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In order to adequately analyze grazing impacts in the Monument and evaluate the current and proposed future grazing program, the DEIS staff must take a hard look at the current conditions in the Monument.  This entails performing rangeland health evaluations for both uplands and riparian areas across the Monument (the Monument staff have been completing these evaluations over the past 2-3 years), and then comprehensively considering the results of these evaluations, always with an eye towards cumulative impacts.  It means going through all the relevant files for the Monument grazing allotments, and studying everything from historic stocking levels to current permitted use and actual use, to years of trend data and utilization levels for those allotments.


The authors of this report have begun to analyze the completed rangeland health assessments and the various grazing-related data mentioned above.  Based on thisinitial review, below we outline the chief problems related to resource degradation that are obvious in the GSENM (Section 3.1), such as loss of riparian and spring water sources, the spread of exotic plants, the decline of native and rare species, and changes in plant community composition, structure and productivity.


Then, we explain why the above problems are real (Section 3.2) – not just degradation that we suspect has occurred or which we think we see when we visit the Monument.  Rather, the level of degradation of these resources is adequately captured by various studies and data collected over the years, chiefly by the BLM but also by other researchers working in the Monument.


Based on the current conditions in the Monument in which rangelands fail to meet the rangeland health standards, an initial assessment of the various causes of degradation should be made, before the formal process of determinations in undertaken.  We make the case that, in general, most of the biotic resource degradation evident in the GSENM can be tied in one way or another to livestock grazing (Section 3.3, however, often livestock grazing impacts act in close conjunction with drought, or poor soils, and in these cases the true impacts of grazing are more difficult to tease out).  However, we also make the case that problems with monitoring, data collection and even the rangeland health assessment methods themselves and how they are performed and results analyzed can further cloud the issue of what exactly is leading to resource degradation (Section 3.4).  Similarly, various problems we see with grazing management in the Monument can compound impacts caused by livestock grazing in GSENM (Section 3.5).



3.1 Ecological Health: identifying compromised habitat


When the Monument was founded in 1996, the President made clear that one of the fundamental values for which the National Monument was established was to protect its outstanding biological diversity.  The management plan reinforces the objective to manage so as to prevent damage to the GSENM’s biological resources (Plan at pgs 3-5). 


            Unfortunately, there are many examples where the natural resources, natural processes, and biological diversity of the Monument are being compromised.  Specifically, we see four areas where habitat condition has been severely compromised over time: loss of riparian and spring water sources and habitat, the spread of exotic plants, the decline of native and rare species, and overall changes in plant community composition, structure and productivity.


 3.1.1  Loss of riparian and spring habitat, and consequences.   The Monument’s management plan is direct in terms of the importance of maintaining riparian zones and wetlands in good health.  The plan states, “the overall objective with respect to riparian resources within the Monument is to manage riparian areas so as to maintain or restore them to properly functioning conditions and to ensure that stream channel morphology and functions are appropriate to the local soil type, climate and landform” (Plan at pg 20).  The plan also states, “the BLM will place a priority on protecting riparian and water resrouces as they relate to fish and wildlife” (Plan at pg 12).


                              Yet, based on the most current field research conducted by the Monument staff,[1] there are currently 71 springs and seeps within the Monument that are either Functioning At Risk (FAR) with a downward trend, or Not Functioning (NF) at all.  In addition, 48 riparian areas are in the same poor shape (NF or FAR with downward trend).1  Moreover, recent vegetation research conducted in the Monument hasfound that rare habitats, such as aspen, wet meadows, and riparian areas, are the most heavily invaded habitats by aggressive exotic plants (NREL 2002).  


                        Wetlands, including both riparian areas and springs, are key to the maintenance of biodiversity within the Monument. The Management plan readily acknowledges this, stating, “riparian areas, though totaling less than 1% of the total lands in the Monument, are some of the most productive [and] ecologically valuable…areas” (Plan at pg. 13).  In addition to supporting rich endemic floras, wetlands are the most productive communities in the arid southwest landscape, with riparian areas in particular providing essential habitat for wildlife breeding, wintering, and migration (Ricketts et al. 1999,Stevens et al. 1977).  Riparian habitats in the Southwest are home to the North American continent’s highest breeding bird density (Carothers et al. 1974)and more than one hundred state and federally threatened and endangered species (Johnson 1989).  As such, these riparian areas are therefore crucial for much of the Monument’s wildlife. Although most terrestrial vertebrates in the Monument use a large range of habitats, most are dependent on stream, riparian and other wetland habitats during either seasonal migrations or seasons and years when surrounding habitats are dry and unproductive.   Riparian corridors are essential not only to migratory vertebrates but to fishes and small terrestrial vertebrates and invertebrates, which are distributionally restricted to these unique habitats (Davidson 1999).  Two of seven recognized centers of endemism for fishes of the western United States are within the Monument, and these organisms clearly rely on functioning streams and rivers (Belnap 1998, Davidson et al. 1996).


                        Some of the rarest species in the Monument and the most spectacular biotic assemblages are those associated with the springs and seeps that dot the landscape within the Grand Staircase- Escalante region (Rushforth 1999).  Just as areas with distinctive soil types are inhabited by their own special floras, the uniqueness of spring and seep habitats usually translates into unusual species communities.  Isolation may lead as well to genetic differentiation, in which particular sub-populations of plants and animals have adapted to local conditions in a given spring or seep (EDF 1995, Davidson 1999).  Moreover, because of the relative isolation of these sites from other areas of similar habitat, their recovery from any form of disturbance is likely to be impeded markedly by the difficulty of recolonization from similar habitats that may be miles away. 


                        When springs and riparian areas are degraded and not functioning properly, a myriad of secondary effects ripple through the ecosystem and biotic communities.  For example, one symptom of degraded riparian zones is a lowered water table, which in turn reduces the capacity for water storage in the system, and ultimately reduces or eliminates perennial flows (Chaney et al. 1993,EPA 1993).  Degraded streams tend to see accrual of sediments in the channel, alteration of channel substrates, transformation of pools to riffles, widening of the channel, and channel incision.  This type of loss in stream channel integrity and diversity is a deleterious modification of aquatic habitat (EPA 1993), with potentially profound effects on aquatic organisms (Platts 1991).   Functioning-at-Risk and Non-Functioning riparian zones also have less plant cover to absorb rain and protect the soil from wind and rain erosion (Ellison 1960), and to trap sediment in the stream channel (Carter 2000).  Degraded streams also experience increases in stream temperatures through lower summer flows, widening of the stream channel (thus exposing more water surface to solar radiation), and increased solar exposure due to reduced shade from streamside vegetation and to loss of undercut streambanks (Belsky et al. 1999).   Increased temperatures can in turn impact fish populations, because of decreases in dissolved oxygen levels triggered by the higher temperatures. 


As stated previously, life forms relying on healthy aquatic habitats on the Colorado Plateau include invertebrates, reptiles, amphibians, fish, birds, and mammals.  Birds are often referenced as one of the significant suites of species relying on healthy riparian zones.  Participants in studies at the High Desert Ecological Research Institute state that “the loss of riparian habitats has been suggested as the most important cause of population decline among land bird species in western North America” (Dobkin et al. 1998).  Degradation of riparian habitats, in terms of simplification of riparian habitat structure and composition, and invasion of riparian zones by exotic weeds, has negative repercussions for wildlife, especially neotropical migrants.


3.1.2 Significant changes in vegetation composition, structure and biomass,  and consequences.  The Monument’s Management Plan emphasizes the importance of ensuring that vegetative communities – including cryptobiotic soils – are in a natural, functioning state.  The Plan underscores the importance of managing for potential natural communities of native vegetation types: “the Monument will be managed to achieve a natural range of native plant associations.  Management activities will not be allowed to significantly shift the makeup of those associations, disrupt their normal population dynamics, or disrupt the progression of those associations” (Plan at pg 22, emphasis added). Structural/Functional health of GSENM plant communities: Based on the most current field research conducted by the Monument staff,[2] 63 different upland rangeland health assessment sites representing 26 allotments received failing scores (1 or 2) for Upland Health Indicator #12 (Functional and Structural Groups), indicating that these sites are far from a natural state of normal function and structure for those vegetative communities.  This indicates a substantial alteration of structure and function of native vegetation communities in the Monument, and is alarming given the weight the Monument’s management plan puts on maintaining these resources in a healthy state. 


                  The structural changes in the plant communities in the Monument have profound impacts on native wildlife and their habitat.  While many would not consider grasslands to have naturally high structural diversity, grasslands do have a vertical structure that develops over time, both within a growing year and from one year to the next, and which is essential to the functions performed by grasslands.  Live and dead standing plants together with fallen dead plant material create the structural diversity and the microclimates necessary to support essential soil microorganisms as well as many species of wildlife (Feller and Brown 2000).


