E.L. Painter 26 July 2010

Bitter Creek National Wildlife Refuge Independent Rangeland Review (M. George and N. McDougald, Final Draft – received 20 May 2010)

My suggested changes are in red in the accompanying Word version of the document.

My comments are below.

I have several working lists (shared with BCNWR and USFWS) for the plant taxa that have been documented or reported on Bitter Creek National Wildlife Refuge (BCNWR), that are available on 2 Excel files: Bitter Creek plant taxa (5 worksheets — taxa, vouchering status, rare taxa, vouchers (i.e., herbarium specimens), rare vouchers (i.e., herbarium specimens) Bitter Creek plants livestock worksheet: (grazing info all taxa) These working lists are updated every time I receive or find new information, so the December 2009 version that the authors included in Appendix B (unaccredited) is not the most current version. These working lists do not constitute a formal report to USFWS.

Scientific nomenclature on the lists follows 2nd edition Jepson Manual (Jepson Flora Project 2010), where available. When a treatment has not yet been posted for the 2nd edition, nomenclature follows the 1st edition (Hickman 1993). When another name has been used on previous lists or other sources, that name is given as synonymy.

Common names on the Bitter Creek plant taxa list were taken from the Common Names external link on the Jepson Interchange1, which can be found by searching by taxon.

Because the 1988 Corps of Engineers wetlands plant list is often used as part of wetland management planning, the wetland status as defined by that list was included on the Bitter Creek plant taxa list.

I did not have time or resources to do a comprehensive search for information on the relationships between livestock and the plant taxa documented or reported on BCNWR. However, I did compile information I found in readily available resources. On the Bitter Creek plants livestock worksheet, I included information on effects of livestock and grazing, forage quality and palatability, and toxicity and livestock hazards.

Data for ‘Bitter Creek plant taxa’ were compiled using the four surveys available (De Vries 2009, Werner 1997, Thomas and Wishner 1996, Lawrence 1983), herbarium records available on the Consortium of California Herbaria (CCH), collection information made available by Pam De Vries (personal communication to E.L. Painter), LeRoy Gross (personal communication to E.L. Painter), Tim Thomas (personal communication to E.L. Painter), and the records for BCNWR included on the Wind Wolves plant list (Clendenen and Thomas undated).

1 http://ucjeps.berkeley.edu/interchange/

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I also prepared a list of ‘applicable’ literature, including literature cited by George and McDougald, literature I cited in the comments below and/or the suggested changes, and additional literature that is related to the topics covered by the George and McDougald report. I did not have time or resources to do a comprehensive search for applicable literature, so this is not an exhaustive list.

In preparing this review, BCNWR taxa lists, etc., I consulted with a number of scientists, including Ihsan Al-Shehbaz (Missouri Botanical Garden,, 2nd edition Jepson Manual editor and author, research on research on evolutionary, phylogeny, systematics of Brassicaceae) Edith B. Allen (University of California, Riverside, soil scientist, research on mycorrhizae, restoration ecology) Katarina Andreasen (Uppsala University, Sweden, research on evolution, systematics, DNA project of Linnaeus’s botanical collections, Malvaceae) Mary Barkworth (Utah State University, senior editor, Flora of North America Poaceae volumes, 1st edition Jepson Manual author, research on systematics of Poaceae) Jayne Belnap (USGS, biological soil crusts) Roxanne Bittman (Department of Fish and Game Botanist for California Natural Diversity Database) David D. Briske (Texas A & M University, range scientist) James Catlin (Wild Utah Project, project coordinator, GIS support and scientific analysis) Caroline Christian (Sonoma State University, research on population and community ecology, conservation biology and planning, restoration ecology, invasion biology) J. Travis Columbus (Rancho Santa Ana Botanical Garden, Poaceae family co-editor, 2nd edition and 1st and 2nd edition author for Jepson Manual, research on systematics of Poaceae) Pam De Vries (field botanist working on BCNWR flora, independent consultant) LeRoy Gross (Rancho Santa Ana Botanical Garden, Senior Curatorial Assistant, field botanist) Elaine Ingham (Soil Foodweb Inc., soil scientist) John R. Johnson (Santa Barbara Museum of Natural History, Curator of Anthropology) Allison Jones (Wild Utah Project, conservation biologist) Jon E. Keeley (USGS, plant ecologist, 2nd edition author for Jepson Manual, research on fire ecology, shrubland ecology, taxonomy of Arctostaphylos) Elizabeth A. Kellogg (University of Missouri, research on evolutionary, phylogeny, systematics of Poaceae) Jaymee T. Marty (The Nature Conservancy, Cosumnes River Preserve, ecologist, research on vernal pools) Misa Milliron [N. Misa Werner, Misa Ward] (California Energy Commission Research Development & Demonstration Division, former CNPS rare plant botanist, author of 1997 BCNWR botanical survey) L. Maynard Moe (California State University, Bakersfield, botanist, ecologist, author of

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A Key to the Vascular Plant Species of Kern County Roger Rosentreter (BLM, biological soil crusts) Andrew Sanders (University of California, Riverside, herbarium curator, field botanist, 2nd edition Jepson Manual author) Larry Saslaw (wildlife biologist, Bureau of Land Management, Bakersfield Field Office) Paula M. Schiffman (California State University, Northridge, research on ecology of California prairies, relationships between native and invasive alien plant taxa, plant/animal interactions) Mary Ann Showers (Department of Fish and Game, Lead Botanist for Habitat Conservation Planning Branch) Lloyd Simpson (Los Padres National Forest botanist, plant ecologist) Tim Thomas (USFWS retired, field botanist) Jan Timbrook (Santa Barbara Museum of Natural History, Curator of Ethnography, ethnobotanist, anthropologist) Margriet Wetherwax (University of California, Berkeley, 1st and 2nd edition Jepson Manual author, Managing Editor Jepson Flora Project) Carl Wishner (field botanist, biologist, independent consultant) Dieter Wilken (Santa Barbara Botanic Garden, Director of Conservation, 1st and 2nd edition Jepson Manual author and member of editorial board)

GENERAL COMMENTS I am disappointed in this report. I had hoped objective, impartial, strongly science- based report. Instead, this report is generally one-sided, weakly documented, and often opinion-based.

Reviews such as this generally avoid use of first and second person pronouns (I, me, we, us, you).

Present tense is generally not used for discussions of the contents of publications, since the preparation of these documents is in the past, as are any conclusions.

Because the authors chose to repeatedly reference the 2008 draft EA, they should have taken into consideration any and all science-based comments received by USFWS on that draft (e.g., Michael J. Connor, Pam De Vries).

Nomenclature sources should be cited for all scientific names used in the document [e.g., The Jepson Manual first edition or The Jepson Manual (second edition (as available), for plant scientific names].

Since most plant taxa have multiple common names (and a few have none), preferential use of scientific names would be less confusing than use of common names. There should be consistent use of scientific and popular (common) names, e.g., putting a scientific name in parentheses the first time a popular (common) name occurs in the document, or vice versa.

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The popular (common) name selected should be as unambiguous as possible. A popular (common) name that is most appropriate at the genus level should not be used for species if there is a more unambiguous name available for the species. The same is true for infraspecific taxa (i.e., subspp. and vars.).

The authors need to refrain from using ‘species’ unless that is the taxonomic level they are addressing. Currently in this report, they use ‘species’ when they are discussing taxa at the family, genus, and infraspecific levels, as well as when they are actually discussing species. If they choose to continue to use ‘species’ non-taxonomically, they need to explain very early in the document that they are using it to mean something other than species in the taxonomic sense, and why they have chosen to use it in a non-taxonomic manner. It is important in a survey for rare plant (and animal) taxa to identify plant taxa below the species level. Examples (using 1st edition Jepson Manual nomenclature): Both Eremalche parryi subsp. kernensis and Eremalche parryi subsp. parryi are documented on BCNWR. The former is federally listed as Endangered, while the latter is not. If these taxa had been identified only to species, a very rare, federally listed taxon would have been missed. Both Caulanthus coulteri var. coulteri and Caulanthus coulteri var. lemmonii are documented on BCNWR. The former is not on CNPS lists, the latter is CNPS List 1B.2. Makes a lot of difference for management. If these taxa had been identified only to species, a rare taxon would have been missed.

It is unclear why, rather than provide a single Literature Cited section for the entire report, the authors have chosen to separate the Literature Cited into pieces (one for each chapter, Chapters 1 and 2, for which the Literature Cited was apparently combined. Are they expecting it to be disassembled and did this to make disassembly easier? If they cannot provide an explanation, they should combine the three Literature Cited pieces into one comprehensive section.

Citations are required wherever a statement would appear to be the personal opinion of the authors if document reference is not provided. As currently presented, the authors appear to be recommending a great deal of management based solely on their personal opinions. Personal opinions are not sufficient to support management decisions for (nor recommendations of management for) the public’s lands, nor is it appropriate to suggest basing management on them2.

All direct quotations require citation of the origin.

2 Unfortunately, without strong science-based management, public lands managers must sometimes overcome a perception of ‘management by myth’ (e.g., O’Brien 2002, Donahue 1999, Blumler 1992, Schiffman 2009) or ‘faith-based management’ (e.g., Nabhan 2005, James Catlin, in presentations and personal communications).

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If quotation marks are being used to call attention to something that is not a direct quotation, single quotation marks are preferable to double (the latter should be reserved for direct quotations from a cited source).

Unless personal observations are those of the authors, then that observation needs to be cited as a personal communication from the observer(s) to the authors.

Personal communications that were not made to directly to the authors need to be cited as personal communications to the third party involved (or the authors need to contact the original communicator and get their own personal communication).

While ‘refuge’ (lower case) is a generalized term that means any place providing protection or shelter, ‘Refuge’ (upper case) can, when discussing National Wildlife Refuges, be used to indicate a unit within the National Wildlife Refuge system. Therefore, when discussing BCNWR, the authors should consistently use the upper case Refuge.

The authors need to choose a single term to use for biological soil crusts (aka cryptogrammic crusts, cryptobiotic crusts, microbiotic soil crusts, microbiotic crusts, biotic crusts) and use it consistently, rather than using multiple terms.

The authors need to choose a single term to use for non-native (aka alien, exotic) and use it consistently, rather than using multiple terms.

In addition to stating that terminology follows SRM (1989) on p. 5, the authors need to define (with appropriate citations) technical terms and jargon and any other terms that may need clarification so that there is no confusion in how the authors intend the terms to be interpreted. Clarification of all terminology should receive the same attention that livestock-grazing management terms receive on p. 8. A glossary or table of definitions (possibly similar to Appendix A in the draft EA (USFWS 2008) probably should be added to this report.

Since the authors rely heavily on measurements of residual dry matter (RDM) throughout the report, they need to define and describe RDM (with citations) well before Chapter 6). Although some of the people reading this report may be familiar with the technique, others will wonder how managers are supposed to measure pounds per acre of plant material. Actually doing so would seem daunting. They need to explain why RDM cannot be found under that name in the indices of the range textbooks they cite (although ‘residue’ can be found in the index of Heady and Child 1994, which they do not cite or include in Additional Important References). If a different name (or names) is used elsewhere, it would be useful to know. How commonly used is RDM outside non-native-annual-dominated ‘grasslands’ in California? Is it regularly used in range management across the country? If so, where to measure what?

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Why do the authors so frequently limit monitoring to RDM, which has known limitations (e.g., see discussion in Painter 1996)? RDM monitoring has limited predictive powers (Vallentine 1990). Because RDM is rarely sorted by species, it provided little or no information of differential impacts, and no information concerning desired conditions or potential natural vegetation. If the authors are going to recommend estimating RDM (or any other parameter) rather than actually measuring, then they must also recommend regular ‘calibration’ of estimates (and cite appropriate methodology on doing so). Cook and Stubbendieck (1986) pointed out that doing estimations requires considerable time checking estimates against actual data and that one can improve reliability by checking estimates daily. Cook and Stubbendieck also pointed out that estimates are “subject to personal error among individuals and for the same individual at different times”. Coulloudon et al. (1999) said that “[e]xaminers must calibrate their estimates when sampling situations change (i.e., different sites, time of day, change of season).”

Because there is not a consensus in the literature as to a definition of ‘grazing’ (see Painter 1995a), it is important that how the authors are using the term be defined very early in this review.

It is important to make obvious when ‘grazing’ refers to utilization by livestock and when it includes native herbivores as well, since the impacts may differ considerably. Therefore, livestock grazing (livestock-grazing when used as an adjective) should be used in all (or nearly all) cases where ‘grazing’ refers to livestock and not to all herbivores.

‘Rangelands’ is not a term necessarily familiar to the general public. Therefore, it should be defined (with appropriate citations). How do the authors define ‘rangelands’? Why do the authors feel that parts of BCNWR should be considered ‘rangelands’?

‘Forb’ is not a term necessarily familiar to the general public, so it should be defined (with appropriate citations). ‘Herbaceous’ is the converse of ‘woody’ (i.e., trees and shrubs). ‘Forb’ is not a term that is used in botanical references like The Jepson Manual (Hickman 1993) or Munz’s (1959) California Flora. If the authors use ‘forb’, they should also consider using ‘graminoid’ to account for non-grass herbaceous plants not usually considered ‘forbs’ (e.g., Cyperaceae and Juncaceae, see Keeley 1990) or provide a definition of ‘forb’ that includes these taxa. While most people may assume that they know what a ‘grass’ is, the term is actually used for plants in a large number of plant families, not just Poaceae (true grasses)3.

3 In addition to Poaceae, families (sensu the Jepson Flora project) in which there are taxa in California with common names referring to ‘grass’ include Acoraceae, Agavaceae, Alismataceae, Amaranthaceae, Apiaceae, Asparagaceae, Asteraceae, Boraginaceae, Brassicaceae, Cabombaceae, Cannabaceae, Caryophyllaceae, Chenopodiaceae, Crassulaceae, Cymodoceaceae, Cyperaceae, Droseraceae, Equisetaceae, Euphorbiaceae, Fabaceae, Geraniaceae, Hippuridaceae,

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Therefore, the authors should make clear whether or not their use of the term is restricted to taxa in the Poaceae, and, if not, what plant families or genera they are lumping into ‘grasses’. Their definition of ‘grass’ greatly influences the definition of ‘grassland’.

The authors need to define what they mean by ‘restoration’. They need to be clear on whether their concept of ‘grassland restoration’ includes returning areas currently dominated by non-native annual plants to areas dominated by grasses and shrubs, grasses and ‘forbs’, and/or oak woodlands with a grassy understory, or whether they are considering only a ‘return’ to vegetation dominated by native grasses.

Discussions of ‘grasslands’ can be complicated by people using the term to include not only ‘non-woody grasslands’ but also savannas, woodlands, shrublands, herblands, etc., in the definition of ‘grasslands’ (Anderson 2006, Schiffman 2007b, Minnich 2008). The authors need to provide a clear definition of their use of the term ‘grassland’ (with appropriate citations). It is currently unclear, although on p. 6, they do include “grass- shrub and grass-forb communities and the understory of oak-woodlands” in “pre- settlement Mediterranean-type grasslands”.

It should be recognized that to be a true grassland, grasses (generally but not always Poaceae) must be the dominant component throughout any given year and between years. In much of California, areas that are dominated by non-native annual grasses in some seasons or some years may be dominated by native herbaceous plants (usually annuals and may include native grasses) during other seasons (e.g., summer and autumn ‘tarplants’) or in other years (which is why wildflower enthusiasts talk of ‘grass’ years and ‘wildflower’ years). These areas are more correctly ‘terrestrial herbaceous communities’ or ‘herblands’ (which include true grasslands as a subset).

As noted in the notes for the September 09 meeting of the advisory team for the Independent range review, it has never been determined to what extent BRNWR area was ‘grassland’ pre-settlement. Therefore, ‘restoration’ of BRNWR non-native- dominated vegetation (including grasslands) should not focus on what may be an inappropriate vegetation type. It is possible that such ‘restoration’ would actually represent vegetation type conversion (as was the alteration to non-native-annual- dominated grassland). In fact, there is no compelling evidence that much or most of what is now dominated by non-native annuals throughout California was originally ‘grassland’. It is, therefore, disappointing that the authors have decided to continue

Hydrocharitaceae, Hypericaceae, Iridaceae, Isoetaceae, Juncaceae, Juncaginaceae, Lamiaceae, Lentibulariaceae, Liliaceae, Loasaceae, Lythraceae, Melanthiaceae, Myrsinaceae, Oxalidaceae, Parnassiaceae, Plantaginaceae, Polygonaceae, Pontederiaceae, Potamogetonaceae, Pteridaceae, Ranunculaceae, Rosaceae, Rubiaceae, Ruppiaceae, Ruscaceae, Scheuchzeriaceae, Sparganiaceae, Themidaceae, Valerianaceae, Verbenaceae, Violaceae, Zannichelliaceae, Zosteraceae (Painter, common names, Jepson Interchange).

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focusing on what could be an expensive misdirection of resources and type-conversion to an inappropriate vegetation type.

As a scientist (range and plant ecologist, plant conservation biologist, plant taxonomist), I strongly believe that management using best available science is essential. I believe that no scientific publication should be accepted without scrutiny and all scientific publications merit intensive examination. Selective critical examination of those documents with which one does not agree while accepting, with little or no criticism, those that appear to support one’s point of view does not represent use of best available science.

When the authors cite Christian et al. (in prep.), what are they actually citing? Christian et al. (in prep.) is a paper that no one has seen yet. Did the authors mean to cite Christian et al. (in BLM 2009a,b) or did they mean the Desert Report article (Christian et al. 2008)? If the former, then the citation would more correctly be Christian et al. (in prep., as described in BLM 2009a,b). In addition to the information available in BLM 2009a,b and Christian et al. 2008, Christian (2008) provides a preliminary data analysis and summary.

Given the conclusions that the authors have drawn from studies and those made in papers cited by the authors that were not actually supported by the methods and data, it is presumptive of the authors to lecture to other researchers on what conclusions they may or may not reach from their own data. Either the authors need to apply the same standards to every paper cited in this report, or they should refrain from criticizing what they do themselves. If the authors are going to apply standards to some of the literature they reviewed, they should apply the same standards to all. Ignoring the flaws in some literature while being hypercritical of similar flaws in others gives the impression of the authors being hypocritical, particularly because the authors fail to criticize literature that supports their opinions while denigrating literature that does not. For example, the authors (p. 8, pdf version) include criticism of reviews that did not cite studies where few or no livestock-grazing effects were found, but were not critical of papers that did the opposite (including this report). Belsky et al. (1999) acknowledged that they had not cited all available literature and pointed out that, because of the extensive literature available, not all papers could be reviewed or cited, they gave highest priority to recent papers in refereed journals presenting experimental manipulations. To avoid appearing hypocritical, the authors should include a similar disclaimer, explaining why much of the applicable literature was omitted. The authors point out (p. 9, pdf version) that “quality grazing management research requires a description of the grazing regime studied (season, frequency, intensity and duration of grazing) and of the site conditions (soils, weather, vegetation, etc) where the study was conducted”. Hays and Holl (2003) provide few (if any) of the p. 9 standards. The authors need to acknowledge that, in their opinion, studies can only draw conclusions about the specific treatments applied and the site studied. And this standard needs to be applied equally to that report benefits and those that report

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E.L. Painter 26 July 2010 adverse impacts of grazing. If one cannot extrapolate from the latter, one cannot extrapolate from the former. The authors are critical of one paper (Kimball and Schiffman 2003) that they feel that “the broad conclusion…were extended beyond the results of the study” (p. 47, pdf version), but not another that did the same. Pyke and Marty (2005) used their model to draw conclusions far beyond the data from a single ranch in eastern Sacramento County on which they were based, violating the p. 47 standards. Other examples of failure to critically review (or at least present the same level of criticism as applied to papers such as Kimball and Schiffman 2003) or Christian et al. (in prep., as described in BLM 2009a,b) can be illustrated by the following: Marty (2005) reported that removal of livestock grazing decreased native vernal pool plant and aquatic invertebrate species and application of livestock grazing increased these species but “ungrazed pools had 88% higher cover of exotic annual grasses and 47% lower relative cover of native species than pools grazed at historical levels (continuously grazed)” (Marty 2005). While Marty (2005) concluded that continuous grazing led to the highest relative cover by natives, figure 1 illustrated that ungrazed sites had the highest absolute cover of natives and continuous grazing had the lowest. No plant species lists were provided in Marty 2005, so there is no way of determining if increases and decreases in native plants represent widespread taxa, local taxa, obligate vernal pool taxa, rare taxa, etc. According to Jaymee T. Marty (personal communication to E.L. Painter), “it was the average number of native species that increased and decreased by treatment. In other words, I saw the average number of natives decline in the ungrazed plots, but I did not see species extinctions in any treatments. So, the species lists would likely be identical for the treatments”, and information on which native and non-native plant taxa increased or decreased “will have to wait for my next series of analyses”. Additionally, the inundation period of the pools was reduced in ungrazed pools, which (based on the Pyke and Marty 2005) model with hypothesized climate changes, could make it difficult for some endemic vernal pool taxa to complete their life cycle. Pyke and Marty (2005) evaluated the ecological implications of interactions between grazing and climate change for branchiopods and the California tiger salamander. Their grazing data covered 3 years from 1 ranch in eastern Sacramento County. They collected no data on salamanders (all extrapolations and modeling based on data from other sites) and data for branchipods was not directly reported. No information was given on reproductive success of branchipods with or without grazing in sampled pools. No information was provided about water quality in sampled pools nor how temperature changes might affect water quality (e.g., bacteria levels), nor how bacteria and other livestock-related pollutants might affect branchiopods and salamanders. Although their data was limited to a short time at a single ranch in the Sacramento Valley, their climate simulations covered more of the Central Valley over a 100-year time frame. The simulation model was based on the hypothesis that data (and conditions) for vernal pools in a localized area of the Sacramento Valley can be applied to all vernal pools in the Central Valley, despite possible soil differences, vegetation differences, weather pattern differences. The model extrapolations for 100 years are based on nothing changing except climate,

