Elizabeth Painter

September 1, 1997

I apologize for the lateness of my comments. Unfortunate family problems have delayed my being able to submit these. I hope that they are not passed the deadline for consideration. The cover letter I received with the draft gave 31 August 1997 as the deadline.

Although this is a sunday of a three-day weekend, and not a work day, I am sending these comments on 31 August 1997, in hopes that you will consider them to be within that deadline. A hard copy of my comments will follow by mail.

I am writing as a concerned member of the public and a professional scientist with both interest and experience with the topic of the Draft Environmental Impact Statement (DEIS). I have graduate degrees in both botany and range science and have published in professional journals on both topics, including invited papers.

As a matter of professional identification only, I hold research associate appointments at both the University of California at Berkeley (University and Jepson Herbaria) and Colorado State University, and am currently editor of Madrono, the journal of the California Botanical Society. My comments are entirely my own; I do not presume speak for either institution nor for the journal nor society. I am not attaching references. However, I will be glad to provide references scientific literature that support my comments below.

Standards and guidelines for grazing management of BLM lands are long overdue and much needed. When I received this document, I had anticipations. I had hoped that this EIS would supply genuine, measurable standards for range management in California and northwestern Nevada and guidelines for meeting them. I was quite disappointed it does not. The public has limited confidence in government agencies to manage public lands (Brunson & Steel 1994 Rangelands 1994). The public-land livestock industry is perceived as an example of harmful tax ayer-subsidized resource extraction (Losos et al. 1995) of limited economic importance (Power 1996). Public lands support a relatively small proportion of the cattle raised in the United States, or in California and Nevada (Forest & Rangeland Resources Assessment Program 1988, Torell et al. 1992, Power 1996) at high ecological cost (Fleischner 1994, Gillis 1991, Mack & Thompson 1982, Milton et al. 1994, Painter 1995) . Therefore, it behooves the BLM to provide genuine quantifiable standards and guidelines to achieve their goals.

The DEIS should be quantifiable standards for each significant soil type, for each vegetation type including (but not limited to riparian areas and wetlands), and for each special status species. There should be concise guidelines for each of these. There needs to be at least a brief discussion of each technique to be used, with a monitoring plan and schedule. There needs to be a clear implementation plan, with schedules for management change on allotments where there is known grazing damage, identified by resources area.

Instead of the clear, concise, quantifiable standards and guidelines needed for ecologically sound management, the Eis depends upon vague statements that are closer to goals than standards and guidelines for meeting those goals.

The DEIS (p. 4) defines 'standard' as "a criterion. . upon which a judgement or decision is based. . . [that) is measurable.......By that definition, there are few 'standards' in any of the alternatives in the Eis, since the 'standards' given under each alternative are not measurable.

Time does not allow me to go into detail as to why most of the 'standards' are not measurable as written. There is a heavy dependence on "sufficient", which is not defined in any measurable way. For example, what constitutes "sufficient" ground cover to protect sites from accelerated erosion? How is it quantifiable? What are the guidelines for this"? Also, how does one know when biological soil crust are appropriate? How does one measure "appropriate"? Unfortunately, these types of vague, nonquantifiable statements are not substitutes for genuine standards.

There are even fewer 'guidelines', as defined by the DEIS on p. 4. What are the criteria for deciding if a grazing system is compatible with the persistence of desired species? What are those desired species? What are the criteria for deciding if a species is desirable or not? How will it be quantified if grazing management practices are allowing for the reproduction of species that maintain riparian-wetland function?

One of the few quantifiable standards presented in the Eis is the use of residual dry matter (RDM). RDM monitoring has limited predictive powers (Vallentine 1990). RDM method was designed for use on private land with alien annual grasslands, to maximize livestock production. It is inappropriate for many vegetation types and it should not be used as a substitute for monitoring that is designed to protect natural resources and special status species. There needs to be a protocol included in the DEIS for measurement of RDM (and all other quantifiable guidelines)

I am aware that a number of conservation and public service organizations (including California Native Plant Society) have been working with government agencies to help develop quantifiable standards and guidelines.

It would have been little more work than what went into this document to adapt these standards and guidelines for Alternatives 2 (statewide consistency) and 4 (rapid improvement/rapid recovery) or to advise RACs on how to adapt them for their areas (Alternative 1). Since there are regulations in place, measurable standards should be available for them. These should have been spelled out in detail, along with appropriate guidelines.

