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Cal/EPA September 5, 1997 Thank you for the opportunity to review the subject DEIS dated May 1997. Despite the fact that there were no water quality representatives on the Regional Advisory Committees (RACs) that helped prepare the recommendations. I commend your efforts to address issues related to water quality. The Federal Clean Water Act establishes the context for most of the following comments. As you may know, the main objective of the Act is to "maintain and restore the chemical, physical and biological integrity of the Nation's waters" to the point that they are fishable, swimmable, and drinkable. Our comments are as follows: 1. It is important that rangeland standards affecting water quality be uniform throughout the State. It is recommended that rangeland guidelines affecting water quality also be consistent throughout the State. It is suggested that targets for mulch management, stubble height, and utilization of desirable plants for upslope and riparian areas be established on a more regional basis. 2. It is highly desirable that the rangeland standards and guidelines be consistent with the Management Agency Agreement (MAA) that we are developing together, with the California Rangeland Water Quality Management Plan certified by the State Water Resources Control Board (SWRCB), and with the Coastal Zone Act Reauthorization Amendments (CZARA) guidelines issued by the U.S. Environmental Protection Agency. 3. The riparian standards proposed by the Bakersfield and Ukiah RACs are the most comprehensive and appropriate. The proposed Statewide and Rapid Recovery riparian standards, although similar, are less clear and focused. 4. The water quality standards proposed by the Bakersfield and Ukiah RACs are the most comprehensive and appropriate. The proposed Statewide and Rapid Recovery water quality standards lack real substance and appear to be inappropriately focused on processes that Bureau of Land Management (BLM) cannot control rather than on things that BLM can actually accomplish. 5. Based on your DEIS, SWRCB staff prepared a tabular listing of information for consideration of statewide standards for Riparian/Wetland and Water Quality (Enclosure 1) to ensure water body integrity. Information relating to Water Quality standards addresses primarily the legal and water column components of integrity; the information relating to Riparian/Wetland standard addresses the remaining aspects. 6. Based on the documents referenced in Item 2 above, SWRCB staff has prepared some considerations for statewide guidelines (Enclosure 2) to ensure water body integrity. 7. For certain situations (particularly those listed in (a) through (c) below) , the standards and guidelines should clearly state that the primary land management objective is resource protection rather than livestock grazing if grazing is contributing to the problem. In addition, the Rapid Recovery alternative presented in your DEIS (with consideration of factors presented in the proposed guidelines in Enclosure 2) should be implemented. This limited application of the Rapid Recovery alternative may allow BLM to better focus its efforts on these high priority situations.
8. Generally, the SWRCB and California Regional Water Quality Control Boards must regulate any activity that discharges or threatens to discharge pollutants into the waters of the State. Water gaps and stream crossings frequently represent a real potential for water quality problems, unless BLM effectively implements best management practices that would significantly reduce that threat. In conclusion, I respectfully recommend that you do the following: (1) adopt statewide rangeland standards and guidelines related to water quality and (2) use the SWRCB standards and guidelines information to assist in that purpose. Sincerely, Jesse M. Diaz, Chief
ATTACHMENT 1 Statewide Standards Information for Riparian Areas and Wetlands Statement of Standard Riparian/wetland vegetation, its Structure and diversity, and water body banks, channels, and floodplains are, or are making significant progress toward, functioning properly and achieving appropriate ecological condition. Management Objective For riparian and wetland areas, the primary management objective is to maintain and promote the following: (a) proper functioning condition (including energy dissipation, sediment capture, groundwater recharge, and channel and bank stability), and (b) the hydrologic and nutrient cycles, and energy flow. This objective is of even higher priority in the following situations: (a) where beneficial uses of water bodies have been listed as threatened or impaired pursuant to Section 303(d) of the Federal Clean Water Act, (b) where habitat is present or has been present for Federal threatened or endangered, Proposed, Category 1 and 2 candidate, and other special status species, and (c) in designated sensitive areas. Meaning that, (consistent with characteristics of the soil type, climate and landform) the vegetation, soils and water body interact to: Provide appropriate vegetative structure, composition and diversity, thereby promoting biodiversity and favorable habitat for aquatic and riparian-dependent species. Provide an appropriate vegetative canopy, thereby providing for water temperature control, shading, food supply, and recruitment of large woody debris. Control instream erosion, retard flood waters, dissipate flood energy, and stabilize stream channel and banks, thereby reducing flood hazard, sustaining high water quality, and maintaining the water table. Capture and filter sediment and pollutants from both upslope and instream sources, thereby providing for floodplain development and sustaining water quality Maintain or recover flow, sediment transport, and channel characteristics that sustain high quality aquatic habitat, other beneficial uses of water, and groundwater infiltration and recharge. As indicated by (consistent with characteristics of the soil type, climate and landform): Riparian/wetland vegetation is vigorous and mostly perennial. Woody riparian/wetland vegetation is diverse in terms of age-class, developmental stages, species composition, rooting depth, and structure. Plant species present indicate that soil moisture characteristics are being