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even if livestock remained excluded for all 100 years (no recovery or natural revegetation anticipated). The assumption is made that changes in vegetation before experiment and in 3 years are permanent and unchanging over 100 years. Although the authors stated that “There is no a priori reason, however, to suspect that site or species-specific variation would confound or contradict the general pattern of results”, there is also no a priori reason to assume that such variation would not. Based on the potential differences among vernal pools throughout the Central Valley and the limited time-frame of data collection (which may not have included rainfall and temperature extremes possible), there is no a priori reason to suspect that these are actually general patterns. Because of the limitations of this study, there is no reason to assume that it is applicable to BCNWR. Weiss (1999) surveyed Bay checkerspot butterfly populations in serpentine ‘grasslands’ south of San Jose, California and found livestock grazing exclusion led to loss of the butterfly. Weiss 1999 is a study of impacts of livestock grazing to a single species (Bay checkerspot butterflies) on a restricted substrate (serpentine), examining the abundance of one of four host plants and none of the nectar source plants, in a site where dry deposition of nitrogen (automobile pollution) was found to be responsible for non-native grass invasion. As such, it has very little relevance to BCNWR. In addition, by failing to examine impacts to all host plants and all nectar source plants, it fails to examine most of the possible impacts to essential butterfly resources. In addition, it should be noted that Harrison et al. (2003) found that “[g]razing increased native species richness on serpentine soils but not on nonserpentine soils.” Thus, even if grazing were effective for very specific management on serpentine areas, it can be inappropriate to extrapolate from these studies to non-serpentine areas. Kelt et al. (2005) is another study that needs careful review. Based on figure 2, they found that the kangaroo rat did not do better with mowing or grazing, compared to control plots. Although, given the lower numbers at time 0, as a percentage of time 0, they may have done as well or better after 2 treatments; there were clear decreases after one treatment. There are a number of problems with Kelt et al. They had problems with their experimental design. “Treatment plots were inadvertently selected to have lower densities than control plots.” There are a number of problems with their habitat description. It is not made clear whether they conducted the survey of plants at the study site or borrowed a list from another source. There is no indication that they had a botanist examine the site nor that they collected voucher specimens to have a botanist ascertain whether their plant list was accurate or even that all plant species on it occur or may occur in Riverside County. At least one plant species they listed is markedly out of range. Trichostema laxum grows only in northern California and adjacent Oregon (Jepson 1943, Abrams 1951, Munz 1959, Hickman 1993, Consortium of California Herbaria), so it is highly unlikely that they would have found it at this site in Riverside County. Because there apparently are no voucher specimens, it is not possible to determine what Trichostema species may actually have occurred at the site. Including plants that are very much out of range indicates a lack of attention to accuracy and calls in to

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E.L. Painter 26 July 2010 question other parts of the study. In addition, they failed to check readily available literature to be sure that they were using current names for plants (e.g., Hickman 1993). Baeria chrysostoma is an antiquated synonym for that has not been used for several decades (as currently circumscribed, Lasthenia californica does not occur on BCNWR although this would be the name used in the 1st edition of The Jepson Manual). Brodiaea pulchella is an antiquated synonym for Dichelostemma capitatum that has not been used for a couple of decades. Bromus mollis has been called Bromus hordeaceus since at least 1993. It is possible that the nomenclature that they used came from Munz (1959); however, at least some of these names were changed in Munz (1968). Munz’s (1959, 1968) Flora and Supplement were superseded by Hickman (1993) as the most up-to-date source for plant nomenclature more than a decade ago. The failure to cite a plant nomenclature source and the use of out of date nomenclature indicates a lack of careful use of best available scientific literature. In his paper on Santa Cruz tarplant (Holocarpha macradenia), Hayes (1998) reported Holocarpha macradenia flourished with grazing but disappeared when grazing was removed. However, he failed to report that healthy populations of Holocarpha macradenia also occur in areas (e.g., Santa Cruz Armory), where there has not been livestock grazing for decades (E.L. Painter, personal observation; Margriet Wetherwax, personal communication). In addition, the USFWS botanists who worked on the listing package and at least two of the three solicited peer reviewers of the package cited livestock grazing as a specific problem for this taxon. They were not extrapolating from research done on in other areas or on other taxa; they were discussing specifically what they knew about this taxon. Given these facts, it cannot be generalized that cessation of livestock grazing is a threat to this species. Also, Holocarpha macradenia is restricted to the central coast area of California, which is much more mesic than BCNWR, also none of the rare, at-risk, threatened or endangered plants on BCNWR are tarplants, thus limiting the any application of this study to BCNWR. Hayes and Holl (2003) is another publication that merits careful review. The issues with methodology may be as great or greater a limitation for generalization as the methodology issues the authors have with Kimball and Schiffman (2003). In their study, Hayes and Holl (2003) reported that “forbs represent the majority of species native to grasslands” and “the majority of grassland species diversity is not in the grass family”, which may indicate that the areas studied may have been herblands (not ‘grasslands’) before settlement or that these relictual forbs that were more resilient to human impact than the taxa no longer present. They found that native annual forb richness and cover were greater in grazed sites and this effect coincided with decreased vegetation height and litter depth. Native grass cover and species richness did not differ in grazed and ungrazed sites but cover and species richness of native perennial forbs was higher on ungrazed sites. Hayes and Holl (2003) concluded that their results suggested that cattle grazing may be a valuable management tool to conserve native annual forbs and possibly other species of concern. This study was done in ‘California coastal prairie’ that is much more mesic

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(up than 84 cm (33 inches) annual rainfall during the study) than BCNWR (about 8– 12 inches (ca. 20–30 cm) annually, M. Stockton personal communication), so it is much less applicable than studies done in habitats similar to BCNWR (e.g., the Carrizo Plain and nearby areas). Hayes and Holl used different methods in surveying for native annual herbs (7 minute survey time for grazed, 22 minute survey time for ungrazed), which could influence their results. The numbers of sites surveyed differed between years, so between year data may not be comparable. It appears that only 2 transects were surveyed at each site, which limits the robustness of some statistical tests (n=2, 1 degree of freedom), and no within site differences are reported. No data on individual taxa, common or rare, is provided so it is not possible to tell if there were similar suites of native taxa in the paired plots, nor to determine if more rare or very common taxa were found in one treatment than the other. There is no way to determine if the numbers of ruderals and local endemics varied between livestock grazing treatments or between sites. Thus, it cannot be determined whether rare plants actually benefited from or were adversely impacted by either treatment. There is no indication whether the sites were similar enough in species compositions of ‘guilds’ at each site to warrant combining all sites. Schiffman (2007a) found very limited similarity among the ‘grasslands’ she studied: only 1% of the plants species were present in all ‘grasslands’ studied. This could be a study of ‘fruit salad’ rather than ‘apples’ or ‘oranges’. As Hayes and Holl pointed out, “[g]razing regimes for the sites varied with respect to duration, stocking rate, and timing”, all of which could profoundly influence species composition and success. There is no species list nor any analysis of how many of the species occurred in multiple sites. To support of their contention that the areas studied were ‘grasslands’ before settlement, they used outdated literature to support, either ignoring the current primary literature or failing to do a sufficiently comprehensive literature search. For example, they cited Heady et al., which is not a primary source, but rather is one of a long series of publications that have perpetuated a Clementsian paradigm (Hamilton 1997). Despite their citation of Edwards 1992 (not peer-reviewed), there is very little evidence that there were significant numbers of grazers in California prior to the introduction of domestic livestock. As Dr. Herbert G. Baker eloquently pointed out, “a few bones do not thundering herds make” (H.G. Baker, personal communication to E.L. Painter). Well-respected experts in applicable fields, including Drs. G.L. Stebbins (1992 and H.G. Baker (1992)4, questioned many of Edwards's opinions in the Fremontia article. Joy Belsky (1992), Mark Blumler (1992, 1993), and Jon Keeley (1993) also weighed in to the Fremontia ‘discussion’. Baker pointed out that Pleistocene megafauna in California “does not appear to have had a tremendous influence on grazing resistance by bunchgrasses” and that modern elk, pronghorn, deer, rodents, and lagamorphs, part-time grazers in the California ‘grasslands’, had a “minor selective influence”. He also pointed out that “selective agents of the Holocene operated more recently than the Pleistocene

4 Because of the differences in expertise, Baker's and Stebbins's opinions on plant evolution prima facie carry more weight than Edwards.

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factors, and we can expect that present-day taxa will reflect the more recent environment”. The cited Axelrod (1985) paper is strictly about the Great Plains. It has nothing to do with ‘grasslands’ in California, and it is inappropriate (at best) to cite it as if it were relevant. The California ‘grasslands’ in which Hayes and Holl worked are very different from the ‘mesic grasslands’ of the Great Plains, with which they compare them. Both Stebbins (1992) and Baker (1992) discuss the differences between Great Plains and California grasses and environment and reasons why they are not comparable. The California ‘grasslands’ in which they worked have winter rains (falling mostly between November and April) and little or no measurable summer precipitation. The Great Plains can experience precipitation year-round, although the majority (ca. 75%) of the precipitation falls between April and August. Great Plains grasslands are dominated by native rhizomatous grasses. The California Mediterranean-climate ‘grasslands’ are often dominated by non-native annual grasses, having some native annual grasses and some native perennial bunchgrasses. There is compelling evidence that most of these non-native-annual- dominated ‘grasslands’ probably were not dominated by grasses before settlement. Germano et al. 2001a was published in the middle of the study and is a summary of the CPNM study with no methods section and few data. To date, no peer-reviewed paper with data based on all 10 years of the Lokern study has appeared in a scientific journal. When considering the Lokern studies, one needs to critically examine the data in all of the 1997– 2006 annual reports (Germano et al. 1999–2006, Rathbun et al. 1997, 1998), as well as the mid-study summary (Germano et al. 2001a). The authors do not make clear why they chose to cite only of these annual reports (Germano et al. 2004, 2006), plus the mid-study summary. There are a number of design problems. Stocking rates within the grazed areas varied between study plots and between years, so at least some of the between-plot data and between-year data may not be directly comparable. Kern mallow (Eremalche parryi subsp. kernensis, Eremalche kernensis) data from the 2004 through 2006 growing seasons were collected on different sampling belts than in previous years (see Germano et al. 2006 figure 4), which means that the later data are not directly comparable to the early data. In his comments on the 2008 BCNWR draft EA, Dr. Michael J. Connor (2008) carefully reviewed the data available in the annual reports and discussed his findings: “Germano et al. (2001) hypothesized that removing livestock grazing could result in localized extinction of native plants and animals that have ‘evolved in sparsely vegetated habitats and rely on open ground to forage and avoid predation’ due to a build of herbaceous cover from introduced grasses that creates an ‘impenetrable thicket for small ground-dwelling vertebrates’. This particularly pertinent to Bitter Creek since Germano et al. suggested that this was relevant to populations of giant kangaroo rats (Dipodomys ingens), San Joaquin kangaroo rats (D. nitratoides), San Joaquin antelope squirrels (Ammospermophilus nelsoni), and blunt-nosed leopard lizards (Gambelia sila). However, long-term

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studies by these same and other researchers provide data to indicate that Germano et al.’s hypothesis does not apply to these species. Germano et al. have been studying the efficacy of light grazing on these species at the Lokern study site that is located near to the Refuge. They have released annual reports of their surveys of the study site since 1997. These are available on the internet.5 The reports document observations of listed and sensitive species and habitat conditions. The Lokern Study Area control plots typically have 2 - 7 times more Residual Dry Matter than treatment (grazed) plots so would seem a useful model for evaluating build up of herbaceous cover. Although the authors frequently state in the reports that based on numbers of individuals observed listed species are more abundant on treated (i.e., grazed) plots species than control plots this fails to take into account the large disparity in the size of treated versus control plots (920 hectares versus 116 hectares) and ignores edge effects which are much larger on the smaller control plots. The differences in abundance between the control and treatment plots look very different when the observations are normalized for plot size. For example, in Germano et al. 2006 the summed control areas support a density of blunt nosed leopard lizards of 1 per 22.5 acres or 10.5 hectares versus the summed treatment areas which support 1 per 34.5 acres or 13.7 hectares. Similarly, for San Joaquin Ground Squirrels the control areas support 1 per 3.3 acres or 1.5 hectares versus the summed treatment plots which only support 1 per 16.5 acres or 6.6 hectares. For both species the population densities are higher on the control versus treatment plots. Similar results are found with the other species of concern and for the other years. A long-term study is also underway on the Carrizo National Monument, specifically designed to evaluate the effects of grazing on native plants and giant kangaroo rats, prey for the San Joaquin kit fox, creating burrows used by the San Joaquin antelope squirrels and blunt-nosed leopard lizards and (through vegetative clipping and seed harvesting) creating habitat for the endangered San Joaquin species. This study is being conducted by the BLM, The Nature Conservancy, the California Department of Game and Fish, and researchers from Sonoma State University. Despite a working hypothesis that cattle grazing would benefit native species, the results of the study has concluded that two of the primary management objectives for using grazing as a management tool, enhancing native species and decreasing exotic plant species, cannot be supported. Similarly, although the study was undertaken with the hypothesis that grazing would have a positive effect on giant kangaroo rat habitat by removing exotic grass, the study has shown that grazing has had a negative effect for four years and no effect for the other two years studied. Results of this study are being readied for publication (Christian et al, in prep. Cited in EA CA169-07- 009).”6

5 http://www.csub.edu/~dgermano/GrazingWebSite.htm 6 Christian, C.E., Saslow, L.R., Pollock, J.F. and Doak, D.F. 2007. Conditional Impacts of Livestock Grazing on an arid California Grassland. Manuscript in preparation.

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The authors chose to focus quite a bit of attention on two studies that have not yet been published — the Germano et al. Lokern study (annual reports Germano et al. 1999– 2006, Rathbun et al. 1997, 1998, mid-study summary Germano et al. 2001a) and the Christian et al. Carrizo Plain study (in prep., as described in BLM 2009a,b, data analysis and summary in Christian 2008, Christian et al. 2008). The authors chose to ignore the most recent (on-going) Carrizo Plain study by Prugh and Brashares (annual reports (Prugh and Brashares 2007, 2008, 2009). For a more complete presentation of livestock-grazing studies conducted near BCNWR, authors should include the Prugh and Brashares study in their discussions.

The authors make no mention of cultural sites (including Native American sites) on BCNWR and the possible impacts of livestock to these sites (e.g., see Van Vuren 1982, Osborn et al. 1987, Nickens 1990, Horn and McFarland 1993). In addition to (including some photo-documented sites on BCNWR (De Vries, personal communication to E.L. Painter, also see Bernard (2008). In addition, according to John R. Johnson (personal communication to E.L. Painter), there is an ethnohistoric Chumash ranchería site (Malpwan) in the vicinity of BCNRW.

Unless the authors can come up with evidence that, in California, livestock grazing has been demonstrated to reduce fire hazard, all discussion of using livestock grazing as a tool to reduce fire hazard is a red herring that will stir up unnecessary controversy. As Huntsinger et al. (2007) pointed out, “[t]he effectiveness of grazing on fire behavior has not at this point been quantified….”

Since the authors rely on the 2008 draft EA, they need to acknowledge that “[t]he draft Environmental Assessment…for the Bitter Creek Grassland Management and Restoration Plan was not finalized and is now obsolete” (USFWS 2010).

Based on locality information in Miller and Kellogg (1955), the following animal taxa probably should be considered as being possible on BCNWR (if not already included in the draft 2008 EA) Sorex ornatus ornatus (ornate shrew) —not in 2008 draft EA Type Locality — Head of San Emigdio Canyon, Mount Pinos, Kern County, Calif. Altitude about 5,500 feet Sylvilagus audubonii vallicola (subsp. of desert cottontail, Audubon's cottontail, Audubon cottontail) — species but not subsp. not in 2008 draft EA Type Locality — San Emigdio ranch (25 miles southwest of Bakersfield), Kern County, Calif. Sylvilagus bachmani cinerascens (California brush rabbit, subsp. of brush rabbit) — not in 2008 draft EA northern limits to San Emigdio Range, Kern County Thomomys bottae pascalis (subsp. of Botta's pocket gopher, Botta pocket gopher, Botta's gopher, southwestern pocket gopher, valley pocket gopher) —not in 2008 draft EA

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less typically, on mountains around head of San Joaquin Valley — Tehachapi to Tejon Pass and San Emigdio Canyon, California Dipodomys heermanni swarthi (subsp. of Heermann's kangaroo rat, Heermann kangaroo rat) — species but not subsp. not in 2008 draft EA Carrizo and Cuyama plains, in southeastern San Luis Obispo County and extreme northern Santa Barbara County; also south-western border of San Joaquin Valley, in vicinity of McKittrick and San Emigdio, Kern County Dipodomys nitratoides brevinasus (subsp. of Fresno kangaroo rat, San Joaquin kangaroo rat) — in text of 2008 draft EA (p. 36) but not Table B CA DFG: Species of Special Concern BLM: Sensitive south to near mouth of San Emigdio Creek, in southwestern Kern County, Calif. Peromyscus truei montipinori (subsp. of pinyon mouse, pinyon-mouse, piñon mouse, True’s piñon deer mouse, True piñon deer mouse, True's deer mouse, True's deer- mouse) — species but not subsp. not in 2008 draft EA northwest in San Emigdio and Temblor Ranges to lat. 35° 20' N. Neotoma lepida gilva (subsp. of desert woodrat) — not in 2008 draft EA Proc. Biol. Soc. Washington, vol. 9, p. 126, July 2, 1894. (San Emigdio, Kern County, Calif.) Microtus californicus kernensis (Kern River meadow mouse) — not in 2008 draft EA southwest to Buena Vista Lake, San Emigdio Creek, and Fort Tejon, in Kern County

Pam De Vries (2008) recommended that the following taxa be addressed in planning documents such as the 2008 draft EA (and provided rationales for their inclusion): Monolopia congdonii (Lembertia congdonii, San Joaquin woolly-threads) — Federally Endangered. Caulanthus californicus (California jewelflower) — Federally Endangered, California Endangered Euproserpinus euterpe (Kern primrose sphinx moth) — Federally Threatened Ammospermophilus nelsoni (Nelson’s antelope squirrel) — California Threatened Masticophis flagellum ruddocki (San Joaquin whipsnake) — CA DFG Species of Special Concern Spea hammondii (western spadefoot) — CA DFG Species of Special Concern Taxidea taxus (American badger) — CA DFG Species of Special Concern Toxostoma lecontei (Le Conte’s thrasher) — CA DFG Species of Special Concern

The report was highly one-sided. The authors chose to expansively discuss possible benefits of livestock grazing on BCNWR, but they chose to largely ignore or minimize potential negative impacts, despite available literature that could have been cited. Before one can consider recommending the implementation of livestock grazing as a management tool, one must give consideration to the potential negative impacts.

One of the major goals for implementing livestock grazing as recommended by the authors seems to be reduction in non-native plants. However, they ignored or

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E.L. Painter 26 July 2010 minimized the literature that indicates that livestock may, in fact, lead to increases in non-native plants. Livestock grazing has been found to be a factor in the proliferation of non-native plants by livestock transporting seeds on their coats, feet, and in their guts into uninfested sites (Lacey 1987, Schiffman 1997, Belsky and Gelbard 2000, Jones 2001), livestock preferentially graze native plant taxa over non-native taxa (Lacey 1987, Fleischner 1994, Belsky and Gelbard 2000, Jones 2001), livestock preferentially grazing perennial plants over annuals (Van Dyne and Heady (1965), livestock can change competitive relationships in ways that favored non-native taxa (Baker 1978, Lacey 1987, Belsky and Gelbard 2000, Jones 2001), livestock create patches of bare, disturbed soils that act as non-native-plant seedbeds (Ellison 1960, Schiffman 1997, Belsky and Gelbard 2000, Jones 2001), livestock destroy biological soil crusts that stabilize soils and inhibit non-native seed germination (Belsky and Gelbard 2000, Belnap et al. 2001), livestock create patches of nitrogen-rich soils, which favor nitrogen-loving non species (Belsky and Gelbard 2000), livestock reduce concentrations of soil mycorrhizae required by most western native taxa (Belsky and Gelbard 2000), and livestock accelerate soil erosion that buries non-native seeds and facilitates their germination (Belsky and Gelbard 2000).

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SPECIFIC COMMENTS

Chapter 1 INTRODUCTION Purpose The first paragraph says that the purpose of this review is to “meet habitat management objectives at Bitter Creek National Wildlife Refuge”. However, the authors provide no reference for said objectives. Are these the objectives listed in the 2008 draft EA? If so, are still the objectives of BCNWR? If not, what are the habitat management objectives? If the objectives have changed but are not yet available to the authors, isn’t a report with the purpose of meeting as yet undefined or unavailable objectives premature?

Since the vegetation at BRNWR has not been surveyed in detail nor adequately mapped, how was it determined that “BCNWR is dominated by non-native annual grasslands”. While this was stated in the 2008 draft EA, it contained no evidence that this statement is true. Statements like this about relative abundance of this or any other vegetation/plant community type cannot and should not be made until comprehensive surveys are done to determine the vegetation/plant community types, the relative abundance of each type, the plant taxa within each type, the relative abundance of each taxon within the type, etc. During the course of her work, Pam De Vries (personal communication to E.L. Painter) found that even in areas where non-native taxa are abundant, there are “many native annuals and perennials mixed in”.

As noted in the notes for the September 09 meeting of the advisory team for the Independent range review, it has never been determined to what extent BRNWR area was ‘grassland’ pre-settlement. Have the authors found evidence that the native vegetation on BCNWR was grass-dominated rather than annual- or perennial- dominated herbland, shrubland, woodland, or some mixture of these? If not, then focusing on ‘grasslands’ (which may be an inappropriate vegetation type for the areas being considered for management by livestock grazing) may result in management failure. It is possible that ‘restoring’ ‘grassland’ would actually constitute a vegetation type conversion.

Grazing and Haying Policies Is haying being considered as a management tool for BCNWR? I could find no mention of haying in the 2006 or 2008 draft EAs. If it is not under consideration, why is it being discussed here? If there is direct relevance, it should be made very clear. If there is not, then discussion of haying is a red herring and all mention of it should be deleted.

If the examples of use of livestock grazing (or haying) are based on literature rather than the personal opinions of the authors, citations are required.

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What is meant by ‘decadent’ grasses? Decaying, aging, or senescent grasses? If so, one of those adjectives would be preferable. The term ‘decadent’ implies unrestrained gratification or self-indulgent as well as decline or decay. I found no record of geese or sandhill cranes being documented or reported on BCNWR, so why should the Refuge be concerned with removing such grasses?

If mention that livestock “grazing and haying may serve in that role by simulating grazing by large native herbivores” is based on literature rather than the personal opinions of the authors, citations are required. Painter (1994) pointed out that livestock differ significantly from the large native herbivores in California. Therefore, it is unlikely that livestock grazing would or could simulate “grazing by large native herbivores” on BCNWR.

The authors point out that grazing by domestic livestock can also cause environmental harm, and give as examples “reducing habitat quantity (e.g., through grazing desirable, non-target plant species), degrading habitat quality (e.g., through deposition of feces in or adjacent to waterways), facilitating introduction of non-native (including invasive) taxa (e.g., through seeds carried in hair, on vehicles and farm machinery, and in feces), and disturbing or competing with wildlife (e.g., through presence of permittees and vehicles/farm machinery, and grazing plants that also provide forage for wildlife).“ However, the authors then chose not to expand on these potentially harmful effects any further in the report.

Scope and Organization The authors state that “non-native annual dominated grasslands containing more than 400 native and non-native annual and perennial species”. First, while there are ca. 480 plant taxa reported or documented from BCNWR, it is not accurate to say that there are more than 400 ‘species’. These taxa have been identified variously to genus, species, infraspecific levels, so the authors’ describing them as ‘species’ is inaccurate. In addition, the available documentation (reports, herbarium specimen labels, etc.) does not indicate that all (or even most) of them are found in vegetation dominated by non- native plant taxa.

What makes literature pertinent? Does this mean that any and all papers not cited are not considered pertinent? While the authors may have reviewed the literature that they deemed ‘pertinent’, they failed to review much of the literature that is applicable. I provided quite a bit of literature that I felt was pertinent that was not included in the report. There was literature citations provided by commenters on the 2008 draft EA (thus considered pertinent) that was not included by the authors. Unless the authors have compelling evidence that the pre-settlement vegetation in areas that now have abundant non-native plant taxa was ‘grassland’, why limit the literature review to “pertinent literature regarding the history of California ‘grasslands’, their restoration and the ecology”, unless the authors have strong evidence that the original vegetation on BCNWR was ‘grassland’. Why not provide a broader California

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vegetation history, ecology, and restoration? Again, unless ‘grasslands’ were the pre- settlement vegetation of most or all of the non-native-annual-dominated vegetation on BCNWR, than this is an inadequate and inappropriately limited review.

