Ventana Wilderness Alliance
NEPA & CEQA Comment Letters

Bruce Emmens, Monterey District Ranger
Los Padres National Forest
406 South Mildred
King City, CA 93930

August 23, 1999

RE: BUCKEYE GRAZING ALLOMENT: SCOPING COMMENTS

Dear Bruce:

Thank you for allowing the Ventana Wilderness Alliance this opportunity to comment on the Buckeye grazing allotment. For a variety of reasons including the presence of sensitive botanical areas, sensitive archaeological areas, recreational conflict, potential depredation and the fact that this allotment lies entirely within the Silver Peak Wilderness Area, we strongly request that cattle grazing not be re-established and that the allotment be permanently retired. If our request is not honored, then please include in the NEPA document prepared for this allotment:

• A specific desired future condition for the allotment that complies with all applicable laws and policies. Please include an explanation of how this desired future condition will be consistent with the final version of the Los Padres National Forest Land and Resource Management Plan that is currently in the process of revision;
• Grazing strategies capable of achieving the desired future condition within a specific timeframe ("moving toward" the desired future condition is an inadequate disclosure of current range condition);
• A comprehensive cost/benefit analysis including costs of resource degradation (e.g. any reductions in the quality and/or quantity of water flowing from a watershed), monitoring, improvement construction and maintenance, reduced carrying capacity for fish and wildlife, applicable administrative overhead, restoration projects, etc. The cost analysis shall also include disclosure of the costs of obtaining equivalent forage on private grazing lands;
• A staffing analysis comparing available staffing resources with monitoring, mitigation and enforcement workload for the allotment and disclosing the likelihood that monitoring, mitigation and enforcement commitments will be met;
• Maximum utilization levels and seasons of use that ensure that the phenological needs of grazed plants are met over extended periods;
• Seasons of use accommodating the social and physical needs of threatened, sensitive, and endangered species as well as management indicator species (examples of social and physical needs include fawn and fawn rearing seasons, nesting, winter and summer range, adequate habitat diversity, hiding and thermal cover, etc.); and
• Permit conditions consistent with LRMP standards and guidelines.

We have the following site-specific concerns about this allotment:

• The most recent permittee of this allotment stated at the Pacific Valley meeting on July 22, 1999, that he canceled and removed his cattle early after 12 calves had been killed by mountain lions. Knowing this fact, re-establishing cattle grazing could lead to a renewal of livestock depredation. The permittee could then request a depredation permit to kill mountain lions from California Department of Fish and Game (CDF&G). This cycle must not be allowed to begin, as it is certainly not in accord with Wilderness values. In the NEPA document being prepared for the Buckeye Allotment please describe and discuss this situation and the management practices you will use to minimize or eliminate depredation of livestock by mountain lions without killing them.
• Describe and discuss the potential for grazing-related impacts on the Southern Redwood Botanical Area (which lies entirely within the allotment boundary) and the Lion Den Springs Botanical Area (which is close to the boundary of the Buckeye Allotment).
• Describe and discuss the potential for conflict between cattle grazing on the Buckeye allotment and recreational use of the Buckeye Flat area. Please include detailed plans for mitigating this conflict by effectively excluding the cattle from the Buckeye Flat environs.
• Describe and discuss the potential for negative impacts and damage by grazing cattle to the archaeologically important Native American midden site located at Buckeye Flat.
• Consider the impacts of cattle on nearby residences and domestic water developments. Describe the methods and range improvements that will be used to minimize these conflicts.

While preparing the NEPA document for the Buckeye allotment, please:

