By FAX (760)-252-6099 Eight pages total.

Copyright © 2007 by Craig Dremann, all rights reserved, including electronic transmission, and posting on the web.

[Please note: Since the BLM Barstow office claims to never have received this FAX, I will be copyrighting the information in this protest, for the future. If you wish to use this information for any purpose, including obtaining a grant to research what I am outlining in this protest, or wriuting a research paper, you need to pay a fee and get a license from Craig Dremann, Box 609, Redwood City, CA 94064 (650) 325-7333]

TO: BLM Barstow Field Office, Attn. Anthony Chavez, Range Ecologist
2601 Barstow Rd., Barstow, CA 92311. Phone (760) 252-6000

Date: July 27, 2007


My name is Craig Dremann, a resident of California since 1956, an Ecological Restoration professional consultant, with my mailing address at Box 609, Redwood City, California 94064 phone (650) 325-7333. I am an interested party, concerned about the management and conservation of the native perennial grass resources on the public lands of my State.

Definition: The three California BLM Desert District allotments, "Shadow Mountain", "Pahrump Valley" and "Stoddard Mountain" hereafter, the "three BLM allotments".

The new issues being protested, regarding the "Three BLM Allotments" is that they all lack adequate scientific standards, guidelines, grazing rules and ecosystem health assessments, to measure any impacts of exotic animal grazing on native ecosystems.

I am protesting that any of these three allotments be allowed to conduct any further grazing, until an adequate measured scientific assessment is conducted on the native grass populations and of the soil phosphorus levels of each allotment, to evaluate the past damages, and to be able to determine if any of these three BLM allotments are healthy enough, to continue to be grazed.

BLM's own documents, state that any decision to issue a grazing permit must be based on sound resource management guidelines. However, none of the three BLM allotment documents contain any direct measurement of the native ecosystem especially the perennial native grasses, nor are there any measurements of the soil phosphorus nutrient conditions, which are basic to management of any grazed area.

Any grazing rules, standard, guidelines and ecosystem health assessments absolutely must have some scientifically measurable links directly to the native grasses and the soil phosphorus nutrient conditions.

Otherwise, when there is no scientific way to measure the impacts of grazing on the native ecosystem, or measurements of the soil phosphorus nutrient levels---then all the rules, standards, guidelines and health assessment are completely arbitrary.

Until adequate native grass health measurements and soil phosphorus nutrient measurements are conducted of each of the three BLM allotments, then grazing must cease.

Grazing should only resume when it is found that each allotment is healthy in both its native grass populations and its soil phosphorus nutrient levels, to be able to continue to be grazed. Furthermore, a system of periodic measurements must be made in the future to monitor the native grass community health, and the soil phosphorus nutrient levels.

PERENNIAL NATIVE GRASSES as a ecosystem health indicator. It is well established for the last 100 years in the writings of grazing ecologists, that perennial native grasses are excellent indicators of ecosystem health, for exotic animal grazing management. The perennial grasses usually will be the first plant family to be utilized, so are good indicator species for both rangeland health and long term monitoring.

The record Mojave desert rainfall in 2005, gives range ecologists an excellent benchmark, to utilize for Mojave ecosystem monitoring. Any native perennial grass seeds in the soil that could germinate, did germinate that year.

ECOSYSTEM HEATH QUESTIONS that could be used to measure the health of the perennial native grasses on the three BLM allotments:

1.) Any native grass species still occur on any of the allotments? What is the age-class of those stands, based on basal diameter of 100 randomly selected plants?

2.) Did native grass seedling result from the 2005 rainfall on any of the three BLM allotments? If no native perennial grass seedlings are found on any allotment, that allotment should be retired from grazing.

3.) What is the expected longevity of the seeds of those different native grass species? 5-10 years if stored in dry, room-temperature laboratory conditions?

4.) Allowing the grass plants to reproduce periodically? If 5-10 years for the longevity of the seeds of the native grass species is the expectation, are each of the three BLM allotments rested for at least one good rainfall year out of a 5-10 year time frame, so that the native grass plants present can produce a crop of seeds, to replenish the soil-seedbank, so that new seedlings will grow within the next good rainfall year?

SOIL PHOSPHORUS NUTRIENT LEVEL questions that could be used to monitor the levels of that critical nutrient.