The auxiliary verb ‘will’ is not needed in listing the sections of the report. It implies that this will be done sometime in the future, rather than that these are part of this report.

Chapter 2 LITERATURE REVIEW & CITATIONS Introduction Since the vegetation at BRNWR has not been surveyed in detail nor adequately mapped, how was it determined that “BCNWR is dominated by non-native annual grasslands”. While this was stated in the 2008 draft EA, it contained no evidence that this statement is true. Until comprehensive surveys are done to determine the vegetation/plant community types, the plant taxa within each type, the relative abundance of each taxon within the type, etc. During the course of her floristic work at BRNWR, Pam De Vries (personal communication to E.L. Painter) found that even in areas where non-native taxa are abundant, there are “many native annuals and perennials mixed in”.

Again, unless the authors have compelling evidence that the pre-settlement vegetation in areas that now have abundant non-native plant taxa was ‘grassland’, why limit the literature review to “pertinent literature regarding the history of California grasslands, their restoration and the ecology”? Why not provide a broader California vegetation history, ecology, and restoration that would include all possible vegetation types (based on native plants known or reported from BCNWR and surrounding areas)? Once more, unless ‘grasslands’ were the pre-settlement vegetation of most or all of the non-native- annual-dominated vegetation on BCNWR, than this is an inadequate and inappropriately limited review.

The literature review will only “improve the science base of future environmental assessments and plans” if it is comprehensive and not restricted by arbitrary limits placed by the authors. By limiting research to ‘grasslands’ and omitting pertinent literature suggested by reviewers of the 2008 draft EA and of earlier drafts of this report, the authors have imposed just such arbitrary limits.

Grassland History Because our knowledge of the origins of many of the ‘dominant’ non-native has changed since 1990 (particularly since the publication of The Jepson Manual and volumes of Flora of North America), the statement on Mediterranean origin may not be accurate (particularly when one considers taxa with broader origins that may include the Mediterranean region). Non-native plant taxa documented or reported on BCNWR (particularly in areas with concentrations of non-native taxa that could be called ‘grasslands’):

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Based on origin information given in The Jepson Manual (Hickman 1993), the following is clearly Mediterranean in origin: Hirschfeldia incana: Mediterranean Based on origin information given in The Jepson Manual (Hickman 1993), the following could be Mediterranean in origin: Avena barbata: southern Europe Polypogon monspeliensis: southern & western Europe Schismus barbatus: southern Europe, Africa Secale cereale: southern Europe, Africa Centaurea melitensis: southern Europe Centaurea solstitialis: southern Europe Herniaria hirsuta var. cinerea: southern Europe, northern Africa, southwestern Asia Stellaria pallida: southwestern Europe Based on origin information given in The Jepson Manual (Hickman 1993), the following have a broader origin than just the Mediterranean (which could be included): Avena fatua: Europe Bromus hordeaceus: Eurasia Bromus diandrus: Europe Bromus madritensis subsp. rubens: Europe Bromus tectorum: Eurasia Hordeum murinum (including subsp. glaucum, subsp. leporinum): Europe Poa bulbosa: Europe Schismus arabicus: Eurasia Vulpia myuros (including var. myuros): probably Europe Hypochaeris glabra: Europe Lactuca serriola: Europe Pseudognaphalium luteoalbum [Gnaphalium luteo-album]: Eurasia Senecio vulgaris: Eurasia Sonchus asper subsp. asper: Europe Capsella bursa-pastoris: Europe Chorispora tenella: Eurasia Descurainia sophia: Eurasia Sisymbrium altissimum: Europe Sisymbrium orientale: Europe Chenopodium album: Europe Salsola tragus: Eurasia Convolvulus arvensis: Europe Erodium cicutarium: Eurasia Erodium moschatum: Europe Marrubium vulgare: Europe Malva parviflora: Eurasia Polygonum aviculare subsp. depressum [Polygonum arenastrum]: worldwide Rumex crispus: Eurasia

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Based on origin information given in The Jepson Manual (Hickman 1993), the following are not Mediterranean in origin: Bromus arenarius (Australia) Matricaria discoidea [Chamomilla suaveolens]: northwestern North America, northeastern Asia Salsola australis: possibly Australia Nicotiana glauca: South America

Given the scientific literature supporting that many, if not most, of what are now called ‘non-native-annual-dominated grasslands’ were not true grasslands pre-settlement, why are the authors proposing to limit ‘restoration’ to ‘grasslands’?

Most definitions of ‘classical’ deal with a relationship to ancient Greek or Roman art, literature, and culture. These do not apply to Frederic Clements, who did most of his work in the early 20th century.

Frederic Clements first proposed that the vegetation of the Central Valley, the central and southern Coast Ranges, and the valleys of southern California was ‘perennial grassland’ (Clements 1920) and proposed that these ‘perennial grasslands’ were dominated by Stipa spp. [Stipa setigera and Stipa eminensa in the 1920 publication, in later writings Stipa pulchra and Stipa lepida] (Clements 1934) (see Hamilton 1997 for history of this hypothesis). Having decided that the original dominants had been Stipa spp., when he came to California, he searched for ‘relict’ patches (Hamilton 1997). Clements relied on observations of scattered patches of purple needlegrass (Stipa pulchra) and nearly pure stands along railroad rights-of-way (Keeley 1990, Hamilton 1997). Holstein (2001) pointed out that Nassella pulchra (Stipa pulchra) is semi-ruderal and not well adapted for dominating ‘pristine’ herbaceous vegetation. It has been suggested that several other perennial grasses (e.g., Poa secunda, Leymus triticoides, Melica spp., Muhlenbergia rigens) were historically more important constituents in some environments (Keeley 1990, Heady et al. 1992, Holland and Keil 1995, Holstein 2001, Schiffman 2007b and references therein).

Before Clements came to California (in 1925, according to Pool 1954), many accepted that the ‘grassland’ was naturally dominated by annuals (Blumler 2002). Clements’s concept of ‘climax’ did not include annuals as dominant ‘climax’ components (Hamilton 1997, Schiffman 2007b). The hypothesis that many of California’s current ‘grasslands’ were formerly dominated by annual vegetation has also received scientific support (e.g., Twisselmann 1967, Wester 1981, Blumler 1992, 2002, Minnich 2008). Keeley (1990) pointed out that this hypothesis is supported by observations made by people like John Muir and Lester Rountree. What are perceived to be non-native-annual-dominated ‘grasslands’ may be dominated by native herbs (usually annuals) during some seasons (e.g., summer and autumn tarplants) or in some years (which is why wildflower enthusiasts talk of ‘grass’ years and ‘wildflower’ years).

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Part of the acceptance of areas as being ‘grasslands’ has been the use of ‘grassland’ as a translation for Spanish words for ‘pasture’ (i.e., areas that could provide forage for livestock) (Minnich 2008). In fact, as Minnich points out, these areas were probably rich in herbaceous vegetation, but not necessarily grasses. Complicating this, a large number of native California plant taxa other than Poaceae (true grasses) have common names referring to ‘grass’7 (Painter, common names, Jepson Interchange). If the members of this group are also considered, then a wide range of habitats would have to be considered ‘grasslands’ and native-dominated ‘grasslands’ may be considered to contain (or be dominated by) many non-Poaceae plant taxa (even if logically one excludes aquatic taxa). In considering what the original vegetation may have been (and what the target vegetation for restoration might be), land managers need to consider the following information: Twisselmann 1967, pp. 188–189 “Ecologists frequently asset that [Stipa cernua] was one the dominant grass in the valley grassland and that it has been replaced by annuals because of grazing; there is little evidence to support this view at least for the upper San Joaquin Valley and surrounding foothills. While the historical record is not detailed, the writings of early explorers strongly imply it was a region of winter annuals (Jose María Zalvidea in 1806; John C. Frémont in 1844; Charles Preuse in 1844; William Ingraham Kip in 1855; and William Brewer in 1863. “The scant rainfall furnishes an even stronger argument; it is extremely doubtful that a perennial grassland ever existed in a region with a median rainfall of less than six inches. Despite a century of grazing, [Stipa cernua] still grows in dense colonies in the foothills in light soils on open slopes in regions with more than eight inches of rainfall. Dense and extensive stands may have grown on flats and valleys in the hills; if so, these were destroyed by tillage, not grazing. Some of the best surviving colonies in eastern San Luis Obispo County grow in the Pinole Hills; here an entire colony of German settlers abandoned their homesteads when their last horse starved in the dry year of 1898 (Mrs. Nellie King Cooper, oral communication). “Thus, it is reasonable to assume that the present annual grassland of the upper San Joaquin Valley did not replace a perennial grassland in which Stipa cernua was a dominant but a vegetation of native annuals; in this process grazing played an important but far from fully understood role.” Hoover 1970, p. 13 “Extensive areas toward the east were clearly treeless in their primitive state, but it is also known that many trees have been, and are being, removed from rangelands. It is therefore sometimes difficult to determine whether an herbaceous community represents the natural condition of a specific locality. I am not convinced that grasses were originally particularly abundant in such communities, and therefore prefer the term ‘herbaceous’ to ‘grassland.’ In any case, native grasses are not now a conspicuous element in the flora of the area

7 See list of families with common names referring to ‘grass’ provided in footnote 1

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in question. Herbaceous communities differ conspicuously from one another, because of soil differences and local climates.” Wester 1981 “…early accounts of Spanish and Anglo-Americans provide some information about their former condition. They suggest that the dry alluvial fans of the San Joaquin Valley, which account for 60 percent by area of California grasslands, were dominated by annual species and xerophytic shrubs. Perennial bunchgrasses were common only on certain well-watered floodplains.” Keeley 1990 “Bartolome and Gemmill (1981)…S. pulchra established seedlings most readily on bare ground but poorly under a cover of litter, a situation typical of an undisturbed grassland. They suggested that one should expect a ‘climax’ species to recruit seedlings without disturbance and therefore this species probably was not one of the dominant grassland species of the pristine prairie.” Blumler 2002 “Initially, grazing was concentrated in what is now known as ‘valley grassland,’ as well as the interfingering oak park forests, which together covered much of the lower elevation portions of the State (Griffin, 1997; Heady, 1997).” These ecosystems sport an extremely high number of endemic plant species, most of them flowering annuals (Raven and Axelrod, 1978; Blumler, 1992b). But today the herbaceous cove is dominated by introduced plants from the Mediterranean region, also mostly annuals, which have been spreading in California since before Spanish settlement (Blumler, 1995; Mensing and Byrne, 1997).” “Paleobotanical (phytolith) investigation of a single site suggests that perennial bunchgrasses such as needle grasses (Nassella spp.) may have been more common than they are today (Bartolome et al., 1986). In contrast, geographers examining the earliest accounts left by Spanish and other explorers have concluded that native annuals dominated many areas (Wester, 1981; Blumler, 1992b, 1995; Mattoni and Longcore, 1997; Minnich and Dezzani, 1998; Minnich and Franco Vizcaino, 1998). Current habitat preferences of native species also suggest that native annuals have been displaced to a greater extent than native perennials. Moreover, although spectacular displays of native annual wildflowers still occur, they have been declining for at least the past century (Roof, 1971). In contrast, there is little evidence for significant decline of bunchgrass abundance during the same time period. Nonetheless, environmental NGOs, such as the Nature Conservancy that are concerned with biodiversity conservation, and government agencies overseeing parks and preserves have almost unanimously assumed that the pre-European ecosystem was bunchgrass-dominated. Management tends to focus on expunging alien species and ‘restoring’ a bunchgrass landscape.” “Clements (1920, 1934) first claimed that perennial bunch-grasses were the natural dominants of California grasslands, based on his model of succession. Evidence he presented to support his opinion was weak (Blumler, 1995), whereas under today’s paradigm about succession, it is plausible that annual plants could have dominated (Blumler, 1984). Before Clements came to

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California, a consensus had long existed that the grassland was naturally dominated by annuals. Yankee settlers in the mid-nineteenth century quickly accepted this as fact and managed their livestock accordingly. They understood many facets of California range ecology that scientists had to relearn in the twentieth century, in part because the scientists were misled by Clementsian theory.” “…our emphasis should be on biodiversity, not on landscape and on native species number, not native purity. Prior to ‘restoration,’ the area should be surveyed and the native species already present identified. Native species should be carefully monitored to ensure that none are seriously harmed by the manipulations used to favor bunchgrasses or oaks.” Jackson and Bartolome 2007 “…searching for edaphic and geographic correlates with N. pulchra, Bartolome and Gemmill (1981) rejected the notion that this species represented relictual dominance and hypothesized that it likely is a disturbance-adapted species that finds refuge in places where light is less limiting than belowground resources.” Keeler-Wolf et al. 2007 “Nassella pulchra (purple needle grass) has been considered the flagship species of the bunchgrasses (Clements 1934; Kuchler 1964; Heady 1988; Holland 1986), but its past role and extent in the Central Valley and the central and southern coast regions of California are currently being debate (Wester 1981; Brown 1982; Hamilton 1997a; Stromberg et al. 2001; Holstein 2001). Some ecologists have concluded that purple needle grass was not the overall dominant but rather was the most opportunistic, r-selected bunchgrass, which explains why it is the most common and widespread bunchgrass in today’s disturbed grassland.” Schiffman 2007b “Frederic E. Clements’ (1934) relict analysis indicated that the perennial bunchgrass Nassella pulchra…had been the historical dominant in California’s grasslands. …Clements’ reputation as a leading twentieth-century ecologist led to the acceptance of his hypothesis among California biologists (e.g., Piemeisel and Lawson 1937; Munz and Keck 1959; Burcham 1961; Heady 1988). However, the relatively mesic and periodically burned fragments that were Clements’ exemplars did not constitute a good representation of the wide range of habitats that supported grassland vegetation in California. In addition, as Hamilton (1997a) convincingly explains, the scientific basis for Clements’ hypothesis was shaky because it relied upon little real data and several erroneous assumptions. Nevertheless, relatively recent references that discuss California grassland composition and ecology in detail still usually identify N. pulchra as the likely historically dominant species (Heady 1988; Schoenherr 1992; Holland and Keil 1995), and field studies, particularly those focused on conservation and restoration, have continued to give more attention to N. pulchra than to any other native grassland species. However, it has also been suggested that several other perennial grasses (e.g., Poa secunda, Leymus triticoides, Melica spp., Muhlenbergia rigens) were historically more important community

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constituents in some environments (Keeley 1990; Heady et al. 1992; Holland and Keil 1995; Holstein 2001).” “But what about the historical importance of forbs? Historical accounts, though limited in ecological detail, did clearly point to the impressive diversity and cover of colorful spring wildflowers. Even Clements recognized perennial forbs as ‘subdominants’ and stated that ‘even more typical are the great masses of annuals, representing more than 50 genera and several hundred species’ (Clements and Shelford 1939: 288). …Clements’ endeavor to draw ecological linkages between California’s grasslands and those of the Midwestern United States demanded that he emphasize perennials, especially grasses (Hamilton 1997a), despite the ubiquity of so many annual forbs.” “The ruderal nature of annual plants (Grime 1979a) was another feature of California’s native forbs that precluded Clements from considering them to be ecologically important. By definition, he viewed climax communities as generally stable associations of species that developed through succession (Hamilton 1997a). So, although vegetation make up of weedy, invasive, non-native annuals including Avena, Bromus, Hordeum, Festuca (Vulpia), and Erodium was considered a ‘proclimax’ community, a stable community dominated by an association of disturbance-adapted native annual plants completely violated his theoretical framework and, therefore, went unrecognized. Today, it is well know that native forbs repeatedly reappear on the same sites or decades, though their covers vary with annual rainfall amounts. In addition, soil disturbances by small burrowing mammals, herbivory, periodic fires, and environmental management by Native people were integral ecosystem processes that had compositional consequences including the promotion of annuals (Blumler 1992; Hobbs and Mooney 1995; Painter 1995; Schiffman 2000; Reichman and Seabloom 2002; Keeley 1990, 2002; Anderson 2005). Surely, the endurance of native annual forbs in California’s grasslands and their apparently adaptive interactions with other organisms and processes reflects their historical ecological significance.” “In recent years, researchers have used evaluations of historical accounts, floristic surveys, relict analyses, and modern experimental and comparative findings to propose alternatives to Clements’ vision of California’s grasslands composition. Several of these reconstructions have suggested that annual plants, rather than N. pulchra or other perennial grasses, had been the most ecologically important species in much of southern California and relatively arid inland environments including the Central Valley (Talbot et al. 1939; Twisselmann 1967; Western 1981; Blumler 1995; Holstein 2000, 2001; Schiffman 2000, 2005). In more mesic areas, annual forbs still constitute a diverse group of plants. …These habitats continue to support very large numbers of native species, particularly forbs, just as they did when Europeans first encountered them.” Minnich 2008 “The diarists had a mandate to look at California from a ‘barnyard/resource’ point of view, with the intent to establish a mission system and to convert the indigenous population to Christianity.”

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“Most Spanish entries [in diaries] use pasto and zacate (sacate) to describe dry herbaceous cover, or variations of the words, such as pastales and zatatón…. The Velázquez Spanish-English dictionary describes zacate, a Nahuatl word from central Mexico, as ‘grass, herbage, or hay.’ It can also refer to forbs (E. Franco-Vizaíno, pers. comm.). Pasto is defined from an agrarian perspective as ‘pasture, ‘ and ‘the grass which serves for the feeding of cattle’. The Velázquez dictionary also equates pasto with hierba, which means an ‘herb, a plant not possessing a woody stem, but dying down after flowering’…. Pasto also means ‘green food for cattle, grass (chiefly in plural, pasturage and grass.’ In view of these definitions, pasto and zacate doubtless have various meanings from one region to another. Zacate can refer to any form of grass, even a lawn. In the Chihuahuan Desert, zacate was used to [refer] to Erodium cicutarium, the dominant forb there, and other ephemeral ground cover (A. Kaus, pers. comm.). Other words used for ‘grass’ consistently refer to plants in riparian settings, not broad scale cover. The word pajon (pajonales), meaning ‘tall grass,’ was used only once in apparent reference to Sporobolus near a river. At one swampy locality, Garcés found a plant that looked like rye (centano), very likely Elymus condensatus, now called wild rye (the whole genus is called wild rye; Brewer 1883). Other words include carrizo (reeds) and tule, plants that both grow near streams or in swamps. Prado was used in the traditional usage, ‘wet meadow.’ The antonym for ‘pasture ‘ is esteril, which means barren, sterile, or unproductive. Perhaps most significant is that words that traditionally refer to ‘bunch grass’ such as grama, sabaneta, or zacate amacollado, never appear in the diaries. In addition, the word grama, is Spanish and refers to a couple of species from Spain, but can also refer to pasturage (E. Franco-Vizaíno, pers. comm.).” “The Spanish expeditions never examined herbaceous cover of interior California in the winter growing season, but the Crespí and Fages expedition of 1772 and the second Anza expedition of 1775-76 reached the Central Valley at Antioch just after herbaceous cover had cured. Crespí and Fages also traversed the Central Valley, both journeys in summer, but their brief journals left little record of the vegetation. All these expeditions leave the same impression: a spectacular barrenness of the interior in the dry season (Wester 1981), in striking contrast with coastal pastures. In contrast with the coast, no burns were described in the interior except in tule swamps.” “A few accounts by the Franciscans suggest that the interior valleys of southern California lacked good forage for livestock in summer. …Not only had the winter herbage dried out, but so little residue was left that the cracks of the earth and the soil were the most conspicuous aspect of the landscape.” “When he [Fages] traveled the plains near Bakersfield, he wrote that he was ‘passing by dry lagunas…and a level plain much undermined by pocket gophers [tusas]. His observations of a landscape of rodent tailings suggest that vegetation was too sparse to obscure them.” “The Zalvidea expedition provided an unwelcoming assessment of the southern San Joaquin Valley. The western and central Cuyama Valley was ‘arid and

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saline [with] …no grass’ (July 22-23, 1806). The eastern Cuyama Valley was ‘arid, without herbage… [but] pasture grew on the nearby hills’ (July 24). …He wrote that the southern San Joaquin Valley ‘from north to south… is surrounded by hills which make a semicircle. All this territory is covered by a species of herb which has a little stem with a yellow flower, the stalk being no more than a quarter [of a yard] high. All the hills which encircle this area have also a little herbage that… is not very dense’ (July 28-30). The flower appears to be a tarweed (Hemizonia spp. or Madia spp.).”

Many of the non-native plant taxa that have successfully invaded or successfully introduced in California originated in areas with similar climates, and many have evolved in close proximity to continual human-imposed disturbances related to agriculture, including domesticated livestock (Baker 1989, Stuckey & Barkley 1993). These together indicate that at least some (probably many) non-native plant taxa that have been successful in California were at least somewhat pre-adapted by selective agents in their original environment to conditions (including livestock) in their new environment. It is worthy of note that the non-native grasses that dominate the non-native-annual- ‘grasslands’ in California are not dominant in the region of their origin (Jackson 1985, Keeley 1990).

Cultivation was not responsible for type conversion of areas that were never farmed. It is probable that the more areas in California dominated by non-native annual plants experienced livestock grazing than were tilled. Unless it can be demonstrated that this is not true, it is inappropriate to try to shift responsibility for conversion from livestock to cultivation. For discussion of tillage to be relevant, there should be discussion of whether parts of BCNWR were cultivated and, if so, how much of it was (with appropriate citations).

“Vegetation type conversions, for the purpose of increasing forage production” is directly related to livestock, not an alternative explanation for changes from native to non-native vegetation.

“transition from a native grassland“ — There is quite a bit of evidence that the pre- settlement vegetation in some parts of California (including the southern San Joaquin Valley) was not dominated by perennials, but rather by native annuals or by native shrubs. Perpetuating the Clementsian myth of the former is a disservice to the concept of use of best available science.

Removal of plant tissue is a fundamental process in all vegetation types, impacting all or nearly all plant taxa – not just grasslands and grasses. Herbivory is a widespread cause of loss of plant tissue; however, terrestrial herbivores can range in size from single cells to elephants (Billings 1970).

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The cited authors (Holechek et al. 2004) are not evolutionary biologists nor grass systematists and the cited publication is a range management textbook, not a study in grass evolution or systematics. Therefore, I consulted with several well respected grass systematists and evolutionary biologists (Mary Barkworth, Elizabeth A. Kellogg, J. Travis Columbus), and they disagree that the statement “[g]rasses have evolved habits and structures to avoid or tolerate … above-ground tissue loss” can be applied throughout Poaceae8, e.g., according to J. Travis Columbus, the statement does not work with either bamboos or giant reeds. Some plants apparently can tolerate a certain amount of herbivory, while others have avoidance mechanisms. Although resistance (avoidance/tolerance, sensu Briske 1991) has been interpreted by some as an adaptation to grazing, it is more probable that the resistance is a strategy to reduce the negative impacts of all types of damage, including herbivory, fire, wind, freezing (Belsky et al. 1993). The same adaptations that permit grasses to endure extreme drought also provide protection during fires (Anderson 1982). These include herbaceous habit and underground vegetative perennating organs (i.e., growing points, renewal buds). These protected growing points also protect grassland plants from fire. Baker (1978) pointed out that California bunchgrasses maintain their renewal buds in the tussock (rather than belowground), which (in contrast to rhizomatous grasses found on the Great Plains) made them susceptible to livestock that defoliate plants closer to the ground than do native elk, deer, and pronghorn.

