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Review Interior Columbia Basin Ecosystem Management Project Draft Environmental Impact Statements

Public Land Grazing Permit Retirement  

**DRAFT**
None of the Alternatives in the ICBEMP Draft Environmental Impact Statement will Protect or Restore Rangelands of the Interior Columbia Basin
**DRAFT**

by: Joy Belsky
Oregon Natural Desert Association
December 14, 1997

The rangeland section of the Draft Environmental Impact Statement (DEIS) is a microcosm of the failure of the Interior Columbia Basin Ecosystem Management Project (ICBEMP). Although approx. 70% of the rangelands in the Interior Columbia Basin are rated as having "low ecological integrity" and only 5% are rated as having "high ecological integrity", the DEIS fails to develop strategies for protecting the still healthy rangelands, or for restoring the rest. Neither does it honestly describe the major factors causing this extensive loss of ecological function, nor past management actions that allowed the degradation to take place. This failure pertains not only to the assessment and management of grass- and shrub-dominated communities, but to grazed woodland and forested ecosystems as well.

The current major environmental problems in grazed ecosystems, i.e. degraded and non-functioning streams, exponential spread of noxious weeds, permanent replacement of grasslands by shrublands and of shrublands by woodlands, and establishment of new and destructive fire regimes (DEIS, 1997, Hann et al. 1997), will continue unabated unless substantive changes are made in the management of rangelands and forests in the Interior Columbia Basin. Such changes are not part of any of the seven DEIS alternatives.

The failures to meet ICBEMP goals to protect and restore Basin ecosystems are due neither to a lack of understanding of rangeland function and forest dynamics, nor to a lack of available management techniques to correct these problems. Instead, they are due to ICBEMP managers failing to utilize this information to develop viable management prescriptions to restore grazed Basin ecosystems. The major problems in the DEIS relating to rangeland and grazed forest management are:

I. Livestock grazing, the dominant environmental factor degrading rangeland communities and one of the major factors permanently altering the dynamics of dry and moist forests, is consistently played down in the analyses and virtually ignored in the standards;

II. The environmental effects of livestock grazing in forests were not evaluated;

III. The standards in the DEIS do not require managers to stop destructive management practices nor adopt new practices that will protect and restore rangelands;

IV. There is no consistent guidance in the DEIS to help district-level managers develop effective site-specific management practices to protect and restore rangelands; and

V. Restoration of degraded ecosystems is encouraged over the prevention of future degradation.

I. Impacts of Livestock Grazing on Rangelands and Interior Forests

Out of 76 million acres of Forest Service and BLM-administered lands in the Interior Columbia Basin, approximately 32 million acres of rangelands and 20 million acres of dry and moist forests are managed for livestock grazing. Development of the Northwest livestock industry in the late 1800s introduced intensive herbivory to herbaceous plant species that had not evolved with heavy grazing. It also introduced extensive soil disturbance from trampling, heavy use of riparian habitats, and intense competition for resources to plant communities and wildlife that were dependent on clean cold water, native bunchgrass communities, periodic, low-intensity fires, and on healthy soil crusts of lichens, algae, and mosses (the microbiotic crust).

Before livestock were introduced, plants were only lightly grazed and communities minimally disturbed by the low densities of native wildlife. High densities of sheep and cattle later destabilized nearly every component of the ecosystem: livestock stripped hillsides of the native grasses necessary to hold soils in place; they denuded riparian areas, thus increasing soil erosion, water temperatures, and sedimentation; they destroyed the fragile microbiotic crust that is critical for stabilizing soils and increasing their fertility; they reduced the vigor of native grasses and herbs so that trees and shrubs more easily invade; they removed the grasses that provide the fuel necessary for the spread of low-intensity surface fires; and they increase the invasibility of native plant communities to noxious weeds.

The environmental consequences of livestock grazing began to occur soon after cattle and sheep were introduced to the Northwest. They continue today. Because of past and present livestock grazing, formerly healthy grasslands and shrub communities are being invaded by noxious weeds, fire frequencies in many communities are reduced, shrubs and trees are invading or increasing in density, and the loss of the microbiotic crust is reducing plant productivity and soil stability ((DEIS 1997, Quigley, 1997, Hann et al. 1997). As a consequence, 70% of Basin rangelands are ranked as having "low ecological integrity" and 70% of Basin streams and riparian areas are classified as being "non-functional" or "functional at risk".