Soil phosphorus nutrients have a fixed threshold number for each species of native plant and exotic plant on the planet. And within a single species, like a native perennial grass, there are several sub-thresholds:

1.) Soil phosphorus nutrient level that is required in order to seedlings of the species to germinate, survive, and for adult plants to get established and reproduce. Since phosphorus is not as mobile nutrient in a desert ecosystem, the soil levels must be right within the seed's reach of its first roots, otherwise it will germinate and die. Pictures at

2.) "Dremann's GRADE A" - NATIVE GRASS SEEDLING SURVIVAL LEVEL. What is the minimum threshold levels of soil phosphorus for each of the various native grass species, found on the three BLM allotments, required for seedling survival?

Measurement of the soil nutrient levels could be conducted around areas where [after the record rainfall] the 2005 native grass seedlings germinated and survived, like the Desert Stipa and Indian Ricegrass along the northern edge of Highway Cal. 58 east of the town of Mojave, for example, to determine these threshold levels.

A second, and lower threshold level for soil phosphorus is where old perennial grass plants still survive, but where the phosphorus level is too low for native grass seedling survival and recruitment. Soil samples could be made around any old populations from the three BLM allotments to determine this threshold level.

4.) "Dremann's GRADE C" - NO MATURE NATIVE GRASS SURVIVAL LEVEL. A third and lower threshold, is where the soil phosphorus nutrient level is too low even for mature native grass plant survival. This is easily measured in areas nearby an existing native grass population that isn't reproducing, a few yards away from the plants.

For example, a May 1992 test of soil at Halloran Summit under mature desert stipa plants was 26 ppm phosphorus, and dropped to only 9 ppm where the grasses didn't exist, only a few feet away.
5.) "Dremann's GRADE D" - ONLY FILAREE OR SCHIMUS SURVIVAL LEVEL. A fourth soil phosphorus nutrient level, is where the perennial grasses can no longer survive, but where the annual weeds like filaree or Schimus can grow in good rainfall years in the shrub interspaces.

6.) "Dremann's GRADE F" - ONLY SAHARA MUSTARD SURVIVES. A sixth soil phosphorus level, is where the annual weeds like Filaree or Schimus cannot survive within the shrub interspaces, but where new exotics like the Saharan mustard or Brassica tournefortii, is able to. Soil tests in 2005 showed that the Sahara Mustard can grow in soil, with only 65% of the minimum nitrogen level, 70% of the minimum phosphorus level, and 46% of the minimum potassium level necessary for Filaree's survival.

The major source of soil phosphorus in soil, is animal bones, and that is the major source of circulating phosphorus in a particular area, accumulated over the last 10,000 years of animals dying on that spot.

The deserts like the Mojave, for the last 10,000 years, has had a low level of animal biomass dying each year, adding to the overall soil phosphorous levels.

Grazing of these low-phosphorous soils, by exotic cows and sheep, and not bringing back to the desert their bones, after they have been slaughtered, causes a "mining" effect on the phosphorus.

Grazing and not returning the bones, can mine the soil phosphorus levels, below the thresholds needed by the desirable native plant seedlings, like the perennial grasses.

EACH OF THE THREE BLM ALLOTMENTS shrub interspaces should be surveyed to determine the soil phosphorus mining grade that current exists, Dremann's "A" to "F".

Allotments with Grade Dremann's "B" to "F" must be retired, and Dremann's Grade "A" needs to be closely monitored so that the soil phosphorus removed from further grazing, doesn't push the nutrient levels below the reproductive threshold levels, into Dremann's Grade "B" or lower.

REPLACING the mined soil phosphorus every year to each of Dremann's Grade "A" allotments, by paying for bone meal and the cost of its application in relationship to the amount of phosphorus removed by the permittee's exotic grazing animals.

Unless the phosphorus soil bank levels are maintained in balance, the mining process that occurs with grazing, with cause the land to degrade to a permanent state that will eventually only support exotic weed species in the shrub interspaces, when the phosphorus drops below the threshold for native seedling survival.

CONCLUSION: The STANDARDS, GUIDELINES, GRAZING RULES and ECOSYSTEM HEALTH ASSESSMENTS for all of the three BLM allotments, are inadequate, because they do not contain any native perennial grass health, reproductive management or monitoring, and do not contain any soil phosphorus nutrient management or monitoring.

Respectfully submitted

Craig Dremann

[Attached: Maps of the three BLM allotment attached. ]

Updated December 27, 2009