Comment from Short, Craig

Hello, I am writing to express great concern about the pest mitigation efforts put forth in this document. Many of the fundamental assumptions of the document seem to be flawed. If grasshoppers are competition for forage in degraded areas, it is because the area has been degraded in the first place by poor management of the land. Cattle grazing is not natural to ecosystems in North America - we know this. Much research has been done to find ways to make it more sustainable, but the economic interests of ranchers and the state and federal bodies granting them public lands have always eclipsed any interest in the clear and devastating effects of cattle on North American ecosystems - soil degradation, damage to riparian areas, overgrazing of forage, the introduction and creation of more suitable conditions for invasive annual grasses, disruption of natural fire regimes. Grasshoppers exist as part of a balanced and sophisticated natural machine (ecosystem) that keeps lands productive and healthy. If their populations are out of balance, it is because that natural machine is itself out of balance. Rather than grasp at fixes for symptoms (grasshopper "outbreaks") we need to put serious effort into addressing the illness (mismanagement of land through cattle grazing). Chemical treatments as listed are guaranteed to further degrade ecosystems. As global insect populations fall, no amount of collateral damage to native pollinator and arthropod populations can be ignored or considered to be inconsequential. These chemical treatments described pose the risk of a vicious cycle of continual habitat disruption, decline in forage availability, subsequent overgrazing, further grasshopper "outbreaks" in response to degraded habitat, and the resulting IPM efforts that have potential to continue degrading habitat. I was concerned to read about the calculation of value for public lands being reduced to a "single market value." This is obviously a poor measure of the worth of land. Even considering recreational or "existence value" (which will clearly never be a legislative priority in this economic climate) seems terribly incomplete. What about the clear economic value of healthy habitat? Living soil and healthy plant communities provide crucial services that cannot be overlooked in our calculations - they retain and store water in soil, enriching watersheds and aquifers and decreasing the amount of water lost to evaporation and runoff. They filter rainwater as it flows through watersheds, improving water quality over a broad area. They reduce heat and improve carbon cycling, which becomes ever more valuable in a warming climate where carbon capture becomes a priority. We cannot improve on the efficacy or thrift of well-adapted ecosystems to provide these services. No human system or invention approaches their sophistication. The degradation of ecosystems has wide-ranging effects on climate, temperature, and water availability. This must be considered in our calculations, and given explicit monetary value based on the potential costs of climate mitigation should the ecosystem be destroyed. Not all of the chemical treatments listed in this document are confirmed to be carcinogenic, but the science on these matters is often slow. Shall rural populations be treated as lab rats while we discover the long term health effects of exposure to these compounds? While we scramble for quick fixes for unbalanced insect populations, we risk poisoning our own people in our haste. Questions I wish were being asked in this review process are as follows: - What are the negative economic consequences of cattle grazing in Western North American ecosystems, and how may we justify them when considering the economic value of healthy habitat? - How could our county, state, and federal governments promote nondestructive economic use of public land that avoids the need for expensive and dangerous treatments for unbalanced insect populations? - How could markets for ranching native grazing animals (bison, elk) be fostered and expanded by government bodies in place of cattle grazing? - How can we more accurately calculate the economic value of healthy habitat, and how can the monetary costs of degrading land be more accurately assessed when considering large scale, landscape-level externalities? I thank you for the opportunity to make my voice heard.