Sierra Club Grazing Team Comment onProposed Agriculture and Food Policy

INTRODUCTION

The Sierra Club Grazing Team appreciates the opportunity to comment on the proposed“Agriculture and Food Policy” that has been developed by the Sierra Club Agriculture and FoodPolicy Task Force. While much of the proposed language in this policy is useful and valuable, theSierra Club Grazing Team believes that some of the proposed policy language concerning LivestockProduction and Grazing displays inadequate understanding of the widespread, adverse impacts oflivestock production on federal public lands. We have included a review of the wide-ranging adverseimpacts of livestock production on federal public lands for the benefit of the Sierra Club Agricultureand Food Policy Task Force. This review, included explicitly for this process, is presented below inAppendix A.

I. General Comments about the proposed “Agriculture and Food Policy”

To start, we must express our concern about the level of assertion that is made with regard to livestock production and grazing. Without an accompanying document that substantiates the claims made in this proposed Agriculture and Food Policy, the proposed language amounts to multiple assertions about livestock grazing with multiple unexamined assumptions embedded in them. These livestock-related assertions and assumptions should be substantiated, and the evidence defending them presented publicly (or at least presented to the SC Grazing Team) before such assertions and language are even considered by the SC Board of Directors for adoption. This process has put the burden of proof on the SC Grazing Team to refute multiple livestock-related assertions and assumptions presented by the Ag and Food TF. This process reflects negatively upon the Sierra Club. Nonetheless, the SC Grazing Team has already produced memos that address many of the claims asserted, and these (along with additionalrecent information summarized below) should be evaluated by the Ag and Food Task Force in revising the proposed Ag policy.

Despite the fact that ecological condition (and the inevitable negative impact of livestock grazing) occurs as a result of the activity without regard to land ownership, the policy section concerning livestock should apply explicitly only to privately-owned lands, or at the least, private and non-federal public lands. Any new livestock-related policy proposal language directed toward Federal public lands, if it should be developed, should be pursued by a different task force at a different time. If pursued, it should be done in close consultation with SC Grazing Team members, who collectively have decades of experience on-the-ground. SC Grazing Team members have a comprehensive competency with respect to the full body of scientific literature informing an understanding of the activity, landscapes, and wildlife at issue. They also have an extensive understanding of administrative, legislative, and judicial policy informing existing livestock management on federal public lands. Needless to say, SC Grazing Team members should be appointed to such a task force if one is created in the future.New livestock-related policy language directed toward Federal public lands should not be developed at all unless it can be justified with a scientifically compelling rationale that is publicly disclosed to all SCmembers.

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Finally, to the extent that the proposed Ag Policy mentions or refers to livestock grazing on federal public lands, it should ONLY reference the Club’s 2000 Grazing Policy, “Grazing on Public Lands,” Adopted Sep 23, 2000). ANYTHING else (even simply repeating language contained in that Grazing Policy) would appear to be superseding the authority of that 2000 Grazing on Public Lands Policy.

II. Particularized comment about the proposed “Agriculture and Food Policy”

Proposed policy language:

Livestock Production and Grazing: the production of domesticated meat and animalproducts has a significant potential for environmental degradation because productioncan require large inputs of many types. Especially in Concentrated Animal FeedingOperations (CAFOs), pollution related to the production can be grossly disproportionateto the amount of food produced. Protection of air quality, water quality, soil productivityand health, wildlife habitat, energy conservation and food safety and quality must be thehighest priority (Grazing on Public Lands Policy).

Comment:

The 2000 SC Grazing on Public Lands Policy does not address food safety and quality, does not directly address air quality, nor does it address energy conservation. Why is the policy being referenced here in this manner? Concerning the relationship between water quality, water quantity, and livestock production, we wish to bring to your attention two recent publications that thoroughly explore this nexus:

“Big Cattle, Big Gulp: Cowboys and cows are soaking the American West dry” by Christopher Ketcham , February 4, 2015, New Republic, at http://www.newrepublic.com/article/120915/american-west-drought-being-worsened-livestock-industry

and “Water for animal products: a blind spot in water policy” by Arjen Y Hoeksta , Environmental Research Web, Jan 27, 2015 at http://environmentalresearchweb.org/cws/article/opinion/59984

Proposed policy language:

Animal grazing systems that mimic the natural ecosystems which created healthy soils,sequestered large amounts of carbon and fostered biodiversity are the preferred livestockproduction systems.

Comment:

This is essentially impossible to do with domestic livestock. Natural ecosystems have a grazing "system" with multiple animals all feeding in the same area. For instance, on the Great Plain—the most tolerant plant community for grazing animals—the grazing system included ground squirrels, prairie dogs, grasshoppers, rabbits, geese, deer, pronghorn, elk, and bison--and even a few more herbivores. On top of these native herbivores, there were ecological processes like wildfire that "consumed" grasses as well. Each of these species ate different plants at different times and had a completely different influence than domestic livestock.

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For the most part, all these native animals are greatly reduced in their influence and remain that way to accommodate domestic livestock forage needs. For instance, grasshoppers are sprayed, prairie dogspoisoned, bison kept from reoccupying public lands, and so forth, primarily to accommodate private individuals and companies utilizing public resources for their private profit.

Concerning the Great Plains, bison once roamed the landscape, but they were not penned, fenced, nor otherwise encumbered. The wild bison behavior of the past is not analogous to that of currently domesticated, managed livestock. The burden of proof should be on the Ag and Food TF to demonstrate that the former can be replicated by the latter.

In general, the proposed language appears to presume that Savory-type Holistic Management (HM) systems can be successfully used to mimic natural ecosystems. We are dubious that these presumed animal grazing systems can really generate a realistic mimicry. We doubt that they are viable and ecologically-valid solutions for livestock-induced degradation on federal lands, as well as viable systems for significantly promoting increased soil-based carbon sequestration. The ubiquitous fact on-the-ground is that federal land managers are unable to effectively manage livestock grazing with even the most meager terms and conditions prescribed (See Appendix A, note 2), let alone with the hyper-intensive management prescriptions necessary to maintain even the pretense of ecological mimicry associated with bison behavior across the landscape. Such management, even if it were possible, is economically unviable—the notion appears to us as both an economic and ecological absurdity. Again,documentation supporting such claims must be presented and be subject to scrutiny.

Proposed policy language:

1. Properly managed livestock grazing can be an appropriate activity on many publicand private lands which are suitable for sustained-yield forage production, and often areunsuitable for row-crop production.

Comment:

A succinct critique of the proposed language in this section, and how it would undermine the core policy statement of the SC Grazing on Public Lands Policy, is included below in Appendix B. The statement proposes the elimination of the words “public and” in this section. An alternative to deleting the words “public and” is the inclusion of the word “non-federal” before the word “public.” For the Sierra Club activists on the ground monitoring the condition of millions of acres of federal public land,“Properly managed livestock grazing” is a novel concept (See again Appendix A, note 2). On public lands, it is important to question the baseline, that is to say: Do livestock-grazed landscapes—no matter the speculative management prescriptions—exhibit higher quality and quantity conservation values than non-grazed landscapes? The Grazing Team is privy to no such situation. Even if there are acute, aberrational landscapes somewhere where proponents might be able to cite solid scientific literature supporting such a notion, it begs the question: Should the Sierra Club adopt a position that is so contrary to the vast majority of scientific literature demonstrating contrary impact to conservation values? Is it wise to allow such an exception to swallow the rule as a matter of Club Policy? No. An analogy would be akin to the Sierra Club adopting a permissive policy relating to the consumption of fossil fuels in response to Climate Change simply because there is an industry-sponsored scientist somewhere willing to cast aspersion on the causal relationship between use of

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fossil fuels and climate change. The Sierra Club needs to consider the background and conflicted interests of the proponents of such language. It is not good policy.

Proposed policy language:

2. Pastures and rangelands should be stocked and managed to provide sustained-yieldforage production, to increase soil organic carbon over time, and to support healthy anddiverse wildlife populations.

Comment:

There is no evidence that livestock grazing of any sort is really sustainable in the long haul or that it supports heathy and diverse wildlife compared to rangelands managed exclusively for wildlife. Of course, the phrase above should be modified to be applicable only to private lands. But even on privatelands, the best that can likely be achieved is better management, as opposed to a meaningful promotionof ecological sustainability and wildlife.

There is no clear evidence that livestock grazing can consistently and significantly enhance soil carbonstores. A thorough exploration of this complex topic is included in Appendix C, Part 1, written by George Wuerthner (Grazing Team member and Senior Scientist for the Foundation for Deep Ecology.)

Moreover, the language above presumes that livestock grazing can be managed to generate net Green House Gas/Global Warming Potential gas reductions. Such a claim is contradicted by a Grazing Team-authored critical analysis of the Franzluebbers and Stuedemann (2009)paper provided below, in Appendix C, Part 2.

Finally, how do domestic livestock support healthy and diverse wildlife populations, especially when such livestock consume and degrade plant and soil resources needed by wildlife populations? The core statement of the Sierra Club Grazing on Public Lands policy acknowledges an essential reality: Livestock grazing on federal public land is, for the most part, fundamentally at odds with providing a place for native wildlife and plants. One cannot be putting the vast majority of forage into the belly of exotic animals without harming native species. Our federal public lands should not be managed as domesticated landscapes! (See Appendix A.)

Literature purporting to support the notion that livestock grazing will consistently generate higher soil carbon sequestration relative to “no grazing” treatments and nullifying factors such as livestock-associated methane emissions should be disclosed to the Sierra Club and be subject to scrutiny prior tothe adoption of the above language.

Again, even if the SC is to adopt the above language, it needs to include the qualifier: “Private and non-federal public” immediately prior to the first word “Pastures.”

Proposed policy language:

3. Appropriately managed, grazing can have a significant positive role in building soilorganic matter, increasing plant and wildlife biodiversity and weed management;

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Comment:

As we argue throughout this comment, managed livestock grazing does not usually generate significantly different results in building soil organic matter when considered in relation to un-grazed treatments and nullifying factors such as livestock-related methane emissions. There are some situations where livestock grazing may shift plant communities toward dominance by species like blue grama that promote enhanced soil carbon sequestration (as in short-grass prairie), but diversity is usually not increased in these situations—livestock grazing usually decreases native plant biodiversity in these cases!

In terms of weed management, the livestock grazing “solution” is a red herring. While this matter callsfor a nuanced perspective, livestock grazing has usually only worked to reduce weeds in very small exclosures, and only after the weeds have virtually taken over. The reason for this narrow range of success is that livestock prefer to eat the desirable plants first, so livestock harm the desirable native vegetation as well. The times that livestock grazing works best for weed control is in very well-defined situations where livestock can be controlled. These limited situations simply do not apply to 99.9% of federal public lands.

More generally, livestock are well-known as a major vector for weed transmission. (See Appendix A, sub-note 8 for more on this issue).

As noted above (and in Appendix C), skepticism towards the soil sequestration claim is warranted, especially if grazed areas are compared with un-grazed areas. For instance, Teague and his co-authors(see Teague, et al. 2011, Appendix C, Part 3 below) document the carbon sequestration benefits of light-to-moderate multi-paddock grazing treatments relative to continuous grazing treatments, but not relative to the “no grazing” treatment.

