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BLM must undertake several detailed analyses to comply with its statutory and regulatory duties.  The agency must determine, based on an understanding of the scientifically documented impacts of livestock grazing on ecological, archeological and recreational resources, and on the principles of multiple use management, 1) whether grazing allotments are meeting the standards and guidelines, 2) whether livestock is the cause for lands not meeting rangeland health standards;  3) which Monument lands are capable of supporting livestock grazing;  4) which lands are appropriate or suitable for livestock use;  5) on those lands that are capable and suitable for grazing, the BLM must determine the forage base, or capacity, of the allotment and set refined stocking rates based on an ecological “forage capacity model,” and 6) determine whether habitats are functioning for threatened, endangered and sensitive species. 


At the same time, BLM must respond to the findings of these analyses.  Where livestock grazing is a significant factor in the failure of an area to meet rangeland health standards, the agency must make adequate changes to grazing management to achieve these health standards and must make these changes before the start of the next grazing season.  Lands that the agency deems are not capable of supporting livestock grazing must be closed to grazing or should not be deemed available for grazing in calculation of stocking levels.  Similarly, lands that are more appropriate for uses other than livestock grazing should be closed to grazing.  Moreover, where BLM allows grazing, the agency must still manage grazing in keeping with multiple use objectives and so as to serve best the interests of the American people. 


We conclude this chapter with recommendations on management prescriptions that tie in to BLM’s rangeland health standards and to the Monument’s Management Plan.  These include generic prescriptions that should be in place, both for allotments that meet the standards, and those that do not.  We also recommend prescriptions that are triggered in times of drought, and give suggestions for more effective monitoring.  Below we outline the analyses and remedies must be in place in the Grazing DEIS if it is to conform to the applicable statutes and regulations.


4.1 Completing evaluations


When conducting evaluations of whether pastures are meeting the standards and guidelines, it's important to follow the guidance found in H-4180-1 (Manual for Rangeland Health Standards), as closely as possible.  Chapter III provides fairly thorough guidance on how the Evaluation process should be executed.


As the BLM evaluates pastures, for each standard in the USGHR the BLM should specify (1) what indicators will be used to evaluate the standard, and (2) what the decision-threshold values are for that indicator in relation to that standard.  For example,


At the same time, Evaluations must be carried out in accordance to the stipulations in the GSENM Management Plan.   For example, there will be cases where a particular site meets rangeland health standards but does not meet Management Plan objectives that are more stringent.  Clark Bench is a great example of this (BLM 2002a).  In fact, and from a legal standpoint, “Management-Plan evaluations” should probably be a component separate from Rangeland Health evaluations.  


Continuing on this approach, Part c of Standard 1, Part b of Standard 2 and Part d of Standard 3 state that the presence of the "desired plant community" identified in the Land Use Plan is a pertinent indicator for evaluating Standard 1, Standard 2 and Standard 3.  While the GSENM Management Plan does not specify a desired plant community for every site in the landscape, it follows logically from Plan decision VEG-00 (Monument Plan, pg. 22) that the desired plant community is the "potential natural community" reflected in the appropriate Ecological Site Description.  The Clark Bench Buy-out EA and other permit-buyout EAs provide precedent for this interpretation of VEG-00 (BLM 2002a, 2002b).


We assume Evaluations will be done on the basis of management units.  The BLM must specify the minimum amount of failed area (i.e., acres, NOT percentage) that triggers a failure for the entire management unit.  Moreover, this threshold-area value could vary depending on the "significance" of the failed ecological site.  For example, in many allotments, sagebrush sites are relatively minor components of the landscape, but they are highly "significant" from a resource perspective (sagebrush habitats are dramatically declining across the West) and they are almost uniformly degraded.  Other "significant" sites are those which provide habitat for edaphic endemics or other sensitive taxa.  ALL wetland and riparian areas are "significant" - so failure of any of these should trigger failure for the management unit.


4.2  Make determinations of what is causing areas to be Functioning at Risk or Not Functioning. 


BLM must determine whether grazing is the cause of degradation when rangeland fails to meet BLM’s rangeland health standards.  We present a method for complying with this obligation in Appendix A. [1]  This method, which we term a “determination assessment,” offers a systematic, repeatable, and legally defensible tool to assist BLM in meeting its obligations under the and the Management Plan and the Fundamentals of Rangeland Health and Standards and Guidelines for Grazing Administration, 43 CFR § 4180.  To this end, we draw upon expert experience and peer-reviewed science to outline a procedure for determining whether current grazing use or management is a significant factor that causes specific livestock grazing allotments or pastures to be classified as non-functioning or functioning at risk with a downward trend, and therefore not meeting BLM’s rangeland health standards.


The determination method described in Appendix A was developed to rely as much as possible on existing data, requires few agency resources, can be consistently replicated, is based in simple observable evidence, and requires technical expertise common to land managers and experienced members of the public.  


In keeping with the structure and approach common to other BLM ecological assessment processes, the determination method presented in Appendix A employs the indicators used in BLM’s upland and riparian rangeland health assessment methods that describe livestock-related conditions of  ecosystem health.  The determination process is based on the significance and number of these indicators that document a failure to meet rangeland health standards.  The methodology is further designed to establish when, by a preponderance of the evidence, grazing is a significant factor in the failure of an area to support healthy ecosystem conditions, as required by 43 CFR § 4180.



4.3.  Capability assessment[2] – determining whether lands can sustain livestock grazing.


Among its other obligations, BLM must determine: 1) if public lands are capable of supporting livestock; and if so, 2) the carrying capacity of the lands.  The first of these obligations comes from FLPMA’s multiple use mandate which, as we have previously detailed, requires BLM to manage public land resources in “the combination that will best meet the needs of the American people.”  This, in turn, requires BLM to weigh the relative benefits and harms of allowing livestock to graze a particular area.  Part of this analysis must be to determine if an area can support and sustain livestock grazing.  If it cannot, there is no benefit that stems from use for livestock and dedicating the land to other uses will almost necessarily be warranted. 


The second obligation comes from BLM’s management obligations relative to grazing permits.  Under these regulations, each grazing permit must include terms and conditions specifying the “kind and number of livestock, the period(s) of use, the allotment(s) to be used, and the amount of use, in animal unit months . . . .”  43 CFR § 4130.3-1(a).  Importantly, “[t]he authorized livestock grazing use shall not exceed the livestock carrying capacity of the allotment.”  Id.  BLM defines “livestock carrying capacity” as “the maximum stocking rate possible without inducing damage to vegetation or related resources.”  43 CFR § 4100.0-5.  Thus, grazing permits must reflect whether lands within an allotment cannot support livestock grazing and therefore have no or de minimus livestock carrying capacity.  Stated another way, the livestock carrying capacity of any given area must take into consideration that part or all of the area is incapable of sustaining livestock use.


Several factors –  slope, soil stability, forage production, and distance from water – are relevant to determining whether an area, or portion of an area, is capable of sustaining livestock use.  Conditions relative to each of these factors must be present in order for an area to be capable of supporting livestock use.  In other words, to support livestock use, an area must be characterized by slopes of less than a certain angle, soils of a certain stability and forage production a minimal value, and the area must be within a certain distance from water. 


It is also important not to treat allotments as indivisible units.  Within a single allotment may be areas capable of sustaining livestock use and areas that are not.  For this reason, the carrying capability of different portions of the allotment may vary, and the grazing permit must accurately reflect this.  Moreover, where an allotment is predominantly incapable of supporting grazing, eliminating grazing on the entire allotment is appropriate, particularly if areas incapable of supporting livestock use, for example, because of unstable soils, must be protected by fencing. 


4.3.1 Capability Factor 1: SlopeCattle prefer “convenient” flat areas, such as valley bottoms, riparian zones and ridge tops, over rough, steep or rugged areas.  Holechek et al. (1998).  The slope of rangeland dictates not only the ease of access by cattle but also the probability of soil erosion due to disturbance.  If stocking rates do not reflect these realities, as Holechek asserts, the result will be “considerable range degradation.”  Id.  For this reason:


Only areas characterized by slopes less than 30%are capable of supporting livestock grazing. 


4.3.2. Capability Factor 2: Soil Stability.  BLM has repeatedly emphasized that grazing has tremendous adverse impacts on soil stability.  These impacts are described in detail in Chapter 3.  As a result, livestock use on highly erodible soils (e.g. decomposed granite in the arid Southwest) will exacerbate soil loss to an unacceptable level.     


