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W.A. Laycock, Professor Emeritus July 9, l997 I find it difficult to believe that a several hundred page document is needed for this DEIS. When the various RACs were formed (I am a member of the Wyoming RAC, which is now under state control) I felt that it was completely unnecessary for this many individual RACs to be working independently on Standards and Guidelines for states or BLM districts within states. This document presents separate S&Gs for 3 different BLM districts. This is unnecessary duplication. In addition, I find little evidence that individual members of the three RACs had much influence in this document. I review many EISs and other documents from the BLM every year and this one has many of the same characteristics of all of the other BLM-written documents I have reviewed. It appears that the 3 RACs simply "rubber-stamped" a BLM- written document. The exception may be some of the items included as "guidelines" for the 3 districts. Some of these indicate input by someone outside the BLM. The membership of the 3 RACs (p. 4-5, Ch. 5) shows a conspicuous absence of anyone from the Range Science community. How can any RAC and the BLM write a document that should represent the state-of-the-art in range science with no representation or input from range scientists? The following comments are somewhat in sequence. However, where appropriate, I grouped comments about a specific topic together even though they referred to different parts of the DEIS. SPECIFIC COMMENTS ON DRAFT ElS "RANGELAND HEALTH STANDARDS AND GUIDELINES FOR CALIFORNIA AND NORTHWESTERN NEVADA" Definitions of "Standards" and "Guidelines": The BLM and the 3 RACs need to look in a good dictionary for the definitions of "Standards" and "Guidelines". The BLM, in the regulations and in this document, reversed these 2 terms and improperly defined them. By dictionary definition, a "guideline" is just that, something broad that is used for guidance. A "standard" is "that which is set up and established by authority as a rule for the measure of quantity, weight, extent, value or quality". Thus, a "standard" should be something that is specified at the site specific (AMP) level which has defined performance criteria tied to it. What the BLM has defined as "standards" are really "guidelines", etc. Why have an English dictionary if any agency can re-define words to fit its own agenda? "Fundamentals" of Rangeland Health: (Ch. 1 D. 3-4. Ch. 2. D. 5 &12): Even though these 4 "fundamentals" of rangeland health are stated in the BLM regulations, that fact does not make them valid as true "fundamentals". The first two "fundamentals" are based on highly modified information from the "Rangeland Health" book but even that book did not call these items "fundamentals". The last two are simply "obey the law" type of statements that have nothing to do with anything resembling a "fundamental". The BLM should re-think these 4 "fundamentals" and work with the range science community to come up with "real" fundamentals of rangeland health. The ones stated simply subject the BLM to criticism. In Chapter 4 (p. 3, 4.2.1 Grazing Management) you state that "l6% (of the 705 grazing allotments) are estimated as currently not meeting one or more of the fundamentals for rangeland health". The way they are written, how can you possibly know that a given allotment is either meeting or not meeting one or more of the "fundamentals"? If Standards and/or Guidelines are properly written and, if ways to monitor them are specified, you may be able to tell if an allotment is not meeting one or more Standards or Guidelines. I do not believe that anyone ever intended that individual allotments be tested to see if they meet any or all of the 4 "fundamentals". Even if the 4 "fundamentals" were really valid (they are not), this would be true, i.e., "fundamentals" are not what you test to see if an allotment is in compliance. The logic of all of this needs to be examined. Overemphasis on utilization and/or stubble height limitations- I find it extremely disturbing that this document dictates utilization or stubble height (residue) limits for all 3 districts. 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. This document dictates utilization limits in Chapter 2 (Table A, p. Il; Table B, p. 17; Table C. p. 28; Table D. p. 33) and Chapter 3 (Table 3.2.5, p. 15). Table 3.2.5 in Chapter 3 is especially disturbing because it was lifted out of a range management textbook intended for use in a beginning- level course and never intended to be used as a management guide. The whole table (3.2.5) uses research data in an extremely inappropriate manner including a reference to one of my published papers. My cited paper (Laycock and Conrad 1981) presented information on the amount of utilization actually observed in a grazing study on high elevation sagebrush rangelands. No where in the paper did we "recommend" that 30-40 percent utilization was the maximum amount of utilization that these rangelands could sustain. Nothing in the paper gave any indication that the observed actual utilization levels should be "limits". However, this is what Holechek's table (and this and the other tables in your DEIS) dictate. The same is true of almost every reference in the Holechek table. Thus, Holechek misused research data in preparing this table and you are missing research data by reprinting this table and the tables referred to above to limit utilization to a predetermined arbitrary level. You also cite a 1991 Molechek paper that is not readily available and was not published in a peer reviewed source. The following statement from his 1991 publication (cited on p. 14 in Ch. 3):
