That has gone on for some little time, and two years ago I attended a meeting of the woolgrowers of that particular forest, at which I made the statement:

You opposed the reductions that were made because you believed that we were understocking, but after the experience of these years I believe the wool men of this forest are in unanimous agreement that we were right.

And I have talked to a large number of those same permittees using that forest, and they agree now that we were right. So in that instance, although we reduced without the consent of the users, time has vindicated our judgment.

During the past 10 years at least there have been no reductions. made on any national forest in district 4 for range protection without the matter was first taken up with the association, and there have been no reductions but what the stockmen have agreed substantially with the necessity therefor.

Then we have the question of the seasons. During the past 10 years there has been no shortening of the season except on substantial agreement with the advisory boards. Now, I want to be frank and admit frankly that we use all the pressure we can if we believe it is necessary to reduce numbers or change seasons as a means of range protection. There is no disposition on the part of the Forest Service to understock, nor is there any disposition upon the part of the Forest Service to keep stock off later than range conditions warrant. In the main, so far as I know, the cattle ranges now are opened as early as there is any reasonable amount of feed for the stock. I admit that occasionally there are spots of range on the lower fringes where perhaps the stock are kept off a little later than forage conditions require, but in those instances we stand ready and have always stood ready to allow the stock on those ranges if the stockmen will confine the stock to the areas that are ready for use.

Now, in doing this we have in mind, of course, the carrying capacity of the range, the numbers of stock that it will carry. We have believed all the time that one of the important things from the livestock standpoint is summer range, because that is the important part of the range business in this district. You are on summer range perhaps more than anywhere else. The summer range is especially disproportionate with the winter range; there is more winter range, in other words, generally speaking. So that, so far as possible, we want to make it possibe to carry the largest possible number of stock on the forest ranges.

We give to these associations, in the main, all the responsibility that we can get them to accept. In the question of allotment boundaries between individual permittees the associations have not seemed to feel that they wanted to take any particularly active part in deciding between individuals. It is the established policy of the district, however, that there will be no changes in allotments between individuals except when the individuals concerned first have an opportunity to be heard.

Many of the restrictions for which the Forest Service has been and is being severely criticized are those that have been requested by the stockmen-not all of them, but many of them. Take the question of seasons on the cattle ranges. Very often the advisory boards and quite a percentage of the permittees, perhaps a majority

of them, do agree that we need later seasons, and they consent to it. There is then a substantial minority who severely criticize the change, because in any unit of range every individual is not equipped with the same kind of operating plant. Many of them may have a plant that provides for them during the winter and spring very well up until the time the season opens.

There are men, however, that do not have that kind of plant, and consequently again the minority rule must apply; because it would be obviously unfair to allow some individuals to enter the range ahead of others who were situated to take care of their stock and who are paying for the use of that range. In other words, they want the feed in the best shape when they get on that range. In certain cases we have special rules requested by the stockmen, as for instance that an individual permittee be not allowed to go on the range to gather his stock except at specified times agreed to by the board and the local ranger; in other words, with the consent of the board and the ranger. That is because of the disturbance that that creates if an individual goes up there and gathers his stock. They have requested these rules, and while we have enforced them, that is where we are subjected to the worst kind of criticism from the few individuals who insist that they should have a right to gather their cattle as they see fit. Transfer cuts have come in for a lot of criticism. I would like to tell the committee here and now that the transfer-cut idea originated on the recommendation of the stockmen. The Idaho wool growers took the initiative in that proposition. They believed that a transfer cut would result in eliminating unnecessary speculation in the permit privilege, and consequently requested that that be made a regulation, and it has been in effect since that time.

The salting proposition, about which there is considerable complaint, is simply another effort to secure uniform utilization of the range and thereby increase the carrying capacity. The old method of salting was generally on the water or on the open flats--not always, but generally. That tends to congregate the cattle in these likable places. Instinctively cattle will go on the flatter and more accessible areas of the range, and unless there is some effort to secure utilization of the rougher portions there is likely to be an economic loss and a reduced carrying capacity.