As for the plant and wildlife biodiversity claims made here, livestock grazing is a well-known factor in contributing to declines in native biodiversity. (See Appendix A.) Also, the biodiversity language above fails to acknowledge that many low-seral plant indicator species that have been encouraged and promoted by livestock grazing typically are (and will be) displaced by later seral-stage native species as livestock pressure is reduced and eliminated. In other words, as previously-grazed areas recover from the adverse impacts of livestock grazing, biodiversity of plant species is likely to change and may technically decline according to a crude definition of biodiversity. This, however, often represents a healthier ecological outcome, especially in high elevation montane riparian meadows, which may become dominated by a smaller subsection of native sedges as meadows recover and vegetation seral stage increases.

The goal of “Sustainable grazing to promote sustainable production” (such as described in Item 13 under “Land Use”) often leads to conversion of wild habitat into non-native, grass-dominated pastures. The resulting loss of biodiversity reduces the ecological functions of these areas, leading to a decline in wildlife populations. Further, the promotion of forage productivity often comes at the expense of riparian areas on wild lands. We should promote the potential of ecosystems to support wildlife and their needs.

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Once again, if the Sierra Club decides as a matter of policy to endorse ecological destruction on private land, inclusion of the qualifying language “on private and non-federal public lands” between “grazing” and “can” need take place.

Proposed policy language:

[I]ntensive rotational grazing with animals moved frequently can increase productivityby 50 percent, and also reduce infestations of invasive plants.

Comment:

No reason is given for why the Sierra Club would want to promote increases in livestock productivity. It should not. Livestock productivity is a wholly extrinsic consideration to that of conservation values except that livestock production is a destructive human impact. Again, the invasive plant claim is contradicted by much scientific literature. See: Appendix A, sub-note 8. The Sierra Club Grazing Team has an HM memo on file that challenges and refutes many typical claims concerning propriety and viability of these models. This memo and additional references to more recent critiques of HM are included in Appendix D.

Likewise, this argument for intensive grazing practices has been refuted in the scientific literature as well. The editor of the journal for the Society of Range Management was the lead author in a study thatlooked at all the independent studies of intensive grazing practices and found that these practices did not improve habitat conditions compared to other grazing practices. Reducing stocking numbers was the key way to improve habitat, not fiddling with grazing practices.

Here is the citation: Rotational Grazing on Rangelands: Reconciliation of Perception and Experimental Evidence D.D. Briske, J.D. Derner, J.R. Brown, S.D. Fuhlendorf, W.R. Teague, K.M. Havstad, R.L. Gillen, A.J. Ash, and W.D. Willms. Rangeland Ecology and Management 61:3–17 January 2008. Briske was the editor of this journal, and a member of the Grazing Team attended a presentation of his where this material was presented publicly.

Proposed policy language:

4. Grazing fees on public lands should reflect the total social, economic andenvironmental costs of the use of this resource.

Comment:

OK, but any statement concerning livestock grazing on Federal public lands should be deleted from this Ag policy.

Proposed policy language:

5. Grazing and pasturage, which recycle animal wastes back into the soil, have thepotential to transform vast amounts of coarse forages into food products. This traditionalsystem is more productive and less destructive than CAFOs, large-scale feed-grainproduction and feedlot operations which, while producing large quantities of food, alsohave solid waste management problems, cause air and water pollution, and consume

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excessive energy. Animals raised on perennial forage pastures cause far less soil erosionand nutrient loss compared with animals in confinement being fed crops from annualrow cropping.

Comment:

Probably accurate, but perennial forage pastures with livestock present will obviously manifest more erosion than uncropped lands with no livestock on them. This once again begs the question: Why is the Sierra Club affirmatively endorsing a human activity that is abusive to the land and conservation values? Even in the event that the Sierra Club believes that such activity is inevitable, purporting that the activity contributes positively to ecological and other conservation values is not accurate.

Proposed policy language:

6. Control of predators should be aimed at individual problem animals.

Comment:

This language needs to be stricken altogether. This language is patently offensive to the interests of the Sierra Club and a majority of its members, activists, and likely staff for myriad reasons. The use of the word “Control” when referring to the slaughter of predators is depraved. There is no such thing as a “problem animal” when referring to an agent of the wild, particularly where predators provide invaluable ecological contributions throughout their entire ecological communities.

In any case, this sentence alone is inadequate to address the broader problems posed by APHIS/Wildlife Services activities. A more thorough analysis and Sierra Club position concerning APHIS/Wildlife Services should be developed, but it should be done separately from this process, and with a different Task Force composition.

Proposed policy language:

7. CAFOs congregate large numbers of animals in relatively small and confined places,and substitute intensive management, an artificial diet, and heavy application ofprophylactic antibiotics and artificial hormones for traditional land and labor practices.Negative impacts include the release of toxic bioactive substances into the environmentand food chain, air and water pollution from animal wastes, degradation of moral valuesarising from the chronic inhumane treatment of animals, health hazards from noxiousfumes, and the diversion of cropland from direct production of human food. CAFOs alsoaccelerate climate change by their disproportionate production of greenhouse gases. TheSierra Club opposes the establishment of new CAFOs, and supports the phasing out ofexisting operations as expeditiously as possible.

Comment:

This is very good language. Still what is missing in this language is an acknowledgement that raising cattle and sheep is damaging no matter where and how it is done. This, of course, raises the following question: should the Sierra Club be endorsing any kind of animal agriculture?

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Proposed policy language:

8. The non-therapeutic use of antibiotics in livestock should be eliminated.

Comment:

Absolutely.

Proposed policy language:

Climate change and Agriculture: Climate change threatens the stability of our globalfood systems, as farmers depend upon relatively stable climate systems to plan forproduction and harvest.

Industrial agricultural and food system practices are a significant contributor to climatechange, and it is essential that they be reformed to minimize contributions to greenhousegases and maximize carbon sequestration in plants and soils. Livestock are the majorsource of greenhouse gases from agriculture, so minimizing the production andconsumption of domestic animals that produce the most methane is one way to reducegreenhouse gas production. Ruminants such as cows, sheep and goats produce the mostmethane (an extremely potent greenhouse gas), and most GHG emissions from livestockcome from cattle.

Comment:

This is good language.

Proposed policy language:

The diet of livestock can and should be managed in ways that dramatically reduce their methane production.

Comment:

If there is an approach to do this in a meaningful and economic way, it should be disclosed by the Ag ad Food TF? If not, then this language should be stricken completely.

More broadly speaking, this proposed language fails to acknowledge the depth and breadth of the problem at hand. Grass-fed beef produces more methane than CAFO operations. While use of supplements, alternate feeds, or multi-paddock grazing may be able to marginally reduce livestock-related methane emissions, methane emissions by livestock are likely to remain substantial. If one wants to dramatically reduce livestock-related methane emissions, one would feed livestock high-quality feed like corn and soybeans. But this approach has its drawbacks due to the GHG emissions associated with corn and soybean row-crop agriculture.

If the Sierra Club is seriously concerned about reducing methane emissions from livestock, it should “cut to the chase”: it should consider adopting a policy in the future that opposes livestock productionof any kind.

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Proposed policy language:

Livestock waste at Concentrated Animal Feeding Operations (CAFOs) should bemanaged to minimize greenhouse gas releases and to maximize soil carbonsequestration.

Soils are a highly effective means of carbon sequestration, but most agricultural soilshave had their carbon sequestration dramatically reduced by soil loss, excessive tillage,overgrazing …

Comment:

This general language does not suggest what level of livestock use will constitute overgrazing with regard to carbon sequestration reductions.

The proposed policy language continues:

… and extensive use of fertilizers. The world’s cultivated and grazed soils have lost 50–70 percent of their original carbon stock, and in the process released billions of tons ofcarbon into the atmosphere. Soil carbon should be rebuilt by employing regenerativeagricultural practices: low-till or no-till agriculture, cover-cropping, reducing oreliminating nitrous fertilizers (a major source of the very potent GHG nitrous oxide)eliminating overgrazing …

Comment:

Again, as noted above, even light-to- moderate multi-paddock grazing is inferior to no grazing concerning soil carbon sequestration—see Teague et al. 2011 and other sources as discussed further below in Appendix C.

Continued:

… minimizing soil erosion, and restoring soil carbon through compost and biochar areall important tools to promote soil carbon sequestration.

An improved soil carbon sequestration regimen can play a significant role in reducingatmospheric greenhouse gas build up and help bring the planet back to a safer 350 ppmcarbon regime.

Comment:

Again, the Teague et al. 2011 study (Appendix C, Part 3) indicates that “no grazing” is still preferable to any grazing regime, multi-paddock or otherwise. The Derner, Boutton, Briske 2006 study is also relevant here. It is not as conclusive as the Teague paper, but on two of the three grass types evaluated in the study, the “no grazing” treatments were still superior in terms of carbon sequestration relative to the grazing treatments. It should also be noted that the “two of the three grass types evaluated” alsocorresponded to the two types that contained the greatest amount of soil organic carbon, in each case containing more than double the amount found in the remaining grass type where the grazed treatment

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surpassed the un-grazed treatment. (See Justin D. Derner, Thomas W. Boutton, and David D. Briske, “Grazing and Ecosystem Carbon Storage in the North American Great Plains.”Plant and Soil (2006) 280:77–90. See in particular Figure 3, p. 85 for details.)

Last (but not least), a recent article by Paul Mahoney concerning cattle-related methane emissions reports research showing that one hectare of grassland in the Snowy Mountain region of Australia can absorb the amount of methane produced by only 0.162 of a cow. In other words, for livestock grazing there to remain “methane neutral”, the density of cattle cannot exceed 1 cow for every 6 hectares. (Go to article (Sec. 2.2) or http://terrastendo.net/2013/07/26/do-the-math-there-are-too-many-cows/)

Proposed policy language:

4. Land conversion from natural states to intensive agricultural operations should bediscouraged as it can change land from a carbon sink to a carbon source. Deforestation,plowing up of prairies, and filling of wetlands must all be avoided to reduce increasingcarbon emissions and releasing carbon from existing carbon sinks.

Comment:

OK.

Proposed policy language:

5. Reduction in consumer food waste, through reduction in serving sizes and diversion,redistribution and composting will also reduce greenhouse gas emissions.

Comment:

OK.

CONCLUSION

The Sierra Club Grazing Team is concerned that proposed language included in the “Agriculture and Food Policy” will impede the Grazing Team’s active efforts to educate members, the public, policy-makers, and federal public lands managers as to the ubiquitous impact associated with public lands ranching. This language will enable Sierra Club activities that will result in cross-messaging and dubious claims (unsupported by sound science and practicable reason) concerning the ecological consequences of livestock on native biota across federal public lands held in common trust. The Grazing Team hopes that our comment proves helpful in encouraging the Club to advance a policy that places the natural values of the landscape and wildlife as highest priority.

Please do not hesitate to give me a call if you have any questions or comment.