                  Indeed, loss of structural diversity has many negative repercussions for rangeland wildlife.  For example, low structural diversity of desert vegetation has been linked to low diversity of the native rodent assemblage (Rosenzweig and Winakur 1969).  A lack of structural diversity at the ground cover layer can affect the nesting success and chick survival for ground-nesting birds such as sage grouse that require low-statured sheltering near the nest (Hein et al. 1980, Webb 1993).  A diverse shrub and ground cover layer is important for shading many animals in the desert heat, as well as providing a thermal cover that moderates both high and low temperature extremes (Feller and Brown 2000).  A lack of litter can impact other ground-nesting animals such as harvest mice (Reithrodontomys megalotis) that require litter for their nests (Jones 2000).  Structural diversity of vegetation in riparian zones has shown to be of paramount importance to various species of birds ranging from neotropical migrants (Hubbard 1987, Taylor and Littlefield 1986) to Mexican spotted owls (Rinkevich 1991, Willey and Van Riper 1993).  Riparian structural complexity allows more options for foraging, allows riparian birds to avoid detection by avian predators such as northern goshawks and great horned owls, and is also important for creating cool microsites for somewhat “heat intolerant” bird species (Stacey and Hodgson 1999).  Another measure of structure - Cryptobiotic Soils: Cryptobiotic soils provide yet another structural component of vegetative communities in the desert southwest.  The Management Plan states, "the overall objective with respect to soil resources within the monument is to manage uses to prevent damage to soil resources and ensure that the health and distribution of biological soil crusts is maintained or improved"  (Plan at pg 21).  The Monument staff has made it clear that they fully understand the considerable problems caused by loss of cryptobiotic soils, as evidenced in their treatment of these important crusts in the EAs that analyzed whether it was appropriate to retire AUMs on a handful of Monument allotments (i.e. Clark Bench, Willow Gulch allotments).   In these analyses the EAs debunk Alan Savory’s suggestion that the presence of well-developed biological soil crusts are indicative of poor range condition (BLM 2002a), and acknowledge that the Monument “ha[s] the potential to support a near-continuous cover of cyanobacteria-dominated crusts in interspaces among rocks and vascular plants” (BLM 2002a, p. 13-14, BLM 2002b, p.12).  These EAs also documented that at some sites, cryptobiotic soils were “moderately reduced relative to potential” (i.e. at two assessment sites – E0068 and E0069 on the Clark Bench allotment, BLM 2002a).


                  Tom Stohlgren and his team from the Natural Resource Ecology Lab at Colorado State University have been recently conducting a comprehensive and ongoing (5 year) landscape-scale assessment of vegetative cover in the Monument, and have established 367, 1 km2 modified-Whittaker vegetation plots throughout the Monument.  This team has found that when averaging cryptobiotic crust cover across these 367 plots, average cover of crusts was only 24.4% (Stohlgren et al. 2001).  Other studies of crust cover in relict sites reveal that anywhere between 38% to near 100% cover of cryptobiotic soils is typical in the soil types typical of the Monument (e.g. West 1983c;  John Carter, unpublished data collected in GSENM, 2003). 


                  The substantial loss of cryptobiotic soil cover in GSENM is of great concern.  Cryptobiotic crusts, which were historically widespread in western arid lands, are being rapidly depleted across rangelands today.  These crusts increase the stability of otherwise easily erodible soils, create excellent microsites for native seed germination, increase water infiltration in a region that receives limited precipitation, and increase fertility of xeric soils often limited in essential nutrients such as Nitrogen and Carbon (Johansen 1993, Belnap et al. 1994). Plant community productivity:  As evidenced elsewhere in this document, the Monument’s vegetative communities are clearly suffering from a drastic loss of forage productivity over the years.  Loss of productivity, or overall vegetative biomass, can have many negative repercussions for ecological processes and biological health of rangelands.  Natural levels of plant productivity ensure appropriate levels of cover necessary to provide forage and cover for native wildlife, as well as preventing unnatural levels of soil erosion. 


                  Measures of productivity are required by law.  As we point out in Chapter 2, these are binding standards that may make continued resource productivity one of the very highest management criteria for GSENM.


                              In closing, we wish to draw to the BLM’s attention that some of the vegetation communities in GSENM are far worse off than others.  Below (Figure 3.1), we have graphed the ratio of sites with “poor” Rangeland Health Assessment ratings (at least one of three land-health attributes are 3 or below) to those with “high” Rangeland Health Assessment ratings (all land-health attributes rated 4 or above) for each of the seven chief community types in GSENM.  One would hope that most ratios would hover around a “1” (or, 1:1 ratio) or below, or that there are not more “poor” sites than “high” sites in any community type.  Unfortunately, as Figure 3.1 shows, all community types but one are above the 1:1 ratio, and semidesert grassland and seeded pasture are well above the line, indicating that these vegetative communities are currently faring much worse than most.  Indeed, it seems that only pinyon juniper communities are faring well.


Figure 3.1 Preliminary Ranking of Community Types by Degree of Diminished Land Health, GSENM, Using a Low:High Land-Health Ratio*

*Ratio = (assessments with ‘low’ ratings) / (assessments with ‘high’ ratings)

‘low’: at least one of three land-health attributes rated as 3 or below

‘high’: all land-health attributes rated 4 or above



3.1.3  Spread of exotic plants, and consequences.  The Monument’s Management Plan states, “the BLM will place a priority on the control of noxious weed species and prevent the introduction of new invasive species” (Plan at pg 22).  In addition, E.O. 13112 on exotic species states that federal agencies shall “prevent the introduction of invasive species.”  The Monument staff has made it clear that they fully understand the considerable problems caused by exotic plants, as evidenced in their treatment of exotics in the EAs that analyzed whether it was appropriate to retire AUMs on a handful of Monument allotments (i.e. Clark Bench, Willow Gulch allotments, BLM 2002a and 2002b). 


                              The Monument is currently suffering a significant and persistent invasion of exotic weeds.  A comprehensive and ongoing (5 year) landscape-scale assessment of exotic plant diversity in the Monument, conducted by Stohlgren et al. from the Natural Resource Ecology Lab, have found exotic frequency and coverage to be a considerable problem within the Monument (NREL 2002).  So far, this team has documented 44 non-native species on the Monument, seven of which were found to be highly invasive (Bromus tectorum, Erodium cicutarium, Poa pratensis, Salsola iberica, Tamarix spp., Taraxacum officinale, and Tragopogon dubius).  Over the past 5 years, the team has established 367, 1 km2 modified-Whittaker vegetation plots throughout the Monument.  The most recent data collected shows that cheatgrass (Bromus tectorum) is the 3rd most common plant on the plots – occurring on exactly two thirds (66.5%) of the 367 plots (NREL 2002).   Stohlgren’s team also found that rare habitats, such as aspen, wet meadows, and riparian areas, are the most heavily invaded habitats by exotics.


                              Based on the most current (2000 through 2002) research conducted by the Monument staff, 46 different upland rangeland health assessment sites representing 25 allotments received failing scores (1 or 2) for Upland Health Indicator #16 (Invasive Plants), indicating that these sites are far from a natural state for these native vegetative communities, which should be virtually free from exotic influences.


                        Once they are established weeds negatively impact western arid ecosystems in numerous ways.  Weed infestations can lead to major changes in community composition (Bock et al. 1986), which often results in reduced biodiversity (Randall 1996) when weeds out-compete and displace certain native plants such as grasses (Rosentreter 1994), and restrict new natives from germinating and spreading.  Increased annual exotics in a community, such as cheatgrass, can increase fire frequency by providing much more flammable cover between shrub interspaces than existed historically (Esque 1999, Brooks et al. 1999).  Other secondary effects from the invasion of exotics ensue, including altered soil microclimate (Evans and Young 1984), expedited loss of topsoil in xeric environments (Lacy et al. 1989), reduced effectiveness of wildlife habitat  (Davidson et al. 1996, Knick and Rotenberry 1997), and ultimately, such profoundly altered ecosystems that nutrient cycling is disturbed and various disturbance regimes are altered (Mack and D’Antonio 1998).


3.1.4.  Imperilment of native species.   There 46 federal and state-listed threatened, endangered, and sensitive (TES) species known to reside in the Monument.  In general, these listed species often have low reproductive potential, restricted geographic ranges, and either persist in small populations or typically experience substantial variation in population size (Terborgh and Winter 1980, Diamond 1984, Pimm et al. 1988, Belovsky et al. 1994).   Of course, all of the TES species have specific habitat needs unique to those species.  While some of these species (especially plants) are intrinsically rare due to the unique features of this part of the Colorado Plateau such as climate, position along migratory routes, and distinctive geologic history and unique substrates (Welsh 1978), many of these species are listed because of the undeniable impacts of humans on their habitats over the decades (i.e. sage grouse, which used to be incredibly prevalent across sagebrush step systems throughout the intermountain West).  In general, the mere fact that there are so many imperiled and listed species within the Monument’s boundaries should be cause for concern for the BLM.   



