Subject: Comments on Draft Southeast Oregon Resource Management Plan and Environmental Impact Statement
My comments focus on the rangeland vegetation and domestic livestock grazing aspects of the Southeast Oregon Resource Management Plan and Environmental Impact Statement (SEORMP).
Given the magnitude of what I consider to be fatal flaws in the SEORMP, I will limit myself to the following flaws:
It is not clear in Chapter 3, The Alternatives, how much domestic livestock use is planned or anticipated under the various alternatives. These estimates appear only in Chapter 4, Environmental Consequences, in the Rangeland/Grazing Use section.
-Alternative A (page 4-105): Permitted AUMs constant to plus 10%.
Except for Alternative E which is provided only for analytic purposes, Alternatives A through D are all the same. All include present levels of use as part of the range of expectations, and the greatest variation contemplated (minus 20%) falls within the normal range of year to year variation. This can be illustrated by examining the authorized use on Section 3 lands for Oregon for the period 1980-1996 (the same period used in SEORMP for evaluating recent fire history) as reported in the respective editions of Public Lands Statistics. The average authorized use for that period was 834,601 AUMs for all Section 3 lands in Oregon, and the confidence interval at the .05 level of significance is plus or minus 210,267, or 25% of the mean (see attachment 1).
Therefore, up to 25% year to year variation in stocking is normal for Oregon public lands livestock operations, and Alternatives A through D are all the same as they all fall within that range of variation.
The "Desired Range of Future Conditions" in the SEORMP are extremely general and vague to the point that just about any kind of rangeland conditions could be rationalized as falling within the ranges specified. The SEORMP is supposed to be tiered to the DEEIS and should, therefore, reflect and refine the desired range of future conditions for the preferred alternative in the DEEIS. The SEORMP does not do this and, rather than being more specific, is actually more general and vague than the parent document.
In the absence of a tie of the SEORMP desired range of future conditions to those specified in the parent document, any analysis of cumulative effects is rendered null. In addition, how can you possibly attempt to manage to achieve those conditions if you haven't even determined what you have now?
The following table compares the desired range of future conditions for the preferred alternative for "Terrestrial Ecosystems - Rangelands" specified on page 3-34 of the DEEIS with an estimate of what you have now. The estimate of what you have now is based on tabulating data from the OAESIS database as presented in the appendix of Some Major Rangeland Potential Vegetation Types and Community Classes in the Interior Columbia River Basin and Northern Great Basin, by Larry L. Walker, BLM Oregon State Office, January 1997. (see attachment 2 for tabulation).
As you have pointed out (page 2-14), you have nearly total coverage with Ecological Site Inventories. Most or all of this information has been compiled into computer databases and geographic information systems (GIS). With these resources, you could readily have produced tables and maps of Ecological Condition at any level of detail - but you have not.
From GIS databases of allotments and pastures (which you also have) combined with monitoring data that you have collected and evaluated in accordance with Oregon's Rangeland Monitoring Handbook (Oregon BLM Manual Supplement H-1734-2) , you could have produced tables and maps of trend - but you have not.
Both of these items are necessary for an effective review of the SEORMP, and they are ESSENTIAL for "adaptive management". The Rangeland Monitoring Handbook, in fact, lays out a program of adaptive management not unlike what you propose (page 3-4), and which you have supposedly been following for over a decade.
In summary, the Southeast Oregon Resource Management Plan fails to comply with the National Environmental Policy Act, fails to fulfill the planning requirements of the Federal Land Policy and Management Act, fails to provide the inventory information required by the Federal Land Policy and Management Act and the Public Rangeland Improvement Act, and fails to comply with the umbrella requirements of the Draft Eastside Environmental Impact Statement.
Given these major deficiencies, I will hold my additional comments pending the release of the "Draft Supplement to the Southeast Oregon Resource Management Plan and Environmental Impact Statement" for review.