![](media/image1.wmf){width="1.0006944444444446in"
height="1.5666666666666667in"}**Western Watersheds Project, Inc.**

P.O. Box 280

Mendon, Utah 84325

435-881-5404 • utah@westernwatersheds.org

February 7, 2006

To: Rich County CRM

From: John Carter, Utah Director

Reports are being prepared for submission to the CRM on the Duck Creek
and North Rich allotments, reflecting data collected by the Wild Utah
Project and Western Watersheds Project (WWP) during 2005. The data and
photographs from this work have already been provided to the CRM in
electronic form. The reports will be available soon and should be
considered in planning grazing for the 2006 season. This letter is
intended to update a previous version sent to the BLM Salt Lake Field
Office (SLFO). It provides a Bibliography of Range Science related
publications and a review of important range science principles which
are generally not addressed in current grazing management decisions.

Our goal is to ensure a systematic, scientific approach to the
management of livestock grazing based on the decades of research
available to us. WWP is concerned that efforts such as the CRM are
hindered by the unwillingness of the public lands agencies and livestock
permittees to actually conduct range management in accordance with the
intent of the law requiring sustainability without impairment of
productivity, adherence to multiple use principles and with range
science. We are familiar with literally hundreds of allotments where
poorly designed projects intended only to maximize livestock use are
implemented to the exclusion of other uses and without any real
accountability to the ecosystem or public interests.

These projects typically:

-   fail to adequately analyze impacts to native plant communities,
    consider and evaluate the hazard of soil erosion, impacts to
    in-stream habitat, wetlands and wildlife;

-   are supported by inadequate and infrequent qualitative monitoring
    with inherent flaws that promote bias and fail to detect impacts to
    these ecosystem components;

-   fail to determine the effectiveness of the grazing systems and
    projects implemented; and

-   they provide no systematic, quantitative evaluation of the land's
    capability and forage capacity to determine allotment or pasture
    capacity, set sustainable stocking rates and promote recovery.

Two decades ago, Rich County was involved in another collaborative
effort, The Experimental Stewardship Program, which was designed to
demonstrate the values of collaboration and good range management. We
understand the program fell apart after a few years. To our knowledge,
no analysis of the outcomes of the ESP has been done. The CRM might be
well served to review the Experimental Stewardship Program as an
exercise to avoid repeating past failures.

WWP has submitted numerous letters and reports to the Salt Lake Field
Office (SLFO) on conditions in Rich County BLM lands showing riparian
degradation and erosion.

In 2003, WWP sent a report to the SLFO showing the severe nature of
riparian damage and overuse as well as livestock trespass into riparian
exclosures on allotments in Rich County[^1]. In 2004, WWP provided a
report to the SLFO documenting the severe livestock damage to Duck Creek
and the springs flowing into Duck Creek as well as livestock trespass
into the reference exclosure on upper Duck Creek. This exclosure had not
been maintained and the gate was left down[^2]. This same exclosure was
again not maintained in 2005 as the upcoming report will show. In 2001,
BLM established riparian stubble height standards. These have not been
monitored or enforced. The upcoming report will document the stubble
heights in the Duck Creek allotment showing violation of this standard.

In the Department of Interior Administrative Hearing on the proposed
Duck Creek project in the spring of 2005, it was suggested by the Court
that BLM discuss settlement of the case with WWP. Western Watersheds
Project looked forward to settling the case by negotiating a means of
implementing suitable grazing systems, monitoring and range management
on the Duck Creek allotment. However, the Salt Lake Field Office decided
to withdraw the project without any negotiation. We have heard that, in
a closed meeting with the permittees, BLM is planning on implementing a
four pasture grazing system on the Duck Creek allotment in 2006,
resulting in many of the same impacts the recently proposed pasture
system would have brought about. We hope we are wrong, but apparently
there will be no justification to the public, no Proposed or Final
Decision under the law, but instead, a unilateral approach that avoids
addressing the Public Interest. This type of action appears to counter
the very goals of the CRM.

The 2005 hearing on the proposed Duck Creek project clearly demonstrated
the failure of the project to adhere to sound, scientific principles.
Evidence at that hearing showed a clear depletion of native, perennial
bunchgrasses such as bluebunch wheatgrass and Indian ricegrass had
occurred across the allotment. This is the case even though the most
recent planning EIS designated bluebunch wheatgrass as the key species
for Rich County (USDOI 1979). The Soil Survey for Rich County lists
bluebunch wheatgrass as a dominant producer of forage on rangelands
managed properly and at potential (USDA 1982). Yet the proposed project
offered no science-based means of achieving or documenting restoration
of productivity of the native perennial grasses.

These situations describe some of the reasons why Western Watersheds
Project takes the positions it does on behalf of the Public Interest
while we continue to try and work with agencies and willing permittees
to establish systematic and quantitative monitoring programs that
provide accountability and effectiveness monitoring as required by law.

Our review is organized by sections including:

1.  Background

2.  What Does Range Science Tell Us?

3.  Management Recommendations for Uplands

4.  Management Recommendations for Riparian Areas

5.  Habitat Requirements for Sage Grouse, Migratory Birds and Pygmy
    Rabbits

6.  Bibliography

The CRM should consider in detail this review and the publications
referenced herein.

**1.0 Background**

BLM's *Rangeland Reform '94 DEIS* and *Executive Summary* (RRDEIS, BLM
1995) reported that riparian areas *"have continued to decline and are
considered to be in their worst condition in history"*; livestock
grazing is identified as the chief cause. Indeed, some riparian areas
have literally been destroyed by improper livestock grazing.\
This is in spite of nearly four decades of implementing water
developments, seedings, sagebrush treatments and rotation grazing.

In its recent DEIS and Proposed Rule[^3] to revise its grazing
regulations, BLM bypassed consideration of best available science. It
pretended that current grazing management is fine if interested publics
and environmental organizations would just get out of the way and quit
holding up BLM and Permittee proposals by creating an administrative
paperwork burden (BLM 2003). BLM asserted that greater cooperation with
stockmen would somehow result in improvement by merely "tweaking"
stocking rates, but then went on to state that this seldom happens, that
changes in grazing really only amount to changes in season or location
of use and that *"Changes in active grazing use in excess of 10% are
infrequent."*

In its RRDEIS, BLM provided definitions describing the status of upland
plant communities. These were:

-   Potential Natural Community (PNC) = existing vegetation is between
    75 -- 100% of the sites potential natural plant community.
    (Corresponds to Excellent Condition)

-   Late Seral Community = existing vegetation is between 50 -- 74% of
    the sites' potential natural plant community, (Corresponds to Good
    Condition)

-   Mid Seral Community = existing vegetation is between 25 -- 49% of
    the sites' potential natural community. (Corresponds to Fair
    Condition)

-   Early Seral Community = existing vegetation is between 0 -- 24% of
    the sites' potential natural community. (Corresponds to Poor
    Condition)

Table 1 indicates that management of uplands since the passage of the
last Rangeland Reform regulation in 1995 has not resulted in improvement
of upland condition. In fact, BLM's own analysis shows that condition
has declined, or at best, remained static. It also shows that
productivity of those lands is greatly below potential with 63% of its
lands below 49% of potential, or in Fair or Poor Condition. The data
also show that BLM's management has failed to produce improvement.

**Table 1. Comparison in BLM Upland Condition Between**

**RRDEIS (1995) and Current Condition (BLM 2003)**

  ----------------- ----------------- ----------------- -----------------
  **Community       **RRDEIS**        **Current DEIS**  **Change '94 to
  Status**                                              date**

  PNC (Excellent)   4%                6%                +2%

  Late Seral (Good) 34%               31%               -3%

  Mid Seral (Fair)  40%               34%               -6%

  Early Seral       15%               12%               -3%
  (Poor)                                                

  Unclassified      7%                17%               +10%
  ----------------- ----------------- ----------------- -----------------

In spite of the evidence of widespread loss of native plant productivity
and ground cover, accelerated erosion and BLM's own documentation of
rapid declines in native species such as native, perennial bunchgrasses
and sage grouse, BLM routinely chooses not to address livestock impacts
in any scientific or sustainable fashion. Instead, BLM proposes more
pipelines, water developments, fences and grazing systems. This ignores
that for decades BLM has been engaged in a massive program of developing
water, putting streams and springs into pipelines, seeding with crested
wheatgrass, building fences, engaging in rotation grazing, and spending
millions of dollars to "even out livestock distribution". Table 1 shows
the results of this -- the Public is left with severely degraded native
plant communities. It must be added that the Forest Service is no less
guilty of the same behaviour.

An early example of this industrialization of public lands, was in BLM's
Vale District, where millions of dollars were spent on crested
wheatgrass seedings and structural range improvements. Today, across BLM
and National Forest lands in the west, many of these systems have fallen
into disrepair, the land has failed to recover and we are faced with
more and more proposals to install grazing systems, water developments,
plow and seed -- not conduct science-based stocking rate determinations
based on forage and native plant status and production monitoring. This
is in spite of the fact that long-term studies, including those from the
Vale District have shown that stocking rate is the critical variable,
not grazing systems.

Much of this degradation follows from agency failures to scientifically
and accurately determine:

-   which lands are capable and suitable for livestock grazing;

-   how much forage is currently available;

-   determine a stocking rate for livestock by properly allocating that
    forage to watershed and stream protection, wildlife habitat and
    food, then to livestock if available; and

-   provide for long-term rest to facilitate recovery.

These failures have prevented the recovery of damaged ecosystems so that
they can sustain use without impairment of productivity as envisioned in
the Taylor Grazing Act and FLPMA. Instead, BLM and the Forest Service
generally continue to use the take "half/leave half" principle for
livestock use. In their permits and analyses, they typically include
livestock use levels of 50% or more of forage as proper. No scientific
foundation for this claim is ever provided, nor is use adequately
monitored to manage livestock and ensure compliance even with this
excessive standard.

The following paragraphs provide a brief summary of the relevant range
science regarding utilization levels, plant growth and productivity,
effects of precipitation regime, capability and suitability, capacity
determinations, stocking rate determinations and economics. These
principles are based on quantitative studies, some over a large span of
years, and are well founded in the range science literature. It is
efforts by organizations such as WWP to have these principles applied
that have lead to current livestock industry proposed regulatory changes
and laws that would take us back to the pre-Taylor Grazing Act days when
livestock users had free run of the Public Domain without any
accountability to the American People, who own these lands.

**2.0 What Does Range Science Tell Us?**

The Rich County CRM members should be aware of the studies cited here
and in the Bibliography in order to participate effectively in
discussing alternative scenarios for Rich County and to ensure that
sustainable multiple use without impairment of productivity is achieved,
while native plant and animal communities are allowed to function
properly.

**2.1 [Plant Growth and Precipitation.]{.underline}** In order to
understand the implications of grazing livestock in arid regions, it is
important to understand the precipitation regime and its relationship to
forage production. Holechek et al (2001) point out what we all
understand at the most basic level. That is, precipitation is the single
most important factor determining the type and amount of vegetation in a
particular area. In the 11 Western States, 80% of the area receives less
than 500 mm (19.6 inches) of annual average precipitation. Further, this
precipitation is subject to great year-to-year variation. The effect of
annual variations in effective precipitation on plant community
production is important to understand in establishing livestock stocking
rates and management.

Two locations representative of precipitation patterns for Rich County
BLM lands are used for illustration. Long-term precipitation records
were analyzed for stations at Randolph and Woodruff. Data was obtained
from the Western Regional Climate Center database[^4]. Table 2 shows
that for both annual and water year seasonally effective precipitation,
Rich County BLM lands experience below normal precipitation in over half
the years.

Periods of precipitation vary in their effects on the plant communities.
Increased precipitation during the spring-summer-fall months may not be
effective due to the higher temperatures occurring then. Typically, the
fall-winter period is the period of greatest increase in soil moisture
due to lower temperatures and lower evapo-transpiration. Precipitation
effectiveness during the warmer spring -- fall periods varies with the
storm intensity and soil condition. Storms must be of high enough
intensity to promote recharge of the soil profile into the root zone to
be effective for plant growth. Generally, this is greater than 0.6
inches in desert shrub types, although very high intensity storms may
not be effective due to rainfall rates in excess of infiltration that
result in overland runoff and flash events.

Spring plant growth in these arid areas depends on the amount of
moisture received and retained during the fall-winter period. Relatively
dry summers may allow little regrowth and by the time fall comes,
temperatures may be low and growth limited. Trampled and compacted soils
exacerbate this effect (Blaisdale and Holmgren 1984). Some desert shrubs
such as Artemisia sp. with both shallow and deep root systems can take
advantage of both shallow and deep soil moisture (West 1983).

**Table 2. Summary of Precipitation Statistics for Three Utah
Locations**

  ---------------------------------------- -------------- -----------------
  **Description**                          **Randolph**   **Woodruff**

  Period of Record                         1982 -- 2005   1948 -- 2005

  Years of Complete Record                 19             56

  Annual average, inches                   13.58          9.4

  Years below average                      10             33

  Percent years below average              52.6%          58.9%

  October -- March Average, inches         5.82           3.63

  October -- March Range, inches           2.07 -- 10.8   1.04 -- 6.46

  Years October -- March below average     10             28

  Percent years October -- March below     52.6%          50%
  average                                                 
  ---------------------------------------- -------------- -----------------

Annual production of available forage at the Desert Experimental Range
in western Utah was highly correlated with total annual precipitation,
with an 800% variation in forage production between the driest and
wettest years (Hutchings and Stewart, 1953). Scientists developing
quantitative ecosystem relationships for the Prototype Oil Shale Program
managed by BLM in Utah's Uinta Basin found that annual sagebrush stem
leader growth used as an index of production had its highest correlation
with winter precipitation (October -- March) and that spring annual (not
perennial) plant biomass was correlated with spring precipitation (ERI
1984; WRSOC 1984). These studies were carried out under the supervision
of BLM's Vernal Field Office.

Perennial grass production and annual precipitation for a study area at
the Chihuahuan Desert Rangeland Research Center in New Mexico had a high
correlation over a 20-year period (Holechek et al, 2001). A graph of
this data is shown in Figure 1. Annual perennial grass production varied
between 6 and 750 lbs per acre, corresponding to the second-lowest and
highest precipitation years. The linear regression plot of the same data
is provided in Figure 2. The Soil Survey of Rich County (USDA 1982)
gives a range of total production of potential plant communities that
varies by about 300% between favorable and unfavorable years. This wide
range in production between dry and wet years is typical in the arid
regions of the West.

