California Mule Deer Association
1673 Fruitvale Road
Lincoln, CA 95648

August 28, 1997

The California Mule Deer Association (CMDA) has reviewed the 1997 Draft Environmental Impact Statement for the California BLM Grazing Standards and Guidelines (DEIS) and provides the following comments:

1. Inadequate Range of Alternatives

The DEIS provided alternatives which were essentially the same based on their predictable impacted to natural resources. No significantly different wide range of alternatives was developed adequately addressing and discussing different levels of grazing intensity, duration and frequency. Nor were the impacts of such alternatives fully disclosed for the document reader to make a reasonably informed decision as to the merits of the alternatives as to their impacts to resources.

2. No "Rapid" Recovery" Alternative Provided in the DEIS

The DEIS provides no alternative which would result in an aggressive, rapid recovery and maintenance of natural resources to different grazing standards/guidelines.

3. Inappropriate "No Action" Alternative in DEIS

The DEIS provides an inappropriate "no action": alternative as the alternative does not accurately reflect current management which this alternative is required to.

4. All Alternatives are Vague and Inadequate in Themselves

No alternative provides specific, quantifiable standards and guidelines for livestock management. This results in the failure of CA BLM to comply with CFRs and promulgation of Rules addressing this document as found in the Feb. 22, 1995 Federal Register which clearly obligated BLM to:

a. Develop and implement specific S/Gs

b. Develop S/Gs which are more specific and detailed than state fallback S/Gs

c. Provide clear authority and guidance for range management

By reviewing all alternatives is quite clear there is not clear guidance, direction, nor specific detailed S/Gs provided the public nor BLM personnel.

5. No Detailed Monitoring Plan Provided in the DEIS

BLM is required, at minimum, to monitor Proper Functioning Condition of riparian areas via its 1996 interagency agreement with the USFS.

The DEIS did not provide specific monitoring direction for uplands.

A specific monitoring plan - who, how, where, when - needs to be provided in the DEIS.

6. No Implementation Plan Provided

DEIS must disclose who will do what, when and how.

7. No Enforcement Plan Provided

DEIS does not address nor discuss enforcement and penalties of the non implementation or compliance of the above plans.

8. No Plan nor Criteria for Allotment Prioritization for NEPA Analysis

DEIS must do so.

9. No Alternatives Avoid Season-Long Grazing

June 1, 1997 satellite transmission by BLM repeatedly acknowledged season-long grazing in riparian and/or uplands as the single most destructive grazing system and clearly not acceptable when developing a compatible grazing system in western rangelands.

10. All Allotments Must Have Interim S/Gs in Place Until Site-Specific Analysis is Complete

We recommend Susanville District Interim Guidelines as general approach.

11. All Alternatives Do Not Incorporate State Water Quality Standards

Each alternative must comply with state water quality standards and such must acknowledge state water quality standards will be complied with.

Sincerely,

Dano McGinn
President

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