3.2  Supporting evidence of ecological conditions in the Monument


3.2.1  GSENM assessments. Some of the most telling information we have, which paints the clearest picture of the state of the resources in the Monument, is the data, assessments, and evaluations collected and performed by Monument staff.  As we outline below, the BLM’s data makes it clear that many of the Monument’s biotic resources are degraded or impaired.  PFC assessments: Based on the most current field research conducted by the Monument staff, [3] there are currently 71 springs and seeps within the Monument that are sufficiently impaired to the point where the Monument must take reparative action: 46 of the springs and seeps were found to be Functioning at Risk (FAR) with a downward trend, and fully 25 of these rare springs were found to not be functioning at all.  A striking indication of the very poor shape these seeps and springs are in is that 71 out of 143 (or, 50%) springs assessed are degraded to the point where corrective action must be taken immediately.  Moreover, the most recent PFC assessments for riparian zones in the Monument[4] revealed that 48 riparian areas within the Monument are sufficiently impaired to the point where the Monument must take reparative action: 27 of assessed riparian zones were found to be Functioning at Risk (FAR) with a downward trend, and fully 21 riparian areas were found to not be functioning at all.  Table 3.1 shows the number of lotic and lentic PFC assessment reaches, per allotment, which are not in Properly Functioning Condition.  Upland rangeland health assessments: In terms of the uplands in the Monument, the BLM’s 2000-2002 assessment results for these areas (using the Indicators of Rangeland Health assessment process), indicates that 44 upland assessment sites received average scores (when the scores for the three functional categories are averaged) of less than 3, thus indicating that these 44 sites are not meeting the Standards for Rangeland Health.  Figure 3.1 depicts the number of Rangeland Health Assessment sites, per allotment, which received a score of 3 or less for any of the three main functional assessment categories (soil stability, hydrologic

Table 3.1  The number of times an URH assessment site received a rating of 3 or less for any for any of the three functional categories, and the number of times a riparian area was rated not PFC, for each allotment in GSENM

Allotment Name

Allotment Number


Number of RLH sites with rating of <=3 for any of 3 functional categories

Number of lentic & lotic sites not PFC

Alvey Wash





Antone Flat



none conducted

none conducted

Big Bowns Bench





Big Horn





Black Ridge





Black Rock










Boulder Creek





Bunting Well





Calf Pasture





Cedar Wash





Circle Cliffs





Clark Bench





Cocks Comb















Cottonwood Springs















Death Hollow





Deer Creek





Deer Range





Deer Spring Point





Dry Valley





Escalante River





First Point





Fivemile Mountain





Flood Canyon





Ford Well





Fortymile Ridge





Franks Resevoir





Granary Ranch





Hall Ranch





Haymaker Bench










Hells Bellows





Johnson Canyon





Johnson Point





Jonson Lakes





King Bench










Last Chance





Little Bown Bench





Little Desert










Lower Cattle





Lower Hackberry





Lower Sink Valley





McGath Point





Meadow Canyon





Mill Creek





Mollies Nipple










Mud Springs





Muley Twist










Nipple Bench





Pet Hollow










Pine Creek





Pine Point





Rock Creek- Mudholes





Rock Reservoir





Round Valley





Roy Willis





Rush Beds





Salt Water Creek





School Section





Second Point










State Block





Steep Creek





Swallow Park





Timber Mountain





Upper Cattle





Upper Hackberry





Upper Paria





Upper Varnet





Upper Warm Creek










Wagon Box Mesa





Wah Weap





White Rock





White Sage





Willow  Gulch











Figure 3.1 The number of Rangeland Health Assessment sites, per allotment, which receive a score of 3 or less for any of the three main functional assessment categories (soil stability, hydrologic function, and biotic integrity). 






function, and biotic integrity).  It is likely that the generally poor showing on the Rangeland Health Assessments in GSENM are driven in a large part by consistently low scores (3 or less) on biotic integrity indicators; Figure 3.2 shows the number of Rangeland Health Assessment sites, per allotment, which received a score of 3 or less for the biotic integrity category.  Utilization: The Monument’s own data on utilization of key forage species, (collected between 1979 and 2002) tells another alarming story.  Out of 1943 records showing utilization levels on key plants, 946 (or 48.6%) of these show utilization levels of 50% or greater, with many cases where utilization rates are 85% and above.  Though the proper utilization rates of preferred forage grasses in southwest deserts is currently a matter of some debate, there is a great deal of consensus that livestock utilization rates of 50% and greater are too high.[5]  Range condition:  The Monument’s Draft Management Plan/DEIS (BLM 1998) reported 37 cases of downward range trend in the Monument, and only 9 cases in which all trend readings in a pasture indicated upward trends only. 


All of these factors combined (50% of springs not properly functioning, 48 or 15% of riparian zones not properly functioning, 44 upland pastures not properly functioning, and utilization levels and stocking rates clearly above where they ought to be) describe a serious departure from the ecological goals outlined in the Monument Plan.  Overall, about 65% of the grazing allotments in the Monument evaluated thus far have failed to meet at least one of the four standards somewhere on the allotment (which means that the allotment itself has failed to meet standards).  Again, this state of affairs reflects the data collected by the agency itself.  Below, we present several interpretations of the Monument’s own data, and additional data collected outside of the agency, to even further the case that the resources in the Monument are in very poor shape indeed.


3.2.2 Our analyses convey additional information on the state of resources in the Monument  If the data collected by the BLM is scrutinized and analyzed in a more thorough and slightly different fashion than is currently being done by Monument staff, yet another story can be told.  There is strong evidence that there are many cases in which the resources of the Monument may in fact be in even greater trouble than what the agency’s data convey:  – When considering the Upland Rangeland Health (RLH) assessment data forms, it is important to scrutinize some telling individual assessment values (scores) and not just use those compiled for groups (soils, water, and biota).  For example,we argue that if certain, particularly key indicators such as RLH #12 (Functional and Structural Groups) and #16 (Invasive Plants) receive scores of 2 or lower, then we would in fact consider the entire assessment area to be FAR, not PFC.

Figure 3.2.  The number of Rangeland Health Assessment sites, per allotment, which received a score of 3 or less for the biotic integrity category.






In terms of Indicator #12, the rationale behind our special scrutiny of this indicator draws from Part c of Standard 1 and Part b of Standard 2 and Part d of Standard 3 in the Standards and Guidelines which state that the presence of the "desired plant community" identified in the land use plan is a pertinent indicator for evaluating these Standards.  It follows logically from the Monument plan decision VEG-00 (plan, at page 22) that the desired plant community is the "potential natural community" reflected in the appropriate NRCS Ecological Site Description for that area.  The Clark Bench EA and other permit-buyout EAs provide precedent for this interpretation of VEG-00.  Thus, we argue that scores of 2s or below for RLH indicator12 (F/S groups) indicators failure of Standard 1, 2, and 3.  It further follows that the assessment site cannot receive a PFC rating with a score of 2 or less for RLH indicator12, even if the average score for the entire assessment is greater than 3.  We found 42 separate cases in the upland RLH assessments where assessment sites receiving a 1 or 2 for Indicator 12 still received an overall average rating of 3 or above.


Moreover, the Functional-Group indicator is useful as a stand-alone measure because it's one of the few RLH indicators that is quantitative, and so it can be tied to the Management Plan objectives for vegetation (i.e. the Potential Natural Community as specified in NRCS Ecological Site Descriptions).


The same case can be made for RLH indicator #16 (Invasive Plants).  This is also a quantitative indicator and can be linked to a presumed quantitative standard of zero (as laid out in both the Management Plan objectives, and E.O. 11312).  For this reason, we stress that an assessment site cannot receive a PFC rating with a score of 2 or less for RLH indicator16, even if the average score for the entire assessment is greater than 3.   We found 33 cases in the upland RLH assessments where assessment sites receiving a 1 or 2 for Indicator 16 still received an overall average rating of 3 or above.  - By looking at data collected and assessments performed independently of the BLM, we start to see a picture of resources that may be impacted more severely than the Monument’s own analyses might suggest:


·        An independent group of riparian scientists recently devised an alternative method for assessing proper functioning condition of riparian areas in the Southwest (Stevens et al., in review).  As part of the development of this alternative protocol, Stevens et al. field-tested the new method on four different stream reaches in the Monument.  While Stevens et al. agreed with the Monument’s PFC rating on Deer Creek, Stevens’ team did not agree with Monument assessments of PFC for The Gulch and Cottonwood Creek (both which resulted in FAR ratings using the alternative protocol), nor did the team agree with the Monument’s FAR rating for Harris Wash (found to be NF with the alternative assessment method).[6] 


·        Additionally, another group of researchers has recently independently assessed forage biomass (grasses and forbs) in a number of sites in the Upper Hackberry allotment, focusing on ecological Range Site Types that are prevalent in the Monument.  By performing estimates of ground cover along with clipping studies to determine forage biomass, Catlin et al. (in prep) found that actual biomass of forbs and grasses in numerous Range Site Types were much less than the biomass potential described by the BLM/SCS 1984 Site Write-ups for those soil types.  For example, the researchers found that in all Range Site Types clipped, actual values of forage were anywhere between 25% and 80% less than the potential biomass described by the BLM/SCS 1984 Site Write-ups, often showing differences of hundreds of pounds per acre.


·        As mentioned previously, independent field research in the Monument by the National Research Ecology Lab (NREL) in Ft. Collins found that average cover of cryptobiotic soil crusts in the Monument is only 24.4% - lower than would be expected for these soil types (Stohlgren et al. 2001), and that cheatgrass is a significant problem.  This exotic species is likely to be the 3rd most common plant in the Monument – occurring on over 66% of all NREL study plots (NREL 2002).



3.3  Causes of Habitat Issues Discussed Above are Generally Tied to Livestock Grazing


                              The Monument staff is well-aware of the literature that exists that firmly connects the role of livestock grazing in arid lands to degradation of riparian zones and wetlands, alteration of vegetation communities, and spread of exotic plants.[7]  It is clear that the Monument staff is aware of this large body of literature, as it is fairly well-cited in some of the recent grazing related Environmental Assessments (EAs) that have been produced by the Monument (BLM 2002a, 2002b).  As the authors of the upcoming Grazing DEIS are familiar with the scientific literature on this issue, we do not need to go into great detail on this here. 


                              However, there are some examples of grazing impact studies that have been conducted within the Monument’s boundaries, and these studies give particular insight into livestock grazing effects on Monument resources.  A study just recently completed by Guenther et al. (in press) in Molly’s Nipple allotment compared a long-time grazed area on Deer Springs Point to a long-time ungrazed (relict) mesa top (No Man's Mesa).  The study found that the grazed area on Deer0Springs Point had lower vegetative species richness, more exotic species, significantly higher shrub cover but lower shrub diversity, and significantly less cryptobiotic crust cover compared to the non-grazed area on No Man's Mesa.