These relationships demonstrate that this is a predictable phenomenon
that should be taken into account in setting livestock grazing seasons,
stocking rates and management on an annual basis as well as over the
longer term. Grazing management and stocking rates should be based on
forage capacity determinations and recognize that over half the years in
Rich County will have forage production below normal. Reliance on water
year precipitation for October -- March would allow managers in Rich
County to establish the annual stocking rates and seasons to balance
with plant production for spring -- fall grazing.

![](media/image2.wmf){width="5.415972222222222in"
height="3.1659722222222224in"}

![](media/image3.wmf){width="5.415972222222222in"
height="3.1277777777777778in"}

**2.2 [Grazing Intensity and Effects on Productivity]{.underline}.**
Much of the current research and analysis of livestock grazing
management, plant productivity and economics has come out of the
Department of Animal and Range Sciences at New Mexico State University.
This work has been presented in a series of textbooks and papers in the
range science literature. These references provide analyses of the
interactions of livestock stocking rates, plant productivity and
economics based on a set of long term grazing management studies from
native rangeland types. They provide recommendations for determining
livestock grazing intensity to maintain vegetative productivity and
economic stability, while taking into account the effects of inherent
variation in precipitation in desert ecosystems.

Franklin Crider's study on root growth stoppage from plant top removal
provided quantitative measurements of plant re-growth under different
amounts of removal (Crider 1955). Three mid-west perennial grasses were
grown from seed in pots under ideal conditions of watering and
fertilization. After sixty days of growth, these potted grasses were
clipped once at intervals from 10% to 90% of the above ground biomass.
Repeat clippings of the potted grasses were made every two days to
return the plants to the same height as the original clipped percent.
Crider concluded that under these ideal growing conditions, if these
species of grasses had 40% or less of their aboveground biomass clipped
either once or many times, then the net root mass was the same or more
at the end of the experiment. Based on this, Crider assumed that grazing
during the entire growing season at 40% or less would sustain plants
from one season to the next. This same study has apparently been used to
justify the 50% use or "take half/leave half" proposition that range
managers have used for decades. The long-term range studies cited below
show that under actual field conditions, these use levels are excessive
and light grazing (25%) combined with adequate rest may be most
equitable to the Federal mandates for sustainable use.

The effect of livestock grazing intensities on forage plant production
was studied in a ponderosa pine type in Colorado as early as the 1940's
(Schwan et al, 1949). This study showed that forage consumption at a
rate of 57% produced an average of twice that as grazing at a rate of
71%. An area ungrazed by livestock for 7 years produced three times as
much forage as the 71% use area. The authors concluded that, as grazing
use increased, forage production decreased. During that same period,
Dyksterhuis (1949), in a classic paper on the use of quantitative
ecology in range management, presented examples of how stocking rates
must be adjusted based on precipitation and range condition, which
included a rating based on departure from the potential plant community.
USDA (1982) considers proper grazing management as that management that
sustains the potential plant community.

The effects of conservative use (30 -- 35%) compared to heavy use (60 --
65%) on grasses and forbs were determined in a New Mexico study (Galt et
al, 1999). Both of these pastures had experienced conservative use for
over 10 years. In 1997, one pasture was changed to heavy use.
Quantitative measurements at key locations in both pastures in the
following year, while being rested, provided the results shown in Table
3.

**Table 3. Standing Crop of Grasses and Forbs from Galt et al (1999)**

+-----------------------+----------------------+----------------------+
| **Location/Forage     | **Spur Pasture**     | **Deep Lake Pasture  |
| Component**           |                      | Conservative         |
|                       | **Heavy Stocking     | Stocking Rate        |
|                       | Rate Pounds/acre**   | Pounds/acre**        |
+-----------------------+----------------------+----------------------+
| Perennial Grasses     | 352                  | 824                  |
+-----------------------+----------------------+----------------------+
| Forbs                 | 256                  | 436                  |
+-----------------------+----------------------+----------------------+
| Total Forage          | 608                  | 1260                 |
+-----------------------+----------------------+----------------------+

This study showed that heavy stocking rates resulted in serious declines
in productivity in the succeeding year. Perennial grass production was
reduced by 57% and forbs by 41% in the heavily grazed pasture compared
to the conservatively grazed pasture. The authors cited a number of
other studies in arid environments that showed heavy stocking rates were
accompanied by decreases in forage production when compared to
conservative use. After drought, the ability of forage plants to recover
was directly related to the standing crop levels maintained during the
dry period. The studies cited showed that grazing during different
seasons was less important than grazing intensity.

Five long-term stocking rate studies from three different locations in
Arizona, New Mexico and Utah documented similar patterns (Holechek et al
1999a). In the Desert Experimental Range in Utah, a 13-year study with
moderate (35%) and heavy (60%) use by sheep resulted in annual forage
production of 198 lbs/acre and 72 lbs/acre, respectively. The authors
recommended 25 -- 30% use of all forage species. A 10-year study at the
Santa Rita Range in Arizona demonstrated that perennial grass cover and
yield showed an inverse relationship to grazing intensity, while
burroweed, an undesirable species, increased with increasing forage use.
The authors recommended a 40% use level. A 37-year study at the Jornada
Experimental range in New Mexico involving conservative (33%) and
moderate (45%) use showed that the lower grazing intensity resulted in
greater black grama (perennial grass) cover. Lowland areas with high
clay content and periodic flooding grazed at moderate intensity had
higher cover of Tobosa, a perennial grass, than heavily grazed areas.
They recommended 30% be used as a stocking intensity with no more than
40% removed in any year. A 10-year study at the Chihuihuan Desert
Rangeland Research Center looked at four grazing intensities of 25%,
35%, 50% and 60%. Light (25%) and moderate (35%) use produced 70% more
forage than 50% use and more than double that achieved at 60% use. Here,
the author recommended conservative stocking at 30 -- 35%.

A review of the "classic" range studies, which are the long-term
stocking rate and grazing system studies that provide the scientific
foundation for modern range management again showed that light use is
closer to sustainable use, while heavy use is not (Holechek et al
1999b). Definitions of "heavy", "moderate" and "light" grazing developed
in 1961 were cited. Heavy grazing was defined as the degree of forage
utilization that does not allow desirable forage species to maintain
themselves. Moderate grazing was defined as the level at which palatable
species can maintain themselves. Light grazing was defined as the degree
of utilization at which palatable species are able to maximize their
herbage producing ability. However, it is clear that using even
"moderate" grazing in depleted areas will not allow them to recover.

When averaged across all the long-term studies for all regions, heavy
grazing was 57% use of primary forage species, moderate use was 43% and
light use was 32%. In arid regions, the research showed that moderate
grazing use was 35 -- 45%. When the average forage production change
over time was compared with use, heavy stocking resulted in a 20%
decline in production, moderate use experienced no change and light use
resulted in an 8% increase. During drought, moderately stocked pastures
produced 20% more forage than heavily stocked pastures, light grazing
produced 49% more forage than heavy and 24% more than moderate stocking
levels. Heavy stocking resulted in a downward trend and light stocking
an upward trend in ecological condition. Moderate stocking showed a
slight, but not significant increase in condition, resulting in depleted
ranges being maintained in depleted condition.

Hutchings and Stewart (1953), suggested that 25 -- 30 % use of all
forage species by livestock was proper. They recommended this level
because routinely stocking at capacity will result in overgrazing in
half the years and necessitate heavy use of supplemental feed. Even with
this system, they recognized that complete destocking would be needed in
2 or 3 out of ten years. Holechek et al (1999a) concluded that the
research is remarkably consistent in showing that conservative grazing
at 30 -- 35% use of forage will give higher livestock productivity and
financial returns than stocking at grazing capacity. They also
recognized that consumption by rodents and other wildlife must be taken
into account as part of this utilization. Otherwise, rangeland
productivity would suffer even at these levels of use. Galt et al (2000)
recommended levels of 25% utilization for livestock with the remainder
for wildlife and watershed protection. In none of these cases have the
scientists recommended 50% utilization by livestock and they are clear
that even at the lower use levels recommended, wildlife use is included.

Federal agencies apparently have never even looked into the issue of the
relationship between their typical riparian greenline stubble height
standard, usually applied to Nebraska sedge, and the effects of applying
this standard on adjacent riparian plant community productivity. Carter
(1998) showed that before greenline N. sedge had been reduced in height
to the standard of 6", riparian grasses had been reduced to 2" stubble
height and 89% of stream banks had been trampled, compacted or were
actively eroding into the stream. Monitoring data from the Wasatch-Cache
National Forest (USDA 1993) included the observation that a Nebraska
sedge stubble height of 7.6" corresponded to an estimated 70% use of
riparian grasses. Lile et al (2003), compared clipping of N. sedge to
stubble heights of 2" and 4" during early season, late season and
multiple clippings to both heights. Late season use or 2" stubble height
did not allow recovery. Only the 4" early season use achieved the 4"
criteria, but did not regrow to meet the 6" criteria by the end of the
growing season. This shows that season-long or late season use does not
allow sufficient time for re-growth and that stubble heights on
greenlines are not effective in protecting riparian vegetation.

Schulz and Leininger (1990) studied long-term riparian exclosures
compared to areas that continued to be grazed. They found that, after 30
years, willow canopy cover was 8.5 times greater in livestock exclosures
than in adjacent grazed riparian areas. Grasses were 4 to 6 times
greater in cover within the exclosure than outside. Mean peak standing
crop of grasses within the exclosure was 2,410 Kg/Ha, while outside in
caged plots, mean peak standing crop was 1,217 Kg/Ha, or a loss of half
in productivity.

**2.3 [Forage Needs Other Than Livestock]{.underline}.** If Crider's
conclusion that 40% removal in a growing season applies to the very arid
lands found in Rich County, then the 40% removed needs to be shared with
all the animals that require forage. Some is needed for wild grazers
(insects, nematodes, mammals), some for the generation of litter and
nutrient cycling. A certain amount of the plant needs to remain to
ensure regeneration of the plant and to ensure plant community structure
is sufficient for wildlife habitat needs and soil erosion protection. A
certain proportion of plants must remain ungrazed to allow for seed and
flower production to ensure propagation of the species and provide food
for pollinators and granivores, an often overlooked requirement.

Existing research helps answer the question of how much of the annual
plant growth is required for wild grazers[^5]. Based on a number of
studies of mammal consumption of forage, some annual forage consumption
needs for mammals in arid systems where mammal populations are at or
near their potential are provided in Table 4:

> **Table 4. Forage Needs of Mammals**

  ---------------------------------- ------------------------------------
  **Mammal**                         **Forage Needs kg/hectare**

  Deer                               12.7

  Rabbits                            72.7

  Rodents                            142.3

  Total                              227.6
  ---------------------------------- ------------------------------------

Less is understood regarding the typical vegetation needs for insects,
although insects play a significant role. For example, harvester ants
are granivores with individual colony populations of tens of thousands
of individuals. Even in the driest and hottest parts of North America,
the total biomass of one species of harvester ant, *Messor (Veromessor)
pergandei* has approximately the same total biomass as the total rodent
population in the same area. One of many ecological roles harvester ants
fulfill is dispersing plants as a result of accidental abandoning of
seeds near the nest.

A number of studies have reported the percent of plant growth consumed
by insects. In grassland and savannah, insect consumption of a single
species varied from less than 1% to 19% with a mean of 3.5% (Wiegert and
Peterson, 1983). Rangeland grasshoppers consume between 1- 3% in typical
years (Mispagel 1978) and up to 99% in periods of super abundance (Nerny
and Hamilton 1969). Hewitt and Onsager (1983) suggest that between
21-23% of available range forage is consumed by all grasshopper species
in the western U.S. each year. This production is transferred to birds
and mammals such as sage grouse and rodents as a food source, to the
soil for nutrient cycling and to higher trophic levels such as raptors
and other carnivores. It is important for ecosystem function and cannot
be dismissed.

Nematodes provide critical soil nutrient cycling and structure
functions. This complex array of species normally has a higher diversity
and biomass than other rangeland flora and fauna combined. Some
nematodes consume plants and should be considered as a component in the
consumption of rangeland plants. Ingham and Detling (1984) estimated
that nematodes consumed between 6 and 13 % of below ground net
productivity in the mixed grass prairie. Other studies by Scott et al
(1979) and Anderson (1987) found that root feeding arthropods and
nematodes consume between 7-26% of the net productivity in normal years.

Holechek et al (2001) provide forage consumption rates for wildlife.
They are summarized in Table 5. Studies in the Vernal resource area
during the 1970's and 1980's generated many years of quantitative data
describing the abundance of many species of animal, bird and insect in
the different vegetation types occurring there. This information is
available in the Vernal Field Office for review and analysis. Some of it
is provided in the (ERI 1984; WRSOC 1984) reports referenced. Final
determinations of livestock stocking rates and utilization criteria for
livestock should take this information into account and allocate forage
to wildlife and these other uses using the current vegetation production
for the area under consideration.

> **Table 5. Wildlife Forage Consumption Rates**
>
> from Holechek et al (2001)

  ----------------------------------- -----------------------------------
  **Animal**                          **Forage Consumption lb/day**

  Elk                                 14

  Moose                               24

  Bighorn sheep                       3.6

  Mule deer                           3

  Pronghorn                           2.4
  ----------------------------------- -----------------------------------

**2.4 [Livestock Forage Consumption Rates]{.underline}.** The Society
for Range Management in 1974 defined an Animal Unit *"to be one mature
(1000 lb.) cow or the equivalent based upon average daily forage
consumption of 26 lbs. dry matter per day."* (SRM, 1974) SRM also
defined an Animal Unit Month as *"The amount of feed or forage required
by an animal-unit for one month."* NRCS defines the forage demand for a
1,000 pound cow as 26 pounds of oven-dry weight or 30 pounds air-dry
weight of forage per day (NRCS, 2002). It is important to ensure that
forage consumption rates by livestock are based on the size of animals
present on the allotment and that stocking rates be based on their daily
consumption rates. The following analysis provides some background and
proposes that a more current forage consumption rate for livestock be
used in stocking rate determinations.

The University of Nevada Agricultural Experiment Station published a
report on cattle production in 1943 (Brennan and Harris, 1943). That
report analyzed 14 years of ranch operation for eleven ranches in
northeastern Nevada. At that time, a mature cow was considered one unit
and a branded calf or weaner as ½ cow unit, for a combined total of 1.5
cow units per cow/calf pair. Bulls were considered 1.5 cow units. For
the period 1938 -- 1940, the average turnoff weight (when they left the
range) of mature cows was 959 pounds, calves were 381 pounds and bulls
were 1222 pounds. This means that in the 1930's, a cow/calf pair was
1340 pounds. With breeding, supplements and hormones, weights have
increased over time, for example, Anderson et al (2000) calculated a 35%
increase in dressed weights per animal between 1975 and 1995[^6].

