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.  In addition, maintaining the health and productivity of southern Utah desert landscapes draws on common values shared among BLM employees, ranchers, and conservationists.  As the BLM embarks on a very important process of analyzing and potentially overhauling the Monument’s grazing program, it must keep in mind these values, while heeding the considerable evidence of the deleterious impacts of cattle grazing to the Monument’s biological and ecological resources.   It is clear that some significant changes in grazing management in GSENM are needed.


In this guidance document, we have carefully outlined what BLM must do in this DEIS process, and made pointed recommendations based on agency policy, national Standards and Guidelines, and the best available science.  For example, and of utmost importance, FLPMA requires the BLM to make a reasoned and informed decision as to whether or not grazing is an appropriate use of each part of the Monument.  And the Monument must make rigorous determinations of whether cattle are indeed the cause of impairment in the Grand Staircase, and act on these determinations.  It would behoove the BLM to adopt part or all of the method we propose to make determinations, as it is based firmly in range science.  Given the extraordinarily high ecological, scenic, and cultural values in the Monument, and the generally poor livestock forage available in the Monument, closure of portions of the Monument to grazing should be a high priority in the upcoming DEIS.  For those allotments that the BLM does determine are indeed capable of and suitable for supporting grazing, we present new methods for setting stocking rates that we strongly urge the Monument to take into account.  And lastly, as the Monument devises and weighs alternatives for the DEIS this fall, it must determine how conformance with Standards and/or progress towards conformance with Standards vary among the different proposed alternatives.


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


The Grazing DEIS should clearly identify what actions will be taken to improve ecosystem health when standards are not being met and grazing is determined to be the cause of degradation.  Using an extensive review of the grazing science literature, the major point that emerges in this document is that increasing grazing intensity leads to increased impacts to the land, most notably degraded streams and riparian areas, changes in vegetation structure and composition, and increased soil impacts such as compaction, erosion and reduced infiltration rates.  It therefore follows that decreases in grazing intensity will reduce or reverse these impacts when they occur.



5.1  The role of science in the Monument’s grazing program[1]


The much-touted role of scientific study in GSENM (BLM 1998) pertains to grazing too.  The final management plan for GSENM gave great fanfare to the role of science in the Monument.  It is certainly appropriate for the BLM to design objective, long‑range studies to isolate the true impacts of practices like differential stocking rates, rotational systems,[2] seasons-of-use, and grazing of different vegetation types on various independent variables.  Then, the findings could lead to important changes in the way the BLM manages cattle.  This would fit nicely into the adaptive management framework described in the GSENM Management Plan, and could set an example for what kinds of management and monitoring efforts are truly required to insure maintenance of native biodiversity and ecosystem processes in arid regions of the intermountain West.  We suspect there are numerous faculty in Colorado Plateau Universities who would like to have their graduate students working with the BLM on important studies such as these.


Of course, any well-designed grazing effect study needs to be compared to ungrazed controls.  The 1-acre exclosures traditionally used by range managers for comparisons are not adequate.   Something that needs to be strongly considered in this DEIS is the retirement of allotments that are failing to meet Standards.  The removal of livestock over very large scales such as those of entire allotments would not only accord with calls from conservation biologists to establish a network of large-scale grazing exclosures throughout western North America (Bock et al. 1993), but was the specific recommendation of over 30 scientists and natural resource experts who provided joint comments and analyses to GSENM during the comment period for the Draft Management Plan (Round River Conservation Studies 1999).  Such large exclosures would be large enough to demonstrate landscape-level ecological effects, and would include a diversity of habitat types, including both riparian and upland communities.


Moreover, with a number of recent buy-outs recently negotiated by the Grand Canyon Trust in the GSENM, the BLM is in a good position to designate these newly ungrazed allotments for research as well.  The Buy-out allotments, as “laboratories,” would allow for invaluable scientific research concerning rates and pathways for successional change for vegetative communities and cryptobiotic soils.  Knowledge gained form such research will aid future management of vegetative and crust communities found on comparable sites in the Monument and across the Colorado Plateau.  In addition, the use of Buy-out allotments for research would expedite experimentation with various treatments designed to restore large, heavily impacted sites such as those associated with water troughs.  Information acquired through this research will facilitate restoration of comparable sites in the Monument and throughout southern Utah.


Importantly, the BLM needs to carefully monitor sites (over the long term) where cattle have been removed and to compare these sites to currently grazed areas to assess effects of cattle removal from the range.  Perfect opportunities for this lie in not only in buy-out pastures, but also in the 40-mile ridge allotments that were recently removed from grazing pressure due to utilization levels in excess of 90%.  Since these allotments are clearly incapable of supporting cattle, they are a likely candidate for a long term recovery study.  We also call on the Monument to turn any existing “grass banks” in GSENM into long-term recovery exclosures.  Tim Graham, of USGS-BRD, is currently conducting a grazing-removal effects analysis in one of the Monument’s grass banks (personal communication with Tim Graham).  However, Dr. Graham’s data will be useless unless two conditions are met: 1) to detect changes in a system, time is needed.  The study must not be interrupted by any cattle for at least a half-dozen years.  2) The grass bank must be fenced.


