College of Agriculture and Home Economics
Animal and Range Sciences
Box 30003. Dept. 3-1
Las Cruces, NM 88OO3-80O3

August 18, 1997

I have enclosed my reviews of the draft EIS "Rangeland Health Standards and Guidelines for California and Northwestern Nevada" and Dr. W. A. Laycock's review of the document. Consider this letter and my reviews official and use them however you wish. I have sent Mr. John Willoughby over 50 studies that relate to the residue issue and some of Dr. Laycock's other comments. I have put 50-60 hours of my time into this task. I have sent all my comments to Dr. Laycock.

An overwhelming number of range studies show soil, watershed, and forage plant health are closely tied to residues (read various enclosures). Therefore, I believe if there must be standards, minimum residues make more sense than any other rangeland characteristic since its the key element in soil stability, watershed health, fish and wildlife habitat, and aesthetic appearance. Further it is the key to preventing downward trends. A recent paper by leading range scientists suggests that the public considers standing biomass to be much more important than species composition (Heitschmidt and Walker 1996, Rangel. J. 18:194-215). The key point here is to strike a reasonable balance between what is practical for the rancher and what is needed to sustain the environment. I have suggested it might be reasonable to allow ranchers to exceed minimum residues or stubble heights 3 years out of 10. Further I have suggested that ranchers be allowed to exceed minimum residues or stubble heights on 3 out of 10 key areas during any particular year. This allows some management flexibility. The critical point here is to avoid having the same key areas out of compliance with residue minimums in year after year.

Residue based range management takes far more skill than prescription based management based on my experiences. However if there is adequate flexibility in the standards it can be a great approach to improving both rangeland and rancher welfare. However I emphasize that adequate flexibility is critical.

It is my hope that you and the RAC's will read the various papers I've sent you along with those from Dr. Laycock and then formulate their own objectives and monitoring plan based on science, equity, and social demand. I also suggest you solicit opinions from other professionals in soil, watershed, wildlife, and range sciences. While I liked the concept of using residue as basis for management in your draft EIS, keep in mind I am merely a scientist and educator and not an authority figure. It is my belief various viewpoints and ideas should be considered in drafting EIS documents.

In New Mexico residue and stubble heights are becoming a primary goal and basis for management on public rangelands. A recent court injunction on grazing on Forest Service lands (see enclosure) in New Mexico reflects what is happening. I have enclosed papers by Heitschmidt and Walker (1996) and Brown (1991) to provide alternative perspectives on residue to those of Dr. Laycock. Without question residue standards are one of the surest ways to end year after year heavy grazing on public lands. However I have never advocated the idea because it can cause undue hardship for the good ranchers if implemented without adequate flexibility.

In closing I appreciate the opportunity you have given me to review the draft EIS and respond to Dr. Laycock in spite of the time requirement. Thank You,

Sincerely,

Jerry L. Holechek
Professor, Range Science

COMMENTS:

1. Title:

I suggest "Objectives and Standards" rather then "Guidelines and Standards."

2. Background:

a. In my opinion objectives and standards would be better than guidelines and standards. What do you want to accomplish?

b. Fundamentals of Rangelands Health

Range health should be related to both ecological condition and soil vegetation cover in my opinion. Limited research indicates late seral communities (55-70% of climax remaining) will best meet the range health criteria described on most western rangelands.

C. Standards and Guidelines

Check definitions - A guideline is a broad measurement of something used for guidance. Standards are rules used to impose regulation authority.

d. Process of Establishing Standards and Guidelines

Shouldn't rangeland, wildlife, watershed, and soil scientists be included on the RAC's?

List the specific objectives of the RAC.

e. Public Scoping Issues

This section seems okay, however the issues read more like objectives.

f. Assumptions

Shouldn't this section be titled - Approaches?

g. Issues not Addressed

This seems okay.

h. Analysis Area

This section seems okay.

1. California Desert Area

This section seems okay.

j. Other Plans and Legal Framework

These sections seem okay.

3. Description of the Alternatives

a. Guidelines in page 9 are really objectives.

b. Table A on page ii - a more current reference would be:

Holechek, J. L., R. D. Pieper, and C. H. Herbel. 1995. Range Management Principles and Practices. 2nd Edition. Prentice-Hall, Upper Saddle River, NJ.

d. Ukiah Guidelines for Livestock Management

This section is okay. I like the idea of using a variety of management practices to accomplish objectives.

e. Susanville Guidelines for Livestock Grazing

What is the Landscape Appearance Method? Is this an accepted technique published in a peer reviewed journal?