USDA market statistics[^7] give the average weights of slaughter cattle
for the week ending August 14, 2004 as 1251 pounds. The estimate for the
same week in 2005 for slaughter cattle average weight was 1260 pounds.
The USDA National Agricultural Statistics Service data for average live
weight of cattle slaughtered in 2004 was 1242 pounds compared to 1187
pounds in 1995, or an increase of nearly 8.5% in those 10 years[^8]. The
Livestock Monitor is a newsletter produced by the North Dakota State
University Extension Service Livestock Marketing Information Center in
cooperation with USDA State Extension Services[^9]. The Livestock
Monitor shows for the week ending August 6, 2005, live weights of
slaughter cattle averaged 1258 pounds.

The potential weights of mature cows can be even larger than these
numbers. For example, NRCS in its National Range and Pasture Handbook,
referenced above, defines body condition scores. A body condition score
of 6 which is described as *"Good, smooth appearance throughout. Some
fat deposits in brisket and over the tailhead. Ribs covered and back
appears rounded."* This body condition score relates to a pregnancy
percentage of 88%, which is important as a goal for cow/calf operations
as dry cows are usually culled and replaced and the weight gain of
calves is important for income. According to Dr. Larry W. Olson,
Extension Animal Scientist at Clemson University, a medium frame cow in
body condition score 6 could easily weigh 1300 -- 1400 pounds[^10].

Holechek et al (2001) summarized the weaning weights of calves grazed on
various types of rangelands at different stocking rates. The data for
the period since 1990 gave an average weaning weight of 430 pounds and a
range of 382 -- 475 pounds. Ray et al (2004) gave a weaning weight of
480 pounds for calves. Using the current market statistics for slaughter
cattle at about 1250 pounds and a calf weight of 300 pounds to allow for
weight gain during the grazing season, an estimate for the average
weight of a cow/calf pair during the grazing season of 1,500 pounds
appears conservative.

As pointed out above, the NRCS used 26 lbs/day of oven dry weight for a
1,000 pound cow and stated this was equivalent to 30 pounds per day
air-dry weight. The NRCS Range and Pasture Handbook value of 30 pounds
air-dry weight would be 3% of body weight for a 1,000 pound cow.
Applying this to the estimate of a current weight of 1,500 pounds for a
cow/calf pair, the daily forage consumption would be 45 lbs of air-dry
forage per day, or for a month (30.4 days), 1368 pounds of forage per
cow/calf pair. This analysis shows that current stocking rates and
forage consumption allocations have been understated significantly. It
is time to base stocking rates on current rates of forage consumption
and current weights of livestock.

Adult domestic sheep weigh from 165 to 440 pounds[^11] and lambs about
129 pounds[^12]. A conservative estimate of the weights of a sheep and
two lambs would be 400 pounds (200 for the ewe and 100 each for each
lamb). The forage consumption for a 125 pound ewe was given as 4.1
pounds per day with a ewe plus lamb as 7.8 pounds per day in the R4
Range Environmental Analysis Handbook (USDA 1969). These figures amount
to about 3.3% of body weight per day consumed as air dry forage weight.
Using the more current weights of mature sheep (ewes) and lambs with two
lambs per ewe and a total weight of 400 pounds would result in forage
consumption of 13.2 pounds per day for each mature sheep with two lambs.
This means that 3 sheep plus lambs is about equivalent to a cow and calf
pair. The current habit of using five sheep as an AUM, while forgetting
to count their lambs or take into account their actual forage
consumption, understates forage consumption by about half. Permits and
AUMs should be adjusted to take these values into account for both
cattle and sheep.

**2.5 [Grazing Systems]{.underline}.** Federal and State agencies never
justify proposed grazing systems with any rational review of existing
studies or monitoring and analysis of the results of the numerous
systems already in place. The following paragraphs discuss what has been
learned regarding grazing systems, the effects of grazing and lack of
rest on native bunchgrasses, and the time needed for recovery of
depleted native plant communities and soils. Much of this information
has been known for decades and is consistently ignored by these agencies
in their current grazing decisions.

In a review paper that considered grazing systems, grazing intensity and
season of use, Holechek et al (1998) determined that, *"financial
returns from livestock production, trend in ecological condition, forage
production, watershed status and soil stability are all closely
associated with grazing intensity."* They found that grazing systems
such as rest-rotation had limited or no benefit in arid systems. Citing
long-term studies in Arizona, they documented that after 12 years of
rest-rotation management compared to continuous grazing, neither forage
plant densities nor forage plant production differed between the
treatments. Grazing intensity employed was 30 -- 35% use with occasional
high use of 50% or more. *"Rest and deferment were not sufficient to
overcome the effects of periodic heavy use on primary forage plants when
rest-rotation grazing was applied on big sagebrush range in northern
Nevada."* In an Arizona study comparing winter-spring grazing with
summer-fall rest to continuous grazing, the rotation scheme was inferior
to the year-long system from the standpoint of perennial grass density
and production. Perennial grass production was closely associated with
the degree of use and was highest where grazing use was lowest. In a
Vale, Oregon study, lasting over 20 years at moderate grazing intensity,
rotational grazing showed no advantage over season-long grazing in
improving range condition or forage production. *"The key factor in
range improvement appeared to be the reductions in grazing intensities
that were applied when the project was initiated..".* (Holechek et al,
1998).

Relying on additional water developments, fences and grazing systems
will not alleviate the problem. The use of range improvements and
rotation systems is not sufficient to correct over-stocking. Results
from 18 western grazing system studies by Van Poollen et al (1979) found
that adjustment of livestock numbers, or stocking intensity was more
important than implementing grazing systems to improve herbage
production. Holechek et al (1999a) recognized that *"various rotation
grazing systems cannot overcome the rangeland deterioration associated
with chronic overstocking."* Holechek et al (2000) also showed that the
various claims made by advocates of short-duration or time-controlled
grazing were false.

A comprehensive discussion of rest-rotation is found in Clary and
Webster's General Technical Report titled *"Managing Grazing of Riparian
Areas in the Intermountain Region."* (Clary and Webster 1989). They
summarized a dozen studies showing significant increases in forage
production occurred with decreased intensities of grazing. The article
described the improvements found in reducing grazing from heavy, to
moderate and then to light grazing. Grazing with utilization above 50%
was described as heavy, moderate was 30 - 50% and \<25-30% was called
light grazing in most of these studies. Clary and Webster's study
concluded that *"managers should place more emphasis on proper stocking
intensity and less on grazing system implementation. The concentrated
use of grazing pastures is not compensated for during rest years if
grazing use is heavy. In summary, although grazing systems have great
intuitive appeal, they are apparently of less consequence than once
thought. In fact as long as good management is practiced so that there
is control of livestock distribution and grazing intensity, the specific
grazing system employed may not be significant."*

Holechek et al (2001) have indicated that, depending on topography,
areas of severe degradation, or *"sacrifice areas"* occur around water
sources including water developments. These can extend from 1 mile to
several miles from these sources if stocking rates are too high. Based
on this, a single water development can result in an area of soil
compaction, erosion and loss of ground cover and vegetation for
thousands of acres. They also indicated that installing water
developments in locations that have had limited access to livestock in
the past may increase ecological damage to areas that are important
refuges for relict plant communities and wildlife that have not been
displaced by livestock.

Hormay and Talbot (1961) wrote the original guidance for rest-rotation
grazing based on intensive field studies. They stated, *"While the idea
of incorporating rest in grazing management is not new, the concept of
longer rest periods than have heretofore (been) recommended, at least
for mountain bunchgrass ranges, and of closer correlation of resting and
grazing with plant growth requirements, is new."* Some points of
interest from the study were that, even with the rest-rotation system,
some areas were more heavily used than others, regrowth was minimal on
clipped plants after the seed-in-milk phase and clipping during active
growth reduced total herbage yield during that year. A single season of
clipping reduced basal area of forbs and grasses the next year. Four
consecutive seasons of clipping at the seed-in-milk phase reduced basal
area of Idaho fescue 80%, bottlebrush squirreltail 62%, longspur lupine
91% and wooly wyethia 16%.

They also found that cool-season grasses such as Idaho fescue varied in
production by a factor of three due to changes in annual precipitation,
while the beginning of growth varied by up to a month with similar
variations on time to flowering and seed ripening. In clipping studies,
they found that a single clipping of Idaho fescue reduced the basal area
of the plant by 49% in the following year, while four years of
consecutive clipping at the seed in milk phase reduced basal area of
Idaho fescue 80% and killed 20% of the plants. Four years' rest after
four years' clipping resulted in little or no recovery of Idaho fescue,
wooly wyethia and longspur lupine. The basic principle enunciated by
Hormay and Talbot, based on their quantitative research, was to require
adequate years' of complete rest from grazing to allow the native plants
to recover their vigor before again being grazed. It is important to
include adequate monitoring of each grazed unit or pasture to determine
if these rest periods are sufficient to maintain or restore production.

Grazing and rest requirements for key species of grass can be critical.
Native cool-season perennial bunchgrasses can be very sensitive to
defoliation and growing season use. For example, Anderson (1991) stated
in regards to bluebunch wheatgrass, *"Effects of growing season
defoliation injury are well documented: basal area, stem numbers and
both root and forage yields are reduced and mortality can be high. ...
Defoliation to very short stubble heights during the boot stage has been
reported to essentially eliminate plants within as few as three years.
... Vigor recovery has been found to require most of a decade, even with
complete protection from grazing."* The author went on to describe
experiments in which a single clipping of the grass during the growing
season produced 43% less herbage and 95% fewer flower stalks the
following year than unclipped plants. Under a deferred system in eastern
Oregon, it was reported that bluebunch wheatgrass could not be
maintained at 30 -- 40% use in the boot stage (early June). A one time
removal of 50% of the shoot system during active growth may require six
years' rest even in an area with 17" precipitation. (Mueggler, 1975).
Anderson (1991) also makes the point regarding bluebunch wheatgrass
that, *"The belief that range improvement will occur after one or two
years of rest following a single season of more than 'light' use during
the growing season is erroneous."* Mueggler (1975) also determined that
Idaho fescue of moderately low vigor required 3 years of rest for
recovery and that plants of bluebunch wheatgrass and Idaho fescue in
very low vigor may require 8 years and 6 years of rest, respectively,
for recovery. These effects of grazing use must be kept in mind when
establishing grazing systems and setting stocking rates.

Eckert and Spencer (1986, 1987) concluded that no management system
appears to be satisfactory if that system results in overgrazing during
the growing season in order to defer or rest vegetation in other grazing
periods. They concluded that the amount of deferment and rest provided
by the 3 pasture system was not sufficient to overcome the effects of
periodic overuse. They recommend the use of utilization levels that
allow plants of desirable species to respond to proper management by
adjusting stocking rates to forage production levels.

In studies at INEEL in Central Idaho following exclusion of livestock,
Anderson and Holte (1985) found recovery of perennial grasses was slow,
but nevertheless it gradually occurred. Basal area of perennial grasses
increased from 0.28% to 5.8% over 25 years. In a later publication,
Anderson and Inouye (2001) found that cheatgrass was less competitive
and able to establish in areas where native perennial grasses were
thriving. Heady and Child (1994) also noted the effects of native
vegetation on suppressing or excluding cheatgrass. McLean and Tisdale
(1971) found it took 20 to 40 years for bunchgrasses to fully recover
from poor to excellent condition under complete rest. Evanko and
Peterson (1955) found that 18 years of livestock exclusion of an area
heavily grazed for 50 years resulted in a decrease in unpalatable forbs
and shrubs, while grass cover, herbage yield, litter cover and water
absorption were greater in the protected areas than in those areas that
continued to be grazed.

Orr (1975) found that more than one complete season of rest was needed
for significant soil recovery as measured by pore volume and
infiltration. Bryant et al (1972) found that under increasing trampling
frequency, soil compaction increased and resulted in a significant
decrease in forage production for tramplings in June and September.
Kauffman et al (2004) studied upland and wet meadow communities that had
livestock excluded for 9 -- 18 years. They found major differences
between these ungrazed communities and those continuing to be grazed. In
each case, the area without grazing had greater belowground plant
biomass, lower soil bulk density and higher soil pore space. In dry
meadows the infiltration rate was 13 times greater than those continuing
to be grazed and in wet meadows, infiltration of rested areas was 2.33
times greater. Bohn and Buckhouse (1985) found that grazing systems
including season-long, rest-rotation and deferred grazing did little to
enhance and sometimes hindered infiltration and beneficial soil
properties. Grazing during wet periods such as spring and fall had
negative impacts on these attributes.

**2.6 [Economic Considerations.]{.underline}** Other than asserting in
various ways that continued livestock grazing at current levels provides
for preservation of rural values and lifestyles, agencies generally do
not provide any economic analysis of the costs and benefits of public
lands livestock grazing and its contribution to local and regional
economies. It does not analyze the values of uses foregone in favor of
livestock grazing and its infrastructure. The following discussion
provides some insight into the relationship of proper grazing management
to economics and issues that should be addressed in making grazing
decisions.

The studies we have cited show that light stocking results in greater
forage production and improvement in range condition when compared to
both heavy and moderate use. Moderate and light use also provided
greater financial returns than those obtained with heavy use. Because
these financial figures included data from humid areas, a separate
analysis taking into account the necessity for destocking during drought
in arid regions showed that conservative stocking (35% use) would
provide the highest long-term financial returns on semi-desert
rangelands in Arizona.

Economic analyses in (Holechek et al, 1999b) show that conservative
stocking rates yield better returns. For example, in the sheep
experiment at the Desert Experimental Range in Utah, the lower stocking
rate (35% use) yielded a financial return of \$0.39/acre compared to
\$0.14/acre for the higher stocking rate (60% use). A modeling study
that evaluated 29 years of financial returns for a cow-calf operation
revealed that a relatively constant stocking rate of 35% use was
considered the best approach. Holechek et al (1999a) analyzed 25 studies
on the effects of grazing intensity on native vegetation and livestock
production and found that across all studies light stocking provided
greater returns and better condition of the land. The results of their
analysis is provided in Table 6.

