Modoc Cattlemen's

Modoc County Cattlemen's Association
202 West Fourth Street
Alturas, CA 96101

August 28, 1997

The Modoc County Cattlemen's Association (MCCA) appreciates the opportunity to comment on the proposed Standards and Guidelines for California and northwestern Nevada. MCCA has several concerns and ideas that we would like to direct your attention to and some questions we would like answered.

MCCA will support Alternative #1, but only after Some minor changes are implemented.

1. Guidelines 14 & 15., the Transitional Guidelines, need to be eliminated from the alternative. These guidelines basically eliminate the benefits of the thirteen guidelines that proceed them, and obviously would take away from the benefits derived from this alternative simply by the time and effort that would be needed to implement them. If there are problems with a grazing system these guidelines do not provide for the solution, they are simply a stop gap measure. MCCA wants to see a site specific allotment analysis done before terms and conditions are decided upon. Please remove Guidelines 14 and 15 from Alternative #1.

2. Chapter 2, page 20, Standard 2: Streams. Criteria to Meet Standard. The third item reads: The stream water surface has a high degree of shading, resulting in cooler water in summer and reduced icing in winter. MCCA would like to see the scientific data that validates the reference to reduced icing in winter

3. Chapter 2, page 19, third paragraph, second and third sentences. MCCA believes this shouldn't apply to areas where significant juniper encroachment has occurred. The habitat could be improved remarkably with proper fire management or different types of control.

4. Chapter 2, page 19, Middle of fourth paragraph. The sentence reads: The Guidelines were designed to provide direction, yet offer flexibility for implementation through activity plans and Terms and Conditions for grazing permits. MCCA feels that having the tool of flexibility is an important Statement and needs to be in the final decision.

5. chapter 2, page 20, Standard 3: Water Quality. The first sentence needs to have added at the end: "and is compatible with private water rights."

6. Chapter 2, page 22, Guideline 2. MCCA feels that the desired seral state does not need to be determined in the Allotment Management Plan because the decision is always so subjective by the individual make the decision.

7. Chapter 2, page 21, Standard 4: Riparian and Wetland Sites. MCCA supports the language and idea presented under Exception and Exemptions to Standard 4 (where Standard 4 is not applicable). MCCA would like to see this language remain in the Final Decision.

8. chapter 2, page 19, Preamble. The first sentence of the preamble makes an important point of how our Healthy Rangelands are liked to the social and economic well being of rural communities in northeastern California and northwestern Nevada. MCCA feels it is important to have this statement in the final decision document.

9. Chapter 2, page 23, Guideline 11. MCCA feels that fire needs to be utilized as a management tool and we strongly support Guideline 11.

MCCA strongly opposes Alternative #4, This Alternative is simply a penalizing and punitive proposal directed toward the livestock grazing permittee which , when implemented, would economically impact the Public Lands Livestock grazing rancher significantly. The only management tool available is to impact the individual permittee. It does not allow for the improvements to go in and maintain the current AUMs with an improved grazing system. Also, we believe Alternative 4 violates the Taylor Grazing Act and the Public Rangelands Improvement Act,

MCCA like Alternative #1 over Alternative #2 and #3 because #1 has been localized by the RAC board and is sensitive to the local needs,

Chapter 4, page 21, Ranching Communities. MCCA feels that you have sidestepped the impact issue you are trying to address in this section. If there is an impact to the industry, then it needs to be stated as such. We don't want to see any type of broad statement which says "To most ranchers, there will be no impacts to their traditional ranching lifeway through implementation of grazing standards," The statement Most Ranchers could mean 51% of the ranchers in the USA. The impacts need to be specific to the BLM Public Land Grazing Ranchers in California and northwestern Nevada. The word lifeway cannot be found in the dictionary and probable should be changed to read way of life, MCCA suggests that the first sentence of this paragraph de deleted.

Sincerely,

Steve Nelson
President
Modoc County Cattlemen's Association