315 



effects of jiiniper invasion from in^jroper livestock gra2ing 

 if they had consulted the local experts named above or e^^en 

 the ranchers who have experienced drying up of springs as a 

 direct result of jxiniper encroachment. Dr. Burkhart, with 

 Tisdale, has reported studies on juniper invasion which show 

 that juniper encroachment destroys understory vegetation and 

 saps the water from the area of encroachment. Local experts 

 azid reuichers can specifically point to areas where the use 

 of fire to bum invading jviniper has resulted in re- 

 emergence of springs that had been sapped by the juniper. 



The eight exan^jles presented merely touch the sxxrface of the 

 contents of this draft which would have benefited from local 

 expert input. The draft is replete with conceptual flaws 

 which detract from its planning value. 



As already mentioned, the draft is negative as to grazing, 

 always emphasizing the adverse conditions which can result 

 from overgrazing. It fails to recognize the positive 

 results of grazing which include increased wildlife in and 

 around public lands where livestock are grazed. It also 

 fails to recognize the improvements in the public lands 

 which have resulted since the Taylor Grazing Act required 

 issuance of permits to individual ranchers who have a 

 proprietary interest in improving the lands for perennial 

 use. 



Chapter l "Purpose and Need" attempts to portray a totally 

 declining ecosystem throughout the project area. Such ' 

 portrayal is not true. BLM's own internal records 

 demonstrate that the public lands have vastly improved since 

 the Taylor Grazing Act mandated permits and preference 

 rights . Apparently not even the government ' s own recorus 

 were utilized by the drafters. Again, local experts on .the 

 range could have provided valuable in^rovement informat.i.on 

 to the drafters. It is ironic to note that the draft EIS 

 repeatedly emphasizes the negative aspects of grazing, and 

 of recreation use, but does not discuss the management 

 techniques of ranchers which have improved the range and 

 habitat for wildlife, and does not discuss the efforts by 

 recreation users in Owyhee County to assist the BLM in 

 various land maintenance operations . Local input would have 

 provided the "science teams" with information about these 

 positive aspects of multiple use. ;' 



Chapter 1 "Purpose and Need" also contends that forest f 

 health has suffered because of "human activities and 

 ma n agement practices" such as timber harvest, livestock 

 grazing, fire exclusion, mining, road development and 

 increased recreation use. While dwelling on the harm which 

 can be caused to forest health by multiple uses, the draft 

 doeq not set forth the harm which is done by the 

 obstructionist activities of some groups which have tried to 