The Natural Resource Conservation Service (NRCS) has surveyed soils in many regions of the country, mapping their location and providing an erosion hazard index.  These designations should be the basis for determining if the soil stability of an area is sufficient to support livestock grazing.


Areas with soils that have a high erosion hazard, and/or unstable or highly erodible soils (as defined by NRCS) should be identified as not capable of supporting livestock grazing.  Those with moderate hazard should be analyzed for slope angle and other factors that exacerbate erosion.


4.3.3 Capability Factor 3:  Forage Production.  Rangelands need to produce a minimum amount of forage in order to be capable of sustaining livestock use.  Recognizing this reality, the Forest Service determined that an area is capable of supporting livestock only if it produces more than 200 pounds of forage per acre.


The Kanab-Escalante Grazing EIS sets minimum forage production at 19 kg/ha.  Because this number represents half of the amount of forage that must be present to support a cow over 40 acres, it represents the absolute minimum forage production for the present inquiry.


Only areas with more than 19 kg/ha of air-dry forage biomass are capable of supporting livestock grazing.


4.3.4. Capability Factor 4: Distance from Water. As Holechek and his colleagues establish, “cattle make little use of areas farther away than 3.2 km (2 miles) from water.”  Holechek (1998, pg. 209).  Particularly in a climate such as that of the Colorado Plateau, ignoring this critical fact, the authors conclude, has been highly detrimental to resource conditions:  “Failure to adjust stocking rates for travel distance to water has resulted in considerable range degradation, particularly in the hot, arid rangelands of the southwestern United States . . ” Holechek (1998, pg. 209).  Only in the winter, when there is snow on the ground or water in pot holes, will water availability cease to be a limiting factor in livestock distribution.  Holechek et al. (2001) recommend that areas more than two miles from water not be considered capable of supporting livestock.


If grazed in the spring, summer, or fall, areas must be within two miles of water to be capable of supporting grazing.  


4.3.5 ConclusionIn sum, only areas that meet each of the conditions specified above are capable of supporting livestock.  In areas that are not capable of  supporting livestock, grazing is not an appropriate use under FLPMA’s multiple use mandate.  Where an area is pocketed with areas incapable of sustaining livestock use, BLM must base carrying capacity and stocking levels on only the portion of the area that can support livestock use.  To calculate capacity and stocking levels otherwise will lead to impairment of production and environmental values and will run afoul of BLM’s statutory and regulatory responsibilities to accurately determine carrying capacity, to manage the lands in a way that best meets the needs of the American people, and to protect and restore ecosystem values.



4.4.  Suitability -- determining whether grazing is appropriate use of particular lands.


This section presents a method that fleshes out the “decisionmaking process” BLM must undertake to comply with FLPMA’s multiple-use mandate.  National Wildlife Fed’n v. BLM, 140 IBLA 85, 101 (1997) (“Comb Wash”).   We set forth the origin and detailed the nature of this obligation in Chapter 2.  There we explained that FLPMA requires BLM to balance competing resource values to ensure that the public lands are managed in a manner “that will best meet the present and future needs of the American people.”  43 U.S.C. § 1702(c); Comb Wash at 101; Monument Management Plan at 41-42 (Management Plan).   


Moreover, FLPMA requires that BLM management include “the use of some land for less than all of the resources . . . .”  Id.  This means that on some lands certain uses must be prohibited in the name of protecting resources harmed by those uses.  To make a determination of where management “for less than all of the resources” is appropriate, BLM must give consideration “to the relative values of the resources . . . .”  Id.  Thus, BLM must assess the value of each resource in the Monument, weigh this value against the value of the resource uses that may cause harm to that resource, and determine which resources uses are appropriate in any given area.  Finally, BLM’s balancing of values must be reasoned and well-informed.  Therefore, the agency must accumulate sufficient data and consider relevant rigorous science to determine what uses are appropriate in any given area.


Applied to grazing in the Monument, FLPMA requires BLM to determine which lands are suitable for livestock use, based on the relative weight of the various values and the fact that many Monument values are highly vulnerable to degradation by livestock use.  The process should be a transparent, display consistent results, and give fair weight to the importance of the values.  


The determination of the “relative value of the resources” is a threshold matter and must occur as part of any legally adequate FLPMA balancing analysis.  In other words, because the definition of multiple use requires that BLM consider the relative values of resources present, BLM cannot make a legally adequate determination regarding grazing management without first completing this analysis.  Moreover, this assessment must occur in the context of the Proclamation creating the Monument, as well as the Management Plan.  As Chapter 2 establishes, the Proclamation and the Management Plan together constitute a factual finding that in the Monument, scientific, historic, biological, paleontological and archaeological resources are always more valuable than other resources.


Finally, should the agency conclude that livestock grazing is an appropriate use, BLM must consider multiple-use values in determining how that area should be grazed.  National Wildlife Fed’n v. BLM, No. UT-06-91-1 (DOI, Office of Hearings and Appeals, Hearings Div.) (Dec. 20, 1993) at 25, aff’d Comb Wash (citing 43 U.S.C. §§ 1701(a)(8), 1702(c)).  Therefore, in establishing grazing thresholds such as stocking rates and utilization levels, BLM is required to abide by “FLPMA’s mandate [that it] protect the full spectrum of environmental, ecological, cultural, and recreational values.”  Id


Although methods different from the one presented here may satisfy FLPMA’s multiple use mandate, BLM must adopt a review process much like that elaborated below.  As described more fully, this methodology contains analyses that BLM is required to undertake.  Moreover, because BLM’s balancing must be reasoned and well-informed, and must consider the “full spectrum” of multiple-use values, the agency is not free to ignore the science cited or the public land values examined here.


4.4.1 Suitability in Addition to Capability Analysis.  To carry out FLPMA’s multiple use mandate, BLM must determine both if an area is capable of supporting livestock use, as well as if the area is suitable for grazing.[3]   In other words, the BLM should first determine whether the area can support grazing (see Section 4.3, above), then whether, consistent with its multiple-use objectives, it should support grazing.  Suitability determinations involve the impact of grazing on other multiple use values such as recreation, cultural resources, scenery, science, and wildlife.


A suitability determination is required in addition to a capability determination for several reasons.  First, because in some areas that can support grazing, grazing will not be an appropriate use.  This is because grazing has an unacceptable impact on other multiple use values such as soils, vegetation, wildlife habitat, wildlife, water quality, and cultural, scenic and recreational resources.  Second, even where grazing is appropriate, multiple use considerations must guide BLM’s management.  Thus, in most cases, the amount of grazing for which an area is suitable will be less than the level of grazing that it is capable of sustaining.  This is because grazing capacity is the amount of grazing that the area could sustain if it were managed for livestock grazing and for no other use.[4]  Under FLPMA’s multiple-use mandate, however, public lands are not to be managed for the benefit of one use to the detriment of all other uses.  If the land is to be used for recreation, scenery, cultural resources, science, and wildlife, livestock must share the land with other uses; the capacity of the land to support grazing may not be strained to its limits.  This is not to say that each area will require the same balance of uses, but that grazing should not predominate in allocating usage of the land.  Some areas may be suitable for grazing to full capacity, but many will not be suitable for grazing at all because only by prohibiting grazing will other uses of the land be adequately protected.


As with capability analysis, it is also important to avoid treating entire allotments as indivisible units in the course of suitability analysis.  This is because, within allotments that are otherwise suitable for grazing, are areas that are not suitable for livestock grazing.  For this reason, different areas within the same allotment may require different grazing levels.  Where an allotment is predominantly unsuitable for grazing, eliminating grazing on the entire allotment may be appropriate rather than allowing grazing on the suitable portions while building fences to protect the unsuitable areas.


Finally, as detailed in Chapter 2, BLM must undertake its suitability analysis in the context of the Proclamation and the Management Plan that identified that the area’s geologic, paleontological, archeological, historical and biological resources are particularly valuable to the American people.  As a result, when undertaking suitability analysis, BLM must address each of the Monument values specifically and consider if the adverse impacts grazing has on each value warrants reducing grazing levels or closing the area to grazing. 


4.4.2 Suitability Factor: Cultural Resources.  As Chapter 2 details, the Proclamation and the Management Plan document the incredible value of the cultural resources in the Monument.  At the same time, the Management Plan finds that this vast array of cultural resources within the Monument are directly and severely threatened by grazing.  This conclusion is echoed in an environmental analysis of livestock grazing in nearby Glen Canyon National Recreation Area, which found that cattle had impacted 25 percent of cultural sites that were assessed.  Glen Canyon National Recreation Area Environmental Assessment (Glen Canyon EA), 28.[5]


Areas where livestock grazing has damaged, or has the potential to damage cultural resources are not suitable for livestock use.   