Brian ErtzChair, Sierra Club Grazing Team208.867.0185brian.ertz@gmail.com

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On behalf of all Grazing Team members (listed alphabetically):

Jim CatlinKen ColeEd DobsonVeronica Egan

Brian Ertz, Team LeaderBrock EvansJanet MaxwellAnne Millbrooke

Wayne HoskissonTodd ShumanGeorge WuerthnerChris Yoder

Appendix A: Public Lands Ranching

Public lands ranching is the most ubiquitous use of public lands in the country, occurring on over 250,000,000 acres of land, an area roughly the size of the states of California and Texas combined.

Whether you’re a public lands advocate, a wolf supporter, a bighorn sheep enthusiast, an angler or hunter, a Yellowstone buffalo activist, a recreationist or in any way interested in public lands—the wholesale abuse of a quarter billion acres of your public land affects you.

Permit and lease renewal of grazing permits may not seem like the sexiest issue, but it’s where the rubber hits the road on a myriad of habitat and wildlife conservation issues. Public lands ranching is theprinciple source of myriad habitat and wildlife conflicts in the western United States.

The conditions of public lands are disastrous across the West.

Federal agencies’ administration of public lands across the West has failed to meet very basic environmental standards as directed by Congress in the agencies’ respective organic acts1 and as established by other environmental statutes and direction. This failure to lawfully administer grazing onfederal public lands is ubiquitous across the western landscape2.

Researchers have suggested livestock grazing is “the most severe and insidious of the impacts on the rangeland” and that grazing is the “most insidious and pervasive threat to biodiversity on rangelands.”3 Wildlife and species populations have declined as direct conflict with livestock and shared habitats sustain a myriad of ongoing impacts from public lands ranching. Direct impacts associated with livestock includes the widespread pollution of water,4 the removal of vegetation—i.e. direct competition with wildlife for food,5 the alteration of complex habitat structures and composition including the most significant contributor to desertification of the western landscape,6 the physical impairment of stream-bank (riparian) habitats7 that a majority of wildlife depend on for survival in the semi-arid and arid west, soil disturbances which allow for displacement of native vegetation with exotic weeds,8 the introduction and continued exposure of disease and a host of additional direct impacts.

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Unnamed creek, ESA listed Bull trout habitat impacted by livestock grazing Pass Creek Allotment, Lost River Ranger District – Challis National Forest.

(Photo: Dr. John Carter)

A. Water Quality

Mismanagement of public lands ranching has resulted in the diminished quality and quantity of water originating from mountain springs and streams, many of which once ran clear and clean enough to drink from directly, a western American pastime. On several public land allotments in Wyoming, the Bighorn National Forest conducted water quality testing on streams running through permitted allotments and found levels of E. coli so high that the water was unsafe to touch with exposed skin, let alone drink from as is the intent of state standards promulgated by Congress as established by the CleanWater Act. In 2010, the Journal of Water and Health published the results of an independent study that was conducted in the Sierra Nevada Mountains of California, a chief source of drinking water for over 40 million American citizens.9 Researchers found livestock grazing on public lands to be the primary source of fecal coliform and E. coli contamination of drinking water. In addition, researchers found thatlivestock may be depositing enough Giardia-transmitting protozoa to infect the entire city of Los Angeles each day. The Forest Service refuses to appropriately respond by reducing livestock impact to California’s drinking water supply.

On a vast majority of waters originating on public lands grazed by livestock, agencies refuse to test, let alone adequately consider water quality impacts in their environmental reviews of permit.

B. Infrastructure

In addition, livestock grazing infrastructure, commonly bought and paid for by the American tax-payer,

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has quite literally tamed the once wild West. Over a million miles of fencing on public lands have obstructed natural wildlife movement and migration, and water developments built to facilitate livestock use of public lands have dewatered springs, seeps, and streams which serve as critical habitatsfor a variety of wildlife across the West.

In administering public land ranching, agencies have subjected public lands to widespread habitat alteration projects. One example took place on public lands just outside of Yellowstone National Park, arenowned public landscape celebrated by a majority of Americans for its wildlife attraction and breathtaking beauty.

On one grazed public landscape near the Antelope Basin/Elk Lake area of Madison Valley over 50 square miles of open, mountain sagebrush grassland habitat was subject to aggressive habitat manipulation, managers prescribed herbicide eradication of sagebrush and forbs, multiple prescribed burnings, and other impacts significantly diminishing wildlife habitat to provide more forage for livestock use of the public land. This type of habitat manipulation to maintain and increase livestock use has occurred, and continues to occur, on millions of acres of western public lands that once teemed with wildlife and championed other recreational opportunities impaired by livestock that the Department of Interior recently found contribute an order of magnitude greater economic value to localeconomies than public lands ranching.10

Livestock infrastructure destroys wildlife (Photo: Katie Fite)

C. Species and Habitat

As a direct consequence of agencies’ continued prioritization of livestock use on public lands and the widespread failure of management to make “significant progress” toward improving public lands habitat conditions on the ground on a significant number of permits throughout the West, species endangerment continues to escalate at an alarming rate. Livestock grazing is a contributing factor to

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more than 175 threatened and endangered species,11 twenty-one percent of imperiled species consideredfor listing on the Endangered Species Act, an amount roughly equal to logging and mining combined.12

Federal agencies have been unable or unwilling to adequately respond by reducing the duration of livestock use or the number of livestock permitted in order to curtail impact.13 Political pressure ensuresthat livestock is always the unchanged factor in management decisions and managers spend reams of bureaucratic resources and time justifying status quo levels of use despite the conspicuous impact on the ground. As habitat continues to diminish, species continue to decline and the administrative burden in response to clear Congressional intent to prevent species extinction, make significant progress toward habitat improvement, and protect environmental values continues to mount.

Cottonwood creek – Owyhee Field Office, Idaho BLM. Monitoring cage illustrates typical degree of forage removed by livestock

that would otherwise stabilize stream-banks, purify water, and be available to wildlife. (Photo: Brian Ertz - Chair, SC Grazing Team)

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Child enjoying the public grasses made available to wildlife on the too few western public lands spared the impact of public lands ranching

(photo: Brian Ertz – Chair, SC Grazing Team)

Footnotes

1. Federal Land Policy Management Act, National Forest Management Act, etc.2. GAO. 1993. Rangeland Management: BLM’s Range Improvement Project Data Base Is Incomplete and Inaccurate.

RCED-93-92. General Accounting Office. Washington, DC. GAO; GAO. 1992. Rangeland Management: Interior’s Monitoring Has Fallen Short of Agency Requirements . RCED-92-51. General Accounting Office. Washington, DC. GAO; GAO. 1990. Public Rangelands: BLM Efforts to Prevent Unauthorized Livestock Grazing Need Strengthening. RCED-91-17. General Accounting Office. Washington, DC. GAO; GAO. 1988. Public Rangelands: some riparian areasrestored but widespread improvement will be slow . RCED-88-105. General Accounting Office. Washington, DC; GAO.1988. Public Rangelands: More Emphasis Needed on Declining and Overstocked Grazing Allotments . RCED-88-80. General Accounting Office. Washington, DC.

3. T. Fleischner. 1994. Ecological Costs of Livestock Grazing in Western North America. Conservation Biology 629; Noss and Cooperrider. 1994. Saving Nature’s Legacy, Island Press. 221, 230, 258. See also, generally, Lauenroth et al., “Effects of Grazing on Ecosystems,” 69.

4. Nearly all surface waters in the West are fouled with livestock wastes that produce harmful waterborne bacteria and protozoa such as Giardia. T. Suk, J.L. Riggs, and B.C. Nelson. 1986. Water contamination with giardia in backcountry areas in Proc. of the National Wilderness Conference. Gen. Tech. Rep. INT-212. USDA-Forest Service, Intermountain Res. Stn. Ogden, UT: 237–39. Livestock grazing is the single largest contributor to non-point sourcepollution in New Mexico, accounting for approximately 15 percent of the water quality impairments statewide. J.Rankin. Plan to take better care of water quality is earning accolades; conservationists disagree. Albuquerque Journal (May 15, 2005).

5. In one study, scientists found that domestic livestock grazing consumed 88.8 percent of the available forage (cattle and [domesticated] horses 82.3 percent, free-roaming horses 5.8 percent, sheep 0.7 percent), leaving 11.2

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percent to wildlife species (mule deer 10.1 percent, pronghorn 0.9 percent, bighorn sheep 0.1 percent, elk 0.1 percent).Cited in R. R. Kindschy, C. Sundstrom, and J. D. Yoakum, 1982, Wildlife habitats in managed rangelands-the Great Basin of southeastern Oregon: pronghorns, Gen. Tech. Rep. PNW 145, USDA-Forest Service; USDI-BLM, Portland, OR: 6.

6. “Improvident grazing … has been the most potent desertification force, in terms of total acreage [affecting 225 million acres or 351,562 square miles], within the United States.” E. Chaney, W. Elmore, and W.S. Platts. 1993. Livestock grazing on western riparian areas. Northwest Resource Information Center. Eagle, ID: 5 (fourth printing; produced for the Environmental Protection Agency). Council on Environmental Quality. 1980. The global 2000 report to the president of the United States: entering the twenty-first century. Pergamon Press. New York, NY.

7. Livestock grazing has damaged 80 percent of the streams and riparian ecosystems in the arid West. A.J. Belsky, A. Matzke, and S. Uselman. 1999. Survey of livestock influences on stream and riparian ecosystems in the western United States. J. Soil & Water Conserv. 54(1): 419 (citations omitted). “Extensive field observations in the late 1980s suggest riparian areas throughout much of the West were in the worst condition in history.” E. Chaney, W. Elmore, and W.S. Platts. 1993. Livestock grazing on western riparian areas. Northwest Resource Information Center. Eagle, ID: 5 (fourth printing; published by the Environmental Protection Agency). In 1988 the General Accounting Office concluded that “poorly managed livestock grazing is the major cause of degraded riparian habitat on federal rangelands.” GAO. 1988. Public Rangelands: some riparian areas restored but widespread improvement will be slow. RCED-88-105. General Accounting Office. Washington, DC: 11.

8. “At the community scale, livestock may be the major factor causing weed invasions.” Livestock cause weed invasion by grazing and trampling native plants; clearing vegetation, destroying the soil crust and preparing weed seedbeds through hoof action; and transporting and dispersing seeds on their coats and through their digestive tracks. A.J. Belsky and J.L. Gelbard. 2000. Livestock grazing and weed invasions in the arid west. Oregon Natural Desert Association. Bend, OR (citations omitted).

9. R.W. Derlet, C.R. Goldman, and M.J. Connor. 2010. Reducing the impact of summer cattle grazing on water quality in the Sierra Nevada Mountains of California. Journal of Water and Health. 8(2): 326–33.

