Kinnikinnick Chapter Of The Idaho Native Plant Society

February 20, 2004  

Director (630), Bureau of Land Management

Eastern States Office

7450 Boston Blvd.

Springfield , VA 22153

We (the Kinnikinnick Chapter of the Idaho Native Plant Society and our membership of over 100 concerned citizens) urge the BLM, in considering proposed changes to grazing rules, to give priority to its mandate to preserve the long-term sustainable use of the lands in its control and to maintain the current process of public input. 

We recognize grazing as an appropriate use for some of the public lands administered by the BLM; an important part of the economies of many western communities.  However, we are concerned that the changes to grazing regulations proposed by the BLM could have an adverse long-term impact on rangeland health and habitat.  To preserve the diverse species of native plants, many of them unique to these rangelands and some of them threatened or endangered from habitat loss, we encourage the BLM to retain current restrictions designed to balance grazing needs and the necessity to keep these lands and their native plants healthy. 

We urge the BLM to specifically reconsider several elements of these proposed rule changes: 

1. Retain 12 months as the time period for deciding on grazing-related actions needed to achieve rangeland health. The proposed 24 months could allow unwarranted habitat destruction.
2. Retain the current requirements for phasing in changes.  Taking 5 years to phase in needed changes over a 10% reduction in head of cattle will provide for a period of destruction so long and severe that the land may be unlikely to recover.
3. Retain the current standards for data required to trigger BLM remedial action. It appears wasteful of resources to require monitoring that BLM is not funded to provide. If you decide to require a greater level of data gathering, the permitee should be required to reimburse BLM for the associated costs, in advance.
4. BLM should retain full administrative control over any “improvements” on its land, not allowing permitees to acquire an “ownership” stake in such projects. By allowing permitees to acquire partial ownership, conflicts and expensive legal issues can arise. The BLM’s capabilities to administer its responsibilities may be diminished. And the public’s rights may be compromised.  The acquisition and maintenance of water rights should remain an option for the BLM. Water rights are a limited resource and the public agency may want to allocate them to uses other than grazing in the future; their value should be retained in the public trust.

We are especially concerned about the proposal to limit opportunities for public input into the BLM’s decisions regarding the administration of grazing permits and land use.  The public needs to retain the right to comment on specific grazing permits as they are renewed or proposed. As a public agency we believe the BLM’s activities should be open to the public for review and suggestion.  A healthy discourse from varied members of society is one of the cornerstones of democracy, a bedrock belief upon which our western lands were settled and have been administered.

Sincerely,

Molly O'Reilly

President

CC:          Senator Craig

                Senator Crapo