CHAPTER 5

CONSULTATION AND COORDINATION

CONSULTATION AND COORDINATION

CHAPTER 5

CONSULTATION AND COORDINATION

Preview of this Section

This section summarizes the public involvement and 

scoping and public comment process conducted for the 

preparation of the Draft PEIS and BA. Summaries of 

agency and government-to-government consultation 

are provided. The individual preparers, with their areas 

of expertise and/or responsibility, are also listed.

Public Involvement

Federal Register Notices and 

Newspaper Advertisements

The BLM published a Federal Register Notice of 

Intent (Notice) on December 21, 2012 (Federal 

Register, Volume 77, Number 246, Pages 75648-

75649). The BLM also released a press release 

concurrent with the Notice. The Notice asked the 

public to provide comments on the proposal to use 

aminopyralid, fluroxypyr, and rimsulfuron in its 

vegetation treatment activities, and to identify issues 

that should be considered in the PEIS. The Notice 

provided the locations and dates of the public scoping 

meetings, and stated that public comments on the 

proposal would be accepted until the close of the 

scoping period, or 15 days after the last public 

meeting, whichever was later. The press release 

indicated that the public comment period for the 

scoping process was 60 days.

Public notices of the scoping period and public 

meetings were placed in newspapers serving areas in 

or near locations where the meetings were held.

Scoping Meetings

Three scoping meetings were held within the 

geographic area covered by the project. One meeting 

was held in Worland, Wyoming (January 7, 2013), one 

was held in Reno, Nevada (January 9) and one was 

held in Albuquerque, New Mexico (January 10). The 

scoping meetings were conducted in an open-house 

style. Informational displays were provided at the 

meetings, and handouts describing the project, the 

NEPA process, and issues and alternatives were given 

to the public. A formal presentation provided the 

public with additional information on program goals 

and objectives. At each meeting, the presentation was 

followed by a question and answer session.

The BLM received 26 requests to be placed on the 

project mailing list from individuals, organizations, 

and government agencies, and 43 written comment 

letters or facsimiles on the proposal. In addition, to 

written comments received at the scoping meetings, 

four individuals provided oral comments. As most of 

the comment letters provided multiple comments, a 

total of 225 individual comments were catalogued and 

received during the public scoping period.

A Scoping Summary Report for Vegetation Treatments 

Using Aminopyralid, Fluroxypyr, and Rimsulfuron on 

Bureau of Management Lands in 17 Western States 

Programmatic EIS (AECOM 2013) was prepared that 

summarized the issues and alternatives identified 

during scoping. 

Frequently Asked Questions

The BLM posted a list of frequently asked questions 

(FAQs) to the project website, with handouts of the 

same information provided at the public meetings. The

FAQ handout discussed the BLM’s proposed project, 

including where the proposed activities would occur. 

The handout also discussed the PEIS development 

process and potential issues to be examined in the 

PEIS, and detailed the public comment opportunities 

and instructions. 

Public Review and Comment on the 

Draft Programmatic EIS

The Notice of Availability of the Draft Programmatic 

Environmental Impact Statement for Vegetation 

Treatments Using Aminopyralid, Fluroxypyr, and 

Rimsulfuron on Bureau of Land Management Lands in 

17 Western States was published in the Federal Register 

on June 19, 2015. On the same date, the BLM issued a 

press release notifying the public that the Draft PEIS 

was available for public review and comment. The

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CONSULTATION AND COORDINATION

Draft PEIS and supporting documentation were posted 

to a BLM website, where the public was able to 

download a copy of these documents. Copies of the 

documents were available upon request and for public 

inspection at all BLM state, district, and field office 

public rooms.

A total of 98 substantive comments were received on 

the Draft PEIS. Comments were received via letter, 

electronic mail, and facsimile. A summary of the 

comments received, issues identified, and specific 

comments and responses are presented in Chapter 6 of 

this PEIS. All comments are reproduced in the CD of 

supporting documentation.