Briske et al. 2003 mention pre-settlement vegetation in relation to the presumed pre- settlement climax community representing excellent range condition (sensu Dyksterhuis 1949). However, they do not specifically discuss “conversion of pre-settlement Mediterranean-type grasslands including grass-shrub and grass-forb communities and the understory of oak woodlands”. In fact, they do not discuss California vegetation at all. That citation should be removed, or the statement changed to reflect the more general discussion in Briske et al. 2003.

The authors fail to consider that what they see as “return to the pre-settlement state is apparently an irreversible transition” may be an indication that it was not a perennial- grass-dominated vegetation before European settlement. With the latter, conversion back to native-dominated herbland, shrubland, or woodland may be possible.

8 Dr. Mary Barkworth: “Wishful thinking. Removal how far? Removal and deposition within 100 meters or deposition 1000 miles away? Big difference. …So — a nice, comforting, simplistic statement. Biology is not simple.”

Dr. Elizabeth A. Kellogg: “There was some indication for a while that grass diversification occurred about the same time as grazer diversification, but the timing doesn't fit so well after all. …So I guess it is correct to say that the grasses have ‘habits and structures that allow them to tolerate aboveground tissue loss’ but it's not clear that the origin of these habits was a response to grazing pressure.”

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Grassland Restoration Given the scientific literature supporting that many, if not most, of what are now called ‘non-native-annual-dominated grasslands’ were not true grasslands pre-settlement, why are the authors proposing to limit ‘restoration’ to ‘grasslands’? As Keeley (1993a) pointed out, attempts to establish native-perennial-grass-dominated ‘grasslands’ in sites that probably did not support them naturally is ‘type conversion’ not ‘restoration’. Restoration of BRNWR non-native-dominated vegetation (including ‘grasslands’) should not focus solely on what may be an inappropriate vegetation type for at least portions of the Refuge. It is possible that such ‘restoration’ would actually represent vegetation type conversion. Because there is no compelling evidence that much or most of what is now dominated by non-native annuals throughout California was originally ‘grassland’, it is disappointing that the authors have decided to continue focusing on what could be an expensive misdirection of resources and type-conversion to an inappropriate vegetation type.

The commentary on botanical collecting, Ft Tejon, etc., needs to tied directly to the subject of the section (grassland ecology).

John C. Frémont used his middle initial and spelled his name with an accent mark. There are 1844 Frémont collections from Kern County in the New York Botanical Garden, several of which can now be found on the Consortium of California Herbaria (CCH). These were made before the 1853 Ft Tejon collections mentioned by the authors as the earliest.

What evidence did the authors find to support their statement that the 1844 Frémont reports and the 1853 Ft Tejon were made “after the start of the invasion of non-native annuals that now dominate the grassland”? (Presumably the authors meant invasion in Kern Co., since that is the subject of the discussion in the paragraph.) How could one know this, if there are not reports or herbarium records? There are more than 1400 records for Kern Co. for before 1900 in CCH. The earliest collection of a non-native annual among the records currently in CCH is Lactuca serriola collected by T.S. Brandegee in 1883. While one cannot be certain what the species composition was, early reports (some dating back to Spanish exploration) do provide general descriptions that provide general vegetation pattern information (e.g., see Twisselmann 1967, Wester 1981, Schiffman 2007b, Minnich 2008).

There is only on species of Juniperus documented or reported from the BCNWR area, Juniperus californica.

Fisher et al. (2009) did not discuss “pre-settlement grassland”.

It is important to attempt to establish what the pre-settlement vegetation in the area to

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be restored probably was (Fisher et al. 2009) before attempting to return vegetation to something approaching its pre-settlement condition. In arid and semi-arid areas such as the arid southwestern U.S. where vegetation recovery can be very slow, where paleoecological data are poor, and where major changes caused by livestock grazing likely occurred during the 19th Century, pre-dating the detailed historical record, this is more important than in areas where pre-settlement vegetation is better understood (Fisher et al. 2009). Therefore, it behooves restoration ecologists to be very familiar with all available literature describing possible original vegetation (e.g., Twisselmann 1967, Hoover 1970, Wester 1981, Blumler 1993, 2002, Jackson and Bartolome 2007, Keeler-Wolf et al. 2007, Schiffman 2007b, Minnich 2008) to assist in making an informed decision on site-specific possible pre-settlement vegetation, as well as preparing as complete a list of native plant species persisting at the site. In addition, in some areas, sediment cores can provide information (e.g., Cole and Liu 1994), as can packrat middens (Fisher et al. 2006, 2009).

Discussions of ‘grasslands’ (and their restoration) can be complicated by people using the term to include not only ‘non-woody grasslands’ but also savannas, woodlands, shrublands, herblands, etc., in the definition of ‘grasslands’ (Anderson 2006, Schiffman 2007b, Minnich 2008).

While, when one is “[w]ithout knowledge of the pre-settlement condition”, the goal should be “to return habitat to a more desirable condition”. However, there are means by which one can more closely approach ‘pre-settlement’ conditions in setting goals for ‘desirable conditions’. For example, one can and should use all available literature describing possible original vegetation when establishing desirable condition. As Blumler (2002) pointed out, in restoration often the “…emphasis should be on biodiversity, not on landscape and on native species number…. Prior to ‘restoration,’ the area should be surveyed and the native species already present identified. Native species should be carefully monitored to ensure that none are seriously harmed [by restoration efforts].”

If among the goals for restoration is to be “return habitat to a more desirable condition involving a particular species composition, community structure, or set of ecosystems functions”, then ‘returning’ non-native-dominated areas to native-dominated or native- rich vegetation similar to what is already know to occur on BCNWR should be considered. This would include ‘returning’ to scrub and woodland vegetation, herb-rich vegetation and non-grass-dominated herblands, as well as ‘grasslands’. Although De Vries (2009b) did not formally survey vegetation nor did she formally delineate vegetation types on BCNWR during her floristic survey, she did provide information on the vegetation types what she observed. The vegetation types she listed were California annual grassland series, native perennial grasslands (nodding needlegrass series, one-sided bluegrass series, creeping ryegrass series), goldenbush scrub, bush lupine scrub, California buckwheat series, rubber rabbitbrush series, mixed saltbush series, mixed scrub oak series, mixed scrub oak/singleleaf pinyon series, California juniper series, red willow series, freshwater marsh, riparian scrub, and

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In addition to reviewing literature concerning restoration of native-dominated ‘grasslands’, the authors need to review literature on restoration of other vegetation types found on or around BCNWR. Included in such a review should be Allen (2004), Allen et al. (2005), Baker (2006), Baker and Shinneman (2004), Cione et al. (2002), Cox and Allen (2008).

While the authors point out that “[r]estoration of the native grassland has been a recurring objective of range managers”, they fail to mention restoration work done by non-range personnel, including restoration ecologists. Stromberg et al. (2007b) cite substantial literature on ‘grassland’ restoration that the authors failed to include, much of it not conducted by range managers.

Although, as the authors point out, “restoration failure is common (and few showcase their failures)”, there are examples that the authors could provide. According to Keeley (1990), Heady found that in the Central Valley ‘annual grasslands’ protected from livestock grazing for more than 40 years may still lack a perennial ‘grassland’ flora. In other studies cited by Keeley (1990), sites protected from livestock grazing for 27 years (Hastings Reserve) and 20 years (Hopland Field Station) also did not have marked increases in perennial grasses.

The problems with establishing or enhancing native perennial grass stands may be related to the appropriateness of these actions (e.g., as related to pre-settlement vegetation). It should be accepted that having non-native-annual-dominated ‘grasslands’ replaced by native-dominated herblands or by native shrublands often does not represent failure of the ‘grassland’ restoration project, but rather return to another type of vegetation that may actually be closer to the pre-settlement vegetation.

Because the original species composition of an area is usually not known, it behooves restoration ecologists to be very familiar with all available literature describing possible original vegetation (e.g., Twisselmann 1967, Hoover 1970, Wester 1981, Blumler 1993, 2002, Jackson and Bartolome 2007, Keeler-Wolf et al. 2007, Schiffman 2007b, Minnich 2008) to assist in making an informed decision on site-specific possible pre-settlement vegetation, as well as preparing as complete a list of native plant species and vegetation persisting at the site.

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As the authors point out, “[w]ithout knowledge of the pre-settlement condition, goals to return habitat to a more desirable condition involving a particular species composition, community structure, or set of ecosystems functions are common (D’Antonio and Myerson 2002)”; however, one can and should use all available literature describing possible original vegetation when establishing desirable condition. As Blumler (2002) pointed out, in restoration often the “…emphasis should be on biodiversity, not on landscape and on native species number…. Prior to ‘restoration,’ the area should be surveyed and the native species already present identified. Native species should be carefully monitored to ensure that none are seriously harmed [by restoration efforts].”

Simply because unidentified fire and grazing studies have not found ways to increase native perennials does not necessarily mean that there would be little opportunity for increasing native perennials. There are other restoration practices that might be successful (e.g., seeding).

The problems with establishing or enhancing native perennial grass stands may be related to the appropriateness of these actions (as related to pre-settlement vegetation). It should be accepted that having non-native-annual-dominated ‘grasslands’ replaced by native-dominated herblands or by native shrublands often does not represent failure of the ‘grassland’ restoration project, but rather return to the pre-settlement vegetation.

If one recognizes restoration of native ‘grassland’ ecosystems may not be ecologically or economically feasible (nor necessarily appropriate), a more feasible objective would be to maintain existing native plant taxa and vegetation, including native annuals and shrubs and/or to attempt to restore appropriate shrublands or herblands. It should be accepted that having non-native-annual-dominated ‘grasslands’ replaced by native- annual-dominated herblands or by native shrublands often does not represent failure of the restoration project, but rather return to the pre-settlement vegetation.

Grazing Management It should be remembered that this is a discussion of livestock grazing. Because there are native animals on BCNWR that may also graze, it is important that it be clear that this discussion pertains solely to livestock. Therefore, the word ‘livestock’ needs to be used frequently within the discussion.

‘Livestock managers’, ‘livestock-grazing’, ‘habitat managers’, or just ‘managers’ may be preferable to ‘grazing managers’, unless the managers are doing the grazing.

It is the authors’ opinion that “[o]ther concerns such as impacts on biological crusts and soil mycorrhizae have not been sufficiently studied to confirm the extent of the impact or practices that could mitigate these impacts”. All of the soil scientists I consulted (Edith Allen, Jayne Belnap, Elaine Ingham, Roger Rosentreter) strongly disagree with the authors’ opinion, at least concerning biological crusts. Because I provided references to literature with my review of their first draft, I too can see no justification for their opinion.

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They all pointed out that there is abundant literature concerning the extent of impact of livestock grazing to biological crusts, including literature referenced in Belnap et al. 2001 (cited in this report) and Warren and Eldridge 2001 (discussed below), as well as the references I provided. Belnap pointed out that most of the literature shows livestock are detrimental to biological crusts (personal communication to E.L. Painter). Rosentreter said that “crusts will suffer in any season except perhaps winter grazing” (personal communication to E.L. Painter).

While there is less literature concerning impacts to mycorrhizae, there are references that the authors should have cited, including Bethlenfalvay and Dakessian 1984, Bethlenfalvay et al. 1984. Edith Allen pointed out that “[m]ost plant species world-wide are mycorrhizal, so you can assume that would be the case for [BCNWR]” (personal communication to E.L. Painter).

Quite a few authors have not only reviewed the effects of livestock grazing on species composition of communities, ecosystem structure (vegetation stratification, soils), and ecosystem function (hydrology, nutrient cycling, and succession), but also effects on biological soil crusts, myrcorrhizae, etc. In addition to Fleischner 1994, Trimble and Mendel 1995, Belsky et al. 1999, citations should include Belnap 1994a,b, Belnap and Gardner 1993, Belnap et al. 2001. Belsky and Blumenthal 1997, Belsky and Gelbard 2000, Bethlenfalvay and Dakessian 1984, Bethlenfalvay et al. 1984, Beymer and Klopatek 1992, Brotherson et al. 1983, Ellison 1960, Lacey 1987, Mack 1981, Mack & Thompson 1982, Painter 1995, 1996, 2004, Roberson 1996, Rosentreter 1994, Schierenbeck 1995, St. Clair and Johansen 1993 (and many others).

Advocates of public-land livestock grazing should be able to demonstrate how ecological costs of livestock grazing (e.g., see Fleischner 1994) can be minimized, not trivialized (Painter 1995b). The authors should have taken the time and space to provide more discussion of the negative impacts of livestock grazing as documented in scientific literature (including reviews), if they are going to propose that impacts can be minimized. By not doing so, they may appear to be attempting to trivialize these impacts.

The “to be fair” paragraph belongs after the “several authors” paragraph and before the discussion of criticisms of exclosure studies.

While papers have shortcomings, it is important not to disregard the valid information they also provide.

It should be acknowledged that there are poorly designed studies that are cited on both sides of this issue, not just by the critics. Many papers presenting the benefits of livestock grazing are and should be criticized for failing to cite studies where the negative impacts outweigh the positive or ignore negative impacts to native species, just as reviews that point out the negative effects of

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livestock grazing “have been criticized for not citing studies where few or no livestock grazing effects were found, for citing studies that were poorly designed, and for not acknowledging similar impacts by native herbivores”. It should be acknowledged that space limitations and other factors limit the cited literature in papers by advocates of both sides. For example, if the authors believe it to be so, it could important to discuss that not all available literature has been cited or discussed in this paper, but efforts have been made to present a balanced citation and avoid the appearance of bias. As Belsky et al. (1999) pointed out, critics of livestock grazing emphasize damage to illustrate the unsuitability of livestock grazing, while advocates of livestock grazing argue that most of the damage occurred before modern livestock-grazing systems were instituted. They also pointed out that, because of the extensive literature available, not all papers could be reviewed or cited, so they gave highest priority to recent papers in refereed journals presenting experimental manipulations.

The authors need to acknowledge that studies that report benefits (as well as those that report adverse impacts of grazing) can, in the authors’ opinion, only draw conclusions about the “specific treatments applied and the site studied”. If, in their judgment, one cannot extrapolate from the latter studies, then logically one cannot extrapolate from the former studies either (including Weiss 1999, Hayes and Holl 2003, Kelt et al. 2005, Marty 2005, Pyke and Marty 2005).

There are exclosure studies designed for purposes other than studying livestock. If the discussion pertains to livestock exclosure, that needs to be made very clear (preferably by frequently adding ‘livestock’ to the discussion.

Did Sarr (2002) review all livestock-exclosure-based research? If not, then the wording needs to be altered somewhat. The authors leave the impression that Sarr found no exclosure studies that he considered scientifically adequate. Is this his conclusion?

Are there any exclosure studies that the authors would consider well designed, etc., or is the suggestion here that they consider all exclosure studies flawed and that all exclosure studies should be ignored? If the latter, how is one to study the impacts of removing livestock?

The authors need to consider what Holechek et al. (1998) pointed out, that exclosures on key grazing areas can be useful in separating climatic from grazing influences.

Bock et al. (1993) also wrote a critique of exclosures, in which they discuss the importance of exclosure research and the limited numbers of exclosures of appropriate size. As they pointed out, “spreading exclosures across all of the thousands of existing grazing leases would result in a highly desirable mosaic of grazed and ungrazed landscape units. The minimum size for an effective exclosure probably should be 1000 ha.” They responded to several probable contentions against creating such exclosures, including “(1) Previous exclosure studies show that livestock do not affect or are

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E.L. Painter 26 July 2010 beneficial to rangelands and their wildlife. Most livestock exclosure studies suggest that, in fact, livestock operate as keystone species in rangeland ecosystems. They do not necessarily preclude vegetation and wildlife, but they frequently determine which species of plants and animals will thrive and which will diminish….”

Comparisons of various livestock-grazing management practices and no livestock grazing are needed so that the long-term effects of livestock grazing on a large number of other ecological parameters (e.g., vegetation, biodiversity, native plant and animal population structure, plant and animal habitats, at-risk plant and animal taxa, soil structure and composition, biological soil crusts, etc.), as well as ecosystem services

Is the “common conclusion” actually the authors’ personal opinion, or do they have literature they could cite to support this?

Is the criticism of exclosure studies that native plants or native grasses do not become dominant? If the authors meant native grasses (rather than the more general native plants, they need to say so. There is considerable difference between these. The implication is that it is the latter, given the authors’ statement that “[a]nother explanation is that, focusing on native perennial grasses, we may fail to detect changes in the composition of other native species.” If this is a common conclusion, then there should be a rather substantial list of citations with it.

Did Huntsinger et al. (2007) summarize all studies of the effects of livestock grazing on native California ‘grassland’ plants? Did they review a substantial portion of the literature, rather than all of it? Unless the authors are sure that they reviewed all available literature, the wording needs to be changed.

It is BCNWR’s and USFWS’s needs that should be addressed by the authors, not society’s in general. This is another red herring. Does BCNWR have ‘need’ for “habitat, open space, biodiversity, clean water, and other ecosystem services” (or a subset of these) that authors feel might be met with livestock grazing? If so, they should specifically say so and spell out which ‘services’.

“transition from a native perennial dominated state“ — There is quite a bit of evidence that the pre-settlement vegetation in some parts of California (including the southern San Joaquin Valley) was not dominated by perennials, but rather by native annuals or by native shrubs. Perpetuating the Clementsian myth of the former is a disservice to the concept of use of best available science.

“year-round livestock exclusion has been shown to reduce diversity of herbaceous native and exotic plant species” — Isn’t reduction in diversity (as well as abundance) of ‘exotic’ (non-native) plant species what one would want?

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“to the detriment of threatened species that depend on non-grass species” — did the authors mean non-native species, rather than non-grass species? Which, if any, threatened species that depend on ‘non-grass’ species have been documented to have been detrimentally affected by removal of livestock? What are the ‘non-grass’ species on which these threatened species depend? Do either the ‘non-grass’ species or the threatened species occur on BCNWR?

Although the authors cited a number of publications that reported that livestock grazing can be detrimental to rare, at-risk, threatened, or endangered plant taxa that are documented or reported on BCNWR (based on the cited literature in the report) they apparently did not find any publications that reported benefits to documented or reported on BCNWR.

While the authors point out that “livestock grazing also has been found to be detrimental to rare at-risk, threatened, or endangered plant species that occur on BCNWR, they fail to point out how extensive the threat is throughout the United States and in California specifically. In 1998, Wilcove et al. reported that, in the United States as a whole, livestock grazing has been found to be particularly harmful to plants, affecting 33% of endangered plant species (compared to 14% of endangered animals) (Wilcove et al. 1998). In 1995, CNPS records showed that, in California, 225 rare, at-risk, threatened, or endangered plants were reported to be threatened by livestock grazing (Painter 1995). Rare, at-risk, threatened, or endangered plants documented or reported on BCNWR that have been reported to be threatened or harmed by livestock grazing or trampling or related activities include Eremalche parryi subsp. kernensis (US Endangered), Caulanthus lemmonii, Astragalus hornii var. hornii, Acanthomintha obovata (both subspp.), Delphinium gypsophilum subsp. gypsophilum, Eriastrum hooveri, Eriogonum temblorense, Fritillaria agrestis, Trichostema ovatum (California Native Plant Society 2010, BLM 2009b, Nevada Native Plant Society 2008, Bates 1993, Andreasen submitted, US Fish & Wildlife Service 1990. 2003, Williams et al. 1998, Mazer et al. 1993, Taylor & Davilla 1986, Cypher 2009). Rare, at-risk, threatened, or endangered plants that have a possibility of occurring on BCNWR (and should be considered when management is planned for suitable habitat) that have been reported to be threatened or harmed by livestock grazing or trampling or related activities include Caulanthus californicus (US Endangered, CA Endangered), Allium howellii var. clokeyi, Antirrhinum ovatum, California macrophylla, Calochortus palmeri var. palmeri, Calochortus fimbriatus [Calochortus weedii var. vestus], Chorizanthe blakleyi, Delphinium recurvatum, Delphinium umbraculorum, Eriophyllum lanatum var. hallii, Eschscholzia lemmonii subsp. kernensis, Layia heterotricha, Lepidium jaredii subsp. jaredi, Madia radiata, Monolopia congdonii, Viola purpurea subsp. aurea [Viola aurea] (California Native Plant Society 2010, Flora of North America, Hickman 1993, BLM 2009b, Williams et al. 1998, Taylor & Davilla 1986).

The authors fail to acknowledge that a number of studies have found that year-round exclusion or removal can be beneficial (e.g., Christian et al. 2008, Correy 2006, Dow

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2008, McEachern 2001, McEachern et al. 2001, Wagner et al. 2004)9. For example, McEachern (2001) reported “significant increases in native grass (particularly Nassella pulchra) and native herbs” following removal of cattle and a “rapid rebound” following removal of sheep. McEachern et al. (2001) reported that, at Pt Reyes, “succession following removal of cattle and sheep tends to go from annual grassland to a perennial grassland/shrubland mosaic” and that “[t]hese changes are evident through an increase in native and non-native perennial grass abundance, the spread of shrubs into grassland areas, an increase in shrub density within shrub patches, an increase in the number and diversity of plant species, greater total biomass, and increasing litter accompanied by decreasing soil erosion through time.”

The authors include Marty (2005) among the citations for research that reported detrimental effects of excluding livestock to threatened species. Since no plant species lists were provided in Marty (2005), there is no way of determining if reported increases and decreases in native plants represent widespread taxa, local taxa, obligate vernal pool taxa, rare taxa (including threatened taxa), etc.

Did the authors mean that Marty (2005) was “well documented” or ‘well designed’? “Well documented is defined as “widely recorded or recounted“10. When people describe something as being “well documented”, they mean that people have written a lot about it and so the facts about it are clear.11 If the authors intended to confer the idea that Marty (2005) is widely cited, then their use of “well documented” is accurate. However, if they were referring to the experimental design or some other aspect of the study, then they need to revise their statement.

Although Hayes (1998) reported that cessation of livestock grazing is a threat to Santa Cruz tarplant (Holocarpha macradenia), which, according to Hayes flourished with grazing but disappeared when grazing was removed. However, healthy populations of Holocarpha macradenia also occur in areas (e.g., Santa Cruz Armory) where there has not been livestock grazing for decades (E.L. Painter, personal observation; Margriet Wetherwax, personal communication) and the botanists at USFWS who worked on the listing package and at least two of the three solicited peer reviewers of the package cited livestock grazing as a specific problem for this taxon, so it cannot be generalized that cessation of livestock grazing is a threat to this species. The botanists at USFWS and the solicited peer reviewers were not extrapolating from research done on in other areas or on other taxa; they were discussing specifically what they knew about this taxon. Holocarpha macradenia is restricted to the central coast area of California, which is much more mesic than BCNWR, also none of the rare, at-risk, threatened, or

9 It should be noted that I found at least as many that reported exclusion or removal as beneficial as the authors reported for detrimental effects. 10 Free Online Dictionary [http://www.thefreedictionary.com/] 11 Longman Dictionary of Contemporary English [http://www.ldoceonline.com/dictionary/]

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E.L. Painter 26 July 2010 endangered plants on BCNWR are tarplants, thus further limiting the any application of this study to BCNWR.