Although the effects of livestock are well documented in the scientific literature, their impacts are systematically devalued in ICBEMP documents. For example, whenever environmental damage due to livestock is mentioned, the DEIS refers to it as being caused by "improper" or "excessive" grazing, or by overgrazing at the turn of the century. In fact, there is ample evidence that all but the lowest levels of livestock grazing are excessive in the arid rangelands of the Intermountain West (Mack and Thompson 1981), which explains the progressive decline of rangeland function over the last hundred years and the widespread invasions of weeds and woody species.

The DEIS attributes most of the recent changes in rangeland communities to (1) fire suppression, (2) "excessive" livestock grazing, (3) invasion of exotics, and (4) the encroachment of junipers. Thus, fire suppression, exotics, and junipers are incorrectly attributed equal status with livestock grazing. This equal status is incorrect because livestock cause the other three environmental changes. They are partially or wholly responsible for the altered fire regimes (through removal of fine fuels), the invasion of exotic pests (by disturbing soils and spreading weed seeds), and encroachment of junipers (by reducing the competitive abilities of grasses and fire frequency) (discussed in Hann et al. 1997). The DEIS is more honest when it states, "The most profound effect [of rangeland management] is the general change in composition and structure within the upland shrub and herb plant communities as a result of heavy early-season or season-long livestock grazing and seeding to perennial exotic grasses." (DEIS, 2-99) But elsewhere (and contrary to most scientific evidence), livestock grazing effects were excluded from evaluations of disturbance because "they were assumed to mimic native grazing and not cause direct change" (Quigley et al. 1997, p. 106)

Soil disturbance and compaction is a major and ubiquitous impact of livestock grazing. Although most of the surface soils on the 32 million acres of grazed rangelands in the Columbia Basin are disturbed and compacted by livestock hooves, this disturbance was virtually ignored in the DEIS. Not only was this disturbance assumed to not cause direct changes (above), but in Table 3.29 (Hann et al. 1997) only 78,000 acres of rangelands are shown to currently be disturbed. Furthermore, some types of livestock grazing are described as "non-impactive" (Table 3.14), a description that is neither defined nor defensible.

The ecosystem component perhaps most critical to healthy rangelands, and the one most disturbed by livestock, is the microbiotic crust. There is a broad consensus among botanists and range scientists that these fragile, living soil covers of the soil surface play a vital role in arid and semiarid rangeland ecosystems (St. Clair and Johansen 1993, Harper and Marble 1988, ICBEMP scientific reviewers Dr. J.D. Williams (1994), BLM botanist J. Kaltenecker, and Boise State Univ. Professor M. Wicklow-Howard (1994)). The most important role of crusts is considered to be their ability to stabilize soil surfaces and improve soil fertility. In addition, crusts increase herbaceous productivity, reduce weed invasions, fix nitrogen from the air, and increase plant nutrient content. Although these crusts are extensive throughout the Great Basin, Intermountain West and Columbia Basin (above references), the DEIS (inaccurately) describes the 100+ scientific studies demonstrating the importance of microbiotic crusts in arid ecosystems as being inconclusive, and concluded that prescriptive management for crusts was premature. In doing so, the DEIS team ignored the consensus of the scientific community as well as the strong advice of the authors of its own scientific assessments.

II. Forest Grazing was not Evaluated

A large percentage of dry and moist forests on public lands in the Interior Columbia Basin (approximately 20 million acres) are leased for livestock grazing (Map 3.25, Hann et al. 1997). Historically, most of the forests were open and park like, and were underlain by a dense layer of grasses and sedges. Since the latter part of the 1800s (Irwin et al. 1994), these forests have been extensively grazed by cattle and sheep. Trampling and grazing changed the composition and dynamics of the forests by reducing the abundance of the grasses and sedges that historically had (1) served as fuel for the low-intensity, surface fires and (2) out-competed tree seedlings for water and light. Consequently, these grasses and sedges were critically important for thinning tree seedlings and keeping forests open and the trees well spaced. By reducing the cover and biomass of the herbaceous cover in forests, livestock contributed to reductions in frequency of low-intensity fires and interspecific competition, and therefore, to higher densities of tree seedlings and saplings. Eventually, these seedlings and saplings developed into forest stands that were overstocked with fire-intolerant species and had greater numbers of diseased and water-stressed trees, higher fuel loads, and a potential for more and hotter fires (Rummell 1951, Madany and West, 1983; Zimmerman and Neuenschwander, 1984; Savage and Swetman, 1990; Belsky and Blumenthal 1996; see Belsky and Blumenthal for additional references). The DEIS virtually ignored the impacts of forest grazing even though NEPA requires an thorough evaluation of all major factors affecting the environment.

