LORP Draft EIR/EIS Issue: 

Grazing Management Plans

Sample Statement

Understory impacts as a result of current grazing are severe in riparian habitats in much of the LORP area.  In many places there is no understory and there are no young willows or cottonwoods.  Several habitat indicator species such as the yellow-breasted chat are dependent on habitats with trees and a dense understory in the riparian zone.  Unless the diversity of habitat provided by understory growth significantly improves, the habitat goals for the river system will not be met.  Monitoring for understory development as described on p. 2-78 will not be conducted unless the need for it is determined in some unspecified future time by unspecified means.  Whether or not this important monitoring function is needed should not be left to some future decision.  There should be a clear comittment to conduct this monitoring as the need for it is obvious.  Protocols for this monitoring data collection and analysis should also be included in the EIR/EIS.

Additionally, individual grazing lease management plans are not provided in the document and LADWP has denied requests by reviewers to see them.  Without these critical documents and with no evaluation of the present lease condition and trend presented in the Draft EIR/EIS there is no way to compare change over time when evaluating whether the goals of the project are being met.  There is no way for commenters to evaluate proposed management, monitoring and the need for mitigation.  This is inadequate.