is not supported by scientific evidence and is contrary to the opinion of most current range scientists. Holechek has a very different view of utilization than the majority of the range science community. Your choice to use him as your sole reference concerning utilization puts a deliberate and unjustifiable slant on the document. Remedy this by including other appropriate literature (see below) and eliminating the Holechek references. This DEIS document should not have any utilization figures or tables in it. As indicated both above and below, utilization is one tool to achieve a land management objective. As such, setting of utilization levels should be done only at the individual AMP level. Utilization levels should not be set at the district or state level covered by this document and all of the tables containing utilization or stubble height (or residue) standards should be removed from the DEIS. The other faulty assumption concerning utilization that occurs throughout this document is that lighter levels of utilization will speed recovery of a plant community. This is community- dependent but, as a general concept, is not true. For most western range communities, imposing light levels of grazing or no grazing at all will not result in faster recovery than will occur with moderate levels of grazing in the proper season. Areas where improvement is desired often are in a lower successional "stable state" (see Laycock 1991) and will not improve with a change in grazing intensity in any time frame meaningful to management. Generally, something else has to be done (like brush control) in conjunction with moderate (not necessarily light) grazing at the proper season, before the desired improvement starts to take place. In most situations, periodic heavy grazing, a change in the season of grazing, or some other specific grazing treatment often leads to desired change much faster than simply reducing or removing grazing pressure. Using utilization as an "objective" instead of a tool-- Coupled with the mis-use of research data in setting utilization limits is the completely erroneous practice of specifying utilization levels as "objectives". On p. 13 of Chapter 3, the last paragraph states: "Management objectives are developed that specify how much utilization is allowed..." As indicated above, utilization (or residue) is a tool to achieve a land management objective (such as a Desired Plant Community) and should never be used or stated as an objective. Recommended papers on utilization--Attached are 3 papers concerning the use, and especially the misuse of utilization. Consider these papers as an official part of my review. All 3 must be cited and referenced in the EIS. More importantly, the information in the papers should be read and understood. The one written by a BLM Range Conservationist in Nevada clearly defines how the FS and BLM misuse utilization. When these papers are used, most of the information on utilization in this DEIS would have to be removed because it is factually and logically flawed and therefore erroneous. Exceptions to Standard 4 (Susanville RAC) Riparian and Wetland Sites--the listed exceptions and exemptions to Standard 4 (Ch. 2, p. 21) are excellent. Stock water facilities, etc., are areas that too many people try to fit into riparian or wetland standards or guidelines. Minimal use of the concept of "Desired Plant Community" (DPC) in either "Standards" or "Guidelines" (Chapter 2): The term DPC is used only sparingly in the document (e.g., Ch. 2, p. 8; Ch. 2 p. 6 & 13 and elsewhere) and is defined in the glossary. DPC is an excellent BLM developed concept that the whole range science community has now accepted and adopted. Why not make more extensive use of this concept in this major BLM document? It should be mentioned in all of the appropriate guidelines for all 3 districts. I know that some environmentalists do not like the DPC concept and I suspect that this is why it is so little used. The following Society for Range Management (SRM) publications explain the DPC concept and basically adopt it as SRM policy. They are not cited in this DEIS (but should be)-
It is amazing that these Important publications outlining the policies and standards of the professional Society for Range Management (SRM) are not even referenced in this document. The lack of any range science input is very conspicuous all through the document but this omission is especially disturbing. "Impacts" on species diversity (Chapter 4)--In two places you state that one of the changes expected is "Increased Species Diversity" (Sagebrush Steppe, p. 6 &11; Riparian, p. S). No data are presented to indicate how or why this will happen or how diversity will be measured. Highest species diversity in a given habitat generally occurs at mid seral (low good to high fair) range conditions. The majority of your communities are now in Hid Seral or higher condition (Table 1, Appendix 7). Improving Mid Seral communities to High Seral or PNC generally will decrease species diversity for that habitat. Table 1 in Appendix 7 indicates that 30% of total acres are in Early Seral, 42% are in Mid Seral, 20% are in Late Seral and 3% are in PNC. This indicates that the greatest possibility for increasing species diversity probably occurs only in the 30% in Early Seral condition. Increases in range condition in the 65% of the acres in Mid Seral, Late Seral and PNC probably will result in either no change or decreases in species diversity. The Tables in Appendix 18 also indicate that you expect all 4 of the Alternatives to cause "Movement toward later seral stages" and "Increased diversity of plants and animals" (Page AlS 4). Except for the 30% of area representing communities in Early Seral condition, these two statements contradict each other, i.e., movement from Mid Seral to Late Seral or from Late Seral to PNC will usually decrease species diversity in the 62% of the area in those conditions. What data do you have to indicate that species diversity will increase under the various alternatives? No