These changes in species composition and forest dynamics in the dry and moist forests of the Interior Basin were attributed in the DEIS nearly entirely to (1) fire suppression and (2) selective logging. Although the ability of livestock to reduce grass biomass on forest floors was mentioned (e.g. DEIS 2-69), this factor was discussed only briefly, as opposed to the long discussions of fire suppression and selective logging. Readers of the DEIS can only conclude that fire suppression and selective logging were the two overriding factors altering forest dynamics, even though there are numerous studies showing that the above changes to Eastside forests began occurring decades before fire suppression or selective logging were introduced (Rummell 1951, Madany and West, 1983; Zimmerman and Neuenschwander, 1984; Savage and Swetman, 1990; Belsky and Blumenthal 1996; see Belsky and Blumenthal for additional references).

III. No Strong Standards Presented for Rangeland Management

Standards for Rangelands

Only three standards were developed for the management of all BLM and Forest Service-administered rangelands in the preferred alternative:

TS-S1: Native plant communities shall be maintained or improved to ensure the proper functioning of ecological processes, and continued productivity and diversity of native plant species. The conversion of native plant communities to exotic communities after disturbances shall be minimized.
TS-S22: Rangeland management strategies shall be implemented to achieve the maintenance or restoration of watershed function; nutrient cycling and energy flow; water quality; habitat for endangered, threatened proposed, candidate or special status species; and habitat quality for populations and communities of native biota.
TS-S23: On dry shrublands, livestock grazing shall be managed to maintain soil and vegetative health and productivity during and directly after drought years.

These standards are inadequate because they simply restate the purpose of ICBEMP: that ecosystem health and ecological integrity be restored or maintained. None incorporate "required management actions addressing how to achieve objectives" (DEIS, 3/59), which is the explicit reason for establishing standards in management plans. These standards also reiterate the objectives of earlier plans, which have long guided Forest Service and BLM managers throughout the Northwest. But in spite of these lofty and long-standing goals, Basin rangelands are still being invaded by noxious weeds at an exponential rate, junipers are still encroaching into grasslands and shrublands, and stand structure and composition are still being altered. Although these and other problems are due to current management practices, none of the standards contain the language necessary to force managers to change destructive activities, to inform them how to achieve management goals, to help them prioritize actions, or to inform them when they have to implement difficult but necessary decisions, such as reducing stocking rates or mandating short- or long-term rest..

Standards for streams and riparian areas

More standards, AQ-S11, 12, 13, 14 and AQ-S50 and 51, were developed to guide livestock management in riparian zones and streams. However, these, too, are mostly restatements of the goals of ICBEMP, which is to restore or maintain healthy ecosystems. Where specific objectives must be achieved (e.g. AQ-S11 and S12), the standards require only that a "upward trend" toward these goals be shown. If the trend is not upward, then "grazing prescriptions that will result in substantial progress towards the recovery of streams and riparian areas" must be used. "Upward trend" and "substantial progress" are neither defined, nor an acceptable rate of change stated. The consequences of the "trend" or "progress" not moving at an acceptable rate, of a failure of grazing prescriptions, or of the number of years movement can be "downward" are not spelled out. Only two standards, AQ-S50 and 51, expressly state actions that must be taken - that livestock be managed to prevent them from disturbing spawning grounds of endangered fish species, but doesn't suggest how.

Standards for wildlife/livestock interactions

Two standards, HA-S20 and 21, recommend that conflicts between wildlife and livestock be minimized, which is only common sense, but doesn't arbitrate who should be favored if conflicts are unavoidable.

Standards for livestock grazing in forested ecosystems

There are none.