Results of seven years' research in New Mexico's Chihuahuan Desert to
evaluate the relationship between range condition and financial returns
showed similar relationships (Holechek et al 1996a). Condition was
evaluated using the Dyksterhuis (1949) definitions based on departure
from climax. This study showed a relationship between forage production
and range condition. Higher condition range, or that nearer climax
community plant composition, had higher production of forage and more
preferred forage species than lower condition range. Excellent range
condition provided over four times the financial return of fair
condition range and 65% greater return than good condition range.

**Table 6. Summary of Data from 25 Classic Grazing Studies (Holechek et
al 1999a)**

  --------------------------- -------------- -------------- --------------
  **Description**             **Heavy**      **Moderate**   **Light**

  Average Forage Use %        57             43             32

  Average Forage Production   1,175          1,473          1,597
  lb/acre                                                   

  Drought Years Production    820            986            1,219
  lb/acre                                                   

  Average Calf Crop %         72             79             82

  Average Lamb Crop %         78             82             87

  Calf Weaning Weight lbs     381            415            431

  Lamb Weaning Weight lbs     57             63             \--

  Gain per Steer lbs          158            203            227

  Steer/calf Gain per Day lbs 1.83           2.15           2.3

  Steer/calf Gain per Acre    40.0           33.8           22.4
  lbs                                                       

  Lamb Gain per Acre lbs      26.0           20.4           13.8

  Net Returns per Animal \$   38.06          51.57          58.89

  Net Returns per Acre \$     1.29           2.61           2.37
  --------------------------- -------------- -------------- --------------

Winder et al (2000) reported on comparisons of stocking rates and
financial returns using 30 or 40% of current years perennial grass
growth. The 30% use level provided greater vegetation productivity and
financial returns. After drought in 1994 through 1996, forage production
on the pastures with the lower stocking rate (30% use) increased 71%
compared to 35% increase on those with the moderate stocking rate (40%).
Economic returns were \$0.52/acre for the conservative use level and
\$0.31/acre for the moderate use level. A combination of stubble
heights, clippings and ocular measures were used to set annual stocking
rates, termination of the grazing season, sale of cattle to balance
numbers with capacity and destocking during drought. Under these
criteria, all pastures were destocked in the summer of 1994 and the
moderately stocked pasture was destocked in May, 1999. After livestock
were removed due to drought, pastures were rested for two years, then
afterwards stocked in late fall according to current year's forage
production.

The reasons for this were the high costs of management and the energy
lost by livestock in seeking forage in lower condition range. In a
companion paper, livestock returns were compared to conventional
investments such as bonds or stocks (Holechek et al, 1996b). This
analysis showed that over-capitalization in infrastructure, coupled with
over-stocking lead ranchers into a boom and bust cycle as climatic
conditions change. In wet years, they added livestock, generally when
prices were high then sold off their herds during dry, or bust periods
when prices and productivity are low. The final analysis concluded that
conservative stocking, minimal investment in range improvements and
greater spacing of watering points reduced fixed costs and insulated the
operation from the vagaries of precipitation and market forces.

Dr. Thomas Power (In Wuerthner and Matteson 2002) shows that *"Livestock
grazing on federal lands is generally unimportant to local economies and
even less so to state and regional economies. In terms of income and
numbers of jobs provided, the contribution of federal lands grazing is
less than 0.1% across the West. Farm and ranch operations are
increasingly reliant on nonfarm income sources to be financially
feasible, while livestock grazing competes with other uses of public
lands -- such as clean water, recreation, wildlife habitat -- that
contribute to the ongoing vitality of western economies."*

In his analysis of the economies of individual rural counties, Dr. Power
showed that federal lands grazing does not contribute significantly to
those economies across the west. In fact, given the high percentage of
ranching families that have jobs, either full or part time outside the
ranch (60 -- 70%), it is ranchers that depend on the other economic
sectors for their ability to persist, not federal grazing. Dr. Power
states, *"It is not that towns depend on agriculture, but that
agriculture increasingly depends on the vitality of urban and
nonagricultural rural economies to provide the nonfarm income that keeps
farm operations alive."*

Dr. Power states that claims about the relative importance of federal
grazing to the economies of western states or counties can be analyzed
by answering these questions:

1.  "*What portion of the value produced by cattle and sheep operations
    is associated with feed used?*

2.  *What portion of the feed for those cattle and sheep operations
    comes from grazing on federal lands?*

3.  *What portion of the total agricultural activity involves raising
    cattle and sheep?*

4.  *What part of the total economy is represented by agriculture."*

Souder (1997) analyzed the economics of livestock grazing in the Central
Winter Ecosystem Management Area on the Kaibab Plateau using readily
available economic data. His analysis showed the values of various
activities in the study area (Table 7).

#### Table 7. Summary of Values Received Annually in the Central Winter EMA 

  ----------------------------------- -----------------------------------
  **Resource**                        **Local Benefits**

  Dispersed Recreation                \$6,400,000 (Locally and
                                      Regionally)

  Hunting Mule Deer and Turkey        \$719,392 (Mule Deer = \$470,528)

  Livestock Grazing                   \$43,283

  Fuelwood Gathering                  \$45,492
  ----------------------------------- -----------------------------------

In WWP's protest[^13] of the Rich County grazing permit renewals in
2001, Appendix B summarized State of Utah economic data for Rich County.
It determined that the BLM grazing permits contributed 2.8% of the
agricultural value in all of Rich County and that the non-agricultural
sector is growing at an annual rate equivalent to the entire annual
value of cattle production on BLM land. BLM never analyzed the economic
value of wildlife displaced by livestock and the loss of hunting,
recreational and fishing values created by grazing.

In addition to the economics of livestock production, Federal Agencies
are required to analyze other economic values and determine the values
foregone by their proposed actions. NEPA (40CFR1508.8) recognizes that
the analysis of effects must include ecological, aesthetic, historic,
cultural, economic, social, or health issues. Federal Agencies have
clouded the distinction between "cultural" as applied to historical
features such as buildings, artifacts, or paleo-resources with societal
lifestyle issues. In particular, in its recent DEIS to revise the
grazing regulations, BLM used the abstraction called "lifeways". It
appears BLM is trying to draw in "lifestyle" or "lifeways" as some sort
of cultural feature that is given protection by the cultural
preservation laws and SHPOs. This is not the intent of these laws nor
NFMA, FLPMA or NEPA.

BLM, the Forest Service and Rich County CRM should include consideration
and analysis of these various resources in their planning and also
provide more analysis of the economic benefits of wildlife through
hunting, fishing and wildlife-watching associated recreation. These
benefits are summarized in the Fish and Wildlife Service *2001 National
Survey of Fishing, Hunting and Wildlife-Watching Associated Recreation*
(DOI 2002). That survey showed that in Utah alone, expenditures for
hunting, fishing and wildlife-associated recreation were
\$1,143,408,000.00 in 2001. The values of forage when allocated to
various uses should be determined and analyzed to determine dollar
values in addition to the intrinsic values displaced by extractive uses.

**2.6 [Grazing Capability and Suitability Determinations]{.underline}**.
Current range science recommendations include adjusting the stocking
rate for livestock in order to account for distance from water and
steepness of slope (Holechek et al, 2001). Their suggested reductions in
grazing capacity for cattle with distance to water and increasing slope
are provided in Table 8. They note that on cold desert ranges of the
U.S., snow reduces water availability problems in winter. Also, sheep do
not require water every day and can use areas further than 2 miles from
water. Sheep on New Mexico winter ranges used slopes of less than 45%
with no adjustment necessary for slope, whereas slopes greater than 45%
were hardly used.

Regional criteria for the Intermountain Region of the Forest Service
currently designates lands with greater than 30% slope as not capable
for cattle and greater than 45% slope as not capable for sheep with a
requirement that forage production must exceed 200 lb/acre, and that
forested areas or areas with highly erodible soil are not capable
(Blackwell 2001; USDA 2001). The Forest Service provided early
quantification of capability criteria in its 1964 R4 Range Environmental
Analysis Handbook[^14].

> **Table 8. Adjustments for Distance to Water and Slope**
>
> **for Cattle (Holechek et al 2001)**

+-----------------------------------+----------------------------------+
| #####                             | **Percent Reduction in Grazing   |
| ### **Distance from Water miles** | Capacity**                       |
+-----------------------------------+----------------------------------+
| 0 -- 1                            | 0                                |
+-----------------------------------+----------------------------------+
| 1 -- 2                            | 50                               |
+-----------------------------------+----------------------------------+
| \>2                               | 100                              |
+-----------------------------------+----------------------------------+
| ### *Slope %*                     |                                  |
+-----------------------------------+----------------------------------+
| 0 -- 10                           | 0                                |
+-----------------------------------+----------------------------------+
| 11 -- 30                          | 30                               |
+-----------------------------------+----------------------------------+
| 31 -- 60                          | 60                               |
+-----------------------------------+----------------------------------+
| \>60                              | 100                              |
+-----------------------------------+----------------------------------+

Suitability determinations should be performed on those lands that are
found capable for livestock to determine whether or not livestock
grazing should be allowed. For example, important or critical fish and
wildlife habitat, recreation areas, locations of sensitive populations,
research natural areas, watershed protection areas among others should
not be considered suitable and should be closed to livestock. These
capability and suitability determinations are critical components in
meeting the definitions and mandates of FLPMA, NFMA and NEPA regarding
sustainability and multiple use.

**3.0 Management Recommendations for Uplands**

It is essential for the CRM to incorporate the science we have cited in
its analysis for planning and permit documents to ensure that best
available science is applied on the ground. This will ensure sustainable
multiple use without impairment of productivity. In this way, it may be
possible to sustain livestock grazing on those lands that are capable
and suitable. The following steps should be implemented.

**3.1 [Literature Review]{.underline}.** Review the literature on the
effects of grazing livestock in arid environments. This review should
address the effects of different levels of grazing intensity (stocking
rate), grazing systems, range improvements and livestock exclusion on
upland habitats. It should include an evaluation of their effects on
maintenance, productivity and recovery rates of native plants and soil
communities. It should also review the use of various standards,
indicators and monitoring methods used to manage grazing and their
ability to accurately and timely assess and be representative of plant
and soil community characteristics. It should also take into account the
needs of native wildlife such as sage grouse, pygmy rabbits and migrant
birds. We have attached a review of needs and recommendations for these
species in Section 5.0 of this document.

**3.2 [Determine Soil and Plant Community Status]{.underline}.** Using
GIS, map all vegetation, range site types and soil types in the affected
areas. Design and carry out a science-based review of existing
information and a field survey to accurately assess current conditions
in the plant and soil community. This survey should determine the
distribution of plant species, their ground cover and production. It
should do this by allotment, pasture and range site (soil) type. Survey
locations should be selected to incorporate distance to the nearest
source of water so effects due to proximity to water can be determined.
The survey should also include considerations of slope in order to
assess the interaction of susceptibility to erosion based on slope and
proximity to water sources. Results should be analyzed in the context of
past grazing management including type of livestock, seasons of use and
grazing intensity. Summarize historical actual use records and grazing
systems for each allotment to provide an evaluation of the effectiveness
of these past systems on current conditions as a starting point for
evaluating proposed actions.

**3.3 [Determine Capable and Suitable Acres for Livestock
Grazing]{.underline}.** Based on the science we have provided and
criteria we have discussed in the documents cited, (slope, distance to
water, forage production, hazard of erosion, etc) establish a
quantitative protocol for determining capable and suitable lands for
livestock grazing. This protocol should include a recovery prescription
for lands that are severely depleted of their native herbaceous plant
communities or have bare ground exceeding thresholds that lead to
accelerated erosion.

**3.3 [Determine a Sustainable Livestock Stocking Rate]{.underline}.**
Establish the percent of diets of domestic sheep, cattle, deer, elk,
pronghorn and sage grouse that are grasses, forbs and shrubs and their
seasonal variation in selection of these foods. We suggest information
from Holechek et al (2001) as a starting point. Using this information
and the population data and management goals for wildlife, calculate
wildlife needs. This should include the required cover, vegetation
height and other criteria (Attachment A) Based on the information
provided in section 2.0 above, and the limitations on use of perennial
grasses established by the scientific review, calculate the available
AUMs of palatable native forage grasses, forbs and shrubs that can be
utilized by livestock without impairment of plant productivity. Use this
analysis to determine livestock stocking rates for each allotment and
pasture for normal and dry precipitation years. Livestock numbers should
not be increased during above normal precipitation years to allow for
improvement of plant and soil conditions. Since half the years are below
normal in precipitation and therefore, plant production, stocking rates
should be based on production during unfavorable years.

**3.4 [Develop a Systematic Monitoring Protocol]{.underline}.** Based on
the science we have referenced here, develop a systematic monitoring
protocol for assessing livestock use (forage amount) in a timely manner
to avoid over use of any pasture. The timing of measurement must be
established relative to the permitted grazing season of use. It is
critical that during the early years of application, these must be
assessed frequently in order to ascertain the length of time livestock
may remain in each pasture before excessive use occurs. This information
will lead to establishment of realistic grazing schedules that lower the
risk of excessive livestock grazing and damage. If indicators such as
stubble height are proposed, they must also have a demonstrated
relationship to actual percent use on grasses, forbs and shrubs by field
testing.

**3.5 [Determine Recovery Prescriptions for Lands Below
Potential]{.underline}.** Analyze peer-reviewed science and government
publications we have referenced as well as others that have specifically
evaluated different grazing scenarios and their ability to recover
native components of damaged arid lands to their potential. Use this
information to develop recovery prescriptions for allotments and
pastures based on their departure from potential species distribution,
ground cover and productivity. Prescriptions that should be evaluated
should include options such as (a) long-term rest, (b) reduced stocking
rates, (c) grazing systems, (d) reseeding, (e) vegetation treatments and
others. The time required for recovery of potential should be evaluated
for each method and if it has not been demonstrated to occur for that
method, it should be abandoned.

**3.6 [Determine Impacts of Water Developments]{.underline}.** Water
developments have been used for decades on the promise that they would
result in better livestock distribution and improvement in conditions on
the ground. In our experience, agencies have never quantitatively
assessed these claims. It is critical that this analysis be done based
on evidence from the literature and surveys of conditions in Rich
County. The analysis described in sections 3.1 and 3.2 above should
include an element that locates and maps all water developments and
water sources. Based on field surveys combined with historical range
data and satellite imagery, determine the impacts and/or benefits of
these past water developments on upland plant communities and soils. The
effects of these water developments on their source waters (spring,
stream or seep) and associated wetland habitats should be assessed,
documented and reported in each project analysis. Such parameters as
flow rates, potential and current aerial extent of riparian and wetland
areas associated with these should be documented

**4.0 Management Recommendations for Riparian Areas**

Current management on allotments in Rich County does not provide assured
protection of springs, streams, riparian areas and wetlands as these
areas are highest in wildlife values, yet occupy only a small land area.
While continuing to propose additional water developments and grazing
systems as a means of protecting riparian areas, grazing project
proposals do not provide scientific evidence that the values of these
areas are actually protected by these methods. The evidence in the
government and scientific literature is that excluding livestock from
riparian areas is the only effective method of protection and recovery.
As noted above, stubble height standards are not currently enforced and
riparian exclosures are not consistently maintained. These conditions
must be corrected at a minimum while best available science is used to
restore these most important resources.