species diversity data are presented in the DEIS and no methodology to measure or estimate diversity are presented. The preceding statements about Species diversity are somewhat contradicted by other statements about landscape diversity. The Susanville RAC guideline 9 (Ch.2, p. 23) states that "Grazing management practices must sustain biological diversity across the landscape. A mosaic of seral stages, vegetation corridors, and minimal habitat fragmentation must be maintained. "Except for fragmentation, which is a very poorly defined concept on rangelands (does it even apply on rangelands?), this is a good statement. However, it does not necessarily agree with the objective of increasing species diversity in all habitats. The concept of a mosaic of seral stages is quite good and should be the goal of management. However, it conflicts with Guideline 2 (Ch. 2, p. 22) which states that achieving potential Natural Communities (PNC) is the goal for all riparian zones. You cannot maintain a mosaic of seral stages if your goal is have everything in PNC. Economics--(Ch. 3, r). 6l-67)--Initially I was pleased to see sections on economics included. However, after looking at these tables and text, my reaction was "so what". The Western U.S. figures mean little in your specific areas. What do all of these figures mean? You never really talk about the impact of reducing federal AUMs on individual operations in your areas in this section. Contact Dr. Bob Fletcher (U. Nev. Reno, stationed in Las Vegas) to get some meaningful figures on this. Economics--(Ch. 4, D. 28)--This section does contain more details on the economic impacts of grazing. It is disturbing that all 4 alternatives call for reductions of between 16,000-36,000 AUMs. I don't see the real justification for that magnitude of cuts anywhere in the document. I am not an economist but I also find it difficult to believe the assumption that a loss of 16,000 AUMs represents a loss of only 8 jobs. You unfairly minimize the magnitude of the cuts by the statement that the loss of 16-36 thousand AUMs does not represent "a significant impact.. even in the 1.5 billion dollar California livestock industry". This insensitive portrayal puts these cuts in such an inappropriately large context that it tends to trivialize the major impact such cuts will have on individual livestock operators and their local economies. "Transitional" Guidelines (4 14)--Susanville RAC(Ch. 2, p. 24)--I am not familiar with the "landscape appearance method" of determining utilization and I object to it being used to determine the "thresholds" outlined here. By its name, this certainly cannot be a very accurate, reliable or repeatable method. Specifying this method is in direct conflict with what is stated in Guideline #15 below, i.e., that monitoring will be conducted using current accepted practices and techniques. The "landscape appearance method" is not accepted as a standard method by the range science profession. Because this method does not fit your stated goal of using accepted techniques (Guideline #15), this Transitional Guideline (#14) should be deleted. Monitoring for trend (Guideline #15, ch. 2, p. 24)--This states that monitoring for trend of rangeland health will be conducted "using current accepted practices and techniques". I know what accepted practices are for monitoring for range condition and trend. These are mentioned in the section on "Quantitative Monitoring" and "Long-term (trend) Monitoring" in Chapter 3 (p. 9-13). The results of conventional quantitative methods are shown in Tables 1-4 of Appendix 7 for range condition and in Tables 5 and 6 of Appendix 7 for trend. What are the "accepted practices and techniques" for monitoring trends in rangeland health? They are not covered in Chapter 3. If you really are talking about accepted practices for determining range condition (and trend) then state it in that way, and don't call it rangeland "health". Otherwise, you need to tell the reader what quantitative methods (not qualitative checklists) you plan to use to measure trends in "health". The matrix presented in Appendix 1 came out of the "Rangeland Health" book but contains little that is quantifiable and nothing that can be used to determine trend. The switch in nomenclature from "condition" to "health" without indicating what changes (if any) will be made in methodology does not give the reader enough information for evaluation. Does the use of the word "health" in the DEIS really mean range "condition" in the traditional sense? "Guidelines" presented in DEIS--With the major exception of the utilization tables (which must be removed from the document), other references to utilization and stubble height or residue, and the other specific things mentioned above, the "guidelines" for Bakersfield (Ch. 2, p. 9-12), Ukiah (Ch. 2, p. 16-23), and Susanville (Ch. 2, p. 22-24) generally tend to be good. References--In addition to the 2 missing SRM "Unity" papers (see above) and the 3 attached papers on utilization, the DEIS does not cite one of the best references on the effects of grazing--
The chapter-- "Implications of Livestock Grazing in the Intermountain Sagebrush Region: plant Composition" by Rick Miller, Tony Svejcar and Neil West-- is an excellent summary for the sagebrush type, with 13-1/2 pages of references. Some of the other chapters in this book may also be pertinent to other vegetation types covered in the D~IS. Glossary-- Biological Diversity--this isn't the accepted definition of biodiversity. See West's invited review paper on "Biodiversity of rangelands" in the 1993 Journal of Range Manage. (p. 2-13) for a much better definition. "Fundamentals of Rangeland Health"--see my earlier comments. "Standards" and "Guidelines"--see my earlier comments on the incorrect use of these two words by BLM. |
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