Willy Hagge
Alturas CA
I appreciate the opportunity to comment on the proposed Standards and
Guidelines for California and Northwestern Nevada. I have several concerns
I hope will be addressed in the final document.
I support Alternative # 1, but only after some minor changes are implemented,
1. Guidelines # 14 & 15 the Transitional Guidelines need to be eliminated
from the alternative. These guidelines basically eliminate the benefits
of the thirteen guidelines that proceed these two and obviously would take
away from the benefits derived from this alternative simply by the time
and effort that would be needed to implement them, If there are problems
with a grazing system these guidelines do not provide for the solution they
are simply a stop gap measure. I want to see a site specific allotment analysis
done before terms and conditions arc decided upon. Please remove Guidelines
14 and 15 from Alternative # 1.
2. Chapter 2, page 20, Standard 2: Streams. Criteria to Meet Standard:
The third item reads, The stream water surface has a high degree of shading,
resulting in cooler water in summer and reduced icing in winter, I would
like to see the scientific data that validates the reference to reduced
icing in Winter.
3. Chapter 2, page 19, third paragraph, second and third sentences. I
believe this shouldn't apply to areas where significant juniper encroachment
has occurred. The habitat could be improved remarkably with proper fire
management or different types of control.
4. Chapter 2, page 19, Middle of fourth paragraph. The sentence reads,
The Guidelines were designed to provide direction, yet offer flexibility
for implementation through activity plans and Terms and Conditions for grazing
permits. I feel that having the tool of flexibility is an important statement
and needs to be in the final decision,
5. Chapter 2, page 20, Standard 3: Water Quality. The first sentence
needs to have added at the end, and is compatible with private water rights."
6. Chapter 2, page 22, Guideline 2: I feel that the desired seral State
does not need to be determined in the Allotment Management Plan because
the decision is always so subjective by the individual making the decision.
7. Chapter 2, page 21, Standard 4: Riparian and Wetland Sites. I support
the language and idea presented under Exceptions and Exemptions to Standard
4 (where Standard 4 is not applicable ). I would like to See this language
remain in the Final Decision.
8. Chapter 2, page 19, Preamble. The first sentence of the preamble makes
an important point of how our Healthy Rangelands are linked to the social
and economic well being of rural communities in Northeastern California
and Northwestern Nevada. I feel it is important to have this statement be
in the final decision document.
9. Chapter 2, page 23, Guideline 11. 1 feel that fire needs to be utilized
as a management tool and we strongly support guideline 11.
I strongly oppose Alternative #4. This Alternative is simply a penalizing
and punitive proposal directed toward the livestock grazing permittee which
when implemented would economically impact the Public Lands Livestock grazing
rancher significantly. The only management tool available is to impact
the individual permittee, it does not allow for the improvements to go in
and maintain the current AUMs with an improved grazing system. Also we believe
Alternative 4 violates the Taylor Grazing Act and the Public Rangelands
Improvement Act
I like Alternative #1 over Alternative #2 and #4 because #1 has been
localized by the RAC board and is sensitive to the local needs,
Chapter 4, page 21, Ranching Communities. I feel that you have sidestepped
the impact issue you are trying to address in this section. If there is
an impact to the industry then it needs to be stated as such. We don't
want to see any type of broad statement which says, "To most ranchers,
there will be no impacts to their traditional ranching lifeway through implementation
of the grazing standards." The statement Most Ranchers could mean 51%
of the ranchers in the USA. The impacts need to be specific to the BLM Public
Lands Grazing Ranchers in California and Northwestern Nevada. The word lifeway
can not be found in the dictionary and probably should be changed to read
way of life. I suggest that the first sentence of this paragraph be deleted.
Sincerely,
Willy Hagge
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