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California Farm Bureau Federation August 29, 1997 The California Farm Bureau Federation is the state's largest agricuIturaI organization representing more than 72,000 member families. While we appreciate the opportunity to comment on the Rangeland Health Standards and Guidelines, we have serious concerns with this proposal and the alternatives offered in the Draft Environmental Statement (DEIS). Our first concern relates to the creation of Resource Advisory Councils (RAC's) and their role in drafting the Standards and Guidelines. These councils are compromised of 10-15 people. There is no requirement that a significant number of council members be public lands ranchers. So far the only meaningful activity conducted by the RAC's was the creation of grazing regulations. Since significant representation from public lands ranchers is not a requirement of the RAC's, we are concerned that councils may in the future consist of a majority of anti-grazing members, and not reflect responsible rangeland managers. The DEIS outlines several alternatives for the public review process. One alternative is missing, current grazing regulations. Under the current regulations, we have seen tremendous improvement in our rangelands. In fact, a 1990 report noted that rangelands nationwide were in the best condition than at any time this century. This trend holds true in California and with the exception of drought impacts. BLM resource lands continue to show steady improvement where grazing occurs. Accordingly, one alternative analyzed in this DEIS should be the current grazing regulations with an emphasis on showing the improvements to resource conditions being made by public lands ranchers. We are startled that the best alternative offered in the DEIS, Alternative One is going to result in a significant reduction in Animal Unit Months (AUM's). The analysis used in the DEIS underestimates the long-term effects of this reduction Ultimately, the loss of AUM's will harm rural communities drastically. This analysis focuses on the impacts to county economics. First, we believe that the analysis conducted does not adequately address these impacts at the county level. In addition, the analysis does not cover the impacts to local towns that will be most affected by a reduction in the grazing AUM's and the corespondent loss of viable ranches. To improve the level of economic analysis, we believe that a private firm should conduct this analysis with input from the agricultural community. Fewer AUM's will also contribute to the loss of viable ranch operations and the corresponding adverse impact to the environment. For some ranching operations, losing additional AUM's will force these operations out of business. When this happens the base ranches wilI likely be sold to the highest bidder, typically, development interests. Rangeland conversion to urban uses replaces valuable, productive and scenic rangelands with subdivisions. The end result of lowering the number of AUM's will be a net loss of habitat for species on private lands, for little or no significant improvement in public land resources. The DEIS fails to address this issue. A final concern relates to the new requirements for monitoring, if any of the alternatives move forward. We are not concerned that additional monitoring wili show adverse conditions; however, we are concerned that the agency will not be able to live up to the new requirements identified in these regulations. We believe that the agency will not have sufficient manpower to complete the additional monitoring requirements. When this happens, the BLM will then be sued by anti-grazing interests who will say that because the agency is unable to abide by the new regulations, that grazing must be stopped until monitoring activities are completed. We have seen this happen in numerous instances and believe that with the new regulations the BLM is destined for failure which ultimately hurts the grazing lands permittee and the resource. In closing, we would restate that Alternative One is the best option offered to responsibly manage BLM rangeland, but we believe that current grazing regulations are exceptional and are already resulting in the improvement or our resource conditions. Sincerely, Bruce Blodgett |
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