Don Mullally

August 19, 1997

I. I submit that several subjects of importance have not been adequately considered or resolved in the Draft EIS for California rangelands administered by the Bureau of Land Management. They are discussed as follows:

1. Vegetation of in the cold boreal climates is particularly sensitive to grazing by sheep and cattle. Herbs, shrubs, and young trees existing near and above timberline are particularly sensitive and rebound from grazing most slowly.

Only minimal grazing should be permitted in vegetation types with canopies dominated by trees including lodgepole pine, western white pine, red fir, foxtail pine, bristlecone pine, white-bark pine, and mOuntain hemlock; or in semi-arid environments devoid of such trees but similar in zonal temperature and elevation. Grazing should not be permitted in the krunholz belt or in alpine environments above the highest zone of trees.

2, Most of the rangelands serve as winter refuges and feeding-foraging areas for species of animals which inhabit higher elevations during the seasons of late spring to mid-fall. Prominent among these species of wildlife are elk, deer, mountain lions, bobcats, coyotes; woodpeckers and various song and shore birds and raptors such as red-tail hawks, goshawks, and great-horned owls. Lowland refuges should be maintained and preserved. Corridors for elevational migration of wildlife must be preserved. What is BLM doing or planning to do in the future to satisfy this need?

3. The principal or representative plant communities and vegetation types of each region should be preserved within refuges of adequate size. Grazing should be banned from the refuges to insure the Survival of all native plants and the development or re-establishment of natural communities. A thin system of such refuges would insure the survival of plant diversity despite losses of species and communities suffered on land subject to grazing or multi-purpose usage. Is such a system of refuges presently in place or planned for the near future?

4. Recruitment and episodic recruitment of native plants are frequently mentioned in the Eis (ie. page 6, in chapter 4). However, long-term survival seems to be of less concern to the Bureau. Recruitment involving the oaks and many other plants has little value or significance if the young plants are allowed to be destroyed by domestic grazing animals or plant community destruction through development or land sales. Changes as presented on page 6 should include survival and maturation and the development of plant communities and age classes. Do BLM policies include general rules which allow for the maturation of the results of recruitment?

5. Rangeland health, by any reasonable and intelligent definition, should be largely determined by the diversity of the vegetation and by the age classes of the species of plants which should be on the land. The characteristics of the soil surface and the height and density of non native grasses should not be of near total importance. Before the European influence, healthy rangeland (utilized by native animals) bad high diversity and depth in age classes. To a high degree, the further the rangelands diverge from this standard, the lower their health. A rich influx of economically valuable non-native species many provide another dimension to range health.

II. Alternatives.

Alternative 4 is my choice.

Alternative 4 is selected for several reasons:

1. The federal public lands of California have been carelessly abused for a century, and in some areas even longer. Since land abuse has been long standing, efforts directed towards relatively rapid resource recoveries are validated and now preferred.

2. Many oak woodlands and wetlands absolutely require quick actions for preservation and reasonable recovery. Restored environments will continue to sustain ranching and meat production into the future. If grazing lands continue to degrade, returns from the land will gradually diminish.

3. In addition, some restored environments available to the public will attract greater numbers of recreationists. Recreationists buy equipment and supplies and spend much money in rural areas improving the state and the local economies.

Don Mullally
Granada Hills, CA