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State of Nevada August 21, 1997 Thank you for allowing the State of Nevada the opportunity to Comment on the Draft Environmental Impact Statement (EIS) for Rangeland Health Standards and Guidelines for California and Northwestern Nevada. As the enclosed comments from the Nevada Division of Wildlife, the Commission for the Preservation of Wild Horses, and the Division of Conservation Districts will show, the State of Nevada has several concerns about the content and methodology used for this draft EIS. The exclusion of wild horse and burro herds from analysis in this draft EIS is a large oversight and should be corrected in the final EIS. Also, in order to conduct a useful analysis, the BLM must use the most current, scientifically sound data. Without such data, it is difficult to develop any meaningful Standards and Guidelines. We hope you will find these comments useful as you develop the final EIS. We look forward to reviewing the final document when it becomes available. Sincerely, Julie Butler, Coordinator
**************************** State of Nevada August 22, 1997 We request that the final EIS more fully discuss the likely effects that the various alternatives may have on further introduction and/or spread of noxious weeds and other exotic species into remaining native-dominated rangelands throughout the analysis area, and the practices that should be adopted to minimize such effects.
State of Nevada July 24, 1997 1. Recommend the adoption of Alternative #1 for Rangeland Health Standards and Guidelines for California and Northwestern Nevada 2. Recommend the Standards and Guidelines be tested in the Surprise Resource Area on the Barrel Springs Allotment. In a visit to the area in early July, the riparian corridor appeared to be at risk because of livestock impact. C.K. Frieman
State of Nevada The Nevada Commission for the Preservation of Wild Horses has reviewed the Draft Environmental Impact Statement - Standards and Guide for California and Northwestern Nevada. Nevada has approximately four interstate and five resident wild horse herds impacted by livestock grazing within the Susanville District. Wild horses were excluded from this draft environmental impact statement. We were disappointed that the Bureau of Land Management did not assess the implementation of these Standards and Guidelines on wild horses. Standards and Guidelines for the Sagebrush Steppe Habitat were intended to establish the limiting factors or resource thresholds that required changes to meet Rangeland Reform. Wild horses adjustments have been the principle management actions to protect resources in Susanville -District the past 15 years of land use planning. Extensive planning efforts have created allotment management plans and grazing systems that were never fully implemented. Wild horse herds have been reduced over 70 percent, resulting in some herds with few as 20 animals. Given the past emphasis to reduce wild horses, it is surprising that the Bureau of Land-Management choose not to hold wild horses to the Standards and Guidelines developed by the Resource Advisory Council. We were not able to determine the criteria for determining which allotments in Nevada did not meet the fundamentals for range health. The documents did not present a list of the few allotments chosen to implement Range Reform. It is difficult to understand how the implementation of livestock adjustments over one to five years will meet the present federal regulations. While we realize that Bureau of Land Management lacks its desired funding level, we fail to find how the proposed action will require 15 years to achieve land use plan objectives or the Standards and Guidelines. In summary, Nevada has not witnessed the evaluation of rangeland monitoring data for allotment specific decisions on the majority of allotments administered by Susanville District. Exhaustive planning efforts and extensive range improvement projects have been applied to a majority of Nevada allotments. While the Standards and Guidelines complement the more specific land use plan objectives, these criteria should now be applied through management actions supported with range land monitoring data to promote heathy rangelands. Wild horses should not be excluded from these criteria. More progressive livestock actions may be necessary to meet the Standards and Guidelines in a more timely manner. Sincerely, Catherine Barcomb
State of Nevada The Nevada Division of Wildlife appreciates this opportunity to comment on the Draft Environmental Impact Statement - Standards and Guidelines for California and Northwestern Nevada. Presently, Nevada has 23 allotments in the Surprise Resource Area and two allotments in the Eaglelake Resource Area administered by the Susanville District. Many of these allotments have been under a formal land use plan for over 15 years. It is our view that Standards and Guidelines should complement these land use plans with more site-specific objectives and responsive management actions to conform with "Range Reform". Since Nevada allotments are within the Sagebrush Steppe Habitat Type, we will limit our comments to those portions of the document relative to Nevada. CHAPTER 1 Information provided in the background section did not include the Federal Lands policy and Management Act of 1976. Multiple use mandates of the Act created the present land use plans that are the basis of regulatory changes in Range Reform 94. The Standards and Guidelines should include Wild Horses and Burros. Wild horse populations throughout Nevada require management to achieve a natural ecological balance. Standards should uniformly be applied to all ungulate uses for monitoring studies and future adjustments in Nevada. CHAPTER 2 Screening criteria, data and assessments to determine the allotments' conformance to the Standards and Guidelines should be included in this Draft Environmental Statement. Data that determined the actual allotments in need of management actions should be included in this document. Prioritization of allotments was completed in the land use plans. A simple assessment of the existing prioritization and criteria should also be included. Implementation of the Standards and Guidelines appear to be limited to the present rule statement: "not later than the start of the next grazing year 1". It would be consistent to have Guidelines with different options for immediate management actions to comply with this rule. Susanville RAC Standards are comprehensive and complement existing land use plan goals, objectives and decisions. However, these Standards are less specific than existing land use plan criteria. For example, allotment final decisions completed in the early 1980's set allowable use levels for key forage species at the "moderate" level or 60% use of annual growth. Threshold stubble height of residual vegetation have been determined, in recent grazing decisions, to be within the range of four and six inches. Grazing decisions, that were based on monitoring studies that found key forage species in need of restoration, determined allowable use levels of 40% use of annual growth. Other examples are found in Guideline 14 that better reflect the existing land use planning. It would appear that these allowable use levels are Standards and management actions required to achieve them should be the Guidelines. CHAPTER 3 Monitoring is essential to the implementation of Guidelines. Use pattern mapping data are critical to determine if thresholds are being met. All data must be quantitative to determine if "significant progress" is being made by present management. We agree that averaging key management area and use pattern mapping data should not be used to determine carrying capacities. Statistical data should be provided to prove "significance" as stated in the rules. Allowable use levels have been established on some Nevada allotments. We would agree that annual precipitation has an effect allowable use levels. However, common practices used to Yield Index the observed utilization data during drought years would be contrary to data displayed in Table 3.2.5.. We suggest provisions be made to prohibit Yield Index procedures throughout the Sagebrush Steppe Habitat. Ecological Site Inventory is a meaningful monitoring tool to establish trend. This process may be more accurate than he inventories for the original land use plan; However, the two inventories are not comparable. Since the land use plan data are now twenty years old, it would be meaningful to compare range condition data. Wild Horses will require frequent gathers to meet the Standards and Guidelines. We agree that horse utilize the land differently than livestock. Therefore, special studies will be required to measure each ungulate use and to allocate available forage. CHAPTER 4 No data were provided to support the finding that 16% of the allotments are not meeting the fundamentals for rangeland health. We found no listing of criteria to measure the fundamentals. It is unknown what allotments in Nevada are within the Proposed Action. We found no data to support the proposed action for livestock use. Phasing in a 9.6 percent livestock reduction in 1-5 years to achieve the Standards within 15 years may be contrary to the stated rules of Range Reform 94. It is understandable that funding reductions of the range program could limit monitoring and data assessment as required by regulations. Failure to adequately monitor federal authorizations may then jeopardize continuation of any action. We hope that District's can make the necessary adjustments to implement and achieve the Standards and Guidelines. Sincerely, Richard T. Heap, Jr. |
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