maintained. Shallow.rooted, invader plant species: (1) comprise little of the cover and (2) are not displacing native species. Recruitment of preferred riparian/wetland species is adequate for sustaining the community. The vegetative canopy provides appropriate shading to the water and riparian zone. The vegetative canopy provides appropriate thermal regulation for fish and other riparian dependent species, resulting in cooler water during summer and reduced icing in the winter. The vegetative canopy provides an appropriate supply of energy, nutrients (through leaf drop and litter) for aquatic and riparian-dependent species. Riparian/wetland vegetation provides appropriate habitat for migration, reproduction, resting, and escape for aquatic and riparian-dependent plant and animal species. Riparian/wetland vegetation provides an appropriate supply of food organisms for aquatic and riparian.dependent species and supports a diversity and abundance of insects and amphibians. Ground cover (downed logs, litter, leaves, grasses, forbs, and shrubs) in the riparian zone, wetland, or floodplain is adequate to capture and filter Out most sediment and other pollutants from overland flows and rills before they enter the water body. Around seeps and springs, the vegetative cover is adequate to control erosion and reflects the potential natural vegetation. Riparian/wetland vegetation provides adequate source for continued recruitment of large woody debris. Large woody debris in the water body: (1) provides physical structure for good aquatic habitat and (2) is largely stable and well embedded into the banks. Shoreline, Stream bank:, and floodplain vegetation is sufficiently dense and stable to dissipate energy and minimize surface erosion during high energy (flood/wind) events. Root masses are sufficient to stabilize stream banks and shorelines. Adequate organic matter (liner and standing dead plant material) is present to protect the site and to replenish soil nutrients through decomposition. Point bars and other coarse textured stream deposits are vegetated or are being successfully colonized Portions of the primary floodplain are frequently flooded (every 1.5 years) and function to slow flood flows (through vegetative roughness), capture sediments, and reduce flood peaks. Stream channel is sufficiently flushed by high flows to provide a clean, well-aerated substrate or aquatic species. The number and diversity of species and the number and age class of the populations supported by the water body are at the desired level or are showing an improving trend. Stream channel has sufficient structural diversity (i.e., cascades, riffles, deep pools, undercut banks) to provide good aquatic habitat during critical life stages of aquatic species. Water flow and fish passage is not significantly obstructed by manmade features or debris accumulations. Stream morphology (i.e., width/depth ratio, roughness, sinuosity, pool frequency): (1) reflects natural functioning or recovery thereof and (2) provides physical structure for good aquatic habitat. Stream bank and shoreline stability reflects natural functioning or recovery thereof. Substrate sediments and sediment transport reflect natural functioning or recovery thereof. Negligible accelerated erosion as a result of human related activities is evident. Exceptions to standard Stockponds and water gaps which : (1) are not natural wetland and/or riparian areas and (2) produce little or no discharge to water bodies or wetlands. Information on Standard for Water Quality Statement of Standard Surface and groundwater quality complies with objective of the Clean Water Act and other applicable water quality requirements. Management Objective For water bodies, the primary management objective is to maintain the existing quality and beneficial uses of water, protect them where they are threatened (and range management is a contributing factor), and restore them where they are currently degraded (and range management is a contributing factor). This objective is of even higher priority in the following situations: (a) where beneficial uses of water bodies have been listed as threatened or impaired pursuant to Section 303(d) of the Federal Clean Water Act, (b) where aquatic habitat is present or has been present for Federal threatened or endangered, Proposed, Category 1 and 2 candidate, and other special status species, and (c) in designated sensitive areas. Meaning that BLM will: Pursuant to the Clean Water Act, maintain the physical, biological, and chemical integrity of waters flowing across or underlying the lands that it administers. Protect the integrity of these waters where it is currently threatened. Insofar as feasible, restore the integrity of these waters where it is currently impaired. Not contribute to pollution and immediately remedy any pollution resulting from its actions that violates applicable California, Nevada or Tribal water quality standards or other applicable water quality requirements (e.g., requirements adopted by SWRCB or USEPA pursuant to section 303(d) of the Clean Water Act or the Coastal Zone Reauthorization Act). Work with the states to establish appropriate beneficial uses for public waters, with the States and/or USEPA to establish appropriate numeric targets for 303(d)-listed water bodies, implement the applicable requirements to ensure that water quality on public lands meets the criteria for the designated beneficial uses of that water. Reasonably implement Best Management Practices (BMPs) approved by the SWRCB to protect and restore the quality and beneficial uses of water, and monitor both implementation and effectiveness of the BMPs. As indicated by: The following do not exceed the applicable requirements: chemical constituents, water temperature, nutrient loads, fecal coliform, turbidity, suspended sediment, dissolved oxygen Achievement of the standards for riparian areas, wetlands, and water bodies. Aquatic organisms and plants (e.g., macroinvertebrates, fish, algae and plants) indicate support for beneficial uses. Acceptable results from implementation and effectiveness monitoring or changes in management to address deficiencies identified by such monitoring. Exceptions Off-stream water troughs and stockponds that produce little or no discharge to surface or ground waters.
