August 31, 1997

This email contains my comments regarding the BLM's draft ElS, "Rangeland Health Standards and Guidelines for California and Northwestern Nevada." I will send a paper copy of these same comments by mail.

1. It has always been my understanding that, to be effective, an ElS should be as detailed and focused as possible. Otherwise, an ElS is completely worthless as a predictor or environmental impacts. I found this DEIS to be lacking in detail and focus, and, instead, to be full of imprecise statements, broad generalities and "weasel words." Moreover, it reads more like a very vague management plan than a statement of specific environmental impacts that grazing has had and may continue to have on BLM-managed lands. This is extremely troubling. The lands under consideration cover a very broad and varied geographic area and support an enormous diversity of organisms, ecosystems and ecological processes. Some of the species native to these lands are listed as threatened or endangered (e.g. giant kangaroo rat, blunt-nosed leopard lizard, San Joaquin kit fox, Caulanthus californica, Eriastrum hooveri, Lembertia congdonii, etc. . . etc. . .). Moreover, several of the communities are in danger of extinction (e.g. California valley grassland and spiny saltbush scrub). This DEIS does not come close to doing justice to the land or the organisms and ecosystems that occupy them. Because of the degree of imprecision, I find this DEIS to be completely unacceptable.

According to sections 1.1 and 1.2, this DEIS is being prepared because of congressional mandate and a directive from the Secretary of the Interior to regulate grazing and to preserve public lands. Presumably, the ElS will serve as a legal document and as the basis for management decisions. Because the language in it is so vague, it is my opinion that this document is just a giant loophole. For example, what exactly is meant by the following statements and terms?

". . . sustaining the capacity of rangeland to satisfy values and produce commodities." (Chapt. 1, p. 3)

". . .ecosystem position, resource risk, biological values. . ." (Chapt. 2, p. 3)

"A. Watersheds are properly functioning; B. Ecological processes are in order; ... D Habitats of protected species are in order." (Chapt. 2, p. 5 and p 12)

"Precipitation is able to enter the soil surface at appropriate rates. . ." (Chapt. 2, p. 6)

"Native or other desirable plant [sic] and animals are diverse, vigorous.. `"

"Levels of non-native plants and animals are at acceptable levels"

"Special status species are healthy..." (Chapt. 2, p. 7)

"Where appropriate, species composition contributes to the desired plant community objectives."

"...significant progress toward functioning properly and achieving an advanced ecological Status." (Chapt. 2, p. 8)

"Aquatic organisms and plants (e.g. macroinvertebrates, fish, algae and plants) indicate support for beneficial uses" (Chapt. 2, p. 9)

"All waters are suitable for original use or desired beneficial use." (Chapt. 2, p. 20)

"Any riparian or wetland areas in functioning-at risk or nonfunctional condition must be in an upward trend. " (Chapt. 2, p. 25)

What is meant by words and phrases such as: "appropriate," "vigorous," "healthy," "sufficient," "desired," "functioning properly," "nonfunctional condition," "advanced ecological status," "beneficial uses" original use" "upward trend"? How does the "knowledgeable BLM staff" (Chapt. 2, p. 5) identify and evaluate the conditions described by these words and phrases?

2. Given the importance of this document, I was disturbed to read (Chapt. 5, p. 2) that "formal consultations" were not held with several presumably interested state and federal government agencies. At a minimum formal consultations should have been pursued with the US Fish and Wildlife Service and the California Department of Fish and Game. Actually, I find it quite remarkable that absolutely no formal consultations regarding this DEIS were sought out and that only a few "informal consultations" were done. Why weren't comments solicited in a proactive way from organizations such as the Sierra Club and the Audubon Society? Why weren't scientists consulted regarding policies that rely on scientific information? I am a Ph.D. scientist, a California State University professor and have been actively engaged in ecological research at the Carrizo Plain Natural Area (one of the BLM's largest non-desert holdings in California). Yet, until about one week ago I was completely unaware of this DEIS and had not been invited to "scope it" by any BLM personnel. I only received a copy of the DEIS in late August 1997 when Emily Roberson (California Native Plant Society) requested that I be invited to make comments. Why - didn't the BLM pursue comments from me and other scientists known to have expertise in this region (at U.C. Berkeley, U. C. Davis, Cal Poly San Luis Obispo and elsewhere)? Although the DEIS states that the BLM sent out news releases and letters to potentially interested parties, it is obvious that the scoping" efforts were far from adequate. It certainly appears as if the BLM is trying to "pull a fast one." The very large number of scoping omissions seem quite telling.

3. What is the logic behind allowing grazing in or near riparian ecosystems? The detrimental effects of cattle on riparian areas is well known (erosion, water pollution, etc). Moreover, most knowledgeable people agree that California's riparian systems are endangered (see Warner, R. E. and K. N. Hendrix (eds). 1984. California Riparian Systems: Ecology, Conservation and Productive Management. University of California Press). Why isn't the book edited by Warner and Hendrix cited in this DEIS? This is a glaring omission!