4.4.3  Suitability Factor:  Recreational and Scenic ValuesThe Monument is an incredible resource for its scenic panorama, solitude, and adventure.  Recreation in the Monument, world class by any standard, will undoubtedly continue to increase, providing economic revenue to local communities in addition to aesthetic enjoyment to recreationists.[6] 


At the same time, grazing impacts often deter recreationists and minimize the enjoyment of their visits.  TheFEIS accompanying the Management Plan recognizes that “[l]ivestock grazing has the potential to impact recreational use by contaminating water sources and by altering vegetation.  Additionally, although some visitors may enjoy viewing livestock and livestock operations in the Monument, others may find their presence an aesthetic and physical intrusion.”  FEIS, 3.88.


In the EA prepared in nearby Glen Canyon National Recreation Area, the Park Service cited visitor surveys that found that the most commonly mentioned dislike of backcountry visitors was cattle grazing. Visitors and recreational users consistently stated that livestock grazing and its impacts adversely affected their experience of Glen Canyon.   For example, the Park Service cited a formal survey showing that 48% of backcountry users stated that the impacts of cattle and grazing had a “very negative” or “negative” impact on their experience.  EA at 35 (34% stating the impact was “very negative”).  In detailing likes and dislikes of their experience of Glen Canyon, the largest percentage (18%) of backcountry named cattle grazing as their number one “dislike.” Id. Similarly, other users “listed ‘water polluted by cattle,’ ‘insects associated with cattle,’ and ‘multiple trails caused by cattle,’” as “dislikes.”  Id


The Park Service recognized that still other adverse impacts to the recreational experience include sighting cattle along the road, encountering cattle “sign” at campsites (both in the backcountry and on the lake and river shores), experiencing foul odor from cow manure, and seeing vegetation damage, trailing, trampled cryptobiotic crusts, erosion, and water pollution caused by livestock.  EA at 39.   Most importantly, this adverse impact is pervasive – livestock graze the majority of Glen Canyon’s lands and grazing “is the most visible non-recreational use” within the recreation area.  Id.  As a result, backcountry users usually cannot escape the adverse impacts associated with grazing.  Id.


In addition, the Park Service concluded that the presence of cattle, roads related to cattle operations, and stock trails negatively impact the viewshed.  EA at 37.  Scenic qualities are also damaged by vegetation utilization, water developments, and impaired streams and springs.  Id.  Not surprisingly, the Park Service concluded that “[t]he presence of livestock or grazing impacts has a negative impact on the recreational values and desired experiences of visitors within Glen Canyon NRA.”  EA at 39. 


Thus, because grazing impacts to recreational and scenic values cannot be readily mitigated:


Grazing that significantly impacts popular recreation use or the scenic view is inappropriate. 


4.4.4 Suitability Factor:  Rangeland RecoveryParticularly where vegetation, soils and other ecosystem values are degraded, ecosystem recovery is an important indicator, along with other values, in assessing whether grazing is appropriate use of an area.  Rangeland health standards help measure some of the key ecological health values BLM must considered when determining that grazing is appropriate under FLPMA.  Rangeland health requirements, however, are insufficient, standing alone, to provide for the weighing of competing uses that is required by law. 


As described in Chapter 2, in assessing whether an area is in compliance with the Fundamentals and Standards and Guidelines, BLM must still undertake FLPMA’s multiple use valueanalysis.  This is because a given area could have particularly important ecological values and the interests of the American people might best be served by maintaining this area in a state that exceeds “properly functioning” condition.


Moreover, where BLM believes grazing management changes could be made or have been made to make progress toward achieving the desired conditions, the time this takes, or the changes to grazing management required – such as expensive range development projects – could tip the FLPMA balancing in favor of closing an area to grazing.  At the same time, livestock grazing in areas that are recovering is of lower relative value.  This is, in part, due to the need to take actions that emphasize plant community and soil recovery that give greater weight to plant community growth and less to livestock grazing.  Recovery may also be necessary because the area is not capable of sustaining livestock use to any beneficial degree.


Finally, non-compliance with the Fundamentals and Standards and Guidelines also provides insight into values that are being compromised by livestock grazing.  Failure to meet the ecosystem standards often indicates that inappropriate harm may have occurred to multiple-use values such as watershed, wildlife, fish, ecological, environmental, and water resources.


Livestock grazing is inappropriate where this use would prevent a timely recovery of lands currently not in compliance with rangeland health standards.  Livestock use is also inappropriate in areas where wildlife habitat of particular worth has been or has the potential to be damaged by livestock use.


Similarly, as a general matter, where BLM has determined that the value of environmental resources such as soils, vegetation, wildlife, and water quality, is particularly high, BLM must weigh these relative values with the harms caused to them by grazing to determine which resource uses are appropriate.  We consider the relevant environmental resources below.


4.4.5 Suitability Factor:  Streams, Riparian areas and Wetlands.  Based on the importance of riparian areas to sustaining Monument values (see Chapter 3, section 3.1.1) and the undeniable link between livestock grazing and damaged riparian areas (see Appendix A, page 17), BLM must determine whether grazing is appropriate in the Monument’s riparian areas.  To undertake this assessment, BLM must consider the relative value of ungrazed riparian areas vis-à-vis the lost value of grazed riparian areas.  Relevant to assessing the importance of riparian areas is the value that healthy riparian provide to wildlife, especially special status species, water quality and hydrological processes.[7]


Where livestock use causes a riparian area not to function properly, grazing is inappropriate.   


4.4.6 Suitability Factor:  Water Quality.  The FEIS that accompanied the final Monument Management Plan recognizes the adverse impacts of livestock grazing on water quality:


Livestock grazing has the potential to impact water quality through the removal of vegetative cover, which thereby increases soil erosion and subsequently increases the turbidity of streams.  In riparian areas, livestock waste has the potential to increase the bacterial content of the water in streamcourses.  (Plan, at pg.3.66).


That an area is not meeting Utah quality standards indicates that the surrounding watershed and/or riparian areas are not healthy.   As shown in Appendix A, page 25, there is an indisputable link between livestock grazing and increased erosion, and therefore sediment loading in streams.  At the same time, livestock denude stream banks, leading to increased temperatures in the water, and deposit fecal matter directly into the stream, thereby increasing levels of fecal coliform and nutrients. 


At the same time, maintenance of water quality is of high value to wildlife, downstream agriculture, recreation and aquatic life, and is mandated by law.  As a result,


Where livestock use causes water quality to fail to meet water quality standards, grazing is inappropriate.


This is particularly true where high water quality is a priority, particularly in Calf, Sand, Mamie and Deer creek, Utah Admin. Code R317-2-12 (Category 1 High Quality Waters).  Where habitats are valuable for aquatic species and wildlife, or where soils are unstable, grazing could well be inappropriate.  Moreover, if grazing is appropriate, the adverse impact it has on water quality should be factored into grazing management decisions.


4.4.7 Suitability Factor:  Special Status SpeciesAs discussed in Chapter 3, many species of wildlife that exist in the Monument, including special status species, have specific habitat needs.  At the same time, these habitats are often rare, degraded or imperiled.  For these reasons, existing and potential habitats for special status species and species with particular habitat needs are of exceptional value. 


There are a number of federal and state-listed threatened, endangered, and sensitive (TES) species known to reside in the Monument, including the Mexican spotted owl and the southwestern willow flycatcher.  Cattle grazing, as is currently practiced, has been determined to be detrimental to the habitat of these species (see discussion in Chapter 3, Section 3.3.3). 


As with other environmental resources, BLM must rely on its relative values assessment in the context of the harm grazing causes to wildlife and special status species to determine if an area is appropriate for grazing.  Again, because an area is properly functioning for the purposes of providing wildlife habitat does not end the FLPMA balancing inquiry.  BLM must also consider biological factors not addressed by the Fundamentals and Standards and Guidelines relative to special status species and their habitats, such as predator control, spread of disease from livestock to wildlife, and cowbird proliferation. 


