Catron County Commission Comments on the Development of Regional Drought Guidelines

Judith Dyess, Rangeland Management Staff
USDA Forest Service
Southwestern Region
333 Broadway Blvd SE
Albuquerque, NM 87102

RE: Catron County Commission Comments on the Development of Regional Drought Guidelines

The Catron County Commission welcomes the opportunity to comment and express our objections to the development of Regional Drought Guidelines:
• The primary concern within drought periods is stocking rates and these tools for proper drought management are currently in place within the USFS (voluntary non-use, adaptive management).
• Drought management is necessary within the Southwestern region, but should be at the allotment level only, between the Range Conservationist and the Allotment Owner.
• When the Range Conservationist and the Allotment Owner fail to reach agreement there is always the Section 8 process or the involvement of a scientific third party.
• The key issues and goals of the USFS and the land user during a drought is the resource. Therefore, monitoring of the forage and watershed health is required before, during and after a dry period or drought. Because drought is difficult to predict, a continuous monitoring needs to be in place for proper management and drought preparation.
• Monitoring is the most important aspect in proper management during periods of drought and non-drought. This allows trend data and current vegetation data in developing the stocking rate for any given time period.
• The necessary resource data will allow the Range Conservationist and the Allotment Owner to make the proper management decisions at the individual allotment level.
• A major concern of a top-down guideline for management of drought conditions is the fact that decisions are dictated from indices or parameters that do not reflect what is on the ground.
• The one issue that the Region Office could address during periods of drought is the resource damage caused by wild ungulates.

The Catron County Commission is concerned with the continual loss of our agricultural tax base. Therefore, guidelines that make it easy to remove cattle and then difficult to restock erodes the stability of our community. Non-resource based decisions threaten; the health of the rangelands, the economic viability of the rancher, and ultimately the community stability.

Respectfully submitted,
/s/
Catron County Commission

Cc Congressman Steve Pearce, U.S. House of Representatives