W call on GSENM to put its money where its mouth is in regards to GSENM’s purported dedication to science within its borders.  This should begin by using opportunities such as buy-out allotments to create large areas free from grazing, and then by inviting scientists and their graduate students to design sophisticated, long-term grazing-impact studies that can seriously inform BLM’s grazing management processes.  The Monument is already putting in place a hand-picked Science Advisory Council, and this group of experts should provide input into this DEIS and the reformed grazing management program we expect will result from it.  Above all, all future monitoring in the Monument should use active hypothesis testing as the chief framework for field data collection.




5.2  This DEIS in light of “Sustainable Working Landscapes”


As the Bureau of Land Management changes how grazing is managed on its holdings, the BLM has the opportunity – through this DEIS process in the Grand Staircase - to ensure that certain key issues (i.e. “FLPMA balancing, forage/capacity analyses, determining causes of impairment, and the crucial issue of permanent impairment of productivity) are identified, reported to the public, and treated in the new policy.   We would argue that in order to sustain ranching, the productivity of our rangelands needs to be restored and any use should occur in deference to the ecological needs necessary to sustain the health and productivity of the land.  The solution of these problems is central to ensure that ranching on public lands is sustainable.


The BLM’s proposal to implement “Reserve common allotments” makes the assumption that there are today ungrazed allotments in reserve and available.  We are concerned that this idea may assign retired grazing allotments to be common allotments.  Allotments that are today managed for multiple uses other than livestock grazing are likely to be chosen and this would have profound negative effect to the health of the land.  We strongly caution the Monument against designating retired AUMs to grassbank status in the Final EIS.  If grassbanks are to be established in the Monument, these allotments should be those that are currently grazed today, and such reserve allotments should be managed to ensure for the health and productivity consistent with ecological needs of all public rangelands.



5.3  This DEIS as a model for other Resource Areas


The BLM has an extremely important job in front of it.  The Grand Staircase Escalante National Monument was the first national monument entrusted to the BLM, and is one of very few monuments managed in this way. The purpose of the upcoming Environmental Impact Statement should not just be to quickly usher through term grazing permit renewals in a boiler-plate fashion (as is being done in the Kanab and San Juan Resource Area), but to take a hard look at the true impacts of grazing on the Monument’s important resources.  The BLM did a fine job on the GSENM Final Management Plan - even many conservationists have praised it.  The BLM needs to approach this DEIS in a similar fashion by embracing all relevant science, working closely with the interested public, and being ready to take Monument grazing management and practices in a new direction.


This DEIS needs to go beyond the assessment of environmental impacts, however.  It needs to take a hard look at the grazing management practices that have become entrenched in the region, and dissect the entire management program, policies and guidelines that have attributed to those practices.  As of 2001, the state of Utah ranked last of all western states in terms of compliance with the national Fundamentals of Rangeland Health (personal communication, National Wildlife Federation).  Moreover, 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).  As evidenced in this guidance document, the BLM’s own data and the scientific literature make an overwhelming case that the generally degraded conditions found in the Monument (and on southern Utah rangelands in general) are attributable to cattle grazing.  BLM has an opportunity to not only steer the Monument’s rangeland health and productivity onto the right track by lowering grazing levels and changing many aspects of grazing management, but also to set an important example and precedent for other Resource Areas that are current undergoing permit renewals and management plan revisions. 


In addition, the BLM must come up with thoughtfully written and detailed AMPs for each allotment in the Monument, as it promised in the Final Management Plan (plan, pg. 2.28). These AMPs must foster site-specific implementation of all grazing prescriptions presented in the FEIS.


In closing, this guidance document compiles BLM’s own data to show that current grazing practices in the Monument are violating the full spectrum of the agency’s legal duties.  Because of excessive livestock grazing, ecosystems are not properly functioning, the beneficial uses of streams are not being met, cultural resources are being destroyed and delicate soils are being irreparably lost.  In response, this document presents a system of livestock grazing, assessment and monitoring that, if implemented, will allow BLM to comply with its legal obligations – or at least will allow the agency to make great strides in that direction.  A system of grazing that does not recognize the science and the analysis presented here and does not address the significant failures of current grazing practices in the Monument will not met the agency’s obligations and will fall hopelessly short of the law.



[1] Unfortunately, many EISs contain inadequate references, use outdated science, and/or rely on scientifically unsubstantiated opinions as science.  Because the public has limited confidence in government agencies to manage public lands (Brunson and Steel. 1994), and because the ecological costs of livestock grazing in arid and semi-arid ecosystems have been clearly elucidated (see chapters 3, 4 and Appendix A), it behooves the DEIS staff to use very solid, contemporary science in analyzing the Monument’s grazing program and assessing its environmental consequences.  Also, without the backing of good science and data, statements regarding grazing effects must be treated as personal opinions, and opinions are not an acceptable basis for management decisions.  Use of scientifically unsubstantiated opinions as a basis for management decisions can leave public-land management agencies and their personnel vulnerable to accusations of 'management by myth'.

[2] 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).