54 



TESTIMONY OF THE 



CALIFORNIA CATTLEMEN'S ASSOCIATION 



REGARDING THE 



UNITED STATES FOREST SERVICE 



APPEALS PROCESS 



Prepared by Daniel K. Macon 

 CCA Director of Industry Affairs 



June 1 7, 1 996 



On behalf of the members of the California Cattlemen's Association, thank you for 

 the opportunity to provide testimony regarding the current appeals regulations for the U.S. 

 Forest Service. We have numerous concerns with the manner in which the current 

 administrative appeals process works, and we also have several ideas for improving this 

 process. 



The California Cattlemen's Association (CCA) represents approximately 3,500 

 members from throughout California on legislative, regulatory and operational issues 

 impacting the beef cattle industry. We also represent 38 local affiliate organizations, and 

 CCA's members include most of the permittees who operate on U.S. Forest Service (FS) 

 lands throughout Region 5. 



Our members have had experience in dealing with both the administrative appeals 

 process and the judicial review process regarding the management of FS rangelands, and we 

 will provide comments on both. We will also provide specific comments that we feel will 

 improve the appeals process for permittees as well as for the agency and the public. 



When the agency issues a decision regarding the management of a grazing allotment, 

 the permittee has the right to appeal the decision due to his/'her contractual relationship with 

 the agency (the grazing permit creates this relationship). Furthermore, members of the 