                              Another recent study on No Man’s Mesa (Harris et al. 2003) also compared conditions on the ungrazed relict mesa top to conditions on two grazed mesas less than 2 km. Away.  The researchers used field studies and imaging spectroscopy to investigate the effects of cattle grazing on vegetation cover.  They found that there was significantly greater percentage of shrubs (27.3%) and significantly lower composition of grasses (34.4%) on the grazed mesas compared to the relict No Man’s Mesa.  The authors concluded, “ our results suggest that grazing has contributed to woody thickening in these pinyon juniper ecosystems through an increase in shrubs in the understory and intercanopy spaces.”


                              In another grazing effect study conducted in the Monument (mentioned in previous section), researchers compared ground cover and forage (grass and forb) biomass present in the Upper Hackberry allotment to ground cover and forage biomass present in the nearby ungrazed Kodachrome Basin State Park.  The researchers found that the mean weight of forage in the Upper Hackberry unit (semidesert sandy loam big sagebrush soil type) ranged from 58 lbs/acre to 195 lbs/acre, whereas the mean weight of forage in the State Park (semidesert sandy loam big sagebrush soil type) was 293 lbs/acre (Catlin et al., in prep). Catlin et al. also found that percent grass cover was twice as high in Kodachrome State Park compared to the same soil type inside the Upper Hackberry allotment.


                              Last year, the Monument staff completed a number of EAs that analyzed whether it was appropriate to retire AUMs on a handful of Monument allotments (i.e. Clark Bench, Willow Gulch allotments).  These EAs gave accounts of livestock-impacted conditions such as this one on Calf Spring in the Clark Bench allotment:


“Calf spring was assessed as FAR …due to accelerated sediment deposition…[which] was attributable to soil destabilization and movement most probably caused by unrestricted livestock access to the pond and wetland….the rate at which the headcut was approaching the earthen dam from below was accelerated due to trampling and shearing of the earthen dam by hoof action.  Fecal deposits lined the margin of the pond and were abundant in the wetland.  The two most abundant plants at the margin of the pond were the non-native Russian thistle and cocklebur.  Establishment of both plants can be facilitated by soil disturbance. Cocklebur is unpalatable and toxic to livestock.” (BLM 2002a, pgs 8-9)


                              These EAs also readily acknowledged the impacts of cattle grazing to semi-arid vegetation types, as they predicted that drastic reductions (near 100%) of cattle on the allotments slated for buy-out would result in “greater structural diversity of vegetation,” would “slow the creation of bare-soil habitat available for colonization by native and non-native weeds,” would result in “development of vegetation


                              Lastly, based on the most current field research conducted by the Monument staff, there are currently 71 springs and seeps within the Monument that are either functioning at risk with a downward trend, or not functioning at all.  In addition, 48 riparian areas are in the same poor shape (non-functional or FAR with downward trend).  Out of the combined 119 wetland (lotic and lentic) PFC assessments that resulted in NF or FAR with downward trend, 70 of them (59%) include assessor comments that implicate cattle grazing as the primary cause (or one of a few primary causes) resulting in the degradation of these wetland areas.


                              There is currently much debate on the topic of whether current or past, historic grazing practices are the chief cause of observable grazing impacts.[8]  Additionally, there is some controversy in the scientific literature concerning how long rangelands need to be rested before the land can recover from overgrazing damage.[9]  Furthermore, it is very challenging to disentangle grazing impacts from other, natural situations like drought, or “poor soils.”  Below, we discuss these issues as they pertain to livestock grazing impacts.  These will obviously be very pertinent issues when the Monument staff addresses cumulative impacts as pertains to grazing in the DEIS.


3.3.1 Drought combined with livestock grazing.   One reason why riparian and wetland areas can be diminished, vegetation communities altered, and exotic species frequencies increased can be tied to long-term, persistent drought.  Yet, there is a fair amount of consensus within the scientific community that drought works in conjunction with continued livestock grazing and/or fire suppression to result in profound changes in vegetative community composition and structure (i.e. the conversion of grasslands to shrublands) (Conley et al. 1992, Fuhlendorf and Smeins. 1997) including admittance of such by the Monument itself (see references in Appendix H, BLM 2002a and b).


Current knowledge leads to the conclusion that drought is not by itself a significant factor for resource degradation in the Monument.  The vegetative communities in GSENM have undergone countless droughts over the past few thousand years,[10] many of them severe, yet these past droughts did not lead to dramatic changes in species composition or structure, as numerous scientific studies have found livestock grazing to do in the arid West.


In addition, a study in Capitol Reef National Park (Cole et al. 1997) used packrat middens to describe vegetation changes in the region over time.  The authors found that pre-settlement middens contained abundant macro-fossils of plant species palatable to livestock, such as winterfat (Ceratoides lanata) and Indian ricegrass.  Their midden analysis demonstrated that drastic vegetation changes, unprecedented during the last 5,000 years, occurred in this part of southern Utah between roughly 1800 and the present.  Species typical of overgrazed range, such as snakeweed, rabbitbrush (Chrysothamnus nauseosus), and Russian thistle (Salsola iberica) were not recorded in middens prior to the introduction of domestic grazing animals.  These changes occurred against a background of regular droughts, yet these historic droughts were not severe enough to change the entire nature of the vegetation; these droughts did not nearly represent the level of disturbance that the advent of livestock grazing did almost 200 years ago.


Six out of the last 10 years have been drought years on the Monument.  The following example on the 50-mile mountain allotment illustrates the problems that can result when drought is combined with poor grazing management. This part of the Monument received only 30% of the average annual precipitation in 2000.  On September 25 of that year the Monument’s Rangeland Management Specialist flew over the entire Lake Allotment and stated: “the uplands have been depleted of grass and much of the browse has been eaten. The riparian areas are in deplorable condition! They have been trampled into oblivion.  It will take more than one year for them to heal.  Conditions grow worse each day” (Allotment Supervision Record, 1.  Lake Allotment, 2000).  The 2000 forage utilization records for the Lake Allotment demonstrate that average utilization levels for all pastures in the allotment in 2000 were 90% for uplands and 99% for riparian areas.  The Rock Creek-Mudholes allotment was in similarly alarmingly poor condition; during the 2000 grazing season, average utilization levels in this allotment were from 73% to 90% in the uplands and 90% in the riparian areas.  These data provide convincing evidence that the Monument is not prepared for extreme drought situations, and that the BLM does not recognize the problem until it is too late.  Moreover, our graph on page 21 (Section 3.1.6 of our “Making Determinations” Section (Appendix A) uses the case of the Hackberry allotment to illustrate that the BLM often delays reductions in stocking during drought and then returns cattle use quickly to lands before they can recover.


Moreover, the consequences of "drought" (as experienced by the ecosystem) is a function of two factors: (1) site hydrologic conditions (drought is exacerbated as a consequence of site degradation – often caused by livestock grazing - that reduces infiltration and increases runoff) and (2) plant physiological condition (which is certainly diminished by excessive herbivory which can diminish root growth and thus exacerbate drought conditions).  These factors are in addition to the climatic conditions we normally consider when we discuss drought and its repercussions to ecosystems.  It follows that “ecological drought” could be much more frequent and of greater magnitude than expected simply on the basis of climatic variables alone (Brown, 1995, Thurow 1991, Thurow 2000), and the reason for this are often tied to livestock grazing, as mentioned above.


3.3.2 Poor soils combined with livestock grazing. In general, soils are considered “poor” if they are shallow and cannot support deep-rooted grasses, or if they are particularly susceptible to erosion.  Below, we chiefly focus on soils that are more prone to erosion, and discuss why this is so, the formulas that determine the degree of susceptibility, and the role livestock grazing has in exacerbating the problem. – Water erosion. In Section 2.3.3(2) of our Forage Analysis/Grazing Capacity section (Appendix B), we summarize literature and provide examples of the serious nature of increased erosion due to livestock grazing.  As described, grazing, by removing vegetative cover and trampling crusts, increases bare ground.  As slope and bare ground percentages increase, erosion increases.  Our review of literature coupled with personal observations showed that potential ground cover in the Monument environment is high, approaching 100%, with a potentially high level of cryptogammic crust cover. 


NRCS provides erosion factors for wind and water erosion for each soil type it surveys.  The erosion factor (K) indicates the susceptibility of a soil erosion by water.  It is one of six factors used in the Universal Soil Loss Equation to calculate the annual soil loss by water erosion.  Values of K range from 0.05 to 0.69 with the higher values being associated with greater susceptibility of erosion.  The USLE, or currently, Revised USLE (RUSLE)[11] is:


A = R * K * LS * C * P



A = estimated average soil loss in tons per acre per year
R = rainfall-runoff erosivity factor 
K = soil erodibility factor
L = slope length factor
S = slope steepness factor
C = cover-management factor
P = support practice factor


The most detailed reference on application of the RUSLE can be found at http://www.ott.wrcc.osmre.gov/library/hbmanual/rusle703.htm#downloadah703 and is the USDA manual on RUSLE application to predicting soil erosion by water (USDA 1996).