Agency Coordination and 

Consultation

Endangered Species Act Section 7 

Consultation

The BLM initiated informal consultation with the 

USFWS and NMFS (the Services) in February 2014. A 

BA evaluating the likely impacts to listed species (and 

species proposed for listing) and critical habitat from the 

proposed action, and presenting programmatic level 

conservation measures to minimize impacts to these 

species, was submitted to the Services for their review 

and comment. An Essential Fish Habitat Assessment, as 

required under the Magnuson-Stevens Fishery 

Management Act, was submitted as an appendix to the 

BA.

After receipt and review of the BA, the BLM and the 

Services held several meetings to discuss the document 

and to respond to information requests from the 

Services. Meetings/conference calls were held on May 

28, June 12, June 23, July 30, August 20, September 3, 

November 6, 2014, and January 9, 2015. The Services 

provided comments on the BA in July 2014, and 

subsequent discussions provided resolutions to issues 

that were raised in the review comments.

Consultation letters were submitted by the Services in 

October, 2015. Copies of these letters are provided in 

the CD of supporting documentation that accompanies 

this PEIS.

Risk Assessment Coordination

Ecological and human health risk assessments for

aminopyralid, fluroxypyr, and rimsulfuron were 

prepared in accordance with the protocols that were 

developed for risk assessments prepared for the 2007

PEIS. In 2002, The BLM convened a group of 

scientists from the USEPA, USFWS, NMFS, BLM, 

and its contractor, ENSR Corporation, to work 

cooperatively to develop protocols for conducting 

HHRAs and ERAs that would meet agency guidelines 

and scientific and public scrutiny. Weekly conference 

calls were held among the participants beginning in 

May 2002, and continuing through November 2002. A 

meeting was held in Boise on September 12 and 13, 

2002, and in Denver, Colorado, on November 5 and 6, 

2002, to discuss the risk assessment protocols. 

Conference calls were held intermittently from 

November 2002 through July 2003 to resolve 

remaining issues related to the protocols. Conference 

calls were also held among agency participants during 

preparation of the risk assessments. The final HHRA 

and ERA protocols were finalized and submitted to the 

Services and USEPA in August 2003. These protocols 

detail the methodology used to evaluate ecological and 

human health risks associated with the use of 

chemicals for controlling invasive vegetation and to 

determine whether these chemicals are safe for use by 

the BLM. The risk assessments evaluated a variety of 

possible exposure scenarios.

Cultural and Historic Resource 

Consultation

The BLM consulted with State Historic Preservation 

Officers as part of Section 106 consultation under the 

National Historic Preservation Act to determine how 

treatments with the three new herbicides could impact 

cultural resources listed on or eligible for inclusion in 

the National Register of Historic Places. Formal 

consultations with State Historic Preservation Officers 

and Indian Tribes also may be required during 

implementation of individual projects. Consultations 

with State Historic Preservation Officers are ongoing 

and will be completed by the time of the signing of the 

ROD.

Government-to-government 

Consultation

Federally recognized tribes have a unique legal and 

political relationship with the government of the 

United States, as defined by the U.S. Constitution, 

treaties, statutes, court decisions, and executive orders. 

These definitive authorities also serve as the basis for 

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Final Programmatic EIS
CONSULTATION AND COORDINATION

the federal government’s obligation to acknowledge 

the status of federally recognized tribes.

The BLM consults with federally recognized tribes, 

consistent with the Presidential Executive 

Memorandum dated April 29, 1994, on Governmentto-Government Relations with Native American Tribal 

Governments; and Executive Order 13175 dated 

November 6, 2000, on Consultation and Coordination 

with Indian Tribal Governments. 

Policies enacted by the USDOI during August of 2012 

require federal agencies to consult with Alaska Native 

Corporations—the entities created under the Alaska 

Native Claims Settlement Act (ANCSA) of 1971—on 

the same basis as American Indian or Alaska Native 

Tribes.