10. DOI Report: The Department of Interior’s Economic Contributions , June 21, 2011.11. USDI-BLM, USDA-Forest Service. 1995. Rangeland Reform ’94 Final Environmental Impact Statement. USDI-

BLM. Washington, DC: 26. See also B. Czech, P.R. Krausman, and P.K. Devers. 2000. Economic associations among causes of species endangerment in the United States. BioSci. 50(7): 594 (table 1) (reporting that authors’ analysis of several studies suggests that 182 species are endangered by livestock grazing) and USDA-NRCS. 1997. America’s private land: a geography of hope. Program Aid 1548. USDA-Natural Resources Conservation Service: 154 (stating that grazing is a contributing factor in the decline of 26 percent or 161 species on the federal threatened and endangeredlist).

12. D.S. Wilcove, D. Rothstein, J, Dubow, A Phillips, and E. Losos. 1998. Quantifying threats to imperiled species in the United States: assessing the relative importance of habitat destruction, alien species, pollution, over-exploitation anddisease. BioScience 48(8): 610.

13. Candidate Species List, U.S. Fish and Wildlife Service.14. See Public Lands Council v. Babbitt, 529 U.S. 728, 741 (2000)e

Appendix B: Concerns that the Proposed Agriculture and Food Policy will weaken the current Grazing Policy

The Sierra Club’s proposed “Agriculture and Food Policy” (http://clubhouse.sierraclub.org/people/committees/board/Agriculture%20Policy%20FINAL%20%2011-10.pdf) (hereafter “Ag Policy”) currently (1 Dec 2014) contains policy language that is inconsistent with the Sierra Club’s “Grazing on Public Lands” policy (http://www.sierraclub.org/policy/grazing-public-lands) (hereafter “Grazing Policy”).

The proposed Ag Policy (under “Item 1” of the section titled “Livestock Production and Grazing”) states that “Properly managed livestock grazing can be an appropriate activity on many public and private lands which are suitable for sustained-yield forage production ” [emphasis added]

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The Grazing Policy, in contrast, states as its first item: “Commercial grazing is not appropriate on federal public lands except where it is shown by science that some grazing is needed to achieve ecological objectives.”

If the Ag Policy statement is interpreted to include “federal lands” within its definition of “public land,”its enactment would effectively change the Sierra Club’s fundamental position concerning livestock grazing on federal public lands. A resource-extractive activity that the Sierra Club has generally considered as inappropriate on federal lands for the last 14 years could now be considered appropriate on many “suitable” federal lands if that activity was “properly managed”.

For the existing Sierra Club Public Lands Grazing Policy to remain unchanged by the new proposed AgPolicy, the words “public and” must be stricken from the first item of the section of the Ag Policy titled“Livestock Production and Grazing” so that the revised statement would read “Properly managed livestock grazing can be an appropriate activity on many private lands which are suitable for sustained-yield forage production, and often are unsuitable for row-crop production.” [1]

[1] A related Sierra Club document asserts that “The existing Public Lands Grazing Policy would be unchanged” by enactment of the Ag Policy. The above comparative analysis clearly challenges that assertion. (See “One Page Synopsis of proposed Agriculture and Food Policy, lines 14–15; http://clubhouse.sierraclub.org/people/committees/board/SYNOPSIS%20OF%20%20AGRICULTURE%20%20POLICY.vb%20edits.pdf)

Why The Current Sierra Club “Grazing on Public Lands” Policy Should Remain Unchanged

1. Sierra Club policy should always give highest precedence to the conservation of natural resources (protection of soil, water, air, fauna, flora) on federal public land. The production of agricultural commodities on federal public land should always be subordinate. The currently proposed Ag Policy language discussed above appears to elevate agricultural production on federal public lands to a higher priority than the conservation of natural resources on federal land.

2. Sierra Club “Grazing on Public Land” policy currently enables Sierra Club entities and activists to advocate for livestock-free federal lands at every stage of the pre-NEPA, NEPA, and post NEPA process. It also enables Sierra Club entities to initiate and support coalition efforts to establish or maintain livestock-free federal lands through litigation. The currently proposed Ag Policy language discussed above would enable ranchers and their allies to use the Sierra Club Ag Policy to more effectively block Sierra Club chapters and other Sierra Club entities from initiating or supporting efforts to create or maintain livestock-free federal public lands.

3. Sierra Club policy implicitly promotes the idea that the burden of proof concerning livestock grazingon public lands should always fall on the grazier rather than on the conservationist. The grazier who wants to graze on federal public lands should have to demonstrate that proposed livestock grazing will achieve ecological objectives, while the conservationist should not have to demonstrate that a proposedelimination or reduction of grazing on federal public land will necessarily yield optimal ecological and social outcomes. The current Sierra Club Grazing policy implies this value preference. The currently proposed Ag Policy language discussed above would change this value preference and reverse the burden of proof from the grazier to the conservationist.

—Brian Ertz, Chair, Sierra Club Grazing Team, brian.ertz@gmail.com

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Appendix C: Soil Carbon Sequestration and Livestock Grazing

Part 1: The Benefits of Removing Livestock from Rangelands to Sequester Carbon

By George Wuerthner, Senior Scientist, Foundation for Deep Ecology, San Francisco, CA, (and Sierra Club Grazing Team member)

INTRODUCTION

Rangelands make up a large proportion of the Earth’s surface, and the soils hold a significant amount of sequestered carbon. Rangelands are estimated to contain more than one-third of the world’s above and below ground carbon reserves.[i] As a consequence, there is interest in determining the potential for soil carbon sequestration in rangeland soils, and if livestock grazing helps or hinders this sequestration.

The potential for sequestering more carbon varies tremendously, however, based upon a number of factors including existing carbon storage (there is a finite amount of carbon that soils can hold before they are “saturated”), plant productivity, grazing management, and climate.

Annual rates of soil organic carbon (SOC) accumulation decline as the soil approaches equilibrium. Sometimes overly optimistic predictions result when SOC accumulations increase in the early years after a change in grazing management, but cannot be extrapolated indefinitely.[ii]

The issue of whether livestock grazing can sequester carbon in soils has gotten greater attention in recent years. Some proponents of livestock grazing assert that grazing can lead to the sequestering of significant amounts of carbon in soils, and thus reduce GHG emissions.

In the most optimistic claims, some, like Allan Savory, suggest that livestock grazing can reduce carbon to pre-Industrial levels. In particular, Savory’s unverified claims have generated a number of responses that dispute his assertions.[iii] [iv] .

While there may be circumstances under which grazing could increase carbon in soil, most rangeland soils have a limited ability to store additional carbon, and under most conditions livestock grazing will reduce carbon storage, rather than increase it.

Efforts to maintain and increase carbon storage in rangelands should focus on reducing livestock grazing in areas where it ecologically inappropriate and causing degradation. Those promoting the climate benefits of livestock grazing must account for effects beyond soil carbon. Livestock are significant sources of methane emissions, so any speculative benefits from increased soil carbon storage are likely offset by increased methane emissions. SOIL CARBON IN RANGELANDS

There is a tremendous amount of carbon tied up in agricultural soils. The amount of carbon bound up in soils is approximately three times the amount of C found in aboveground biomass. The argument goes that a small increase in soil carbon pools could have a major impact on reduction of global GHG emissions.

The basic way that carbon is sequestered in soil is by plant growth, primarily through roots, in the

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soil, along with micro bacteria, soil microbes and other soil life that are able to live on plant material.

Given the existing condition of many rangelands, the biggest concern is maintaining current carbon, and avoiding losses through soil erosion, degradation of plant productivity and other changes that lead to soil carbon losses. In other words, the best way to reduce CO2 emissions from rangelands globally is to reduce rangeland degradation. Since livestock grazing is frequently the major source of rangeland degradation, a reduction in grazing pressure, can in many ecosystems, potentially preserve more soil carbon.

While increasing soil carbon storage may be theoretically possible in some circumstances, the ability of soil to absorb carbon is limited. Many ecosystems are at or near equilibrium and cannot store additional carbon. To bind more carbon in the soil requires a continuous input of new organic matter. The soils that have the best opportunities for additional carbon storages are thosethat have been depleted by overgrazing and ecosystem degradation, but these landscapes frequently require a long period of time to recover. They are also the most difficult to recover.[v]

This gets into the time factor regarding global GHG emissions. Reducing emissions is more important now than in future decades. Due to the slow accumulation rate of carbon in soils, even if certain grazing practices could enhance carbon storages in some situations, the process may not help reduce global CO2 levels in a useful time frame.

By contrast, methane emissions from livestock are a major contributor to GHG warming now, and these emissions are one of the easiest (relatively speaking) human anthropogenic sources of CO2 equivalents to reduce.

LIVESTOCK AS A SOURCE OF METHANE

Livestock are among the largest sources of global anthropogenic methane. Depending on which study is used, anywhere from 14-51% of the global GHG emissions in CO2 equivalences are due tolivestock production (UN Livestock’s Long Shadow [vi]or Climate Change and Livestock, Worldwatch Institute).[vii] Even if livestock grazing could generate some carbon sequestration over the long term (and as we shall see below, this is not a proven given), the presence of livestock emissions occurring in the interim would still be a significant problem. One would have to balance any carbon sequestration against the methane emissions to see if livestock grazing were a net benefit.

A study in China found that the uptake of CH4 (methane) by grassland soils only offset 3.1-8.6% of methane emissions from grazing sheep.[viii]This suggests that even if livestock grazing could promote the sequestration of methane, it would not be significant enough to outweigh the emissions resulting from livestock digestion.

One problem to keep in mind is that methane is 84 to 86 times more effective than CO2 in trapping heat during the first 20 years after its release into the atmosphere (IPCC, Fifth Assessment Report, 2013.) (Over a 100 year time scale, methane breaks down into CO2; the IPCC currently considers methane to be approximately 28 to 34 times more effective than CO2 in

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trapping heat over the 100 year time scale.) Since reducing global heating is a priority now, not 100 years from now, the more effective heat trapping properties of methane in the first decade or two after emission make it especially dangerous.

VARIATION IN CARBON STORAGE

When viewing the contribution that livestock grazing may make to carbon sequestration there are a few other considerations that must be part of an informed decision.

The first is that there is tremendous variation in reported soil carbon storage due to variation in ecosystems, grazing methods and management, the soil profile and depth analyzed, study duration, grass type, and precipitation. Accounting for this variation is context-based and making comparative statements difficult as a result.[ix]

GRAZING INFLUENCES ON SOIL CARBON STORAGE

Grazing can affect carbon storage losses by shifting plant species dominance in some communities. Ecosystems where heavy grazing by native ungulates was historically common (likethe Great Plains) have an ability to facilitate soil carbon sequestration by a shift in plant species.For example, a long term study of the Northern Great Plains in North Dakota found that moderate grazing resulted in 17% less soil carbon sequestered than in ungrazed exclosures; however, heavygrazing resulted in a shift towards blue grama, a grazing tolerant species with shallow, but dense roots. The dominance by blue grama resulted in levels of sequestered soil carbon similar to those found in the ungrazed exclosure.[x]

A similar situation was found in a study of alpine meadows in China where medium to heavy grazing increased soil carbon in the top soil layers as a result of a shift in plant species to grasses tolerant of heavy grazing. These grasses have dense roots, thereby increasing soil organic carbon.[xi]

However, even where a shift in plant dominance may appear to improve soil carbon storage potential, there is a great variation in rates of sequestration due to the influence of other climate variables, such as drought and increased soil temperature.