IV. Inaccurate, Inconsistent, and Contradictory Guidance for Rangeland Managers

Riparian grazing

The DEIS and other ICBEMP documents state that "there are numerous prescribed grazing strategies for livestock that can be successful in riparian areas" (Hann et al. 1997, p. 769). They mention different strategies such as season of use, and different grazing systems such as rest-rotation, deferred grazing, and short-duration grazing. However, the same documents (as well as many studies in the range science literature such as Elmore and Kauffman 1994, Clary and Webster, 1989, etc.) report that springtime grazing leads to loss of native bunchgrasses and serious damage to wet soils and streambanks (p.780); summer grazing leads to loss of woody species, loss of plant vigor, and loss of seed crops (p. 770 and 780); autumn grazing leads to loss of woody species, long-term streambank disturbance, and loss of vegetative cover needed to protect riparian soils (p.770, 780, 781); and winter grazing can lead to loss of woody species, compaction and disturbance of wet soils, and loss of litter needed to protect soils (p. 771, 780, 781). In other words, there are no seasons in which grazing is not harmful. The suggestion in the DEIS that managers alter season of use is confusing and could lead to increased range damage..

In addition, Hann et al. (1997 p. 771, 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. Hann et al. (1997,) also conclude that season-long grazing, spring and fall grazing, and spring and summer grazing do not provide for successional advancement of riparian vegetation. Elsewhere (Table 3.173), however, Hann et al. (1997, p. 774) contradict these conclusions by stating that winter grazing, early growing season grazing and early rotation are acceptable because they lead to increases in shrubs and herbs, and stabilization of streambanks.

The above confusion is not necessary. When Clary and Webster (1989) summarized research on different riparian grazing systems, they concluded that "experience in riparian areas has generally failed to show an advantage to any specific grazing system" (p. 8). They also concluded that "the level of utilization [i.e. the percentage of the current year's crop consumed] to be the most important consideration" (p.1). Platts (1989) agreed and recommended (1) the use of riparian pastures (which strictly limits riparian grazing), (2) streamside fencing, (3) increased periods of rest, and (4) reduced intensity of use as the best ways to restore degraded streams. Reduced levels of use and non-use were therefore his main recommendations for restoring streams..

The only grazing system consistently found to restore and protect streams at an acceptable rate is "no grazing" and "corridor fencing" (Elmore and Kauffman 1992, Ohmart, 1996, Belsky et al. (in press) and most fisheries biologists). In fact, Meehan and Platts (1978) and Platts and Wagstaff (1984) found no grazing system that was compatible with healthy aquatic ecosystems. Hann et al. (1997) admitted that exclusion of livestock for two or more years was necessary for initiation of recovery of degraded streams (p.771 and p773). However, exclusion of livestock was not recommended in any of the alternatives, not even for non-functional streams or to improve highly sensitive riparian areas such as critical spawning areas for sensitive fish species. Instead, Hann et al. (1997) repeatedly, and contrary to scientific evidence, stated that reduction in livestock numbers will typically have little positive effect on riparian systems. To support this, they cited a paper finding that salmon spawning was enhanced by the presence of livestock! This last paper was never published in a refereed journal and was severely criticized by top fisheries biologists who were studying the same stream segment. Such papers, which present isolated and unverified conclusions, should not be used to support questionable practices on public lands.