Livestock grazing in a manner that prevents habitat from meeting the needs of native wildlife, especially special status species, is inappropriate


Thus, to fulfill its FLPMA obligations, BLM must identify, with the help of the U.S. Fish and Wildlife Service and Utah Division of Wildlife Resources, any critical habitats and  special status species whose habitat and diet needs will not be protected adequately by properly functioning conditions or that will not adequately recover without added safeguards.  Where these species or critical habitats are found, BLM should restrict livestock grazing in order to ensure that the critical habitats meet that species’ special needs.  This is particularly true where the precarious condition of special status species increases their relative value and requires that exceptional steps be taken to ensure their recovery.


4.4.8 Suitability Factor:  Biological Soil Crusts.  As the Proclamation and Management Plan make clear, biological soils crusts are a key Monument value, paying a critical ecological role in soil stability, nitrogen fixation, nutrient availability, seedling germination and plant growth.  Moreover, these “fragile” crusts are highly susceptible to damage and annihilation by livestock grazing.  See Appendix A, page 33, as well as Chapter 3, Section


Where areas with biological crusts are susceptible to damage by livestock use and livestock grazing cannot be managed to protect these soils, grazing is inappropriate.


4.4.9 Suitability Factor :  Land Use Designations and Land Use Plans.  Even if BLM could guarantee that grazing and properly functioning ecological conditions could co-exist, the analysis to determine if grazing is appropriate could reveal that grazing is not is the best interests of the American people.  This is because a given area could have particularly important ecological values and, therefore, the interests of the American people might best be served by limiting or not allowing grazing.  For example, an area could be Critical Habitat as defined by the Endangered Species Act.  The area could be the only in the Monument that provides habitat for a particular species.  Or, the area could support a combination of factors – such as the ecological and cultural resource values.  In each of these cases, the harms caused by grazing – even though they do not bring the area into the realm of non-functioning may lead to BLM concluding that livestock grazing is inappropriate for part or all of an allotment for reasons for related to a land designation.


BLM should review land designations such as Existing Outstanding Natural Areas, Areas of Critical Environmental Concern, Special Use Areas for recreation, and other special designated lands to determine if grazing is compatible with the values that led to the designation.   


Grazing is not appropriate in areas where grazing practices are not compatible with those values specifically protected by existing land designations or land use plans.


4.4.10 Suitability Factor:  Economic Values. In its suitability analysis, BLM must put a value on livestock use.  Again, because FLPMA focuses on the needs of the American people, it gives priority to national, rather than regional needs.  Therefore, on some level, the value livestock use, as with the other uses of the Monument, must be couched on a national scale. 


Two economic calculations are relevant to weighing the relative value of livestock use vis-à-vis other multiple uses.  The first concerns the economic value of the cow:calf operations that characterize livestock use on the Monument.  In cow:calf operations, the calves produced by the grazing mothers typically stay on the range for nine months and help constitute the marketable crop.  In this context, it is possible to determine the value of producing this crop or the price people will pay for “the use.”  Price reflects the demand for the use, which indicates the demand for or value of the use.  This demand could be further understood in terms of beef production.  


However, to accurately determine the value of livestock use, the costs of this use must be subtracted from the worth or value of the marketable crop.  Thus, costs to the permittee and costs to BLM must be factored into the calculation of worth.  Grazing fees should not be considered a cost, because, while fees are a cost to the permittee, they are a benefit to BLM, thereby essentially canceling out.  Thus, the economic value of grazing constitutes the value of the marketable crop minus the costs to BLM and the permittee of creating this crop.  Once BLM establishes the value of livestock use, the agency must compare this to the value of other resources and uses in the Monument on a case-by-case basis to determine the relative value of the various uses.  


The second economic analysis concerns BLM’s fiscal resources.  The decision to permit livestock grazing with the accompanying stipulations constitutes a promise that BLM can deliver the services necessary to manage grazing within the standards described by law.  This promise covers monitoring, analysis, habitat restoration, enforcement of permit conditions, and range developments.  The cost of supplying these services, particularly if they are necessary to achieving compliance with the law, must be considered in calculating the relative value of livestock grazing.


The relative economic value of livestock use should be determined from the value of the marketable crop minus the costs of grazing.  The costs of grazing must include necessary services and facilities provided and paid for by the BLM.  Finally, where BLM lacks the resources to manage grazing in compliance with the law, this use is inappropriate.


4.4.11 ConclusionIn sum, BLM’s obligation weigh the relative values of FLPMA’s multiple use factors and find the combination of uses that best meets the needs of the American people is critical to the successful management of the Monument.  Because Monument resources are of particularly high value to the American people and also significantly vulnerable to livestock grazing, this assessment takes on even greater importance.  BLM cannot fulfill its obligations to the public unless it makes deliberate, well-reasoned and science based decisions whether, in any given area, grazing is an appropriate use of the land. 



4.5 Forage analysis/capacity model: setting new stocking rates


Appendix B presents a new model for the Monument staff to use for calculating the forage that can be allocated to livestock while still allowing for the ecological needs of the land to be met.[8]  Based on a wide array of range science, this ecologically based forage capacity analysis is a tool to help BLM determine appropriate stocking levels for livestock in the GSENM. This forage capacity model uses computer mapping and ecological field data to estimate the amount of grazing that a grazing permit can allow, while still being in compliance with the standards and guidelines. 


The standards call for management of grazing in deference to the health of ecosystems. Ecosystem health is in turn 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 meet the standards, and restore and maintain rangeland ecosystems so that these systems will have the resilience that ensures productivity of the land over time.


Such an ecologically based forage capacity analysis is timely because grazing capacity has not been systematically reviewed for most allotments in the GSENM for at least two or perhaps four decades.  Galt et al. (2000) recommend that grazing capacity surveys should be conducted every ten years.  This is a good recommendation that aligns with typical permit terms and is logical to carry out.  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 DEIS.  BLM has a legal requirement to consider this issue as part of the EIS.      


The material in Appendix B develops and illustrates our proposed, science-based model for determining appropriate stocking levels for cattle in GSENM grazing allotments.  This new formula separates the ecological needs of the land and wildlife into several categories.  These are: wild herbivore needs;  insect and nematode forage needs;  and vegetation community viability, regeneration and resilience including soil stability and resistance to erosion.  Based on literature on these topics, we have developed proposed allocations for these ecological factors.  We demonstrate the utility of this new model by using an actual example in the Monument (the Upper Hackberry allotment).



4.6 Determine whether habitats are functioning for threatened, endangered and sensitive species. 


In addressing rare species management in GSENM, consideration must be given to recognize, protect and maintain the natural ecosystems and habitats that are essential for long-term viability of the rare species that exist within those ecosystems.  The Presidential Proclamation for GSENM calls for the protection of the region’s “objects” and resources – including both biotic and abiotic elements.  This mandated protection of these objects and resources includes associated values and attributes as well (such as predator-prey cycles, nutrient cycling, and population cycles of native species).  


The Monument’s management plan states, “the BLM will continue to ensure that authorized actions do not jeopardize the continued existence of any special status animal species” (Plan at pg 13).  Authorized actions (recreation, vegetation treatments, and most of all livestock grazing) are not likely to affect Threatened/Endangered/Sensitive (TES) species directly, but rather these impacts will usually indirectly affect these species’ habitats.  It is important that the Monument assess whether habitats likely to contain TES species are properly functioning for those species.  This is something that the BLM should be doing on all of its holdings, but is almost never done.


Of relevance to this DEIS process and the assessment of whether habitats are functioning for TES species, the Monument should include in the DEIS an assessment of to what extent livestock grazing is currently impacting or potentially impacting habitats for federally listed species (such as the southwestern willow flycatcher, Mexican spotted owl and federally listed plants).  The Monument has barely begun the process of consultation with the USFWS for this DEIS (personal communication, Dennis Pope), and so the direction that GSENM can take in this process is still very open and available to lend itself to a proactive approach.  Of great importance regarding TES 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 in Chapter 3 and should be incorporated into the Grazing DEIS.


In summary, the Monument needs to be assessing potential TES habitat for proper function across the Monument, and where habitats are found to not be functioning properly for those species, the BLM needs to determine why.  As shown in Chapter 3 through a review of the scientific literature, its is likely that where cattle grazing occurs within known or suspected habitat for TES species, it will usually be causing these habitats to not function properly for these species.          



4.7  Remedies the Monument must devise


                  There are a number of remedies, in a large part based on analyses recommended above, that we recommend BLM implement in the Grazing DEIS.  These remedies primarily take the form of grazing prescriptions that are spelled out in the grazing permits.