Specifically how will residues be monitored?

f. I have no problem with how Table D on page 33 will be used. Basically it is back-up mechanism to deal with possible overgrazing problems.

4. Affected Environment

a. Generally this section is well written and well directed.

b. I consider the key area-key species approach to monitoring to be sound. It has been widely and successfully used on BLM lands in New Mexico.

c. The discussion on pages 13-16 is well directed. Heitschmidt and Walker (1996, Rangel. J. 1:194-215) provide an interesting discussion on this subject. On page 218 they suggest society's acceptance of given grazing practices primarily depends on standing biomass rather than species composition. The best way to avoid downward trends is to maintain adequate residues and stubble heights (see Thurow et al. 1988, JRM 41:296; Rhodes et al. 1964, JRM l7:l85). There is no doubt that residue approaches work well for rangeland health. However ranchers tend to resist it on public lands because it can result in termination of grazing at times unfavorable to them and cause financial losses if implemented without adequate flexibility. The issue here is to strike a balance between rangeland conservation and rancher welfare. I consider it reasonable to reduce livestock numbers or apply some other management change if stubble guidelines were exceeded more than 3 years out of every 10 years or 2 consecutive years in a row. Here I am referring to the average for key sites across the allotment. For individual key sites it seems about 70% of them should meet minimum stubble height guidelines in most years. This allows a rancher some flexibility in drought years. Generally under use in wet years will compensate for moderate overuse in dry years. However repeated overuse will damage most rangelands. Monitoring stubble heights allows range managers and ranchers to identify areas receiving consecutive years of overuse and make adjustments.

5. Soils

This section seems okay.

6. Vegetation

This section reads well and seems okay.

7. Upland Conditions and Trends

Tables 1-7, Appendix 7 are informative. They indicate some progress in improving ecological condition. However the fact only 23% of the total is late seral or climax is low from my point of view. In my opinion a reasonable goal might be 50-60% in late seral or climax ecological condition.

Pages 37-38 - Although research is limited on this subject, available studies indicate a late seral stage with 55-70% of climax will best meet multiple use needs (see Holechek 1996, Rangelands, Vol. 18, April p. 52) in most arid and semi-arid areas. Areas in early and mid seral stages often have inferior soil cover and produce much less forage for livestock than those in late seral condition. On seeded pastures, annual grasslands and forest areas ecological condition is not very useful as a measure of rangeland health.

8. Riparian - Wetlands and Stream Channels

Could outside finding from environmental groups be used to fence critical riparian habitat?

Will rest-rotation, deferred rotation, etc., systems permit riparian zone improvement? I suggest this be discussed.

9. Water Quality

This section seems okay.

10. Wildlife

a. I suggest more discussion on upland game species. How are populations of the different species (particularly sage grouse and mountain quail) holding up?

b. I suggest the primary threatened and endangered species be listed in a Table.

11. Recreation, Wilderness and Cultural Resources

I had no problem with these sections.

12. Economics

a. This section is interesting and important. I believe it does a good job in showing the economics of public land grazing.

b. Information on the net returns per animal unit and per acre for the grazing districts covered by the EIS would be useful.

13. Impact Analysis

a. Generally this section reads well and is sound.

b. Ranching communities p. 21

Upgrading ecological condition of the area covered should increase grazing capacity overtime. Will ranchers be given additional AUM's if forage production increases? This needs to be addressed in the EIS.

c. Grazing Management - p. 21-23

I have no major problems with this section, but I do wonder how the reduction of 16, 267 AUMs was determined.

d. Impacts on Individual Operators

Is there any way ranchers losing AUMs can be compensated for their loss? There should be assurance AUMs can be increased if meaningful increases in forage production occur through time.

14. Consultation and Coordination

a. This Section generally seems okay.

b. I suggest at least 1 each range, wildlife, watershed, and soil scientists be put on the RACs.

15. Appendices

This section seems in order.

16. Overall Evaluation

I think overall this is a good document. I think there should be more specifics on how monitoring will be conducted. I commend the RAC's for using residue as basis for monitoring, but feel strongly there should be some flexibility allowed with this approach. This flexibility needs to be carefully thought-out and specifically stated. I have previously given suggestions on what might be reasonable flexibility based on my work with ranchers, range conservationists and county governments here in New Mexico. Condition and trend data are quite useful and needed but are costly and difficult to collect. The best way to prevent downward trends and maintain soil, watershed, wildlife, and aesthetic values is to maintain adequate vegetation residues.

