314 



makes no mention of this improvement, or the methods by . 

 which grazing has been used to accomplish the improvement. 



(6) On page 22, the comments as to drought and 

 the adverse impact of livestock grazing are directly 

 contradicted by such scientific data as Dr. Lee Sharp's \ 

 collection of slides representing 40 years of research. < 

 Those slides and the narration have been offered to the BLM 

 staff in the past and they were not ijaterested in seeing 

 them. The "science team" of the ecosystem project should 

 have viewed them. The members of the "science team" may not 

 even. know who Dr. Sharp is, but they would have if they had 

 coordinated their planning effort with ours. 



Specifically, the statement is made that "By 

 the time a drought is inevitable, livestock have been out on 

 the range for months, and the ability for most livestock 

 operators to roiind up their cattle and take them to another 

 area is limited." we have no idea where the "science team" 

 could have come up with this conclusion, but certainly not 

 from any expert range consultant or rancher. Spring * 

 moisture gives the rancher early warning of drought or ' 

 potential drought before the cattle are ever turned out.^ 

 The rancher then regulates his stock numbers in accordance 

 with the conditions evident to him. Many of our ranchers 

 have kept 30 to 40% of their stock off the range for 3-4 

 weeks because of moisture conditions which were evident to 

 them. A good manager knows of prospective drought before 

 his stock ever hit the range. Research which has been 

 conducted in the Dakotas and in Squaw Butte, Oregon 

 demonstrates that moderate level grazing during and after 

 drought periods is not adverse to the range. Our ranchers 

 use only moderate grazing levels during such times. 



i It is interesting that the negative and 



inaccurate conclusions stated in this section regarding 

 drought do not even attempt to define the term "drought." 

 Again, input by the experienced remge consultants named, 

 oibove could have supplied useful definitions to the "science 

 team" . 



■i (7) On page 22, the comment is made that 

 "Increased fire frequency has caused a loss of shrub 

 cover..." The comment is misleading because it does not 

 clearly demonstrate that it is referring only to lowlands 

 where juniper has not invaded and driven out useful species. 



I 



(8) On page 34, the comment is made that; "The 

 hydrological effects of western juniper increase are 

 difficult to separate from those resulting from inproper 

 livestock grazing, but where improper livestock grazing has 

 contributed to the decline in understory vegetation it has 

 probably contributed to increased rvinof f and erosion . " , The 

 drafters would have had less difficulty separating the i 



