Certified Weed Free Feed Dictum by Feds

[connie B Berto <cberto@juno.com>]

To equestrians, their organizations, and the American Horse Council:  
Please read this message, and then think of its possible applications to
every horseback rider in the United States, and all  sanctioned rides by
AERC, NATRC, etc., etc.  ---   and then contact your congressional
representatives....    Connie B
 ------------------------------Forwarded Message-----------

	Subject:   US Forest Service, Bureau of Land Management and
National
Park Service mandating that the State of California adopt a Certified
Weed
Free Feed program for Recreational Stock use on Federal Lands.

	Dear Toby:
	This problem has been perking along for the past several years,
with
horsemen either being unaware of it or ignoring it.  It has been a
potential
threat in San Mateo County since 1996, spurred on by the California
Native
Plant Society (CNPS).  I strongly caution the Back Country Horsemen (BCH)
NOT to view this as simply
a back country horse issue.  The reality is that with the Feds moving
rapidly along the path described by your memo below, it is conceivable
that
every watershed, open space district, state and county park could also be
forced into implementing similar flow down regulations under pressure
exerted by the very powerful CNPS.  It is not difficult to conceive of a
condition where horses will not be allowed on public lands unless there
is
proof of certified weed free feed consumption.  If this reality occurs,
feed
suppliers will need to be producing enough feed for recreational users
throughout the state (and nation) which will drive up the cost of feed
production across the board.

	What is most galling is that this unilateral decision has been
made
without science and data to support its need.  It is imperative that
equestrians mount a full blown research project THIS WINTER to collect
manure and feed samples from all over the state.  Each source must be
analyzed for gross number of seeds, then those from the manure germinated
to
determine viability and type of seeds.  If a significant proportion of
the
exotic noxious weed seeds are present, then we have a problem which will
justify a new feed cropping pattern and certification.  If not, then we
have
ammunition to ask them to back off or do their own studies.

	The main culprit is probably in the feed stock itself.
Documentation exists that these exotics were introduced to North America
both from disgorging ballasts of ships and in feed stock brought imported
to
support the early livestock industry.  Some of these exotic seeds can be
viable 80 years.  Controlling seeds in feed stock introduced to
trailheads/campsites,etc. should be a relatively simple procedure,
reliant
on heated food products currently available as suggested below. This
issue
of certification of the feed stock from the farmer as outlined by the
attachment seems reasonable enough, but will add to costs.

	But what about the horse itself as a seed carrier?  EnviroHorse
has
looked into published research on this issue to some extent.  Many of the
really invasive plant species are toxic to horses, so probably are not
being
consumed and spread in manure.  If eaten in the pasture, they are likely
to
ingest seeds too immature to reproduce. However, we DO NOT KNOW THIS FOR
CERTAIN.  Lacking the information, we cannot proffer the argument.  WE
MUST
HAVE RESEARCH.  It must be undertaken by credible scientists.  Once we
know
our potential risk, then we can chart a reasonable response.

	Clearly the issue that will be most difficult for the horse
community is to develop a mechanism that does not require the 12 hour
quarantine at a public corral before we can use any public lands.  This
type
of enforcement could pose significant health hazards to livestock and
inconvenience to owners.  We must come up with a voluntary,
self-regulating
mechanism to identify horses who are in the midst of a weed free feed
eating
regimen.  Some ideas that immediately come to mind include:
1.	A tag that could be affixed to a bridle, bozall, etc. saying "I
am
weed seed free"
2.	A certification that could be placed on file with the land
management jurisdiction promising compliance for some time certain
(annually, 3 years, etc) when expecting to use the property.
3.	Making weed free feeding a condition of membership for BHC, Cal
State Horsemen, and other organizations, commercial stables, pack
strings,
etc. (as part of a business license). 
4.	Many of use carry keys which access private and public land
which
could serve as weed free feed passports.  Certification could occur at
application for the access.
5.	Etc

	I cannot urge you strongly enough in the direction of research. 
If
data support the fact that horses only ingest 30% of seeds found in feed
stock; if only 10% of seeds ingested are viable; and if <1% of viable
seeds
are the exotics of concern DO HORSES POSE MUCH RISK?  We cannot know what
level of risk we pose without doing these studies.  I believe that the
horse
community must fund this research asap to keep this steamroller from
getting
out of control.

	Thanks for all of your hard work and keeping us informed. 
Regards
from Adda Quinn of EnviroHorse

	******To the recipients of the copy of this letter I am asking
for input
on what mechanism you can think of to indicate a weed free feed status
for
our horses to avoid quarantines being proposed.  Also, if BHC (or other
?)
decides on research, would your clubs and associations be willing to help
fund?  ******


	Letter from Toby Horst to BCHC Members and Friends:

	I know these reports are happening rapidly and we never seem to
get
our breath.  That is the situation of the BCHC and Public Lands Issues. 
We
can only take one at a time and respond the best way we can.  

	On this issue of Certified Weed Free Feed (CWFF) we seem to have
been sucked into a one way street.  Our only recourse seems to be work
with
the Ag Commissioners and get the best program possible.  The feds have
forced the State into the program.  We can write our Representatives and
inform them that we are fed up with manipulative government. I'm not sure
what good it will do but it relieves our frustrations.

	In the mean time lets go after the Sierra Nevada Framework
Project
which was the project that set this in motion. We need to respond in mass
to
the one year review period and be ready to respond to the DEIS when it is
issued in October.