A study in a mixed grass ecosystem on the Great Plains found that heavy grazing (50 percent utilization) over a 10 year period resulted in a 30% loss in soil organic carbon (SOC). This was a consequence of shifting plant dominance from mixed prairie grasses to blue grama, a grass that tolerates heavy grazing. Blue grama has dense but shallow roots; thus, SOC accumulates closer to the surface where it is more easily lost.[xii] Under conditions of drought, gradually increasing soiltemperatures, and heavy grazing, the blue grama root system was unable to retain carbon that had previously been accumulated under the wetter, cooler-soil conditions of the previous decade. (Significantly, this study also documented that there was little change in SOC in the no grazing and light grazing [10 percent utilization] treatment areas over this same dry, warmer-soil period. It also documented that increases in total nitrogen accumulated in the no grazing and light grazing treatments over this period while nitrogen stores declined in the heavy grazing treatments.)

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Climatic influences are more likely to affect shallow SOC deposits like those found in blue grama grasslands. For instance, another study on the Great Plains found that in a wet year carbon storage by cool season grasses improved, and there was greater carbon storage in an exclosure, while the following year a grazed pasture dominated by blue grama had a higher CO2 exchange rate.[xiii]

This variability in results also points out the danger of short term studies that are the most common in the research world. Depending on what the climatic conditions were in the years measurements are taken, may greatly influence the findings and conclusions.

Many of the studies of soil carbon storage have been done in ecosystems where there was significant evolutionary grazing influence from native species such as bison like on the Great Plains which may bias conclusions. In these areas, plants exist that have developed tolerance for heavy grazing. However, in areas where native grazers were less abundant (like the Great Basin and many desert areas) the ability of plants to adapt to livestock grazing appears to be less resilient, however, there have far fewer studies conducted grazing influence on soil carbon in these ecosystems.

Livestock grazing is the primary factor in tipping some ecosystems, such as the rangelands found in the Great Basin, over ecological thresholds. For instance, exotic shallow rooted cheatgrass has replaced deep rooted native bunchgrasses and shrubs on some western rangelands. Cheatgrass sequesters very little carbon and increases SOC rate of turnover.[xiv] .

As the author notes; “The elimination of perennial understory vegetation and cryptobiotic crusts is a nearly inevitable consequence of livestock grazing in deserts. This opens these systems to annual grass invasion, subsequent burning, and loss of a major carbon sink, a heavy price to pay for the minimal economic gains derived from direct use of these intrinsically unproductive lands for livestock production” [xv]

Changing disturbance intensity (grazing) in an ecosystem with low disturbance regimes can lead to a cascade of events. One study found that after a shift to high disturbance, photosynthesis decreased followed by a decline in root biomass and a change in plant community structure 1.5 months later. Those changes led to a decrease of soil fungi, a proliferation of Gram(+) bacteria and accelerated decomposition of old particulate organic C (<6 months). At last, accelerated decomposition released plant-available nitrogen and decreased soil C storage. The results indicate that intensified grazing triggers proliferation of Gram(+) bacteria and subsequent faster decomposition by reducing roots adapted to low disturbance.[xvi]

A study in China found that grazing exclusion resulted in greater aboveground biomass, root biomass and plant litter compared to grazed grasslands. Grazing exclusion significantly increased C and N stored in plant biomass and litter and increased the concentrations and stocks of C and N in soils. Furthermore, these differences were accentuated the longer grazing was excluded with the highest C and N stocks in a 17 year grazer excluded grassland.[xvii]

In another study in China, variation in precipitation had a greater effect on carbon uptake and

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release. The ungrazed plots had less variation and the authors concluded that ungrazed lands may have greater resistant to changing climate.[xviii]

A third study in China’s Inner Mongolia found standing dead plant and litter carbon (C) decreasedsignificantly in light grazing conditions (when compared to a non-grazed exclosure that had been fenced for 26 years), but light grazing did not significantly affect live plant C, total aboveground plant C, total root C (0–60 cm), and soil C (at 0–100-cm depths). Heavy grazing extensively reduced carbon in three pools, total aboveground plant C, subsoil C (at 60–100 cm), and total soil C (at 0–100 cm), but did not affect topsoil C (at 0–60 cm). The lack of an effect on topsoil C can be explained by a slight increase in root C (0–60 cm) and a higher ratio of root to vegetation C in the heavy grazing site. The decrease in subsoil C under heavy grazing is attributable to the organic carbon decomposition due to increased root C as a source of fresh carbon. Total ecosystem C decreased from 150.62 Mg C/ha in the NX site to 143.78 Mg C/ha in the LG site (a 4.5% decrease) and to 122.43 Mg C/ha in the HG site (an 18.7% decrease).[xix]

Similarly, in a fourth study of Loess Plateau in China, a twenty year exclusion of livestock grazing significantly increased above and below ground biomass, species richness, cover and height for five different communities. The authors concluded that “long-term exclusion of livestock grazing can greatly improve properties of typical steppe in the Loess Plateau.[xx]

The point of all conflicting results is that one cannot generalize and always assume that grazing will increase soil carbon stocks. Clearly in many areas grazing exclusion is the best way to store and even increase soil carbon.

Briske and colleagues question how much carbon can be sequestered in rangelands in general, due to the low productivity of rangelands ecosystems. As they note, rangelands are known to be very weak sinks for atmospheric C because plant production is water limited and more C is often released into the atmosphere from soil respiration than is take up by vegetation, especially duringdrought periods.[xxi]

A further complicating matter is how vegetation affects soil carbon storage. For instance, under heavy grazing in the Great Plains, blue grama, a sod-forming grass very resistant to grazing, tends to increase. Blue grama roots are denser and found in shallower soil profiles than other grasses. Hence measurements of soil carbon can be affected by the dominant species and the depth of soil profiles examined. Heavy grazing may increase soil carbon in the Great Plains by favoring blue grama, but at the expense of a greater diversity of deep rooted grasses.[xxii]

Another problem is that even if livestock grazing could enhance carbon sequestration, it would take a long time to implement at large landscape scale and there are also limits to how much carbon soils can absorb.[xxiii]

CAUTIONARY REMARKS

Beyond the methane production from livestock, in particular, cattle, one must also look at the collateral damage from livestock grazing. Livestock production does not occur in isolation. Cattle,

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in particular, produce a large amount of manure that is a major source of water pollution. Cattle destroy biocrusts, particularly in arid ecosystems, fostering the spread of weeds and exotic plantslike cheatgrass. Cattle trample riparian areas in arid ecosystems that are critical habitats for 70–80% of all wildlife. Cattle hooves compact soils, reducing infiltration of water. In most of the world, protecting livestock from predators is one of the primary factors contributing to the decline and endangerment of many predator species. And growing of forage for livestock is a major reason tropical forests are cleared (for hay and soy production,) with a sequent loss of carbon to the atmosphere. It is also the reason for much of the destruction of native vegetation in places like the Midwest of the US, where livestock forage crops like corn and soy dominate. Since much of the hay/alfalfa grown in the arid West requires irrigation, the impoundment of rivers with dams is yet another consequence of livestock production.[xxiv]

Grazing can also alter plant communities, with ecological consequences not only for livestock production, but also wildlife. For instance, a heavily grazed short grass steppe in Colorado shifted from mixed prairie with cool season plants to a plant community dominated by the warm season grass blue grama. This reduces the available forage earlier in the season, which can affect livestock productivity, but which also has obvious impacts on native wildlife that may depend on early green up of cool season grasses.[xxv]

In yet another study in New Mexico, grazing shifted grasslands to mesquite. The deep rooted mesquite had far more carbon storage than the grasslands.[xxvi] However, many ecologists see the shift to mesquite as a degraded ecosystem.

Exclosures tended to have a more diverse flora, including more forbs (flowers) and cool season grasses. In particular, the presence of forbs may be important to pollinating insects like butterfliesand flies, and the effects on total biodiversity should be considered, not just whether there are greater soil carbon accumulations.[xxvii]

Thus, focusing on carbon storage without considering other ecosystem values may be counterproductive.

GRASS-FED BEEF

Grass-fed beef is not a panacea either, as grass is nutritionally poor and requires greater transits time in the cow’s rumen, resulting in anywhere from 2-4 times as much methane production. For instance, one study reported a 48% increase in methane production by cows feeding on natural grasslands.[xxviii] In another study comparing CAFO farmed animals with natural pasture feed cattle, the grass-fed beef had significantly greater methane emissions.[xxix]

Furthermore, any increase in cattle production (as advocated by Allan Savory and others) would likely come at the expense of forests, since the majority of new livestock pasturage is carved from forested landscapes. (Most natural grasslands are already under livestock production and have little space available for increasing animal numbers.) Since forests capture and store far more carbon than any grassland pastures that replace them, expanding livestock production would likely result in a net loss in carbon storage.

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In their assessment of the full life cycle estimate of GHG emissions attributable to livestock (which includes collateral impacts like forest clearing), Goodland and Anhang suggest that nearly 51% of the annual worldwide anthropogenic GHG emissions are attributable to livestock.[xxx]

A reduction in livestock numbers and production would permit the reforestation of millions of acres of land that were cleared for livestock pasture. This would effectively store far more carbon than livestock grazing could achieve through any stimulation of plant production and SOC storage.[xxxi]

SUMMARY

There is no clear evidence that livestock grazing can significantly enhance soil carbon stores. Conflicting evidence exists that demonstrates greater carbon storage with no grazing, while in other ecosystems, grazing may enhance soil carbon. But there are many cautionary remarks on how to measure and interpret findings. Climatic conditions year to year, for instance, can shift carbon storage in grazed areas from a positive to a negative. Furthermore, any storage is slow andtakes years to accumulate, while carbon uptake by soils is finite and slows over time. And compared to almost all other ecosystems, arid rangelands are among the least productive ecosystems—hence have little potential for soil carbon storage compared to other ecosystems like forests.

Because of this time factor and the need to reduce CO2 levels now, the use of rangelands as a carbon sink—even if it were proven effective—is a poor strategy for a host of reasons. One cannotlook at the soil carbon storage issue out of context. Livestock are among the greatest source of GHG emissions-now—and reducing livestock numbers is the quickest and perhaps the most effective means of significantly altering GHG emissions.[xxxii] Furthermore, there are a host of collateral damages created by livestock production, from the destruction of soil biocrusts, killing of predators, water pollution, clearing of forests for pasture, and so on. One cannot look at the carbon-livestock-soil issue in isolation. Taken as a whole, the production of livestock has many significant ecological impacts, not the least of which is its contribution to global GHG emissions. [i] Ingram L.J. et al. 2008. “Grazing impacts on soil carbon and microbial communities in a mixed grass ecosystem.” Soil Sci. Soc. Am. J. 72:939–48.

[ii]Powlson et al. 2014. “Limited potential of no-till agriculture for climate change mitigation.” Nature Climate Change, July 30 2014.