Don Duff (1977) published results of studies in Rich County that showed
greater fish and vegetation production and stream bank recovery occurred
within exclosures on Big Creek than outside in grazed areas. He stated
that conditions outside the exclosures continued to decline. He
concluded that 6 to \>8 years of rest were necessary to restore aquatic
and riparian habitat. Even after 30 years of excluding livestock,
sediment from uplands and riparian areas outside the exclosures continue
to impair salmonid spawning, rearing and feeding substrates. The
literature is consistent in showing that exclusion of livestock from
riparian areas is the most effective method of restoring their
ecological integrity. There is little evidence that continued livestock
grazing of degraded streams under various management schemes leads to
recovery of habitat attributes required for native fish and wildlife.
Any alternatives to livestock exclosures should be evaluated in the
literature review proposed in paragraphs (4.1) and (4.7) below and
include those evaluations and the science upon which they are based in
project analysis.

We are concerned over the lack of quantitative monitoring of streams,
springs and riparian areas. Some of the limitations of the current PFC
assessment technique are discussed in Stevens et al (2002). Generally we
are not provided with any systematic protocol for monitoring stream
habitats, while spring or wetland conditions are not addressed. We are
concerned that reliance will be placed on stubble heights without
providing any evidence that, in arid ecosystems, use of this standard
promotes recovery of critical habitat elements in damaged stream or
wetland systems, or for that matter, prevents degradation of those
attributes.

**4.1 [Literature Review]{.underline}.** Review the literature on the
effects of livestock grazing, grazing systems, range improvements and
livestock exclusion on stream, spring and riparian habitats, their
maintenance and recovery as well as water quality. Carter (2001)
reviewed the general effects of livestock grazing on riparian areas and
water quality[^15]. Review the use of various indicators such as
riparian stubble height and bank trampling measures, their application
and relation to stream bank stability, riparian vegetation productivity,
in-stream aquatic habitat and restoration rates. This review should
incorporate analysis of the literature we have referenced in addition to
any other applicable sources.

**4.2 [Assessment of Current Condition of Springs, Seeps and
Wetlands]{.underline}.** Locate and map all springs and wetlands not
associated with perennial streams. Photograph and describe each,
document whether and how they have been modified for water developments
and if so, whether the development is still functioning. Assess their
current condition, wetland extent (area) and flow using photographs and
DOI (1994). These habitats should be surveyed to establish a current
baseline. The surveys should also be repeated during each permit
mid-term and one year prior to permit renewal. Conduct the baseline
mapping, analysis and photographs for each project.

**4.3 [Develop a Monitoring Protocol for Springs, Seeps and
Wetlands]{.underline}.** Based on the science reviewed in section 4.1,
develop a systematic monitoring protocol for livestock use of
riparian/wetland herbaceous vegetation at springs, streams and wetlands.
This assessment protocol will:

a.  Establish livestock trampling and utilization standards and assess
    these effects at each spring and wetland area and at multiple
    locations on each flowing stream within each pasture. A defined
    protocol should specify the number of measurements to be taken at
    each location, the length of stream reach to assess and a method to
    evaluate trampling damage to springs and wetlands.

b.  Measure percent use of riparian grasses, not sedges. These
    measurements will be taken in the riparian aquatic influence zone
    outside the stream channel, not along the greenline.

c.  Monitor water quality for conformance to standards for coliform
    bacteria and compliance with temperature criteria for cold water
    fisheries.

d.  Establish a schedule for each allotment/pasture that measures these
    parameters no later than 2 weeks after livestock enter a particular
    pasture or allotment subdivision and repeat until the removal date
    is determined. It is important to measure these use levels early in
    the grazing period so stocking rates and management can be adjusted
    in a timely manner to prevent exceeding the standards. Accelerated
    measurements during the first years, in particular, are necessary to
    refine the schedule for future years.

e.  Record the data, including allotment, pasture, location designation,
    turn-in date, monitoring date, riparian species measured, percent
    bank trampling, percent area trampled (springs and wetlands) and
    utilization levels. Record raw data on prepared forms and enter this
    information into an electronic database that can be regularly
    updated following each monitoring event and is accessible to
    interested parties either on-line or by request.

**4.4 [Assessment of Current Condition of Streams]{.underline}.** Based
on best available science, describe a methodology and schedule for
performing stream habitat and water quality surveys. This should include
analysis of existing data and collection of baseline habitat and water
quality data, maps and photographs that will be included in each project
analysis.

**4.5 [Develop Stream and Water Quality Monitoring
Protocol]{.underline}.** In addition to the baseline survey, a
monitoring protocol should be developed that provides for assessment of
stream habitat and water quality during succeeding permit terms near the
permit or lease mid-term and the year prior to renewal. This monitoring
protocol could continue to include PFC assessments using DOI (1993) as
modified by Stevens et al (2002). Winward (2000) also provides insight
into stream and riparian monitoring technology. Any of these ocular
protocols should be supplemented by collecting additional data that
quantitatively documents certain critical stream habitat conditions. We
suggest the Rosgen method, USDA (1992, 1997) or other acceptable fish
habitat survey protocols. Regardless of method, certain critical pieces
of information must be collected to supplement PFC assessments. The
literature should be reviewed and analyzed and details of methodologies,
data management, reporting and public access explained. This critical
supplemental data includes:

a.  Establishing permanent, marked stream cross-section survey points
    for determining channel profile, width and depth similar to those
    used by Duff (1977). Priority locations are in Rosgen Type "C"
    channels (low-gradient reaches), if available and should encompass a
    complete meander with multiple cross-sections (minimum 3 at each
    reach). These channel surveys and the following data should be
    collected for a minimum of two reaches of each perennial stream in
    each pasture.

b.  Bank condition surveys including measurement of the following
    parameters over a minimum 100' stream reach or full meander on both
    sides of the stream (Winward, 2000, recommends 363 feet). Bank
    condition parameters (i -- iv) will be assessed from the water line
    to the top of the bank, not at the greenline, parameters (v -- vi)
    will be assessed relative to the wetted area of the stream:

    i.  the linear feet of stream banks that are vegetated/stable

    ii. the linear feet of stream banks that are vegetated/unstable

    iii. the linear feet of stream banks that are unvegetated/stable

    iv. the linear feet of stream banks that are unvegetated/unstable

    v.  the linear feet of stream banks that are undercut

    vi. the linear feet of stream bank with overhanging vegetation.

c.  During the baseline survey, and during succeeding permit terms, at
    permit mid-term and last permit year, collect triplicate MacNeil
    Core Sediment samples of salmonid spawning gravels (\<2") near the
    downstream extent of each stream in each pasture. Based on the
    literature, establish criteria for sediment fines (\<6.35 mm) as a
    percent of substrate that allows successful salmonid reproduction.
    Generally, levels of sediment fines above 20% may result in
    significant mortality of eggs and larvae.

d.  Data collected will be systematic and quantitative in order that
    statistical analysis can be employed. All data will be entered into
    an electronic database for access by interested parties.

Describe the monitoring protocols. This description will include: the
actual methodologies, data entry forms, schedules and locations; provide
maps of all locations for monitoring; and incorporate an electronic
database with links to maps that is accessible to the interested public.
Include the baseline data in each project analysis. Projects should not
be proposed unless there is a demonstrated capability to collect the
systematic and quantitative data needed for evaluation of their
effectiveness.

**4.6 [Develop Stream, Spring and Wetland Recovery
Prescriptions]{.underline}.** For streams, springs and wetlands that are
not functioning properly, have impaired water quality or lack
significant in-stream habitat features such as undercut banks, woody
debris, overhanging grasses or canopy cover , analyze available methods
for their recovery. Include an anticipated time frame for recovery to
take place based on the scientific literature. Discuss and evaluate
these options for recovery, including their costs and benefits and
review the scientific literature provided. Methods for recovery should
include consideration of: (a) closing pastures; (b) exclosure fencing;
(c) removal of water developments; (d) restoration/replanting of
riparian areas; (e) active herding to minimize livestock use; (f)
removal of livestock when utilization standards are reached and (g) any
other methods discovered in the literature. Propose and adopt methods
that will best recover these degraded streams during the first permit
term. In the on-going permitting, management and monitoring of livestock
grazing, documentation of condition and recovery rates by implementation
of the described monitoring program must continue.

**5.0 Habitat Requirements for Sage Grouse, Migratory Birds and Pygmy
Rabbits**

**[5.1 Sage Grouse Habitat Requirements]{.underline}.** Several authors
have reviewed and documented the biology and habitat requirements for
sage grouse during their various life stages. These life stages include
leks or breeding, nesting, brood-rearing and wintering.

Braun et al (1977) in their review found that leks or breeding sites
were generally open areas surrounded by sagebrush and that nesting areas
appeared to occur within a few kilometers of the lek sites. The maximum
distance between leks and nesting sites reported was 12.9 km, with 59%
being within 3.2 km. Successful nest sites had significantly greater
sagebrush canopy cover (27%) as opposed to unsuccessful sites at 20%. An
important component of the nesting sites is also the cover provided by
herbaceous vegetation, particularly grasses. Connelly et al (2000)
reported a range of grass height at nest sites between 14 -- 34 inches
and a mean of 20 inches with canopy cover of grasses ranging from 4 to
51% with a mean of 16%. During brood-rearing, grouse with chicks
preferred more open sagebrush uplands at about 10% - 14% canopy, while
loafing of adults occurred in stands with 30% canopy. Beginning in June
and during mid-late summer, broods moved to more mesic sites such as
meadows. Hockett (2002) stressed the importance of riparian and wet
meadow sites during summer and fall. Wintering sites were reported to
have greater than 20% sagebrush canopy cover.

Connelly et al (2000) summarized some general characteristics of sage
grouse habitat in the following table

![](media/image4.png){width="4.958333333333333in"
height="1.7638888888888888in"}

The sagebrush canopy characteristic for breeding habitats is reported as
a broad range, but it is important to remember that successful nests
occur in areas with canopy cover at the high end of the range or higher
as cited above.

Diets of sage grouse vary through the year and by age. Sage grouse
depend entirely on sagebrush from October through April. In May, they
shift to a forb-dominated diet (20 -- 60%) with the remainder being
mostly sagebrush. They shift back to sagebrush during September. Chicks
begin life depending heavily on insects at about 60%, then shift to a
forb dominated diet with about 15% sagebrush during the second month.

Braun et al (1977), Welch et al (1990), Connelly et al (2000) report
that spraying, burning and mechanical treatments of sagebrush resulted
in declines of sage grouse. Other activities such as construction of
roads, powerlines, fences, reservoirs, ranches, farms and housing
developments have resulted in sage grouse habitat fragmentation and
loss. Structures such as fences and powerlines provide perch sites for
raptors that prey on sage grouse and also result in injury or death when
grouse collide with these.

Connelly et al (2000) and Hockett (2000) reported that sage grouse have
high seasonal fidelity to seasonal ranges and females return to the same
area to nest each year. Hockett (2002).

Beck and Mitchell (2000) and Hockett (2002) reviewed the effects of
livestock grazing on sage grouse. They report that livestock, by
consuming herbaceous vegetation and reducing grass cover needed to
conceal grouse nests from predation, reduce grouse production. Ground
squirrels favored by high levels of grazing, combined with drought
conditions account for significant nest predation. The depletion of
forbs and loss of associated insects can directly impact chick survival.
Mattise (1995) noted that "we have poor strategies for protecting
important brood rearing habitat during severe drought conditions.
Riparian areas, springs and seeps are not being managed to provide
vegetative recovery and enhancement."

Rich (1985) reviewed historical studies of sage grouse populations from
32 years of monitoring in southern Idaho and northwestern Utah. He
concluded that sage grouse experience cyclic population patterns with 10
year highs. Mitchell and Maxfield (2001) analyzed results of lek counts
in Utah from 1967 through 2000. They found a decreasing trend in numbers
of males per lek site, and their data clearly shows a 10 year cycle of
peaks and valleys. The last valley was found in 1996 with an uptrend
through 2000. It is important to reflect on these possible trends when
analyzing results for short periods. Rich (1985) states, "evaluations of
grouse population responses to habitat changes are critically dependent
on understanding the long-term population dynamics of the species,
especially where such evaluations may be done over a period of a few
years." He concludes that "Ten years data may be required to even begin
an adequate definition of just the breeding habitat of a population."

**5.2 [Guidelines for Management of Sage Grouse Habitat]{.underline}.**
These authors (Braun et al, Connelly et al, and Welch et al) have
provided a variety of guidelines for management of sage grouse habitat.
These include:

-   Sagebrush eradication should not be practiced. Treatments can be
    used to thin dense sagebrush stands to a range of sagebrush cover
    from 15% to 25%. Burns should be avoided in xeric Wyoming big
    sagebrush habitats). Only small burns to create mosaics in mountain
    big sagebrush should be contemplated and these are considered
    experimental.

-   Rehabilitation following wildfire or other disturbances should focus
    on re-establishing sagebrush and native herbaceous plants. Annual
    grass establishment following fire is detrimental. Grazing should
    not be allowed on seeded areas until plant recruitment has occurred.

-   Range seedings should focus on establishing forbs, native grasses
    and sagebrush. Monoculture seedings of crested wheatgrass and other
    non-natives are discouraged.

-   Applying insecticides to summer habitat is not recommended.

-   Livestock use around water sources and wet meadows in brood rearing
    areas should be regulated through fencing or other management to
    restrict overuse.

-   Grazing practices should be adjusted to maintain residual grass
    growth essential for nest concealment and then delay grazing the
    same areas until after nesting.

-   Plot sage grouse use areas including leks, nesting areas, wintering
    sites, meadows and summer range or brooding areas on maps.

-   No sagebrush will be treated or removed until a comprehensive plan
    has been formulated for management of the area.

-   Sagebrush control projects will include provisions for long-term
    quantitative measurement of vegetation before and after to determine
    effects on habitat and whether objectives were met.