SOME COMMENTS ON DR. LAYCOCKS REVIEW OF
"RANGELAND HEALTH STANDARDS AND GUIDELINES
FOR CALIFORNIA AND NORTHWESTERN NEVADA"

Jerry L. Holechek, Ph.D.
Professor, Range Science
Department of Animal and Range Sciences
New Mexico State University
Las Cruces, NM 88003

Date: July 30, 1997

A. Dr. Laycock charges that I misused research in preparing the table on utilization guidelines for different rangeland types. Some key counter points are:

1. The utilization guideline table has been published in two refereed journal articles, two textbooks (Vallentine 1990, Holechek et al. 1995), 1 invited proceeding article, nd has been cited in several refereed journal articles and textbooks.

2. 1 had the table reviewed and approved by several leading range scientists before submitting it for peer review in refereed journals (Rangelands, Journal of Soil and Water Conservation),

3. The utilization guidelines in the table were not intended to be limits, and I have made no Statements recommending that they should be limits.

4. Gray used the same approach in his 1968 textbook, `Ranch Economics."

B. Dr. Laycock claims that the following statement by Holechek 1991 is not supported by scientific evidence and is contrary to the opinion of most current range scientists.

Holechek 1991 statement: "However in most cases it (50% utilization) causes range destruction in the rugged, arid ranges of the West."

In my opinion Dr. Laycock is contradicted on this point by the following papers (posted with John Willoughby, BLM, CA):

1. Pickford and Reid 1948
2. Johnson 1953
3. KIipple and Costello 1960
4. Paulsen and Ares 1961
5. Beetle et al. 1961
6. Houston and Woodward 1966
7. Smith 1967
8. Hyder 1953
9. Skovlinetal. 1976
10. Martin and Cable 1974
11. Hughes 1990
12. Hughes 1992
13. Clary 1995

C. Dr. Laycock claims that imposing light levels of grazing on most western ranges will not result in faster recovery than will occur with moderate levels of grazing in the proper season.

This generalization is not valid if a careful evaluation is made of the long term grazing studies. Although in some cases Dr. Laycock's statement holds, I believe it is contradicted by the following studies:

1. Skovlin et al. 1976
2. Klipple and Bement 1961
3. Sims et al. 1976
4. Paulsen and Ares 1961
5. Johnson 1953
6. Smith 1967
7. Smoliak 1974
8. Valentine 1970
9. Beetleetal. 1961
10. Lewis et al. 1956
11. Taylor et al. 1997
12. Klipple and Costello 1960
13. Woolfolk 1949
14. Launchbaugh 1957
15. See review by Lacey and Van Poollen 1981

These papers are posted with John Willoughby.

D. Dr. Laycock makes the statement that periodic heavy grazing will in most situations give faster recovery than reducing grazing pressure. I believe several papers by leading researchers contradict him on this point. They include:

1. Pieper and Heitschrnidt 1988
2. Hart et al. 1993
3. Taylor et al. 1997
4. Review paper by Van Pollen and Lacey 1979
5. Review paper by Lacey and Van Pollen 1981

In the humid range types and in riparian areas, heavy grazing that is carefully timed has sometimes been effective in promoting range recovery. There are cases where carefully timed heavy grazing by sheep and goats has been effective in reducing unwanted plants. However these strategies usually adversely impact livestock performance and leave little residue to protect soil and provide food and cover for wildlife.

E. Dr. Laycocks statement that areas where improvement is desired often are in a lower successional stable state and will not improve with a change in grazing intensity in any time frame meaningful to management is somewhat misleading. Surveys indicate about 38% of BLM lands west wide are in a mid seral condition and about 13% are in a early seral condition. Nearly all lands in a mid seral condition have some residual climax decreaser species. Several studies have shown meaningful improvement of these areas over 20-50 year periods under reduced grazing pressure or no grazing. Some of these studies include:

1. Anderson and Holte 1981
2. McCormick and Galt 1993
3. Holechek et al. 1994
4. Potter and Krenetzby 1967
5. Yorks et al. 1992
6. Yorks et al. 1994
7. Smith and Schmutz l995
8. Cooper 1953

I believe Dr. Laycock's (1991) "stable state" paper is most applicable to arid areas in a early seral condition but is less relevant to mid seral areas. What constitutes meaningful improvement is largely a social judgement. Demand and value of red meat, recreation, water and other products drive whether active (brush control) or passive range management practices are appropriate at any time.

