nevada"

The following comments reference the chapter and section of the Draft Environmental Impact Statement for "Rangeland Health Standards and Guidelines for California and Northwestern Nevada."

CHAPTER 1

Section 1.2 - The purpose and need for standards and guidelines do not describe any economic considerations, such as sustaining traditional livelihood, as being a factor. Rather, the purpose and need of this document, and of standards and guidelines, are purely ecologically based. Yet, an economic analysis of costs to ranchers is included with no corresponding analysis of benefits (monetary as well as ecological) to California for the listed alternatives.

Section 1.3 - Alternative 4 cannot be called a `rapid recovery" alternative, because recovery and protection were called for decades ago. For example, existing (and longstanding) regulations direct the authorized officer to ensure watersheds are in, or making significant progress toward, proper functioning condition (PFC); the Taylor Grazing Act in 1934 and the Public Rangelands Improvement Act in 1978, as well as other laws and regulations, have directed the Bureau of Land Management (BLM) to protect resources from degradation for many years.

Section 1. 3c - Compliance with State water quality standards is fundamental to rangeland health. However, the Susanville Resource Advisory Council (RAC) area has exempted itself from this requirement.

Section 1.3d - "Habitats are, or are making significant progress." Significant is undefined. How will significance be measured? How does the trustee agency for wildlife (DFG) fit in the process of determining whether recovery of wildlife (hereafter refers to all species of fish, wildlife, and native plants) is being made?

Section 1.7 - Assumption 10, how could BLM know that removing livestock will not fix a problem" if they don't remove livestock to determine whether livestock have an impact? From an ecosystem perspective, this assumption fails to consider the reality of indirect effects of livestock on the environment.

Section 1.8 - The statement "The viability of native plant and animal communities must be addressed..." is not addressed.

"BLM will continue to follow existing laws such as the Clean Water Act..." The Department believes BLM must follow existing laws. Why does the Susanville water quality standard (see Chapter 2, page 20) not follow existing law?

CHAPTER 2

Section 2.4, Prioritization - BLM cannot conclude an area that is "severely degraded" or has "passed a threshold", or has "little or no chance for recovery" is of low priority if recovery has not been attempted. BLM should be consistent in their management direction (towards ecosystem health) and implement grazing exclusion on a landscape scale to test whether such areas can recover. Too often, BLM states there is no potential for recovery without having tested on a large ecosystem scale, yet at the same time, continues to authorize status quo livestock grazing in those very areas.

Section 2.5 - Setting standards and guidelines based on local interests that "...would meet the needs of their area" has excluded the majority of Californians and Americans concerned about public lands issues.

Section 2.51 - The standard for species provides no indicators for animals other than "special status" species. What are the indicators for other animal species, such as the hundreds of game and nongame fish, bird, mammal, and amphibian species?

Guideline 16 - The BLM should implement grazing systems that will be in compliance with water quality standards rather than promote compliance with the standards.

Section 2.52 - The riparian standard for Ukiah desires to achieve "late seral stages", while for Bakersfield it desires to achieve "advanced ecological status", and for Susanville they merely want to achieve PFC. These standards are inconsistent and do not meet the riparian standards described in the referenced document Rangeland Health 1994.

Under the standards for species, the Department of Fish and Game recommends that adequate stubble height (ground cover) of grasses and forbs be maintained to provide nesting and escape cover for ground nesting birds. This is a quantifiable objective.

Guideline 17 contradicts the previously mentioned Section 2.4 on prioritization. The Department concurs with this guideline that degraded areas should first be completely rested to determine whether recovery can occur. This should be a management action prior to dismissing an area as having "passed a threshold" or having "little or no chance for recovery." This guideline should apply to all three RACs.

Section 2.53 - Standards should relate to site capability or potential, however, BLM must determine whether a site has greater ecological potential than believed through the use of real information and data. Complete rest from livestock grazing on an allotment scale has not been attempted to evaluate whether Susanville area allotments have more potential to recover or produce a diverse mix of vegetative growth than BLM describes in this document. If restoration actions are determined to be infeasible, then, and only then, should the BLM accept a lesser "modified capability" standard.

How will BLM monitor/assess capability of aquatic/fishery resources given staffing limitations in some areas, such as Susanville, with no fishery biologists?

Standard 2 - The stream water surface temperature criteria is vague, with the standard not well described. What is meant by "high" shading, and for what distance along the stream channel?

