Water Quality Control Board

California Regional Water Quality Control Board
Central Valley Region
415 Knollcrest Drive, Suite 100
Redding, CA 96002

September 5, 1997

We have reviewed the May, 199? draft EIS for Rangeland Health Standards and Guidelines for California and Northwestern Nevada. Our comments follow.

Through state and national policy directives, it is apparent that BLM is committed to the long-term health of public rangelands including protection and restoration of streams, wetlands and riparian areas. We support this direction and this commitment. Through our involvement in recent years with BLM sponsored stewardship programs and restoration projects, we have seen significant improvements in water quality and aquatic habitat conditions in streams such as Fitzhugh Creek in Modoc County and Cedar Creek in Lassen County. These programs and projects provide an example of what can be achieved through proper management direction and the cooperative efforts of permittees, resource agencies and environmental interest groups. Hopefully, through the provisions of "Rangeland Reform 94", and the adoption of these rangeland standards and guidelines, we will see continued watershed improvements.

The draft Eis contains four alternatives for establishing rangeland standards and guidelines. However, the actual standards and guidelines under the four alternatives are similar, and as stated in Chapter 4 (Impact Analysis), all would result in enhancement of water quality, riparian, and wetland conditions. Our review focused on the standards and guidelines recommended by the Susanville RAC. Standards and compliance criteria are listed for streams, water quality and riparian/wetland sites. While we generally concur with the standards, it should be noted that they are mostly qualitative and opinions may differ on whether the standards are being met. Regardless, the narrative criteria do provide a reasonable basis for interpreting standard compliance and for guiding management decisions. Under Standard 3: Water Quality, we recommend adding a nondegradation statement (i.e. maintain existing high quality) in addition to "at a minimum, maintain water quality adequate to protect existing and potential beneficial uses." Criteria to meet this standard should include compliance with adopted state water quality standards in addition to the narrative criteria listed for streams, riparian and wetland areas.

The standards are followed by guidelines which describe practices or methods to be used to ensure that grazing management activities meet standards. The guidelines are similarly qualitative but provide that site specific measurable terms and conditions (e.g. utilization standards) will be included in individual grazing permits. We concur with this approach.

In summary, we concur with the Rangeland Health Standards and Guidelines set forth in the draft Eis. It has been our experience however, that water quality and watershed improvements will mostly depend on the commitment and capability of BLM to conduct watershed assessments, monitor livestock cause and effect relationships, establish and/or participate in collaborative management approaches (i.e CRMs, stewardship programs) and implement management change where appropriate.

James C. Pedri, P.E.
Assistant Executive Officer