4.7.1 Generic prescriptions that need to be applied to all allotments that will have continued grazing.  The decision on management of livestock grazing is described in the form of a prescription for each grazing allotment.  These prescriptions can be simple and only prescribe stocking levels and seasons of use.  Prescriptions can also describe rest rotation programs, and present other management directions.


The grazing management prescriptions proposed below differ from those currently issued by BLM in several ways.  The prescriptions presented here assume that grazing use is the same as permitted use for the average forage production year.   Currently, BLM grazing permits list the permitted number of AUMs.  However in many cases, BLM often intends to graze livestock (actual use) at amounts less than the permitted level for normal forage production years.  Unfortunately, this places BLM’s decision at risk since the environmental analysis that supports the decision is often based on stocking levels less than permitted.  As a result, the environmental analysis for grazing decisions often fails to meet the requirements of NEPA.


Our proposed prescriptions further differ some from BLM’s current prescriptions by describing measurable monitoring indicators that trigger management change.  While BLM monitors trend and utilization, permits and related management plans normally lack a systematic method for making decisions based on monitoring. In addition to this, when management changes are made a record may not show this change and its rationale.  In response to this, the prescriptions presented below provide a clear method that links changes in ecological condition with required changes in grazing management.


In this section we describe steps that guide the development of grazing prescriptions based on a number of conditions.  These prescriptions fall into two general categories.  One set of prescriptions pertains to those rangelands that now meet rangeland health standards.  The second set pertains to range sites that fail to meet the standards.  Monitoring and its use in adapting grazing practices is a critical part of any prescription.  We give special attention to drought situations, and allotments where productivity is clearly impaired.  This section also suggests consistent collection of monitoring and management data.


We recommend that GSENM staff take the following steps when developing a grazing prescription.  These steps incorporate processes described in more detail below, as well as elsewhere in this document:


·        Determine which lands are capable of supporting grazing (i.e. is there capable topography, soils, minimal productivity, access to water, etc.  See Section 4.3 and Appendix B).

·        Of those areas capable of supporting livestock, determine which are suitable for grazing (take into account management issues, critical and rare habitats, FLPMA balancing, etc.  See Section 4.4 and Appendix B).

·        Determine if allotment is meeting the rangeland health standards and guidelines, and/or whether productivity is significantly impaired (less than 50% of available forage predicted by NRCS Ecological Site Descriptions). If all the pastures, wetland areas, and riparian reaches meet the standards, and productivity is not impaired, then go to section  If the allotment is not meeting standards, and/or productivity is impaired, then go to section 

·        Is the area suffering from drought? If so, section addresses how to adjust stocking rates and grazing management to respond to this condition.

·        Implement a comprehensive monitoring program for the allotment, and include these protocols and conditions in the grazing permit.  Section features our discussion on the importance of adequate monitoring, and our suggestions for monitoring.  Prescription for rangelands that meet the rangeland health standards, and/or productivity is not impaired.  We recommend the Monument take the following steps for areas that meet the rangeland health standards, and/or productivity is not impaired:


1.   Determine the livestock forage capacity based on ecological needs of the land (see Appendix B for our proposed method for doing this).  Set a new stocking rate for the allotment based on this forage analysis.  

2.   Will grazing use occur during the early part of the growing season (March through May)?  If this is the case, the forage produced during the growing season will be less than its potential, and thus the forage capacity will be similarly reduced.  If livestock grazing occurs for more than 2-3 weeks in the first part of the growing season, reduce the stocking level by half of that amount calculated in step1, above.

3.   Will grazing occur in riparian or wetland areas?  Because livestock use riparian areas far more than wild herbivores, a stocking level designed for upland rangelands will lead to over utilization in riparian areas.  We recommend that if livestock are certain to be grazing in riparian areas, reduce the stocking level calculated above by 50%.

4.   Make the final stocking rate calculated above part of the grazing permit as the number of permitted AUMs.

5.   The monitoring protocol should establish measurable goals for habitat function for key indicator species.  These should include those species most sensitive to habitat change, those in decline or at risk, those most impacted by grazing, and those that are the best indicators of habitat condition.  All monitoring methods and goals should be clearly outlined in the grazing permit.  We discuss our recommendations for monitoring more thoroughly in Section

6.  Determine management actions that will be triggered when monitoring goals are met, and not met.  These management actions should be described in the grazing permit.

    “Recovery Prescription” for rangelands that do not meet the rangeland health standards, and/or where productivity is impaired.  For reasons described elsewhere in this paper, where rangelands are identified that fail to meet the rangeland health standards, this is often an understatement of the magnitude of the ecological problem with these lands.  Similarly, where actual available forage biomass is less than 50% of the potential forage predicted by NRCS, this is an indicator of seriously impaired productivity.  For this reason, most rangelands not meeting the rangeland health standards or that contain less than half of the potential annual productivity, require an aggressive “Recovery Prescription[9]:”

1.   Using the determination assessment method described in Appendix A, assess whether livestock are one reason that the allotment fails to meet one or more rangeland health standards.  If the answer is no (grazing is not the cause), then other management actions outside range management may be required, and the prescription described in section, above, should be used.  If the answer is yes, then proceed with the next steps. 

2.   Determine the degree to which conditions differ from their potential and identify the management practices that will lead to the area meeting the standards in the future.  Can it be determined that conditions can be restored within the next grazing permit period?   If the answer is no (recovery will take longer than 10 years), the area should be designated as unsuitable for grazing.[10]  This period of unsuitability will continue until a recovery plan is in place that can ensure that the standards can be met within a lease period.  If it is determined that the allotment can be brought back to its ecological potential within the next grazing lease, proceed to step 3, below.

3.   For those allotments not meeting the rangeland health standards and/or that have impaired productivity but can feasibly be restored within ten years, implement the following steps: 

(3a) Discontinue grazing during the growing season (typically from March to mid June).

(3b) Determine the amount of grazing that can occur while still allowing the recovery schedule to be met.  The literature cited in the following sections indicates that recovery is very slow even in areas closed to grazing.  It is possible that there is no minimum stocking rate that will allow recovery of degraded uplands within decades.  Therefore, we recommend complete rest or allocations of only 5% of the annual forage production (during normal precipitation years) to livestock use. 

(3c) Will grazing occur in riparian or wetland areas?  Because livestock use riparian areas far more than wild herbivores, a stocking level designed for upland rangelands will lead to over utilization in riparian areas.  If livestock graze riparian areas for periods longer than one week during the growing season, reduce the stocking level decided in step 3b by half.

(3d) Initiate a recovery monitoring program and analysis (see Section  Such analysis should consider the length of time that an area will need to be rested from domestic livestock in order to restore soil nutrients, plant community composition, and productivity to near their potential.  Monitoring on an annual basis should be conducted to measure plant community composition, ground cover (including cryptobiotic crusts and litter), and annual forage production.  If the monitoring shows that these indicators will not be within 50% or better of the site potential by the end of the grazing permit period, grazing use should be discontinued until such a time that the site is on schedule to recovery.  Special Prescriptions for drought situations. In semiarid areas, drought is an expected occurrence.  For example, between 1903 and 2000, 58% of all years in the Kanab region have been below average precipitation years.  Hard winters and long droughts are a natural method of controlling wild herbivores.  Unfortunately, livestock forage is supplemented from developed agricultural lands, protecting livestock from the mortality losses that wildlife would normally experience during drought.  We recommend management prepare in advance of any drought and respond quickly before habitat damage occurs.  For this discussion, we define drought to be precipitation that is less than 2 inches below normal for the year.


            Flexibility must be built into the established grazing levels on permits to account for drought, so that a greater proportion of biomass is left when plants are more stressed, such as occurs in drought years.  Since forage production can vary by 500% and plant species respond differently to defoliation under stress, the same proportion of forage used has different impacts in wet and dry years (Vallentine, 1990).  Therefore, no single stocking level is appropriate for all years, all vegetation types, and all plant species.  These differences need to be incorporated into allotment management plans and grazing permits.  As we have repeatedly emphasized and shown in this guidance document, the negative consequences of over-stocking and over-utilization can be severe.    