Rangeland (upland) grazing

ICBEMP documents repeatedly concluded that there is also no reason to reduce stocking rates (i.e. number of livestock) on rangelands (uplands) in the Basin. Instead, ICBEMP authors concluded that "Improving ecological conditions on rangelands depend more on grazing systems [i.e. deferred grazing, rotational grazing, etc.], season of use, and improvements than on strictly controlling the number of livestock grazed [i.e. the stocking rate]." (DEIS, 4-169, Quigley et al. 1997, p.102)). This position, which seems to have been used to rationalize maintaining current livestock numbers in all DEIS alternatives (except reserves), is thoroughly refuted by top range scientists. For example, Pieper and Heitschmidt (1988) concluded that "stocking rate is and always will be the major factor affecting degradation of rangeland resources". Vallentine (1990) concluded that "it almost appears in some cases that grazing systems have been introduced as substitutes for good livestock and forage management". In a review of grazing systems, Herbel (1974) concluded that grazing systems did not result in an improvement in range condition and that stocking rate is likely the overriding factor in determining whether a grazing system works. Mueggler (1975) found that Idaho fescue and bluebunch wheatgrass required 3 and 6 years of rest, respectively, to recover from grazing, a longer period than any grazing system permits. And Hart et al. (1989, 1993) found that proper stocking rates were more important than grazing systems in improving rangeland vegetation. Clary and Webster (1989) summarized these findings: "recent information on grazing uplands suggests that although conventional grazing systems have great intuitive appeal, they are less effective at maintaining ecological quality and livestock production than previously thought" (p.1). More recently, Taylor et al. (1997) concluded that "rotational stocking ... was not able to sustain initial species composition at any stocking rate tested", and Ortega et al. (1997) conclude that "stocking rates … have a more significant impact on phytomass [plant biomass] than grazing systems".

Furthermore, Eckert and Spencer (1987) concluded that season of use has not been found to compensate for heavy grazing at any time of the year, and Trlica et al. (1977) found that most species required more than two years of rest after defoliation during most seasons of the year. Anderson (1991) reviewed the literature on grazing on bluebunch wheatgrass in the Northwest for the Idaho BLM Office and concluded that grazing damages bluebunch wheatgrass, the most important native bunchgrass in the Basin, during all seasons of the year, including during the dormant season. He found that grazing was especially damaging during the spring. And Sauer (1978) found that standing dead litter is beneficial to bluebunch wheatgrass, which declines with overuse in the winter. These conclusions in the scientific literature about spring and winter grazing are important because these are the seasons ICBEMP recommended for grazing activities.

Microbiotic crusts

The critical importance of microbiotic crusts to rangeland ecosystems for stabilizing soils, increasing soil fertility, etc. is discussed in the DEIS and Hann et al. (1997), as well as being thoroughly discussed in ICBEMP ecological assessments by Williams (1994) and Kaltenecker and Wicklow-Howard (1994). Their conclusions were well documented by peer-reviewed papers, and are the consensus of academic as well as BLM scientists (e.g. Dr. Roger Rosentreter and Julie Kaltenecker, Boise State BLM Office). In spite of this, the DEIS stated that microbiotic crusts would not be considered for management purposes (DEIS 2-114), explaining (inaccurately) that the role of crusts is not "conclusive at this time". However, these roles are certainly more conclusive than Hann et al.'s beliefs in the efficacy of grazing systems and the benefits of livestock grazing on salmon spawning, which are questioned by most of the experts in the field. Interestingly, the authors of ICBEMP assessments on microbiotic crusts explicitly recommended that Basin rangelands be managed for healthy microbiotic crusts (Dr. John Williams, 1994, p. 42) and appealed for strong protection for all remaining areas in the Basin with intact crusts (Kaltenecker and Wicklow-Howard, 1994, p.38). The authors of the DEIS did not explain why they ignored their own scientific experts.

Juniper encroachment

The inconsistency in the DEIS is also evident in the discussion on juniper invasions. The DEIS states that juniper establishment in shrublands is occurring both "with and without" livestock grazing (p.775), thus implying that grazing is not a cause of juniper encroachment. However, Eddleman et al. (1994), the authors of the ICBEMP ecosystem assessment on junipers, recommended non-use under some circumstances, including up to 4 years of non-use in severely degraded systems. These recommendations were not incorporated into any of the alternatives.

Restoration and stocking rates

The conclusion that runs through all ICBEMP documents -- that reduction of stocking rates will not increase rangeland recovery (because some Basin rangelands have supposedly passed through "thresholds" into new "stable" states) -- is not only refuted by leading range scientists (see above) 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, quoted in Hann et al. 1997, p.765);

(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; and

(4) For all rangeland vegetation types, including riparian, grassland, dry shrub, and cool shrub, the highest departures of these community types from their original species composition and structure "were in areas subjected to high levels of continuous season-long or early-season grazing" (Hann et al. 1997, p.505 and elsewhere). Lower stocking rates may not have caused as much damage.

What is neither discussed nor evaluated anywhere in the DEIS and associated documents is whether non-use or reduced stocking rates plus some restoration activities would have had the highest probability of restoring rangeland ecosystems. There is no doubt that they would have.

