Lassen Sportsmen

Organized Sportsmen of Lassen County

August 31, 1997

Thank you for the opportunity to comment on the Rangeland Health Standards and Guidelines Draft EIS. WE have a number of comments we wish to be considered.

First is the makeup of the Resource Advisory Councils {herein known as RACs} in terms of members, particularly the Susanville RAC. On page 5 1.5, it states the RACs are made up of a "cross-section of varying interests in public land management." It should be noted that the makeup of the Susanville RAC Is heavily slanted in favor of the livestock industry and its supporters, especially so after you capitulated to the livestock industry and its political supporters and placed three additional members on the Susanville RAC who are ranchers or are pro-livestock bringing the membership from the norm of twelve to a cumbersome fifteen.

This action on your part does a tremendous disservice not only to the concept of the RAC but to the public as well. It ruins the whole concept of balance in terms of interest and gives wildlife, our primary concern, the short end of the stick as happens so often with BLM decisions. The aforementioned "cross-section" is really a cross-section of the livestock industry and its supporters with but a smattering of other affected interests. In order for a RAC to be truly effective, it must be a balanced membership and be able to focus on rangeland health without being constrained to only focus on grazing and its impacts.

The second comment concerns the total lack of information relevant to the economic value of wildlife and recreation in this document. This severely flaws the entire purpose of the document in that it does not describe in detail other economic values of healthy rangelands. While the livestock economics are described in relative detail, there is no information given regarding the economic value of wildlife and recreation. Both the Calif. Dept. of Fish and Game and the Nevada Dept. Of Wildlife have done studies on the economic value of wildlife, hunting and fishing. This important information is easily obtained and should have been included in this document.

Third comment. We have always maintained that hunting and fishing and recreation bring in more monies to local economies than the heavily subsidized public land grazing. U.S. Taxpayers are losing approximately four dollars for every one dollar the federal government spends on public land grazing. The demographics of the West are rapidly changing and the welfare days for public land grazing are drawing to a close. Recognition must be made of these facts and our lands managed appropriately in accordance with true "multiple-use." Wildlife must never again take a backseat to livestock or other interests.

Fourth comment. The National Environmental Policy Act mandates equal consideration for wildlife when actions are proposed or taken on our public lands. This equal consideration s not being given in this document. Indeed, these Standard and Guideline proposals should have been inclusive of all needs and interests on public lands - not just for public land grazing.

After coming to the conclusion that BLM will never conclude this document to be flawed and short-sighted and fails to consider other interests but in the most rudimentary sense, we can not recommend any of the alternatives because of the severe lack of information presented, particularly that which pertains to economics related to hunting, fishing and recreation to mention just a few. We feel that it would be far better to flesh this document out to the extent that it reflects all activities and interests that occur on public lands. Without this critical information, it remains impossible to make accurate, unbiased, and effective decisions. Only when all interests and their activities are studies and assessed can we be able to bring our public lands back to a healthy, viable standard of productivity.

Respectfully submitted,

Wayne Jambois, Spokesman
Organized Sportsmen of Lassen County