serve foremost to drive a wedge between the wildlife conservation and public land livestock communities. Since these two groups depend on one another of necessity, we find that unacceptable. The finding in S. 852 that “maintaining the economic viability of the western livestock industry is essential to maintaining open space and habitat for big game, wildlife and fish. . ." we heartily endorse. The more private ranching operations that remain intact the better, in our view. Wildlife and outdoor recreation would he hurt by their loss. Consequently, it has been the position of the Wildlife Management Institute for decades that the public land livestock industry, wildlife conservationists and wildlife users should be partners rather than antagonists. We also are supportive of permittees having assurance of long tenure on their allotments, provided that they comply with management provisions needed to restore and maintain rangelands. Unfortunately, there have been and are what we view as extremists in both camps who seem always to prefer confrontation rather than seeking common ground upon which all interests benefit. What S. 825 does is charge the atmosphere for these radicals to make more irrelevant calls to throw ranchers off public land or disenfranchise wildlife and wildlife conservationists. The concern is that if our relatively small camps continue to feud, the majority in this country will kick both of us off public land. If livestock grazing can be eliminated from public rangeland, so can hunting and fishing. Mr. Chairman, we must oppose, as called for in S. 852, that livestock grazing become the dominant use of our rangelands, that sportsmen and conservationists be cut out of the decision-making process, that taxpayers be squeezed to pay for unneeded advisory groups, that public land ranchers be above conservation laws, that livestock get all available public rangeland forage and wildlife get nothing, that managers cannot reduce livestock numbers anywhere to protect public resources, that ranchers cannot voluntarily reduce allotment use for conservation purposes, that scientific methods cannot be used to determine if permittees are in compliance with the rules, that national grasslands revert to primarily agricultural use and be subjected to give-a-way or other disposal, that water developments now available to wildlife be fenced off for livestock use only, and so forth. Our opposition is based as much in the economic detriment that S. 852 would impose on the outdoor recreation industry as with the apparent disregard for public participation in and use of land-management decisions and public resources. The Institute was organized by the sporting arms and ammunition industry 84 years ago. We have been funded by that industry since that time with the sole purpose of restoring and improving the management of wildlife resources in North America. More than 80 percent of our industry's business depends on healthy wildlife populations. Federal public land is especially important, providing 80 percent of the habitat for such species as elk and bighorn sheep. Our industry's 20,000 employees and $600 million payroll have a major economic interest in how wildlife is treated on public land. Considerable research in recent years into the economics of fish and wildlife and their use supports our long-held contention that these resources are among this nation's most valuable assets. Fishing in America generates $19.7 billion in personal earnings, $963.8 million in federal income tax, $398.2 million in state income tax, and $1.3 billion in state sales tax annually. Hunting has a total economic impact of $34 billion annually in the U.S., which exceeds the sales of such companies as Coca Cola, Caterpillar and RJR-Nabisco. For every 50 hunters in the U.S., enough economic activity is generated to create one job, which works out to 380,000 jobs nationwide. Add to the sportfishing and sporthunting dollars the economic activity generated by nonhunting recreational uses and commercial uses, far more than one million jobs are dependent on how well governments manage basic resources in the public trust. Federal public lands account for a large part of this economic engine. Rather than pursuing enactment of S. 852 and forcing the outdoor recreation industry, conservationists, sportsmen and the general public to battle public land livestock grazers, we urge that the Committee institutionalize in legislation a range management program that is supported by all public land interest groups and has proven itself over a number of years. The program is called "Seeking Common Ground." It originated from a symposium held several years ago on solving livestock/big game conflicts on federal land. Following that symposium, the U.S. Forest Service, Bureau of Land Management, state wildlife agencies, livestock groups, wildlife conservation groups, sportsmen's organizations and the National Fish and Wildlife Foundation developed a partnership whereby range management problems were addressed at the local level by all interest groups and the needed work funded by all concerned. The program has been nothing short of spectacularly successful. A brochure describing that program is attached. Mr. Chairman, the public land livestock industry and wildlife conservation interests must work together. Neither of us are going away and near radical proposals such as S. 825 do nothing but threaten both our places on rangeland. We respectfully urge the Committee to steer clear of legislation that would divide us and move toward mutually beneficial programs such as Seeking Common Ground that would unite us. We would be most pleased to work cooperatively with the Committee and other interest groups to legislatively implement the Seeking Common Ground approach on all public rangelands. Thanks so much for hearing our views. STATEMENT