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Modoc County Board of Supervisors
Box 131
Alturas, CA 96101
August 19, 1997
The Modoc County Board of Supervisors wishes to submit the following
comments regarding the Rangeland Health Standards and Guidelines for California
and Northwestern Nevada Draft ElS. The comments were prepared by the Modoc
County Land Use Committee and were approved by the Board of Supervisors
at its regularly scheduled meeting of August 19, 1997.
1. Modoc County supports Alternative 1, specifically the Susanville
RAC recommended Standards and Guidelines with the exception of Guideline
14, Transitional Guidelines.
a. The County applauds the hard work of the Susanville RAC whose
volunteers put in long hours to produce this alternative.
b. The opening sentence in the preamble is especially valid. "Healthy
Rangelands contribute to the social and economic well being of rural communities
in Northeastern California" . . .
c. Standard 4: Riparian and Wetland Sites - Exceptions and Exemptions
to Standard 4 is especially singled Out for support. Areas around watering
and handling facilities have proved to be monitoring sore points in the
past.
d. The County believes guideline 14 is unnecessary and could cause
harm. Because it would require immediate action take place on an allotment
that does not meet standards, many options to solve the problem would not
be available. The time frame would not allow, for example, the construction
of any kind of improvement to help bring the allotment into compliance
because of the time necessary for NEPA analysis, Construction etc. Therefore,
the only remedies are those which reduce livestock numbers, season of use,
etc., all which have adverse economic impacts on local communities. Guideline
14 should be removed so all the tools that could bring an allotment into
full compliance remain available.
2. Modoc County opposes Alternative 2, the Statewide Standards. While
not being too much different than the status quo, the local standards and
guidelines of Alternative I are preferred.
3. Modoc County rejects Alternative 3, the National Fall Back Standard
and Guidelines. Once again, this alternative is less desirable than Alternative
1, which was developed locally.
4. Modoc County strongly opposes Alternative 4. The implementation
of this alternative would have significant negative economic impacts to
Modoc County without a corresponding improvement in rangeland health. The
livestock numbers would go down, but the BLM lacks the resources to immediately
manage these problems. Rangeland problems can be corrected under Alternative
1 with less impact on livestock operators, local communities and the agency
Economics
a. It is unclear whether the multiplier was applied to the dollar
impacts displayed.
b. It is unclear whether a separate job multiplier was used when
assessing job impacts.
c. Modoc County appreciates the fact that early scoping identified
that the County could be severely impacted and therefore was included with
Lassen and Washoe as a principle grazing county to be more closely analyzed.
However, failure to display the data because it wasn't available from the
local resource area is not acceptable. Even if the discussions have shown
the impact is minimal, display the data to show that information.
d. While permittees living outside the County have some impact on
how the AUM's or loss of AUM's are analyzed, Modoc County is unique in
that regard. As a significant number of Washoe County AUM's are grazed
by livestock owned by operators in Modoc County (Surprise Valley), a display/analysis
of this unique situation would be helpful.
e. Overall, this is the best economic analysis done by a federal
agency since Modoc County has begun reviewing projects.
6. Miscellaneous
a. The County is concerned about implementation of the selected alternative.
The level of impact will be dictated by whether the final decision is implemented
all at once or on a priority basis. Modoc County encourages that it be
done on a priority basis as resources are available. While references are
made throughout the text that implementation will be prioritized, it appears
language such as Guideline 14 in the Susanville RAC Standards and Guidelines
would override implementation by priority. The County would again recommend
removal of that guidelines.
b. It is unclear if allotments that fail to meet standards and guidelines
for reasons not directly associated with livestock (i.e., juniper encroachment)
could still be exposed to possible livestock reduction.
Thank you allowing Modoc County to respond.
Sincerely,
Ben Zandstra
Chairman
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