Lassen County Farm Bureau
P.O. BOX 151
Susanville, CA 96130

August 30, 1997

Comments Rangeland DEIS

The Lassen County Farm Bureau would like to put forth these comments on the "Rangeland Health Standards and Guidelines for California and Northwestern Nevada" Draft Environmental Impact Statement (DEIS) published in May of 1997. We would like to point out of our areas of concern and will include suggestions that we feel you should direct toward the final document and notice of decision.

We believe the continued trend of improved resource conditions demonstrates permittees and BLM should look at this as a indicator of the cooperation and effort both have made over the last 20 years We hope these new standards are implemented in a way that continues this positive trend.

Chapter 1: Introduction

The analysis rangeland health should also include causes of unhealthy conditions such as roads, wild horses and burros, recreation and camping, ATV's and any other uses. Although this document is for grazing only, grazing does not contribute to many problem areas where the above mentioned forces are the causing factor. We do not feel removal of livestock is the answer to arbitrary resource damage. Removal of livestock cannOt be the preferred method of addressing rangeland problems as seems to be the cause in these 4 alternatives. Further efforts should be made to manage some of the other impacts mentioned above.

Chapter 2 Description of Alternatives

We agree with the preamble in the Susanville RACs standards and guides that notes healthy rangelands and social and economic well beings of rural communities are linked. Rural communities are suffering with economic woes and we hope these standard can be implemented in a way as to not increase the economic blight.

We feel the strategy of implementing these guidelines is very subjective. Since BLM allows that they cannot provide the personnel or financial resources to evaluate every allotment and will allow judgments to be based on available data and professional judgment: we feel determinations will be made that do not accurately portray the on the ground conditions. Decisions will be forced on public pressure. It would be more efficient to add these guides and standards to permits as they are renewed or issued. It would also help continue the climate of cooperation.

Alternative 1

We support this alternative. We feel the stubble height for stream sides areas is realistic. Local management decisions is appropriate here. We also support guideline 4. We question the authority and need for the transitional guidelines (guideline 14) proposed by the Susanville RAC. The agency already has this authority to deal with serious resource problems. This should be eliminated.

Alternative 3

This alternative is less comprehensive than 1. We do not think several of the fall back guidelines are proper and should not be included, specifically 11. Permittees need to be included in decisions.

Alternative 4

This alternative uses the incorrect assumption that removal of livestock provides rapid improvement in degraded resources. It does not take into account the many other factors which affect rangeland resources. Nothing has documented that livestock exclusion increases the rate of recovery. Guideline 2 is confusing and should not be used. We feel a rigid stubble height of 4 to 6 inches should be changed. This alternative is very costly and should be eliminated because it could not be supported by agency budgets.

Chapter 3: Affected Environment

The chapter needs to include the benefits of range improvements such as springs, wells, and off-stream water developments for wildlife. This is a huge benefit to the resource area. When referring to the past conditions of the Great Basin the term "pristine" is used. Those pristine conditions existed with grazing. Today the larger forces seem to be lack of natural fire and intense human impact which are not examined. The DEIS states that riparian areas absorb much recreation activity. They also tremendously degrade these areas as well which needs to be included. We also noted the range is supported 45 percent more wild horses than the agency's target figures. There impact needs to be included because their overpopulation greatly affects rangeland condition.

Chapter 4: Impact Analysis

Alternative 3 should he eliminated because it fails to address fully watershed function, nutrient cycling, and energy flow. Chapter 4 needs to recognize that removal of grazing is not the only management tool available. It is misleading to assume that this alternative will provide the fast recovery. Wild horse and burro overgrazing needs to be addressed in this analysis. They create many problems than livestock producers get blamed. For any standards and guides to be successful horses and burros must be managed accordingly. Recreational uses also degrade resources and they should be following the same standards by which permittees are held. We also feel BLM should analysis the impacts of conversion of rangelands to development as ranchers are forced off their permits.

Conclusion

Lassen County Farm Bureau supports continued responsible grazing of BLM lands because of the economic value it contributes to our community. We hope that new standards and guidelines can be implemented in a manner to continue the upward trend in range conditions as well as continue the viability of the ranching operation. Thank you for considering our comments.

Sincerely,

Hannah Tangeman-Cheney, President
Lassen County Farm Bureau

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