4. Chapter 3 includes a brief discussion of the climate in the region and a few average annual rainfall amounts are listed (for Los Angeles, San Francisco and Crescent City -- 3 locales where grazing is a non-issue). It should be prominently noted that average annual rainfall is a very poor description of the rainfall in the region under discussion. This is because of the very large amount of year-to-year variability in precipitation. In Bakersfield, for example, rainfall since 1954-55 has averaged 15.01 Cm per year (July - June). But, in 1971-72 rainfall totaled only 7.62 am. The following year, nearly three times that amount (20.32 am) was received at the same location. In fact, since 1954-55 there has not been a single year in which 15 am of rain has fallen in Bakersfield! Moreover, rainfall varies considerably within a given rainy season. Rain might fall steadily for 3 or 4 months, as it did in Bakersfield in 1991-92, or it might be largely restricted to a single month (e.g. 11 Cm of rain fell in Bakersfield in March 1991). Still another point that should be emphasized is the large difference in the amounts of precipitation received by areas categorized as California prairie (or valley grassland or annual grassland) . For example:

LOCATION	JAN. AVG (S.E.)	FEB. AVG (S.E.)	ANNUAL AVG (S.E.)
Bakersfield	2.43 cm (0.28)	2.75 cm (0.41)	15.01 cm (0.86)
Delano	3.19 cm (0.43)	3.38 cm (0.50)	18.65 cm (1.17)
Coalinga	4.34 cm (0.64)	4.18 cm (0.60)	20.87 cm (1.40)
Fresno	5.31 cm (0.69)	4.87 cm (0.65)	27.89 cm (1.78)
Merced	5.89 cm (0.69)	5.37 cm (0.60)	31.04 Cm (1.82)
Sacramento	9.78 cm (1.06)	7.51 cm (0.96)	44.61 cm (2.78)
Willows	10.09 cm (1.18)	7.91 cm (0.91)	46.14 cm (2.78)

(these data were extracted from NOAA publications)

The unpredictability in rainfall and the large geographical differences in the amounts received strongly suggest that management of lands in this region is difficult and requires caution and a long-term perspective. Management decisions based on 1 or 2 years worth of information may turn out to be hasty and problematic. In addition, the rainfall data suggest that, in decision making, the extrapolation of a few small studies to the entire region is probably a bad idea. Simply put, it is unlikely that the native organisms and natural ecological processes that occur in the southern San Joaquin Valley (e.g. Bakersfield or Coalinga) have much resemblance to those of the Sacramento Valley. Grazing in the San Joaquin Valley is likely to have radically different ecological impacts than grazing in the Sacramento Valley.

5. This DEIS should state clearly that the ecosystems in California grazed today by cattle and sheep had never been grazed historically by large native herbivores (see Painter, E. L. 1995. Threats to the California flora: ungulate grazers and browsers. Madrono 42:180-188. -- again, why wasn't this important citation mentioned in the DEIS?). Cattle and sheep are not surrogates for native grazers like pronghorn antelope and tule elk. Their ecologies are enormously different. In fact, it should be noted that rabbits, gophers, kangaroo rats and other small herbivores are capable of removing a great deal of biomass in California's grasslands.

6. The discussion of "annual grasslands" in Chapter 3 has a relatively lengthy discussion of the importance of native perennial bunchgrasses such as Nassella pulchra. The basis for the idea that perennials grasses once dominated is extremely tenuous, however. Had scientists such as myself or Dr. Elizabeth Painter (U.C. Berkeley's Jepson Herbarium) or Dr. Jon Keeley (Occidental College/National Science Foundation) been consulted about this topic, a radically different (and more comprehensive) view of the historical species composition of this vegetation type would have been readily apparent. For example, this ecosystem is habitat to several hundred different native annual forb species. How might the grazing management plan discussed in this DEIS affect this incredible forb diversity. Does grazing affect these native annual forbs in the same way that it affects alien annual grasses? Or native perennial bunchgrasses? Hmmmm..

7. This DEIS ignores a fairly extensive body of research literature on California vegetation, grazing, wildlife, etc... Are the BLM's scientists and managers familiar with the information that's available? If so, it is not apparent from this DEIS.

8. Had the writing of this DEIS been more precise and detailed and less vague, the issues and questions that I have mentioned here would have been readily apparent. Moreover, it would have been obvious that the BLM-managed lands in California and northwestern Nevada cover too much terrain and support too much valuable biodiversity to be adequately discussed in a single short ElS. It is my professional opinion that acceptance of this deficient DEIS could likely lead to disastrous management decisions with potentially irreversible consequences (extinctions I.)

The above comments were made by:

Paula N. Schiffman, Ph.D.
Associate Professor of Biology
California State University, Northridge
Northridge, CA 91330-8303

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