[iii] Carter, J. et al. 2014. “Holistic Management: Misinformation on the Science of Grazed Ecosystems.” International Journal of Biodiversity Volume 2014, Article ID 163431, 10 pages

[iv] Briske, D. et al. 2013. “The Savory Method cannot green deserts or reverse climate change. A response to Allan Savory’s TED video.” Rangelands 35(5):72–74 doi: 10.2111/RANGELANDS-D-13-00044.1

[v] Sommer R. and D Brossio. 2014. “Dynamics and climate change mitigation potential for soil carbon sequestration,” J of Environmental Management 144:83–87.

[vi] Steinfeld, H. et al. 2006. Livestock’s Long Shadow. UN Food and Agricultural Organization. http://www.fao.org/docrep/010/a0701e/a0701e00.HTM

[vii] Goodland, R Anhang, J (2009) Livestock and Climate Change: What if the key actors in climate change were pigs, chickens and cows? World Watch, November/December 2009. Worldwatch Institute, Washington, DC, USA. Pp. 10–19.

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Available at: http://www.worldwatch.org/files/pdf/Livestock%20and%20Climate%20Change.pdf

[viii] Xiaoya Wang, Yingjun Zhang, Ding Huang, Zhiqiang Li, and Xiaoqing Zhang. “Methane Uptake and Emissions in a Typical Steppe Grazing System during the Grazing Season,” Atmospheric Environment 105 (2015): 14–21.

[ix] Mcsheery M. and Mark Richie. “Effects of grazing on grassland soil carbon: a global review.” Global Change Biology 19 (2013): 1347–57, doi: 10.1111/gcb.12144

[x] Frank, A.B. et al. 1995. “Soil carbon and nitrogen of Northern Great Plains grasslands as influenced by long term grazing.” J. Range Management 48:470–74.

[xi] Gao. Y.H. et al. 2007. “Grazing intensity impacts on carbon sequestration in an alpine meadow of the eastern Tibetan Plateau.” Research Journal of Agriculture and Biological Sciences, 3(6): 642–47.

[xii] Ingram, LJ. et al. 2008. Grazing impacts on soil carbon and microbial communities in a mixed-grass ecosystem. Soil Sci. Soc. Am. J. 72:939–48.

[xiii] LeCain et al. 2004. “Carbon exchange and species composition of grazed pastures and exclosures in the shortgrass steppe of Colorado.” Agriculture, Ecosystems and Environment 93, 421–435.

[xiv] Meyers, S. 2011. “Is climate change mitigation the best use of desert shrublands?” Natural Resources and Environmental Issues: Vol. 17, Article 2. Available at: http://digitalcommons.usu.edu/nrei/vol17/iss1/2

[xv] Meyers, S. 2011. “Is climate change mitigation the best use of desert shrublands?” Natural Resources and Environmental Issues: Vol. 17, Article 2. Available at: http://digitalcommons.usu.edu/nrei/vol17/iss1/2

[xvi] Klumpp, K., Fontaine, S., Attard, E., Le Roux, X., Gleixner, G. and Soussana, J.-F. (2009), Grazing triggers soil carbon loss by altering plant roots and their control on soil microbial community. Journal of Ecology, 97: 876–885. doi: 10.1111/j.1365-2745.2009.01549.x

[xvii] Qiu, L. et al. 2013. “Ecosystem carbon and nitrogen accumulation after grazing exclusion in semiarid grassland.”PLOS ONE | http://www.plosone.org 1 January 2013 | Volume 8 | Issue 1

[xviii] Shao, C. et al. 2013. “Grazing alters the biophysical regulation of carbon fluxes in a desert steppe.” Environ. Res. Lett. 8 (2013) 025012 (14pp)

[xix] Fang Fei, Chang Rui-ying1, Tang Hai-ping 2014 “Effects of Grazing on Carbon Sequestration in Temperate Grassland, Inner Mongolia of North China,” Vegetos- An International Journal of Plant Research Volume : 27(3): 126–34.

[xx] Cheng, J. et al. “Cumulative effects of 20 year exclusion of livestock grazing on above and belowground biomass oftypical steppe communities in arid areas of the Loess Plateau, China.” Plant Soil Environ. 57, 2011 (1): 40–44.

[xxi] Briske, D. et al. 2014. “The Savory Method cannot green deserts or reverse climate change. A response to Allan Savory’s TED video.” Rangelands 35(5):72–74 doi: 10.2111/RANGELANDS-D-13-00044.1

[xxii] Ingram L.J. et al. 2008. “Grazing impacts on soil carbon and microbial communities in a mixed grass ecosystem.”Soil Sci. Soc. Am. J. 72:939–48.

[xxiii] Sommer R. and D Brossio. 2014. “Dynamics and climate change mitigation potential for soil carbon sequestration,” J of Environmental Management 144: 83–87.

[xxiv] Wuerthner G. and M. Matteson eds. 2002. Welfare Ranching. Island Press.

[xxv] LeCain et al. 2004. Carbon exchange and species composition of grazed pastures and exclosures in the shortgrass steppe of Colorado. Agriculture, Ecosystems and Environment 93:421–35.

[xxvi] Bird, S.B. et al. 2002 “Spatial heterogeneity of aggregate stability and soil carbon in semi-arid rangelands.” Environmental Pollution 116:445–55.

[xxvii] Reeder, J.D. and G.E. Schuman. 2001. “Influence of livestock grazing on C sequestration in semi-arid mixed grass and short grass rangelands.” Environmental Pollution 116:457–63.

[xxviii] Grobler, S.M. et al. 2014. “Methane Production in different breeds, grazing different pastures or fed a total

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mixed ration as measures by a Laser Methane Detector.” South African Journal of Animal Science 44 (Issue 5, Supplement 1).

[xxix] Pelletier, N. et al. 2010. “Comparative life cycle environmental impacts of three beef production strategies in the Upper Midwestern United States.” Agricultural System 103 (2010) 380–89.

[xxx] Goodland, R Anhang, J (2009) Livestock and Climate Change: What if the key actors in climate change were pigs, chickens and cows? World Watch, November/December 2009. Worldwatch Institute, Washington, DC, USA. Pp. 10–19. Available at: http://www.worldwatch.org/files/pdf/Livestock%20and%20Climate%20Change.pdf

[xxxi] Goodland, Robert. January 2014. Happier Meals. Climate Alert. Climate Institute. http://www.climate.org/publications/Climate%20Alerts/2014-january/happier-meals.html

[xxxii] Ripple, W. et al. 2014. Ruminants, Climate Change and Climate Policy. Nature Climate Change 3 http://www.nature.com/natureclimatechange

Part 2: Grazing Team Critique of Franzluebbers and Stuedemann, 2009

A.J. Franzluebbers and J.A. Stuedemann, “Soil-profile organic carbon and total nitrogen during 12 years of pasture management in the Southern Piedmont USA,” Agriculture, Ecosystems and Environ-ment 129 (2009): 28–36.

Critique: Grass-fed beef advocates have widely embraced the findings of Franzluebbers and Stuedemann (2009) that purportedly demonstrate that soil sequesters more atmospheric carbon (C) as pasture under “Low Grazing Pressure” (LGP) than as pasture left ungrazed by cattle. Let’s more closelyexamine the situation. For the LGP regime (averaged over three nutrient source treatments), the authorsreport (on p. 33, Table 4) an annual rate of change in soil organic carbon of 0.796 Mg/ha compared with only 0.28 Mg/ha for “unharvested” biomass (averaged over those same three nutrient treatments, and with all soils assessed to a depth of 150 cm). At face value, this looks like a significant claim for the superiority of grazing over non-grazing, as the grazed pasture sequesters nearly three times as muchC as the ungrazed one on an annual basis.

Now let's look at the amount of C emitted by the steers that grazed the pasture. The LGP trials consisted of 5.8 steers per hectare grazing for 140 days/yr during the first 5 years of the study, and for approximately 310 days/yr during the remaining 7 years. The amount of methane (CH4) annually emitted by a typical steer ranges from 60 to 71 kg.1 As a concession to ranching advocates, we'll perform the calculation with the low end of the range: 60 kg/yr. And we’ll also charge to the steers the CH4 emitted only during their presence on the experimental landscape over the 12 years of the study. We calculate the weighted average of the annual CH4 emissions per steer over the two periods of the 12-year study, multiplied by the number of steers per hectare. All this yields 0.228 Mg/ha/yr of CH4, ofwhich about 75 percent by mass is C (0.170 Mg/ha/yr). From the perspective of ranching advocates, this still looks like a favorable result, as the amount of C sequestered by the soil (0.796 Mg/ha/yr) is nearly five times the amount of C emitted by the steers (0.170 Mg/ha/yr.)

But here’s a problem for grazing advocates. It’s reasonable to assume that most of the C absorbed by the soil is from carbon dioxide (CO2) rather than from CH4, such as that emitted by the steers.2 Considered over a 20-year period (and without climate-carbon feedbacks), CH4 has 84 times the Global-Warming Potential (GWP)3 of an equivalent mass of CO2. Therefore, the methane emitted annually by the steers/ha has a GWP equal to 84 x 0.228 Mg (i.e. 19.152 Mg) of CO2. But the C

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sequestered annually by the soil (0.796 Mg/ha) represents only 2.95 Mg of CO2 (as C represents only 27 percent of a CO2 molecule). On balance, the CH4 emitted by the steers and the CO2 absorbed by the soil yields a net increase in atmospheric carbon with a GWP equivalent to 16.1 Mg of CO2. (Note: if the impact of CH4 is considered over a 100-year interval, rather than a 20-year interval, as has been common practice in many climate reports, the GWP [without climate-carbon feedbacks] is currently pegged at 28. Under that assumption, we find a steer/ha methane emission GWP equal to 28 x 0.228 Mg of CO2: 6.384 Mg —yielding a net annual atmospheric carbon increase equivalent to 3.434 Mg of CO2 after accounting for soil sequestration.)

From the perspective of sequestering atmospheric C, it would have been better to forego the grazing and settle for the lower rate of C sequestration afforded by the “unharvested” biomass treatment. But even this option begs a larger question about land use if the highest objective is to sequester atmospheric C. Consider that the landscape studied in Franzluebbers and Stuedemann (2009) is not a natural grassland, but was originally forest that was cleared to grow crops. Presumably, if allowed to doso, that land would revert to forest. And when it would, how much C would it likely sequester?

That question is answered by Huntington (1995),4 which like the Franzluebbers and Stuedemann (2009) study, was conducted in Georgia. Specifically, Huntington's work examined the rate of soil C sequestration over a 70-year period for abandoned cropland regenerating as forest. The rate of soil C sequestration was observed to range from 0.34 to 0.79 Mg/ha/yr. When above-ground biomass was included, the rate of C sequestration was observed to range from 1.81 to 2.26 Mg/ha/yr. These inclusiverates are 2-to-3 times greater than the best management regime (LGP) of land maintained as pasture in the Franzluebbers and Stuedemann (2009) study.