At the most basic level, however, from the equation it is readily seen that as slope increases, ground cover decreases, and thus soil loss increases.  The graph of soil erosion as a function of slope and ground cover provided in our forage capacity/stocking analysis (Appendix B, pg 18) clearly indicates the exponentially increasing nature of soil erosion as slope increases and cover decreases.  For 30% slopes, which are at the upper limit for cattle capability given in the graph in Appendix B, it is clear that for that fine-grained soil, as ground cover declines below 100%, there is a linear decline to 80%.  At that point, erosion rates accelerate following an exponential or geometric increase.  For that soil type, it is evident that ground cover must be maintained above 80% to constrain erosion by water.  This implies a trampling and ground disturbance standard of 20% or less for combined trampling of crusts and removal of plant, litter cover.  Thus, it is clear that cattle grazing combined with naturally highly erodible soils (i.e. steep slopes) is a serious confounding factor when determining the true impacts of grazing to land and soil resources.  Wind Erosion:  The Agricultural Research Service[12] also has developed methods of calculating wind erosion.[13]  These can be found at: http://www.weru.ksu.edu/weps.html


The general equation is: E = f (I, K, C, L, V), where E is the potential average annual soil loss, I is the soil erodibility index, K is the soil ridge roughness factor, C is the climate factor, L is unsheltered distance across a field, and V is the equivalent vegetative cover.   Wind erosion susceptibility is grouped into 8 Wind Erodibility Groups by NRCS in their soil surveys.  Sands to sandy loams are highly erodible by wind and fall into the three highest erosion categories.  Soil disturbance can result in huge soil losses by wind.  It is clear from the general relationship given that increased vegetative and soil cover is essential to protect the soil from wind erosion. 


As livestock grazing has clearly been implicated in increased rates of soil erosion (see discussion elsewhere in this document), there is no question that livestock grazing combined with easily erodible soils (and other types of “poor” soils) will only serve to exacerbate the problem. 


3.3.3 Special consideration of livestock grazing impacts on federally listed species. Of great importance regarding federally listed Threatened and Endangered species in the DEIS is the scientific literature describing the impacts of cattle grazing to federally listed species.  This literature, as is pertains to the Mexican spotted owl, southwestern willow flycatcher, and federally listed plants, is summarized below and should be incorporated into the Grazing DEIS. Mexican spotted owl: While there have actually not been any studies that have looked at the effects of cattle grazing on Mexican spotted owls (Strix occidentalis lucida) (MSOs) themselves, there are studies that have demonstrated impacts of grazing on other raptors (e.g. Duff 1979, Kochert et al. 1988, Kochert 1989).  Furthermore, the indisputable impacts that cattle have been shown to have on MSO habitat and prey base on the Colorado Plateau have prompted many ornithologists to voice concern about the potential effects of cattle on MSOs (Howe 1994, Willey 1999, Stacey - in TWP 2000).  When assessing the effects of cattle grazing on MSOs, two critical life-requirements must be reviewed.  One is quality and quantity of suitable habitat, and the effects that cattle grazing has on these parameters.  The other is availability of suitable small mammal prey, and the effects cattle grazing has on these communities.  These same two avenues of analysis were used in the Mexican Spotted Owl Recovery Plan (USFWS 1995) to determine possible effects of grazing on owls.


Research has shown that MSOs in Utah require well-developed riparian vegetation (Rinkevich and Gutierrez 1997) with dense understories (Rinkevich 1991), and multi-layered, deciduous habitats (Willey 1991 and 1992, and Willey and Van Riper 1993).  Research throughout the Colorado Plateau has revealed that MSOs  require high canopy closure, high stand density, substantial vertical and horizontal diversity, and a multi-layered canopy resulting from an uneven aged stand (McDonald et al. 1991, Gutierrez et al. 1995, Zwank 1996,  Stacey and Hodgson 1999).  Furthermore, Stacey and Hodgson (1999) have identified deciduous understory plants as being particularly important to MSOs, because they offer the greatest vertical riparian vegetative structure and canopy cover. Almost all researchers who study habitat requirements for MSOs agree that structural complexity is paramount.  Structural complexity allows MSOs to avoid detection by avian predators such as northern goshawks and great horned owls.  It is also important for creating cool microsites for the notably “heat intolerant” MSO (Willey 1991 and 1992,Stacey and Hodgson 1999).


Cattle grazing has been shown to impact all of the structural habitat attributes, outlined above, that are important to MSOs.   Long-term grazing can inhibit or retard an area’s ability to produce mature trees (USDI 1995).  While upper canopy species like large cottonwoods are not directly impacted by grazing, cattle grazing in riparian zones has been shown to eliminate or reduce the upper canopy by preventing the establishment of seedlings, which leads to a loss of the upper canopy over time (Gilinski 1977).  In addition, long-term negative effects of cattle grazing on tree seedling establishment can result in decreased stand density, and more open, thermally unfavorable micro-sites (Howe 1994). Age structure of riparian trees also becomes even-aged due to cattle grazing (Kauffman et al. 1983).  Reduced seedling establishment due to ingestion and trampling by livestock has transformed a variety of southwest riparian systems into even-aged, non-reproducing communities (Carothers 1977, Davis 1977, Szaro 1989).  In general, both vertical and horizontal structure of riparian areas is simplified due to cattle grazing (Taylor 1986, Knopf et al. 1988, Medin and Clary 1989), through ingestion and trampling of seedlings by cattle, and butting/rubbing and browsing shrubs and saplings (Howe 1994).  Decreased structural complexity can in turn impact quality and quantity of perches used by MSOs for hunting, courtship and territorial defense (Howe 1994).


In addition to impacting quality of MSO habitat through reduction of structural complexity, there are concerns about cattle’s impact on quantity of MSO habitat.  The MSO recovery plan voices concern about the decrease in herbaceous ground cover attributed to cattle grazing, and thus increased chances of catastrophic fire in MSO habitat (USFWS 1995), with concomitant effects on MSO foraging/wintering/ dispersal/roosting and nesting habitats.   The recovery plan also states that grazing can “generally degrade, and in some cases through erosion and lowering of the water table, virtually eliminate some riparian areas, and reduce them to a non-functioning condition, thereby impairing use of riparian areas by owls.”   The Wildlands Project shares this concern; in a recent publication on a New Mexico/Arizona reserve design project that uses the MSO as a focal species, TWP states that, “loss of riparian areas from livestock grazing may be a major factor in continuing population declines” of the MSO (TWP 2000).


              The second critical aspect of determining potential effects of cattle on MSOs is to explore the impacts of grazing on the MSO prey base.  It has been suggested that MSOs select habitat based partially on the availability of prey (USDI 1995).  Small mammals by far make up the most important component of MSO diets (Howe 1994). In southern Utah, woodrats (Kertell 1977, Rinkevich 1991, Sureda and Morrison 1998) and white-footed mice, or Peromyscus species (Rinkevich 1991, USDI 1995, Willey - unpubl data), have been identified as the most important prey species for MSO. Grazing can influence prey availability and diversity by altering various habitat conditions for small mammals (USDI 1995).  In terms of Peromyscus species, a study in southeast Utah (Sureda and Morrison 1998) found that these mice were most often found in areas with heavy brush, a component that is not likely to be present in heavily grazed areas.  In New Mexico, cattle grazing has been shown to reduce abundance of Mexican voles (Microtus mexicanus) (Ward 1996), another important prey species for MSOs (personal communication, Peter Stacey).  West-wide, cattle grazing has been shown to reduce both species density (NV - Medin and Clary 1989 and 1990) and diversity (UT-Duff 1979, NV-Medin and Clary 1989 and 1990) of rodent populations in riparian areas.


              MSOs are not by any means “restricted” to riparian or forested habitats.  MSOs inhabit relatively open country along the northwest part of the species’ range in southern Utah.  Here, the MSO is strongly associated with steep sandstone canyonlands that include relatively open Great Basin desert scrub and woodland communities (Brown 1982, Willey 1995 and 1998).  Pinyon-juniper habitat has also been identified as an important component of MSO home ranges during summer and fall (Willey 1992).   These mesa/upland habitats contain substantial rodent populations, which can be severely impacted by cattle grazing, via impacts to alterations to vegetative structure and composition (see small mammal section, above).  Sureda and Morrison (1998) found that Peromyscus species were significantly more abundant in mesa habitats than canyon (riparian) habitats in southeastern Utah. Southwestern willow flycatcher:  There have been a number of studies that have researched the role of cattle grazing in southwestern willow flycatcher (SWF) (Empidonax tralii extimus) habitat degradation, with associated effects on SWF populations.  Livestock grazing has been implicated in willow flycatcher habitat loss and habitat changes (Sogge et al.  1997a), reduced quality of willow flycatcher habitat (Taylor 1986, Sanders and Flett 1989) reduced nest productivity (Johnson 1999), and nest failure due to direct impacts by cattle (Stafford and Valentine 1985, Valentine et al. 1988). In light of these considerable impacts cattle have on riparian areas in the southwest, the original petition to list the SWF stated that, “grazing of domestic cattle is probably the single greatest direct and indirect threat to southwestern willow flycatcher habitat” (Suckling et al. 1992).


SWFs are riparian obligates (Paradzick et al. 2000)and require a diverse combination of over - and under-story vegetation (Hubbard 1987).  Taylor and Littlefield (1986) also detected a correlation between Empidonax tralii abundance and riparian habitat heterogeneity.  Knopf et al. (1988) detected a similar correlation, and primarily attributed reduced abundances of sensitive riparian passerines to the impact of cattle on the horizontal patterning of the vegetative community.   When willows are “notched” or “highlined” by cattle, they become top heavy with live branches above, with few remaining below.  Serena (1982) noted this condition in otherwise suitable habitat in southern California where willow flycatchers were conspicuously absent.  