See General Comments for concerns with Marty (2005), Pyke and Marty (2005), Weiss (1999), and Hayes and Holl (2003). Unless the authors are willing to present the short- comings of these papers, based on their own standards, it is inappropriate to use them to support their arguments.

If the authors are going to use common names, they need to provide scientific names to clearly delineate which taxa are being discussed, e.g., medusahead (Taeniatherum caput-medusae), yellow starthistle (Centaurea solstitialis).

‘Red brome’ is a common name applied to Bromus madritensis subsp. rubens, not Bromus madritensis as a whole. The statement needs to be corrected to reflect whether Savelle and Heady (1970), Germano et al. (2004), McGarvey (2009), and/or Battles et al. (in press) were referring to the former (in which case the name in parentheses needs correcting) or the latter (win which case the common name needs correcting).

It is probable that the establishment of Baccharis pilularis in non-native-dominated sites represents recolonization by a native shrub rather than ‘invasion’ by a species not previously known from the site.

Neither Taeniatherum caput-medusae nor Baccharis pilularis have been documented or reported on BCNWR.

While, according to the authors, DiTomaso 2000, 2006, DiTomaso et al. 2008 “[g]razing management has been effective in controlling noxious weeds such as…yellow starthistle, other authors have reported contrary results with Centaurea solstitialis. Thomas et al. (1993) reported that properly timed grazing effectively manages starthistle on a seasonal basis but does not eliminate populations. D'Antonio et al. (2007) reported that it increased with decreased livestock grazing. Hierro et al. (2006) reported that fire or grazing increased its success in California. Belsky and Gelbard (2000) reported that it was less frequent in ungrazed or lightly grazed communities. The authors need to cite all of this literature.

While, according to the authors, “[p]roperly timed grazing can reduce flowering in non- native annual plants such as …red brome (Bromus madritensis) (Savelle and Heady 1970, Germano et al. 2004, McGarvey 2009, Battles et al. in press)”, other authors again found contrary results. Clements (1920) considered it an overgrazing indicator. The Global Invasive Species Database and The Nature Conversancy Element Stewardship Abstracts both say that grazing and burning may lead to an increase. Germano et al. 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006 reported that cover was higher in control plots than grazed plots.

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Although I did not do a comprehensive literature survey, I found (see Bitter Creek plants livestock worksheet) that, in addition to Bromus madritensis (including subsp. rubens) and Centaurea solstitialis, other non-native plant species documented or reported on BCNWR that have been reported to benefit (increase) with or to be highly tolerant of livestock grazing (see Bitter Creek plants livestock worksheet), including Centaurea melitensis, Hypochaeris glabra, Sisymbrium altissimum, Erodium cicutarium, Erodium moschatum, Malva parviflora, Avena fatua, Bromus hordeaceus, Bromus tectorum, Hordeum murinum, Poa bulbosa, Polypogon monspeliensis, Schismus arabicus, Schismus barbatus, Vulpia myuros, Tamarix ramosissima. As with Bromus madritensis (including subsp. rubens) and Centaurea solstitialis, responses for some of these to livestock may not be consistent. Therefore, livestock grazing may not be a suitable tool to control or reduce these taxa.

Neither USFWS 2005 (proposed designation of critical habitat for the California red- legged frog) nor USFWS 2004 (determination of threatened status for the California tiger salamander) indicated that livestock grazing per se was beneficial, although the proposed designation lists over-grazing as a threat and the final designation includes unsuitable grazing as one of several factors that may reduce habitat quality.

Based on the 2008 draft EA, neither California red-legged frog nor California tiger salamander have been documented or reported on BCNWR.

Germano et al. 2001a is a mid-study summary, and has no methods section and few data. Without data, one cannot determine what, if anything, they actually ‘found’. Wording needs to be changed to reflect this uncertainty.

If the authors cite one annual report for an on-going study, they need to cite all of the annual reports. For the Lokern study, they need to cite Germano et al. 1999–2006, Rathbun et al. 1997, 1998.

It needs to be pointed out that there are no are no peer-reviewed studies conducted in California on fuel reduction by livestock. As Huntsinger et al. (2007) pointed out, “[t]he effectiveness of grazing on fire behavior has not at this point been quantified….”

Models cannot show that spread rate and flame length are lower, they can only demonstrate that (under the model conditions) they may be lower under conditions within the parameters of the model. A more detailed discussion of fire models (and modeling in general) is probably in order, since many if not most readers will be unfamiliar with them. The extent to which the Scott and Burgan models may apply to BCNWR has not been tested. Scott and Burgan (2005) models apparently referenced by authors: GR1 (101) Short, Sparse Dry Climate Grass (Dynamic) Fine fuel load (t/ac) 0.40. primary carrier grass, sparse or discontinuous GR2 (102) Low Load, Dry Climate Grass (Dynamic): Fine fuel load (t/ac) 1.10, primary

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carrier grass, more continuous, average depth about 1 foot (shrubs, if present, do not affect fire behavior) Scott and Burgan (2005) models apparently not referenced by authors that might be applicable (since livestock might use similar habitats on BCNWR): GS1 (121) Low Load, Dry Climate Grass-Shrub (Dynamic) Fine fuel load (t/ac) 1.35, primary carrier grass and shrubs combined, Shrubs about 1 foot high, grass load low SH1 (141) Low Load Dry Climate Shrub (Dynamic) Fine fuel load (t/ac) 1.7, primary carrier woody shrubs and shrub litter, some grass may be present SH2 (142) Moderate Load Dry Climate Shrub Fine fuel load (t/ac) 5.2, primary carrier woody shrubs and shrub litter, no grass present SH5 (145) High Load, Dry Climate Shrub Fine fuel load (t/ac) 6.5, primary carrier woody shrubs and shrub litter

Table 1 The authors provide very little or no science to support ‘management practices’ that they say would “reduced or prevent” the impacts of negative impacts of livestock and grazing listed in the table. Without citations, it must be assumed that these are the personal opinions of the authors. Public lands management should be science-based, and should not ever be based on personal opinions.

Is the statement that “[i]n the context of BCNWR or anywhere in California’s annual dominated grasslands there is no such thing as an uninfested site” the personal opinion of the authors or do they have documentation to support this assertion?

Non-native plant taxa documented or reported on BCNWR that may be dispersed by livestock, hay, livestock-related vehicles, and other livestock-related activities include the following (see Bitter Creek plants livestock worksheet): Hypochaeris glabra, Chorispora tenella, Descurainia sophia, Cyperus rotundus, Bromus diandrus, Bromus madritensis subsp. rubens, Bromus tectorum, Hordeum murinum, Polypogon monspeliensis, Schismus arabicus, Schismus barbatus, Rumex crispus, Nicotiana glauca.

Vehicle traffic, management staff, and wildlife, as well as livestock, may be vectors. The fact that there are other vectors does not negate the impacts of livestock, nor is it a justification for allowing livestock to continue to introduce to and move non-native plants around the Refuge. These other vectors may not transport the same plant taxa, may not transport them in the same quantities, and may not impact the same areas as livestock. Also, transport by some of these other vectors (e.g., vehicles, management staff) may be, at least sometimes, indirectly related to livestock grazing.

Postponing addressing the transportation of non-native species until after “non-native plant suppression is effectively reducing competition” assumes that it will be effective and that the introduction of new taxa will not compound or out-pace the current status.

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Maintaining a resident herd of livestock, viewed the authors as “the most logical means of stopping livestock transport of non-native seed”, would require year-round grazing in at least some portion of the Refuge. A resident herd and year-round grazing would only be effective at stopping livestock transport of non-native plants on to BCNWR if no new animals were ever introduced into the herd from the outside (i.e., only calves born in situ could ever be added to the herd). However, a resident herd would not stop livestock from transporting non-native plants from one area of BCNWR to another, increasing what may now be only localized infestations.

“Quarantine of incoming livestock in corrals or holding pastures” would only be effective if said corrals or holding pastures were set aside as ‘sacrifice areas’ (where introduction of non-native plants was accepted) on the Refuge or were not on the Refuge but on adjacent private lands. Is BCNWR willing to set aside ‘sacrifice areas’? Has it been proposed to the neighboring ranchers that they might be asked to do so? Even if quarantining incoming livestock was effective in removing all seeds, fruits, etc., that were internally transported, incoming livestock would have to be carefully inspected before they could leave a quarantine area, to make sure that seeds, fruits, etc., were not attached to the animals. Animals carrying seeds in their coats or hooves could not be allowed on to non-sacrifice portions of BCNWR.

Is it the personal opinion of the authors or do they have citations to support their contention that “[h]igh stock densities for short periods of time followed by adequate rest periods can effectively reduce the effects of preferential grazing”? This would only be possible if the preference is for non-native plants. Otherwise, the high number of animals, even for a short time, could decimate the preferred natives — even if they also took out some of the non-natives.

Is “[u]se light to moderate stocking rates” a contradiction of “[h]igh stock densities” recommended above it?

The authors need to choose a single term to use for biological soil crusts (aka cryptogrammic crusts, cryptobiotic crusts, microbiotic soil crusts, microbiotic crusts, biotic crusts) and use it consistently, rather than using multiple terms.

Since biological soil crusts have been photographed on BCNWR, consideration of impacts from livestock grazing most assuredly is an issue on BCNWR, even if the authors choose to maintain their uncertainty.

As Jayne Belnap pointed out (personal communication to E.L. Painter): “Much more work has been done on biological soil crusts in the 27 years since Brotherson (1983) and Anderson (1982). Almost all recent studies have shown livestock have a negative impact on biological crusts, as summarized by Warren and Eldridge (2001).” According to Warren and Eldridge (2001): "Trampling is the most common disturbance caused by grazing animals to biological soil crusts. A thorough review of the literature reveals an overwhelming consensus that trampling is detrimental to biological soil crusts

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in arid regions. Numerous studies in Australia, North America, central Asia and the Middle East reveal marked reductions in the cover, frequency, biomass and diversity of the crusts in actively grazed areas when compared with long-term exclosures or relic areas where domestic livestock are absent (Poulton 1955; Crisp 1975; Phillips et al. 1977; Nechaeva 1981; Otterman 1981; Anderson et al. 1982a, b; Brotherson et al. 1983; Graetz and Tongway 1986; Hacker 1987; Jeffries and Klopatek 1987; Marble and Harper 1989; Meyer and García-Moya 1989; Beymer and Klopatek 1992; McCune and Rosentreter 1992; Abaturov 1993; Eldridge 1993; Karnieli and Tsoar 1995; Tsoar and Karnieli 1996; Eldridge and Robson 1997; Memmott et al. 1998; Kaltenecker et al. 1999a,b). These comparative differences may persist for many years, even where grazing is terminated (Kleiner and Harper 1972, 1977; Antonova 1981; Nechaeva 1981; Kleiner 1982, 1983; Johansen and St. Clair 1986; Jeffries and Klopatek 1987; Evans and Belnap 1999)."

It is strictly the personal opinion of the authors that “[l]ike other impacts of grazing, we are uncertain whether all grazing is detrimental or if there are grazing management practices that can ameliorate or prevent effects on cryptogrammic crusts.” However, given the large body of literature available, both about other impacts of livestock grazing and impacts of livestock grazing to biological soil crusts, if the authors are uncertain whether there are any management practices that could ameliorate or prevent the documented negative impacts, shouldn’t they err on the side of caution and recommend against what could be very damaging actions (i.e., livestock grazing) rather than recommending actions that they can’t defend?

Although the authors state that “[m]ycorrhizae requirements of western native species are not sufficiently known”, Edith Allen said that “[m]ost plant species world-wide are mycorrhizal, so you can assume that would be the case for [BCNWR]” (personal communication to E.L. Painter). She pointed out that “[t]here are a number of books on mycorrhizae that make the statement that most plants are mycorrhizal, and the non- mycorrhizal plants are the exceptions. The exceptions are colonizing annuals in a number of families, such as Chenopodiaceae, Amaranthaceae, Brassicaceae, Papaveraceae (Eschscholzia californica is sometimes reported as non-mycorrhizal, sometimes as weakly mycorrhizal). All perennial plants are mycorrhizal, except plants of aquatic environments because the fungi do not survive in permanently flooded soils” (personal communication to E.L. Painter). As general references, she recommended Smith and Reed (2008) and Allen (1991).

Belsky and Gelbard (2000) actually was peer-reviewed, although it was not published in a peer-reviewed journal. If the authors feel it necessary to point out that this is not peer-reviewed, then they should make similar notations for all other citations throughout this report of all other cited documents that are not peer-reviewed.

There is at least one study on mycorrhizae that the authors should have been able to find and cite. Bethlenfalvay and Dakessian (1984) published their study of grazing

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effects on mycorrhizal colonization in the Journal of Range Management.

Literature Cited There are several publications cited in the body of this section (chapters 1, 2) that are not listed in the Literature Cited. The authors need to rectify this.

There are several publications listed out of alphabetical order. The authors need to rectify this.

There is one publication listed that I could not find cited in the body of this section. The authors need to rectify this.

Given Harold Heady’s important role in California range science and management, it seems odd that the authors chose not to include Heady and Child (1994) among the range textbooks listed in Additional Important References.

Chapter 3 RESOURCE INVENTORY This chapter is seriously lacking in citations. For example, until the Vegetation section of this chapter, there are not citations that would give the reader any idea where the authors got their information. It is essential that the authors provide citations for all information that is not their personal opinion. Otherwise, this chapter will have the appearance that it was invented whole cloth.

Introduction There is not a single citation provided to give any idea of the source(s) of information in this section.

If the goals of BCNWR are now more than preserving essential foraging and roosting habitat for condors, that should be stated after the final sentence in this section.

Land Use History There is not a single citation provided to give any idea of the source(s) of information in this section.

The common name ‘mustard’ is used for the family Brassicaceae as a whole and for multiple Brassicaceae taxa.

The only species of Brassica (sensu lato) that has been documented or reported from BCNWR is Hirschfeldia incana (which has sometimes been treated as Brassica geniculata, although not in the most recent treatments of California Brassicaceae), therefore “Brassica spp.” is an error. If the authors are not referring to Hirschfeldia incana, then Brassica would also be an error, although Brassicaceae would be correct.

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Who was on the 1996 review panel? Are there findings public? If so, why aren’t their findings cited?

Climate and Weather There are very few citations provided to give any idea of the source(s) of information in this section.

Fire There is not a single citation provided to give any idea of the source(s) of information in this section.

Earthquakes There is not a single citation provided to give any idea of the source(s) of information in this section.

Soils There is not a single citation provided to give any idea of the source(s) of information in this section.

Are most of these soils clays, sandy, loam, or what? How do the soils influence the vegetation? Which soils are most likely to have what the authors call ‘grasslands’.

Vegetation Given the attention given to ‘wildlife resources’ on BCNWR, it would seem reasonable for the authors to provide more information on the plant and vegetation resources. For example, what proportion of the documented and reported taxa are native or non- native? What proportion of the documented and reported taxa or annuals, perennials, shrubs, or trees? Are there more non-native annuals than non-native perennials? What are the rare, at-risk, threatened, or endangered taxa and what are their conservation statuses?

Do the authors have any evidence that the “current BCNWR grassland areas were probably a mix of native annual and perennial grasses and forbs” or is this simply their personal opinion? Did they consider the discussions of the San Joaquin Valley vegetation provided by Twisselmann 1967, Hoover 1970, Wester 1981, Schiffman 2007b, Minnich 2008? If so, why did they not cite them? If not, why not?

What is the source of the nomenclature used in the first paragraph? Several of the names are out of date, not conforming to names in 1s edition of The Jepson Manual (Hickman 1993) nor those available in posted treatments for the 2nd edition (Jepson Flora Project. 2009). Ericameria linearifolia is the name currently used for what was called Haplopappus linearifolius. Poa secunda subsp. secunda is the name currently used for what was called Poa scabrella. Erysimum capitatum var. capitatum is the name currently used for what was called Erysimum moniliforme. In California, the name

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Sambucus mexicana has been misapplied to what is actually Sambucus nigra subsp. caerulea.

The common name ‘goldenbush’ is applied to multiple Asteraceae taxa. One common name (of several available) for Ericameria linearifolia (Haplopappus linearifolius) is linear-leaved goldenbush. While ‘pine bluegrass’ is one of several common names applied to Poa scabrella, that common name is not generally applied to Poa secunda as a whole nor to subsp. secunda. The common name ‘yellow wallflower’ is applied to multiple Erysiumum taxa. The common name ‘golden poppy’ is applied to multiple Papaveraceae taxa. One common name (of several available) for Eschscholzia californica is California golden poppy. The common name ‘fiddleneck’ is applied to multiple Boraginaceae taxa. The common name ‘squirrel tail grass’ is applied to multiple Poaceae taxa. One common name (of several available) for Elymus elymoides is bottlebrush squirrel tail grass. The common name ‘elderberry’ is applied to the genus Sambucus as a whole. One common name (of several available) for Sambucus nigra subsp. caerulea is western blue elderberry. The common name ‘saltbush’ is applied to taxa in multiple families. Common names available for the genus Atriplex include orach, orache, salt-sage, salt sage, salty sage.

It is probable that reports are in error and Artemisia californica (California sagebrush) does not occur on BCNWR. It was not found by De Vries during her 2009 and 2010 surveys, nor by LeRoy Gross during has collecting work in 2009 and 2010. There are currently no collections from Kern County in CCH. Artemisia tridentata (big sagebrush) has been documented on BCNWR.

The De Vries survey has continued into 2010. She has added several taxa to the list this year. She files a report with BCNWR after each visit to the Refuge.

My working file is a continuously updated Excel spreadsheet. It is not and was not a formal report to USFWS or BCNWR. I shared it with the advisory committee as a source from which committee members or USFWS might extract information. I did not expect it to be incorporated into this report. The authors did not include it in the Literature Cited for this section. As far as I can determine from my files, the authors did not seek nor did I give permission for this working document to be used.

My working file includes not only taxa from the reports listed but also herbarium records. This needs to be included to make the statement accurate. The December 2009 list (included by authors as Appendix B without attribution) has been updated several times and an updated was provided to the authors 13 May 2010. The current list has 480 documented or reported taxa for BCNWR (32 only identified to genus), of which at least 363 have been collected and are vouchered (or soon will be) at publically accessible

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herbaria. There are an additional 29 rare, at-risk, threatened, or endangered taxa for which suitable habitat has been identified on BCNWR, but have not yet been documented or reported. An additional 12 rare, at-risk, threatened, or endangered taxa have been identified as having limited potential of occurring on BCNWR.

Actually, most of the surveys do provide information on the relative abundance, at least for those taxa that were vouchered. If the authors are interested in the available relative abundance information, they need only look at the labels on the herbarium specimens.

The authors need to explain what is meant by ‘upper Sonoran Life Zone’ and ‘lower Sonoran Life Zone’ as used by Twisselmann (1967).

I don’t know what constitutes “officially found” in the opinion of the authors. There are at least 3 specimens (collected in 2009 and 2010) at Rancho Santa Ana Botanical Garden herbarium (RSA). After careful examination of the De Vries and Gross specimens and consultation among four botanists (LeRoy Gross, Dieter Wilken, Pam De Vries, E.L. Painter), using documentation provided by Katarina Andreasen and her draft submitted treatment (2nd edition of the Jepson Manual), and examination of the holotype, it has been confirmed that these specimens best fit the circumscription of Eremalche parryi (Greene) Greene subsp. kernensis (C.B. Wolf) D.M. Bates. Both Mary Ann Showers and Roxanne Bittman (CA DFG, personal communications to E.L. Painter) agree that current evidence is sufficient to constitute “officially found”.

Since Kern mallow (Eremalche parryi subsp. kernensis, Eremalche kernensis) is currently recognized at the subspecific level, it is not taxonomically accurate to call it an “endangered species”, although that may be its legal status (if used in the latter sense, ‘species’ or ‘endangered species’ should be in single quotation marks).

The authors’ statement concerning the name change of Eremalche kernensis to Eremalche parryi subsp. kernensis is inaccurate and misleading. The change was not made because of “narrow botanical definition” but rather because taxonomic, systematic, and molecular studies indicated that this was the level at which the taxon was best treated (see Andreasen submitted, Andreasen 2005, Andreasen and Baldwin 2003, Andreasen et al. 2002, Bates 1993). Botanists (at least taxonomists and systematists, the botanists who deal with plant names) do not “believe that Parry’s mallow (Eremalche parryi) may be Kern mallow” (which would make Eremalche parryi a synonym of Eremalche kernensis), but rather the evidence supports that Kern mallow be treated as a subsp. of Parry’s mallow (thus making Eremalche kernensis a synonym of Eremalche parryi subsp. kernensis).

Because the authors provided no citations, it cannot be determined where the habitat information on Kern mallow came from, although it does not appear to have come from the two most recent treatments. According to Andreasen (submitted) and Bates (1993), Kern mallow grows on eroded hillsides and alkali flats with shadscale, at 100 to 1000 m (ca. 328 ft to 3280 ft). While specimens from the Carrizo Plain were factored into the

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Andreasen and Bates habitat and elevation reports, the more recently discovered populations on BCNWR have not been. Additional habitat and elevation information can be garnered for the label data on specimens in herbaria.

In addition to Eremalche parryi subsp. kernensis, there are other rare, at-risk, threatened, or endangered plants documented or reported on BCNWR (or for which suitable habitat is present and thus may occur although not yet documented) that may be threatened or harmed by livestock grazing or trampling or related activities. If USFWS is serious that they plan to address at-risk taxa (including CNPS List 1B, 2, 3, 4 plants) in the upcoming CCP and want to manage for them (Chris Barr, personal communication to E.L. Painter, 27 April 2010), then all of these need to be considered when preparing a livestock-grazing management plan (at least to the same extent that at-risk animals are).

De Vries (2009b) described “vegetation types”, not “plant communities or series”, although some of the “vegetation types” were ‘series’ (sensu Sawyer and Keeler-Wolf 1995, whose nomenclature she followed).

Presumably, the authors meant that the entire De Vries 2009b report could be found in Appendix C of this report, not that the De Vries descriptions of “plant communities or series” could be found in Appendix C of the De Vries report. I think rewording is in order.

Microbiotic Crusts The authors need to choose a single term to use for biological soil crusts (aka cryptogrammic crusts, cryptobiotic crusts, microbiotic soil crusts, microbiotic crusts, biotic crusts) and use it consistently, rather than using multiple terms.

If the authors are seriously interested in management of areas with biological soil crusts, they need to discuss those portions related to livestock grazing in Belnap et al. 2001, which covered both ecology and management of these crusts.