Standard 3 - Water quality standard must comply with Clean Water Act. The standard described is vague. A desired beneficial use of water on public lands is to provide drinking water and clear running streams for resource values.

Standard 4 - Fails to meet the goals set by BLM for riparian/wetland areas. This riparian standard has no stated intent to improve riparian conditions in the Susanville RAC. There muSt be measurable significant progress made. As this document identifies northeastern California (Modoc and lassen counties) as being the major problem in the State needing grazing reductions (Section 4.3.4.4, page 37), logic suggests that significant progress is especially needed in the Susanville RAC, as well as in the other RACs.

The Department recommends that standards for ground cover of herbaceous vegetation and for vertical wildlife nesting/escape cover be established.

Any livestock watering system that occurs on the stream (e.g., water gaps in fences) is part of the riparian system because of the downstream effects of siltation, nutrient/bacteria loading, erosion, hoof action, and slope destruction. The impacts of livestock at these sites and their impacts downstream has not been presented. Nor has there been any disclosure about how these parameters will be monitored or mitigated.

Highly valued plant communities, such as bitterbrush, mountain mahogany, riparian, and aspen. should be allocated for their own intrinsic value and their wildlife value, rather than for livestock grazing. Yet there are no proposed standards for browse species in these habitats. Guidelines allowing 50% utilization of browse will not achieve the desired rangeland health.

Guideline 1- The stubble height threshold is too obscure and does not consider residual litter requirements needed to maintain and enhance soil conditions, vegetative productivity, and plant vigor. The "requirement" for plant vigor, bank protection, and sediment confinement is not defined.

The "fragile fisheries habitats" are the norm for northeastern California, given the harsh climate, compounded by impacts of livestock grazing. The "restrictive utilization thresholds" will and should apply to all fishery/riparian habitats rather than stating they may require...

Hoof action monitoring must consider the impacts of bank sloughing, compaction, and hummocking of the primary flood plain, as well as instream impacts.

Guideline 2 - Potential natural communities (PNCs) are supposedly stable communities in the absence of human caused influence. However, this guideline identifies a "desired" seral state in the presence of livestock. These are contradictory statements, and it is unclear whether the guideline applies only to riparian zones. If so, does that mean grazing will be excluded from riparian areas until PNC is achieved?

Guideline 3 - How will periods of rest be implemented, and at what scale? The Department recommends that rest periods be implemented at an ecosystem, or at least an allotment, scale. Environmental stress occurs every year in the plant community.

Guideline 5 - Desired plant species are not identified, nor is it made clear "desired" for what purpose. The Department recommends local ecotypes of native grass, forb, shrub, and tree species as being desired.

Guideline 8 This guideline is vague. Who will determine the habitat requirements for wildlife, at what level will requirements be set, what are the consequences if requirements are not met for any of the hundreds of fish, wildlife, and plant species that occur in the Susanville RAC? As written, this guideline has little substance and could be subject to wide interpretation. As trustee for the State's wildlife, the Department should make the determination as to whether grazing use has adequately provided for habitat requirements of fish, wildlife, and native communities.

Guideline 10 - National Environmental Policy Act (NEPA) review to consider impacts to nontarget species must be completed prior to implementation of plant species eradication projects.

Guideline 13 - The developments described in this guideline need to consider the direct impacts on fish and wildlife already dependent upon these water sources (before the development project is initiated). Wildlife, fish, and habitat "health" should be promoted in addition to "rangeland health."

Guideline 14a states "Maximum 60% utilization of herbaceous vegetation" and "Maximum 50% utilization of perennial or native herbaceous and browse species..."

These utilization levels are too high to enable recovery and maintenance of rangeland health. For example, Holechek's (1991,1995) work, cited in Chapter 3, pages 14-15, indicates that 50% utilization causes range destruction in most of the arid west; stocking at 3040% will enable recovery; and ranges that are in poor condition or are grazed during active growth (as is done in California) should receive utilization on the low end of those described in Table 3.2.5, or no more than 30% utilization for northeastern California ranges.

For purely range livestock management purposes, such high levels of utilization may be acceptable. However, BLM's objectives and goals go beyond what we traditionally would call proper range management for livestock. Objectives/goals have evolved into attempting to restore, enhance, and protect ecosystem health for all resources, not just to provide food and fiber. Because of this shift in direction, traditional range management options no longer suffice.