Similarly, undisturbed (native) forest in the same ecoregion was found in the Huntington study to contain soil C in the amount of 122 Mg/ha. Compare this to the 69.9 Mg/ha obtained with the best of the treatments (LGP) evaluated by Franzluebbers and Stuedemann on pasture, averaged over three zones to a cumulative depth of 150 cm (p. 31, Table 2). This data reveals that forest soil holds 74 percent more C than soil in the best managed pasture. 1. K.A. Johnson and D.E. Johnson, “Methane Emissions from Cattle,” Journal of Animal Science, 73 (8) (1995): 2483–92.

2. A Chinese grassland was found to offset only 3.1–8.6 percent of CH4 emissions from grazing sheep. See Xiaoya Wang, Yingjun Zhang, Ding Huang, Zhiqiang Li, and Xiaoqing Zhang. “Methane Uptake and Emissions in a Typical Steppe Grazing System during the Grazing Season,” Atmospheric Environment 105 (2015): 14–21.

3. Joe Romm, “More Bad News for Fracking: IPCC Warns Methane Traps Much More Heat Than We Thought,” ClimateProgress, http://thinkprogress.org/climate/2013/10/02/2708911/fracking-ipcc-methane/ (accessed 28 January 2015)4

4. Thomas G. Huntington, “Carbon Sequestration in an Aggrading Forest Ecosystem in the Southeastern USA,” Soil Sci-ence Society of America Journal 59(5) (1995): 1459–67.

Part 3: Grazing Team Critiques of the Teague, Burras, and Reeder Studies

Both Allan Savory (in his TED talk of February 2013) and Bill McKibben (in his Australian lecture of 2013) claimed that livestock grazing under Holistic Management would increase the soil’s ability to se-quester atmospheric carbon. Neither provided sources to substantiate their claims. A citation on a Savory Institute webpage (W. R. Teague, S. L. Dowhower, S. A. Baker, N. Haile, P. B. DeLaune, and D. M. Conover, “Grazing Management Impacts on Vegetation, Soil Biota and Soil Chemical, Physical

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and Hydrological Properties in Tall Grass Prairie,” Agriculture, Ecosystems and Environment 141 (2011): 310–22) may be that source. The Savory site notes that Teague et al. demonstrates that “regen-erative grazing” increases soil carbon by 30 tons per acre over that from conventionally grazed pas-tures. While the statement accurately reflects the findings of the cited research, the relevance to HolisticManagement is dubious, as the multi-paddock grazing studied in the research was described as “light tomoderate,” NOT the intense grazing advocated by Allan Savory. Not mentioned on the Savory Institute site, but even more significant from the perspective of reducing atmospheric carbon, the researchers found that multi-paddock grazing did not result in significantly greater soil carbon than that found in soil of comparable land from which grazing had been long excluded (see Teague et al., Table 5, p. 314).Since the addition of cattle to the landscape would introduce carbon into the atmosphere through meth-ane produced by enteric fermentation, the most effective action, from the perspective of reducing atmo-spheric carbon, WOULD BE “no grazing.”

Groups promoting grass-fed beef have asserted a number of carbon-sequestration claims supposedly based upon the following studies:

L. Burras and J. McLaughlin. 2002. “Soil Organic Carbon in Fields of Switch Grass and Row Crops as well as Woodlots and Pastures across the Chariton Valley, IA.” Final Report. Ames, IA: Iowa State Uni-versity.

Critique: A bar graph purportedly based on this study is currently posted on at least two grass-fed beef advocacy websites. The bar graph is both an oversimplification and misrepresentation of the findings ofthe study. While the overall soil carbon sequestration rates are higher on average for grazed pasture plots compared to un-grazed switchgrass plots, sequestering of carbon into the soil on medium-to-old-aged switchgrass plots occurred at values only marginally less than grazed pasture plots. Moreover, a significant number of the individual switchgrass plots registered sequestered carbon at very high levels that either matched or exceeded the highest values associated with pasture, woodland or corn row crop plots. In any case, the study failed to factor in methane emissions from livestock in its overall carbon budget accounting, resulting in a conclusion that seriously and inappropriately ignores the nullifying ef-fect of livestock-related methane emission on purported livestock-associated soil carbon sequestration.

J.D. Reeder and G.E. Schuman, “Influence of livestock grazing on C sequestration in semi-arid mixed grass and short grass rangelands,” Environmental Pollution 116 (2001): 457–63.

Critique: First, there is no accounting of cattle methane emissions in the overall carbon assessment; the study therefore ignores the nullification of any vegetation-induced soil carbon sequestration that would have likely been generated by cattle methane emission occurring on the grazed lands of the study. Sec-ond, the documented soil carbon sequestration differences in the short grass vegetation types of the study area are largely due to a vegetation type conversion generated by heavy grazing. This conversion could have been achieved without cattle, through burning the original vegetation type and replanting with blue grama grass. This alternative approach could have generated the soil carbon sequestration po-tential of blue grama grass without generating the cattle-induced methane emissions that likely counter-acted the blue grama-induced soil carbon sequestration that occurred.

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Appendix D: Critiques of Holistic Management

For the most recent broad critique of HM, see John Carter, Allison Jones, Mary O’Brien, Jonathan Ratner, and George Wuerthner, “Holistic Management: Misinformation on the Science of Grazed Ecosystems,” International Journal of Biodiversity, 2014, Article ID 163431 (10 pages).

The citation for the recent Briske et al. 2013 critique of the Allan Savory TED talk (which includes controversial carbon sequestration claims) is “The Savory Method Can Not Green Deserts or Reverse Climate Change,” Author(s): David D. Briske, Brandon T. Bestelmeyer, Joel R. Brown, Samuel D. Fuhlendorf, and H.Wayne Polley. Source: Rangelands, 35(5): 72–74. 2013. URL:

http://http//:grassworks.org/?300604/The Savory Method Can Not Green Deserts or Reverse Climate Change.pdf (Note that clicking on this link should download a pdf file to your computer. If, for some reason, the file does not automatically download, or the downloaded file cannot be located, the Briske et. al. 2013 paper can be accessed and downloaded by going to http://www.grassworks.org clicking on “Events”, then “Grazing News”, and then clicking on “response posted by Society for Range Management.”)

An enlightening debate between Teague and Briske (and his co-authors) was precipitated by this paper. The debate is presented in the following Rangeland articles:

Richard Teague. (2014) “Deficiencies in the Briske et al. Rebuttal of the Savory Method.” Rangelands 36:1, 37–38. 1-Feb-2014.David D. Briske, Brandon T. Bestelmeyer and Joel R. Brown. (2014) “Savory's Unsubstantiated ClaimsShould Not Be Confused With Multipaddock Grazing.” Rangelands 36:1, 39–42. 1-Feb-2014. (We wish to note that this Briske et.al. 2014 reply to Teague’s 2014 critique argues that many of Teague’s key claims concerning HM are, in fact, contradicted by Teague’s own 2011 study discussed above.)

The Sierra Club Grazing Team Memo on HM, dated April 2, 2013 is presented below:

From: Sierra Club Grazing Core TeamTo: Sierra Club staff & volunteers (particularly those involved with

sustainable-energy/climate-change campaigns, and commercial grazing onpublic lands)

Subject: Allan Savory’s proposed application of “Holistic Management” to grasslands, including desert grasslands, for the purpose of increasing sequestration of atmospheric carbon

Date: April 2, 2013Contact: Mike Hudak, Leader, Grazing Core Team, 607-240-5225, mailto:mike.hudak@gmail.com

Summary

Recent widespread interest in Holistic Management (HM), primarily stemming from Allan Savory’s presentation at the February 2013 Long Beach, CA, TED conference, makes it important that Club members and staff be consistent in their response to calls for application of HM. Savory has received considerable attention for his claim that application of HM to husbandry of ungulate livestock (typically cattle) in the world’s grasslands could sequester sufficient atmospheric carbon to reduce atmospheric carbon concentrations to pre-industrial levels. The Sierra Club’s Grazing Core Team urges

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the Sierra Club to reject HM as a tactic to reverse climate change for the following reasons:

1) independent scientific research (in contrast to anecdotes from promoters and users of HM) since the early 1980s has not shown HM to perform better than other grazing management methods,

2) applications of HM have produced mixed results, but in arid regions worldwide have often led to further environmental degradation,1

3) Savory’s characterization of a “desertified” grassland is contradicted by well-established scientificunderstanding of desert ecology, particularly as regards biological soil crusts, and

4) claims of HM’s widespread ability to increase sequestration of atmospheric carbon have not been independently studied and are indirectly contraindicated by recent, peer-reviewed research showing that grazing exclusion in some grasslands actually increases carbon sequestration relativeto continued grazing.

Details

Holistic Management (HM) is a general plan for land management promoted by its developer Allan Savory2 under one name or another since the 1970s. The best-known application of HM occurs in livestock husbandry. Most attractive to ranchers has been the claim that through the use of HM, they could greatly increase their production of livestock—doubling it or more.

At the February 2013 Long Beach, CA, TED conference, Allan Savory,3 went further, stating that HM applied to husbandry of ungulate livestock in grasslands worldwide could reduce atmospheric concentrations of carbon to pre-industrial levels. This miracle would supposedly occur through the sequestering of atmospheric carbon that would result from the greater production of vegetation in turn resulting from the grazing of livestock. The Sierra Club Grazing Core Team questions Savory’s claim on several grounds.

Savory proposes using domesticated livestock, such as cattle or sheep, to replicate the behavior of migrating native ungulates in grassland ecosystems. In the desert grasslands of the American West, much of which are managed as federal public lands, large herds of large ungulates in any way resembling cattle have been absent for more than 10,000 years. Consequently, intensive herding of cattle in these regions does not replicate any natural process with which the current native vegetation has evolved.

1�. David E. Brown, “Out of Africa,” Wilderness (Winter 1994): 24–27, 30–33; Jon Skovlin, “South Africa’s Experience with Intensive Short Duration Grazing,” Rangelands 9(4) (August 1987): 162–67.2�. Allan Savory, Holistic Management (Washington, DC: Island Press, 1999).3�. Allan Savory: How to Green the Desert and Reverse Climate Change, TED: Ideas Worth Spreading, filmed February 2013, posted March 2013, http://www.ted.com/talks/allan_savory_how_to_green_the_world_s_deserts_and_reverse_climate_change.html (accessed March 23, 2013)

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Savory’s TED talk and the website of his organization (Savory Institute, http://www.savoryinstitute.com/) provide examples of environmental improvement of ranched landscapes after application of HM. Lacking, though, is independent verification of these claims, without which we cannot know whether such improvement occurred because of HM or coincidentally for other reasons. Sierra Club Grazing Core Team member George Wuerthner in his 2002 book WelfareRanching4 noted that HM requires much more diligent monitoring of livestock than is typical, particularly for ranching on public lands. The very act of paying greater attention to livestock grazing (and properly responding to on-the-ground conditions) may be the major factor underlying improved environmental conditions.

We also note that versions of HM have been studied by academic researchers since the early 1980s. Results of many such studies have been compiled into what are called “summary” or “synthesis” papers. Particularly notable are such studies by Skovlin (1987),5 Holechek et al. (1999),6 and Briske et al. (2008).7

In general, these authors did not find support for claims that HM with high-stocking rates benefits cattle and the environment. And when stocking rates were comparable to those of other grazing approaches, performance of HM also was not superior.