I put together the following information on biological soil crusts for my comments on the Draft Environmental Impact Statement and Resource Management Plan for the Carrizo Plain National Monument: Biological (cryptobiotic, cryptogamic, microflora, microphytic, microbiotic) soil crusts are important elements of arid and semi-arid ecosystems worldwide, representing over 70% of living cover in some of these systems (Belnap et al. 1994, 2001, Beymer and Klopatek 1992, St. Clair and Johansen 1993). In North America, they are found in semiarid regions of the Columbia Basin, Great Basin, and Colorado Plateau, extending into hotter, more arid deserts, as well as the deserts and Mediterranean regions of California. Biological soil crusts can be found on a variety of soils including (but not limited to) those derived from sandstone, gypsum, limestone, and shale parent material, although development may vary among

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substrates (Belnap and Gardner 1993). They are found in many types of vegetation, including shrub and succulent deserts, open woodlands, steppe formations, chaparral, scrub, Mediterranean-climate forests, alpine vegetation, tundra, grasslands, and prairie (Belnap et al. 2001). Biological soil crusts consist of eukaryotic algae, lichens, bryophytes, cyanobacteria, and fungi that live on or just below the soil surface (Belnap et al. 2001; Beymer and Klopatek 1992, St. Clair and Johansen 1993). Biological soil crusts stabilize soils and reduce wind and water erosion, aid in water infiltration, improve seedling establishment, increase soil organic matter and nutrients, and increase survival of some higher plant taxa (Belnap 1994, Belnap and Gardner 1993, Belnap et al. 1994, 2004, Beymer and Klopatek 1992, Brotherson et al. 1983, Harper and Marble 1988, Harper and Pendleton 1993, St. Clair and Johansen 1993). The presence of biological soil crusts on soils may be especially important in areas with a combination of highly erodible soils, steep slopes, and sparse vegetation may permit large amounts of water runoff and soil loss unless soil surfaces are protected (Belnap 1994a). Biological soil crusts can mitigate these. They are involved in the operation of the system including energy flow, water cycling, and nutrient balance (Billings 1994). Biological soil crusts also reduce wind and water erosion, hold otherwise loose material on steep slopes, increase water-holding capacity of sandy soils, and reduce water runoff, Cyanobacteria and cyanobacterial components of soil lichens fix atmospheric N, and are sometimes the dominant source for associated seed plants. Levels of N, P, K, Fe, Ca, Mg, Mn have been found to be higher in plants growing on crusted soils. Both free-living and lichenized cyanobacteria fix atmospheric nitrogen in significant amounts (St. Clair and Johansen 1993). Ecosystems west of the Rocky Mountains may be dependent on nitrogen provided by biological soil crusts (Belnap et al. 2001). Belnap et al. (2001) included livestock among the threats to biological soil crusts. Trampling, compaction, and other disturbances caused by hooves of domestic livestock have negative impacts on soil crusts, especially during dry periods (Belnap 1994a, Belnap and Gardner 1993, Beymer and Klopatek 1992, St. Clair and Johansen 1993). Both cover and biomass of the biological soil crusts have been found to be reduced on areas grazed by domestic livestock and exposed soil to increase (Beymer and Klopatek 1992, Brotherson et al. 1983). Damage can not only reduce soil stability, but soil fertility and soil moisture retention (Belnap 1994a). Impacts need not be direct to be devastating to crusts, and water- or wind-borne sediments from nearby destabilized areas can bury living crusts (Belnap 1994a). Significant correlations can exist between biological soil crust cover and the

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composition of vascular plant communities, so that damage can result in an altered vascular flora (Beymer and Klopatek 1992, Brotherson et al. 1983). Intensive livestock grazing has been used to break up physical soil crusts (Belnap et al. 2001). However, the result is short-lived. To effectively address physical soil crusting, management must promote greater soil aggregate stability. According to Belnap et al. (2001), management that promotes soil surface protection (through plant and biological soil crust cover) and increases soil organic matter is the only lasting solution to physical soil crust reduction. Livestock and cultivation have been responsible for loss of crusted soil (Mack 1981). Trampling, compaction, and other disturbances caused by hooves of domesticated livestock have negative impacts on soil crusts, especially during dry periods (Belnap and Gardner 1993; Belnap et al. 2001; Beymer and Klopatek 1992; Mack and Thompson 1982; St. Clair and Johansen 1993). Biological soil crusts are susceptible to impacts from hoofed animals, as well as burial from wind- and water- borne sediment from nearby destabilized areas (Belnap 1994a).

Wildlife Resources The first paragraph has no citations and definitely needs them, as do several of the individual species sections.

It is possible that blunt-nosed leopard lizard was seen this year on BCNWR. Before stating that it has not been found, the authors should check with the Refuge manager about this.

If there have been no kit fox sightings on BCNWR since 1996, why are there reports in Appendix D for 2004–2007?

Are blunt-nosed leopard lizard found in “spotted” vegetation or spotty (or patchy) vegetation? If the authors intended “spotted”, then they need to explain what the mean by ‘spotted vegetation’, since this is not a term generally used by vegetation ecologists.

When the authors cite Christian et al. (in prep.), what are they actually citing? Christian et al. (in prep) is a paper that no one has seen yet. Did the authors mean to cite Christian et al. (in BLM 2009a,b) or did they mean the Desert Report article (Christian et al. 2008)? If the former, then the citation would more correctly be Christian et al. (in prep., as described in BLM 2009a,b). In addition to the information available in BLM 2009a,b and Christian et al. 2008, Christian (2008) provides a preliminary data analysis and summary.

The publically available information from Christian et al. (in prep., as described in BLM 2009a,b), together with Christian et al. 2008 and Christian 2009, is of at least as much value grazing management as several of other papers cited in this report (e.g., Hayes and Holl 2003) that provide less than adequate information on intensity of grazing,

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E.L. Painter 26 July 2010 stocking rates, duration of grazing, etc. If the authors are going to discount the value of Christian et al.’s work, they should to apply the same standards to any and all studies they cite that do not provide intensity of grazing information.

What do the authors mean by the “population as a whole”? Are they referring to a single population, an undefined metapopulation, or the species as a whole? If the latter, then ‘population’ should be changed to ‘species’.

The common name ‘tule rush’ are applied to multiple Scirpus taxa, not just Scirpus acutus. Scirpus acutus (common tule) has not been documented nor reported from BCNWR, although Scirpus maritimus (maritime bulrush) has been vouchered.

The common name ‘stinging nettle’ is applied to Urtica as a whole. One common name applied to Urtica dioica subsp. holoserica is hoary stinging nettle.

Management Units While one can assume that ‘carrying capacity’ and ‘RDM targets’ may be the work of the authors, what is the source of the vegetation types data reported in Table 2? Did the authors visit each management unit and not vegetation types? Did they attempt to determine vegetation types in some other (unreported) manner?

The authors need to explain why grazing use should be reduced in areas more than 1 mile from water and provide citations.

While Unit 2 may be “a key unit” in the future of livestock grazing on BCNWR, it is possible that other units may also be ‘key’ to overall successful management of BCNWR. Eremalche parryi subsp. kernensis [Eremalche kernensis] grows in Unit 2. Therefore, needs to be thorough surveys for more than just blunt-nosed leopard lizards and giant kangaroo rats in Unit 2. Any and all management plans for Unit 2 would have to take into consideration any and all at-risk, rare, threatened, or endangered plants (and animals) in the Unit. Unit 2 is also a key area for the tule elk on BCNWR. Any and all management plans for Unit 2 would have to into consideration forage needs of the elk, potential conflicts or competition between livestock and elk, etc. Unit 2 is where I photographed biological soil crust, so a thorough survey is in order for that as well. Any and all management plans for Unit 2 would have to take into consideration all possible negative impacts of livestock to these crusts and the implications of such impacts not only to the soil crusts but also to other organisms that may be dependent upon them.

How much and which portions of Unit 2 have “areas of gentle slopes”? Based on the contour lines on Figure 2, it appears that significant portion of the unit has steep slopes.

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Are there sufficient areas in Unit 2 with “gentle slopes” to support the levels of livestock usage suggested by the authors (i.e., maintaining a herd on the Refuge all year-round)? A significant portion of the unit has steep slopes (e.g., see contour lines on Figure 2). According to Tables 3 and 4 in this report, carrying capacity significantly decreases with increasing slope and areas with slopes of 25–40% sometimes have 0 carrying capacity, and areas with slopes >40% often do.

What is the basis of the authors’ opinion that “[n]ative perennial grasses are common on BCNWR”? Personal observation? Do they have data or information in addition to what is in De Vries (2009) or the available herbarium vouchers? Do the authors mean that that all the native perennial grass taxa are common or that native perennial grasses (taken together) are common, even if no individual taxon is? The De Vries (2009) report said that “Scattered native perennial grasses… occur in many areas of the California annual grasslands at low densities”. “The most common native perennial grass species observed on the Refuge is one- sided blue grass [Poa secunda]. A native perennial grassland dominated by this species occurs in the southeast portion of the Refuge in Unit 6 on north-facing slopes west of the water tank. A large area of nodding needlegrass (Nassella cernua) perennial grasslands occurs on south-facing slopes in the same area. Nodding needlegrass grasslands were also observed in the extreme northwest portion of Unit 12. Creeping ryegrass (Leymus triticoides) forms extensive native perennial grasslands in areas where water is close to the soil surface. These scattered areas are typically associated with natural seeps and outflow areas close to water tanks.” Documentation of BCNWR of occurrences of native perennial grasses (De Vries, personal communication to E.L. Painter): Achnatherum speciosum — vouchered in Unit 11, observed in Unit 10A Bromus carinatus — vouchered in Units 3, 10A, 11 Distichlis spicata — vouchered in Units 2, 9, observed in Units 10B, 11 Elymus multisetus — vouchered in Unit 11, observed in Units 10A, 10B, 12 Koeleria macrantha — vouchered in Unit 11 Leymus triticoides — vouchered in Units 3, 12, observed in Units 6, 9, 10B, 11, abundant in some areas Melica imperfecta — vouchered in Units 3, 11 Nassella cernua — vouchered in Unit 11 Nassella pulchra — vouchered in Units 9, 12 Poa secunda — vouchered in Units 3, 9, observed in Units 1, 2, 6, 10A, 10B, 12, abundant in 2010 Additional abundance data can be garnered from labels on herbarium specimens. Several of these native perennial grass species are reported to be negatively impacted by or to decrease with livestock grazing (see Bitter Creek plants livestock worksheet), e.g., Achnatherum speciosum, Bromus carinatus, Melica imperfecta, Poa secunda (and sometimes Nassella pulchra). How would the authors propose protecting stands of these species from livestock damage?

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Why do the authors change from ‘management units’ to ‘pastures’? Do they view ‘pastures’ as equivalent to management units or subdivisions of management units on BCNWR? [This question is answered later in the report (chapter 4, prescribed grazing).] The authors need to define ‘pasture’ the first time they use it, not wait until the next chapter. Better still would be to exclusively use the term used on USFWS BCNWR maps, ‘management units’. Because ‘pasture’ has not been defined, it is unclear to which areas the authors are referring when they say “these pastures”? Units 6 and 12, or some portion of one or both of these? Are they proposing to use one unit as a grazing trial and the other as an ungrazed control? Do they have evidence that these two units are enough similar size, elevation, soils, plant species, vegetation types, etc., for any such comparison to be valid?

The authors need to explain why they recommend grazing ‘pastures’ containing native grasses to stubble heights of 2 to 4 inches, and need to provide appropriate citations. Do they have literature that has found that this would be beneficial to the native grasses (rather than negatively impacting them) and that grazing them to these heights will lead to increases (not decreases)? Which native grass taxa do they think would benefit or increase? What evidence can they provide?

Several of the native perennial grass taxa documented or reported on BCNWR are reported to be negatively impacted by or to decrease with livestock grazing (see Bitter Creek plants livestock worksheet), in particular ‘severe’ grazing (which might grazing these grasses to stubble heights of 2–4 inches): Achnatherum speciosum, Bromus carinatus var. carinatus, Elymus glaucus, Melica imperfecta, Poa secunda (and sometimes Nassella pulchra). Vulpia microstachys (a native annual grass species documented on BCNWR) is also reported to be negatively impacted by or to decrease with livestock grazing. Which (if any) of the native grass taxa do the authors think would benefit or increase with defoliation by livestock to 2–4 inches? What evidence, if any, can they provide that would predict there could be any benefits or increases to any of the native grass taxa? If they believe there would be a benefit to the native grass taxa from the ‘severe’ grazing they recommend, why do they proposed it? Which native grass taxa do they recognize might be negatively impacted by defoliation by livestock to 2–4 inches?

Since, as the authors have pointed out in this report, they did not have adequate abundance data available for the plant taxa on BCNWR, how do they know that red brome (Bromus madritensis subsp. rubens) is the “most prevalent annual competitor”? Do they have any evidence is this a personal opinion?

What do the authors mean by “perennial grass…spread”? Do they mean cover? If so, do they mean basal or aerial cover?

Carrying Capacity

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Management units (at least on the map provided by BCNWR personnel) are numbered, not identified by plant taxa or vegetation types. What do the authors mean by “grassland, juniper and oak-woodland management units”? If they are referring to management units with ‘grasslands’, juniper woodlands, and/or oak woodlands, then they need to clearly say so. The authors need to provide specific information (and maps) as to which areas in which management units were used to ‘field verify’ the scorecards.

Since the vegetation at BRNWR has not been surveyed in detail nor adequately mapped, how was it determined that “most of the refuge is grassland”?

Table 2 Although the table lists De Vries (2009b) as the source for vegetation type data, I cannot find where in the report the vegetation types are listed for each unit. I did find some units identified in some of the Vegetation Types descriptions, although no specific units were identified for California Annual Grassland Series. If the authors meant that the nomenclature followed De Vries (2009b), rather than citing De Vries for which vegetation types were found in which units, this needs to be made clear. If De Vries (2009b) is not the source for the vegetation types listed for each unit or is the source for only part of them, then the authors need to insert an explanation of their source(s) for these.

Table 2 should also have a column for sensitive/rare taxa. I don’t have sensitive/rare animal taxa distribution by management unit, but the information may be available from USFWS personnel. Below is sensitive/rare plant taxa distribution by management unit (De Vries 2009a, De Vries personal communication to E.L. Painter) for those taxa that are documented. Additional plant information may be available from herbarium specimen labels or from the collectors. Unit 2 Eremalche parryi subsp. kernensis [Eremalche kernensis] Delphinium gypsophilum subsp. gypsophilum Unit 3 Androsace elongata subsp. acuta Caulanthus lemmonii [Caulanthus coulteri var. lemmonii] Gilia latiflora subsp. cuyamensis Lupinus elatus Perideridia pringlei Unit 6 Eremalche parryi subsp. kernensis [Eremalche kernensis] Unit 10B Caulanthus lemmonii [Caulanthus coulteri var. lemmonii] Unit 11 Eremalche parryi subsp. kernensis [Eremalche kernensis] Castilleja plagiotoma

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Delphinium gypsophilum subsp. gypsophilum Fritillaria agrestis Gilia latiflora subsp. cuyamensis Unit 12 Delphinium gypsophilum subsp. gypsophilum

Literature cited There are several citations on this list that I could not find in Chapter 3.

There are several publications cited in Chapter 3 that are not in the literature cited.

CHAPTER 4 GRAZING AND VEGETATION MANAGEMENT Introduction Citations would be of use, unless statements here are strictly the opinions of the authors.

Prescribed Grazing Since, according to the authors, “[t]here are no studies that have tested an array of season, intensity, frequency and duration of grazing treatments”, is it appropriate, given the goals mandated for USFSW, to turn BCNWR into a large livestock-grazing study that might be detrimental to at least some of resources USFWS is charged with protecting?

In addition to range scientists and managers, USFWS would need to consult with plant and animal ecologists and biologists knowledgeable about the native plants and animals (including rare, at-risk, threatened, endangered), vegetation ecologists knowledgeable about the vegetation types on BCNWR, soil and biological soil crust ecologists, weed scientists, and an array of other scientists before any management that might negatively impact the resources on BCNWR is implemented.

Why limit monitoring to RDM, which has known limitations (e.g., see discussion in Painter 1996)? RDM monitoring has limited predictive powers (Vallentine 1990). Because RDM is rarely sorted by species, it provided little or no information of differential impacts, and no information concerning desired conditions or potential natural vegetation. The authors need to explain why a “moderate grazing intensity with an RDM target of 300 to 600 lb/a (Bartolome et al. 2006)” was chosen. Is ‘moderate’ (as opposed to ‘light’) arbitrary or is there a science-based rational for it? Why an RDM target of 300–600 lb/acre? Frost et al. (1990) recommended a minimum RDM for annual-dominated ‘grasslands’ of approximately 400 lb/acre for lower flat slopes, 600 lb/acre for average gentle slopes, and 800 lb/acre for steep upper slopes (annual-dominated ‘grasslands’ are not the only vegetation type at BCNWR, even these levels may be inappropriate when managing for native-perennial-dominated vegetation or the herbaceous layer of woody vegetation).

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What ‘parcels’ would the authors consider similar to low-elevation portions of Unit 2? Would the similar ‘parcels’ be external to or part of Unit 2? Why would the authors consider these to be similar (e.g., do they have similar soils, plant composition, slopes, aspects)? In order for any comparative monitoring to be scientifically valid, such similarities would have to be established.

What ‘parcels’ would the authors consider similar to high-elevation portions of Units 1, 1B, 3 east, 2 west, 6, 7, 8, 9,10A, 10B, 11, 12? Would the similar ‘parcels’ be external to or part of Units 1, 1B, 3 east, 2 west, 6, 7, 8, 9,10A, 10B, 11, 12? How similar in size would the ungrazed and grazed ‘parcels’ be? Would the grazed and ungrazed ‘parcels’ have similar soils, plant composition, slopes, aspects? In order for any comparative monitoring to be scientifically valid, such similarities would have to be established.

Why limit monitoring to RDM? Although RDM monitoring may be “a proven method” used by managers to assess the results of livestock grazing, there are known limitations (e.g., see discussion in Painter 1996). RDM monitoring has limited predictive powers (Vallentine 1990). Because RDM is rarely sorted by species, it provided little or no information of differential impacts, and no information concerning desired conditions or potential natural vegetation.

The authors need to explain why it would be appropriate to “attract livestock into under- used areas such as steeper slopes or areas that are more then 1/4-1/2 mile from water” and provide documentation that this would not be harmful to soils, native vegetation, etc. Did the authors consider impacts such as terracette formation (terracettes have been observed on BCNWR). Terracettes (step-like microforms) develop as a response to livestock trampling fundamentally unstable slopes (Higgins 1982, Klein 1987, Butler 1995, Trimble and Mendel 1995). Terracettes occur commonly on very steep slopes, along side large rotational slips, shallow soil slides, and theater-headed gullies. On very steep slopes, the step-like terracette forms disintegrate into a jumbled lattice network that lacks continuity across contours. Terracettes on steep slopes are likely to fail unless they possess sufficient silt and clay to impact cohesion to the coarse sandy soil.

Which “special status species” would benefit from “short, sparse ground cover”? Which might be harmed?

Which non-native annual plant taxa have been found to have reduced “competitive advantage” in scientific studies of targeted grazing? What studies conducted in California are there of use of targeted grazing to control or reduce non-native annual plant taxa? Do these non-native annual plant taxa occur on BCNWR?

Livestock Distribution Have there been any scientific studies that would support the authors’ opinion that “[t]rampled supplement sites could be good sites for native plant seeding trials”? If so,

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E.L. Painter 26 July 2010 where were they not cited? If not, why would the authors believe this to be a possibility?

Targeted Grazing Management What studies conducted in California are there of use of targeted grazing to control or reduce non-native annual plant taxa? Do these non-native annual plant taxa occur on BCNWR?

The discussion of targeted livestock-grazing management needs to be much more substantial if the authors are seriously recommending it for BCNWR. What studies have been done in California? What types of livestock were used? What non-native plants were targeted? Was substantial training of livestock helpful or required? Which non-native plant taxa on BCNWR would be suitable for control or reduction using targeted livestock grazing? Is there scientific evidence that these taxa can be controlled or reduced in this manner? How would the authors recommend coordinating the timing of grazing in relation to the timing of growth and reproduction in the targeted plant taxa? If these are not coordinated, the livestock grazing may have no effect on the targeted plant taxa. In one study (Allen 2003), the grazing treatment was not effective in controlling grasses in two out of three years because the livestock did not consume targeted grasses. It was found that timing of grazing was not compatible with timing of precipitation (thus growth and seeding in the grasses).

What scientific evidence is there that targeted livestock grazing might be effective for any of the habitat goals proposed by the authors? (1) Has targeted livestock grazing been used successfully for ‘habitat management’ for any of the rare, at-risk, threatened or endangered taxa documented or reported on BCNWR? If so, which taxa? Have any been found to be negatively impacted? What habitat parameters of which taxa were successfully manipulated? (2) Which non-native annual plant taxa documented or reported on BCNWR have been documented to have been successfully suppressed by targeted livestock grazing? (3) “The effectiveness of grazing on fire behavior has not at this point been quantified….” (Huntsinger et al. 2007), so effectiveness of targeted livestock grazing also has not been. (4) Which native ‘forb’ and perennial grass taxa documented or reported on BCNWR have been documented to have been successfully maintained using targeted livestock grazing? (5) Has targeted livestock grazing been used successfully for protection of riparian areas and management of riparian vegetation? If so, how similar were these to the riparian areas and vegetation on BCNWR? (6) Has targeted livestock grazing been used successfully to maintain a mosaic of herbaceous standing crop? If so, how similar were these areas to the herbaceous vegetation on BCNWR? Why would maintaining standing crop be preferable to maintaining a mosaic if native herbaceous taxa or high native biodiversity?

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Define ‘standing crop’.

Grazing Alternatives In addition to the three alternatives given in the 2008 draft EA, the authors should discuss a fourth: Native Plant Re-seeding, but No Livestock Grazing. No Herbicide Application, and No Mowing as Primary Strategies (enhanced native plants alternative). A number of studies have documented that one limiting factor in reestablishment of native vegetation is lack of an available seed bank (e.g., Hamilton et al. 1999). Therefore, in order to determine of recovery is possible, enhancement of native plants but no livestock is a reasonable alternative.

Grazing and Native Plants What constitutes “extreme competition”? What makes it “extreme”?

What evidence do the authors have that “extreme competition from non-native grasses threatens the existing plant biodiversity” on BCNWR? Of the 462 plant taxa for which nativity can be established, 405 (88%) are native. This indicates a rather high existing native plant biodiversity. If maintaining the level of native plant biodiversity (or increasing it) is a goal for BCNWR, then it is important that the authors provide evidence that the types of livestock they are proposing will do no harm.

While the authors yet again cite the same studies with limited application to BCNWR to support their contention that removal of grazing reduces diversity and is detrimental to grazing to threatened species, they have also (yet again) ignored studies that have found that year-round exclusion or removal can be beneficial (e.g., Christian et al. 2008, Correy 2006, Dow 2008, McEachern 2001, McEachern et al. 2001, Wagner et al. 2004). For example, McEachern (2001) reported “significant increases in native grass (particularly Nassella pulchra) and native herbs” following removal of cattle and a “rapid rebound” following removal of sheep. McEachern et al. (2001) reported that, at Pt Reyes, “succession following removal of cattle and sheep tends to go from annual grassland to a perennial grassland/shrubland mosaic” and that “[t]hese changes are evident through an increase in native and non-native perennial grass abundance, the spread of shrubs into grassland areas, an increase in shrub density within shrub patches, an increase in the number and diversity of plant species, greater total biomass, and increasing litter accompanied by decreasing soil erosion through time.”