The evidence that cattle grazing reduces SWF numbers is irrefutable.  In southern California, Harris et al. (1987) noticed that SWF numbers increased by 50% during a 5-year period in which The Nature Conservancy acquired the area and greatly reduced the intensity of cattle grazing.  And SWF appeared on the Brock Canyon allotment in the Gila National Forest the second year after cattle were removed (Suckling et al. 1992).  In southeastern Oregon, AUMs on a test plot were steadily lowered from 1973 to 1982, resulting in SWF presence at the site only at the end of the experiment when AUMs had declined by a factor of four (Taylor and Littlefield 1986).  In fact, many of the locations where SWF still occur (i.e. Rio Grande Conservancy land outside Albuquerque, the New Mexico Game and Fish wildlife enclosure, Grand Canyon National Park), are areas from which cattle have been excluded or dramatically reduced.


Livestock grazing can also increase parasitism by brown-headed cowbirds (Molothrus ater) (Kimball 1993), an exotic nest parasitizer that has been shown to be a factor in willow flycatcher nest failure (Whitfield 1990,Sogge et al. 1997b, and Sedgewick and Iko, unpublished manuscript) and population declines (TWP 2000).  Brown-headed cowbirds, formerly associated with bison (Bison bison), are now followers of cattle and are attracted to the grass stubble they leave behind (Suckling et al. 1992).  Not only do cattle bring cowbirds into riparian areas, they can increase fragmentation of willow habitat, thus creating more edge habitat that makes SWFs susceptible to cowbird parasitism. 


The Monument has already acknowledged the impact of cattle grazing to the SWF;  in the recent EAs that analyzed whether it was appropriate to retire AUMs on a handful of Monument allotments, the Monument staff wrote, “habitat [for SWF] and change has occurred because of…..livestock grazing” (BLM 2002a p.15, BLM 2002b p. 13). Threatened/Endangered plants in Utah:  While most research attention usually focuses on federally listed animal species, its important not to discount the adverse effects of cattle grazing on threatened and endangered plants in southern Utah.  Southern Utah contains far more T/E plants than one would expect.  This is partly the result of intrinsically high rates of endemism in the Colorado Plateau due to climate, the intersection of different ecological provinces on the plateau, and distinctive geologic formations and substrates (Welsh 1978).  This results in very small populations of unique plants that have evolved in relative isolation and are adapted to specific habitats.  There are nine federally listed (or candidate) species known or suspected to occur within the Monument’s boundaries (BLM 1998).


One reason for the preponderance of T/E plants in southern Utah is high intrinsic rates of endemism; the other is that the habitats for these plants have been threatened by many human activities.  One of these activities is cattle grazing.  With ranges as narrow as those occupied by these rare species, it is conceivable that a whole population of the rarest species could be decimated if it existed within one or two poorly placed or overstocked grazing allotments.  Detrimental impacts of cattle grazing have been documented on Townsend’s aprica (Townsendia aprica), Wright’s fishook cactus (Sclerocactus wrightii), and Winkler’s pincushion (Pediocactus wrinkleri) cactus in Capitol Reef National Park (San Juan College 1994).  These impacts primarily consisted of death and damage to plants due to trampling.  While trampling may not necessarily kill plants, it often destroys the meristem, and the plant fails to produce flowers, fruit, and seeds.  The highest percentage of damaged T/E plants in Capitol Reef were found near water sources.


3.3.4 Summary: livestock grazing impacts.  In closing, we wish to call to the DEIS staff’s attention that the above impacts to resources in the Monument (illustrated in Sections 3.1 and 3.2) reflect actual use on GSENM allotments – not permitted use.  This is significant in that it illustrates that these effects are triggered by lower numbers of cattle than are often permitted.  As the Monument staff takes a comprehensive look at the current conditions in GSENM and what might be causing impairment, they need to keep in mind that the determinations, analyses, remedies and future proposals of grazing levels  must be carried out at the level of actual use – not permitted use.  We discuss this problem further, later in this chapter.





3.4  Limitations in Monitoring/Data Collection and Range Health Assessment Methods and How they are Applied and Analyzed. 


As the Monument writes the DEIS, it is instructive to not only look at the most obvious cause of resource degradation: livestock grazing (or grazing combined with other factors like drought and poor soils), but to also consider the various tools and methods the BLM utilizes to set stocking rates, track cattle numbers, measure utilization and trend, and monitor and assess rangelands.  One of the current problems with the Monument’s grazing program (and the impacts to the resources that result) stem from problems we perceive in monitoring, data collection and range health assessment methods and how they are applied and results analyzed.[14] 


3.4.1  BLM’s methods for tracking cattle numbers and actual use.   Far too often, it seems that the BLM does not know the exact number of cattle on the range at a given time.   Direct observation by the authors in a few cases has revealed what may be a serious problem should this situation exists in more allotments.  Rancher reported grazing use (actual use reports described by the permittee) appears to be higher than what is actually used.  Rarely does the agency directly count livestock on the land. This practice can result in more grazing use reported than actually occurs.  This in turn can distort the grazing management analysis and lead to incorrect estimates of allowed stocking levels.  We hope to work with BLM to make the “actual use” more accurately report rancher grazing use.

One of the key issues in grazing management concerns stocking levels.  As part of the grazing EIS, it is important to report the process that was used to establish today’s level of grazing use.  This may require presenting a history of adjustment dating back to when the stocking level was first determined.  The DEIS must also provide information about how often stocking rates and seasons of use have been increased or decreased in the past, why they were changed, and what impact these changes had on utilization and ecological condition.   Livestock must be removed as soon as it is determined that minimum stubble heights/maximum utilization levels are being approached, regardless of calendar date or length of time on allotment. Any protocol that does not provide for frequent assessment of utilization and rapid adjustments of stocking rates is not designed to protect the habitats. 


3.4.2  Adequate grazing capacity analysis.  Levels of livestock use on BLM lands today may or may not have been determined as the result of a range capacity analysis.  The record is unclear on the basis for today’s stocking levels.  Where such capacity analysis was performed, such analysis was not consistent with today’s rangeland health policy and did not consider the ecological needs of the land.  In some cases, the stocking level may have been derived without capacity analysis.  In these cases, stocking levels represents ongoing adjustments that date back to the initial adjudication under the Taylor Grazing Act more than six decades ago.


Past grazing capacity analysis focused on sustained forage production.  As a result, this method did not consider key ecological factors such as plant community composition, excessive grazing use in key habitats such as riparian areas, soil nutrient cycle maintenance, and nongame wildlife needs.  For the past twenty years, BLM has not used forage capacity analysis in determining stocking levels.   This must change as BLM implements the new rangeland health standards developed six years ago.  The standards call for management of grazing in deference to the health of ecosystems.  Ecosystem health is linked to the productivity of the land and its ability to service local communities on a sustained basis (CSC 1997).  The loss of biodiversity, and ecosystem structure and function, has long-term implications for the health of watersheds and the ability of the land to provide abundant forage for a number of uses.  BLM needs to undertake forage capacity analyses that will allow the standards to be met, restore and maintain ecosystems, and provide for ecosystem resilience that maintains the productivity of the land over time.


BLM’s need for forage capacity analysis as part of the upcoming grazing EIS for the GSENM is justified by community needs, agency policy (both current and proposed), rangeland science, and the agency’s legal requirements.   Such an ecologically-based forage capacity analysis is timely because grazing capacity has not been systematically reviewed for GSENM allotments for at least two or perhaps four decades.  BLM is required to periodically adjust management decisions based on ongoing inventories, and this DEIS will be renewing permits for most, if not all, grazing allotments in the Monument.  Furthermore, range capacity based on ecological needs was raised as a significant issue in the GSENM grazing EIS.  BLM has a legal requirement to consider this issue as part of the EIS and set new stocking rates based on a sophisticated forage capacity model.


3.4.3  Range condition, and trend, concept. Range condition trend measurements should describe the changes in range condition over time.  Range condition is defined by the Public Rangelands Improvement Act (PRIA) of 1978 (PRIA 43 USC 1901 et seq.) as “the ability in specific vegetative areas to support various levels of productivity in accordance with range management objectives and the land use planning process, and relates to soil quality, forage values (whether seasonal or year round), wildlife habitat, watershed and plant communities, the present state of vegetation of the range site in relation to potential plant community for that site, and the relative degree to which the kinds, proportions, and amounts of vegetation in a plant community resemble that of the desired community for that site” (Coggins, 1984).


                        We believe there is a problem with the way the BLM carries out typical range condition assessments.  BLM limits its assessment of range condition to an analysis of plant community composition as expressed in the percent of each species of plant at a monitoring site, and a comparison of those values to potential community composition of the site.  This is a reasonable approach, but can backfire in communities, such as Pinyon-Juniper, which have naturally very low levels of grasses and forbs.  PJ communities are often ranked high in terms of range condition, even though grasses and forbs are usually well below their potential.  This happens because the potential grass/forb cover of PJ communities is usually only a small percentage of the total plant community composition.  If all grass and forbs are removed from the site, the condition assessment will still find that the shrub and tree component are well within expected range (say, comprising over 90% of all plants on the site, as one might expect) and so the site is considered in good or excellent condition.  What we find is the BLM’s range condition assessment method can seriously under-report impaired PJ rangelands.


