Nelson Ranches

August 26, 1997

I appreciate the opportunity to pro~de comments on the "Rangeland Health Standards and Guidelines for California and North Western Nevada" (DEIS), published in May 1997.

I have several suggestions and concerns that need to be addressed for the final document and decision notice.

(1) NEPA) requires agencies to analyze the direct and cumulative impacts of proposed actions while (DEIS) in most cases analyzes the direct impacts, it fails to analyze cumulative impacts of this and other actions (including the Federal Endangered Species Act).

(2) Nelson Ranch supports the idea that "for any standards, guide, 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.

(3) Nelson Ranch also supports the preamble to the Susanville RAC, standards and guidelines that healthy rangelands and the social and economic well being of rural communities are linked.

(4) We will only support Alternative #4 if guidelines #14 and 15 are removed from Alternative #4. If there are problems with a grazing system these guidelines do not provide for the solution they are simply a stop gap measure.

(5) Chapter 2, page 20, standard #3 regarding water quality. This statement is very vague and needs to be clarified. What does "original use" mean? What does "desired beneficial use" mean? If water quality is regulated by a State Water Resources Control Board, then this Water must be applied to Beneficial Use only to protect private water rights.

(6) Chapter 2, page 22 guideline #2: Desired seral states will be determined through the Allotment Management Plan". This statement needs further explanation. For what reasons does this have to be determined through the Allotment Management Plan?

(7) Chapter 2, page 21, standard # 4. Riparian and wetland sites: Nelson Ranch supports the language and the idea presented under Exception and Exemption to standard 4 (where standard 4 is applicable). I would like to see this language remain in the final decision.

(8) Nelson Ranch strongly opposes Alternative #4. This alternative is a penalizing proposal directed toward the livestock grazing permittee which when implemented would impact the Public lands Livestock grazing ranches significantly.

(9) Nelson Ranch prefers Alternative # 1 over Alternative # 2 and # 3 because #1 has been localized by the RAC Board and is sensitive to the local needs.

(10) Chapter 4, page 21, "Ranching community impacts and issues", needs luther analysis because much of the data is incomplete.

(11) A Possessory Interest study should be included in the DEIS.

(12) Chapter #2, page 19: ""be guidelines were designed to provide direction, yet offer flexibility for implementation through activity plans terms and condition for grazing permits". Flexibility is a very important part of the above quote, and FLEXIBILITY needs to be included in any final decision.

Thank you for the opportunity to comment on the Proposed Rangeland Health Standard and Guides for California Western Nevada.

Sincerely,

Stephen C. Nelson
Nelson Ranches