Carl Twisselman

Carl F. Twisselman II
McKittrick, CA

August 4, 1997

Comments on DEIS for S & G for grazing:

I recommend the choice of alternative 1- individuals in each area know their area best; each RAC spent a lot of time coming up with their documents. In the case of the Bakersfield RAC, the preamble is a very important part of the document and I would like it included in the final S & G regardless of which alternative is chosen, or if some consolidation is used.

Alternative 4 is not feasible and requires conditions that cannot be met. There is no evidence that their proposed changes would lead to better range land health, and the costs would be so high that grazing would be eliminated in many allotments.

Chapter 2, page 5-last sentence- There are many BLM parcels that have no public access so the public cannot be a participant in monitoring; maybe this line should be deleted or the meaning of active participant' should be defined further.

Chap 2, page 1- forage utilization requirements- I have received complaints about the 4-6 inch stubble height in riparian areas. Some permittees say that the grass in their area does not normally grow to that height, or that they need to graze before that height is reached to prevent weeds from taking over.

Chap 3, page II- "Key area concept" I have trouble with this idea- maybe from lack of understanding. It has been my belief that when measuring R D M, samples are taken throughout a pasture and an average use is determined. I would not like to see management of a large area hinge On a small key area that is subjectively chosen.

Chap. 3, page 7- 1 have read studies that indicate that hoof action and manure can be beneficial to soil and vegetation growth, but, throughout this draft, the negative aspects of grazing are emphasized and, in most cases, the positive aspects are left out.

Chap 3, page 20- 1 doubt that perennial grasses ever dominated the west side of the San Joaquin Valley; what perennial grass grows with only 4 inches of rain all of which comes in 4 months?

Chap. 3, page 25- Grazing doesn't harm the new saltbush seedlings in my area. I watched cattle and goats grazing among new seedlings, they didn't eat them at all, but grazed the mature saltbush in the same area. If you don't graze saltbush areas, wildfires will be so hot that they will kill the saltbush.

Chap 3, page 65- Where did you get a figure of $5.76 per AUM for rangeland costs in 1993, did you include Ed Hastey's salary? The cash cost of 3% for - ranchers must include their entire operation, not just the BLM part. Only the costs directly attributable to livestock grazing should be included in these figures, not the cost of politically driven items such as this EIS.

Chap 3, page 77 - Did you get lots of offers to sell unimproved grazing land at $2,215.00 per acre? You must be selling to the Nature Conservancy.

Chap 4, page 23- 1 doubt that you can build fence on BLM land for $3,000.00 per mile.

Overall, I thought that your job was very well done and appreciate the effort. The economic analyses was inaccurate, at least for the Bakersfield District, but that probably doesn't have much to do with setting the S&G anyway. Glossary was good, and very useful.