V. Restoration is Encouraged over Prevention

Noxious weed prevention

Noxious weeds are spreading through rangelands at an "exponential rate" and are now found in every county in the Basin. These weeds are highly aggressive, highly competitive, tolerant of livestock grazing or unpalatable, alter ecosystem processes, and can form new stable communities that exclude native plant species, perhaps forever. Since most rangeland cover types are susceptible to weed invasions, it is critical that the highest priority be given to reducing or stopping their spread.

Discussions of control of noxious weeds in the ICBEMP documents led to some of the most insidious, confusing, and potentially damaging management proposals in the DEIS. Topics discussed in the documents could have, and should have, guided the DEIS team to formulate better weed management plans for the Columbia Basin. Among these topics are the following:

(a) Most of the invasive weeds are "pioneer" species that colonize soil surface disturbances, such as those created by the trampling of soils and microbiotic crusts by livestock hooves;

(b) A few noxious weed species can invade relatively undisturbed sites, making it critical that effective preventative measures be used to stop invasions or reduce weed abundance in surrounding lands;

(c) The very low densities of noxious weeds on reserves and lands with healthy, vigorously growing bunchgrasses and intact microbiotic crusts demonstrate that healthy rangeland communities are our best, and maybe our only, tools for fighting the invasion and spread of weeds.

(d)"Noxious weed control on BLM- or Forest Service-administered lands has generally been ineffective", mainly due to limited budgets (weed control is expensive), lack of coordination, and an inability to get ahead of the weed problem (DEIS); and

(e)"The least expensive, most effective, and the highest priority weed management technique is prevention" (DEIS, 2-104 and 105).

The author of the ICBEMP weed assessment, Dr. Roger Sheley (1994), emphasized that "Preventing the introduction of rangeland weeds is the most practical and cost-effective method for their management. Prevention programs include such techniques as limiting weed seed dispersal, minimizing soil disturbance, and properly managing desirable vegetation." (p. 3). Throughout this report, the importance of preventing invasions was emphasized: "riparian areas must be protected from invasion by noxious weeds"; "once the infestation becomes established, eradication is unlikely"; "minimizing soil disturbance by vehicles, …, and livestock is central to preventing weed establishment", etc. The overall consensus of weed professionals (e.g. the individual authors of reports in Sheley (1994)) is that the best methods for preventing weed invasions is by (1) limiting weed seed dispersal, (2) minimizing soil disturbances, (3) managing native grasses so they remain vigorous and competitive, and (4) establishing competitive grasses where they have been lost. These recommendations were either ignored or presented with no concrete recommendations on how to implement them.

An extensive scientific literature going back many years (i.e. Piemeisel 1951, Mack 1981, Lacy 1987, 1990, Young 1994, Young and Longland 1996, and others cited in Sheley 1994), suggests that livestock grazing is the major cause of the spread of weeds in rangelands in the western U.S. Livestock disturb the soil, create microsites for weed seed germination, increase soil temperatures, pulverize microbiotic crusts that prevent the establishment of weeds, reduce the vigor and competitive ability of native plant species, and transport weed seed from infested areas into non-infested areas. One study, for example, found that one cow transported over 900,000 viable seeds from 36 different weedy species in her gut and coat in a single season (Dore and Raymond 1942).

Instead of creating standards that would prevent the invasion and spread of weeds into uninfested or sparsely infested rangelands, the DEIS requires managers to use Integrated Weed Management (IWM), which emphasizes weed control over prevention. It says little about preventing livestock disturbance and reduction of plant vigor, except after infested areas have been re-seeded. In Step 2, Preventing Weed Encroachment, IWM recommends that new weed introductions be minimized by using weed-seed-free hay, refraining from driving vehicles and machinery through weed infestations before driving into uninfested areas, placing livestock in a holding area for 14 days before moving them into weed-free areas, and requesting campers to brush and clean themselves before moving into uninfested areas. It also suggests minimizing unnecessary soil disturbance and managing grasses for vigor, but gives no recommendations. Most of IWM has to do with detecting, containing, and controlling large-scale infestations.