	Toby Horst
	BCHC Public Lands regional Coordinator 

	
----------------------------------------------------------------------------
-----------------
	BCHC, do you want a Certified Weed Free Feed Program for your
Recreational Stock (Horses, Mules, Burros, Llamas and Goats)?

	The title of this report is a leading question but summarizes the
intent and discussion that is involved about the US Forest Service,
Bureau
of Land Management and National Park Service mandating that the State of
California adopt a Certified Weed Free Feed program for Recreational
Stock
use on Federal Lands. 

	Introduction

	The Backcountry Horsemen of California (BCHC) were ask to attend
a
meeting in Sacramento, Monday, Sept. 13 1999, to discuss and be informed
on
the developing details of the Certified Weed Free Feed (CWFF) Program and
to
solicit our support. Those present from BCHC were Dan Suther D.M.V., Past
BCHC President, and Toby & Katie Horst, Public Lands Regional
Coordinators.
We were informed that it is not a question of whether the program goes
ahead
but only in what form and would we please work with the State Department
of
Food and Agriculture  and County Agriculture Commissioners to make the
program practical and workable from the Recreational Stock perspective.
After listening to the details of the program developed thus far, we
agreed
that we would work with the Commissioners to develop a CWFF program. BCHC
still seriously questioned the evidence that Recreational Stock Use on
public lands is a cause of the spread of noxious weeds (non native) in
California.  The BCHC also agreed, based on the evidence of past and
present, that there is a serious problem in the State of California with
the
spread of noxious weeds and their effect on private and some public
lands. 
	California is not the only State developing such a Certification
Program.  Colorado, Wyoming, Montana, parts of Utah and Idaho already
have
such programs.  The programs differ some from state to state but their
purpose is all the same, the control of the spread of noxious weeds. 
	All this being said, the meeting proceeded to outline the
requirements of setting up such a program and making it workable for the
Recreational Stock User.

	Some pertinent facts to consider:

	... It is estimated that no more than 12,000 tons/yr. of alfalfa
hay
would be involved for use in federal lands by Recreational Stock Users
(18
National Forests and BLM areas).  This is an estimate of Commercial
Packers,
Private Recreational Stock, Cattle Grazing Permiteešs riding stock and US
Forest Service or BLM Stock. 
	... This amount of hay is a very small percentage of the alfalfa
production in California.
	... Every federal land stock user would have to have access to
certified feed in their geographic area.
	... The small user would have to be able to purchase CWFF in less
than 10 bale portions.
	... The program will have the means to trace certification from
groweršs field to end user for evidence of use.
	... It is proposed that Recreational Stock Users would have to
feed
CWFF to their stock in a confined area at least12 hours before stock use
on
federal lands. While riding on federal lands use only CWFF.
	... The Forest Service is proposing the possibility of
"quarantine
public corrals" to facilitate control of 12 hour period
	... Oat hay and other forms of forage were not considered in this
evaluation but would also have to be CWFF.
	... All grains for supplemental feed must be also certified weed
free. Heating the grain kills the seed germ so it will not propagate
therefore pellets and steam rolled grains are acceptable as weed free.

	Discussion Points:

	... The meeting was well organized and the County Ag.
Commissioners
expressed frustration at not getting the BCHC and other equestrian groups
to
participate in the development of the CWFF program.
	... The Commissioners expressed doubt that the cost for CWFF
would
cause a significantly increase. BCHC commented that when considering the
grower availability and distribution process for user access, we expected
costs would increase.  How much is an open question. 
	... There are 130 plus noxious weeds on the California State weed
list.  As we understand it, none of these would be allowed in the CWFF
program.
	... The BCHC expressed doubts that a " Forest Service Quarantine
Corral Process" as proposed in the SNFP would be reasonable or practical
considering the amount of day ride users of federal lands in California.
This would add an additional day of on site commitment to every user any
time a trip is planned. There are now very few corrals on Forest Service
property.  Is the Forest Service planning to add corrals?
	... BCHC expressed concern that there is no record keeping system
of
users except in Wilderness Areas and Parks.  Is the Forest Service and
BLM
going to institute a system for Recreational Stock that records all other
areas and day use?  If so, BCHC is strongly opposed especially when we
see
no documentation or survey data that supports the contention that the
spread
of noxious weeds in California is caused by Recreational Stock. 
	... BCHC perform thousands of volunteer work hours each year on
public lands.  To have to conform to the proposed Sierra Nevada Framework
(SNFP) Standards and Guidelines would significantly effect the planning
and
work period because of the on site confined holding period.  Why not
trust
the people to hold their recreational stock in personal confinement and
show
certified feed documentation that CWFF was used? 
	... There will be another CWFF Program meeting in mid October.
Representatives of BCHC have been invited to attend.  We need comments
from
as many BCHC Units as possible in order to represent your thoughts and
concerns.

	Toby Horst,  BCHC Public Lands Regional Coordinator
	Tel  559-855-7765 
	FAX  559-855-2236
	Easyrider@psnw.com <mailto:Easyrider@psnw.com> 

	Cc:	Joanna Cline, US Forest Service
		Karl Bishop, Agricultural Commissioner, Plumas/ Sierra
Counties

	The document below is the government proposal:

 <<weedfreefeeddraft.doc>> 



--------- End forwarded message ----------


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