BLM knows full well of this Department's concerns (based on several years of East Lassen discussions, meetings, comment letters, and appeals) about allowing browse utilization of up to 50%, particularly on bitterbrush, willow, aspen, ceanothus, and mahogany stands.

The Department recommends no more than 20% use on any browse species by livestock, because of the "switching" phenomenon exhibited by livestock from herbaceous to browse forage after they exceed desired levels of use on herbaceous forage. Such a level would be consistent with the broader desire of BLM to initiate proper ecosystem management, as opposed to proper range management, as previously mentioned.

The Department, as trustee for California's wildlife, does not have a category titled Crucial (Essential) Deer Habitat.,, Please describe the intent and geographic areas involved.

There is no guideline relating to the extensive areas of ephemeral range which the Susanville BLM has identified with use pattern mapping. A guideline similar to Guideline 15 of Alternative 3 is needed for the Susanville RAC to address the vast acreages of ephemeral ranges in that area. When the ephemeral range does not produce forage, all herbivores rely on the limited upland shrub and riparian vegetation, thereby exceeding desired grazing levels.

Section 2.6, Alternative 2 - Statewide Consistency

There is no preamble for Alternative 2. What is the intent of Alternative 2?

The standard for all riparian areas regardless of RAC area should be a measurable upward trend if they are functioning at risk or are nonfunctional. This standard should be applied to each of the alternatives.

Water quality standard must be in compliance with the Clean Water Act and other existing laws. That is the minimum standard.

Section 2.6, Alternative 3 - No Action

The "fall-back standards" provide compelling evidence of the lack of progress intended for the Susanville RAC. All four fall-back standards (for soils, riparian/wetland, stream function, and native species) are nearly verbatim the standards proposed for the Susanville RAC. Consequently, the BLM is proposing "no action" for the Susanville RAC, despite identifying the area as having the greatest problems related to livestock grazing. BLM has, in effect, proposed Alternative 3 for the Susanville RAC.

Guidelines 1-7 are inadequate to meet objectives for improving overall rangeland condition. Maintaining status quo should not be a minimum guideline.

Guidelines 8-15 appear appropriate for improving overall rangeland condition and ought to be incorporated in all RACs.

There is no Section 2.7. The table of contents doesn't correspond with the chapter section numbers.

Section 2.8, Alternative 4

The BLM has not provided any reasoned analysis, consistent with Federal Lands Policy and Management Act requirements, describing why a "gradual, incremental, approach toward improved management" is more desirable than correcting problems as fast as possible." Alternative 4 advocates improvement that has been known to be needed for decades, but has not been implemented. It is not a rapid recovery or rapid improvement alternative, rather it is a benchmark that needs to be crossed for BLM to show it has the temerity to implement needed (and required) change after decades of posturing and debate.

The isolation of the water quality standard as the only item differing from Alternative 2 indicates the reluctance of the BLM to comply with clean water standards in RACs where less than compliance is currently accepted, namely the Susanville RAC.

Modification of grazing strategy (numbers, duration, season) are clearly the most cost- effective mechanisms available to the ELM to attempt to overcome unsatisfactory conditions caused by livestock. While improvement cannot be guaranteed on many areas with the removal of livestock, case study after case study published in Rangelands magazine indicates it works.

CHAPTER 3

Page 8 - The category "I"allotments are identified here as "improvement needed", while in Appendix 5 they are identified as allotments having "potential for increasing resource production or conditions. The two descriptions are not the same, and the Department has been led to believe over the years that category "I" allotments are those specifically targeted for and needing improvement. Which interpretation, if either, is correct?

Section 3.5, Wildlife, page 49 - The section describing elk needs to include the significant presence of elk populations in northeastern California. These populations have been on the increase for the past decade or so, with elk expanding their range into California's part of the Great Basin. BLM should recognize that allocation of forage resources to this growing population of elk will have to be made just as they are for wild horses and burros.

The wildlife section only describes ecological factors for three big game species and a handful of upland game species. If the intent is to produce an ecosystem-based management scheme for rangelands to help conserve California's biodiversity, then this document is inadequate in describing the affected environment.

According to the figures provided in the document, wild horses and burros account for 13 percent of the total animal unit months (AUMs) in northeastern California (31,080 AUMs out of 238,975 AUMs). Control of these populations is needed; however, it obviously would be more effective to consider modifying the 87 percent AUMs attributed to livestock to achieve management goals and objectives.