F. Dr. Laycock strongly opposes the stubble height and residue standards in the draft EIS. In my opinion this is a social choice that depends on the objectives of the RAC. There can be no question that residue plays a vital role in sustaining aesthetic appearance, soil stability, watershed quality, wildlife habitat, and fish habitat. Further it lowers rancher risk and plays a key role in livestock nutritional status. On the other hand maintaining minimum residues every year on areas grazed by livestock will be difficult due to drought. I suggest a compromise be reached with the goal to maintain minimum residues 7 years out of 10. 1 also suggest that a rancher be allowed to have up to 3 out of 10 key areas below residue minimums in any year. The key here is to avoid exceeding minimums in year after year on the sarne key areas. If standards are to be used in public rangeland management I hold the opinion that residue makes more sense than any other measurement. The best way to avoid or reduce downward trends and promote upward trends on arid and semi-arid rangelands is to maintain adequate residue. Minimum residues protect soil, watershed, wildlife, fish and aesthetic values. This statement is based on a massive amount of research.

0. A practical problem with short term heavy stocking in the proper season as suggested by Dr. Laycock is that it often does not accommodate rancher seasonal or annual forage needs. Another problem is heavy grazing almost always reduces livestock performance.

H. I consider the coverage of the utilization issue by recent "Rangelands" articles suggested by Dr. Laycock somewhat one sided. I agree with the articles that percent utilization has low value in yearly management decisions (see Jasmer and Holechek 1984). However stubble heights and residues have proven to be a very practical management tool and can be easily measured. Jasmer and Holechek (1984) reviewed this issue in detail (paper enclosed). Dr. Laycock fails to consider that several leading range scientists through the years have advocated residue and stubble heights as a basis for management.

Dr. Laycock states that I have a very different view of utilization than the majority of the range science community. I believe he should describe how my view differs from the majority of the range science community using papers that I and the others have published. I believe my papers show that I favor stubble heights and residue to monitor of grazing intensity but recommend that utilization coefficients be used to assign harvest efficiency to livestock. These ideas come from the long term stocking rate studies by Johnson 1953, Klipple and Costello 1960, Hooper and Hooper 1970, Bement 1968, Paulsen and Ares 1961, etc. My ideas are being tested on public rangelands in New Mexico. I would be most pleased to provide documents that support this statement.

Dr. Laycock makes the judgement "This EIS document should not have any utilization figures or tables in it." He states "Such limits should be set only at the AMP level only as a "tool" to achieve a stated objective, and never as a land management objective. " Dr. Laycock should clearly explain why he is so right on this issue and the RAC's are so wrong.

K. It may be that the real issue between Dr. Laycock and myself centers around prescription versus information based range management. The residue approach to range management involves more knowledge, effort, and skill than prescription range management that centers around set grazing periods and set animal numbers with little emphasis on values other than desired plant composition. Prescription range management provides certainty to ranchers, it does not require the effort of annual residue checks by ranchers and range managers, and there can be no real assessment of management effectiveness until 5-10 years have passed and trend can be assessed. In the past the prescription approach relied heavily on active vegetation manipulation (i.e., Vale Project) funded by the federal government. More recently reductions in livestock numbers have been widely used. Under information based range management ranchers need to be given wide flexibility in management options and government serves more as a source of information rather than as a source of funds for range improvements. Information from society on what it wants from federal rangelands plays a part in rancher management approaches and goals. The role of public rangeland managers is more as educators, mediators, and facilitors and less as regulators and prescribers. Under the information approach ranchers are not tied to set stocking rate or permit numbers. The rancher's annual report card might center around what percentage of the key areas were in compliance with residue or stubble height minimums while his longer term grade would place more emphasis on plant composition objectives. Low grazing fees, hunting permits, recreational fees, and biodiversity trust fund fees are some ways ranchers might be rewarded for doing well on their report cards. In order for information based range management to be effective ranchers need appropriate incentives, considerable flexibility, and better access to sound information (see Holechek and Hess, 1996, Fomm for Appliers and Public Policy, p. 5-15) 1 believe it will require much change in attitude and training by professional range managers. I feel fortunate I have been given some opportunities to test the information approach in New Mexico. Without change away from the old ways, I believe the future of public land livestock grazing could be in great jeopardy.