-   No sagebrush control projects will be done on areas where live cover
    is less than 20%, on steep slopes or upper slopes with skeletal
    soils where big sagebrush is less than 30 cm.

-   No sagebrush control along streams, meadows or intermittent
    drainages. A 100 meter strip of live sagebrush should be left on
    each edge of meadows and drainages.

-   When sagebrush control is found to be unavoidable, treatment
    measures should be applied in irregular patterns using topography
    and other ecological considerations. Widths of treated and untreated
    areas can vary except treated areas will not be wider than 30 meters
    and untreated areas will be at least as wide.

-   Manage breeding habitats to support 15 -- 25% canopy cover of big
    sagebrush, perennial herbaceous cover ≥18 cm in height with ≥ 15%
    canopy cover of grasses and ≥ 10% canopy cover of forbs.

Miller and Eddleman (2000) also provide an excellent review of sage
grouse ecology, habitat and management. They emphasize that sage grouse
habitat management plans must take into account landscape heterogeneity,
site potential, site condition and habitat needs of sage grouse during
different parts of their life cycle (breeding, nesting, brood rearing,
wintering). They also stress the importance of accurate resource
inventories and assessments before making management decisions as to
when and how each community across the landscape should be managed.
Grazing management plans must identify potential conflicts between sage
grouse and livestock.

**5.3 [Pygmy Rabbits]{.underline}.** In the fall of 2003, Dr. Bruce
Welch of the Forest Service's Intermountain Research Station visited
Hogback Ridge in Sections 29 and 30 immediately south of Six Mile Creek
(South Fork). He found visual sign of pygmy rabbit activity (burrows and
pellets) at 30 locations in 21.2 miles of transects walked (Welch,
personal communication).

Welch (2004, in press) reports his research in which he walked 300 miles
in pygmy rabbit habitat, covering areas where pygmy rabbits were
previously reported. In 37 stands of big sagebrush in northern Utah, he
found 11 pygmy rabbits, with 8 occurring in a single stand of sagebrush.
Out of 11 sites previously reported as supporting pygmy rabbits, he
found no signs of occupancy with only four sites now having suitable
habitat.

Suitable habitat consisted of big sagebrush ≥ 20% canopy cover and ≥ 22
inches in height. He reports on significant deterioration and loss of
habitat for pygmy rabbits through conversion of sagebrush stands to
agriculture and treatments designed to improve forage conditions for
livestock by reducing sagebrush cover. In his literature review, he
gives some additional parameters describing wintering habitat for pygmy
rabbits. The research showed the areas of highest winter use were in
basin big sagebrush with canopy cover of 51% compared to areas with
moderate us having 42.7% canopy and low use in 38.6% canopy. Diets
consist of 99% sagebrush in winter and 51% during summer.

DOI (2001) summarizes additional diet characteristics for pygmy rabbits.
In particular, they were reported to rely on 39% grasses such as native
Agropyron species and 10% forbs. Other characteristics described in both
references include descriptions of soil conditions amenable to
burrowing.

**5.4 [Migrant Birds]{.underline}.** Woodyard et al (2003) conducted
bird censuses along an elevational gradient in east-central Nevada.
These censuses were conducted in study plots monitored in 1981 and 1982
by Dean E. Medin and found fewer species and total numbers of birds (62%
less). Parrish et al (2002) also describe the declines in these birds
due to a variety of factors relating to habitat. They provide
descriptions of the birds in Utah most in need of conservation and
describe their habitat requirements, threats and management
considerations. They discuss habitats most in need of conservation.
Habitats such as shrub-steppe occurring in the Duck Creek allotment are
described as in need of protection. Medin et al (2000) provide a
discussion of bird-habitat relationships for the Great Basin that
provide insight into the habitats that occur in the Duck Creek allotment
and their relationships to these birds. Many of these birds are
dependent on riparian areas.

Paige and Ritter (1999) cite population declines of 63% and 70% in shrub
dependent and grassland bird species during the last 30 years across the
U.S. In the Intermountain West, more than 50% of shrub- and grassland
species show downward trends with sagebrush steppe as the highest
priority for conservation based on trends for habitat and bird
populations. They provide detailed descriptions of the history,
characteristics and management of these systems with management
recommendations. They note that cattle grazing in sagebrush steppe first
select grasses and forbs and avoid browsing on sagebrush. In addition,
even light grazing can put pressure on the herbaceous plants favored by
livestock and intensive spring grazing prevents bunchgrasses from
reproducing, eventually eliminating the palatable native bunchgrasses.
They also discuss the response time for recovery of these systems and
parasitism by cowbirds, a significant factor in decline of songbirds in
some areas.

Taylor (1986) evaluated the effects of cattle grazing on birds nesting
in riparian habitats. He found that increased grazing resulted in
decreases shrub volume and density and decreased bird abundance. "The
longer the time since a transect was last grazed correlated
significantly with increases in bird abundance, shrub volume and shrub
height". Bird species decreased with increased brazing, bird counts were
5 to 7 times higher on an area ungrazed since 1940 thatn on 2 areas
grazed annual until 1980 and 11 to 13 times higher on a transect
severely disturbed.

Krueper et al (2003) studied the changes in vegetation and breeding
birds in the San Pedro River, Arizona following removal of cattle in
1987. Birds were monitored for five years. Mean numbers detected along
riparian transects increased by 23% per year or from 103/km in 1986 to
221/km in 1992. Earnst et al (2004) compared songbird abundance in
2000-2001 to that in 1991-1993, following cattle removal from the
Sheldon National Wildlife Refuge in 1990. Of 51 species for which
abundances were sufficient to calculate changes, 71% exhibited a
positive trend. Detections of ground/low cup and high cup nesting
species, ground/understory foraging species, aerial and overstory
foraging species increased significantly.

Rich (2002) evaluated the ability of riparian PFC assessments as
employed by BLM and noted that they lacked the ability to incorporate
assessment of land breeding bird communities. He constructed a list of
riparian-obligate birds that should occur on the site during the
breeding season and used that to score the site based on the percent of
those occurring there.

**5.5 [Management Recommendation for Migratory Birds]{.underline}.**
Partners in Flight (Paige and Ritter, 1999) provide management
recommendations for sage grouse and migratory birds obligate to
sagebrush-steppe. These include:

-   Identify and protect those habitats that still have a thriving
    community of native understory and sagebrush plants.

-   Maintain large, continuous blocks of unfragmented habitat

-   Maintain seeps, springs, wet meadows and riparian vegetation in a
    healthy state

-   Avoid practices that convert sagebrush to non-native grassland or
    farm land.

-   Maintain stands of sagebrush for a balance between shrub and
    perennial grass cover.

-   In large disturbed areas, sagebrush and perennial grasses may need
    to be reseeded to shorten recovery time.

-   To maintain bluebunch wheatgrass vigor, avoid grazing during the
    growing season until plants begin to cure. Bluebunch wheatgrass is
    especially sensitive to heavy grazing during the growing season.
    Recovery of these plants following heavy grazing during a single
    spring can require 8 years under the best management and
    environmental conditions.

-   Grazing plans will depend on the current condition and plant
    composition of the area. Defer grazing until after crucial growth
    periods. Note that in the presence of cheatgrass, deferred grazing
    can favor the cheatgrass.

-   For sage grouse maintain average grass height of at least 18 cm in
    May and early June. Sharp-tailed grouse require 20 cm.

-   Consider livestock exclusion from heavily damaged areas,
    particularly wet sites.

-   Livestock concentrations around water developments can increase
    cowbird parasitism.

-   Use fences with smooth top and bottom wires for exclosures around
    wet sites.

**6.0 Bibliography**

Anderson, Jay E. and Karl E. Holte. 1981. Vegetation development over 25
years without grazing on sagebrush-dominated rangeland in southeastern
Idaho. Journal of Range Management 34(1):25-29.

Anderson, David C., Kimball T. Harper and Ralph C. Holmgren. 1982.
Factors influencing development of cryptogammic soil crusts in Utah
deserts. Journal of Range Management 35(2):180-185.

Anderson, A. N. 1987. Effects of seed predation by ants on seedling
densities at a woodland site in SE Australia. Oikos 48:171-174.

Anderson, Loren D. 1991. Bluebunch wheatgrass defoliation, effects and
recovery -- A Review. BLM Technical Bulletin 91-2, Bureau of Land
Management, Idaho State Office.

Anderson, Jay E. and Richard S. Inouye. 2001. Landscape-scale changes in
plant species abundance and biodiversity of a sagebrush steppe over 45
years. Ecological Monographs 71(4):531-556.

Armour, C.L., D.A. Duff and W. Elmore. 1991. The effects of livestock
grazing on riparian and stream ecosystems. Fisheries 16(1): 7 -- 11.

Austin, Miriam. 2003a. Water developments and wildlife. Violating the
public trust. Red Willow Research.

Austin, Miriam. 2003b. BLM Pleasantview allotment wildlife deaths, 2003.
Red Willow Research.

Bartos, Dale L. and Robert B. Campbell, Jr. 1998a. Water depletion and
other ecosystem values forfeited when conifer forests displace aspen
communities. Rangeland Management and Water Resources of American Water
Works Association. May 1998: 427-433.

Bartos, Dale L. and Robert B. Campbell, Jr. 1998b. Decline of Quaking
Aspen in the Interior West -- Examples from Utah. Rangelands
20(1):17-24.

Beck, Jeffrey, L. and Dean L. Mitchell. 2000. Influences of livestock
grazing on sage grouse habitat. Wildlife Society Bulletin
28(4):993-1002.

Belnap, Jayne. 1995. Surface disturbances: their role in accelerating
desertification. Environmental Monitoring and Assessment 37:39-57.

Belnap, Jayne. 1996. Soil surface disturbances in cold deserts: effects
on nitrogenase activity in cyanobacterial-lichen soil crusts. Biology
and Fertility of Soils 23:362-367.

Belnap, Jayne and D. A. Gillette. 1997. Disturbance of biological soil
crusts: impacts on potential wind erodibility of sandy desert soils in
southeastern Utah. Land Degradation and Development 8:355-362.

Belnap, Jayne, Roger Rosentreter, Steve Leonard, Julie H. Kaltnecker,
John Williams and David Eldridge. 2001. Biological soil crusts: ecology
and management. U.S. D.O.I. Bureau of Land Management Technical
Reference 1730-2.

Belsky, A.J., A. Matzke, and S. Uselman. 1999. Survey of livestock
influences on stream and riparian ecosystems in the western United
States. Journal of Soil and Water Conservation 54(1): 419-431.

Belsky, A. Joy and Dana M. Blumenthal. 1997. Effects of livestock
grazing on stand dynamics and soils in upland forests of the Interior
West. Conservation Biology 11(2):315-327.

Belsky, A. Joy, and Jonathan L. Gelbard. 2000. Livestock Grazing and
Weed Invasions in the Arid West. A Scientific Report Published by the
Oregon Natural Desert Association. Portland, Oregon.

Beymer, Renee J. and Jeffrey M. Klopatek. 1992. Effects of grazing on
cryptogamic crusts in pinyon-juniper woodlands in Grand Canyon National
Park. American Midland Naturalist 127:139-148.

Blaisdell, James P. and Ralph C. Holmgren. 1984. Managing Intermountain
Rangelands -- Salt-Desert Shrub Ranges. USDA Forest Service,
Intermountain Forest and Range Experiment Station, Ogden, Utah. General
Technical Report INT-163. 52p.

Blackwell, Jack. 2001. Letter on capability and suitability. Regional
Forester, Intermountain Region.

BLM. 1994. Rangeland Reform '94 Draft Environmental Impact Statement.

BLM. 2003. Proposed Revisions to Grazing Regulations for the Public
Lands, Draft Environmental Impact Statement DES 03-62.

Bock, Carl E., Jane H. Bock, William R. Kenney and Vernon M. Hawthorne.
1984. Responses of birds, rodents and vegetation to livestock exclosure
in a semidesert grassland site. Journal of Range Management
37(3):239-242.

Bohn, C.C., and J.C. Buckhouse. 1985. Some responses of riparian soils
to grazing management in northeastern Oregon. Journal of Range
Management 38(4):378-381.

Braun, Clait E. 1977. Guidelines for maintenance of sage grouse habitat.
Wildlife Society Bulletin 5(3):99-105.

Brennan, C. A. and Fred B. Harris. 1943. Fourteen Years Cattle
Production and Ranch Earning Power in Northeastern Nevada 1928 to 1941.
University of Nevada Agricultural Experiment Station, Reno.

Brotherson, Jack D., Samuel R. Rushforth and Jeffrey R. Johansen. 1983.
Effects of long-term grazing on cryptogam crust cover in Navajo National
Monument, Ariz. Journal of Range Management 36(5):579-581.

Bryant, H.T., R.E. Blaser, and J.R. Peterson. 1972. Effect of trampling
by cattle on bluegrass yield and soil compaction of a Meadowville loam.
Agronomy Journal. 64:331-334.

Carlson, Cathy and John Horning. 1992. Big profits at a big price --
Public Land ranchers profit at the expense of the range. Publication No.
79950, National Wildlife Federation, 1400 Sixteenth St. N.W. Washington,
D.C. 64p.

Carter, John. 1998. Investigation of Spawn Creek, Utah Coliform
Contamination and Stream Bank Stability in Relation to Cattle Grazing.
Willow Creek Ecology report.

Carter, John G. 2001. Livestock and water quality. Western Watersheds
Project Report.

Catlin, James, Joro Walker, Allison Jone, John Carter and Joe Feller.
2003. Multiple use grazing management in the Grand Staircase National
Monument. A tool provided to the Monument range staff by the Southern
Utah Land Restoration Project.

Clary Warren and Bert Webster. 1989. Managing grazing of riparian areas
in the Intermountain Region. Intermountain Research Station, Forest
Service. General Technical Report INT-263

Cummins, K.W. and George L. Spengler. 1977. Stream ecosystems. Water
Spectrum. 10:1-9.

Cummins, K. W. 1974. Stream ecosystem structure and function. Bioscience
24:631-641.

Connelly, John W., Michael A. Schroeder, Alan R. Sands and Clait E.
Braun. 2000. Guidelines to manage sage grouse populations and their
habitats. Wildlife Society Bulletin 28(4):967-985.

Cottam, Walter P. 1947. Is Utah Sahara bound? Bulletin of the University
of Utah 37(11):1-41.

Crider, Franklin J. 1955. Root-growth stoppage resulting from
defoliation of grass. Technical Bulleting No. 1102. USDA Soil
Conservation Service. 23p

D'Antonio, C. M. and P. M. Vitousek. 1992. Biological invasions by
exotic grasses, the grass/fire cycle, and global change. Annual Review
of Ecology and Systematics 23:63-87.