Perhaps even more damning of HM than the three articles cited above is one by Joseph et al. (2002)8 which reviewed the Charter Grazing Trials, of which Allan Savory once wrote “The only trial ever conducted proved what I have always advocated and continue to advocate when livestock are run on any land.”9 But Joseph et al. in summarizing these Trials stated “Our review of findings from African studies on short-duration grazing including the ‘Charter Trials’ shows a very high similarity to those from North America summarized by Holecheck et al. (2000).” The Holechek et al. (2000) study (as cited in footnote #6) reports that HM (studied as “short-duration grazing”) performed no better than continuous grazing in regard to water infiltration, soil erosion, plant succession, range condition, forageharvest efficiency, and financial return when stocking rates were comparable. And short-duration grazing actually performed worse than continuous grazing when stocking rates were higher!

But although Allan Savory has since the 1970s promoted HM (or its predecessors “Savory Grazing Method” and “Holistic Resource Management”) as the solution to repairing degraded landscapes and

4�. George Wuerthner, “The Donut Diet: The Too-Good-To-Be-True Claims of Holistic Management,” In Welfare Ranching:The Subsidized Destruction of the American West, ed. George Wuerthner and Mollie Matteson (Washington, DC: Island Press, 2002), 292, http://www.publiclandsranching.org/htmlres/wr_donut_diet.htm (accessed March 23, 2013)5�. Jon Skovlin, “South Africa’s Experience with Intensive Short Duration Grazing,” Rangelands 9(4) (Aug 1987): 162–67.6�. Jerry L. Holechek, Hilton Gomes, Francisco Molinar, Dee Galt, and Raul Valdez, “Short-Duration Grazing: The Facts in 1999,” Rangelands 22(1) (February 2000): 18–22.7�. D.D. Briske, J.D. Derner, J.R. Brown, S.D. Fuhlendorf, W.R. Teague, K.M. Havstad, R.L. Gillen, A.J. Ash, and W.D. Willms, “Rotational Grazing on Rangelands: Reconciliation of Perception and Experimental Evidence,” Rangeland Ecology& Management 61(1) (January 2008): 3–17.8�. Jamus Joseph, Francisco Molinar, Dee Galt, Raul Valdez, and Jerry Holechek, “Short Duration Grazing Research in Africa,” Rangelands 24(4) (August 2002): 9–12.9�. Allan Savory, “Letter to the Editor,” Rangelands 22(3) (June 2000): 32–33.

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increasing the wealth of ranchers, he has now gone one huge step further in his Feb 2013 TED talk by suggesting that HM applied especially to grasslands of Africa and the Middle East is the only hope formitigating the causes of global climate change.10 In challenging this claim, we cite peer-reviewed studies that contraindicate using ANY livestock grazing to increase sequestration of atmospheric carbon. For example:

1) That desert biological soil crusts “can be dominant sources of productivity and carbon sequestration in extremely dry environments, and they can contribute to soil fertility through the fixation of nitrogen.”11 These are the same crusts that Allan Savory in his February 2013 TED talk referred to asa “cancer” on the landscape, the destruction of which he advocated through the grazing of livestock.12

2) A study of Leymus chinensis grasslands of China with exclusion of livestock grazing for 3-yr, 8-yr, 20-yr, 24-yr, and 28-yr found the highest amount of carbon sequestration in soil and aboveground biomass after 20 years. Study authors conclude “Grazing exclusion for two decades increased the soil C [carbon] and N [nitrogen] storage by 35.7% and 14.6% respectively, in the 0- to 40-cm soil layer. The aboveground net primary productivity and soil C and N storage were the highest with 24-yr GE [grazing exclusion] and the lowest with free grazing.13

3) Study of a semi-arid grassland in China found “The C stocks in aboveground biomass, belowground biomass and litter were 64–86% (P<0.01), 58–157% (P<0.01) and 55–125% higher (P<0.01), respectively, in grazer excluded grassland than in grazed grassland.” While C in aboveground biomass and surface litter maxed out after grazing exclusion of 22 years, C in roots biomass was maximum after 27 years of grazing exclusion. Grazing exclusion also significantly increased organiccarbon (OC) concentration and stocks in the 0–80 cm soil layer. The OC concentration was 6–14% higher (P<0.01), and OC stocks were 49–77% higher (P<0.05) in grazer excluded grassland than in grazed grassland, with highest concentrations and stocks in the 17-year grazing exclusion treatment.14

10�. Savory’s relevant statements from his Feb 2013, Long Beach, CA, TED Talk: “I remind you that I am talking about most of the world’s land here that controls our fate, including the most violent region of the world, where only animals can feed people from about 95 percent of the land. What we are doing globally is causing climate change as much as, I believe, fossil fuels, and maybe more than fossil fuels. But worse than that, it is causing hunger, poverty, violence, social breakdown and war, and as I am talking to you, millions of men, women and children are suffering and dying. And if this continues, we are unlikely to be able to stop the climate changing, even after we have eliminated the use of fossil fuels.” And “if we do what I am showing you here, we can take enough carbon out of the atmosphere and safely store it in the grassland soils for thousands of years, and if we just do that on about half the world’s grasslands that I’ve shown you, we can take us back to pre-industrial levels.”11�. Zoe G. Cardon, Dennis W. Gray, and Louise A. Lewis, “The Green Algal Underground: Evolutionary Secrets of Desert Cells,” BioScience 58(2) (February 2008): 114–22.12�. Allan Savory’s relevant statement from his Feb 2013 TED Talk pertaining to biological soil crusts reads: “But if you do not look at grasslands but look down into them, you find that most of the soil in that grassland that you’ve just seen is bare and covered with a crust of algae [a.k.a., “biological soil crusts”], leading to increased runoff and evaporation. That is the cancer of desertification that we do not recognize till its terminal form.”13�. Wu L, He N, Wang Y, and Han X, “Storage and Dynamics of Carbon and Nitrogen in Soil after Grazing Exclusion in Leymus Chinensis Grasslands of Northern China,” J Environmental Quality 37(2) (Mar–Apr 2008): 663–68.14�. Qui L, Wei X, Zhang X, Cheng J, “Ecosystem Carbon and Nitrogen Accumulation after Grazing Exclusion in Semiarid Grassland,” PLoS ONE 8(1): (2013): e55433. Doi:10.1371/journal.pone.0055433.

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4) In an Australian semi-arid (12" mean annual precipitation) shrubland, destocking currently grazed areas for 20 years resulted in net C accretion in the order of 6.5 Mg/ha.15

Conclusion

WHEREAS, a generation of independent, peer-reviewed, scientific studies have failed to verify the significant benefits claimed for HM as a land management tool; and

WHEREAS, peer-reviewed studies demonstrating that desert biological soil crusts (targeted for destruction by HM’s developer Allan Savory) sequester atmospheric carbon and nitrogen, and whose disruption decreases organism diversity, soil nutrients, soil stability, and organic matter;16 and

WHEREAS, peer-reviewed studies demonstrating that exclusion of livestock grazing in grasslands increases carbon sequestration relative to such grazing;

THEREFORE, the Sierra Club Grazing Core Team urges the Sierra Club (and its related entities, e.g., Sierra magazine) to reject HM as a tool to reduce atmospheric carbon.

To the extent that application of HM to a given situation leads to improved range conditions, the most likely reasons are incidental to, and in spite of, the purported ecological underpinnings of HM—those reasons being improved livestock distribution, improved control of the frequency and severity of defoliation of individual plants, and intensified management, as was pointed out many years ago.17

Allan Savory’s Feb 2013 TED talk has drawn harsh, widespread criticism from knowledgeable, conservation-minded individuals18—criticism indicative of how the Club’s credibility could be diminished by its association with HM in pursuit of combating global climate change.

15�. Stefani Daryanto, David J. Eldridge, and Heather L. Throop, “Managing Semi-arid Woodlands for Carbon Storage: Effects on Above- and Belowground Carbon,” Agriculture, Ecosystems and Environment 109 (2013): 1–11.16�. An Introduction to Biological Soil Crusts (updated April 24, 2006), USGS Canyonlands Research Station, Southwest Biological Science Center, Moab, UT, http://www.soilcrust.org/crust101.htm (accessed March 26, 2013)17�. Rod Heitschmidt and John Walker, “Short Duration Grazing and the Savory Grazing Method in Perspective,” Rangelands 5(4) (August 1983): 147–50.18�. Adam Merberg, “Cows Against Climate Change: The Dodgy Science Behind the TED Talk,” Inexact Change: Thoughtson Science, Politics, and Social Progress, March 11, 2013, http://www.inexactchange.org/blog/2013/03/11/cows-against-climate-change/ (accessed March 23, 2013); Chris Clarke, “TED Talk Teaches Us to Disparage the Desert,” March 15, 2013, http://www.kcet.org/updaily/socal_focus/commentary/east-ca/learn-how-to-hate-the-desert-with-ted.html (accessed March 23, 2013); Chris Clarke, “TED Talk: Spreading Bullshit About the Desert,” Pharyngula, http://freethoughtblogs.com/pharyngula/2013/03/15/ted-talk-spreading-bullshit-about-the-desert/ (accessed March 26, 2013); Michael Tobis, “Alan Savory, Dyson and Soil Sequestration,” Planet3.0: Beyond Sustainability, March 17, 2013, http://planet3.org/2013/03/17/alan-savory-freeman-dyson-and-soil-sequestration/ (accessed March 23, 2013); Chris Clarke, “Adam Merberg on Grazing and Allan Savory and TED,” Pharyngula, March 17, 2013, http://freethoughtblogs.com/pharyngula/2013/03/17/adam-merberg-on-grazing-and-allan-savory-and-ted/ (accessed March 26, 2013); Ralph Maughan, “Alan Savory Gives a Popular and Very Misleading TED Talk,” The Wildlife News, March 18, 2013, http://www.thewildlifenews.com/2013/03/18/alan-savory-gives-a-popular-and-very-misleading-ted-talk/ (accessed March 23, 2013); “Great White Hunter,” Sustainability for Animals, March 23, 2013, http://foranimals.org/great-white-hunter-2/ (accessed March 25, 2013); Guy R. McPherson, “Peak Patriarchy?,” Nature Bats Last, March 24, 2013, http://guymcpherson.com/2013/03/peak-patriarchy/ (accessed March 25, 2013); Robert Goodland, “Meat, Lies, & Videotape (A Deeply Flawed TED Talk).” Planetsave, March 26, 2013, http://planetsave.com/2013/03/26/meat-lies-videotape-a-deeply-flawed-ted-talk/ (accessed March 28, 2013)

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Signed:

All members of the Sierra Club Grazing Core Team (listed alphabetically):

Greta AndersonJim CatlinKen ColeEd DobsonVeronica Egan

Brian ErtzBrock EvansJanet MaxwellAnne MillbrookeWayne Hoskisson

Mike Hudak, Team LeaderMark SalvoGeorge WuerthnerChris Yoder

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