Attachment 2 Information on Statewide Guidelines General Guidelines Ecology Maintain or promote the appropriate kinds and amounts of soil organisms. plants and animals to support the hydrologic and nutrient cycles and energy flow Biodiversity Maintain and promote biological diversity across the landscape by providing a mosaic of seral stages and vegetation corridors with minimal habitat fragmentation. Fish and Wildlife Maintain and promote the physical and biological habitat conditions necessary to sustain native populations and communities of fish and wildlife. In areas that provide habitat for Federal threatened or endangered. Proposed, Category I and 2 candidate, and other special status species, the primary land management objective is to maintain. enhance and restore these species and the habitats on which they depend. Beneficial Uses of Water In watersheds draining into water bodies that have been listed or are proposed for listing as having threatened or impaired beneficial uses. and where rangeland management activities may contribute to the pollutants causing such impairment, the primary management objective is to fully protect. enhance. And restore the beneficial uses of water. Soils Maintain and promote infiltration. permeability, soil moisture. and soil stability appropriate to climate, soils, and ecological site conditions. Cultural Heritage Protect and maintain identified sensitive cultural areas. Other Rangeland management shall be coordinated with other uses of public lands (e.g., recreation, archaeological sites, Wildlife, horses and burros, mineral resource extraction, etc.) so that overall use does not detract from the goal of achieving rangeland health. Maintain and promote populations of desirable tree, shrub, herbaceous and grass species by taking advantage of transitional opportunities (e.g.: drought, flood,fire). Desired Plant Community (DPC) and Potential Natural Vegetation Community Maintain or promote achievement of the potential natural vegetation community or DPC (where that has been determined). Promote growth and reproduction. seed dissemination and seedling establishment for desired species when climatic conditions (generally in one out of every three years for grasses) and space allow. Enhance or establish populations of desirable tree. Shrub. herbaceous and grass species by taking advantage of transitional opportunities (e.g.: Drought, flood, fire). Maintain and promote the presence of desired seedlings, saplings, and/or mature plants in the plant community Utilization levels by establishing and implementing appropriate utilization levels. Native and Perennial Plant Species Maintain or promote the physical and biological conditions necessary to sustain viable populations and communities of native and perennial plants (including special status plants) by allowing them to complete their entire life cycles and sustaining the spatial distributiOn of microsites necessary for seed germination at appropriate intervals. Take aggressive action to reduce the invasion of undesirable exotic plant species into native plant communities. In addition to grazing management, the spread of noxious weeds will be controlled through other appropriate methods. such as fire management, use of weed-free hay, livestock purging periods,and appropriate levels of plant matter. Limit perennial plant utilization to appropriate levels of the current years growth, unless it has been proven that this level of use is incompatible with the continued existence of the plant. Annual Rangeland Guidelines Maintain and promote the presence and distribution of microsites~ for seed germination. Maintain and promote sufficient amounts of residual dry matter (RDM). or standing plant material throughout the grazing season to conform with Guidelines - - -by establishing target forage use levels and implementing mulch management Mulch levels shall include a "buffer" to account for RDM loss from other natural processes (decomposition, animal use, etc.). Exceptions to mulch management targets may be approved during the green season when substantial regrowth is expected or if lower ROM levels are required to meet particular rangeland health objectives, such as reducing competition for a desired species. Perennial Rangeland Guidelines Developed and adopt appropriate regional guidelines specific to the perennial species on perennial rangelands. Water Body and RiparianIWetland Area Guidelines In riparian areas, the primary management objective is to maintain and promote riparian dependent special status species (where they occur) proper functioning condition (including energy dissipation, sediment capture, groundwater recharge. and streambank stability), the hydrologic and nutrient cycles, and energy flow. Maintain and promote stream channel morphology (e.g. gradient. width I depth ratio, channel roughness and sinuosity) and functions appropriate to the climate and landform. Potential Natural Communities snail be achieved in the riparian zone. Maintain and promote sufficient residual vegetation (residual stubble and regrowth) and perennial woody vegetation to protect. improve. or restore riparian-wetland functions of energy dissipation. sediment capture, groundwater recharge and stream bank stability and protection, plant vigor, plant and wildlife habitat, stream shading and temperature control, and sediment entrapment. Establish thresholds for mulch management (RDM and stubble height) and for utilization of herbaceous and woody plants for riparian/wetland and stream-side areas. General Rangeland Management Practice and Guidelines Livestock grazing shall be managed