August 27, 1997

Thank you for the opportunity to comment on the Draft Environmental Impact Statement, Rangeland Health Standards and Guidelines for California and Northwestern Nevada dated May, 1997.

The purpose of environmental documents is disclosure of information. I found this document extremely hard to read, especially since it contains so much verbiage and so little useful information. The appendices are especially cryptic and lacking useful information. I find the document to he lacking coverage of the subject of mitigation and monitoring of the standards set forth in the document. I will be specific in my comments as follows:

General comments:

1.) Though standards and goals are set forth in the document, albeit in a very general fashion, there is no mention in the document for specific mitigation strategies for countering the devastating effect of grazing animals on the native habitat of numerous species. By mitigation strategies, I mean such protective mechanisms such as fencing off riparian areas to prevent the damaging effect that commercial grazing animals have on stream habitats. These damaging effects include an increase in turbidity of the waters through erosion of stream banks, collapsing undercuts of stream banks, introduction of urine and fecal material into the stream water and destruction of stream canopy, emergent vegetation and introduction and spread of such water-borne diseases as giardia and cryptosporidium. This fencing needs to he carefully designed to keep commercial grazing animals out of the riparian areas, yet still allowing native animals full use of the riparian areas and corridors. Another example of a possible protective mechanism is prohibition on the use of rock slope protection (rip rap) in riparian areas. Once a repair has been made using rock, the canopy in that area of the stream is deficient forever, whereas use of alternate repair strategies such as geo grid slopes maintain the possibility of canopy restoration.

2.) There are no specific commitments to mitigation or monitoring the health of the rangeland under the jurisdiction of the Bureau of Land Management and no date of implementation of any mitigation measures or review of this document.

3.) There is no mention of the acreage of jurisdictional waters of the U.S. that come under the requirements of a 404 permit from the U.S. Army Corps of Engineers. This would he the area within the Ordinary High Water Mark (OHWM) for each stream, perennial or ephemeral, and all other water bodies within the bounds of BLM grazing land including wetlands as defined in the 1987 Corps Manual.

4.) The document does not mention the threat of cryptosporidium contamination of water systems by grazing animals. Cryptosporidium is a health hazard for humans and can be life threatening to immunosuppressed individuals. The document should discuss the implications of water contamination by animal borne pathogens and how these effects can be mitigated.

5.) There is no mention of restoration of areas that have been over grazed, how this will be accomplished, or monitored.

6.) The maps on in Chapters, MAP-I .2, 3, and 4 are not very helpful in determining location of ELM administered lands. They are just gray smudges on a small map of California. Closer. separate maps of each resource area is needed to allow the reader to understand the map. Regardless, it is hard to follow listed species possibilities when the areas are outlined as smudges on small map.

7.) These may be included in the special study, but there is no reference in the document to having gotten a listing of current listed species from either the U.S. Fish and Wildlife Service or the California Department of Fish and Game. These lists should be included and at least referenced in the document and the date which they were obtained.

Specific Comments:

1.) Page 61-63

a.)What is the makeup of the permitees granted grazing rights on BLM land, i.e. how many are Americans and how many are foreign-owned?

b.) How do grazing rights rates on ELM land compare to those on other properties both government and privately owned land?

c.) How much do the taxpayers of the U.S. benefit from the granting of grazing rights on this public land?

Appendix 9

Page A9-9 The guidelines provided on this page all use the term "should" instead of the more enforceable "shall". it is my feeling that "shall" should replace the "shoulds" in this document to make these guidelines more enforceable, and thus protect the habitat.

Appendix 11

a.) What is meant by UG "ungrazed", for instance Jepson's onion, Allium jepsonii, is found in serpentine areas and volcanic slopes and flats, 300 m to 600 rn altitude. Are these areas fenced off in the Folsom Resource area or is it the document's contention that these areas don't exist within grazing areas? How do you know? Please at least give reference to the study that made this finding.

b.) What is the basis for finding a "neutral" or "positive" effect of grazing on these species, i.e. what specific studies have been performed to show a neutral effect of grazing on these species. Direct reference or footnotes of the scientific studies used as a basis for these findings would be useful in this regard. Also less use of acronyms and codes would make these tables easier to read.

c.) Many species are missing from Appendix 11. 1 will give a few for instances, but there is not enough room in this letter to cover them all:

Scientific Name	Common Name	Federal Status	CA Status	Characteristic
Amsinckiau gandiflora	large-flowered fiddleneck	ENDANGERED	ENDANGERED	Central Valley, Valley, grassy slopes below 300 m.
Asfragalus agnicidus	Humboldt milkvetch	ENDANGERED	ENDANGERED	Open soil in woodland south Humboldt Co.
Astragalus albens	Cushenbury rnilkvetch	ENDANGERED	NONE	Rocky areas 1200-1800 m NE San Bern.
Astragalus clarianuus	Clara Hunt's milkvetch	PROPOSED ENDANGERED	THREATENED	Open grassy areas Sonoma, Napa Cos.
Atriplex tularensis	Bakersfield smallscale	SPECIES OF CONCERN	ENDANGERED	Alkaline soils, lakeshore, south San Joaquin Valley
Berberis nevini	Nevin's barberry	CATEGORY I	ENDANGERED	Sandy to gravelly soils, washes below 650 m south western CA
Blennosperma bakeri	Sonoma sunshine	ENDANGERED	ENDANGERED	Vernal pools wet grasslands below lOOm north coast region CA
Brodiaea filifolia	thread-leaved brodiaea	PROPOSED THREATENED	ENDANGERED	Grassland, vernal pools, 60-300 m San Diego Co.
Brodiaea insignis	Kaweah brodiaea	SPECIES OF  CONCERN	ENDANGERED	Foothill woodland south Sierra Foothills Threatened by grazing

What is the basis for finding a "neutral" or "positive' effect of grazing on these species, what specific studies have been performed to show a neutral effect of grazing on these species. Direct reference or footnotes of the scientific studies used as a basis for these findings would be useful in this regard. Also less use of acronyms and codes would make these tables easier to read.

Please send me a copy of the Final Environmental Impact Statement when it is issued. Thank you for the opportunity to comment.

Sincerely,

Sveinn Erik Olafsson
Emeryville, CA

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