             Grazing levels often stay constant well into a drought, thus extending grazing impacts at a level far beyond what the forage base can endure during a drought.  Grazing use should come with the stipulation that, should average standing forage biomass or expected precipitation not occur, then grazing use will be reduced before the start of the grazing season.  During a time of drought, grazing should never occur during the first three months of the growing season, and monitoring should occur during the grazing season and should increase in frequency.  Lastly, grazing levels should not return to previous levels until the productivity of the range has returned to its potential quantities. Monitoring and management analysis.  Monitoring for trend and utilization over the past four decades in GSENM has not provided the necessary information to assess rangeland health (according to the standards) or range condition as described by PRIA.[11]  Upland Rangeland Health assessments conducted over the past four years in the Monument have provided some helpful information.  However, these assessments come with some limitations in that they may miss a few key rangeland health indicators.  A good example is rangeland forage productivity, which is not measured with current rangeland health methods and monitoring protocols.[12]


             In order for BLM to meet its requirements under PRIA, the Monument Management plan and the Standards and Guidelines for Healthy Rangelands, monitoring needs to be expanded and given a higher priority.  It is critical that monitoring be explicitly tied to specific operational goals, objectives, and expectations; and clearly outline numerical standards that are measured in kg/ha, % cover, population sizes, etc.[13] 


            We recommend that traditional monitoring change in four ways in GSENM.  First, ecological reference areas need to be established that represent riparian areas and habitat types for each allotment.  This does not require that all allotments have an exclosure for each of the Range Site Types in the allotment.  However, an exclosure of each of the Range Site Types does need to be established somewhere in the Monument, so this exclosure can be compared to grazed examples of this Range Site Type throughout GSENM.  Second, annual monitoring must assess forage production.  At least every five years, monitoring needs to be conducted that assesses plant community composition, biomass and ground cover for all species, cryptobiotic crusts, and litter.  Holechek et al. (2001) recommend this as well. Third, scientific studies of experimental management prescriptions, using hypothesis testing, should be conducted on numerous allotments to validate management practices.  Lastly, more accurate records on grazing use and the implementation of prescriptions need to be kept.  Below, we go into further detail on these four points as they might relate to reformed monitoring programs for GSENM:


·        Establish an adequate number of ecological reference areas. Rangeland health assessments rely on comparison of current conditions with the potential expected for the same area.  Very few relict habitats exist in the Monument.  Existing exclosures, some of which are thirty years old, are helpful but often deviate from the potential for an area.  There are a number of reasons why existing exclosures fail to represent the natural potential plant community.  For example, most were established after nearly a century of grazing use.  Many have plant communities that are at a state where they will not change further without some significant event.  In addition, most small exclosures are over-utilized by wild grazers.  These small exclosures often provide the last remaining source of lush forage, and are usually easily accessible to rodents, rabbit, and deer.  Therefore, heavy use of these small exclosures by native herbivores is common.


            It is particularly important that the BLM establish new, large exclosures in riparian areas.  In the case of riparian PFC assessments, adequate determination of riparian and stream health requires comparison against the standard of reference (control) sites (see Appendix C).  Riparian habitats considered suitable as ecological reference sites should be located, described in detail, and analyzed through PFC assessments to provide controls against which PFC assessment sites can be evaluated.  Reference sites should have close to natural conditions, and must be as free as possible from anthropogenic disturbance, especially livestock grazing. Reference sites should be selected across the Monument, and include a wide elevation gradient and in different stream types. Reference sites also will be useful for understanding the range of natural ecological variability in the Colorado Plateau, and for training PFC teams. The data collected from these sites should be used to develop a regional model of stream and riparian habitat structure and characteristics. 


            In summary, BLM needs to establish large, ecological reference areas in both uplands and riparian zones that better reflect potential plant communities, and must ensure that accurate conclusions are drawn from monitoring sites that are compared to reference areas.  These exclosures should be of sufficient size and with several compartments that exclude a variety of native herbivores in order to identify wild herbivore impacts.  Also, the establishment of a large exclosure in each of the larger allotments in the Monument should be a priority.


·        Monitor key ecological habitat indicators. Past trend monitoring and utilization data offer little insight into range condition or ecological health.  Often focused on one or two key forage species preferred by cattle, trend data sample size and data collection frequency offer inadequate insight into plant community composition, ground cover, and range productivity.  Often, many native species are not included in the list of key species that are monitored.


            Monitoring is required to assess range condition and trend of change of range condition.    Section 1902 of the Public Rangelands Improvement Act describes range condition as: “the quality of the land reflected in its ability in specific vegetative areas to support various levels of productivity . . the present state of vegetation of a range site in relation to the potential plant community for that site, and relative degree to which the kinds, proportions, and amounts of vegetation in the plant community resemble that of the desired community for that site.”


            A set of plant indicator (“key”) species should be used for monitoring.  These should be native species and should include several species from each community type.  Each community indicator group should include (as applicable) trees, shrubs, forbs, and grasses, and should be selected to include those most sensitive to and/or preferred by livestock, and those only consumed under duress.  Important food plants for a large array of wildlife should also be treated as indicator species, as well as plant species that have been found to be good indicators of ecosystem stability, all rare and endemic plant species, and species known to be limited by livestock herbivory and species that are indicative of “endangered habitats” (e.g., riparian lowlands), or are considered rare.  Plant species have differing tolerance of grazing (even on the same site), and tolerable utilization for one species may severely stress another.  Therefore, stubble heights/utilization levels must be set for minimizing impacts to the most susceptible species or must vary by species. 


            Currently, monitoring in GSENM is not conducted to the degree required in the land use plan and required for accurately carrying out the upland rangeland health assessments.   To improve upon this situation, we recommend that: (1) each year, BLM measure annual forage production[14] for all “key” native grasses in each Range Site Type on an allotment;  (2) at intervals of no longer than five years, BLM collect data along transects in each allotment Range Site Type to determine plant community composition (including relative abundances of exotics), amount of litter, and crypto-biotic crust cover,[15] (3) on a periodic basis, wild herbivore populations should be inventoried using transects to tabulate wildlife presence such as burrows and feces; and (4) Properly Functioning Condition assessments for riparian areas and wetlands should be conducted at least every other year and Upland Rangeland Health assessments should be conducted at intervals of no more than five years.


            Annual photographs should be used to document progress towards standards. Photographs should be carefully standardized following an accepted published protocol (e.g. EPA, 1993; Kinney and Clary, 1994). Where available, photographs showing current range condition should be included in the Grazing DEIS


            In summary, without baseline data it is not possible to quantify or evaluate changes, thus not possible to make informed management decisions.  Desired conditions need to be defined, using not only current vegetation composition but as much historical and paleobotanical information as possible.  the Grazing DEIS should describe comprehensive monitoring plans, with timelines, to ensure that the proper ecological indicators, compliance with standards, and progress towards desired condition are measured and reported regularly and accurately.  If monitoring is not being done frequently and properly, or if evaluation of the monitoring data cannot take place within a year of data collection, livestock should be excluded from that allotment. 


·        Hypothesis testing as a form of monitoring. Scientific studies of experimental management prescriptions,[16] using hypothesis testing, should be conducted on numerous allotments to validate management practices.


·        Monitoring data management.  The Monument’s present process for collecting, storing, archiving and distributing grazing-related information could stand improvement.  BLM does not clearly define data management and archival protocols, issues that are central to the credibility of this NEPA process. Interpretation of regional patterns and scientific defensibility of management decisions requires ease of access to historical as well as recent data.  We wonder to what degree the DEIS staff is currently reviewing the voluminous existing available data to understand local and regional patterns, over decades, in GSENM. Historical and recent field data, as well as all monitoring and management protocols, should be clarified at the local, state and national levels by the BLM, and we strongly recommend that the BLM consider and implement a sound data management strategy for all of its term permit renewal and land management plan revision processes.  In all cases, the data collected should be electronically compiled and managed for ease of review and comparison with future site visits and NEPA analyses. Those data should be made available on-line to the public in a national database and in accord with federal information standards.


            In summary, making grazing monitoring and management data more available to the public will lead to broader understanding by the public of range conditions and actual management practices.  In the absence of objective visible data, grazing issues become distorted.  The political fallout of this distortion can have lasting negative effects on the land.  We recommend that BLM continue to educate the public on how rangelands are monitored and make this data more available to the public by way of the internet.  Grazing permits, annual amounts of allowed grazing, and reports of grazing use should also be made available over the internet. Additional discussion of the “Recovery Prescription”: how much rest is necessary? If the BLM finds that the estimated biomass of available forage is 50% or less of the potential production of the site (as defined by NRCS), or that the site is not meeting Standards, we argue above that the allotment should receive a special "recovery prescription" (described above).