The references to minimizing soil disturbances and vegetative vigor are briefly mentioned in a long and otherwise detailed document, and are embedded near the end of a long list of preventative activities. Recent BLM weed management plans that utilize this same IWM strategy emphasize herbicide control of weeds, while totally ignoring weed prevention by limiting livestock movements and their disturbances to the soil, microbiotic crust, and native plants.

The above may explain why noxious weed control on BLM- or Forest Service-administered lands has "generally been ineffective". It also explains why IWM will not successfully control weeds in the Interior Columbia Basin. There is nothing in the DEIS standards or in the description of IWM to force managers to reduce disturbances to the soil and crust or permit native species to become more competitive. In fact, BLM and Forest Service managers will be encouraged to disregard livestock impacts by such statements in the DEIS as "weeds would continue to spread even in the absence of grazing" (DEIS 4-88) and speculation that "improved livestock grazing strategies" (2-84, 85) would reduce the adverse effects of grazing. The fact that the "reserves" were predicted to have worse weed infestations than grazed areas also suggests to managers that livestock are not the causes of the weed problem. This is totally absurd. The take-home message in the DEIS to BLM and Forest Service range managers is that livestock management has little to do with invasions.

Fires, junipers, and shrubs

As discussed earlier, the DEIS attributes the changes and degradation of Basin rangelands as much to changes in the fire regime, weed invasions, and juniper and shrub encroachment as to livestock grazing. To correct these problems, all restoration alternatives recommend prescribed fire, Integrated Weed Management, and the logging or burning of junipers and shrubs. Although all of these recent changes in Northwest rangelands may negatively impact ecosystems by reducing biodiversity, initiating new degraded stable states, etc., they are also normal environmental responses to grazing and therefore can be prevented. In other words, the DEIS treats these environmental consequences of livestock grazing as the causes of the problems. And the true cause of the problem - livestock grazing - is relegated to a minor role that DEIS authors believe does not require controlling except by vague and unproved techniques. Without addressing the cause of the altered fire regimes, weed invasions, and woody plant encroachment, the problems will simply come back, as occurred in the Southwest where junipers and pinyon pine simply reinvaded after they had been controlled by fire, logging, and chaining. Eventually, BLM stopped their control efforts because of the expense. This will also happen after expensive restoration efforts are applied to rangelands in the Columbia Basin, if care isn't taken to avoid the conditions that caused the problems in the first place. The DEIS does not focus its attention on effective prevention, only on excuses.

What is only partially discussed in the DEIS, and is thoroughly confusing, is damage to native ecosystems and species caused by the restoration programs. Reintroduction of fire at this time may cause an irreversible loss of nitrogen, which is lost from burning vegetation. More than 100+ years of livestock grazing has resulted in serious depletion in nitrogen stores in the soils (due to destruction of the microbiotic crust, losses of nitrogen from volatilization from urine and manure, consumption of nitrogen (in plant leaves) by livestock that are taken away to stockyards, and increases of denitrification due to soil disturbance). Additional losses of nitrogen from shrub- and juniper-burning programs may push extensive plant communities over "thresholds" into new and permanently degraded stable states. No satisfactory recommendations were made in the DEIS on how these potential and very serious problems should be handled..

Juniper control poses additional environmental threats. Logging to remove juniper will necessitate the construction of roads and cause disturbances to microbiotic crusts. Disturbances to the soil will therefore increase weed densities. Even if every driver of every logging truck and piece of machinery adheres to recommendations to wash the undercarriage of their vehicles before entering non-infested areas (doubtful), weeds will be brought in and distributed over the landscape. Additionally, juniper control often causes weed explosions due to nutrient enrichment from decomposing tree roots (Evans and Young 1985), as when control of juniper with picloram caused cheatgrass to increase under canopies from "almost none to about 1400 km/ha within 4 yr after treatment". Between tree canopies, cheatgrass also increased and medusahead became dominant.

Weed control may be the restoration activity most damaging to the environment. IWM is being interpreted by the agencies as giving them permission to spray large areas of public lands with toxic herbicides such as 2,4 D (which effects the growth, behavior, and development of birds, fish, and insects), Picloram (which kills non-target plant species, is persistent in the soil, and leaches into the groundwater and streams), Dicamba (which can leach into groundwater and streams and causes a variety of cancers and genetic damage), and glyphosate (which is acutely toxic to many species, including beneficial insects, fishes, birds, and earthworms, is persistent in soils, and significantly impacts non-target plant species). Spraying at the level necessary to kill most of the weeds also causes the death of native plants and many of the soil organisms necessary for nutrient cycling (conclusions of several speakers at a conference on Rangeland Restoration, Washington State University, March 24-25, 1997). The costs of herbicide spraying in terms of environmental damage were not discussed.