COLLEGE OF AGRICULTURE AND HOME ECONOMICS
ANIMAL AND RANGE SCIENCES
Box 30003, Dept. 3-1
Las Cruces. New Mexico 88OO3-8OO3

August 18, 1997

To: Dr. W. A. Laycock
Department Rangeland Ecology and Management
University of Wyoming
Laramie, WY 82071

I have enclosed my reviews of "Rangeland Health Standards and Guidelines for California and Northwestern Nevada Draft EIS" and your comments on the document. These reviews were requested by John Willoughby. You will note I take exception to some of your statements. I am particularly interested in why you are so opposed to residues and stubble heights as guidelines or objectives and how you believe I have misused the research data to prepare the table on utilization guidelines. My approach of relating percent use to heavy, moderate, and light grazing came from Gray (1968). He considered terms like heavy, moderate, and light grazing to be somewhat ambiguous unless related to level of utilization. You will note (see enclosure) he generalizes moderate grazing to be 30-50% use. Keep in mind my position has consistently been that grazing intensity should be monitored with stubble heights or residue (see Jasmer and Holechek 1984) and that utilization data are best used as harvest efficiency coefficients in grazing capacity determinations (Holechek 1988). While percent use is not well related to grazing severity in particular years, when it is averaged over 5-10 years it is fairly well related to rangeland trend and health (see Johnson 1953, KIipple and Costello 1960, etc.)

You will note I disagree with you on certain statements regarding grazing intensity outcomes. I have filed the studies that are the basis for my views on these issues with John Willoughby, and assume you already have them. These studies are cited in the documents I've enclosed. If you need any of them I'll be glad to send them to you. I have long considered the Johnson (1953) study to be an outstanding classic.

Residue has become an important concern on public rangelands here in New Mexico. Grazing intensity standards are now being applied on some Forest Service lands. While I've never advocated standards of any kind or that stocking rates be regulated on public lands, this is becoming more and more a part of grazing policy. At the invitation of both public range managers and ranchers, Dr. Dee Galt and myself (we are partners) are under contract to apply my approaches in grazing surveys on public and private rangelands in New Mexico. We are working closely with Dr. Chris Allison of the Range Improvement Task Force and Brian Sandford of the New Mexico State Department of Agriculture in these cases. We have had favorable responses to our surveys so far but more testing is needed. I would be pleased to provide you with our reports if your are interested in them.

I have enclosed an article by Heitschmidt and Walker (1996) that you may not have. They suggest on page 208 that standing biomass is much more important to the public than plant composition. They also advocate moderate stocking rates but they are vague about what specifically moderate stocking involves. Another article I've enclosed by Brown (1991) gives an environmentalist/hunter perspective on the residue issue.

Rather than resist residue approaches, I have tried to develop some reasonable compromises here in New Mexico. We are trying to get the Forest Service to go along with standards that provide ranchers some flexibility such as allowing them to exceed minimum residues 3 years out of 10. We are also trying to get them to permit up to 30% of the key areas to exceed minimum residue/stubble height guidelines during any year. We are presently testing both my stocking rate and stubble height techniques on the 550 AU Sacramento Allotment on Forest Service lands near CloudaoIt, NM. The ideas I have advanced on flexibility are also being considered. At this point in time we have had strong support from the ranchers, county planners, Range Improvement Task Force and NMDA. We believe application of sound range science can create win-win situations and avoid another fiasco such as the "Diamond Bar." A major part of this initiative is to train ranchers and Forest Service range managers on how to use the stubble height/residue approaches. One of our objectives is to move away from the prescription permit numbers approach and encourage ranchers to manage their rangelands around residue. So far I am most encouraged by our experiences on the Sacramento and the Copper Creek Allotments. However it is too early to declare our approach a model other areas can use.

I will be interested in learning more about your ideas on this subject and consider this a great opportunity to improve my own range science skills and knowledge. I allow that I don't have all the answers and there is room for improvement in my ideas and approaches. I would greatly value your review of the enclosed paper "Conducting Grazing Surveys: Some Experiences and opinions" by Dr. Galt and myself. Thank You.

Sincerely,

Jerry L. Holechek
Professor, Range Science

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