There appear to be no guidelines in the Draft Environmental Impact Statement for any of the three RACs that describe actions to be taken if/when livestock use on herbaceous or shrub vegetation, or impact on soil or water, exceeds the levels described in standards and guidelines. What are the guidelines for implementing management change, such as livestock increases or reductions based on monitoring data? How soon does action take place if specific standards and guidelines are not being met (e.g., two weeks, a month, or the following grazing season)?

Section 3.8 - The BLM appears to be arguing to accept negative ecological impacts of livestock grazing so that the "positive" effect of seeing cattle on western ranges by people from outside the United States can feel they are in the "wild west." The logic here is Incorrect, as well as being an untested conclusion. The overwhelming number of foreign tourists in the west come to see the natural beauty of wildlife and landscapes in the absence of livestock (e.g., national parks and monuments). The so-called positive impacts or "city slicker" activity applies well to dude ranches on private lands, but not on public lands.

Negative impacts of the proposed standards and guidelines on hunting and fishing or wildlife viewing opportunity are not considered. We refer the BLM to their own documentation in the Fish and Wildlife 2000 series as to the importance of hunting and the potential impacts of grazing on recreational opportunity. There is no disclosure of the tradeoffs between the negative impacts on the hundreds of wildlife species (and concomitant negative impacts on recreation economics) and the positive impacts of livestock discussed on local economics or foreign tourists.

As none appear to be cited in this chapter, there apparently are no positive, ecological impacts of livestock grazing.

Section 3 11, Economic Conditions - The economic conditions of the effects/impacts of grazing on the ecosystem, on wildlife, and on recreational opportunities are not considered in this document. There is no way from an economic perspective to weigh the benefits or costs of the various alternatives. All we can determine from this analysis is the single-use economics related to the few permittees of ELM lands in California, as opposed to the millions of "user days" on these lands for recreational purposes. The economic analysis is inadequate and does not provide the required reasoned analysis required by federal law.

CHAPTER 4

This chapter lumps the three RACs together in impact analysis, although they each have their own specific and varying standards and guidelines, This makes it impossible to reasonably evaluate the potential impacts of each RAC's proposed actions within that RAC.

Section 4. 1 - The "fallback standards" do not address the "fundamentals of watershed function, nutrient cycling and energy flow, water quality, and habitat for special status species and native plant and animal populations." As the Susanville RAC proposal is virtually identical to the fallback standards, the BLM is concluding that the Susanville RAC proposal is inadequate, and the Department agrees.

Section 4.2.2.1 - ELM h,as concluded that little can be done with allotments infested with medusa head. While this may be true, ELM has yet to experimentally test the hypothesis on a large scale using treatments such as grazing exclusion for several years at an allotment scale.

Section 4.2.2.2- If the positive changes described for sagebrush-steppe would occur the fastest under Alternative 4, why would another alternative be preferred? As previously stated, the Susanville utilization guidelines are excessive and inappropriate to achieve the stated goals of rangeland health. Several BLM documents written between 1991 and 1994 for the East Lassen area confirm that the allowable utilization proposed is too high to achieve rangeland health and PFC in those areas that aren't already there.

Section 4.2.3.2 - If the positive changes described for riparian vegetation would occur the fastest under Alternative 4, why would another alternative be preferred? The statement about the Susanville RAC changing fastest under Alternatives 1 or 2 is inconsistent, because the Susanville proposal is nearly identical to Alternative 3. The conclusion is inconsistent with the entire intent of a "rapid-recovery" alternative.

Does reducing or excluding livestock from severely degraded areas require major work as suggested? Degraded areas should be obvious to document, and it should he straightforward to change the grazing regime. The Department and Nevada Division of Wildlife have brought many of these areas to the attention of the BLM in northeastern California.

Section 4.2.3.3 - There is no assessment as to which alternative results in the most desired and quickest response in riparian hydrology or water quality. The Department assumes that Alternative 4 would he the "best" in this regard.

Section 4.2.4 to 4.2.5 - There is no assessment or disclosure of how each alternative will impact wildlife communities, habitats, vegetation types, mule deer, elk, pronghorn, upland game, or fisheries. However, Alternative 4 is identified as accomplishing some goals the fastest.