Forest grazing

In spite of extensive evidence documenting that livestock grazing is one of the major factors causing increased tree densities and fuel buildups in dry and moist forests, this factor was neither evaluated in the review documents nor addressed in the management plans. Without addressing all causes of forest problems, they will not go away. Once again, the DEIS recommends treating the symptoms, not the disease.

Conclusion

Although many of the discussions in the DEIS of rangeland ecosystem function and recent ecosystem changes in the DEIS are accurate, the take-home message, as well as the implicit recommendations to managers, is that weeds, junipers, shrubs, and fire are the problems that must be corrected, not livestock grazing. As a consequence, no substantive changes in grazing management or in stocking rates were recommended. Only quick-fix changes in grazing strategies were proposed, even though years of research have shown that none work as well as reductions in livestock numbers. No proof of their efficacy is demanded in the standards, nor a time table for the changes required. It is possible that one grazing system can be substituted for another for years, with no necessity to show an upward trend. Consequently, the ICBEMP management recommendations are a prescription for failure.

It is clear from the socio-economic surveys conducted by the Scientific Assessment Team (Status of the Interior Columbia Basin, 1996) that continued livestock grazing with its concomitant loss of habitat, species, and ecological function is not what the citizens of the Basin want. The ecological costs of grazing are far greater than the economic and social benefits of public-land ranching. When the citizens of the Columbia Basin were asked how they value the Basin's public lands, they rated the "existence value" of unroaded areas highest (47%), followed by recreational opportunities such as camping, motor viewing, and winter sports (38%). The value placed by the public on livestock grazing was not presented, but it is probably less than 1%. (Grazing was embedded in a category called Other (3.4%) that included mushroom and firewood gathering, Christmas tree harvesting, and berry picking).

Employment in the ranching industry was likewise of low importance in the Basin. Ranching produces just 1% of jobs in the entire Interior Columbia Basin, and federal-land grazing produces only 0.01 - 0.3% of the jobs in Oregon, Idaho, Washington, and Montana (Powers 1996, p. 184). This finding was reinforced by ICBEMP economic studies that showed a maximum of only 243-263 jobs generated by ranching on federal lands in eastern Oregon and Washington (DEIS, Table 4-57). Further demonstrations of the relatively minor importance of public-land ranching to the Basin's economy is that BLM and Forest Service lands provide only 7.0% of the forage used in the Basin and that cattle dependent on federal forage for some part of the year account for only 2% of total agricultural sales across the Columbia Basin (DEIS p.2-180, Haynes and Horne 1997, p. 1769).

The economic benefits of our public lands do not flow equitably to all permit holders of public lands. The bulk of the benefits go to a small number of individuals, corporations, and partnerships. The 1,000 largest BLM permit holders over the entire West (out of 22,000 permittees) control 50% of the total forage (AUMs), and the 1,000 largest Forest Service permit holders (out of 8,200 permittees) control 63% of the forage. Conversely, the 1,000 smallest permit holders of BLM or Forest Service forage control 0.3-0.4% of the forage (Haynes and Horne, 1997, p 1770). Only the largest permit holders appear to not be losing money on their operations (Table 6.17, Haynes and Horne, 1997, p.1770)

It is clear that the economic benefits that accrue to the few ranchers who lease BLM and Forest Service lands for grazing do not begin to match the economic and ecological losses to the public of healthy plant and animal populations, functioning ecosystems, clean water, recreation, and the knowledge that wild places still exist. These benefits certainly don't match the costs to the American public in terms of range management, road construction and obliteration, weed control, juniper burning programs, protection of endangered species, and restoration of streams and hillsides. By ignoring the realities of the ecology and economics of the Columbia Basin and the needs of the vast majority of its people, the authors of the DEIS, by choosing to maximize commodity extraction over every other use, have done the public a great disservice.

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