The alternatives contain no specific quantifiable guidelines as to what will actually instigate management changes in the field. There are no provisions such as "if bare soil exceeds an average of 5% in a pasture, grazing use will cease" or "if browse damage of riparian woody indicator species exceeds 5% grazing will cease". Instead, what is provided are vague, unmeasurable goals. There are no monitoring plans of any kind in the DEIS. Even the best standards will not produce change without careful, appropriate monitoring.

Although the DEIS points out that there is livestock-related ecological damage on BLM lands, it provides no list of priority allotments nor any plans for management change. Specific plans for identified allotments, with actions and time projections, is essential to meet the stated goals.

The evaluation of current ecosystem condition is in chapter 3 is subjective and inadequate. It incudes very little quantitative information on soil conditions, weed infestations, riparian physical and biological condition, etc. It does not reference any of the documents available on the condition of special status species, including US Fish and Wildlife Service findings and the numerous studies that have been done on these species (many funded by BLM).

The DEIS does not include information about numbers of acres or allotments that have been surveyed for weeds nor for rare and endangered species. The most recent data available to me indicate that there are large gaps in BLM data, but the DEIS does not include a plan to fill those gaps.

The DEIS has no program to survey for nor eradicate alien weeds. In fact, BLM appears to be specifically managing for the maintenance of a vegetation type dominated by alien biologically weedy (sensu Baker 1974) plant species -- Mediterranean-annual-dominated grasslands.

Appendix 11 does not correspond with special status plant species lists that can be found in NEPA documents for subunits within the area covered by the DEIS. The former should be a subset of the latter. The DEIS should have an explanation why there is a discrepancy.

Appendix 11 defines 'positive' effects on special status plant species only in terms of supposed benefits from reduction in residual dry matter and presumed reduction in competition from annual grasses. This definition assumes that reduced residual dry matter in facts is beneficial to all special status plant species and that their is reduced competition from annual grasses and that such competition is in fact limiting.

The best available scientific literature includes many cases where litter and/or standing dead biomass are in fact important to plants and that reduced amounts has negative impacts to those plants. Thus, it needs to be demonstrated that the special status plant species on the list do better with reduced litter and standing dead biomass than they do with the material in place. To simply assume this without specific data, assuming a 'benefit' just wishful thinking, which is a very poor basis for management decisions.

Van Dyne & Heady (1965) pointed out that livestock generally do not preferentially feed on alien annual grasses. Only by such preferential feeding on the alien annual grasses and preferential avoidance of the special status species would livestock grazing lead to a significant shift in competition. Therefore, it needs to be quantifiable demonstrated that such differential use does occur in the habitats of each special status plant species and that there is a statistically correlated increase in the numbers of the special status species. Without these data, simple declaring a 'benefit' can only be wishful thinking. Management decisions for federally and state listed species should be based on best available science.

The DEIS needs to consider all possible impacts of livestock (both direct and indirect) when considering whether impacts are negative, positive, or neutral, including (but not limited to) defoliation, pull-up, trampling, soil compaction, damage to mycorrhize, damage to cryptobiotic crust, damage to nurse plants, and changes in nutrient cycles and continual export of nutrients. For example, Taylor and Davilla 1986) included loss of cryptobiotic crust and associated increases in weedy alien annual grasses as a negative impact of livestock to Caulanthus californicus.

Statements in Appendix 11 concerning effects of livestock grazing under current management on the special status plant species are contradicted by reports for species on this list I was able to quickly review, including Caulanthus californicus (Taylor & Davilla 1986; Mazer & Hendrickson 1993), Eremalche kernensis (Taylor & Davilla 1986; Mazer, LeBuhn , & Meede 1993), Eriastrum hoover (Taylor & Davilla 1987), and Lambertia congdonii (Taylor 1987; Mazer & Hendrickson 1993). These call into question the rest of the purported effects. The DEIS needs to cite all available research and/or monitoring data for each species and state whether those data provide evidence for negative, positive, or neutral effects. The current information is meaningless and misleading.

Thank you for your consideration of these comments and concerns.

Elizabeth L. Painter, Ph.D.
Santa Barbara, CA