Shirley Murrer

August 26, 1997

I appreciate the opportunity to comment on Rangeland Health Standards and Guidelines for California and Northwestern Nevada DEIS'. However, I have a number of concerns and suggestions.

Basically, I support Alternative I because I feel that less federal control and more local control is the way to achieve any objective. More knowledgeable decisions can be made by the people working on the ground -they can be more site specific. I believe in working from the bottom up, not the top down.

As presented in Appendix 18, the impacts per alternative are, in the majority of the cases, the same between Alternatives 1-3. Therefore, the most logical and "user friendly" (both to land and permittee) approach is the local approach - Alternative 1.

I would like to point out some inconsistency in text. In the Table of Contents, Chapter 2, 2.3 Alternative 2: the wrong title is listed. 2.4 Alternative 3: the wrong title is listed. The two have been transposed.

Chapter 1, page 8, 1.9 Analysis Area states "Currently there are 705 grazing allotments . . ." in Table 1.9: Analysis Area, the Total # Allotments is 667. Why the difference?

General Comments:

I strongly believe that for any standard, guideline, term or condition to work, it must be capable of being achieved, based on sound science or good common sense, and be measurable, understandable, and economically feasible.

Not enough emphasis is placed on the fact that healthy rangelands are important to satisfy values and "produce commodities".

Not enough emphasis is placed on cost effectiveness. (The cost to implement some guidelines is just not worth the end result.)

Specific Comments:

CHAPTER 2 DESCRIPTION OF ALTERNATIVES

2.53 Susanville RAC Guidelines for Livestock Grazing Preamble

Insert at beginning of first paragraph: "Rangeland Health is important in order to satisfy values and produce commodities. (Rangeland Health, 1994 pp. 4 and 5)." Healthy Rangelands contribute . . . the most reliable "insert-production" of rangeland resources "insert-and commodities.

Standards

Second paragraph, end of first sentence, add - but realize that perfection is unattainable.

Susanville RAC Guidelines for Livestock Grazing

Guideline 1: A stubble height threshold "insert-site specific," will be . . .

Guideline 3: Question the meaning of what plant growth. and during critical times of plant growth." Does this mean all plant growth? or just sensitive plant growth?

Guideline 4: Not only plans for grazing, but the allowance of other uses need to be managed or restricted to ensure the goal of achieving rangeland health.

Guideline 12: insert after first sentence "And will not be held accountable for the self same transitional opportunities or disasters."

Guideline 14: This guideline should be eliminated. It would need personnel and time that are not available to implement punitive measures across the board. Initiation of allotment specific analysis for terms and conditions on individual permits will be conducted on a priority bases. Therefore taking care of any extreme existing conditions first. Transitional guidelines, therefore, are unnecessary.

CHAPTER 3 AFFECTED ENVIRONMENT

3.3.3 Upland Conditions and Trends. Problems with the use of Ecological Site Inventory (ESI) to determine range condition.

The concept of proper functioning conditions of Uplands needs to be incorporated into BLM's inventory procedures.

Clarify that when the condition is poor, with no upward trend, this does not necessarily mean that the area is in poor health. Why make or use these classifications if it doesn't represent the true area health?

3.8 Recreation

Sixth paragraph. ". . . and the visual intrusion of seeing livestock in primitive areas where people expect a natural environment." Question fact of this statement. Ouestion whether it is a visual intrusion? and that livestock are not natural?

CHAPTER 4 IMPACT ANALYSIS

4.2.9 Cultural Resources

Ranching Communities

"To most ranchers, there will be no impacts to their traditional ranching lifeway . . " Question the truth of this statement. There is always an impact.

4.3.4.1 EIS Study Area Analysis

Income & Employment Impact

This section states that a reduction in AUM's resulted in income and employment loss. How can the Standards & Guidelines be implemented effectively when there are not enough personnel to accomplish this? Therefore, is this whole process capable of being achieved and cost effective?

Thank you for your consideration of these comments.

Sincerely,

Shirley Murrer
Susanville, CA