Section 4.2.7 - No disclosure of how recreational opportunities would he affected by alternatives is provided, although Alternative 4 is again identified as providing some of the fastest desired effects.

Section 4.3.4 - The economic analysis fails to disclose the potential impacts of each alternative on wildlife recreation-related economics, a significant component of the lands in question. Hunting, fishing, wildlife viewing, and associated supporting uses (groceries, fuel, supplies, lodging, sale of hunting access by ranchers, guide services, etc.) are not considered at all. The economic analysis provided is only one small component of the economic picture on public lands. No reasonable conclusions based on this limited analysis are possible in making a determination as to suitability of one alternative over another.

BLM has available their document Big Game Habitat Management - Fish and Wildlife 2000 (1993), which provides an inkling of some of the wildlife value on ELM lands in the State. For deer alone, the value in 1985 dollars was estimated to be over $13 million a year, much of which is directed back to local, rural economies where hunting occurs. This does not include the value of pronghorn, elk, black bear, or upland game/waterfowl species values for hunting. Nonconsumptive wildlife values (defined by BLM as observing, photographing, or feeding wildlife-note that doing same for livestock is not considered a recreational opportunity, as suggested in the Draft Environmental Impact Statement on page 57 of Chapter 3) were valued at $27 million per year in 1985 dollars. Combined, the nonlivestock value of ELM lands is staggering compared to the value of the grazing on these lands, especially when the number of 3+ million visitor days is considered. Why are not these values, and their expected changes according to the alternatives, included in the economic analyses?

The analysis provides the reader with information only on the costs of alternatives to the rancher, local community, and the BLM, with little or no information provided on other costs (e.g., wildlife loss, soil degradation, resource conditions, or recreation) or the diverse benefits of each alternative to these same entities, as well as to other economic values.

Section 4.3.4.1 - As the "fallback" no action alternative has the same economic consequences as the proposed alternative, and the changes in AUMs are the same, the proposed alternative is essentially the same as the no action alternative in terms of grazing management. That is, if no action results in reduction of 16,267 AUMs and the proposed action also results in a reduction of 16,267 AUMs, bow can the proposed action succeed at meeting the goals and objectives?

BLM has concluded that rapid recovery of the ecosystems they administer would require approximately $800,000 over 5 years statewide in program costs. BLM has also concluded that about 10 jobs and $1 million would be the cost to the ranching industry to implement rapid recovery, as opposed to the proposed alternative. Not included in the analysis to fairly evaluate the proposal is the likely benefit to fish and wildlife resources and concomitant recreational value that would rapidly accrue with implementation of Alternative 4.

BLM has concluded that they could well be on the road to "rapid" recovery of rangelands they administer in California for about $2 million additional cost to California and the United States over the next 5 years, or approximately $400,000 per year. What is the benefit to California and the United States to implement recovery of rangelands at a rapid rate? BLM has not provided that number, but the Department believes it far exceeds the cost.

Appendix 7 - Why is there no condition and trend assessment provided for riparian/wetland areas, as these are the most significantly impacted and so heavily focused on for monitoring purposes?

Final Comments

As range scientists and managers know, once you have achieved good to excellent rangeland health conditions, you can typically carry more livestock than you previously had supported. Alternative 4 begins to get at the long-term approach needed for management of western rangelands.

Long-term understanding of rangeland dynamics and productivity and a new investigation and study of potential productivity are needed on an allotment-level or ecosystem-level scale. Manipulation of herbivores on a large scale may be necessary to adequately begin to understand the factors affecting ecosystem health. We recommend this involve allotment-scale studies that preclude all livestock grazing for a period of time. This would enable the most rapid recovery opportunity on some components, while illustrating that recovery of all degraded rangelands likely involves far more effort, and is more complex, than simply removing livestock.

Time frames to achieve restoration objectives should be clearly stated. When will recovery efforts begin, how long are they expected to take, and what actionS will be implemented if progress toward restoration is not occurring as rapidly as expected or desired? This is especially important where livestock grazing is allowed to continue at some level in areas where the rangeland is considered "unhealthy" or is not at PFC.

Given the greater rangeland health improvements offered by Alternative 4 compared to the other three alternatives, countered only by some economic consequences associated with loss of AUMs (and the lack of disclosure about the nonlivestock economic benefits/costs of alternatives), the Department supports Alternative 4.

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