                        There are a number of different methods for measuring trend, but each depends on counting the number of plants of each species along a series of transects or in a series of sample quadrants.  The BLM identifies “key” or “decreaser” plant species (desirable native forage species that are susceptible to depletion if grazed too heavily) and “increaser” or “invader” species (less palatable or toxic plants that increase in abundance in response to grazing).  Range condition trend is considered “upward’ or “improving” if key species are increasing in abundance relative to increaser or invader species, “downward” if key species are decreasing, and “stable” or “static” if the species composition of the rangeland is not changing significantly.


                        There are a number of problems inherent in the use of such trend measurements (Feller and Brown 2000).  First, trend studies are designed only to detect changes in rangeland condition from the “status quo” at the beginning of the study period.  They do not reflect the extent to which that status quo itself may be a result of drastic grazing-induced ecological changes that occurred before trend studies began.  A “stable” trend may simply reflect a system that has reached rock-bottom. Second, BLM trend studies do not directly measure soil compaction, erosion, or loss of soil nutrients.  These effects may be reflected in trend measurements only when they have progressed to an advanced stage, at which time it may be too late to take corrective action.  Third, BLM trend studies typically utilize only a handful of sample sites to monitor trends on an allotment that may be tens or hundreds of thousands of acres in size.  The use of such a limited number of sample locations presumes a degree of spatial uniformity, so that the trend at the monitoring station may be used to infer the trend over a much larger area.  This presumption is generally not valid, as livestock grazing impacts typically vary dramatically across an allotment depending on distance to water, terrain features, slope, soil type and livestock movement (Feller and Brown 2000). 


                        Finally, trend studies do not meet the monitoring requirements established by PRIA (outlined above) to assess “the kinds, proportions, and amounts of vegetation” in relation to the potential or desired plant community.   In particular, BLM limits its assessment of range condition to an analysis of plant community composition as expressed in the percent of each species of plant in a community. Such an analysis makes no determination on the productivity of the site. Thus a site with seven species of plants producing 150 lb per acre of forage a year would have the same range condition as another site with seven species of plants producing 1,500 lb per acre of forage a year, as long as the relative percentage of those seven species were the same for each of these example sites.  As addressed elsewhere in this guidance document, the failure of the BLM to adequately measure productivity of the vegetative community can be seen at many levels of monitoring and range management, and is a requirement required by law.


3.4.4  inconsistencies found in PFC and rangeland health assessments.   Many of the rangeland health assessment methods and monitoring tools are in danger of being used subjectively and/or misapplied, due to the often unstructured character of the monitoring or assessment methods.  For example, with BLM’s PFC assessment protocol for riparian areas,a significant problem with the method is how the individual yes/no ratings translate into a final rating of PFC, FAR, or NF.  The present checklist items are answered with either a “yes,” or a “no,” without quantitative reference to conditions on the ground.  Moreover, the PFC technical manuals provide no clear instruction to field staff on how to answer difficult checklist items consistently.  The current assessment procedure’s leaves much room for subjective judgment. The linkage between indicator conditions and the final rating is not described clearly, and the technical manuals provide insufficient guidance on how to use “yes” and “no” answers with other information to establish a final rating. This inherent subjectivity built in to the PFC assessment procedure can lead to under-reporting of problem areas.


3.4.5  Utilization measurements. Currently, utilization measurements made by the BLM are based on forage species that represent the most dominate perennial grass. Unfortunately, species most at risk are not measured.  Both the sample sizes used in measuring these variables, and the intervals of sampling, are usually inappropriate.  Moreover, measuring utilization of key forage species does not tell you anything about the overall amount (biomass) of forage that is eaten, or left standing.  As a result, utilization monitoring, as has been practiced, does not show changes in forage productivity over time.


                        Perhaps the biggest concern we have concerns the utilization rates that the BLM believes the forage can withstand.  This topic is discussed in more detail on pg. 8 of our “Making Determinations” segment (Appendix A) but, in short, the range science literature tells us that typical utilization levels of about 50% are responsible for significant resource damage across the Colorado Plateau.  In the Monument, BLM has typically set utilization levels at around 50%.  Actual utilization data recorded by BLM shows that actual utilization levels routinely reach and often significantly exceed these permitted levels. 


The standard 50% utilization standard, developed from research on root-growth stoppage as a result of grazing (Crider 1955) and sometimes known as the “take half and leave half” policy, is inappropriate for the Colorado Plateau.   Crider grew several Midwestern perennial grasses under ideal precipitation conditions and monitored root growth changes due to clipping over a period of two months.  Crider concluded that root growth at the end of the growing season was not impaired when a single clipping removed 50% or less of the above ground biomass under these ideal conditions for these particularly robust Midwest perennial grasses. 


The ecological needs of the land were not analyzed by Crider.  Plant regeneration, wildlife habitat structural needs, soil nutrient generation, plant community composition change over the longer term, ecological events (e.g. drought) are a few of the factors not considered in the take half leave half policy.  In short this utilization standard is inconsistent with both the goals of the Monument and rangeland health standards. As a result, range scientists have concluded that there is no scientific basis behind BLM’s policy for utilization (Caldwell 1984).  Still, allowable utilization rates of 50% seem to dominate AMPs in the intermountain West.


That utilization levels of 50% will cause significant damage to ecosystem values is bourn out by the range science literature.  For example, in their well-respected range management text, Holechek et al. (2001), summarize multiple long-term studies analyzing utilization, or grazing intensity, and its impact on forage production.  Holechek and his colleagues determine, that while acceptable use ranged from 40% to 60% on productive rangelands, acceptable rates ranged from just 30% to 40% on more arid rangelands, such as those found on the Colorado Plateau.  Moreover, the authors caution that only arid and semi-arid “[r]anges in good condition and/or grazed during the dormant season can withstand the higher utilization level [of 40%]” while those “in poor condition or grazed during active growth should received the lower utilization level [of 30%].  (Holechek et al. 1998, p. 206).  In yet another meta-analysis of grazing studies, Holechek concludes that “moderate” utilization levels of 50% “results in rangeland deterioration in semi-arid grasslands, desert and coniferous forest rangelands” and heavy utilization rates of 57% “consistently cause a downward trend in ecological condition” in all areas. Holechek et al. (1999, p. 13). 


Cook (1971) determined that, to maintain plant vigor and reproduction, utilization should be limited to 25% on plants grazed every spring.  He found that 50% spring utilization is acceptable only every other year and only if the plants receive complete, year-long rest in the alternate yearsAnd Galt et al. (1999) recommend a lower or utilization rate of 35% for arid areas.  Importantly, they also point out that actual measured use is generally higher than the intended use.  For example, on New Mexico rangelands, actual measured use was 10-15% higher than intended due to livestock trampling, wildlife use and weathering.  Ultimately, the authors recommend assigning 25% of forage to livestock, 25% to wildlife and natural disappearance and 50% to site protection, concluding that the 25% utilization rate is the “surest way to avoid chronic forage deficits and land degradation” for arid areas. 


            In the Monument, utilization rates – typically at 50% – are above appropriate levels.  Moreover, these rates do not take into consideration critical factors such as grazing during the growing season, the condition of the range, or that actual use is higher than intended use.  Examples bear this out.  The 1983 AMP for the Upper Cattle Allotment, which implements a deferred rotation grazing scheme, allows utilization levels to reach 60% from November 1 to April 15, and 50% during the growing season from April 16 to June 15.  The AMP allows these high utilization levels despite BLM determination that 72% of the allotment was in poor to fair condition, and findings of soil erosion, overstocking, and poor cattle distribution.  Recent BLM records show that high utilization of the Upper Cattle Allotment has continued – often exceeding 50% to 60% levels.  Thus, utilization levels on this allotment not only exceed the 30% levels Holechek recommends for poor condition semi-arid range or range grazed in the growing season, but also surpass the 40% utilization levels he considers appropriate for only arid lands in good condition, grazed in the dormant season. 


            Management of the Lake Allotment similarly allows an untenable utilization level of 60%.  This level was set in 1989 despite findings that 58% of the allotment was in poor condition, 17% in fair condition, 24% unsuitable for livestock and only 1% in good condition.  The BLM also found riparian areas being utilized on average 85-90%, active erosion throughout the allotment, poor livestock distribution, and poor condition of wildlife habitat.  Again, record data shows excessive utilization levels on this allotment.  BLM’s 1997 allotment evaluation notes indicate that riparian vegetation had disappeared from some areas, and from1989 to 1996, utilization of riparian areas was 95%.  More recent data establishes that significant overuse of uplands and riparian areas on this allotment have continued.  Thus, both the permitted utilization and the actual utilization on Lake Allotment greatly exceeds Holechek’s recommendations and fails to take into consideration growing season and the condition of the range.


Across the Monument, the story is the same. As a rule, the BLM does not condition permitted utilization levels based on Holechek’s findings and does not accommodate growing season or the condition of the particular allotment.  Moreover, GSENM’s own utilization data confirms that the Monument is routinely overgrazed.  Out of 1,943 records showing recent utilization levels on key plants, 946 (or 48.6%) of these show utilization levels of 50% or greater, with many cases of utilization rates of 85% and above.



3.5  Grazing Management and its contribution to habitat change


In addition to concerns with various range assessment and monitoring tools and how they’re applied, certain practices in grazing management conducted in the Monument (such as season of use stipulations, and rotational grazing), can also help lead to some undesired habitat changes.