Hamilton et al. (1999) reported that, in their studies, the results suggested that “persistence of native bunchgrasses may be enhanced by greater mortality of annual than perennial seedlings during drought, and possibly by reduced competition for water in wet years because of increased resource availability.”

Hamilton et al. (2002) reported that, in their studies, non-native annuals, by themselves,

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“did not seem to cause decline in Nassella [pulchra] stands, but light grazing did cause reduction in Nassella [pulchra] basal cover.”

Iris spp., Orthocarpus spp., Ranunculus californica, Limnathes spp., and Orcuttia spp. are neither documented nor reported on BCNWR, so discussion of them is probably not relevant to this report. Are there any reports of increases with livestock grazing of native ‘forb’ taxa that have been documented or reported on BCNWR?

I don’t know what constitutes “officially found” in the opinion of the authors. There are at least 3 specimens (collected in 2009 and 2010) at Rancho Santa Ana Botanical Garden herbarium (RSA). After careful examination of the De Vries and Gross specimens and consultation among four botanists (LeRoy Gross, Dieter Wilken, Pam De Vries, E.L. Painter), using documentation provided by Katarina Andreasen and her draft submitted treatment (2nd edition of the Jepson Manual), and examination of the holotype, it has been confirmed that these specimens best fit the circumscription of Eremalche parryi (Greene) Greene subsp. kernensis (C.B. Wolf) D.M. Bates. Both Mary Ann Showers and Roxanne Bittman (CA DFG) agree that current evidence is sufficient to constitute “officially found”.

Since Kern mallow (Eremalche parryi subsp. kernensis, Eremalche kernensis) is currently recognized at the subspecific level, it is not taxonomically accurate to call it an “endangered species”, although that may be its legal status (if used in the latter sense, ‘species’ or ‘endangered species’ should be in single quotation marks).

In addition to Cypher (1994), the authors should include mention of the impacts of grazing as reported in Bates (1993), Andreasen (submitted), USFWS (1990), USFWS Species Account, Williams et al. (1998), Mazer et al. (1993), Taylor & Davilla (1986), BLM (2009b), Cypher (2009). Also, see Bitter Creek plants livestock worksheet.

Unless the authors surveyed all (or most) of the scientific literature, it is an overstatement to say that “[s]pecies composition has been largely unaffected by manipulation of grazing intensity in non-native annual grassland sites with only negligible native plant cover….”

it should be noted that Harrison et al. (2003) found that “[g]razing increased native species richness on serpentine soils but not on nonserpentine soils.” Thus, even if grazing were effective for very specific management on serpentine areas, it can be inappropriate to extrapolate from results of studies on serpentine (e.g., Weiss 1999) to non-serpentine areas.

If there was not experimental control for comparison, how did Reeves and Morris 2000 or Kephart 2001 reach the conclusion that there was an increase in perennial

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bunchgrasses and a decrease in Taeniatherum caput-medusae or Centaurea solstitialis. To document a change, one must have some sort of comparison.

Taeniatherum caput-medusae has not been documented or reported on BCNWR.

Carrizo Plain National Monument Despite the title of the section, and the opening statement that “some of the analyses and findings of the Carrizo Plain National Monument (CPNM) Draft Resource Management Plan and Environmental Impact Statement may have relevance to Bitter Creek National Wildlife Refuge”, much of the discussion and many of the studies cited by the authors were not done on the CPNM, e.g., Germano et al. 2001, Savelle and Heady 1970, DiTomaso 2008, McGarvy 2009, Battles et al. in press). Discussion of these does not belong in this section and should be moved to another section of the report.

The authors focused the Christian et al. Carrizo Plain study (in prep., as described in BLM 2009a,b, summary in Christian et al. 2008) and Kimball and Schiffman (2003). They did not cite the data analysis and summary in Christian (2008), although it was available to them. And they chose to ignore Williams et al. (1993) and the most recent (on-going) Carrizo Plain study by Prugh and Brashares (annual reports (Prugh and Brashares 2007, 2008, 2009). For a more complete presentation of livestock-grazing studies conducted on CPNM, authors need to include Williams et al. (1993) and the Prugh and Brashares study in their discussions.

Williams et al. (1993) reported that, in their 20-month study on the Carrizo Plain, impacts of cattle grazing on populations of kangaroo rats and blunt-nosed leopard lizards were not statistically apparent and that more topsoil eroded from the grazed pasture compared to the exclosure protected from cattle grazing. The Prugh and Brashares study is 4 years into a long-term study of interrelationships between giant kangaroo rats (GKR), plant dynamics, and cattle grazing, with three annual reports available (Prugh and Brashares 2007, 2008, 2009). In neither the 2007 nor the 2008 annual report were there any short-term conclusions concerning these interrelationships, although in 2008 it was noted that “discrepancy among years highlights the sensitivity of this annual plant community to changes in rainfall patterns and indicates that more years of data will be necessary to adequately assess the relationships between native plant cover, cattle grazing, GKR activity, and rainfall.“ In the 2009 annual report, it is noted that “[t]otal plant biomass and native plant cover were both higher on plots inside cattle and GKR exclosures in comparison to plots exposed to grazing by GKR and cattle.”

It should be noted that the Environmental Impact Statement and Resource Management Plan for the Carrizo Plain National Monument (CPNM RMP, BLM 2009a,b) was fairly even-handed in how it dealt with any ecological uncertainties about grazing effects (i.e., see Chapter 4).

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The results of the Kimball and Schiffman (2003) experiments are similar to the results of the Christian et al. study. This similarity is particularly notable because Kimball and Schiffman focused on small plots that were artificially grazed (clipped) over 3 dry years while Christian et al. focused on large pasture-size plots that were grazed by cattle and monitored for 7 years (1997–2003) — some dry, others wetter.

If the authors do not approve of others broad conclusions about grazing practices were extended beyond the results of the study, then they should refrain from doing the same. They draw broad conclusions from studies like Hayes and Holl (2003) that are not supported by the methodology and data provided in the publications.

When the authors cite Christian et al. (in prep.), what are they actually citing? Christian et al. (in prep.) is a paper that no one has seen yet. Did the authors mean to cite Christian et al. (in BLM 2009a,b) or did they mean the Desert Report article (Christian et al. 2008)? If the former, then the citation would more correctly be Christian et al. (in prep., as described in BLM 2009a,b). In addition to the information available in BLM 2009a,b and Christian et al. 2008, Christian (2008) provides a preliminary data analysis and summary.

The authors’ comments might be a little more helpful if they would substantiate them by giving some examples of how broad conclusions were extended from the Christian et al. study. Although the authors consider the Christian et al. study to be “an example of a paper where broad conclusions about livestock-grazing practices were extended beyond the results of the study”, Christian et al. (2008) in fact went to considerable lengths to do just the opposite. In discussing their giant kangaroo rat (GKR) results, Christian et al. (2008) said “caution must be applied when extrapolating results from this study to other taxa.” Christian et al. (2008) pointed out that their study “was conducted only within plant communities found on the valley floor and lower foothills. The effects of grazing in the mountainous regions found in the Caliente and Temblor Mountains were not assessed. Finally, although the results from the study indicate that grazing has negative effects on native plants and GKR, the ecological reasons underlying these results were not assessed.” Christian (2008) pointed out that “[a]s with any study, it is critical to point out limitations. First, the results from the Carrizo grazing study cover only a seven-year period from 1997-2003. However, during this time, a major rainfall event occurred (1998), and despite dramatic increases in plant biomass during this period, no benefits of grazing were detected for the plant community or GKR. Indeed, results indicate that grazing during the high-rainfall years had adverse effects on native plants and GKR. Another limitation is that this study does not address grazing impacts on other sensitive species found at CPNM, especially blunt-nosed leopard lizard and other federally endangered species. Thus, caution must be applied when extrapolating results from this study to other taxa. Similarly, the study was conducted only on plant communities found on the valley floor and lower foothills. The effects of grazing have not been assessed for the more mountainous regions found in the Caliente and Temblor Mountains. Finally,

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although the results from the study indicate that grazing has negative effects on native plants and GKR, the ecological mechanisms underlying these results were not assessed.”

I have never heard of a plant ecological experiment being described as ‘abusive’12. I haven't come across this concept in any of the literature or experimental design and methodology books that I have read. The use of that term is judgmental, patronizing, condescending, denigrating, and inappropriate in what is purported to be a science- based report. In general, when one discusses vegetation, one usually speaks of a plant community type or a vegetation type, rather than a vegetation community type.

Although the authors say that the Christian et al. study was conducted over “more than ten years”, Christian (2008) says that the study lasted for “a seven year period from 1997-2003”.

One interesting finding reported in Christian (2008) was that the “results indicate that grazing during the high-rainfall years had adverse effects on native plants and GKR.”

According to Christian (2008), the study design was complex, with 11 predictor variables and 7 response variables.

There are problems with the Germano et al. Lokern study that the authors need to consider when discussing that research. When considering the Lokern studies, one needs to critically examine the data in all of the 1997– 2006 annual reports (Germano et al. 1999–2006, Rathbun et al. 1997, 1998), as well as the summary (Germano et al. 2001a). Germano et al. 2001a is a summary that was published in the middle of the study. To date, no peer-reviewed paper based on all 10 years of the Lokern study has appeared in a scientific journal. Stocking rates within the grazed areas varied between study plots and between years, so at least some of the between-plot data and between-year data may not be directly comparable. Kern mallow (Eremalche parryi subsp. kernensis, Eremalche kernensis) data from the 2004 through 2006 growing seasons were collected on different sampling belts than in previous years (see Germano et al. 2006 figure 4), which means that the later data are not directly comparable to the early data. In his comments on the 2008 BCNWR draft EA, Dr. Michael J. Connor (2008) carefully reviewed the data available in the annual reports and discussed his findings:

12 “abusive simulated grazing” sounds more like something that would come from the tongue-in-cheek ‘American Society for the Prevention of Cruelty to Plants’ (ASPCP) or the ‘Plant Liberation Front’ (see the Northern Nevada Native Plant Society Newsletter (1991) 17(4):6 or ‘Metaphoric Control of the Fearsome Coyote(-brush)’ at http://www.rangebiome.org/editorials/coyotebrush.html)

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“Germano et al. (2001) hypothesized that removing livestock grazing could result in localized extinction of native plants and animals that have ‘evolved in sparsely vegetated habitats and rely on open ground to forage and avoid predation’ due to a build of herbaceous cover from introduced grasses that creates an ‘impenetrable thicket for small ground-dwelling vertebrates’. This particularly pertinent to Bitter Creek since Germano et al. suggested that this was relevant to populations of giant kangaroo rats (Dipodomys ingens), San Joaquin kangaroo rats (D. nitratoides), San Joaquin antelope squirrels (Ammospermophilus nelsoni), and blunt-nosed leopard lizards (Gambelia sila). However, long-term studies by these same and other researchers provide data to indicate that Germano et al.’s hypothesis does not apply to these species. Germano et al. have been studying the efficacy of light grazing on these species at the Lokern study site that is located near to the Refuge. They have released annual reports of their surveys of the study site since 1997. These are available on the internet.13 The reports document observations of listed and sensitive species and habitat conditions. The Lokern Study Area control plots typically have 2 - 7 times more Residual Dry Matter than treatment (grazed) plots so would seem a useful model for evaluating build up of herbaceous cover. Although the authors frequently state in the reports that based on numbers of individuals observed listed species are more abundant on treated (i.e., grazed) plots species than control plots this fails to take into account the large disparity in the size of treated versus control plots (920 hectares versus 116 hectares) and ignores edge effects which are much larger on the smaller control plots. The differences in abundance between the control and treatment plots look very different when the observations are normalized for plot size. For example, in Germano et al. 2006 the summed control areas support a density of blunt nosed leopard lizards of 1 per 22.5 acres or 10.5 hectares versus the summed treatment areas which support 1 per 34.5 acres or 13.7 hectares. Similarly, for San Joaquin Ground Squirrels the control areas support 1 per 3.3 acres or 1.5 hectares versus the summed treatment plots which only support 1 per 16.5 acres or 6.6 hectares. For both species the population densities are higher on the control versus treatment plots. Similar results are found with the other species of concern and for the other years. A long-term study is also underway on the Carrizo National Monument, specifically designed to evaluate the effects of grazing on native plants and giant kangaroo rats, prey for the San Joaquin kit fox, creating burrows used by the San Joaquin antelope squirrels and blunt-nosed leopard lizards and (through vegetative clipping and seed harvesting) creating habitat for the endangered San Joaquin species. This study is being conducted by the BLM, The Nature Conservancy, the California Department of Game and Fish, and researchers from Sonoma State University. Despite a working hypothesis that cattle grazing would benefit native species, the results of the study has concluded that two of the primary management objectives for using grazing as a management tool, enhancing native species and decreasing exotic plant species, cannot be supported. Similarly, although the study was undertaken with the

13 http://www.csub.edu/~dgermano/GrazingWebSite.htm

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hypothesis that grazing would have a positive effect on giant kangaroo rat habitat by removing exotic grass, the study has shown that grazing has had a negative effect for four years and no effect for the other two years studied. Results of this study are being readied for publication (Christian et al, in prep. Cited in EA CA169-07-009).”14 The statement in Christian et al. (2008) that “[c]ontrary to recent cattle-grazing studies done elsewhere in California, the results from the CPNM study do not support the general hypothesis that seasonal grazing is beneficial for the native plant communities found in the study area” refers to the general hypothesis that has been applied to studies done elsewhere. This is a valid conclusion, since the results of the Christian et al. study do, in fact, contradict this general hypothesis from other California studies. If the authors conclude that the conclusion reached by Christian et al. (2008) is not valid, then they must also accept that the broader conclusions in many of the other papers they cite in this report also need to be discounted.

Since none of the examples cited ((Savelle and Heady 1970, DiTomaso 2008, McGarvy 2009, Battles et al. in press) are studies done at CPNM, they to not applied to your premise (at the beginning of this section) that “some similarities and proximity some of the analyses and findings” of research done on CPNM may be relevant to BCNWR. Therefore, discussion of these does not belong in this section. There is insufficient information provided to make clear why the authors feel that these may be “more appropriate” than the Carrizo Plains studies. Did they study all non-native annual grasses? If not, please specify which non-native annual grass taxa were studied. Otherwise, this is the sort of over-generalizing of which the authors are critical. ‘Non-native annual grass’ is not a sufficient identification to be able to determine if there were similarities in taxa between these studies and BNCWR. Which non-native grass taxa that also are documented or reported on BCNWR were targeted in Savelle and Heady (1970), DiTomaso (2008), McGarvy (2009), Battles et al. (in press) studies? If these were not studies that targeted taxa also on BCNWR, then they cannot be considered “more appropriate”. What were the treatments in Savelle and Heady (1970), DiTomaso (2008), McGarvy (2009), Battles et al. (in press) that were “more appropriate” to BCNWR than those in the Christian et al. study? What were the stocking rates in Savelle and Heady (1970), DiTomaso (2008), McGarvy (2009), Battles et al. (in press) that were “more appropriate” to BCNWR than those in the Christian et al. study?

Taeniatherum caput-medusae (subject of the DiTomaso (2008) study) has been documented or reported on BCNWR.

The clipping height used by Kimball and Schiffman (2003) is not “a problem” with the

14 Christian, C. E., Saslow, L. R., Pollock, J. F. and Doak, D. F. 2007. Conditional Impacts of Livestock Grazing on an arid California Grassland. Manuscript in preparation.

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study or study design (as seen by the authors) but rather is a limitation of its application to management practices. In fact, it provides evidence of what the stresses of poor livestock-grazing management may be. While the clipping height used by Kimball and Schiffman (2003) may be a simulation of poor livestock-grazing management, it is also a realistic simulation of at least some of the livestock grazing in the Carrizo area, based on recent photos taken on the Carrizo Plain Ecological Reserve, submitted by several conservation groups to California Department of Fish and Game (Kuyper et al. 2009). [I can provide a copy of the letter with attached photos.] Since such severe defoliation has and does occur in the area, the Kimball and Schiffman study is not an invalid examination of what may happen to the plants subjected to such severe condition. Paula M. Schiffman (personal communication to E.L. Painter) said that the original plan was to include clipping at a greater height but, in the years of the study, the vegetation did not get tall enough during the study period to allow that. Based on the years of the Christian et al. study (which overlapped with Kimball and Schiffman), there were cattle on CPNM in spite of the low production. Therefore, the severe defoliation simulated by Kimball and Schiffman may not have been unrealistic for what occurred on CPNM during those years. Since natural selection results from extremes, not averages, 1 cm is also not an unreasonable test of stress resulting from defoliation.

The authors provide no evidence that 300 to 600 lb/a typically represents a clipping level of 2.5 to 5 cm. Equivalent clipping level not discussed in Bartolome et al. so an additional citation is needed to support clipping level values.

While, as the authors indicate, a 1 cm grazing height would reduce litter (RDM) to less than 300 lb/a), this in fact would result in RDMs similar to those reported by Germano et al. (2003, 2004, 2006) for the Lokern study and the authors for BCNWR (often without livestock grazing). Germano et al. (2003) reported RDMs of 48, 159, 184, 194, 234, 262, 271 lbs/acre and Germano et al. (2004) reported RDMS of 50, 98, 110, 141, 148, 205) for 7 of 8 plots with no cattle. In Appendix E, the authors reported RDMs of 250 lbs/acre in Unit 2 NW in 2005, 25 lbs/acre in Unit 2 NW in 2006, and 184 lbs/acre in Unit 12 in 2005. Germano et al. (2006) reported 127 lb/acre that for treatment plot 29T – is this evidence of “poor grazing management” as defined by the authors? If so, why was this not worthy of the kind of discussion the authors presented for Kimball and Schiffman (2003)?

The Kimball and Schiffman (2003) study provided information on which Christian et al., Prugh and Brashares, Hayes and Holl, and others have drawn. Do the authors feel that it was inappropriate for these authors to have cited Kimball and Schiffman?

Effects of removal of mulch was another part of the Kimball and Schiffman (2003) study. Was there sufficient mulch and soil protection on the Germano et al. plots in 2003,

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2004, 2006 or on the BCNWR plots in 2005 or 2006? If not, why was there not on those plots with out livestock utilization (i.e., without severe defoliation similar to that simulated by Kimball and Schiffman).

It is not automatically necessary for clipping studies to include multiple clipping heights. It would have been necessary for Kimball and Schiffman (2003) to include multiple clipping heights if that were appropriate to their research questions. If the research questions did not include effects of different intensities of clipping, then multiple clipping heights would not have been needed.

When and did targeted grazing systems enter the discussion of Kimball and Schiffman (2003)? Kimball and Schiffman did not address them. The Kimball and Schiffman study would need to reflect the grazing levels that might be the objective of a well managed targeted livestock-grazing system only if that were appropriate to their research questions. This study was not designed to examine the well managed livestock-grazing systems, targeted or seasonal, and the objectives of their study did not include examining well managed livestock-grazing systems. Therefore, there was no need for them to simulate conditions of such a system, however much the authors might have wanted them to.

Kimball and Schiffman (2003) said that the negative effect of defoliation was evident after just one clipping, which suggested that “the presence or absence of herbivores, rather than the intensity of herbivory, determined community composition.” They concluded that the removal of biomass through cattle grazing can create profound changes in ‘grassland’ communities and that careful studies are necessary to document the responses of individual species and the entire community before initiation of any restoration attempts.

The authors should make clear that the discussion of what they feel should be the limitations on conclusions drawn by and from Kimball and Schiffman (2003) are their personal opinions. Given the conclusions that the authors have drawn from studies and those made in papers cited by the authors that were not actually supported by the methods and data, it is presumptive of the authors to lecture to other researchers on what conclusions they may or may not reach from their own data. Either the authors need to apply the same standards to every paper cited in this report, or they should refrain from criticizing what they do themselves.

While “[s]tudies of multiple intensities or clipping at different seasons and frequencies could provide new knowledge that could be used to design targeted grazing regimes that could reduce non-native annuals while attempting to maintain or increase native plant species”, this is not relevant to a discussion of Kimball and Schiffman (2003). This sentence should be moved to a portion of the report where it is relevant.

Since the Kimball and Schiffman study was not designed to provide information directly

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related to targeted livestock-grazing regimes, the authors could and should have looked at the data to see what could be garnered from the study. Quite a bit of information can be gained from this study related to the impacts of severe defoliation on a number of native and non-native plant taxa. This information can very useful in decision making at the species level. Certainly other researchers have drawn on this study, including Christian et al., Prugh and Brashares, Hayes and Holl.

It is unclear what the following statements have to do with the Carrizo Plain National Monument: “Grazing is a complex ecosystem process. To test the hypothesis that livestock grazing can be used as a tool to meet ecosystem objectives we must have knowledge of the effects of season, intensity, frequency and duration of grazing on ecosystem services. There is not enough time or money to study the effect of all of the combinations of these grazing parameters. But we can increase our chances of learning how to properly apply grazing if we manage grazing using an adaptive management approach that includes measurable objectives/hypotheses, appropriate monitoring and long-term involvement of university and agency researchers, some of whom understand grazing and ranching practices and their application.” “Grazing is an ecosystem process that results in environmental impacts. The mechanisms that result in environmental impacts are poorly understood by the public and by many conservation organizations that make public input to environmental assessments (EAs), environmental impact studies (EISs) and environmental impact reports (EIRs). While these reports are often well written, well researched documents, others base management plans on popular (but scientifically unsubstantiated) concepts (Painter 1995). While the public and interested parties have the right to make input, agency personnel who must process this public input need to seek outside assessments to establish the credibility of popular and peer reviewed science used to support their positions.” There only function this section seems to be to lead into yet another criticism on the Christian et al. and Kimball and Schiffman studies. If the authors had another purpose for including these statements in the report, the statements need to be moved to a section where they would be more relevant and more appropriate.

Vegetation Management Practices While it is understandable why one might want to use herbicides to reduce non-native taxa like yellow starthistle (Centaurea solstitialis). However, there is no reason why BCNWR should want to reduce native shrubs such as juniper (Juniperus) and rabbitbrush (Chrysothamnus s.l.). The latter are important native components in native vegetation on the Refuge.

Literature cited Is Bailey and Welling 2001, as cited in the chapter, the same as Bailey et al. 2001 listed in the literature cited?

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Is Battles et al. in press as cited in the chapter, the same as Battles in press listed in the literature cited?

Either Christian et al. is in preparation or it was completed in 2007, but it cannot be both

DiTomasso 2008 was cited in the chapter but omitted from the literature cited. Is DiTomasso 2008 as cited in the chapter, the same as DiTomaso et al. cited elsewhere in the report?

Painter 1995, Savelle and Heady 1970 are cited in the chapter but omitted from the literature cited.

CHAPTER 5 MANAGEMENT GOALS, OBJECTIVES, AND PROCEDURES Adaptive Management Unless most of this section is based strictly on the personal opinions of the authors, there needs to be a lot more literature cited. Do the authors have any references for studies of successful adaptive management involving livestock in California?

