May 12, 2005


The Honorable Chris Cannon
2436 RHOB
Washington, D.C. 20515

Dear Mr. Cannon:

We are asking for your help to get the General Accounting Office to withdraw, correct and reissue their seriously flawed review of federal grazing policy on arid and semi-arid rangelands. This report, “BLM's Hot Desert Grazing Program Merits Reconsideration” (RCED-92-12, November 26, 1991), is frequently cited by opponents of grazing on these kinds of public lands. It is frequently included in media reporting, is used by anti-grazing bureaucrats to justify their opposition to grazing and even negatively influences legal proceedings related to public lands grazing. .

In this report, the GAO suggested that federal policy that currently permits grazing on arid and semi-arid public rangelands should be changed to eliminate this use. These recommendations have been substantially implemented in many federal jurisdictions without real justification. It is becoming increasingly clear that this report is based on incomplete review of the science and faulty analysis and interpretation of the results of scientific studies.

Many prominent range scientists and grazing experts widely consider this study to have been politically motivated and scientifically indefensible at the time it was issued. In the succeeding thirteen years, the accumulation of evidence that it is scientifically incorrect has become overwhelming. Yet, this flawed report continues to inappropriately and negatively influence federal rangeland policy and administration.

We are including several documents that will help you understand why we think that this study must be withdrawn, corrected and reissued. In summary, however, these are the major problems we have identified:

• Its conclusions could not be supported scientifically even in 1991. More recent scientific findings have further eroded its findings and assertions. For example, the GAO authors failed to interview top federal and university scientists who


would have presented more balanced and factual perspectives. They also ignored
long-term (100+ years of data) findings at places such as Jornada and Santa Rita Experimental Ranges and elsewhere which document negative long-term outcomes from livestock removal in hot deserts. These outcomes are ecologically undesirable, injurious to native herbaceous and animal biodiversity and destabilizing of watersheds and living communities.

• These negative impacts extend to other federal resource management objectives, such as pre-suppression wildfire activities, controlling noxious weeds and recovering endangered species. Looking at endangered species impacts, not only are endangered species recovery plans often hijacked by anti-grazing activists to achieve their purposes, but the justification this GAO report appears to give anti-grazing federal bureaucrats frequently results in policies that actually harm efforts to recover these species. For example, the unjustifiable removal of cattle has resulted in habitats that favor the predatory non-native fish which prey on endangered fish species. It has also allowed federal agencies to justify ignoring the spectacular successes of endangered bird species recovery on grazed private ranch land adjacent to public lands where grazing has been reduced or eliminated.

• The report is based on disproved plant succession assumptions which were outdated even in 1991

• The authors failed to consider other valuable ecosystem services performed by managed livestock grazing.

• The authors also failed to consider damage to unique rural cultures associated with livestock stewardship. They presented only economic analysis lacking in context. Agriculture represents a small part of total economic activity in almost all states in the U.S. but this does not mean that agricultural activity is unimportant to the country. Locally and culturally, raising livestock has tremendous importance in many hot desert areas.


The enclosed material presents some additional background on these points. One is a comprehensive, peer reviewed survey of the scientific literature on grazing, “Controlled Grazing Versus Grazing Exclusion Impact on Rangeland Ecosystems: What We Have Learned” done by New Mexico State University Range Professor Dr. Jerry Holechek. He concludes “there is scientific evidence that controlled grazing can play an important role in managing, maintaining and improving rangelands in arid and semi-arid regions for a variety of uses and ecosystem services…Claims that managed, information based livestock grazing is unsustainable in arid and semi-arid areas are refuted.”

We are also enclosing two articles from Range Magazine written by Steve Rich, President of the Rangeland Restoration Academy and the Manager of our Ranching and Rangeland Revitalization Project. One, “Ranching is For the Birds,” explains how managed ranchland benefits a wide range of bird species, including endangered species.
The other, “Special Report: Refuting the Myths” exposes the anti-livestock bias in the federal management agencies.

These are just a few of the hundreds of studies and research reports that demonstrate conclusively that this GAO report is fatally flawed. We would be happy to provide you with additional material if you need them.

We stand ready to help you and the Western Caucus in whatever way we can to get the GAO report withdrawn, corrected and reissued. A scientifically accurate GAO report could bring much needed balance to the policy debate over federal grazing policy. Until this report is corrected, however, it will continue to skew the debate in a direction that is clearly refuted by range science. That clearly does not serve the public interest.


Sincerely,


Mark O. Walsh
Executive Director

Enclosures