3.5.1. Grazing during the growing season.  The scientific literature generally concludes that allowing livestock to graze during the growing season is detrimental to the vegetation and soil communities of arid and semiarid climes, such as that of the Colorado Plateau.  Therefore, where grazing is allowed during the growing season, use levels or stocking levels must be reduced appropriately to account for the additional loss of annual biomass growth that is lost due to growing season grazing.  However, in the Monument, BLM more often than not allows spring grazing to occur, and does so without reducing use or stocking levels. 


It is generally established by the scientific literature that livestock grazing during the growing season reduces net annual biomass production and thus increases the likelihood of compromised health of range ecosystems of the arid West (Holechek et al. 2001).  Grazing up to the period of flowering may prevent plant recovery and seed generation (Heady 1984).  While there is evidence that grazing during the growing season can lead to some compensatory growth in plants that co-evolved with large, hooved ungulates, grazing is damaging to vegetation of the intermountain west, especially during the growing season (Painter and Belsky 1993, and references therein).   For example, spring grazing has been shown to increase mortality of certain species of sagebrush (Chambers and Norton 1993), which is a species that has been in considerable decline in Utah. 


The dominant grasses in sagebrush-grassland, being cool-season types, complete their growth during spring when soil moisture is highest from the over-winter accumulation of snow.  These plants are susceptible to grazing damage during their active spring growing period due to depletion of carbohydrate reserves, loss of seed pools and ultimately loss of the plant entirely.   In lower elevation salt-desert shrub communities, with little vegetation growth during dry years, spring grazing can deplete the herbaceous plants and without summer precipitation, no regrowth can occur.  In pinyon-juniper communities, with a mixture of warm- and cool-season grasses, spring grazing has been detrimental to the cool-season grasses.  This has resulted in increased juniper canopy with loss of the perennial grasses and forbs (Holechek et al, 2001).  


A study carried out 1963 by Cook and Stoddart studies the effects of intensity and season of use on the vigor of desert range plants.   They studied the effects of different times and intensities of simulated grazing on desert forage species.  It was concluded that desert ranges are best adapted for winter grazing, with springtime being the worst time to graze(Cook and Stoddart 1963).  In another study on the topic of spring grazing by livestock, Hann et al. (1997) concluded that spring grazing does not provide for successional advancement of riparian vegetation. 


            These conclusions are echoed by the BLM in the Management Framework Plan for the Escalante Resource Area.  The agency found that “[t]he most damage [from grazing] occurs when plants are grazed during the growing season[,] which reduces the amount of food made and stored by the plant.”  (MFP, Recommendation RM-1.1).  Indeed, the BLM confirmed that “[c]ontinued grazing each year during the growing season can severely weaken or kill the plants.”  As a result, BLM recommended that, with some exceptions, that the period of use on the Escalante allotments be changed so that grazing is not permitted during the growing season. 


By far the most compelling reason to foreclose grazing in the spring is the damage that livestock cause to moist and wet soils.  The pressure from livestock hooves, especially cattle, easily compacts soil in the spring when the soil is wet and most vulnerable to compaction (Brady 1984, Warren 1987).  Fine textured soils or those with inorganic crusts are particularly susceptible when wet (Webb and Wilshire 1983).  


Of even more concern is the effect of livestock trampling on the rare and ecologically important cryptobiotic soil crusts in the arid West.   Crusts are only metabolically active when wet (Belnap et al. 2001.).  Winter use by livestock has been shown to have less of an impact on crust cover and species composition than spring use (Belnap et al. 2001).  In a study of livestock grazing impacts on cryptogamic crust communities, Marble and Harper (1989) found that grazing in late winter and into spring reduced cryptogamic cover and species richness.


Spring grazing can also be deleterious for various soil-related variables such as streambank morphology and erosion potential.  Grazing stream banks during spring when soils are wet or saturated can lead to hoof shear and compaction, resulting in greater stream bank erosion and sedimentation (Trimble and Mendel, 1995; Clary and Leininger 2000).  Lusby (1979) demonstrated in western Colorado that early winter grazing results in less runoff and erosion than continuing grazing into spring.


Despite consistent findings that grazing during the growing season degrades various ecosystem values, grazing practices in the Monument do not sufficiently curtail spring grazing. Currently, 46 out of 76 allotments (over 60%) are grazed during some part, or all, of the growing season.  Moreover, as stressed above, the Monument does not predicate spring use on light utilization level, contrary to the recommendations of Holechek and others. 


3.5.2. Rest - Rotational grazingeffectiveness is questioned.   Most commonly, rest rotation, as a standard BLM prescription, implies a one or two year rest for a pasture.  In some cases, rest can mean a reduction of the length of grazing or shift in the time of year of grazing.   As described below, here is a growing knowledge that rest for such short periods, especially for rangelands that fail to meet rangeland health standards, is not effective. 


While many livestock growers advocate the use of special grazing management, such as rotational grazing, as a tool to moderate or ameliorate grazing impacts, the scientific literature is very divided regarding the benefits of these practices as traditionally practiced.  In fact, there is evidence that the use of some of these management methods can actually worsen the condition of pastures.  Holechek et al (1999) demonstrate the ineffectiveness of rotational grazing systems in improving rangeland conditions, as this paper reviews dozens of studies that show such systems are generally ineffective. In his range management text, Holechek and his colleagues explain that deferred-rotation and rest rotation grazing schemes have not been found to have an appreciable benefit to resource conditions when compared to continuous grazing.  In analyzing the former grazing scheme, the authors note that on flat sage brush and shortgrass rangelands, the scheme results in no vegetation benefits when compared to continuous or season-long grazing.  Along the same vein, the authors also conclude that “[o]n flat arid and semiarid rangelands, deferred-rotation grazing has shown no advantages over continuous grazing.”  Holechek et al. (1998, p. 238).


Moreover, Clary and Webster (1989) report that numerous hydrologic studies have upheld the conclusions of Blackburn et al. (1982), who stated that little information supports claims for specialized grazing systems.  In a review of recent studies, Pieper and Heitschmidt (1988) found no results to suggest that the application of short-duration grazing has a different effect on hydrologic performance and soil characteristics than does any other grazing system.  They concluded that heavy stocking would result in long-term downward trend in hydrologic characteristics and that vegetation growth response in a short-duration grazing system is similar to that expected from any other grazing system.  They suggested that stocking rate is and always will be the major factor affecting the degradation of rangeland resources. 


            Moreover, while rest periods arguably may allow the marginal recovery of individual plants, rotation schemes cannot mitigate the loss of vegetative cover that provides soil protection, thermal regulation, nor can these schemes mitigate water absorption and retention, or the alteration of plant competitive interactions that results from removal of biomass by grazing.  These conclusions are echoed in a 1989 Forest Service paper that concludes that short duration livestock grazing has no different effect on hydrologic performance and soil characteristics than any other grazing system. “[H]eavy stocking would result in downward trend in hydrologic characteristics and  vegetation growth response in a short-duration grazing system similar to that expected from any other grazing system”  (Clary and Webster 1989, pg 6).  In sum, they noted, “no grazing system can counteract the negative impacts of overstocking on a long-term basis.”



[1] Lentic and lotic PFC assessments were conducted by Monument staff between 1993 and 2002

[2] The upland assessments used in this DEIS were performed by GSENM staff between summer 2000 and December 2002.

[3]Lentic PFC assessment sites were assessed by Monument staff between 2000 and 2002

[4] Lotic PFC assessment sites were assessed by Monument staff between 1993 and 2002

[5] See our “Problems with Monitoring” section later in this chapter, and pg 8 (section 3.1.1) of  Appendix A,for more discussion on this topic

[6] These results were presented by Stevens et al. to the Monument in May of 2002 in a report entitled “Riparian ecosystem evaluation: a review and test of BLM’s Proper Functioning Condition assessment guidelines.” The most recent version of this manuscript, in review with Journal of Ecological Restoration, can be found inAppendix C.

[7] One of the authors has conducted an extensive literature review on the effects of cattle grazing in the arid West, with a discussion of the implications for BLM grazing management in southern Utah.  This literature review has been made available to some members of the Monument staff who are assembling the Grazing DEIS.  We recommend that Monument staff borrow liberally from this literature review in their preparation of the DEIS.  Please contact the authors if you would like to receive an additional copy of this comprehensive literature review, entitled “Review and analysis of cattle grazing effects in the arid west, with applications for BLM grazing management in southern Utah.”

[8] See our “Making Determinations” section (Appendix A, pg 39) for more discussion on this topic

[9] See Chapter 4, section more discussion on this topic

[10] The precipitation data for the period of record in the Monument is evidence that droughts are very common in this part of Utah (see Appendix B, Section 3.1.6,page 20 for more discussion on precipitation data in GSENM). 

[11] Another model developed by USFS (called WEPP) also models sediment and runoff on both rangeland and forested systems.  WEPP can be accessed on-line at: http://forest.moscowfsl.wsu.edu/4702/wepp0.html and is being developed by an interagency group including the USFS, Agricultural Research Service, NRCS, BLM and USGS to develop WEPP in order to replace the Universal Soil Loss Equation (USLE).

[12] EPA also has methodologies for calculating wind erosion.  One of these can be found at:  http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s02-5.pdf which is typically applied in calculating emissions for wind erosion for purposes of permitting industrial facilities. 

[13] This method is for cropland rather than rangeland.

[14] While we stress that we don’t believe all BLM monitoring to be inadequate, by any means (indeed, it is often the only information available on which to base management decisions), existing monitoring data often understate the extent of the problems on BLM rangelands.