to achieve the forging standards and guidelines. The factors to be considered in grazing management systems include, but are not limited to the following: 1) the kind and class of livestock to be grazed; 2) intensity (stocking level). frequency, season, and duration of grazing; 3) distribution of grazing pressure away from sensitive areas (e.g.. fencing. herding); 4) pasture rotation and rest; 5) rotating concentrated use areas (e.g.. bedding grounds and gathering areas); 6) any mulch management (RDM and stubble height) thresholds; and 7) any utilization levels for desirable plants. More restrictive management practices and mulch and utilization thresholds shall be established in special situations, including, but not limited to the following; 1) at the end of the growing season and/or at the end of the grazing season (if after fall dormancy); 2) presence of critical fisheries and/or special status species; 3) Unstable stream bank or channel conditions or unhealthy riparian areas (those not fully meeting standards. or those functioning at risk"); 4) water bodieS that have been listed as having threatened or impaired beneficial uses; 5) I (Improvement) and M (Maintenance) category allotments. Continuous. season-long livestock shall occur only when it has been demonstrated to be consistent with achieving healthy, properly functioning ecosystems. Grazing on designated ephemeral (annual and perennial) rangeland shall occur only if reliable estimates of production have been made, an identified level of annual growth or residue to remain on site at the end of the grazing season has been established and adverse effects on perennial species are avoided. Livestock grazing in new allotments On native perennial grasslands Shall occur only where guidelines specific to the perennial species are developed and adopted. Prescribed fire and (natural) prescribed fire may be utilized where needed to promote a mosaic of healthy plant communities and vegetative diversity. Initiate erosion control practices in areas where soil is compacted or prone to accelerated erosion after livestock grazing or other disturbance (e.g., construction and use of roads and Other facilities). Locally-collected native species should be used for all revegetation and enhancement projects. If they are not readily available. other native species may be used. Non-native plant species shall be used only where native species are not available in sufficient quantities or are incapable of maintaining or achieving properly functioning conditions and biological health.
Management Practice Guidelines for Water Bodies and Riparian/WetIand At least the minimum RDM, stubble height, and utilization thresholds shall be maintained on all riparian/wetland and stream-side areas during and at the end of the grazing season, and/or livestock shall be removed to allow time for plant regrowth sufficient to achieve the thresholds. Where needed to minimize impacts on water bodies, water sources. wetlands and riparian areas livestock access these areas shall be restricted (i.e., fencing herding). Any necessary access points (e.g.. Water gaps. stream crossings) shall be located and designed to stabilize conditions and minimize discharges of sediment and animal waste (e.g, hardening of surfaces). The development of water sources (including springs and seeps)or other projects affecting water and associated resources shall promote and maintain rangeland health, ecologic and hydrologic function and processes of watercourses and riparianiwetland areas, and where practicable. year long use by wildlife. Locate salt blocks, other supplemental feed and alternate shade sources well away from water bodies and riparian/wetland areas. New livestock handling facilities (i.e.. watering facilities. trails, and roads) shall be located outside of riparian/wetland areas and designed to minimize concentrations of livestock where discharges of sediment and animal wastes to water bodies could occur. If existing livestock handling facilities that are located inside a riparian/wetland area threaten attainment of standards. the threat shall be eliminated. either by modifications to the design and use of the facility or by relocating it as a new facility. Limit livestock trailing, bedding, watering. loading, and other handling efforts to those areas and times that will not retard or prevent attainment of standards. Avoid trailing in vernal pools and wetlands whenever possible. Rangeland Monitoring and Adaptive Management Guidelines Rangeland monitoring to determine utilization of forage resources and trend of rangeland health shall be conducted as needed in each allotment based on current accepted practices and techniques. Monitoring methodologies will be applicable to local conditions and developed in consultation with permittees and interested publics. Rangeland monitoring to determine the implementation and effectiveness of the standards, guidelines, and the practices specified under them shall be conducted in all special situations (as identified pursuant to guideline#--). If monitoring or verified observation indicates that one or more of the standards or guidelines is not being met or that substantial progress is not being made toward meeting a standard or guideline, and if there is evidence that current rangeland management practices are causing or contributing to this unsatisfactory condition, appropriate adjustments (more or less restrictive) shall be made to the thresholds for RDM, stubble height, and/or plant utilization and to allowable rangeland management practices. |
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