Danvir, Rick. Ca2003 (undated). Sage grouse ecology and management in
northern Utah sagebrush-steppe. Deseret Land and Livestock, Woodruff,
Utah.

Dodge, Marvin. 1972. Forest fuel accumulation -- a growing problem.
Science 177:139-142.

DOI. 1993. Riparian Area Management: Process for Assessing Proper
Functioning Condition. Department of Interior, BLM TR 1737-9.

DOI. 1994. Riparian Area Management: Process for Assessing Proper
Functioning Condition for Lentic Riparian-Wetland Areas. Department of
Interior, BLM TR 1737-11.

Donahue, Debra L. 1999. The western range revisited -- removing
livestock from public lands to conserve native biodiversity. University
of Oklahoma Press, Norman.

Duff, D. A. 1977. Livestock grazing impacts on aquatic habitat in Big
Creek, Utah. In: Proceedings of the Workshop on Livestock and
Wildlife-Fisheries Relationships in the Great Basin. University of
California Agric. Station, Sci. Spec. Publication 3301. Berkeley,
California.

Duff, Donald A. 1979. Riparian habitat recovery on Big Creek, Rich
County, Utah. In Proceedings: Forum -- Grazing and Riparian/Stream
Ecosystems. Trout Unlimited, Inc. 91 p.

Dyksterhuis, E. J. 1949. Condition and management of range land based on
quantitative ecology. Journal of Range Management 2:104-115.

Ecosystem Research Institute. 1984. 1983 Annual Report Ecosystem
Analysis. Report to White River Shale Oil Corporation, Salt Lake City,
Utah. 106p. Report available thru Western Watersheds Project Utah Office
at P.O. Box 280, Mendon, Utah 84325.

Eckert Jr., Richard E. and John S. Spencer. 1986. Vegetation response on
allotments grazed under rest-rotation management. Journal of Range
Management 39(2):166-174.

Eckert Jr., Richard E. and John S. Spencer. 1987. Growth and
reproduction of grasses heavily grazed under rest-rotation management.
Journal of Range Management 40(2):156-159

EPA. 1998b. The quality of our Nation's water: 1996 -- Executive Summary
of the National Water Quality Inventory: 1996 Report to Congress.
EPA841-S-97-001 Office of Water, U.S. Environmental Protection Agency,
Washington, D.C.

EPA. 1976. Quality criteria for water, July 1976. Fecal coliform
bacteria. U.S. Environmental Protection Agency, Washigton, D.C.: 42-50

Evanko, Anthony B. and Roald A. Peterson. 1955. Comparisons of protected
and grazed mountain rangelands in southwestern Arizona. Ecology
36(1):71-82.

Fleischner, Thomas L. 1994. Ecological costs of livestock grazing in
western North America. Conservation Biology 8(3):629-644.

GAO. 1988. Rangeland management: more emphasis needed on declining and
overstocked grazing allotments. U.S. General Accounting Office,
GAO/RCED-88-80, Washington, D.C.

GAO. 1991. Public land management: attention to wildlife is limited.
GAO/RCED-91-64

GAO. 1995. Animal waste I and water quality issues. Publication no.
GAO/RCED-95-200BR. 97pp. General Accounting Office, Washington, D.C.

Galt, Dee, Greg Mendez, Jerry Holechek and Jamus Joseph. 1999. Heavy
winter grazing reduces forage production: an observation. Rangelands
21(4):18-21

Galt, Dee, Francisco Molinar, Joe Navarro, Jamus Joseph and Jerry
Holechek. 2000. Grazing capacity and stocking rate. Rangelands
22(6):7-11.

Green, D. M. and J. B. Kauffman. 1995. Succession and livestock grazing
in a northeastern Oregon riparian ecosystem. Journal of Range Management
48:307-313.

Gregory, Stanley V., Frederick J. Swanson, W. Arthur McKee and Kenneth
W. Cummins. 1991. An ecosystem perspective of riparian zones. Bioscience
41(8): 540-550.

Hanley, T. H. and J. L. Page. 1981. Differential effects of livestock
use on habitat structure and rodent populations. California Fish and
Game 68:160-173.

Harper, K. T., R. Van Buren, and S. Kitchen. 1996. Invasion of alien
annuals and ecological consequences in salt desert shrublands of western
Utah. Pages 58 -65 in J. R. Barrow, E. Durant, R.E. Sosebee and R. J.
Tausch, editors. Proceedings: Shrubland ecosystem dynamics in a changing
environment. General Technical Report-338. U.S. Forest Service
Intermountain Research Station, Ogden, Utah.

Heady, H.F. and R. D. Child. 1994. Rangeland Ecology and Management.
Westview Press, San Francisco, California.

Hewitt, G.B. and J. A. Onsager. 1983. Control of grasshopper in
rangeland in the United States -- a perspective. J. Range Management.
36:202-207.

Hild, A.L., M.G. Karl, M.R. Heferkamp and R.K. Heitschmidt. 2001.
Drought and grazing III: root dynamics and germinable seed bank. Journal
of Range Management 54(3):292-298.

Hobbs, R. J. and L. F. Huenneke. 1992. Disturbance, diversity, and
invasion: implications for conservation. Conservation Biology 6:324-337.

Hockett, Glenn A. 2002. Livestock impacts on the herbaceous components
of sage grouse habitat: a review. Intermountain Journal of Sciences Vol
8(2):105-114.

Hoffman, L., and R.E. Ries. 1991. Relationship of soil and plant
characteristics to erosion and runoff on pasture and range. Journal of
Soil and Water Conservation, p. 143-147.

Holechek, Jerry L. 1996a. Financial returns and range condition on
southern New Mexico ranches. Rangelands 18(2):52-56

Holechek, Jerry L. 1996b. Drought and low cattle prices: hardship for
New Mexico ranchers. Rangelands 18(1):11-13.

Holechek, Jerry L. and Karl Hess, Jr. 1996c. Grazing lands: prices,
value, and the future. Rangelands 18(3):102-105

Holechek, Jerry L., Hilton de Souza Gomes, Francisco Molinar and Dee
Galt. 1998. Grazing intensity: critique and approach. Rangelands
20(5):15-18

Holechek, Jerry L., Hilton Gomez, Francisco Molinar and Dee Galt. 1999a.
Grazing studies: what we've learned. Rangelands 21(2):12-16

Holechek, Jerry L., Milton Thomas, Francisco Molinar and Dee Galt.
1999b. Stocking desert rangelands: what we've learned. Rangelands
21(6):8-12

Holechek, Jerry L., Hilton Gomez, Francisco Molinar, Dee Galt and Raul
Valdez. 2000. Short-duration grazing: The facts in 1999. Rangelands
22(1):18-22.

Holechek, Jerry L., Rex D. Pieper and Carlton H. Herbel. 2001.Range
Management: Principles and Practices, Fourth Edition. Prentice-Hall, New
Jersey. 587p

Hormay, A. L. and M. W. Talbot. 1961. Rest-rotation Grazing -- A New
Management System for Perennial Bunchgrass Ranges. USDA Forest Service
Production Research Report No. 51.

Howard, Gary L., Steven R. Johnson and Stanley L. Ponce. 1983. Cattle
grazing impact on surface water quality in a Colorado front range
stream. J. Soil and Water Conservation. March-April 1983:124-128.

Hubbard, R.K., D.L. Thomas, R.A. Leonard and J.L. Butler. 1987. Surface
runoff and shallow ground water quality as affected by center pivot
applied dairy cattle wastes. Trans. ASAE 30(2):430-437.

Hutchings, S.S. and G. Stewart. 1953. Increasing forage yields and sheep
production on Intermountain winter ranges. U.S. Department of
Agriculture Circular 925. 63p.

Ingham, R.E. and J. K. Detling. 1984. Plant-herbivore interaction in
North American mixed-grass prairie. III. Soil nematode populations and
root biomass onCynomus ludovicianus colonies and adjacent uncolonized
areas. Oecologia 63:307-313.

Jacobs, Lynn. 1991. Waste of the West.

Johansen, Jeffrey R. 1993. Cryptogamic crusts of semiarid and arid lands
of North America. Journal of Phycology 29:140-147.

Jones, Allison. 2000. Effects of cattle grazing on North American arid
ecosystems: a quantitative review. Western North American Naturalist
60(2):155-163.

Jones, Allison L and William S. Longland. 1999. Effects of cattle
grazing on salt desert rodent communities. The American Midland
Naturalist. 141(1):1-11.

Julander, Odell. 1962. Range management in relation to mule deer habitat
and herd productivity in Utah. Journal of Range Management
15(5):278-281.

Kauffman, J. Boone and W.C. Kreuger. 1984. Livestock impacts on riparian
ecosystems and streamside management implications -- a review. Journal
of Range I 37(5): 430 -- 437.

Kauffman, J. Boone, Andrea S. Thorpe, and E. N. Jack Brookshire. 2004.
Livestock exclusion and belowground ecosystem responses in riparian
meadows of eastern Oregon. Ecological Applications 14(6):1671-1679.

Kay, Charles E. and Dale L. Bartos. 2000. Ungulate herbivory on Utah
aspen: assessment of long-term exclosures. Journal of Range Management
53(2):145-153.

Kay, Charles E. 2001. The condition and trend of aspen communities on
BLM administered lands in central Nevada -- with recommendations for
management. Final Report to Battle Mountain Field Office, Bureau of Land
Management.

Kie, John G. 1996. The effects of cattle grazing on optimal foraging in
mule deer (Odocoileus hemionus). Forest Ecology and Management
88:131-138.

Kleiner, Edgar F. and K. T. Harper. 1972. Environment and community
organization in grasslands of Canyonlands National Park. Ecology
53(2):299-309.

Knick, Steven T., David S. Dobkin, John T. Rotenberry, Michael A.
Shroeder, W. Matthew Vander Haegen and Charles Van Riper III. 2003.
Teetering on the edge or too late? Conservation and research issues for
avifauna of sagebrush habitats. The Condor 105:611-634.

Knopf, Fritz L., James A. Sedgwick and Richard W. Cannon. 1988. Guild
structure of a riparian avifauna relative to seasonal cattle grazing.
Journal of Wildlife Management 52(2):280-290.

Kreuger, William C. and A. H. Winward. 1974. Influence of cattle and
big-game grazing on understory structure of a Douglas-fir Ponderosa
Pine- Kentucky bluegrass community. Journal of Range Management
27(6):450-453.

Kreuper, David, Jonathan Bart and Terrell D. Rich. 2003. Response of
vegetation and breeding birds to the removal of cattle on the San Pedro
River, Arizona (USA). Conservation Biology 17(2):607-615.

Lacey, J. R. 1987. The influence of livestock grazing on weed
establishment and spread. Proceedings: Montana Academy of Science
47:131-146.

Lile, David F., Kenneth W. Tate, Donald L. Lancaster and Betsy M. Karle.
2003. Stubble height standards for Sierra Nevada meadows can be
difficult to meet. California Agriculture, 57(2):60-64.

Loft, Eric R., John W. Menke and John G. Kie. 1991. Habitat shifts by
mule deer: the influence of cattle grazing. Journal of Wildlife
Management. 55(1):16-26.

Loope, Walter L., and Neil E. West. 1979. Vegetation in relation to
environments of Canyonlands National Park. In: R. M. Linn (ed.)
Proceedings of he First Conference on Scientific Research in the
National Parks. Vol. 1. U.S. Dept. of Interior, NPS Trans. And Proc.
Series No. 5.

Lusby, Gregg C. 1979. Effects of grazing on runoff and sediment yield
from desert rangeland at Badger Wash in western Colorado, 1953-73. U.S.
Geological Survey Water Supply Paper 1532-1.

Lusby, Gregg C. 1970. Hydrologic and biologic effects of grazing vs.
non-grazing near Grand Junction, Colorado. Journal of Range Management
23(4):256-260.

Mack, R. N. 1981. Invasion of Bromus tectorum L. into western North
America: An ecological chronicle. Agro-ecosystems 7:145-165.

Mack, R. N. and J. N. Thompson. 1982. Evolution in steppe with few
large, hooved mammals. American Naturalist 119:757-773.

Madany, Michael H. and Neil E. West. 1983. Livestock grazing -- fire
regime interactions within montane forests of Zion National Park, Utah.
Ecology 64(4):661-667.

Marble, James R. and Kimball T. Harper. 1989. Effect of timing of
grazing on soil surface cryptogamic communities in a great basin low
shrub desert: a preliminary report. Great Basin Naturalist
49(1):104-107.

Marcuson, Patrick E. 1977. Overgrazed streambanks depress fishery
production in Rock Creek, Montana. Fish and Game Federation Aid Program.
F-20-R-21-11a.

Martin, John H. Jr. 1997. The Clean Water Act and animal agriculture. J.
Environmental Quality 26:1198-1203.

Mattise, Samuel N. 1995. Sage grouse in Idaho: Forum '94. Idaho BLM
Technical Bulletin 95-15. 10p.

Maxfield, Brian D. and Dean L. Mitchell. 2001. Sage grouse in Utah. Utah
Division of Wildlife Resources. 10p.

McKee, T.B., N.J. Doesken, and J. Kleist, 1993.  The relationship of
drought frequency and duration ot time scales.  Eighth Conference on
Applied Climatology, American Meteorological Society, Jan 17-23, 1993,
Anaheim CA, pp. 179-186.

McLean, A. and E.W. Tisdale. 1972. Recovery rate of depleted range sites
under protection from grazing. Journal of Range Management 25:178-184.

Medin, D. E., and W. P. Clary. 1990. Small mammal populations in a
grazed and ungrazed riparian habitat in Nevada. Research Paper INT-413.
U.S. Forest Service, Intermountain Research Station, Ogden, Utah.

Medin, Dean E., Bruce L. Welch and Warren P. Clary. 2000. Bird habitat
relationships along a Great Basin elevational gradient. USDA Forest
Service Rocky Mountain Research Station Research Paper RMRS-RP-23. 22p.

Miller, Richard F. and Lee L. Eddleman. 2000. Spatial and Temporal
Changes of Sage Grouse Habitat in the Sagebrush Biome. Oregon State
University Agricultural Experiment Station Technical Bulletin 151. 35p.

Mispagel, M.E. 1978.  The ecology and bioenergetics of the acridid
grasshopper, *Bootettix punctatus* on creosotebush, *Larrea
40uality40te*, in the northern Mojave Desert.  Ecology 59(4):779-788.