The BLM formally consults with federally recognized 

tribes and Alaska Native Corporations before making 

decisions or undertaking activities that will have a 

substantial, direct effect on federally recognized tribes, 

or their assets, rights, services, or programs. To this 

end, formal government-to-government consultation 

with federally recognized traditional governments and 

Alaska Native Corporations was initiated by written 

correspondence in April 2013 (see Appendix B).

The letter sent to all of the tribal governments and 

Alaska Native Corporations described the proposed 

action. The tribes and native corporations were 

provided with information on the project and were 

asked to provide the BLM with their concerns about 

vegetation treatments with the three new active 

ingredients and their impacts on subsistence, religious, 

and ceremonial purposes and traditional cultural 

properties. The BLM also invited the tribes and native 

corporations to call if they had questions or concerns, 

or wanted additional information.

The BLM prepared an ANILCA Section 810 analysis 

of subsistence impacts to evaluate the potential 

impacts to subsistence pursuits in Alaska. This 

analysis is found in Appendix C of this PEIS.

List of Preparers of the 

Programmatic EIS and BA

The following specialists (and company/agency and 

area of specialty) that participated in the development 

of this PEIS are listed below (Table 5-1). Because 

much of the information in this PEIS was summarized 

or incorporated by reference from the 2007 PEIS, the 

people who contributed to the 2007 PEIS also 

contributed to the current document. Those 

individuals, though not listed here, are included by 

reference (USDOI BLM 2007a:5-5 to 5-9). Agencies 

included the BLM, USEPA, USFWS, and NMFS. 

Subcontractors that provided assistance to the BLM 

during preparation of the PEIS included AECOM 

(previously ENSR Corporation); Historical Research 

Associates (HRA); Planera, Inc. (Planera); and Paleo 

Consultants.

TABLE 5-1

List of Preparers of the Programmatic EIS/BA

Contributor Areas of Specialty Years of 

Experience Highest Degree/Education

Bureau of Land Management

Francis Ackley Wild Horses and Burros 29 B.S., Range and Forest 

Management

Cathi Bailey Wild and Scenic Rivers 27 B.S., Wildland Recreation 

Management

Jerry Cordova Native American and Alaska Native 

Issues and Tribal Liaison Coordinator 40 B.S., Political Science and Native American Studies

Scott Davis Soil and Water Science, Forestry, and 

Ecology 39 M.S., Soil and Water Science

Mike DeArmond

Vegetation, Range, Emergency 

Stabilization and Rehabilitation, and 

Riparian Areas

35 B.S., Forest Management

Melissa Dickard Wetlands and Riparian Areas 11 M.S., Wildlife and Fisheries 

Science

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CONSULTATION AND COORDINATION

TABLE 5-1 (Cont.)

