Bob Wilson

August 20, 1997

The main positive key in this document is the statement on page 8, "There will be no arbitrary removal of livestock. If removing livestock will not fix the problem, then livestock will not be removed."

Over grazing by wildlife is a management problem not addressed. Where damage is due to recreation or wildlife, these activities or species (wild horses or elk) should be removed, not livestock. Livestock contribute to the stability of local economy, where as wildlife and recreation often contribute to the cost of crime enforcement. This is not addressed.

Alternative 4 should not even be considered. This plan could be used by anti-grazing biased personnel. Even temporary removal of livestock may put a tremendous burden on the permittee who may have other place to go with his animals and be forced to sell. Other unused permits must by offered to ease the burden. Any loss of ranches means loss to the local economy and loss of winter maintenance of wildlife.

The main problem in the future of BLM will be the availability of unbiased, knowledgeable and experienced personnel! Common sense and cow sense have got to be emphasized. Permittees must have the right to appeal any decision before livestock removal.

We have in the past had experience with Forest personnel who changed the utilization of a meadow from 60% utilized to 40% utilized after being show a nearby enclosure by the permittee. Its a good thing he was there.

Another Forest personnel claimed overgrazing in an area where snow had slowed growth. She had to be shown by the permittee that grass that has been grazed is chopped off at the tip, not pointed.

Long term past management practices should be documented so that new BLM personnel can know what has been tried before and whether a permit's trend is upward or downward.

I highly recommend the article "It may be Utilization, but is it Management?" by Earl McKinney in the July Rangelands and in the August Cascade Cattlemen

Alternative 1 is the least objectional. There is still no way a inexperienced manager could use this Standards and Guidelines without practical knowledge and local advice.

Since weather is the main variable, changes should be long term and not as drastic as in Alternative 4.

Sincerely,

Bob Wilson
Carmel Valley, CA