Little research exists concerning the level of livestock grazing that can occur on

"recovering" arid or semi-arid rangelands where productivity is fair or poor.   Further, the literature is inconsistent as to exactly "how much rest" is required to recover degraded rangelands in arid or semi-arid environments.  Below, we highlight some of the key literature that clearly shows that, in general, the recovery of impaired rangelands appears to require long periods of time - certainly more than a year or two of rest.


            Many researchers suggest complete rest as the most effective and rapid method to repair grazing damage to soils and other resources, particularly in damaged riparian areas (Clary and Webster, 1989; Chaney et al., 1993).  Elmore and Kauffman (1994) note that livestock exclusion has consistently resulted in the most dramatic and rapid rates of riparian ecosystem recovery.  These authors also note, however, that "simply excluding the riparian area into a riparian exclosure does not address the needs of the upland vegetation or the overall condition of the watershed."  Unless a landscape-level approach is taken, important ecological linkages between uplands and riparian cannot be restored and riparian recovery will likely be limited. This may mean that livestock exclusion must be extended to an entire watershed.

The literature confirms that total, long term rest is effective.  Potter and Krenetsky

(1967) found that grass densities and total ground cover tripled following 25 years of non-grazing.   Blydenstein et al. (1957) similarly determined that perennial grass densities and the palatable shrub Krameria grayi increased in a Sonoran desert grassland protected from grazing for 50 years, and the authors were most taken by the notable increase in overall plant cover and density.  More recently, Anderson and Inouye (2001) found landscape-scale changes in plant species abundance (greater) and biodiversity (greater) of a previously grazed sagebrush steppe over 45 years of rest, with perennial grasses experiencing a 13-fold increase in cover during that time.  Analyzing riparian areas, Platts and Nelson (1985) determined that herbaceous vegetation can recover within several growing seasons and woody vegetation within 5-10 years if grazing stress is removed from a deteriorated riparian area and sufficient residual shrubs are present to allow re-growth and expansion.

           At the same time, others have concluded that short-term rest from grazing may not

sufficiently allow for recovery of ecosystem values.  McPherson et al. (1990) compared ungrazed and a formerly grazed (with 5 years of rest) juniper woodlands, finding that the ungrazed plot had more grass, the grazed more forbs.  The authors concluded that "[t]he effects of long-term continuous cattle grazing persisted 5 years after removal of livestock" and that the "succession following grazing will proceed slowly or will be unpredictable."  In a study of the Kaiparowits Basin, Jeffries and Klopatek
(1987) compared heavily grazed sites, a site ten years into recovery from heavy grazing, and a relict, never-before grazed site.  The authors found that the relict site had significantly more herbaceous cover (comprised mostly of perennial grasses) than all other sites. There were no significant differences between the heavily grazed site and the recovering site for any of the measured parameters, leading the authors to conclude that recovery from grazing can take a very long time indeed.


             Some authors suggest that conservative grazing use and other changes in management (rest rotation, etc.) can be very effective in protecting soil health, while maintaining some grazing use. However, Elmore and Kauffman (1994) report 3 major short-comings of these grazing strategies that fail: (1) the “cookbook approach,” or no recognition of complexities or heterogeneity of riparian zones, (2) many strategies do not consider woody vegetation, streambank integrity, or riparian function, and (3) many strategies were developed to maximize livestock production rather than to protect other resources. Any mitigation or recovery plan must have resource condition as its first priority, rather than the continuation of historical grazing use.

             An interesting study in Canyonlands National Park (Kleiner 1968) offers some insight into the difficulty of range recovery.[17]   Kleiner compared vegetative cover and diversity between a recently grazed (four years rest) and ungrazed study sites within the Park, and found that plant diversity, ground cover and productivity were significantly less at the rested site than the ungrazed site.  This is an indication that, in this case, four years of rest was clearly not enough to allow for full recovery of this system. 
              What level of grazing can occur on degraded rangelands that are only 50% or less of their potential productivity, while still allowing them to recover?  As evidenced by the above examples, we argue that the answer is likely to be none, at least for a few years.  It is even more likely that complete rest for much longer periods, up to several decades, may be necessary to allow even slight progress towards restoration of community diversity and production.  Certainly the study by Anderson and Inouye (2001) shows that progress is very slow (with a period of nearly 50 years in which the plant community still had not reached potential).  How much rest is necessary to bring back the desired productivity of these impaired ranges? We don't have an answer to this question.   However, as outlined above, the literature is filled with evidence that prescriptions of short periods of rest (like those used with rest-rotation schedules) are not enough to ensure recovery in semiarid desert lands.  Is the answer 5 years, or 10 years, or 25 years?  We look to the Monument to heed its own call for strong science within its borders, and establish long-term exclosures to study the beneficial effects of long term rest from grazing, to help determine a definitive "rest prescription" for those allotments that clearly need to be put into "recovery mode."  Further, the Monument must establish quantitative and significant goals against which to measure restoration progress, either by comparison to exclosures or as gains toward potential productivity (as described by NRCS) and ground cover (as the literature cited herein describes).


4.7.2 Grazing prescriptions that are inappropriate.  Certain livestock management prescriptions are essential to sound grazing management and we have listed many of these previously in this section.  There are yet another set of prescriptions that are either unsupported by scientific analysis or rarely appropriate to apply: Rest-rotation as traditionally practiced.   While many 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.  In fact, there is evidence that the use of some of these management methods, as have been traditionally practiced by federal lands managers, can actually worsen the condition of pastures.  Holechek et al. (1999) demonstrate the ineffectiveness of rotational grazing systems in improving rangeland conditions, and 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. (2001).[18]


In addition, 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 such as rest-rotation.  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.  In addition, Hann et al. (1997, referring to work by Clary and Elmore, 1989, Platts 1989, and Elmore and Kauffman 1994) state that the three-pasture, rest rotation grazing system promotes shrub browsing that can exceed growth during rest years;  three-pasture, deferred rotation inhibits growth of woody species; early rotation damages herbaceous species; rotational grazing leads to declining woody species; and short duration grazing damages streambanks, shrubs, and herbaceous regrowth.  Lastly, Taylor et al. (1997) concluded that “rotational stocking ... was not able to sustain initial species composition at any stocking rate tested.”


            Moreover, while rest periods arguably may allow the marginal recovery of individual plants, rotation schemes cannot mitigate the loss of soil protection, thermal regulation, or water absorption and retention, or the alteration of plant competition that results from removal of biomass by grazing.  These conclusions are echoed in a 1989 Forest Service paper which 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 is 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.”


            In summary, rest rotation involves removing livestock from a pasture for short periods of time, often for only one year.  Rest rotation as has been traditionally practiced often rests the land for too short a period of time to allow for recovery.  Rest periods for rangelands where productivity is excellent require a short time to recover from light use.  However, the more common situation relates to degraded rangelands where a much more extended rest from grazing is needed. Prescriptions involving new water developments. It is inappropriate for the Monument to set stocking rates at levels higher than the land and its productivity can support and argue that new water developments will increase the carrying capacity of the allotment.  The reliance on water developments and fencing to gain better distribution of livestock ignores the reality that placing water developments in locations previously unavailable to livestock may introduce additional competition for forage in those areas.  Given the already depleted forage resource in areas of the allotment accessible to water, these less accessible areas may be the only forage available for wildlife.  Installation of water developments can degrade habitats that may be in better ecological condition, resulting in further impacts to wildlife (Holechek et al. 2001). 


The BLM often claims that by providing water to cattle in upland areas, they can reduce detrimental grazing impacts along streams and wetlands by luring cattle away from these sensitive areas and into the uplands.  A number of studies have recognized that these types of improvements (construction of new watering facilities in uplands) are ineffective at bringing about real improvement in conditions when compared to removal of livestock (e.g. GAO 1988).  For example, McInnis and McIver (2001) showed that use of off-stream supplements of water did not significantly reduce stream bank impacts.  Most water developments for cattle divert or gather water from other, natural sources;  drilling wells to provide stock water can deplete aquifers or disrupt hydrologically connected surface flows (Donohue 1999).  Any diversion of water away from riparian areas, seeps, springs and other wetland areas is ecologically damaging: these projects reduce the size of the original wetland, as well as its productivity.  Indirect effects similarly ensue in these areas; for example a reduction in surface water area caused by water diversion can lead to a decrease in insect populations, thereby decreasing the wetland’s value as potential habitat for bats (RRCS 1999).  In addition, additional stock tanks in uplands leads to the condensed density of cattle near a stock tank contributing to pollution of surface waters in the region (Donohue 1999), through storm run-off that will eventually make it back to the wetlands/riparian areas that the BLM was trying to protect in the first place.


