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This guidance document presents an analysis and recommended approach for grazing management in the Grand Staircase Escalante National Monument (GSENM) that will allow rangelands, where healthy, to continue being productive, and, where degraded, to recover.   Consistent with BLM’s rangeland health standards and other regulations, the guidance recommended here provides methods that will help make range management decisions transparent, gather key ecological data efficiently, and use analysis techniques based on the best scientific knowledge we have today.   While the focus here is on grazing decisions, the approach described will go a long way in helping resolve a number of related issues that range from helping species at risk to the continued viability of ranching.



1.1   The Monument in the context of southern Utah rangelands, and natural heritage


From an ecological perspective, properly functioning ecosystems are productive and resilient to major events such as drought.  Having evolved over millennia, these natural communities have adapted to a variety of episodic events.  As a result, they can still thrive in an efficient and productive manner, even after severe drought.  Maintaining and restoring rangelands to their potential ecological condition is a benefit not only to forage grasses and soil communities, but also the myriad of native fish and wildlife species that have evolved with these arid rangeland communities.


Maintaining the health and productivity of (and where needed, restoring) rangelands draws on common values we all share.  The health of the land is a fundamental “endowment” to which all human endeavors are linked.   Even in a time when we are becoming more dependent on a global economy, the foundation for communities still relies on working ecosystems.   Healthy ecosystems directly provide products such as grazing forage and water.  Thus, the core values of local and rural communities by and large relate to the land and its natural processes.  Damaged ecosystems impact agriculture, hunting, fishing, our watersheds, our heritage and eventually put at risk the continued existence of rural communities.


As the population of Utah grows, our communities become ever more dependent on the health of our public lands.  Unfortunately, land use has increased even faster than our population has.   As a result, community water sources, wildlife resources, and recreation are increasingly being compromised.  Changes in grazing management, for example in GSENM, are needed if we are to reverse this trend.




1.2  What the BLM must do in this DEIS process


When the Monument was founded in 1996, the President made clear that one of the fundamental purposes for establishing the National Monument was established was to protect its outstanding biological diversity.  The Monument Management Plan reinforces the objective to manage in order to preserve biological resources (plan, at pg 2.2).  The evidence of deleterious impacts of cattle grazing to the Monument’s biological and ecological resources (many of which are presented in subsequent chapters) is great. 


The BLM has an extremely important job in front of it.  The Grand Staircase Escalante National Monument was the first national monument entrusted to the BLM.  The purpose of the upcoming Environmental Impact Statement goes beyond the requirement to renew grazing permits.  In one sense a model for grazing decisions elsewhere, BLM will be retooling grazing within the Monument to meet ecological goals and legal requirements. The BLM did a fine job on the GSENM Final Management Plan that provides clear direction on meeting the objectives of a Monument.  The BLM needs to approach this DEIS in a similar fashion.  The Monument’s Management Plan was developed by embracing all relevant science, working closely with the interested public, and being willing to take Monument management and practices in a new direction.  This programmatic DEIS on the Monument’s grazing program must do the same.


In the chapters that follow we carefully outline our recommendations on the best approach for BLM in developing this DEIS, and make pointed recommendations based on agency policy, national standards and guidelines, and the best available science.  For example, and of utmost importance, FLPMA requires the BLM to make a reasoned and informed decision as to whether or not grazing is an appropriate use of each part of the Monument.  Given the extraordinarily high ecological, scenic, and cultural values in the Monument, and the generally poor livestock forage available in the Monument, closure of portions of the Monument to grazing should be a high priority in the upcoming DEIS.  For those allotments that the BLM does determine are indeed capable and suitable for supporting grazing, we present new methods for making determinations and setting stocking rates. 


BLM would be justified in using this comprehensive guidance document as the basis for the preferred alternative in the DEIS.  In addition to meeting the agency’s policies and regulations for grazing and wildlife habitat management, this guidance document is consistent with the management stipulations found in the GSENM management plan.  Indeed, we argue that using this document as the cornerstone of the DEIS will ensure that the grazing plan for GSENM will be consistent with the Standards and Guidelines for Healthy Rangelands, and all relevant laws and regulations. 





1.3  How this document is organized


            Chapter 2 lays out the laws and regulations that BLM must conform with as it conducts NEPA analyses and writes the DEIS, as well as referring to the stipulations of the Land Use Plan and Monument Management Plan that apply to this process, and the Monument’s grazing program. 


Chapter 3 describes the current conditions in the Monument.  Specifically, we highlight the loss and degradation of springs and riparian areas, the spread of exotic species, and the profound changes seen in the vegetative communities – notably loss of structure, diversity and productivity.  The evidence of these profound changes and their negative repercussions can be found in Monument studies, and studies performed by the authors and other independent scientists in the Monument.  We conclude Chapter 3 with a discussion of how the Monument’s grazing program is a significant contributor behind these current conditions in GSENM.


Chapter 4 outlines the analyses the BLM must undertake, and the remedies and prescriptions the Monument must put in place in this DEIS process.  This includes a FLPMA-based Suitability analyses, Forage Capacity analysis, and the determination process.  We offer new, proposed methods for undertaking all of these analyses.[1]  The Monument also needs to devise specific prescriptions that will automatically be engaged in drought years, in allotments that are failing to meet Standards, in allotments that are meeting standards, and so forth.  We give recommendations for these prescriptions, in addition to discussing prescriptions that are inappropriate.


We close (Chapter 5) by arguing that adopting this guidance document as the cornerstone of the DEIS is the only was that the BLM will truly abide by the Standards and Guidelines, and relevant laws and regulations, in this DEIS.  We call on the Monument to take this opportunity to use science in this Monument as a means to test and develop grazing management that leads to healthy and productive rangelands.  We sincerely hope this scientifically driven, and somewhat more “enlightened” NEPA-analysis will serve as a model for other BLM Resource Areas in the West.


Several appendices offer detailed analysis methods as part of developing the EIS. Appendix A presents a process that will help the BLM determine whether grazing is the cause of degradation when rangeland fails to meet BLM’s rangeland health standards.  The material in Appendix B develops and illustrates our proposed, science-based model for determining appropriate stocking levels for cattle in GSENM grazing allotments.   Lastly, Appendix C documents a new approach for determining properly functioning condition of lower-elevation streams and riparian zones on the Colorado Plateau.


[1] Two of these methods (making determinations, and assessing forage capacity and setting revised stocking rates for GSENM allotments) were presented to Dave Wolfe, Thomas O’Dell and Walt Fertig in May and June of this year.