Now, so far as the Forest Service is concerned, if the stockmen want to stock on the basis of the area used rather than on the total carrying capacity of the possibly useable area, certainly we are perfectly willing to do that, except that we believe it is poor administration. We want, as I said before, to get out of those ranges the fullest possible carrying capacity.

In the development of grazing regulations the livestock associations have had a very prominent part. The Idaho woolgrowers in particular were active for years in recommending changes in regulations. The Lincoln County Wool Growers' Association, of which I believe Mr. Noblitt is president, have had a prominent part in suggesting changes.

The Nevada association and many other associations have constantly suggested changes that have become a part of the regulations. I do not mean to imply that the stockmen have agreed to all the regulations, but I do say that a substantial part of the regulations is

the outgrowth of hundreds-yes, thousands-of conferences between Forest Service officers and the stockmen. We have sat together repeatedly in deliberate and sincere consideration of the problems with an effort to work out what seemed to be in the interest of good administration and in the interest of the livestock business. We have often stood out, admittedly, against the recommendations of the stockmen, sometimes because of administrative needs and the other interests involved in national-forest administration, and sometimes on questions where we believed the stockmen themselves were recommending things that would be detrimental to their own interests.

In that connection I want to call attention to the commensurability standard that has been so severely criticized and under which we have been accused of forcing overinvestment in ranch lands.

The commensurability standards, as they have been applied, so far as we could get the stockmen to act, have been based on the recommendations of the stockmen. Within the last year we have attempted to modify those standards, and personally I have had a decided disposition to modify them downward. In every instance where I presented that problem to the stockmen I have met opposition. And it has taken consistent and persistent argument to convince the stockmen that they were working against their own interests in attempting to force up those commensurability standards.

I fully appreciate why the stockmen have tended to do that, because I believe sincerely that a high standard would tend to militate against the newcomer. It has been a hard problem to convince the stockmen that you can not create standards that will eliminate the beginner, because the beginner can meet any standard that you fix. If he can not meet it for a thousand head, he can meet it for 500 head. So that you can not attempt to establish a standard of commensurability that the beginner can not meet for some number or another.

Speaking of the question of stability, from the outset there has been a decided disposition in Forest Service administration to stabilize the livestock industry in so far as it was affected by the use of the national forests. In the first place, we attempted to protect the range. We reduced numbers, admittedly often against the wishes of the stockmen, but with the express purpose of protecting the resource on which that industry is built.

The numbers of stock grazed by individuals has been largely worked out in cooperation with the stockmen themselves. From the outset, and particularly in the beginning, the division of range or the division of preferences between the individual was largely based on the judgment of the stockmen. Obviously the Forest Service officers had no way of knowing or determining, except with the help of the stockmen, how many this fellow should have or that fellow should have, and so on, because the stockmen themselves know best how they had operated, and who had operated and the numbers of stock they had generally operated. So that in the main the division of the privileges in the first place were largely the outgrowth of the combined judgment of the Forest Service officers and stockmen.

It is true we have admitted beginners. And it is also true that a percentage of the stockmen have consistently opposed that principle. It is likewise true that a large percentage of the stockmen

have favored that principle. But notwithstanding the fact that we have admitted them, we have also surrounded the beginner with such restrictions as to substantially militate against the necessity of wholesale admittance. Because we fully appreciate that a wholesale admittance would paralyze the operations of the man already established.

The qualifications required of the beginner and the limitations placed on numbers with which we would admit him, of course have materially curtailed the encroachment from that source. To indicate the extent to which we have kept them out consistently for the past 15 or 18 years the following figures are significant. We have approved in the last 10 years 7,360 beginners for cattle.

Mr. BOWDEN. Is that in this district?

Mr. WINKLER. That is in this district. We have denied during that time 4,350 cattle beginners, with 124,687 cattle.

We have admitted 1,815 beginners with 470,000 sheep.