• Consider the alternative of allotment retirement.
• Prepare and include orthophoto quads or maps for the area. (FSM 2212.11). On these maps please show Ecological Units and existing vegetation, structural and nonstructural improvements (both existing and proposed), seasonal and perennial water sources, and other features significant to management.
• Develop and include both Suitability and Capability Analyses for this allotment. The NFMA (36 CFR ß 219.20), the Forest Service Manual (FSM 2212.11) and the Range Analysis Handbook for Region 5 all require suitability analyses for livestock grazing.
• Describe any special circumstances involved in the approval or planning of this allotment regarding:
  • steep slopes
  • highly erosive soils
  • threatened or endangered species or their critical habitat
  • flood plains
  • domestic-supply watersheds
  • wilderness areas
  • roadless areas
  • Native American religious or cultural sites
  • archaeological sites
  • historic sites
• Consider the impacts of livestock grazing on the Silver Peak Wilderness Area. Essential elements of this analysis include the impacts of grazing on the natural integrity of the area as well as the effect of livestock on opportunities for solitude and high-quality recreational experiences. Please bear in mind that the Forest Service Handbook states that if a "substantial alteration" of a roadless area's primitive character is proposed an EIS must be prepared (1909.15 Section 20.6 WO Amendment 1909.15-92-1).
• Consult with the Monterey Bay National Marine Sanctuary as part of the due diligence to be completed prior to authorizing this grazing allotment. The marine environment is very sensitive to pollutants carried into the ocean from management practices allowed on land, and the watercourses draining the allotment flow directly into the sanctuary and pose potential impacts in terms of turbidity, siltation, pathogenic pollution etc. Please include in the NEPA document a synopsis of the consultation, including recommended mitigation measures.
• Discuss and describe any established hiking trails or areas within the allotment known for their camping, fishing, hunting, wildlife viewing, or other forms of recreation. Also, please discuss how these recreational opportunities will be impacted by the allotment, and detail what steps will be taken to mitigate these impacts.
• Reveal whether or not an archaeological survey has been completed within the analysis area and, if so, when the survey was conducted and what was found (we do not need to know the location of archaeological sites). We also request that historic and cultural sites be avoided at all costs and that methods of avoidance and mitigation be fully explained in the NEPA document prepared for this allotment. We also request that local Native American community members be contacted regarding this allotment in compliance with law and policy.
• Conduct a cumulative watershed effects (CWE) analysis for the watersheds in the allotment area and present this data in the NEPA document. Please also disclose the percent of equivalent roaded acres in the watershed, the threshold of concern, the natural suitability index, and how this allotment (combined with both past and anticipated future projects on both private and public land) will impact these key indices. Please also discuss the measures that will be taken to eliminate or reduce these effects.
• Describe the condition of the watersheds in the allotment area in terms of CWE, ownership patterns, land disturbance history, sensitive habitat, and other issues. In addition, please disclose when, and how many, surveys have been conducted in these watersheds and whether or not these field surveys suggested upgrading the risk of cumulative watershed effects in the affected watersheds. We also request that you consider the cumulative impacts of past, present, and future projects (including those on private land) within these watersheds and discuss ways to minimize or eliminate these impacts.
• Discuss and disclose all grazing-related impacts on water quality in the analysis area including sediment, increased nutrient loads, fecal contamination, the introduction of pathogenic (cryptosporidium, giardia, salmonella, shigella, and enteric viruses) and non-pathogenic (fecal coliform and enterococci) organisms that can contaminate drinking water and harm aquatic ecosystems. Also, please describe how the production of these pollutants can be eliminated or minimized within the allotment area.
• Describe the condition of aquatic communities in the affected watersheds and describe ways in which allotment-related impacts to fish and other aquatic life will be minimized or eliminated. Also, please describe the current state of the essential habitat elements within the allotment area's aquatic ecosystems, including the:
  • Level of coarse woody material (and potential for further recruitment of this material)
  • Pool-to-riffle ratio
  • Condition of hiding and resting cover (logs, overhanging banks, riparian vegetation, etc.)
  • Quality of the water in terms of turbidity, toxicity, temperature, dissolved oxygen and Ph.
  • Streambank stability
• Discuss how you will meet the USFS Region 5 Soil Quality Standards as part of this allotment and specifically describe:
  • How class three, four, and five down logs will be protected in the allotment area
  • How unstable slopes, highly erosive soils, poorly maintained culverts, and road maintenance problems in the analysis area will be identified and either protected or corrected
  • The erosion hazard rating in each area of the grazing allotment.
  • How grazing-induced erosion, compaction, and other problems will be corrected if they are already present, or prevented if they do not currently exist.
• Describe how this allotment fits into the landscape level strategy for the management and protection of biological diversity as per the National Forest Management Act (36 CFR, sec 219.27 [g]) and how the planning for this allotment relates to biological diversity maintenance concerns for the past, present, and future.
• Describe the potential impacts to the National Forest Management Indicator Species (MIS) and whether or not these impacts have been analyzed. Discuss how habitat for MIS may be impacted or improved by this allotment, and how the allotment will impact the prey base, breeding, foraging, and movement of sensitive species in the area. Please discuss the mitigation techniques you plan to use in order to ensure the safety of these species and their habitat.
• Cite the relevant habitat capability models for the MIS in this allotment and describe what other scientific information you have utilized in your analysis of effects on MIS.
• Describe how the California Department of Fish and Game's Deer Herd Management Plan will be implemented in the allotment area and in what ways, if any, the allotment is inconsistent with the management plan. Post-project foraging resources for deer, including square feet of basal area of oak and other forage species should be included, as well as the potential for improvements in these habitat values.
• Discuss the ratio of cover to forage, and include the potential pressure from livestock grazing (competition for foraging/fawning habitat, etc.) on the deer population in the area.
• Discuss any Federal, State, Region-5 Sensitive or California Native Plant Society listed rare plants within the analysis area and whether recent surveys have been made for these sensitive plants during the key period for botanical identification. Include whether or not the survey protocol has been met and what impacts you foresee to sensitive plants as a result of this allotment. Please also discuss what mitigation measures you will implement to protect sensitive plants.
• Describe the condition and trend of the key vegetation indicators and aquatic indicators on the proposed Buckeye allotment, what the Forest Service believes to be the baseline condition for these, and whether this baseline condition is the best estimate for the pre-settlement environment (we believe pre-settlement condition--not the degraded conditions of the last century or more--must be our baseline for judging the success or failure of grazing management).
• Describe the monitoring program being developed for this allotment, to include monitoring implementation, effectiveness, validation and documentation. Please include how this program will be funded, what criteria will be used to determine objectives, and how, when and where these criteria be measured. Also include what records will be kept, and what decision points are in place if objectives are not being met. Furthermore, please include the last five years of monitoring data and evaluation documentation conducted on this allotment.

Thank you for this opportunity to comment. Please mail us a copy of the draft NEPA document for this allotment so that we may offer further input.

Sincerely,

Steve Chambers
Jon Libby
Boon Hughey
Ventana Wilderness Alliance Grazing Committee Co-chairs