OF FRED C. BRYANT, PRESIDENT, SOCIETY FOR Range ManagemENT PREAMBLE CONCERNS It is the belief of over 5,000 members of the Society for Range Management that any "Act" or "Reform" set forth by Congress to manage public rangelands must first and foremost encourage, foster, and promote proper stewardship of all rangeland amenities and resources including forage, wildlife habitat, watersheds, and open space. Relative to the Livestock Grazing Act (LGA), there is an obvious lack of emphasis on resource conservation and good stewardship. Thus, in its present form, this important aspect is largely assumed or ignored. In our view, the overarching goal of the Livestock Grazing Act should, in each and every section, be explicit in directing a program which achieves sustainable rangeland ecoystems and improves the condition and health of these lands. GENERAL RECOMMENDATIONS 1. The LGA, if adopted by Congress, should definitely broaden its scope to include both the U.S. Forest Service and the Bureau of Land Management. All federal agencies charged with responsibility to oversee public lands for numerous uses must (1) agree to and utilize state-of-the-art science and technology and (2) utilize the same assessment and monitoring procedures. 2. Management Plans should be targeted at a Desired Plant Community (the plant community, of several plant communities that may occupy a site, that has been identified through a management plan to best meet the plans objective for the site) for each range site within an AMP. 3. Rangeland Assessment and Monitoring must be conducted in a manner that is scientifically based and statistically verifiable. The ultimate goal should be to assess and monitor trend toward the Desired Plant Community. Trend must be determined by actual measurements or monitoring rather than checklists or rapid assessments. 4. Rules and policies regarding Rangeland Betterment or Improvement Funds were omitted. LGA, if adopted, must direct portions of the annual grazing fee receipts to be used for on-the-ground improvements. These funds so allocated should not be directed toward agency salaries, overhead, or administration or other activities unrelated to rangeland improvements. 5. Temporary non-use for range improvement purposes was omitted. This or a similar provision should be included in the LGA. 6. A statement of fundamentals of rangeland condition and health must be included. This statement should address forage production, watershed function, ecological processes, wildlife habitat, and water quality. Furthermore, standards must address progress toward improved or sustainable rangeland condition and health. 7. The LGA must not impede sound rangeland stewardship by discouraging local flexibility and adaptive and innovative management techniques. 8. This LGA seems to ignore_the_present societal attitudes towards rangelands and the many uses they have. The LGA also ignores the evolution of collaborative decision making. SRM recognizes these are important components of land-use planning. The Act should recognize the value of these concepts as a prelude to development of livestock grazing plans. SPECIFIC RECOMMENDATIONS: (SUGGESTED TO IMPROVE CLARITY OR ECOLOGICAL/ BIOLOGICAL INTEGRITY OF THE ACT) Page 1. Line 2. The statement “To provide for uniform . . . other purposes". This statement focuses on a single use of public lands de-emphasizing by other public uses and values. This statement should be broadened, along with the content of the bill to address other uses and values to society. Page 3. Section 101. Line 14. (1) Rangeland resources such as wildlife, watersheds, forage and browse, unique All other findings would be renumbered and remain as they currently are. Addi- Page 8. Section 103. (2) Line 8-11 • add wildlife habitat • delete "woody", because not all invasive plant species are "woody" (4) (proposed revision) performance of range assessment and monitoring be con- (5) delete "consideration of" and change to "enhancement of" wildlife populations Page 8. Section 104. General-for consistency, definitions (where terms are similar) should conform to (7) Animal Unit Month This definition is purely for billing purposes and should be stated and qualified Page 13. Line 13. Add: Desired Plant Community and its definition. "Desired Plant Community which Page 14. Line 25. Add: "Guidelines" definition. For example, there are general policy statements that Page 15. Line 4. (21) If the USFS is included, Forest Plans will also need to be referenced. Page 15. Line 18. (23) ⚫ delete the word maximum • Line 21 re-word as follows without inducing permanent damage to watershed function: vegetation vigor, Page 15. Line 23. (24) Replace with: Monitoring.-The term monitoring means orderly collection of data Page 17. Line 12. Add: Standard (Technical Standard) Specifications in the AMP that spell out specific Page 17. Line 15. Stubble height (or residue)—the height or amount of herbage remaining on the ground after grazing. When appropriate local standards have been developed, stubble height may be used in lieu of utilization. Page 18. Line 9. (33) Add: Trend must be determined by actual measurements or monitoring taken over time and not from checklists or rapid assessment techniques. Page 18. Line 12. (34) Change to: The term... percentage or proportion of the total years herbage production herbivores. Page 19. Line 14. Reword to read: These two should be separated into Standards (see definition) and Guidelines. Standards affect and are specific to the AMP, while Guidelines refer to actions or policies above the AMP level. Page 20. Line 16. (c) Comment: NEPA should be addressed at the area (BLM) or Ranger District (USFS) levels. NEPA assessments should not be required at the AMP level. Currently, NEPA is too time consuming and not effective in improving management. Page 21. Line 3. Sec: 107 