Land management agencies and wildlife professionals often claim that man-made water sources in arid habitats inherently benefit wildlife, but these perspectives on benefits are primarily based on game bird and ungulate studies.  In light of this, Burkett and Thompson (1994) investigated effects of “human-altered water units” on small mammals, herpetofauna, and invertebrates in New Mexico.  After comparing species richness of these guilds in 20 paired comparisons of watering units versus sites without water, they found that animal richness did not differ between water units and non-water units across vegetation communities.  


In summary, and as Holechek et al. (2001) have indicated, areas of severe degradation or “sacrifice areas” occur around water sources including water developments.  These can extend from one mile to several miles from these sources and out further if stocking rates are too high.  Based on this, a single water development can result in an area of soil compaction, erosion and severe loss of ground cover and vegetation for thousands of acres.  Holecheck et al. also indicate that installing water developments in locations that have had limited access to livestock in the past may increase ecological damage to areas that are important refuges for relict plant communities and wildlife that have not been displaced by livestock.  It is critical that the BLM not rely on future water developments to correct overstocking in GSENM as the evidence is clear that these “improvements” only exacerbate existing problems. Prescriptions calling for continuation of grazing because range is “past threshold of recovery.”  The conclusion that reduction of stocking rates or cessation of grazing on an allotment will not increase rangeland recovery (because the site has supposedly passed through “thresholds” into new “stable” states) is not only refuted by leading range scientists but is belied by the following:


(1)  There are numerous rangeland ecosystems, i.e. riparian, grassland, open ponderosa pine-grassland, etc. that adhere to the traditional Clementsian succession model and will recover when disturbances (such as livestock grazing) are removed (Laycock 1994);

(2)  Continued grazing can degrade already degraded rangeland systems still further, esp. during droughts, thus moving rangelands into more degraded stable states and making them even more difficult to restore;

(3)  Restoration of rangelands, in most cases, can start only with improved soil fertility and enhanced native plant vigor, which are consistently reduced by livestock grazing.



4.8 Summary, and Role of Science


In summary, we stress that the above analyses and remedies must be in place in GSENM’s comprehensive Grazing DEIS if it is to conform with the Standards and Guidelines for Healthy Rangelands, as well as abiding by all existing laws and regulations.


Moreover, we argue that all of the above suggested analyses, remedies and prescriptions should be conducted in a scientific manner (not just the monitoring, as we discuss above).  From now on, all assessment procedures, grazing management decisions, field data collection, and implementation of grazing prescriptions should essentially be framed as hypotheses for testing.  The best science and tools must always be applied.  We call to the attention of the DEIS staff the tribute that the GSENM Plan makes to science, and the Plan’s clear call for the use of hypothesis testing in evaluating and setting grazing management practices:  “The Monument provides an unparalleled opportunity for the study of scientific resources.  In addition,…this setting allows study of such important [topics] as… improving land management practices.” (Plan at pg 5); and “the geology, soils, and erosional characteristics in the Monument and the resulting plant communities provide opportunities to test, validate and develop management methods, criteria or techniques which will lead to improved grazing practices” (Plan at pgs 42-43, emphasis added).


[1] Because of the length of this section, and because we already submitted this portion of the Guidance Document to the Monument, we have attached it as Appendix A.

[2] The capability analysis recommended in this section is compatible with the Capability Analysis presented in Section 2.6, pg. 6 of the Forage analysis/capacity brief (Appendix B).  The concept of  "capability" in both of these models (determining capability in terms of “FLPMA balancing” here, assessing range capacity and stocking rates in Appendix B) are the same.  In our Forage/capacity model, the concept is used to exclude particular areas as incapable of supporting livestock grazing when determining stocking rates with a GIS.   In the context of FLPMA balancing (here), capacity is used to determine appropriateness of grazing in some or part of a pasture, as well as to inform appropriate grazing management decisions such as stocking rates and utilization levels.  In other words, capacity analysis is required, whether by FLPMA or when setting stocking rates.  This analysis should occur as a threshold matter, to determine if grazing is an appropriate use of an allotment or portion of an allotment, and it should occur again (or the same analysis reexamined), if the agency concludes grazing is appropriate, as a basis for making sound grazing management decisions in the context of BLM's multiple use mandate.

[3] This suitability analysis overlaps with our analysis of stocking rates (Appendix B). 

[4] See Joseph M. Feller, “The Comb Wash Case: The Rule of Law Comes to the Public Rangelands,” 17 Public Land & Resources L. R. 25, 50-51 (1996) (“[G]razing capacity should be considered an outside, upper limit on livestock numbers, not a desirable level or a goal.  Grazing by a number of livestock equal to, or even below, an area’s measured grazing capacity can, and often does, seriously degrade other resources and seriously affect other land uses that are not taken into account in the measurements used to determine capacity.”).

[5] The finding by the Park Service that ongoing livestock grazing was damaging and destroying cultural resources in Glen Canyon National Recreation Area is discussed more fully in Chapter 2.

[6] In Environmental, Economic and Legal Issues Related to Rangeland Water Developments, Jon Souder undertook to assess the relative value of various uses of the Kaibab Plateau.  He determined that “the vast majority of public benefits, whether locally or regionally, result from recreation-related uses of the Central Winter EMA.”  How Does Livestock Grazing Fit Into the Larger Societal Uses of Wildlands? at 304.  While Souder represents the relative values of the resources uses in terms of dollars, such an approach is not necessary.  Moreover, the assigning of values is not an economic notion, as FLPMA specifically notes that the best combination of resource uses need not generate the most economic return.  However, FLPMA does require some method for assessing the relative value of the various uses of the land.

[7] Appendix C discusses the factors most important to a determination of whether steams and riparian areas are properly functioning.


[8] Because this is a lengthy section of the guidance document, and because we already submitted this portion of the guidance document to the GSENM, it is housed as a “stand-alone piece,”as Appendix B

[9] “Recovery Prescriptions” should also consider recovery from exotic species infestation and the eventual return to a more normal fire regime. 

[10] Some parts of an allotment may be unsuitable for grazing because of specific situations (such as deteriorated biological crusts) that can take many decades to recover.  In order for part of an area to be successfully managed as unsuitable, some form of control must be implemented to prevent grazing in unsuitable areas.  In most cases, this means that the unsuitable area is fenced from grazing use.

[11] BLM has a long history of not doing required monitoring studies.  In 1992, the General Accounting Office (GAO) issued a report (GAO/RCED-92-51) on rangeland management, finding that the Department of the Interior’s monitoring program had fallen short of agency requirements.  It found that required monitoring was not occurring on most grazing allotments; that BLM was not making decisions with the available monitoring data; and that grazing decisions were often not adequately documented.

[12] However, in some Resource Areas in northern Utah and Idaho, BLM is monitoring forage productivity on an annual basis.  Particular examples are the Salt Lake Field Office use of forage capacity to determine stocking rate, exclosures, wildlife monitoring and annual capacity surveys to adjust stocking on an annual basis.  Another example is the Jarbidge Resource Area in Idaho where annual forage production measurements covering large areas have been conducted beginning in 2001.

[13] That said, the Monument staff should recall that in cases where resources are clearly degraded, the BLM does not need quantitative data to make management changes such as removing such degraded areas from grazing.  This is stated in Handbook 4180-1, pg. III-14.

[14] Estimation of annual production (and methods used) needs to be carefully designed, since, according to Biondini et al. (1991), over-estimations of production are common. 

[15] We feel the BLM could do a more comprehensive job surveying cryptobiotic crusts in GSENM.  The BLM should produce a map showing those areas capable of having cryptobiotic crusts, and what condition crusts are in in thos locations (i.e. near potential?).

[16] It has been called to our attention that one alternative in the DEIS may consider “experimental” grazing management, where various Holistic Range Management (HRM) practices advocating by Alan Savory and others will be “tested.”  We call attention to the scrutiny and skepticism recently directed to these practices by renowned ecologists and conservation biologists (see Appendix D), and the Monument’s own EAs for the Buy-out allotments (i.e Clark Bench, Willow Gulch – see Appendix H: “Effects of herbivory and trampling, BLM 2002a and b).

[17] See pg. 11 of Appendix B for more discussion of the Chestler Park study

[18] Deferred-rotation may have a benefit where various areas are more convenient to livestock than others and therefore are more regularly used.