List of Preparers of the Programmatic EIS/BA

Contributor Areas of Specialty Years of 

Experience Highest Degree/Education

Scott Feldhausen

Fish and Fish Habitat, and Threatened, 

Endangered, and Sensitive Species 

Consultation

25 B.S., Fisheries

Coreen Francis Forestry and Woodland Resources 21 M.F., Silviculture

Eric Geisler

Alaska State Program Lead Forestry, 

Weeds, Botany, Soils, Range, and 

Emergency Stabilization and 

Rehabilitation

40 Master of Management and 

Administration

Krista GollnickWade Fire and Fuels Management 30 M.S., Fire Ecology and 

Environmental Management

Leonard Gore Data Coordinator 14 M.S., Geography

Doug Herrema Special Areas (NLCS) 7 J.D., Law

Mike “Sherm” Karl

Plant Ecology, Livestock Grazing 

Management, Terrestrial Vegetation, and 

Rangelands

32 Ph.D., Rangeland Ecology

Lee Koss Surface Water, Hydrology, and Riparian 

Restoration 43 B.S., Water Resource Management, Civil Engineering, and Biology

Richard Lee Herbicide Use and Management, and 

Integrated Pest Management 30 Ph.D., Weed Science

Dave Maxwell Air Quality, Smoke Management, and 

Climate 40

M.S., Air Pollution

M.B.A., Business

M.P.A., Public Administration

John McCarty Visual Resource Management 32 B.S., Landscape Architecture

Dorothy Morgan Recreation 20 B.S. Recreation and Parks 

Management

Arie Pals Public Affairs 2 M.A., Sustainable Development 

Practice

Frank Quamen Spatial Data Analyst 6 Ph.D., Wildlife Biology

Gina Ramos

Project Manager and Weed 

Management, Invasive Species, 

Pesticide Use, Range Management, and 

Economics

33 B.S., Range Science

M.B.A., Business Administration

John Sherman Wildlife Habitat 31 B.S., Wildlife Science and 

Microbiology

Josh Sidon Economic Conditions and Social 

Environment 8 Ph.D., Economics

Carol Spurrier

Native Plant Communities, Species of 

Concern, and Threatened and 

Endangered Plants

34 M.S., Biology

Jeanne Standley Natural Resources Specialist 23 B.S., Rangeland Resources

Paul Summers Groundwater Hydrology and Water 

Resources 44 B.S., Geology and Water Resources

Rob Sweeten Visual Resource Management 14 B.L., Landscape Architecture and 

Environmental Planning

Peter Teensma Fire Ecology, Fire Management, and Air 

Quality Management 28 Ph.D., Geography

Kim Tripp Threatened and Endangered Animals 18 M.S., Zoology

Jennifer Whyte Rights-of-Way 7 M.P.A, Public Administration

Dana Wilson Public Affairs 5 M.P.P., Public Policy 

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TABLE 5-1 (Cont.)

List of Preparers of the Programmatic EIS/BA

Contributor Areas of Specialty Years of 

Experience Highest Degree/Education

Kate Winthrop

Native American and Alaska Native 

Issues, Paleontology, and Cultural and 

Historic Resources

35 Ph.D., Anthropology

AECOM 

Alan Abramowitz Archaeology and Anthropology 12 M.A., Anthropology

Kim Anderson Assistant Project Manager, Vegetation, 

and Species of Concern, 15 M.S., Environmental and Forest Biology

Christine Archer Ecological Risk Assessment 10 B.S., Zoology

Suzy Baird Ecological Risk Assessment 7 M.S., Toxicology

Lisa Bradley Human Health Risk Assessment 23 Ph.D., Toxicology

Kristen Durocher Ecological Risk Assessment 11 M.S., Natural Resources and 

Terrestrial Ecology

Sarah Esterson Air Quality/Greenhouse Gases 9 M.S., Public Administration

Michael Inman Graphics 9 B.S., Geography

Adrienne Kieldsing Ecological Risk Assessment 8 M.S., Environmental Science with a 

specialty in Atmospheric Studies

George Lu Greenhouse Gas Emissions and Climate 

Change 10 B.S., Environmental and Resource Sciences

Amanda MacNutt Air Quality Dispersion Modeling 13 B.S., Meteorology

Glen Mejia Fish, Wildlife, Livestock, and Wild 

Horses and Burros 17 B.A., Environmental Studies and Biology

Tina Mirabile Water Resources 14 M.B.A., Business Administration

Robert Paine Air Quality 31 M.S., Meteorology

Melissa Paliouras Ecological Risk Assessment 7 B.S., Environmental Science

Stuart Paulus Project Manager, NEPA Specialist, and 

Wildlife Ecology 34 Ph.D., Wildlife Ecology

Colin Plank Ecological and Human Risk Assessment, 

and GLEAMS Modeling 12 M.S., Geology

Kelly Vosnakis Human Health Risk Assessment 11

M.S., Civil and Environmental 

Engineering and Environmental 

Health

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