Unless the authors are directly parties to the Comprehensive Conservation Planning process, the sentence should read something like this: We recommend that, during the Comprehensive Conservation Planning process, the USFWS develop specific achievable and measurable objectives for each management unit at BCNWR and that these objectives be used to gauge progress. and performance.

When done correctly, adaptive management can require a great deal of expensive, manpower-intensive monitoring. There is usually a need for quite a bit of research. The monitoring and research should be linked.

For adaptive management to be successful, monitoring must be designed to assure that any adverse impacts are detected quickly.

In order to develop “feasible objectives”, managers (and authors of management plans) need to know a great deal more than ‘grassland’ history, restoration, and grazing management. They need to be familiar with all the vegetation history for their area, including a familiarity with the pertinent historical, ecological, and botanical literature, restoration literature beyond ‘grasslands’, and management beyond livestock grazing (e.g., vegetation management, rare plant and animal management, weed management).

Again, the authors need to admit that ‘restoration’ of non-native-annual-dominated vegetation might lead to shrublands and woodlands, as well as (or instead of) “ecosystems dominated by native annual and perennial plants”.

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Maintaining existing native plant species is not directly tied to testing grazing. The two would be separate objectives (and might be mutually exclusive in some parts of BCNWR).

Why did the authors omit native perennials and native trees from the ‘natives’?

Has livestock been shown to consistently reduce non-native annual grass competition with native plants with any of the non-native annual grass taxa or native plant taxa documented or reported on BCNWR? If so, which non-natives and which natives?

De Vries (2009b) described “vegetation types”, not “plant communities or series”, although some of the “vegetation types” were ‘series’ (sensu Sawyer and Keeler-Wolf 1995, whose nomenclature she followed).

How can a book published in 1990 document activities between then and 2005? Does Allbright (1990) provide any documentation of which parts of BCNWR were grazed and which parts were farmed? Does Allbright (1990) document when any such farming terminated? When I searched for Allbright (1990) on Google, the only record of it that comes up is this report.

There is location and often abundance information available and accessible for native (and non-native) plant taxa documented (vouchered) on BCNWR and not infrequently for reported plant taxa. Location and usually abundance is well documented for native (and non-native) plant taxa that are vouchered. De Vries (2009b) and Werner (1997) provided lists of specimens, which could facilitate the authors’ finding them and garnering label information. Thomas generously provided me with a list of specimens, and would probably do the same for the authors and BCNWR upon request. In addition, De Vries (2009a) provided information on which native (and non-native) plants had been found in each BCNWR management unit. De Vries field-notes (submitted regularly to BCNWR) contain location and often abundance information for each native (and non-native) plant taxon reported.

While it is true that “[n]atural and man-caused fires are hazardous to BCNWR facilities and resources and adjacent properties that depend on grazing for their livelihood”, since, as Huntsinger et al. (2007) pointed out, “[t]he effectiveness of grazing on fire behavior has not at this point been quantified…”, the relevance of the authors’ statement to this report (or their proposals for grazing on BCNWR) is questionable.

While it may be true that non-native annual plants compete with some (possibly many) of the native plants on BCNWR, the authors have provided documentation of non-native annual plants competition with only a few of the 405 native plant taxa documented or

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reported on BCNWR. Therefore, it is unclear how “we can be reasonably certain” that non-natives compete with “many” of the natives or many of the native dominants.

Potential Goals, Objectives and Procedures There are at least 3 more goals that are needed: Conduct comprehensive surveys for all animal taxa (including mammals, reptiles and amphibians, birds, insects, etc.) Conduct comprehensive surveys for all plant taxa (including vascular and non- vascular plants) Conduct comprehensive surveys for biological soil crusts

Comprehensive surveys for all animals and plants (including special-status taxa), vegetation/plant communities (including composition), biological soil crusts, etc. should be completed before any management decisions concerning livestock are made.

It is as important to maintain populations of native perennial non-grass herbaceous plants, native annual herbaceous plants (including native annual grasses), native trees, and native shrubs as it is to maintain populations of native perennial grasses.

It is important to protect native plants and animals for whom habitat requirements may be known as well as those for whom habitat requirements are unknown or uncertain.

It is important in a survey for rare plant taxa to identify plant taxa below the species level. Examples (using 1st edition Jepson Manual nomenclature): Both Eremalche parryi subsp. kernensis and Eremalche parryi subsp. parryi are documented on BCNWR. The former is federally listed as Endangered, while the latter is not. If these taxa had been identified only to species, a very rare, federally listed taxon would have been missed. Both Caulanthus coulteri var. coulteri and Caulanthus coulteri var. lemmonii are documented on BCNWR. The former is not on CNPS lists, the latter is CNPS List 1B.2. Makes a lot of difference for management. If these taxa had been identified only to species, a rare taxon would have been missed.

Goal A: Conduct a baseline inventory of plant communities and plant species composition. Why map only ‘grassland’, oak, and juniper vegetation? What about the other vegetation types listed by De Vries (2009b)? Do the authors assume all of them would not be visible on aerial photographs?

Do the authors not feel that mapping each type or series of ‘grassland’ listed by De Vries (2009b) merits separate mapping? If so, why not?

There is no reason to limit recommended methodology sources, nor is it necessarily appropriate. Bonham (1989) and Cook and Stubbendieck (1986) are widely cited

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E.L. Painter 26 July 2010 sources for range methods. Hays et al. (1981) was originally designed for wildlife habitats and contains an extremely useful table with a matrix of habitat variables and appropriate techniques. Mueller-Dombois and Ellenberg (1974) and Greig-Smith (1964) are two widely cited ecological methods texts. CA DFG (2009) Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities is a frequently used methodology source in California.

The authors need to choose a single term to use for biological soil crusts (aka cryptogrammic crusts, cryptobiotic crusts, microbiotic soil crusts, microbiotic crusts, biotic crusts) and use it consistently, rather than using multiple terms.

US Fish and Wildlife Service (USFWS 1997, 2000), California Department of Fish and Game (CA DFG 2000), and California Native Plant Society (CNPS 2001) all provide protocols and guidelines for botanical field surveys and documentation. USFWS Guidelines (2000): “List every species observed and compile a comprehensive list of vascular plants for the entire project site. Vascular plants need to be identified to a taxonomic level which allows rarity to be determined” and “a comprehensive list of all vascular plants occurring on the project site for each habitat type”. CA DFG Guidelines (2000): “A floristic survey requires that every plant observed be identified to the extent necessary to determine its rarity and listing status. In addition, a sufficient number of visits spaced throughout the growing season are necessary to accurately determine what plants exist on the site. In order to properly characterize the site and document the completeness of the survey, a complete list of plants observed on the site should be included in every botanical survey report”. CNPS Guidelines (2001): “A floristic survey requires that every plant observed be identified to species, subspecies, or variety as applicable. In order to characterize the site properly, a complete list of plants observed on the site shall be included in every botanical survey report. In addition, a sufficient number of visits spaced throughout the growing season is necessary to prepare an accurate inventory of all plants that exist on the site. The number of visits and the timing between visits must be determined by geographic location, the plant communities present, and the weather patterns of the year(s) in which the surveys are conducted.” In addition, the Endangered Species Recovery Program at California State University Stanislaus has also prepared survey guidelines (Cypher 2002).

Goal C: Protect special status taxa and manage suitable habitat Why are special status plant taxa not included in Goal C?

If the authors are going to recommend estimating RDM rather than actually measuring, then they must also recommend regular ‘calibration’ of estimates (and cite appropriate methodology on doing so). Cook and Stubbendieck (1986) pointed out that doing ocular estimations requires considerable time checking estimates against actual data

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and that one can improve reliability by checking estimates daily. Cook and Stubbendieck also pointed out that estimates are “subject to personal error among individuals and for the same individual at different times”.

Goal D: Reduce fire hazard Unless the authors can come up with evidence that, in California, livestock grazing has been demonstrated to reduce fire hazard, Goal D (reduce fire hazard) is a red herring that will stir up unnecessary controversy. Huntsinger et al. (2007) pointed out, “[t]he effectiveness of grazing on fire behavior has not at this point been quantified….”

Goal E: Maintain native perennial grass populations Eremalche parryi subsp. kernensis (Eremalche kernensis) has been documented in Management Units 2 and 6 (as well as 11). Conservation of this Federally endangered plant needs to be considered in any management plans for these units.

Estimations of RDM at the end of the growing season will not provide any information on whether native perennial grass populations are being maintained. To do this, on-the- ground data would have to be collected, using quadrats or line-transects (as appropriate) and identifying individual plant taxa.

If the authors are going to recommend estimating RDM (or any other parameter) rather than actually measuring, then they must also recommend regular ‘calibration’ of estimates (and cite appropriate methodology on doing so). Cook and Stubbendieck (1986) pointed out that doing ocular estimations requires considerable time checking estimates against actual data and that one can improve reliability by checking estimates daily. Cook and Stubbendieck also pointed out that estimates are “subject to personal error among individuals and for the same individual at different times”.

Why do the authors think that moderately grazing management units with native perennial grass patches would (or could) reduce fire hazard? Since there is not quantitative evidence, this might only be a recommendation to damage native perennial grass species, including those reported to be negatively impacted by or to decrease with livestock grazing (see Bitter Creek plants livestock worksheet), e.g., Achnatherum speciosum, Bromus carinatus, Melica imperfecta, Poa secunda (and sometimes Nassella pulchra).

Do the authors have documentation that livestock would preferentially consume Bromus madritensis subsp. rubens, while not consuming the native perennial grasses (which would be needed if livestock were to reduce competition to the latter). Van Dyne and Heady (1965) reported that, in their study, livestock preferentially ate the perennials. Have there been additional studies that found the opposite? If native perennial grasses are preferentially grazed, reducing flowering in Bromus madritensis subsp. rubens compensate for damage to the perennials.

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Since, as the authors admit, using livestock grazing in this manner has been “little studied in red brome” so there is little (if any) evidence that this might be effective, is it worth the risk to native perennial grasses (and other plants, including some at-risk taxa, in these areas) to “test the effect” on a National Wildlife Refuge dedicated to the conservation of the native taxa and habitats15? While such experimentation may be useful, given the risks, it might be more appropriate if conducted elsewhere.

What method(s) would the authors recommend for surveying flower density? Is this density within or between plants? plots? What methodology source(s) would they cite? Why do the authors recommend line-point intercept to estimate ground cover of Bromus madritensis subsp. rubens? Is this basal cover or aerial cover? What methodology source(s) suggest this method? What methods would the authors recommend for estimating changes in native perennial grass density and patch size? What methodology source(s) would they cite?

Goal F: Maintain native forb populations Is it strictly the authors’ opinion that “close grazing” can “increase forb production and composition” or is there actually evidence? If so, why do they not cite it?

Is it strictly the authors’ opinion that “[m]ost forbs are suppressed by competition from taller growing non-native annual grasses” or is there actually evidence? If so, why do they not cite it?

Estimations of RDM at the end of the growing season will not provide any information on the production and composition of ‘forbs’. To do this, on-the-ground data would have to be collected, using quadrats or line-transects (as appropriate) and identifying individual plant taxa.

If the authors are going to recommend estimating RDM rather than actually measuring, then they must also recommend regular ‘calibration’ of estimates (and cite appropriate methodology on doing so). Cook and Stubbendieck (1986) pointed out that doing ocular estimations requires considerable time checking estimates against actual data and that one can improve reliability by checking estimates daily. Cook and Stubbendieck also pointed out that estimates are “subject to personal error among individuals and for the same individual at different times”.

Goal G: Maintain, protect and enhance riparian areas. What is a ‘grassland riparian zone’? Is this a recognized vegetation type? De Vries (2009b) included riparian scrub and red willow series (a series within riparian forest and

15 “The mission of the System is to administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.” National Wildlife Refuge System Improvement Act of 1997, Public Law 105–57—October 9, 1997

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woodland in Sawyer and Keeler-Wolf 1995) among the vegetation types observed on BCNWR but not “grassland riparian”.

Goal H: Manage invasive weeds other than annual grasses (e.g. Yellow starthistle Centaurea solstitialis) Which weeds documented or reported on BCNWR do the authors feel need to be managed? Is there management literature available for these?

If the authors are going to recommend estimating density rather than actually measuring, then they must also recommend regular ‘calibration’ of estimates (and cite appropriate methodology on doing so). Cook and Stubbendieck (1986) pointed out that doing ocular estimations requires considerable time checking estimates against actual data and that one can improve reliability by checking estimates daily. Cook and Stubbendieck also pointed out that estimates are “subject to personal error among individuals and for the same individual at different times”.

Goal I: Protect native plants and animals with unknown or uncertain habitat requirements Authors need to define ‘functional group’. Do they think that most or all members of these groups actually biologically, physiologically, and/or ecologically function ways similar enough to lump them?

Where did the number 400 come from?

“no grazing” and “heavy grazing” are not ground vegetation levels (although they may cause them).

Define ‘standing crop’.

RDM will not predict or confirm that native plants and animals are being protected? Define ‘standing crop’.

Define ‘indicators’? Which plants and animals to the authors recommend be utilized as indicators? How do they recommend selecting them? What monitoring techniques do the authors recommend to “[m]onitor and compare indicators of plant and animal abundance”? Which methodology source(s) do the authors recommend to select and establish these techniques?

CHAPTER 6 RANGELAND INVENTORY AND MONITORING Introduction

If monitoring should be based on measurable objectives, why do the authors sometimes recommend estimating (rather than actually measuring).

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Why would a National Wildlife Refuge like BCNWR want to decrease Juniperus cover? Is this an example of a measurable objective that the Refuge would consider or the authors recommend? If not, the authors should replace this example with something more appropriate.

How does RDM (a measure of what is left not what has been removed, i.e., ‘used’) establish a record of annual use of plants by livestock? Define ‘annual-use’.

Resource Inventory All English units (feet, inches, degrees F, etc.) need to be followed by metric units (meters [m], centimeters [cm], degrees C, etc.).

Resource inventories should be completed before any management change that might affect the resources is implemented.

Resource inventories need to include all biological ‘resources’, e.g., all animals (vertebrate and invertebrate), and plants (vascular and nonvascular, including lichens), biological soil crusts.

The inventory of cultural resources, including both pre-settlement Native American sites and artifacts, as well as current and past structures such as buildings, roads, and fences.

In addition to seasonal vegetation productivity, daily temperature and precipitation examined over time can help explain changes in relative plant and animal abundances, apparent presence and absence of some plant taxa, etc.

Vegetation surveys are NOT same as floristic (plant taxa) surveys. The two should never be confused or used as synonyms.

Of the surveys listed, only Lawrence (1983) could be considered a vegetation survey that also resulted in a plant taxa list. Werner (1997) and De Vries (2009b) were floristic surveys that also provided some vegetation information.

Werner (1997) and De Vries (2009b) both provided some vegetation information, but neither contained results of a comprehensive systematic vegetation survey of BCNWR.

Although De Vries (2009b) did not formally survey vegetation nor did she formally delineate/classify vegetation types on BCNWR during her floristic survey, she did provide information on the vegetation types what she observed. De Vries (2009b) described “vegetation types”, not “plant communities or series”, although some of the “vegetation types” were ‘series’ (sensu Sawyer and Keeler-Wolf 1995, whose nomenclature she followed).

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My working file is a continuously updated Excel spreadsheet. It is not and was not a formal report to USFWS or BCNWR. I shared it with the advisory committee as a source from which committee members or USFWS might extract information. I did not expect it to be incorporated into this report. The authors did not include it in the Literature Cited for this section. As far as I can determine from my files, the authors did not seek nor did I give permission for this working document to be used. My working file includes not only taxa from the reports listed but also herbarium records. This needs to be included to make the statement accurate. The December 2009 list (included by authors as Appendix B without attribution) has been updated several times and an updated was provided to the authors 13 May 2010.

While the plant taxa lists usually do not provide information on details of abundance, density, or location, location and usually abundance is well documented for the BCNWR native plant taxa that are vouchered. If the authors (or planners) are interested in the available relative abundance information, they need only look at the labels on the herbarium specimens (or, in many cases, contact the collectors).

All plant locations should be GPS’d.

Vegetation Mapping Extensive and comprehensive vegetation surveying in needed before mapping suitable for most management purposes can be developed.

There has been only one, rather rudimentary, vegetation survey done. Lawrence (1983) did vegetation surveying, using line transects. He divided the vegetation he surveyed into four ‘vegetation types’: ‘trees’, ‘shrubs’, ‘grass’, ‘forbs’.

Because composition usually cannot be determined from aerial photography, the maps generated would be rather general (i.e., ‘grassland’, herbland, shrubland, savanna, woodland) and quite probably would not provide sufficient information for most purposes.

How does one distinguish juniper from scrub oak in an aerial photograph? Are there publications the necessary characters for such a distinction, or would one have to hire experts?

All vegetation maps would need to be ground-truthed. In addition, ground surveys may be needed to distinguish between types of ‘grasslands’, etc.

De Vries (2009b) described “vegetation types”, not “plant communities or series”, although some of the “vegetation types” were ‘series’ (sensu Sawyer and Keeler-Wolf 1995, whose nomenclature she followed).

Plant Species Composition

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Define ‘key area’. How would the authors recommend that ‘key areas’ be selected? What methodology source(s) would they cite for this? How many ‘key areas’ would be needed per unit area or vegetation type?

The authors need to choose a single term to use for biological soil crusts (aka cryptogrammic crusts, cryptobiotic crusts, microbiotic soil crusts, microbiotic crusts, biotic crusts) and use it consistently, rather than using multiple terms.

When would accounting for every plant taxon not be appropriate or desired?

The authors need to define and describe ‘modified Whittaker approach’. The primary reference for the ‘modified Whittaker approach’ is Stohlgren et al. 1995 (which is cited in Herrick et al 2005b: “For more information on the modified Whittaker approach, please see recent publications by Tom Stohlgren and others listed here in the References.).”

Survey rare plant species CA DFG (2009) Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities is a frequently used methodology source for conducting rare plant in California. Another source for plant population surveying and monitoring methodology is Elzinga et al. (1998), a technical report prepared for BLM.

Before one begins to survey for rare plant (or animal) taxa, one needs to determine what is already known. For plants, one should request from CNPS a list of rare plant in the USGS quads of interest and surrounding quads. One needs to check for lists for nearby areas (e.g., for BCNWR, the Carrizo Plain). One needs to obtain rare, sensitive, special status, at-risk lists from other government agencies managing land in the area (e.g., BLM or USFS). Using a list of ‘possible’ taxa prepared from these, one can then search the California Consortium of Herbaria web site for records from on or near the targeted area. Because not all herbaria are completely databased, visits to major and regional herbaria are also in order. For BCNWR, it known that there are specimens at Rancho Santa Ana Botanical Garden (RSA), California Polytechnic State University San Luis Obispo (OBI), Santa Barbara Botanic Garden (SBBG), University of California, Riverside (UCR), University of California, Berkeley (UC, JEPS), Victor Valley College (no acronym). While not all of the known specimens are of rare taxa, one should search for the rare taxa at each institution.

It is important in a survey for rare plant taxa to identify plant taxa below the species level. Examples (using 1st edition Jepson Manual nomenclature): Both Eremalche parryi subsp. kernensis and Eremalche parryi subsp. parryi are documented on BCNWR. The former is federally listed as Endangered, while the latter is not. If these taxa had been identified only to species, a very rare, federally listed taxon would have been missed.

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Both Caulanthus coulteri var. coulteri and Caulanthus coulteri var. lemmonii are documented on BCNWR. The former is not on CNPS lists, the latter is CNPS List 1B.2. Makes a lot of difference for management. If these taxa had been identified only to species, a rare taxon would have been missed.

Are the reasons that plants may be rare the authors’ personal opinions or did they get this from a literature source they should have cited? This looks like it was lifted from Fiedler (2001) or from Rabinowitz (1981). If so, then the source needs to be credited.

The authors need to define and describe ‘modified Whittaker approach’. The primary reference for the ‘modified Whittaker approach’ is Stohlgren et al. 1995 (which is cited in Herrick et al 2005b: “For more information on the modified Whittaker approach, please see recent publications by Tom Stohlgren and others listed here in the References.).”

There are plant taxa that are present or abundant enough to find only in some years, so surveys must be conducted of several years.

The authors need to prepare a section, with the same level of detail as given in the ‘survey rare plant species’ section for surveying rare animal taxa.

Residual Dry Matter RDM is only a measure of use during the year if comparative areas without grazing are also measured and if there are measurements from both the beginning and end of the year.

Photo-monitoring Would the “photos of RDM” be of the clipped material separate from the site or of the plots before they are clipped? “photos of RDM” would mean the former.

What do the authors mean by “reasonable rates of vegetation change”?

Vegetation Monitoring Publications There is no reason to limit recommended methodology sources for monitoring techniques, nor is it necessarily appropriate. Bonham (1989) and Cook and Stubbendieck (1986) are widely cited sources for range methods. Hays et al. (1981) was originally designed for wildlife habitats and contains an extremely useful table with a matrix of habitat variables and appropriate techniques. Mueller-Dombois and Ellenberg (1974) and Greig-Smith (1964) are two widely cited ecological methods texts. CA DFG (2009) Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities is a frequently used methodology source in California.

Literature cited At least on citation in the chapter was omitted from the Literature cited.

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Appendices Appendix A. Grazing and Haying NWRS Legal and Policy Considerations Since not all of the legal and policy considerations discussed in the appendix are directly related to livestock grazing or haying, a more appropriate title might be the following: NWRS Legal and Policy Considerations Directly or Indirectly Related to Livestock Grazing and Haying

I could find no mention of haying in the 2006 or 2008 draft EAs. If haying is not under consideration for BCNWR, why include the ? If there is direct relevance, it should be made very clear. If there is not, then discussion of haying is a red herring and all mention of it should be deleted.

What is meant by ‘decadent’ grasses? Decaying, aging, or senescent grasses? If so, one of those adjectives would be preferable. The term ‘decadent’ implies unrestrained gratification or self-indulgent as well as decline or decay. I found no record of geese or sandhill cranes being documented or reported on BCNWR, so why should the Refuge be concerned with removing such grasses?

Appendix B. Bitter Creek National Wildlife Refuge plant taxa The authors fail to credit me with the list in the appendix. There is no citation/attribution with the title for the appendix. As this appendix title reads now, it would appear that they, not I, had done this work.

As far as I can determine from my files, the authors did not seek nor did I give permission for this working document to be used. I shared it with the advisory committee as a source from which committee members or USFWS might extract information. I did not expect it to be incorporated into this report. My working file is a continuously updated Excel spreadsheet. It is not and was not a formal report to USFWS or BCNWR. If the authors are going to include a working document in their report, they need the compiler/author’s permission.

The December 2009 list has been updated several times and an updated was provided to the authors 13 May 2010. The authors need to include the date on which this file was generated as part of the citation/attribution.

Appendix D. Record of San Joaquin Kit Fox sightings at Bitter Creek National Wildlife Refuge. Citations or additional information are necessary to make clear the source(s) of the sightings information.

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Appendix E. Bitter Creek National Wildlife Refuge residual dry matter (RDM) monitoring data. A citation or additional information is necessary to make clear the source(s) of the RDM data. Methodology (with references) needs to be cited, so that one can determine such necessary information as whether data were collected or estimated, size of quadrat, dates of data collection, and frequency of calibration (with estimations). Without citations and methodology, these data are of little (if any) use.

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