We have denied 2,245 beginners with 1,494,000 sheep.

In addition to that we have denied increases to the small men who are already in to 34,811 cattle permittees, and denied increases to 1.978 sheep permittees.

Mr. BOWDEN. Are those figures for this district or for all the national forests?

Mr. WINKLER. That is for this district, the 26 forests.

It has been the policy from the outset to associate beginners' privileges with dependent commensurate ranch properties.

We have cut the established outfits to admit beginners only when there was a clear-cut evidence of dependency on the part of that beginner.

Now admittedly during all this time there have been a lot of mistakes made. The Forest Service and regulated grazing was a new thing. We had no precedent to follow, because it was the first effort to regulate grazing on public lands in this country. It is unfortunate that those mistakes were made. But on that point I have no particular apology to offer, because I sincerely believe that the thing was done by the agency that handled it perhaps as well as any other agency could have done it.

I

say that because in the beginning in particular there was an outstanding jealously and envy between the stockmen themselves. I want to say right here than the bulk of the decisions that the Forest Service officers were forced to make were not between the Forest Service and the individual, but we were forced in a position. where we had to make the decision between individuals and the bulk of the decisions that the Forest Service makes are not made between the Forest Service and the individual, but they are made. between individual stockmen.

As further evidence of stability, as early as 1909, in order to protect the established outfit we entered into five-year contracts with the permittees. It is true that contract carried with it a provision that a reduction to the extent of 5 per cent for distribution might be made during the term of the contract. It also provided that no cuts Tould be made on those individuals, and we did not make cuts on those individuals if we had already made cuts for protection.

There has always been a divided opinion on the policy of reductions for distribution. The small permittee and beginner were

insistent that they should be admitted. The man who was being cut and whose ranch property was thereby affected of course was decidedly opposed. It should be said in fairness that the men who were being cut were and have been and still are decidedly in the mniority, because the great majority of permittees are not cut for that purpose. And along that line I might say that there has been more consistent criticism because of failure to cut for distribution than there has been because of the cut.

Changes in regulations have been made consistently with the idea of stabilizing the industry. The maximum limits have been more generally liberalized. Exemption limits have been established within which reductions for distribution would not be made. We have tried to liberalize more the sales and purchase policy so as to fit into the natural business tendencies. We have liberalized on the

nonuse.

Years ago one year's nonuse was about all that was permitted. Now we can extend nonuse to most any reasonable limits, in order to meet an extraordinary situation.

In order to relieve the stockmen the Forest Service encouraged the division of fees so that he could pay them in two installments, so he would not have his money tied up for a period of six months before he actually got the full benefit of it.

The sliding scale cut that was originally in effect which cut the big man more than it did the next class below has been abolished, and cuts for all purposes have been placed on a flat rate basis.

The consolidation and division of outfits has been very materially liberalized.

And for 1925 we have gone into a 10-year permit contract. It is true that contract carries with it the provision that a cut to the extent of 10 per cent for distribution can be made at the end of five years, provided that a cut for protection has not been made. If a cut for protection to the extent of 10 per cent has been made no cut for distribution would be made during the life of the 10 year

contract.

Now on this question of stability I am inclined to believe that there has been a substantial stability in the livestock business as connected with the national forests. So far as my personal observation goes and I have had a lot of opportunity to watch the situation-I believe that there has been as much stability in the livestock business on the national forests as there is on any other range, including private ranges.

This question of stability, of course, is a problem. There is no phase of the livestock business that is stable. There is no phase of industry that is absolutely stable. Our currency is not even stable. A dollar at the beginning of the war would perhaps buy at least 40 per cent more than it would at the end of the war. Taxation is not stable. There is no phase of industry that is. Wages are not stable. Wool markets are not stable. There is no phase of industry that is stable. But so far as it has been reasonably possible there has been a decided tendency to stabilize the livestock industry.

To avoid cuts on established outfits I might further state that we disapprove applications to the extent of 61,000 cattle in this district annually. We disapprove applications to the extent of 448.000