Bill Phillips

Bill Phillips

July 31, 1997

Following are my comments about the Rangeland Health Standards and Guidelines:

General Comment:

As a taxpayer, it is my opinion that the effort and dollars spent on "Rangeland Reform 94" and "Rangeland Health Standards and Guidelines" would have been much more productive had it been spent to solve specific on the ground problems using existing law and regulation.

It is my opinion that the Susanville Resource Advisory Council has made a very conscientious effort in this exercise.

Specific Comments:

Page 19, preamble: Paragraph one, sentence one: "Healthy rangelands contribute to the social and economic well being of rural communities in Northeastern California and Northwestern Nevada, and they provide over the long term, the most reliable harvest of rangeland resources." Change the word "harvest" to "production."

Page 20. Standard 2, Streams
Criteria to meet Standard
paragraph 3
"Tile stream water surface has a high degree of shading resulting in cooler water in summer and reduced icing in winter.

I don't understand shading reducing icing in winter. Why is the frost always about twice or three times as deep on the north side of a building?

Page 21 -- Standard 4: Riparian and Wetland Sites.

Meaning that: The riparian and wetland vegetation is controlling erosion, stabilizing streambanks, shading water to reduce water temperatures. The underlined should read: shading water areas to slow the rise of daily water temperatures.

Page 23-. Guideline 5

This must recognize that in some cases that a very long time may be required to obtain potential natural vegetation.

Page 24-- Guideline 14: Transitional Guidelines

Both the amended regulations and the Draft ElS transitional guidelines require immediate action if the standards are not being met. These are as follows:

4180.1 Fundamentals of Rangeland Health:

The authorized officer shall take appropriate action under subparts 4110, 4120, 4130 and 4160 of this part as soon as practicable but not later than the start of the next grazing year upon determining that existing grazing management needs to be modified to ensure that the following conditions exist.

Guideline 14: Transitional Guidelines

Due to the extended period of time that will likely be needed to initiate allotment specific analyses for terms and conditions on individual permits, the following guidelines will be applied immediately upon implementation of the Standards and Guidelines. The transitional guidelines represent the minimum necessary guidelines to prevent the most abusive grazing practices from occurring. Range site specific exemptions to the Standards and Guidelines would only be allowed in the most extreme situations (refer to preamble, paragraph 3). Transitional Guidelines will be appended to the existing land use plans.

I am not sure what conditions will require the use of Guideline 14. This will depend on the opinion of someone. Different people will look at this differently. If immediate implementation is not intended, then it should say so in the guidelines. Immediate implementation has the potential to cause heavy reductions for some allotments, thus causing rancher anger. If implementation is delayed, some other groups will become angry. This will cause a court battle which will tie up dollars that can better be spent at solving on the ground problems.

Discussion follows under a 1, 2, and 3

a 1: Riparian (permanently saturated areas of perennial streams) Threshold: Maximum 60 percent utilization of herbaceous vegetation to be measured by the Landscape Appearance Method.

It is assumed that the 60 percent utilization is to be measured at the end of the growing season and grazing season, however, the guideline does not say that Perennial streams will cause less conflict than small permanently saturated areas. Many of the streams in the Susanville District have been placed under restrictive grazing at the present time. Some of the use on these steams has been under controlled grazing for several or many years. Others are presently planned for more restrictive grazing. ff this guideline is applied to all saturated areas, major reductions of livestock grazing will occur for some allotments and all livestock grazing will be eliminated from some areas where there are even a few wild horses. A few wild horses can keep very small saturated areas grazed very close, even where there is super abundance of forage nearby. Where there are no wild horses in some cases grazing would be eliminated by July 15 of every year.

It is my opinion that the BLM should Continue to fence springs and associated saturated areas and pipe water to tanks outside the fence. Generally, a secondary riparian area can be fenced in the overflow area. Often a spring developmen¿ry up an existing riparian area.

It is my opinion that some small seeps should be left unfenced as water sources for wild horses and burros, pronghorn, deer, sagegrouse and livestock without placing priority on riparian values. Some of these areas are very small and not feasible for spring development. Generally such areas on a grazed landscape are grazed to about 85 percent. This can occur within a day or two after animals enter the area.

Indicator: No net loss of wetlands from livestock trampling. The problem is not the net loss of wetlands as much as it is preventing the recovery of wetlands by continued trampling by livestock

a-2: Uplands

Threshold: Maximum 50 percent utilization of perennial or native herbaceous and browse species to be measured by the Landscape Appearance Method.

Here again, the 50 percent utilization should be based on the total growth per year.

Grazing in the Great Basin in general is very uneven. The percentage of utilization measured can vary greatly from transect location This can cause great conflict in interpretations of the guideline.

a-3. Crucial (essential) Deer Habitat

Threshold: Maximum 20 percent utilization of annual growth on key browse species prior to October 1, in identified concentration areas. This will be measured by the Landscape Appearance Method.

From my experience with BLM, I see a serious push to put Guideline 14 (Susanville) into effect, then backing off after conflicts come to a head. This places the field people open to heavy criticism. It appears to me that addressing problems on a priority basis rather than with a broad brush is a better approach.

Note that I do not approve of the gross abuse of a landscape. However, this can be taken care of with present law and regulation. In Susanville, the problem is mostly coming up with management for the sore spots, of which there are many. However, each year there are fewer of these.