Moore, Elbert, Eric Janes, Floyd Kinsinger, Kenneth Pitney and John
Sainsbury. 1979. Livestock grazing management and water quality
protection. U.S. Environmental Protection Agency and the Bureau of Land
Management.

Mueggler, W.F. 1975. Rate and pattern of vigor recovery in Idaho fescue
and Bluebunch wheatgrass. Journal of Range Management 28(3):198-204.

National Research Council. 2002. Riparian Areas: Functions and
Strategies for Management, National Research Council, Committee on
Riparian Zone Functioning and Strategies for Management, Water Science
and Technology Board, Board on Environmental Studies and Toxicology
(National Academy Press, 2002).

Nerny, J. J. and A.J. Hamilton. 1969. Effects of rainfall on range
forage and populations of grasshoppers. San Carlo Apache Indian
Reservation. Arizona J. Econ. Entomol. 62:329-333.

NRCS. 2002. National Range and Pasture Handbook.

NWF. 1997. Comb Wash decision, National Wildlife Federation v. Bureau of
Land Management, 140 IBLA 85 (Aug. 21, 1997)

Orr, Howard K. 1975. Recovery from soil compaction on bluegrass range in
the Black Hills. Transactions of the ASAE 1076-1081.

Owens, L.B., W.M. Edwards and R.W. Van Keuren. 1996. Sediment losses
from a pastured watershed before and after stream fencing. Journal of
Soil and Water Conservation 51(1):90-94.

Packer, Paul. 1998. Requirements for watershed protection on western
mountain rangelands. Unpublished manuscript. Dr. Packer is retired from
the USDA Intermountain Forest and Range Experiment Station, Logan, Utah.

Paige, Christine and Sharon A. Ritter. 1999. Managing sagebrush habitats
for bird communities. Partners in Flight, Western Working Group, Boise,
Idaho.

Parrish, Jimmie R., Frank Howe and Russell Norvell. 2002. Utah Partners
in Flight Avian Conservation Strategy Version 2.0. Utah Division of
Wildlife Publication No. 02-27. 305p.

Pearce, Richard. 1988. Where deer and cattle roam. USDA Forest Service
Pacific Southwest Research Station.

Pell, Alice N. 1997. Manure and microbes: public and animal health
problem? J. Dairy Sci. 80:2673-2681.

Peterjohn, W.T. and D. L. Correll. 1984. Nutrient dynamics in an
agricultural watershed: observations of a riparian forest. Ecology 65:
1466-1475

Platts, W. S. 1991. Livestock Grazing. *In: Influence of Forest and
Rangeland Management on Salmonid Fishes and Their Habitats.* American
Fisheries Society Special Publication 19:389-423.

Ratliff, Joe and Charles Keeports. 2000. Surface water analysis and
management recommendations for the Carico Lake Allotment. U.S. Dept. of
Interior Bureau of Land Management, Battle Mountain Field Office,
Nevada.

Ray, D.E., A.M. Lane, C.B. Roubicek, and R.W. Rice. 2004. Range beef
herd growth statistics. In: Arizona Rancher's Management Guide. Arizona
Cooperative Extension, College of Agriculture, University of Arizona.

Rich, Terrell. 1985. Sage grouse population fluctuations: evidence for a
10-year cycle. Idaho BLM Technical Bulletin 85-1. 20p.

Rich, Terrell D. 2002. Using breeding land birds in the assessment of
western riparian systems. Wildlife Society Bulletin 30(4):1128-1139.

Rosenzweig, M. L. and J. Winakur. 1969. Population ecology of desert
rodent communities: habitats and environmental complexity. Ecology
50:558-572.

Rummell, Robert S. 1951. Some effects of livestock grazing on Ponderosa
pine forest and range in central Washington. Ecology 32(4):594-607.

Saxon, Keith E., Lloyd F. Elliott, Robert I. Papendick, Michael D.
Jawson and David H. Fortier. 1983. Effect of animal grazing on water
41uality of non-point runoff in the Pacific Northwest. Project Summary,
Robert S. Kerr Environmental Research Laboratory, Ada, Oklahoma.
EPA-600/S2-83-071. 7p.

Schepers, J.S., B.L. Hackes and D.D. Francis. 1982. Chemical water
quality of runoff from grazing land in Nebraska: II. Contributing
factors. J.Environ. Qual., Vol 11(3):355-359.

Schulz, Terri T and Wayne C. Leininger. 1990. Differences in riparian
vegetation structure between grazed areas and exclosures. Journal of
Range Management 43(4):295-299.

Scott, J.A., N.R. French, and J.W. Leetham. 1979. Patterns in
consumption in grasslands, p 80-105. In N.R. French (ed.) Perspectives
in grassland ecology. Springer-Verlag, New York.

Schwan, H.E., Donald J. Hodges and Clayton N. Weaver. 1949. Influence of
grazing and mulch on forage growth. Journal of Range Management
2(3):142-148.

Sharp, Lee A., Ken Sanders and Neil Rimbey. 1992. Variability of crested
wheatgrass production over 35 years. Rangelands 14(3):153-168

Society for Range Management. 1974. A Glossary of Terms Used in Range
Management.

Souder, Jon A. ca1997. How Does Livestock Grazing Fit Into the Larger
Societal Uses of Wildlands? Methods for Determining Benefits and Their
Application to the Kaibab Plateau. College of Ecosystem Science and
Management, Northern Arizona University.

Stevens, Lawrence E., Peter Stacey, Don Duff, Chad Gourley and James C.
Catlin. 2002. Riparian ecosystem evaluation: a review and test of BLM's
proper functioning condition assessment guidelines.

Stewart, Kelley M., R. Terry Bowyer, John G. Kie, Norman J. Cimon, and
Bruce K. Johnson. 2002. Temprospatial distributions of elk, mule deer,
and cattle: resource partitioning and competitive displacement. Journal
of Mammalogy. 83(1):229-244.

Taylor, Daniel M. 1986. Effects of cattle grazing on passerine birds
nesting in riparian habitat. Journal of Range Management 39(3):254-258.

Thelin, Richard and Gerald F. Gifford. 1983. Fecal coliform release
patterns from fecal material of cattle. Journal of Environmenatl Quality
12(1):57-63.

Tiedemeann, A.R., D.A. Higgins, T.M. Quigley, H.R. Sanderson and D.B.
Marx. Responses of fecal coliform in streamwater to four grazing
strategies. Journal of Range Management 40(4):322-329.

Trimble, Stanley W. and Alexandra C. Mendel. 1995. The cow as a
geomorphic agent -- a critical review. Geomorphology 13:233-253.

USDA. 1969. Range Environmental Analysis Handbook Intermountain Region
FSH 2209.21.

UDWR. 1997. Conservation Agreement and Strategy for Bonneville Cutthroat
Trout in Utah. Utah Division of Wildlife Resources Publication 97-19.

USDA. 1981. America's soil and water: condition and trends. U.S.
Department of Agriculture Soil Conservation Service, Washington, D.C.
33p.

USDA. 1982. Soil Survey of Rich County Utah. USDA Soil Conservation
Service, Forest Service and Bureau of Land Management.

USDA. 1992. Integrated riparian evaluation guide. U.S. Department of
Agriculture, Region IV Forest Service, Ogden, Utah.

USDA. 1993. Monitoring data from the North Rich allotment, Logan Ranger
District, Wasatch-Cache National Forest.

USDA. 1996. Intermountain Regional Assessment: Properly Functioning
Condition. USDA Forest Service, Region IV, Ogden, Utah.

USDA. 1997. R1/R4 (Northern/Intermountain Regions) Fish and Fish Habitat
Standard Inventory Procedures Handbook. USDA Forest Service General
Technical Report INT-GTR-346.

USDA. 1998. Draft Sub-regional Assessment of Properly Functioning
Condition for Areas Encompassing the National Forests of Northern Utah.
USDA Forest Service, Region IV, Ogden, Utah.

USDA. 2001. Process Paper I: rangeland capability and suitability for
sheep and cattle ranges. Caribou National Forest.

USDA. 2002. Final Environmental Impact Statement for the Curlew National
Grassland. Caribou National Forest.

U.S. Department of Interior, U.S. Fish and Wildlife Service, U.S.
Department of Commerce and U. S. Census Bureau. 2002. 2001 National
Survey of Fishing, Hunting and Wildlife-Watching Associated Recreation.
170 p.

USDOI. 1979. Randolph Planning Unit Grazing Management Environmental
Impact Statement. Bureau of Land Management.

VanHaveren, Bruce P., Eric B. Janes and William L. Jackson. 1985.
Nonpoint pollution control on public lands. Journal of Soil and Water
Conservation p.92-94.

Van Poollen, H.W. and J. R. Lacey. 1979. Herbage response to grazing
systems and stocking intensities. Journal of Range Management
32:250-253.

Walker, Larry. 2002. Impact of grazing on 153 species of southwestern
birds. <http://rangenet.org/directory/walker/swbirds.html> .

Wambolt, C.L., K.S. Walhof and M.R. Frisina. 2001. Recovery of big
sagebrush communities after burning in south-western Montana. Journal of
Environmental Management 61:243-252.

Weigert, R.G. and C.E. Petersen. 1983. Energy transfer in insects. Ann.
Rev. Entomol. 28:455-486.

Welch, Bruce L. and Craig Criddle. 2003. Countering Misinformation
Concerning Big Sagebrush. USDA Forest Service Rocky Mountain Research
Station. Research Paper RMRS-GTR-40. 28p.

Welch, Bruce L.   2005.  Big sagebrush:  A sea fragmented into lakes,
puddles, and ponds.  Gen. Tech. Rep. RMRS-GTR-144. Fort Collins, CO: 
U.S. Department of Agriculture, Forest Service, Rocky Mountain Research
Station: 210p.  Data on file at the Shrub Sciences Laboratory, 735 N 
500 E, Provo, Utah 84606.

Welch, Bruce L. and Craig Criddle. 2003. Countering misinformation
concerning big sagebrush. Forest Service Rocky Mountain Research Station
Research Paper RMRS-RP-40.

Welch, Bruce L., Fred J. Wagstaff and Richard L. Williams. 1990. Sage
grouse status and recovery plan for Strawberry Valley, Utah. USDA Forest
Service Intermountain Research Station Research Paper INT-430. 10p.

West, Neil E. 1981. Nutrient cycling in desert ecosystems. In: Arid Land
Ecosystems: Structure, Functioning and Management, Volume 2. Cambridge
University Press.

West, Neil E. 1983. Western Intermountain Sagebrush Steppe. In Temperate
Deserts and Semi-deserts, edited by N. E. West. Elsevier Scientific
Publishing, Amsterdam. P351-373.

White, Clifford A., Charles E. Olmstead and Charles E. Kay. 1998. Aspen,
elk and fire in the Rocky Mountain national parks of North America.
Wildlife Society Bulletin 26(3):449-462.

White, Richard K., Robert W. VanKeuren, Lloyd B. Owens, William M.
Edwards and Roberty H. Miller. 1983. Effects of livestock pasturing on
non-point surface runoff. Project Summary, Robert S. Kerr Environmental
Research Laboratory, Ada, Oklahoma. EPA-600/S2-83-011. 6p.

White River Shale Oil Corporation. 1984. Progress Report Environmental
Programs 1983. White River Shale Oil Corporation, Salt Lake City, Utah.
785p. Report available thru Western Watersheds Project Utah Office at
P.O. Box 280, Mendon, Utah 84325

Winward, Alma. 2000. Monitoring the Vegetation Resources in Riparian
Areas. USDA Forest Service General Technical Report RMRS-GTR-47

Winder, J.A., C.C. Bailey, M.G. Thomas and J.L. Holechek. 2000. Breed
and stocking rate effects on Chihuahuan Desert cattle production.
Journal of Range Management 53(1):32-38.

Woodyard, John, Melissa Renfro, Bruce L. Welch and Kristina Heister.
2003. A 20-year recount of bird populations along a Great Basin
elevational gradient. USDA Forest Service Rocky Mountain Research
Station Research Paper RMRS-RP-43.

Wuerthner, George and Mollie Matteson. 2002. Welfare ranching: the
subsidized destruction of the west. Island Press.

Zimmerman, G. Thomas and L.F. Neuenschwander. 1984. Livestock grazing
influences on community structure, fire intensity, and fire frequency
within the Douglas-fir/ninebark habitat type. Journal of Range
Management 37)2):104-110.

[^1]: John G. Carter. 2003. Western Watersheds Project Report to Glen
    Carpenter, BLM Salt Lake Field Office dated November 9, 2003.

[^2]: John G. Carter. 2004. Western Watersheds Project Report to Glen
    Carpenter, BLM Salt Lake Field Office dated June 21, 2004.

[^3]: Proposed Revisions to Grazing Regulations for the Public Lands,
    Draft Environmental Impact Statement DES 03-62, dated December, 2003
    and Proposed regulations 43 CFR 4100 described in Federal Register
    Volume 68, No. 235 released on December 8, 2003/Proposed Rule.

[^4]: <http://www.wrcc.dri.edu/index.html>

[^5]: <http://rangenet.org/directory/jonesa/sulrprec/index.html>

[^6]: <http://agecon.uwyo.edu/RiskMgt/marketrisk/TheCattleCycle.pdf>

[^7]: <http://www.ams.usda.gov/mnreports/SJ_LS712.txt>

[^8]: <http://www.usda.gov/nass/pubs/agr05/acro05.htm>

[^9]: <http://www.ag.ndsu.nodak.edu/aginfo/lsmkt/monitor.htm>

[^10]: Email correspondence with Dr. Olson dated 8/18/05.

[^11]: <http://www.wildlifeprairiestatepark.org/animalpages/domestic_sheep.htm>

[^12]: <http://www.usda.gov/nass/pubs/agr04/04_ch7.pdf>

[^13]: Western Watersheds Project. 2001. Protest Environmental
    Assessments (EA) UT-020-00-12, UT-020-01-37 and UT-020-01-38,
    Findings of No Significant Impact, Standards and Guidelines
    Assessments and Proposed Decisions for New Canyon, Woodruff
    Pastures, Big Creek, Cutoff Canyon, Stuart, Eastman, Middle Ridge,
    Deseret, Meachum Canyon, South Woodruff, Sage Creek, Duck Creek,
    Rabbit Creek, Dry Basin and Bear Lake Allotments. Dated July 4,
    2001.

[^14]: USDA. 1964. R4 Range Environmental Handbook. FSH 2209.21.

[^15]: <http://www.westernwatersheds.org/reports/grazeWQ_JCarter/WQWWP.doc>