Comment: It is ecologically inappropriate to freeze livestock levels at a previous date without regard to grazing capacities that may now differ. This is also true because local weather or climatic vagaries routinely affect grazing capacities. Further, increases in wild or feral ungulates since 1993 may influence current grazing capacities. Page 32. Line 1. (2) Reword: "When trend determined by monitoring over time shows. . . objectives. Reductions in active use should be based on trend data, backed, if appropriate, by utilization or stubble height studies and data. Page 33. Line 6. (B). Comment: Because of drought, reductions may need to move faster than over a 5-year period. This approach also would delay resolving resource problems to five years. A rapid appeal: resolution process should be developed. Page 33. Line 14. (c). Add: If adequate and acceptable/measured trend data are properly. . . paragraph. Add: Objectives; and meet objectives to achieve the Desired Plant Community. Practices or improvements could include: fencing, brush or weed control, water development, salting, riding or herding, deferred grazing, vacating portions (temporary) of the allotment, others. Page 37. Line 24. This agreement should document expected value of the proposed improvement to wildlife and wildlife habitat, as well as other uses of the land. Page 39. Line. 20. Add: This application should specify the projected value to wildlife and wildlife habitat. Add: Carrying capacity must be determined by standard, scientific techniques taking into account wild or feral ungulates when appropriate. Page 50. Line 7. Question: Does this conflict with state law? Page 52. Line 6. Reword: 114. Add: as determined through monitoring of range condition and trend. section Livestock carrying capacity must be determined by measured trend studies and must consider wild ungulate population levels in collaboration with state agencies. Carrying capacity should not be based solely on utilization or stubble height measurements. Page 78. Line 11. Add New Number (3). (3) Training-committees will receive training in rangeland management principles, ecological principles, and conflict resolution. Such training shall be administered by universities (land grant or non-land grant) or professional societies. We encourage the use of Coordinated Resource Management (developed by Society for Range Management) or other collaborative processes as an operating principle for advisory groups to be trained in and for their use. (4) Qualifications (Continue) Page 81. Line 7. Add a training statement for Resource Advisory Council as written above Comment: This seems redundant to have a third advisory group. This may create duplication and conflicts among advisory groups. Page 91. Sec. 201. It is not clear who will administer these lands. A new bureaucracy? The BLM? The NRCS? The state agencies? This section will not be palatable with the general public and many other groups and professional societies, unless strong rangeland conservation measures and stewardship programs are embodied in the administration of these lands. STATEMENT OF R. MAX PETERSON, EXECUTIVE VICE PRESIDENT, INTERNATIONAL ASSOCIATION OF FISH AND WILDLIFE AGENCIES The Association appreciates the opportunity to share with the Committee our perspectives on S. 852, the "Livestock Grazing Act". We believe some reform of the regulations governing grazing use of public lands administered by BLM is long overdue, and have provided comments throughout the process. However, while we believe that there are parts of S. 852 which may be helpful, we also find that several areas of the bill present serious problems both to long term management of important public lands and to the relative rights and responsibilities of grazing permittees and other equally valid users of these lands. In short, we believe that S. 852 sets back the management of our public rangelands several decades and changes the focus to single purpose use which is contrary to the multiple purpose mandate. This would simply not be responsible stewardship of our public lands for our citizens, for whom they are held in the public trust. We believe that considerable progress has been made in harmonizing different uses of public rangeland, while still maintaining the sustainability of the soil, water, plant and animal communities found thereon. Our concern is that this bill will polarize that effort and the many diverse users of rangelands by making grazing the apparent dominant use of public ranges and severely limiting managers' ability to make important and timely management decisions that are vital to long term multiple use of such lands. We believe that scenario is ultimately not beneficial to the interest of the livestock industry, rural communities or other uses of the public lands. The International Association of Fish and Wildlife Agencies, founded in 1902, is a quasi-governmental organization of public agencies charged with the protection and management of North America's fish and wildlife resources. The Association's governmental members include fish and wildlife agencies of the states, provinces, and federal governments of the U.S., Canada, and Mexico. All 50 states are members. The Association has been a key organization in promoting sound resource management and strengthening federal, state, and private cooperation in protecting and managing fish and wildlife and their habitats in the public interest. States have broad trustee responsibilities for the conservation of fish and wildlife resources within their borders, including on most Federal public lands. State fish and wildlife agencies share concurrent jurisdiction with the Federal government for migratory birds, anadromous fish and listed threatened and endangered species. Therefore, while the habitat on public grazing lands is managed by the BLM or |